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HomeMy WebLinkAbout07-0876GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagors and Real Owners 2 Hemlock Drive Mechanicsburg, PA 17055 Defendants Term CIVIL ACTI©N: ?10?T?'AC P04REECLOSUfRF NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov_ for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-430-5262 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionna,goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1662. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The names and addresses of the Defendants are ARNOLD F. GREENLUND, 2 Hemlock Drive, Mechanicsburg, PA 17055 and ANNE M. GREENLUND, 2 Hemlock Drive, Mechanicsburg, PA 17055, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On March 09, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1857, Page 4932. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for September 01, 2006 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ...................................................................... Interest from 08/01/2006 through 02/28/2007 at 10.9900%..... Per Diem interest rate at $35.49 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ... Late Charges from 09/01/2006 to 02/28/2007 .......................... Monthly late charge amount at $72.34 C f t d 'P;+1 S h .........$116,244.29 .............$7,523.88 ................ $5,812.21 ...................$434.04 oats o sui an i e %, .............................................................. Escrow Advance .................................................................................. Fees .................................................................................................... Recoverable Balance .......................................................................... ...... $900.00 ...$4,290.96 ......$106.00 ......$120.00 Suspense .................................................................................................. -$1,508.94 Monthly Escrow amount $862.82 $133,922.44 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $133,922.44, together with interest at the rate of $35.49, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. BY• l_k. C ?-* LD ECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Erin Kelly, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: Z ' 1 , Erin Kelly, Sr. Foreclosure ecialist AMERIQUESTMORTGAGE CORPORATION Ekr,hibitA Conestoga Title Insurance Company Commitment Number: 2004020179• SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN lot of ground situate in the Township of Upper Allen, County of Cumberland and Stale of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Hemlock Drive (40 feet wide) which said point is in the vision line between Lot Nos. 41 and 42 on the hereinafter mentioned Plan of Lots; thence along the Southern late of r. Hemlock Drive in a Northeasterly direction by the arc of a circle curving to the left, said circle having a radius of ' two hundred (200) feet, the arc distance of eighty-three and sixteen one-hundredths (83.16) feet to a point; thence continuing along said line of Hemlock Drive, North 49 degrees 29 minutes 30 seconds East, forty-two and forty-eight one-hundredths (42.48) feet to a point thence South 45 degrees 13 minutes East, one hundred fifty-three and three one-hundredths (153.03) feet to a point thence South 72 degrees 45 minutes West, one hundred seventy-four and eighty-five one-hundredths (174.85) feet to a point; thence South 79 degrees 03 minutes West, twenty and thirty-nine one-hundredths (20.39) feet to a point in the division line between Lots No. 41 and 42, aforesaid; thence along the division line between Lots Nos. 41 and 42, North 16 degrees 41 minutes West, ninety-eight and sixty-three one-hundredths (98.63) feet to a point in the Southern line of Hemlock Drive, aforementioned, at the point and place of BEGINNING. BEING Lot No. 41 In a certain Plan of Lots known as Webercroft, Block "D", which said Plan of Lots is recorded in the Cumberland County Recorder's Office, in Plan Book 15, Page 13. Parcel M 42.25-0030-120 FOR INFORAMATIONAL PURPOSES ONLY. Cumberland County has property assessed as 2 Hemlock Drive. ALTA Commiw"ni Schedule C =04020179.PFD/20040M179/33) BKI857PS4948 Ex, hibit B P.O. Bo:11609 Santa Ana, CA 92711-1699 7182 6389 3060 0934 6933 1111"C MORTGAGE SERVICES December 07, 2006 ARNOLD GREENLUND ANNE GREENLUND 2 HEMLOCK DR MECHANICSBURG, PA 17055 I 1 NM ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE AVISO: Este documento explica Como los propietarios de casas pueden evitar perder sus hogares debido a demoras de pagos. Para informaci6n en espai)ol flame a su prestamista. STATEMENTS OF POLICY Loan Number: 0071096465 Property Address: 2 HEMLOCK DR, MECHANICSBURG PA, 17055 Original Leader: AMC Mortgage Services, Inc. Current Lender/Servicer: AMC Mortgage Services, Inc. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WELL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortgage on your home is in default and the leader intends to foreclose. Specific information about the nature of the defauk is provided is the attacked pays. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to kelp to save your home. This Notice explains how the proaram worlrs. To see if HEM" can kelp. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any Questions, you may call tke Pennsylvania Hoadag Finance Agency toll free at 14899,42-23970ersoas with impaired kearint can call (717) 7W1869). This Notice contains important kgal information. N you have any questions, representatives at the Consumer Credit Counseling Agency may be able to kelp explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SII CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO EFON2101CM-M Also doing business as Delaware AMC Mortgage Services, Inc., in the states of Texas, Rhode Island, and New Hampshire ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI IIR SII HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: z IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, z IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND : IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action aga 9you for thirty (30) days after the date of this meeting The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which theprooerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and Ste a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fax-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. 6MOJMIC%2-06 December 07, 2006 Loan Number: 0071096465 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Briat it ua to date). NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 2 HEMLOCK DR, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 09/01/06 thru 12/01106 at $1812.64 per month monthly Payments plus late charge or other fees: $5915.36 Total Aismat to Care Default: $591536 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT -Yon may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5915.36 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or mone9 order made payable and sent to: AMC Mortgage Services 505 City Parkway West, Sane 6100 Orange, CA 92868 You can care any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N!A IF YOU DO NOT CURE THE DEFAULT--If you do not core the default within THIRTY (30) DAYS of the date of this Notice, the leader intends to eureise its rights to accelerate the sortute debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to on legal action to foreclose upon your worttatted pnwdy- IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your can to its attorneys, but you care the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you care the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sae you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cared the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon still have the riebt to can the di h and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and W other costs connected with the Sheriff s Sale as specified in writing by the lender and by SF OJNC*2-M performing another requirements under the mortgage. Curing your default in the warner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of coarse, the amount needed to care the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: AMC Mortgage Services PO Box 11000 Santa Ana, CA 92711-1000 Phone Number 1100430-5262 Fa: Number 714-347-5037 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments. charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: z TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. : TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. s TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) s TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, s TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER z TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED If you need additional assistance or counseling you may also find a Housing Counseling Agency in your area by calling Toll-free (800) 5694287 or TDD (800) 877-8339. AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Loan Number: 0071096465 Mailed by 1st Class Mail and by Certified Mail EsOUVN?wM-a Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 p 44 ?j c 43 l? cr co In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURIT INC., ASSET BACKED PASS-THROUGH CERTIFIC SERIES 2004-R4 UNDER THE POOLING AND SER r° AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-876 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against ARNOLD F. GREENLUND and ANNE M. GREENLUND by default for want of an Answer. Assess damages as follows: $135,886.81 Debt Interest from 03/30/07 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIE UNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE C PL T. I certify that written notice of the intention to file this praecipe was mailed or delivered to e p against judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to a of ling of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. ld Jr. Attorney for lainti I.D. #16132 AND NOW 4L L DO ?dgment is entered in favor of DEUTSCHE BANK NAXIUN4LTRUST S TR- RTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE and against ARNOLD F. GREENLUND and ANNE M. GRE NLUND by default for want of an Answer and damages assessed in the sum of $135,886.81 as per the above cey"cation. t Prodidinotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff No. 07-876 vs. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagors and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 AMQ-1662 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 14, 2007 TO: ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND {Mortgagor(s) and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) TO: ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 07-876 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?asevFi . Qfd&eck 7r GOLDBECK MCCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 AMQ-1662 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 14, 2007 TO: ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) TO: ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-876 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?use Fr. r,A a - - - Czec?x GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ARNOLD F. GREENLUND, is about unknown years of age, that Defendant's last known residence is 2 Hemlock Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ANNE M. GREENLUND, is about unknown years of age, that Defendant's last known residence is 2 Hemlock Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or o erwise within the provisions of the Soldiers' and Sailors' ivirl Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) No. 07-876 ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVIC AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, and against ARNOLD F. GRE and ANNE M. GREENLUND for failure to file an Answer in the above action within (20) ys (o sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in t e s of $135,886.81. Joseph A. Gi Attorney for I hereby certify that the above names are correct and that the precise i creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUS MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH C UNDER THE POOLING AND SERVICING AGREEMENT DATED AS O RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that address(es) of the Defendant(s) is/are ARNOLD F. GREENLUND, 2 Hemlo 1 and ANNE M. GREENLUND, 2 Hemlock Drive Mechanicsburg, PA 17055; ,pe'e address of the judgment OF AMERIQUEST FICATES, SERIES 2004-R4 Y 1, 2004, WITHOUT ne(s) and laq known ive PA 17055 R & McKEEVER GOLDBECK McC Leck, BY: Joseph A. GolAttorney for Plainti ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 08/01/2006 through 03/29/2007 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Advance Fees Recoverable Balance Suspense $116,244.29 $8,553.09 $5,812.21 $506.38 $900.00 $5,153.78 $106.00 $120.00 -$1,508.94 $135,886.81 GOLDBECK McCAFF)"RT & BY: Joseph A. Goldbeck, Jr Attorney for Plaintiff , AND NOW, this3(Le-L day of L , 2007 damages are assessed as above. Pro Pro y Q) J C R 5 /ice PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) . P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagor(s) and Record Owner(s) 2 Hemlock Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-876 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 03/30/07 to Date of Sale at 10.9900% $135,886.81 (Costs to be added) GOLDBECK Mc F & McKEEVER BY: Joseph A. Gol Jr Attorney for Plainti Alp ? v? W o d 'a a o??QOw .A ZW A d v w ora Z H r? A Qo °?x Wd° H Mo W t? w ?, v AH? O Q ? H j J G:rO ?? w V ??? o Gd o A G''' C y o W (paw °' y4 ou ' ? Wt A oN U a CT ce) r:-L? ?S 3- ?. fJ ? ? y ?r t ?V x ? o s+ M .pa le a?a td t7o ?aso`??a?n o `? oQ r d? a 0 N W ,? M ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE SOUTHERN LINE OF HEMLOCK DRIVE (40 FEET WIDE) WHICH SAID POINT IS IN THE DIVISION LINE BETWEEN LOT NOS. 41 AND 42 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF HEMLOCK DRIVE IN A NORTHEASTERLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE LEFT, SAID CIRCLE HAVING A RADIUS OF TWO HUNDRED (200) FEET, THE ARC DISTANCE OF EIGHTY-THREE AND SIXTEEN ONE-HUNDREDTHS (83.16) FEET TO A POINT; THENCE CONTINUING ALONG SAID LINE OF HEMLOCK DRIVE, NORTH 49 DEGREES 29 MINUTES 30 SECONDS EAST, FORTY-TWO AND FORTY-EIGHT ONE-HUNDREDTHS (42.48) FEET TO A POINT; THENCE SOUTH 45 DEGREES 13 MINUTES EAST, ONE HUNDRED FIFTY-THREE AND THREE ONE- HUNDREDTHS (153.03) FEET TO A POINT; THENCE SOUTH 72 DEGREES 45 MINUTES WEST, ONE HUNDRED SEVENTY-FOUR AND EIGHTY-FIVE ONE- HUNDREDTHS (174.85) FEET TO A POINT; THENCE SOUTH 79 DEGREES 03 MINUTES WEST, TWENTY AND THIRTY-NINE ONE-HUNDREDTHS (20.39) FEET TO A POINT IN THE DIVISION LINE BETWEEN LOTS NO. 41 AND 42, AFORESAID; THENCE ALONG THE DIVISION LINE BETWEEN LOTS NOS. 41 AND 42, NORTH 16 DEGREES 41 MINUTES WEST, NINETY-EIGHT AND SIXTY- THREE ONE-HUNDREDTHS (98.63) FEET TO A POINT IN THE SOUTHERN LINE OF HEMLOCK DRIVE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING, BEING LOT NO. 41 IN A CERTAIN PLAN OF LOTS KNOWN AS WEBERCROFT, BLOCK "D" WHICH SAID PLAN OF LOTS IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE, IN PLAN BOOK 15, PAGE 13. PARCEL # 42-25-0030-120 Cvldbeck McCafferty & McKeever Y': Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004- R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-876 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2 Hemlock Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ANNE M. GREENLUND 2 Hemlock Drive " Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 CHELSEA SETTLEMENT SERVICES INC. 3800 MARKET STREET CAMP HILL, PA 17011 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 2 Hemlock Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the e t of my personal knowledge or information and belief. I understand that false statements herein are made subject t th penalties of 18 Pa.,C.S. Section 4904 relating to unworn falsification to authorities. DATED: March 29, 2007 GOLDBECK Mc E & McKEEVER BY: Joseph A. Goldb ck, Jr., sq. Attorney for Plaintiff 4;w 7) L,i:? Tar' - -1 07-876 GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagor(s) and Record Owner(s) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s; Term No. 07-876 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GREENLUND, ARNOLD F. ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 Your house at 2 Hemlock Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $135,886.81 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-114 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS w 07-876 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-876 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-430-5262 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionaa,goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1662. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ?'..? r-? a cam; _...+ ? °::? t??` z?- s?? ? ? [?c? r=? f-; r. T. t.Z3 07-876 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagor(s) and Record Owner(s) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s', Term No. 07-876 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GREENLUND, ANNE M. ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 Your house at 2 Hemlock Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff s Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $135,886.81 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 07-876 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-876 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-430-5262 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggLoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1662. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ;' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-876 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, Plaintiff (s) From ARNOLD F. GREENLUND AND ANNE M. GREENLUND (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $135,886.81 L.L. $.50 Interest FROM 3/30/07 TO DATE OF SALE AT 10.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $148.80 Plaintiff Paid Other Costs Date: APRIL 3, 2007 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF 40?? v Curtis R. Lo ro 0 of By: Deputy Telephone: 215-627-1322 Supreme Court ID No. 16132 SHERIFF'S RETURN - REGULAR L''ASE NO: 2007-00876 P • COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GREENLUND ARNOLD F ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GREENLUND ARNOLD F the DEFENDANT , at 2000:00 HOURS, on the 21st day of February-, 2007 at 2 HEMLOCK DRIVE MECHANICSBURG, PA 17055 by handing to ARNOLD GREENLUND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 .00 3?b??o1 ?. ? 36.80 Sworn and Subscibed to before me this of day So Answers: A! R. Thomas Kline 02/22/2007 GOLDBECK MCCAFFERTY MCKEEVER By. uty Sheriff 61De A.D. SHERIFF'S RETURN - REGULAR ,.,+CASE NO: 2007-00876 P s COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GREENLUND ARNOLD F ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GREENLUND ANNE M the DEFENDANT , at 2000:00 HOURS, on the 21st day of February , 2007 at 2 HEMLOCK DRIVE MECHANICSBURG, PA 17055 ARNOLD GREENLUND, HUSBAND by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 3jeijul C?, ?16.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/22/2007 GOLDBECK MCCAFFERTY MCKEEVER By. D ty Sheriff A.D. Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Asset Backed Pass-Through Certificates, Series 2004-R4 Under the Pooling and Servicing Agreement Dated as of May 1, 2004, Without Recourse VS Arnold F. Greenlund and Anne M. Greenlund In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-876 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 25, 2007 at 0925 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Arnold F. Greenlund and Anne M. Greenlund, by making known unto Anne M. Greenlund personally, and wife of Arnold F. Greenlund, at 2 Hemlock Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Joseph Goldbeck. Sheriff s Costs: Docketing $30.00 Poundage 2.06 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy 15.00 Surcharge 30.00 Share of Bills 15.69 $ 104.85 So Answers: ?v?C " R. Thomas Kline, Sheriff BY Real Estate ergeant ? F(x3j U1 I)- ?,, iglagi Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004- R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-876 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2 Hemlock Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 ANNE M. GREENLUND 2 Hemlock Drive 4, v Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 CHELSEA SETTLEMENT SERVICES INC. 3800 MARKET STREET CAMP HILL, PA 17011 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 2 Hemlock Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to thee t of my personal knowledge or information and belief. I understand that false statements herein are made subject t th penalties of 18 Pa. ,- .S. Section 4904 relating to unswom falsification to authorities. DATED: March 29, 2007 GOLDBECK Mc E & McKEEVER BY: Joseph A. Goldb ck, Jr., Esq. Attorney for Plaintiff 07-876 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagor(s) and Record Owner(s) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s; Term No. 07-876 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GREENLUND, ANNE A ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 Your house at 2 Hemlock Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff s Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $135,886.81 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 07-876 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 40 07-876 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-430-5262 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1662. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-876 GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ARNOLD F. GREENLUND ANNE M. GREENLUND Mortgagor(s) and Record Owner(s) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s Term No. 07-876 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GREENLUND, ARNOLD F. ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 Your house at 2 Hemlock Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $135,886.81 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 46 07-876 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-876 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-430-5262 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1662. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE SOUTHERN LINE OF HEMLOCK DRIVE (40 FEET WIDE) WHICH SAID POINT IS INTHE DIVISION LINE BETWEEN LOT NOS. 41 AND 42 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF HEMLOCK DRIVE IN A NORTHEASTERLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE LEFT, SAID CIRCLE HAVING A RADIUS OF TWO HUNDRED (200) FEET, THE ARC DISTANCE OF EIGHTY-THREE AND SIXTEEN ONE-HUNDREDTHS (83.16) FEET TO A POINT; THENCE CONTINUING ALONG SAID LINE OF HEMLOCK DRIVE, NORTH 49 DEGREES 29 MINUTES 30 SECONDS EAST, FORTY-TWO AND FORTY-EIGHT ONE-HUNDREDTHS (42.48) FEET TO A POINT; THENCE SOUTH 45 DEGREES 13 MINUTES EAST, ONE HUNDRED FIFTY-THREE AND THREE ONE- HUNDREDTHS (153.03) FEET TO A POINT; THENCE SOUTH 72 DEGREES 45 MINUTES WEST, ONE HUNDRED SEVENTY-FOUR AND EIGHTY-FIVE ONE- HUNDREDTHS (174.85) FEET TO A POINT; THENCE SOUTH 79 DEGREES 03 MINUTES WEST, TWENTY AND THIRTY-NINE ONE-HUNDREDTHS (20.39) FEET TO A POINT IN THE DIVISION LINE BETWEEN LOTS NO. 41 AND 42, AFORESAID; THENCE ALONG THE DIVISION LINE BETWEEN LOTS NOS. 41 AND 42, NORTH 16 DEGREES 41 MINUTES WEST, NINETY-EIGHT AND SIXTY- THREE ONE-HUNDREDTHS (98.63) FEET TO A POINT IN THE SOUTHERN LINE OF HEMLOCK DRIVE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING, BEING LOT NO. 41 IN A CERTAIN PLAN OF LOTS KNOWN AS WEBERCROFT, BLOCK "D" WHICH SAID PLAN OF LOTS IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE, IN PLAN BOOK 15, PAGE 13. PARCEL # 42-25-0030-120 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-876 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE, Plaintiff (s) From ARNOLD F. GREENLUND AND ANNE M. GREENLUND (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $135,886.81 L.L. $.50 Interest FROM 3/30/07 TO DATE OF SALE AT 10.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $148.80 Other Costs Plaintiff Paid Date: APRIL 3, 2007 C s R. Lon o tary (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 e • Real Estate Sale # 09 On April 13, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 2 Hemlock Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. ? Date: April 13, 2007 By: ? ? S? (f Real Estate Sergeant LC :8 'V' `3- Ldr L `UI KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. ~ ® `_, -a3 oti N z -+ ~ . ~ Z ~,,,~ ~ ~ v„ C ~ ,~ r-- ' ' !? C ~ t r i `~ r z w - -~c~ z ca ~~ b ~ --~ ~ cn ~ ~ By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Krishna Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. ID 205047 Attorneys for Plaintiff t.,.~ 'T'I -i m ~ ,-. ~~ c~ d --a ~~ IN THE COURT OF COMM6~1 P~'EAS?? of Cumberland County No. 07-876 g~3~Z $q. so PA N`rT'~ ~,~r~~t.3(~9a ,~# a8a983 KML LAW GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, A5 TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE No. 07-876 Angela M. Smith ,hereby certifies that heJshe did serve true and correct copies of Praecipe to Vacate Judgment and al(l supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on / ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 By: KML LA GROUP, P.C. Angela M. Smith ,Legal Assistant asmith~a kmllawgroup.com 215-825-6325 (Direct Phone) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record owner(s)) 2 Hemlock Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 07-876 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: CS c N a f.,.". -v 3 "" --i ~~ ~ ~ o •c r- -v , cn ~'" ..~ D ~ ~ =oc~ t~ ~~ ~~ "~ ~ a a o.-~..,, ~ ~„ r_ ^ ca zn ° n° ° ~ ~ cn '" r r rv Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Joshua 1. Goldman Pa. ID 205047 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215)627-1322 for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2004, WITHOUT RECOURSE Plaintiff vs. ARNOLD F. GREENLUND ANNE M. GREENLUND (Mortgagor(s) and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE No. 07-876 Angela M. Smith ,hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on l ~'S ~OZ ARNOLD F. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 ANNE M. GREENLUND 2 Hemlock Drive Mechanicsburg, PA 17055 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFE Y & McKEEVER By: An la M. Smith ,Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE