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HomeMy WebLinkAbout07-4053GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagors and Real Owners 335 Wolf Bridge Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Term CIVIL ACTI4N~ ~7~~TC,AGF FD~~CL~'11~i1A Defendants 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 maybe 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 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. PARR DEFENDERSE ES NECESSARIO QUE USTED, 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 S1N 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 LISTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LISTED 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 LISTED 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 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 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(a,goldbecklaw.com. Call Seth 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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE, 10801 6th Street, Suite 130 Rancho Cucamonga, CA 91730. 2. The names and addresses of the Defendants are DAVID L. JOHNSON JR., 335 Wolf Bridge Road, Carlisle, PA 17013 and PENNY L. JOHNSON, 335 Wolf Bridge Road, Carlisle, PA 17013, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On September O5, 2003 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 1835, Page 3577. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 March O1, 2007 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 ..................................................................................$206,088.24 Interest from 02/01/2007 through 06/30/2007 at 7.5000% .......................$6,440.99 Per Diem interest rate at $42.94 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$10,304.41 Late Charges from 03/01/2007 to 06/30/2007 .............................................$357.95 Monthly late charge amount at $89.49 Costs of suit and Title Search ......................................................................$900.00 Fees ................................................................................................................$87.00 Recoverable Balance ....................................................................................$125.00 Suspense ..................................................................................................... -$223.75 $224,079.84 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above maybe 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 Sheriff s 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 Plaintiffhas 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 $224,079.84, together with interest at the rate of $42.94, 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~ c4 DBECK McCAFFERTY & McKEEVER Y: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, KELLY L. RADER, 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: June 29, 2007 #0054088208 -DAVID L. JOHNSON JR. and PENNY L. JOHNSON ExFiiditA Daze 9/5Jp3 order Number; 000o1497a Re: David G. Johnson, Jr. Paaay L. Johnson U lime: 11:DS;16 :ut 335 WOLP BRIDGE ROAD ' CARLI6LE, PA 17013 CIAIBERLAMD County g%HIBIT 'A' ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate to the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded sad described ae follows: BEGINNING. at a point in the canter line of Township Road T-508 known ae Hole Bridge Road, which $oint at the place oL BEGINNING is 1,511.54 Last North of the center line of Township Road T-501 known as Clemson Drive at corner oP land now or formerly of Irwin C. Treaater et al.; thence from said point at the place oL beginning along the center line of said Wolf Bridge Road, North OS degrees 56 minutes 20 seconds Saet, a distance of 115 Paet to a point; thence Bouth D9 degrees 24 minutes 20 seconds East, a'diatance of 209.76 Leet to a point; thence South OS degrees 56 minutes 20 seconds Hest, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treasker et al.; thence along the Northern line oP said land now or formerly of Irwin C, Treaatar, et al., North 84 degrees 29 minutes 20 seconds Nest, a distance of 209.76 Peat to a point in the canter line oP said Wolf Bridge Road, the point and place of BEGINNING, C~ON1'AINING 115 Peet in front along the center lino of 41o1f Bridge Road and extending Eaetwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and aluminum eiding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. PagK 6 of 6 only sunba DODD]~972 E~(zi6it B 1 1 1 1 1.~. 1! - `~ P.O. Boz 11000 MORTGAGE SERVICESSutaAna.CA 92711-1000 ~{B WNKZZS DAVID L ]OHNSON JR „, „,~ PENNY L JOHNSON 335 WOLF BRIDGE RD CARLISLE, PA 17013-8476 ~~~III~~~II1~~~~~~11~~11~1~~1~~1~~11~~~1~11~~~~11,~1~1~~1~1~ May 02, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE AVISO: Este documer~to explica Como los propietarios de casas pueden evitar perder sus hogares debido a demoras de pagos. Para information en espailol llama a su prestamista. STATEMENTS OF POLICY Loan Number: 0054088208 Property Address: 335 WOLF BRIDGE ROAD, CARLISLE PA, 17013 Original Lender: AMC Mortgage Sewices, Inc. CnrreM Lender/Servicer: AMC Mortgage Services, Inc. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOII IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATTON OBTAINED FROM YOII WILL BE IISED FOR THAT PIIRPOSE. IF YOII HAVE PREVIOIISLY RECEIVED A DISCHARGE IN BANHRIIPTCY, THIS CORRESPONDENCE IS NOT AND SHOIILD NOT BE CONSTRIIED TO BE AN ATTEMPT TO COLLECT A DEBT, BIIT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is as ot[iciai splice flat the mortaate oa •oar tome is in ddaaN. ud the lender iatuds to foreekae. Specdie information shoat rie aafare of the ddult is r-rovided is the attached nattes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM t'HEMAP) ma• be abk to hela to save •oar homy This Notice emlains how the r-rotram works. To see if HEMAP can help. •oa mast MEET WITH A CONSIIMER CREDIT COIINSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with •oa whea •oa meet wilt the Coanadiat A=eacv. The name. address ud phone camber o[ Consamer Credit Coaesdint Atendes serving •ear Coant• are bated at the end of this Notice. If oa ha•e u• aaestiors. •oa ma• call the Pen~e•Ivuia Hoasiaa Finuce Atteacv tdl free at 1-800-342-2397.(Persona with impaired hearint can call (717) 780-1869). This Notice contains importut k=al iaformation. I[ you have uy gaestions, representatives at the Gossamer Credit Coaasdiai Afency may be able to help ezplain it. Yoa may also wut to eoataet u attorney is your arcs. The Iocal bar association may be able to hdp you find a lawyer. LA NOTIFICACION EN ADJIINTO ES DE SIIMA 1MPORTANCIA, P17ES AFECTA SII DERECHO A CONTINIIAR VIVIENDO EN SII CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA 17NA TRADIICCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOIISING FINANCE AGENCY) SIN CARGOS AL NIIMERO MENCIONADO "°""~"""'°` Also doing bnainess as Delaware AMC Mortgage Services, Inc., in the states of Taxes, Rhode Island, aad New Hampshire ARRIBA. PITEHES SER ELEGIBLE PARR IIN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CIIAL PiTEDE SALVAR SII CASA DE LA PERDIDA DEL DERECHO A REDl1VIIR SII HIpOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOII MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WffiCH CAN SAVE YOIIR HOME FROM FORECLOSI7RE AND HELP YOII MAKE FIITIIRE MORTGAGE PAYMENTS 1F YOII COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOII MAY BE ELIGIBLE FOB EMERGENCY MORTGAGE ASSISTANCE; : 1F YO17R DEFAIILT HAS BEEN CAIISED BY CIRCIIMSTANCES BEYOND YOIIR CONTROL, z IF YOII HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YODUR MORTGAGE PAYMENTS, AND z IF YOII MEET OTHER ELIGIBILITY REQIIIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOIISING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSITRE -Under We Act, yor are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During chat time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling ageaciea listed at the e~ of this Notice. TffiS MEETING MIIST OCCITR WITHII~T THE NERT (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. CONSIIMER CREDIT COIINSELING AGENCIES -- if you med with one of the consumer credit caaHeeling aEency listed at the end a~f this notice the lender may NOT take actin against von for thirty !30) love after the date of this meeting. The names. addresses and telephone numbers of designated eonsrmer credit eomseling ageaciea for the county rn which the property 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 af' your interions. APPLICATION FOR MORTGAGE ASSISTANCE - Yoor mortgage is in a default for the reasons set forth later in this Notice (see following pages for spcci5c information shoat the nature of your default.) If yon 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 511 out, sign and file a complded Homeowner's Emergenry Assistance Program Application with one of the designated consumer credit counseling age~ies listed at the end of this Notice. Only oonsraner credit counseling agencies have applications for the program and they will assist yon in srbmiging a complete application to the Pennsylvania Housing Finau~ce Agency. Yom application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOII MIIST FILE YOIIR APPLICATION PROMPTLY. IF YOII FAIL TO DO SO OR IF YOII DO NOT FOLLOW THE OTHER TIIVIE PEEIODS SET FORTH Ilv TffiS LETTE$ FORECLOSIIRE MAY PROCEED AGAINST YOIIR HOME IMMEDIATELY AND YOIIR APPLICATION FOR MORTGAGE ASSISTANCE WII.L BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. That' will be disbursed by the Agency ender the eligrbility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your appBcation. Daring that time, no forxlosme proceedings will be porsncd against you if you have met the time requirements set forth above. Yon will be noti5ed directly by the Pennsylvania Horsing Finance Agency of its decision on your application. ..o.o.~H:-e. May 02, 2007 Loan Number: 0054088208 NOTE: IF YOU ABE CURRENTLY PROTECTED BY THE FILING OF A PETTI'ION IN BANKBIIPTCY~ THE FOLLOWING PAST OF THIS NOTICE IS FOB INFORMATION PIIBPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yon have Clod bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CIIBE YOIIB MORTGAGE DEFAIILT Brine it ao to daft) NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property totaled at: 335 WOLF BRIDGE ROAD, CARLISLE, PA 17013 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: 03/01/07 thra OS/O1/07 Minimum Payments plan late charge or other fees: 54554.52 Mitimim Amount to Care De[aalt: 54554.52 B. YOII HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use J not annlit:able): N/A HOW TO CURE THE DEFAULT -Yon may care the default within THIRTY (30) DAYS oar the date of this notice BY PAYING THE TOTAL AMOIINT PAST DIIE TO THE LENDE$ WHICH IS 54554.52 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments mn~ be made either by ~h, crier's check cerliSed check or money order made payable and sem to• AMC Mortgage Services P.O. Box 5926 Caml Stream, IL 60197-5926 Yoa can ewe 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 YOII DO NOT CIIBE THE DEFAIILT-If yon do not core the default within THIRTY (30) DAYS of the date of this Notice, the b~ader intends to exercise its rlgbts to aeeekrate the mortgdg~d~f, 'T'his means chat the esdire o~standing balance ~ this debt will be considered doe immediately and you may lose the chance to pay the mortgage in mo~hly 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 start legal action 1o toreel_~^oen yosr mo ~aed p~~• IF THE MORTGAGE IS FORECLOSED IIPON -The mastgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its altomeys, b~ yon core the delingneary before the lends begins legal proceedings against yon, yon will strll be required to pay the reasonable attorney's fees that were actually incurred, np to SS0.00. However, if legal proceedings are started against yon, yon will have to pay all reasonable attorney's fees actaelly mcnmd by the lender even if they exceed 550.00. Any attorney's fees will be added to the amount yon owe the lender, which may also include other reasonable costs. If you care the defiuk wiriie ibe THIRTY (,'10) DAY period, yea will not be repaired to pay akoraey's freq. OTHER LENDER REMEDIES -The lender may also sue yon personally for the unpaid principal balance and all other soma due ender the mortgage. RIGHT TO CIIBE THE DEFAIILT PBIOB TO SHERIFF'S SALE - If you have not corod the default within the THIRTY (30) DAY period and foreclosure proceedings have began, you still have the ri¢PM to cme the drf'nlr and urevent the sale ffi env b'me uo to ~e how 1+ro+*+r the Ch s Sn_ Yon may~~y~ng the mini m emo~t then pest due plus env late or older hAwq then due. reasonable attorney's fees and onata cnnnerleel a,;th th.. [sow[hcgi-m cerforming any other r ' ementa ande~r the morig,~e. G~riag year ddult it the meaner set forth is this notice wi71 restore your mortgage to the acme position as if you had never ddulted. EARLIEST POSSI)~LE SHERIFF'S SALE DATE - It is estimated that the earliest date that each a Sheriffs Sale of the mortgaged property could be hehi 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 w~71 increase the bnger you wait. Yoe may find out at any time exactly what the requited payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: AMC Mortgage Services PO Bo: 11000 Suta Ana, CA 92711-1000 Phone Number 800-430-5262 Fax Number 714-347-5037 EFFECT OF SHERIFF'S SALE -Yoe should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you contiaoe to live in the property after the Sheriff s Sale, a lawsuit to remove yon end your famishings a~ other belongings could be started b9 the lender at any time. ASSIIMPTION OF MORTGAGE - Yoa _ may or X may sot (CHECK ONE) sell or transfer your home to a buyer or transferee who will assome the mortgage debt, provided that all the outstanding payme~a, charges and attorney's fees and coats are paid prior to or at the sale and that the other rogniremeata of the mastgage an satisfied. YOII 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. z 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 TIINES IN ANY CALENDAR YEAR) : TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, : TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER = TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSIIMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED If yon need additional assistance or counseling yon may also find a Housing Counseling Agency in your area by Calling Toll-free (800) 569-4287 or TDD (800) 877-8339. AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Loan Number: 0054088208 Mailed by 1st Class Mail ud by Certified Mai EfONYIMQM-01 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 Lmglestown 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 '^..J ~i ' r C .. ~ p !? Cr7 ~ S .it.,d _ .fl _. ~ ~. ,Q -~ c...~ ,~) rn .~-- SHERIFF'S RETURN - REGULAR r VASE NO: 2007-04053 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS JOHNSON DAVID L JR ET AL MEGAN HARLOW Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON DAVID L JR the DEFENDANT at 1728:00 HOURS, on the 10th day of July 2007 at 335 WOLF BRIDGE ROAD CARLISLE, PA 17013 by handing to together with and at the same time directing Her attention to the contents thereof. PENNY JOHNSON, WIFE a true and attested copy of COMPLAINT - MORT FORE Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 S ~1~16't ~ 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 07/11/2007 GOLDBECK MCCAFFERTY MCKEEVER By., ?~ D puty Sheriff A.D. SHERIFF'S RETURN - REGULAR CpiSE NO: 2007-04053 P ~_ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS JOHNSON DAVID L JR ET AL MEGAN HARLOW Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON PENNY L the DEFENDANT at 1728:00 HOURS, on the 10th day of July 2007 at 335 WOLF BRIDGE ROAD CARLISLE, PA 17013 PENNY JOHNSON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 ~, ~ 3~~~? ~ / 16.0 0 So Answers: R. Thomas Kline 07/11/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day eputy Sheriff of A.D. In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-4053 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 DAVID L. JOHNSON JR. and PENNY L. JOHNSON by default for want of an Answer. Assess damages as follows: Debt $226,148.18 Interest from 08/14/2007 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED M UNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FRO TH COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the a against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten a s prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Goldbe J Attorney for Plainti f I.D. #16132 AND NOW , Jud t is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUES M RTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER HE DOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECD S and against DAVID L. JOHNSON JR. and PENNY L. JOHNSON by default for want of an Answer and damages s sed in the sum of $226,148.18 as per the above certification. j 53825FC 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: July 31, 2007 TO: PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) TO: PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW Action of Mortgage Foreclosure Term No. 07-4053 TMPnRTANT NnTIC'F. 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 IIVIPORTANT 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Libeeiy Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 53825FC 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: July 31, 2007 TO: DAVID L. JOHNSON JR 335 Wolf Bridge Road Carlisle, PA 17013 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) TO: DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW Action of Mortgage Foreclosure Term No. 07-4053 iMPnRTANT NnTiC.'F, 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 LAWI'ER, 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 PROVII7E YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 se~ti.,~. Tafrfl~ec~?r 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, DAVID L. JOHNSON JR., is about unknown years of age, that Defendant's last known residence is 335 Wolf Bridge Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the M' ry or Naval Service of the United States or its Allies, or of erwise within the provisions of the Soldiers' and Sailo s' Civ 1 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, PENNY L. JOHNSON, is about unknown years of aqe, that Defendant's last known residence is 335 Wolf Bridge Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Milit ry or Naval Service of the United States or its Allies, o oth rwise within the provisions of the Soldiers' and Sailor Civi 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 07-4053 ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATION TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSI CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SER` OF NOVEMBER 1, 2003, WITHOUT RECOURSE, and against DAVIh JOHNSON for failure to file an Answer in the above action within (20) d~ United States of America) from the date of service of the Complaint, in th R T COMPANY, AS BACK PASS THROUGH [CING A REEMENT DATED AS ~. JOHN N JR. and PENNY L. s (or sixt (60) days if defendant is the sum of $ 26,148.18. Joseph A. Goldbeck, Attorney for Plaintiff I hereby certify that the above names are correct and that the precise re creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUS E OF MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH R IFIC. UNDER THE POOLING AND SERVICING AGREEMENT DATED AS F N VE RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 a d that the address(es) of the Defendant(s) is/are DAVID L. JOHNSON JR., 335 Wol Bridge o PENNY L. JOHNSON, 335 Wolf Bridge Road Carlisle, PA 17013; GOLDBECK MICA) BY: Joseph A. Goldb Attorney for Plaintiff ess of the judgment VI RIQUEST SERIES 2003-11 R 1, 2003, WITHOUT -e(s) and last known Carlisle, ~A ~ 17013 and McKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $206,088.24 Interest from 02/01/2007 through $8,330.35 08/13/2007 Reasonable Attorney's Fee $10,304.41 Late Charges $536.93 Costs of Suit and Title Search $900.00 Fees $87.00 Recoverable Balance $125.00 Suspense -$223.75 $226,148.18 GOLDBECK McCAI BY: Joseph A. Goldb Attorney for Plaintiff AND NOW, this ~5~ day of 2007 damages are assessed /C. r Prothy ' -``7r~ ^~ ia. r °-l "~ w ..fl x ~ `-3 ~j~Y y l~' ~ ~` t ;_ ~ . ; t't . . 7 ~' J ~ _ ..c Y ~ ~ Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff No. 07-4053 vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagors and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary B'IS~oCISD'] By: ~ Dlr$ Deputy 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 e , ~- 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 07-4053 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 08/14/2007 to Date of Sale at 7.5000% $226,148.18 (Costs to be added) GOLDBECK McCAFFERT BY: Joseph A. Goldbeck, Jr. Attorney for Plaintiff ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at corner of land now of formerly of Irwin C. Treaster et al., thence from said point at the place of beginning along the center line of said Wolf Bridge Road, North OS degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South OS degrees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a point in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and aluminum siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253-113 ~; `n ~ ~; H ~ ~, ~~H~o W ~ ~ Z W Pa+ U~vOd~ z ~~'cx70Q~ ~ `~"' cn W E--' x,00 ~w¢~WH z~ Qap w3 'Z' '~ -' o O ~Wx~^c4o U ~ c-~ W ~ ~~d--^ ~ x~~~,~ ~,~ c~> x p~~ ~ ~~ ~ ,J c• ..... ".~.. "" ~.. ~ ~ ~ cOn~d~O O x ° ~^ Z~ ~~ a > O'er ~ o ~~ ~3 Qaoo~nMU Q o ~~ O g 0 H D W ~ ~ ~ W o si- a ~w a ~ ~ Q k aR W ti~ w' o' C7 Q v~ ~f-. fie` 9b;~W6`X'~ "~ o 00 e o$oooo _ . ~t b '0 = -Il d `~ y ~, ~, ~ ~, ~~ ~, J ~,p ~ o ~ ; ~ ~ °?~ ~ y d ~ o~i,~~ ~N o ~ Via, ~,o ~~~vi ,~ r ~ ~t ~ ~ o ~ ,°'a °o a O y ~~ ~ c-7 ~~ ~, ~a ~ --~ u; .~.' : , _ _. -- )~j x c.~~ ~ v:' ~ ~ c 1 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. IN THE COURT OF COMMON PLEA5 of Cumberland County CML ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants; Term No. 07-4053 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: JOHNSON JR., DAVID L. DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December O5, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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). Y_OU 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 maybe 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 Sheriff s 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 J 07-4053 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov, for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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(a,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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants Term No. 07-4053 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: JOHNSON, PENNY L. PENNY L. JOHNSON 33S Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December O5, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS ~. 07-4053 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 an 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 t 07-4053 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.go_v for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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(a,goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-$25-6429. 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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a paint in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at corner of land now of formerly of Irwin C. Treaster et al., thence from said point at the place of beginning along the center line of said Wolf Bridge Road, North OS degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South OS degrees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a point in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.7b feet and having. thereon erected a two story brick and aluminum siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253-113 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-4053 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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: 335 Wolf Bridge Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE 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: HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest maybe 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 335 Wolf Bridge Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to he best my personal knowledge or information and belief. I understand that false statements herein are made subje to the nalties of 18 Pa. .Section 4904 relating to unsworn falsification to authorities. DATED: August 13, 2007 zF~~ s ' --~ tJ1 ~,, ..-~ - .. irel l1 ~ C J `:.-~ .V`^"~ ~ -_`~~ ~~ ~ ~_1 c =~ =t ~ 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) AS IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney action, and I further certify that this property is subject to Act 91 of 1983 and tl~ the provisions of the Act. NO. 07-4053 for the Plaintiff in this has complied with all Joseph A. G• Attorney for ;~ s ~ rl ~ ~-s's f'"~ ~.....~ ,--~1 _ ..~ ..-~ ~t`T`i ~~.. 4! .. ~ ~ "' . l_ )_ i ~`~ 3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF 11-01-03, WITHOUT RECOURSE Plaintiff (s) From DAVID L. JOHNSON, JR. & PENNY L. JOHNSON (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 $226,148.18 L.L. $.50 Interest from 8/14/2007 to Date of Sale at 7.5000% Atty's Comm % Due Prothy $2.00 Atty Paid $167.80 Other Costs Plaintiff Paid Date: 8/15/07 is R. Long, Prothonota (Seal) By: ~. Deputy I REQUESTING PARTY: Name JOSEPH A GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 for 53825FC CF: 07/05/2007 SD: 12/05/2007 $226,148.18 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4053 C3 C `. 335 Wolf Bridge Road _ Carlisle, PA 17013 rY`? ;4' Defendant(s) - - -- cn ~~ CERTIFICATE OF SERVICE -, PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) _ ~~' c~~ Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service v~4 the ~ ,•E Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. O m ~~ T ':i J ~^ _ c ~:.? __ _,~ J ~-r, c ectfully submitted, • Joseph A. Gold eck, Jr. Attorney for Plaintiff • rc ~~ p po N W° v- ~~ l~~ !I~ a N ~a d~ ! ~ ~ Yr~B N o ~ p3~ o 0 1 ~~ ~~ lf.~ ~~` x ~~~ ~~ ~; ~` d ~, ban. ~.~~~~ s :~~'~ a m $ Z ~ Z ~ Q ~ ~~ ~ o g~.~ ~ ~ K K K H ~ V ~ ~ ~ E ooa^ ~, o w z °a ~ ~ ~ ~, ~ Z ~~~ ~j ~ ~ N o ~ J r z.~a coiw~` u'~ ~ ~ E ~ ~ ~ ~a:~ ~Da t mid ^~p0 wZ °~ ~wGC m~~ o ~m~ m goo ~ zma ~°~ ~ ~q~~ U UQ.U ~r2 U.-U mYa= D Z W Q s ~a ~ ~a 2 ~V°oYJN mma~W~ mo~~~~ ~J _O ZOO=~ ~" N C9N~•d~ o tt°,J U F- N ~w ~~~ a ~Q~ ~~~ c~ ~ N t7 cfl d a ZQo a ~ ~ ~ U ~ ~ N !L~(? J oaz ~ ~ Y T m~0 ~~~ Q~Om =oo- w~~ ?°°•~ ~~~ oo ~ QvC9 =aw g Q 7~~ ~ U ~^ ~~~ ~ma a a ,; ~~~ ~ }w-cMU d ~~ d Z~ ~, ~~ ~C O h a .~~ a d a ti ~ $ ~f a ai Z o ~ m Z O J N ~ } 3 Z Q U a a ~ ~ O 7 ~ Z ~ ~ U Z 2 O is U ~ ~ N ~ a ~ p ~~ ~ ~ ~ p~ ~~ N U N O o0 ~! a~ •NUS o~- o s a ~ r ~} N t ~ u. ~gt!-Tf ~ ~y ~ ~Q ~ ~~ ~ NC Oa y • ~ Z 7 ~ °~~r A o~ 11.* d ~ ~ w ~ ~~~ ~~ ~ ~~ ~ ~~ o gg ~ o~ ^^^D ~ ~ ~ _ 'Z5 ~ QQaa~~ ~ $ Z X ~ ~ g i58- xx ul0g - OODO j°°Z O =a~ ~~ W Q `o ~d ~ d1 s F" a. a ~ ~ty~~W~ ~~~a~ C .a D N • ga ~ R = 3 U a r: °~ uV.. ~~ ~ N a ~ Z O z 0 J W a d O N Z 2 O ~i 0 Q ;; ~, ,~ ~1 `! :: ~i t`V ,V 1 .l 1~' r,~ ~'%_' ~~~~ ti Date Produced: 09/17/2007 GOLDBECK MCCAFFERTY ~ MCKEEVER The following is the delivery information for Certified item number 7111 4342 3630 00171800. Our records indicate that this item was delivered on 09!'14/2007 at 11:46 a.m. in CARLISLE, PA, 17013. The scanned image of the recipient information is provided below. -~.~1hM'"''~'~'r'"'"' ...::..- Signature of Recipien#: ~! w ""`~~~- "`" Address of Recipient: ~ ~ ~ ~. :/~ ~ _ r Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representitive. Sincerely, United States Postal Service The cus#omer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 4340453 16625576 ,~~ ti~rr~~t~si ~t~ Date Produced: 09/17/2007 w GOLDBECK MCCAFFERTY & MCKEEVER The following is the delivery information for Certfied item number 7111 4342 3630 00171817. Our records indicate that this item was delivered on 09/14/2007 at 11:46 a.m. in CARLISLE, PA, 17013. The scanned image of the recipient information is provided below. Signature of Recipientt:' - ~ ~ . T:.7 ....J:. Address of Recipient: ~ ~ y^ ~~' ~~ 5 C :~;,..Y:..F.. ,~ ,} . 1 Thank you for selecting the Postal Service for your mailing needs. If you require additional ~' assistance, please contact your local post office or Postal Service representitive. Sincerely, .~ United States Postal Service r ~ .. z ' ~. ~~ The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. ~~ '~` Customer Reference Number: 4340453 16625576 ,~ ~~ ,' GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 -Mellon 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 SECiJRTT1ES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Cazlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4053 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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: 335 Wolf Bridge Road Cazlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Cazlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. 33S Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 33S Wolf Bridge Road Carlisle, PA 17013 3. Name and last lrnown address of every judgment creditor whose judgment is a record lien on the property to be sold: 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 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. P.O. BOX 9068 BRANDON, FL 38509-9068 HOUSEHOLD REALTY CORP. 2S GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 170SS AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 S. Name and address of every other person who has any record interest in or record lien on the property and whose interest maybe 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 maybe 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 maybe affected by the sale. TENANTS/OCCUPANTS 335 Wolf Bridge Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 6, 2007 BECK cCAFFERTY & McKEEVER B :Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Deutsche Bank National Trust Company, as In the Court of Common Pleas of Trustee of Ameriquest Mortgage Securities, Inc., Cumberland County, Pennsylvania Asset Backed Pass Through Certificates, Series Writ No. 2007-4053 Civil Term 2003-11 Under the Pooling and Servicing Agreement Dated as of November 1, 2003 without recourse VS David L. Johnson, Jr. and Penny L. Johnson William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 0929 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: David L. Johnson, Jr. and Penny L. Johnson, by making known unto David Johnson, personally and adult in charge for Penny L. Johnson at 335 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 0929 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of David L. Johnson, Jr. and Penny L. Johnson located at 335 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: David L. Johnson, Jr. and Penny L. Johnson by regular mail to their last known address of 335 Wolfs Bridge Road, Carlisle, PA 17013. These letters were mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. 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 Poundage Posting Bills Advertising Law Library Prothonotary Mileage Levy Surcharge Postpone Sale Law Journal Patriot News Share of bills 30.00 17.83 15.00 15.00 .50 2.00 4.80 15.00 30.00 20.00 377.00 367.25 14.92 $ 909.30 / ~/>j~ ° ~ 0 R. Thomas Kline, Sheriff B1~~ ~ _ c Z ~/D Real Estate ergeant J~G~v3~ /Ce<,.~ 6 y 8 ~ I ~^_ Goldbeck 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-4053 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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: 335 Wolf Bridge Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE PENNY L. JOHNSON 335 Wolf Bridge Road .~ , Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE 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: HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest maybe 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 maybe 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 335 Wolf Bridge Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to a best my personal knowledge or information and belief. I understand that false statements herein are made subje to the nalties of 18 Pa. .Section 4904 relating to unsworn falsification to authorities. DATED: Au~;ust 13, 2007 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants; Term No. 07-4053 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: JOHNSON 1R., DAVID L. DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December O5, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-4053 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I . 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 or1-866-413-2311 and 2. You maybe 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 fmd 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-4053 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 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 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 1-866-413-23.11 or via email at homeretention(cr~~oldbecklaw.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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Term No. 07-4053 THIS LAW FIItM 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: JOHNSON, PENNY L. PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December O5, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $22b,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-4053 YOU MAYBE 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 or1-866-413-2311 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 fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the $uyer 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-4053 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 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 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(a,~oldbecklaw.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 53825FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at corner of land now of formerly of Irwin C. Treaster et al., thence from said point at the place of beginning along the center line of said Wolf Bridge Road, North OS degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South OS degrees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a point in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and aluminum siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253-113 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF 11-01-03, WITHOUT RECOURSE Plaintiff (s) From DAVID L. JOHNSON, JR. & PENNY L. JOHNSON (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 $226,148.18 L.L. $.50 Interest from 8/14/2007 to Date of Sale at 7.5000% Atty's Comm % Due Prothy $2.00 Atty Paid $167.80 Other Costs Plaintiff Paid Date: 8/15/07 5 's R. Long, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 i Real Estate Sale # 47 On August 20, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 335 Wolf Bridge Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 20, 2007 By: ~ ~ ~~~ Real Estate Sergeant ,The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE c~e~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday! Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/24/07 10/31/07 11107107 i ~ ~ i t ~ !?r-~~ AfL~initaf Y ~ d ~ ~ ~ ' ~~~ m ' bowiird ,ad, .drllprAMd~7#s r~ #~wiYp iriF'~Ji~IMat ae Sworn to and ubs ibed befor a this 30 day of November, 2007 A.D. No ry Public CpMMONWEALTH OF PENNSYLVANIA Notarial Seal James L. CIaAc. Ny~o>arY Pu~b~licp~~~y~ MY Commission E~res June 2, 2008 Member, Pennsylvani2 Association of Notaries PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~~ Lis Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 9 day of November, 2007 Notary NOTARIAL SEAL DEBORAH A COILINS Notary Pubilc CARLISLE BORO, CUMBERLAND COUNTY My Commisalon Expires Apr 28, 20 T 0 REAL >~TA'i"E $ALt 1[O. 47 Writ No. 2007-4053 Civil Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Asset Backed Pass Through Certificates, Series 2003-11 Under the Pooling and Servicing Agreement Dated as of November 1, 2003 Without Recourse vs. David L. Johnson, Jr. and Penny L. Johnson Atty.: Joseph Goldbeck DESCRIPTION ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at comer of land now of formerly of Irwin C. Treaster et al., thence from said point at the place of beginning along the center line of said Wolf Bridge Road, North 05 degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South 05 de- grees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Trwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a paint in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and alumi- num siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253- 113. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 07-4053 DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $22b,148.18 Interest from 08/14/2007 to Date of Sale per diem at $42.94 (Costs to be added) r-- GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ~~ ~ ~'' H U W ~~~~o a OWU~O~ z. ~d~oQo `~ ~~owQ~ ~O ~~E'" ~+AQ ~t--w Ovlrn ~H ~' za Qap~~~3 G ~ W, Up~o ~Q ~ ~ ~ d ~ r~+ ~ W [~ W ~ w ~,~ ~ r v A ~ '~ `~ ~- O ~ U ~ ~ ~ -~ ~ ~ W c6 M ~°°~o O o d ~~ o ~~ O ; .o d ~o~~~, ~ a w ,, 'O ~ yj OS ~- ~ o w ~~ ~ ~a ~ w ~ ~ Q p ~~ ~~ S~ t~1 W ~. ~_ ~¢ i ~'' ~yT~ .~ "f GQ T .5.7 W ~~ ~ g .~ G ~ ~ ~ ~ v z v .+ d N y U N ~ ~ v ~~ ~ocv ~^" N ~'~~~ U o~ Rv, 41 N .., ~ N ~~ ro ~ ~ ~' ,~^^ ~„;„~ t ~ ~ ~ b Y ~ - ry -' E .. ~: . -^{" ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at corner of land now of formerly of Irwin C. Treaster et al., thence from said point at the place of beginning along the center line of said Wolf Bridge Road, North OS degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South OS degrees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a point in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and aluminum siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253-113 MIDDLESEX TOWNSHIP IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: DAVID L. JOHNSON JR. CHAPTER 13 CASE NO.: 1:07-bk-03847-MDF Debtor(s) ORDER DISMISSING CASE It appearing that the above-named debtor(s) has/have failed to to comply with the Stipulation entered on June 10, 2008,upon filing of Trustee's Certificate of Default, and it having been determined that the case shou{d be dismissed, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U.S. Bankruptcy Court. ~~ tlt~ C'o~u°~t, This docume~at #s electror~icaddy sagraed arad fated ova tdae same date. Dated: August 22, 2008 MDPA-DISMISSI.WPT REV. 04/08 Case 1:07-bk-03847-MDF Doc 40 Filed 08/22/08 Entered 08/22/08 11:10:42 Desc Main Document Page 1 of 1 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-4053 DEUTSCHE BANK NATIONAL TRUST COMPANY, A5 TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 335 Wolf Bridge Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 HOUSEHOLD REALTY CORP. P.O. BOX 9068 BRANDON, FL 38509-9068 AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 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 335 Wolf Bridge Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 28.2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C? ~„ ~~ ~ -r~ ~ c' 7'., ~ ~ F 1~~L -'y-~. `-~~ ~.. ^~ Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Plaintiff Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY N0.07-4053 I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Michael T. McKeever Attorney for plaintiff ~ C? ~ c~ ~. ~ ~., ~ : ~,,.. ~~ _e n=' , sj ~?,; -~•~ , - : ` a ~ ( ~~ ~ : 07-4053 GOLDBECK McCA.FFERT'Y & McKEEVER BY: Michael T. McKeever Attorney LD.#56129 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants; Term No. 07-4053 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: JOHNSON JR., DAVID L. DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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. 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 4. 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 maybe 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 r 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-4053 .y 07-4053 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 maybe 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real asnx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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,~oldbecklaw.com. Call Seth 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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ~, 07-4053 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants; Term No. 07-4053 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: JOHNSON, PENNY L. PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS ~- ' 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 or1-866-413-2311. 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. 4. 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 07-4053 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ~. 07-4053 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 maybe 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.or~/consumers/homeowners/real. aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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(cr~~goldbecklaw.com. Call Seth 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 53825FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE Plaintiff (s) From DAVID L JOHNSON JR PENNY L JOHNSON (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 $226,148.18 L.L. Interest FROM 8/14/2007 TO DATE OF SALE PER DIEM AT $42.94 Atty's Comm Atty Paid $1,098.60 Plaintiff Paid Date: August 29, 2008 (Seal) Due Prothy $2.00 Other Costs S ~.~,; ~ ~ urtis R. Long, Prothonotary ~,.. ~ By: .~ ~..~e_J Deputy REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQ Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA , PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court lD No. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 53825FC CF: 07/05/2007 SD: 12/10/2008 $226,148.18 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4053 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (o~l~~le4 Personal Service by the Sheriff s Office%e ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney far Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff s Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff • ~ I I O ao to q Doq _° ~ N ~ ~ ~ OI ~N M q W 0 ~ U N ~ ~ ~ ~ t ~ t ~ W 6 N ~ Q ~ > ~ r~ ~ Q~ Nod p p ''~ • •~1,, i . y . 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Wz~ m p ~ m m 7 ~OJ ~ ~ ,~ E OOOw ZmQ Q~mQ ~U ~ oc~aU ~~= am=a U~c~ ~ a a`s C ~ 2 ~ WQ y ~a a ~ cn F - $Yoriia UoY--j a~ '~ mmWQ~r =N Z O ~ p = r ~ CV M d' ~ Cp l~ 00 ~ ~ d C d° m C ~: A o a0 v o 0 a m m is N `O C ._ 7 d ~ U ~ ~ o ~ o N ~' U 7 M V w N a ~ Z O m Z 2 O _i } Z Z W ~. z O z 0 J 0 Q Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Assett Backed Pass Through Certificates, Series 2003-11 Under the Pooling and Servicing Agreement Dated as of November 1, 2003, without recourse VS David L. Johnson, Jr. and Penny L. Johnson In the Court of Common Pleas of /~~ Cumberland County, Pennsylvania `~`~,~',Tjj~ Writ No. 2007-4053 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 19, 2008 at 1430 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: David L. Johnson, Jr. and Penny L. Johnson, by making known unto David L. Johnson, Jr., personally and husband of Penny L. Johnson, at, 335 Wolfs Bridge Road, Cazlisle,Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 8, 2008 at 0906 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the shove entitled action, upon the property of David L. Johnson, Jr. and Penny L. Johnson, located at 335 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: David L. Johnson, Jr. and Penny L. Johnson, by regular mail to their last known address of 335 Wolfs Bridge Road, Carlisle, PA 17013. These letters were mailed under the date of October 7, 2008 and never returned to the Sheriffs Office. f~ R Thomas Kline, Sheriff a GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4053 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE, Plaintiffin the above action, by its attorney, Michael T. McKeever, 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: 335 Wolf Bridge Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. . 335 Wolf Bridge Road • Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 HOUSEHOLD REALTY CORP. P.O. BOX 9068 BRANDON, FL 38509-9068 AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 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 335 Wolf Bridge Road Carlisle, PA 17013 (attach sepazate sheet if more space is needed} I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 7, 2008 ~~= mil, yy`^.c.~ 1~-(/~LC IC,-rc~rM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff ,rte') r'y 4..3 ~`:"° :t t 'w; 'r, 1t"':~ GC3 ~t~~ "r ;' ~. r ~w i vp .j P`7'; 1 <" f -+~~ m.~ Deutsche Bank National Trust Company, as Trustee of In the Court of Common Pleas of Ameriquest Mortgage Securities, Inc., Assett Backed Cumberland County, Pennsylvania Pass Through Certificates, Series 2003-11 Under the Writ No. 2007-4053 Civil Term Pooling and Servicing Agreement Dated as of November 1, 2003, without recourse VS David L. Johnson, Jr. and Penny L. Johnson William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 19, 2008 at 1430 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: David L. Johnson, Jr. and Penny L. Johnson, by making known unto David L. Johnson, Jr., personally and husband of Penny L. Johnson, at, 335 Wolfs Bridge Road, Carlisle,Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 8, 2008 at 0906 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of David L. Johnson, Jr. and Penny L. Johnson, located at 335 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: David L. Johnson, Jr. and Penny L. Johnson, by regular mail to their last known address of 335 Wolfs Bridge Road, Carlisle, PA 17013. These letters were mailed under the date of October 7, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request form Attorney Michael McKeever. Sheriff s Costs: Docketing $30.00 Poundage 59.66 Advertising 15.00 Posting Handbills 15.00 Mileage 10.00 Levy 15.00 Surcharge 30.00 Prothonotary 2.00 Postpone Sale 20.00 Law Journal 377.00 Patriot News 401.00 Share of Bills 14.92 $989.58 ~/ ~z~a3~09 ~- ~ ~..~-. R. Thomas Kline, Sheriff a • crv BY s`J ~ ~ ,U ,1~M i ~. Real Estate Sergeant c:.h. G ~ a 3$ ~~g~~ r f Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Mazket 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON (Mortgagor(s) and Record Owner(s)) 335 Wolf Bridge Road Carlisle, PA 17013 No. 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 335 Wolf Bridge Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING HARRISBURG, PA 17121 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 HOUSEHOLD REALTY CORP. P.O. BOX 9068 BRANDON, FL 38509-9068 AMERICA BANK OF USA. N.A. 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 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 335 Wolf Bridge Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DAT$D: Au,~ust 28.2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 07-4053 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Mazket 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants; Term No. 07-4053 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: JOHNSON, PENNY L. PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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 or1-866-413-2311. 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. 4. 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 07-4053 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-4053 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 maybe 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http: //www.phfa.org/consumers/homeowners/real. aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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,~oldbecklaw.com. Call Seth 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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. r 07-4053 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DAVID L. JOHNSON JR. PENNY L. JOHNSON Mortgagor(s) and Record Owner(s) 335 Wolf Bridge Road Carlisle, PA 17013 Defendants Term No. 07-4053 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: JOHNSON JR., DAVID L. DAVID L. JOHNSON JR. 335 Wolf Bridge Road Carlisle, PA 17013 Your house at 335 Wolf Bridge Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $226,148.18 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS J 07-4053 YOU MAYBE 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, 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. 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. 4. 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 maybe 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 07-4053 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-4053 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 maybe 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa. or~/consumers/homeowners/real. aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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(cr~,goldbecklaw.com. Call Seth 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 53825FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 335 Wolf Bridge Road Carlisle, PA 17013 SOLD as the property of DAVID L. JOHNSON JR. and PENNY L. JOHNSON TAX PARCEL #21-15-1253-113 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-4053 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 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE Plaintiff (s) From DAVID L JOHNSON JR PENNY L JOHNSON (1) You are duected 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 $226,148.18 L.L. Interest FROM 8/14/2007 TO DATE OF SALE PER DIEM AT $42.94 Atty's Comm Atty Paid $ 1,098.60 Plaintiff Paid Date: August 29, 2008 (Seal) Due Prothy $2.00 Other Costs l5l C~ R. ~ uri s R. Long, Prothonotary r-~ Deputy REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQ Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA , PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale #71 On September 5, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 335 Wolfs Bridge Rd., Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2008 By: ~ ( ~~~~ `~~_. Real Est Sergeant ~~ ~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 31, November 7 and November 14, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Y~.: ~'- Marie Coyne, SWOIbDTh'O AND SUBSCRIBED before me this 14 day of November 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL li~'TA-T)c B~Ad.S RO. 71 Writ No. 2007-4053 Civil Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Asset Backed Pass Through Certificates, Series 2003-11 Under the Pooling and Servicing Agreement Dated as of November 1, 2003 without recourse vs. David L. Johnson, Jr. and Penny L. Johnson Atty.: Michael McKeever ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in the Village of Glenwood in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-508 known as Wolf Bridge Road, which point at the place of BEGINNING is 1,511.54 feet North of the center line of Township Road T-508 known as Clemson Drive at corner of land ntrw of fcxmery of Irwin C. Trc~uiaGer et al., thence ffrront said point apt the pl~rce of along the center line of said Wb~~dge Road, Ntsrth 05 degrees 56 minutes 20 seconds East, a distance of 115 feet to a point; thence South 84 degrees 24 minutes 20 seconds East, a distance of 209.76 feet to a point; thence South O5 de- grees 56 minutes 20 seconds West, a distance of 115 feet to a point at the Northeast corner of said land now or formerly of Irwin C. Treaster et al.; thence along the Northern line of said land now or formerly of Irwin C. Treaster, et al., North 84 degrees 24 minutes 20 seconds West, a distance of 209.76 feet to a point in the center line of said Wolf Bridge Road, the point and place of BEGINNING. CONTAINING 115 feet in front along the center line of Wolf Bridge Road and extending Eastwardly therefrom at an even width a distance of 209.76 feet and having thereon erected a two story brick and alumi- num siding covered dwelling house with attached two-car garage, known as 335 Wolf Bridge Road, Carlisle, Pennsylvania, 17013. TAX PARCEL NO: 21-15-1253- 113. MIDDLESEX TOWNSHIP. ' - The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ~llatriot-hews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/29/08 11/05/08 11/12/08 f November, 2008 A.D. wv~aiy ruuu~ COMMONW~ ~~~ PENNSYWANIA No{a~l Seai Sheer L Kisner, ~ryin uCou~Y ~y of Hs,rrietw~~ ~. ~~ 2011 Memo ~. Pa~nia Assoclatlon of Notaries ~E~AL ~1 ALL THAT CEi[Cjpg+{ tray of ~, Bogel6er w~ dte ~ppn , sNeate n the 'Village of (i!amwood in Middlesex P'e~plvania, at a pow is the cea~r liee of Road 7308: ~~ as Wolf fridge ROB pnipt ~!<1e p~ac of B~GIlYNIING is 1,S11Sd ~eet I!fo~t=af ~ cenoer ~ of Toad R,oail 7598 kaa.n as Qeffison Brine at corner of lred aorr of Y of Irwin C. Treasoer-et al:, ice fiom ~ point at the Imo' ofbe~pg a~.~ adator tine of said Wolf ~ ~~Nawh~ degrees 56 matiutes ~se~~aof115feettoa p~fi tfir'ace Soar 84,degteea 24 minutes 2ll ~'on~ , F~ a dismrace of 204.76 feet to a poiah lbcagce Sarlb 03 dtgreta 56 mintdes 20 ~. a dili~ce of 113 fleet to a peimt at ~ N 'cotnar of sadd land now or f°mr~r!'fi~'~ C:? et al,; th¢ace a~png the Ndelhad tine bf said lapel now or of Irwin C. Tmaatti; er el.; Nonfr 84 de minutes°20 seco~ War: a di.~toce of 2ti9.7b fieetto a pt~;e~.~e of said Wotf '-limed, tlk P~ and place of ~~ ~I(i 115 feA is front alogg the cen~r line oF' lp6if Bridge' -Rued and extendipg ~°'~Y >J at >e even width a distance of 209.16 feet .and ~LavmB Neon. }xected a taco story brick add a) sid~g arien'd d ltnttse ~ +~Ited ~o-car B~Se, known as 335 Waif' g~ Roat1, ~adisle;s; T7Di?: TAI!C '~9F 22•IS~tS53.113 litf d ~ du; +'~t! Ptir~y t„ ~~t GOLDBECK McCAFFERTY ~ McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attomey for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 07-4053 PRAECIPE TO VACATE JUDC~rTT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. MICHAEL T. MCKEEVE , ESQUIRE s ~:~-~ _ ~ ~~ ~.. ,~ ~_} ? . ~ :, ~ fem.. ~ ~ ~. °~ ~ ~ , ~, ~~ ' ~~ ~ 1 `~ ~ ~ ._w._ l t'T7 ' ~ ` ~ V , ~, w +' . ` ~ f .A © \ GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 1910b-1532 215-825-6321 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET BACKED PASS THROUGH CERTIFICATES, SERIES 2003-11 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF NOVEMBER 1, 2003, WITHOUT RECOURSE 10801 6th Street No. 07-4053 Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. DAVID L. JOHNSON JR. PENNY L. JOHNSON 335 Wolf Bridge Road Carlisle, PA 17013 Defendants PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. ~~ ~ ~~~~.~Q~ Michael T. McKeever, Esquire Attorney for Plaintiff {~_1 t`T d-~ ~~ ~ i'7 ~'; ~tl~ re ~ .~~ ~.~.~ ~ : ;° , ;, ~ t y` • • _'-. ('TE ~,.9 ..r.,.f °^~.i