HomeMy WebLinkAbout07-5440GOLDBECK 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
W W W.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-ARl UNDER THE
POOLING & SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
Martgagors and Real Owners
120 Emerson Drive
Carlisle, PA 17013
Defendants
Term
No. b7 . $~}~~ CiV i~ TuM
CIVIL ~lFtE~~~E
F~~~+ •
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 aze 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
IN THE COURT OF COMMON PLEA5
OF CUMBERLAND COUNTY
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
AVISO
LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED 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 SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIItA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ~STE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELI~FONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEER>; CON INFORMACIbN DE CbMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ~STA 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
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 800-211-6926 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 homeretentionCa~goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure andlor
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 56442FC.
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.
Resources available for Homeowners in Foreclosure
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-ARl UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JANUARY 1,
2003, WITHOUT RECOURSE, 10801 6th Street, Suite 130 Rancho Cucamonga, CA 91730.
2. The names and addresses of the Defendants are MAXINE E. METZGER, 120 Emerson Drive, Carlisle
PA 17013 and DONALD L. METZGER, 120 Emerson Drive, Carlisle PA 17013, who are the
mortgagors and real owners of the mortgaged premises hereinafter described.
3. On December 03, 2002 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 1786, Page 4843. 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-AR1 UNDER THE POOLING & SERVICING AGREEMENT
DATED AS OF JANUARY 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 Plaintiffhas been andlor will be lodged for recording
with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) aze
matters of public record and aze 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 aze 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 aze due and unpaid
for May 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
chazges aze due and collectible.
6. The following amounts aze due to Plaintiff on the Mortgage:
Principal Balance ..................................................................................$113,879.24
Interest from 04/01/2007 through 09/30/2007 at 8.9500% .......................$5,180.72
Per Diem interest rate at $28.31
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$5,693.96
Late Charges from 05/01/2007 to 09/30/2007 .............................................$283.35
Monthly late chazge amount at $56.67
Costs of suit and Title Seazch ......................................................................$900.00
Escrow Advance .......................................................................................$1,776.81
Fees ................................................................................................................$87.00
Recoverable Balance ....................................................................................$931.00
$128,732.08
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 "i~ersonam" 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 $128,732.08,
together with interest at the rate of $28.31, 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 Sherii~s Sale of the Property.
By: ~ ~~~.k--
L BEC McCAFFERTY & McKEEVER
BY: 70SEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, RENEE WINTERS, 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
~oiporation 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 a. .S. 4904 relating to unsworn falsification to authorities.
Date:
RENEE WINTERS,FORECLOSURE SUPERVISOR
#0440831547 - MAXINE E. METZGER and DONALD L. METZGER
~ki6itA
r -- - - - - -- -- - - - -
.~
a
~ ALL that certain tract of land situate fn South Nlkidk3ton Township, Cumberland Couniy, PennayNania, bounded
~ ~ and described as folk~wa;
BEO1NN114O at a point on the Northam Ifne of a proposed Thirly~abc (~) feet wide arrest to bs known as
Emerson Drive at the SouUreas~m comer of Lot of land crow or formerly of John Bowies and wflb described kr
deed from Sylvester R. Snyder and wife ~ John Bowles and wHb dated June 21,1963 and recorded fn the
~ hereinafter mentioned Recorder's Ofltoe in Deed Book W, Va. 20, papa 636 tfterrce ikon said print at the pbwe
~ of beginning atorrg tine of saki land crow or formerly of John Bowles and wife. North 48 degrees 30 minutes East,
a distance of One Hundred Fogy (140) feet to a point at crorner corrwnort to end of saki John Rowbo and wife,
land now or torrrrery of Legrand S. Gleim and wife and trend now or formerly of lCerwrs9t W, t3reider and wife;
thence abng said fine of land crow or forrrrarly of Kenneth W. C3reider and w1te, South 41 degrees 30 mbxrtes
East, a distance of One Hundred Four (104) fleet ip a pow therx:e along Arlo of fend of Sylweler R. Snyder and
wife, Sorgh 48 degnea 3o minutes Wit, a distance of one Hundred Forty {140) feet to a pant on the Worurem
~ ~ std Proposed Thkh--sbc (36) tea wide street to be known as Emerson Drive; thence along the NatFrem
Nne of saki Tfrirrty~Ix (36) feet wide sheet b be known ae Emerson Dl1w, North 41 degrees 30 minutes West, a
di~ence of One Hundred Four (104) feet tp a pare; the place of BEGINNttVC3.
Tax ID No.: 40-24-0748-010
c~sa¢one~.raaoremn
j
i 1
I Certify this to be recorded ~ -
It2 Cumberland County pq
O ~
z7. ~,p~
1L~,
C~ i a.
'.... ,
.. Recorder of Deeds
BK 1786pG4859 - _ -
~hi6it B
P.O. Ilea 110N
B.Ne Aa. Cw muat~
7182 6389 3060 1043 7545
DONALD L MBTZGER , ~ ,,,,~
MA]~IE E METZQ<BR
I20 ~R80N DR
CARLISLE, PA 17013
1 8 8 8 LLZI ~ B~
MORTGAGE SERVICES
lay 16, 2007
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME
FRAM FORECLOSURE
AVISO: Este doauaento explica como bs propietarios de cases pooden eviler perder sus hogares debido a demotes
de pagos. Para informacidn en eapaifol llama a su prestamista.
Lon Number: 0040831547
7 120 B1~~RSON DRIVB, CARLISLB PA, 17013
Ot~l Laaaer: AMC Mode Servlca, lac.
Camat Laaiee-Servioer: AMC MaefeaBe Servkp, Iac.
THIS 1IlM IS A DE1T COLLECTQ! ATIZIIQTING TO COLLiICT A D1vT. T~ffi NOTICIZ
ffi 81tNT TO YOII IN AN ATT#l[PT TO COLLiCT THIC IIPTK#1'IE#lIp~81~~#'i+p
HICR#IN AN# ANY 1NB'Ola(AT10N O#TAU>ZD 1~OM YOII w-#It S IIS~ 1'O>t THAT
PO'B1OS1I. D YOII HAVt !lzV10IISLY >tNC14IVit# A #ISCIIAIiGS IN sAl~IIP'LCY, TIiiB
CO>t1~PON#3l(Ciz 18 NOT AN# SHOIIL# NOT #IC CONST1~Oit# TO II# AI(AT'I'Zll[P'P TO
COLLECT A Dt#T, sIIT ONLY iclfDO>tCt3~NT 01 A Li1ZXN AGAINST I"tOPli<TY.
Tl~ ^OIIiO~i-lfEnl'S MOYPGAGE ASSISTANCE PiOG=AI[ (HZ_.~A~ atn M aW M ~ M /aee wear
TW NNiee aeahiru b>Negat ~ lal~atiea, V Pw Oare nT mss, re frantaltres at tYs CMmrer
Chit Cwaeeitai ABeuP ru7 ie atie to ldP ea*laia K Yea mq idn wnt f, aataet as attwaq is ~~
nee. TM heal Nit aeaeiatlea mq ie abk M be4 7w ffai a IawPer.
LA NOTD'ICACION EN A#701IT0 ES #E BIIMA II1t!'OlTANCIA, PIIl~S AT~CTA SII #E=EC'HO A
CONTIl1i7A1t VM!!l#O EN SII CASA. SI NO C'O !I. CONTEN>HO #E =ETA
NOTUICACION O#TENGA IINA TsA#IICCION II'Fi1EE#ITAMEi(TE LLAIIfAN#O ESTA AGENCIA
(PENNSYLVANIA HOIISING 11NANCE AGENCl~ SIN CAi<GOB AL NIIII[E#O MENCIONA#O
Abo doie8 bewen r Delnnre AMC Maur Serrice~, hc., is tl+e dates of Tee, R>.ode Ielnd„ eed New
AtttBA. FII3D33 S3>t EL3GIBL3 PR=A IIN 1R33TAM0 !OS 3L FI<OG>tAMA LLAMADO
"HON30WNE='S 3N>d>tG3NCY MO1tTGAGE ASSISTANCE ?IdOG=Alll" EL Ct1AL lIIED3
SALVA>t SII CASA DE LA !3>vIDA DEL D3>t3CH0 A It3DII1~ SII HIIOTtCA.
HOM30WNEt'S ENElGENCY MOiTGAG3 ASSISTANCE rDOGItAM
YOII NAY DE ELIGD >: >M>t FI1I.~mt'[wT. • ~e~
CAN SAVE YOIIt HQ,QII[ FQ~R Alm
$SIl' YOII 11dA~ FffTFtlilr NOttTG_wrm! FAYNENTS
IF YOII CONlLY W1TH THE MOVISIONS OF 77Q HOi1t30WN3>t'8 3N31IG3NCY MOlt7'GAG3
ASSISTANCE ACT OF lfai (THE "ACT'7, YOII MAY >N 3LIGDL3 FO= 3M3iG3NCY MOlTGAG3
ASSISTANCE:
= IF YOII>t DEFAIILT HAS B33N CAIIBED DY CItCIIl1[STANC33 B3YOND YOt1>t CONT>tOL,
s IF YOII HAVE A >t3ASONABL3 lILOSl3CT OF B3ING ABLE TO FAY YOIIi MOItTGAG3
rwYMZNTS, AND
: IF YOII N=ET OTHZS ELIG1DILiTY DEQIII:ENE1Pi'$ ESTADLNHED BY THE
P3NNSYLVANIA HOIISIIrG FQIANC3 AGENCY.
T3NMD~AtY STAY O! FO>tECI.(lSII1t3 - Under ie Act. you aro aatitld to a tampaary ~ dfaodotue
er yon' !br iMT (30} da'a from is dab dtria Nolioe. DmiaS irM time you anal u~at`o and agaad a
taoe-to-8oa moetia3 witti we d tLo carwa~ar arodit oou'eliD a Wted at Oe oil d t~ Nalioe. T
ms wtrr u waucr ass p~pN{y is Ioaled nee let fair at ie ed d Ilde Notioe. It is ory recamq to rcredde are
Sae-to-Sae n~agir3. Advice yarr leader oaf yarr idealiore.
APlI.ICATION FOl NO><TGAG3 ASSIST~3 - Yoar mataaae» it a da6rlt for Ire ratora ast Sei iger
~ Nia Natioe (tee lbllo~viaa paSaa Sr O idbrmatior groat tk a~lare dyaa; BeSmlt.) If )ar tars tiled nail
are amble b resoba Nis problem wilt Ne leader, yot itaae tre Hiatt b apply for Smrcid auiMaroe lbgn Ne
Haoeowrat'a ~7 Mataaas Aatiaaroe FioSam. To do to, ]or mat ~ oat, siP aril Sic a oorq~leled
Homeowaet'a limerasrcy AatirGaoe Pragam wii aw d tro daaiaarlsd oaap~er ciadil caiosabra
ageacia YaAod assts ad d tri. Notioe. O~y oo.we~ar corodi[ooareN~ aaerciea ran appNcatio.a for ue
program and tray v+Hl amiat la+a is wbr3pLa a oomplds to trs Pearaldvsria Hamdra Fiauoa Aaercy
Yorr applioatior MUST be Sind a poata~arked witria may (30} days dyer faoa-IO-Sx maedrs.
YOII MIIST FII.3 XOt7>t ARLICATIOIi !=ONri'LY. IF YOII FAII. TO DO SO OH IF YOII DO IiOT
FOLLOiY TH3 OTHS>: TINE 1"31ZIOB3 837' FORTH IN THt3' LETTis. FI1>R3CI.03~3 NAY
!>tOCEEB AGAIII3T YO1J>t HOM3 IIIRNZDL-TELY AND YOIII< A!'ltiCATION FO>< NO>tTGAG3
ASSISTANCE R-II.L BE DENIER
AGENCY ACTION -Ara>tiabla finds ibt emeraeaK,7 moeta+t~ amitlaroe aro nary limited. Trey wriD 6e diobaraed
by ~ A6~! ~* ~ eliai6ilily alablirred by tra Rat Tre Peoayha•ia Hooia Fiaarae ASscy ran
tasty (60) dys b mara a daciaaa alter S reoaivaa ye.r apptipUoa Daiy iat lima. as lixedo~asa psaoe~
w~l ~ pfd ~ y~ 3ya rare mat ie lima rogiemaata rat tai abow+e. Yor nit be aWided d~ectly by
tre lwemtaylvaria Hoatiaa Fiaara Aaerry d ib dacaaaa ar yoar tppKcatioa.
..oas.n•s
riy 16, tom
Lon Namber: 0040831347
NOTES T! YOII A!E CII1ttENTLY MOT=CT=D DY TIC 1II.IIrG O! A 1DT1110Ii II~i
DANttIIlTCY. THE ITOLLOWIIiG lAYI' OZ THtB NOTICE 181011 INl01t>r<ATlON
!II>tlOSES ONLY AND SHOIILD NOT isZ COI(S~EIRED AS AN A'1Ttltll"P TO COLLECT
THE HED1:
(It yw leave lned yw corn stltl fie ~ Awe,)
HOW TO Ct7)<E YOIII l[OtTGAGt D TAIIL•T (Deilaae R as t• ~~
NATURE OF THB DEFAULT -Tke MORTtlAf3B debt y tke abvyp laadsr a yoen properq located b;
120 EA~RSON DRIVE, CARLISLE, PA 11013 IS SERIOUSLY IN DEFAULT bep~se:
A. YOU HAVE NOT MADE MONTHLY MOR'IGA(IE PAYA48NT8 fat tke followit6 aoatY and tke
followitS amoaaa are now pap deu:
05/01!07 tbn m101/t)7
Mia~m Paymeals pbes !pe ci+ar3e or otka fees:13E66.60
Miaia~n Aatetat t• Cave Detaalt:l3fif.6t1
B. YOII HAYS ):AQ.ED TO TAEZ THE 10LLOW1!(G ACTION (~ neR cue i[ cut pa~Yea,YMk 1~i/A
SAY TO CIIEtE DTH E~)RApLT -Yoe maT care Oe ddglt why THIRTY (30) DAYS dtle ate dtW
notice. DY lAYII'(GTHE TOTAL All[OIINT LAST D1UE TO TItID LENDEIt, RnQCH ~ 333f f#
PLUS ANY MORT(tAA(~ PAYMt3NTS AND LATE CHARt3B8 WHICH BECOMB DUB DURiNO THE
THIRTY (30) DAY PBRIOD ~w aent be Wade ebYer ~~ Wort zL--'a cl~ oerli~ clr~ ar moa~a
ardor made tetvable atd neat to• -
AMC Moeisaae Saviors
P.O. Boe< 3926
Carol Stream,lL 60197-3926
Yon pa care ~! otter defaHt b7' 1ddaE flee foBowita adi~ Wilkie THIRTY (30) DAYS d flee date d tW letter:
~ not ase if not appiicwbk) NIA
u z vv a+u rvz cva~ rns tN'JAULT-If you do net pro tM defadt wilkia THIRTY (30) DAYS dtke dpe
d Ois Nolioe, Tkis meaes tkst the eakere
otpaedieS balance dtbis deb will be ooesidaed dne iaffiedipel~ and Tan mq lone the cAaros b pe,T Oe
matiSsse is moat#ly . fflWi paTmeat dtbe taW aaimoat pap dee is not made wiWe THIItTY (30)
DAYS. Oa bade aba iatetds b bssl[ad ba attoreaTs b pact !anal ac8aa b
!!ll.~Z•
I1' THE MORTGAGE ~ CLOSED IIMN - Tbw aaat~ed prapsA,y will be sold by flea Ske~b pq aQ
ike morfA3e debt. N the leader rders Tote aue b its allaoeys, beat yon core ~ y bdara tls leader
bs~ias MEV pip asaisst yoe, 7a wHl pill be redaired b pq the raseeelsle dlooq's fen tkp were
actrally i.cmrad. ep b 130.00. However, if lean! proaeedia~r are stinted aSsiast 7~. Tor w~ bans to paT V
rasoaabia agoree~'s fees acWlly iecnrred bT the letda eve if tbay a:ooad 130.00. Aq allaraeT's ltla win be
added b the amoaat Ton ogre Oe !order, w4aiClt aaaT afro ieciade otka nttoeable naps, g nor see Ike dadrsk
OTHEt t.@iDEi IES - Tle !Gorda may aba ue you persoealfy for tke aaprid pe'scipal ba4eoe and aH
otter seams dne ender the mart~e.
sutaea i rv Guars T s arsswur.T nt STD 8HEJ1'/'S SAT ~ - IfTa I~rE ~ plOd 1k0 de6aM writ
Ike THIRTY (30) DAY period aed foredoseee proceediep ba-e beSae,
.~a~....._..L~-.~.~_~.-~-~--~_._ _. .. .~ -- -- - -
s.ruMraa..
~~L 7ev dstaa! L tie aunaer eat t~efi ie tick
attics wi seM~re pate esertpts b tie ease ~eifiea u it pw tad never ietaalted.
SST iND~L>S 8HSli1l'9 SALiE DATis - It is ecliecatad that the eastieat drte that sash a SheriB'e Ssk
of tie n~oAP6ed >!uP~!' codd be held world be appoaimt~ (6) MONTHS Eroa lie date oitlde Nbtioe. A
aotioe dtie acaalJpe of the Sheris"s Sak wi/ be seat b 7oa hotbse tie ads. Of ceases, tllc anoart needed to
cme the delriah wdfl t>,a loa8es ~ wait Yon ant sad oat ai ant tie e:asdt what tie segsind Paper
a aclioa will be bt oouaclies the leader.
HOW TO COPTACT THE LEND)EL•
A8!<C 11[eet8~e Soniea
PO llsr 118N
Santa Ana, CA (2711-1tIN
!teas ria~ N~43!-tS2f2
irar Nca•ier Tit-347-6S37
)c1fRCT O)r SHIClI11r'S S_wyt -Yon dwaW zalize that a State's Sale wID end pone owsaraiip attic
n~8~ PmPmh +rd yoar s3ait to ooatpt it. If ton coaeiae to live it the pc~sleslt idlat See SMeie's Sale, a
4wwit to remove 7~ and yorr i~paiahim8a and othsr bdoa~p Dodd 1M; sheted hT the Ia~1er al sat tine.
A88011Q1TOri 0>R ll[OlTGAGE -Yon _ nut ar Z rut net ((3iECg ONE) aaS at ttau/er poor home
to a bapar or tnac&de who wiH snare t4 nost~e dcM, ptavidsd tW a8 the ostetcn~diaS pepserb, ~ ad
atboay'e fen ad ooab are paid prior u ar at the ads and fief the otter regoi~u dthe saoetpSe ue rasased.
YOII ASAY ALSO HAVD TH)Z lit3HT
: TO SELL TH8 PROPERTY TO OBTAW MONEY TO PAY OFF THE MOR7'GAt18 DEBTOR TO
BORROW MONEY FROM ANOTHBR LSNDIIJG INSTITUTION TO PAY OFF THIS DBBT.
: TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
: TO HAVE THE MORTGAGE RESTORED TO THE BAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IP YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TD~S IN ANY CALENDAR YEAR)
: TO ASSERT TSE NONEXISTENCE OF A DEFAULT IN ANY Ft)itECdASURE PROCEEDWG OR ANY
OTHffit 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.
CO1fiSII11t3:! ClIEDTT COUNBEI.ING AGENCi1rS SElVII~iG YOII! COIINTY A!E
ATTACB3H
if you aced additional aWpaaoe or carasdipl tar nap alw sad a Hoaai•8 Caaaedia8 ABeaep ~ tsar ana bt
~ ToH$ee (800) 369-4287 or TDD (800) 877-8339.
AMC Marge Servioea
Cc: AMC Mort~c 3esvioa
Attn: Celledioaa Depattiaeat
Lana Namber: 0040631347
MaNei h let Clan Mail aai it Certised Mail
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
Adams County Inxerfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 334-1518
CCCS of Western PA
2000 I.inglestown Rosd
Harrisburg, PA 17102
I-888-511-2227
Community Action Commiasion of Captial Region
1514 Derry Street
Harrisburg, PA 17104
(71?) 232-9757
I.oveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
(717)232-2207
Maranatha
43 Phgadei Avenue
Waynesboro, PA 17268
(717)762-3285
PHFA
211 North Fromm St+~eet
Harrisburg, PA 17110
1-800-342-239"1
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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 SECURITIES INC., ASSET BACKED
PASS-THROUGH CERTIFICATES, SERIES 2003-
ARl UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003,
WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
Term
No. 07-5440
GOLDBECK, McCAFFERTY & McKEEVER
By Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION -LAW
ACTION OF MORTGAGE
FORECLOSURE
~ ~
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SHERIFF'S RETURN - NOT FOUND
CASE N0: 2007-05440 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MAXINE E ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
METZGER DONALD L but was
unable to locate Him in his bailiwick. He therefore returns the
!'~/'1T /1T1T T TT7T !uI/lDT L~(ID L~
the within named DEFENDANT
120 EMERSON DRIVE
METZGER DONALD L
NOT FOUND as to
CARLISLE, PA 17013
PER POST OFFICE, DEFENDANT MOVED AND
LEFT NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing 6.00
Service .00
Not Found 5.00
Surcharge 10.00
.00
I o/3 0~~0 ? ~w, 21.0 0
...
So answe -~' --
._.- _
~~~~~
r' _~
R. fihbma~ Kline
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
10/11/2007
Sworn and Subscribed to before
me this day of
A.D.
SHERIFF`S RETURN - NOT FOUND
CASE N0: 2007-05440 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MARINE E ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
METZGER MARINE E but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
NOT FOUND as to
the within named DEFENDANT METZGER MARINE E
120 EMERSON DRIVE
CARLISLE, PA 17013
PER POST OFFICE, DEFENDANT MOVED AND
LEFT NO FORWARDING ADDRESS.
Sheriff ' s Costs : So answ J~%~? --~'~
' 18 0 0 ~ ~`'~
Docketing ~-'`"` ~' -- " _ ~~
.. f ,.
Service 4.80 ~ ~-~--~
Not Found 5.00 R. Th as Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
~,,. j~'3a/o? 37.80 GOLDBECK MCCAFFERTY MCKEEVER
10/11/2007
Sworn and Subscribed to before
me this day 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-AR1
UNDER THE POOLING & SERVICING AGREEMENT DATED AS
OF JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
No. 07-5440
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT
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 MAXINE E. METZGER and DONALD L. METZGER by default for want
of an Answer.
Assess damages as follows:
$130,940.41
Debt
Interest from 12/12/2007 to Date of Sale
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED UNT ALLEGED TO BE DUE IN
THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPL INT.
1 certify that written notice of the intention to file this praecipe was mailed or delivered to the pa y agains whom. judgment is to be entered
and to his attorney of record, if any, after the default occurred and at least ten days prior to the d to of the iling'of this praecipe. A copy of
the notice is attached. R.C.P. 237.1
Joseph A. Goldbe r~
Attorney for Pl '
LD. #16132
AND NOW ~ , ~pZ X07 J dgment is entered in favor of
DEUTSCHE BANK NA V~AR'~, AS TR~TEEEI{TQII~ST~bR GAG SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & S RV ING AGREEMENT DATED
AS OF JANUARY 1, 2003, WITHOUT RECOURSE and against MAXINE E. METZGER and DON LD L. METZGER by default for
want of an Answer and damages assessed in the sum of $130,940.41 as per the above certification.
5 ~.
r thonotary
56442FC
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: November 27, 2007
TO:
MARINE E METZGER
112 Winchester GDNS
Carlisle, PA 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC.,
ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2003-ARl UNDER THE POOLING & SERVICING
AGREEMENT DATED A5 OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
vs.
MARINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
TO: MARINE E METZGER
112 Winchester GDNS
Carlisle, PA 17013
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION -LAW
Action of
Mortgage Foreclosure
Term
No. 07-5440
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOLJ 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 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES lNC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Joseph A. Goldbeck, Jr
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
56442FC
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: November 27, 2007
To:
DONALD L METZGER
112 Winchester GDNS
Carlisle, PA 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC.,
ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2003-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
TO: DONALD L METZGER
112 Winchester GDNS
Carlisle, PA 17013
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION -LAW
Action of
Mortgage Foreclosure
Term
No. 07-5440
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES 1NC
8 ]wine Row
Carlisle, PA 17013
717-243-9400
Joseph A. Goldbeck, Jr
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
56442FC
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: November 27, 2007
TO:
MARINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC.,
ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2003-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
vs.
MARINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
TO: MARINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION -LAW
Action of
Mortgage Foreclosure
Term
No. 07-5440
1MPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOLJ HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FII,E 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. ff 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.
CUMBF,RLAND C OUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Joseph A. Goldbeck, Jr
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
56442FC
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: November 27, 2007
TO:
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC.,
ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2003-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
TO: DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION -LAW
Action of
Mortgage Foreclosure
Term
No. 07-5440
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOLJ 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 COUN'11' BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 livine Row
Carlisle, PA 17013
717-243-9400
Joseph A. Goldbeck. Jr
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, MAXINE E METZGER, is
about unknown years of age, that Defendant's last known
residence is 112 Winchester GDNS, Carlisle, PA 17013, and is
engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldier; f
Congress of 1940 and its A
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, DONALD L METZGER, is
about unknown years of age, that Defendant's last known
residence is 112 Winchester GDNS, Carlisle, PA 17013, and is
engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldier: f
Congress of 1940 and its A
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-AR1
UNDER THE POOLING & SERVICING AGREEMENT
DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 07-5440
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET B ED PASS-THROUGH
CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & SERVI G GREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE, and against MAXINE E. ETZ Rand DONALD L.
METZGER for failure to file an Answer in the above action within (20) d ys (or ixty (60) days if defendant is
the United States of America) from the date of service of the Complaint, i the of $130,940.41.
Joseph A. G•
Attorney for
I hereby certify that the above names are correct and that the prec:
creditor is DEUTSCHE BANK NATIONAL TRU5T COMPANY, AS TI
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
UNDER THE POOLING & SERVICING AGREEMENT DATED AS O:
RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730
address(es) of the Defendant(s) is/are MAXINE E. METZGER, 120 Eme~
DONALD L. METZGER, 120 Emerson Drive Carlisle, PA 17013;
GOLDBECK'.
BY: Joseph A.
Attorney for P
ff
lenc address of the judgment
t/ OF AMERIQUEST
FIC TES, SERIES 2003-AR1
Y 1, 2003, WITHOUT
the nam s) and last known
ve Ca sle. PA 17013 and
& McKEEVER
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 04/01/2007 through
12/11/2007
Reasonable Attorney's Fee
Late Charges
Costs of Suit and Title Search
Escrow Payments Due 3 X $0.00
Escrow Advance
Fees
Recoverable Balance
$113,879.24
$7,219.04
$5,693.96
$453.36
$900.00
$0.00
$1,776.81
$87.00
$931.00
$130,940.41
GOLDBECK McC ~~& McKEEVER
BY: Joseph A. G b r.
Attorney for Pl iff
AND NOW, this F' da of ~~
~G1 Y IUQ.C'. 2007 damages are assessed as above.
~-e,s ~
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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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagors and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
No. 07-5440
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothonotary
BY: ~
Deputy
If you have any questions concerning the above, please contact: ~a/~~~ 7
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
PRAECII'E 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-AR1
UNDER THE POOLING & SERVICING AGREEMENT
DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
No. 07-5440
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
12/12/2007 to Date of
Sale at 8.9500%
(Costs to be added)
$130,940.41
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ALL that certain tract of land situate in South Middleton Township, Cumberland County,
Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Northern line of a proposed Thirty-six (36) feet wide
street to be known as Emerson Drive at the Southeastern corner of Lot of land now or
formerly of John Rowles and wife described in deed from Sylvester R. Snyder and wife
to John Rowles and wife dated June 21, 1963 and recorded in the hereinafter mentioned
Recorder's Office in Deed Book W, Vol. 20 page 656 thence from said point at the place
of beginning along line of said land now or formerly of John Rowles and wife, North 48
degrees 30 minutes East, a distance of One-Hundred Forty (140) feet to a point at corner
to land of said John Rowles and wife, land now or formerly of Lagrand S. Gleim and
wife and land now or formerly of Kenneth W. Greider and wife; thence along said line of
land now or formerly Kenneth W. Greider and wife, south 41 degrees 30 minutes East, a
distance of one Hundred Four (104) feet to a point; thence along line of land of Sylvester
R. Snyder and wife, South 48 degrees 30 minutes West, a distance of One Hundred Forty
(140) feet to a point on the Northern line of said proposed Thirty-six (36) feet wide street
to be known as Emerson Drive; thence along the Northern line of said Thirty-six (36) feet
wide street to be known as Emerson Drive; North 41 degrees 30 minutes West, a distance
of One Hundred Four (104) feet to a point; the place of BEGINNING.
Tax ID No.: 40-24-0746-010
~, A~'~
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney LD. #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-
AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003,
WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MARINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 07-5440
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-ARl UNDER THE POOLING
& SERVICING AGREEMENT DATED AS OF JANUARY I, 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:
120 Emerson Drive
Carlisle, PA 17013
l .Name and address of Owners} or Reputed Owner(s):
MARINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
MARINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
DONALD L. METZGER
120 Emerson Drive
.~'
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
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:
CITIFINANCIAL, INC.
1 VALLEY STREET
STE 103
CARLISLE, PA 17013
CITIFINANCIAL MORTGAGE CO. INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
ASSOCIATES FINANCIAL SERVICES INC.
1111 Northpoint Drive, Bldg 4, Ste. 100
Coppell, TX 75019-3931
SUMMIT MORTGAGE
555 HERNDON PARKWAY
STE 200
HERNDON, VA 20170-5291
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
120 Emerson Drive
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 b st of y person knowledge or information and
belief. I understand that false statements herein are made subject to the penalties of 18 a. C . Sectio 4904 relating to unsworn
falsification to authorities.
DATED: December 11.2007
GOLDBECK M TY & McKEEVER
BY: Joseph A. of e , Jr., Esq.
Attorney for P ~ ~
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~ 07-5440
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-ARl UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 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
MARINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendants
Term
No. 07-5440
THIS LAW FIRM I5 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: METZGER, MARINE E.
MARINE E METZGER
112 Winchester GDNS
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130,940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 1, 2003, WITHOUT RECOURSE against you.
NOTICE OF OWNER'S RIGHTS
r "
07-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution. is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVF, 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
07-5440
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.~ov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at 800-211-6926 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 56442FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
.-t
C'
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
07-5440
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2003-AR1 UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
Term
No. 07-5440
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: METZGER, DONALD L.
DONALD L METZGER
112 Winchester GDNS
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130,940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 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
~, .
._ .
0 %-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the 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 7l 7-240-6390.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
}`~
r
07-5440
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.~ov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at 800-211-6926 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(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 56442FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
.n
07-5440
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2003-AR1 UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
Term
No. 07-5440
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: METZGER, MAXINE E.
MAXINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130,940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 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
07-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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:
215-825-6329 or 1-866-413-2311
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 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
07-5440
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 800-211-6926 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 56442FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
07-5440
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2003-AR1 UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 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
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
Term
No. 07-5440
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: METZGER, DONALD L.
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130,940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 1, 2003, WITHOUT RECOURSE against you.
NOTICE OF OWNER'S RIGHTS
07-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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:
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.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
07-5440
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 800-211-6926 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 56442FC.
Para information en espanol puede communicarse con Loretta a1215-825-6344.
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-ARl UNDER THE
POOLING & SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E. METZGER
DONALD L. METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
NO. 07-5440
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the
action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has
the provisions of the Act. ~~
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF
MORTGAGE FORECLOSURE
Ff in this
with all
Joseph A. Go , Jr.
Attorney fo la' 'ff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-5440 Civil
CIVIL ACTION -LAW
TO TIDE 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-ARl UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF 01/01/03 WITHOUT RECOURSE, Plaintiff (s)
From MAXINE E. METZGER & DONALD L. METZGER
(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 $130,940.41
Interest from 12/12/07 to Date of Sale at 8.9500%
Atty's Comm
Atty Paid $285.40
Plaintiff Paid
Date: 12/12/07
(Seal)
L.L.$.50
Due Prothy $2.00
Other Costs
P othonotary
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR.
Address: GOLDBECK McCAFFERTY & McKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHL4, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-05440 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MAXINE E ET AL
WILLIAM CLINE Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
METZGER MAXINE E the
DEFENDANT at 1508:00 HOURS, on the 6th day of November 2007
at 120 EMERSON DRIVE
CARLISLE, PA 17013 by handing to
DONALD L METZGER ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
i~~o9~0? C~,,.,
18.00
4.80
.00
10.00
~ .00
So Answers:
s
32.80
Sworn and Subscibed to
before me this day
of ,
R. Thomas Kline
11/07/2007
GOLDBECK MCCAFFERTY MCKEEVER
By . ~~
Deputy Sheriff
A.D.
SHERIFF'S RETURN - REGULAR
~SE~ NO: 2007-05440 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MARINE E ET AL
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
METZGER DONALD L
DEFENDANT
the
at 1508:00 HOURS, on the 6th day of November 2007
at 120 EMERSON DRIVE
CARLISLE, PA 17013
DONALD L METZGER
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
Sworn and Subscibed to
before me this day
So Answers:
R. T omas Kline
11/07/2007
GOLDBECK MCCAFFERTY MCKEEVER
Deputy Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-05440 P Amended
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MAXINE E ET AL
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
METZGER MAXINE E
the
DEFENDANT at 1508:00 HOURS, on the 6th day of November 2007
at 112 WINCHESTER GARDENS
CARLISLE, PA 17013
by handing to
DONALD L METZGER
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Amended
Sheriff's Costs:
Docketing 18.00
Service 4.80
Affidavit .00
Surcharge 10.00
)?.~rOrO 7 00
3 2. 8 0
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
11/14/2007
GOLDBECK MCCAFFERTY MCKEEVER
By ~ ~~
Deputy Sheriff
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-05440 P Amended
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
METZGER MARINE E ET AL
WILLIAM CLINE Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
METZGER DONALD L the
DEFENDANT at 1508:00 HOURS, on the 6th day of November 2007
at 112 WINCHESTER GARDENS
CARLISLE, PA 17013 by handing to
DONALD L METZGER ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Amended
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
/ ~//% ~
6.00
.00
.00
10.00
.00
-~16.00
Sworn and Subscibed to
before me this
day
So Answers:
R. Thomas Kline
11/14/2007
GOLDBECK MCCAFFERTY MCKEEVER
By . s~/f~%~~~ ~~
Deputy Sheriff
of A.D.
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
56442FC
CF: 09/13/2007
SD: 06/11/2008
$130,940.41
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-
THROUGH CERTIFICATES, SERIES 2003-ARl
UNDER THE POOLING & SERVICING AGREEMENT
DATED AS OF JANUARY 1, 2003, WITHOUT
RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and
Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMUN YLI/A~
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 07-5440
CERTIFICATE OF SERVICE
PURSUANT TO Pa.RC.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:
p(j Personal Service by the Sheriffs Office%e~pet~t e~(copy of return attached).
( ) 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 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 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
Qttnrnpv fnr Plaintiff
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Deutsche Bank National Trust Company, In the Court of Common Pleas of
As Trustee of Ameriquest Mortgage Cumberland County, Pennsylvania
Securities Inc., Asset Baked Pass-Through Writ No. 2007-5440 Civil Term
Certificates, Series 2003-ARl Under the
Pooling & Servicing Agreement Dated as of
January 1, 2003, without recourse ~~ ~~~,,/~
~
'~~
~
Vs l
~0'T'T~~~
Maxine E. Metzger and Donald L. Metzger
Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on February
27, 2008 at 1250 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: Maxine E.
Metzger and Donald L. Metzger by making known unto Maxine E. Metzger personally and adult in
charge for Donald, at 112 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on Apri104,
2008 at 1425 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 Maxine E. Metzger and Donald L.
Metzger located at 120 Emerson Drive, 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: Maxine E.
Metzger and Donald L. Metzger by regular mail to their last known address of 112 Winchester
Gardens, Carlisle, PA 17013. This letter was mailed under the date of March 31, 2008 and never
returned to the Sheriffs Office.
So Answe
~_.~~`
R. Thomas Kline, Sheriff
(,
Real Estate rgeant
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-
ARl UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003,
WITHOUT RECOURSE
108016th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
bIAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 07-5440
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-ARl UNDER THE POOLING
& SERVICING AGREEMENT DATED AS OF JANUARY 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:
120 Emerson Drive
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
MAJ{INE E METZGER
112 Winchester GDNS
Carlisle, PA 17013
DONALD L METZGER
112 Winchester GDNS
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
MARINE E METZGER
112 Winchester GDNS
Carlisle, PA 17013
DONALD L METZGER
112 Winchester GDNS
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
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
ASSOCIATES FINANCIAL SERVICES INC.
1111 Northpoint Drive, Bldg 4, Ste. 100
Coppell, TX 75019-3931
CITIFINANCIAL, INC.
1 VALLEY STREET
STE 103
CARLISLE, PA 17013
CITIFINANCIAL MORTGAGE CO. INC.
111 I Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
SUMMIT MORTGAGE
555 HERNDON PARKWAY
STE 200
HERNDON, VA 20170-5291
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
120 Emerson Drive
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 Irnowledge 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: May 1, 2008
~'~c-~ s~_~e,9 ~ ~c~~~ n c 1 re~~
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
t l ;<a
- t~
-.-, ~~.?
-~, °rt
_a.~ '~
~ -
~'1
~e•f
+-4w
f,,,,) i i
... ~-~ x,y:f
(.;,,' '\
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which AMERIQUEST MTG SECURITIES INC TR is the grantee the same having
been sold to said grantee on the 11TH day of JUNE A.D., 2008, under and by virtue of a writ Execution
issued on the 12TH day of DEC, A.D., 2007, out of the Court of Common Pleas of said County as of
Civil Term, 2007 Number 5440, at the suit of AMERIOUEST MTG SECURITIES 1NC TR against
MAXINE E METZGER & DONALD L is duly recorded as Instrument Number 200820743.
IN TESTIMONY WHEREOF, I have her unto set my hand
and al of said office this C~ day of
A.D. --C~-~ ~
Fl~oo~dpr of Dssds, Cumbo~nd County Carfi~, PA
My Canrn~ion Expira~ tt~e Fleet Monday of Jm. X10
Deutsche Bank National Trust Company, In the Court of Common Pleas of
As Trustee of Ameriquest Mortgage Cumberland County, Pennsylvania
Securities Inc., Asset Baked Pass-Through Writ No. 2007-5440 Civil Term
Certificates, Series 2003-AR1 Under the
Pooling & Servicing Agreement Dated as of
January 1, 2003, without recourse
Vs
Maxine E. Metzger and Donald L. Metzger
Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on February
27, 2008 at 1250 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: Maxine E.
Metzger and Donald L. Metzger by making known unto Maxine E. Metzger personally and adult in
charge for Donald, at 112 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on Apri104,
2008 at 1425 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 Maxine E. Metzger and Donald L.
Metzger located at 120 Emerson Drive, 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: Maxine E.
Metzger and Donald L. Metzger by regular mail to their last known address of 112 Winchester
Gazdens, Carlisle, PA 17013. This letter was mailed under the date of Mazch 31, 2008 and never
returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and
legal notice had been given according to law, he exposed the within described premises at public
venue or outcry at the Courthouse, Cazlisle, Cumberland County, Pennsylvania on June 11, 2008 at
10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on behalf
of Deutsche Bank National Trust Company, as Trustee, in Trust for the Registered Holders of
Ameriquest Mortgage Securities Inc., Asset-Backed Pass-Through Certificates, Series 2003-AR1. It
being the highest bid and best price received for the same, Deutsche Bank National Trust Company,
as Trustee, in Trust for the Registered Holders of Ameriquest Mortgage Securities Inc., Asset-
Backed Pass-Through Certificates, Series 2003-AR1 of 10801 6th Street, Suite 130, Rancho
Cucamonga, CA 91730, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum
of $1,001.13.
Sheriffls Costs:
Docketing 30.00
Poundage 19.63
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Mileage 9.60
Levy 15.00
Surchazge 30.00
Law Journal 355.00
Patriot News 372.17
Shaze of bills 14.73
Distribution of proceeds 25.00
Sheriff s deed 39.50
$1,001.13
So Answers:
r~~
R. Thomas Kline, Sheriff
BY ~ d
Real Estate Se eant
/ t~~~s~6 P ~"``
u~
~Ig ~.° ~-° ti-
a ~ sJ ~
~ ~ y.~~~
1~o~P7
~ Goldbeck 1V~cCafferty & McKeever
LY: Jo~~~ph A. Goldbeck, Jr.
Attortifey LD. #16132
' Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, A5 TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED
PASS-THROUGH CERTIFICATES, SERIES 2003-
AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 1, 2003,
WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
vs.
MAXINE E. METZGER
DONALD L. METZGER
(Mortgagor(s) and Record Owner(s))
120 Emerson Drive
Carlisle, PA 17013
Plaintiff
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 07-5440
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR1 UNDER THE POOLING
& SERVICING AGREEMENT DATED AS OF JANUARY 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:
120 Emerson Drive
Carlisle, PA 17013
I .Name and address of Owner(s) or Reputed Owner(s):
MAXINE E. METZGER
120 Emerson Drive
Carlisle, PA ] 7013
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
MAXINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
CNIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
DONALD L. METZGER
120 Emerson Drive
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
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:
CITIFINANCIAL, INC.
1 VALLEY STREET
STE 103
CARLISLE, PA 17013
CITIFINANCIAL MORTGAGE CO. INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
ASSOCIATES FINANCIAL SERVICES INC.
1111 Northpoint Drive, Sldg 4, Ste. 100
Coppell, TX 75019-3931
SUMMIT MORTGAGE
555 HERNDON PARKWAY
STE 200
HERNDON, VA 20170-5291
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.
TENANTSlOCCUPANTS
] 20 Emerson Drive
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 b st of y person knowledge or information and
belief. I understand that false statements herein are made subject to the penalties of 18 a. C . Sectio 4904 relating to unsworn
falsification to authorities.
DATED: December 11. 2007
GOLDBECK M TY & McKEEVER
BY: Joseph A. of e , Jr., Esq.
Attorney for P ~ ~
07-5440
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
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-AR1 UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendants
Term
No. 07-5440
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: METZGER, DONALD L.
DONALD L. METZGER
120 Emerson Drive
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130;940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-ARl UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 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
07-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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:
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be. receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
' 07-5440
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 800-211-6926 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 56442FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
~, .
07-5440
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2003-ARl UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
JANUARY 1, 2003, WITHOUT RECOURSE
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
Plaintiff
vs.
MAXINE E METZGER
DONALD L METZGER
Mortgagor(s) and Record Owner(s)
120 Emerson Drive
Carlisle, PA 17013
Defendants
Term
No. 07-5440
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: METZGER, MAXINE E.
MAXINE E. METZGER
120 Emerson Drive
Carlisle, PA 17013
Your house at 120 Emerson Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $130,940.41 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-ARl UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF JANUARY 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
07-5440
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-AR1 UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF JANUARY 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:
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your House. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
07-5440
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.~ov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at 800-211-6926 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 56442FC.
Para information en espanol puede communicarse con Loretta al 215-825-6344.
ALL that certain tract of land situate in South Middleton Township, Cumberland County,
Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Northern line of a proposed Thirty-six (36) feet wide
street to be known as Emerson Drive at the Southeastern corner of Lot of land now or
formerly of John Rowles and wife described in deed from Sylvester R. Snyder and wife
to John Rowles and wife dated June 21, 1963 and recorded in the hereinafter mentioned
Recorder's Office in Deed Book W, Vol. 20 page 656 thence from said point at the place
of beginning along line of said land now or formerly of John Rowles and wife, North 48
degrees 30 minutes East, a distance of One-Hundred Forty (140) feet to a point at corner
to land of said John Rowles and wife, land now or formerly of Lagrand S. Gleim and
wife and land now or formerly of Kenneth W. Greider and wife; thence along said line of
land now or formerly Kenneth W. Greider and wife, south 41 degrees 30 minutes East, a
distance of one Hundred Four (104) feet to a point; thence along line of land of Sylvester
R. Snyder and. wife, South 48 degrees 30 minutes West, a distance of One Hundred Forty
(140) feet to a point on the Northern line of said proposed Thirty-six (36) feet wide street
to be known as Emerson Drive; thence along the Northern line of said Thirty-six (36) feet
wide street to be known as Emerson Drive; North 41 degrees 30 minutes West, a distance
of One Hundred Four (104) feet to a point; the place of BEGINNING.
Tax ID No.: 40-24-0746-010
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-5440 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-ARl UNDER THE POOLING & SERVICING
AGREEMENT DATED AS OF 01/01/03 WITHOUT RECOURSE, Plaintiff (s)
From MAXINE E. METZGER & DONALD L. METZGER
(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 $130,940.41
Interest from 12/12/07 to Date of Sale at 8.9500%
Atty's Comm
Atty Paid $285.40
Plaintiff Paid
Date: 12/12/07
L.L.$.50
Due Prothy $2.00
Other Costs
Pr thonotary
By:
(Seal)
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR.
Address: GOLDBECK McCAFFERTY & McKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 16
On February 15, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA
Known and numbered as 120 Emerson Drive, Carlisle,
more fully described on Exhibit A
filed with this writ and by this reference
incorporated herein.
Date: February 15, 2008 By: f ~ - .~ .~
Real Estate ergeant
. ~ ~:
.The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
the ~ahiot Netus
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:
... .. ~~~~.~~~..V .............
Sworn to a d s cribed before me this 27 day of May, 2008 A.D.
Notary
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Chyrle L. Sheppard, Notary Public
City OI Hasrisbutp, Dauprii~ County
My Commission Expires May 29, 2010
Member, Pennsylvania Association of Notaries
04/23/08
04/30108
05/07108
Real Estate Sale #16
Writ No. 2007-5440 Civil Term
Deutsche Bank National Trust
Company, as Trustee of
Ameriquest Mortgage Securities
Inc., Asset Backed Pass-
Through Certificates Series
2003-AR1 Under the Pooling &
Servicing Agreement dated as
of Ot-01-03 without Recourse
VS
Maxine E. Metzger and Donald
L. Metzger
Attorney: Joseph Goldbeck
DESCRIPTION
ALL that certain tract of land situate in South
Middleton Township, Cumberland County,
Pennsylvania, bounded and described as
follows:
BEGINNING at a point on the Northem line of
a proposed Thirty-six (36) feet wide street to be
known as Emerson Drive at the Southeastern
comer of Lot of land now or formerly of John
Rowles and wife described in deed from
Sylvester R. Snyder and wife to John Rowles
and wife dated June 2L 1963 and recorded in
the hereinafter mentioned Recorder's Office in
Deed Book W, Vol. 20 page b56 thence from
said point at the place of beginning along Gee of
said land now or formerly of John Rowles and
wife, North 48 degrees 30 minutes East, a
distance of One-Hundred Eorty (140) feet to a
point at corner to ]and of said ]ohn Rowles and
wife, land now or formerly of Lagrand S. Gleim
and wife and Land now or formerly of Kenneth
W. Greider and wife; thence along said line of
land now or formerly Kenneth W. Greider and
wife, south 41 degrees 30 minutes East, a
distance of one Hundred Four (104) feet to a
point; thence along line of land of Sylvester R.
Snvder and wife, South 48 degrees 30 minutes
West. a distance of One Hundred Eorty (140)
feet to a point on the Northem line of said
proposed Thirty-six (36) feet wide street to be
known as Emerson Drive; thence along the
::orthem line of said Thirty-six (36) feet wide
street to be known as Emerson Drive; North 41
degrees 30 minutes West, a distance of One
Hundred Four (104) feet to a point; the place of
BEGINNING.
Tax 1D No.: 40-24-0746-010
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:
May 2, May 9, and May 16, 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.
~--=
iG. ~~
isa Marie Coyne, itor
SWORN TO AND SUBSCRIBED before me this
6 day of May. 2008
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 20T 0
int. ilrtass was ~. u
Writ No. 2007-5440 Civil
Deutsche Bank National Trust
Company, as Trustee of Ameriquest
Mortgage Securities Inc., Asset
Backed Pass-Through Certificates
Series 2003-AR1 Under the Pooling
8a Servicing Agreement dated as of
01-01-03 without Recourse
vs.
Maxine E. Metzger and
Donald L. Metzger
Atty.: Joseph Goldbeck
ALL that certain tract of land situ-
ate in South Middleton Township,
Cumberland County, Pennsylvania,
bounded and described as follows:
BEGINNING at a point on the
Northern line of aproposedThirty-six
(36) feet wide street to be known as
Emerson Drive at the Southeastern
corner of Lot of land now or formerly
of John Rowles and wife described in
deed from Sylvester R. Snyder and
wife to John Rowles and wife dated
June 21, 1963 and recorded in the
hereinafter mentioned Recorder's Of-
fice in Deed Book W, Vol. 20 page 656
thence from said point at the place of
b al,~sg line of said land now
or ' of Jotsn Rowka and wife,
Nort#- 48 de~rdea 30 minutes East, a
distance ~' One-Hundred Forty (14oJ
feat to a post at corner to lane! of said
Jahn Rowiea and wife, lead now ar
formerly of Lagrand S. Gleim and wife
and land now or formerly of Kenneth
W. Greider and wife; thence along
said line of land now or formerly Ken-
neth W. Greider and wife, south 41
degrees 30 minutes East, a distance
of one Hundred Four (104) feet to a
point; thence along line of land of Syl-
vester R. Snyder and wife, South 48
degrees 30 minutes West, a distance
of One Hundred Forty (140) feet to
a point on the Northern line of said
proposed Thirty-six (36) feet wide
street to be known as Emerson Drive;
thence along the Northern line of said
Thirty-six (36) feet wide street to be
known as Emerson Drive; North 41
degrees 30 minutes West, a distance
of One Hundred Four { 104) feet to a
point; the place of BEGINNING.
Tax ID No.: 40-24-0746-010.
Assignment of Bid
NO. 07-5440 - METZGER
120 Emerson Drive
Carlisle, PA 17013
I, Michael T. McKeever, Esquire, as attorney for the successful bidder, hereby assign
my bid at the Sheriff Sale dated June 11, 2008 to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE, IN TRUST FOR
THE REGISTERED HOLDERS OF AMERIQUEST MORTGAGE SECURITIES INC.,
ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-ARl
10801 6th Street
Suite 130
Rancho Cucamonga, CA 91730
GOLDBECK MCCAFFERTY & MCKEEVER
Date: June 16, 2008
_'~~~~
MICHAEL T. MCKEEVER