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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 ~ws.n-. _ # _' O d c ap GO c ~ ~, r r . ~ ~ ~ -~ -~ s ~ ~ ~ ~ ~ ~~ ~~' ~ ~ .. 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 ~ ~ - ~ ~ rt ~~ ro O N `l~ ~ ( ~ t : k .~ ? '~ ` ~ ~ ~ ' ~ ~ ~~ ^' :.G ~ ~ _ 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 ~ r Prothy "~ C`~3 r-- ~ ~. _ , 1/'~ ~ v 7 55 _d 4 b _.. ,- ~,~ ward `- ~~ ~'~ ~~ Y;..v ;~. 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 ~ ~, vi C7 W d ~^~~Uo ~ ~~~wo a p`w"Wa3 O `~C7~aZv' ~s, ~F-~~Od~ u ~O Q~Fx-~~0~ Z~ Q~;a,wQ0 x o zwQ Q~ ~ x~H3 ~a U¢~ H wohow ~ UW~~~ ~. h-~ ~~Qw¢ Q ~ Z ~ z 0 ~ ~ + ~ O 4! M ~ N `d 'i. 0 W ~" N~ 0~1~ w~rx ~d v O ~ ° ~ ~ u ,, ~ ~ fW Q ^w~ ~' a z ~°~; ° o~ ~ n ~ ~ ~ ~ ~ w ,. d a ~ "' O o~0 6~ ~ j ~ ~ ~ J ~ „ O ~ g ~ ~, U-~ ppO ~OOpO0 ~ O O -0 (}~. ~ (~ n a O ~. --~ .~ U N b 0 C7 d ti ~. ~~ ~v U u _ O 'C3 r" ~" N _~1 y ~ ~ N `il ., N wax ~~ ~ ~ ~ a, ,~, ~ ~ _ a~ .-~ O ~ ~ ~~ ~o a ~° ~7 3 _"•a ~.~ ',,r 1 e r.~~ ~ ~~: .. ,y~X.-~~• _:7 may r ~,, l~ ,~~ ' f ti: y y ~~s 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 ~ ~ _. r-a ~ C ~ ,_..., ~ ---a t ~ ` ~ ~ ~~ . ' N i i ..-~ i i'i ~:j ~ •-- ~ c: w ~ 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 o ^m 00 o r. ~ ~ ~~N~ ~ ' ~ ~ '~~ ~~ ,F~ ~ ~ ~ c ,.,~ .. •~ r ~~~ ,. ~ _ ~N Q ~ r V r per,- _ N p +~AM[t O a ~.r ~~ V b g o = U ~w~~~ ~~ ffi ~g x~5 ~d ¢~ b'S a~ a ffi G~ ~ O g d ~ w ~d A w z ~ .n ~ ~ m~ ~ E ~~~ ° a ~ ,,., o $ w w a g~ Q m O aW "- ~ m N' ¢ ~ ~ m ¢_ w U ~ a w~ ~ N d ~ ~° a ~ ~ z ' ~ ~r , ~ Zw ~° ~~ d' Z ~a ~ c n .. ° ~~ ~ ~ •~ w N Z W Z ~~ ~ H ~ ~ Z ~ U V O w. F-- ~a ° Q C } ~ ~z ~'~ z t/~ 0 m a 0000 g~m = ooo~ a ~~ . a~c4l .~ ,~~ ~o ~> ~ a ~ upi ~$ a ~_ ~ zw ° U UUdU ~f~Sa. T Ur ~ U Ur U ~ Q aid V i ~ ~c '~Q 3 z ~ z ~~ ~a m ` °' ~ ~ ~~ _ ~~ ' F- o. W~~~~tf c•- ~ ~~ m a mQW QC~ EJ~'~..Jo ~ z$ ~o~ ;_~, ~~~~.~ ~ N M ~ ~ ~ ~ ~ ~~ c m d C a N a 0 z r r m m Tv C 4~ V C c4 U c~ u, w N h- lll J o!S w N t1J w z 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