HomeMy WebLinkAbout04-1142
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
IN THE COURT OF COMMON PLEAS
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO
NOVEMBER I, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Term
No. 04 -11"1 ^'
C/~l{
----
'~
vs.
CRICKET M. KRICK
HARRY O. KRICK JR.
Mortgagor(s) and Real Owner(s)
CIVIL ACTION: MORTGAGE
FO/l!!:CL08URE
115 S. George Street
Mechanicsburg, P A 17055
Defendant(s)
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice
are served, by entering a written appearance personally or by attomey and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint offor 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 00 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
SlrvineRow
Cllrlisle,PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
A..Y.il..Q
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENT ADAS, ES ABSOLUT AMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE20 mAS DESPUES DE SER SERVIOO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU
ABOGADO. REG ISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USlED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: 51 USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE,
SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA 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 LLEV AR ESTE PAPEL A SU ABOGAOO ENSEGUIDA. SI USTED NO IlENE UN ABOGADO, VA Y A 0 LLAME POR TELCFONO LA OFICINA FIJADA
AQui ABAJO. ESTA OFICINA PUEDE PROVEERC CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE P AGARLE A UN ABOGADO, CST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARia REDUClOO 0 GRATIS.
LEGAL SERVICES INC
S Irvine Row
Carlisle,PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiffi's DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002~4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER I,
2002, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868.
2. The name(s) and addressees) of the Defendant(s) is/are CRICKET M. KRICK, lIS S. George Street,
Mechanicsburg, PA 17055 and HARRY O. KRICK JR., 115 S. George Street, Mechanicsburg, PA
17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described.
3. On August 28, 2002 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book 1776 Page 0982. The mortgage has not
been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned
mortgage was assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF
AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT
DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE by Assignment of Mortgage, which
Assignment is being lodged for recording. These documents are matters of public record and are
incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due
November 01, 2003, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 10/01/2003
through 03/31/2004 at 7.7500%
Per Diem interest rate at $17.41
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 11/01/2003 to 03/31/2004
Monthly late charge amount at $35.08
Costs of suit and Title Search
$80,883.72
$3,186.03
$4,044.19
$175.39
Escrow
Fees
NSF Charges
Monthly Escrow amount $142.81
$900.00
$89,189.33
+$385.13
+$106.00
+$25.00
$89,705.46
7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania
law, and, will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is
reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually
performed.
8. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant(s) 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 "A". The Defendant(s) has/have not had the required face-to-face meeting
within the required time and Plaintiff has no knowledge of any such meeting being requested by the
Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate
Consumer Credit Counseling Agency.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $89,705.46,
together with interest at the rate of $1 7.41, per day and other expenses incurred by the Plaintiff which are
properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the
mortgaged premises.
By:
n~\nrf, Q j J/\
\ot~i~~(r~~CAFFERTY & MCKEEVER"\::; r;f\
By: JOSEPH A. GOLDBECK, JR., ESQUIRE
A lTORNEY FOR PLAINTIFF
VERIFICATION
I, Stephen C. Whitaker, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. CoSo 4904 relating to unsworn falsification to authorities.
Date: 3-II-iJi
St 'taker
AMERIQUEST MORTGAGE COMPANY
, '.
COMMITMENT
SCHEDULE C
File Number: 02.462KS
ALL that certain triangular lot of ground situate on the East side of George Street in the Borough of
Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as
follows, to wit:
BEGINNING at a point on the Eastern line of said George Street marked by a Monument corner of
lands of the United States of America; thence in a Northerly direction along the Eastern line of said
George Street 63.5 feet to a point at comer of Lot No. II on the hereinafter mentioned Plan of Lots;
thence in an Easterly direction along the line of said Lot No. 11, 310 feet, more or less, to an iron pin at
a corner of lands now or formerly of May Sultzberger and others; thence in a Westerly direction along
lands ofthe United States of America, 314.46 feet to a point on the Eastern line of said George Street
and at the Place of Beginning.
BEING lot numbered 12 on a Plan of Lots known as Green Acres, which Plan is recorded in the
Recorder's Office in and for said Cumberland County, Plan Book 4 at Page 4.
BEING the same premises which Miriam Burdge Krick, by Deed dated 04/07/99 and recorded 04121/99
in Cumberland County Record Book 197, Page 942, granted and conveyed unto Harry O. Krick, Jr. and
Cricket M. Krick, husband and wife; and Owen Orville Krick, unmarried, in fee.
SEE ATTACHED COURT ORDER GRANTING HARRY O. KRICK, JR. AND CRICKET M.
KRICK AUTHORITY TO MORTGAGE THE INTEREST THAT OWEN ORVILLE KRICK,
MINOR CHILD, HAS IN THE ABOVE REFERENCED PROPERTY.
Parcel No: 20-24-0785-119
BK t 776PG0998
P.O. Do. 11"0
Su.. AD.. CA 9Z711-1010
)1l
~l~~~I'
7182 6389 3060 0342 6549
January 05, 2004
HARRY 0 KRICK JR
CRICKET M KRICK
115 S GEORGE ST
MECHANICSBURG, PA 17055
1110 I OlMC
EXI-'UBIT A
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME
FROM FORECLOSURE
STATl:MENTS OJ'POLICY
Loan Number:
Property Address:
0rigiDal Leoder:
CwrCDI Lender/Servicer:
0038442547
115 S GEORGE STREET, MECHANICSBURG PA, 17055
Ameriques! Morl8llgc Company
AmeriquCSl Mortgage Company
THIS J'lRM IS A DEBT COLLECTOR A 1TJ:MPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN A'lTJ:MPT TO COLLECT TIU: INDEBTl:DNJ:SS REJ'EIUU:D TO
HEREIN AND ANY INJ'ORMATION OBTAINJ:D J'ROMYOU WILL BE USED I'OR THAT
PURPOSE. or YOU HAVE PREVIOUSLY RECEIVJ:D A DISCHARGE IN BANKRUPTCY, THIS
COIUU:SPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTDIPT TO
COLLECT A DEBT, BUT ONLY ENJi'ORCEMENT OJ' A LD:N AGAINST PROPJ:RTY.
Till. I. u oIIIdll1 .otice tIIat tile ..ortaa.. oa Toor h_e I. Ia default. ud tile leader Ialead. to foreelooe.
S....1fie Iaf_a1I01l ......t the .ature of tile defauh I. DrovIded Ia t1Ie attaehed D.....
TIle HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM an:MAP) ..ay he ahle to hiD to 11ft y...r
ho.... TIll. Nodee eQlaI.. how tlte Dro...... ...0......
To _ if REMAP c.. .eID. T'" ...at MEET WITH A CONSUMJ:R CRJ:DIT COUNSELING AGENCY
WITHIN 30 DAYS OJ' TIU: DATI: Oil' THIS NOTICE. Take till. Nodee with YOU ...... y.....eet with the
Con...I.. A.scY.
The ...... addre.. ud Dho.e amber of Coo.....er Credit C.......I.. A_cleo oenl.. y...r Coo.ty are
lilted at tile cad of tllla Nodce. If y.. have ..y aaeotloa.. YOO ..ay cll11 tile Pe..sylTula Hoool.. J'lauee
AaeacY toll free at 1-l1OO-U2-2397./Penoa. with IaoDalred .earla.... call (717) 780-18").
TIll. Notlee eoatalu I..portaat Iepllaformatlo.. If "... .aft u" quettloa.. rep_taII.... at tlte Co.....er
Credit C.......inS Aaeae:r ..a" be aiJle to .eIp uplala it. You ..a" aI.. .....t to cootact u _racy Ia your
areL T.e loeaIllar _Ialloo ...,. be a11le to .e1p "OIl n.d a lawyer.
LA NOTIJ'ICACION EN AD.I1JNTO ES DE SUMA IMPORTANCIA, PUES ARCTA SU DERECHO A
CONTINUAR VIVD:NDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIJ'ICACION OBTl:NGA UNA TRADUCCION INMJ:DITAMJ:NTE LLAMANDO ESTAAGENCIA
(pENNSYLVANIA HOUSING J'lNANCE AGENCY) SIN CARGOS AL NUMJ:RO MENCIONADO
_11N1Ne~"..
AJUmiA. PUEDES SER ELEGIBLE PAllA UN PIlJ:STAMO POR EL PROGIlAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SALV AB SU CASA DE LA PERDmA DEL DERECBO A REDIMIR SU HIPOTECA.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE JIOR J'INANCIAL ASSISTANCE
WHICH CAN SA VI: YOUR HOME PROM I'ORECLOSUJU: AND
HELP YOU MAKE J'UTURE MORTGAGE PAYMENTS
III YOU COMPLY WITH THE PROVISIONS 01' THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT 01' 1.,.3 (THE "ACT"), YOU MAY BE ELIGIBLE I'OR EMERGENCY MORTGAGE
ASSISTANCJ:,
. III YOUR DEI'AUL T HAS BJ:EN CAUSJ:D BY CIRCUMSTANCJ:S BEYOND YOUR CONTROL,
. III YOU HA VI: A REASONABLE PROSPECT 01' BJ:ING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
. III YOU MEET OTHER ELIGIBILITY REQunu:MENTS J:STABLISBJ:D BY THE
PENNSYLVANIA HOUSING J'INANCE AGENCY.
TEMPORARY STAY OI'I'ORECLOSUJU: - UDde:rthe Act, yon are entided to a temporary stay offo_I08DlC
on yonr mortgage for thirty (30) days from the date of this Noti"", Daring that time yon mast arrange and attend a
fa",,-to-face meeting with one of the consnmer cIcdit counseling agencies listed at the eDd of this Notice. THIS
MEETING MUST OCClJR WITBIN THE NJ:XT (30) DAYS, IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE, TIlE PART OF THIS
NOTICE CALLED 'HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE,
CONSUMER CREDIT COUNSELING AGENCIES --If yon meet with one of the conanmer credit counseling
aacncv listed at the CIld of this noti"". the lender mav NOT take action aaainst yon for thirtv (30) daYS after the date
of this meeting. The names. addressca and telephone namben of desipated consnmer credit connseling IIIICIlcies for
the connIY in which the prOPCrtv is located BrCI set forth at the CIld of this Noti"", It is only necessary to schcdnle one
fa""-1<>-face meeting. Advise yonr leader immediatelv ofyonr intentions.
APPLICATION I'OR MORTGAGE ASSISTANCE - Yonr mortgage is in a defanlt for the reasons set forth later
in this Noli"" (see following pages for specific information aboot the naInrc of your dcfanlt,) If yon have tried and
arc nnable to resolve this problem with the ICIlder, yon have the right to apply for financial aaaislancc from the
Homeowner's Emergency Mortgage Assistance ProgJlllIl To do so, yon mast fill on!. sip and file a completed
HomeowncTs Emergency Assistance Program Application with one of the designated consumer credit counseling
ageDCiesIistcclat the eDd of this Notice, Only consnmer credit connseling agCllcies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency,
Your application MUST be filed or postmarked within thirty (30) days ofyonr face-to-face meeting.
YOU MUST I'ILE YOUR APPLICATION PROMPTLY. III YOU I'AIL TO DO SO OR III YOU DO NOT
I'OLLOW THE OTHER TIME PERIODS SJ:T JIORTH IN THIS LETTEIl, JIORECLOSUJU: MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION JIOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGJ:NCY ACTION - Available funds for emergency mortgage assistance are very limited. They win be di&burscd
by the Ascncy under the elill'lrility criteria established by the Act The PcnnsyIvania Honsing Finance AgCllcy has
sixty (60) days to make a decision after it receives yonr application. During that time, no foreclosure proceedings
will be pursued against yon if yon have met the time requirements set forth above. Yon will be notified directly by
the Pennsylvania Housing Finan"" Agency of ita decision on yonr application,
,.......enlr<<:.IJ'.OI
llU111l1Ij O~, 2004
Loan Number: 0038442547
NOTE: III YOU AJU: CURIU:NTLY PROTECfED BY TBJ: F'lLING Oil' A PETITION IN
BANKIlUPTCY. THE II'OLLOWING PAllT Oil' THIS NOTICE IS II'OIl INIIORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSmEIU:D AS AN ATTEMPT TO COLLECT
THE DEBT.
(H y... loa.... liled b...kruptey y... .... IdD apply for Eme....,. Mort.a.. Auista....)
HOW TO CUIU: YOUll MORTGAGE DEII'AUL T /Bria. it aD to date).
NATURE OF THE DEFAULT -ne MORTGAGE debt bytbe above lender onyODI property loctcd at:
81115 S GEORGE STREET, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT becan..:
A, YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
foDowing amOUDts are now past cine:
11/01/03 thru 01/01104 at 5727.42 pcr month
Monthly Payments plaslate charge or other fees: 52300,00
Total Am....t to Care Default: 52300.00
B. YOU BA VI: II'AILED TO TAKE TBJ: II'OLLOWING ACTION (Do aot nle if aot UDlicable): N/A
HOW TO ClJIlI: THE DEII'AULT--Yon may cure thedcfau1t within THIRTY (30) DAYS of the date of this
notice BY PAYING TBJ: TOTAL AMOUNT PAST DUJ: TO TBJ: LENDEIl, WHICH IS 52300.00
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE
THIRTY (30) DAY PERIOD. Payments mast be made either by cash. caabier's cbeet. certified chcct or moncv
order made lIIyable and scnt to:
Amcriqnest Mortgage Compaoy
505 City Partway We'" Suite *100
Orange, CA 92868-2912
Yon can cure any other dcliwlt by taking the following actioD within THIRTY (30) DAYS of the date ofthislcttcr:
(Do not use if not apolicable,) NI A
III YOU DO NOT cmu: THE DEII'AULT-Ifyon do not cure the defan1t within THIRTY (30) DAYS oftbe date
of this Notice, the leader mlead. to Derelseil. ripts to a<<eIente tile ..ortD. debt. This means that the entire
onl...ndi~g baIaoce of this debt wiD be considered due immediately and yon may lose the chance to pay the
mortgage in monthly insta1lmcnts. If full payment oflbe tota1l111101111l past dne is not made within THIRTY (30)
DAYS, the lender also intends to insIrnct its attorneys to start legal action to foreclose a_ TOIlr ..ort1l....d
Drooem.
III THE MORTGAGE IS II'OIU:CLOSED UPON - no mortgaged property will be sold by the Shcriffto pay off
the DIOrtsagc debt. If tho Icndcr refers your case to its attorneys, bnt yon cure the dclinqUOllcy before tho lender
begins legal prococdiogs opinat you, you will still be required to pay the rcasooablo attomcy's fees that wore
actua1ly incurred, up to 550.00. Howcw:r, iflcgal proceedings are started against you, you wiD havo to pay aU
rcasooablo attorney'. fees actually incurred by tho 1000dor ...,u if they exceed 550,00, ilJ1y attorney's foos will be
added to the amount you owe tholCllclcr, which may also include other rcasooablo costs. If Y'" eare tile default
withia tile TBIllTY (30) DAY period, yea will .ot ho reqaired to p.y _...y'. feeL
OTHER LENDER ~MJ:Dn:S - nolenclor may also sue you porsooally for tho unpaid priucipal ba18DCC and aU
other sums duo undor the mortgage,
RIGHT TO cmu: THE DEII'AULT PJlIOR TO SHEJUFIl"S SALE - If you ha... not cured tho defan1t within
the THIRTY (30) DAY period andforec1oourc p""""""i"ll" have begun, you..i11 ""... th'rlrhf to con: tho d.r.ult
and prevent the salo 81 any time up to oue hour before the Sheriff's Sale. You may do so by paving the total amount
then put due, ploa any late or other charges then due, reasooablo attorney's foos and costs cOllllOCtcd with tho
foreclosure salo and any other cOBls colUlCctcd with the Sheriff's Sale as specified in writina by Ibe IoDdcr and by
~"'ACTWf<<:I'''-02
perfo~ any other requirements ander the mortgqe, Curial your default ill the ....aer llet fortb ill thi.
aotice ..ill relltore your mortpp to the .....e pOlinoa .. if you bd aever defaulted.
EARLIEST POSSIBLE SIIERIJ""S SALE DATE --It is ellimatcd tbat the earliest date tbat SIlCb a Sberift's Sale
oflbe mortppd property coald be held would be approximately (6) MONTHS from Ibe date oftbis Notice. A
uoticc of the achuII date of Ibe Sberift's Sale will be sent to you before Ibe sale, Of coarse, the amont Deeded to
care the default will iIlcrcase the Ioager you wait. You may fiDd out at any time exactly what Ibe required paYmeJlt
or ac1iou will be by coutactiag Ibe leader,
HOW TO CONTACT TIlE LENDER:
Ameriquest Morta.... C_p..y
PO Bos 11000
Or..... CA 92711-1000
PIt..... Namber 800-430-5262
Fa>: Number 714-347-5037
EJlFJ:CT OF SIIERIn"S SALE - You shoaId realize tbata Sberift's Sale will eDd yoar ownership of the
mortgaged property and yoar right to occupy it, If you coDtinae to live ill the property after Ibe Sberift'. Sale, a
lawsuit to remove you aDd your famisbiDgs aDd other beloagiags could be started by the lender at any lime.
ASSUMPTION OF MORTGAGE -- You _ ".Y or -X- m.y aot (CHECK ONE) seD or transfer your bome
to a buyer or lIIIn&ferce wbo will assmae the mongage debt, provided that all the oatstaDdiag paymeDlS, cbarges and
attorney's fees and costs arc paid prior to or at Ibe sale and tbat Ibe other rcqairemeDta of Ibe mortgage arc IlIIia6ed.
YOU MAY ALSO HAVE TIlE RIGHT:
. TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE TIlE MORTGAGE RESTORED TO TIlE SAME POSmON AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE TIlE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
. TO ASSERT TIlE NONEXiSTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER TIlE MORTGAGE DOCUMENTS,
. TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTiON BY TIlE
LENDER.
. TO SEEK PROTECTION UNDER TIlE FEDERAL BANKRUPTCY LAW.
CONSUMER CIlEDIT COUNSELING AGENCIES SERVING YOUR COUNTY AIlE
ATTACHED
Very Truly Your.,
Ameriquest Mortpp Company
Cc: Ameriques! Mortgage Company
Attn: Collectiona Departmeat
Loan Number: 0038442547
Mailed by 1.t C1au Mall ..d by Certified MaD
PlIl-"O/Na'11-1l3
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc,
2000 Linglestown Road
Harrisburg, P A 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N, 6th Street
Harrisburg, P A 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX (717) 234-2227
...o.~1f"e""'o,
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(117) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, PAl 7325
(717) 334-1518
FAX (717) 334-8326
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-01142 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
KRICK CRICKET M ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KRICK CRICKET M
the
DEFENDANT
at 1425:00 HOURS, on the 5th day of April
, 2004
at 115 S GEORGE STREET
MECHANICSBURG, PA 17055
by handing to
HARRY 0 KRICK, HUSBAND
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
So Answers:
18.00
20.70
.00
10.00
.00
48.70
.~~~~..~,;;-c~
R. Thomas Kline
04/06/2004
GOLDBECK MCCAFFERTY MCKEEVER
Sworn and Subscribed to before
By:
)'hf~) ~
Deputy She);ff
me this /2 i:!-
day of
Q~ 2L'()'f A.D.
'- )'-'JL' Q 7ru/~h-' ~
-----;" J!'rothonotary .
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-01142 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
KRICK CRICKET M ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KRICK HARRY 0 JR
the
DEFENDANT
, at 1425:00 HOURS, on the 5th day of April
, 2004
at 115 S GEORGE STREET
MECHANICSBURG, PA 17055
by handing to
HARRY O. KRICK
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Additional Comments
DEFENDANT STATED THAT PROPERTY HAD BEEN SOLD.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
--"1<:1'--:""""/"/<"/
,.,,"~ .._.':::;r.;-;~',A<,-"
/'~...P
R. Thomas Kline
04/06/2004
GOLDBECK MCCAFFERTY MCKEEVER
Sworn and Subscribed to before
By:
)Lttl 4j~__
Deputy She~
me this
....
/2
day of
~A.J \ d<JO'i A,D.
LJ.,,,~ 0 )}~~.
~othonotary ,
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106-1532
215-627-1322
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
'Is.
No. 04-1142 CIVIL TERM
CRICKET M. KRICK and HARRY O. KRICK JR.,
Individually and as guardians of OWEN ORVILLE
KRICK
115 S. George Street
Mechanicsburg, P A 17055
THIS LAW FIRM IS A DEBT COLLECTOR AND W'E ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLING THE DEBT.
PLAINTIFF'S MOTION TO AMEND COMPLAINT
Plaintiff, Deutsche Bank National Trust Company, As Trustee, by its attorney, Kristina
G. Murtha, Esquire, respectfully requests that this Honorable court enter and Order granting
Plaintiffs Motion to Amend Complaint in the above-captioned matter for the following reasons:
1. Plaintiff commenced the above-captioned mortgage foreclosure civil action on
March 18,2004, by filing its complaint, a true and correct copy of which is attached hereto as
Exhibit A. The complaint seeks to foreclose Plaintiffs mortgage encumbering real property
commonly known as 115 S. George Street, Mechanicsburg, P A 17055, hereinafter "the
property."
2. Subsequent to filing the Complaint it was discovered that the property had been
deeded to Harry O. Krick, Jr. and Cricket M. Krick, husband and wife, and Owen Orville Krick
by deed dated April 11, 1999 and recorded April 21, 1999.
3. Upon information and belief, Owen Orville Kriek was a minor child in 1999 and
is still a minor child. As a minor child, Owen Orville Krick lacks the capacity to mortgage real
property, despite his status as an owner of said real property, and lacked said capacity at the time
the mortgage was executed.
4. In order to mortgage the ownership interest of the minor child Owen Orville
Krick, his parents and co-defendants herein, Harry O. Crick, Jr,. and Cricket M. Krick, petitioned
the Cumberland County Orphans' Court for an order allowing them to execute a mortgage on the
property on behalf of their minor child.
5. Said petition was granted and, by order of the Orphans' Court of Cumberland
County, dated October 5, 1998, Harry O. Krick, Jr. and Cricket M. Krick were authorized to
place a mortgage on the property, and to execute said mortgage on behalf of their minor son,
Owen Orville Krick. A true and correct copy of said order is attached hereto as Exhibit A.
6. Despite the above-r~ferenced order, at the time the mortgage was executed, Harry
O. Krick, Jr. and Cricket M. Krick signed only individually, and not on behalf of their minor son,
Owen Orville Krick.
7. The Orphans' Court order makes clear the intent of the parties to mortgage the
interest of Owen Orville Krick and, together with the mortgage,. is proof of Plaintiff s perfected
security interest in the property.
8. Plaintiff therefore seeks to leave to file an Amended Complaint to plead the facts
set forth above and to set forth a cause of action to foreclose th(;: interest of Owen Orville Krick,
by and through his guardians Harry O. Krick, Jr. and Cricket M, Krick.
9. Owen Orville Krick is a necessary party to these proceedings pursuant to Pa.
R.C.P. 1144(a)(3). A true and correct copy of the proposed Amended Complaint is attached
hereto, made part hereof, and marked Exhibit C.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court
grant its Motion to Amend Complaint to foreclose the interest of Owen Orville Krick, by and
through his guardians Harry O. Krick, Jr. and Cricket M. Krick.
Respectfully submitted,
GOLDBECK McCAF RTY & McKEEVER
//
BY:
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
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
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
'Is.
No. 04-1142 CIVIL TERM
CRICKET M. KRICK and HARRY O. KRICK JR.
Individually and as guardians of OWEN ORVILLE
KRICK
115 S. George Street
Mechanicsburg, P A 17055
PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF
MOTION TO AMEND COMPLAINT
Rule 1033 of the Pennsylvania Rules of Civil Procedure specifically provide that:
A party may, by leave of court at any time, amend his
pleading. The amended pleading may aver transactions
or occurrences, which have happened before or after
filing of the original pleading. . .
Subsequent to filing the Complaint it was discovered that the new real owner of the
Property at issue is Owen Orville Krick who, upon information and belief, is a minor child. As
set forth in the accompanying motion, Plaintiff s complaint seeks to foreclose Plaintiff's
mortgage encumbering real property commonly known as 115 S. George Street, Mechanicsburg,
P A 17055, hereinafter "the property." However, subsequent to filing the Complaint it was
discovered that the property had been deeded to Harry O. Krick, Jr. and Cricket M. Krick,
husband and wife, and Owen Orville Krick, who was and, upon information and belief, still is a
minor child.
As a minor child, Owen Orville Krick lacks the capacity to mortgage real property,
despite his status as an owner of said real property, and lacked said capacity at the time the
mortgage was executed. In order to mortgage the ownership interest of the minor child Owen
Orville Krick, his parents and co-defendants herein, Harry O. Crick, Jr. and Cricket M. Krick,
petitioned the Cumberland County Orphans' Court for an order allowing them to execute a
mortgage on the property on behalf of their minor child.
Said petition was granted and, by order of the Orphans" Court of Cumberland County,
dated October 5, 1998, Harry O. Krick, Jr. and Cricket M. Kri(:k were authorized to place a
mortgage on the property, and to execute said mortgage on behalf of their minor son, Owen
Orville Krick. Despite the above-referenced order, at the time the mortgage was executed, Harry
O. Krick, Jr. and Cricket M. Krick signed only individually, and not on behalf of their minor son,
Owen Orville Krick.
The Orphans' Court order makes clear the intent of the parties to mortgage the interest of
Owen Orville Krick and, together with the mortgage, is proof of Plaintiffs perfected security
interest in the property. Plaintiff therefore seeks to leave to fil(~ an Amended Complaint to plead
the facts set forth above and to set forth a cause of action to foreclose the interest of Owen
Orville Krick, by and through his guardians Harry O. Krick, Jr. and Cricket M. Krick.
Owen Orville Krick is a necessary party to these proceedings pursuant to Pa. R.C.P.
1144(a)(3). Moreover, his interest in the property must be temlinated by the foreclosure
proceedings, or the inadvertent error made at closing, whereby his parents neglected to sign the
mortgage individually and on behalf of their minor son, Owen Orville Krick, will constitute a
cloud on title.
The clear intent of the parties was to mortgage the entir,ety of the ownership interest in
the property to Plaintiff, in exchange for the mortgage loan. That one owner was a minor child
was dealt with by obtaining a court order allowing his parents to execute the mortgage on his
behalf. It was only due to an inadvertent error at closing that the Defendants herein did not sign
individually and as guardians of their minor child. This honorable Court is empowered to correct
such inadvertent errors by the Pennsylvania Rules of Court.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court
grant its Motion to Amend Complaint to foreclose the interest of Owen Orville Krick, by and
through his guardians Harry O. Krick, Jr. and Cricket M. Krick.
Respectfully submitted,
GOLDBECK McC
ERTY & McKEEVER
BY:
DATE: October 18.2004
EXHIBIT "k"
IN RE:
OWEN ORVILLE KRICK,
a Minor
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 98 - 729
ORPHANS'
ORDER OF -COURT
AND NOW, this 5 n-f day of cr1 (1.1: .
" 1998,.upon consideration of
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Cumberland County. Pennsylvania. and to execute said mortgage on behalf of their minor son. I
I
Petioner's Petition, and after a hearing on this matter held September 30, 1998, it is hereby
ordered that Petitioners HARRY O. KRICK, Jr., and CRICKET M. KRICK are hereby
authorized to place a mortgage on the property at 115 South George Street, Mechanicsburg,
OWEN ORVILLE KRICK, a part owner of the aforesaid pmperty_
Io//Jiwr Jio~ Wi::/f
A TRLi~ CC~')':' FP.CM RECORD
tn T""tlr:-:~;"'~' .;..' \ "-'} ~..{. I tl :~t)!.:n~':) :rt't I"!'!l' h~nd
~4m:Ii~
Cumbertend County OK 117 6 PG 0 9 9 9
EXHIBIT "p "
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR. \". Iil"';~- .~ . R Nf Yc
ATTORNEY I.D. #16132:~~~. ~ . . ., THIS IS
SUITE 5000 - MELLON INDEPENDENJE&:~ER. fj I " ,~ '. ~E~~~";;tc~~TA~Opy OF
701 MARKET STREET 0 PVUt: AND CC, .ru.... oJ ,v ·
PHILADELPHIA, PA 19106 C THE ORIGiNAL FILED
(215) 627-1322
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO
NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Term
No. 0.., -J/"~~
'Is.
CRICKET M, KRICK
HARRY O. KRICK JR.
Mortgagor(s) and Real Owner(s)
115 S. George Street
Mechanicsburg, P A 17055
CIVIL ACTION: MORTGAGE
FQMClOIURE
Defendant(s)
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLE,CTING THE DEBT.
NOTICE
Yau have been sued in court. If you wish to defend against the claims set forth in the following pages, you must lake action within twenty (20) days after the Complaint and notice
are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. Yau are warned that if
you Cailto do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim
or relief requested by the Plaintiff. You may lose money or property or other rights important to you. ,....,
YOU SHOUID TAKE TIllS PAPER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE AlA WYBR OR CANNOT AFFORD ONE. GQlo OR~EP~E THE
OmCE SET FORm BELOW. TIllS OmCE CAN PROVIDE YOU WITH INFORMATION ABOlJf HIRING AlA WYER. ;:...;; ..<--
IF YOU CANNOT AFFORD TO HIRE A lAWYER, TIllS OmCE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOlTf A(}~CIES T9XT M~FFER
LEGAL SERVICES TO EUGlBLE PERSONS AT A REDUCED FEE OR NO FEE. c'.' ~:::: hi :;g
- ....'-' r
"- . - -:-t f'11
LEGAL SERVICES INC -~) 0
Slrvine Row .;~.'..' C0 t:.-:' ,1.)
Carlis]e, PA ]7013 :::.2 >i';
717-243-9400 ~. ;::-;:~
~~~ ?~
:::~~
CUMBERLAND COUN1Y BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
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LE HAN DEMANDADO A USTED EN lA CORTE. SI DESEA DEFENDERSE CONTRA lAS QUE/AS PERESENTADAS, ES ABSOLlJfAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA IDEFENDERSE ES NECESSARIO QUE USTED, 0 SU
ABOGADO, REGISTRE CON lA CORTE EN FORMA ESCRlTA, 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 PROSEGUlR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, lA COOTE PUEDE,
SIN NOTIFICARlO, DECIDlR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPlA CON TODAS lAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE
ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEV AR EsTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TEL<;FONO LA OFICINA F1JADA
AQui ABAJO. ESTA OFICINA PUEDE PROVEER~ CON INFORMACION DE COMO CONSEUlR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, <;8TA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIa REDUCIDO 0 GRATIS.
LEGAL SERVICES INC
S Irvine Row
Carlisle, P A 17013
717-243-9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
_~"7\ ~,e'~~'i,~r';T:.;"
COMPItAi\ci IN! . A .' . , KRTIFY THAT THIS Ie.
" .....,"\. )1'""" V
H I "',u:~ :_', -- ';,:T COpy 0;:;-
I. Plaintiff is DEUTSCHE BANK NA TICQg~ ANY, AS .;i~~~~~~f~RIQU~ST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,
2002, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868.
2. The name(s) and addressees) ofthe Defendant(s) is/are CRICKET M. KRICK, 115 S. George Street,
Mechanicsburg, PA 17055 and HARRY O. KRICK JR., 115 S. George Street, Mechanicsburg, PA
17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described.
3. On August 28,2002 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the
Office ofthe Recorder of Deeds of Cumberland County as Book 1776 Page 0982. The mortgage has not
been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned
mortgage was assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF
AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT
DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE by Assignment of Mortgage, which
Assignment is being lodged for recording. These documents are matters of public record and are
incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9).
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due
November 01,2003, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 10/01/2003
through 03/31/2004 at 7.7500%
Per Diem interest rate at $17.41
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 11/01/2003 to 03/31/2004
Monthly late charge amount at $35.08
Costs of suit and Title Search
$80,883.72
$3,186.03
$4,044.19
$175.39
Escrow
Fees
NSF Charges
Monthly Escrow amount $142.81
$900.00
$89,189.33
+$385.13
+$106.00
+$25.00
$89,705.46
7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania
law, and, will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is
reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually
performed.
8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant(s) by Certified and regular mail, as requ.ired 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 "A". The Defendant(s) haslhave not had the required face~to~face meeting
within the required time and Plaintiff has no knowledge of any such meeting being requested by the
Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate
Consumer Credit Counseling Agency.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $89,705.46,
together with interest at the rate of $17.41, per day and other expenses incurred by the Plaintiff which are
properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale ofthe
mortgaged premises.
By:
~V-.
DBE McCAFFI~RTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FORPLAmTWF
VERIFICATION
I, Stephen C. Whitaker, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint ar"e true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: ]-( /--oj
St . taker
AMERIQUEST MORTGAGE COMPANY
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COMMITMENT
SCHEDULE C
File Number: 02-462KS
ALL that certain triangular lot of ground situate on the East side of George Street in the Borough of
Mechanicsburg, in the County of Cumberland and State of Penn:~ylvania, bounded and described as
foJlows, to wit:
BEGINNING at a point on the Eastern line of said George Streel; marked by a Monument comer of
lands of the United States of America~ thence in a Northerly direl:;tion along the Eastern line of said
George Street 63.5 feet to a point at corner of Lot No. 11 on the hereinafter mentioned Plan of Lots;
thence in an Easterly direction along the line of said Lot No. 11, 31 () feet, more or less, to an iron pin at
a comer of lands now or formerly of May Sultzberger and others; thence in a Westerly direction along
lands of the United States of America, 314.46 feet to a point on th'e Eastern line of said George Street
and at the Place of Beginning.
BEING lot numbered 12 on a Plan of Lots known as Green A(:res, which Plan is recorded in the
Recorder's Office in and for said Cumberland County, Plan Book 4 at Page 4.
BEING the same premises which Miriam Burdge Krick, by Deed dated 04/07/99 and recorded 04/21/99
in Cumberland County Record Book 197, Page 942, granted and conveyed unto Harry O. Krick, Jr. and
Cricket M. Krick, husband and wife; and Owen Orville Krick, unmarried, in fee.
SEE ATI'ACHED COURT ORDER GRANTING HARRY O. KRICK, JR. AND CRICKET M.
KRICK AUTHOIDTY TO MORTGAGE THE INTEREST THAT OWEN ORVILLE KRICK,
MINOR CIDLD, HAS IN THE ABOVE REFERENCED PROP]~RTY.
Parcel No: 20-24~0785-1l9
OK t 776PG0998
P.O. DOI UIM
Sn" All.. CA '2711-1_
1111 I III!
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~t.~~r
71&2 63&9 3060 0342 6549
January OS, 2004
HARRY 0 KRICK JR
CRICKET M KRICK
115 S GEORGE ST
MECHANlCSBURG, PA 17055
110 I NNC
EXttlBiT A
ACT 91 NOTIC:E
TAKE ACTION TO SAVE ~(OUR HOME
FROM FORECLO~)URE
STATJ:MJ:NTS OJ'POLICY
Loan Number: 0038442547
Property Address: liS S GEORGE STREET, MECHANICSBURG PA,170S5
Origiul Leader: Ameriques( Mortgage Company
Current Leader/Servicer: Ameriques( Mortgage Company
THIS YIllM IS A DKBT COLL~CTOR ATl'DlPTlNG TO COLLKC1' A DKBT. THIS NOTICK
IS SENT TO YOU IN AN A'ITJ:MPT TO COLLKCT TBJ: INDKBTJ:DNJ:SS UnRUD TO
HKUIN AND ANY INJ'ORMATlON OBTAlNBD nOM YOU WILL BE USKD J'OR THAT
Pu..MSJ:. II' YOU HA VI: PUVIOUSLY UCJ:IVJ:D A DISCHARG:I: IN BANKll1JllTCY, THIS
CORUSPONDJ:NCJ: IS NOT AND SH01JLD NOT BE CONSTR1JJ:D TO BE AN A'ITJ:MPT TO
COLLECT A DJ:BT, BUT ONLY ENJ'OllCJ:MJ:NT OJ' A LD:N AGAINST PllOPJ:RTY.
Till. I. D oIIidal .otiee tltu tlte .onu. oa ,,_r 1l0000e I. Ia delalt. ad tile leader latead. to foreelole.
Soee. I.f_ad. aboat the ....re 01 tile delalt I. Dnmded ia tile .t1taded D.'"
TIle HOMJ:OWNJ:R'S MOllTGAG~ ASSISTANCE PIlOGllAM (DMAP) .." be able to II. to taft "..r
1l0000Co TIll. NotIee PDI"., Il.w tile DroU'Ua workt.
To see if HJ:MAP CD llelD. yo. ..It MJ:ET WITH A CONSUMJ:R Cll:EDIT COUNSELING AGENCY
WITIIlN 3t DAYS OJ' TIIJ: DATI: 0"-1'IIISNOTICi:. Take tId. N0de4l witIl yo. wllea y_ lDeet wltll tile
Coaalell.. AICIlC'f.
TIle uae. addreu ad Dllne ...ber of Coa...er Credit Co..lella. .theadcsservi.. y.r C......, are
lI.ted at tile ead of till. Notice. If y_ Ila.,e au oestIo... y. .u call tile PeIlUYIv..I. H..si.. n...ce
A.a" toll free.t 1-800-342-2397.(Penoa. witll laDalred Ilearia. CD wi (717) 781-1869).
Till. Notiee eeatala. iDIportaat le.aI l...o.....tIo.. If J- Ilave uJ ..enuHU, represeatatiTel .t tile C....er
Credit C.aselia. AaeaeJ ..J be able to Ilelp aplaia It. YCMI ..aJ aI.. ,.rut to e_tact.. attoraeJ ia Joar
areL TIle local bar auoelatiCMI IOJ be ule to Ilelp J- Ii.. a lawyer.
LA NOTmCACION EN ADI1JNTO ES DE SUMA IMPOllTANCIA, P1JJ:S ARCTA SU DEUCHO A
CONTINUAll VIVIJ:NDO EN SU CASA. SI NO COMPUNDE J:L CONftNJDO DE ESTA
NOTmCACION OBTJ:NGA UNA TllADUCCION INMJ:DITAMJ:NT:! LLAMANDO UTA AGENCIA
(PJ:NNSYLV ANIA HOUSING J'INANCE AGENCY) SIN CARGOS AL NUMJ:110 MJ:NCIONADO
"'~."
ARRIBA. PW:DES SER ELEGDLE PAllA UN P:USTAMO' PO'R EL PRO'GllAMA LLAMADO'
"HO'MJ:O'WNJ:R'S J:MJ:RGJ:NCY MO'RTGAGE ASSISTANCI: PRO'GlIlAM" EL CUAL PW:DE
SALV All SU' CASA DE LA PEllDmA DEL DEnCHO' A nDIMIll Sl:r HIPO'TECA.
HO'MEO'WNER'S EMERGENCY MO'RTGAGE ASSISl'ANCI: PRO'GRAM
YO'U'MAY BJ: ELIGDLE FOR J'INANCIAL ASSISTANCJ:
WHICH CAN SA VI: YOUR HO'ME nO'M I'O'RJ:CLOSmtJ: AND
HJ:LP YO'U' MAD J'UTU'U MO'RTGAGE P~~YMJ:NTs
II' yaU' CaMPLY WITH THJ: PRaVISIONS 0'1' TIIJ: HaMEaWNER'S J:MJ:RGJ:NCY MO'RTGAGJ:
ASSISTANCE ACT aJ' 1983 (THE "ACT"), yau MAY BE ELIGDLE FaR J:MERGENCY MaRTGAGE
ASSISTANCJ::
2 IJ' yan DJ:J'AlTL T HAS BEEN CAU'SED BY CIRCUMSTANCES BEYO'ND yO'n CaNTRaL,
2 IJ' yaU' HAVI: A RJ:ASaNABLJ.: PRaspJ:CT aJ' BEING ABLE TO PAY yan MaRTGAGE
PAYMJ:NTS, AND
2 IJ' yaU' MEET aTIIJ:R ELIGDILITY REQ1JIRJ:MJ:NTS J:STABI.ISHJ:D BY THJ:
PJ:NNSYLVANIA HaU'SING J'lNANCI: AGENCY.
TJ:MPaIlARY STAY 0'1' l'aRJ:CLOSlJRE - UDder the Act, you arc CDtitlled to a tcmporuy stay offorcclonrc
on your mortgage for thirty (30) days from the date of this Notice. Dnring that time you must anange and attend a
face-to-face mcctiDg with ODe of the CODS1lD1el credit counseling agencies Hsted at the eDd of this Notice. THIS
MEETING MUST aCCUR. WITHIN THJ: NJ:XT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGEN'CY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF nns
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT- EXl'LAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
caNSUMER CRJ:DIT CaUNSELING AGENCIJ:S - If you meet witIl one of the consmner credit COIIDSCting
al!Cnev Hsted at the cad of tlais notice. the lender mav NOT take action aaaiut yOU for thirtv (30) clavs after the elate
of this m~ The names. addresses and telephone Dumbers of dcsinatcd coJl8UDler credit counseling aacacies for
the county in which the prOj)CIty is located arc set forth at the cad of this Notice. It is only ncccssary to schcdalc one
face-to-face mcctiDg. Advise your lender immccliately of your intCDtioDS.
APPLlCATIaN l'aR MaRTGAGE ASSISTANCE - Your mortgage is in a default for the J'CUODS set forth later
in this Notice (see following pagc8 for &pCicific information about the D8hde of your ddaalt.) If jOa have tried and
are 1III8ble to resolve this problem with the lender. you have the right to apply lbr fiDancial auistaDcc from the
Homcowner's Emergency Mortsa8e A81istance Propam. To do 80. you must fiill out. lip and file a completed
Homcowner's Emerpcy Anistan<:e Program AppHcation with ODe of the desiignated COD81ID1Cl credit counscling
agencies Hsted at the end of this Notice. Only consumer credit counscling agCII.cies have applications for the
program and they will auist you in submittiag a complete application to the Pe:DDSylvuia Housing FiDaDcc Agency.
Your application MUST be filed or postmutcd within thirty (30) days of your face-to-face meeting.
yaU MUST J'D..J: yaUlt APPLICATIO'N PRaMPTLY.II' yaU PAIL TO' DO' sa aRII' YO'U' DO NaT
paLLaw THE OTIIJ:R TIMJ: PEJlIaDS SJ:T J'ORTH IN THIS LETTIeR, J'ORJ:CLO'SUllJ: MAY
PROCJ:J:D AGAINST YOUR Ba~ IMMJ:DIATJ:LY AND yalJR APPLICATIaN FOR MaR.TGAGE
ASSISTANCI: WILL BJ: DENRD.
AGENCY ACTIaN - Available fuDds for emergency mortgage assistance art= very Hmited. They will be disbursed
by the Agency UDder the eHgibility criteria established by the Act. The Pennsylvania Houling FiDaDcc Agcacy has
sixty (60) clays to make a decision after it receives your appHcatioD. During that time. DO forcclo8urc proceedings
will be pursued apiDst you if you have met the time requirements set forth abcllVC. You will be notified cIircdly by
the PcJUlS)'lvania Housing Finance Agency of its decisioD on your 'application.
PAACT2fNCpfP'-ot
JlUl1I8IY OS, 2004
Loan Number: 0038442547
NOTE: IJ' YOU AIU: C1JIUlJ:NTLY PROn:Cl'J:D BY TIlE I'U.ING Oil' A PETITION IN
BANKRUPTCY, mE 1l'0LLOWING PART Oil' THIS NOTICE IS roR 1NIl'0llMATION
PURPOSES ONLY AND SHOULD NOT BE CONSmEIlJ:D AS J'-N ATTEMPT TO COLLECT
THE DEBT.
(If YCMlltave filed b....kraptey y" en still apply for Emerplley Mort.a. Auistanee.)
HOW TO CUD YOUR MORTGAGE DEIl'AUL T (lJri.. it.D to datel.
NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property loctccl at:
at 115 S GEORGE STREET, MECHANICSBURG, P A 17055 IS SERIOU8L Y IN DEFAULT becaase:
A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
foUowing amounts are now past due:
11/01/03 th1u 01/01/04 at $727.42 per month
Monthly Payments plas late charge or other ~c:es: $2300.00
Total Aaoant to C1are Deralt: 5%300.00
B. YOU HA VI: Il'AILED TO TAKJ: TIlE 1l'0LLOWING ACTION ~ not aM if not uDlicule): N/A
HOW TO C1JIlJ: TIlE DEIl'AUL T -You may cure the default within THIRTY (30) DAYS of the dale of this
notice BY PAYING TIlE TOTAL AMOUNT PAST DUI: TO TIlE LENDER, WHICH IS $2300.01
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH EIBCOME DUE DURING THE
THIRTY (30) DAY PERIOD. Pavments must be made either by cash. cashier's check. certified check 01 mouev
order made Dllvable and sent to:
AmeJiquest Mortgage Company
S05 City Parkway West, Suite '100
Oranl~, CA 92868-2912
You can cure any other default by tatiDg the following action within THIRTY (30) DAYS of the date of this letter:
(Do not use if not ap,plicable,) NI A
IJ' YOU DO NOT CURl: mE DEPAUL T-Ifyou do DOt cme the default lrithin THIRTY (30) DAYS of the date
ofthia Notice, tile leader intea.. to oereise itt rinn to acceIente tile aonap debt. TlUs DlC8III that the entire
outltandillg baIuce of tlUs debt wiD be couiderecl clac immecJiatcly and you lmay 10Ie the chaDce to pay the
mortgage in monthly iaslaDments. IffaU payment of the totallDlO1lDt past dul: is not made withia THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to IIaIt legal action to i.reel.. .... Yftr aoma.d
prooeri1.
IJ' 'DR MORTGAGE IS roUCLOSED UPON - The mortgaged propelrty will be sold by the Sheriff to pay off
the mortgage debt. If the lender refers you cue to its attomcya, but you care the clelinqaency before the lender
begiu legal proceedinss against you, you will ati1l be reqairccl to pay the rcasoDable attorney's fees 1hat were
actaa1ly incurred, up to $50.00. However, if legal proc:ecdinga arc started api_ you, yoa wiD have to pay aD
reasouble aUomey'1 fees actually mCUllCd by the lender even if they exceed ~~50.00. AJry attorney's fees wiD be
added to the amount you owe the lender, which may also include other rcuoaable coats. If 1" aare tile def_1t
witllin tile THIRTY (30) DAY period. ,o. willa. be reqwirH to Ja, attl)raey'l feeL
OTHJ:R LENDER UMJ:DIJ:S - The lender may also sae you personaDy for the aupaid principal balaace BDd aD
other sums due UDder the mortgage.
RIGHT TO C1JIlJ: THJ: DEPAULT PRIOR TO SHE:RIJ'I"S SALE -If you have DOt cared the default within
the THIRTY (30) DAY period aad foreclosure ~ill8' Ilave began, )'mUUll have the tiPt to cure the d~f.Dh
BDd prevent the sale at 8DJ' time up to ODe hoar before the Shcrift's Sale. You lmay do 10 by paying the total amount
then IlUt due. plus 8DJ' late or other charges then due. reasoD8'ble attorney's fees and coati connected. willa the
foreclosure sale aad uy other coats coDDCCtcd with the Sherift's Sale u ~ed in writiu by the lender aDd by
.~
perform"" ~ other reqJrirements under the mortgage. c.rial y.r del..lll ia tile ....er set fortll ia tltls
.otiee will raton year .ort... to the same poIitiou u if y. 'ad ueYell' deI..lted.
J:ARLIJ:ST POSSIBLJ: SJD:RII'J"S SALE DA TJ: - It is estimated that tlte earliest cIate that such a Sheriff's Sale
of the mortgaged property could be held would be approximately (6) MON'IHS from the date of this Notice. A
notice of the ac:tual date of the Sheriff's Sale will be sent to yo. before the sale. Of coarse, the amount needed to
cure the default will iIlcrease the longer you wait. Yo. may fiDd out at any time exactly what the required payment
or action will be by contacting the leader.
HOW TO CONTACT THJ: LENDER:
Ameriqust Mortaaae COIIlpaay
PO Box 11000
Or.... CA 92711-1000
PIlOlle Nu.ber 800-430-5262
Fax Number 71"-347-5037
EFJ'I:CT OF SHJ:llIJ.i'Il"S SALI: - You should realize that a Sheriff's SalewiJl end your ownership of the
mortgaged property and your right to occupy it. If you contiDue to live ill the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other beJoJl8ings could be nll1cd by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ may or ~ may uot (CHECK ONE) seD or transfer your home
to a buyer or transferee who wiD assume the mortgage debt, provided that aD the outslaDding payments, charges and
auomey's fees and costs are paid prior to or at the sale 8Dd that the other requirements of the mortgage are satiIfiecI.
YOU MAY ALSO HAVE THE RIGHT:
'Z TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER. LENDING INSTITUTION TO. PAY OFF TIllS DEBT.
'Z TO HAVE TIllS DEFAULT CURED BY ANY TIllRD PARTY ACTDlG ON YOUR BEHALF.
'Z TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HA VB TIllS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR)
'Z TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORE:CLOSURE PROCEEDING OR ANY
OTHER. LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
'Z TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
'Z TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY L"'- W.
CONSUMJ:. CUDIT COUNSELING AGENCIJ:S SERVING YOllJI COUNTY AU:
ATTACBJ:D
Very Truly Yours,
Ameriquest Mortgage Company
Cc: Amcriquest Mortsagc Company
Attn: CoJJediou Departmcot
Lou Number: 003M42547
Mailed 1t111t C1.. Mail ..d 1t1 Certified MaD
1F11ADfNCm:-os
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
CCCS of West em Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, P A 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, P A 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX (717) 234-2227
AOJ'CMt .".....
Financial Counseling Services of Franklin
31 West 3rd Street
WaynesbolrO, PA 17268
(717) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-.3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysbur8~ P A 17325
(717) 334-1518
FAX (717) 334-8326
, . 1"
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.c;" 0''"'''''.' ~T fiL,;1
';;") '.~4,'" .
i;I.: t~.-, ~.. , I'
"'.JL.iI~~
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
IN THE COURT OF COMMON PLEAS
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO
NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
OF Cumberland COUNTY
CIVIL ACTION - LAW
AMENDED ACTION OF MORTGAGE
FORECLOSURE
No. 04-1142 CIVIL TERM
Plaintiff
'Is.
CRICKET M. KRICK
HARRY O. KRICK JR.
Individually and as guardians of minor child
OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
Defendants
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLI~CTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice
are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim
or relief requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOUW TAKE THIS POPER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE AlA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PAl 70 13
717-243-9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
A.Y.l..S...Q
LE HAN DEMANDADO A USTED EN lA CORTE. SI DESEA DEFENDERSE CONTRA lAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU
ABOGADO, REGlSTRE CON lA CORTE EN FORMA ESCRIT A. EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA lAS QUElAS EN EST A DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTlCIPACION. ENTONCES, lA COUTE PUEDE,
SIN NOTIFICARIO, DECIDlR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPlA CON TODAS lAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE
ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO. PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LlAME AL "lAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PAl 70 13
717-243-9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
AMENDED COMPLAINT IN MORTGAGl8: FORECLOSURE
. COUNT ONE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,
2002, WITHOUT RECOURSE, 505 City Parkway West, Suit(~ 100 Orange, CA 92868.
2. The names and addresses ofthe Defendants are Cricket M. Kriick and Harry O. Krick, Jr., Individually
and as guardians of Owen Orville Krick, 115 S. George Street, Mechanicsburg, P A 17055, who are the
mortgagors and real owners of the mortgaged premises hereinafter described.
3. On August 28, 2002 mortgagors made, executed and delivered a mortgage upon the premises hereinafter
described to AMERIQUEST MORTGAGE COMPANY, whic:h mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County as Book 1776 Page 0982. The aforementioned mortgage
was assigned to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,
2002, WITHOUT RECOURSE by Assignment of Mortgage which Assignment has been lodged for
recording; and these documents are matters of public record and are incorporated herein by reference in
accordance with Pennsylvania Rule of Civil Procedure 1019(g).
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due
November 01,2003, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 10/01/2003
through 03/31/2004 at 7.7500%
Per Diem interest rate at $17.41
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 11/01/2003 to 03/31/2004
Monthly late charge amount at $35.08
Costs of suit and Title Search
$80,883.72
$3,186.03
$4,044.19
$175.39
Escrow Balance Debit
$900.00
$89,189.33
$516.13
$89,705.46
7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania
law, and, will be collected in the event ofa third partypurchast::t' at Sheriffs Sale. If the Mortgage is
reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually
performed.
8. Notice ofIntention 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 dates set forth in the true and correct copy of such notices
attached hereto as Exhibit "A". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $89,705.46, together
with interest at the rate of $17.41, per day and other expenses incurred by the Plaintiff which are properly
chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged
premIses.
COUNT TWO
9. Subsequent to filing the Complaint it was discovered that th(~ property had been deeded to Harry O.
Krick, Jr. and Cricket M. Krick, husband and wife, and Owen Orville Krick, by deed dated April 11 ,
1999 and recorded April 21, 1999.
10. Upon information and belief, Owen Orville Krick was a minor child in 1999 and is still a minor child.
As a minor child, Owen Orville Krick lacks the capacity to mortgage real property, despite his status
as an owner of said real property, and lacked said capacity at the time the mortgage was executed.
11. In order to mortgage the ownership interest of the minor child Owen Orville Krick, his parents and co-
defendants herein, Harry O. Crick, Jr. and Cricket M. Krick, petitioned the Cumberland County
Orphans' Court for an order allowing them to execute a mortgage on the property on behalf of their
minor child.
12. Said petition was granted and, by order of the Orphans' COUlt of Cumberland County, dated October
5, 1998, Harry O. Krick, Jr. and Cricket M. Krick were authorized to place a mortgage on the property,
and to execute said mortgage on behalf of their minor son, Owen Orville Krick.
13. Despite the above-referenced order, at the time the mortgage was executed, Harry O. Krick, Jr. and
Cricket M. Krick signed only individually, and not on behalf of their minor son, Owen Orville Krick.
14. The Orphans' Court order makes clear the intent of the partie:s to mortgage the interest of Owen
Orville Krick and, together with the mortgage, is proof of Plaintiffs perfected security interest in the
property.
15. Plaintiff, through this action, seeks to foreclose the interest of Owen Orville Krick, by and through his
guardians Harry O. Krick, Jr. and Cricket M. Krick. Owen Orville Krick is a necessary party to these
proceedings pursuant to Pa. R.C.P. 1144(a)(3).
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $89,705.46, together
with interest at the rate of $17.41, per day and other expenses incurred by the Plaintiff which are properly
chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged
premises against Harry O. Krick, Jr. and Cricket M. Krick and Owen Orville Krick, by and through his
guardians Harry O. Krick, Jr. and Cricket M. Krick.
By:
. GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR., ESQUIRE
A TIORNEY FOR PLAINTIFF
i ·
I
I
I
i
. '. .
COMMITMENT
SCHEDULE C
File Number: 02-462KS
AIL that certain trianguJar lot of ground situate on the East sidt' of George Street in the Borough of
Mechanicsburg, in the County of Cumberland and State of Pellnsylvania, bounded and described as
follows. to wit:
/'
BEGINNING at a point on the Eastern line of said George Street marked by a Monument comer of
lands of the United States of America; thence in a Northerly direction along the Eastern line of said
George Street 63.5 feet to a point at corner of Lot No. 11 on the hereinafter mentioned Plan of Lots;
thence in an Easterly direction along the line of said Lot No. 11. 310 feet. more or less, to an iron pin at
a corner of lands now or formerly of May Sultzberger and others;; thence in a Westerly direction along
lands of the United States of America. 314.46 feet to a point on the Eastern line of said George Street
and at the Place of Beginning.
BEING lot numbered 12 on a Plan of Lots known as Green Acres. which Plan is recorded in the
Recorder's Office in and for said Cumberland County. Plan Book 4 at Page 4.
BEING the same premises which Miriam Burdge Krick, by Deed dated 04/07/99 and recorded 04/21/99
in Cumberland County Record Book 197. Page 942, granted and conveyed unto Harry O. Krick, Jr. and
Cricket M. Krick, husband and wife; and Owen Orville Krick, unmarried, in fee.
SEE ATfACHED COURT ORDER GRANTING HARRY O. KRICK, JR. AND CRICKET M.
KRICK AUTHORITY TO MORTGAGE THE INTEREST THAT OWEN ORVllLE KRICK,
MINOR ClIILD, HAS IN THE ABOVE REFERENCED PROPERTY.
Parcel No: 20-24-0785-119
OK t 776PG0998
P.O. BOl[ II'"
SID" AIla, CA '2711-1100
IIIIIIIIII~I
)11
~l~~
71&2 63&9 3060 0342 6549
Januuy os, 2004
HARRY 0 KRICK JR
CRICKET M KRICK
115 S GEORGE ST
MECHANICSBURG, P A 17055
1to J NMe
EXHIBiT A
ACT 91 NOTICE
TAKE ACTION TO SAVE ~(OUR HOME
FROM FORECLOSURE
STATl:MJ:NTS OIl'POLICY
Loan Number:
Property Address:
OrigiDal Lender:
CunCDt LcndcrlScrviccr:
0038442547
lIS S GEORGE STREET, MBCHANICSBURG PA,170SS
Ameriqucst MoItgagc Company
Ameriqucst Mortgage Company
THIS JI'IJtM IS A DJ:BT COLLJ:CTOIl A Tl'J:MPTlNG TO COLLJ:Ct' A DJ:BT. THIS NOTICJ:
IS SJ:NT TO YOU IN AN A1TJ:MPT TO COLLl:CT TJD: INDJ:BTl:DNJ:SS RJ:RIlRJ:D TO
HJ:DIN AND ANY INJ'ORMATION OBTAINJ:D nOM YOU WILL BJ: USJ:D 1I'01l THAT
PUllPOSJ:.1J' YOU HA VI: PRJ:VIOUSLY UCJ:IVJ:D A DISCBAllGll: IN BANKIlUPTCY, THIS
COJlRJ:SPONDENCE IS NOT AND SHOULD NOT BE CONSTIlUJ:D TO BJ: AN ATl'J:MPT TO
COLLECT A DJ:BT, BUT ONLY J:NJ'ORCJ:MJ:NT Oil' A LD:N AGAIlIliST PRonRTV.
TU. is 18 offid.. .otice tltat tlte ..ort.a. oa ,oar It...e i. fa del_It. 18,11 tlte leader Ia.u to loreclose.
Sgeeifie Wormati.. __t tlte ....re 01 tlte delu" i. Dnmded Ia tlte attulted D..eL
Tlte HOMJ:OWNJ:R'S MORTGAGJ: ASSISTANCJ: PROGRAM tllJ:M:AP) ..ay be able to lIelD to ..ft ,oar
ItOIH. TIll. Notice CXDI... It.. tlte Dm..... works.
To lee if HJ:MAP eu ltelD. ".. ...It MJ:J:T WITH A CONSUMJ:R C1RDIT COUNSJ:LING AGENCY
WITHIN 30 DAYS Oil' TJD: DATI: or THIS NOTICt. Take tId.Nodee.witIl ,oa wllea Y" IDeetwitlt tlte
CRaseD.. Aaean.
TIle ...1. addreu ud ulloae R..ber of Coa...er Credit Coa.lella. A.ReBdaleni.. YOur Coa.ty are
lilted at tile ead 01 tills N otiee. If yo. ltaTe UJ ..CId.... Joa ..u eall tile Peuu"""l. H..... Ji'iauee
A_an tolllree.t 1-8GO-U2-2397.(Penoas witIt iauaired Itearia. eu call (717) 781-18").
Tlds Notice coatUu iIIlportaat leJallafonaatioa. lIyoa fla"e 181 quatiGu. repretelltadves at tile Coa_er
Credit C...lelia, Aaeaey ".1 be able to lIeIp uplala it. Yoa ..al allO ",ut to e_tact a. aUoraey Ia your
.reL TIle loeal b.r auoel.tioa ".1 be able to Itdp loa Bad a laWJer.
LA NOTIJ'ICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, P'UJ:S ARCTA SU DJ:RJ:CHO A
CONTINUAR VlVD:NDO J:N SU CASA. SI NO COMPRJ:NDJ: J:L COllliTJ:NIDO DE J:STA
NOTIJ'ICACION OBTJ:NGA UNA TRADUCCION INMJ:DITAMJ:NTli: LLAMANDO ESTA AGJ:NCIA
(pJ:NNSYLV ANIA HOUSING II'INANCJ: AGJ:NCY) SIN CARGOS AL NUMJ:RO MJ:NCIONADO
1n\1KJICPtI..
AJllUBA. PUDES SER ELEGIBLE PAllA 'UN PIlJ:STAMO POR EL PROGllAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PR04:;RAM" EL ClJAL PODE
SALV AR SU CASA DE LA PERDmA DEL DEUCHO A UDIMIR S:U BIPOTECA.
HOMEOWNER'S :EMERG:ENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE II'OR Il'INANCIAL ASSISTANCE
WIDCH CAN SA VI: YOUR HOMl: nOM II'OUCLOSUU AND
HJ:LP YOU MAD Jl'UTUU MORTGAGE IIAYMJ:NTS
IJl' YOU COMPLY WITH nn: PROVISIONS 0' nn: HOMEOWNER'S J:MJ:RGENCY MORTGAGE
ASSISTANCE ACT 011' 1983 (TIIJ: "ACT"), YOU MAY BE ELIGIBLlt 'OR EMERGENCY MORTGAGE
ASSISTANCE:
'Z I' YOUR DEII'AULT HAS BE:EN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
'Z II' YOU HA VI: A UASONABLJ: PROSPECT 011' BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
'Z II' YOU MEET OTHJ:R ELIGIBILITY IlI:Qunu:MJ:NTS EST AJI~LISHJ:D BY TIIJ:
PENNSYLVANIA HOUSING Jl'INANCI: AGJ:NCY.
TEMPORARY STAY 011' 1I'0Ill:CLOS1JJlJ: - Under the Act, you uc CDtided to a temporary stay of forcclO81llC
on your mortgage for thirty (30) days from the date of this Notice. Daring dull time you must anmge and attend a
face-to-face mcctiDg with one of the consumer credit coanscliDg agencicslistcd at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THJ: NJ:XT (30) DAYS. IF YOU no NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. 11J:g PART OF TInS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT- EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONS1JMJ:R CUDIT CO'UNSJ:LING AGJ:NCD:S - If you meet with C1tDC of the CODSllD1Cl credit couscliq
ageDCV listed at the c:acl of this notice. the lender may NOT take action Jurmld vou for thirty (30) clays after the elate
of this meetUur The Dames. addresses and telephone numbers of dcsipJltf!d c:GlIIAIIIler credit counseliag agcacics for
the county in which the 'Dropcrtv is located arc set forth at the cad of this Notice. It is only ncccssuy to IChcdale one
face-to-face meeting. Advise your lender immccliatclv of your intentions.
APPLICATION "OR MORTGAGE ASSISTANCJ: - Your mortgage is in a clefa1l1t for the IC8SOns set forth later
in this Notice (see following JIIlgel for specific iDformation about the DIdure c){ your default.) If you have tried and
are 1IIUlble to resolve this problem with the lender, yoo have the right to appl]r for financial auistaDcc from the
Homeowner's Emergency Mortgage Assistance Propun. To do 10, you Dl1lR fill out, sign and file a completed
Homeowner's Emergency AIsistaucc Program Application with one of the c1csignatccl CODSUDlcr credit c:oanscling
ageDCics listccl at the end of this Notice. Only coDSllDler crcclit counseling agc:acics have applications for the
program and they will assist you in submitting a complete application to the ))cnnsy1vania Housing FiDaDce Agency.
Your application MUST be filecl or postnwlcd within thirty (30) daYB ofYOllIl face-to-face meeting.
YOU MUST I'ILE YOUR APPLICATION PROMPTLY. II' YOU "An, TO DO SO OR D' YOU DO NOT
II'OLLOW THE OTHJ:R TIMJ: PERIODS SET Il'ORTH IN THIS LJ:T1rJ:R, J'OUCLOSUU MAY
PROCEED AGAINST YOUR HOMl: IMMJ:DIATELY AND YOUR AI~PLlCATlON "OR MORTGAGJ:
ASSISTANCI: WILL BE DENlJ:D.
AGJ:NCY ACTION - Available fonds for emergency mortgage assistance lire very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act The ~rJvania Housing FiDance Agency has
sixty (60) clays to mate a decision after it receives your application. During dUd time, no foreclosure proccediuga
will be pursued against you if you have met the time requirements set forth above. You will be notificcl cIire<:tly by
the PeDDlylvania Housing Finance AgeDCy of its decision on your -applicatiorl.
PMCT2INt"'~OI
JllIlD8l'Y OS, 2004
Loan Number: 0038442547
NOTE: IJ' YOU AU CUJUU:NTLY PROn:crED BY TIR I'ILING OJ' A PETITION IN
BANKRUPTCY, THE J'OLLOWING PAllT OJ' THIS NOTIC:): IS J'OR INJ'ORMATION
PUIlPOSES ONLY AND SHOULD NOT BE CONsmERJ:D AS,~ ATTJ:MPT TO COLLECT
THE DEBT.
(If YIMI have filed baakruptey YIMI eaa still apply for Emerplley Mort.ap Auistaaee.)
HOW TO CURl: YOUR MORTGAGE DEJ'AUL T (llIia. it aD to datel.
NATURE OF THE DEFAULT -The MORTGAGE debt bytbe above lender on your property loctcd at:
at 115 S GEORGE STREET, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because:
A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts arc now past due:
11/01/03 thm 01101104 at $727.42 per month
Monthly Payments plus late charge or other ~ees: $2300.00
Total AmlMlat to Care Delult: 51300.00
B. YOU HA VI: J'AILED TO TAD TIR J'OLLOWING ACTION ~, Dot 1I1e if Dot aoolieable): N/A
HOW TO CURE TIR DJ:J'A'ULT -You may cure the defmlt within THIRTY (30) DAYS of the date ofthia
notice BY PAYING THJ: TOTAL AMOUNT PAST DUI: TO THJ: LJ:NlI)J:1I, WHICH IS $2381.0'
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES wmCH EIECOME DUE DURING THE
THIRTY (30) DAY PERIOD. Pavments must be made either by cash. cashier's check. certified check or money
order made Mvable and scot to:
AmeJiquest Mortgage Company
50S City Paa1way West, Suite'l00
Oranl~, CA 92868-2912
You can care BDy other defmlt by takiDg the following action within TmRTY (30) DAYS of the date of this letter:
(Do not use if aot applicable.l NI A
IJ' YOU DO NOT Cmu: TIIJ: DJ:J'AULT-Ifyou do IlOt cure the default lrithin THIRTY (30) DAYS of the elate
ofthia Notice, tile leader _tea.. te aerdle it. rip" to accelerate tile ..onp. debt. This DlC8IlI that the cDtirc
outstanditlg baJuce of this c1ebt will be coasiderccl clue immecliately and you JID&Y 10lt the chaDce to pay the
mortgage in moJldaJy insta1lments. Iffall paymeot of the total amomd past dul: is DOt made withiD. THIRTY (30)
DAYS, tile ICIlcler also intCllds to instruct its Ittomeya to start legal action to foredOle apea YOar ...maaed
'1'OfeI11.
IJ' THE MORTGAGE IS J'OUCLOSJ:D UPON - The mortgaged propcJrty will be sold by the Sheriff to pay off
1be moJtgage debt. If the lender refers your case to its attomcys, but}'Oll CUJC the clcJinqueDcy before the lender
begins legal proccecliDSs against you, you will still be rcquirecl to pay the reasoDllble attomcy's fces that were
actua1ly incarrecl, up to $50.00. HowC\'Cr, if legal proceedings are started agaiM you. JOU wiD have to pay aD
rcasoll8ble attorney's fees actually iIlcurrccl by the IeDcler C\'CD if they exceecl ~~50.00. AIry aUomcy's fees will be
added to the amount you owe the ICIlder, which may also include other reasonable costs. If yea alre tle default
witliD tile TBIJlTY (30) DAY pelied, yea win Dot be reqaired to pay attlmaey's fees.
OTBJ:ll LENDKR UMJ:DRS - The leader may also sue you pcrsonaDy for the UDpaid principal balance and aD
other II1JIDI clue 1IIlller the mortgage.
UGHT TO Cmu: THJ: DJ:J'AULT PUOR TO SHJ:UJ'J"S SALE - If~rou haft IlOt c:urccI the default withia
~e TmRTY (30) DAY period and forcclOlllIC ~;1\gI have bepD, JOIUtill have the rtpt to cure tile defilDIt
aDd prevent the sale at aay time up to one Iloar before the Sheriff's Sale. You JIDay do so by payiag 1be total amouat
thea )lUt due. plus any late or other charges the:a due. reasollable attorney'. to:. and costs collllCCtecl witIl the
foreclo&ure sale ad any other costa coDDCc:ted wit1l the Sheriff's Sale as speciiled is wriIiu by the Ie_r 8Dd ~
P~Ol
performinr llQY other ~ircmen"1JDder the mortgage. c.rialY08r delaalit ia tile .....er set fortll ia tills
Bod<< will restore y.r ..ortpp to tile ....e positiOB .. if yo. hd Bever defaulted.
EARLIEST POSSIBLE SIRRIJ'J"S SALE DATE -It is estimated that tile earliest date that such a Shcri1J's Sale
of the mortgaged property could be held would be approximately (6) MON1HS from the elate of this Notice. A
notice of the actual date of the Sherift's Sale will be sent to yoo before the salle. Of course, the amount nccdccl to
cure the default will increase the longer you wait. Y 00 may find oot at any tilDe exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT TIll: LENDER:
AIIIeriqult Mort... COIIlpaay
PO Bo]l: 11000
Oraae. CA 9%711-1000
P1tOlle N.lIlber 800-430-5%'%
:Fu Number 714-347-5037
E:rn:CT O:F SIRRIJ':F'S SALE - You should realize that a Shcri1J's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings aDd other belongings could be stilted by the lender at any time.
ASSUMPTION O:F MORTGAGE -- You _ ".Y or -X- ".Y Bot (CHECK ONE) seD or transfer your home
to a buyer or transferee who will assume the mortgage debt, providccl that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale aDd that the other requirements of the mortgage are satiJfied.
YOU MAY ALSO HA V& TIll: RlGB:T:
2 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE: MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TOI PAY OFF TIllS DEBT.
2 TOHAVB THIS DEFAULT CURED BY ANY THIRD PARTY ACTnmONYOURBEHALF.
2 TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER., YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALEND.A.R YEAR.)
2 TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER. LA WSIDT INSTITUTED UNDER. THE MORTGAGE DOCUMENTS,
2 TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER
2 TO SEEK PROTECTION UNDER. THE FEDERAL BANKRUPTCY LA. W.
CONSUMER CUDIT COUNSELING AGENCIES SERVING YOUR COUNTY A1lJ:
ATTACHED
Very Truly Yoors,
Ameriquest MortgaSCI Company
Cc: Ameriques! Mortgage Company
Attn: Collections Department
Loan Number: 0038#2547
Mailed Itylst C1.. Mail ad by Certified MaD
RIADJMI:P'fl4
Homeownerst Emergency AssistJlnCe Program
CUMBERLAND COUNTY
CCCS of West em Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, P A 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX (717) 234-2227
AQPM1""'"
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762..3285
YWCA ot' Carlisle
301 G Str.~et
Carlisle, P A 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
IN RE:
OWEN ORVILLE KRICK, :
a Minor
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANSJ' COURT DIVISION
NO. 98 - 7'29
ORPHANS'
ORDER OF .COURT
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Cumberland County. Pennsylvania. and to execute sald mortgage on behalf of their minor son. 1
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AND NOW, this 5 TH day of m a.. i:. . _' 1998" upon consideration of
Petioner's Petition. and after a hearing on this matter held September 30. 1998, it is hereby
ordered that Petitioners HARRY O. KRICK, Jr., and CRICt<ET M. KRICK are hereby
authorized to place a mortgage on the property at 115 South George Street, Mechanicsburg,
OWEN ORVILLE KRICK, a part owner of the aforesaid pr1operty.
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?Jf' / <feorge E. er. PJ
A TP.IJ~ CO:'2'!' FP.CM RECORD
fn T~t1t:-{';"'~' ./ I -..~ g~. f "::t>t:n~') ::-~! f'!!j' h~nd
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Cumbertend County OK I 7 7 6 PG 0 9 9 9
VERIFICATION
JOSEPH A. GOLDBECK, JR. hereby states that he is the attorney for Plaintiff herein, and that all of the
facts set forth in the attached Amended Complaint are true and correct to the best of his knowledge, information
and belief.
The undersigned understands that statements herein are made subject to the penalties of 18 P.S., section
4904.
Joseph A. Goldbeck, Jr., Esquire
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQUIRE
AttorneyI.D. #61858
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 2002-4
UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1, 2002,
WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 04-1142 CIVIL TERM
'Is.
CRICKET M. KRICK and HARRY O. KRICK JR.
Individually and as guardians of OWEN ORVILLE
KRICK
115 S. George Street
Mechanicsburg, P A 17055
CERTIFICATION OF SERVICE
\
I hereby certify that a true and correct copy of Motion to Amend Complaint,
Memorandum of Law in support thereof and Motion Court Coversheet was sent by first class
mail, postage pre-paid, upon the following on the date listed bdow:
CRICKET M. KRICK and HARRY O. KRICK JR.
Individually and as guardians of OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
GOLDBEC M,cCAFFERTY & McKEEVER
Date: October 1~. 2004
VERIFICATION
KRISTINA G. MURTHA, ESQUIRE hereby states that she is the attorney for Plaintiff
herein, and that all of the facts set forth in the attached Motion to Amend Complaint is true and
correct to the best of her knowledge, information and belief.
The undersigned understands that statements herein are made subject to the penalties of
18 P.S. ~ 4904.
Date: October 18. 2004
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GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106-1532
215-627-1322
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE,
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
'Is.
No. 04-1142 CIVIL TERM
CRICKET M. KRICK and HARRY O. KRICK JR.,
Individually and as guardians of OWEN ORVILLE
KRICK
115 S. George Street
Mechanicsburg, P A 17055
ORDER
AND NOW, this /Z9day of Ili-~
, 2004, upon consideration of the
Motion to Amend Complaint and Memorandum of Law and Response (if any) filed by
Defendants, it is hereby
ORDERED that Plaintiff is hereby authorized to file and serve upon Defendants an
Amended Complaint in the form attached to this motion as Exhibit B.
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GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEYI.I>.#16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC., ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO
NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
OF Cumberland COUNTY
CIVIL ACTION - LAW
MlENDED ACTION OF MORTGAGE
FORECLOSURE
No. 04-1142 CIVIL TERM
Plaintiff
'Is.
CRICKET M. KRICK
HARRY O. KRICK JR.
Individually and as guardians of minor child
OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
Defendants
TillS FIRM IS A DEBT COLLECTOR ANI> WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you mm,t take action within twenty (20) days after the Complaint and notice
are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or 0 bjections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim
or relief requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE TIllS POPER 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PAl 70 I3
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PAl 70 I3
A..Y.ll.Q
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUFJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVlDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU
ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUFJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE,
SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE
ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300.
LEGAL SERVICES INC
8 Irvine Row
Carlisle. PAl 70 I3
717-243-9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle. P A 17013
AMENDED COMPLAINT IN MORTGAGE FORECLOSURE
COUNT ONE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,
2002, WITHOUT RECOURSE, 505 City Parkway West, Suite LOO Orange, CA 92868.
2. The names and addresses of the Defendants are Cricket M. Krick and Harry O. Krick, Jr., Individually
and as guardians of Owen Orville Krick, 115 S. George Street, Mechanicsburg, P A 17055, who are the
mortgagors and real owners of the mortgaged premises hereinaj[ler described.
3. On August 28,2002 mortgagors made, executed and delivered a mortgage upon the premises hereinafter
described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County as Book 1776 Page 0982. The aforementioned mortgage
was assigned to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,
2002, WITHOUT RECOURSE by Assignment of Mortgage which Assignment has been lodged for
recording; and these documents are matters of public record and are incorporated herein by reference in
accordance with Pennsylvania Rule of Civil Procedure 1019(g).
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due
November 01, 2003, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 10/01/2003
through 03/31/2004 at 7.7500%
Per Diem interest rate at $17.41
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 11/01/2003 to 03/31/2004
Monthly late charge amount at $35.08
Costs of suit and Title Search
$80,883.72
$3,186.03
$4,044.19
$175.39
Escrow Balance Debit
$900.00
$89,189.33
$516.13
$89,705.46
7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania
law, and, will be collected in the event ofa third party purchaser at Sheriffs Sale. If the Mortgage is
reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually
performed.
8. 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 dates set forth in the tme and correct copy of such notices
attached hereto as Exhibit "A". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such mt~eting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $89,705.46, together
with interest at the rate of$17.41, per day and other expenses incurred by the Plaintiff which are properly
chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale ofthe mortgaged
premIses.
COUNT TWO
9. Subsequent to filing the Complaint it was discovered that the property had been deeded to Harry O.
Krick, Jr. and Cricket M. Krick, husband and wife, and Owen Orville Krick, by deed dated April 11,
1999 and recorded April 21, 1999.
10. Upon information and belief, Owen Orville Krick was a minor child in 1999 and is still a minor child.
As a minor child, Owen Orville Krick lacks the capacity to mortgage real property, despite his status
as an owner of said real property, and lacked said capacity at the time the mortgage was executed.
11. In order to mortgage the ownership interest of the minor child Owen Orville Krick, his parents and co-
defendants herein, Harry O. Crick, Jr. and Cricket M. Krick, petitioned the Cumberland County
Orphans' Court for an order allowing them to execute a mortgage on the property on behalf of their
minor child.
12. Said petition was granted and, by order of the Orphans' Court of Cumberland County, dated October
5, 1998, Harry O. Krick, Jr. and Cricket M. Krick were authorized to place a mortgage on the property,
and to execute said mortgage on behalf of their minor son, Owen Orville Krick.
13. Despite the above-referenced order, at the time the mortgage was executed, Harry O. Krick, Jr. and
Cricket M. Krick signed only individually, and not on behalf of their minor son, Owen Orville Krick.
14. The Orphans' Court order makes clear the intent of the parties to mortgage the interest of Owen
Orville Krick and, together with the mortgage, is proof of Plaintiffs perfected security interest in the
property.
15. Plaintiff, through this action, seeks to foreclose the interest of Owen Orville Krick, by and through his
guardians Harry O. Krick, Jr. and Cricket M. Krick. Owen Orville Krick is a necessary party to these
proceedings pursuant to Pa. R.C.P. 1144(a)(3).
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $89,705.46, together
with interest at the rate of $17.41, per day and other expenses incurred by the Plaintiff which are properly
chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged
premises against Harry O. Krick, Jr. and Cricket M. Krick and Owen Orville Krick, by and through his
guardians Harry O. Krick, Jr. and Cricket M. Krick. ~ _
By:
GOLDBE
By: JOSEP
ATIORNEY F
cCAFFE:RTY & McKEEVER
OLDBECK, JR., ESQUIRE
LAINTIFF
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COMMITMENT
SCHEDULE C
File Number: 02-462KS
AIL that certain triangular lot of ground situate on the East side of George Street in the Borough of
Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as
foUows, to wit:
/
BEGINNING at a point on the Eastern line of said George Stree:t marked by a Monument comer of
lands of the United States of America; thence in a Northerly din:ction along the Eastern line of said
George Street 63.5 feet to a point at comer of Lot No. 11 on the: hereinafter mentioned Plan of Lots;
thence in an Easterly direction along the line of said Lot No. 11, 310 feet, more or less, to an iron pin at
a corner oflands now or formerly of May Sultzberger and others: thence in a Westerly direction along
lands of the United States of America, 314.46 feet to a point on the Eastern line of said George Street
and at the Place of Beginning. -
BEING lot numbered 12 on a Plan of Lots known as Green Acres, which Plan is recorded in the
Recorder's Office in and for said Cumberland County, Plan Book 4 at Page 4.
BEING the same premises which Miriam Burdge Krick, by Deed dated 04/07/99 and recorded 04/21/99
in Cumberland County Record Book 197, Page 942, granted and conveyed unto Harry O. Krick, Jr. and
Cricket M. Krick, husband and wife; and Owen Orville Krick, unmarried, in fee.
SEE ATTACHED COURT ORDER GRANTING HARRY o. KRICK, JR. AND CRICKET M.
KRICK AUTHORITY TO MORTGAGE THE INTEREST THAT OWEN ORVILLE KRICK,
MINOR CHILD, HAS IN THE ABOVE REFERENCED PROPERTY.
Parcel No: 20-24~0785-1l9
OK t 77 6 PG 0 9 9 8
P.O. Box U"O
S.... AlIa, CA '2711-1"0
)1)
~l~~r
71&2 63!9 3060 0342 6549
1anuary OS. 2004
HARRY 0 KRICK JR
CRICKET M KRICK
115 S GEORGE ST
MECHANICSBURG, PA 17055
'110 I "Me
EXHIBIT ,A
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME
FROM FORECLOSURE
STATEMENTS O)l'POLICY
Loan Number: 0038442S-~7
Property Address: 115 S GEORGE STREET. MECHANICSBURG PA. 17055
OrigiDal Lender: Ameriqucst Mortgage Company
Current LendedServicer: U Am.eriqucst Mortgage Company
THIS Ji'DlM IS A DEBT COLLECTORATTJ:MPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN A'l"RMPT TO COLLECT 'tHI: INDEBTEDNESS UnllRED TO
HEDIN AND ANY INJ'ORMATION OBTAINJ:D ROM YOU WILL BE usn )l'OR THAT
PUllPOSE. IJi' YOU SAn PDVlOUSLY UCJ:1VJ:D A DISCHARGJ: IN BANKRUPTCY, THIS
COIlUSPONDENCJ: IS NOT AND SHOULD NOT BE CONSTIlUED TO B:I AN ATI'J:MPT TO
COLLECT A DEBT, BUT ONLY ENJI'ORCEMENT 0)1' A LIJ:N AGAJNST PROPERTY.
Tills I. IB offidll notice that tile morine.. nor IlOde I. Ia del..lt. aa. tlte leader latead. to foreclose.
Speelfk Jaf_adOll &hoet the .atare 01 the del..1t I. .nJided Ia the a<<aged ...es.
Tile HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HJ.:MAP) may be able to help to I&ft YHr
home. This Nodee explaia. lI.ow the protrua works. .
To see if JlEMAP CIB ..e.... YOU ...st MEET WITH A CONSI1MJ:R CUDIT COUNSELING AGENCY
WITHIN 30 DAYS 0)1' TJIJ: DA TJ: OJi111UfNO'l'ICI:. Take t.... Notice with YOU wh. Joe meet with the
Cooasellal AleBey.
Tile a..e. addreu IBd pboae ....ber of C......er Credit Cou_sellal Areades lemal your County are
listed at the ead of tIli. Notice. If yo. Itave IBY aaestio.s. YCMl an ull the Fe_sylvala Hoa.iat Fi.anee
Area" toll free at t-800-U2-2397.lPenoa. wit.. bDpured Itearial can call (717) 780-t8'9).
Tills Notice eoaWa. importat Iqallafonaatloa. If yo. have aay questions, repretelltadves at tile C.._er
Credit C..sellal Apaq ..ay be able to Ilelp explala It. Yoe ..ay a110 want to eoatact aa attorney ia ,.owr
area. T"e loeal bar usoelatioa ..a,. be able to Itel, "08 fiad a lawyer.
LA NOTmCACION EN ADIUNTO ES DE SUMA IMPORTANCIA, PlrJ:S ARCTA SU DEIlJ.:CHO A
CONTlNlJAR VIVIENDO EN SU CASA. 81 NO COMPUND:I EL CONUNIDO Dt ESTA
NOTD'lCACION OB'nNGA UNA TIlADUCCION INMJ:DITAMJ:NTE LLAMANDO ESTA AGJ:NCIA
(pENN8YLV ANIA HOUSING J1NANCE AGENCY) SIN CARGOS AL NUMERO MIlNCIONADO
Ifl) 11N1NCPII-tI
ARRIBA. PUDES SER ELEGmLE PAllA UN PUSTAMO POR EL PROGJlAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROIGRAM" EL CUAL PUEDE
SALV AR SU CASA DE LA PERDIDA DEL DEUCHO A UDIMIR SU BIPOTECA.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGmLl: FOR J'lNANCIAL ASSISTANCE
WIDCH CAN SA VI: YOUR HOME FROM J'OUCLOSUJU:, AND
HELP YOU MAD J'UTUU MORTGAGE )'AYMENTs
IF YOU COMPLY WITH THE PROVISIONS OJ' THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OJ' 1983 (THE "ACT"), YOU MAY BE ELIGDLJC J'OR EMERGENCY MORTGAGE
ASSISTANCE:
'Z IF YOURDEJ'AULT HAS BEEN CAUSED BY CIItCUMSTANCES BEYOND YOUR CONTROL,
'% IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE 1'0 PAY YOUR. MORTGAGE
PAYMENTS, AND
'Z IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING J'lNANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are cutilded to a tempor8ly stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. Daring that time you must arrange and attend a
face-to-face meeting with one of the consumer credit counseling agencies lillted at the end of this Notice. THIS
MEETING MUST OCCUR. WITBIN TIlE NEXT (30) DAYS. IF YOU no NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR M()RTGAGB UP TO DATE: THE! PART OF TInS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If yoll meet witIa. OM of the COJlS1UJlCr credit c:ounscliag
a~acv listed at the cad of this notice. the lender may NOT take acUoa agaiast YOU for thirty (30) clavs after the elate
of this mectiag. The Dames. addresses aud telephone numbers of desiftlllfed couamer credit counsclins agcacies for
the county in which the property is located arc set forth at the end of this Notice. It is only necessary to schedule ODe
face-to-face meeting. Advise your lender immediatcJy of your intClltiODJ.
APPLlCATJON J'01l MOIlTGAGE ASSISTANCE - Your mortgage is ill a default for the ICASODJ act forth later
in this Notice (see following pages for specific iDformation about the Daturc of YOUl default.) If yoa have tried aDd
are 'lIDable to resolve this problem with the lender, yoa have the right to lIpply for fiaancial usistaAcc nom the
Homeowner's Emcigcncy Mortgage Assistance ProgJam. To do 50, you malt :ml oa1, alga 8Dd file a complctCcl
Homeowncr's Emergency Alaistauoc Program Applicatioa with one of the deuipatecl coDJalller credit COUDJeliag
agcacies listed at the end of this Notice. 0aIy consumer credit counscling agcllcies have applications for the
program and they will assist you in sabmittiag a complete application to the Pcusylvaaia Housing FiDlUlCC Agency.
YOlll application MUST be filed or postmarked within thirty (30) days ofYoaJf face-to-face meeting.
YOU MUST FO..E YOUR. APPLICATION PROMPTLY. IF YOU PAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FOIlTH IN THIS LETTER, FOUCLOSUU MAY
PIlOCEED AGAINST YOUR. HOME IMMEDIATELY AND YOUR. APPLICATION I'OR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available fuads for emergency mortgage assistance Be vcry limited. They wiD be disbursed
by the Agency under the eligibility criteria CllIablished by the Act. The PeDasytvauia Houalng FiDaace Ageacy has
alxty (60) clays to make a decisioa after it receives yoar application. Daring.1d time, no forcclosute proccediDgs
will be parsaed against you if you have met the time requirements act forth o:m. You will be notified directly by
thc Pennsylv8Dia Housing Finance Agcncy of its decision oa Y01Il-application.
'M~,""l
January 05,2004
Loan Number: 0038442547
NOTE: IF YOU ARE CUIUU:NTLY Plt.On:CfED BY THE F"[LING Oil' A PETITION IN
BANIOlUPTCY, THE FOLLOWING PAlt.T OF THIS NOTICE IS )l'OR INFORMATION
PlJIlPOSES ONLY AND SHOULD NOT BE CONSmElt.ED AS AN ATTJ:MPT TO COLLECT
THE DEBT.
(II you. have filed bankruptcy you. ean liill apply for Emel'JeIlCY Mort.a. Assistanee.)
HOW TO CUD YOUR MORTGAGE DEFAULT (JIri..'t w. to date).
NATURE OF THE DEFAULT -The MORTGAGE dcbt by the abovelendcr on your propertylocted at:
at liS S GEORGE STREET, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEPAUL T because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for IIhe following months and the
following amounts are now past dlle:
11101103 thru o 110 l/04 at $727.42 per month
Monthly Payments pins late charge or other ~ees: $2300.00
Total Amount to Cure Default: $2300.00
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ~Dot use iraot applicable): N/A
BOW TO CURl: THE DEFAULT -You may cure the default within THIRTY (30) DAYS oftheclate of this
notice BY PAYING THE TOTAL AMOUNT PAST DUE TO mE LENlIER. WHICH IS $1300.00
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WIllCH B:BCOME DUE DURING THE
TIllR.TY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or moneY
order made Jl8yable and sent to: .
AmCIiiquest Mortgage Company
505 City Parkway West. Suite '100
Oranll~, CA 92868-2912
You can cure any other default by taking the following action within TIDRTY (30) DAYS of the date of this letter:
(Do not use ifDat applicable.) N/A
IF YOU DO NOT CURl: 11IE DEJ'AULT-IfY01l do DOt care the default lIitmaTHIR.TY (30) DAYS of the date
of this Notice, tlte leader iateads to exereJse ita rip" to acedent. the mOI~,ap debt. nis meaDS that the entire
outstandiag balaDce of this debt will be coDSidcrtd clue immediately and you 1l1IA1 lose the clwacc to pay the
mortgaAC in montlaJy instaUm.ents. II fall payment of the total amoUDt past duc: is not made within THIRTY (30)
DAYS, the Ic:ader also intends to instruct its attorneys to start legal actiOD to fl.reelose .poIl Joar mon,aaed
property.
IF THE MORTGAGE IS )l'OllECLOSED UPON - The mortgaged propeJlty will be sold by the Sheriff to pay off
the mortgage debt. II the lender refers your case to its attorneys, but you cure the delinquc:acy before the lender
bcginJ Jegal proceedings against you, yoo will still be required to pay the reaselnable dorney'l fees that were
actnaDy incurred, up to $50.00. However, iflcgal proceedings arc started agaillSt you. you wiD have to pay aD
reasoD8ble aUorney's fees actually incurred by the lc:ader eve_ ifthcy exceed $50.00. AIry aUorney's fees will be
added to the III101IIlt you owe the lc:ader. which may also incluclc other rcasoJlllblc coati. II you. CD re tile defaalt
with'. the THIllTY (30) DAY period. J08 wlllaot be reqaired to pay a<<oneY'1 fees.
OTJl);R LENDER REMEDIES - The lender may also sue yon personaDy fc>r the anpaid principal balance lUId aD
other sums due UDder the mortgage.
IUGHT TO CUD TIlE DEII'AULT PIUOlt. TO SHERIJ'Il"S SALE - Ifyoo have BOt cared the default within
the THIRTY (30) DAY period and foreclosure proccediDgI have begun. JmLJljJl have the tiaJd to cure the default
and prevent 6e sale at any time 1IIl to one hoar before the Sherift'1 Sale. You. IiIIA}' clo 10 by paying the total amount
then put due, plullDY late or other charges then clue. reasonable attorney'1 feci u4 COlts cODBectcd with the
forcclosuJC sale and 8DT other costs coDDC<:ted with the Sheriff's Sale as lDCCifiied in writina by the lender and by
PAACTltHCPfe-a
perfomUDg any other requirements under the mortgage. Curiag your default ia the mUlDer set forth ia this
notice will restore your mortgage to the same position as if you had never' defaulted.
EARLRST POSSIBLE SHERIFF'S SALE DA T:E -It is estimated that the earliest date that such a Sheriff's Sale
of the mortgaged property could be held would be approximately (6j l..iONTI-IS nom the date of this Notice. A
notice of the ac:tual date of the Sheriff's Sale win be sent to you before the sak Of course, the amoUDt needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT TIIJ: LENDER:
AIIleriq.est Mortlale Compoy
PO Box 11000
Or.... CA 92711-1000
PIloae N.mber 800-430-5161
Pax Number 714-347-5037
:EFFECT OP SBE:RIFF"S SALE - You should realize that a Sheriff's Sale will end your ownership ofllie
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could be staded by the lender at any time.
ASSUMPTION 01' MORTGAGE - You _ mayor..L.... may not (CHECK ONE) seD or transfer your home
to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requilremems of the mortgage are IatisiJed
YOU MAY ALSOHAVEmE.RIGH1r:
'Z TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO :PA Y OFF THIS DEBT.
'Z TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
'Z TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER., YOU DO NOT HA VB THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
'Z TO ASSEllT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTIIER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
'Z TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACI'lON BY THE
LENDER.
'Z TO SEEK PROTECI'lON UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CUBIT COUNSELING AG:ENCIES SEIlVING YOUR COUNTY AU
ATTACHED
Very Truly Yours,
Ameriqucst Mortgage Company
Cc: Amcriquest Mortgage Company
Attn: Collections DcpartmCllt
Lou Number: 0038442547
Mailed .y ht Clall Mall ..d by Certified MaD
.."',.._,..,..
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
CCCS of West em Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg. P A 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
IS 14 Derry Street
Harrisburg. P A 17104
(717) 232-9757
FAX (717) 234-2227
AGI'fM'........
Financial Counseling Services of Franklin
31 West :Jrd Street
Waynesboro, P A 17268
(717) 762'.-3285
YWCA of Carlisle
301 G Street
Carlisle, I>>A 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
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IN RE:
OWEN ORVILLE KRICK, :
a Minor
IN THE COIURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
.
.
NO. 98 - 7:29
ORPHANS'
ORDER OF .COURT
AND NOW, this 5 ni day of (] (!.. 1:.. . ~. 1998,' upon consideration of
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CUmberland County. Pennsylvania, and to execute said mortgage on behalf of their minor son. I
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Petioner's Petition, and after a hearing on this matter held September 30, 1996. it is hereby
ordered that Petitioners HARRY O. KRICK, Jr., and CRrCI<:ET M. KRrCK are hereby
authorized to place a mortgage on the property at 115 South George Street, Mechanicsburg,
OWEN ORVILLE KRICK, a part owner of the aforesaid pmperty.
l.,<l~M e.~4
.pwy-/ deorge E. err PJ
A TP.Vi; CO?'! F?CM RECORD
In Tt{1tlt:~;...~, .:."', .~.; ~~. t f1 :~t."~n}') ::'~! I'!!}' h~nd
$~~~;l~ -
Cumbertend Ooonty BK J 116 PG 0 9 9 9
~
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
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,
505 City Parkway West
Suite 100
Orange, CA 92868
IN TIm COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
'IS.
No. 04-1142 CIVIL TERM
CRICKET M. KRICK and HARRY O. KRICK JR.,
Individually and as guardians of OWEN ORVILLE
KRICK
115 S. George Street
Mechanicsburg, P A 17055
ORDER
AND NOW, this/..2-~ayof~
, 2004, upon consideration of the
: I
Motion to Amend Complaint and Memorandum of Lav' ;Jnd Response (if any) filed by
Defendants, it is hereby
ORDERED that Plaintiff is hereby authorized to file and serve upon Defendants an
Amended Complaint in the form attached to this motion as Exhibi1tB.
BY THE COURT:
)41i~ ~ ~
J.
TAUI: COPY FROM RECORU
tn T Ntimony wher6Of, I here unto set my haftd
and the neat of said Court at CarlisJe. Pa.
~~~y~ (2~zl::o/;:
J Prothonotary
VERIFICATION
JOSEPH A. GOLDBECK, JR. hereby states that he is the attomey for Plaintiff herein, and that all of the
facts set forth in the attached Amended Complaint are true and correct to the best of his knowledge, information
and belief.
The undersigned understands that statements herein are made subject to the penalties of 18 P.S., section
4904.
------
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GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SIlITR 50lltI - MF,I"'oN INOF,PF.NORNCF, CF,NTF,R
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 2002-4 UNDER
THE POOLING AND SERVICING AGREEMENT
DATED AS FO NOVEMBER 1,2002, WITHOUT
RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CNIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
vs.
Term
No. 04-1142 CNIL TERM
CRICKET M. KRICK and HARRY O. KRICK JR.
Mortgagor(s)
115 S. George Street
Mechanicsburg, PA \7055
Defendant(s)
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on / 6? / 13 / tJ 'i
he did serve upon Defendant(s) CRICKET M. KRICK and HARRY O. KRICK JR. a true and correct
copy ofthe above-captioned Amended Complaint by certified and regular mail Pursuant to Rule
440(a)(2)(ii). The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
RespectfullY subm itted,
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GOLDBECK MccAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK. JR. ESQUIRE
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-01142 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
KRICK CRICKET M 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
KRICK HARRY 0 JR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, KRICK HARRY 0 JR
116 NORTH HANOVER STREET #5
CARLISLE, PA 17013
KRICKS WERE EVICTED FROM 116 N HANOVER ST CARLISLE.
THEIR MAIL IS BEING HELD AT POST OFFICE.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
6.00
.00
5.00
10.00
.00
21.00
So ans~S/... .' / > ... .......... ~~
~~::~~
R. T~S Kline
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
01/04/2005
Sworn and subscribed to before me
this
*'
IV -
day of 0.-<"'7
.J
.,)il1J5 A.D.
p~taS
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-01142 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
KRICK CRICKET M 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
KRICK CRICKET M
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, KRICK CRICKET M
116 NORTH HANOVER STREET #5
CARLISLE, PA 17013
KRICKS WERE EVICTED FROM 116 N HANOVER ST CARLISLE.
THEIR MAIL IS BEING HELD AT POST OFFICE.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
3.70
5.00
10.00
.00
36.70
So answers-'-___~
-,"-::..-:~~"'::::
~' ji7~~'::;;0-~
/ R.' ThofuSs Kline
Sheriff of Cumberland County
~
GOLDBECK MCCAFFERTY MCKEEVER
01/04/2005
Sworn and subscribed to before me
this
""
1'1 -
/~,
day of YA>>A-J
2/JV( A. D.
, ){1t' Q 'Jh,pi" , #
Pro honotary ,
-
GOLDBECK McCAFFERTY & McKEEVER
BY: Jo'seph A. Goldbeck, Jr.
Attorney 1.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,
SERlES 2002-4 UNDER THE POOUNG AND SERVICING
AGREEMENT DATED AS FO NOVEMBER I, 2002,
WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
Plaintiff
ACTION OF MORTGAGE FORECLOSURE
vs,
CRICKET M, KRICK Individually and as guardian afminor
child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian of minor
child OWEN ORVILLE KRICK
(Mortgagor(s) and Record owner(s))
115 S. George Street
Mechanicsburg, P A 17055
No. 04-1142 CIVIL TERM
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMP ANY, AS TRUSTEE OF
AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4
UNDER THE POOLING AND SERVICING AGREEMENT DATED AS FO NOVEMBER I, 2002, WITHOUT
RECOURSE, and against CRICKET M, KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK and
HARRY 0, KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK for failure to file an
Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from
the date of service of the Complaint, in the sum of $96,446.25.
Joseph A. GoldbecK, r.
Attorney for Plaintiff
I hereby certify that the above names are correct and that the precise resid nce address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED P ASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West
Suite 100 Orange, CA 92868 and that the name(s) and last knowu address(es) of the Defendant(s) is/are CRICKET M.
KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK, 115 S. George Street Mechanicsburg, PA
17055 and HARRY 0, KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK, lIS S. George
Street Mechanicsburg, P A 17055; f\
GOLDBEC
BY: Joseph A. 0
Attorney for Plaintiff\
\
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
$80,883.72
Interest from 1 % 1/2003 through
03/29/2005
$9,505.86
Attorney's Fee at 5.0000% ofpnncipal
balance
$4,044.19
Late Charges
$596.35
Costs of Suit and Title Search
$900.00
Escrow Balance Deficit
$516.13
($0.00)
$96,446.25
GOLDBECK
BY: Joseph A, Goldbe
Attorney for Plaintiff
AND NOW, this /.J+~ day of ~p~' L ,2005 damages are assessed as above.
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-Mili tary 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, CRICKET M. KRICK
Individually and as guardian of minor child OWEN ORVILLE KRICK,
is about unknown years of age, that Defendant's last known
residence is 115 S. George Street, Mechanicsburg, PA 17055, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Mili tary 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, HARRY O. KRICK JR.
Individually and as guardian of minor child OWEN ORVILLE KRICK,
is about unknown years of age, that Defendant's last known
residence is 115 S. George Street, Mechanicsburg, PA 17055, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE
,OF AMERlQUEST MORTGAGE SECURITIES INC., ASSET
BACKED P ASS-THROUGH CERTIFICATES, SERIES 2002-4
UNDER THE POOLING AND SERVICING AGREEMENT DATED
AS FO NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
Plaintiff
No. 04-1142 CIVIL TERM
vs.
CRICKET M, KRICK Individually and as guardian of minor child
OWEN ORVILLE KRICK
HARRY O. KRICK JR, Individually and as guardian afminar child
OWEN ORVILLE KRICK
(Mortgagor(s) and Record Owner(s))
115 S. George Street
Mechanicsburg, P A 17055
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 CRICKET M. KRICK Individually and as guardian afminar child
OWEN ORVILLE KRICK and HARRY O. KRICK]R, Individually and as guardian afminar child OWEN ORVILLE KRICK by default
for want of an Answer.
Assess damages as follows:
$96,446.25
Debt
Interest - 1010112003 to 0312912005
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the arty against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at st ten ys prior to the date of the
filing of this praecipe, A copy of the notice is attached. RC.P, 237.1
AND NOW , J dgme t is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES lNG, ASSET
BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED
AS FO NOVEMBER 1,2002, WITHOUT RECOURSE and against CRICKET M, KRICK Individually and as guardian of minor child
OWEN ORVILLE KRICK and HARRY O. KRICK JR. Individually and as guardian afminor child OWEN ORVILLE KRICK by dcfault
for want of an Answer and damages assessed in the sum of $96,446.25 as per the above certification.
Prothonotary
- ----------------------------------
AMQ-0167
. THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERlQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS.THROUGH CERTIFICATES,
SERIES 20024 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS
FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway We$t
Suite loo
Orange, CA 92868
In the Court of COllUTlOn Pleas
of Cumberland County
CIVIL ACTION. LAW
ACTION OF
MORTGAGE FORECLOSURE
Plaintiff
Tenn
No. 04-1142 C[V\L TERM
v,
CRlCKET M. KRICK lndividually and as guardian of minoT child OWEN ORVILLE
KRICK
HARRY O. KRICK JR. lndividuatly and as guardian of minor child OWEN ORVILLE
KRICK
(Moltgagor(s) and Record Ownel'{s))
115 S. George Street
Mechanicsburg, PA 17055
Defendant(s)
TO: CRICKET M. KRICK Individually aud as guardian of minor child OWEN ORVILLE KRICK
I \ 5 S. George Street
Mcchanicsburg, PA 17055
IMPORT A NT NOTlCR
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER 1\ WRllTEN 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 WSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS 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 1\ LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU wrrn
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGlBLE PERSONS AT A REOUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle., PAt 70 13
717-243.9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty A venue
Carlisle,PA 17013
~~
GOLDBECK MeCAFFERTY & MeKEEVER
BY: Joseph A. Goldbeck. Jr" Esq. ___~_ ___ ______~___
Attorney for Plaintiff
Suite 5000 - Mellon IndqJcndence Center
701 Mwkct Street
Philadelphia, P A 19106 215-627-1322
AMQ-0167
.THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURfTlES INC.. ASSET BACKED PASS-THROUGH CERTIFICATES,
SERIES 2002.4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS
FO NOVEMBER I, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
In the Court of Common Pleas
of o.unba"land County
CIVIL ACTION . LAW
ACTION OF
MORTGAGE FORECLOSURE
Plaintiff
Tenn
1'0.04.1142 CIVIL TERM
YS.
CRICKEr M. KRICK Individually and as guardian of minor child OWEN ORVILLE
KRICK
HARRY O. KRlCK JR. lndividu<llly and as guardian of minor child OWEN ORVILLE
KRICK
(Mortgl'lgot1S) and Record Owner(s))
I. 15 S. George Street
Mechanicsburg, PA 17055
Oefendant(s)
TO: HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
TMPORT ANT NOTTCF.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRrITEN APPEARANCE PERSONALLY OR BY ATIORNEY AND
FILE iN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHiN TEN (] 0) DAYS FROM THE DATE OF THlS NOTICE, A JUDGMENT MAYBE ENTERED AGAiNST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RlGIITS. YOU SHOULD TAKETHlS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH iNFORMATiON
ABOUT HIRiNG A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCiES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES iNC
8 Irvine Row
Carlisle, PA 170/3
7]7.243.9400
CUMBERLAND COUNTY BAR ASSOCIA T]ON
2 Liberty Avenue
Caliisle, P A 17013
;fJIt~
GOLDBECK M,CAFFERTY & M,KEEVER
BY: Joseph A. Goldbeck, Jr:~_
Attorney for Plaintiff
Suite 5000 - Mellon Independence Center
70 I Market Stl-eet
Philadelphia, PA t9106 215-627-1322
AMQ-0167
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
CRICKET M. KRICK IndividuaUy and as guardian of minor child OWEN ORVll..LE KRICK
116 N Hanover Street 5
Carlisle. P A 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES,
SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT 0/\ TED AS
FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION. LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Tonn
No. 04.1142 CIVIL TERM
vs.
CRlCKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE
KRICK
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE
KRICK
(Mortgagor(s) and Record Owner(s))
115 S. George Street
Mechanicsburg, PA 17055
Defendant(.<,)
TO: CRICKET M. KRICK IndividuaUy and as guardian of minor child OWEN ORVILLE KRICK
116 N Hanover Street 5
Carlisle, P A 17013
IMPORT A NT NOTlC'F.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIITEN 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 (1 0) 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 TillS PAPER TO YOUR LA WYER AT ONCE. IF YOU 00
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAYBE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT M/\ Y OFFER LEGAL SERVICES TO EUGlBLE PERSONS AT A REDUCED FEE OR NO FEE
LEGAL SERVICES INC
8 bvine Row
Carlisle, PAt 70 13
717.243.9400
CUMBERLAND COUNTY BAR /\SSOCIA TION
2 Liberty Avenue
Carlisle, PA 170lJ
EVER
-----------
---------------
- -----------------------
AMQ-0167
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT, ANY INFORMA nON OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
HARRY O. KRICK JR. Individuaily and as guardian of minor child OWEN ORVll.LE KRICK
116 N Hanover Street 5
Carlisle, P A 17013
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERlQUEST
MORTGAGE SECURITIES INc., ASSET BACKED PASS.THROUGH CERTIFICATES,
SERIES 2002-4 UNDER THE POOUNG AND SERVICfNG AGREEMENT DATED AS
FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway West
Suite tOO
Orange, CA 92868
[n the Court of Common Pleas
of Cumberland County
CIVIL ACTION . LAW
ACTION OF
MORTGAGE FORECLOSURE
?faintiff
TenT!
No. 04.1142 CIVIL TERM
vs.
CRICKET M. KRICK lndivldually and as guardian ofminm child OWEN ORVlLLE
KRICK
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE
KRICK
(Mortgagor(s) and Record OwneJ{s))
liS S. George Street
Mcchanicsburg, PA 17055
Defendant(s}
TO: HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
116 N Hanover Street 5
Carlisle, P A 17013
TMPORTANTNOTTCF,
YOU ARE fN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRmEN APPEARANCE PERSONALLY OR BY A TlORNEY AND
FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE ClAlMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (10) DAYS FROM THE DATE OF 11IIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARlNG AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGlITS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR 'TELEPHONE THE omCE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFlCE MAY BE ABLE TO PROVIDE YOU WITH
INfORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 ltvtne Row
Carlisle,PA 170J3
717-243.9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Uhe!ty Avenue
Cal1isle, PA 170]3
-fi?'t~
.______________ _ _ _________-=LDBECK-McCAI'J1ERl'\'-&.M~----------
BY: Joseph A. Goldbock, Ir., Esq
Attorney for Plaintiff
Suhe 5000 - Mellon Independence Center
701 Ma.rkel Street
Philadelphia, PA 19106 215-627-1322
-----------
~._._~----------
-------------
- -- -- - -- --------
AMQ-0167
'THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
CRICKET M. KRICK Individually and as gnardian of minor child OWEN ORVILLE KRICK
807 CNUS Hwy15
DiIl,burg, P A 17019
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE Of AMERIQUEST
MORTGAGE SECURITIES ING, ASSET BACKED PASS.THROUGH CERTIFICATES,
SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS
FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION. LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Tem
No. 04.] 142 CIVIL TERM
YS.
CRICKET M. KRlCK lndividually and itS guardian of minor child OWEN ORVILLE
KRICK
HARRY O. KRJCK JR_ lndividually and as guardian of ItItoorcbild OWEN ORVILLE
KRICK
(Moltgagor(s) and Record Ownel{s))
115 S. George Street
Mechanicsburg, PA 17055
Deftnda/tr(s}
TO: CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
807 CN US Hwy IS
Dillsburg, PA 17019
IMPORT A NT NOTTCF.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIITEN APPEARANCE PERSONALLY OR BY A1TORNEY AND
FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SEf 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 HEARlNG AND YOU
MAY lDSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, 00 TO OR TELEPHONE THE OFfiCE SET FORTH BElDW 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 THAr MAY OfFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES lNC
8 Irvine Row
Carlisle, PA 17013
7]7-243.9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 liberty A venue:
Carlisle, P A ] 70 13
C McCAFFERT
B . oscph A. Goldbeck, Jr., Esq.
__,_,_________~___..___.~ _ ____._.___.__.______.__________~'"_ ___ __----Attgmey..fer-Waifltiff..--.------.-------~--------.-~
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106 215-627-1322
AMQ-0167
,
.THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: March 3, 2005
TO:
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
807 eN us Hwy 15
Dillsburg, P A 17019
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS.THROUGH CERTIFICATES,
SERIES 20024 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS
FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
[n the Court 'Of Common Pleas
of Cumberla.nd County
CfVILACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Plaintiff
Tenn
1'0.04.1142 CIVIL TERM
vs.
CRICKET M. KRICK Individually and as guardian of minor cbild OWEN ORVILLE
KRICK
HARRY O. KRICK JR, lndividuaHy and as guardian of minor child OWEN ORVILLE
KRICK
(MOItgagor(s) and Record Ownerts))
115 S. Gemge Street
Mecbanicsburg, PA 17055
Defendalll(s)
TO: HARRY O. KRICK JR. Individually and as guardla. of minor child OWEN ORVILLE KRICK
807 CN US Hwy 15
Dillsburg, PA 17019
IMPORT A NT NOTICF
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRJTIEN APPEARANCE PERSONALLY OR BY A TIORNEY AND
FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECfIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (I 0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOur A HEARING AND YOU
MAY WSE YOUR PROPERTY OR OTHER lMPORT ANT RJGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU 00
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HlRlNG A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH
INFORMAT10N ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 hine Row
Carlisle, PA 17013
717-24J.9400
CUMBERLAND COUNTY BAR ASSOClA TION
2 Uberty Avenue
Carlisle, PA 17013
:fJ't~
- --- ~---- ----- -- --------.------~--_GObI)BEGKMcA;AFFER~&_MelffiE\lER_---.---~,-
BY: Joseph A. Goldbeck, Jr., Esq
Attorney for Plaintiff
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106 215-627-1322
--v::,.
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------
Rl!le ot"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 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
Plaintiff
No. 04-1142 CIVIL TERM
VS.
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
(Mortgagors and Record Owner(s))
115 S. George Street
Mechanicsburg, P A 17055
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothonotary
~~ ()~ C - 2 ./~Cl2frz.1.ul
Deputy
If you have any questions concerning the above, please contact:
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19]06
2]5-627-]322
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
,
-
JoseJlii A Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
70 I 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 P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER
THE POOLING AND SERVICING AGREEMENT
DATED AS FO NOVEMBER 1, 2002, WITHOUT
RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
vs.
No. 04-1142 CIVIL TERM
CRICKET M. KRICK Individually and as guardian of
minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian of
minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
115 S. George Street
Mechanicsburg, P A 17055
Defendant( s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$96,446.25
Interest from
10/0 1/2003 to
03/29/2005 at
7.7500%
(Costs to be added)
GOLDBECK M
BY: Joseph A
Attorney for Plai
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ALL THAT CERTAIN part lot or piece of ground situate, lying and being in the City of
Shamokin, formerly the Borough of Sham ok in, County of Northumberland and Commonwealth
of Pennsylvania, and being known, designated, and described on the general plot or plan of said
City of Sham ok in, as a portion of Lot-numbered Thirty-Eight (38) in Block numbered One
Hundred Fifty-Two (152) and being more particularly bounded and described as f(Jllows, to wit:
BEGINNING at a point on the South side of Sunbury Street, said point being Eight-seven (87)
Feet, One (I) Inch East of the southeastern comer of Franklin and Sunbury Streets, and being on
the division line between Lots numbered Thirty-eight (38) and Thirty-nine (39) in Block
numbered One Hundred Fifty-Two (152); thence in a southerly direction and parallel with
Franklin Street, along the division line between Lots Numbered Thirty-Eight (38) and Thirty-
nine in said Block numbered One Hundred Fifty-Two (] 52); one hundred (i 00) feet to a point;
thence in a westerly direction parallel with Sunbury Street, twenty (20) Feet and Eight (8) Inches
to a point; thence in a northerly direction and parallel with Franklin Street through the middle of
the partition wall which divides thc dwelling erected upon the place of ground intended hercby to
be conveyed tl'om the dwelling adjoining it on the West One Hundred (100) Feet to the southem
line of Sunbury Street in an easterly direction along the southern line of Sunbury Street; Twenty
(20) Feet and Eight (8) inches to the place of Beginning, and having erected thereon one. three-
story (3) brick dwelling of row of Three (3) brick dwellings and known as 608 East Sunbury
Street.
Tax Parcel No. 20-24-0785
Having thereon erected a dwelling known as 115 S. George Street. Mechanicsburg, P A ! 7055
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-1142 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 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff(s)
From CRICKET M. KRICK INDIVIDUALLY AND AS GUARDIAN OF MINOR CHILD
OWEN ORVILLE KRICK, HARRY O. KRICK, JR. INDIVIDUALLY AND AS GUARDIAN OF
MINOR CHILD OWEN ORVILLE KRICK
(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) Ifproperty 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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $96,446.25
Interest FROM 1011/03 TO 3/29/05 AT 7.7500%
Atty's Corom %
Atty Paid $204.40
Plaintiff Paid
Date: APRIL 4, 2005
L. L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothon:a p 7 .
~: fVL f/ 7J- "z/2cLu
Deputy
.------
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQillRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court lD No. 16132
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney 1.D. #16132
Suite 50,QO - Mellon Independence Center
701 Market Street
Philadelphia, P A 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 2002-4
UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1, 2002,
WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
vs.
CRICKET M. KRICK Individually and as guardian of
minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
(Mortgagor(s) and Record Owner(s}}
115 S. George Street
Mechanicsburg, P A 17055
No. 04-1142 CIVIL TERM
Defendant( s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,2002, 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:
115 S. George Street
Mechanicsburg, P A 17055
I.Name and address ofOwner(s) or Reputed Owner(s):
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg. P A 17055
HARRY O. KRICK JR. Individually and as gUludian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
2. Name and address ofDefendant(s) in the judgment:
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
liS S. George Street
Mechanicsburg, P A 17055
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, PAl 7055
3. Nam" iind 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
P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be aflected 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
115 S. George Street
Mechanicsburg, P A 17055
(attach separate sheet if more space is needed)
[ verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOLDBECK McCA
BY: Joseph A. Goldbec
Attorney for Plaintitl
DATED: March 29. 2005
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04-1142 CIVIL TERM
...
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorneyl.D.#16132
Suite 5000- Mellon Independence Center
70 I Market Street
Philadelphia, P A 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 2002-4 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS FO
NOVEMBER I, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
vs.
Term
No. 04-1142 CIVIL TERM
CRICKET M. KRICK Individually and as guardian
of minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
liS S. George Street
Mechanicsburg, P A 17055
Defendant( s
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: KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK, CRICKET M.
CRICKET M. KRICK Individually and as guardian of minor child OWEN
ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
Your house at 115 S. George Street, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs
Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $96,446.25 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED
1
""
04-1142 CIVIL TERM
PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER I, 2002, WITHOUT RECOURSE against yon.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you mnst take innnediate action:
1. The sale will be cancelled if yon pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER I, 2002, WITHOUT RECOURSE, the back payments, late
charges, costs and reasonable attorney's fees dne. To find ont how mnch yon mnst pay call:
215-627-1322
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 Conrt to postpone the sale for good cause.
3. Yon 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.
I. 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 bnyer pays the Sheriff the full amount due in the sale. To find
ont if this has happened, you may call the Sheriff of717-240-6390.
4. If the amonnt due from the Buyer is not paid to the Sheriff, yon will remain the owner ofthe
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
distribntion of the money bid for your house will be filed by the Sheriff 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 distribntion is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
04-1142 CIVIL TERM
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04-1142 CIVIL TERM
tjOLDBECK McCAFFERTY & McKEEVER
flY: Joseph A. Goldbeck, Jr.
, AttorneyID.#16I32
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 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 2002-4 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS FO
NOVEMBER I, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
vs.
Term
No. 04-1142 CIVIL TERM
CRICKET M. KRICK Individually and as guardian
of minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
115 S. George Street
Mechanicsburg, P A 17055
Defendant( s
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: KRiCK JR. Individually and as guardian of minor child OWEN ORVlLLE KRICK, HARRY o.
HARRY O. KRICK ,JR. Individually and as guardian of minor child OWEN
ORVILLE KRICK
I] 5 S. George Street
Mechanicsburg, P A 17055
Your house at lIS S. George Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs
Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $96,446.25 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED
04-1142 CIVIL TERM
.
~SS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER I, 2002, WITHOUT RECOURSE against you.
NOTICE OF OWNER'S RIGHTS
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 P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the jndgment 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.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
ont the price bid price by calling the Sheriff of717-240-6390.
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 ifthis has happened, you may call the Sheriff of71 7-240-6390.
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 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 (] 0) 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
inunediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, P A 17013
04-1142 CIVIL TERM
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attome for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-
THROUGH CER TIFICA TES, SERIES 2002-4 UNDER
THE POOLING AND SERVICING AGREEMENT
DATED AS FO NOVEMBER I, 2002, WITHOUT
RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
AMQ-0167
CF: 03/18/2004
SD: 09/07/2005
$96,446.25
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 04-1142 CIVIL TERM
Plaintiff
vs.
CRICKET M. KRICK Individually and as guardian of
minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian of
minor child OWEN ORVILLE KRICK
Mortgagor(s) and
Record Owner(s)
115 S. George Street
Mechanicsburg, PAl 7055
Defendant(s)
~
( )
( )
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defetan~fthe ~~~b~hH!~~ wsMdVia: N.D.S. ,iJJ't,' DII ill!" ID5
f~ersona~ce by the Sheriff's O~ce/.I .y~M".J 11 ( fJ'~" M~' Ill' i .
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).CnC(d:
Certified mail by Sheriff's Office. Jtll~
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record ()I\
(proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
( )
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.
Section 4904.
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Certified Mail Provides:
. A mailing receipt
. A unique identifier tor your mailp;ece
. A record of delivery kept by the Postal Service fOT two years
Imp.ortant Reminders:
. Certified Mail may QNL Y be combined with Fir5t~Class Ma;\.n! or Priority Maill!ll.
. Certified Mail is not available for any class of international mall. ~
. NO INSURANCE COVERAGE IS PROVIDED with Certified MaiL For
valuables, please consider Insured or Registered Mai\.
. For an additional fee, a Return Receipt may be requested tOJ'ToVide proof at
delivery. To obtain Return Receipt selVlce. pfease complete an attach a Return
Receipt (PS Form 3811) to the article and add applicable postage to cover the
tee. Endorse mailpiece ~Return Receipt Requested". To receive a tel, waiver tor
a duplicate return receipt, a USP$e postmark on your Certified Mall receipt is
reqUired.
. For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agl:lnt. Advise the clerk or mark the mailpiece with the
endorsement "Restricted-DeliveryN.
. If a postmark on the Certified Mail receipt is desired, please present the arti-
cle at the post office for postmarking. If a postmark on the Certified Mail
receipt is not needed, detach and affiX label with postage and mail.
IMPORTANT: Save this receipt and presenllt when making an inquiry.
Internet access to delivery information is not available on mail
addressed to APOs and fPOs.
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See Reverse/Of Instructions
Certified Mail Provides:
. A mailing receipt (9SJ(J/l9H) G:OOZ eunr 'ooa~ Lluo.:l Sd
. A unique identifier for your mailpiece
. A record of delivery kept by the Postal Service for two years
Iml?ortant RemInders:
. Certified Mail may ONLY be combined with First-Class Mai~ or Priority MaUll'}.
. Certified Maills not available for any class of international mail.
. NO INSURANCE COVERAGE IS PROViDED with Certified Mail. For
valuables, please consider Insured or Registered MaiL
. For an additional fee, a Return Receipt may be requested to provide proof of
delivery. To obtain Return Receipt selVlce, praasa complete and attach a Return
Receipt (PS Form 3811) to the article and add applicable postage to cover the
fee. Endorse mailpiece "Return Receipt Requested". To receive a fQe weiver for
a duplicate return receipt, a USPSqp postmark on your Certified MaJl receipt is
reqUIred.
. For an additional fee, delivery may be restricted to the addressee or
addressee's authorized ag!lnt. Advise the clerk or mark the mailpiece with the
endorsement "Restricted Delivery".
. If a postmark on the Certified Mail receipt is desired, please present the arti~
cle at the post office for postmarking. If a postmark on the Certified Mall
receipt is not needed, detach and affix label with postage and mail.
IMPORTANT: Save this receipt and presenl it when making an inquiry.
Internet access to delivery information is not available on mall
addressed to APOs and FPOs.
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· A r~cord of delivery kept by the POstal Service for two years
I,; lPOrtant Reminders:
· Ce,jified Mail may ONLY be combined with First.Ciass Mai.. 0' Prio.ity Mail"
. Certified Mail ;s nof available for any class of International mail,
· NO INSURANCE COVERAGE IS PROVIDED wilh Certified Mail. For
valuables, please consider Insured or Registered Mail.
· co, an additional fee, a Return Receipt may be requested to provide pmol 01
,fellve,\,. To obtain Return Receipt se"'ce, prease completa and attach a Return
fleceipl (PS Form 38111 to the article and add applicabla postage to COve, tha
fee. Endorse mailpiece Retum Receipt Requ_". To receiVe a fee waiver for
a duplicate return receipt, a USPs" postmark on YOur Certified Mail receip; is
ruQUlred.
· F,,, an additional fee, delive,\, may be restricted fo the addressee or
add.essee's authorized a.Qent. Advise the clerk or mark fhe mallplece with the
endorsement ~RestrictedDeljvery~
· If" postmark on the Certified Mail receipt is desired, please present fhe arti.
clo at the post office for POStmarking. tf a postmark on the Certified Mall
receipt is not needed, detach and affix label with POstage and mal/.
IMPORTANT: Savo Ihi. rOcolpland pro,ont it When making an InqUiry.
Inlornet a..O"'o delivery Informa"on I. nOlavailahle on mall
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II A maWng receipt (BSJaIIa1:J) <:OO(:'9unr 'OOSE: lfJO.::l Sd
n A unique identifier for your mailpiece
h A rocord of delivery kept by the Postal Service for two years
Important Reminders:
. Certified Mail may ONLY be combined with First.Class Mai~ or Priority Malle.
. Certified Mail is not available for any class of international mall.
. NO JNSURANCE COVERAGE IS PROVIDED with Certified Mail. For
valuables, please COnsider Insured or Registered Mail.
. For an additional fee, a Return Receipt may be requested to provide ~rOOf of
delivery. To obtain Return Receipt service, please complete and attach a Return
Receipt (PS Fonn 3811) to the article and add applicable postage to cQver the
fee. Endorse mailplece nRetum Receipt Requested". To receive a fee waiver for
a duplicate return receipt, a USP~ postmark on your Certified Malt re~eipt is
reqUIred.
. For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agent. Advise the clerk or mark the mailpiece with the
endorsement ORestrictedDe/iveryo.
. "a postmark on the Certified Mail receipt is desired, please present the arti-
cle at the post office for postmarking. It a postmark on the Certified Mail
receipt ;s not needed, detach and affix label with postage and mail.
IMPORTANT: Save this receipt and present it when making an inquiry.
Internel access to delivery Information Is nol available on mail
addressed to APOs and FPOs.
· Complete items 1, 2, and 3. Also complete
nem 4 if Restricted DaliYElf)' is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailplece,
or on the front If space permits.
1. Article Addressed to:
AMQ-01679/7
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KRICK Individually and as guc.
115 S. George Street'
Mechanicsburg, PA 17055
2. Article Number
"~~lI!llIIoo
PS Form 3811. February 2004
3. Service Type
1;1 CertIIIed Mall Cl Express Mall
o Registered CJ Return Receipt for Merchandise
lJ Insurad Mall CI C.O.D.
4. Restricted Delivery? ~_ Fee) lJ Yes
102596-02-M_1540
First-Class Mail
postage & Fees p'aid I
USPS
Permit No. G-10
. Sender: Please print your name, ~ dd r3~! , ~ lnd ZIP+4 ill this box.
~ un, ,
UNITED STATES POSTAl SERVICE
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GOLOBECKMCCAfFER""'( & MCKEE\fER
SiE 5000 _ MELLOU Hltl2.I'E.NDENCE CE.NiE.
701 MARKET ST
PHILADELPHIA PA 1!1103-\538
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED
PASS-THROUGH CERTIFICATES, SERIES 2002-4
UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER I,
2002, WIlliOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Term
No. 04-1142 CIVIL TERM
vs.
CRICKET M. KRICK Individually and as guardian of
minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
115 S. George Street
Mechanicsburg, PAl 7055
Defendant(s)
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS FO NOVEMBER I, 2002, 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:
liS S. George Street
Mechanicsburg, P A 17055
l.Name and address ofOwner(s) or Reputed Owner(s):
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
liS S. George Street
Mechanicsburg, P A 17055
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
410 South York Street
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
410 South York Street
Mechanicsburg, P A 17055
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 \7013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
CUMBERLAND COUNTY ADULT PROBATION
I COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
BOROUGH OF MECHANICSBURG
W. STRAWBERRY @NORTHMARKET STREET
MECHANICSBURG, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
115 S. George Street
Mechanicsburg, PA 17055
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: August 5, 2005
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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 Sheriffs Deed in which Central Penn Property Services Inc is the grantee the same having been sold
to said grantee on the 7th day of September A.D., 2005, under and by virtue of a writ Execution issued
on the 4th day of April, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term,
2004 Number 1142, at the suit of Ameriquest Mtg Securities Inc, Tr against Cricket M, Harry 0 Ir &
Owen Orville Krick, Guardian is duly recorded in Sheriffs Deed Book No. 271, Page 2454
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ~ day of cQ.{A-; A.D. 200S
Y>1:t 1 A U~~ (~~ 9
.. . i f t7
Recorder of Deeds, Cumberland ~ C8rtlsle PA
My Commission Expires the Fnt Mor1d8V of Jan.'2OOI
Recorder of Deeds
Deutsche Bank National Trust Company In The Court of Common Pleas of
Et al Cumberland County, Pennsylvania
VS Writ No. 2004-1142 Civil Term
Cricket M. Krick, individually and as guardian
Of minor child Owen Orville Krick and
Harry O. Krick, Jr., individually and as
Guardian of minor child Owen Orville Krick
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he made
a diligent search and inquiry for the within named defendant, to wit: Cricket M. Krick,
individually and as guardian of minor child Owen Orville Krick, but was unable to locate
her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania, to
serve the within Real Estate Writ, Notice of Sale and Description according to law.
York County Return: And Now, July 26, 2005 at 11 :00 o'clock AM, served the
within Real Estate Writ, Notice of Sale and Description upon Cricket M. Krick by
handing to Cricket M. Krick personally at 807C North Route 15, Dillsburg, PA 17019.
So Answers: William M. Hose, Sheriff of York County, Pennsylvania.
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on June 16,2005 at 7:40 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Harry O. Krick, Jr., individually and as guardian of
minor child Owen Orville Krick, by making known unto Harry O. Krick, personally, at
The Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County,
Pennsylvania, its contents and at the same time handing to him personally the said true
and correct copy of the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on July 11,2005 at 3:50 o'clock P.M., he posted a true copy ofthe within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Cricket M. Krick and Harry O. Crick, Jr., individually and as guardian of minor child
Owen Orville Krick, located at 115 South George St., Mechanicsburg, 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
defendant, to wit: Cricket M. Krick, by regular mail to her last known address of 807C
North Route 15, Dillsburg, P A 17109. This letter was mailed under the date of August
25,2005 and never returned to the Sheriffs Office.
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
defendant, to wit: Harry O. Krick, by regular mail to his last known address of
Cumberland County Prison, 1101 Claremont Road, Carlisle, P A 17013. This letter was
mailed under the date of July 01,2005 and never returned to the Sheriffs 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, Carlisle, Cumberland
County, Pennsylvania on September 7,2005 at 10:00 o'clock A.M. He sold the same for
the sum of $74,010.00 to Andrew O'Dell for Central Penn Property Services, Inc. It
being the highest bid and best price received for the same, Central Penn Property
Services, Inc. of 100 South 7th Street, Akron, P A 17501, being the buyer in this
execution, paid to SheriffR. Thomas Kline the sum of74,010.00.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Out of County
York County
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
$30.00
1,480.20
15.00
15.00
30.00
10.00
.50
1.00
8.00
6.28
15.00
30.00
9.00
58.88
347.00
317.36
18.20
25.00
39.50
$ 2,455.92
Sworn and subscribed to before me
2005, A.D.
So Answers:
r~~~
R. Thomas Kline, Sheriff
BY .J ~ CLv] )'jrvJL ~
Real Estate sergeant
~~
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3D ';)D
I. c.k. '). j{, J... 'i
~. /101/1
Goldbeck McCafferty & McKeever ~
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERlQUEST
MORTGAGE SECURITIES INC., ASSET BACKED
PASS-THROUGH CERTIFICATES, SERIES 2002-4
UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1,2002,
WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
vs.
CRICKET M. KRICK Individually and as guardian of
minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
(Mortgagor(s) and Record Owner(s))
115 S. George Street
Mechanicsburg, P A 17055
No. 04-1142 CIVIL TERM
Dcfendant( s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE
SECURlTIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOUNG
AND SERVICING AGREEMENT DATED AS FO NOVEMBER 1,2002, 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:
liS S. George Street
Mechanicsburg, P A 17055
I.Name and address of Owner(s) or Reputed Owner(s):
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg. P A 17055
2. Name and address of Defendant(s) in the judgment:
CRICKET M. KRICK Individually and as guardian of minor child OWEN ORVILLE KRICK
liS S. George Street
Mechanicsburg, P A 17055
HARRY O. KRICK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
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
P A DEP AR TMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, P A 171 05-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUP ANTS
115 S. George Street
Mechanicsburg, PAl 7055
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
infonnation and belief. 1 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: March 29, 2005
(/
',---
GOLDBECK :rylcCA 1':
BY: Joseph A. Goldbec
Attomey for PlaintitT
I
\ '
~
\
\
\
04-1142 CIVIL TERM
,
.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 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 2002-4 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS FO
NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
vs.
Term
No. 04-1142 CIVIL TERM
CRICKET M. KRICK Individually and as guardian
of minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
115 S. George Street
Mechanicsburg, P A 17055
Defendant( s
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: KR1CK JR. Individually and as guardian of minor child OWEN ORVILLE KRICK, HARRY O.
HARRY O. KRICK .JR. Individually and as guardian of minor child OWEN
ORVILLE KRICK
115 S. George Street
Mechanicsburg, PAl 7055
Your house at 115 S. George Street, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriff's
Sale on Wednesday, September 07,2005, at 10:00 MI, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $96.446.25 obtained by DEUTSCHE BANK NA T10NAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED
,
.
04-1142 CIVIL TERM
PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1, 2002, WITHOUT RECOURSE against you.
NOTICE OF OWNER'S RIGHTS
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 P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717 -240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
4. Ifthe 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 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
inunediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
.
~
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty A venue
Carlisle, P A 17013
04-1142 CIVIL TERM
04-1142 CNIL TERM
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.# 16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMP ANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2002-4 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS FO
NOVEMBER 1, 2002, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
vs.
Term
No. 04-1142 CIVIL TERM
CRICKET M. KRICK Individually and as guardian
of minor child OWEN ORVILLE KRICK
HARRY O. KRICK JR. Individually and as guardian
of minor child OWEN ORVILLE KRICK
Mortgagor(s) and Record Owner(s)
115 S. George Street
Mechanicsburg, P A 17055
Defendant( s
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: . KRICK Individually and as guardian of minor child OWEN ORVILLE KRlCK, CRICKET M.
CRICKET M. KRICK Individually and as guardian of minor child OWEN
ORVILLE KRICK
115 S. George Street
Mechanicsburg, P A 17055
Your house at 115 S. George Street, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs
Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $96,446 .25 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED
04-1142 CIVIL TERM
PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING MID SERVICING
AGREEMENT DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE against you.
NOTICE OF OWNER'S RIGHTS
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 P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS FO NOVEMBER 1,2002, WITHOUT RECOURSE, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
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 STll.,L 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 of7l7-240-6390.
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 tlle money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, P A 17013
04-1142 CIVIL TERM
ALL THAT CERTAIN TRIANGULAR LOT OF GROUND SITUATE ON THE EAST SIDE
OF GEORGE STREET IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS
FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF SAID GEORGE STREET
MARKED BY A MONUMENT CORNER OF LANDS OF THE UNITED STATES OF
AMERICA; 11IENCE IN A NORTHERLY DIRECTION ALONG 'fHE EAS'fERN LINE OF
SAID GEORGE STREET 63.5 FEET TO A POINT AT CORNER OF LOT NO. 11 ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN AN EASTERLY DIRECTION
ALONG THE LINE OF SAID LOT NO. 11,310 FEET MORE OR LESS, TO AN IRON PIN
AT CORNER OF LANDS NOW OR FORMERLY OF MAY SUL TZENBERGER AND
OTHERS; THENCE IN A WESTERLY DIRECTION ALONG LANDS OF THE UNITED
STATES OF AMERICA, 314.46 FEET TO A POINT ON THE EASTERN LINE OF SAID
GEORGE STREET AND AT THE PLACE OF BEGINNING.
BEING LOT NO. 12 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND
COUNTY, IN PLAN BOOK 4 AT PAGE 4.
TAX PARCEL NO. 20-24-0785
BEING KNOWN AS PROPERTY 115 S. GEORGE STREET, MECHANICSBURG, PA
17055
WRIT OF EXE;CUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
NO 04-1142 Civil
CIVIL ACTION - LAW
AS TRUSTEE OF AMERlQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS-
THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff (s)
From CRICKET M. KRICK INDIVIDUALLY AND AS GUARDIAN OF MINOR CHILD
OWEN ORVILLE KRICK, HARRY O. KRICK, JR. INDIVIDUALLY AND AS GUARDIAN OF
MINOR CHILD OWEN ORVILLE KRICK
(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 $96,446.25
Interest FROM 10/l/03 TO 3/29/05 AT 7.7500%
L.L. $.50
Atty's Comm %
Atty Paid $204.40
Plaintiff Paid
Date: APRIL 4, 2005
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonot~
~.A'-U?/1o..r ~2 7~4/7~Y"_ .~
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: 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 #27
On May 17, 2005 the Sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, P A
Known and numbered as 115 South George Street,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: May 17,2005
By: J ocL..{ JYVL'rtJ,
Real Estate Deputy
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SCHEDULE OF DISTRIBUTION
SALE NO. 27
Date Filed: October 7, 2005
Writ No. 2004-1142 Civil Term
Deutsche Bank, National Trust Company, as Trustee of Ameriquest Mortgage Securities,
Inc., Asset Backed Pass-Through Certificates, Series 2002-4 Under the Pooling and
Servicing Agreement Dated as November 1,2002, without recourse
VS
Cricket M. Krick, individually and as guardian of minor child Owen Orville Krick, and
Harry O. Krick, Jr., individually and as guardian of minor child Owen Orville Krick
115 South George Street
Mechanicsburg, P A 17055
Sale Date:
Buyer:
Bid Price:
September 7, 2005
Central Penn Property Services, Inc.
$74,010.00
Real Debt:
Interest:
Attorney Costs:
$96,446.25
11,141.12
204.40
Total:
$107,791.77
DISTRIBUTION:
Receipts:
Cash on account (05/09/2005):
Cash on account (09/07/2005):
Cash on account (09/22/2005):
$ 1,500.00
7,401.00
70,077.80
Total Receipts:
$78,978.80
Disbursements:
Sheriffs Costs
Legal Search
State Transfer Tax
Local Transfer Tax
Mechanicsburg Borough
Attorney Joseph Goldbeck
Deutsche Bank, National Trust Company
Total Disbursements:
Balance for distribution:
So Answers:
r~-r~
R. Thomas Kline
Sheriff
$ 2,455.92
200.00
894.30
894.30
1,504.17
1,500.00
71,530.11
($78,978.80)
0.00
.. "
I
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECf TO THE FOLLOWING
ITEMS, WHICH WILL BE EXCEPfED IN THE POLICY UNLESS SATISFACfORY
EVIDENCE PERMITfING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 27
Held Wednesday, September 7, 2005
Date: September 7, 2005
T AXES: Receipts for all taxes for the years 2002 to 2004 inclusive. Taxes for the current year
2005.
WATER RENT:
SEWER RENT
Company assumes no liability for private supply of water or sewer.
Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIP AL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated ,2005, and recorded
, 2005, in Cumberland County Deed Book , Page
RECITAL: Being the same premises which Miriam Burdge Crick, by deed dated April 9, 1999
and recorded April 21, 1999 in the Office of the Recorder of Deeds in and for Cumberland
County, at Carlisle Pennsylvania, in Deed Book 197, Page 942, granted and conveyed to Harry
O. Crick, Jr., and Cricket M. Crick, husband and wife, and Owen Orville Crick..
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area
and encroachments which an accurate and complete survey would disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of George Street.
6. Mortgage in the amount of $81,600.00 given by Sherry O. Crick and Cricket M. Crick
to Ameriquest Mortgage Company dated August 28, 2002 and recorded October 4,
2002 in Mortgage Book 1776, Page 982. Said mortgage was assigned to Deutsche
-
Bank National Trust Company, Trustee of Ameriquest Mortgage Securities, Inc., by
instrument recorded June 18,2004 in Miscellaneous Book 709, Page 749.
Complaint in mortgage foreclosure filed by Deutsche Bank National Bank versus
Cricket M. Crick and Harry O. Crick, Jr., in the Office of the Prothonotary of
Cumberland County on March 18,2004, to File No. 2004-1142. Judgment in the
amount of $96,446.25 entered April 4, 2005.
7. Municipal lien filed by the Mechanicsburg Borough against Harry O. Crick, Jr.,
Cricket M. Crick, and Owen O. Crick, as Defendants, on August 11, 2004 to File No.
2004-3954 in the amount of $581.77.
8. Judgement in the amount of $2,971.92 entered by Cumberland County, Adult
Probation Office, Plaintiff, against Harry O. Crick, Jr., as Defendant on December 1,
2004 to File NO. 2004-6016. Said judgment is a lien on the subject premises by
virtue of a divorce of Cricket M. Crick and Harry O. Crick, Jr., entered September 26,
2003 to File No. 2003-5116.
9. Rights granted to the Bell Telephone Company of Pennsylvania by instrument
recorded February 3, 1948 in Miscellaneous Record Book 88, Page 113.
10. Rights granted to Pennsylvania Power and Light Company by instrument recorded
February 16, 1948 in Miscellaneous Record Book 88, Page 163.
11. Building conditions and setbacks as shown on or set forth on the Plan of Lots known
as Green Acres recorded in Cumberland County Plan Book 4, Page 4.
12. Satisfactory evidence to be produced that proper notice was given to the holders of all
liens and encumbrances intended to be divested by subject Sheriff Sale.
19. Satisfactory evidence to be produced that proper notice of said Sheriff sale was given
despite the reference to any improvements on the subject property.
20. Real estate taxes accruing on and after January 1, 2006 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has
any search been made for environmental liens in Federal District Court.
~.''''j
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Rotiert G. Frey, Agent
Note: This Title Report shall not be valid or bi
until countersigned by an authorized signatory.
"
REAL ESTATE SALE NO. 27
Writ No. 2004-1142 Civil
Deutsche Bank National Trust
Company, as Trustee of
Ameriques!. Mortgage Securities
Inc.. Asset Backed Pass-Through
Certificates, Series 2002-4. Under
the Pooling and Servicing
Agreement Dated as of November
1. 2002, without recourse
vs.
CIicket M. lWck. individually
and as guardian of minor chUd
Owen Orville Krick and
Harry O. KIick. Jr.. individually
and as guardian of minor chUd
Owen Orville Krick
Atty.: cJoseph Goldbeck
ALL THAT CERTAIN triangular lot
of ground situate on the East side
of George Street In the Borough of
Mechanicsburg. in the County of
Cumberland and State of Pennsyl-
vania. bounded and described as
follows:
BEGINNING at a point on the
eastern line of said George Street
marked by a monument comer of
lands of the United States of Amer-
Ica: thence In a northerly direction
along the eastern line of said George
Street 63.5 feet to a point at comer
of Lot No. 11 on the hereinafter
mentioned Plan of Lots; thence in
an easterly direction along the line
of said Lot No. 11. 310 feet more or
less. to an Iron pin at comer oflands
now or formerly of May Sultzenber-
ger and others; thence In a west-
erly direction along lands of the
United States of America. 314.46
feet to a point on the eastern line of
said George Street and at the place
of beginning.
BEING Lot No. 12 on a Plan of
Lots known as Green Acres. which
plan is recorded In the Recorder's
Office in and for said Cumberland
County. In Plan Book 4 at Page 4.
TAX PARCEL NO. 20-24-0785.
BEING KNOWN AS PROPERTI
115 S. GEORGE STREET. MECHAN-
ICSBURG. PA 17055.
. j,," ,
.,.
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 19th and 26th day(s) of July and the 2nd
day(s) of August 2005. 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 subse uently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscel us Book "M",
Volume 14, Page 317.
COpy
S ALE #27
Sworn to and subscri d
PUBLICATION
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A. 17013
Statement of Advertising Costs
,
To THE PATRIOT-NEWS CO.
For publishing the notice or publication attached
hereto on the above stated dates
317.36
REAL ESTATE SALE No. 27
Writ No. 2004-1142
Civil Term
Deutsche Bank National Trust
Company, as Trustee of
Ameriquest Mortgage Securities,
Inc., Asset Backed PasS-Through
Certificates, Series 2002-4 Under
the Pooling and Servicing
Agreement Dated a~of November
1, 2002,
Without Recourse
Vii'
Cricket M. Krick, Individually and
as guardian of minor child Owen
Orville Krick, and Hany O. Krick
Jr., Individually and as guardian
01'" Clllldo.. 0ntIIt KI'Ic*
AtIt': .........1111. Uk
DESCIWTION
AIL that certain triangular lot of ground &iluate
CI\ die east side of George Street in the Iloiou;I of
Mecbanicsbwg, in the County of Cwnberland and
State of Pennsylvania, bounded and described as
follows:
Beginning at a point on the eastern line of said
George street IIllIIked by a monument comer of
lands of the United States of America; thence in a
northerly direction along the eastern line of said
George Street 635 feet to a point at comer of lot
No. II on the hereinafter mentioned plan of lots;
thence in an easterly direction along the line of
said lot No, II, 310 feet more or less, to an iron
pin at comer of lands now or formerly of May
Sultzenberger and ~ thence in a westerly
direction along lands of the United States of
America, 314.46 feet to a pOint on the eastern line
of said George Street and at the place of
Beginning, .
BEING lot No. 12 on a plan of lots known as
Green Acres, which plan is recorded in the
Recorder's Office in and for said Cwnberland
County, in Plan Book 4 at Page 4.
TAX PARCEL NO, 20-2Ml785.
Being known as Property 115 S. George Street,
Mecbanicsburg, PA 17055
~
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
SSe
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:
July 15, 22, 29, 2005
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.
4
~
o AND SUBSCRIBED before me this
day of July, 2005
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
Car~sle 8oro, Cumberland County
My Commission Expires March 5. 2009
REAL ESTATE SALE NO. 27
Writ No. 2004-1142 Civil
Deutsche Bank National Trust
Company, as Trustee of
Ameriquest Mortgage Securities
Inc., Asset Backed Pass-Through
Certificates, Series 2002-4, Under
the Pooling and Servicing
Agreement Dated as of November
1, 2002, without recourse
vs.
Cricket M. Krick, individually
and as guardian of minor child
Owen Orville Krick and
Harry O. Krick, Jr., individually
and as guardian of minor child
Owen Orville Krick
Atty.: Joseph Goldbeck
ALL THAT CERTAIN triangular lot
of ground situate on the East side
of George Street in the Borough of
Mechanicsburg, in the County of
Cumberland and State of Pennsyl-
vania, bounded and described as
follows:
BEGINNING at a point on the
eastern line of said George Street
marked by a monument comer of
lands of the United States of Amer-
ica; thence in a northerly direction
along the eastern line of said George
Street 63.5 feet to a point at comer
of Lot No. lIon the hereinafter
mentioned Plan of Lots; thence in
an easterly direction along the line
of said Lot No. 11, 310 feet more or
less, to an iron pin at comer oflands
now or formerly of May Sultzenber-
ger and others; thence in a west-
erly direction along lands of the
United States of America, 314.46
feet to a point on the eastern line of
said George Street and at the place
of beginning.
BEING Lot No. 12 on a Plan of
Lots known as Green Acres, which
plan is recorded in the Recorder's
Office in and for said Cumberland
County, in Plan Book 4 at Page 4.
TAX PARCEL NO. 20-24-0785.
BEING KNOWN AS PROPERTI
115 S. GEORGE STREET, MECHAN-
ICSBURG, PA 17055.
..:' .......,
-