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Home My WebLink About09-8847D - Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Pass-Through Certificates Under the Pooling & Servicing Agreement dated as of December 1, 2002 without recourse , PLAINTIFF, V. James Moul Any/All Tenants/Occupants 16 W. Main St. Camp Hill, PA 17011, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 0 ?,W41 7 c Qw I -?«A-- CIVIL ACTION EJECTMENT COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE 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 this 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 claimed in the complaint or for any other claim of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Pass-Through Certificates Under the Pooling & Servicing Agreement dated as of December 1, 2002 without recourse , PLAINTIFF, V. James Moul Any/All Tenants/Occupants 16 W. Main St. Camp Hill, PA 17011, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: D I - (-(?- y7 cam{ I geca,. CIVIL ACTION EJECTMENT COMPLAINT 1. Plaintiff, Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Pass-Through Certificates Under the Pooling & Servicing Agreement dated as of December 1, 2002 without recourse (hereinafter "Deutsche Bank"), is a corporation, partnership, limited partnership, limited liability company, federal savings bank, or national banking association under and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. § 1 et seq.) with an address at 6501 Irvine Center Drive, Irvine, CA 92618. 2. Defendants are James Moul, an adult individual, and any/all tenants/occupants residing at 16 W. Main St., Camp Hill, PA 17011. 3. At all times material hereto, plaintiff was, and still is, the owner in fee simple of the real estate situated at 16 W. Main St., Camp Hill, PA 17011 ("Property"). 4. The legal description of the Property is described on Exhibit "A", attached hereto and incorporated herein by reference. The abstract of title to the Property upon which Plaintiff relies is a Sheriffs Deed which Deed has been prepared, executed, recorded, and is in the possession of Plaintiff. A true and correct copy of the Sheriff's Deed is attached hereto as Exhibit "B" and made a part hereof. COUNT I: EJECTMENT 6. Plaintiff incorporates the foregoing paragraphs by reference as though more fully set forth herein. 7. At all times material hereto, Defendants have unjustifiably withheld and continue to unjustifiably withhold possession of the Property from Plaintiff. Despite the granting to Plaintiff of a Sheriffs Deed, Defendants have unjustifiably refused to vacate the Property and continue to unjustifiably withhold possession thereof from Plaintiff. 9. Defendants are occupying the Property illegally. 10. After being provided with the aforesaid notice under and pursuant to the Protecting Tenants at Foreclosure Act of 2009 (P.L. 111-22), there was no contact from Defendants. Defendants have confirmed that they are not, individually or collectively, parties or signatories to any lease or sublease with respect to the Property. ( X ) it has been confirmed that Defendants are not bona fide tenants under and pursuant to the Protecting Tenants at Foreclosure Act of 2009 (P.L. 111-22). 11. Plaintiff has complied with the Protecting Tenants at Foreclosure Act of 2009 (P.L. 111-22) at all material times hereto and in all respect to the extent it is applicable. 12. As the legal owner of the Property, Plaintiff is entitled to immediate possession and immediate enjoyment thereof. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor and against Defendants, James Moul, and any/all tenants/occupants found in possession of the Property for immediate possession of the Property; for immediate ejectment of Defendants; for an award of Plaintiff s attorneys' fees; and for such other relief as this Court deems just and proper. COUNT II: ATTORNEYS' FEES 13. Plaintiff incorporates the foregoing paragraphs by reference as though more fully set forth herein. 14. Pursuant to 42 Pa. C. S. ' 2503(7), Plaintiff is entitled to an award of its attorneys' fees incurred in connection with this matter, as Defendants conduct in refusing to dispossess and vacate the Property is per se dilatory, obdurate, vexatious, in bad faith, and without justification. 15. Plaintiff has incurred $450.00 in attorneys' fees as of this date. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor and against defendants, James Moul, and any/all tenants/occupants found in possession of the Property for immediate possession thereof, for immediate ejectment of Defendants, for an award of Plaintiff s attorneys' fees, and for such other relief that this Court deems just and proper. Respectfully submitted, Dated: December 23, 2009 RICHARD M. SQUIRE & ASSOCIATES, LLC BY, Richard M. Squi*tsquire Attorney for Plain iff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Pass-Through Certificates Under the Pooling & Servicing Agreement dated as of December 1, 2002 without recourse, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: PLAINTIFF, V. James Moul Any/All Tenants/Occupants 16 W. Main St. CIVIL ACTION EJECTMENT Camp Hill, PA 17011, DEFENDANTS. VERIFICATION M. Troy Freedman, Esquire, hereby states that he is one of the attorneys for the Plaintiff, a corporation unless designated otherwise; that he has personal knowledge of the facts averred in the foregoing pleading in having coordinated efforts to obtain and having, in fact, obtained the subject Sheriff's Deed for the Plaintiff; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Respectfully submitted, RICHARD M. SQUIRE & ASSOCIATES, LLC Dated: December 23, 2009 BY: &6L" 4 i and M. Squire, squire Attorney for Plaintiff Exhibit "A" ALL THAT CERTAIN piece or parcel of land, situate, lying and being in the Borough of Shiremanstown, Cumberland County, Pennsylvania, being more fully bounded, limited and described as follows, to wit: BEGINNING at a point on the North by Main Street, having a frontage of forty feet; on the East by land now or formerly of Gary-Alan Development Corp., one hundred eighty-three (183) feet, more or less to Courtland Alley; on the West by land now or formerly of Lester J. Mayberry, one hundred eighty-three (183) feet, more or less, to Main Street, the place of BEGINNING. HAVING THEREON ERECTED a two and one-half story brick dwelling house being known and numbered as 16 West Main Street, Shiremanstown, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN James R. Moul and Mayre Erin Moul, his wife, by Deed from Brian C. Sweeney and Laura M. Sweeney, husband and wife, dated 04/09/2001, recorded 04/19/2001, in DeedBook 243, page 14. PREMISES BEING: 16 WEST MAIN STREET, CAMP HILL, PA 17011 PARCEL NO. 37-23-0555-032 Exhibit "B" II11MIWI1I Tax Parcel No. 37-23-0555-032 Know all Men by these Presents That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Deutsche Bank National Trust Company, as Trustee on Behalf of the Certificateholders for Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Certificates Sale No. 66 Writ No. 2007-711 Civil Term Deutsche Bank National Trust Company as Trustee of Ameriquest Mortgage Securities, Inc., Series 2002-D, Asset Backed Pass-Through Certificates Under the Pooling & Servicing Agreement Dated as of December 1, 2002 without recourse VS. James R Moul Mayre Erin Moul a/k/a Mayre Erin Coyne Atty: Daniel Schmieg ALL THAT CERTAIN piece or parcel of land, situate, lying and being in the Borough of Shiremanstown, Cumberland County, Pennsylvania, being more fully bounded, limited and described as follows, to wit: BEGINNING at a point on the North by Main Street, having a frontage of forty feet; on the East by land now or formerly of Gary-Alan Development Corp., one hundred eighty-three (183) feet, more or less to Courtland Alley; on the West by land now or formerly of Lester J. Mayberry, one hundred eighty-three (183) feet, more or less, to Main Street, the place of BEGINNING. HAVING THEREON ERECTED a two and one-half story brick dwelling house being known and numbered as 16 West Main Street, Shiremanstown, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN James R. Moul and Mayre Erin Moul, his wife, by Deed from Brian C. Sweeney and Laura M. Sweeney, husband and wife, dated 04/09/2001, recorded 04/19/200 1, in DeedBook 243, page 14. PREMISES BEING: 16 WEST MAIN STREET, CAMP HILL, PA 17011 PARCEL NO. 37-23-0555-032 1210312009 10:31:59 AM CUMBERLAND COUNTY Intl 200937607 - Page 1 of 5 The same having been sold by me to the said grantee on the 2nd day of September, Anno Domini Two Thousand and Nine (2009) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 27th of March Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Seven (2007) Number 711 at the suit of Deutsche Bank National Trust Company as Trustee of Ameriquest Mortgage Securities, Inc., Series 2002-D, Asset Backed Pass-Through Certificates Under the Pooling & Servicing Agreement Dated as of December 1, 2002 without Recourse --vs- James R. Moui and Mayre Erin Moul a/k/a Mayre Erin Coyne. 12/0312009 10:31:59 AM CUMBERLAND COUNTY Intl 200937607 - Page 2 of 5 In Witness Wereof, I have hereunto affixed my signature this 30th day of October Anno Domini Two Thousand and Nine (2009) R. Thomas Kline, heriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 30th day of October Anno Domini Two Thousand and Nine (2009) PROTHONOTARY, NOTARY R" CARLISLE CUMBERLAND COUNTY COURTHOt1SE MY COMMISSION WIRES JANUARY S, 2010 Ow4 x "o ? ?aG••:,lii ?,?;y,? ' I hereby certify that the residence And Post Office address of the Within Grantee is 505 City Park Way West, Suite 100 Orange, CA 92868 Solicitor , 12/03/2009 10:31:59 AM CUMBERLAND COUNTY Instl 200937607 - Page 3 of 5 RECORDER'S USE ONLY : Paid _ REALTY TRANSFER TAX COMMONWEALTH OF PENNSYLVANIA STATEMENT OF VALUE DEPARTMENT OF REVENUE BUREAU OF INDIVMUAL TAXES I rage mumoer J(' 01 - ,76,0.7 1 DEPT. 280603 See Reverse for Instructions Date Recorded 11, HARRISBURG, PA 17128-0603 Complete each section and file in duplicate with Recorders of Detds when (1) the full valuelconsideration is not set forth in the deed, (2) when the deed is without consideration, or by gift, or (3) a tax exemptions is claimed. A statement of value is not required if the transfer is wholly exempt from tax based on (1) family relationship or (2) public utility easement If more space is needed attach additional sheet(s). A CORRESPONDENT - All inquiries may be directed to the following person: Name Telephone Number: P14ELAN HALLINAN & SCHMIEG,LLP Suite 1400 Area Code ( 215 ) 563-7000 Street Address city state Zip Code One Penn Center at Suburban Station, Philadelphia PA 19103 1617 JFK Blvd. B TRANSFER DATA Date of Acceptance of Document Grantor(s)/Lessor(s) Grantet(s)/Lessee(s) R. Thomas Kline - Office of the sheriff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS FOR AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-D, ASSET-BACKED CERTIFICATES Street Address Street Address One Courthouse Square 505 City Park Way West, Suite 100 City State Zip Code city state Zip Code Carlisle PA 17013 Orange CA 92868 C PROPERTY LOCATION Street Address City, Township, Borough est m ree I 1W 1 County School District Tax Parcel Number CUMBERLAND Shiremanstown Borou h 37-23-0555-032 Control #37000034 D VALUATION DA TA 1. Actual Cash Consideration 2. Other Consideration 3. Total Consideration $1,149.22 + .-0- = $1,149.22 4. County Assessed Value 5. Common Level Ratio Factor 6. Fair Market Value S136.700.00 x 1.26 = $172,242.00 6 W %A-. Q# t Cam Hill PA 17011 Shiremanstown Borough E EXEMPTION DATA In. Amount of Exemption Claimed lb. Percentage of Interest Conveyed Ic. Percentage of Grantor's Interest Conveyed 100% 100% 100% >.. Check Appropriate Box Below for Exemption Claimed :1 Will or intestate succession - (Name of Decedent) (Estate File Number) :1 Transfer to Industrial Development Agency. :1 Transfer to a Trust. (Attach complete copy of trust agreement identifying all beneficiaries.) I Transfer between principal and agent/straw party. (Attach complete copy of agency/straw parry agreement.) I Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or in lieu of condemnation. (if condemnation or in lieu of condemnation, attach a copy of resolution.) K Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of Mortgage and note/Assignment.) (If condemnation or in lieu of condemnation, attach copy of resolution.) 7 Corrective or confirmatory deed. (Attach complete copy of the prior deed being corrected or confirmed.) Statutory corporate consolidation, merger or division. (Attach copy of articles.) Other (Please explain exemption claimed, if other than listed above. _ Under Penalties of law, I declare that I have examined this Statement, including accompanying information, ana to the nest of my cnnwledae and helieL it is true. Correct and complete r Signature of Correspondent or Responsible Nora M. Ferrer ?AILURE TO COMPLETE THIS FORM PROPERLY OR IECORDER'S REFUSAL TO RECORD THE DEED. Date: JINJI-- I (o I 1,Y10 APPLICABLE DOCUMENTATION MAY RESULT IN THE 12103/2009 10:31:59 AM CUMBERLAND COUNTY Inst.# 200937607 - Page 4 of 5 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200937607 Recorded On 11/6/2009 At 8:30:40 AM * Total Pages - 5 * Instrument Type - DEED-SHERIFF'S Invoice Number - 55602 User ID - AF * Grantor - MOLL, JAMES R * Grantee - AMERIQUEST MTG SECURITIES INC SERIES 2002-D * C tourer - SHERIFF us * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 $2 00 COUNTY ARCHIVES FEE ROD ARCHIVES FEE MECHANICSBURG SCHOOL DISTRICT SHIREMANSTOWN BOROUGH TOTAL PAID $3.00 $0.00 $0.00 $49.50 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA n RECORDER O D DS + - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11111111111111111 12/03/2009 10:31:59 AM CUMBERLAND COUNTY Instl 200937607 - Page 5 of 5 rF) l' _ r 4' V r,, ;. . r ? ?a,6() A a-#y L?-A l 7 3 7,2 SHERIFF'S OFFICE OF CUMBERLAND ~~~ Ronny R Anderson Sheriff ~, ~.~,~,~~F; zo ~ a ~~~~ ~ 3 r~~ i~~ z ~ Jody S Smith '"'~~~ ~~r"~ Chief Deputy - Edward L Schorpp P~~ u'~JY3_'~A'a Solicitor Deutsche Bank National Trust Company vs. James R Moul Case Number 2009-8847 SHERIFF'S RETURN OF SERVICE 01/07/2010 04:21 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 7, 2010 at 1621 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: James R. Moul, by making known unto himself personally, at 105 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 01/07/2010 08:27 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 7, 2010 at 2027 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Occupant of 16 West Main Street, Camp Hill, PA 17011, by making known unto Erin Moul, current resident a 16 West Main Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $66.50 January 08, 2010 SO ANSWERS, yy ~~~ +~ ~tl~• ~ ~~Y R ANDERSON, SHERIFF Deputy S eriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~4,~~~tr of ~aur~g~,~,~~ry~ ~, ~. a,.~ ;~~, C,iFF-~Ci ~'?~"~F ".RIFF OF THE p~TN~tVi~TAF?Y zoro ~aR - ~ P~ t : s2 CU~,~F~~;~.~,~~~ GJUi~TY pENIvSYLYA~t~ Deutsche Bank National Trust Company vs. James R Moul Case Number 2009-8847 SHERIFF'S RETURN OF SERVICE 02/25/2010 04:30 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1620 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupant, 16 West Main Street, Camp Hill, Cumberland County, Pennsylvania 17011. At that time it appeared to be vacant. 02/25/2010 04:30 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1620 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: James R. Moul, 16 West Main Street, Camp Hill, Cumberland County, Pennsylvania 17011. At that time it appeared to be vacant. SHERIFF COST: $73.50 March 01, 2010 ;cl CourfySuite Shenff. Teieosnft, Inr,. SO ANSWERS, ~-.,.. RON R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY { ,. ~_ , , -,. ;;,~ ~.; .,. . :~ ~. -, . 'l ~ _ ~4 ii. J~~~ - J ~';'..: Deutsche Bank National Trust Company vs. James R Moul SHERIFF'S RETURN OF SERVICE Case Number 2009-8847 04/01/2010 08:30 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 2030 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: James R. Moul, of 16 West Main Street, Camp Hill, (Borough of Shiremanstown) Cumberland County, Pennsylvania 17011. At that time it appeared to be vacant. 04/01!2010 08:30 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 2030 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupants, of 16 West Main Street, Camp Hill, (Borough of Shiremanstown) Cumberland County, Pennsylvania 17011. At that time it appeared to be vacant. 04/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is returned STAYED, per request from plaintiff's attorney, as defendant has entered into Chapter 13 bankruptcy. SHERIFF COST: $99.39 SO ANSWERS, -~-_.~ April 05, 2010 RON ~ R ANDERSON, SHERIFF -, n B ~Fr ,. Sharon R. Lantz SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~'1.~!"rI Sheriff ~~~ ~~ ~~~~! "~ ci ~tur~t~ Jody S Smith ~~~~ ~~~"~'~b Chief Deputy ~~~~-KAY I ~ AM 8~ ~1$ " ; Edward L Schorpp Ct.~RB~fil..*+,''~; ~ Solicitor '" " ~ PENNSI"LV,4~A Deutsche Bank National Trust Company Case Number vs. James R Moul 2009-8847 SHERIFF'S RETURN OF SERVICE 05/10/2010 08:15 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 1620 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupants, of 16 West Main Street, Camp Hill, Cumberland County, Pennsylvania 17050. Per defendant James R. Moul, the premises at 16 West Main Street is vacant. 05/10/2010 04:45 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 1620 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: James R. Moul, by making known unto James R. Mout personally, at 105 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $40.00 SO ANSWERS, May 11, 2010 RON RANDERSON, SHERIFF Gerald orthi ton, Deputy o,+ C~un!ySuite Shrrff. Teleos 't. I n,^.. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~,,,~ rr~~~~ , r, .~,~ ~ 1. _ ; c~~~ ~ ~ : ~ err =~wsi~~ a , ~.:'t.i1V"~ r UIY! 1 ~"' ' V IC.~r .I~ 1 t ~ Deutsche Bank National Trust Company vs. James R Moul Case Number 2009-8847 SHERIFF'S RETURN OF SERVICE 05/10/2010 08:15 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 2010 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupants, of 16 West Main Street, Camp Hill, Cumberland County, Pennsylvania 17050. Per defendant James R. Moul, the premises at 16 West Main Street is vacant. 05/10/2010 04:45 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 1620 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: James R. Moul, by making known unto James R. Moul personally, at 105 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 06/03/2010 By virtue of this writ, on the 3rd day of June, 2010, Sheriff Ronny R. Anderson caused the within named Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage Securities Inc., Series 2002-D, Asset-Backed Pass-Through Certificates Under The Pooling & Servicing Agreement Dated As Of December 1, 2002, without recourse, to have possession of the premises described as 16 West Main Street, Camp Hill, (Shiremanstown Borough), PA 17011. SHERIFF COST: $100.00 June 07, 2010 SO ANSWERS, ~ -OLD F~ . ~o (c Cour4yStrite ShenYf, Teleasofit h?c. ~~"'~` RON ~'R ANDERSON, SHERIFF