The URL can be used to link to this page

Home My WebLink About10-2204GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WW W.GOLDBECKLAW.COM ()r r?.r is "ir.r : }. `1f i DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IAI 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagors and Record Owners 3879 Spring Road Shermans Dale, PA 17090 Defendants IN THE PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 10 -dolDq CIVIL ACTION: MORTGGAGE TerM IECLOSUflf 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 SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 s LEGAL SERVICES INC a•? PA A'r?-y 8 Irvine Row cc b9q04I Carlisle, PA 17013 P* a *733 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y 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 LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.gs x. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 95866FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1, 4650 Regent Blvd, Irving, TX 75063. 2. The names and addresses of the Defendants are MELISSA A. SUNDY, 3879 Spring Road, Shermans Dale, PA 17090 and MARK E. SUNDY, 3879 Spring Road, Shermans Dale, PA 17090, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On August 14, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#: 1830, Page 3782. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 by assignment of Mortgage February 07, 2008 and recorded on March 17, 2009 as Instrument#200907909. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$42,774.22 Interest from 06/01/2009 through 03/09/2010 at 5.1000% .......................$1,689.90 Per Diem interest rate at $5.98 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,138.71 Late Charges from 07/01/2009 to 03/09/2010 .............................................$256.00 Costs of suit and Title Search (Estimated) ...................................................$900.00 Escrow Advance Balance ............................................................................$729.13 Recoverable Balance ....................................................................................$109.60 Monthly Escrow amount $155.67 $48,597.56 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. VERIFICATION The undersigned attorney for Plaintiff is authorized to make this verification and states that the facts set forth in the foregoing Complaint are true and correct to the best of his or her knowledge, information and belief. The undersigned understands that statements made in this verification are subject to the penalties of 18 Pa.C.S.A. §4904. Date: flo /C/ By: ,90LDBECK MCCAFFERTY & MCKEEVER /Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kfistina Murtha Pa. ID 61858 Aavid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff #95866FC MELISSA A. SUNDY and MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and 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 a de terris judgment in mortgage foreclosure in the sum of $48,597.56, together with interest at the rate of $5.98, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mort and heriff s Sale of the Property. By: ' GOLDBECdk MC FFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 ristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF ?hibl*tA Daft 6J13J03 Tnir. 1:24,0 PM Ozdrr Number. 000014782 Re: Xkft 1, ftoft 3879 SPRING pQ= MKIAAM A. Bundy SHERm"s nns, PA 1.7090 aMERUWD County xT ?A? All that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described pursuant to a survey be Earl D. Palm a SMS, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of fozmer Highway Route No. 34, also )mown as Sterrets Gap Road; thence al=g a post fence, by land now or formerly of Elmer Nountz, South 36 degrees 55 minutes 20 seconds Bast 249.15 feet to an Iron pint thence by the center of A atone row, South 5 degrees 5 minutes 52 seconds Halt 248.71 feet to an iron pin, thence by land now or formerly of the Thon"on Beira, South 82 degrees 19 minutes 28 scoonda pest 238,54 feet to stones; thence by land now or Ponaarly of William L. Arndt, North 6 degrees 12 minutes 13 seconds West 288.81 feet to an iron pin; thence by the tee, North 30 degrees 28 minutes 45 seconds Nest 107.29 fee to an iron pin is the zoad bed of former Highway Route No. 34 aforesaids thence in said road bed, North 56 degrees 33 minutes 55 seconds East 179.73 feet to the Place of BMNNZNGi being improved with a two and one-half story house, OK 1830PG3798 Page: 6 of G Qrft NWVw 000©14782 E.xhibit B AUJA 5=;'1 I 1111111 November 25, 2009 7104 5400 2100 2546 4656 0 0 0 3 9 9 2 6 9 5q Mark E Sundy 3879 Spring Rd Shermans Dale, PA 17090-9608 November SS ?01111211J09 ACTIO91 NpOTIACEE Y HOME CTOM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ONPAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMP) maybe able to help to save your home This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Mark E Sundy PROPERTY ADDRESS: 3879 Spring Rd Shermans Dale, PA 17090 LOAN ACCT. NO.: 4000301764 ORIGINAL LENDER: AMERIQUEST MORTGAGE COMPANY CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc. Page two 4000301764 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE. IF YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITIONINBANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONPURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 3879 Spring Rd, Shermans Dale, PA 17090 IS SERIOUSLY IN DEFAULT because: 4000301764 A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTSfor the following months and the following amounts are now past due: (a) Monthly payments from 07/01/2009: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 11/24/2009: $3,445.00 $160.00 $100.00 $0.00 $3,705.00 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,705.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as .specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount 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. Page four HOW TO CONTACT THE LENDER Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-877-304-3100 Fax Number: 1-866-497-1263 Contact Person: Brandon Wirth, Glenda Mathews E-mail Address: Brandon.wirth@ahmsi3.com, Glenda.mathews@ahmsi3.com 4000301764 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell 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 requirements of the mortgage are satisfied. YOU MAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ONPAGES 5-7. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-877-304-3100 * Indicates Counties Serviced Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 'Bucks, Chester, Delaware, Montgomery Philadelphia Action Housing Inc 425 6th Avenue, Suite 950 Pittsburgh, PA 15219 (412) 281-2102 'Allegheny, Beaver, Butler. Fayette, Greene, Washington, Westmoreland Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 3341518 'Adams, Cumberland, Franklin, York Advocates for Financial Independence 1B06 S Broad Street, Suite 1B Philadelphia, PA 19145 (215) 389-2810 'Philadelphia Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 (215) 389-2810 'Delaware Allegheny County Acorn 5907 Penn Avenue, Suite 300 Pittsburgh, PA 15206 (412)441 6551 'Allegheny American Credit Counseling Institute 21 S Church Street West Chester, PA 19380 (888) 212-6741 'Chester American Credit Couseling institute 526-528 Dekalb Street Nornstown, PA 19401 (610) 971-2210 (888) 2126741 'Montgomery, Delaware American Credit Counseling Institute 530 W Street Road, Suite 201 Wamknster, PA 18974 (215) 4449429 (888) 2126741 'Bucks, Montgomery, Philadelphia American Credit Counseling Institute 937 North Hanover Street Pottstown, PA 19460 (888) 2126741 'Barks, Bucks, Montgomery American Credit Counseling Institute 229 East Chestnut Street Coatesville, PA 19320 (888) 212-6741 'Chester, Lancaster American Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267) 228-7903 'Mifflin American Financial Counseling Services 405 West Germantown Pike Norristown, PA 19403 (267) 228-7903 'Mifflin, Montgomery American Financial Counseling Services 2880 Bergey Road Suite 4 Hatfield, PA 19440 (267) 228-7903 'Barks, Chester, Montgomery American Financial Counseling Services 175 Strafford Avenue, Suite One Wayne, PA 19087 (610) 971-2210 (888) 212-6741 'Bucks, Chester, Delaware, Mongomery, Philadelphia American Financial Counseling Services 906 Penn Avenue Wyomissing, PA 19610 (267) 228-7903 (800) 490-3039 't3erks American Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267) 2287903 'Montgortrery American Financial Counseling Services 1917 Welsh Road Philadelphia, PA 19115, PA 19610 (267) 2287903 'Bucks, Montgomery, Philadelphia American Red Cress - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 'Adams, Franklin, York American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 (610) 8741484 'Chester. Delaware APM 2147 Nortt Sixth Street Philadelphia, PA 19122 (215) 2356788 'Chester, Delaware, Philadelphia, Bucks Armstrong CO Community Action Agency 124 Arnsdale Road, Suite 211 Kittanning, PA 16201 (724) 5483405 'Armsfrorg Base, Inc. 447 South Prince Street Lancaster, PA 17603 (717) 392-5467 'Lancaster Blair County Community Action Agency 2100 6th Avenue, Suite 102 P.O. Box 1833 Altoona, PA 16602 (814) 946-3651 'Blair Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 'Crawford, Erie, Warren Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 (866) 866-0280 'Bucks Bucks County Housing Group 2324 Second Street Pike, Suite 17 Wlightstown, PA 18940 (866) 866-0280 'Bucks Bucks Canty Housing Group 470 Old Dublin Pike Doylestown, PA 18901 (866) 866-0280 'Bulks Bucks County Housing Group 349 Durham Road Penndel, PA 19047 (866) 866-0280 'Bucks Bucks County Housing Group 515 West End Blvd Quakertown, PA 18951 (856) 866-0280 'Bucks Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (610) 375-7866 'Barks, Chester, Schuylkill Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 (215) 877-1157 'Chester, Delaware, Philadelphia Catholic Social Services Saint Catherine Manor 5 Knox Road Scranton, PA 18505 (570) 558-3019 'Wyoming, Wayne, Bucks, Lackawanna, Monroe, Philadelphia CCCS of Delaware Valley 1230 New Rodgers Road, Suite F1 Bristol, PA 19007 (215) 5635665 'Bulks CCCS of Delaware Valley 1777 Sentry Parkway W, Suite 200 Blue Bell, PA 19422 (215) 563-5665 'Montgomery CCCS of Delaware Valley 280 North Providence Road Media, PA 19063 (215) 563-5665 'Chester CCCS of Delaware Valley Marshal Building 790 E Market St, Suite 170 West Chester, PA 19382 (215) 563-5665 'Chester, Bucks CCCS of Delaware Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215) 563-5665 'Bucks, Philadelphia CCCS of Delaware Valley One Cheny Hill, Suite 215 Cherry Hill, PA 08002 (215) 563-5665 'Philadelphia CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 821-4011 (800) 837-9815 'Becks, Bucks, Carbon, Lancaster, Lehigh, Northhampton, Schuylkill CCCS of Northeastern PA 201 Basin Street, Suite 6 W Iliamsport, PA 17701 (570) 32316627 'Centre, Linton, Lycoming, Northumberland, Union CCCS of Northeastern PA 202 W Harrktton Avenue State College, PA 16801 (814) 238-3668 'Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18540 (570) 602-2227 'Bradford, Carbon, Columbia, Lackawanna, Lyooming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeastern PA 411 Main Street, Suite 104 Stroudsburg, PA 18360 (570)420.8980 'Bradford, Carbon, Monroe, Pike, Wayne CCCS of Western PA 1 North Gate Square 92 Garden Center Dr Greensburg, PA 15601 (888) 511-2227 *Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Western PA 55 Clover Hill Road Dallastown, PA 17313 (888) 511-2227 'Fulton, Crawford, Lancaster * Indicates Counties Serviced CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (888) 511-2227 'Adams, Cumberland, Dauphin, Franklin, Perry, Synder, York Chester Community Improvement Project 412 Avenue of the States P.O. Box 541 Chester, PA 19016 (610) 876-8663 'Chester. Delaware, Montgomery, Philadelphia Dversified Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 (215) 336-3511 'Bucks, Chester, Delaware, Philadelphia Indiana Co. Cortnmunity Action Prog. 827 Water Street Box 187 Indiana, PA 15701 (724) 465-2657 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland CCCS of Western PA 312 Chestnut Street, Suite 227 Meadville, PA 16335 (888)511-2227 'Lawrence CCCS of Western PA 41 East Chestnut Street Washington, PA 15301 (888) 511-2227 `Westmoreland CCCS of Western PA 4402 Peach Street Erie, PA 16509 (888) 511-2227 'Crawford, Erie, Warren CCCS of Western PA 524 Franklin Avenue Aliquippa, PA 15001 (888)511-2227 'Cambria CCCS of Western PA 917 A Logan Boulevard Altoona, PA 16602 (888) 511-2227 'Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Union CCCS of Western PA Pullman Commerce Center 112 Hollywood Or Baler, PA 16001 (888) 511-2227 'Butler, Clarion, Jefferson, Mercer, Venango CCCS of Western PA River Park Commons 2403 Sidney Street Pittsburgh, PA 15203 (888) 511-2227 'Allegheny Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 (814) 3375450 'Columbia, Venargo Centro Pedro Claver, Inc 627 West Erie Avenue PMladelpia, PA 19140 (215) 227-7111 'Philadelphia Comm. On Eoon Opportunity of Luzeme Co. 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 *Carbon, Luzeme, Schuylkill, Wyoming Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17094 (717) 232-9757 'Cumberland, Dauphin, Franklin, Perry, Synder Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehem, PA 18015 (610) 691-5620 'Barks, Carbon, Lehigh, Monroe, Northhampton Community Action Development Comm - CADCOM 113 E Main Street Norristown, PA 19401 (610) 2775353 'Montgomery Community Action Southwest 150 W Beau Street, Suite 304 Washington, PA 15301 (724) 225-9550 'Monroe Community Action Southwest 58 E Greene Street Waynesburg, PA 15370 (724) 852-2893 'Allegheny, York, Fayette, Greene, Washington, Westmoreland Comm. on Econ. Opportunity of Luzeme County 163 Amber Larne W11kesBarre, PA 18702 (570) 826-0510 (800) 822-0359 'Wyoming Congreso 216 West Somerset Street Philadelphia, PA 19133 (215) 763-8670 'Philadelphia Council of Spanish Speaking Organization 705-09 North Franklin St Philadelphia, PA 19123 (215) 627-3100 'Philadelphia Credit Counseling Center 832 Second Street Pike Richboro, PA 18954 (215) 396-1880 'Bucks Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc Inc. 4225 Chestnut Street 2840 Liberity Ave., Suite 205 Philadelphia, PA 19104 Pittsburgh, PA 15222 (215) 386.1298 (412) 391-2535 `Philadelphia 'Allegheny Fayette Co. Community Action Agency Inc 137 North Beeson Avenue Uniontown, PA 15401 (724) 4375050 'Fayette, Somerset Korean Comm. Develop. Services Center 6055 North 5th Street Philadelphia, PA 18505 (215) 276-8630 'Philadelphia FOB CDC 1201 West Only Avenue Philadelphia, PA 19141 (215) 549-8755 'Bucks, Chester, Delaware, Philadelphia Garfield Jubilee Associates 5138 Penn Avenue Pittsburgh, PA 15224 (412) 565-5200 'Allegheny Germantown Settlement 5538 Wayne Avenue Bldg C Philadelphia, PA 19144 (215) 849-3104 'Bucks, Chester, Delaware, Montgomery, Philadelphia Greater Ede Commun. Action Committee 18 West Stn Street Erie, PA 16501 (814) 4594581 'Crawford, Ede, Venango, Warren HACE 167 W Allegheny Ave., 2nd Floor Philadelphia, PA 19140 (215) 426-8025 'Bucks, Chester, Delaware, Philadelphia Hispanic Alliance for Community Advancement 2740 North Front Street Philadelphia, PA 19133 (215) 667$932 'Monroe Housing Assoc. of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 'Philadelphia, Monroe Housing Opportunities of Beaver Co. 320 College Avenue, Unit 1 Beaver, PA 15009 (724) 728-7511 'Beaver, Lawrence Housing Partnership of Chester County 41 West Lancaster Avenue Downingtown, PA 19335 (610) 518-1522 'Chester, Delaware, Montgomery Lawrence County Social Services, Inc. 241 West Grant Street P.O. Box 189 New Castle, PA 16103 (724) 658-7258 'Lawrence Liberty Resources 714 Market Street, Suite 100 Philadelphia, PA 19106 (215) 634-2000 'Philadelphia Loveship, Inc. 2320 North 5th Street Harrisburg, PA 1711 (717) 232-2207 'Cumberland, Dauphin, Perry Lycom-Clntn Co Comm fo Comm Action 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 (570) 326-0587 'Centre, Clinton, Lycorning, Union Maranatha 43 Ptwladelphia Avenue Waynesboro, PA 17268 (717) 762-3285 'Adams, Cumberland, Franklin, Fulton, Perry Media Fellowship House 302 South Jackson Street Media, PA 19063 (610)565.0434 'Chester, Delaware Mon Valley Unemployment Cornmittee 1800 West St., 3rd Floor Homestead, PA 15120 (412) 462-9962 'Allegheny, Washington, Westmoreland Mt. Airy, USA 6703 Germantown Ave., Suite 200 Philadelphia, PA 19119 (215) 844-8021 'Philadelphia Nazareth Housing Services 301 Bellevue Road Pittsburgh, PA 15229 (412) 931.69% •Alle9heny " Indicates Counties Serviced Neighborhood Housing Services of Reading 213 N 5th St., Suite 1030 Reading, PA 19601 (610) 372-8433 'Barks Neighborhood Housing Services, Inc. 710 5th Avenue, Suite 1000 Pittsburgh, PA 15219 (412) 281-9773 'Allegheny New Kensignton Community Development 2515 Frankford Avenue Philadelphia, PA 19125 (215) 427-0350 'Warren The NORCAM Group 4200 Crawford Avenue Suite 200 Northern Cambria, PA 15714 (814) 946-0444 'Cambria, Clearfield Northern Tier Community Action Corp. 135 West 4th Street P.O. Box 389 Emporium, PA 15834 (814) 4861161 'Cameron, Elk, Mckean, Potter Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia Nueva Esperanza 4261 North 5th Street Philadelphia, PA 19140 (215) 324-0746 'Philadelphia Opportunity Inc. 301 East Market Street York, PA 17403 (717) 424-3645 'Montgomery The Partnership CDC 4020 Market Street, Suite 100 Philadelphia, PA 19104 (215) 662-1612 'Monroe Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd., Bldg 200 Pittsburgh, PA 15220 (412) 429-2842 'Allegheny PHFA 211 North Front Street Harrisburg, PA 17110 (800-) 342-2397 'Cumbedand, Dauphin Philadelphia Council for Comm. Advmnt. 100 N 17th St, Suite 600 Philadelphia, PA 19103 (215) 567-7803 (600) 930-4663 'Chester, Delaware, Montgomery, Philadelphia Philadelphia Senior Center 509 South Broad Street Philadelphia, PA 19147 (215) 546-5879 'Philadelphia Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 (570) 622-1995 'Barks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 981-5310 'Crawford, Lawrence, Mercer South Philadelphia H.O.M.E.S. 1444 Point Breeze Avenue Philadelphia, PA 19146 (215) 334-4430 'Philadelphia Southwest Community Development Corp. 6368 Paschall Avenue Philadelphia, PA 19142 (215) 729-0600 'Montgomery St. Martin Center 1701 Parade Street Erie, PA 16503 (814) 452.6113 'Crawford, Erie, Venango, Warren Tableland Services Inc. 535 East Main Street Somerset, PA 15501 (814) 445-9628 *Cambria, Fayette, Somerset, Westmoreland Tabor Community Services 308 E King Street, Suite 1 Lancaster, PA 17602 (717) 397-5182 (800) 788-5062 'Chester, Lancaster, Lebanon The Trehab Center of Northeastern PA 10 Public Avenue P.O. Box 366 Montrose, PA 18801 (570) 278-3338 (800) 9624045 'Susqut'ttarma The Trehab Center of Northeastern PA 115 SR 92S Tuckharmock, PA 18657 (570) 836-6840 (800) 9824045 'Wyoming The Trehab Center of of Northeastern PA 1225 Main Street Honesdale, PA 18431 (570) 253-8941 (800) 9824045 'Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming The Trehab Center of Northeastern PA 144 E East Avenue Wellsboro, PA 16901 (570) 724-5252 (800) 9824045 'Tioga The Trehab Center of Northeastern PA German Street P.O. Box 389 Dushore, PA 18614 (570) 928-9667 (800) 9824045 'Sullivan The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Ave., Suite M-0 Sayre, PA 18840 (570) 888-0412 (800) 9824045 'Bradford United Communfies Southeast Philadelphia 2029 South 8th Street Philadelphia, PA 19148 (215) 467-8700 'Philadelphia United Neighborhood Centers of NoMeastem PA 425 Alder Street Scranton, PA 18505 (570) 346-0759 'Lad(awanna, Wyoming, Wayne, Luzeme Urban League of Philadelphia 1818 Market Street Philadelphia, PA 19103 (215) 561-0070 'Bucks, Delaware, Philadelphia Urban League of Philadelphia 610 Wood Street Pittsburgh, PA 15229 (412) 931-6996 'Allegheny Voices for Independence 1107 Payne Avenue Erie, PA 16503 (814) 874-0064 (800)838-9890 'Erie Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave W. P.O. Box 547 Warren, PA 16365 (814) 725-2400 'Forest, Waren West Oak Lane CDC 6259 Limekiln Pike Philadelphia, PA 1914 (215) 224-0880 'Monroe AUdl SO-0-0.14-11 November 25, 2009 11111111111pi Melissa A Sundy 3879 Spring Rd Shermans Dale, PA 17090-9608 November 25, 2009 T?ACTIOMN ? This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Melissa A Sundy 3879 Spring Rd Shermans Dale, PA 17090 4000301764 AMERIQUEST MORTGAGE COMPANY American Home Mortgage Servicing, Inc. In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) PRAECIPE FOR JUDGMENT No. 10-2204 CIVIL TERM na o ;^, a ~ ~.. Ci ' -v ~~-~ ~ a era .. -..aR 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 MELISSA A. SUNDY and MARK E. SUNDY by default for want of an Answer. Assess damages as follows: Debt Interest from 05/28/2010 to Date of Sale per diem at $5.98 $49,377.78 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 m filed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default c ed and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237. By: GOLDBECK AFFER Y & MCKEEVER Mac i McKeever Pa. ID 56129 G yMcCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW ,~ ~1L~nE o20/D ,Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-T OUGH CERTIFICATES, SERIES 2003-IA1 and against MELISSA A. SUNDY and MARK E. SUNDY by default fort of an Answer and damages assessed in the sum of $49,377.78 as per the above certification. othonotary ~ I~.oo P O A7ri/ C# 531 °I Da r?" a~la9ys I~~, IUou.(~P Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagors and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) No. 10-2204 CIVIL TERM 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. Protho By: Deputy If you have any questions concerning the above, please contact: /v~///O Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 95866FC THIS LAW FIItM 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: May 13, 2010 TO: MELISSA A. SUNDY SUNDY, MELISSA A. 3879 Spring Road Shermans Dale, PA 17090 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 TO: MELISSA A. SUNDY 3879 Spring Road Shemlans Dale, PA 17090 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVII., ACTION -LAW Action of Mortgage Foreclosure Term No. 10-2204 CIVIL TERM IIVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIvIPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIIZE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 95866FC 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: May 13, 2010 TO: MARK E. SUNDY SUNDY, MARK E. 3$79 Spring Road Shermans Dale, PA 17090 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) TO: MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW Action of Mortgage Foreclosure Term No. 10-2204 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIvIPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, MARK E. SUNDY, is about unknown years of age, that Defendant's last known residence is 3879 Spring Road Shermans Dale, PA 17090, 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: TINAMARI BOSCHETTI VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, MELISSA A. SUNDY, is about unknown years of age, that Defendant's last known residence is 3879 Spring Road Shermans Dale, PA 17090, 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: ' s~~~ TINA E BOSCHETTI GpLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-2204 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003- IA1, and against MELISSA A. SUNDY and MARK E. SUNDY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of 'ca) from the date of service of the Complaint, in the sum of $49,377.78. By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 G~ McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 and that the name(s) and last known address(es) of the Defend t e MELISSA A. SUNDY, 3879 Spring Road Shermans Dale, PA 17090 and MARK E. SUNDY, 3879 Spring R S e s ale, PA 17090; By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Qary McCafferty Pa. ID 42386 /Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 06/01/2009 through 05/27/2010 Reasonable Attorney's Fee Late Chazges Costs of Suit and Title Search Escrow Payments Due 2 X $155.67 Escrow Advance Balance Recoverable Balance $42,774.22 $2,158.78 $2,138.71 $256.00 $900.00 $311.34 $729.13 $109.60 49,377.78 By: GOLD CK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 GyeGy McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this ~~ day of ~~o , 2010 damages are assessed as above. ro Prothy ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff P.R.C.P 3180-3183 ~"r'~ ~.~ THc ~~~'~AY 101Q ,JtIH - i P~f 3:47 ~~~u ~=iY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 10-2204 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due moo. 00 CBF Interest from ~a.00 " 05/28/2010 to Date of I~. 00 " Sale per diem at $5.98 a.so-• (Costs to be added) # x$$.50- P4A~ $49 377.78 A,-~~ 01, oo ~ue(a 50 L.l. ~~5~~9oa GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 G~y McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff W a a ~z W0~, ~O ~V Ha0 N [..~ O_ -`~ O ~ z~ w F ¢w awv ~ ~ ~ r.. O~~Q F..QZo ~ F ~ N E~-~O¢~~ Z ~ Q ~ ~ j U W ¢a~¢ Z W F~ ~ d Q ~ ~ car~¢w xoz~ vU,W`r F. t- Q h z O n H ~ D ~ 0 ~ ~ U w r ~o A `~ W b ¢ L1 '~ o~°a W O ~ N bA ['~ uj ~ '~ Q ~~ ~ ~ fx 3 ~ ~ ~ ~ ~ ~~ ~ ~ 0 ~ ~ ~ ~ w a a, ~. a~ ~Ur /-. U ~, Y L ~, ~ ~ 0> as ~, U u ~ ~ ~ ~ o Y ~ ~ ~ ~ N ~.d~a~ i W H ~ ~ ~ O ~ g ~, ~~ ~~ 'd N ~ ~ O y oo f1. ,~ o o~ v All that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania bounded and described pursuant to a survey be Earl D. Palm & Sons, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of former Highway Route No. 34, also known as Sterrets Gap Road; thence along a post fence, by land now or formerly of Elmer Mountz, South 36 degrees 55 minutes 20 seconds East 249.15 feet to an iron pin, thence by the center of a stone row, South 5 degrees 5 minutes 52 seconds East 248. 71. feet to an iron pin; thence by land now or formerly of the Thompson Heirs, South 82 degrees 19 minutes 28 seconds West 238.54 feet to stones; thence by land now or fomerly of William L. Arndt, North 6 degrees 12 minutes 13 seconds West 288.81 feet to an iron pin; thence by the same, North 30 degrees 18 minutes 45 seconds West 107.29 fee to an iron pin in the road bed of former Highway Route No. 34 aforesaid; thence in said :road bed, North 56 degrees 33 minutes 55 seconds East 179.73 feet to the Place of BEGINNING, being improved with a two and one-half story house. BEING THE SAME PREMISES BY DEED DATED 12/15/95, CONVEYING FROM SCOTT M. WERT AND TAMMY S. WERT, HUSBAND AND WIFE TO MARK E. SUNDY AND MELISSA A. SUNDY, RECORDED 12/18/85, IN BOOK 132, PAGE 881. BEING KNOWN AS 3879 SPRING ROAD, SHERMANS DALE PA 17090 TAX PARCEL NO: 21-04-0373-021 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY LD. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IAl 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) -~ i3F 1N~ P~Tlp~'IIRV' 101p JUN - I PM 3~ ~~ ~'~ 'tCUklMY PENN~n"Y~1A~A IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2204 CIVIL, TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GO B CK McCAFFERTY & McKEEVER Mic el McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney LD. #56129 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 FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003- IA 1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 10-2204 CNIL TERM DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 3879 Spring Road Shermans Dale, PA 17090 1.Name and address of Owner(s) or Reputed Owner(s): MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 2. Name and address of Defendant(s) in the judgment: MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 ~~ ~~F THE F~O~I~'~l~RY 2010 JUN - ! Ph 3~ 0~ of Cumberland County CIVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MEMBERS FIRST FEDERAL CREDIT UNION P.O. Box 40 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 3879 Spring Road Shermans Dale, PA 17090 (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: May 27, 2010 GOLDBEC McCAFF TY & McKEEVER BY: TINAMARIE BOSCHETTI 10-2204 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 7F THIS PRQ?'~-~h~~TARY 20t0 JUIi - I PM ~= 0~ Ct~tB~~~ CQt~ZY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 IN THE COURT OF COMMON PLEAS Plaintiff Defendants; of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2204 CNIL TERM 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: SiJNDY, MELISSA A. MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 Your house at 3879 Spring Road, Shermans Dale, PA 17090 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $49,377.78 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 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: 10-2204 CIVIL TERM 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2003-IA1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd 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 compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www. hin ladelphiafed.ora/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cazlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 10-2204 CIVIL TERM Carlisle, PA 17013 717-243-9400 10-2204 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httn://www.phfa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 95866FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 10-2204 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IAl 4650 Regent Blvd Irving, TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Plaintiff Defendant(s) of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2204 CIVIL TERM THIS LAW FIItM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SiJNDY, MARK E. MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 Your house at 3879 Spring Road, Shermans Dale, PA 17090 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $49,377.78 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Z~ 10 JUN - I Pn 3~ 0~ ~~~~i IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 10-2204 CNIL TERM 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2003-IA1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 10-2204 CNIL TERM Carlisle, PA 17013 717-243-9400 10-2204 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1}. Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov_ for Help for Homeowners Facing the Loss of Their Homes. 4}. Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http:!/www.phfa. org~consumers/homeownersJreal. aspx. 5}. Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 95866FC. Para information en espanol puede communicarse con Loretta. al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2204 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 for AMERIQUEST MORTGAGE SECURITIES INC, ASSET-BACKED PAS- THROUGH CERTIFICATES, SERIES 2003-IA1, Plaintiff (s) From MELISSA A. SUNDY and MARK E. SUNDY (1) You are directed to lery 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 $49,377.78 L.L.$.50 Interest from 5/28/10 to Date of Sale per diem at $5.98 Atty's Comm % Due Prothy $2.00 Atty Paid $188.50 Other Costs Plaintiff Paid Date: 6/2/10 David D. Buell, Prothonotary (Seal) By: REQUESTING PARTY: Name: LISA LEE, ESEQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy •GOLDBECK MCCAFFFRTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 .`? ???, 21 P? 3:43 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA 1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) 95866FC CF: 03/31/2010 SD: 09/08/2010 $49,377.78 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2204 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office%^?rnP*°?' = copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( } Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Keith C. Halili Legal Secretary o? Q' ei l U, m ? ti ? p v ? n - W U C. Q ?$ (Y m p ° p Z _ - x ? Q o l U) a a ma °°3 ° v, 5- o m O) U D N m c mo o ?' ? ` LL u- ? oa U ? ? O al Q coo o 0-0 U) C - W o'er Y--n. ? - Q ? E ---- -- m 2i U o WU? CA Wnm ? o m a d ?a HMCO rz U) ? U C d 0 o Z < ?m? m ^ E m N lm JCn, tL o ! V OP 7 N C Q m X 7 0 a 3: E E ( ) Q> ?LO? LL _ o 0 _2? O CO ZE ' Z W ' U fC 0 [L O a CV IJ C LM LO .m c ? Q M ? Q N O 0 o T mm N ZCn >• ?o c (D Q t7 _? d) m m' o N 4! X' y U ( l(i u F(3 U C) L a. C F IL O Q) 070 m J D 1u x a. (a Z; ???? y m N V 5: Om o ?? C m 0 on- ca L L n U am= _ I D m ? 0 W Z co uj Q V o Q S2 co 4 45YOwn=. ¢ C) mMLO<0 Q z0 C7 O I r. ao CD L m O d m U Q U CL ID m U) c m d C O a _ ++ I m O i Y C i 3 I C O. T F- a T ? w a, 2 5 E O v C v o ? N 00 E O m Z ? C] N N ry Q C (U z a ?? o c W A o tL ? U Y ? ? C o Z O C6 c C N N q'S F LC E 7 U Z D ILL CO a o, w M U Q 'ate I ? LL ? Z ri LL coio w w U) a LO rn m' :ml SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Mark E. Sundy (et al.) Case Number 2010-2204 SHERIFF'S RETURN OF SERVICE 06/2612010 10:53 AM - Noah Cline, Deputy Sheriff, who being duly swam according to law, states that on 6-26-2010 at 1053 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mark E. & Melissa A. Sundy, located at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania according to law. 06/26/2010 10:53 AM - Noah Cline, Deputy Sheriff, who being duly swam according to law, states that on 6-26-2010 at 1053 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Marts E. Sundy, by making known unto, Melissa A. Sundy, personally, at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06126/2010 10:53 AM - Noah Cline, Deputy Sheriff, who being duly swam according to law, states that on 6-26-2010 at 1053 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Melissa A. Sundy, by making known unto, Meliss< A. Sundy, personally, at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $908.92 July 02, 2010 }tsar of t waa#r14 rri, r OnZi OF rH F S4ERfF9 SO ANSWERS, RON R ANDERSON, SHERIFF LoontySuils She Y. Te4aoso!L Inc. GOLDBECK McCAFFERTY & WKEEVER BY: Michael T. McKeever Attorney I.D.956129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA 1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County C1V 1L ACTION - LA W ACTION OF MORTGAGE FORECLOSURE Tenn No. 10-2204 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IAI, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was fled the following information concerning the real property located at: 3879 Spring Road Shennans Date, PA 17090 1.Name and address of Owner(s) or Reputed Owner(s): MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 MARK E. SUNDY 3 879 Spring Road Shermans Dale, PA 17090 2. Name and address of Defendant(s) in the judgment: MELISSA A. SUNI)Y 3879 Spring Road Shermans Dale, PA 17090 MARK E. SUNDY 3 Spring Road Shermans Dale, PA 17090 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MEMBERS FIRST FEDERAL CREDIT UNION P.O. Box 40 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 3879 Spring Road Shermans Dale, PA 17090 (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 25. 2010 ` &- GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ` Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Mark E. Sundy (et al.) c~'~~' e, ~; ~ ~ x'rr;~r .~ ~~ Case Number 2010-2204 SHERIFF'S RETURN OF SERVICE 06/26/2010 10:53 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1053 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mark E. & Melissa A. Sundy, located at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania according to law. 06/26/2010 10:53 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1053 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mark E. Sundy, by making known unto, Melissa A. Sundy, personally, at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/26/2010 10:53 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1053 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Melissa A. Sundy, by making known unto, Meliss< A. Sundy, personally, at, 3879 Spring Road, Shermansdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 09/09/2010 Ronny R. Anderson, 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 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Thomas Puleo on behalf of Deutsche Bank National Trust Company, As Trustee for Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2003-1A1 4650 Regent Blvd, Irving, TX 7506 ,being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 856.64 SHERIFF COST: $856.64 SO ANSWERS, October 11, 2010 RON R ANDERSON, SHERIFF ~~ t~ ~~' C'lz~r ~rG. a~ ~~ a ~~ ~~ ~ ~, r !~ _!! f+. ~ ~ ~+R, ~ [ ~.. ~ { ae S ~, f°I Goldbeck McCafferty ~ McKeever BY: Michael T. McK~;ever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003- IA 1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. MELISSA A. SUNDY MARK E. SUNDY (Mortgagor(s) and Record Owner(s)) 3879 Spring Road Shermans Dale, PA 17090 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CNII. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 10-2204 CNII., TERM AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 3879 Spring Road Shermans Dale, PA 17090 1.Name and address of Owner(s) or Reputed Owner(s): MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 2. Name and address of Defendant(s) in the judgment: MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 3. Name and last knc~w~ddress of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MEMBERS FIRST FEDERAL CREDIT UNION P.O. Box 40 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 3879 Spring Road Shermans Dale, PA 17090 (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 penaaties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 27, 2010 GOLDBEC McCAFFE TY & McKEEVER BY: TINAMAIrtTF. BOSCI~TTI 10-2204 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 4650 Regent Blvd Irving, TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shennans Dale, PA 17090 Plaintiff Defendants; IN THE COURT OF (:OMMON PLEAS of Cumberla~id County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Tenn No. 10-2204 CIVIL TERM THIS LAW FIItM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SUNDY, MELISSA A MELISSA A. SUNDY 3879 Spring Road Shermans Dale, PA 17090 Your house at 3879 Spring Road, Shermans Dale, PA 17090 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $49,377.78 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC.., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA1 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: 10-l_204 CNIL TERM 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- T`HROUGH CERTIFICATES, SERIES 2003-IA1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You maybe able to stop the sale by filing a petition asking the Court to stril:e or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one„ the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE: OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. 'Che 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. 8. You may contact the Foreclosure Resource Center: http://www_philadelphiafed.oreJforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 10-2.204 CNIL TERM Carlisle, PA 17013 717-243-9400 r 10-2,204 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME. FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989•-2227 for free counseling. 3). Visit HUD'S website www.hud.~ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa. or~Jconsumers/homeowners/real. aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 95866FC. Para informacion en espanol puede communicarse con Loretta ~d 215-825-6344. r All that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania bounded and described pursuant to a survey be Earl D. Palm & Sons, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of former Highway Route No. 34, also known as Sterrets Gap Road; thence along a post fence, by land now or formerly of Elmer Mountz, South 36 degrees 55 minutes 20 seconds East 249.15 feet to an iron pin, thence by the center of a stone ro~~, South 5 degrees 5 minutes 52 seconds East 248. 71. feet to an iron pin; thence by land now or formerly of the Thompson Heirs, South 82 degrees 19 minutes 28 seconds West 238.54 feet to stones; thence by land now or fomerly of William L. Arndt, North 6 degrees 12 minutes 13 seconds West 288.81 feet to an iron pin; thence by the same, North 30 degrees 18 minutes 45 seconds West 107.29 fee to an iron pin in the road bed of former Highway Route No. 34 aforesaid; thence in said :road bed, North 56 degrees 33 minutes 55 seconds East 179.73 feet to the Place of BEGINNING, being improved with a two and one-half story house. BEING THE SAME PREMISES BY DEED DATED 12/15/95, CONVEYING FROM SCOTT M. WERT AND TAMMY S. WERT, HUSBAND AND WIFE TO MARK E. SUNDY AND MELISSA A. SUNDY, RECORDED 12/18/85, IN BOOK 132, PAGE 881. BEING KNOWN AS 3879 SPRING ROAD, SHERMANS DALE PA 17090 TAX PARCEL NO: 21-04-0373-021 10-2204 CIVIL TERM GOLDBECI~ McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IA 1 4650 Regent Blvd Irving, TX 75063 vs. MELISSA A. SUNDY MARK E. SUNDY Mortgagor(s) and Record Owner(s) 3879 Spring Road Shermans Dale, PA 17090 Plaintiff Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2204 CIVIL TERM 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 YO[1 WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: S[JI3DY, MARK E. MARK E. SUNDY 3879 Spring Road Shermans Dale, PA 17090 Your house at 3879 Spring Road, Shermans Dale, PA 17090 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $49,377.78 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-IAl 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: ' ~ 10-2204 CNIL TERM 1. 'The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL 'TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2003-IA1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff; you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid t:o the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. "The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or~~/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 10-2204 CNIL TERM Carlisle, PA 17013 717-243-9400 10-2204 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http•/Jwww phfa ors/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention package. Call our toll free number at 1-866-413-2311 or via email at homeretention(cr~,~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you. leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 95866FC. Para informacion en espanol puede communicarse con Loretta ~~1215-825-6344. All that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania bounded and described pursuant to a survey be Earl D. Palm & Sons, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of former Highway Route No. 34, also known as Sterrets Gap Road; thence along a post fence, by land now or formerly of Elmer Mountz, South 36 degrees 55 minutes 20 seconds East 249.15 feet to an iron pin, thence by the center of a stone row, South 5 degrees 5 minutes 52 seconds East 248.71. feet to an iron pin; thence by land now or formerly of the Thompson Heirs, South 82 degrees 19 minutes 28 seconds West 238.54 feet to stones; thence by land now or fomerly of William L. Arndt, North 6 degrees 12 minutes 13 seconds West 288.81 feet to an iron pin; thence by the same, North 30 degrees 18 minutes 45 seconds West 107.29 fee to an iron pin in the road bed of former Highway Route No. 34 aforesaid; thence in said :road bed, North 56 degrees 33 minutes 55 seconds East 179.73 feet to the Place of BEGINNING, being improved with a two and one-half story house. BEING THE SAME PREMISES BY DEED DATED 12/15/95, CONVEYING FROM SCOTT M. WERT AND TAMMY S. WERT, HUSBAND AND WIFE TO MARK E. St1NDY AND MELISSA A. SUNDY, RECORDED 12/18/85, IN BOOK 132, PAGE 881. BEING KNOWN AS 3879 SPRING ROAD, SHER_MANS DALE PA 17090 TAX PARCEL NO: 21-04-0373-021 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-2204 Civil COUNTly OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for AMERIQUEST MORTGAGE SECURITIES INC, ASSET-BACKED PAS- THROUGH CERTIFICATES, SERIES 2003-IA1, Plaintiff (s) From MELISSA A. SUNDY and MARK E. SUNDY (I) 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 $49,377.78 L.L.$.50 Interest from 5/28/10 to Date of Sale per diem at $5.98 Atty's Comm % Due Prothy $2.00 Atty Paid $188.50 Other Costs Plaintiff Paid Date: 6/2/10 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LISA LEE, ESEQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone : 215-627-1322 Supreme Court ID No. 56129 On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 3879 Spring Road, Shermansdale, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a-legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication. attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 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 s ~ements as to time, place and character of publication are true. S O AND SUBSCRIBED before me this 0 da of Jul 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Pubiio CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expiros Apr 28.2014 lam-- _ L' a Marie Coyne, itor W T tar Writ No. 2010-2204 Civil Deutsche Bank National Trust Company vs. Mark E. Sundy Melissa A. Sundy Atty.: Thomas Puleo All that certain tract of land situ- ate in Middlesex Township, Cumber- land County, Pennsylvania bounded and described pursuant to a survey be Earl D. Palm & Sons, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of former Highway Route No. 34, also known as Sterrets Gap Road; thence along a post fence, by land now or formerly of Elmer Mountz, South 36 degrees 55 min- utes 20 seconds East 249.15 feet to an iron pin, thence by the center of a stone row, South 5 degrees 5 minutes 52 seconds East 248. 71. feet to an iron pin; thence by land now or for- merly of the Thompson Heirs, South 82 degrees 19 minutes 28 seconds West 238.54 feet to stones; thence by land now or fomerly of William L. Arndt, North 6 degrees 12 minutes 13 seconds West 288.81 feet to an iron pin; thence by the same, North 30 degrees 18 minutes 45 seconds West 107.29 fee to an iron pin in the road bed of former Highway Route No. 34 aforesaid; thence in said :road bed, North 56 degrees 33 minutes 55 seconds East 179.73 feet to the Place of BEGINNING, being improved with a two and one-half story house. BEING the same premises by deed dated 12/15/95, conveying from Scott M. Wert and Tammy S. Wert, husband and wife to Mark E. Sundy and Melissa A. Sundy, recorded 12/ 18/85, in Book 132, Page 881. BEING KNOWN AS 3879 SPRING ROAD, SHERMANS DALE, PA 17090. TAX PARCEL NO: 21-04-0373- 021. The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c'rl~e ~latriot News NOw you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in tree office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/09/10 07/16/10 07/23/10 to d subscribed befor me is 05 of August, 2010 A.D. ,' ~ ~ __.~_. Notary Pub !c COMNIONWEgL7~~i tiF i~ENNSYLVANIH Notarial Seal -~-°-_) Lowe rPaxton Twpr Dauphin Colunty ! My Commission Expires Nov, 26, 2011 ~ Membe-, Pennsvivan!a Association of N- ~~rje5 '~ wrtt No. 2oia~aa ci~it Tarn, DAUtsche Bak National Trust Company Vs Mark E. Sundt' Melissa A. Bundy Atty: Thomas Putao All that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania bounded and described pursuant to a survey be Eazl D. Palm 8r Sons, dated April 13, 1984, as follows: BEGINNING at an iron pin in the old road bed of former Highway Route No. 34, also known as Sterrets Gap Road; thence along a post fence, by land now or formerly of Elmer Mountz, South 36 degrees SS minutes 20 seconds East 249.15 feet to anuon pin, thence by the center of a stone row, South 5 degrees 5 minutes 52 seconds East 248.71. feet to an iron pin; thence by land now or formerly of the Thompson Heirs, South 82 degrees 19 minutes 28 seconds West 238.54 feet to stones; thence by land now or fomerly of William L. Arndt, North 6 degees ]2 minutes 13 seconds West 288.8'1 feet to an iron pin; thence by th'e same, North 30 degrees 18 minutes 45 seconds West 107.29 fee to an iron pin in the road, bed of former Highway Route No. 34 aforesaid; thence in said :road bed, North 56 degees 33 minutes 55 seconds East 179.73 feet to the Place ofBEGINNING,beingtmproved with atwo and one-half story house. BEING THE SAME PREMISES BY DEED DATED 12115/95, CONVEYING FROM SCOTT M. WERT AND TAMMY S. WERT, HUSBAND AND WIFE TO MARK E. SUNDY AND MELISSA A. SUNDY, RECORDED 12118/85, IN BOOK 132, PAGE SBI. BEING KNOWN AS 3879 SPRING ROAD, SHERMANS DALE PA 17090 TAX PARCEL N0: 21-04-0373-021 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Ameriquest Mortgage Securities Inc, Tr is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 2nd day of June, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 2204, at the suit of Ameriquest Mortg_a~e Securites Inc, 'Tr against Melissa A & Mark E Sundy is duly recorded as Instrument Number 201029363. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this j ~`tday of :7 . " ~ ' Recorc't~r of Deeds Recorder of Deeda, Cumberand County, Cede. Pt> "'. MY Commission E~ires the Frst Maiday of Jen. 2014