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HomeMy WebLinkAbout04-5044GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE, OF AMERIQUEST MORTGAGE SECURITES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2003-1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2003, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff Vs. PATRICIA A. HENNEGHAN Mortgagor(s) and Real Owner(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No.Q4-swy ew?? CIVIL ACTION: MORTGAGE r0RECL0@UfW 134 W. Penn Street Carlisle, PA 17013 Defendant(s) THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you most 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 m do so the case may proceed without you and ajudgment may be entered against you by the Court without further nonce for any money claim in the Complaint of for any other claim or reliefrequested by the Plaintiff. You may lose money orproperty 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, 0 SO ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEIAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A USIA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA CORTE 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 DUE USTED PUEDA PERDER OINERO, 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 OFICRVA 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 REOUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE, OF AMERIQUEST MORTGAGE SECURITES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2003-1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2003, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The name(s) and address(es) of the Defendant(s) is/are PATRICIA A. HENNEGHAN, 134 W. Penn Street, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On December 23, 2002 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1808 Page 1294. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE, OF AMERIQUEST MORTGAGE SECURITES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2003-1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2003, WITHOUT RECOURSE by Assignment of Mortgage, which is being lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due June 01, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $61,580.85 Interest from 05/01/2004 $2,596.24 through 10/31/2004 at 8.2500% Per Diem interest rate at $14.11 Attorney's Fee at 5.0% of Principal Balance $3,079.04 Late Charges from 06/01/2004 to 10/31/2004 $504.62 Monthly late charge amount at $26.60 Costs of suit and Title Search $900.00 $68,660.75 Escrow Advance +$60.54 Fees +$106.00 Other Fees Due +$40.00 Monthly Escrow amount $64.46 $68,867.29 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff s Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $68,867.29, together with interest at the rate of $14.11, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By. ?KF p LD CK MICA ER'l??yY & McKEEV BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: AMERIQUES RTGA COMPANY Exhibit "A" File Number: 524959 Description: The land referred to herein is situated in the State of Pennsylvania, County of Cumberland, City of Carlisle described as follows: ALL'THAT CERTAIN LOT OF GROUND INTHE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, BEING LOT 4 OF THE FINAL SUBDIVISION PLAN FOR CARLISLE OPPORTUNITY HOMES, INC., AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 68, PAGE 91, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE DIVIDING LINE BETWEEN LOTS 3 AND 4 OF THE AFORESAID SUBDIVISION PLAN; THENCE NORTH 04 DEGREES 49 MINUTES 48 SECONDS EASTA DISTANCE OF 59.78 FEET TO A POINT, THENCE CONTINUING SOUTH 06 DEGREES 17 MINUTES 37 SECONDS EAST A DISTANCE OF 50.62 FEET TO AN IRON PIN; THENCE ALONG WEST PENN STREET SOUTH 83 DEGREFS 53 MINUTES 54 SECONDS WEST A DISTANCE OF 32.38 FEET TO THE POINT OF BEGINNING. SOURCE OF TTrLS: BOOK 230 PAGE 320 (RECORDED 10/04/2000) APN: 05-20-1798-143 I Certify this to be recorded In Cumberland County PA Recorder of Deeds 0K 18 0 8 Poll j t:- -,= - R, -,id&- R ..M2*23 afiinoR P. 4e FS P.O. Box line Santa Ass, CA 92711-1006 7182 6384 3060 0421 4541 PATRICIA A HENNEGHAN 134 W PENN ST CARLISLE, PA 17013 ACT 91 NOTICE ? AMERIQUEST MORTGAGE COMPANY August 03, 2004 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OF POLICY Loan Number: 0041836964 Property Address: 134 W PENN ST, CARLISLE PA, 17013 Original Lender: Ameriquest Mortgage Company Current LenderlServicer: Ameriquest Mortgage Company THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE 18 SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is as official notice that the mortgage on your home is in defaut and the leader intends to foreclose. Specific Information about the nature of the default Is provided in the attached pates. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save Your home. This Notice explains how the program works. To see N HEM" can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Coanseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. H yon have any questions, yea may call the Pennsylvania Housing Nuance Agency toll free at 1-800-342-2997.(Peneas with impairod hearing cast call (717) 780-1869). This Notice contains important legal Information. H 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 year aura. The local bar association may be able to help yaw find a lawyer. LA NOTIFICACION EN ADdUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SII DERECHO A CONTINUAR VIVIENDO EN SII CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO [rtllMlwvl,-m ARRIBA. PUZDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDRWM SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE 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: s 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. During that time you most arrange and attend a face-to-face meeting with one of the consumer credit connecting agencies Bated at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. 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 --1f you meet with one of the consumer credit counseling agency 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 -mos. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the uroperty ie located are set fotth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your tatemious. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your det$ult.) If you have tried and are unable to resolve this problem with the lender, 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 Homeowcers 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. Your application MUST be filed or postmarked within thirty (30) days of your lace-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTEB" FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, AGENCY ACTION - 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. snedSNCrh?vi August 03, 2004 Loan Number: 0041856964 NOTEt IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. Of you have filed bankruptcy yon can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property lotted at: at 134 W PENN ST, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 06/01/04 thin 08/01104 at $532.14 per month Monthly Payments plus late charge or other fees: $2084.92 Total Amount to Care Default: $2084.92 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use it not applicable): N/A HOW TO CURE THE DEFAULT --You may care the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LE"M WHICH IS $2084.92 PLUS ANY MORTGAGE PAYMENTS AND LATE 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 vavable and sent to: Ameriquest Mortgage Company 505 City Parkway West, Suite #100 Orange, CA 92868-2912 You can core any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N/A IF YOU DO NOT CURE THE DEFAULT--If yon do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights 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 open 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 care 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 care 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 cored the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still hsye the right to cure the dr&uIt and prevent the sale at soy time ap to oa 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 writimt by the leader and by performing any other requirements under the morteaae. Curial 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 (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you betbre the sale. Of course, the amount needed to core the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Ameriquest Mortgage Company PO Box 11000 Orange, CA 92711-1000 Phone Number 000430-5262 Fax Number 714-347-5037 EFFECT OF SHERIFFS SALE --You should realize that a, Sheriffs 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 famishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ may or R may not (CHECK ONE) 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 MAY ALSO HAVE THE RIGHT: z TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. z TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. s 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 TAMES IN ANY CALENDAR YEAR.) x TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, r 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 ARE ATTACHED Very Truly Yours, Ameriquest Mortgage Company Cc: Amerignest Mortgage Company Attn: Collections Department Loan Number: 0041056964 Mailed by 1st Class Mail and by Certified Mail 6011 C?MVIFOf Homeowners' Emergency CUMBERLAND CCCS of Western Pennsylvania, Inc, 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Assistance Program COUNTY Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region Adams County Housing Authority 1514 Derry Street 139-143 Carlisle St Harrisburg, PA 17104 Gettysburg, PA 17325 (717) 232-9757 (717) 334-1518 FAX (717) 234-2227 FAX (717) 334-8326 RUT,IIMC/I6-01 '?- ?-?t ? ? .- , _, 0 ? ? ° - =° ??? SHERIFF'S RETURN - REGULAR CASE NO: 2004-05044 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS HENNEGHAN PATRICIA A CHIEF DEPUTY RONNY ANDERSON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HENNEGHAN PATRICIA A the DEFENDANT , at 1205:00 HOURS, on the 12th day of October , 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to PATRICIA A HENNEGHAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this day of Vv A.D. J P othonotary So Answers: R. Thomas Kline 10/12/20IMCCAFFERTY GOLDBECK CK R By. Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE, OF AMERIQUEST MORTGAGE SECURITES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2003-1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2003, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. PATRICIA A. HENNEGHAN (Mortgagor(s) and Record owner(s)) 134 W. Penn Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County No. 04-5044 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE r-a C` ?,a O C-- ` ', -n :,? ? w y? .-i??7 ?3 V ?Z ? --? ^^??