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HomeMy WebLinkAbout05-1289 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INe., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite roo Orange, CA 92868 OF Cumberland COUNTY CNIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, OS -12P'1 CUlt YtI<.Jv Plaintiff' vs. CHESTER J, JUMPER DAISY MAY JUMPER Mortgagors and Real Owners 13 N, Queen Street Shippensburg, P A 17257 CIVIL ACTION: MORTG,t,l3L FOR~CLOgL!RF Defendants 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 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 EST A DEMANDA Y A VISO, PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRIT A, EL PUNTO DE VISTA DE USTED Y CUALQUlER OBJECC10N 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 DEMAND ANTE Y REQUER1RA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO, ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO, SI USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES 1NC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTlNGTO 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. I). Call an attorney, For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or , 2), Call Pennsylvania Housing Finance Agency at 800-342-2397 for a counseling agency in your neighborhood, 3). Visit HUD'S website www.hud.gov/offices/hsglsfuleconlecon.cfin for Help for Homeowners Facing the Loss of Their Homes, 4). Call your lender 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options, 5), Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package, Call Carol at 215-825-6329 or Nancy at 215-825-6358 or fax 215-825-6429 or 215-825-6458, 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 Edward Sparkman who can be reached at 215-825-6318 or Fax: 215-825- 6418, Please reference our Attorney File Number of AMQ-0474, Para informacion en espanol puede communicarse con Loretta aI215-825-6344, 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 OF AMERIQUEST MORTGAGE SECURITIES INC" ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The names and addresses ofthe Defendants are CHESTER J, JUMPER, 13 N, Queen Street, Shippensburg, P A 17257 and DAISY MAY JUMPER, 13 N, Queen Street, Shippensburg, P A 17257, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On July 23, 2002 mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to AMER1QUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1766 Page 3333, The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMER1QUEST MORTGAGE SECURITIES INC" ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE by Assignment of Mortgage, which is being lodged for recording, The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Ci vii Procedure 10 19(9) 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". 5, The mortgage is in default because monthly payment of principal and interest upon said mortgage due February 01,2004, and each month thereafter are due and unpaid, and by the telU1s of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6, The following amounts are due on the mortgage: Principal Balance Interest from 01/01/2004 through 03/31/2005 at 8,9990% Per Diem interest rate at $13.62 Reasonable Attorney's Fee If the Mortgage is reinstated prior to a Sheriffs Sale the Attorney's Fees may be less than this amount based on work actually perfolU1ed, The Attorney's Fees requested are in confolU1ity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's fees of up to 5% of the remaining principal balance ($2,724.27) in the event the Property is sold to a third party purchaser at Sheriffs Sale or ifthe complexity ofthe action requires additional fees in excess of the amount demanded in the Action, Late Charges from 02/01/2004 to 03/31/2005 Monthly late charge amount at $30.23 Costs of suit and Title Search $54,485.44 $6,210,72 $1,250,00 $604,60 Fees Escrow Advance $900.00 $63,450,76 +$124,05 +$335,82 NSF Charges Recoverable Balance +$20,00 +$1,680.00 $65,610_63 7, Plaintiff is not seeking a judgment of personal liability (or in personam judgment) against the Defendants in this Action but reserves it's 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. 8. Notice oflntention 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 $65,61 0,63, together with interest at the rate of $13,62, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property, By: 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 unsworn falsification to authorities, Date: :;- / 0 ~C' \ ~l(hi6it .9L ALfA LOAN POLICY SCH~DULE A CON~INUED Order No. , policy NO, , 000003664 05 - 057564 Legal Description ALL that certain lot of land situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit:: BEGINNING at a point on North Queen Street at corner of an alley; thence eastwardly from the inner edge of pavement with Baid alley 190 feet to land now or formerly of C, W. Thrush; thence in a northwardly direction parallel with Baid Queen Street 64 feet to land now or fo.r:merly of J. W, Kline; thence westwardly by lot now or formerly ot J, W. Kline 190 feet to said Queen Street; thence southwardly by said Queen Street 64 feet to the place of BBGINNING, EXCEPTING therefrom, however, a lot of ground to the rear of said tract having a depth at 59 feet with a width along said alley of 64 feet, which tract R. Paul Smith and Catherine W, Smith, husband and wife, conveyed to Lawrence Rinehart, et ux., by deed dated August 23, 154B and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 13-X at Page 226. This policy is inValid unless chs in8ur~ng provielona and sahedulos A and B are ~t~Qchea First Ame~ican Title Ins~rapce Company ~~hi6it r:B Ameriquest Mortgage Company P,O, Box 11000 Santa Ana, CA 92711-1000 CHESTER J JUMPER DAISY MAY JUMPER 13 N QUEEN ST SHIPPENSBURG,PA 17257 January 11, 2005 .11 ~"R ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OF POLICY Loan Number: Property Address: Original Lender: Current LenderlServicer: 0037186632 13 N QUEEN ST, SHIPPENSBURG PA, 17257 Ameriquest Mortgage Company Ameriquest Mortgage Company THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS 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 an official notice that the mort!!3e:c on Your home is in default. and the lender intends to foreclose~ Snecific information about the nature of the default is orovided in the attached Daees. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) m.v he able to help to save vour home. This Notice exolains how the oroe:ram works. To see if HEMAP can help, von must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselinl! Al!cncv. The name. address and ohone number of Consumer Credit Counseline Aecncies servine: your Canntv are listed at the end of this Notice. If vou have anY Questions~ vou may call the PennsYlvania Housim! Finance A.encv toll free at 1-800-342-2397.!Persons with impaired hearin. 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 NOTlFICACION EN ADJUNTO ES DE SUM A IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTlFICACION OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO EST A AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO PAAcrfiiNCPiR_Ol ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR 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: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PA YMENTS, 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 must arrange and attend a face-ta-face meeting with one of the consumer credit counseling agencies listed 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 --If you meet with one of the consumer credit counseling a2encv listed at the end of this notice. the lender may NOT take action asminst yoU for thirty (30) days after the date of this meeting. The names. addresses and telenhone numbers of desil!nated consrnner credit counseline: allencies for the county in which the orooertv is located are set forth at the end ofthis Notice. It is only necessary to schedule one face-ta-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in a default for the reasons set forth later in this Notice (see following pages tor specific information about the nature of your default.) If you have tried and are tmable 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 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. Your application MUST be filed or postmarked within thirty (30) days of your face-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 LETTER, 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. PMU,.'N"P.'(U1 Janul\r)' 11,2005 Loan Number: 0037186632 NOTE: 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. (If you bave med bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin2 it un to date). NATURE OF THE DEF AUL T -The MORTGAGE debt by the above lender on your property locted at: at 13 N QUEEN ST, SH[PPENSBURG, PA [7257 [S SERIOUSLY [N DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 02/01104 tbm 0[/0[/05 at $503,82 per month Monthly Payments plus [ate charge or other fees: $8318.26 Total Amounllo Cure Default: $8318.26 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnotannlicable): N/A HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $8318.26 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TH[RTY (30) DAY PER[OD. Pavrnents must be made either by cash. cashier's check. certified check or money order made navable and sent to: Ameriquest Mortgage Company 505 City Parkway West, Suite #100 Orange, CA 92868-2912 You can cure any other default by taking the following action within TH[RTY (30) DAYS of the date of this letter: (Do not use if not aonlicable,) N/ A IF YOU DO NOT CURE THE DEFAUL T--Ifyou do not cure the default within THIRTY (30) DAYS ofthe date of this Notice, the lender intends to exercise its ril!hts to accelerate the morte:ae:e 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 ofthe total amount past due is not made within TH[RTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose UDon vour mortl!aeed Ofoocrtv. IF THE MORTGAGE IS FORECLOSED UPON ,- The mortgaged property will be sold by the Sheriff to payoff 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, iflegal 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 vou cure the default within the THIRTY (30) DA Y period. vou will not be reauired 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) DAY period and foreclosure proceedings have begun, you stillluwe the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by payin~ 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 anv other costs connected with the Sheriff's Sale as soecified in writing bv the lender and bv '-' PMCTBINCPIB-02 nerfor-minll any other reauirements under the mortllaee, 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 (6) MONTHS from the date of this Notice. A notice of the aclnal 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. HOW TO CONTACT THE LENDER: Ameriquest Mortgage Company PO Box 11000 Orange, CA 92711-1000 Phone Numher 800-430-5262 Fax Number 714-347-5037 EFFECT OF SHERIFF'S 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 Sheriff's 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_ mayor -L 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: . TO SELL TilE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT, . TO HAVE THIS DEFAULT CURED BY ANY TIlIRD PARTY ACTING ON YOUR BEHALF, . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSlTlON AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEF AUL T 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 ARE ATTACHED Very Truly Yours, Ameriquest Mortgage Company Cc: Ameriquest Mortgage Company Attn: Collections Department Loan Number: 0037186632 Mailed hy 1st Class Mail and by Certified Mail "FO,AD,'NCP'B.()] Homeowners' Emergency Assistance Program CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc, 2000 Linglestown Road Harrisburg, PAl 7102 (717) 541-1757 Urban League of Metropolitan Harrisburg N, 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Rcgion 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Wayncsboro, PA 17268 (717) 762-3285 YWCA of Carlisle 30 I G Street Carlisle, P A 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 fJ (.:J -fq f1- 1(; ~ q:. ,lr( ;::: RJ Dvt ...... ,9..) G' ...... C2 ii :V Vv p:: ~ "-< I , " ._,._ c., ....., (:~~ 0 c'","" ..n =\: <,,:,'-'" \,() G) SHERIFF'S RETURN - REGULAR CASE NO: 2005-01289 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS JUMPER CHESTER J ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according 0 law, says, the within COMPLAINT - MORT FORE was served upon JUMPER CHESTER J the DEFENDANT at 2034:00 HOURS, on the 24th day of March 2005 at 13 NORTH QUEEN STREET SHIPPENSBURG, PA 17257 by handing to DAISY JUMPER, WIFE a true and attested copy of COMPLAINT - MORT FORE together w' th and at the same time directing Her attention to the contents ther of. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 14.80 .00 10.00 .00 42.80 So Answers: ,../} ",/ ..~ >>~"'~ R. Thomas Kline ~ me this of Deputy Sheriff Sworn and Subscribed to before By: A.D. ,~n SHERIFF'S RETURN - REGULAR CASE NO: 2005-01289 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS JUMPER CHESTER J ET AL BRIAN BARRICK .... . , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according 0 law, was served upon says, the within COMPLAINT - MORT FORE JUMPER DAISY MAY th DEFENDANT , at 2034:00 HOURS, on the 24th day of March 2005 at 13 NORTH QUEEN STREET SHIPPENSBURG, PA 17257 DAISY JUMPER by handing to a true and attested copy of COMPLAINT - MORT FORE together ' th and at the same time directing Her attention to the contents the eof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this of A.D. J,,)\---v1~l ' (~I'(j So Answers: ",..-/')",:7 ,?~ J::'?'",":' ~":'~"'/-.,,-: .,,,' /~~ ..... -j' .--~ R. Thomas Kline 03/28/2005 GOLDB::~ MCCAF~~~~EVER Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER 'BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. No. 05-1289 Civil Tenn CHESTER J. JUMPER DAISY MAY roMPER (Mortgagor(s) and Record owner(s)) 13 N. Queen Street Shippensburg, P A 17257 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE, and against CHESTER J. JUMPER and DAISY MAY JUMPER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $66,049.46. ;,7 , r. 'ff I hereby certify that the above names are correct and that the p e ise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, A RUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROU H CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known address(es) of the Defendant(s) is/are CHESTER J. JUMPER, 13 N. Queen Street Shippensburg, PA 17257 and DAISY MAY JUMPER, 13 N. Queen Street Shippensburg, P A 17257; GOLDBEC BY: Joseph Attorney for ASSESSMENT OF DAMAGES ,TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $54,485.44 Interest from 01101/2004 through 04/30/2005 $6,619.32 REASONABLE Attorney's Fee $1,250.00 Late Charges $634.83 Costs of Suit and Title Search $900.00 FEES ESCROW ADVANCE NSF CHARGES RECOVERABLE BALANCE $124.05 $335.82 $20.00 $1,680.00 $66,049.46 GOLDBECK Me BY: Joseph A. Gal Attorney for Plainti f TY & McKEEVER AND NOW, this 3n-c:l day of f2:a'i , 2005 damages are assessed as above. (lhb-h; > 2.4 Pro Prothy . VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation wi thin 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 subj ect to penal ties of 18 Pa. C. S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CHESTER J. JUMPER, is about unknown years of age, that Defendant's last known residence is 13 N. Queen Street, Shippensburg, PA 17257, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best knowledge, information and belief. I understand that statements therein are made subj ect to penal ties of 18 Pa. C. S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DAISY MAY JUMPER, is about unknown years of age, that Defendant's last known residence is 13 N. Queen Street, Shippensburg, PA 17257, and is engaged in the unknown business located at unknown address. of my false 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: In the Court of Common Pleas of Cumberland County ,DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 No. 05-1289 Civil Tenn Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record Owner(s)) 13 N. Queen Street Shippensburg, PA 17257 Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against CHESTER J. JUMPER and DAJSY MAY JUMPER by default for want of an Answer. Assess damages as follows: Debt $66,049.46 Interest - 0110112004 to 04/30/2005 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against wbom judgment is to be entered and to his attorney of record, if any, after the default occurred and at east ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. RC.P. 237.1 ~' - Joseph A. Gold e : Attorney for Pl'n f J.D. #16132 AND NOW fYl;;J 'Jt ..... ~ , d.n()." <:; , Judgment is entered in favor of DEUTSCHE BANK NATIONA TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE and against CHESTER J. JUMPER and DAISY MAY JUMPER by default for want of an Answer and damages assessed in the sum of$66,049.46 as er the above certification. AMQ-0474 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: April 14, 2005 TO: DAISY MAY JUMPER 13 N. Queen Street Shippensburg, P A 17257 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERlQUEST MORTGAGE SECURlTIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERlES 2002-4 UNDER THE POOUNG AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002. WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange. CA 92868 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Plaintiff Term No. 05-1289 Civil Term vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record Owner(s)} 13 N. Queen Street Shippensburg, P A 17257 Defendant{s} TO: DAISY MAY JUMPER 13 N. Queen Street Shippensburg, P A 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WJTH THE COURT YOUR DEFENSES OR OBJECI'IONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THiS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HJRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVJCES TO ELlGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC SIrvineRow Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNlY BAR ASSQCIA nON 2 Uberty Avenue Carlisle,PA 17013 GOLDBECKM,CAFFERTY & M,KEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 ~ Mellon lndependence Center. 101 Market Street Philadelphia, PA 19106 215-621.1322 AMQ-0474 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: April 14, 2005 TO: CHESTER J. JUMPER 13 N. Queen Street Shippensburg, PAl 7257 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURlTIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 20024 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 In the Court of Conunon Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Plaintiff v,. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record Owner(s)) 13 N. Queen Street Shippensburg, PA 17257 Term No. OSMl289 Civil Term Defendant{s) TO: CHESTER J. JUMPER 13 N. Queen Street Shippensburg, P A 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TIffi COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE DATE OF THIS NOTICE, A WDGMENT MAYBE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RJGHTS. YOU SHOULD TAKE THJS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THJS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THJS OFFICE MAY BE ABLE TO PROVIDE YOU WJTIllNFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, fA 17013 717-243-9400 CUMBERlAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. fA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia,PA 19106 215-627-1322 c?C> l;), Jl +-- - - ~ ~ ~ - IV ~ ,--... \~ ~ ~~ ~ (- t1- .-\ r:" f, ,t,., o ~-;. ...' C-~=' C.::> <-" ...,... ~: --< , W -0 :?..: o 'Tl -' -.: h'~ ~nin COJ? ~')l(*"j ~~,r. ':n ("\-,-' S}f~ _-,J -< .c- o -.l ,Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff No. 05-1289 Civil Tenn vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagors and Record Owner(s)) 13 N. Queen Street Shippensburg, P A 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. B' Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Ioseph A. Goldbeck, Jr. AttorneyI.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER Mortgagor(s) and Record Owner(s) 13 N. Queen Street Shippensburg, P A 17257 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 05-1289 Civil Tenn TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from 0110112004 to 04/30/2005 at 8.9990% (Costs to be added) $66,049.46 ~ ~ g~ ,,~ ~~ .~ 0 .~ u ~~;..o }-I~ ~~ 00 Zu I'" ~ ~ ,fi0 (/l~~15N :,,:....r::UO ~~ '<.l., _ 0- ~""~U>M ....~ " ... ,,,- U-....'" ~~~Vlt;:l ;;;:Vl~~1'!I 8\3u~;;;:~ [-<:,,:::r:(:)~iQ Vl08;So;:J ~~O,..lZO [-<o~8'O~ ,..l;;;:[-<~(/l~ <C [-< , ,,' ~ [-< ZVl~El"'::> S~<C[-<OO [-<;:J~P::~::r: <C~O""~\:: ~~b2~0~ ~~~..ili >'I...~~;;;: ~O\;lg~ 'O\llVlM't,i c/lt...... UJ cfl 0 [-<(/l'<.~< ~~0~ o [-<15 Vl _. f~; c- O 'cfi ~~ ,.... do > ~ ~ 00 >::' ~ r- oO " '" ~~o~E ~;;2;"i!b<c ~2g~~. 2~~g~ ",;";lo~ "'" ." f;j :>' ,",Z " """"r/)~f"") '6: Ii; '< g,_ ~ ""0'" Vl '0 ~ 6 ~ .... i-" ;:J U " ~,. I'" a " ~-g ,. i-" " &l~ ~" =:- 0" ... " I'" e: u ~ J'K-: ct~ 'ti , -Jd (>-1 () v <J~ . . ~<-( -......~ ~ ::;~ ~ .~ "" " 3$3 ,g~ - .... 0<13 (:). >> <C S ].0 oo~ o - t ,." " " ~u " " ~ ~ ~ "" - ~""90o,n ...0........('1 ~ fr~<C::; ?i"'d +-' ~ I l-< ~ ~ ti~ ".... ....'"" '" lO-o <;j c:l ~ I "';o~EtVj u=?oo.- () Q ........ "0 ('~ ~~j2~ I -" ~o p... "0 "'0 "'''' -13 " .'" " (/l A -f ( r" "- , ~ , ~ ~ - ~ ~ ~ ~ :: In c:: I I (J ~ r-l \ 4 <"6 I C\ () to (} -=H () a c.. ....... ~ "1 Cl v, a v, <:) -e.,.. ri ...! V, 0- \'t ~ '0 \J) ....... - ..."... Legal Description ALL that certain lot of land sit.uate in !;he Borough of Shippensburg, Cumberland Count:y, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on North Queen St.reet at corner of an aLley; thence eastwardly from the inner edge of pavement with said alley 190 feet to land now or formerly of C. W. Thrush; thence in a northwardly di.rection parallel with said Queen Street 64 teet t.o land now or formerly of. J. W. Kline; thence westwardly by lot now or formerly of J. W, Kline 190 feet; t;o said Queen St;reet,. !;bence southwardly by said Queen Street 64 feet to the place of BEGINNING. EXCEPTING therefrom, however, a lot of ground to the rear of said tract having a depth of 59 feet; with a width along said alley of 64 feet, which tract R. paul Smith and Catherine W. Smith, husband and wife, conveyed to Lawrence Rinehart, et ux" by deed dated August. 23, 1948 and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed BOOK 13-X at Page 228. WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-1289 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC, ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002 WITHOUT RECOURSE, Plaintiff (s) From CHESTER J. JUMPER AND DAISY MAY JUMPER (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $66,049.46 Interest FROM 1/1/04 TO 4/30/05 AT 8.990% L.L. $.50 Atty's Comm % Atty Paid $140.80 Plaintiff Paid Date: MAY 3, 2005' Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary -J3y: ~ a.-, ~ P. 7& /?/ "J'-- Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 croldbeck McCafferty & McKeever . BY: Joseph A. Goldbeck, Jr. Attorney 1.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record Owner(s)) 13 N. Queen Street Shippensburg, P A 17257 No. 05-1289 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the real property located at: 13 N. Queen Street Shippensburg, PA 17257 I.Name and address of Owner(s) or Reputed Owner(s): CHESTER J. JUMPER 13 N. Queen Street Shippensburg, P A 17257 DAISY MAY JUMPER 13 N. Queen Street Shippensburg, P A 17257 2. Name and address of Defendant(s) in the judgment: CHESTER J. JUMPER 13 N. Queen Street Shippensburg, PA 17257 DAISY MAY JUMPER 13 N. Queen Street ,. Shippensburg, P A 17257 . 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, PAl 70 13 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: 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 wbich may be affected by the sale. TENANTS/OCCUPANTS 13 N. Queen Street Shippensburg, P A 17257 (attach separate sheet ifmore space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. 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. GOLD BY: Joseph Attorney for PI FERTY & McKEEVER d ck, Jr., Esq. iff DATED: April 30. 2005 Q ,. (~ ( :~ r-> = c:.:, c.ro ~ ~ o .." --< L-r; fne :Sl!J ;"--\ 1., ,.-;c .- II '~~'~~ o -, ~" ..JJ -< I W -n :3: "':-. c::> -J Joseph A. Goldbeck, Jr. Attorney J.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC" ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE CHESTER J. JUMPER DAISY MAY JUMPER Mortgagor(s) and Record Owner(s) 13 N. Queen Street Shippensburg, P A 17257 NO. 05-1289 Civil Term Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify Ihat I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. () ~ u C~ 2: -" -( ...., = = "" o -n "i!..,., fl1p -nf" :O~-:: :~:-~ (::> ~.~:~ i~~ Clrn --I :p~ :J,J -< -",.. ~~ ~ I W ....,., :3'1: ~ c:> -J 05-1289 Civil Term - GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttorneyI.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19 I 06 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Ternl No. 05-1289 Civil Term CHESTER J. JUMPER DAISY MAY JUMPER Mortgagor(s) and Record Owner(s) 13 N. Queen Street Shippensburg, PA 17257 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JUMPER, CHESTER J. CHESTER J. JUMPER 13 N. Queen Street Shippensburg, P A 17257 Your house at 13 N. Queen Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07,2005, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$66,049.46 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS . 05-1289 Civil Term YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627 -1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to tbe value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. 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 tbe Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 170 \3 .. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 05-1289 Civil Term o ~; ~~~~. :"j .~ ...., c:'::' C_? ,," ~. -"- ~~ o -n _-1 "L-n rl1F;;: ""drn ::J'i' ':.:JC> ~:-:_-:; "l-, '.-q ,~f~\ .I~'" ~ I e,,) ::? -'- .r .. c::> -...l GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County No. 05-1289 Civil Term Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record owner(s)) 13 N. Queen Street Shippensburg, PA 17257 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. ~~ JOSEPH A. GOLDBECK, JR., ESQUIRE -'0 "" 'i'" c.:) 0 c::_} en 'TI r ~ ~ (/) :r"" M "U rnr.: C.v -0 iT! }J " c;:j f'ST '-- "" ~.~ , '1 C' '--\ y--, -0 ~i~~'B g --......, ~ "'0 -~ '",0 W ~',,:,,;'ITl -' -I;:: ~'-I 0 :rj -< GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County No. 05-1289 Civil Term Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record owner(s)) 13 N. Queen Street Shippensburg, PA 17257 PRAJO:CIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only, ;flIt~- JOSEPH A. GOLDBECK, JR., ESQUIRE Cl ~:; ~ ~ o S \ v:> Sf. ..--\ :(,-n ,"11P' -L_\0 ---\....._~ .,:.\{;:~ ".-{" "~26 '.:~;{\\ "j;"" ~ ~:: -'- Cf! :;;- -' ..------------- c:: _.'/~ ::::. ""'- - Deutsche Bank National Trust Co. VS Chester J. Jumper and Daisy May Jumper In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-1289 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is retumed STAYED per instructions from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing Poundage Advertising Posting Handbills Levy Mileage Certified Mail Surcharge Law Joumal Share of Bills Prothonotary 30.00 1089.70 15.00 15.00 15.00 32.00 3.92 30.00 103.00 18.20 1.50 $1353.32 Sworn and subscribed to before rne 2005, A.D. Prothon ary So Answers: r~-;..~t!/~ R. Thomas Kline, Shenff BY ,j d~ Jvvv:ih Real Esta e Sergeant 1 . ,,0 J. g ut.- ,9 N ev. jt,f.J'tj (ioldbeck McCafferty & McKeever BY: .Ioseph A. Goldbeck,.Ir. Attorney I.D #16132 Suite 5000 - Mellon Independence Center 701 Market Slreet Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE flANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. CHESTER J. JUMPER DAISY MAY JUMPER (Mortgagor(s) and Record Owner(s)) 13 N. Queen Slreet Shippensburg, P A 17257 No. 05-1289 Civil Term Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the real property located at: 13 N. Queen Street Shippensburg, P A 17257 I.Name and address ofOwner(s) or Reputed Owner(s): CHESTER 1. JUMPER 13 N. Queen Street Shippensburg, P A 17257 DAJSY MAY JUMPER 13 N. Queen Street Shippensburg, P A 17257 1 Name and address of Dcfendant(s) in the judgment: CHESTER J. JUMPER [3 N. Queen Street Shippensburg, PAl 7257 DAISY MAY JUMPER 13 N. Queen Street Shippensburg, PA p257 3. Name and last known address of every judgment creditor \vhose judgment is a record lien on the property to be .";(l!d: DOMESTIC RELA'J IONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELF ARE - Bureau of Child Support Enforcement Health and Welt"re Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage ofrecord: 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 1,1,'110111 the plaintiff has knO\vtedge \vho has any record intcres1 in the property which may be at1ected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property' which may be affected by the sale. TENANTS/OCCUP ANTS 13 N. Queen Street Shippensburg, P A 17257 (attach separate sheet if more space is needed) 1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 30. 2005 FERTY & McKEEVER d ck, Jr, Esq. 1 iff \ \. 05.1289 Civil Tem1 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr. Attomey LD.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attomey for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Term No. 05-1289 Civil Term CHESTER 1. JUMPER DAISY MAY JUMPER Mortgagor(s) and Record Owner(s) 13 N. Queen Street Shippensburg, P A 1725? Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JUMPER, DAISY MAY DAISY MAY .JUMPER 13 N. Queen Street Shippensburg, P A 17257 Your house at 13 N. Queen Street, Shippensburg, P A 17257 is scheduled to be sold at Sheritfs Sale on Wednesday, September 07,2005, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,049.46 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 05- J 289 Civil Tern1 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURJTIES INC., ASSET BACKED P ASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE, the back payments, lale charges, costs and reasonable attorneys fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RJGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may tind out the price bid price by calling the Sheriff of717-240-6390. 2. Y 01' may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. 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 (I 0) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act inunediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 170] 3 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 05-1289 Civil Tenn OS-12,') Civil Term GOLDBECK McCAFFERTY & McKEEVER BY: Jo,eph A. Goldbeek..lf. Attomcy LD.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 2002, WITHOUT RECOURSE 5(j~ City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff VS. Term No. 05-1289 Civil Tenn CHESTER J. JUMPER DAISY MAY JUMPER Mortgagor(s) and Record Owner(s) 13 N. Queen Street Shippensburg, P A 17257 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERWF'S SALE OF REAL PROPERTY TO: JUMPER, CHESTER J. CHESTER ,J. ,JUMPER 13 N. Queen Street Shippensburg, PA 17257 Your house at 13 N. Queen Street, Shippensburg, PA 17257 is scheduled to be sold at SheritTs Sale on Vv'edncsday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enfloree the courtjudgll1ent of$66.04946 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE or AMlcRIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTlnCAlES. SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVFM BER 1,2002, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 05-1289 Civil Term YOUIVlAY BE ABLE TO PREVENT TmS SIlERIFF'~ SALE To prevent this SherifPs Sale you must take immediate action: I. The sale will be cancelled ifyoll pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, ,\S 1 RUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED PASS- THROUGH CERTIFICATES. SERIES 2002-4 UNDER THE POOUNG AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 2 I 5-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. Yau 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. Yau 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 IL\ VE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sherift's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sherifl of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. 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. Yau have a right to remain in the property until the full anaount due is paid to the Sherifl 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 \viIl state who will be receiving that money. The money \vill be paid out in accordance with this schedule Lmless exceptions (reasons \vhy 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 aner the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOlJ DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICI' I.ISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC g Irvine Rov./ Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty ^ venue Carlisle. PAl 71J 13 05-128') Civil Term IJegal Description ALIJ that ce1:tain lot of land sit.uate in the Do:cough oE S~d.ppen5burg, Cumberland County, Pennsylvania, bounded and described r:.S follcMs, to wit: BEGINNING at a poiDt on North Queen St.reet at Corner of a.n alley; thence eastwardly from the inner edge of paveinent witll said alley 190 feet to land now ot' formerly of C. N. Thrush; thence in a northwardly direction parallel \vit.h said Queen Street 64 feet to land now or formerly of. IT. \'1. Kline; thellCe westwardly by lot nOv.l OJ: fonnerly of J. N. Kline 190 feeto to said Queen Street; tohence southwardly by said Queen Street 60 feet to the place of BEGINNING. EXCEPTING therefroml however, a lot of ground to the I.-ear of said t:r'act having a depth of 59 feet with a 'Hidth along said alley of 64 feet, which tract R. Paul Smith and Catherine vl. Smith, husband dnd wife, conveyed to Lawrence Rinehart, et ux., by deed dated August 23, 1948 and recorded in the Office of the R.ecorder of Deeds of Cl1lnberl.:::lnd County in Deed Book 13-X at Page 228. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-1289 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC, ASSET BACKED PASS- THROUGH CERTIFICATES, SERIES 2002-4 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 2002 WITHOUT RECOURSE, Plaintiff (s) From CHESTER J. JUMPER AND DAISY MAY JUMPER (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 gamishee(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 $66,049.46 Interest FROM 1/1/04 TO 4/30/05 AT 8.990% L.L. $.50 Arty's Comm % Atty Paid $140.80 Plaintiff Paid Date: MAY 3,2005' Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Prothon<;Jtry n en; ,-By: ~O--?...e.. L. -I-f!/?/2/L / Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale #28 On May 09, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA Known and numbered as 13 North Queen Street, Shippensburg, more fully described on Exhibit "A" Date: May 09, 2005 BpJDcW JVVu,/1J1 Real Estat'e Deputy {-"l c::;.;:;] c::;.;:;] C::::-..:::J @ I'i\iil filed with this writ and by this reference incorporated herein. I Z :E d h- J.VH ~OOl Vd 'AltWU,; U,i\~'I:'imjn:.; .:l.:lllJ3HS 3Hl jO 381.:1:10 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATEOFPENNSYLVANIA : 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 Curnberland 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 aU 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, Vtz: ff/ / t /5 ~c:JoS--- , Affiant further deposes that he is authorized to verify this staternent by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject rnatter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before rne this /0 day of ()~ d(}O~ I NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carnsle Boro, Cumberland County My CommissiOll Expires March 5, 2009 REAL ESTATE SALE NO. 28 Wrtt No. 2005-1289 Civtt Deutsche Bank National Trust Company. as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass-Through Certificates, Series 2002-4 Under the Pooling and Serv1cing Agreement Dated as of November 1. 2002, without recourse VS. Chester J. Jumper and Daisy May Jumper Atty.: Joseph Goldbeck Legal Description ALL that certain lot of land situ- ate in the Borough of Shippensburg, Cumberland County. Pennsylvania. bounded and described as follows, to wit. BEGINNING at a point on North Queen Street at comer of an alley; thence eastwardly from the inner edge of pavement with said alley 190 feet to land now or formerly of C. W. Thrush: thence in a north- wardly direction parallel with sald Queen Street 64 feet to land now or formerly of J. W. Kline; thence west- wardly by lot now or formerly of J. W. Kline 190 feet to said Queen Street: thence southwardly by said Queen Street 64 feet to the place of BEGINNING. EXCEPTING therefrom. however. a lot of ground to the rear of said tract having a depth of 59 feet with a width along said alley of 64 feet, which tract R. Paul Smith and Cath~ erine W. Smith. husband and wife, conveyed to Lawrence Rinehart. et ux, by deed dated August 23. 1948 and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 13-X at Page 228.