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Home My WebLink About05-5885 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.J? #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION. AS TRUSTEE, OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 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 Term . No. O~>- S HS Cw:J .- I #--- vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagors and Real Owners 57 Tabor Road Newburg, P A 17240 CIVI,- J\CTiON: MORTGAGE ~ECL~mF 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 wamed 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARlO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARlO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRlTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. . RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARlO. DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQuI ABAJO. EST A 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 HONORARlO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call the following number: 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-0674. 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, OF AMERlQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH 'CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1,2002, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The names and addresses of the Defendants are JOSEPH A. ROHM. 57 Tabor Road, Newburg, PA 17240 and ANNA M. ROHM, 57 Tabor Road, Newburg, P A 17240, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On May 22,2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERlQUEST MORTGAGE COMP ANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1760, Page OOiO. The mortgage has been assigned to: U.S. BANK NATIONAL ASSOCIATION. AS TRUSTEE, OF AMERlQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES. UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE by assignment of Mortgage which assignment is 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 Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2005 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 06/01/2005 through 11/30/2005 at 12.9900% Per Diem interest rate at $21.13 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 07/0112005 to 11/30/2005 Monthly late charge amount at $39.23 Costs of suit and Title Search Escrow Advance Fees Corporate Advance Suspense Monthly Escrow amount $108.81 $58,548.17 $3,866.79 $2,927.41 $254.52 $900.00 $401.36 $106.00 $20.00 -$76.78 $66,947.47 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess ofthe amount demanded in the Action. 8. Plaintiff is not seeking ajudgment of personal liability (or an "in personam" judgment) against the . Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy. but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania. on the 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$66,947.47, together with interest at the rate of $21.13, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: tl .L L ECK McCAFFERTY & McKEEVER By: Jo EPH A. GOLDBECK, JR.. ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Nanci Jimenez . 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. I . .... Date: j\-I\)'-~''''' P,~lii6it }l , , LEGAL DESCRIPTION 51 TABOR ROAD NEWBURG, PA 11240 CUMBERLAND County EXHI!U'l' fAr ALL that certain traGt of land situate in the Township of Hopewell, Cumberland County, Penn~ylvaniaf bounded and described as follows: BEGINNING at a point in a Township Road at corner of lands now or formerly of Richard GUY~~; thence in a Southerly direction and by land nOW or formerly Richard Guyer and also by lands now or formerly of George Monn, 500 feet to an iron pin; thence in an Easterly direction by lands now or formerly of J. Preston Tnrush 150 feet to an iron pin; thence by the sama in a Northerly direction .500 feet to a point in the center of the aforesaid Township Road; thence by the canter of the aforesaid Township Road in a Nesterly direction 150 feet to the place of BEGINNING. BlfI',7' 6 0 PGO 02 6 ~-_. P,~lii6it (]3 'P.O. Box 11000 Santa A.a. CA 92711-1000 ~.AMC MORTGAGE SERVICES 7182 b389 3060 0672 9913 September 02, 2005 JOSEPH A ROHM ANNA M ROHM 57 TABORRD NEWBURG, PA 17240 "/NMt" ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OFPOLIQ: Loan Number: Property Address: Original Lender: Current Lender/Servicer: 0036002251 57 TABORRD, NEWBURG PA,17240 AMC Mortgage Services, Inc. AMC Mortgage Services, Inc. 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 INFORMA. TION 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 ao. orru:iai o.oIlee that the morla.ae 00. your home is ill der.lllt. .Ild the leJlcler ID.teo.ds to roreelo... Soecifie in.formation about the nature of the dee.lIlt is provided ill the attacked pallet.. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) maY be .ble to heIIl to "YO your home. This Notice exolahll how the ul'Oaram works. To see ir HEMAP ee helll. va.. m..st MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice witb. YOU wb.ell YOU meet witb. tb.e COgnaeliDR Alencv. The name. address aDd Dhone Dumber of Consumer Credit Coonselin. A2eJlcles lemDR your COUll" are listed. at the. cad of lltb N otite. If TOU have allY Question.. you maT can tile PellDlVlvui. Rou.i.. Finance Aaenev toll free at 1-300-341-2397.lPersollS witb. Impaired hearl... ea.. ..II (717) 780-18691. This Notice eontains important legal information. If you have any questions, representativeJ at the CODsumer Credit CounsellD.f! A!!<o.ey may be able to help explalD. it. Yon m.y als. wet to eOlltact am .ttonley ID. your area. Thel..al bar .....iali.1l m.y be able to help yon find. I.wyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIIi'ICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO trU."V/1ltFI5-05 Also doing business as Delaware AMC Mortgage Services, Inc., in the states of Texas, Rhode Island, and New Hampshire. 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 REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WIDCH 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: r IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUll. CONTROL, r IF YOU HAVE A REASONABLE 'PROSPECT OF BEING ABLE TO 'PAY YOUR MORTGAGE PAYMENTS, AND r IF YOU MEET OTHER ELIGIBD..ITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary SIIry offoleclosure on yom mortgage for thirty (30) da)'1l from the date of this Notice. During thnI time yon mnst urange and attend a face-Io-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUlI. WITHIN THE NEXT (30) DAYS. IF YOU DO NtYI' 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' EXPLAlNS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -!fyou meet with one of the consUDlOJ credit counseling a~...cv listed at the end of Ibis notice. the lender mav NOT take action aeainst YOu for thirtv (30) daYS after the date of this mcetinlr. The names addresses and telephone numben of desienated consumer credit connselin. aeOllcies for the county in wbich the oronertv is localed are sel forth at the Olld of this Notice. It is only necessary to schedule one face-to-face meeting. Advise yom lander immediatelv 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 for specific information about the nature of your default.) !fyon have tried and are unable to resolve this problem with the lender, you have the right to apply fOI financial assistance from the Homeownel's Emelgency Mortgage Assistance Ptognun. To do so, yon mnst fill out, sign and file a completed Homeowners EmelgOllcy Assislance Progtam Application with one of the designated consumer cledit counseling agencies listed at the end of this Notice. Only consumer credit connseling agencies have applications!ol the progtam and they will assist yon in submitting a complete application to the Pennsylvania Housing Finance Agency. YoUJ application MUST be filed 01 postmukcd within thirty (30) days ofyoUJ face-to-face meeting. YOU MUST FILE YOUll. APPLICATION PROMPTLY. IF YOU FAD.. TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN TIDS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUll. APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance ue vel}' limited. They wiJl be disbDlSCd by the Agency nndel the eligibility criteria established by the Act. The Pennsylvania Housing Finanee AgOllCY has sixty (60) days to make a decision after it receives your application. During thnI time. no foleclosure proceedings will be punued against you if you have met the time requiJemcnts set forth above. You wiJl be notified diJectly by the Pennsylvania Housing Finance Agency of its decision On your application. il'0lI0Jlr<<:PI~~0I; September 02, 2005 LOllD Number: 003600225 I NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLWWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you Irave filed bukrupt.y you ... .till apply for Emerl"ney Mort.al" A..ist.....) HOW TO CUllE YOUR MORTGAGE DEFAULT {]IrinR it UD to datel. NATURE OF THE DEFAUL 1: - Tbe MORTGAGE debt by the above lender on your property located at: 57 TABOR RD, NEWBURG, PA 17240 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following mouths and the following amounts are now past due: 07/01105 tlrru 09/01105 at $763.22 per month Monthly Paym.nta plualate charge or other fcea: $2388.94 Total Amount to Cure Ddanlt: $1388.94 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not uoe imot aODlicable): 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 52388.94 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by cash. cashier's cbeck, certified cbeck or money order made uavable lIDd aent to: AMC Mortgage Services 505 Cily Parkway West, Suite *100 Orange. CA 92868 You can curellDY other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not aoolicable.) N/ A IF YOU DO NOT CURE THE DEFAULT--Ifyon do oot cure the ddanh within THIRTY (30) DAYS of the date of this Notice, tire lender Intend. to exerci,e It, ri~lrt, to aeeelerate tire mortule debt. Thia means that the entire ontstanding balance of this debt will be considered due immediately and you may lose tbe chance to pay the mortgage in monthly installments. IffnIl payment of the total amount past due is not made within TIDRTY (30) DAYS, the lender also intends to instruct it. attorney. to start legal action 10 foreel...e lIDon vour mortRued Jlrooertv. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refen yonr case to its attorneys, bnt you cure the delinquency before the lender begins legal proceeding. against you, yon will still be required to pay tbe reasonable tlItorney', fees that wete actually incurred, np to $50.00. However, if legal proceedings are atatted against yon, YOD wiD have to pay all reasonable attorney' a fees actually incurred by the lender even if they exceed $50.00. Any tlItorney's feea will be added to the amount yon owe the lender, which may also include other reasonable cost.. !fyou rare tbe default witlrin the THIRTY (30) DAY periud, you will not be required to ply Ittoney', fee~ OTHER LENDER REMEDIES - The lender may also sue yon persoually for the unpaid princi]lOll balance and aU other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you bave not cured the default within the THIRTY (30) DAY period and forecloslUe proceedinga have begun, Y<>11 81m have me right 10 cure the default and orevent the sale at anv time up to one hout bcfore the Sheriffa Sale. You mav do so bv payinl! the total amount then past due. plus any late or other char~c::s then duc, reasonable attorney's fees and costs connected with 1hc foreclosure .ale and anv other costs connected with the Sherifi'. Sale as llDecified in writina by the leader and by [F~O~IHCPI~OA performin2 any other requiremenlli under the mort2ase Curlngyuur deCault In the manner .et Corth In thl. notiee will restore your mortj:age 10 the I..e position a. if you had never defaulted.. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It i. estimated that the earliest date that snoh a Sheriff's Sale of the mortgaged propeny could be held would be approximately (6) MONTHS from the date of this Notice. A notice of Ihe actual date of the Sheriff's Sale will be senllo you beCore 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 payroent or action will be by conlacting the lender. HOW TO CONTACT THE LENDER: AMC Mortgage Service. PO Bos 11000 Santa An.. CA 9%711-1000 Phone Number 80~30-526Z F", Number 714-347-5037 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged propeny and your right to <K:Cl1py it. lfyou continue to live in the propeny after lbe 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 nnt (CHECK ONE) seD or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payroents, charges and attorney's fees and costs are paid prior to or at the sale and that lbe other requirements of1he mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE TillS DEFAULT CURED BY ANY TillRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HA VB 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 BELmVE YOU MAY HA VB TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUll COUNTY ARE ATTACHED Very Truly Yours, AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Departmenl Loan Number: 0036002251 Mailed by 1st CIa.. Mail and by Certified Mail ~FOo\OUN:PI1.1lIi Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of We stem PA 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Lovesbip, Inc. 2320 North 5th Street Harrisburg, P A 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 APA0411U:;P!2_or; 0 ...., 0.;;,:-:-' 0 ...... c_ " ~'\.~ "j\ -11 ..... "n -I C; T ~ (\: r ~ ..'.1 (,,\ ' \ F - \ '>-' . -c :'5.1 " .. f,:"j c .J:.. v-, , "'9 <:, t:\ Tv __J " -.c, <.oJ ~o (" V, I:::', - -------- , SHERIFF'S RETURN - REGULAR CASE NO: 2005-05885 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS ROHM JOSEPH A ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ROHM JOSEPH A the DEFENDANT at 1525:00 HOURS, on the 13th day of December, 2005 at 57 TABOR ROAD NEWBURG, PA 17240 by handing to DARRYL OTT, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 19.20 .00 10.00 .00 47.20 -~/-'-;.~:;" r- (-:, ..' . ~:':''''''''':'''''''''''-'-'''/' . ~"'~.'--'''''~' ,'- '~""""'..- '// '-'/;/0 -~:~q~:.~ R. Thomas Kline 12/14/2005 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before '" me this -<8- day of '~ ~ -' . \ .. tl/ Deputy ~rl~ ~J.{ ,'fffloo~ A.D. SHERIFF'S RETURN - REGULAR .. CASE NO: 2005-05885 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS ROHM JOSEPH A ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ROHM ANNA M the DEFENDANT at 1525:00 HOURS, on the 13th day of December, 2005 at 57 TABOR ROAD NEWBURG, PA 17240 by handing to DARRYL OTT, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 R. Thomas Kline .',~.<::e-.~{::? ~';, me this IP' "jS- day of 12/14/2005 GOLDBECK MCCAFFERTY MCKEEVER ~~~i(- De uty S erl Sworn and Subscribed to before A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck., Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia. P A 19106-1532 215-825-6321 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, OF AMERlQUEST MORTGAGE SECURITIES INe., SERIES 2002-3, ASSET- BACKED P ASS- THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1,2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN TIIE COURT OF COMMON PLEAS of Cumberland County No. 05-5885 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mu.~r(8) lIIIfI Record OWner(lI)) 57 Tabor Road Newburg, PA 17240 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. SQUIRE () f; 's. i'J {-f EIlr: ~;;c ~:-..~ "-;"\ j~ ~~i ?j -', ...., = = C" :J:: ::> :;;0 C> -n :::r!'7l rnr- 15eJ ::) ,l.~ ~~ ,..) :::'.1 ".::;,. :0 -< U'l -0 ::J!: (-:? (;n