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HomeMy WebLinkAbout06-0084GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff IN THE COUR1 Ur OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagors and Real Owners 136 Sunnyside Drive Carlisle, PA 17013 Defendants Term No. 010 -?1u ? J elv?? ??ILm ??4?E;I..d13I>?1E 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, PA 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 ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES VERIFICATION 1, NL ACi 1iMpnez , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. 3 o'. Date: anci Jime ez AMC MOR7 ERVICES ,.ki6it A Eyt ` J ' 0&SC IO(i5J03 ?/ Tme; ]:go;ni PM Order Numbcri 000015053 Re! Robert C. Drabanstadt, Sr. auean L. Drabanatedt 5XHTSZT -A, 136 SUMYSIDE DRIVE CARLIOLR, PA 17013 CUMBERLAND County !h a_ tract of ground situate in Fiiddloaam 'LCamehip, Cor^,.borland c.tg: - ilaai-, '^ownded :m_+ :9a?^^_riHed -e :a:Le°ag; r3 a. a point as the nort::-rz side of sunn,a -;rive {Lng'_a7_ai2 ,2 Route 213121 .^.t a point between -'=da of =..v Qb=Ioor and landA of 2dward 'rartman; thence along lands of the mentioned Rarcmnn north 20 degrees 56 minutes 04 neconds wear. a distance of 127.60 feet to a stone pile; thence along lands now Or formerly oP Donald E. 81iko south el degrees 25 minutes 51 seconds east a distance of 311.97 feet; thence along said lands of 91ike north 06 degrees 12 minutes 13 aocends east a distance of 97.61 feet to appoint; thence along the same north 86 degrees 12 minutea 13 saconda east a distance of 510.12 feet to a point being a 24 inch ask; thence along lands now or formerly of Leonard L. McLaughlin south 36 degrees 24 minutes 12 seconds war a distance of 455.76 feet to a point in the middle of the mentioned sunny-,ids Drive; tierce north 23 degrees 30 miinutea went a distance of 24.94 font to a n iran pin an the northern side of the 5unnyside Drive right-of-way; thence along said suhnyoida Drive having a radius of 1,578.92 feet and a length of 400.59 feet to an iron pin; thence along acid Susnyoids Driva north 69 degrees, 17 minutas 03 seconds west a distance of 146.55 feet to a point being the place of BEGINMW. THE above deacription is in accordance with the a=way prepared by Tabu K. sixler, ITZ, dated September 20, 1988, which survey was recorded in the Cumberland County Recorder of needs office on Movomber 3o, 1988 with Deed recorded in Dead Hook uR'r, Volume 33, Page 773. Nos 6 of 6 Order Nuclear 000015053 BK 1842PGO280 Ex,hibit (B RW1 I III P.O. Box I1000 MORTGAGE SERVICES SantaAna,CA 92711-1000 i RWNK//S ROBERTC DP ABENSI:ADTJR I?6 til NA'Y'SIDL DR GUZLISLL. PA 11-013 September 27, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STA1 EMENTS OF POLICY Loan Number: 0059811489 Property Address: 136 SUNNYSIDE DR. CARLISLE PA, 17013 Original Lender: AMC Mortgage Services, [tic. Current Lendcr,Serv ices 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 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 CONS'T'RUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPER'L'Y. This is an official notice that the morhragc on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached oases. 'The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. 'To sec if HFMAP can help you must MFET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania (lousing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA 11KPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. S1 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO VIsodom, hus'mess as DeIto,arc iAMC Mort agc Services. Inc., in the doles ofTezus, 121tode Island and Nei, II ampslii rc. ARRIBA. I'LEDES SER ELEGIBLE PARA UN PRESTANIO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE; ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CAS.A DE LA PERDIDA DEL DERECHO A REDLMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE - NN IIR 11 CAN SAFE N OUR HOME FROM FORECLOSt RF. AND IIEI.I' YOL M.\t:F: T (:It RF MORI 1;.1C;1? P.U vIF:NI S IFN"OUCOMI'IA NIIll1HE PROVISIONSOFTHE[tO31EO\b'NER'S EMERGENCY :VIOR IG. AGF. ASSISTANCE: ACT OF 1983 (THE: "ACT"), N`OU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE.: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF N-OU ME: 1:T O LHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY TIIE PENiN'SN' LN' AN'IA HOUSING FINANCE AGENCY. FEMPORARN" S"GAY OF FORECLOSURE -- Under the Act, you tie 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-to-lace 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 ['OR FMFRGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MOR"I'CAGE UP "TO DATE THE PART OF TI [IS NOTICE CALLED "IIOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS I IOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COLINSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice the lender may NOT take action against you for thirty (30) days after the date of this meeting The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set Forth at the end of this Notice. It is only necessary to schedule one face-m-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 for specific information about the nature ofyour default.) If you have tried and arc unable to resolve this problem with the lender. you have the right to apply for financial assistance fiont the I lomeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed I lomeowner'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 tiled 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 AGAINS"1' 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 I lousing 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 Pennsykania I lousing Finance Agency of its decision on your application. September 27, 2005 Loan Number 0059811489 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PET'IT'ION IN BANKRUPTCY, THE FOLLOWING PARTOF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NO"1' BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. _(it'vou have (Sled bank[ uptcs ',oil can still :ipplc lot I:meroen<c Alori att,e Assis(:uace.) HOW TO CURE l"OUR :MORTGAGE DEF'AU'1 T IEring it up to (late)NATURE OF 'THE DEFAULT -The MORTGAGE debt by the above lender on your property located at 136 SUNNYSIDE DR, CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU ILAVE NOT MADE MONTIILY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 07/01/05 thru 09/01/05 at $767.22 per month Monthly Payments plus late charge or other fees: $1987.10 l'otal Amount ill Cure Default: $1987.10 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE TIIE DEFAULT--You may cure the default within T I ARTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1987.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY IRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check or money order made pavable and sent to- AMC Mortgage Services 505 City Parkway West, Suite 4100 Orange, CA 92868 You can cure any other default by taking the following action within IT IIRTY (30) DAYS of the date of this letter: (Do not use if not applicable) N/A IF YOU DO NOT CURE THE DEFAULT--IfYOU do not cure the default within TI IIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the mortEat!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 mortaage in monthly installments. If full payment of the total amount past due is not mode within I I IIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON --The mortgaged property will be sold by the Sheriffto pay off the mortgage debt. If the lender refers vein 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. l low %er, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pav attorney's fees. OTHER LENDER REMEDIES -- The lender may also site YOU personally for the unpaid principal balance mad all other sums due under the mortgage. RIGHT TO CURE 'THE DEFAULT PRIOR TO SHERIFF'S SALE -- Ifyou have not cured the default within the "f111RTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the SheritT's Sale You may do so by paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sherift -Sale as specified in writing, by the lender and by nt rbonnin<r any other rec tftirentenls under the nwrtetc Curing your default in the manner set forth in this notice will restore your mortgage to the same position as it 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 approxinmtely (G) MON IF IS from the date of this Notice. A notice of the actual date of the Sheriff s 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 IInd out at any time exactly whit the rccnined payment or action will be by contacting the lender. IION% TO CONIAC1I IIE LENDER AMC Mortgage Services PO Box 11000 Santa Ana, CA 92711-1000 Phone Number 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. Ifyou continue to live in the property after the Sheriffs Sale. a kmsfl t to remuce con and your liuni9hings and usher belongings could be started by the lender Lit any time. ASSUMPTION OF MORTGAGE -- You may or X may not (Cl IECK ONE) self or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and Lana nev's fees and costs are paid prior to or at the sale and that the other requircmantS of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL TI IE PROPERTY TO OBTAIN MONEY TO PAY OFF TIIE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO IIAVETi 11S DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEI UNIT. • 10IIAVETUE MORTGAGE RF.STORFDT0 TIIE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (IIOW'EVER, YOU DO NOT IIAVF.II IIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • 10 ASSERT ANY OTHER DEFENSE YOU BELIEVE. YOU MAY IIAVE 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, AMC' Mortgage Services Cc AMC !Mortgage Services Attn: Collections Department Loan Number: 0059811489 Mailed by 1st Class Mail and by Certified Mail Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 C I1igh Street Gettvsbur,. PA 17325 717) 3, 31 4-I31` CCCS of Western PA 2000 Linglestown Road I larrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street llanisbure, PA 17104 (717)232-9757 Loveship.Inc_ 2320 North 5th Street Harrisburg, PA 171 l0 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 P) IFA 21 1 North Front Street Harrisburg, PA 171 10 1-800-342-2397 n ? '64 ? ?' a ? r ?? c? :" n ?._ •-? -_ ?'? ?_ ;? -?, ?- ;, ?, ,_, ?: GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004- X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 06-84 GOLDBECK,,, McCAFFE?''R-TY//& McKEEVER VL IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff , _ _ ? = ., -. ? ; ?" ?,? l + ' i _.. i:::?. . _... In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS (RUSTLE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DA"1 F.D AS OF JUNE 24, 2004, WIFHOUT RECOURSE 505 City Parkway West Suite loo Orange. CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT (Mortgagor(s) and Record Owner(s)) 136 Sunnyside Drive Carlisle. PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 06-84 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 ROBERT C. DRABENSTADT JR. and SUSAN L. DRABENSTADT by default for want of an Answer. Assess damages as follows: Debt Interest- 0601,2005 to 03/302006 Total (Assessment of Damages attached) $122.947.40 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 d -red to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurre and qt least ten days prior to the date of the filing of this praccipc. A copy of the notice is attached. RCP. 237.1 i ,. Joseph A. Go beck, Jr. Attorney; tot laintifl' ED.ft16 ?- AND NOW 3 ???.. Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURI"DIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE and against ROBERT C. DRABENSTADT JR. and SUSAN L. DRABENSTADT by default for want of an Answer and damages assessed in the sum of $122,947.40 as per the above certification. Protho od taryy AMQ-0748 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: March 14, 2006 TO: SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT 1R. SUSAN L. DRABENSTADT (Mortgagor(s) and Record Owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) TO: SUSAN L.DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 06-84 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 -z so . ti,;d CJO(Aeck r GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 AMQ-0748 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: March 14, 2006 TO: ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT (Mortgagor(s) and Record Owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) TO: ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-84 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO T14E 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 z o P hA Gofd& c-k !Zr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NA IIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 PlaintilT No. 06-84 vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENS"IADT (Mortgagors and Record Owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 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 i5 given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotar Bv: 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 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ROBERT C. DRABENSTADT JR., is about unknown years of age, that Defendant's last known residence is 136 Sunnyside Drive, Carlisle, PA 17013, 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 194'0 and its Amendments. Date: 31?t / ?, ' VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SUSAN L. DRABENSTADT, is about unknown years of age, that Defendant's last known residence is 136 Sunnyside Drive, Carlisle, PA 17013, 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: 11?? 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 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSE"f-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. ROBERT C. DRABENSTAD"F .I R. SUSAN L.DRABENSTADT (Mortgagor(s) and Record owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 IN IHE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW Plaintiff Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 06-84 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 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE, and against ROBERT C. DRAB ENSTADT JR. and SUSAN L. DRABENSTADT 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 gYth? Complaint, in the sum of $122,947.40. Joseph A Attorney j r. I hereby certify that the above names are correct and that the precise residence address of thejudgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SFCURIIIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2. UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WIIHOUI RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known address(es) ofthe Defendant(s) is/are ROBER"F C. DRABF.NSTADT JR.. 136 Sunnvside Drive Carlisle. PA 17013 and SUSAN L. DRABENSTADT, 136 Sunnyside Drive C>4islc, PA 17013; AFFERTY & MCKEEVER BY: Jos h A Goldbeck, Jr. Attorney ? laintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $108,087.45 Interest from 06/01/2005 through $8,480.97 03/30/2006 Reasonable Attorney's Fee $5,404.37 Late Charges $345.23 Costs of Suit and Title Search $900.00 Pees $106.00 Recoverable Balance $36.00 Suspense Balance 4406.62 Total $122,947.40 GOLDBFCK cCAFFERTY & McKELVER BY: Jose It Goldbeck, Jr. Attorney o laintitf AND NOW, this day of 2006 damages are assessed as above. pro P othy I F, v fy V1? ;u M1a I j I ( .J .t G? PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.# 16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OP AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE. POOLING & SERVICING AGREEMENT DATED AS OF .TUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-84 ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/01/2005 to 03/30/2006 at 9.5000'% $122,947.40 (Costs to be added) GOLDBECK M CAFFERTY & MCKFEVER BY:Joscph,?A. ' ldbeck,Jr. Attorney for aintiff F^ / U: WZ7 m dU"'W w z?n W ?,o Htixzri a?.?owyyu ,v°.C Ou y?O w ?. E- Q p. G g G1 p.' d d ?"r< ?-^ W P? H ? o ? o W O r ?- Y Q?pv.., W o o` ??dd od ?+w P ?ro ? U ?t Q co ? p. d N Y y ?I J N, N 'x y Y ? o.' dr n a z v <-?r ? a `YV e be c v ALL THAT TRACT of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Sunnyside Drive (Legislative Route 21012) at a point between lands of the Grantor and lands of Edward Hartman; thence along lands of the mentioned Hartman north 20 degrees 58 minutes 04 seconds west a distance of 127.60 feet to a stone pile; thence along lands now or formerly of Donald E. Slike south 81 degrees 25 minutes 51 seconds east a distance of 31 1.97 feet; thence along said lands of Slike north 86 degrees 12 minutes 13 seconds east a distance of 87.61 feet to appoint; thence along the same north 86 degrees 12 minutes 13 seconds east a distance of 510.12 feet to a point being a 24 inch oak; thence along lands now or formerly of Leonard L. McLaughlin south 36 degrees 24 minutes 12 seconds west a distance of 459.76 feet to a point in the middle of the mentioned Sunnyside Drive; thence north 23 degrees 30 minutes west a distance of 24.94 feet t an iron pin on the northern side of the Sunnyside Drive right-of-way; thence along said Sunnyside Drive having a radius of 1,528.92 feet and a length of 400.59 feet to an iron pin; thence along said Sunnyside Drive north 69 degrees, 17 minutes 03 seconds west a distance of 145.55 feet to a point being the place of beginning. BEING the same premises which Robert C. Drabenstadt, Jr., by Deed dated October 14, 2003 and recorded in the Cumberland County Recorder of Deeds Office on October 23, 2003 in Deed Book 260 Page 53, granted and conveyed unto Robert C. Drabenstadt, Jr., and Susan L. Drabenstadt, husband and wife. TAX PARCEL #21-04-0371-27 MUNICIPALITY: MIDDLESEX TOWNSHIP PROPERTY ADDRESS: 136 SUNNYSIDE DRIVE, CARLISLE, PA 17013 V?> \. N r' 3V W i o ? c I F ?i^ `tea r N s La f 0 f) -74 rrir CJ i .J l? ll WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N006-84 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 2004-X2 under the Pooling & Servicing Agreement Dated as of June 24, 2004, without recourse 505 City Parkway West, Suite 100, Orange, CA 92868 Plaintiff (s) From Robert C. Drabenstadt, Jr., Susan L. Drabenstadt 136 Sunnyside Drive Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $122,947.40 Interest from 06/01/2005 to 03/30/2006 at 9.5000% Any's Comm % Arty Paid $131.28 Plaintiff Paid Date: April 3, 2006 (Seal) L.L.$.50 Due Prothy $1.00 Other Costs Prothonotary, By: Deputy REQUESTING PARTY: Name Goldbeck McCafferty & McKeever Joseph A. Goldbeck, Jr. Address: Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 =.D.st It?l.7? Goldbeeck McCafferty & McKeever OnY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004- X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT (Mortgagor(s) and Record Owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-84 DEU ISCHE BANK NATIONAL TRUST COMPANY, AS -1 RUSTLE OF AMERIQUF.S"I MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004. 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 information concerning the real property located at: 136 Sutmyside Drive Carlisle, PA [7013 I .Name and address of Owner(s) or Reputed Owner(s): ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 SUSAN L.DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 2 Name and address of Defendant(s) in thejudgmcnc ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUSAN L.DRABENSTAD"f 136 Sunnyside Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BENNER CADILLAC OLSMOBILE 2222 Paxton Street Harrisburg, PA 17111 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMFN"f 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: HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IF 60126 HOUSEHOLD REALTY CORP. 25 Gateway Drive, Gateway Square, Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff' has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 136 Sunnyside Drive Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: March 30, 2006 GOLDBFtGo RT Y R McKLFA, I R BY: Josepk, Jr., Esq. Artorney f ?.. _--t -ra (a ?:?: G.; . dir. L ? r 06-84 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' DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Plaintiff Tenn No. 06-84 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: DRABENSTADT IR., ROBERTC ROBERT C. DRABENSTADT JR. 136 Sunnysidc Drive Carlisle. PA 17013 Your house at 136 Sunnyside Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enti'rce the court judgment of $122,947 40 obtained by DFUTSCHF. BANK NAIlONAI. "CRUST COMPANY-, AS TRUST FF OF AMERIQUEST MORI GAGF SECURITIES, INC., ASS] C-BACKED PASS THROUGH CERTIFICA"I ES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN TI IF COURT OF COMMON PLEAS Of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 06-84 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 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, 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. 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. L If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. Fo find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be tiled 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 Al ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNO1 AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SCRViCLS INC R Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA LION 2 Liberty Avenue Carlisle, PA 17013 .-.J -l ??? =fi ?i .. _-.. °.; .:: Y ?.'. v% ?t) -i . • ': 06-84 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.416132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney tor Plaintiff DLUTSCI IE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUESF MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Term No. 06-84 '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 TOt DRABBNSTADT, SUSAN L. SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 Your house at I % Sunnyside Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Kin 2nd I L Courthouse to enforce the court judgment of S122.947.40 obtained by PH ITSCHf BANK NATIONAL-CRUST COMPANY, AS I RUS IEL OF ANILRIQUEST MORTGAGE SH URI I'IES, INC ASS[t-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WR HOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE fo prevent this SherilJ's Sale you must take immediate action: 00-84 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUS"F COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICA"ITS, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, W11 ROUT RECOURSE, the back payments. late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 2li-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 sate for good cause. 3. You may also be able to stop the sate through other legal proceedings. You may need an attorney to assert your rights.] he 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 HAVF, 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 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 ofyour property. 3. The sale will go through only if the buyer pays the Sheriff the full amount clue in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be tiled by the Sheriff within thirty (30) days from the date of the Sheriff's 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 sate. YOU SHOULD TAKP. TIIIS PAPERTO YOUR LAWYER AI ONCE. IF YOU DO NO I HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR I ELI[PI-IONI:: THE OFFICE LIS"IED BILLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SFR\'ICIS INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUN I Y BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 ,?, iJ •.4; '? C1 ... _._ i'I?L? _??i_,,.,. ? C,J _?'?;4. ?? __.? __ ;) `? Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff' DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 06-84 1, Joseph A. Goldbeck, Jr., Esquire hereby certify that 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. Joseph A. old eck, Jr. Attorney f r intiff ?: *v ?J :?7 T f ,r i r?` •- ?Yr ?i ,` ? \r i7 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 136 Sunnyside Drive Carlisle, PA 17013 SOLD as the property of ROBERT C. DRAB ENSTADTJR. and SUSAN L. DRABENSTADT TAX PARCEL #21-04-0371-027 tJ -ii Cn? z7 ALL THAT TRACT of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Sunnyside Drive (Legislative Route 21012) at a point between lands of the Grantor and lands of Edward Hartman; thence along hinds of the mentioned Hartman north 20 degrees 58 minutes 04 seconds west a distance of 127.60 feet to a stone pile, thence along lands now or formerly of Donald E. Slike south 81 degrees 25 minutes 51 seconds east a distance of 311.97 feet; thence along said lands of Slike north 86 degrees 12 minutes 13 seconds east a distance of 87.6t feet to appoint; thence along the same north 86 degrees 12 minutes 13 seconds east a distance of 510.12 feet to a point being a 24 inch oak; thence along lands now or formerly of Leonard L. McLaughlin south 36 degrees 24 minutes 12 seconds west a distance of 459.76 feet to a point in the middle of the mentioned Sunnyside Drive; thence north 23 degrees 30 minutes west a distance of 24.94 feet t an iron pin on the northern side of the Sunnyside Drive right-of-way; thence along said Sunnyside Drive having a radius of 1,528.92 feet and a length of 400.59 feet to an iron pin; thence along said Sumryside Drive north 69 degrees, 17 minutes 03 seconds west a distance of 145.55 feet to a point being the place of beginning. BEING the same premises which Robert C. Drabenstadt, Jr., by Deed dated October 14, 2003 and recorded in the Cumberland County Recorder of Deeds Office on October 23, 2003 in Deed Book 260 Page 53, granted and conveyed unto Robert C. Drabenstadt, Jr., and Susan L. Drabenstadt, husband and wife. TAX PARCEL #21-04-0371-27 MUNICIPALITY: MIDDLESEX TOWNSHIP PROPERTY ADDRESS: 136 SUNNYSIDE DRIVE, CARLISLE, PA 17013 ?_' i_) (': TI ?? -i `.l-f1 ;; _i Ci ? '. , [`r[; '; J SHERIFF'S RETURN - REGULAR CASE NO: 2006-00084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS DRABENSTADT ROBERT C JR ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE DRABENSTADT ROBERT C JR the DEFENDANT , at 1930:00 HOURS, on the 21st day of February , 2006 at 136 SUNNYSIDE DRIVE CARLISLE, PA 17013 by handing to ROBERT DRABENSTADT JR 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 18.00 Service 5.28 Affidavit .00 Surcharge 10.00 .00 33.28 Sworn and Subscribed to before me this ) ; V day of ?z 2"(, A . . rothonota So Answers: R. Thomas Kline 02/22/2006 GOLDBECK MCCAFFERTY MCKEEVER By: a ?l/Gc I ?? lip Deputy Sheriff was served upon SHERIFF'S RETURN - REGULAR a CASE NO: 2006-00084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS DRABENSTADT ROBERT C JR ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DRABENSTADT DEFENDANT the , at 1930:00 HOURS, on the 21st day of February , 2006 at 136 SUNNYSIDE DRIVE CARLISLE, PA 17013 by handing to ROBERT DRABENSTADT JR, 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 1 ? day of Z s?dfees o2 bttJ A othonotar So Answers: Y R. Thomas Kline 02/22/2006 GOLDBECK MCCAFFERTY MCKEEVER By : /1 - Z ? - eputy Sheriff s GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215.627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) AMQ-0748 CF: 01/04/2006 SD: 09/06/2006 $122,947.40 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-84 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2 Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). 60 Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. s A. oldbe c , Jr. Voe Plaintiff ¦ Complete Rams 1, 2: and 3. Also complete Item 4 it Restriated Delkwy is dealred. - 0 Aaant ¦ print your name and address on the reverse < C> El Addresses so that we can return the card to you. S. RaeNwd by (FrMbd /awls) C..D ra of Deemy ¦ Attach thta card to the heck of tin msilplece, rJ AV K 4 Y ? or on the front If space permits. . 1. AM* Addressed to: D.bdelNayaddrsesdirmaxtromrmnl? 0Yes AMQ-0748 on If YES, artier delivery address babes: 13 No DRASENSTADT JR., ROBERT " I 136 Sunftyelde Drive Ca1lIMe, PA 17013 3. Snvbo type JV Cardffstl Mal ? EWM Mal O Rephtersd 0 Rearm Receipt for Mercdumme 0 Insssd Mar 0 C.O.D. - 4. Restricted DMhrery`! (Ekes Fee) ? YM 2. Article N tm "Mail ?f /W' 11 (/MeMfia aarvkaYWp * 700531, 2nnRy PS Form 3811, February 2004 DorrMW Return Rr0 0 _ 101105oe#41510 ¦ Complete Kom 1, 2, and 3: Also complete Item 4 If RestrIcted DalNery Is deeired. ¦ Print your name and address on the reverse so that we oan return the card to you. ¦ Attach thle card to the back of the mailpbce, or on the front N spsoe permits. 1. Ahab Addressed to: AMQ-0740 6/6/06 DRABENSTADT, SUSAN L. 136 Sunrepide Drive Cerilepe, PA 17013 A M x S. Received by (Pr~ AMrry C. D • of DaMry D. Is das+ary address different fror?TMlir17 nxm If YES, antes denary address bSIM 0 No 0001111140M 0 Express Map R"Wered 0 Ream Receipt for Msr"A%o 0 IMnd Mal 0 C.O.D. 4. FNstrcted Dallvery9 9*0 Fee) 0 Yes 2. Ardoe Number Marm { '*¦ (ilrrsler tom servloa leash 7 A 0' S R PS Forth 3811, Februry 2004 Domesee Rsasn 10re5-oz4A-150 KLL O DO ? = N W - LL p m ?N 0 N? pwo W . ? t o ` . a jo 6 0 `O' N O Q Q ° um o o rl ov C ? ? y a ?- ?v v ma .. ?c amE K NN LL gg o s a i ffi a g -- e c ?€ w ' d .? n & o ? U m d " y 6R 2 Q N . + J 2 E a 19 W N W d j N E Kin CD U v o OEl L? ? m ?? O U) awm 03i'nr' o co J y J Q Oa 0 d M o m -? i O Zfn R LLJ ? W N x W a; X'C m C U F O U? E 8i ?N $$ 0 n4 Q Ca O 1n g = ?L3(~D 099 J(OJ 00, J TD Uv? O m ?0-5w 2) L CL ?x OJ a00 0 wo wdc C? u ? as ul w Z wNm 00 ¢?a O E O wpm M N T- U 6. U a m 2 d S d W S N r U o c W E Z j n Q s ?a Q a < i F CL C4 ?W?WL 1 „m apQGQ? 1 . E-ji- ZO?7G;W N M 7 Ili) (D I? W m O C d E N a V a U ILA FL 0 0 ?a E Eo Z a `off E u EN 'a yE m a c a° m m `o c « F a m E 0 V N `o d A a 0 LL M O 6 LL a Q A z h+? r? V z z W J Z 06 K F C/) Z W 0 U LU W m x WWI l r GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-84 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, 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 information concerning the real property located at: 136 Sunnyside Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT C. DRA13ENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BENNER CADILLAC OLSMOBILE 2222 Paxton Street Harrisburg, PA 17111 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 HOUSEHOLD REALTY CORP. 25 Gateway Drive, Gateway Square, Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 136 Sunnyside Drive Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: August 14, 2006 G DB K Iv c kFFERTY & McKEEVER B : Jos h A. Goldbeck, Jr., Esq. Attorney for Plaintiff C7 N ? T G; m vc mr; ? CT) n' -n GCa .p L?.G7 .- t_ Deutsche Bank National Trust Company, As Trustee of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass Through Certificates, Series 2004-X2, Under the Pooling & Servicing Agreement Dated as of June 24, 2004, Without Recourse VS In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-84 Civil Term Robert C. Drabenstadt, Jr. and Susan L. Drabenstadt R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing 30.00 Surcharge 30.00 Law Library .50 Prothonotary 1.00 Mileage 12.32 Advertising 15.00 Law Journal 437.00 Patriot News 389.60 Share of Bills 19.31 Poundage 19.69 Postpone Sale 20.00 Posting Handbill 15.00 Levy 15.00 42 $1 004 . , So Answers: r R. homas Kline, Sheriff BY Real Estat 7rgeant ,a` s??ry7 A 4 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 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIFS, INC., ASSET-BACKED PASS THROUGH CER'T'IFICATES, SERIES 2004- X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT (Mortgagor(s) and Record Owner(s)) 136 Sunnyside Drive Carlisle, PA 17013 No. 06-84 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 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, 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 tiled the following information concerning the real property located at: 136 Sunnyside Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle. PA 17013 SUSAN L. DRABENS 1 ADT 136 Sunnyside Drive Carlisle. PA 17013 2. Name and address of Defendant(s) in the judgment: ROBERT C. DRABENST,MDT JR. 136 Suiuiyside Drive Carlisle, PA 17013 SUSAN L. DRABENSTADT 136 Sunnvside Drive Carlisle, PA 17013 IN 1'HE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE i 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BENNER CADILLAC OLSMOBILE 2222 Paxton Street Harrisburg, PA 17111 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: HOUSEHOLD REALTY CORP. P.O. Box 8604 Elmhurst, IL 60126 HOUSEHOLD REALTY CORP. 25 Gateway Drive, Gateway Square, Suite 107 Mechanicsburg, PA t7055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may he affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 136 Sunnyside Drive Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relatinL to unsworn falsification to authorities. DATED: March 30, 2006 \ PW `-1. GOLDBECK i CAFFERfY & NIcKEEVF_R dbeck, Jr.. Esq. BY: Joseph A. Jiff Attorney for z d h - Hdb gaaz 06-84 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Defendant(s) Term No. 06-84 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: DRABENSTADT, SUSAN L. SUSAN L. DRABENSTADT 136 Sunnvside Drive Carlisle, PA 17013 Your house at 136 Sunnyside Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $122947.40 obtained by DEUTSCHE BANK NATIONAL TRUST COA,IPANY. AS TRUSTEE OF ANIERIQUEST MORTGAGE SECURITIES, INC.. ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGRFEMENNI'DATED AS OF JUNE 24. 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 'To prevent this Sheriff's Sale you must take immediate action: 06-84 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 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, 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. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. 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 BFL.OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. L.LGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Z i .E, d il - ddv 9001 :'c ?,iPa 06-84 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 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT Mortgagor(s) and Record Owner(s) 136 Sunnyside Drive Carlisle, PA 17013 Defcndant(s Term No. 06-84 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: DRABENS rADT JR., ROBERT C. ROBERT C. DRABENSTADT JR. 136 Sunnyside Drive Carlisle, PA 17013 Your house at 136 Sunnyside Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale ott Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $122,947.40 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF ANIERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2. UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 06-84 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 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, 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 of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. 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 tiled. 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 TELFPIIONE THE OFFICE LISTED BELO%k' TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SFRVICLS INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Z I .E d h - 8dd 9001 wc; ;: iii ALL THAT TRACT of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Sunnyside Drive (Legislative Route 21012) at a point between lands of the Grantor and lands of Edward Hartman; thence along lands of the mentioned Hartman north 20 degrees 58 minutes 04 seconds west a distance of 127.60 feet to a stone pile; thence along lands now or formerly of Donald E. Slike south 81 degrees 25 minutes 51 seconds east a distance of 311.97 feet; thence along said lands of Slike north 86 degrees 12 minutes 13 seconds east a distance of 87.61 feet to appoint; thence along the same north 86 degrees 12 minutes 13 seconds east a distance of 510.12 feet to a point being a 24 inch oak; thence along lands now or formerly of Leonard I- McLaughlin south 36 degrees 24 minutes 12 seconds west a distance of 459.76 feet to a point in the middle of the mentioned Sunnyside Drive; thence north 23 degrees 30 minutes west a distance of 24.94 feet t an iron pin on the northern side of the Sunnyside Drive right-of-way; thence along said Su nyside Drive having a radius of 1,528.92 feet and a length of 400.59 feet to an iron pin; thence along said Sunnyside Drive north 69 degrees, 17 minutes 03 seconds west a distance of 145.55 feet to a point being the place of beginning. BEING the same premises which Robert C. Drabenstadt, Jr., by Deed dated October 14, 2003 and recorded in the Cumberland County Recorder of Deeds Office on October 23, 2003 in Deed Book 260 Page 53, granted and conveyed unto Robert C. Drabenstadt, Jr., and Susan L. Drabenstadt, husband and wife. TAX PARCEL #21-04-0371-27 MUNICIPALITY: MIDDLESEX TOWNSHIP PROPERTY ADDRESS: 136 SUNNYSIDE DRIVE, CARLISLE, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N006-84 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass through CertificatesySeries 2004-X2 under the Pooling & Servicing Agreement Dated as of June 24, 2004, without recourse 505 City Parkway West, Suite 100, Orange, CA 92868 Plaintiff (s) From Robert C. Drabenstadt, Jr., Susan L. Drabenstadt 136 Sunnyside Drive Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description , (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $122,947.40 L.L.$.50 Interest from 06/01/2005 to 03/30/2006 at 9.5000% Atty's Comm % Due Prothy $1.00 Atty Paid $131.28 Other Costs Plaintiff Paid Date: April 3, 2006 71 Prothonotary (Seal) By: _ Deputy REQUESTING PARTY: Name Goldbeck McCafferty & McKeever Joseph A. Goldbeck, Jr. Address: Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Real Estate Sale # 10 On May 04, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Tov ship, Cumberland County, PA Known and numbered as 136 Sunnyside Dr., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 04, 2006 By: Real Estate Sergeant Z I :E d h - ddb 9001 JJN Hs 3HI J033IJ-PO PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 21, July 28, and August 4, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 4 day of August, 2006 _ NOTAP 7 w,, E.SNY"",' F -'? Carlisle Bore REAL ESTATE SALE NO. 10 Writ No. 2006-84 Civil Deutsche Bank, National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass Through Certificates, Series 2004-S2, Under the Pooling and Servicing Agreement Dated as of June 24, 2004, without recourse vs. Robert C. Drabenstadt Jr. and Susan L. Drabenstadt Atty.: Joseph Goldbeck Atty.: Joseph Goldbeck ALL THAT TRACT of ground situ- ate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Sunnyside Drive (Legislative Route 21012) at a point between lands of the Grantor and lands of Edward Hartman; thence along lands of the mentioned Hartman north 20 degrees 58 min- utes 04 seconds west a distance of 127.60 feet to a stone pile; thence along lands now or formerly of Donald E. Slike south 81 degrees 25 minutes 51 seconds east a dis- tance of 311.97 feet; thence along said lands of Slike north 86 degrees 12 minutes 13 seconds cast a dis- tance of 87.61 feet to a point; thence along the same north 86 degrees 12 minutes 13 seconds east a dis- tance of 510.12 feet to a point be- ing a 24 inch oak: thence along lands now or formerly of Leonard L. McLaughlin south 36 degrees 24 minutes 12 seconds west a distance of 459.76 feet to a point in the middle of the mentioned Sunnyside Drive; thence north 23 degrees 30 minutes west a distance of 24.94 feet to an iron pin on the northern side of the Sunnyside Drive right- of-way; thence along said Sunnyside Drive having a radius of 1,528.92 feet and a length of 400.59 feet to an iron pin; thence along said Sunnyside Drive north 69 degrees, 17 minutes 03 seconds west a dis- tance of 145.55 feet to a point be- ing the place of beginning. BEING the same premises which Robert C. Drabenstadt, Jr., by Deed dated October 14, 2003 and recorded in the Cumberland County Recorder of Deeds Office on Octo- ber 23, 2003 in Deed Book 260 Page 53, granted and conveyed unto Robert C. Drabenstadt, Jr., and Susan L. Drabenstadt, husband and wife.. TAX PARCEL #21-04-0371-27 MUNICIPALITY: Middlesex Town- ship. PROPERTY ADDRESS: 136 Sunnyside Drive, Carlisle, PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ............. ................................. COPY Sworn to and s s r e efore me this 16th d bRRlk"fA :NNbYLYANIA SALE#10 T rry L. , ? . 1-Nary Pubk Q Of Harr;SV, ± ; rtuphin county COMM* June 6, 2010 er sy!var.i. u ys t:1a11 n of Notaries NOTA PUBLIC ' a CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 10 writ No. CNNTerm Dot a Denk.1ll d m mei Thant C6n*w , me Thistes of Ant Mortgage secur Nkme, Mc., -- Pow Through CardSoabs, Series 200442, Under Ow Pooling & Servicing Agremam t dated as of June 24,20K vrithout Ve Robert C. Draberstadt Jr. and Suaan. Drabertistedt Attorney Jo?ewh ti3otdbeck DESCiN YWN ALL THAT TRACT of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a pant on the northern side of Sunnyside Drive (tq*Wve Route 21012) at a point between lands of the Grantor and lands of Edward Hartman; thence along lands of the mentioned Hartman north 20 degrees 58 minutes 04 seconds west a distance of 127.60 feet to a stone pile; thence along lands now or formerly of Donald E. SWm sash 81 degrees 25 minutes 51 seconds east a duce of 311.97 few thence along said lands of Slke north 86 degrees 12 minutes 13 seconds east a distance of 87.61 feet to appoint; thence along the same north 86 degrees 12 mitres 13 seconds east a distance of 510.12 feet to a pout being a 24 inch oils, thence along lands now or formerly of Leonard L MdAughlin south 36 degras 24 minces 12 seconds west a 11 l d e >4 e 23 ?? ??tiant t ra train }itttt rut iritlmt? alit? at ttw amide Dnra -ter; thrnee ttlauLr aaia Drain having a radius of 1,52892 feet ad a WO of 490.59 feet to an irdh pin; them d" acrid Str"side Drive north 69 degrees, 17 ¦ivMea 03 mmmds west a distance of 145.55 feet to a point being the place of begimi4. BEING the same premises which Robert C. Drabeostadt, Jr., by Deed dad October 14, 2003 and recorded in the Cumberland Query Recmxw of Deeds Office on October 23, 2003 in Deed Book 260 page 53,-granted and conveyed unto Robert C. Dcabenstak Jr., ,. ud Susan L. h>vs?d and wife. tr214W71.27 1CfWNSHIP 4I , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET- BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ROBERT C. DRABENSTADT JR. SUSAN L. DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Docket No. 06-84 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE GOLDBECK WCAFFERTY McKEEVER A PROFESSIONAL CORPO TION SUITE 5000 - MELLON INDEPEND NCE CENTER 701 MARKET STREE PHILADELPHIA, PA 1910 1532 (215) 627-1322 FAX (215) 627-7734 November 7, 2007 PROTHONOTARY OF CUMBERLAND COUNTY Curt Long Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: Docket Number: 06-84 Dear Sir or Madam: Kindly file of record the enclosed Praecipe to Vacate Judgment. A time stamped copy does not need to be returned to our office. Goldbeck McCafferty & McKeever Bridget Marie Speck, Legal Assistant Direct Dian: 215-825-6384 Email: B§peck@goldbecklaw.com Main number: 215-627-1322 Enclosures M GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS THROUGH CERTIFICATES, SERIES 2004-X2, UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF JUNE 24, 2004, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. ROBERT C. DRABENSTADT JR. SUSAN L.DRABENSTADT 136 Sunnyside Drive Carlisle, PA 17013 TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Docket No. 06-84 Defendants PRAECIPE TO VACATE JIJDGKCNT I Kindly vacate the judgment upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE UD d-Y W TS c.n