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Home My WebLink About06-0270 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, 1Ne. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 200S-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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 PlailltilJ Term No.Di... -;rt6 C!;oi 19L~ vs. WILLIAM S. BROWJ\ Mortgagor and Real Owner 379 Old State Road Gardners, P A 17324 Defelldalll CIVllA('; P~tLC )ATCAGE NOTICE You have been sued in eourt. I f 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 attomey 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 CANJ\OT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU \VIm INFORMATION ABOUT HIRlNG 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 ELIGffiLE 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 Libetjty Avenue CarlislefPA 17013 A ISO LE HAN DEMANDADO A USTED EN LA C RTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUT AMENT NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ES A DEMANDA Y AVISO, PARADEFENDERSE ES N!,\CESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICTP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE US TED CUMPLA CON TODAS LAS PROV1S10NES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPlEDAD U OTROS DERECHOS 1MPORTANTES, USTED DEBl, LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA, SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO, ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO, SI USTEI) NO PUEDE P !\GARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGEI\CIAS QUE PUEDAN OFRECER SERVIC10S LEGAL A PERSONAS ELIGlBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 TIDS FIRM IS A DlmT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO mlt CLIENT. ANY INFORMATION OBTAINED FROM YOU \VII,L BE liSED FOR THE PURPOSE OF COLLECTING THE DEBT. Resourcl's avai lable for Homeowners in Foreclosure ACT NOW! Even though your lender (and our elient) 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 Consumcr Crcdit Counseling Agency at 1-800-989-2227 for free counseling, 3), Visit HUD'S wcbsitc 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 spe.ak to someone about Loss Mitigation or Home Retention options, 5), Call or contact our office to request the amount to bring the ac<count current, or payoff the mortgage or request a Loan Workout I Home Retention Package, Call Beth at 215-825-6329 or fax 215-825-6429, The figure andlor package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The altamey in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-()318 or Fax: 215.825-6418, Please reference our AttomeyFile Number of AMQ-0767, Para infoTI11aciol1 en espanal ptledc communicarse con Loretta aI215-825-6344, This Action of Mortgage Foreclosure will continue unle!is you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE Bi\1\'I( NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868, 2, The name and address oftne Defendant is WILLIAM S, BROWN, 379 Old State Road, Gardners, PA 17324, who is the mortgagor and real owner of the mortgaged premises hereinafter described, 3, On December 21,2004 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to AM ER IQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder ofDceds of Cumberland County as Book 11893, Page 451. The mortgage has been assigned to: DEUTSCH I' BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICA TES SERlES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY \,2005, 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 relerence in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plainlill from its obligation to attach documents to pleadings ifthose documents are matters of public record. 4, The Propcrty subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5, The mortgage is in default beCClllse the monthly payments of principal and interest are due and unpaid for September 0 1,2005, and each month thereafter and by the terms ofthe Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due and other charges are due and collectible. 6, The following amounts arc duc to Plaintiff on the Mortgage: Principal Balance Interest li'om 08/01/200'\ through 0 I/31/20()6 at 7.2500% Pcr Diem interest rate at $24.20 Reasonable Attorney's Fe", at 5'Yo of Principal Balance as more fully explained in the next numbered paragraph Latc Chdrges Ji'OI11 O')/() 12005 to 01/31/2006 Monthly late charge amount at $49.47 Costs or suit and Title Search Fees Suspense $120,187,94 $4,452,80 $6,009.40 $247.35 $900,00 $106,00 -$449.47 $131,454.02 7, If the Mortgage is reinstated prior to a Sheriffd Sale, the Attorney's Fees set forth above maybe less than the amount dcmanded based on work actu~lly performed. The Attorney's Fees requested are in conformity with the Mortgagc and Pennsylvani~ law, Plaintiffres(~rves its right to collect Attorney's fees of up to 5';;, of the rcmaining principal bal~nce in the event th(: Property is sold to a third party purchaser at Sheriff's Sale or i ('the complexitylofthe action requin~s additional fees in excess of the amount demanded in the Action. I , 8, Plaintiff is not seeking a j udgnlcnt 0 r pcrsonalliability (or and "i!!JDersonam" judgment) against the Defendant in \I\is Action but reserves it's right to bring a separate Action to establish that right, if such right exists. I I' Defendant has reccived a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, 811 attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgag,~ and sell the Property pursuant to Pennsylvania law. 9. Notice ofJntent;on to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Dcl'cndant by ccrti licd and regular mail, as required by Act 160 of 1998 ofthe Commonwcal\h of Pennsylvania, on the date($) set forth in the tme and correct copy of such notice(s) attached hcreto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency, WHEREFORE, Plainl i 1'1' dcmands a QC tcrri~ judgment in mortgage foreclosure in the sum of $131 ,454,02, together with interest al thc rate 0 I' 5>24.20, pcr day and other expenses costs and charges incurred by the Plaintiff which arc properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in fu11, and I'DI' the roreclosure of the Mortgage and Sheriffs Sale of the Property, By: (j ECK McCAFFERTY & McKEEVER By: OSEPH A, GOLDBECK, JR" ESQUIRE ATTORNEY FOR PLAINTIFF VERIfICATION Nanci Jimenez I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do mak<: this verification on behalf of the Plaintiff corporation and the facts set forth in ~he 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 rela1ing to unsworn falsification to authorities, ! Date: /-/{J-ck cf:(fi\i6it Jl \ ~ Stewart Title Guaranty Company Commitment Number: 2004120060' SCIjlEDULE C PROPER-r1,Y DESCRIPTION The land referred to in this Commitment is described as fallows: ALL THAT CERTAIN tracts of land situate in Dickinson Township, Cum be-land County, Pennsylvania, bounded and described as follows: TRACT #1: BEGINN ING at a point In the center line of the old Carlisle - Gettysburg Highway, which point is as comer of Tract No.2 on the hereinafter mentioned Ian of lots recorded in the Office of the Record of Deeds in and for Cumberland County at Carlisle, Pennsylv~ni ,in Plan Book 10, Page 52; thence by said Tract No, 2, Norlh seventy-four (74) degrees twenty (20) minute West, a distance <if one hundred forty-six and live-tenths (146.5) feet to a point (iron pin); thence atong line f tract #3 hereinafter described, North fifteen (15) degrees twenty-live (25) minutes East, a d'lstance of forty-e' ht and one-tenth (411,1) feet 10 a point (iron pin); thence along land now or formerly of Lena K. Kuntz and Chester J. Kuntz, her husband, south seventy-three and one-fourth (73 1/4) degrees East, a distance of one hundred forty-six and five-tenths (146,5) feet to a point in the center line of said Old Carlisle - Gettysburg H;ghway; thence by the center line of said Highway, Soulh fifteen and one-half (151/2) degrees West, a distanc~ of forty-six and four-tenths (46.4) feet to a poinl the place of BEGINNING. i , BEING improved With a I-story frame bungalow an~ also being Tract NO.1 as designaled on a Plan of Lots recorded in the Office of the Recorder of Deeds in anI far Cumberland County, in Plan Book la, Page 52, TRACT tr2: BEGINNING at a pOint in the center of Ihe old Carlisle, Gettysburg public road at comer of land conveyed 10 Christine L Beam by deed dated J Iy 24, 1964 and recorded in the hereinafter mentioned Recorder's Office in Deed Book J, Volume 21, Page 1131; Ihence along said land nOW or formerly of Christine L. Beam, North 73 1/2 degrees West, a distance f 148 feel to an iron pin; thence along line of Tract #3 hereinafter described. North 14 degrees East, a dist nee of 15 feet 10 a perint at corner of Tact #1 hereinbefore described; thence along Tracl H1, Soulh 73 1/2 deg es East, a dislance of 148 feet to a point in the center line of the Old Carlisle - Gellysburg public Ihence along he center line of the rold Carlisle - Gettysburg public road; thence along the center line of the Old Carlisle - Get sburg public road, South 13 degrees, West, a distance of 15 feet to a point, the place of BEGINNING. CONTAINING 15 feet in front along the center line f the old Carlisle - Gettysburg public road and extending Westwardly therefrom at an even width a distance 0 148 feel, in accordan,ce with surveys made by F. S. Orner on August 17, 1944 and April 18, 1945. TRACT #3: BEGINNING at a common paint of land of Raymond L. Rickroade and now or formerly of Arthur Murray, said point being approximately 147.5 feet fr m the centerline of T-552, Old Gettysburg Road; thence along Lot No. 10, as shawn on the above plan, Norl 74 degrees 23 minutes 00 seconds Wesll00.00 feet to an iron pin; thence along Lot No.1, North 15 degre s 30 minutes 25 seconds East, 63.23 feet 10 an iron pin; thence atong Lot No. 12, south 74 degrees 23 minute 00 seconds East, 100.00 feet to an iron pin; thence atong lands now orlormerly of Arthur Murray, South 15 degrees 30 minutes 25 seconds West, 63,23 feet 10 an iron pin, the place of BEGINNING CONTAINING 0.1452 acres and tIeing Lot No. 11 0 a plan prepared by Eugene A. Hockensmith, R. $" dated February 5, 1998 and recorded In the Office of the R corder of DeedS' for Cumberland County, in'Plan Book 55, Page 16. Parcel #08-38-2175-033 Al TA Commitment Schedule C (2004120060.PFDI2004120060122) BK'18 9 3reGO 467 r!!!' AMC P.O, B..1I000 MORTGAGE SERVrCES SantaA~1 CA 92711-1000 November 02, 200S oiBWNKZZS WILLIAM S BROWN 379 OLD STATE RD GARDNERS, PA 17324,8939 II.)N'" 1'1111111.1..11".1.1,1"11,,1.1.1'11.11.1,1111,,.11.1..1111.1 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FO ECLOSURE Loan Number: 0102904745 Property Address: 379 OLD STAlE RD, G Original Lender: AMC Mortgage Services, In . Current Lender/Servicer: AMC Mortgage Services, In . TIDS FIRM IS A DEBT COLLECTOR ATTEMPT IS SJl:NT TO YOU IN AN ATTEMPT TO OOLUC HJl:RJ:IN AND ANY INFORMATION OBTAINED PURPOSJI:. IF YOU HAVE PRJ:VIOUSLY RJ:CJI: CORRJ:SPONDENCE 1S NOT AND SHOULD NO COLLECT A DEBT, BUT ONLY ENFORdEMJ: G TO COLLJl:CT A DUT. THIS NOTICE THE INDJl:BTJ:DNESS IlJ:n:RRJ:D TO OM YOU WIlL U USED FOR THAT D A DISCBARGJI: IN BJINKIlUPTCY, THIS BJI: CONSTRUED TO BJI: AN ATTJl:MPT TO OF A LlJ:N AGAINST PltOPJl:RTY. T OFPOLICY This i an official dotice that tbe mo a eo our b me i.' del..1 aad tlte ade.. latelld. to foted... S eeific informatioD about the nature of the 'detaalt . rovided ill the attached lanl. The HOMEOWNER'S MORTGAGE ASS TANC PROGRAM borne. This Notice eIDlaio!l how the 1'U"Ollr.otworlu. To see if HEMAP can hel ou must MEE'I1 WITH CONSUMER CUBIT C'OUNSELING AGENCY WITHIN 30 DAYS O"FTHE DATE OJ.' TB NOTI 'I.. Take thil Notleewith IlMI wit_ vOtl..eetwitll the Couaselin2 Aeency. mllV be able to "an to ..ft vUIlr The .am address and bune number of lilted atthc end of this Notice. If ou bave a A eae toll free at 1-800-342-2397. erIO.! er te4lt Couasel" A dellleniall vDllr C..an are .estl., o...a ean th. Pen...lvaala B_d.. ....aate ith. im: 'red hearhl ~.. caU 71 780-1869\. Tbis Notice contains important legal i.fonattio.. H 011 bave any qu.eltioal, repreaeatativel at t"e C......er Credit Counseling AgenC}' may be able to help espl it. YOll may a110 wut to t:Glltad ad aUoraey ia your area. The local bar association may be able to belp y fiad . lawyer, LA NOTIFICACION EN ADJUNTO ES DlJ SUMA PORTANCIA, PUES AlI'I:CTA SU DJl:UCHO A CONTINUAR VIVIENDO EN SU CASA. Sl NO C RJ:NDJI: Jl:L CONTJ:NlDO DJI: Jl:STA NOTIFICACION OBTF,NGA UNA TRADu!CCION lNMEDlTAMENTE LLAllIANDO Jl:STA AGJl:NCIA (pJl:NNSYLV ANIA HOUSING FINANCJI: AGJl:NC SIN CARGOS AL NUMJ:RO MJ:NCIONADO .....I\lIl<.?lll... Also doing business as Delaware AMC Mortgage Service. Inc_. in the states of Texas. Rl10de IalBDd, and New Hampshire. ARRIBA. PUEDES SER ELEGffiLE PARA UN PIp:STAMO POR EL PROC;:RAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ~SSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DEIUlCHO A UDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANC1: PROGRAM R FINANCIAL ASSISTANCE ME J1Il MFOUCLOSmu: AND MORTGAGE PAYMl~NTS IF YOU COMPLY WITH THE PROVISIONS OF Irm: HOMEOWNER'S nlERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU \wAY BE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: ' . IF YOUR DEFAULT HAS BEEN CAUSED B CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELlGffiILlT'\' lIEQ MENTS ESTABLlSm:D BY THE PENNSYLVANIA HOUSING FINANCE AGE CY. TEMPORARY STAY OF FORECLOSU!U: Und thcAct. you arc CDtitIcd",.tcmporory llIay offoteciol1DC on your mortgage for thirty (30) days from the date of 's Notice. Duringtbat timcrou must IlII8IIge 8D.d atteD.d a face-to-face meeting with one of the consumet credit unseling agencies listed at the cud of thiJ Notice. ~ MEETING MUST OCCUR WITHIN TIlE XT 0 DAY . IF YOU DO Nor APPLY FOR EMERGENCY MORTGAGE ASSISTANCE"LOU MUST B G Y UR MORTGAGE UP TO [lATE. TIlE PART OFTIIIS NOTiCE CALLED "HOW TO C\jRE YOUR ORT AGE DEFAULT" EXPLAnIS HOW TO BRING YOUR MORTGAGEJ!I'.TO DATE. CONSUMER CREDIT COUNSELING A NCIE BeeDCV Jisted atJhc__cnd of~~is no.tige the len r of this meeting. The names, addr~sses and tele hon n the county i~__whichJl1e prQP~Llyis locs.led are 'set forth face-to-face meeting. Advise your lender inun~diate1v -- If YOu meet with ooc oftb,e consomcr credit couseling take action uainst vou fell thirtv (30) davs after the date n of dcsi-At~d consumc:t' credit counBClio.l! ucnciea for 1he en olth. Notice. It is only Dcceasary to schedule ooc your intentions. APPLICATION FOR MORTGAGE ASSIS1J'ANCE Your m.ortgagcilin a dcfa:ohfOfthe rCAlODllCtforth later in this Notice (see following pages for specificiinform 'OD about the nature of your clcfault.) If you have tried and are uuble to resolve this problem with the leneler, you ve the right to apply for:fintmcial auislanCe from the Homeowner's Emergcncy Mortgage Assistance Prog . To do SO, you must fill out. sign and file a completed Homeowner's Emergency Assistance Program A..pplic with one of the designated CODSPIDer credit COUIIICIing agencies listed at the end of this Notice. Only donsumcr credit counseling agcociea hllVe applicatiou for the program. and they will assist you in submitting a campi application to the PCDIlIyh'ania. HOIlIing FiDaDce Agency. Your application MUST be filed or postmarked witbin (30) days ofyODt faCC-t1J-face meeting. YOU MUST FILE YOUR APPLICATION l'ROMP LY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FO m IN THIS LETTER, FOUCLOSUIIE MAY PROCEED AGAINST YOUR HOME IMMJ:DIAT LY AND YOURAPPLICAmON J'ORMORTGAGE ASSISTANCE WILl. BE DENIED. AGENCY ACTION -- Available fund-slot emergency by the Agency under the eligibility criteria established sixty (60) days to make a decision after it receives your will be pursued against you if you have met the time re the Pennsylvania Housing Finance Agency of its decisi .._.l\IIt~."" gage assistance are very limited. They will be disbursed. the Act. The Pcmuylvania Houaing Fio.aDce Agency has plication. During that time. no fOICCkm1re procecdiDgI . emCDtS set forth above. You will be notified directly by on yOOl application. November 02, 200S Loan Number: 0]02904745 I NOTE: IF YOU ARE CURRENTLY PROTECTED BY THJ: JlILINli, Oil A PETmON IN BANKRUPTCY. THE FOLLOWING PA T OF THIS NOTICE IS 1I0R IN\IOlIMATION [PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT E DEBT. (If you have filed bankruptcy yoo eo a ply for J:meJ'IU.eJ' Morttap Aailtaace.) ROW TO CURE YO M T A J: D FA T . i aD to date) NATURE QF 'TffE DEF A UL 1. -The MORTGAGE de by the above lender on your property located at 379 OLD STATE RD, GARDNERS, PA [73241S SE OUSLY IN DEFAULT bo"",..: A. YOU HAVE NOT MADE MONTHLY MORTG GE PAYMENTS for the following moDtbJ and the following amounts are now past due: 09/01105 thrn 11/0I/05 at $824.48 per onth Monthly Payments plus late charge or 0 r fees: $2172.38 Total Amount to Cure Default: 52172 8 B. YOU HAVE FAILED TO TAKE THE FOLLO ING ACTION (Do aot al. H .olanalle.ble): N/A BOW TO CURF, THE DEFAULT --Yoa may cure edcfaullwitbia TInRTY (30) DAYS of the dale oftbio notice BY PAVING THE TOTAL AMOUNT PAST UE TO THJ: LENDER, WHICH IS 51172.38 PLUS ANY MORTGAGE PAYMENTS AND LATE BARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. payments must be de ithcrbv cash cashier's check. certified cbcct.or monef order.made onyablcalLd sent to: AMC M rtgagc Services 505 City P ay Wcst. Suite '100 Orang . CA 92868 You can cure any other default by taking the following ction within THIRTY (30) DAYS of the date oflhi, letter: (00 not u~~iLl!Qt apDlicable.)_N/A III YOU DO NOT CURE THE DEFAULT--Ifyond DOl curc the dcfanIJ witbiaTHIRTY (30) DAYS of the _ of Ibis Notice, th~J~I!.c}.~r intell4s_ to exercise it. ri Itt. to ac:c:el rate tile m~debt. This means that the entire outstanding balance of this debt win be considered due ediatcly aDd you may IOlc the ebanco to pay the mortgage in monthly instaUments. If full payment ofth total amount past due is not made within THIRTY (30) DAYS. the lender also intends to instwct its attorneys start legal action to foreelOle UDoa Toar moma.cd ~!'1I. III mE MORTGAGE IS FORECLOSED UPON -- e mortgaged property will be IOld by the Sberiffto pay off the mortgage debt. If the lender refers your case to its at meys. but you cure the de1iaquency before the lendet begins legal proceedings against you, you will still be r wed. to pay the reasonable illtlOrney'S feel that werc actually incuncd, \1pto SSG.GO_ Howevct, iflegal pI dings arc started a.gaiustyou, you win have to pay all reasonable attorney's fees actually incurred by the lrode even if they exceed $50.00. Any attorney', fees will be added to the amount you owe the lender. which may iac:ludc other RaIOnable COIRI. If 1011 Oft tile default "hili. thc_TRI1;lTY (30)DAV pe:riod ou will Dot b re uired to DAY atton.ey'. fea. OTHER LENDER REMEDIES -- The lender may aI sue you personally for the lImpaid principal balance aDd aD other sums due under the mortgagc RIGHT TO CURE THE DEFAULT PRIOR TO sa RIJIF'S SALE --If you bave DOl cured thedcfanIJ witbia the THIRTY (30) DAY period and foreclosUJc proceedi haYe bcpn, you Jdill ha:vr.: 1hl'J ,"pi tn cnre the d...fAnlt and orevent the ~?-I~ atllD)'Jimc llP to one hourhefore Sheriffs Sale. You ma do so by oavina'thetotal amount then past due, pl!!.s <lny_~_tc:_or oth~r char es then due r ooable alto s fees and oostl connected with the foreclosur~ ia1c and am' other__c_osts connected ith thc heriff's Sale as soeci:fied in lmtiu: bv the Icoder and by ....O"lNcrl>-O. performiogJIDY_9.thcr reguiLemeots under the mortlWlCl Carlal your default ia tlu~~ mUller let fortll ia thiJ aotice will restore )'our mortgage to the lame pOlitiOD ., if you had. JleVer clefuked.. EARLIEST POSSmLE SHERIFF'S SALE DATE ~- !tis estimated that the earU~date that mcha Sheriff', Sale of the mortgaged property could be held would be appljOxiJPateJy (6) MONTHS from the date ofthil Notice. A notice of the actual date of the Sheriffs Sale will be se,t to you before the sale. Ofocnane, the amount needed to cure the default will increase the longes: you wait. You 1p1a:y find out at auy time exac;tly what the Ulquired payment or action wilJ be by contacting the lender. I HOW TO CONTACT THE LENDER: AMC Mortgage SeM'ice. pO Box 11000 Santa Ana, CA 92711-1000 Phone Number 800-430-5261 F"I Number 714-347-5037 'EFFECT OF SHERIFF'S SAI.,E -- You shouldrealiz that a Sheriff's Sale will ellllyout ownership of the mortgaged property and your right to occupy it. If you ontinue to live in the property after the Sheriff', Sale, a lawsuit to renlOVC you and your furnishings and other b oagings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ may to a buyer or transferee who will assume the nlortgage attorney's fees and costs arc paid prior to or at the sale I ....!.- m.y Dot (CHECK ONE) seD or transfer your home obt. provided tbal all the out_8 paymeut, cbaIgos and that the other requirements of the mortgage SIC Illtilfied. . YOU Y ALS TO SELL THE PROPERTY TO OBTAIN MONE BORROW MONEY FROM ANOTHER LENDIN HAVE THE RIGHT: TO PAY OFF THE MORTGAGE DEBT OR TO INSTITUTION TO PAY OFF TIllS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY RD PARTY ACTING ON YOUR BEHALF. , TO HAVE TIlE MORTGAGE RESTORED TOT SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. OWEVER, YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . TO ASSERT TflE NONEXISTENCE OF A DEF UL T IN ANY FORECLOSURE PROCEEDING OR ANY OTIIER LAWSUIT INSTITUTED UNDBR THE ORTGAGE DOCUMENT!:, 'I TO SEEK PROTECTION UNDER THE FED BANKRUPTCY LAW. . TO ASSERT ANY OTHER DEFENSE YOU BEL VE YOU MAY HAVE TO SUCH ACTION BY THE LENDER CONSUMER CREDIT COUNSELING AGEN as SERVING YOUR COUNTY AU: ATTACHED cry Truly Youu, MC Mortgage Services Cc: AMC Mortgage Services Attn: Collections DcpartItlcnt Loan Numb<:r: O}02904745 Mailed by 1st Class Mail and by Certified Mail U""~I~-~ ~ Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, P A 17325 (7]7)334-1518 eees of West em PA 2000 Linglestown Road Harrisburg, P A 17102 1-888-51 ]-2227 Community Action Commission ofCaptial Re~on ]5]4 Derry Street , Harrisburg, PA 17104 ' (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Wayoesboro, PA 17268 (7] 7) 762-3285 PHFA 211 North Front Street Harrisburg, P A 17110 ]-800-342-2397 .........lINe.IN,. j:.; \.) 19. ri 1 U( ,iii :::s ~\ ~ )lJ ~ CY CIg 6'- -) ~ __ r,'V U '-' r-- I '" :e ~ ;".; r.~.~ , ,', ~<.- o .... ~....Q LJ SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00270 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BROWN WILLIAM S R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BROWN WILLIAM S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , BROWN WILLIAM S 379 OLD STATE ROAD GARDNERS, PA 17324 DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS, Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 9,68 5.00 10,00 .00 42.68 S~~ R, Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 01/25/2006 Sworn and subscribed to before me this ;oM day of ,yanUc:lr,. / "~lf;~ GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B, Fein, Esq, Attorney J.D,#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY I, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No, 06-270 vs, WILLIAM S, BROWN 379 Old State Road Gardners, PA 17324 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. MOTION FOR SUBSTITUTED SERVICE UNDER P A.R.C.P. 430(a) Plaintiff, by and through its attorney, David B, Fein, Esq" in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 379 Old State Road, Gardners, PA, 17324, hereinafter, the "mortgaged premises". 2. Defendant, WILLIAM S, BROWN, is the mortgagor and real owner of the mortgaged premises, 3, The last known address of Defendant, William S, Brown is as set forth in Paragraph 2 of the Complaint. 4, The Sheriff has been unable to effect service of the Complaint upon Defendant, William S, Brown at his last known address because the Defendant moved and left no forwarding address, per Sheriff, 5, The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, William S. Brown. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant, William S, Brown by posting the pr [ s and certified and regular mail to the Defendant's last known address, BY: David B, Fein, Esq, ERSAL SERVICES . . ,At. Affidavit of Good Faith Investi';lOtion Client provided information: File Number: AMQ-0767 Attorney Firm: Goldbeck, McCatferty & McKeever File Name: Brown Subject Name: William S, Brown Property Address: Street: 379 Old state Road City: Gardners State: PA Zip: 17324 Skip Results: Last Known Street: 379 Old State Road City: Gardners State: P A Zip: 17324 Death Records: As of 12/28/2005, the Social Security Administration has no death record on file for William S. Brown, Social Security Number search completed, Employment Search: Unable to verily current employer. Credilor information: Creditors indicated the last reported address lor William S, Brown as 379 Old Slale Road, Gardners, PA 17324 Department of Motor Vehicle Records: The Pennsylvania Department 01 Molar Vehicles provided no change lor William S. Brown lrom 379 Old State Road, Gardners, P A 17324 Public Licenses (Pilot. Real Estate, etc): Search performed provided no inlormalion. Voter Registration Information: The County Voters Registration Of lice has no listing lor William S, Brown. National Postal Address Search: Has no change lor William S, Brown from 379 Old State Road, Gardners, PA 17324 Comments: 717-732-2615: Called possible relative, Donald Brown, Sr" left message on answering machine, no response. 717-258-4181: Spoke with possible relative, Donald Brown, Jr., does not known current address, 717-486-5150: Called possible neighbor, John Muller, answering machine answered, no message ieft, Date of Birth: March 1967 Dates: As of Phone: Universal File Number: 41160 12/28/2005 On 12/28/2005, I. Patti Garrett being duly sworn according to the law, deposes and says: I am employed by Universal Default Service, I have conducted an investigation into the whereabouts 01 the above named subject. Above are the results 01 my investigation, ('''---, . Subscribed arid .worn 10 before me. NOlory ~ a-h-/l~,__. Date: 1 2/28/2005 6;>;~ KIM ATTEBERY "( ,,*_*:.;; NOClryPublic i " . '.il STAn OF TEXAS f ''<w.~(r;# ComMnJOI'I &p I)~. 12"201>9 , 329 OAKS TRAIL PlAZA . SUITE 202 . GAAl..AND, TEXAS 75043 OFFICE: (972) 226-88$3. FAX: (972) 226-8887 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00270 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BROWN WILLIAM S R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BROWN WILLIAM S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , BROWN WILLIAM S 379 OLD STATE ROAD GARDNERS, PA 17324 DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 9.68 5.00 10.00 ,00 42,68 s~~ R, Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 01/25/2006 Sworn and subscribed to before me day of this A.D, Prothonotary GOLDBECK McCAFFERTY & McKEEVER JOSEPH A, GOLDBECK, JR, Attorney 1.D,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq, Attorney 1.D,#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC, ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No, 06-270 vs, WILLIAM S, BROWN 379 Old State Road Gardners, P A 17324 VERIFICATION I, David B. Fein, Esq" Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service 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 BY: David B. Fein, Esq, relating to unsworn falsification to authorities, GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esg, Attorney I.D,#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC, ASSET BACKED PASS THROUGH IN THE COURT OF COMMON PLEAS CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF Cumberland COUNTY OF FEBRUARY 1, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868" No, 06-270 vs, WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, William S, Brown, which the Sheriff has been unable to personally serve upon Defendant, William S. Brown, As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success, Accordingly, the Court may approve alternative means of service, See Pa,R,C,P.430(a), CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, William S, Brown by posting the premises and certified mail and regular mail to the Defendant's last known address, Respectfully submitted, David B, Fein, Esq, GOLDBECK McCAFFERTY & McKEEVER JOSEPH A, GOLDBECK, JR. Attorney I,D,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B, Fein, Esq, Attorney I.D,#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC, ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County No, 06-270 vs, WILLIAM S, BROWN 379 Old State Road Gardners, PA 17324 CERTIFICATE OF SERVICE David B, Fein, Esq., does hereby certify that true and correct cppies of the foregoing Motion for Substituted Service have been served upon the Defendant, William S, Brown this 8th day of February 2006, by first class mail, postage prepaid, ar. David B, Fein, Esq, BY: ",J :::...., .." {:> -n '-! ."j:': -r1 fn;,- (,...: -'~-; (."r (,'j ("'0) -- -~. '.~<. .~ DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC, ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER TH EPOOLlNG AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYl V AN IA V. WilLIAM S. BROWN 379 Old State Road Gardners, PA 17324 06-270 CIVil ORDER OF COURT AND NOW, this 16'h day of February, 2006, upon consideration of the Plaintiff's Motion for Substituted Service under PaRc'P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, William S. Brown have been unsuccessful, Plaintiffs Motion is GRANTED. IT IS ORDERED AND DIRECTED: 1. That the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon Defendant, William S. Brown by posting a copy of the Complaint upon the premises, 379 Old State Road, Gardners, PA, 17324; 2. That the Plaintiff serve the Compiaint by certified and regular mail to the Defendant's last know address at 379 Old State Road, Gardners, PA 17324; 3. That the Plaintiff effect service by publication to inciude the notice prescribed in Pa.R.C.P. 430, in a legal journal and newspaper of generai circulation in Cumberland County, Pennsylvania; 4. All further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, William S. Brown by sending copies of same to Defendant's iast know address by certified and regular mail, by posting the premises and by publication to include the notice as prescribed in Pa.R.C.P. 430, in a legal journal and newspaper of general circulation in Cumberland County, Pennsylvania. By the Court, ''t ~ M. L. Ebert, Jr., J. 1.0 :D L ""J;~! O'1j -.'''-' .f."j" io:'li!( l.,_ ,,:Jt.'J 11 :fCi " . ~ David B. Fein, Esquire bas ] ,J -f7---rJf.t, 6n ~ GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. AITORNEYI.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHlLADELPHlA, PA 19106-1532 (215) 627-1322 A ITORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, 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 Term No. 06-270 Plaintiff vs. WILLIAM S. BROWN 379 Old State Road Gardners, PAl 7324 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER ~ 41wJ1i~ By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff ,~,'-' '. r c:.: . . 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 2005-Rl. UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, 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 vs. Term No. 06-270 WILLIAM S. BROWN Mortgagor(s) 379 Old State Road Gardners, PA 17324 Defendant(s) CERTIFICATE OF SERVICE tJJA -ch I) d-tfcl0 JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on /" 11. . he did serve upon Defendant WILLIAM S. BROWN a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated February 16, 2006. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, tc~l BEC McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ESQUIRE In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 No. 06-270 Plaintiff VS. WILLIAM S. BROWN (Mortgagor(.) and Record Owner(.)) 379 Old State Road Gardners, PA 17324 Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against WILLIAM S. BROWN by default for want of an Answer. Assess damages as follows: Debt $ 133,273.23 Interest - 08/01/2005 to 04/10/2006 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certifY that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred nd a least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ANDNOW _ flld'-f _~, .;!OOb , Judgment is entered in favor of DEUTSCHE BANK NArrqNALlkuST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE and against WILLIAM S. BROWN by default for want ofan Answer and damages assessed in the sum of$ 3,273.23 as per the ab certification, AMQ-0767 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 27, 2006 TO: WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 DEUTSCHE BANK NATIONAL TRUST COMPANY. AS TRUSTEE OF AMERIQUEST MORTGAGE SECURffiES. INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 200S-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY t. 2005, WITHOUT RECOURSE 505 City Parkway West Suite tOO Orange. CA 92868 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Plaintiff vs. Tenn No. 06.270 WILLIAM S. BROWN (Mortgagor(s) and Record Owner(s)) 379 Old State Road Gardners. P A 17324 Defendant(s) TO: WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 IMPORTANT NOTICF, YOU ARE IN DEF AUL T BECAUSE YOU HA VE 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 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, PA t 7013 7t7-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carliste.PA 17013 Josepli)if f)or<f6ec~ Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 70 I Market Street Philadelphia, P A 19106 215-825-6318 SHERIFF'S RETURN - REGULAR ,. CkSE NO: 2006-00270 P ~ . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BROWN WILLIAM S SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BROWN WILLIAM S the DEFENDANT , at 1115:00 HOURS, on the 25th day of February, 2006 at 379 OLD STATE ROAD GARDNERS, PA 17324 by handing to POSTED PROPERTY AT 379 OLD STATE ROAD GARDNERS a tr~e 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 Posting Surcharge So Answers: 18.00 9.68 6.00 10.00 .00 43.68 ?'~ -/-t: ~ R. Thomas-Kline 02/27/2006 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: ~k- eputy Sheriff me this day of A.D. Prothonotary . ' , . ., GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY J.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 2005-R1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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 vs. Term No. 06-270 WILLIAM S. BROWN Mortgagor(s) 379 Old State Road Gardners, P A 17324 Defendant(s) CERTIFICATE OF SERVICE A1- fA /, ')tP & JOSEPH A. GOLDBECK, JR ESQUIRE hereby certifies that on I'f j}rf/tfl he did serve upon Defendant WILLIAM S. BROWN a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated February 16, 2006. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BEC McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ESQUIRE ,. .:1 .:... 01 0:... "'I ..... &lo! go! , 0 ~~ 11)0 ~ ~\\ ~~ ~ GO h i! ~ !" ~f o~ s ~ \~~~ C 0 &- "':< - J...'q" II} 0 C ~ ~ ~~ GO E .s ~ ~ "''''''' J! ~.. -' ...:.. a- ll> ~&' NOe( 1l <13',LINO 00 ~ <( >- u !: 'C Q. ~ I i Is >- a ~ ~ 18 J I~ ~ i ~ ",1"'0; I 0000 ~ .~ I ~ L j .. '" v lj Ii n:ll I Ubi 9ESh EE'ilO <9 I 1 ~ I ~ ~ m ~ c . l1. I 8 l1. - "" tti <0 r-: 0:; i l1. ~ 'is l1. ! ~ o ,. S 1 ~ t ! u jiO '01j i~ zi jg~ I'! 0: N '0 ~ ~ g. e, ~ o N Z ~ ~ ~ ~.~ .... .... CJi ~"'. ~ ~ :!'~ ~ ~ <I: ~CJ3. ~ ~'~ ' --- .ti ;j ~~ ZA! ~!l " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the Cotmty 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 March 3, 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. S TO AND SUBSCRIBED before me this 3 day of March, 2006 NO A SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas Cumberland County eM! Action-Law Term No. 06-270 DEUTSCHE BANK NATIONAL muST COMPANY. AS TRUSTEE OF AMERlQUEST MORTGAGE SECURmES. INC.. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 200S-RI. UNDER THE POOUNO AND SERVlCINO AOREEMENf DATED AS OF FEBRUARY I, 2006, WITHOUT RECOURSE Plaintiff vs. WILLIAM S. BROWN Mortgagor and Real Owner Defendant NOTICE OF ACTION IN MORTOAOE FORECLOSURE WlLUAM S. BROWN. MORTOA- OOR AND REAL OWNER. DEFEN- DANT whose last lmown address Is: 379 Old State Road Gardners. PA 17324. THIS FIRM IS A DEBT COlLEC- TOR AND WE ARE A'ITEMPl'ING TO COlLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECf- ING THE DEBT. You are hereby notified that Plain~ tiff DEUTSCHE BANK NATIONAL mUST COMPANY, AS mUSIEE OF AMERlQUEST MORTOAOE SECU- RITIES. INC. ASSET BACKED PASS THROUOH CERTIFICATES SERIES 2oo5-RI. UNDER THE POOLINO AND SERVIClNO AGREEMENT DATED AS OF FEBRUARY I, 2005. WITHOUT RECOURSE, has filed a Mortgage Foreclosure Complaint en- dorsed with a noUce to defend against you in the Court of Common Pleas of Cumberland County. Pennsylva- nia, docketed to No. 06-270 wherein Plaintiff seeks to foreclose on the mortgage secured on your property located. 379 Old State Road. Oanl- ners, PA 17324 whereupon your property will be sotd by the Sheriff of Cumberland. NOTICE You have been sued in court If you wish to defend against the claims set forth in the following pages. you Illust take action within twenty (20) days after the Complaint and notice are served. by entering a written appearance personally or by attor- ney and fllmg 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 ComplaJnt or for any other claim or relief requested by the P1a.1n~ tiff. You may lose money or prop- erty or other rtghts important to you. YOU SHOULD TAKE THIS PA- PER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFOR- MATION ABOUT HIRlNO A LAW- YER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIfAT MAY OFFER LEOAL SERV- 3 . CUMBERLAND LAW JOURNAIL ICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC. 40 I E. Louther St. Ste. 103 Carlisle. PA 17013 (717) 243-9400 CUMBERLAND COUNIY BAR ASSOCIATION 32 South Bedford St. Carlisle. PA 17013 JOSEPH A. GOLDBECK. JR. GOLDBECK McCAFFERTY & McKEEVER. PC Attorneys for Plainttff Suite 5000 MeHon Independence Center 701 Market Street Philadelphia. PA 19106-1532 Mar. 3 4 j , ! " PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) March 01, 2006 COPY OF NOTICE OF PUBLICATION ~ IN THE COIIRT OF COMMoN PLEAS CUMBEA~D COUNTY . CIIIIlAenoN''lAW , "" " , ' ACTION OF r.f9RT~<le ~oRECLOSUA~ ,. ' " , Tel11l No. 08-210, " " ,,_::. " . NOTICE Ol':~ IN MORTG:AG:E .FORECU:>SURE :' DEUTSCHE BANK NAtJON!\l TI-lUSTCOMp~N'I. AS TRu$TEe OFAMERIQOEST MORTG:AG:E SECUAlTtes.INC.-BACKED PABS,rHRO\!GHPER'I1FfcATES semES ~1.\JNDER lIlE POOLING AND SERY.ICINQ'AOAE.EMeNT DATED AS PF FEBRUARY 1 ,2005. WIlHOUT RECOURSE . ' . PIlI. va: WIUIAM S.BROWN,' Mortgagol'arid ANI 0Wr1e. . i' 0.;""'" WILLIAMS. SROWN, MORT"GQA ~ND REAl. OWNER. DEFENDANT ~ 1a.1 . _l!IO_Ia$~0Id~R<>l'<I.__;PA1~4. . ' .". THIS RRM IS A DEBT CoueCTOR ANl/.WEARE ATTEMPTING TO COlLECT A OEBT OWED TO OUR CLIENT: ANV ltolFORMATION OBTAINED FROM VOU WILLBf,USEO FOR lIlE PIIRl'OSE ClF COlLECTING THE PE8T: you.... helOby notlIiodlhat PtaIntifI; DEUTSCIIEBANKNATIClNAL lAUST COMPANY, AS TRUSTEE OF AMERIQUES't MQf'ITGAGE Sl;CURITtES,INC. BACKEppABS THROUQH CElmFIl;AnS SEIlIEIl2Qd5-Rl. UNDER TIle , PClClLlNG ANDSERVlPINl; AG/'IEEMEN1' .DATED.&S OF !'EBIlUARY " 2QQli . WITHO.Ule ReCO~Rllit.... _ B MortgigB ForOciIoou" ccitnlililinl.ridQBed wftt, .~IO~.llBII*_Iri"'CciunofCOO1rno(l PIBB,ofCUrilllB/I8nd . County, _\llY....,.doCkBtodlO No. D6'270""",", Plalntilf_ to__ 'on lI.mi;Ut9age'N1~~ on yourp~rty located, 379 Qtd,State RoiId.Gafdners. ,PA 17~4 -"\JPCfl your propeny will bB sold by'" SKBrIlfof Cumbirlllnd, /IQII!Z' You have ~n sued 10 court. If you. wls~ to defend Bgalnit ~ c4alme "'fpI1h In'the foIiCI,Mlingpages, you mUlf_.actioriwlthin. twen. tY(,2020.) ,daysaft,erltilt.Coi'n,,1I.1nI and notice are tMr'<Ied. by entering'. wnn.n appearaij;6 ,pel'&Oi1l11lyor't)y...uo~ and, fHln..Q!~ ,~~ng Wfth,~ (:OUrt.y'ourd~ses o. r obJitcaons to the CielmaMI foi1h agaif!lstYtiO-. 'YGu '8At Wilrijed ~~~.IO'dO so' the Case may proceed without '-r.;"a~~~=~o'"'~~~~~,,~:rr:~~=~ PlaJnIiff.,Vou _may_10M mone)"-:or pitiper1y 9r otttenklhti'lmportant to )'QU. " !'~ YOU-SHOULD TAKE THIS PAPER TO YOUR LAWYEIoI AT ONCE. IF YOODO NOr HAVE A LAWYER OR CANNOTAFFCl~D ONI;, GO TO OR TELEPHClNE THE bFFICE SEr FOR~H SELClW.lIlIS OFFICE CAN PROVID~ YOU WITH INFORMA'lKlN ABOuT HIRING A,LAWYER. . " . . IF YOU CANNOT AFF.O~O TO ~IRE A LAWYER, THIS OFFICE MAY BEADlE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ~LI\lIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SEfWICES INC 81rill'le Row. Cafflsle, PA 17013 717.243--94eQ CUMBERlAND COUNTY BAR ASSOCIATION 211berty'Avenue C8lftsIe, ~A 17013 Josepli A. GoIdbedc, Jr. Attorney tor pta)ntIft , Goldbeck McCafferty & McKeever. PC Suite 5000, Mellon Independence Center 101 Market Street ' P_lphla, PA 191D6'1532 "'-".'f. Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true \ / Sworn to and subscribed before me this Olst day of March2006. ~'I\.~ Notary P hc My commission expiresH II /()9 COMMONWEALTH OF PENNSYLVANIA NaI8rIaI SeoI 0lris1lna L, WdIe. NolaIy PullIic Carlisle Boro. CumbeItand County My~ exp..SepL 1. 2llO6 Member. Pennsytvenia A158oclatlon Of Notaries , . . . ~ DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER TH EPOOLlNG AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM S, BROWN 379 Old State Road Gardners, PA 17324 06-270 CIVIL ORDER OF COURT AND NOW, this 16'h day of February, 2006, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, William S. Brown have been unsuccessful, Plaintiff's Motion is GRANTED. IT IS ORDERED AND DIRECTED: 1. That the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon Defendant, William S. Brown by posting a copy of the Complaint upon the premises, 379 Old State Road, Gardners, PA, 17324; 2. That the Plaintiff serve the Complaint by certified and reguiar mail to the Defendant's last know address at 379 Old State Road, Gardners, PA 17324; 3. That the Plaintiff effect service by publication to include the notice prescribed in Pa.R.C.P. 430, in a legal journal and newspaper of general circulation in Cumberland County, P~nnsylvanja; 4. All further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, William S. Brown by sending copies of same to Defendant's last know address by certified and regular mail, by posting the premises and by publication to include the notice as prescribed in Pa.R.C.P. 430, in a legal journal and newspaper of general circulat!on in Cumberland County, Pennsylvania. By the Court, T~!,JE~~~':l~n:~C.ORD,a _: 01 sa:d ColIn Ci:ki!;, day - '.2oQfe PrOthOllO ~ \, i. ~r M. L. Ebert, Jr., J. Rule of Civil Procedure No. 236 ~ Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff No. 06-270 vs. WILLIAM S. BROWN (Mortgagors and Record Owner(s)) 379 Old State Road Gardners, PA 17324 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary a ~ ~ By: /(/ A~ _ ~ ReV r~ 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, WILLIAM S. BROWN, is about unknown years of age, that Defendant's last known residence is 379 Old State Road, Gardners, PA 17324, 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: ~\~b~V GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. No. 06-270 WILLIAM S. BROWN (Mortgagor(s) and Record owner(s)) 379 Old State Road Gardners, PA 17324 Defendant( s) ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY I, 2005, WITHOUT RECOURSE, and against WILLIAM S. BROWN for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $133,273.23. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY I, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known address(es) of the Defendant(s) is/are WILLIAM S. BROWN, 379 ate Road Gardners, PA 17324; GOLDBEC Mc AFFERTY & McKEEVER BY: Joseph . oldbeck, Jr. Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $120,187,94 Interest from 08/01/2005 through $6,122,60 04/10/2006 Reasonable Attorney's Fee $6,009,40 Late Charges $396.76 Costs of Suit and Title Search $900.00 Fees $106.00 Suspense -$449,47 Total $133,273.23 GOLDBE BY: Josep A. Idbeck, Jr. Attorney for aintiff AND NOW, this o?4ay of r>:6'i' 2006 damages are assessed as above. -p ~ ~ C*''l6 ~ \) r~~-J ~~~P- ~ () fi'"' :p r::--.. t ~. ~' () C. ;'. o -<1 ..... ~f, :g \ ~ -'~ \~j \ ->-) N 1:-(, ~:'_'~ ;.-'~,~.;~"?\ c5 "/;; - '~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P 3180-3183 Joseph A Goldbeck, Jr. Attomey LD.#16l32 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, lNC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs, No. 06-270 WILLIAM S. BROWN Mortgagor(s) and Record Owner(s) 379 Old State Road Gardners, P A 17324 Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $133,273.23 Interest from 08/0 I /2005 to 04/10/2006 at 7,2500% (Costs to be added) GOLDB K CAfFERTY & McKEEVER BY: Joseph . Goldbeck, Jr. Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-270 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 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE, Plaintiff (s) From WILLIAM S. BROWN (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $133,273.23 Interest FROM 8/1/05 TO 4/10/06 AT 7.2500% L.L $.50 Arty's Comm % Arty Paid $168.36 Plaintiff Paid Date: MAY 2, 2006 Due Prothy $1.00 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JOSEPH A- GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 f '" Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005- RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. WILLIAM S. BROWN (Mortgagor(s) and Record Owner(s)) 379 Old State Road Gardners, P A 17324 No. 06-270 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMP ANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 200S-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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: 379 Old State Road Gardners, PA 17324 l.Name and address of Owner(s) or Reputed Owner(s): WILLIAM S. BROWN 379 Old State Road Gardners, P A 17324 2, Name and address of Defendant(s) in the judgment: WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 . ' , PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 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/OCCUP ANTS 379 Old State Road Gardners, P A 17324 (attach separate sheet if more space is needed) I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. CAFFERTY & McKEEVER A. oldbeck, Jr., Esq. aintiff DATED: April II , 2006 o C. ~ ,;:;'~ 0"" -- ....;'':'-- :;:'~ \ ( \ ('.:l Q, ..... --:(~..,-! ~"1'\.'~- '-- ,..;::~'c'~ - ~ ~ : i;\~\ ~,c: \,\-\. C.J _.\ -~ ~:"" -' 12 .~~,. :'3: -- -J " - 06-270 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomeyi.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attomey for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. WILLIAM S. BROWN Mortgagor(s) and Record Owner(s) Term No. 06-270 379 Old State Road Gardners, PAl 7324 Defeudant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BROWN, WILLIAM S. WILLIAM S. BROWN 379 Old State Road Gardners, P A 17324 Your house at 379 Old State Road, Gardners, P A 17324 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 $133,273.23 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOUNG AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: -... . 06-270 L The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff 0017 -240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. 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 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 sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 n c: r--' C"',~l ~ cr. ~ ~,. o "'" .-1 f"f1;o .1~11;j "",C.J- --,:\;-j ,n C/" ~ --< .;.:>-" -c I N :::;; <2 -' SHERIFF'S RETURN - REGULAR CASE NO: 2006-00270 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BROWN WILLIAM S SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BROWN WILLIAM S the DEFENDANT at 1115:00 HOURS, on the 25th day of February, 2006 at 379 OLD STATE ROAD GARDNERS, PA 17324 by handing to POSTED PROPERTY AT 379 OLD STATE ROAD GARDNERS 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 Posting Surcharge So Answers: 18.00 9.68 6.00 10.00 .00 43.68 t:::~ ~~<: ~.J R. omas Kllne 02/27/2006 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: me this "" "to - day of l"~~J,,"" ~AD 'rf:;S/f: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Altom for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 AMQ-0767 CF: 01/11/2006 SD: 09/06/2006 $133,273.23 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-270 Plaintiff vs. WILLiAM S. BROWN Mortgagor(s) and Record Owner(s) 379 Old State Road Gardners, P A 17324 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO ps.ac.p. 3129.2 (e) (2) Joseph A. Goldbeck, Jr., Esquire, Attomey for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff's Office/competent adult (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. f'(l"~ie~ "'/~()6. ('l() Premises was posted by Sheriff's Officel'lIl1llllhR~ all.1t (11111) 8f ...lun. ..lb..:l,~d). ( ) Certified Mail & ordinary mail by Sheriff's 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. i . 11, 1t"_' , n' I., <I ..II I\J a- Ir I'- lTl C C nJ C C """"" o (a.ck,.~lllld 0- ,.q taA._._! M lTl OFF 10051 A L USE - - - 767 9/06 I.tl C . c lIOii(Aji'm:__u~....Q.l.d._.s.taLe.._B.oad.....__........--. I'- <<po..",..' Gardners, PA 17324 iliiii._~....._.._.._._.._m..._.._._...._....._.._....__._...m__- f.!. ~\~~~ .------ ~! \ ",II ~ .~ w ~~o ",u. \V:i t " ol\ t <nu. \ 011 ,f~\ ,,~ 0: ou. ~ \~ ~~ a b ,~:'O;% ~. 'C :. ~g 4- t !\~ 1/' 03,uN(\ 0 0 ::; ~ 0 ,~. I::'. 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"00 _0- ~~ ~\ ~\\ ....'" \cci 'ti.... ~~ 1\,1\ ~Ti ~t \$~ Oi "5 ~ Wi ~ '" % z ~ ~ JJ :2 ~ ,.. to ~ '" ,.. % '6 ~ 2 I J ! . : DEUTSCHE BANK NATIONAL TRUST COMPANY, AS : tN THE COURT OF COMMON PLEAS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. : OF CUMBERLAND COUNTY. ASSET BACKED PASS THROUGH CERTIFICATES SERIES : PENNSYLVANIA 2005.R1. UNDER TH EPOOLlNG AND SERVICtNG AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE 505 City Par1<way West Suite 100 Orange, CA 92888 , V. WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 : 06-270 CIVIL ORDER OF COURT AND NOW, this 16" day of February, 2006, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, William S. Brown have been unsuccessful, Plaintiff's Motion is GRANTED. IT IS ORDERED AND DIRECTED: 1. That the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon Defendant, William S. Brown by posting a copy of the Complaint upon the premises. 379 Old State Read, Gardners, PA, 17324; 2. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's last know address at 379 Old Slate Road, Gardners, PA 17324; 3. That the Plaintiff effect service by publication to include the notice prescribed In Pa.RC.P. 430, in a legal joumal and newspaper of general circulation in Cumberland County, Pennsylvania: 4. All further service of legal papers, inCluding but not limited to motions, petitions and rules be made by certified and regular mail 10 Defendant's last known address and that Notice of Sheriff Sale pursuant 10 Pennsyivanla Rule of Civil Procedure 3129 may be made upon Defendant, William S. Brown by sending copies of same to Defendant's last know address by certified and reguler mail, by posting the premises and by publication to include the notice as prescribed in PaRC.P. 430, in a legal journal and newspaper of general clrc~lat~on in Cumberland County, Pennsylvania. By the Court, TP,t'~,!~~ PROM R~<?ORD :X ,'::"........,,"to,<<: <<.: .c'iQ -f~/~~ ~ "1. l0,~ M. L, Ebert, Jr., GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey LD.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-825-6320 Attomey for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005- RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY I, 2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Term No. 06-270 vs. WILLIAM S. BROWN Mortgagor(s) and Record Owner(s) 379 Old State Road Gardners, PA 17324 Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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 conceming the real property located at: 379 Old State Road Gardners, P A 17324 LName and address ofOwner(s) or Reputed Owner(s): WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 2. Name and address ofDefendant(s) in the judgment: WILLIAM S. BROWN 379 Old State Road Gardners, PA 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 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: 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. TENANT~OCCUPANTS 379 Old State Road Gardners, P A 17324 (attach separate sheet if more space is needed) I verilY that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s. Section 4904 relating to unsworn falsification to authorities. DATED: August 14,2006 McC FERTY & McKEEVER BY: Josep A. Goldbeck, Jr., Esq. Attorney f< r Plaintiff ..., "'" "'" "" 'P' c:: G'J t"V "" (j C -? ,,~ ~G" rrH", -/'" ~;( (hC' ::...(,. r:' r ' <<:.. }Ze ~C) }."1"C: Z ::;! ..., ::J;.: Q. ~~ -om -net DO +~~ :;,.. ':C ...,-i, (:)(') :;';" f11 9\ ~ :;,:: ~ r- ..a COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Deitsch Bank National Tr Co Tr is the grantee the same having been sold to said grantee on the 6th day of ~ A.D., 2006, under and by virtue of a writ Execution issued on the end day of May, A.D., 2006, out ofthe Court of Common Pleas of said County as of Civil Term, 2006 Number 270, at the suit of Deutsch Bank National Tr Co Tr against William S Brown is duly recorded in Deed Book No. 276, Page 4422. IN TESTIMONY WHEREOF, I have hereunto set my hand :<'1 day of and seal of said office this ~ , A.D. d-!)c b ~ (3 ~l-<l; ~ RIcoldIf of DeIdI, Cumbelland CoIIlty, CIdIII. PA My Catl.riilllon EJpINI" FInIt MGIdIy ot....1010 Recorder of Deeds I . Deutsche Bank National Trust Company, as Trustee In the Court of Common Pleas of VS Cumberland County, Pennsylvania William S. Brown Writ No. 2006-270 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2006 at 12:41 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: William S. Brown, by posting the premises at 379 Old State Road, Gardners, Cumberland County, Pennsylvania, pursuant to order of court according to law. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 7,2006 at 10:45 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of William S. Brown located at 379 Old State Road, Gardners, Pennsylvania 17324 according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: William S. Brown, by regular mail to his last known address of 379 Old State Road, Gardners, Pennsylvania 17324. These letters were mailed under the date of June 26, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 6, 2006 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Joseph Goldbeck for Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc. Asset Backed Pass Through Certificates Series 2005-R1, Under the Pooling and Servicing Agreement Dated as ofFebuaryl, 2005, without Recourse. It being the highest bid and best price received for the same, Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities, Inc. Asset Backed Pass Through Certificates Series 2005-R1, Under the Pooling and Servicing Agreement Dated as ofFebuary1, 2005, without Recourse of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$1,701.06. Sheriffs Costs: Docketing Poundage Posting Bills Advertising $30.00 33.35 45.00 45.00 { jt Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge Posting Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 30.00 10.00 .50 1.00 17.60 45.00 40.00 6.00 761. 00 552.80 19.31 25.00 39.50 n $1,701.06 V" Jblo(,lbl. ~ So Answers: ",~~ R. Thomas Kline; Sheriff B~nt~j,^ Real Est ()o , 3D' ~1) I. tJt sS 7/9 i~ );l/861 r " \, Goldbeck McCafferty & McKeever BY: Joseph A Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED P ASS THROUGH CERTIFICATES SERIES 2005- Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. WILLIAM S. BROWN (Mortgagor(s) and Record Owner(s)) 379 Old State Road Gardners, P A 17324 No. 06-270 Defendant(s) AFFIDA VIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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: 379 Old State Road Gardners, P A 17324 l.Name and address ofOwner(s) or Reputed Owner(s): WILLIAM S. BROWN 379 Old State Road Gardners, P A 17324 2. Name and address of Defendant(s) in the judgment: WILLIAM S. BROWN 379 Old State Road Gardners, P A 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 ,. .. P A DEPARTMENT OF PtlBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 379 Old State Road Gardners, P A 17324 (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. CS. Section 4904 relating to unsworn falsification to authorities. CAFFERTY & McKEEVER A. oldbeck, Jr., Esq. aintiff DATED: April 11, 2006 ., '. 06-270 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LA W Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. WILLIAM S. BROWN Mortgagor(s) and Record Owner(s) Term No. 06-270 379 Old State Road Gardners, PAl 7324 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BROWN. WILLIAM s, WILLIAM S. BROWN 379 Old State Road Gardners, P A 17324 Your house at 379 Old State Road, Gardners, P A 17324 is scheduled to be sold at Sheriff's Sale on Wednesday, September 06,2006, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$133,273.23 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: -- " ( . 06-270 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INe. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-RI, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, 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 (l0) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 . TRACT # 1: beginning at a point in the centerline of the old Carlisle-Gettysburg Highway, which point is a comer of tract No.2 on the hereinafter mentioned plan of lots recorded in the office of the Record of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in plan book 10, page 52: thence by said tract No.2, north seventy four (74) degrees twenty (20) minutes west, a distance of one hundred forty six and five tenths (146.5) feet to a point (iron pin); thence along line of tract No.3 hereinafter described, north fifteen (15) degrees twenty five (25) minutes east, a distance of forty eight and one tenth (48.1) feet to a point (iron pin); thence along land now or formerly of Lena K. Kuntz and Chester J. Kuntz, her husband, south seventy three and one fourth (73 ~ ) degrees east, a distance of one hundred forty six and five tenths (146.5) feet to a point in the center line of said Old Carlisle-Gettysburg Highway; thence by the center line of said highway, south fifteen and one half (15 12 ) degrees west, a distance a distance of forty six and four tenths (46.4) feet to a point, the place of beginning. Being improved with a I-story frame bungalow and also being tract No. 1 as designated on a plan of lots recorded in the Office of the Recorder of Deeds in and for Cumberland County, in plan book 10, page 52. TRACT #2: beginning at a point in the center of the Old Carlisle-Gettysburg public road at comer of land conveyed to Christine L. Beam by deed dated July 24, 1964 and recorded in the hereinafter mentioned Recorder's Office in Deed Book J, Volume 21, page 1131; thence along said land now or formerly of Christine L. Beam, North 7312 degrees West, a distance of 148 feet to an iron pin; thence along line of Tract #3 hereinafter described, North 14 degrees East, a distance of 15 feet to a point at comer of Tract #1 hereinbefore described; thence along Tract #1, South 7312 degrees East, a distance of 148 feet to a point in the center line of the Old Carlisle- Gettysburg public thence along the center line of the Old Carlisle - Gettysburg public road; thence along the center line of the Old Carlisle - Gettysburg public road, South 13 degrees, West, a distance of 15 feet to a point, the place of BEGINNING. CONTAINING 15 feet in front along the center line of the Old Carlisle - Gettysburg public road and extending Westwardly therefrom at an even width a distance of 148 feet, in accordance with surveys made by F.S. Orner on August 17, 1944 and April 18, 1945. TRACT #3: BEGINNING at a common point of lands of Raymond L. Rickroade and now or formerly of Arthur Murray, said point being approximately 147.5 feet from the centerline ofT-552, Old Gettysburg Road; thence along Lot No. 10, as shown on the above plan, North 74 degrees 23 minutes 00 seconds West, 100.00 feet to an iron pin; thence along Lot No.1, North 15 degrees 30 minutes 25 seconds East, 63.23 feet to an iron pin; thence along Lot No. 12, South 74 degrees 23 minutes 00 seconds East, 100.00 feet to an iron pin; thence along lands now or formerly of Arthur Murray, South 15 degrees 30 minutes 25 seconds West, 63.23 feet to an iron pin, the place of BEGINNING. CONTAINGING 0.1452 acres and being Lot No. lIon a plan prepared by Eugene A. Hockensmith, R. S., dated February 5, 1998 and recorded in the Office of the Recorder of Deeds for Cumberland County, in Plan Book 55, Page 16. DEED BOOK: 255 PAGE: 3954 TAX PARCEL NO. 08-38-2175-033 MUNICIPALITY: DICKINSON TOWNSHIP PROPERTY ADDRESS: 379 OLD STATE ROAD, GARDNERS, PA 17324 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL V ANfA) COUNTY OF CUMBERLAND) NO 06-270 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 2005-Rl, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1, 2005, WITHOUT RECOURSE, Plaintiff (s) From WILLIAM S. BROWN (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $133,273.23 Interest FROM 8/1105 TO 4/10/06 AT 7.2500% L.L. $.50 Atty's Comm % Atty Paid $168.36 Plaintiff Paid Date: MAY 2, 2006 Due Prothy $1.00 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 '~I (-,< ~ ir'-~-~ , ~...~ ''-0 Real Estate Sale # 28 On May 17, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 379 Old State Road, Gardners, more fully described on Exhibit" A" filed with this writ and by this reference incorporated herein. Date: May 17,2006 By: JtclLf ~~ Real Estate Sergeant E E :b '\/ S - AVW qOOZ Vd 'AlI~nlJ:J U;"II(Lhj~~nJ .:l.:lIH3I-1S 31-11 .:10 331.:1,j0 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ; July 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. SWORN TO AND SUBSCRIBED before me this 4 day of August. 2006 NOTARIAL SEAL LOIS E. SNYDER, Notary Public CarHsle 8oro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 28 Writ No. 2006-270 Civil Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass Through Certificates Series 2005-Rl, under the Pooling and Servicing Agreement Dated as of February 1, 2005, without recourse vs. William S. Brown Atty.: Joseph Goldbeck TRAGI' # 1: beginning at a point In the centerline of the old Carlisle- Gettysburg Highway, which point is a comer of tract No. 2 on the here- inafter mentioned plan of lots re- corded in the office of the Record of Deeds in and for Cumberland County at Carlisle, Pennsylvania, In plan book 10, page 52: thence by said tract No.2, north seventy four (74) degrees twenty (20) minutes west, a distance of one hundred l forty six and five tenths (146.5) feet' to a point (iron pin); thence along line of tract No.3 hereinafter de- scrtbed, north fifteen (15) degrees twenty five (25) minutes east, a dis- tance of forty eight and one tenth (48.1) feet to a point (tron pin); thence along land now or formerly of Lena K. Kuntz and Chester J. Kuntz, her husband, south seventy three and one fourth (73 1/4 ) de- grees east, a distance of one hun- dred forty six and five tenths (146.5) feet to a point In the center line of said Old Carlisle-Gettysburg High- way; thence by the center line of said highway, south fifteen and one half (15 1/2 ) degrees west, a dis- tance a distance of forty six and four tenths (46.4) feet to a point, the place of beginning. Being improved with a I-story frame bungalow and also being tract No. 1 as designated on a plan of lots recorded in the Office of the Recorder of Deeds in and for Cumberland County, In plan book 10, page 52. TRACI' #2: beginning at a point in the center of the Old Carlisle- Gettysburg public road at comer of land conveyed to Christine L. Beam by deed dated July 24, 1964 and recorded in the hereinafter men- tioned Recorder's Office in Deed Book J, Volume 21, page 1131; thence along said land now or for- merly of Christine L. Beam, North 73 1/2 degrees West, a distance of 148 feet to an iron pin; thence along line of Tract #3 hereinafter de- scrtbed, North 14 degrees East, a distance of 15 feet to a point at cor- ner of Tract # 1 hereinbefore de- scribed; thence along Tract # I, South 73 1/2 degrees East, a dis- tance of 148 feet to a point In the center line of the Old Carlisle- Gettvsbure: public thence alone: the Carlisle-Gettysburg public road, South 13 degrees, ~. a d1stance of 15 feet to a point, the place of BEGINNING. CONTAINING 15 feet in front along the center line of the Old Carlisle-Gettysburg public road and extending westwardly therefrom at an even width a distance of 148 feet, in accordance with surveys made by F.S. Orner on August 17, 1944 and April 18, 1945. TRACT #3: BEGINNING at a com- mon point of lands of Raymond L. Rickroade and now or formerly of Arthur Murray, said point being approximately 147.5 feet from the centerline of T -552, Old Gettysburg Road; thence along Lot No. 10, as shown on the above plan, North 74 degrees 23 minutes 00 seconds West, 100.00 feet to an iron pin; thence along Lot No. 1, North 15 degrees 30 minutes 25 seconds East, 63.23 feet to an iron pin; thence along Lot No. 12, South 74 degrees 23 minutes 00 seconds East, 100.00 feet to an iron pin; thence along lands now or formerly of Arthur Murray, South 15 degrees 30 minutes 25 seconds West, 63.23 feet to an iron pin, the place of BE- GINNING. CONTAINING 0.1452 acres and being Lot No. lIon a plan prepared by Eugene A. Hockensmith, R. S. dated February 5, 1998 and re- corded In the Office of the Recorder of Deeds for Cumberland County, In Plan Book 55, Page 16. DEED BOOK: 255 PAGE: 3954. TAX PARCEL NO. 08-38-2175- 033. MUNICIPALflY: Dickinson Town- ship. PROPERTY ADDRESS: 379 Old State Road, Gardners, PA 17324. } ... ... 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 S ALE #28 ~AN'A CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Assieomeot of Bid NO. 06-270 - BROWN 379 Old State Road Gardners, PA 17324 I, Joseph A. Goldbeck, Jr., Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated September 06, 2006 to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES, INC. ASSET BACKED PASS THROUGH CERTIFICATES SERIES 2005-R1, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF FEBRUARY 1,2005, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 GOLDBECK MCCAFFERTY & MCKEEVER ;?/'~ JOSEPH A. GOLDBECK, JR. Date: September 14.2006