HomeMy WebLinkAbout06-2251
GOLDBECK McCAFFERTY & McKEEVER
,By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, P A 19106
(215) 825-6318
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES
INC" ASSET BACKED PASS-THROUGH
CERTIFICATES, SERIES 2003-11 UNDER THE
POOLING & SERVICING AGREEMENT DATED AS OF
NOVEMBER 1, 2003, WITHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Plaintiff
Term '
No. {t, . ~ / Cud
vs,
GERALD BUSH
SHARON BUSH
Mortgagors and Real Owners
4 Hunter Lane
Camp Hill, PA 17011
Defendants
CIViL ACTIQN: MORTGAGE
fEOm!CL~
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON 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 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty A venue
Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES
NECESSARlO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRlTA, EL
, PUN TO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUlR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARlO, DECIDIR A
FAVOR DEL DEMAND ANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORT ANTES.
USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQuI ABAJO. EST A OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARlO REDUCIDO 0 GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PAl 7013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available fDr Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able tD SAVE YOUR HOME FROM FORECLOSURE.
I). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 or .
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Call the Plaintiff (YDur lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation
or Home Retention options.
5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The
figure and/or package you requested will be mailed to the address that you request or faxed if you leave a
message with that information. The attorney in charge of our firm's Homeowner Retention Department is David
Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
AMQ-0955.
Para informacion en espanol puede communicarse con Loretta aI215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
I. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES
2003-11 UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER I,
2003, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868.
2. The names and addresses of the Defendants are GERALD BUSH, 4 Hunter Lane, Camp Hill, PA 17011
and SHARON BUSH, 4 Hunter Lane, Camp Hill, P A 170 II, who are the mortgagors and real owners of
the mortgaged premises hereinafter described.
3. On November 22,2003 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book 1847, Page 3973. The mortgage has
been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF
AMERIQUEST MORTGAGE SECURITIES INC., ASSET BACKED P ASS-THROUGH
CERTIFICATES, SERIES 2003-11 UNDER THE POOLING & SERVICING AGREEMENT DATED
AS OF NOVEMBER I, 2003, WITHOUT RECOURSE by assignment of Mortgage, which is lodged
for recording. The Mortgage and assignment( s) are matters of public record and are incorporated by this
reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public
record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for November 01, 2005 and each month thereafter and by the terms the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance
Interest from 10/01/2005
through 04/30/2006 at 9.5500%
Per Diem interest rate at $28.08
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 11/01/2005 to 04/30/2006
Monthly late charge amount at $58.07
Costs of suit and Title Search
Escrow Advance
Fees
NSF Fees
Recoverable Balance
Suspense Balance
Monthly Escrow amount $101.50
$105,851.96
$5,952.96
$5,292.60
$348.42
$900.00
$5,501.28
$106.00
$40.00
$5.00
-$54.27
$123,943.95
7" If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% ofthe remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge oftheir personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
9. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $123,943.95,
together with interest at the rate of $28.08, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property.
BY:~l i\.b~{kl~oL.
OL BEC'K McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICA nON
I, NANCI JIMENEZ, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pac C.S. 4904 relating to unsworn falsification to authorities.
Date: C.( - 2 () -0-6
P,~hi6it Jl
. .
EXHIBIT "A" - Legal Description
4 Hunter Lane
Camp HillPA 17011
All that certain tract of land located in East Pennsboro Township,
Cumberland County, Pennsylvania, bounded and described as follows,
to wit:
Beginning at a point on the eastern side of Hunter Lane and on the
northern line of Lot No. 13 on the hereinafter mentioned Plan of Lots;
being 117.24 feet northwest of Brentwood Road; thence along the
eastern side of Hunter Lane north twenty-eight degrees forty-five
minutes west seventy-five (N 28 degrees 45' W 75') to a point on the
southern line of Lot No. 1 on the hereinafter mentioned Plan of Lots;
thence along the southern line of Lot No. 1 north sixty-one degrees
fifteen minutes east one hundred twenty-four and twenty-nine one-
hundredths feet (N 61 degrees IS' E 124.29') to a point on other land
now or formerly of Charles A. Holmes; thence along said land south
sixty-one degrees no minutes east thirty feet (S 61 degrees 00' E 30') to a
point; thence continuing along the land now or formerly of Charles A.
Holmes south five degrees twenty-five minutes west sixty feet (S 25' W
60') to a point on the northern line of Lot No. 13; thence along the
northern line of Lot No. 13 south sixty-one degrees fifteen minutes west
one hundred six and fifty-seven one-hundredths feet (S 61 degrees 15' W
106.57) to the place of beginning.
Being Lot No. 14, Block G, on the Plan known as Long Meadow Plan
No.1, recorded in Cumberland County Plan Book 6, page 23
Parcel #: 09-19-1590-024
FOR INFORMATIONAL PURPOSES ONLY. Cumberland County has
property assessed as 4 Hunter Lane
BK' 84 7PG3989
P,~hi6it (8
P.O. Dos: U_
Sant.A.., CA 92711-10~
~AMC
MORTGAGE SERVICES
7182 b389 30bO 0743 2331
January OS, 2006
SHARON BUSH
GERALD BUSH
4 HUNTER LANE
CAMP HILL, PA 17011
22IIN"""
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME
FROM FORECLOSURE
ST A TJ:MENTS OJi' POLICY
Loan Number:
Property AddJc..:
0rigiDa1 uDder:
CDR'CDt LendcrlServiccr:
0063423545
4 HUNTER LANE, CAMP HILL PA, 17011
AMC Mortgage Services, Inc:.
AMC Mortgage ScIVices, Ioc.
THIS Ji'IIlM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTJ:MPT TO COLLECT TIlE INDEBTJ:DNJ:SS IlJ:Ji'J:IlIlJ:D TO
HEIlJ:IN AND ANY INFORMATION OBTAINJ:D ROM YOU WILL BE USED Ji'OR THAT
PUIlPOSE. Il1 YOU HA VI: PIlJ:VIOUSLY IlJ:CEIVJ:D A DISCHARGE IN BANKRUPTCY. THIS
COIlIlJ:SPONDENCE IS NOT AND SHOULD NOT BE CONSTIlUED TO BE AN ATTEMPT TO
COLLECT A DEBT. BUT ONLY ENJi'ORCEMENT OJi' A LIEN AGAINST PROPERTY,
~. i. .. ofIIdal.otiee that tile mom..e OD nor lI.ome Isla del..lt. aDd tile leader la_tis to foreelose.
SDecifie i.fol'lllmoa abolIt at ..ture of ae default i. Drorided ill D.e attached DaReL
n. HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (lIJ:MAP) maT b. able to belo 10 .... ,...
"GIlle. nil Notice emlal.. how the Dl'ORram workL
To He if IIJ:MAP eID ..... ,... moll MEET WITH A CONSUMER CIlJ:DIT COUNSELING AGENCY
WITHIN 30 DAYS 0)1' TIll: DAn: OJ' THIS NOTICE. Take tbis Notiee wit. 1'_ wile. 1'011 meet with the
Cou.IeU.. Asrean.
Tile .ame. .44ft.. aa.d .bOll' Bamber of COIlllllller Credit CouaseIiaa A..des lema. vou.r C...tv are
lilted at th ea. of thi. Notiee. If "011 have .." aaestiou. T08 may call the Pe_.vlvaala ROIlR.. J'iauce
A.Rn toll free at 1-800-3...2-2397.CPeno.1 with _Daind "caria. en ull (717) 780-1869).
Till, Nodce eoatai.. importaat lepl illformatloa. If y,,"ave o.y qaeltioDJ, reprele8.tativel at tile CoalAUDer
Credit Cou.IeI.. Aaea~y may be able to llelp uplaia it. You may also wut to eoa.tact.. attoney ia yoar
areL The local bar auoeiatioa may be able to help you. fiad a lawyer.
LA NOTIl1ICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUJ:S AJi'J:CTA SU DEIlJ:CHO A
CONTINUAR VlVII:NDO EN SU CASA. SI NO COMPIlJ:NDE EL CONTENIDO DE ESTA
NOTIl1ICACION OBTJ:NGA UNA TIlADUCCION INMEDrrAMENTE LLAMANDO ESTA AGENCIA
(pENNSYLVANIA HOUSING Ji'INANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
"'_vlM""'._""
Also doing busiDess as Delaware AMC Mortgage Services, IDe., in the states of TexlllI, Rhode hland. and New Hampshire
AIlIlIJIA. PUJ:DES SER ELEGmLE PAllA UN PIlJ:STAMO POR EL PROGIlAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGIlAM" EL CUAL PUJ:DE
SALV AR SU CASA DE LA PERDIDA DEL DEIlJ:CHO A IlJ:DIMDl SU HIPOTECA.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELlGmLE roR J'lNANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME J'JlOM FOIlJ:CLOSlllIJ: AND
HJ:LP YOU MAKE FlTTlJIlE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THJ: PROVISIONS OF TIIJ: HOMEOWNER'S I:MJ:RGENCY MORTGAGE
ASSISTANCE ACT OF .983 (THJ: "ACT"). YOU MAY BE ELlGmLJ: FOR EMERGENCY MORTGAGE
ASSISTANCE:
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCIJMSTANCES BEYOND YOUR CONTROL.
z IF YOU HAVE A IlJ:ASONABLJ: PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS,AND
z IF YOU MEET OTIIJ:R ELlGmILITY IlJ:Qmu:MENTS EST ABLISIIJ:D BY THJ:
PENNSYLVANIA HOUSING J'lNANCI: AGENCY.
TEMl'OIlARY STAY OF rollJ:CLOSlllIJ: - UndeI the Act, you are entitled to a temporlllY stay offo"",loo"",
on yOO1 morlgage for thirty (30) clays from the date ofthi. Notice. Doring that time yon mnst ammge and attend a
face-to-face meeting with oat of the COBSUmeI credit COUDSCtiq agencies listed. 8l the end of this Nonce. THIS
MEETING MUST OCCUR wrrHIN TIIJ: NEXT (JO) DAYS. IF YOU 00 NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PAR1 OF THIS
NOTICE CALLED 'HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAiNS HOW TO BRING YOUR
MORTGAGE UP 10 DATE.
CONSIJMJ:R CIlJ:DIT COUNSELING AGENCIES -- If yon meet with ODC of the consnmer aedit connaeling
a.."", listed at the end of thi. notice the IendeI may NOT tate action ""aiDat von for !I!i!!Y (30) claVI afler the date
of this mcctin2. The umes addreSBCS and telcnhone numbc~.of dcsi2D8tcd consumer credit coonseJine uencics for
the coontv in which the otODCItv illotBted. ate set forth at 'the c::nd of this Notice:. It is only ncccsS8I)' to schedule one
face-to-face meeting. Advise your lender immcdiatclv of YOUl intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgnge is in a defnnItfor the......,....t forth later
in thi. Notice (Bee following Jlllge. for specific information about the D8lure of your defnnh.) If yon bove tried and
arc unable to resolve this problem with the lender, you have the right to apply for fiDanciallllsiBl8nce from the
HOJIlCOWDCts Emetgency Mortgage Assista:ace Progmm. To do SO, yoo must fill oot, sign and file a completed
Homeowner'1 EDlCfgency AsaiBtancc Program Application with one of the designated consumer credit counseling
agencies lilled. at the CDd. oftbis Notice. 00Jy COD&um.cr credit counseling agencies have applications for the
program and they will assist. you in Illbmitting a complete application to the Pennsylvania Housing FUIIlJlCe Agency.
Yonr appIication MUST be filed or postmalkcd within thirty (30) clay. ofyoor face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHJ:R TIMJ: PERIODS SET roRTH IN THIS LETTER, rollJ:CLOSUIlJ: MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION roR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available fnn4. for emergency mortgage aaustance arc very limited. They win be di.bnlBed
by the Agency onder the eligibility criteria established by the Act. The Pcnnsylvania Housing Flnnncc Agency haa
sixty (60) days to mate a decision after it receives your application. Doring that time, no forcclosnre proceedings
will be pursned against you if you have met the time rcqniremcnlS lOt forth above. You win be notified dilecdy by
the Pennsylvania. Housiag Finance Agency of its decision on your application.
.....,..."""'.-..
18ll1llUY OS, 2006
Loan Numbc..: 0063423545
NOTI:: IF YOU AllI!: CUIlUNTLY PROTJ:CTJ:D BY TIIJ: I'lLING OF A PJl:TmON!l
BANKll1ll'TCY. THE FOLLOWING PART OF THIS NOTICJ: IS FOR INFORMATION .
PURPOSI:S ONLY AND SHOULD NOT BI: CONSIDI:UD AS AN ATTJ:MPT TO COLUCT
THE DI:BT.
(If you "ave filed baa.kr.ptey YOIl cultil1 appl, for I:.DlerJU.CJ Mort... Allittaue..)
HOW TO CUllE YOUR MORTGAGE DJ:J'AULT fBri.. it aD to date).
NA TUBE OF THE DEF AUL 1: -The MORTGAGE cleht by the above lender on y.... property located at:
4 HUNTER LANE, CAMP HILL, PA 17011 IS SERIOUSLY IN DEF AUL T beca...:
A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the fnllowmg months and the
following amounts are now put due:
11/01/05 thzn 01/01/06 at $1005.97 per month
Monthly Payments plullate c1uuge 01 othel fecs.: $3109.73
T.... Am...t to eurellefaolt, $3109.73
--'
B. YOU RAVJI: FAILI:D TO TAKE Tn FOLLOWING ACTION (Bo not... Ih.t IDnlleahlo), N/A
HOW TO CUD THI: DI:FAULT-Yon may cure the default within TIllRTY (30) DAYS of the date oftbis
notic:e BY PAYING TIIJ: TOTAL AMOUNT PAST BUJ: TO TIIJ: LI:NDI:R, WUICHrs 53209.73
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WIllCH BECOME DUE DURING THE
TIllRTY (30) DAY PERIOD. Pavmen.. mnst be made either by cash. coshier's check. certified check or monev
0.1 mad.e ntl.vable and sent to:
AMC MOJ\Bagc SeniCC:B
505 City Pa_ay West. Suite *100
Orange, CA 92116&
Yon can cure any other defiudt by takiDg the followmg action within TIllRTY (30) DAYS of the date oftbis letter:
(Do not use unot aDDlicablc.) N/A
IF YOU BO NOT cun THE DEFAUL T--If yon do not cure the defauh within TIllRTY (30) DAYS of the date
of ibis Notice, t.e leader iIl_d, to exercise it. riRh.. to aeeelerate tb ..~deb" This means that the entire
ontRfanding balance of this debt will be coa.si.dcrcd. due immedistcly aDd you may lose the chance to pay the
mortgage in monthly iutallments. If foil payment of the total amount past due is not made within THIRTY (30)
DAYS, the lcoder also iDtmds to instruct its attorneys to start legal action to 'oftCIOIe~ wur laomaud.
~-
IF THE MORTGAGI: IS FOUCLOSI:D UPON -- The mortgagee! property will be sold by the Sheriff to pay off
the mortgage debt. If the lender refers your case to its attorneys, bot you core the delinquency ben"e the lender
begins legal procceding. agaiDat yvu, you will still be requited to pay the reasonable attomey's feea that were
actually incurred, up to S50.00. However, if legaJ proceedings arc started against you, yoo will have to pay all
reasonable attorney's fees actnally incurred by the iender even if they exceed $50.00. Any _'s feea will be
added to the amount you owe the IcDdcr, which may also iDclude othc:t reasonable costs. If..108 &:lire tile default
witlliD the THIRTY (30) DAY period. you. wlllaot be requited to on attoney', fee..
OTIIJ:R LENDER HMJ:DIES - The lender may also sue you personally for the unpaid principal balance and aD
othCI sums due DDCler the mortgage.
RIGHT TO CUD Tn BEVAUL T PRIOR TO SHERlFlI'S SALI: --If you have not cured the defanh within
the TIIIRTY (30) DAY period and fOfCclosUl'C proceedings have begun. you still have the right to cure the di'!fAnlt
and DtC'Vcnt the sale at 8DV time lID to one hour before the Sheriffs Sale. You mB.V do 10 by ~R the total amount
then past due. plus any late or other charges then due, reasonable attomcr's fees and costs cODDOCted with the
foreclosure sale and anv other cOlts connected with the Sheriff's Sale as mccified in. ~bx..mc lender and. bv
"_."c~t>...
ucrformjn" 8DV othCI rcaoiremcnts undCI the mort2a{!:e. Curial yoar defult ill. the maser llet forth ia ."0
sod" will restore your ..ol'tple to the lame pOlltioa. u if you had aever defaulted.
EAllLn:ST POSSmLE SBJ:RIn"S SALE DATE -It is estimated that the earliest date that such a Sheriff's Sale
ofth. mortgaged property could b. hold would ho approximately (6) MONTHS from tho date of this Notice. A
notice of the actual date of the Shcriff's Sale will be sent to you before the sale. Of course, the amount needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
01 action will be by contacting the IcndCl.
HOW TO CONTACT TIIJ: LJ:NDJ:R:
AMC Mortaale Semen
PO BO]l 11000
Santa AIla, CA 91711-1000
Pboae Na..ber 808-430-5162
Fu N...ber 71~47-5037
J:I'FECT Oil SJD:IlJ]!]1'S SALJ: - You should rcalizo that a Shorifl's Sal. wiD.... your ownonbip of tho
mortgaged property and YOUI right to occupy it. If you continue to live in the property aftcr the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lendel at any time.
ASSUMPTION OJ' MORTGAGE - You _ may 01 ~ may aot (CHECK ONE) seD 01 tran&fCI you home
to a bU}'CI 01 transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
aUorney's fces aod costs lIe paid priOI to or at the sale and that the other requirements of the mortgage arc satisfied.
YOU MAY ALSO BA VI: THJ: RIGHT:
. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY TInRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME PosrrION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSillT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER
. TO SEEK PROTECfION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMJ:R CUDIT COUNSJ:LING AGJ:NC1J:S SJ:RVING YOUR COUNTY AIlJ:
ATTACHJ:D
Very Truly Yours,
AMC Mortgage Services
Cc: AMC Mortgage Services
AUn: Collections Dcpartment
LOlID Number: 00634Z3~4~
Mailed by lit Cia. Mail ad by Certified Mail
<>ooo<}NI;P!>-<oo
.
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg. PA ] 7325
(7]7) 334-]5]8
CCCS of Western PA
2000 Linglestown Road
Harrisburg. PA ]7]02
]-888-511-2227
Community Action Commission ofCaptial Region
] 5] 4 Derry Street
Harrisburg. PA ]7]04
(7] 7) 232-9757
Loveship, Inc.
2320 North 5th Street
Harrisburg. P A 17110
(717) 232-2207
Marsnatha
43 Philadelphia Avenue
Waynesboro, PA ]7268
(717) 762-3285
PHFA
211 North Front Street
Harrisburg. PA ]7110
] -800-342-2397
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GOLDBECK McCAFFERTY &: MeKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE OF AMERIQUEST
MORTGAGE SECURITIES INC., ASSET
BACKED PASS-THROUGH CERTWICATES,
SERIES 2003-11 UNDER THE POOLING &
SERVICING AGREEMENT DATED AS OF
NOVEMBER 1, 2003, WIlHOUT RECOURSE
505 City Parkway West
Suite 100
Orange, CA 92868
IN THE COURT OF COMMON PLEAS
of Cumberland County
No. 06-2251
Plaintiff
vs.
GERALD BUSH
SHARON BUSH
(Mortgagor(s) and Reeord owner(s))
4 Hunter Lane
Camp Hill, PA 17011
lRAECItE 1'9 QISCONJINVE AND END
TO THE PROlHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
~~-
JOSEPH A. GOLDBECK, JR., ESQUIRE
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2006-02251 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BUSH GERALD ET AL
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
BUSH GERALD
the
DEFENDANT
, at 1922:00 HOURS, on the 25th day of April
2006
at 4 HUNTER LANE
CAMP HILL, PA 17011
by handing to
GERALD BUSH
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
12.32
.00
10.00
.00
40.32
.~~~
R. Thomas Kline
t;h. 5'/~:v/t; I,
Sworn and Subscribed to
before
04/26/2006
GOWB::~ MCCMFLM~KEt-
Deputy She ff
me this
day of
A.D.
Prothonotary
SHERIFF'S RETURN - REGULAR
.....- . ~..
CASE NO: 2006-02251 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BUSH GERALD ET AL
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
BUSH SHARON
the
DEFENDANT
, at 1922:00 HOURS, on the 25th day of April
, 2006
at 4 HUNTER LANE
CAMP HILL, PA 17011
by handing to
GERALD BUSH, HUSBAND
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
~ 5/Ja/o(,
Subscribed to before
So Answers:
?y~~:,,~~c</~
R. Thomas Kline
day of
04/26/2006
GOLDB:~~ MCCAFFER~~~
Depu y Sheriff
Sworn and
me this
A.D.
Prothonotary