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IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY

TRIAL DIVISION-CIVIL

Deutsche Bank National Trust Co, :


as Trustee for Ameriquest Mortgage :
Securities Inc., Asset-Backed Pass- :
Through Certificates, Series 2005-R11 :
C/O Ocwen Loan Servicing, LLC :
1661 Worthington Road :
Suite 100 :
West Palm Beach, FL 33409 :
:
Plaintiff :
: NO. 2016-3253
v. :
:
BEVERLY DIPIAZZA :
511 UNDERWOOD AVENUE :
A/K/A/511 UBDERWOOD AVENUE :
ROSCOE, PA 15477 :
:
LAWRENCE D. PIAZZA A/K/A :
LARRY DIPIAZZA :
511 UNDERWOOD AVENUE :
A/K/A/511 UBDERWOOD AVENUE :
ROSCOE, PA 15477 :
:
Defendant(s) :
:

DEFENDANT’S PETITION TO POSTPONE SHERIFF’S SALE OF REAL PROPERTY

Comes now, Beverly Dipiazza and Larry Dipiazza, Defendants in this foreclosure case.

1. We own the property in this foreclosure matter located at 511 Underwood Avenue

Roscoe, PA 15477.

2. We currently reside at 511 Underwood Avenue Roscoe, PA 15477.

3. The Sheriff’s Sale in this matter is currently scheduled for November 4, 2016 at 10:00

a.m.
4. We respectfully request this honorable court postpone the Sheriff’s sale because upon

further investigation we have discovered breaks in the Chain of Title, Defective Assignments and

other Violations. A Securitization Audit has been started and legal representation for this matter

is in the process of being obtained for the purpose of a Federal Hearing concerning Violations of

Truth In Lending Act (TILA) as well as RESPA and OCC regulations. We believe that there is

enough evidence to call into question the enforceability of the Note and we ask that the courts

postpone any further proceedings until we have had the opportunity to have this case heard

before the Federal Courts.

Respectfully Submitted,

BEVERLY DIPIAZZA
511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477

LAWRENCE D. PIAZZA A/K/A

LARRY DIPIAZZA

511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477
VERIFICATION

This Petition is verified by me. I understand that the statements contained in this Petition are true

and correct to the best of my knowledge, information and belief. I understand that the statement

herein is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn

falsification to authorities.

BEVERLY DIPIAZZA
511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477

LAWRENCE D. PIAZZA A/K/A

LARRY DIPIAZZA

511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477
IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY

TRIAL DIVISION-CIVIL

Deutsche Bank National Trust Co, :


as Trustee for Ameriquest Mortgage :
Securities Inc., Asset-Backed Pass- :
Through Certificates, Series 2005-R11 :
C/O Ocwen Loan Servicing, LLC :
1661 Worthington Road :
Suite 100 :
West Palm Beach, FL 33409 :
:
Plaintiff :
: NO. 2016-3253
v. :
:
BEVERLY DIPIAZZA :
511 UNDERWOOD AVENUE :
A/K/A/511 UBDERWOOD AVENUE :
ROSCOE, PA 15477 :
:
LAWRENCE D. PIAZZA A/K/A :
LARRY DIPIAZZA :
511 UNDERWOOD AVENUE :
A/K/A/511 UBDERWOOD AVENUE :
ROSCOE, PA 15477 :
:
Defendant(s) :
:
AFFIDAVIT OF SERVICE

I hereby verify, subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn

falsification to authorities, that a copy of the Petition to Postpone Sheriff’s Sale of Real Property

has been served on the Plaintiff’s attorney as follows:

Date Served:

TO: UDREN LAW OFFICES, PC


ELIZABETH L. WASSELL ESQUIRE
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRYHILL, NJ 08003
856-669-5400 [email protected]

This pleading was faxed and emailed to the above listed attorney.

BEVERLY DIPIAZZA
511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477

LAWRENCE D. PIAZZA A/K/A

LARRY DIPIAZZA

511 UNDERWOOD AVENUE

A/K/A/511 UBDERWOOD AVENUE

ROSCOE, PA 15477

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