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BROADVIEW MORTGAGE COMPANY : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 94• (e 73 Cc.. Tt .
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER : CIVIL ACTION - LAW -
Defendants : IN MORTGAGE FORECLOSURE
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.
N 0 T I C E
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 claimed in the Complaint or 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 TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumherland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S O
LE HAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, O 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 110 REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SER1'IClO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
BROADVIEW MORTGAGE COMPANY
Plaintiff
Va.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 51601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BROADVIEW MORTGAGE COMPANY
Plaintiff
VS.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9,11'. (,.J 7 3 OttiV Tr,
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, BROADVIEW MORTGAGE COMPANY, is a corporation,
with an address of 95 EAST WILSON BRIDGE ROAD. WORTHINGTON, OHIO
43085.
2. Defendant, BRET HARRISON BITTNER, is an adult individual
whose last known address is 215 LIMEKILN ROAD, NEW CUMBERLAND,
PENNSYLVANIA 17070. Defendant, TAMMY EVETTE BITTNER, is an adult
individual whose last known address is 215 LIMEKILN ROAD, NEW
CUMBERLAND, PENNSYLVANIA 17070.
3. On or about August 10, 1995, the said Defendants
executed and delivered a Mortgage Note in the sum of $50,145.00
payable to BROADVIEW MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1157, Page 0294 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 215 LIMEKLIN ROAD,
NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on January 1,
1999 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 48,909.64
(b) Interest at $19.82 per day
from 12/1/98 to 11/1/99
(based on contract rate of 9.000%) 6,639.70
(c) Accumulated Late Charges 367.35
(d) Late charges at $20.08
per month for 11 months 220.88
(e) Escrow Credit 0.00
(f) 5% Attorney's Commission 2,445.48
$ 58,583.05
*Together with interest at the per diem rate noted in (b) above
after November 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of Intention to Foreclose and accelerate the
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 9.0001 ($19.82 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL...-KPJJG &hIALLER
By " Cs
Leon P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
FHA CASH NO.
STATR.OP PENNSYLVANIA
FHA MULTI-STATE NOTE
AUGUST 10 ,1995
215 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070
(Fropenyndaml)
1. PARTIES
'Borrower' mcam each person signing at the end of this Note, and the permn't successors and assi 'Larder'
moons BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, ON 43085
and Its successors and assigns.
2. BORROWER'S PROMISE TO PAYI INTEREST
In «tum for a loan received tram Lender. Borrower p
HUNDRED FORTY-FIVE AND NO/100*********
tumof FIFTY THOUSAND ONE
(Ids. S 50,145.00 ), plus interest, to the a rder or Lender. Interest will be charged on unpaid
principal. tram the data ofdisbursementof the loan proceeds by Lender, at the rate of NINE********************
fMttffHMMf ••f f Hf HMHfNf tit •M#Hff •Nf M#f stiff tftfif ffttffHtftffifHf#ti
percent ( 9.000 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a monsam deed of trust of similar security instrument that is dated she Mme
date as this Note and called the 'Security InMMCnL' That Security Instrument protects the Lender from losses which
might result If Borrower defaults under this Nola
4. MANNER OF PAYMENT
(A) Time
Bormwer shall make a payment of principal and interest to Lender on the rust day of each month beginning on
OCTOBER 1, 1995 .Any principal and interest remaining on the fnaof SEPTEMBER
2025 , will be due on that date, which is piled the maturity date.
(B) Platt
Payment shall be made at BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD,
WORTHINGTON, ON 43085
or at such other piece as Lender my designate In writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be In the amount of S 403.48
This amount
will be part of a larger monthly payment required by the Security Instrument. that shell be applied to principal, interest and
other items In the order describe! in the Security Instrument.
(D) Allonge to this note fur payment adjustments
If an allonge providing for payment adjusunenu Is executed by Borrower together with this Note, the covenants
of the sllongo shall be incorpomlel into and almtl emend and supplement the covenants of this Note M if the allonge were
a pan of this Note. (Check applicable box.)
Crowing Equity Allonge El Graduated Payment Allonge
Other Ispecify)
S. BORROWER'S RICIRT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, In whole or In pan, without charge or penalty, on the
fiat day Of.nny.mmmh....-.
6. BORROWER'S FAILURE TO PAY - -
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument. as described in-
Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Land" may suBecl a lase charge
Indlcamountof FOUR**f*tt**tf*i*****tttfatfif#ttaattfftt#ittifrttiftiiatttitiftttitt
#it#HtMtN#Hf #tHfltff fftHNHitiNtttittl ftH#fiHHtfHf tttl HHMltiMf tlH
Percent ( 4.00 %) of the overdue amount of each payment
em
YW lIW aW,1 /Ira M.
IlaYaplll total ONN eo,Ieafrll fMp d.yr M(Il) hoNWca ILMpp qIy IIF 1.1111
r1 f AC( T/ 52440
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(D) Default
If Dorrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
rmaining.AuaamLall aeaued.lntemst-Lento sy.ehoosa nolw esacise thls.opdon.without walvintlts dgbts.la the-..
event of any subsequent dclwlL In many circumstances regulations Issued by the Seerctary will limit Lender's rights to
require Immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not
permiucd by HUD regulations. As used in this Note,'Sesetary' means the 5ccreary of Housing and Urban Devdopmuu
or his or her designee.
(C) Payment of Costs and Expenses
If Lender.has rcquhcd.Immcdiate paymenLin fuD,mAescribed above, L=du.may.fcqulm Borrower io.pay coru .
and espaaar including reaumbic and cwwmary attorneys' Ice for enfuming this Nutty Such fees and ants dull bear
Interest from tee date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive this rights of presentment and notice of
dishonor. 'lYeswuneriV means the right to require Lauder to demand payment of amounts duo. 'Notice of dishonor'
marts the right to require Lender to give notice m other persons that amounts due have not been paid.
1. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivomi; It or by mailing it by rust class mail to Borrower at the property address above or at a different
address N Borrower has given Lender a notice of Borrower's different addrw.
Any notice that must be given to lender under this Note will be given by lust clan mail to Lender at the address stated
In Paragraph s('B) or at a different add=s if Borrower 6 given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If moss than one person signs this Note, each person Is fully and personally obligated to keep all of to promises made
In this Note, Including the promise to pay the full amount owed. Any pawn who is a guarantor, surety or endow of this
Nom is also obligated to do thew t Inge. Any person who takes over these obligations, including the obligations of a
guawtor, surety or endorw of this Nom, Is also obligated to keep dl of the promises made in this Now Lender may
enforce its rights under this Nom against each person Individually or against all signatories together. Any one person
signing this Nom may be required to pay all of the amounts owed under this Now
BY SIGNING BELOW and agrees to the toms and covenants contained In pages t and 2 of this
Now
(SEAT.) /C? •'t-?!-'-c_CUI?I? Z?iy_ rr7(SFAL.)
RET- I ON BITTNER- - taw ?-•h TAMMY EVET E BITTNER-• - B? -
(SEAL.) (SEAL)
hw,own ft n
(SEAL)
Bwrawu
WITH= RDCWRSE, PAY TO THE ORDER OFs
DROABVIEH IDRTGpO//E OCHPANYy.
BYR
Martha Barnhart
Assis!ant Scaetary
aMuw I.I..4 ¦
rtwuns Pun o«uraoeharna (Mr•7•fr/Mr••) r.>MW hdMnaarm ores hn nr.huh
gCCT1 652440
• r
Number:95095CAP
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of Fairview, County of
York and State of Pennsylvania, more part icu a-F7 bled aannd-andas
follows, to wit:
BEGINNING at a brad in the center line of Township Road T-955 at the western
line of lands now or late of Henry Bowman; thence South 12 degrees 47 minutes
East 77 feet to a stake; thence South 77 degrees 17 minutes West by lands of
same 112 feet to a stake; thence North 12 degrees 40 minutes West by lands of
same 40 feet to a brad in the center line of said Township Road) thence North
59 degrees East by said center line 117.96 feet to a brad, the point and place
of BEGINNING.
HAVING thereon erected a one and half story frame dwelling with attached
masonry garage known and „,:Tti?.?a ^^ 215 Limekiln Road.
THE ABOVE described premises are conveyed subject to an Avigation Easement to
the Commonwealth of Pennsylvania set forth in Deed book 64-T, Page 152.
BEING THE SAME premises which Dennis A. Morian by deed dated November 1, 1990
and recorded in the Office of the Recorder of Deeds in and for York County,
Pennsylvania in Book 100-B, Page 590, granted and conveyed unto David Riddle and
Melissa Yale, now known as Melissa Riddle, Grantors herein.
I Certify This Document 7b Be
Recorded In York County, PD.
.• : ;..19 REi Gr •.
•4 up.f
VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts contained in the foregoing COMPLAINT for Mortgage Foreclosure
are true and correct to the best of my knowledge, information, and
belief based upon information provided by Plaintiff, BROADVIEW
MORTGAGE COMPANY and that said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
/l
V
Date: October 11, 1999
Leon P. Haller, Esquire
I
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BROADVIEW MORTGAGE COMPANY IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
Vs.
No. 99-6273 CIVIL TERM
BRET HARRISON BITTNER AND CIVIL ACTION - LAW -
TAMMY EVETTE BITTNER IN MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY:
Kindly settle and discontinue, without prejudice, the
above matter of record.
PURCELL, KRUG & HALLER
Leon P. Haller
I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
(Attorney for Plaintiff)
DATE: December 14, 1999
!' " cam: };• s
gifts 1W MIlV lOOIU N vis B fllle
OM 11Y01 MlWN1YOfl f1110 '11f 1
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-06273 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BROADVIEW MORTGAGE COMPANY
VS.
BITTNER BRET HARRISON ET AL
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: BITTNER BRET HARRISON
but was unable to locate Him in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND as to the within named defendant
BITTNER BRET HARRISON
ADDRESS IS IN YORK COUNTY, ATTORNEY DID NOT
FORWARD NEEDED FUNDS IN ORDER TO DEPUITZE PRIOR TO EXPIRATION DATE.
Sheriff's Costs: So answe
Docketing 18.00
NOT FOUND RETURN 5.00
Affidavit .00 i '
Surcharge 8.00 ,
$3TU0 12/14/1499RUG & HALLER
Sworn and subscribed to before me
this /1. t?- day of
0 ;lA7Vy A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-06273 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BROADVIEW MORTGAGE COMPANY
VS.
BITTNER BRET HARRISON ET AL
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: BITTNER TAMMY EVETTE
but was unable to locate Her in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND , as to the within named defendant
BITTNER TAMMY EVETTE
ADDRESS IS LOCATED IN YORK COUNTY ATTORNEY
DID NOT FORWARD ADDITIONAL FUNDS REQUIRED TO DEPUTIZE PRIOR TO
EXPIRATION DATE.
Sheriff's Costs: So answe
Docketing 6.00
NOT FOUND RETURN 5.00 ???
Affidavit .00
Surcharge 8.00 K-/
nomas , bnurILL
$Z9-.-IT0 12?14?L UG & HALLER
Sworn and subscribed to before me
this 1146 day of
bf •7?O ?,A A. D. AQ??
C??'d L y
BROADVIEW MORTGAGE COMPANY
Plaintiff
VS.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
THIS LAW FIRM IS A DEBT
TO COLLECT A DEBT OWED
OBTAINED FROM YOU WILL
COLLECTING THE DEBT.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. ?I7• G.273 8.4,z4
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COLLECTOR AND WE ARE ATTEMPTING
TO OUR CLIENT. ANY INFORMATION
BE USED FOR THE PURPOSE OF
N O T I C E
You have been sued in court. If you wish to defend against the claims net
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 claimed in the Complaint or 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 TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S 0
LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO 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 PARTICIPACION. ENTONCES, IA CORTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES. 1
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17017 jf?l))= ??,,^q•?2, .; ,o,? {?;:.;•.,?I?
717-243-9400 ,
BROADVIEW MORTGAGE COMPANY
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
. NO.
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 51601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BROADVIEW MORTGAGE COMPANY
Plaintiff
Vs.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9ef - L.2 73 C4, .t 7-,-
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
1. Plaintiff, BROADVIEW MORTGAGE COMPANY, is a corporation,
with an address of 95 EAST WILSON BRIDGE ROAD. WORTHINGTON, OHIO
43085.
2. Defendant, BRET HARRISON BITTNER, is an adult individual
whose last known address is 215 LIMEKILN ROAD, NEW CUMBERLAND,
PENNSYLVANIA 17070. Defendant, TAMMY EVETTE BITTNER, is an adult
individual whose last known address is 215 LIMEKILN ROAD, NEW
CUMBERLAND, PENNSYLVANIA 17070.
3. On or about August 10, 1995, the said Defendants
executed and delivered a Mortgage Note in the sum of $50,145.00
payable to BROADVIEW MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to Original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds office of the within County and
Commonwealth in Mortgage Book 1157, Page 0294 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 215 LIMEKLIN ROAD,
NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly
described in Exhibit "B" attached hereto.
? r
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on January 1,
1999 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 48,909.64
(b) Interest at $19.82 per day
from 12/1/98 to 11/1/99
(based on contract rate of 9.000%) 6,639.70
(c) Accumulated Late Charges 367.35
(d) Late charges at $20.08
per month for 11 months 220.88
(e) Escrow Credit 0.00
(f) 5% Attorney's Commission 2,445.48
$ 58,583.05
*Together with interest at the per them rate noted in (b) above
after November 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth zoove are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
e. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of Intention to Foreclose and accelerate the
r
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 9.000% ($19.82 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL-e&WG &,41ALLER
By ?? C--
Leon P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
1?.
STATE OF PENNSYLVANIA
PFR RACASONO.
FHA MULTI-STATE NOTE
AUGUST 10 ,1995
215 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070
(Ropeny Addrais)
1. PARTIES
'Bomowce meant each person Signing at that end of this Note, and the person's succetsm and assign. 'Lender'
memo BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, ON 47085
and Its successor and assigns.
1 BORROWER'S PROMISE TO PAY{ INTEREST
In return fors loan received from Lender, Borrower promhes to pay he principal turnof FIFTY THOUSAND ONE
HUNDRED FORTY-FIVE AND NO/100arrarrraarararrrrra laaanrararrrararrarrrnraaaararrr
araraaaarrarrrarrrarrrraarrarrrrrrruraaaaaaura lrarrraraaarraarraarr?raanarOo0?
(U,S. S 50,145.00 plus interest, to the t trier of Lends. Interest will be charged on unpaid
principd,0omthe dateofdisbununeotofdlokm proxWSbyLender,atthemeof NINEaarrrrrrrarrrrraaa**
rrarrnr:arrrraarurrrrara urrnaaraarr raaarrararrraaarrrarrraurrurrarrrrrraaaar
percent ( 9.000 %) per year undl the full amount of principal has been paid,
3. PROMISE TO PAY SECURED
Borrower's promiso to pay is secured by it mortgage, decd of oust or similar security Instrument dot It dated the sane
dab as this Nola and called the 'Security IrmrumenV Thai Security Instrument protects the Lender from bsses which
might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall male a Payment of principal and Interest to Lender on the rust day of each month beginning on
OCTOBER 1, 1995 .Anyprincipal and Interest temainingan the f4stof SEPTEMBER ,
2025 , will be duo on that data, which is called the maturity data
(d) Place
Paymcrusha0bomadcat BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD,
WORTHINGTON, ON 43085
(C) or at such other place as Lender may designme in writing by notice to Dorrower.
Amount
Each monthly payment of principal and interest will be In the amount of S 40].48
This amount
will be pmt of a larger monthly payment required by the Security Instrument. that shall be appliod in principal, Interest and
odor Items in the order described In that Security Instru ncnl
(D) Allonge to this note for payment adjustments
If an allenga providing for payment adjustments is executed by Borrower together with this Note, the covenants
of da WWII@ shall be incorporotal Into and shall amend and supplement the covenants of this Note as U that dlenge were
9 pan of this Nora (Check applicable box.)
Growing Equity Allonge Graduated Payment Allonge
Other (specify)
S.'DORROWER'S'RIGIITTO PREPAY'
Borrower her the right to pay the debt evidenced by this Note, in whole or in part, without chute or Penalty, on the
first day af.any.mundL %...
6. BORROWER'S FAILURE TO PAY - ° •• - -° - •°^•
(A) Lott Charge for Ovrrdue Payments
If Lender has not received the full monthly payment required by the Security Instrument as described 1w,
Paragraph 4(C) of this Note, by the end of sifter calendar days after the payment is due, Lender may collm a laic chugs
Inthoomountof FOUR"'t" rarrrarrraaraaaarrrarrraaararararrrerrarrrrrrrraaaaaarardrr
rararrre?areaaararaaaaaraaarrrraerarurneaaaeaararaarrrrraaarrraanraaa»raaraear
percent ( 4.00 'A) of that overdue amount of each paymcoL
NI
w,YleW Irrr IA,,
Illy e,elll 161031 eMN PeMONIeI k 0
(0111 all sal) \11,a 441-mmercEfy ll I. jb
r?,llilblfi A A (III b'L 9
W
(It) Default
If Borrower defaults by failing to pay In full any monthly payment, then Leader may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal halanco
remainin&.duc.andat acaued.interesLLenda.may.choow not.m eserctle thts.optors.whhoul waiving.As dgbu.sa dw-..
event of any tubsequent default In many circumstances regulations Issued by the Sceretay will limit Lender's rights to
require immediate payment In full in the caw of payment defaults. Tlhts Note does not auhhodu seeclandon when not
permitted by HUD regulations. As used In this Note,'Sc=wy* means the Secrdtary of Housing and Urban Development
or his or her designar.
(C) Payment or costs and Expenses
If Lmder.haf rcgabcd.lmmaluu paymcntinfu0,as.descsibcd.aiavc, Lcmict.may.roquire.Borrower. uspay costs.-
ad cgasnsnr including rent it stile and twtumary.atWmeys'.foes for curuming this Nute; Such'foa; and cusu•d Wi bear -•'
inlurst from the date of disbursement at the some rate as the principal of this Note.
7. WAIVERS -
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishmnor. "Presentment' meant the right to require Lends to demand payment of amounts due. 'Notice of dtsdgnor'
mean the right to require Lender to give notice to other persons that amounts due have not bowl paid.
S. GIVING OF NOTICES
Unless Applicable law requbet A different method, any notice that mutt be given to Borrowe under this Nom will be
given by deliveing It or by mailing it by rust clan mail to Borrower at dm property address above or at a different
address it Borrower has given Iarhder a notice of Borrower's diRuent address.
Any notkA that must be given m Lender undo ih6 Nom will ba given by fort class mailm Lander a ten address stated
In Paragraph I p,) or at a different address if Bonowa is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If mom tan one person signs this Nom, each person is fully and personally obligated to keep all of the promises made
In this Note, Including the promise to pay the full amount owed. Any person who Is a guarantor, surety or endor= of this
Note Is also obligated to do these things. Any person who takes over these obligations, Including the obligations of a
gumntm, surery or endorses of this Note, is also obligated to keep all of the promises made In this Notc. prude may
enforce Its rights under this Note against each pawn individually or against all signatories together. Any one peson
signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BPZ.OW and agrees to Ne tams and covenants contained in pages I and 2 of Uts
Nom.
1
(SEAL) / a!a ?ftct_C6 . &III(SEAL)
RET• I ON - BITTNER-• ua9rnv TAMMY EVET E BITTNER-•• a?,lou ••^-
(SEAL) (SEAL)
R."g, . Rene.ar. .
(SEAL) (SEAL)
awra?ur Bahwv
WITH= RIX=SE, PAY 10 THE ORIML Ors
DRUM D1 ?Aa70kcE OWN/',
Berl f / rlL?? .{iA„?
Martha namhart
Assistant Secretary
ITEW"ma 191011 p11909909Nr11 YM Ww1?1.1w Iww, MO¦
fr.jla.?7/9jurf r9aW W 1INa0-2383 CPU 110-111 fill
gCCTI 652440
Number:95095CAp
LEGAL
ALL THAT CERTAIN tract of land situate in the Township of Fairview county of
York and State of Pennsylvania, more particu ar y bounded and aescribed as
follows, to wit:
BEGINNING at a brad in the center line of Township Road T-955 at the western
line of lands now or late of Henry Bowmanj thence South 12 degrees 43 minutes
East 77 feet to a stake; thence South 77 degrees 17 minutes West by lands of
same 112 feet to a stakel thence North 12 degrees 40 minutes West by lands of
same 40 feet to a brad in the center line of said Township Road; thence North
59 degrees East by said center line 117.96 feet to a brad, the point and place
of BEGINNING.
HAVING thereon erected a one and half story frame dwelling with attached
masonry garage known and 215 Limekiln Road.
THE ABOVE described premises are conveyed subject to an Avigation Easement to
the Commonwealth of Pennsylvania set forth in Deed book 64-T, Page 152.
BEING THE SAME premises which Dennis A. Morian by deed dated November 1, 1990
and recorded in the Office of the Recorder of Deeds in and for York County,
Pennsylvania in Book 108-B, Page 590, granted and conveyed unto David Riddle and
Melissa Yale, now known as Melissa Riddle, Grantors herein.
I Certify This Document To Be .
Recorded In York County, Pa.
?.:,?•}R. RECgp •,•
[: yt <q
%
"• s?: • 01• hord.rdW.4
n
c
VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts contained in the foregoing COMPLAINT for Mortgage Foreclosure
are true and correct to the best of my knowledge, information, and
belief based upon information provided by Plaintiff, BROADVIEW
MORTGAGE COMPANY and that said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: October 11, 1999
Leon P. Haller, Esquire
Q81ite E R't mr g 3gF?+g?
GIiN
Pct I. q. ae FM, '9$
MIN,)
Yt.'/QillA
±F
}
f ?5
'z
BROADVIEW MORTGAGE COMPANY
Plaintiff
Vs.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
THIS LAW FIRM IS A DEBT
TO COLLECT A DEBT OWED
OBTAINED FROM YOU WILL
COLLECTING THE DEBT.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. C,a T'^
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COLLECTOR AND WE ARE ATTEMPTING
TO OUR CLIENT. ANY INFORMATION
BE USED FOR THE PURPOSE OF
N 0 T I C E
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 no the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or 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 TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S O
LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO DUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALOUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, BE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DE14MDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
B Irvine Row, Carlisle, PA 17013
717-243-9400
TWE COPY Fri^°., rux.,ORD
hi Toslimr?(y tihrrcl, ! )Kr:, tints s!t my B.?t?f
Ind ley. tl OdS.11i U:iil Jl Pa.
r- 'of
y 61.AGa r 19.49
AC n
Prothonotary
BROADVIEW MORTGAGE COMPANY
Plaintiff
VS.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 51601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BROADVIEW MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Va.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
NO. J)9. 6..2 73 -r-
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
1. Plaintiff, BROADVIEW MORTGAGE COMPANY, is a corporation,
with an address of 95 EAST WILSON BRIDGE ROAD. WORTHINGTON, OHIO
43085.
2. Defendant, BRET HARRISON BITTNER, is an adult individual
whose last known address is 215 LIMEKILN ROAD, NEW CUMBERLAND,
PENNSYLVANIA 17070. Defendant, TAMMY EVETTE BITTNER, is air adult
individual whose last known address is 215 LIMEKILN ROAD, NEW
CUMBERLAND, PENNSYLVANIA 17070.
3. On or about August 10, 1995, the said Defendants
executed and delivered a Mortgage Note in the sum of $50,145.00
payable to BROADVIEW MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to Original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds office of the within county and
commonwealth in Mortgage Book 1157, Page 0294 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 215 LIMEKLIN ROAD,
NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on January 1,
1999 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 48,909.64
(b) Interest at $19.82 per day
from 12/1/98 to 11/1/99
(based on contract rate of 9.000%) 6,639.70
(c) Accumulated Late Charges 367.35
(d) Late charges at $20.08
per month for 11 months 220.88
(e) Escrow Credit 0.00
(f) 5k Attorney's Commission 2,445.48
$ 58,583.05
*Together with interest at the per diem rate noted in (b) above
after November 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of Intention to Foreclose and accelerate the
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 9.000% ($19.82 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL.,41WG &AiALLER
By p Cs
Leon P. Haller
Attorney for P aintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
FICA CASH NO.
I 3S. FR-44 -SO _17
SPATROF PENNSYLVANIA
FHA MULTI-STATE NOTE
AUGUST 10 ,1995
215 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070
(?mpedy Add,su)
1. PARTIES
'Borrower' means each person signing a the end of this Nom, and the person's summers and assiteL 'Leader-
mean BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, ON 43085
and Its Successor and assign.
2. BORROWER'S PROMISETO PAYI INTEREST
In return for a loots received Oran )ender, Borrower promises to pay he principal sum or
HUNDRED FORTY-FIVE AND NO/100•••+•••+•••++•••*•+•••+++•+•+•••+
(U.S. S 50,145.00 ), plus imerer4 to the t rder of (.ender. Interest will be charged on unpaid
principal, From "doe otdisbutsemat ortholoan pratecdsbyLender, attherueor NINEara?aaa••aaa?aaa?•ra
•••ar•aaa•aar••raaaraa•aa?aara•••a•naaaa•a••aaaaaaaaaa•raa•araaauara•aaanaa?•aa
Percent ( 9.000 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is serval by o mongage, dad of trust or similar security Instrument that is dated the same
dam as this Nom and called the -Security InstrumenL- Tint Security Interment protau the lender from losses which
might result IF Bono= defaults under this Now.
4. MANNER OR PAYMENT
(A) Time
Borrower shall matte a payment of principal end Interest to Lender on the rust day of each month beginning on
OCTOBER 1, 1995 .Any principal and interest remaining on the rimof SEPTEMBER ,
2025 , will be due on that dole, which is tolled the maturity date.
(B) Place
Paymenishallbemdem BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD,
WORTHINGTON, ON 43085
or m such other place as Lender may designate In writing by notku to Borrower.
(C) Amount
Each monthly payment of principal and interest will be In the amount of S 403.48 .
This Manuel
will be pan or a larger monthly payment mquhed by the Security Instrument, that shall be applied to principal, interest and
other Items In the order described in the Security Instrument.
(D) Allonge to Ihb note fur payment adjustments
If an allcnge providing for payment adjustments Is eseculul by Borrower together with this Nom, the covenants
of the allonge shall be Incorporated Into gad shall w=d and supplement the covenants of this Nom at if the allonge were
a pan of this Nom. (Check applicable boa.)
FjOrowing Equity AUange Graduated Payment AUtnge
n Other (specify)
S. TIORROIVER'S RIGHT TO PREPAY'
Borrower has the right to pay the debt evhknced by this Note, in whole or In part without charge or penalty, on tse
first day orany.month.:.._.
6. BORROWER'S FAILURE TO PAY ` '• - "•• - •°-°-
(A) Lair Charge far Overdue Payments
If Lender has not received the full monthly payment required by the Security Inset men4 as described in-
Paragraph 4(C) of this Note, by the end or fifteen calendar days arter the payment Is due, Lander may collect a Late charge
Intheamountof FOURa•••a•aaan••aa••aarra••aaa•a••a••a•aaararaaaaaaaraaaaaa•aa••ra•a
a••aaua••a•aa•araaar•••••aa••a•aa•aaaa•a•a?•a•aa••aa•••a•aa•a••arraa•••a•rar•a•a•
Percent ( 4.00 %) of the overdue amount of each paymenL
wet
nla"nil nlen o.,Idee00000111 4W Y4/rwwI.e.W IS
(polo 10frplo,) r.GrOutI Mnc?fyIfi 244b
(0) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case or payment defaults, require Immediate payment in full of the principal balance
remalning,.duc.andAll acrued.bacraL. Lender-may.ehooaa not so uuetm.thh.optlon.widmuL.walvinglu djbu.in the_
event of any tubttquent default. In many cbeumstanw regulations issued by the Serrelary will limit Leader's rights to
require immediate payment in full in the case of payment defaults. Mils Note does not authorize Acakration when not
permitted by HUD regulations. As used in this Note,'Soeretary' means die Secretary of Housing and Urban Development
or his or her designer. •
(C) Payment of Costs and Expense
If Lender.has requited. ImmediatepaymenUrtluB,mAextibcd.above, Luidv.may.rrqulreBorrower. to.pay costs
_._
and cgicaser including reasonable, amt custuma y'suumeys'.fss for'enforcing,0ts Nuta•Such'fm and wstrdu ! bar -••.
Inlereat from the date of disbursement it the same rate ss the principal of this Note.
7. WAIVERS -
Borrower and any Ada Person who has obligations under this Note waive the rights of presentment and notko of
dishonor. 'Pn=tmmF' means the right to require Lender to demand payment of Amounts duc.'Notke of dishonor'
means the right to require Lender to give notice to other persons that Amounts due have not been paid.
1, GIVING OF NOTICES
Unkts Applicable law requires a different method, any notion that must be given to Borrower under this Now will be
given by delivering it or by malling It by first clan mail to Dorrowcr at the property address above in at a different
address if Borrower has given Lender a notk of Borrower's dlrree t Address.
Any notice that must be given to Lander under this Note will be given by lust class mall to lender at the address Mated
In Paragraph 4(13) or at a different address If Borrower is given a notice of that different addrm.
P. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more that one person signs this Note, each person h fully and personally obligated to keep all of the promises nude
In this Note, Including rte promise to pay the full amount owed. Any pawn who Is a guarantor, surety or endorser of this
Note is aim obligated to do these things. Any person who lakes over these obligations, Including the obligations of ¦
guarantor. surety or endoser of this Note. Is also obligated to keep all of the promises mado in this Notes Lender may
enforce Its rights under this Note against each person iodlvidually or against all signatories together. Any am person
signing this Note may be required to pay all of the amounts owed under this Nola.
BY SIGNING BELOW LiLand agrees to die terms and covenants contained in pages 1 and Z of aids
Notes
(Span.) ? I[<..n??.?C ?.vr.?(SEAL)
RET- I ON•BITTNER••- aw?A TAMMY EVETYE BITTNER-•- ea.at--•
(SEAL) (SEAL)
n,vrewtr . ltwva a. . .
0«EAL) eMAI
NtTINVP RMOME, PAY 70 711E OADFR oFs
BROAMEN i1Yt1= Cwii /'?
Martha Barnhart
Assistant Secretary
a.... rose, as
119M asna nun a..nraw ¦
a.uanrooaru Wee arya pro) sew wharr»atn ore ntfill .tw
!)_CCTI 652440
Numbert95095CAP
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of Fairview, County of
York and State of Pennsylvania, more part icu ar y oun a and--Uicribed as
follows, to wit:
BEGINNING at a brad in the center line of Township Road T-955 at the western
line of lands now or late of Henry Bowmanj thence South 12 degrees 43 minutes
East 77 feet to a stake; thence South 77 degrees 17 minutes West by lands of
same 112 feet to a stake; thence North 12 degrees 40 minutes West by lands of
same 40 feet to a brad in the center line of said Township Road; thence North
59 degrees East by said center line 117.96 feet to a brad, the point and place
of BEGINNING.
HAVING thereon erected a one and half story frame dwelling with attached
masonry garage known and n,?.w°••9. ,? 215 Limekiln Road.
THE ABOVE described premises are conveyed subject to an Avigation Easement to
the Commonwealth of Pennsylvania set forth in Deed book 64-T, Page 152.
BEING THE SAME premises which Dennis A. Morian by deed dated November 1, 1990
and recorded in the Office of the Recorder of Deede in and for York County,
Pennsylvania in Book 10B-B, Page 590, granted and conveyed unto David Riddle and
Melissa /ale, now known as Melissa Riddle, Grantors herein.
I Cortify This Document 4b Be
Recorded In York County, Pa.
4is all
??1 ?
X14,11
C,
VERIFICATION
i, Leon P. Haller, Esquire, hereby swear and affirm that the
facts contained in the foregoing COMPLAINT for Mortgage Foreclosure
are true and correct to the best of my knowledge, information, and
belief based upon information provided by Plaintiff, BROADVIEW
MORTGAGE COMPANY and that said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: October 11, 1999
Leon P. Haller, Esquire
;f antiFBc
a?u?l X99,
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t?Ett';t?
OEM
BROADVIEW MORTGAGE COMPANY
Plaintiff
VS.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. c/ q- G J I3 ?cvc:l T.
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
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.
N O T I C E
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 claimed in the complaint or 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 TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S 0
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO 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 PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
;nTc::?n:r.r??,?'??:':f-1 ?I,i',t•U?'t7e.??r.`ltw?nd
a•,f. Vin,) $ul n' S_i? :?.NItt, d( i.J',:1ti. I'd.
Prothonotary
BROADVIEW MORTGAGE COMPANY- : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER CIVIL ACTION - LAW -
Defendants IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
1
BROADVIEW MORTGAGE COMPANY
Plaintiff
VS.
BRET HARRISON BITTNER AND
TAMMY EVETTE BITTNER
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- L 173 (c: U 7f
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, BROADVIEW MORTGAGE COMPANY, is a corporation,
with an address of 95 EAST WILSON BRIDGE ROAD. WORTHINGTON, OHIO
43085.
2. Defendant, BRET HARRISON BITTNER, is an adult individual
whose last known address is 215 LIMEKILN ROAD, NEW CUMBERLAND,
PENNSYLVANIA 17070. Defendant, TAMMY EVETTE BITTNER, is an adult
individual whose last known address is 215 LIMEKILN ROAD, NEW
CUMBERLAND, PENNSYLVANIA 17070.
3. On or about August 10, 1995, the said Defendants
executed and delivered a Mortgage Note in the sum of $50,145.00
payable to BROADVIEW MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to Original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds office of the within County and
Commonwealth in Mortgage Book 1157, Page 0294 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 215 LIMEKLIN ROAD,
NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgago rs have failed to pay the in stallment due on January 1,
1999 and all subsequent installments thereon, and th e following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 48,909.64
(b) Interest at $19.82 per day
from 12/1/98 to 11/1/99
(based on contract rate of 9.000%) 6,639.70
(c) Accumulated Late Charges 367.35
(d) Late charges at $20.08
per month for 11 months 220.88
(e) Escrow Credit 0.00
(f) 5% Attorney's Commission 2,445.48
$ 58,583.05
*Together with interest at the per diem rate noted in (b) above
after November 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees uet forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
B. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of Intention to Foreclose and accelerate the
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 9.000k ($19.82 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL-AMUG &,HALLER
By lop, . C?
Leon P. Haller
Attorney for P aintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
.
FHA CASg N0.
STATE OP PENNSYLVANIA
FHA MULTI-STATE NOTE
AUGUST 10 ,1995
215 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070
alw•nynuNlq
1. PARTIES
'Bonowee means each person signing m the end of this Nou, and the person's successors and asalgm. 'fader'
mom BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 47085
and Its successors and sedges.
t BORROWER'S PROMISE TO PAY[ INTEREST
In mean for a loon received from Lender. Borrower promises to pay he principal sum of FIFTY THOUSAND ONE
HUNDRED FORTY-FIVE AND NO/100+++++++++++++++++++++++++nrrraurrrr+rrrrrrrrrrarrr
rrr•ararnararrraaranarrrrarrraaarrrrruarr?ara lrrrrrrrauraaarrrrrrrranrrrpo?
N.S. S 50,145.00 ), plus interest, u the a rder of Lender. Interest will be charged on unpaid
print from the date of d•Hbunement or to ban proceeds by Lender. at the rate or NINE++rrrrrrrrar?rrrar**
perant ( 9.000 %) per year undl the full arneant of principal has been paid.
S. PROMISE TO PAY SECURED
Borrower's promise re pay Is aeeuret by a mortgage, dad of trust or similar senHity Wtrument that is dared to ume
dare u this Nob and calla! the'Security Im:mment.- Tint Security Instrument protects the Lender from boa which
might result U Borrower defaults under Nis Noss.
4. MANNER O? PAYMENT
(A) Time
Borrower :hail make a payment of principal and Interest m Lender on the Rust day of each month beginning on
OCTOBER 1, 1995 .AnyprincipalandInterestremainingonthefunof SEPTEMBER
2025 , will be due on that data, which is called the maturity data
(0) Place
Payment shall be madeat BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD,
WORTHINGTON, OH 4]085
or at such otter place o Lender may designs in writing by notice re Borrower.
(Cy Amount
Poch monthly payment of principal and interest will be in the amount of S 407.48
This amount
wW be port of a Larger monthly payment required by the Security Instmmen4 tut shall be applied to principal interest red
other items in the order described In the Security Imuumenl
(D) Allonge to Ibis note fur payment adjustments
If an albnge providing for payment adjusunenu Is executed by Borrower toget er with this Note, the covenants
of the Merge shall be Incorporated into and shall amend and supplement to covenants of this Noss as U the allonge were
a post of this Now. (Check applicable box.)
n Crowing Equity Ailonge Oraduared Payment Allonge
11 Other [specify]
S.70ORROWER'S RIGHT TO PREPAY'
Borrower hm tho right m lay the debt evidenced by this Note, In whole or in pan, without charge or penalty, on the
Gras day orany.mandh.:.._
•4.BORROWER'SFAILURETOPAY °••- .°°••-
(A) Late Charge for Overdue Payments
If Lender has not received the pull monthly payment required by the*Security Instrument. as described'Irr
paragraph 4(C] of this Note, by the end or rtfuen calendar days after the payment is due, ]auks may collect a late charge
Intheamountor FOUR+rrrraaauaaaraa•rrrraraaaraaaraaaaaaaraaa?aaaaraarraaarrrararraa
ararraa:uaarraaraa•aaraaarr•rrrraaaaaaaarrar•aaaaraceaarrarrarrrrrrrrraarrraaaaarr
percent( 4.00 %)ortheoverdueomountoreachpaymenL
wl
YWt,MIw F?Ift¦
IIIa M,r,l 1x1111 DNN /Ialewlq Irs1l•fI Mps) I, m+ae IJFOFOar I IM1$111
ti4ii]bIf %A ` ACgTI 6?2?4b
(B) Dcrault
11 Borrower defaults by failing to pay in full any monthly payment, Wen Lender may, except as limited by
regulations of the secretary in the ease of payment defaults, require immediate payment in full of the principal balanoo
remalning.duo.anlLall accrucd.1ntesesl.Lendermay.choose not is exercise this. optioa.wlthout waiving.ltr sigbts.sa do...
event of Any subsequent default. In many circumstances rcgulations Issued by the Secretary will Wnlt Lender's rights to
require immediate payment in full In the cam of payment defaults. This Note does not authorize acceleration when not
pcm ucd by HUD regulations. As used In this New. *Secretory' means the Secretory of (lousing and Urban Development
or his or het design=
(C) Payment of Costs and Expense&
If Lender.has tequlttd.Immediate payment. In full, asdc=ibcd above, Lender.may.require Borrowa.lo.pay costs
And cspatser Including reasonable and customary auumeys' fees for cnfoming this Nutt,Such•fcs and watsthall bear
interest from We date ord6bur cmem at the same rate as the principal of this Note,
7. WAIVERS
Borrower zeal any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor.'Presomment' means the right to require lender to demand payment or amounts dua'Notice of dishonor'
means die right to require Lender to give notice to other persons that amounts due have not boon paid.
a. GIVING OPNOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Nom will be
given by delivering it or by mailing It by rbst class mail to Borrower at die pmpcny address dove a at a different
address if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Nom will be given by rust class mail to Lender at the address slated
in Paragraph 4(B) or At a different address if Borrower Is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If mom alum one pawn signs ibis Note, each person Is fully and personally obligated to keep all of the promises made
In this Now, including the promise to pay the fail amount owed. Any person who It a guarantor, surety or endow of this
Nom 4 also obligated to do thew thints. Any person who takes ova thew obligations, including the obligations of a
guarantor, runty or endorser or this Nom, is also obligated to keep all or the promises made In this Notes Lender may
enforce Its rights under this Nom against each person Individually or slalnat all signatories together. Any one person
signing this Nom may be required to pay all of the amounts owed under this Nom.
BY SIGNING BELOW wand agrees m the tams and covenants contained In pages 1 aad 2 of this
Note.
4 LO(SEAL) 1
RET- 1 ON •BITTNER••- a {r TANNY EVET E BITTNER••- 11L ......
ftvk N,vmwar, . ll n
(SEA)
WITH= REM M, PAY 70 7RE OR= OPI
BROADVIL1s M?RTIIAOg CdSP? ! /J/"?l
syl
Martha Barnhart
Atnislani Secretary
I.la ll{a a...Y Ina4 ¦
I11Y{11I11111a11 p,11 //{I{MlQ f1.1(1}ef}p}tl) heeded NI{na/1n OIIa 11atl41Y1
4CCTf 652440
Numbert95095CAP
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of Fairview, County of
York and State of Pennsylvania, more particu ar y oun a and--described as
follows, to Mitt
BEGINNING at a brad in the center line of Township Road T-955 at the western
line of lands now or late of Henry Bowmanj thence South 12 degrees 43 minutes
East 77 feet to a etakej thence South 77 degrees 17 minutes Went by lands of
same 112 feet to a etakej thence North 12 degrees 40 minutes West by lands of
name 40 feet to a brad in the center line of said Township Roadl thence North
59 degrees East by said center line 117.96 feet to a brad, the point and place
of BEGINNING.
HAVING thereon erected a one and half story frame dwelling with attached
masonry garage known and 215 Limekiln Road.
THE ABOVE described premises are conveyed subject to an Avigation Easement to
the Commonwealth of Pennsylvania not forth in Deed book 64-T, Page 152.
BEING THE SAME premises which Dennis A. Morian by deed dated November 1, 1990
and recorded in the Office of the Recorder of Deeds in and for York County,
Pennsylvania in Book 100-8, Page 590, granted and conveyed unto David Riddle and
Melissa Yale, now known as Melissa Riddle, Grantors herein.
I Cortify This Document To Be
Recorded In York County, Pa.
QD ^•
•''4 ?"IkU•U4?"??P?' Rw.4.rdD..4
CXwol t?ls
! r
VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts contained in the foregoing COMPLAINT for Mortgage Foreclosure
are true and correct to the best of my knowledge, information, and
belief based upon information provided by Plaintiff, BROADVIEW
MORTGAGE COMPANY and that said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: October 11, 1999
Leon P. Haller, Esquire
.