Opinion
ADVERSARY NO.: 07-00232.
March 17, 2008
Kimberly D. Marshall, Waldorf, Maryland Attorney for Defendant.
Shannon B. Kreshtool, Baltimore, Maryland, Attorney for Plaintiff.
STIPULATION OF SETTLEMENT
NAPUS Federal Credit Union, by its attorneys Shannon B. Kreshtool, Lindsay C. Cooper and Weinstock, Friedman Friedman, P.A., and Shirley Mae Graham, by Kimberly Marshall, her attorney, hereby stipulate and agree as follows:
1. Trial in this matter shall be generally continued upon the following terms and conditions:
2. Defendant/Debtor agrees to pay attorneys for Plaintiffs the sum of $2,481.48, plus pre-judgment interest in the amount of $22.55, plus contract attorney's fees in the amount of $372.22, plus court costs; payable at a rate of $75.00 per month, beginning September 15, 2007, and due on the 15th of each consecutive month thereafter until paid in full. Payments shall be mailed or delivered to Plaintiff directly.
3. Upon completion of Defendant's timely payments as set out in Paragraph 2 above, counsel for Plaintiff shall enter a dismissal with prejudice in this matter.
4. If Defendant shall default with respect to time or amount of any payment set out in Paragraph 2 above, counsel for Plaintiff shall, and is hereby authorized by Defendant to enter judgment by consent in favor of Plaintiff and against the Defendant in the amounts set out in Paragraph 2 above, and deducting all payments previously made by Defendant pursuant to this Stipulation.
5. The parties further stipulate that in the event counsel for Plaintiff requests judgment by consent under Paragraph 4 above, Defendant's only possible defense will be that timely payment was in fact made to counsel for Plaintiff under the terms of Paragraph 2 above.
AGREED AND CONSENTED:
WEINSTOCK, FRIEDMAN FRIEDMAN, P.A.