Opinion
Case No. 07-14389-WIL, First Notice of Default Doc No. 31.
November 25, 2008
SEEN AND AGREED: Gene Jung, Esq., MD Fed. Bar No. 14950, Kensington, Maryland, Counsel for Movant.
Sari Karson Kurland, Esquire, The Law Offices of Sari K. Kurland, LLC, Rockville, Maryland, Counsel for Debtor.
JOINT STIPULATION AND CONSENT AGREEMENT EXTENDING TIME TO CURE FIRST NOTICE OF DEFAULT
Citibank, N.A. c/o Wilshire Credit Corp. (hereinafter "Movant") and Juanita Ransom-Ashmon (hereinafter "Debtor") have reached a joint stipulation and consent agreement with regard to the First Notice of Default (Doc. No. 31) and Debtor's Objection (Doc. No. 32) thereto, and respectfully represent as follows:
On or about November 7, 2007 (Doc. No. 29) the parties entered into an agreement evidenced by a Consent Order Modifying the Automatic Stay providing for the cure of post-petition mortgage arrearage payments due with regard to the property located at
1806 Taylor Avenue, Fort Washington, Maryland 20744 (hereinafter the "Property").
Debtor defaulted on several payments, and consequently Movant filed the First Notice of Default and Notice of Termination of Automatic Stay (Doc. No. 31) on August 4, 2008.
COMES NOW, the Debtor and Movant having reached an agreement whereby Debtor has been provided an extension of time to cure the First Notice of Default, and the parties stipulate and consent to the following:
1. That the arrearage figure of $3,729.20, indicated in the First Notice of Default is true and accurate, and that there is no dispute; and,
2. That whereas the terms of the Consent Order Modifying Automatic Stay requires that any delinquency be cured within ten (10) days of the date of the First Notice of Default, the Movant agrees to extending the deadline; and,
3. That the parties agree to enter into an Amended Consent Order Modifying Automatic Stay, and that the parties intend to conduct themselves henceforth pursuant to the terms contained therein.
SO ORDERED.
Notice Recipients
Recipients of Notice of Electronic Filing: Recipients submitted to the BNC (Bankruptcy Noticing Center):
District/Off: 0416-0 User: mburkhart Date Created: 11/25/2008 Case: 07-14389 Form ID: pdfparty Total: 5 tr Nancy L Spencer Grigsby Grigsbyecf@ch13md.com aty Gene Jung gene.jung@junglawgroup-llc.com aty Sari Karson Kurland skurland2@comcast.net TOTAL: 3 db Juanita Ann Ransom-Ashmon 1806 Taylor Avenue Ft. Washington, MD 20744-2917 cr Citibank, N.A. c/o Wilshire Credit Corp. The Jung Law Group, LLC P.O. Box 2374 Kensington, MD 20891 TOTAL: 2