Craig R. Brewster and Angela K. Brewster

»' \
FROM : - FflX NO. :6108960347 Oct. 23 2007 11:24AM P2
10/R1/2007 22:39 FAX 7 . 1002/004
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
I n"re: Craig R. firewater And Angela K.
Brewsier,
Debtors.
CHAPTER 13
BANKRUPTCY CASE NUMBER
07-12329/3KF
Everfaom* Mortgage,
Mpvaat;
v.
Craig R, Brewster And Angela K.
Debtors,
and
William C, Miller, Trustee,
Additional Respondent.
STIPULATION AND ftfeft&Et
AND NOW, in <x>nadeiation of 1hc mutual proi^»s and agreement m forth below^ tnd
other good and valuable corutiderotion, 1he wcsipt and sufficiency of Whiet is hereby
1, it is hereby stipulated and agreed to by and between the undersigned as follow j;
1. This Stipulation Shall govern all post-petition payments due and owing to Movint,
(those that fell due after the arreare,fta set fonh below,]
2. The post-petition fmrearttges oa the mortgage held by Mown* on Debtors'
property at 44 Chwry Street, Willow Grova. PA 10090, aw 87,1 39,70 tfwough October 31, 2C 07,
m«luding late charges and attonwy fees of $650.00 and costs of $150.00.
3 . Debtors shall cure the arrearages in the following manner:
(«,) A lump sum payment of $2,048.48 shall be made on or before October 31, 20C 7;
(b) The balance of the arrears, to-wit, S5,l 10.82» shall be cut<4 by the payment b)
Debtors of th« sum of $851.80 conuneneisg November 1, 2007, and cotttinuing fax € consecuave
months through and including April 1, 2008, until the afrears are cured, togetiher with the regi .lar
o<r * i .IVM ^. ™- an MtYtA m*y hft »4i jjsted from time to time in
I\0
Case 07-12329-jkf Doc 68 Filed 10/29/07 Entered 10/31/07 14:22:58 Desc Main
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FRDM : iir " . FfiX NO. : 6108960347 Oct. 23 2007 11:2SH1 P3
IO/tl/2007 22.40 FAX 7 ' ' 8003/004
accordance wiih Paragraph («) hareof, for the totai monthly payment amount of 51,876.24,
payable on the due date of Debtors' mortgage;
(o) If funds are not received prior to the 15ih of the month, then the payment shall
include all applicable late charges,
(d) All payments to Movant tut to be in CERTIFIED FUNDS, MONEY ORDER, or
BANK. CASHIER'S CHECK -with the Loan No, 9000225952 wriagn on the ftcft thereof, and
shall be made directly to Attention: BANKRUPTCY DEPARIfc^NT, EverHoroe Mortgage* at
8100 Nations Way, Jacksonville, Florida 32236,
(e) Debtors are responsible TO pay the mentally payment as thai amount may be
adjusted from time to time by Movant in accordanec'wfth standard escrow practices;
(f) AU payments mode pursuant to this Stipulation and 6rd*r shall b« applied firsi to
reimburse Movant for its attorneys' fees snd costs (as provided for above) in connection with liis
motion. All fbrther payments will be Applied to the arrears and/or monthly payments in the
manner piescribsd by the Mortgage and Note.
4. Tn the event thut Debtors fail to make Any of the payments set forth above,
Movani shall notify Dsbiois and Debtors' attorney of the default in writing and Debtors may > we .
the default wttbin 15 days of the notice, tf Debtors steroid fail to cure the defaul; within 15 diys.
Movant may file a Gratification of Ewfiwiit with the Court, and upon the filing of fee
Ccmfioation, Debtors consent to the Court entering an Order granting Movant relief from the
Automatic Stay.
5. Debtors Dadetstand that should Movant be forced to provide a written Notice i >f
Default of this Stipulation, that Debtors shall be responsible for any reasonable attorney fees
incurred by Movant as a result of preparation of same.
Case 07-12329-jkf Doc 68 Filed 10/29/07 Entered 10/31/07 14:22:58 Desc Main
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FROM :
10/2V200T 22:40 FAX FOX NO. :S10896034?
7 Oct. 23 2007 11:26AM P4
@ 1)04/00 4
6, Debtors agree that the Court waive Rute 4001 (a)(3), pwnitting Movan' to
immediately implement and enforce the Court's order.
Dated: Danielle Boyie-Ebatsole, Esquire
Attorney for M
Dated: Richard F,
Attorney foiDebtorss
AND NOW, this
ORDERED that tbc foregoing Si . it is hereby
f lit
;ON
Y JUDGE
Case 07-12329-jkf Doc 68 Filed 10/29/07 Entered 10/31/07 14:22:58 Desc Main
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