Free Letter - District Court of Delaware - Delaware

Case 1 :08-cv-00242-JJF Document 3 Filed O4/28/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RBS CITIZENS, N.A., successor by merger )
to Citizens Bank, )
1
Plaintiff} )
I saii
v. ) Civil Action No. ° if · ‘'(‘# ei
)
CALDERA MANAGEMENT INC., a )
Delaware corporation; MARK G. )
McGREEV Y; DANIEL B. McGREEVY ) ,.._,
and MARGARET M. McGREEVY, ) §
> te
Defendants. ) $·?%?’*
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as
ar
NOTICE LETTER OF ENTRY OF JUDGMENT if
m
TO: Caldera Management Inc. Mark G. McGreevy F ‘’’``` T
37041 Rehoboth Avenue Extension 4260 Highway One
Unit 6 Suite 6
Rehoboth Beach, DE 19971-7145 Rehoboth Beach, DE 19971
Daniel B. McGreevy Margaret M. McGreevy
251 Crum Creek Road 251 Crum Creek Road
Media, PA 19063 Media, PA 19063
1. RBS Citizens, N.A., successor by merger to Citizens Bank ("Plaintit`f"),
intends to obtain a court judgment against Caldera Management Inc., Mark G. McGreevy, Daniel
B. McGreevy, Margaret M. McGreevy, jointly and severally (jointly and severally, the
"Debtors") in the U.S. District Court for the District of Delaware based on the enclosed
documents for the aggregate amount of:
Principal $12,682,8%.35
Accrued Interest as of 4/ l5f08 S 359,217.41
Late Fees S 285,000.00
Forbearance Fees S 69,500.00
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§:wL,—` Case 1:08-cv-00242-JJF Document 3 Filed O4/28/2008 Page 2 of 3
Attorneys’ Fees & Costs S 2,608,421.15l
together with floating gr dg:_n; interest in the amount of $3,559.02.2
2. Plaintiff alleges that the Debtors have waived their rights to notice and
hearing prior to the entry of judgment.
3. The entry of such a judgment will result in a lien against all of Debtors’
real estate and the means, in default payment, whereby the Marshall can levy against and
ultimately sell at public auction Debtors’ personal property and real estate for credit against the
debt.
4. In default of payment in appropriate cases, the Marshall may seize some
portion of Debtors’ wages for credit against the debt.
5. Debtors may file with the Court, Clerk of the Court, U.S. District Court
for the District of Delaware, J. Caleb Boggs Federal Building, 844 N. King Street, Loekbox 18,
Wilmington, Delaware, 19801, an objection to the entry of judgment by a date two (2) weeks
following the date on which the notice letter for the entry of judgment was mailed. When the
objection is filed, a hearing will be scheduled by the Court. At the hearing, the Plaintiff will be
required to prove that Debtors have effectively waived any rights to notice and a hearing prior to
the entry of j udgment.
6. No objection is required but, if no objection is made, judgment will be
entered by default.
collect those a*aorneys’ Ezes and costs incurred from time to time.
2 Loan tt: 080-001-2787911-0101 3},789.21
Loan 080-001-2536250-0101 S 893.14
Loan tt: 080-001-2605812-0lOl S 876.67
-2-
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7. If you have any questions about these matters, you shouid consult a lawyer
immediately.
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