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Re: 11-62926--Michael and Dana Seros/19853 Shorecrest Drive, Clinton, MI



Well, my clients would like an opportunity to cure.  We stated in the petition that my clients would "retain and pay" regarding the mortgage.  So unless your objective is to cause your client (and mine) to incur unnecessary legal expenses (as well to cause the Bankruptcy Court to expend resources/time unnecessarily), I would suggest that my clients are are afforded reasonable opportunity to cure.
 
Please construe this email as my client's formal request to cure and to avoid unnecessary legal expenses.
 
Please let me know your client's response.
 
Cordially,
 
Nick

On Tue, Sep 6, 2011 at 2:48 PM, Marla Skeltis <mskeltis@rsmalaw.com> wrote:

Good Afternoon:

 

Yes, but your clients are due and owing from June 1, 2011 to the present so we are proceeding with the motion.

 

Thank you.

 

Marla A. Skeltis

Attorney at Law

Randall S. Miller & Associates, PC

43252 Woodward Ave, Ste 180
Bloomfield Hills, MI 48302
Phone: (248) 335-9200
Fax: (248) 335-1335

mskeltis@millerlaw.biz

 

 

*Please note that, effective September 6, 2011, our domain name will change from @millerlaw.biz to @rsmalaw.com and all future correspondence should be forwarded to mskeltis@rsmalaw.com.  Thank you!

 

 

 

 

 

From: Nick Hadous [mailto:nhadous@hadousco.com]
Sent: Tuesday, September 06, 2011 2:46 PM
To: Marla Skeltis
Subject: Re: 11-62926--Michael and Dana Seros/19853 Shorecrest Drive, Clinton, MI

 

I think their intention is to retain the home pursuant to the contract. 

On Tue, Sep 6, 2011 at 10:56 AM, Marla Skeltis <mskeltis@rsmalaw.com> wrote:

Pursuant to LBR 9014-1(g), I am seeking concurrence for my Motion for Relief as to the mortgage secured by the property located at 19853 Shorecrest Drive, Clinton, MI.  Your concurrence is sought by the end of business on August 9, 2011.  If I have not received a response from you by that time, I will assume that concurrence has been denied and will proceed with filing my motion.  If concurrence is granted, I will forward a stipulation and proposed order for your signature.  Please feel free to contact me with any questions.

 

Thank you for your attention to this matter

 

 

Marla A. Skeltis

Attorney at Law

Randall S. Miller & Associates, PC

43252 Woodward Ave, Ste 180
Bloomfield Hills, MI 48302
Phone: (248) 335-9200
Fax: (248) 335-1335

mskeltis@millerlaw.biz

 

 

*Please note that, effective September 6, 2011, our domain name will change from @millerlaw.biz to @rsmalaw.com and all future correspondence should be forwarded to mskeltis@rsmalaw.com.  Thank you!

 

 

 

 

 




--

____________________________________
H
ADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ

 

Nick N. Hadous

Admitted:

-  State Bar of Arizona

-  State Bar of California

-  United States District Court,

    District of Arizona

     Eastern District of Michigan

____________________________________

 

Direct:    313.415.5559
Office:    313.450.4670
Fax:        313.846.6358
Email:    nhadous@hadousco.com
              www.hadousco.com

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that, to the extent that this communication or any attachment addresses a tax matter, it was not written to be (and may not be) relied upon to (i) avoid tax-related penalties under the Internal Revenue Code; or (ii) promote, market or recommend to another party any transaction or matter addressed herein or in any such attachment.

CONFIDENTIALITY NOTICE: This email message and all attachments transmitted with it are intended solely for the use of the addressees and may contain legally privileged, protected or confidential information. If you have received this message in error, please notify the sender immediately by email reply and please delete this message from your computer and destroy any copies.

 

 




--
____________________________________
HADOUSCO. |PLLC
Offices in Dearborn, MI and Scottsdale, AZ

Nick N. Hadous
Admitted:
-  State Bar of Arizona
-  State Bar of California
-  United States District Court,
    District of Arizona
     Eastern District of Michigan
____________________________________

Direct:    313.415.5559
Office:    313.450.4670
Fax:        313.846.6358
Email:    nhadous@hadousco.com
              
www.hadousco.com

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that, to the extent that this communication or any attachment addresses a tax matter, it was not written to be (and may not be) relied upon to (i) avoid tax-related penalties under the Internal Revenue Code; or (ii) promote, market or recommend to another party any transaction or matter addressed herein or in any such attachment.

CONFIDENTIALITY NOTICE: This email message and all attachments transmitted with it are intended solely for the use of the addressees and may contain legally privileged, protected or confidential information. If you have received this message in error, please notify the sender immediately by email reply and please delete this message from your computer and destroy any copies.