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UNITED STATES DISTRICT COURT i
DISTRICT OF NEW JERSEY
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• In Proceedings for an Arrange-
ment Under Chapter XI of the
In the Matter of ) Bankruptcy Act
No. B-76-2704
GEORGE A. COSTA, et al., )
APPLICATION TO APPROVE AND s
Debtors. ) PERMIT DEBTORS TO ENTER INTO
FOREBEARANCE AND MODIFICATION
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AGREEMENT WITH LIBERTY LIFE !
INSURANCE COMPANY
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TO THE HONORABLE D. JOSEPH DE VITO,
BANRRUFTCY JUDGE: '
The application of Myron S. Lehman respectfully
represents:
1. One of the assets owned by the Debtors herein
is a motel-hotel operation located on North Beach, Fort Pierce,
St. Lucie County, Florida, now operated as a Ramada Inn.
2. The real property is owned by Lucille V. Costa i
one of the Debtors herein; and Bears Nest, Inc. is the owner and
holder-of the leasehold interest, with the original executed
mortgage held by Liberty Life Insurance Company having been re-
corded on November 7, 1973, by the two Debtors herein.
3. The .foreclosure proceeding against said prop-
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erty was commenced by Liberty Life Insurance Company, as first
mortgagee, grior to the filing of the original Petition in
Chapter XI herein.
- 4. As a result of the filing of said Petition,
the mortgage foreclosure was stayed; and from time to time, said
Liberty Life Insurance Company would make application before this
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