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fifteen (15) days after service of said motion, Bears Nest and Lucille V.
Costa and George A. Costa may cure any such default by payment in full of
all amounts necessary to cure such default or performance of any other
acts necessary to cure such default. Upon receipt of such payments or
proof of the curing of any such defaults, Liberty shall file a Withdrawal
of Notion for Entry of Final Judgment and the request for entry of Final
Judgment of Foreclosure shall stand withdrawn. In the event of a failure
of Bears Nest and the Costas to cure such default within said fifteen
(15) day period, a Judgment of Foreclosure in substantially the form
attached hereto as Exhibit C shall be entered by the Court fifteen (15)
. days after service of the motion for entry of judgment of foreclosure upon
ex parte application of Liberty unless Bears Nest or the Costas shall file
a sworn denial of default specifically setting forth the facts demonstrating
that no additional default has occurred under the Forebearance Agreement or
the original-loan documents as set forth in the Plaintiff's motion for entry
of judgment of foreclosure. Said sworn denial shall specifically meet the
allegations of the Liberty motion for entry of judgment of foreclosure or
that the amounts claimedtherein are incorrect and in what manner they are
incorrect. In the event such denial is filed, then a trial shall be held
solely on the issues created by the motion for entry of judgment of
foreclosure and the denial of default, all other allegations of the
' original Complaint herein having been admitted by all of the parties hereto.
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The Court shall reserve jurisdiction to determine fees and costs on
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s motion upon entry of a judgment of foreclosure as hereinabove set forth
unless the amounts thereof are set forth in Liberty's sworn motion or
affidavits attached thereto and the same are not denied by the Defendants,
o Bears `lest, Lucille V. Costa and George A. Costa.
4. All motions and notices provided for in this Stipulation shall
be served upon the attorneys for the parties herein.
~ 5. Bears Nest, Lucille V. Costa and George A. Costa shall be
~ personally~liabYe pursuant to the terms of their unconditional
guaranty and the execution of the Forebearance Agreement to the extent
of the arrearages to5ether with interest thereon as therein set forth
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and shall further be personally liable for costs incurred hereafter
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in enforcing, collection or foreclosing pursuant to the terms of said
BOOK 3~V PaGE 670
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