Summons MF-000086 Keener
September 12, 2019 at 6:04 p.m.
By -
STATE OF INDIANA
SS
COUNTY OF KOSCIUSKO
LAKE CITY BANK, Plaintiff
vs.
CHRIS A. KEENER, Defendants
IN THE KOSCIUSKO SUPERIOR COURT
CAUSE NO. 43D03-1908-MF-000086
COMES NOW the Plaintiff, Lake City Bank (“Lake City”), by counsel, having filed its Complaint and Affidavit in the above-entitled cause, hereby requests that the Clerk of Kosciusko Superior County issue the Summons by publication as follows:
1. This Summons by publication is specifically directed to Defendant, Chris A. Keener, whose last known address was 1205 W. Main Street, #A, North Manchester, IN 46962, and present address is unknown.
2. The nature of the above-captioned cause is that on May 17, 2002, Chris A. Keener (the “Borrower”) executed and delivered to Lake City a certain Promissory Note (the “Note”) by which he promised to pay to the order of Lake City the principal sum of $60,500.00, together with interest. As of August 2, 2019, there is a principal balance due and owing with respect to the Note in the amount of $39,274.90.
3. To secure payment of the Note, the Borrower executed and delivered to Lake City a Mortgage dated May 17, 2002 (the “Mortgage”). The real estate, which is the subject matter of the Mortgage, is described as follows, to-wit:
Part of the Southeast Quarter of Section 23, Township 32 North, Range 7 East, 2nd P.M., Kosciusko County, Indiana, being part of the land of Clint and Marie Bowling, (Deed Record 286, Page 301), and more particularly described as follows:
Commencing at the Northeast Corner of the Southeast Quarter of said Section, said point being marked by a railroad spike at the intersection of the centerlines of County Road 150 South and 900 East; thence North 90 Degrees 00 Minutes West (assumed bearing) along the centerline of County Road 150 South and the North line of said Southeast Quarter, a distance of 630.4 Feet to a PK nail found in County Road 150 South, said point being the point of beginning; thence South 1 Degrees 57 Minutes West a distance of 400.0 feet to a 1/2 inch iron rebar found in place; thence South 90 Degrees 0 Minutes West a distance of 930.55 Feet to a wood fence post; thence North 2 Degrees 40 Minutes 21 Seconds East a distance of 400.21 Feet to the North line of said Quarter and the centerline of County Road 150 South, said point being marked by a PK nail set this survey; thence North 90 Degrees 0 Minutes East along the North line of said Quarter and County Road 150 South a distance of 925.5 Feet to the point of beginning.
To be known as:
A tract of land being a part of the Southeast Quarter of Section 23, Township 32 North Range 7 East, 2nd P.M., Washington Township, Kosciusko County, Indiana, more particularly described as follows:
Commencing at the Northeast corner of the Southeast Quarter of said Section 23, said point being marked by a railroad spike at the intersection of the centerlines of County Roads 150 South and 900 East; thence North 90 Degrees 00 Minutes West (assumed bearing) along the centerline of County Road 150 South and along the North line of said Southeast Quarter, 630.4 Feet to a PK nail at the point of beginning; thence South 01 Degrees 57 Minutes West, 400.00 Feet to a 1/2 inch iron bar; thence South 90 Degrees 00 Minutes West, 930.55 Feet to a wood post: thence North 02 Degrees 40 Minutes 21 Seconds East, 400.21 Feet to a PK nail on the North line of said Southeast Quarter; thence North 90 Degrees 00 Minutes East, along said North line, 925.5 Feet to the point of beginning.
Commonly known as: 8847 East 150 South, Pierceton, IN 46562
(the “Real Estate”).
4. Lake City has accelerated the entire balance due and owing on the Note and Mortgage, due to the Borrower’s failure to make the required payments to Lake City. The Borrower is also responsible for prejudgment interest as set forth in the Note and reasonable attorney’s fees incurred by Lake City.
5. The Defendant, Chris A. Keener, named herein must answer this Summons in writing, personally or by counsel, on or before thirty (30) days from the date of the third publication hereof. If said Defendant fails to do so, judgment may be rendered against them for the relief demanded.
Dated this 12th day of September, 2019.
Respectfully submitted,
ROTHBERG LOGAN & WARSCO LLP
By: Thomas B. Trent
Supreme Court No. 23173-02
505 East Washington Boulevard
P.O. Box 11647
Fort Wayne, Indiana 46859-1647
Telephone: (260) 422-9454
Facsimile: (260) 422-1622
ATTORNEYS FOR PLAINTIFF
9-14,21,28 hspaxlp
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STATE OF INDIANA
SS
COUNTY OF KOSCIUSKO
LAKE CITY BANK, Plaintiff
vs.
CHRIS A. KEENER, Defendants
IN THE KOSCIUSKO SUPERIOR COURT
CAUSE NO. 43D03-1908-MF-000086
COMES NOW the Plaintiff, Lake City Bank (“Lake City”), by counsel, having filed its Complaint and Affidavit in the above-entitled cause, hereby requests that the Clerk of Kosciusko Superior County issue the Summons by publication as follows:
1. This Summons by publication is specifically directed to Defendant, Chris A. Keener, whose last known address was 1205 W. Main Street, #A, North Manchester, IN 46962, and present address is unknown.
2. The nature of the above-captioned cause is that on May 17, 2002, Chris A. Keener (the “Borrower”) executed and delivered to Lake City a certain Promissory Note (the “Note”) by which he promised to pay to the order of Lake City the principal sum of $60,500.00, together with interest. As of August 2, 2019, there is a principal balance due and owing with respect to the Note in the amount of $39,274.90.
3. To secure payment of the Note, the Borrower executed and delivered to Lake City a Mortgage dated May 17, 2002 (the “Mortgage”). The real estate, which is the subject matter of the Mortgage, is described as follows, to-wit:
Part of the Southeast Quarter of Section 23, Township 32 North, Range 7 East, 2nd P.M., Kosciusko County, Indiana, being part of the land of Clint and Marie Bowling, (Deed Record 286, Page 301), and more particularly described as follows:
Commencing at the Northeast Corner of the Southeast Quarter of said Section, said point being marked by a railroad spike at the intersection of the centerlines of County Road 150 South and 900 East; thence North 90 Degrees 00 Minutes West (assumed bearing) along the centerline of County Road 150 South and the North line of said Southeast Quarter, a distance of 630.4 Feet to a PK nail found in County Road 150 South, said point being the point of beginning; thence South 1 Degrees 57 Minutes West a distance of 400.0 feet to a 1/2 inch iron rebar found in place; thence South 90 Degrees 0 Minutes West a distance of 930.55 Feet to a wood fence post; thence North 2 Degrees 40 Minutes 21 Seconds East a distance of 400.21 Feet to the North line of said Quarter and the centerline of County Road 150 South, said point being marked by a PK nail set this survey; thence North 90 Degrees 0 Minutes East along the North line of said Quarter and County Road 150 South a distance of 925.5 Feet to the point of beginning.
To be known as:
A tract of land being a part of the Southeast Quarter of Section 23, Township 32 North Range 7 East, 2nd P.M., Washington Township, Kosciusko County, Indiana, more particularly described as follows:
Commencing at the Northeast corner of the Southeast Quarter of said Section 23, said point being marked by a railroad spike at the intersection of the centerlines of County Roads 150 South and 900 East; thence North 90 Degrees 00 Minutes West (assumed bearing) along the centerline of County Road 150 South and along the North line of said Southeast Quarter, 630.4 Feet to a PK nail at the point of beginning; thence South 01 Degrees 57 Minutes West, 400.00 Feet to a 1/2 inch iron bar; thence South 90 Degrees 00 Minutes West, 930.55 Feet to a wood post: thence North 02 Degrees 40 Minutes 21 Seconds East, 400.21 Feet to a PK nail on the North line of said Southeast Quarter; thence North 90 Degrees 00 Minutes East, along said North line, 925.5 Feet to the point of beginning.
Commonly known as: 8847 East 150 South, Pierceton, IN 46562
(the “Real Estate”).
4. Lake City has accelerated the entire balance due and owing on the Note and Mortgage, due to the Borrower’s failure to make the required payments to Lake City. The Borrower is also responsible for prejudgment interest as set forth in the Note and reasonable attorney’s fees incurred by Lake City.
5. The Defendant, Chris A. Keener, named herein must answer this Summons in writing, personally or by counsel, on or before thirty (30) days from the date of the third publication hereof. If said Defendant fails to do so, judgment may be rendered against them for the relief demanded.
Dated this 12th day of September, 2019.
Respectfully submitted,
ROTHBERG LOGAN & WARSCO LLP
By: Thomas B. Trent
Supreme Court No. 23173-02
505 East Washington Boulevard
P.O. Box 11647
Fort Wayne, Indiana 46859-1647
Telephone: (260) 422-9454
Facsimile: (260) 422-1622
ATTORNEYS FOR PLAINTIFF
9-14,21,28 hspaxlp
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