REED AND EARHART ATTORNEYS AT LAW, P.C., DAVID P. WILSON, and
SCOTT J. LENNOX, Defendants.
COMES NOW the Plaintiff, Lake City Bank (the “Bank”), by counsel, having filed its Complaint and Affidavit in the above-entitled cause, hereby requests that the Clerk of Kosciusko Superior Court, issue the Summons by publication as follows:
1. This Summons by publication is directed to Defendant, Reed and Earhart Attorneys at Law, P.C. (the “Law Firm”), whose last known address was and is: 318 South Buffalo Street, Warsaw, Indiana 46580, and its present address is unknown.
2. This Summons by publication is also directed to Defendant, Scott J. Lennox (“Lennox”), whose last known address was and is: 1519 South Riverside Avenue #3, St. Clair, Michigan 48097, and his present address is unknown.
3. The nature of the above-captioned cause is that on December 10, 2015, the Law Firm executed and delivered to the Bank a certain Note, Disclosure and Security Agreement (the “Note”) by which it and David P. Wilson promised to pay to the order of the Bank, the sum of $37,077.84, together with interest, and as of December 4, 2019, there is a principal balance owing in the amount of $10,491.25.
4. To secure repayment of the Note, the Law Firm. and David P. Wilson granted the Bank a security interest in their 2015 Buick Enclave (VIN: 5GAKVBKD4FJ169416) (the “Collateral”), as set forth in the Note.
5. To further secure repayment of the Note, Lennox executed a certain Consumer Guaranty (the “Guaranty”) dated October 19, 2015, in favor of the Bank. Pursuant to the Guaranty, Lennox personally guaranteed all of the Law Firm’s current and future indebtedness to the Bank.
6. Lake City Bank, as the holder of the Note, has accelerated the entire balance due and owing on the Note, due to the Law Firm’s and David P. Wilson’s failure to make the required payments and has demanded immediate possession of the Collateral.
7. The Defendants, Reed and Earhart Attorneys at Law, P.C. and Scott J. Lennox, 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 Defendants fail to do so, judgment may be rendered against them for the relief demanded.
NOTICE: ROTHBERG LOGAN & WARSCO LLP IS A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
