IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KANSAS

 

UNITED STATES OF AMERICA,

Plaintiff,

v.

Civil No. 2:19-cv-02605-DDC-TJJ

ASHLEY CLARK, ANGELA CLARK, KEITH CLARK, and The Unknown Heirs, Executors, Administrators, Devisees, Trustees, Legatees, Creditors, and Assignees of the Deceased Borrower, CHARLES M. CLARK, and the Unknown Spouses of the Deceased Borrower and other Defendants; Unknown Stockholders, Officers, Successors, Trustees, Creditors and Assignees of Defendants as are existing, dissolved or dormant corporations; Unknown Executors, Administrators, Devisees, Trustees, Creditors, Successors and Assignees of Defendants as are or were partners or in partnership; and Unknown Guardians, Conservators and Trustees of Defendants as are minors or are in any way under legal disability; and Unknown Heirs, Executors, Administrators, Devisees, Legatees, Trustees, Creditors and Assignees of any Person alleged to be deceased and made Defendants,

Defendants.

 

NOTICE OF SUIT

 

THE UNITED STATES OF AMERICA TO: Defendants Ashley Clark, Angela Clark, Keith Clark, and The Unknown Heirs, Executors, Administrators, Devisees, Trustees, Legatees, Creditors, and Assignees of the Deceased Borrower, Charles M. Clark; the Unknown Spouses of the Deceased Borrower and other Defendants; the Unknown Stockholders, Officers, Successors, Trustees, Creditors and Assignees of such Defendants as are existing, dissolved or dormant corporations; the Unknown Executors, Administrators, Devisees, Trustees, Creditors, Successors and Assignees of such Defendants as are or were partners or in partnership; and the Unknown Guardians, Conservators and Trustees of such of the Defendants as are minors or are in any way under legal disability; and the Unknown Heirs, Executors, Administrators, Devisees, Legatees, Trustees, Creditors and Assignees of any Person alleged to be deceased and made Defendants as such:

YOU ARE HEREBY NOTIFIED that a Complaint has been filed in the United States District Court for the District of Kansas, by the United States of America, on behalf of the Rural Housing Service, United States Department of Agriculture, by and through the United States Attorney for the District of Kansas, praying for judgment in rem on the Promissory Notes dated March 31, 1993, and November 12, 1993, in the amount of $40,137.38, which includes principal, advances, and any other recoverable costs; plus interest on principal and advances in the amount of $2,053.59 as of February 21, 2019; plus interest accruing thereafter at the daily rate of $6.8661; plus $19,073.57 in subsidy subject to recapture; plus the costs of this action and for foreclosure of real estate mortgages executed on March 31, 1993, and November 12, 1993, covering real property located in  Johnson County, Kansas, described as:

 

Lot 6, Block 2, DEMEADOWS 1ST PLAT, a subdivision in the City of DeSoto, Johnson County, Kansas,

 

and you are hereby required to plead to said Complaint on or before March 6, 2020, in the United States District Court at Kansas City, Kansas.  Should you fail therein, judgment and decree may be entered in due course upon the Complaint.

Respectfully submitted,

 

STEPHEN R. McALLISTER

United States Attorney

District of Kansas

 

s/ Andrea L. Taylor

ANDREA L. TAYLOR

Assistant United States Attorney

KS Fed. Bar No. 70422

500 State Avenue, Suite 360

Kansas City, Kansas 66101

PH: (913) 551-6730

FX: (913) 551-6541

Email: [email protected]

Attorneys for the Plaintiff