First Suburban National Bank v. Forsgren et al

Filing 14

MOTION by Plaintiff First Suburban National Bank for Entry of Ex Parte judgment by confession (Attachments: # 1 Exhibit Promissory Note, # 2 Exhibit Affidavit of Thomas A. Gehrke, Jr., # 3 Exhibit Confession of Judgment)(Dillon, Thomas) Modified on 2/8/2010 (ca, ).

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FIRST SUBURBAN NATIONAL BANK, Plaintiff, v. KEITH C. FORSGREN and JANET M. FORSGREN, Defendants. ) ) ) ) ) ) ) ) ) ) Case No. 1: 09-cv-08024 Judge Kennelly

Amount Claimed: $78,836.10 plus interest, costs and attorneys fees

CONFESSION Defendants, Keith C. Forsgren and Janet M. Forsgren,

individually and jointly and severally, by their attorney, Timothy J. Somen, Esq., waive service of process and confess that there is due to plaintiff, First Suburban National Bank, under the

Promissory Note at issue in the above-captioned cause the following amounts as of December 28, 2009: Principal: Interest: TOTAL AMOUNT DUE: $ $ 78,836.10 5,728.94 84,565.04

Plus additional accrued interest subsequent to December 28, 2009 at the per diem rate of $55.44. Defendants, Keith C. Forsgren and Janet M. Forsgren, agree that judgment may be entered against them, individually and jointly and severally, for the total set forth above and for costs and attorneys fees and hereby release and waive all rights as

authorized in the warrant of attorney set forth in the Note.

Respectfully submitted,

s/ Timothy J. Somen, Esq. Attorney for defendants, Keith C. Forsgren and Janet M. Forsgren Timothy J. Somen (Ill.ARDC No. 6279438) 120 South LaSalle Street Suite 1335 Chicago, Illinois 60603 [phone]