Christiana Trust, a division of Wilmington Saving Fund Society, FSB v. James

Filing 52

MOTION by Plaintiff Mortgage Electronic Registration Systems Inc. et. al. for judgment (Attachments: # 1 Exhibit Affidvit of Proof - exhibits)(Trausch, James)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
The Bank of New York Mellon Trust
Company, National Association, as grantor
Trustee of the Protium Master Grantor Trust,

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Plaintiff,
-vs.-

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Michael A. James, Non-Record Claimants
Unknown Owners
Defendants

Case Number: 11 CV 05905
District Judge: Honorable John
Tharp
Magistrate Judge: Jeffrey Cole

MOTION FOR JUDGMENT
NOW COMES the Plaintiff, by and through its Attorneys, Jaros, Tittle & O'Toole, Limited
and moves this Court for the entry of a judgment of foreclosure and sale and appointment of selling
officer, and, in support of its position, states as follows:
1. That this Court has previously entered summary judgment in this cause
2. That Plaintiff has previously submitted an Affidavit of Amounts Due in connection with
said Motion
3. That said affidavit sets forth the following amounts as due:
Principal Balance due as of Default
Accrued Interest thereon to August 1 2012
Accrued Late Charges
Advances for:
Property Inspections
BPO’s
Real Estate Taxes
Hazard Insurance
Escrow Credit applied November 25 2008

$844,629.48
$261,694.40
$8,132.00
$347.00
$585.00
$20,005.79
$11,921.00
$(8,883.52)

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Escrow Credit applied November 25 2008
Funds in suspense for benefit of borrower

$(253.12)
$(18,365.38)

4. That by virtue of the above, plaintiff is entitled, pursuant to Section 15-1506(a) of the
Illinois Mortgage Foreclosure Law (S.H.A. 735 ILCS 5/15-1506(a)), to a Judgment of Foreclosure
and Sale and appointment of Selling Officer.
WHEREFORE, Plaintiff prays for the entry of a judgment of foreclosure and sale.

James E. Trausch
Signed-One of its Attorneys
JAROS, TITTLE & O'TOOLE, LIMITED
Attorney for Plaintiff
20 North Clark Street
Suite 510
Chicago, IL 60602
312-750-1000
02MotionDefault&Judg10-1-2002

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