U.S. Bank, National Association v. Silver et al

Filing 53

MOTION by Plaintiff U.S. Bank, National Association for judgment of foreclosure (Adams, Megan)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

U.S.
Bank,
National
Association
as trustee under Securitization Servicing
Agreement Dated as of July 1, 2005
Structured Asset Securities Corporation,
Structured Asset Investment Loan Trust
Mortgage Pass-Through Certificates, Series
2005-HE1,
Plaintiff,

)
)
) Case No: 11-cv-06332
)
) Judge: Honorable Judge Darrah
)
)
)
)
)
v.
)
Stanford D. Silver, Denise J. Silver, Kitchen )
Distributors of America, Inc., Northwest )
Millwork Company, Suburban Concrete, Inc. )
)
Defendants.
PLAINTIFF’S MOTION FOR JUDGMENT OF FORECLOSURE
NOW COMES, the Plaintiff, U.S. Bank, National Association as trustee under
Securitization Servicing Agreement Dated as of July 1, 2005 Structured Asset Securities
Corporation, Structured Asset Investment Loan Trust Mortgage Pass-Through Certificates,
Series 2005-HE1, by and through its attorney, Megan Christine Adams, and respectfully requests
the Court enter a Judgment of Foreclosure. In support thereof, Plaintiff states as follows:
1. On December 4, 2013 the Court granted Plaintiff’s Motion for Default Judgment against
the Defendants.
2. On December 4, 2013 the Court granted Plaintiff’s Motion to Appoint a Special
Commissioner, “for the purpose of conducting a public foreclosure sale of the property in
accordance with the terms of the Judgment of Foreclosure.” [ECF #47]
3. For reasons unknown, a Judgment of Foreclosure was never entered.
4. A Judgment of Foreclosure is needed to proceed with the sale of this property.
WHEREFORE, Plaintiff respectfully requests the Court enter a Judgment of Foreclosure.
Plaintiff will provide a proposed Judgment of Foreclosure reflecting the amounts due as provided
in the Affidavits on the record. [ECF# 37-2, 37-3].
Respectfully submitted,
/s/ Megan Christine Adams
Potestivo & Associates, PC
Megan C Adams (ARDC#6312221)
223 West Jackson Blvd., suite 610
Chicago, IL 60606
[e-mail]