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

Filing 30

MOTION by Plaintiff U.S. Bank, National Association for judgment nunc pro tunc (Adams, Megan)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
U.S.
Bank,
National
Association
as Trustee under the Pooling and Servicing
Agreement dated as of February 1, 2007,
GSAMP Trust 2007-NC1, Mortgage PassThrough Certificates, Series 2007-NC1,

)
)
)
) Case No: 12-cv-02756
)
)
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Plaintiff,
)
V.
) Judge: Edmond Chang
Robin Silver, RBS Citizens NA successor in )
interest to St. Paul Federal Bank for Savings
)
)
)
Defendants.
MOTION FOR JUDGMENT NUNC PRO TUNC
NOW

COMES

the

Plaintiff,

U.S.

Bank,

National

Association

as Trustee under the Pooling and Servicing Agreement dated as of February 1, 2007, GSAMP
Trust 2007-NC1, Mortgage Pass-Through Certificates, Series 2007-NC1, by and through its
attorney, Megan Christine Adams, and moves this Honorable Court for Entry of Judgment of
Foreclosure Nunc Pro Tunc. In support thereof, Plaintiff states as follows:
1. On March 7, 2013 this Honorable Court entered Judgment of Foreclosure in favor of the
Plaintiff in the amount of $265,827.65. (See Dkt. # 25).
2. That $265,827.65 figure comes from the Affidavit of Debt by Mekeisha Neil (Dkt. #19-4)
and the Affidavit of Attorney’s fees by Phillip A. Pluister (Dkt.#19-5).
3. However, the $265,827.65 figure did not take into account the per diem interest of
$3,244.74 that the Plaintiff was entitled to as of March 7, 2013.
4. Additionally, a Judgment of Foreclosure was never entered.
WHEREFORE, Plaintiff respectfully requests that its Motion for Judgment Nunc Pro
Tunc be Granted, that this Court enter a judgment of foreclosure in favor of Plaintiff effective as

of March 7, 2013, and enter an award of $269,072.39 as of March 7, 2013.
Respectfully submitted,
/s/ Megan Christine Adams
Megan Christine Adams ARDC#6312221
Potestivo & Associates, P.C.
223 West Jackson Blvd, suite 610
Chicago, IL 60601
[phone]