HSBC Bank USA, NA v. Howey et al

Filing 36

MOTION by Plaintiff HSBC Bank USA, NA for judgment with Damages (Attachments: # 1 Affidavit of Debt by Donovan L. Pitterson, # 2 Affidavit of Attorney Fees by Julia M. Bochnowski)(Bochnowski, Julia)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
HSBC BANK USA, N.A., AS INDENTURE
TRUSTEE FOR THE REGISTERED
NOTEHOLDERS OF RENAISSANCE HOME
EQUITY LOAN TRUST 2007-2
PLAINTIFF

CASE NUMBER:1:12-cv-3321

VS.

DISTRICT JUDGE: Charles R. Norgle, Sr.

PAUL D. HOWEY, CHICAGO TITLE AND
TRUST COMPANY, AN ILLINOIS
CORPORATION, JPMORGAN CHASE BANK,
NA, SUCCESSOR IN INTEREST TO GREAT
WESTERN BANK, KAREN HOWEY,

MAGISTRATE JUDGE: Martin C. Ashman

DEFENDANT(S).
AMENDED AFFIDAVIT OF ATTORNEY'S FEES
735 ILCS 5/15-1506(a)(1)
Pursuant to 735 ILCS 5/15-1506(a)(1), the undersigned, being duly sworn, states and affirms
that the following facts by way of prove-up of the complaint:
1.
That he is the attorney for HSBC Bank USA, N.A., as Indenture Trustee for the registered
Noteholders of Renaissance Home Equity Loan Trust 2007-2.
2.
That he is familiar with the material allegations of the complaint heretofore filed in the above
entitled cause, and that those allegations are true in substance and in fact.
3.
Pursuant to the terms of the Note and Mortgage Deed, the Mortgage-Defendant is also obligated
to pay all the expenses of these foreclosure proceedings; the known expenses to date which the Plaintiff
has paid, or has become obligated to pay are as follows:
a. Process Server Expense:
b. Recording Expense:
c. Court Costs:
d. Attorney’s Fees:

$285.00
$70.50
$350.00
$1,550.00

4.
That there are other charges which the Mortgagor-defendant is obligated to pay under the terms
of said Note and Mortgage Deed, and while these charges are not definitely ascertainable at this time,
provision for their payment and assessment should be made in the Judgment of Foreclosure.
5.

That the premises herein are commonly known as 635 Saint Andrews Drive, Crete, IL 60417.

6.

The attorney fees set forth above are reasonable for the following reasons:
a. The fee is based on the experience, reputation and ability of the lawyer or lawyers performing
the services and is similar to fees customarily charged in the locality for like services; and
b. The amount at issue and the results obtained bear a reasonable relationship to the fee claimed.
c. My hourly fee is $200.00. A breakdown of the time spent follows:
1) Received new referral, review documents,
.90
opened file, and ordered title search;
2) Conference and correspondence with client;
.50
3) Review title work;
.30
4) Preparation of complaint and accompanying
documents;
1.00
5) Prepare summons and issue to process server .35
6) Preparation and recording of lis pendens;
.50
7) Prepare and mail notice to municipality
.25
8) Request and review updated title work;
.25
9) Checked service of process and file returns;
.40
10) Review Defendant’s Answer
.25
11) Attend status hearing
.50
12) Prepare Motion for Judgment on the Pleadings 1.00
13) Prepare Affidavit of Debt
.30
14) Preparation and filing of judgment documents .50
15) Attend judgment hearing
.75
Respectfully submitted,
By:_____/s/ Julia M. Bochnowski

JULIA M. BOCHNOWSKI #6301499
Burke Costanza & Carberry LLP
150 N. Michigan, 8th Floor
Chicago, IL 60601
[phone]