The Bank of New York Mellon v. Banks et al

Filing 29

MOTION by Plaintiff The Bank of New York Mellon for judgment of foreclosure against Arrow Financial Services LLC (Adams, Megan)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
The Bank of New York Mellon f/k/a The
Bank of New York as successor trustee for
JPMorgan Chase Bank, N.A., as Trustee for
the Benefit of the Certificateholders of Equity
One ABS, Inc. Mortgage Pass-Through
Certificates Series 2004-1,
Plaintiff,
V.
Robert D. Banks; Arrow Financial Services
LLC; Midland Credit Management, Inc;
Shona L. Banks,
Defendants.

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) Case No: 1:12-cv-7767
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) Judge: Robert W. Gettleman
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PLAINTIFF’S MOTION FOR JUDGMENT OF FORECLOSURE AGAINST ARROW
FINANCIAL SERVICES LLC
NOW COMES Plaintiff The Bank of New York Mellon f/k/a The Bank of New York as
successor trustee for JPMorgan Chase Bank, N.A., as Trustee for the Benefit of the
Certificateholders of Equity One ABS, Inc. Mortgage Pass-Through Certificates Series 2004-1,
by and through its attorneys Potestivo & Associates, PC., and hereby requests this Honorable
Court enter a Judgment of Foreclosure against Arrow Financial Services LLC. In support
thereof, Plaintiff states as follows:
1. On August 19, 2014 Arrow Financial Services LLC (“Arrow”) was defaulted for their
failure to answer Plaintiff’s Complaint.
2. As a result, all allegations in Plaintiff’s Complaint are taken as true as against Arrow.
3. Arrow’s lien/interest is subordinate and inferior to the lien of the Plaintiff’s.
4. Therefore, Plaintiff seeks a Judgment of Foreclosure be entered against Arrow
Financial Services, eliminating their lien against the property located at 2136 Hagen
Lane, Flossmor, Illinois.
WHEREFORE, Plaintiff respectfully requests the Court enter a Judgment of Foreclosure
against Arrow Financial Services LLC.
Respectfully submitted,
/s/ Megan Christine Adams
Potestivo & Associates, P.C.
Megan C. Adams (ARDC# 6312221)
223 W. Jackson Blvd., Suite 610
Chicago, Illinois 60606
Telephone: [phone]
Main Fax: [phone]
Cook County Firm ID #: 43932
DuPage County Firm ID #: 223623
Attorneys for Plaintiff
Our File No.: C13-91829