Deutsche Bank National Trust Company v. Morgan et al
Filing
24
MOTION by Plaintiff Deutsche Bank National Trust Company for judgment of Foreclosure (Attachments: # 1 Exhibit Affidavit of Amounts Due and Owing, # 2 Exhibit Certificate of Prove-up of Foreclosure Fees and Costs)(Adams, Megan)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE FOR GSAMP
TRUST 2007-FM2, MORTGAGE PASSTHROUGH CERTIFICATES, SERIES 2007FM2,
Plaintiff,
V.
EUALL D.
MORGAN,
MORGAN;
Defendants.
SHANNA
)
)
) Case No: 1:13-CV-3466
)
)
)
) Judge: Amy J. St. Eve
)
R. )
)
)
MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE
NOW COMES the Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS
TRUSTEE FOR GSAMP TRUST 2007-FM2, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2007-FM2, by and through its attorney, Megan Christine Adams, and
moves this Honorable Court for Entry of Judgment of Foreclosure. In support thereof, Plaintiff
states as follows:
1. Attached please find Plaintiff’s Affidavit of Prove-up attached hereto as Exhibit 1.
2. Attached please find Plaintiff’s Certificate of Prove-up of Foreclosure Fees and Costs
attached hereto as Exhibit 2.
WHEREFORE, Plaintiff respectfully requests that its Motion for Entry of Judgment of
Foreclosure be Granted, that this Court enter a judgment of foreclosure in favor of Plaintiff, enter
an award of $292,298.23 as of April 18, 2014, with interest accruing on the unpaid principal
balance at $55.59 per day, plus attorney’s fees and foreclosure costs of $1,297.50, incurred by
the Plaintiff as a result of the foreclosure, and all other relief just and proper.
Respectfully submitted,
/s/ Megan Christine Adams
Megan Christine Adams ARDC#6312221
Potestivo & Associates, P.C.
223 West Jackson Blvd, suite 610
Chicago, IL 60601
(312)263-0003
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