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)

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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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