Deutsche Bank National Trust Company v. Slaughter et al

Filing 20

MOTION by Plaintiff Deutsche Bank National Trust Company for judgment of Foreclosure (Adams, Megan)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON
ASSET SECURITIES TRUST 2007-1
MORTGAGE LOAN ASSET BACKED
CERTIFICATES, SERIES 2007-1,
Plaintiff,
V.

)
)
) Case No: 1:13-CV-3916
)
)
)
)
) Judge: Gary Feinerman
ALICIA M. SLAUGHTER, UNITED )
STATES OF AMERICA, INTERNAL )
REVENUE SERVICE
)
)
Defendants.
MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE
NOW COMES the Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-1 MORTGAGE LOAN ASSET
BACKED CERTIFICATES, SERIES 2007-1, 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 $174,200.87 as of September 23, 2013, with interest accruing on the unpaid
principal balance at $22.39 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
[phone]