FirstMerit Bank, N.A.v. Grantham et al

Filing 36

MOTION by Plaintiff FirstMerit Bank, N.A. for judgment revival (Griseta, Thomas)

Case: 1:13-cv-06017 Document #: 36 Filed: 12/22/20 Page 1 of 3 PageID #:192

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FirstMerit Bank, N.A, successor in
interest to Midwest Bank and Trust
Company,
vs.

Plaintiff,

Case No. 13-cv-6017

Sandra Grantham, et al.,
Defendants.
PETITION TO REVIVE JUDGMENT
The Huntington National Bank1 (“Huntington”), successor by merger with
FirstMerit Bank, N.A., by and through its attorneys, respectfully requests that this
Court revive the judgment previously entered against Sandra Grantham (the
“Judgment Debtor”). In support, Huntington respectfully states as follows:
1.

On February 6, 2014, this Court entered a judgment (the “Judgment”)

in favor of FirstMerit Bank, N.A. and against the Judgment Debtor in the amount
of $110,242.82 (Dkt. No. 26).
2.

On or about June 1, 2018, Huntington and the Judgment Debtor entered

into a settlement agreement to resolve the debt due under the Judgment. The
settlement agreement called for the Judgment Debtor to make settlement payments
to Huntington over time. The Judgment Debtor is actively making settlement
payments, but her obligations thereunder are ongoing.
3.

Since entry of the Judgment Order, statutory interest, costs, and fees

have accrued as follows:
Interest:

$801.99

1 Effective August 16, 2016, FirstMerit Bank, N.A. merged with and into The Huntington National
Bank. Contemporaneous with the filing of this petition, Huntington is filing a motion to substitute
in as plaintiff.

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Case: 1:13-cv-06017 Document #: 36 Filed: 12/22/20 Page 2 of 3 PageID #:193

Costs:
Attorneys’ Fees:
4.

$311.45
$0

To date, Huntington has received $44,547.00 toward satisfaction of the

Judgment.
5.

The current amount due on the Judgment is $66,809.26 (the “Current

Judgment Balance”). Should the Judgment Debtor fully comply with the settlement
agreement, however, she will not be required to pay the entire Current Judgment
Balance.
6.

Pursuant to 735 ILCS 5/2-1602, a judgment may be revived to permit its

continued enforcement.
7.

Huntington respectfully requests that this Court revive the Judgment

entered against the Judgment Debtor.
8.

Thirty days’ notice of this petition has been provided to the Judgment

Debtor as required by 735 ILCS 5/2-1602 (c).
WHEREFORE, Huntington respectfully requests that this Court grant the
relief sought herein and such further relief as is appropriate under the circumstances.
Dated: December 22, 2020

Respectfully submitted,
The Huntington National Bank,
successor by merger with FirstMerit
Bank, N.A.

William J. Factor (6205675)
Thomas H. Griseta
THE LAW OFFICE OF
WILLIAM J. FACTOR, LTD.
105 W. Madison Street, Suite 1500
Chicago, IL 60602
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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By: /s/ Thomas H. Griseta
One of Its Attorneys

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