The Bank of New York Mellon v. Aressy et al

Filing 10

MOTION by Plaintiff The Bank of New York Mellon for judgment for Foreclosure and Sale (Attachments: # 1 Affidavit of Military Status by Julia M. Bochnowski, # 2 Affidavit of Attorney Fees by Julia M. Bochnowski, # 3 Affidavit of Debt by Krystle Hernandez)(Bochnowski, Julia)

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 TO JPMORGAN CHASE
BANK, NATIONAL ASSOCIATION, AS
TRUSTEE FOR RENAISSANCE HOME
EQUITY LOAN TRUST, SERIES 2003-2

CASE NUMBER:1:13-cv-6797

PLAINTIFF
VS.

DISTRICT JUDGE: Ruben Castillo

CHRISTOPHER ARESSY, JULIA BENOIT,
MAGISTRATE JUDGE: Michael T. Mason
CAVALRY PORTFOLIO SERVICES, LLC AS
ASSIGNEE OF CAVALRY SPV I, LLC AS
ASSIGNEE OF CITIBANK, CITY OF
CHICAGO, DEPARTMENT OF WATER
MANAGEMENT,
DEFENDANT(S).
AFFIDAVIT OF ATTORNEY'S FEES
735 ILCS 5/15-1506(a)(1)
Pursuant to 735 ILCS 5/15-1506(a)(1), the undersigned, being duly sworn, states and
affirms that the following facts by way of prove-up of the complaint:
1.
That she is the attorney for The Bank of New York Mellon, f/k/a, The Bank of New York
as successor to JPMorgan Chase Bank, National Association, as Trustee for Renaissance Home
Equity Loan Trust, Series 2003-2.
2.
That she is familiar with the material allegations of the complaint heretofore filed in the
above entitled cause, and that those allegations are true in substance and in fact.
3.
Pursuant to the terms of the Note and Mortgage Deed, the Mortgage-Defendant is also
obligated to pay all the expenses of these foreclosure proceedings; the known expenses to date
which the Plaintiff has paid, or has become obligated to pay are as follows:
a. Process Server Expense:
b. Recording Expense:
c. Court Costs:
d. Attorneys Fees:

$300.00
$54.00
$400.00
$1,750.00

4.
That there are other charges which the Mortgagor-defendant is obligated to pay under the
terms of said Note and Mortgage Deed, and while these charges are not definitely ascertainable

at this time, provision for their payment and assessment should be made in the Judgment of
Foreclosure.
5.
That the premises herein are commonly known as 2856 East 87th Street, Chicago, IL
60617.
6.

The attorney fees set forth above are reasonable for the following reasons:
a. The fee is based on the experience, reputation and ability of the lawyer or lawyers
performing the services and is similar to fees customarily charged in the locality
for like services; and
b. The amount at issue and the results obtained bear a reasonable relationship to the
fee claimed.
Respectfully submitted,
By:_____/s/ Julia M. Bochnowski

Burke Costanza & Carberry LLP
JULIA M. BOCHNOWSKI #6301499
150 N. Michigan Ave, Suite 800
Chicago, IL 60601
[phone]