BBCN Bank v. Lee et al

Filing 23

MOTION by Plaintiff BBCN Bank for judgment Plaintiff's Motion for Entry of Judgment of Foreclosure and Sale (Gattone, Wendy)

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IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION BBCN BANK, successor to FOSTER BANK, Plaintiff, v. JAE GEUN LEE a/k/a JAE GUEN LEE JOO SIL LEE, MAX 969, Inc., and WINDY CHICAGO 2016, Inc., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 14-cv-07255 Judge: Hon. Gary Feinerman Magistrate Judge: Hon. Mary M. Rowland PLAINTIFF’S MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE AND SALE NOW COMES the Plaintiff, BBCN Bank, successor to Foster Bank (“Plaintiff” or “BBCN”), by and through its attorneys Thomas J. Dillon, Wendy Kaleta Gattone, Nicholas S. Maragos and McFadden & Dillon, P.C., and for its Motion for Entry of Judgment of Foreclosure and Sale: 1. On March 3, 2015, the Court entered an Order of Default against all defendants. 2. BBCN’s claim of damages is for the sum that is made certain by computation and is more specifically set forth in BBCN’s supporting Affidavit of Proof. 3. Plaintiff moves this court for the entry of a Judgment of Foreclosure and Sale based on the pleadings of record with this Court. WHEREFORE, the Plaintiff, BBCN Bank, successor to Foster Bank requests that this Court (i) enter a Judgment of Foreclosure and Sale pursuant to the Order of Default entered herein and (ii) grant such further relief as the Court may deem just and proper. Respectfully Submitted, /s/ Wendy Kaleta Gattone One of the attorneys for plaintiff, BBCN Bank, successor to Foster Bank Thomas J. Dillon (ARDC#3124223) t.dillon@mcdillaw.com Wendy Kaleta Gattone (ARDC#6226119) w.skrobin@mcdillaw.com Nicholas S. Maragos (ARDC#6306503) n.maragos@mcdillaw.com McFadden & Dillon, P.C. 120 S. LaSalle Street Suite 1335 Chicago, Illinois 60603 (312) 201-8300

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