United States of America v. Gerts (Deceased) et al

Filing 71

MOTION by Plaintiff United States of America for judgment of foreclosure (Attachments: # 1 Exhibit Exhibit A Affidavit for Prove-Up, # 2 Exhibit Exhibit B Certificate of Attorney Fees and Costs)(Rasmussen, Ashley)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA on behalf
of its agency SECRETARY of the
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT,
Plaintiff,
v.
WILLIAM P BUTCHER AS SPECIAL
REPRESENTATIVE FOR IVA G GERTS
(deceased); U.S. BANK NATIONAL
ASSOCIATION S/I/I to FDIC as receiver for
PARK NATIONAL BANK, a corporation of
ILLINOIS, duly authorized to accept and
execute trusts within the state of ILLINOIS,
as trustee under the provisions of a certain
trust agreement dated March 16, 2010, and
known as trust number 32721; RICHARD E
GERTS; SANDRA J OLSON; VICKI L
RAMOS; WILLIAM P BUTCHER as special
representative for JACK L GERTS
(deceased); JACK T GERTS, KERRY A
GERTS, SCOTT J GERTS, SHELLY J
OLESEN; unknown heirs and legatees of IVA
G GERTS;
Defendant.

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No. 16-c-9168
Judge Bucklo

MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE
The United States of America, by its attorney John R Lausch Jr., Acting United States
Attorney for the Northern District of Illinois moves for the Entry of a Judgment of Foreclosure.
Plaintiff’s claim of damages is for a sum that is made certain by computation and is more
specifically set forth in its supporting Judgment Affidavit. (Ex. A, Affidavit of amounts due and
owing and Ex. B, Certificate of prove-up of foreclosure fees and costs).

WHEREFORE, the United States moves this Honorable Court for entry of a Judgment of
Foreclosure, and for that amount as set forth and made certain in its Judgment Affidavit and
Certificate of Prove-up of Foreclosure Fees and Costs.
Respectfully submitted,
JOHN R LAUSCH Jr.
United States Attorney
By: s/Ashley K Rasmussen_______
Ashley K Rasmussen
Attorney for the United States
[e-mail]
223 W. Jackson Blvd., Suite 610
Chicago, Illinois 60606
[phone]