United States of America on Behalf of Its Agency Secretary of U.S. Department of Housing and Urban Development v. Harrell (Deceased) et al

Filing 20

MOTION by Plaintiff United States of America on Behalf of Its Agency Secretary of U.S. Department of Housing and Urban Development for judgment of Foreclosure (Attachments: # 1 Exhibit Certificate of Prove-Up, # 2 Exhibit Certificate of Attorneys' Fees)(Rasmussen, Ashley)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA ON BEHALF OF ITS AGENCY
SECRETARY OF U.S. DEPARTMENT OF HOUSING AND URBAN
DEVELOPMENT,
Plaintiff,
v.
WILLIAM P BUTCHER AS SPECIAL REPRESENTATIVE FOR
VIVIAN R HARRELL a/k/a VIVIAN RITA DADE HARRELL
(DECEASED); WALTER HARRELL;
UNKNOWN HEIRS AND
LEGATEES OF VIVIAN R HARRELL A/K/A VIVIAN RITA DADE
HARRELL; UNKNOWN OWNERS AND NON-RECORD CLAIMANTS;
Defendants.

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Case No. 16-cv-9193
Judge: John J Tharp, Jr.
Magistrate Judge
Susan E. Cox

MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE
NOW COMES, Plaintiff, UNITED STATES OF AMERICA, ON BEHALF OF ITS AGENCY,
SECRETARY OF U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, by and through
its attorneys, Potestivo & Associates, P.C., and moves this Honorable Court, 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. (See Exhibit A, Affidavit of Amounts Due and Owing; see
Exhibit B, Certificate of Prove-up of Foreclosure Fees and Costs).
WHEREFORE, the Plaintiff, UNITED STATES OF AMERICA ON BEHALF OF ITS AGENCY
SECRETARY OF U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, 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,
ZACHARY T. FARDON,
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]