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)

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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. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 16-cv-9193 Judge: John J Tharp, Jr. Magistrate Judge Susan E. Cox CERTIFICATE OF PROVE-UP OF FORECLOSURE FEES AND COSTS I, the undersigned, an attorney with Potestivo & Associates, P.C., Attorneys for Plaintiff, in support of Plaintiff’s motion for Judgment of Foreclosure herein, do hereby state that I have personal knowledge of the following facts, and do, therefore, certify as follows: 1. The following court costs and expenses were incurred by Plaintiff herein and ought to be assessed as costs and expenses as provided in the subject mortgage and note: Fees & costs of suit: (i) Title Commitment Costs $350.00 (ii) Recording/Certification Costs: $52.00 (iii) Special Representative Fees: $500.00 (iv) Publication Costs: $180.00 (v) Costs for service of Process on Defendants: $65.00 (vi) Judicial Foreclosure Attorney Fees: $1,300.00 Total fees & costs of suit: 2. $2,447.00 That the foreclosure attorney’s fees stated in paragraph 1 will be, or have been received by Potestivo & Associates, P.C. and the request for attorney’s fees is reasonable in that: a. Based upon the experience, reputation and ability of the lawyer or lawyers performing the services; the skill requisite to perform the services properly; and the fees customarily charged in the locality for like services, the fees charged in this case are reasonable. b. The fee charged was reasonable required to perform the legal services actually rendered. c. The amount at issue and the results obtained bear a reasonable relationship to the fee claimed. 3. Under penalties as provided by law pursuant to Section 5/1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that the undersigned verily believes the same to be true. By: s/Ashley K Rasmussen Ashley K Rasmussen Attorney for the United States arasmussen@potestivolaw.com 223 W. Jackson Blvd., Suite 610 Chicago, Illinois 60606 (312) 263-0003

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