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

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
[e-mail]
223 W. Jackson Blvd., Suite 610
Chicago, Illinois 60606
[phone]