Deutsche Bank National Trust Company v. Edge et al

Filing 19

MOTION by Plaintiff Deutsche Bank National Trust Company for judgment -Plaintiff's Motion to Revise Judgment of Foreclosure- (Pappas, James)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION Deutsche Bank National Trust Company, as Trustee for the Registered Holders of Morgan Stanley ABS Capital I Inc. Trust 2007-HE7 Mortgage PassCASE NUMBER: 3:12-cv-50160 Through Certificates, Series 2007-HE7 PLAINTIFF VS. DISTRICT JUDGE: Philip G. Reinhard Gina C. Edge, Jerome R. Edge, II, Amcore MAGISTRATE JUDGE: P. Michael Mahoney Mortgage, Inc., United States of America, Internal Revenue Service, DEFENDANT(S). PLAINTIFF’S MOTION TO REVISE JUDGMENT OF FORECLOSURE Now Comes the Plaintiff, Deutsche Bank National Trust Company, by Burke Costanza & Carberry, LLP, one of its attorneys, and in support of its Motion to Revise the Judgment of Foreclosure, states as follows: 1. 2. 3. 4. Plaintiff filed its Complaint to Foreclose Mortgage on May 4, 2012. Defendants, Gina C. Edge, Jerome R. Edge, II, Amcore Mortgage, Inc., United States of America, Internal Revenue Service, on September 24, 2012 were Defaulted and a Judgment of Foreclosure was entered. On October 29, 2012, Plaintiff’s attorney received a letter from the United States Attorney’s Office requesting additional language be included in the Judgment of Foreclosure. As a result, Plaintiff wishes to Revise the Judgment of Foreclosure to add the requested language recommended by the United States of America, Internal Revenue Service. WHEREFORE, Plaintiff moves this Court to Revise the Judgment of Foreclosure in this matter so that Plaintiff may proceed in its efforts to foreclose the mortgage that is the subject of this case. Respectfully submitted, BURKE COSTANZA & CARBERRY LLP By:/s/ James N. Pappas James N. Pappas, #6291873 225 W. Washington St., Ste. 2200 Chicago, IL 60606 Phone: (219) 769-1313 {File: 00745687.DOCX}

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