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)

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: [phone]
{File: 00745687.DOCX}