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    Exhibit - '1C: Case No.: 10 CH 53201

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    ChicagoCitizens EmpowermentGroup
    This document is a motion for summary judgment filed in the Circuit Court of Cook County, Illinois. It seeks summary judgment against defendants Alfredo Castillo and Beatris Castillo in a mortgage foreclosure case. The motion argues that the defendants failed to adequately answer interrogatories and document requests regarding payments made under the note and mortgage. It also references an affidavit of proof being filed contemporaneously. The plaintiff argues they are entitled to summary judgment based on the defendants' failure to respond to discovery requests regarding their defenses.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Exhibit - '1C: Case No.: 10 CH 53201

    Uploaded by

    ChicagoCitizens EmpowermentGroup
    73 views4 pages
    This document is a motion for summary judgment filed in the Circuit Court of Cook County, Illinois. It seeks summary judgment against defendants Alfredo Castillo and Beatris Castillo in a mortgage foreclosure case. The motion argues that the defendants failed to adequately answer interrogatories and document requests regarding payments made under the note and mortgage. It also references an affidavit of proof being filed contemporaneously. The plaintiff argues they are entitled to summary judgment based on the defendants' failure to respond to discovery requests regarding their defenses.

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    motion for summary judgment sample

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    75 080612 p mtn for summary judgment

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    This document is a motion for summary judgment filed in the Circuit Court of Cook County, Illinois. It seeks summary judgment against defendants Alfredo Castillo and Beatris Castillo in a mortgage foreclosure case. The motion argues that the defendants failed to adequately answer interrogatories and document requests regarding payments made under the note and mortgage. It also references an affidavit of proof being filed contemporaneously. The plaintiff argues they are entitled to summary judgment based on the defendants' failure to respond to discovery requests regarding their defenses.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    73 views4 pages

    Exhibit - '1C: Case No.: 10 CH 53201

    Uploaded by

    ChicagoCitizens EmpowermentGroup
    This document is a motion for summary judgment filed in the Circuit Court of Cook County, Illinois. It seeks summary judgment against defendants Alfredo Castillo and Beatris Castillo in a mortgage foreclosure case. The motion argues that the defendants failed to adequately answer interrogatories and document requests regarding payments made under the note and mortgage. It also references an affidavit of proof being filed contemporaneously. The plaintiff argues they are entitled to summary judgment based on the defendants' failure to respond to discovery requests regarding their defenses.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 4

    ATTORNEY NO.

    51207

    IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


    CHANCERY DEPARTMENT, FIRST DISTRICT

    THOMAS PEREZ,

    Plaintiff,

    v. Case No.: 10 CH 53201 \

    ALREDO CASTILLO AND BEATRIS


    CASTILLO ; CITY OF CHICAGO
    DEPARTMENT OF WATER
    MANAGEMENT; CITY OF CHICAGO;
    MARIA VASQUEZ; UNKNOWN OWNERS
    AND NON-RECORD CLAIMANTS,

    Defendants.

    NOTICE OF MOTION

    To: Mr. Jeffrey D. Javors CITY OF CHICAGO MARIA VASQUEZ


    111 W. Washington Street do Dept. of Law 5743 S. KENNETH
    Suite 1240 121 N. LaSalle Street Chicago, IL 60629
    Chicago, IL 60602 Room 600 - City Hall
    Chicago, Illinois 60602

    PLEASE TAKE NOTICE that on August Zig , 2012 at 9:30 a.m. or as soon

    thereafter as counsel may be heard, I shall appear before the Honorable Presiding

    Judge Darryl B. Simko or any judge sitting in his stead, in Room 2806, Richard J. Daley

    Center, 50 West Washington Street, Chicago, Illinois, and present the attached

    Motions for Default, for Summary Judgment, and to Appoint Selling Officer

    I, Michael B. Elman, certify that I served this notice a d motion by mailing a copy

    to the above named individual(s) at the address(es) ind ed on , 2012_

    Michael B. Elman, Attorney for Plaintiff


    Michael B. Elman & Associates, Ltd.
    10 South LaSalle Street, Suite 1420
    Chicago, Illinois 60603
    (312) 541-0903 DEFENDANT CASTILLO
    Attorney No.: 51207 MOTION TO VACATE
    53201
    JUDGMENT - 2010CH

    EXHIBIT - '1c
    ATTORNEY NO. 51207

    IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS


    COUNTY DEPARTMENT, CHANCERY DIVISION
    '45=
    THOMAS PEREZ,
    ')
    0 op
    Plaintiff,
    0 12"
    --` ?•D
    v. Case No.: 10 CH 53201. a3 cc>
    •
    ALREDO CASTILLO AND BEATRIS
    CASTILLO ; CITY OF CHICAGO
    DEPARTMENT OF WATER
    MANAGEMENT; CITY OF CHICAGO;
    MARIA VASQUEZ; UNKNOWN OWNERS
    AND NON-RECORD CLAIMANTS,

    Defendants.

    MOTION FOR SUMMARY JUDGMENT AGAINST


    ALFREDO CASTILLO AND BEATRIS CASTILLO

    Plaintiff, THOMAS
    THOMAS PEREZ, through his attorney, MICHAEL B. ELMAN &

    ASSOCIATES, LTD., moves this Court, pursuant to Illinois Code of Civil Procedure,

    Section 5/2-1005, for Motion for Summary Judgment against Alfredo Castillo and

    Beatris Castillo and, pursuant to the Illinois Mortgage Foreclosure Law, Section 5/2-

    1506(a) for entry of a judgment of foreclosure and sale. In support thereof, Plaintiff

    states as follows:

    1. Plaintiff initiated this proceeding on December 16, 2010 by filing a

    Complaint to Foreclose Mortgage (a copy of the complaint is attached hereto as Exhibit


    2. On November 17, 2011 Defendants filed their Amended Answer (a copy

    thereof is attached hereto as Exhibit 2). 1

    3. In their Amended Answer, Defendants neither admit nor deny paragraphs

    1, 2, 3(e), (f), (g), (j), (p), (q), 5 and 6. Defendants deny paragraphs 3(b), (c), (I), (n), (o)

    and 7.

    4. On about March 27, 2012 Defendants were served with Plaintiff's First Set

    of Interrogatories. Interrogatory number 4 asked Defendants to state all facts

    supporting their denials of the paragraphs in the complaint described above.

    Interrogatory number 5 asked Defendants to identify all facts supporting Defendants'

    inability to answer the paragraphs wherein they deny knowledge. Interrogatory number

    6 asked Defendants to identify all payments made under the Note and Mortgage.

    Defendants have never answered these interrogatories.

    5. On or about March 27, 2012 Defendants were served with Plaintiff's First

    Request for Production of Documents. Request number 4 sought Defendants'

    documents relating to payments made under the Note and Mortgage. Defendants have

    not produced any documents establishing the payments they purportedly made under

    the Mortgage and Note.

    6. Contemporaneously with the filing of this motion, Plaintiff has filed an

    Affidavit of Prove-Up pursuant to Section 5/15-1506 of the Illinois Mortgage Foreclosure

    Law.

    7. Accordingly, Plaintiff is entitled to summary judgment with respect to

    Alfredo Castillo and Beatris Castillo.

    1 The Amended Answer contained affirmative defenses which were dismissed by the Court on March 22.

    2012.

    2
    WHEREFORE, Plaintiff, THOMAS PEREZ, respectfully requests that the Court

    enter an order for summary judgment against Defendants Alfredo Castillo and Beatris

    Castillo and for the relief sought in the complaint and entry of judgment of foreclosure

    and sale.

    /
    Resped .1Iy sub fitted,

    MICHAEL B. ELMAN, Attorney for Plaintiff

    Michael B. Elman & Associates, Ltd.


    10 South LaSalle Street, Suite 1420
    Chicago, Illinois 60603
    (312) 541-0903
    Attorney No. 51207

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