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foreclosure, if sought: Pursuant to 735 ILCS 5/12-101 and 735 ILCS 5/12-122,
the redemption period shall expire six (6) months from the date of sale.
q. Statement that the right of redemption has been waived by all owners of
redemption, if applicable: Not applicable.
r. Facts in support of request for attorneys' fees and of costs and expenses if
applicable: Pursuant to 735 ILCS 5/12-112 and 735 ILCS 5/12-205, the Plaintiff
is entitled to recover her court costs, statutory interest, title costs, attorney fees
and other expenses in prosecuting this action.
s. Facts in support of a request for appointment of mortgagee in possession or for
appointment of receiver, and identity of such receiver, if sought: Plaintiff
reserves the right to file a separate petition for appointment of agent of possession
or receiver, as applicable.
t. Offer to mortgagor in accordance in accordance with Section 15-1402 to accept
title to the real estate in satisfaction of all indebtedness and obligations secured by
the mortgage without judicial sale, if sought: No allegation of such an offer is
made however Plaintiff alleges that it is not precluded from making or accepting
such offer by the filing of the instant foreclosure action.
u. Name or names of defendants whose right to possess the mortgaged real estate,
after the confirmation of a foreclosure sale, are sought to be terminated and, if not
elsewhere stated, the facts in support thereof:
4. Plaintiff avers that in addition to persons designated by name herein and the Unknown
Defendants herein before referred to, there are other persons, and/or non-record claimants
who are interested in this action and who have or claim some right, title, interest or lien in,
to or upon the real estate, or some part thereof, in this Complaint described, including but
not limited to the following:
That the name of each of such persons is unknown to Plaintiff and on diligent inquiry
cannot be ascertained, and all such persons are therefore made party defendants to this
action by the name and description of UNKNOWN OWNERS and NONRECORD
CLAIMANTS.
5. That should a deficiency result from the foreclosure sale of the subject property, Plaintiff
may seek a deficiency judgment.
WHEREFORE, THE PLAINTIFF REQUESTS THE FOLLOWING:
(i) A judgment of foreclosure and sale.