Preview
Hearing Date: 8/12/2024 9:15 AM
Location: Court Room 2810
Judge: Wright, James A
FILED
6/13/2024 3:14 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
2024CH05582
Calendar, 64
28109389
Cook County #21762
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT - CHANCERY DIVISION
Seattle Bank
PLAINTIFF
Vs. No. 2024CH05582
Marilyn D. Bridges; Unknown Heirs and Legatees of
Rose Ross; United States of America - Secretary of 60 E 161st Pl, South Holland, IL 60473
Housing and Urban Development; Village of South
Holland; Unknown Owners and Nonrecord Claimants
DEFENDANTS
COMPLAINT TO FORECLOSE MORTGAGE
NOW COMES the Plaintiff, SEATTLE BANK, by and through its attorneys, CODILIS & ASSOCIATES, P.C.,
complaining of the defendants herein and, pursuant to 735 ILCS 5/15-1101, states as follows:
1. Plaintiff files this Complaint to Foreclose the mortgage, trust deed or other conveyance in the nature of a
mortgage (hereinafter called "Mortgage") hereinafter described, and joins the following persons as "Defendants":
Marilyn D. Bridges; Unknown Heirs and Legatees of Rose Ross; United States of America - Secretary of Housing
and Urban Development; Village of South Holland; Unknown Owners and Nonrecord Claimants
2. Attached as "EXHIBIT A" is a copy of the Mortgage (Home Equity Conversion Mortgage). Attached as
''EXHIBIT B'' is a copy of the Fixed Rate Note (Home Equity Conversion Mortgage). Attached as "EXHIBIT C"
is a copy of the Corporation Assignment of Mortgage. Attached as "EXHIBIT D" is a copy of the Corporation
Assignment of Real Estate Mortgage. Attached as "EXHIBIT E" is a copy of the Corporation Assignment of
Mortgage. Attached as "EXHIBIT F" is a copy of the Assignment of Mortgage.
3. Information concerning said Mortgage:
(A) Nature of the instrument: Mortgage.
(B) Date of the Mortgage: 4/22/2008
(C) Name of mortgagor(s):
Rose Ross executed the mortgage, however this individual is deceased and is not named as a defendant
in this lawsuit
(D) Name of the original mortgagee:
First Reverse Financial Services, LLC a subsidiary of Family Federal Savings of Illinois
(E) Date and Place of Recording or Registering:
5/8/2008
Office of the Recorder of Deeds of Cook County Illinois
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
(F) Identification of Recording: Document No. 0812933052
(G) Interest subject to the mortgage: Fee Simple.
(H) Amount of original indebtedness:
(1) Original Indebtedness: $264,000.00maximum balance
(I) Both the legal description of the mortgaged real estate and the common address or other information
sufficient to identify it with reasonable certainty:
LOT 36 IN DEBOER'S SUBDIVISION BEING A SUBDIVISION OF PART OF THE WEST HALF OF
THE SOUTHWEST QUARTER OF SECTION 15, TOWNSHIP 36 NORTH, RANGE 14, EAST OF THE
THIRD PRINCIPAL MERIDIAN, IN COOK COUNTY, ILLINOIS.
COMMONLY KNOWN AS: 60 E 161st Pl, South Holland, IL 60473
TAX PARCEL NUMBER: 29-15-310-007-0000
(J) Statement as to defaults: The loan is accelerated and due and payable upon the death of the borrower
and the borrower is deceased as of 10/02/2015. Principal balance due on the Note and the Mortgage is
$502,880.58 as of 3/13/2024. Interest accrues pursuant to the note, and the current per diem is $97.85.
(K) Name of present owner(s) of said premises:
Marilyn D. Bridges
Unknown Heirs and Legatees of Rose Ross
(L) Names of other persons who are joined as defendants and whose interest in or lien on the mortgaged real
estate is sought to be terminated and alleged to be subordinate and inferior to the mortgage of the Plaintiff,
and any additional lien of the plaintiff which is sought to be terminated:
Unknown Heirs and Legatees of Rose Ross, by virtue of the fact that, upon information and belief, Rose
Ross is deceased. The name(s) of said unknown heirs and legatees is not known to the Plaintiff;
United States of America - Secretary of Housing and Urban Development, by virtue of a Mortgage executed
by Rose Ross, dated 4/22/2008, and Recorded/registered on 5/08/2008 in the office of the
Recorder/Registrar of Deeds of Cook County, Illinois, as Document No. 0812933054, to secure a note in the
principal sum of $264,000.00;
Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $339.04
and recorded on 10/196/2017 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as
Document No. 1729257222, for waterworks system. Plaintiff alleges that the interest of this defendant is
inferior and subordinate to its mortgage.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 31633, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 11/30/2018 as Document No. 1833447041 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 30987 and 31995, in the Circuit Court of Cook County, Illinois, and filed in
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 2/27/2019 as Document No.
1905847055 in the sum of $750.00 + $750.00, respectively, for total of $1500.00 + maintenance + coats.
The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 32530 and 32599, in the Circuit Court of Cook County, Illinois, and filed in
the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/26/2019 as Document No.
1908557101 in the sum of $750.00 + $750.00, respectively, for total of $1500.00 + maintenance + coats.
The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $300.0 and
recorded on 5/13/2019 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as
Document No. 1913347037, for grass cutting. Plaintiff alleges that the interest of this defendant is inferior
and subordinate to its mortgage.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 32022, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 9/26/2019 as Document No. 1926947047 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 33722, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 10/31/2019 as Document No. 1930447066 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 33166, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 02/21/2020 as Document No. 2005257092 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 34005 and 34330, in the Circuit Court of Cook County, Illinois, and filed in
the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/20/2020 as Document No.
2008057115 in the sum of $750.00 + $750.00, respectively, for a total of $1,500.00 + maintenance + coats.
The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $300.00
and recorded on 7/23/2020 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as
Document No. 2020517044, for grass cutting. Plaintiff alleges that the interest of this defendant is inferior
and subordinate to its mortgage.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 35586 and 35690, in the Circuit Court of Cook County, Illinois, and filed in
the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 11/30/2020 as Document No.
2033547178 in the sum of $500.00 + $500.00, respectively, for a total of $1,000.00 + maintenance + coats.
The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 35994, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 1/22/2021 as Document No. 2102213098 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 36066, in the Circuit Court of Cook County, Illinois, and filed in the office
of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/29/2021 as Document No. 2108825172 in
the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Ticket No. 36976 and 37278, in the Circuit Court of Cook County, Illinois, and filed in
the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 4/14/2021 as Document No.
2110404030 in the sum of $750.00 + $1,900.00, respectively, for a total of $2,650.00 + maintenance + coats.
The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Violation No. BC1803, in the Circuit Court of Cook County, Illinois, and filed in the
office of the Recorder/Registrar of Deeds of Cook County, Illinois on 10/04/2021 as Document No.
2127704008 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to
that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Violation No. BC2473 and BC2594, in the Circuit Court of Cook County, Illinois, and
filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 1/14/2022 as Document
No. 2201416034 in the sum of $750.00 + $750.00, respectively, for a total of $1,500.00 + maintenance +
coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Violation No. BC3417 and BC3505, in the Circuit Court of Cook County, Illinois, and
filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 4/26/2022 as Document
No. 2211642009 in the sum of 810.00 + $810.00, respectively, for a total of $1,620.00 + maintenance +
coats. The interest of this Defendant is subordinate to that of Plaintiff.
Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject
property, rendered in Violation No. BC4223, in the Circuit Court of Cook County, Illinois, and filed in the
office of the Recorder/Registrar of Deeds of Cook County, Illinois on 7/01/2022 as Document No.
2218233050 in the sum of 810.00 + maintenance + coats. The interest of this Defendant is subordinate to
that of Plaintiff.
Marilyn D. Bridges, by virtue of the fact that, upon information and belief, he/she is believed to be an Heir
of Rose Ross, deceased, and may have some interest in the subject real estate; the interest, if any, of Marilyn
D. Bridges is subordinate and inferior to the interest of the Plaintiff herein.
(M) Names of defendants claimed to be personally liable for deficiency, if any:
None.
(N) Capacity in which Plaintiff brings this foreclosure: Plaintiff is the Mortgagee under 735 ILCS 5/15-
1208. On information and belief the Note has been lost.
(O) Facts in support of a redemption period shorter than the longer of 7 months from the date the mortgagor
or, if more than one, all the mortgagors have been served with summons or by publication or have otherwise
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
submitted to the jurisdiction of the court, or 3 months from the entry of the judgment of foreclosure,
whichever is later, if sought:
The redemption period shall be determined pursuant to 735 ILCS 5/15-1603.
(P) Statement that the right of redemption has been waived by all owners of redemption: There has been no
executed waiver of redemption by all owners of redemption, however Plaintiff alleges that it is not precluded
from accepting such a waiver of redemption by the filing of this complaint.
(Q) Facts in support of request for attorneys' fees and of costs and expenses, if applicable: The subject
mortgage provides for payment of attorney fees, court costs, and expenses in the event of a default under the
mortgage.
(R) Facts in support of a request for appointment of mortgagee in possession or for appointment of a
receiver, and identity of such receiver, if sought: Unless otherwise alleged, Plaintiff will pray for said relief
after the filing of the instant foreclosure action by separate petition if such relief is sought.
(S) Offer to the mortgagor 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
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.
(T) Name or names of defendants whose rights 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:
Marilyn D. Bridges;
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:
Unknown Owners and NonRecord Claimants, if any.
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.
REQUEST FOR RELIEF
WHEREFORE, THE PLAINTIFF REQUESTS:
(i) A judgment of foreclosure and sale.
(ii) An order granting a shortened redemption period, if sought.
(iii) An order granting possession, if sought.
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
(iv) An order placing the mortgagee in possession or appointing a receiver, if sought.
(v) A judgment for attorneys' fees, costs and expenses, if sought.
(vi) For the appointment of a Selling Officer, if deemed appropriate by this court.
(vii) Such other and further relief as this court deems just.
Seattle Bank
BY: /s/ Matthew Naglewski
ARDC No. 6322722
CODILIS & ASSOCIATES, P.C.
One of its Attorneys
Codilis & Associates, P.C.
15W030 North Frontage Road, Suite 100
Burr Ridge, IL 60527
(630) 794-5300
pleadings@il.cslegal.com
Cook #21762
14-24-00908
NOTE: This law firm is a debt collector.
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
EXHIBIT C
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
EXHIBIT D
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
EXHIBIT E
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
FILED DATE: 6/13/2024 3:14 PM 2024CH05582
Preview
Hearing Date: 8/12/2024 9:15 AM Location: Court Room 2810 Judge: Wright, James A FILED 6/13/2024 3:14 PM IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 6/13/2024 3:14 PM 2024CH05582 2024CH05582 Calendar, 64 28109389 Cook County #21762 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - CHANCERY DIVISION Seattle Bank PLAINTIFF Vs. No. 2024CH05582 Marilyn D. Bridges; Unknown Heirs and Legatees of Rose Ross; United States of America - Secretary of 60 E 161st Pl, South Holland, IL 60473 Housing and Urban Development; Village of South Holland; Unknown Owners and Nonrecord Claimants DEFENDANTS COMPLAINT TO FORECLOSE MORTGAGE NOW COMES the Plaintiff, SEATTLE BANK, by and through its attorneys, CODILIS & ASSOCIATES, P.C., complaining of the defendants herein and, pursuant to 735 ILCS 5/15-1101, states as follows: 1. Plaintiff files this Complaint to Foreclose the mortgage, trust deed or other conveyance in the nature of a mortgage (hereinafter called "Mortgage") hereinafter described, and joins the following persons as "Defendants": Marilyn D. Bridges; Unknown Heirs and Legatees of Rose Ross; United States of America - Secretary of Housing and Urban Development; Village of South Holland; Unknown Owners and Nonrecord Claimants 2. Attached as "EXHIBIT A" is a copy of the Mortgage (Home Equity Conversion Mortgage). Attached as ''EXHIBIT B'' is a copy of the Fixed Rate Note (Home Equity Conversion Mortgage). Attached as "EXHIBIT C" is a copy of the Corporation Assignment of Mortgage. Attached as "EXHIBIT D" is a copy of the Corporation Assignment of Real Estate Mortgage. Attached as "EXHIBIT E" is a copy of the Corporation Assignment of Mortgage. Attached as "EXHIBIT F" is a copy of the Assignment of Mortgage. 3. Information concerning said Mortgage: (A) Nature of the instrument: Mortgage. (B) Date of the Mortgage: 4/22/2008 (C) Name of mortgagor(s): Rose Ross executed the mortgage, however this individual is deceased and is not named as a defendant in this lawsuit (D) Name of the original mortgagee: First Reverse Financial Services, LLC a subsidiary of Family Federal Savings of Illinois (E) Date and Place of Recording or Registering: 5/8/2008 Office of the Recorder of Deeds of Cook County Illinois FILED DATE: 6/13/2024 3:14 PM 2024CH05582 (F) Identification of Recording: Document No. 0812933052 (G) Interest subject to the mortgage: Fee Simple. (H) Amount of original indebtedness: (1) Original Indebtedness: $264,000.00maximum balance (I) Both the legal description of the mortgaged real estate and the common address or other information sufficient to identify it with reasonable certainty: LOT 36 IN DEBOER'S SUBDIVISION BEING A SUBDIVISION OF PART OF THE WEST HALF OF THE SOUTHWEST QUARTER OF SECTION 15, TOWNSHIP 36 NORTH, RANGE 14, EAST OF THE THIRD PRINCIPAL MERIDIAN, IN COOK COUNTY, ILLINOIS. COMMONLY KNOWN AS: 60 E 161st Pl, South Holland, IL 60473 TAX PARCEL NUMBER: 29-15-310-007-0000 (J) Statement as to defaults: The loan is accelerated and due and payable upon the death of the borrower and the borrower is deceased as of 10/02/2015. Principal balance due on the Note and the Mortgage is $502,880.58 as of 3/13/2024. Interest accrues pursuant to the note, and the current per diem is $97.85. (K) Name of present owner(s) of said premises: Marilyn D. Bridges Unknown Heirs and Legatees of Rose Ross (L) Names of other persons who are joined as defendants and whose interest in or lien on the mortgaged real estate is sought to be terminated and alleged to be subordinate and inferior to the mortgage of the Plaintiff, and any additional lien of the plaintiff which is sought to be terminated: Unknown Heirs and Legatees of Rose Ross, by virtue of the fact that, upon information and belief, Rose Ross is deceased. The name(s) of said unknown heirs and legatees is not known to the Plaintiff; United States of America - Secretary of Housing and Urban Development, by virtue of a Mortgage executed by Rose Ross, dated 4/22/2008, and Recorded/registered on 5/08/2008 in the office of the Recorder/Registrar of Deeds of Cook County, Illinois, as Document No. 0812933054, to secure a note in the principal sum of $264,000.00; Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $339.04 and recorded on 10/196/2017 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as Document No. 1729257222, for waterworks system. Plaintiff alleges that the interest of this defendant is inferior and subordinate to its mortgage. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 31633, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 11/30/2018 as Document No. 1833447041 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 30987 and 31995, in the Circuit Court of Cook County, Illinois, and filed in FILED DATE: 6/13/2024 3:14 PM 2024CH05582 the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 2/27/2019 as Document No. 1905847055 in the sum of $750.00 + $750.00, respectively, for total of $1500.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 32530 and 32599, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/26/2019 as Document No. 1908557101 in the sum of $750.00 + $750.00, respectively, for total of $1500.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $300.0 and recorded on 5/13/2019 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as Document No. 1913347037, for grass cutting. Plaintiff alleges that the interest of this defendant is inferior and subordinate to its mortgage. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 32022, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 9/26/2019 as Document No. 1926947047 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 33722, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 10/31/2019 as Document No. 1930447066 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 33166, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 02/21/2020 as Document No. 2005257092 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 34005 and 34330, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/20/2020 as Document No. 2008057115 in the sum of $750.00 + $750.00, respectively, for a total of $1,500.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Claim for Lien against subject property in the amount of $300.00 and recorded on 7/23/2020 in the Office of the Recorder/Registrar of Deeds of Cook County, Illinois, as Document No. 2020517044, for grass cutting. Plaintiff alleges that the interest of this defendant is inferior and subordinate to its mortgage. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 35586 and 35690, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 11/30/2020 as Document No. 2033547178 in the sum of $500.00 + $500.00, respectively, for a total of $1,000.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 35994, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 1/22/2021 as Document No. 2102213098 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. FILED DATE: 6/13/2024 3:14 PM 2024CH05582 Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 36066, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 3/29/2021 as Document No. 2108825172 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Ticket No. 36976 and 37278, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 4/14/2021 as Document No. 2110404030 in the sum of $750.00 + $1,900.00, respectively, for a total of $2,650.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Violation No. BC1803, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 10/04/2021 as Document No. 2127704008 in the sum of $750.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Violation No. BC2473 and BC2594, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 1/14/2022 as Document No. 2201416034 in the sum of $750.00 + $750.00, respectively, for a total of $1,500.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Violation No. BC3417 and BC3505, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 4/26/2022 as Document No. 2211642009 in the sum of 810.00 + $810.00, respectively, for a total of $1,620.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Village of South Holland, by virtue of a Memorandum of Findings, Decision, and Order against subject property, rendered in Violation No. BC4223, in the Circuit Court of Cook County, Illinois, and filed in the office of the Recorder/Registrar of Deeds of Cook County, Illinois on 7/01/2022 as Document No. 2218233050 in the sum of 810.00 + maintenance + coats. The interest of this Defendant is subordinate to that of Plaintiff. Marilyn D. Bridges, by virtue of the fact that, upon information and belief, he/she is believed to be an Heir of Rose Ross, deceased, and may have some interest in the subject real estate; the interest, if any, of Marilyn D. Bridges is subordinate and inferior to the interest of the Plaintiff herein. (M) Names of defendants claimed to be personally liable for deficiency, if any: None. (N) Capacity in which Plaintiff brings this foreclosure: Plaintiff is the Mortgagee under 735 ILCS 5/15- 1208. On information and belief the Note has been lost. (O) Facts in support of a redemption period shorter than the longer of 7 months from the date the mortgagor or, if more than one, all the mortgagors have been served with summons or by publication or have otherwise FILED DATE: 6/13/2024 3:14 PM 2024CH05582 submitted to the jurisdiction of the court, or 3 months from the entry of the judgment of foreclosure, whichever is later, if sought: The redemption period shall be determined pursuant to 735 ILCS 5/15-1603. (P) Statement that the right of redemption has been waived by all owners of redemption: There has been no executed waiver of redemption by all owners of redemption, however Plaintiff alleges that it is not precluded from accepting such a waiver of redemption by the filing of this complaint. (Q) Facts in support of request for attorneys' fees and of costs and expenses, if applicable: The subject mortgage provides for payment of attorney fees, court costs, and expenses in the event of a default under the mortgage. (R) Facts in support of a request for appointment of mortgagee in possession or for appointment of a receiver, and identity of such receiver, if sought: Unless otherwise alleged, Plaintiff will pray for said relief after the filing of the instant foreclosure action by separate petition if such relief is sought. (S) Offer to the mortgagor 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 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. (T) Name or names of defendants whose rights 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: Marilyn D. Bridges; 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: Unknown Owners and NonRecord Claimants, if any. 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. REQUEST FOR RELIEF WHEREFORE, THE PLAINTIFF REQUESTS: (i) A judgment of foreclosure and sale. (ii) An order granting a shortened redemption period, if sought. (iii) An order granting possession, if sought. FILED DATE: 6/13/2024 3:14 PM 2024CH05582 (iv) An order placing the mortgagee in possession or appointing a receiver, if sought. (v) A judgment for attorneys' fees, costs and expenses, if sought. (vi) For the appointment of a Selling Officer, if deemed appropriate by this court. (vii) Such other and further relief as this court deems just. Seattle Bank BY: /s/ Matthew Naglewski ARDC No. 6322722 CODILIS & ASSOCIATES, P.C. One of its Attorneys Codilis & Associates, P.C. 15W030 North Frontage Road, Suite 100 Burr Ridge, IL 60527 (630) 794-5300 pleadings@il.cslegal.com Cook #21762 14-24-00908 NOTE: This law firm is a debt collector. FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 EXHIBIT C FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 EXHIBIT D FILED DATE: 6/13/2024 3:14 PM 2024CH05582 EXHIBIT E FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582 FILED DATE: 6/13/2024 3:14 PM 2024CH05582