MOTION FOR JUDGMENT OF FORECLOSURE AND SALE

NOW COMES the Plaintiff, PNC Bank, National Association, successor to National City Bank, successor in interest to Mid America Bank, fsb, by its attorneys Crowley & Lamb, P.C., and moves the Court for the entry of a Judgment of Foreclosure and Sale in its favor and against the Defendant(s):

and as grounds thereof state:

As appears from the Affidavit of Plaintiff placed on file in support of this Motion attached hereto as Exhibit "1", and from the pleadings and admissions on file, there is no genuine issue as to any material fact, and the Plaintiff is entitled to a Judgment of Foreclosure and Sale in this case as a matter of law.

EXHIBIT 1

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

AFFIDAVIT OF MORTGAGEE IN SUPPORT OF THE MOTION FOR JUDGMENT OF FORECLOSURE AND SALE

I, Jeffrey Claerr, being first duly sworn on oath deposes and states that if sworn as a witness would testify as follows:

1. I have personal knowledge of the facts stated in this Affidavit and if sworn as a witness I could testify competently thereto.

2. I am an Assistant Vice President of PNC Bank, National Association, successor to National City Bank, successor in interest to Mid America Bank, fsb, ("Plaintiff" or "PNC"). As part of my duties with Plaintiff, I oversee and manage certain loan accounts of Plaintiff including this subject loan. In such capacity I am familiar with the books and records of the Plaintiff; I have personally examined same; and I am duly authorized to make this Affidavit on behalf of the Plaintiff.

3. This Affidavit is made pursuant to 735 ILCS 5/15-1506(a) for the purpose of proving and verifying the facts alleged in the Complaint herein.

4. I am familiar with the instruments to be foreclosed: a Mortgage executed by Teresa Orozco ("Borrower") on May 9, 2006, as Mortgagor, in favor of Plaintiff, as Mortgagee, and recorded against the Property commonly known as 1515-1519 N. Mannheim Road, Stone Park, Illinois 60165 (the Property") to secure a loan in the sum of $600,000.00 as evidenced by a Promissory Note executed by Borrower in favor of Plaintiff on May 9, 2006 (the "Note"). Copies of the Note and Mortgage are attached to Plaintiff Complaint as Exhibits B and C.

5. PNC Bank, National Association, successor to National City Bank, successor in interest to Mid America Bank, fsb, is the legal holder of the Note and the Mortgage given as security therefore.

6. The real estate conveyed by the Mortgage was fee simple.

7. I am familiar with the books of original entry and accounts maintained by PNC Bank, National Association, successor to National City Bank, successor in interest to Mid America Bank, fsb, for the collection due on the Note.

8. I am familiar with the current status of the mortgage account.

9. A default occurred due to Borrower's failure to make the monthly installment payments due under the Note for April of 2014 and thereafter, and failure to pay the 2011, 2012, and 2013 real estate taxes under the terms of the Note.

10. By reason of these defaults Plaintiff has elected to accelerate the debt thereby claiming the entire balance due under the terms of the Note and Mortgage and authorized the filing of this foreclosure suit.

11. These defaults have not been cured under the provisions of Section 15-1602 of the Illinois Mortgage Foreclosure Law (735 ILCS 5/15-1602).

12. Attached hereto as Exhibits A, B, and C are true and correct copies of the Mortgage, Note, and the Loan History relied upon by affiant in making this affidavit.

13. The Loan History is generated by a computer system that is used by PNC to track payments made towards accounts, interest calculations for amounts due and owing on accounts, update balances due on accounts and in order to track, maintain and calculate all amounts due and owing on any PNC account. The computer program, entitled Advanced Commercial Banking System ("Computer Program"), has been used by Plaintiff for a number of years in the regular course of its business.

14. Programs similar to the Computer Program used by PNC are customarily used in the banking industry.

15. The Computer Program is periodically checked for reliability.

16. The Computer Program has always been found to be both accurate and reliable in calculating the amounts due and owing on any PNC account.

17. When payments towards accounts are received by PNC, employees of PNC credit said payments to the appropriate accounts. In the same manner, when charges are made against an account, employees of PNC debit the appropriate accounts.

18. This payment and debit information entered into the computer program is set forth in the Loan History. It is entered into the computer program in the ordinary course of business by PNC and it details all of the transactions that occur relating to the specific account for the history of the account.

19. It is the regular course of business for PNC to make the memoranda set forth in said Loan History at the time of its occurrence or within a reasonable time thereafter, Further, the memoranda are not made in anticipation of litigation.

20. When Mid America Bank, fsb merged with National City Bank, it was National City's standard procedure to transfer the loan balances and records from all Mid America Bank's loan accounts to National City Bank's loan records. Further, when National City Bank merged with PNC, it was PNC's standard procedure to transfer the loan balances and records from all National City loan accounts to PNC's loan records. As such, PNC has integrated and relies upon the records of Mid America Bank, fsb and National City Bank.

21. It is the Loan History and the records set forth therein upon which I relied in making this Affidavit on behalf of PNC.

22. There is due and owing to the Plaintiff the following amounts:

WHEREFORE, affiant further sayeth naught.

EXHIBIT A