MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE

JAMES HOLDERMAN, District Judge.

NOW COMES the Plaintiff, WELLS FARGO BANK, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO WELLS FARGO BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR MERRILL LYNCH MORTGAGE INVESTORS TRUST, MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2003-HE1, by and through its attorney, Megan Christine Adams, and moves this Honorable Court for Entry of Judgment of Foreclosure. In support thereof, Plaintiff states as follows:

WHEREFORE, Plaintiff respectfully requests that its Motion for Entry of Judgment of Foreclosure be Granted, that this Court enter a judgment of foreclosure in favor of Plaintiff, enter an award of $276,818.88 as of September 25, 2013, with interest accruing on the unpaid principal balance at $45.85 per day, plus attorney's fees and foreclosure costs of $1,447.50, incurred by the Plaintiff as a result of the foreclosure, and all other relief just and proper.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS NORTHERN DIVISION

AFFIDAVIT OF AMOUNT DUE AND OWING

I, Nicole Boutin, am a Contract Management Coordinator of Ocwen Loan Servicing, LLC (hereinafter referred to as Servicer). I have personal knowledge of the facts stated herein and if called to testify as a witness, I would testify consistent with the facts stated herein. I am authorized to provide this Affidavit on behalf of Ocwen Loan Servicing, LLC. The Servicer currently services a loan on behalf of the Plaintiff that originated on 04/16/2003 in the original amount of $243,000.00 that was recorded with the COOK County Recorder of Deeds on 5/29/2003 as document number 0314902041 and that is secured by the property commonly known as 5320 N Sheridan Road Unit 2102 Chicago, IL 60640 (hereinafter the "Subject Loan"). In the ordinary course of my employment as a Contract Management Coordinator, my responsibilities include reviewing and analyzing the business and loan records for loans that the Servicer services. I am familiar with the Servicer's books and records including records concerning loans the Servicer services. In the ordinary course of business, the Servicer maintains business records and a loan file for each loan that it services, containing among other things, a loan payment history, and computer generated records. I have access to said records as a function of my employment. I have reviewed and am familiar with the business records of the Subject Loan in connection with executing this affidavit, including but not limited to the records referenced above. I have knowledge that the records kept with respect to any mortgage loan are comprised of entries made at or near the time of the event or occurrence by persons trained and authorized to make such entries.

Servicer acquired the servicing rights for the Defendant's loan on 11/01/2011 from Litton Loan Servicing LP. At the time of this transfer, the Defendant's loan was in default.

The amount due is based on my review of the following records: payment history and other electronic records concerning the subject mortgage loan. A true and accurate copy of the payment history and any other document I reviewed when making this calculation is attached to this affidavit.

Servicer uses "Real Servicing" to automatically record and track mortgage payments. This type of tracking and accounting program is recognized as standard in the industry. When a mortgage payment is received, the following procedure is used to process and apply the payment, and to create the records I reviewed:

A. Authorized persons receive and credit periodic payments at or near the time of the receipt of the payment. The sources of the payments include personal checks, cashier's checks, and/or money orders; Automated Clearing House ("ACH") withdrawals from the Defendant's bank account; and/or telephonic payments.

B. Servicer utilizes its computer systems which are accessible and used by authorized persons to input and record account activity at or near the event or occurrence. The computer system automatically dates the entries when made. It is servicer's regular practice to make such records.

C. The record identifies the transaction type. If the record relates to the application of a payment or disbursement it will itemize the amounts applied. The computer system will then automatically calculate running account totals in order that all account balances can be accurately reproduced.

The records that I reviewed are made in the regular course of servicer's business. In the case at bar, the entries reflecting the Defendant's payments were made in accordance with the procedure detailed above, and these entries were made at or near the time that the payment was received. "Real Servicing" (name of the computer program/software) accurately records mortgage payments when properly operated. Based on the foregoing, in the case at bar, "Real Servicing" (name of the computer program/software) was properly operated to accurately record the Defendant's mortgage payments.

Based on the foregoing, Jonathan Renkas failed to pay amounts due under the Note, and the amount due and owing as of 09/25/2013 is: