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Deutsche Bank National Trust Company, As Trustee Under Pooling v. Edward Grossman

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


February 28, 2012

DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER POOLING AND SERVICING AGREEMENT DATED AS OF JANUARY 1, 2006 MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-NC1
PLAINTIFF
v.
EDWARD GROSSMAN, AS SPECIAL REPRESENTATIVE FOR THE ESTATE OF LAMUEL JACKSON, PEOPLES GAS LIGHT AND COKE CO, RUSH PRESBYTERIAN ST. LUKE`S MEDICAL CENTER,
DEFENDANT(S).

The opinion of the court was delivered by: District Judge: Amy J. St. Eve

AFFIDAVIT OF ATTORNEY'S FEES

735 ILCS 5/15-1506(a)(1)

Pursuant to 735 ILCS 5/15-1506(a)(1), the undersigned, being duly sworn, states and affirms that the following facts by way of prove-up of the complaint:

1. That he is the attorney for DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee under POOLING AND SERVICING AGREEMENT Dated as of January 1, 2006 MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-NC1.

2. That he is familiar with the material allegations of the complaint heretofore filed in the above entitled cause, and that those allegations are true in substance and in fact.

3. Pursuant to the terms of the Note and Mortgage Deed, the Mortgage-Defendant is also obligated to pay all the expenses of these foreclosure proceedings; the known expenses to date which the Plaintiff has paid, or has become obligated to pay are as follows:

a. Process Server Expense: $285.00

b. Recording Expense: $102.00

c. Court Costs: $350.00

d. Attorneys Fees: $1,000.00

e. Special Representative Fees: $500.00

4. That there are other charges which the Mortgagor-defendant is obligated to pay under the terms of said Note and Mortgage Deed, and while these charges are not definitely ascertainable at this time, provision for their payment and assessment should be made in the Judgment of Foreclosure.

5. That the premises herein are commonly known as 11630 S. Wallace Street, Chicago, IL 60628.

6. The attorney fees set forth above are reasonable for the following reasons:

a. The fee is based on the experience, reputation and ability of the lawyer or lawyers performing the services and is similar to fees customarily charged in the locality for like services; and

b. The amount at issue and the results obtained bear a reasonable relationship to the fee claimed.

Respectfully submitted,

By:

James N. Pappas

JAMES N. PAPPAS #6291873 Burke Costanza & Carberry LLP 225 W. Washington St, Suite 2200 Chicago, IL 60606 (219) 769-1313

20120228

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