IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEUTSCHE BANK NATIONAL TRUST 

COMPANY, AS TRUSTEE FOR MORGAN 

STANLEY ABS CAPITAL I INC. TRUST 

2007-NC2 MORTGAGE PASS-THROUGH 

CERTIFICATES, SERIES 2007-NC2,

Plaintiff,

-v.- 1 : 12 CV 4128

MICHAEL J. O'DONNELL; HSBC NEVADA, 

NA FKA HOUSEHOLD BANK; WEST 

SUBURBAN BANK,

JUDGE Robert W. Gettleman

Defendant

MOTION FOR JUDGMENT ON COUNTS II, III, AND IV

NOW COMES, Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS 

TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-NC2 

MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-NC2, by and through its 

attorneys, Potestivo & Associates, P.C., and moves this Honorable Court for an Order reforming 

the Mortgage, Assignment of Mortgage and Warranty Deed to include the correct the legal 

description, and in support thereof states as follows: 

1. That Plaintiff and Defendant(s) Michael J. O’Donnell entered into a mortgage contract 

dated November 10, 2006 which was recorded January 19, 2007 as document number 

R2007011941 in Will County Recorder of Deeds affecting the property commonly 

known as 32215 S. Route 53, Wilmington, IL 60481.

3. That due to a scrivener’s error, the mortgage contained an incorrect legal description. 

The incorrect legal description is:

PARCEL I: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATE ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE 100 FEET, THENCE IN 

A SOUTHEASTERLY DIRECTION AT RIGHT ANGLES TO SAID CENTER LINE 

OF THE SAID HIGHWAY, 690 FEET, THENCE SOUTHEASTERLY 100 FEET 

PARALLEL TO THE SAID HIGHWAY, THENCE NORTHWESTERLY 690 FEET 

TO THE POINT OF BEGINNING.

PARCEL II: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: COMMENCING AT THE CENTER OF 
SAID SECTION 35, THENCE WEST ALONG THE CENTER LINE 2351.2 FEET TO 

THE INTERSECTION WITH THE CENTER LINE OF THE HIGHWAY KNOWN AS 

ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE, 871 FEET TO THE POINT OF 

BEGINNING, THENCE NORTHEASTERLY ALONG THE CENTER LINE, 50 FEET, 

THENCE AT RIGHT ANGLES IN A SOUTHWESTERLY DIRECTION 50 FEET, 

THENCE AT RIGHT ANGLES IN A NORTHWESTERLY DIRECTION 690 FEET TO 

THE POINT OF BEGINNING.

PARCEL III: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS; BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, A DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE 

HIGHWAY KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES 

ROUTE 66, THENCE NORTHEASTERLY ALONG SAID CENTER LINE, 870.2 

FEET TO THE POINT OF BEGINNING, THENCE NORTHEASTERLY ALONG 

SAID HIGHWAY CENTER LINE .8 FEET, THENCE IN A SOUTHEASTERLY 

DIRECTION AT RIGHT ANGLES TO SAID CENTER LINE OF SAID HIGHWAY 

690 FEET, THENCE SOUTHWESTERLY .8 FEET PARALLEL TO THE SAID 

HIGHWAY, THENCE NORTHWESTERLY 690 FEET TO THE POINT OF 

BEGINNING, ALL IN WILL COUNTY, ILLINOIS.

4. That the correct legal description should be:

PARCEL I

THAT PART OF THE NORTHWEST 1⁄4 OF SECTION 35, IN TOWNSHIP 33 NORTH 

AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER OF SAID SECTION 35, THENCE 

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35 A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 770.2 FEET TO THE POINT 

OF BEGINNING THENCE NORTHEASTERLY ALONG SAID HIGHWAY 

CENTER LINE 100 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT 

RIGHT ANGLES TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET 

THENCE SOUTHWESTERLY 100 FEET PARALLEL TO SAID HIGHWAY, 

THENCE NORTHWESTERLY 690 FEET TO PLACE OF BEGINNING.

PARCEL II

THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN TOWNSHIP 

33 NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED 

AS FOLLOWS: COMMENCING AT CENTER OF SAID SECTION 35, THENCE 

WEST ALONG THE CENTER LINE 2351.2 FEET TO ITS INTERSECTION WITH 

THE CENTER LINE OF THE HIGHWAY KNOWN AS ILLINOIS ROUTE 4 OR 

ALTERNATE UNITED STATES ROUTE 66; THENCE NORTHEASTERLY ALONG 

SAID CENTER LINE 871 FEET TO THE PLACE OF BEGINNING; THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 50 FEET; THENCE AT RIGHT 

ANGLES IN A SOUTHEASTERLY DIRECTION 690 FEET THENCE AT RIGHT 
ANGLES IN A SOUTHWESTERLY DIRECTION, 50 FEET THENCE AT RIGHT 

ANGLES IN A NORTHWESTERLY DIRECTION 690 FEET TO THE PLACE OF 

BEGINNING.

PARCEL III

THAT PART OF THE NORTHWEST 1⁄4 OF SAID SECTION 35 TOWNSHIP 33 

NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER LINE OF SAID SECTION 35, THENCE 

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35, A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 870.2 FEET TO THE PLACE OF 

BEGINNING; THENCE NORTHEASTERLY ALONG SAID HIGHWAY CENTER 

LINE .8 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT ANGLES 

TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET, THENCE 

SOUTHWESTERLY .8 FEET PARALLEL TO SAID HIGHWAY THENCE 

NORTHWESTERLY 690 FEET TO THE POINT OF BEGINNING.

5. It was Plaintiff and Defendant(s) Michael J. O’Donnell’s intent to create a valid mortgage 

contract encumbering the correct legal description as referenced above.

6. That the Assignment of Mortgage Plaintiff seeks to reform was recorded on April 20, 

2012 in Will County Recorder of Deeds as document number R2012046194.

7. That due to a scrivener’s error, the assignment of mortgage contained an incorrect legal 

description. 

The incorrect legal description is:

PARCEL I: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATE ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE, A DISTANCE OF 

770.2 FEET TO THE POINT OF BEGINNING; THENCE NORTHEASTERLY, 

ALONG SAID HIGHWAY CENTER LINE 100 FEET, THENCE IN A 

SOUTHWESTERLY DIRECTION AT RIGHT ANGLES TO SAID CENTER LINE OF 

THE SAID HIGHWAY, 690 FEET, THENCE SOUTHWESTERLY 100 FEET 

PARALLEL TO THE SAID HIGHWAY, THENCE NORTHWESTERLY 690 FEET 

TO THE POINT OF BEGINNING.

PARCEL II: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE, 871 FEET TO THE 
POINT OF BEGINNING, THENCE NORTHEASTERLY ALONG THE CENTER 

LINE, 50 FEET, THENCE AT RIGHT ANGLES IN A SOUTHEASTERLY 

DIRECTION 690 FEET, THENCE AT RIGHT ANGLES IN A SOUTHWESTERLY 

DIRECTION 50 FEET, THENCE AT RIGHT ANGLES IN A NORTHWESTERLY 

DIRECTION 690 FEET TO THE POINT OF BEGINNING.

PARCEL III: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, A DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE 

HIGHWAY KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES 

ROUTE 66, THENCE NORTHEASTERLY ALONG SAID CENTER LINE, 870.2 

FEET TO THE POINT OF BEGINNING, THENCE NORTHEASTERLY ALONG 

SAID HIGHWAY CENTER LINE .8 FEET, THENCE IN A SOUTHEASTERLY 

DIRECTION AT RIGHT ANGLES TO SAID CENTER LINE OF SAID HIGHWAY 

690 FEET, THENCE SOUTHWESTERLY .8 FEET PARALLEL TO THE SAID 

HIGHWAY, THENCE NORTHWESTERLY 690 FEET TO THE POINT OF 

BEGINNING, ALL IN WILL COUNTY, ILLINOIS.

8. That the correct legal description should be:

PARCEL I

THAT PART OF THE NORTHWEST 1⁄4 OF SECTION 35, IN TOWNSHIP 33 NORTH 

AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER OF SAID SECTION 35, THENCE 

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35 A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 770.2 FEET TO THE POINT OF 

BEGINNING THENCE NORTHEASTERLY ALONG SAID HIGHWAY CENTER 

LINE 100 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT 

ANGLES TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET THENCE 

SOUTHWESTERLY 100 FEET PARALLEL TO SAID HIGHWAY, THENCE 

NORTHWESTERLY 690 FEET TO PLACE OF BEGINNING.

PARCEL II

THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN TOWNSHIP 

33 NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED 

AS FOLLOWS: COMMENCING AT CENTER OF SAID SECTION 35, THENCE 

WEST ALONG THE CENTER LINE 2351.2 FEET TO ITS INTERSECTION WITH

THE CENTER LINE OF THE HIGHWAY KNOWN AS ILLINOIS ROUTE 4 OR 

ALTERNATE UNITED STATES ROUTE 66; THENCE NORTHEASTERLY ALONG 

SAID CENTER LINE 871 FEET TO THE PLACE OF BEGINNING; THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 50 FEET; THENCE AT RIGHT 

ANGLES IN A SOUTHEASTERLY DIRECTION 690 FEET THENCE AT RIGHT 

ANGLES IN A SOUTHWESTERLY DIRECTION, 50 FEET THENCE AT RIGHT 

ANGLES IN A NORTHWESTERLY DIRECTION 690 FEET TO THE PLACE OF 

BEGINNING.
PARCEL III

THAT PART OF THE NORTHWEST 1⁄4 OF SAID SECTION 35 TOWNSHIP 33 

NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER LINE OF SAID SECTION 35, THENCE 

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35, A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 870.2 FEET TO THE PLACE OF 

BEGINNING; THENCE NORTHEASTERLY ALONG SAID HIGHWAY CENTER 

LINE .8 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT ANGLES 

TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET, THENCE 

SOUTHWESTERLY .8 FEET PARALLEL TO SAID HIGHWAY THENCE 

NORTHWESTERLY 690 FEET TO THE POINT OF BEGINNING.

9. That it was Plaintiff and Defendant(s) Michael J. O’Donnell’s intent to create a valid 

mortgage contract encumbering the correct legal description as referenced above.

10. That the Warranty Deed Plaintiff seeks to reform was recorded on September 15, 2005 in 

Will County Recorder of Deeds as document number R2005159186.

11. That due to a scrivener’s error, the Warranty Deed contained an incorrect legal 

description. 

The incorrect legal description is:

PARCEL I: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATE ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE, A DISTANCE OF 

770.2 FEET TO THE POINT OF BEGINNING; THENCE NORTHEASTERLY, 

ALONG SAID HIGHWAY CENTER LINE 100 FEET, THENCE IN A 

SOUTHEASTERLY DIRECTION AT RIGHT ANGLES TO SAID CENTER LINE OF 

THE SAID HIGHWAY, 690 FEET, THENCE SOUTHWESTERLY 100 FEET 

PARALLEL TO THE SAID HIGHWAY, THENCE NORTHWESTERLY 690 FEET 

TO THE POINT OF BEGINNING.

PARCEL II: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS: BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE, 871 FEET TO THE 

POINT OF BEGINNING, THENCE NORTHEASTERLY ALONG THE CENTER 

LINE, 50 FEET, THENCE AT RIGHT ANGLES IN A SOUTHEASTERLY 

DIRECTION 690 FEET, THENCE AT RIGHT ANGLES IN A SOUTHWESTERLY 
DIRECTION 50 FEET, THENCE AT RIGHT ANGLES IN A NORTHWESTERLY 

DIRECTION 690 FEET TO THE POINT OF BEGINNING.

PARCEL III: THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN 

TOWNSHIP 33 NORTH AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL 

MERIDIAN, DESCRIBED AS FOLLOWS; BEGINNING AT THE CENTER OF SAID 

SECTION 35, THENCE WEST ALONG THE EAST AND WEST CENTER LINE OF 

SAID SECTION 35, 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY 

KNOWN AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE, 870.2 FEET TO THE 

POINT OF BEGINNING, THENCE NORTHEASTERLY ALONG SAID HIGHWAY 

CENTER LINE .8 FEET, THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT 

ANGLES TO SAID CENTER LINE OF HIGHWAY 690 FEET, THENCE 

SOUTHWESTERLY .8 FEET PARALLEL TO THE SAID HIGHWAY, THENCE 

NORTHWESTERLY 690 FEET TO THE POINT OF BEGINNING, ALL IN WILL 

COUNTY, ILLINOIS.

12. That the correct legal description should be:

PARCEL I

THAT PART OF THE NORTHWEST 1⁄4 OF SECTION 35, IN TOWNSHIP 33 NORTH 

AND IN RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER OF SAID SECTION 35, THENCE

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35 A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 770.2 FEET TO THE POINT OF 

BEGINNING THENCE NORTHEASTERLY ALONG SAID HIGHWAY CENTER 

LINE 100 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT 

ANGLES TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET THENCE 

SOUTHWESTERLY 100 FEET PARALLEL TO SAID HIGHWAY, THENCE 

NORTHWESTERLY 690 FEET TO PLACE OF BEGINNING.

PARCEL II

THAT PART OF THE NORTHWEST QUARTER OF SECTION 35, IN TOWNSHIP 

33 NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED 

AS FOLLOWS: COMMENCING AT CENTER OF SAID SECTION 35, THENCE 

WEST ALONG THE CENTER LINE 2351.2 FEET TO ITS INTERSECTION 

WITH THE CENTER LINE OF THE HIGHWAY KNOWN AS ILLINOIS ROUTE 4 

OR ALTERNATE UNITED STATES ROUTE 66; THENCE NORTHEASTERLY 

ALONG SAID CENTER LINE 871 FEET TO THE PLACE OF BEGINNING; 

THENCE NORTHEASTERLY ALONG SAID CENTER LINE 50 FEET; THENCE AT 

RIGHT ANGLES IN A SOUTHEASTERLY DIRECTION 690 FEET THENCE AT 

RIGHT ANGLES IN A SOUTHWESTERLY DIRECTION, 50 FEET THENCE AT 

RIGHT ANGLES IN A NORTHWESTERLY DIRECTION 690 FEET TO THE PLACE 

OF BEGINNING.

PARCEL III
THAT PART OF THE NORTHWEST 1⁄4 OF SAID SECTION 35 TOWNSHIP 33 

NORTH RANGE 9 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS 

FOLLOWS: BEGINNING AT THE CENTER LINE OF SAID SECTION 35, THENCE 

WEST ALONG THE EAST AND WEST CENTER LINE OF SAID SECTION 35, A 

DISTANCE OF 2351.2 FEET TO THE CENTER LINE OF THE HIGHWAY KNOWN 

AS ILLINOIS ROUTE 4 OR ALTERNATE UNITED STATES ROUTE 66, THENCE 

NORTHEASTERLY ALONG SAID CENTER LINE 870.2 FEET TO THE PLACE OF 

BEGINNING; THENCE NORTHEASTERLY ALONG SAID HIGHWAY CENTER 

LINE .8 FEET THENCE IN A SOUTHEASTERLY DIRECTION AT RIGHT ANGLES 

TO SAID CENTER LINE OF SAID HIGHWAY, 690 FEET, THENCE 

SOUTHWESTERLY .8 FEET PARALLEL TO SAID HIGHWAY THENCE 

NORTHWESTERLY 690 FEET TO THE POINT OF BEGINNING.

13. That on information and belief, it was the intent of the prior owners of the property to 

transfer the property described in the above-referenced correct legal description to 

Michael J. O’Donnell.

WHEREFORE, Plaintiff prays as follows:

a. That this court enter an order reforming the mortgage, assignment of mortgage 

and warranty deed which is the subject matter of this action to correct the legal 

description, and

b. Such other and further relief as the Court deems just.

By:__/s/ Megan Christine Adams

 

Potestivo & Associates, P.C.

Megan C. Adams (ARDC# 6312221)

223 W. Jackson Blvd., Suite 610

Chicago, Illinois 60606

Telephone: (312) 263-0003

Main Fax: (312) 263-0002

Cook County Firm ID #: 43932

DuPage County Firm ID #: 223623

Attorneys for Plaintiff

Our File No.: C14-95327