EXHIBIT 14
COUNT Il - REFORMATION OF MORTGAGE 

1-3 Plamtiff realleges paragraphs 1-3 of Count I and mcorporates same herem by reference 

4 That plamtiff and defendant-borrower entered mto a mortgage contract dated 1/26/2006 

wtuch was recorded on 02/22/2006 as document number 0605346110 affectmg the property 

commonly known as 407 Beach A venue, LaGrange Park, IL 60526 

5 That due to a scnvener's error, the mortgage contained an incorrect legal descnpt1on 

6 That the correct legal descnptton for the property 1s attached as Exh1b1t C herein 

7 That 1t was plamtlff and defendant-borrower's intent to create a vahd mortgage contract 

contammg the correct legal descnpnon as referenced herem 

WHEREFORE, plamtlff prays as follows 

1 That this court enter an order refonrung the mortgage wlu 

action to correct the legal descnpt10n 

2 For such other and further rehef as this court deems J 

FREEDMAN ANSELMO LINDBERG & RAPPE LLC 

1807 W Diehl Rd Ste 333 

Napcrv1llc IL 60S66 7228 

630 983 0770 866 402 8661 

630-428-4620 (fax) 

Attorney No Cook 26122 DuPage 42005 Kane 031 26104 

Peona 1794 Winnebago 3802 IL 03126232 

Steven Lindberg 3126232 Louis Freedman 3126104 Thomas Anselmo 3125949 

Roben Rappe 6201817 Doug Ohver 6273607 Barbara Nilsen 6287524 

Clay R Mosbcrg 1972316 Vincent A Chavama 6291469 

e subJect matter of this 

CONFIDENTIAL WF_GARCIA_00003101
PRAYER 

WHEREFORE, the Pia.muff, prays as follows 

1 For foreclosure of such Mortgage, 

2 An Order grantmg a shortened redemption penod, 1f authonzed by law, 

3 For a personal def1c1ency Judgment agamst Eduardo Garcia-Munoz only, 1f sought 

4 A Judgment for attorneys' fees, costs and expenses, 

5 Such other rehef as equity may require 

ADDITIONAL REQUEST FOR RELIEF 

Plamtlff also requests that the Judgment for foreclosure or other orders entered herem provide for 

the followmg 735 ILCS 5/15-1506(t) 

1 A sale by pubhc auction 

2 A sale by open bid 

3 A Judge of tlus Court or Shenff of the County, Intercounty Juchc1al Sales or The Judicial 

Sales Corporation, shall conduct the sale 

4 Title m the real estate may be subject, at the sale, to excepttons mcludmg general real estate 

taxes for the current year and for the precedmg year which have not become due and payable 1 

as of the date of entry of the Judgment of Foreclosure, any special assessments upon the real 1 

estate, and easements and restncttons of record 

5 In the event a party to the foreclosure 1s a successful bidder at the sale, such party shall be 

allowed to offset agamst the purchase pnce to be paid for such real estate amounts due such 

party under the Judgment of Foreclosure or Order conftnrung the sale 

R250 

CONFIDENTIAL WF_GARCIA_00003102
E Date and place of recording of Mortgage February 22, 2006 m the office of the Recorder 

of Deeds or Registrar of Titles 

F Ident1ficat1on of recording 0605346110 

G Estate Conveyed Fee Simple 

H Amount of Ongmal Indebtedness, mcludmg subsequent advances made under the mortgage 

$223,000 00 

I Legal Descnpt1on and common address of Mortgaged Pretruses 

(1) Legal Descnptton SEE ATIACHED 

(2) Common Address 407 Beach Avenue, LaGrange Park, IL 60526 

(3) PIN 15-33~416-007-0000 

J Statement as to mortgage loan default 

Unpaid Pnnc1pal 

Total Balance Due 

Date of Calculation December 31, 2008 

$218,440 53 

$231,923 69 

Loan due for September 1, 2008 and a default occurred 30 days thereafter 

K Name of present owners of said prem1ses Eduardo Garcia-Munoz 

L Names of other persons who are JOtned as Defendants and whose interest m or hen on the 

mortgage real estate 1s sought to be tennmated 

1) Eduardo Garcia-Munoz, as owner(s) of the real estate foreclosed herem, 

2) Eduardo Garcia-Munoz, as mortgagor(s) of the real estate foreclosed herem, 

3) Unknown Owners and Non-Record Claimants 

M Names of persons claimed to be personally hable for deficiency Eduardo Garcia-Munoz 

N Capacity m whlch Plaintiff bnngs this sutt As "mortgagee" as that tenn 1s defined at 735 

ILCS 5/15-1208 

0 Facts m support of request for attorneys' fees and of costs and expenses, tf appltcable 

Pla.mttff has been reqwred to retam counsel for prosecunon of tlus foreclosure and to mcur 

substantial attorneys' fees, court costs, ntle msurance and other expenses which should be 

added to the balance secured by said mortgage 

P Plamttff seeks to tenrunate the nght to possess the mortgaged real estate after confinnatton 

of a foreclosure sale against all defendants who have the nght to possess the property 

CONFIDENTIAL WF_GARCIA_00003103
IN THE CIRCIDT COURT OF COOK COUNTY 

COOK COUNTY, ILLINOIS 

W08120202 

Deutsche Bank National Trust Company, as Trustee 

for Morgan Stanley 00S Real Estate Capital Trust, 

2006-1 

Plaintiff, 

vs 

Eduardo Garcia-Munoz, 

Juba E Escamda, 

Unknown Owners and Non-Record Clannants 

Defendants 

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- - j -- t - .NJ ,.i I ""f~ i l~ 11 

l ~1.lllU , ,r. Sr Ill 398 

t) ~ 07-1 ,or 

COMPLAINT TO FORECLOSE MORTGAGE :r ~rt735 ILCS 5/15-1504(a)(l) through (3)) 111:cv,: ~~~O" inn 

t 1 "' \i 

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Ju~ r -

NOW COMES the Plamt.tff, Deutsche Bank Nat10nal Trust Company, as..'f ~ti_e fof Morgan Stanley :.. ' 

IXIS Real Estate Capital Trust, 2006-1, by aad through its attorney, FREEDMAN,A1\lSEfMO l.INDBERG I <.I 

& RAPPE, LLC and complains of the above Defendants as follows : 1 "'J , ,, 

lll<'iNr, Hlll 

1 Plamtiff flies this Com pl amt to Foreclose the Mortgage heremafter descnbed and JOms the following 

2 

3 

persons as Defendants 

A Eduardo Garcia-Munoz, Juha E Escanula, 

B Plamttff avers that m add1t10n to persons designated by name herein, and the unlmown 

defendants herembefore referred to there are other persons who are mterested m this action 

and who have or clrum some nght, t:Jtle, mterest or lien m, to or upon the real estate sought 

to be foreclosed m this Complrunt, that the name of each of such other person or persons IS 

unknown to Plamttff, and on dthgent mqmry cannot be ascertamed, and all such persons are 

hereby made partles Defendants to this proceeding by the name and descnption of 

UNKNOWN OWNERS and NON-RECORD CLAilv1ANTS 

That attached hereto as Exh1b1t "A" and incorporated herein 1s a true c4py of srud W9rtgage That 

attached hereto as Exh1b1t 11B" and incorporated herem 1s a true copy of the Note sdiilred thereby 

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r- .- - c_ • , - \:,.. 

Infonnauon concerning said Mortgage attached as Exh1b1t "A11 1 =--··:; ~.: r -c - GO ~•ry 

A Nature of the Instrument Mortgage r -

B Date of the Mortgage January 26, 2006 - - -, - - ., .. ) ,._, 

C Name of the Mortgagors Eduardo Garcia-Munoz 

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2) 

Name of the Mortgagee Deutsche Bank National Trust Company, as Trustee for 

Morgan Stanley IXIS Real Estate Capital Trust, 2006-1 

Current Loan Servicer Amenca's Serv1cmg Company 

CONFIDENTIAL WF_GARCIA_00003104