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Complaint filed seeking temporary restraining order to stop Kluever and Platt LLC from collecting debts without a collection agency license.
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IN THE CIRCUIT COURT OF COOK tmU1
3. Venue for this action properly lies in Cook, County, Illinois, pursuant to Sections
2-101 and 2-1 02(a) of the Illinois Code of Civil Procedure, 735 ILCS 5/2-101,
735 lLCS 5/2- 1 02(a), in that Cook County is the county of KLUEVER'S business.
PARTIES
4. Plaintiff, THE PEOPLE OF THE STATE OF ILLfNOIS, by 09154050180000
LLC I, by its attorney CYRUS K. HOSSEfNI, is authorized to file this suit
pursuant to the ICAA, 225 ILCS 42511 et seq.
5. Defendant, KLUEVER, is an Illinois Limited Liability Company, registered with
the Illinois Secretary of State on May 29, 2001. KLUEVER'S principal office is
located at 65 E WACKER DR STE 2300 CHICAGO, Cook County, lL 6060 I.
6. For purposes of this Complaint for Injunctive and Other Relief, any references to
the acts and practices of the Defendant shall mean that such acts and practices are
by and through the acts of KLUEVER, its members, managers, owners, directors,
employees, salespersons, representatives and/or other agents.
DEFENDANT'S BUSINESS PRACTICES
7. As described below, Defendant has engaged in acts or practices that violate
Illinois Law. Defendant's conduct is ongoing and impacts many Illinois
consumers. Therefore, any examples provided of specific consumer experiences
are simply illustrations and should not be construed as the only instance in which
Illinois consumers were harmed or could potentially be harmed by Defendant.
8. Since at least July 25 , 2001, and continuing to date, KLUEVER has provided debt
collection services.
2
9. KLUEVER has filed at least 3,700 lawsuits in Cook County and other counties
since July 25, 2001 to collect on debt and/or property for others.
10. KLUEVER is not now and has never been licensed as a debt collection agency.
II. KLUEVER is not exempt because it is not a licensed attorney at law (see
Exhibit "A").
12. Filing a lawsuit to collect a debt is an "exercise [of] the right to collect" (225
ILCS 425/4). Illinois courts have repeatedly held both in cases arising under the
ICAA and otherwise, that litigation is a form of debt collection. Business Servo
Bureau V. Webster, 298 Ill. App. 3d 257 (Ill. App. Ct. 4th Dist. 1998); Petrick v.
Kaminski, 68 Ill. App. 3d 649 (Ill. App. Ct. 1 st Dist. 1979). Similarly, federal
courts applying the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
("FDCPA") ho ld that litigation is a form of debt collection. Heintz v. Jenkins, 514
U.S. 291 (U.S. 1995) ("litigating ... seems simply one way of collecting a debt");
FTC v Check Investors, Inc., 502 F.3d 159 (3rd Cir. 2007); Farber v NP Funding
II , LP, CV-96-4322 (CPS), 1997 U.S. Dist. LEXIS 21245, *15 (E.D. N.Y., Dec. 9,
1997) ("litigation is one form of debt collection"). L VNV Funding, LLC v. Trice,
952 N.E.2d 1232, 1237 (Ill. App. Ct. 1st Dist. 2011) ("IfLVNV had not
registered before it filed the complaint against Trice, it committed the crime of
engaging in debt collection").
13. KLUEVER, by filing lawsuits to collect debt, is acting as a "collection agency" as
defined in Section 2 of the ICAA (225 ILCS 425/2) .
3
Consumer Illustrations
14. The following allegations in Paragraphs 15 through 28 are pled as examples of
Defendant's unlawful business practices and are not meant to be exhaustive. The
unlawful conduct of Defendant is ongoing and continuous. Plaintiff reserves the
right to prove that consumers other than those alleged in Paragraph 15 through 28
have been injured as a result of Defendant's unlawful business practice.
A. Consumer Dragon Dobobrov
15. Dragan Dobobrov purchased a property located at 210 Cottonwood, Northbrook,
Illinois (hereinafter "Cottonwood") on December 8, 2006. Simultaneous with this
purchase, he took out a mortgage with MERS as nominee for Credit Suisse
Financial Corporation.
16. Dragan Dobobrov purchased Cottonwood primarily for personal, family, or
household purposes. It was his and his family's personal residence from the date
of purchase until the date he was evicted by KLUEVER.
17. On July 1,2008, KLUEVER filed a Complaint for Foreclosure and other Relief,
which requested a deficiency judgment in the Circuit Court of Cook County as
case number 2008 CH 23682, on behalf of U.S. Bank National Association, as
trustee, on behalf of the holders of the Adjustable Rate Mortgage Trust 2007-1 ,
Adjustable Rate Mortgage-Backed Pass-Through Certificates, Series 2007-1
(hereinafter "U.S. Bank"). (Exhibit "B").
18. By filing case 2008 CH 23682, for U.S. Bank, KLUEVER was attempting to
collect the debt while not registered as a co llection agency.
4
19. The complaint was not signed by any attorney.
B. Consumer Charles Chevrie
20. Charles Chevrie lived at 364 W 63rd Street, Willowbrook, Illinois 60527
(hereinafter 63rd Street property") as hi s personal residence. He used the 63 rd
Street property primarily for personal , family, or household purposes.
21. Charles Chevrie took out a mortgage with MERS as Nominee for Taylor, Bean &
Whitaker Mortgage Corporation on March 1, 2006 to finance the 63 rd Street
property.
22. Charles Chevrie received an "EVICTION NOTICE" by the Order of the Circuit
Court of DuPage County, case number 09 CH 11 29 in DuPage County, with an
eviction date of July 17, 2012. (see Exhibit "C")
23. The EVICTION NOTICE is signed by Deputy "J6337" of the DuPage Sheriff s
Office.
24. The EVICTION NOTICE was based on ajudgment received by The Bank of
New York, the Plaintiff in case number 09 CH 1129.
25. Upon contacting DuPage Sheriffs Office on June 26, 2012, Cyrus K. Hosseini ,
Plaintiffs attorney, was informed that the EVICTION NOTICE was initiated by
KLUEVER. (see Kuroush Khajehhosseini's Affidavit in Exhibit "D" and "Exhibit
I to the Affidavit").
26. Upon information and belief, KLUEVER does not own the 63rd Street property.
27. Upon information and belief KLUEVER filed the eviction with the Sheriff of
DuPage County for The Bank of New York.
5
28. Defendant is attempting to collect property from a person without being registered
as a collection agency pursuant to Section 4 of the ICAA (225 ILCS 425/4).
APPLICABLE STATUTES
29. Section 1 of the Illinois Collection Agency Act, 225 ILCS 42511, provides:
(la) Declaration of public policy. The practice as a collection agency by any entity in the State of Illinois is hereby declared to affect the public health, safety and welfare and to be subject to regulation and control in the public interest. It is further declared to be a matter of public interest and concern that the collection agency profession merit and receive the confidence of the public and that only qualified entities be permitted to practice as a collection agency in the State of Illinois. This Act shall be liberally construed to carry out these objects and purposes. It is further declared to be the public policy of this State to protect consumers against debt co llection abuse.
30. Section 2 of the Illinois Collection Agency Act, 225 ILCS 425/2, provides:
(2)
"Debt collection" means any act or practice in connection with the collection of consumer debts.
"Debt collector", "collection agency", or "agency" means any person who, in the ordinary course of business, regularly, on behalf of himself or herself or others, engages in debt collection.
31. Section 3 of the Illinois Collection Agency Act, 225 ILCS 425/3, provides:
(3) A person, association, partnership, corporation, or other legal entity acts as a collection agency when he or it: (a) Engages in the business of collection for others of any account, bill or other indebtedness;
32. Section 4 of the Illinois Collection Agency Act, 225 ILCS 425/4, provides:
6
(4) No collection agency shall operate in this State, directly or indirectly engage in the business of collecting, solicit claims for others, have a sales office, a client, or sol icit a client in this State, exercise the right to collect, or receive payment for another of any account, bill or other indebtedness, without regi stering under this Act
33. Section 14 of the Illinois Collection Agency Act, 225 ILCS 425114, provides:
(14) Engaging in the collection of debts without first having obtained a certificate pursuant to this Act, or carrying on such business after expiration of the certificate or after receipt ofa notice of revocation or suspension of the certificate is a Class A misdemeanor. The penalties provided by this Act shall not be exclusive, but shall be in addition to all other penalties or remedies provided by law.
34. Section 14a of the Illinois Collection Agency Act, 225 ILCS 4251l4a, provides:
(l4a) Unlicensed practice; Injunctions. The practice as a collection agency by any
enti ty not holding a valid and current license under thi s Act is declared to be
inimical to the public welfare, to constitute a public nuisance, and to cause
irreparable harm to the public welfare . The Director, the Attorney General, the
State's Attorney of any county in the State, or any person may maintain an action
in the name of the People of the State ofIllinois, and may apply for injunctive
relief in any circuit court to enjoin such entity from engaging in such practice.
Upon the filing of a verified petition in such court, the court, if satisfi ed by
affidavit or otherwise that such entity has been engaged in such practice without a
valid and current li cense, may enter a temporary restraining order without notice
or bond, enjoining the defendant from such further practice. Only the showing of
nonlicensure, by affidavit or otherwise, is necessary in order for a temporary
injunction to issue. A copy of the verified complaint shall be served upon the
defendant and the proceedings shall thereafter be conducted as in other civil cases
7
except as modified by this Section, If it is established that the defendant has been
or is engaged in such unlawful practice, the court may enter an order or judgment
perpetually enjoining the defendant from further practice, In all proceedings
hereunder, the court, in its di scretion, may apportion the costs among the parties
interested in the action, including cost of filing the complaint, service of process,
witness fees and expenses, court reporter charges and reasonable attorneys' fees,
In case of vio lation of any injunctive order entered under the provisions of this
Section, the court may summarily try and punish the offender for contempt of
court, Such injunction proceedings shall be in addition to , and not in lieu of, all
penalties and other remedies provided in this Act.
COUNT I
VIOLATIONS OF THE COLLECTION AGENCY ACT
35, Plaintiff realleges and incorporates by reference the allegations in Paragraphs I
through 34,
36, Pursuant to the ICAA, 225 ILCS 425/3, a person, association, partnership,
corporation, or other legal entity acts as a collection agency when he or it:
(a) engages in the business of collection for others of any account, bill
or other indebtedness,
37, Defendant has fil ed at least 3700 suits in Cook County alone since July 25, 2001
38, The act of filing a lawsuit is a debt collection practice pursuant to Section 2 of the
ICAA (225 ILCS 425/2),
39, Pursuant to Section 2,03(5), the ICAA does not apply to Licensed attorneys at law,
However, KLUEVER is not a licensed attorney at law, A letter from the Supreme
8
Court of Illinois (Exhibit "A") states that a search "did not reveal that "Kluever &
Platt LLC" is registered with the Supreme Court of Illinois under Supreme Court
Rule 721." Supreme Court Rule 721, allows limited liability companies to engage
in the practice of law in Illinois. Therefore, KLUEVER is not authorized to
engage in the practice of law in Illinois.
40. KLUEVER has collected debts and is continuing to attempt to collect debts
without registering under the ICAA. KLUEVER has received numerous
judgments to collect, or receive payment for another of accounts, bills or other
indebtedness in the State of Illinois.
41. The Defendant, KLUEVER, was not registered with the Supreme Court of Illinois
under Supreme Court Rule 721 , at the time that they were attempting to collect
money from Dragan Dobobrov or Charles Chevrie. (see Exhibit "A")
42. Defendant's practice as a collection agency while not holding a valid and current
license under the ICAA is inimical to the public welfare, and constitutes a public
nuisance, causing irreparable harm to the public welfare pursuant to Section l4a
of the ICAA (225 ILCS 425114a).
43. Such practices constitute a temporary restraining order without notice or bond,
enjoining the defendant from such further practice pursuant to 225 ILCS 425114a.
44. See affidavit of Kuroush Khajehhosseini showing Eviction Notice for Charles
Chevrie in DuPage County was initiated by KLUEVER (see Exhibit "0").
45. See affidavit of Kuroush Khajehhosseini with State of Illinois searches (Exhibit
"E"), which shows KLUEVER does not have a license and is not registered with
9
28. Defendant is attempting to collect property from a person without being registered
as a collect ion agency pursuant to Section 4 of the ICAA (225 ILCS 425/4).
APPLICABLE STATUTES
29. Section I of the Illinois Collection Agency Act, 225 ILCS 425/1, provides:
( I a) Declaration of public policy. The practice as a collection agency by any entity in the State of Illinois is hereby declared to affect the public health , safety and welfare and to be subject to regulation and control in the public interest. It is further declared to be a matter of public interest and concern that the collection agency profession merit and receive the confidence of the public and that only qualified entities be pennitted to practice as a collection agency in the State of Il linois. This Act shall be liberally construed to carry out these objects and purposes. It is further declared to be the public policy of this State to protect consumers against debt collection abuse .
30. Section 2 of the Illinois Collection Agency Act, 225 ILCS 425/2, provides:
(2)
"Debt co llection" means any act or practice in connection with the collection of consumer debts.
"Debt collector", "collection agency", or "agency" means any person who, in the ordinary course of business, regularly, on behalf of himsel f or hersel f or others, engages in debt collection.
31. Section 3 of the Illinois Collection Agency Act, 225 ILCS 425/3, provides:
(3) A person, association, partnership, corporation, or other legal entity acts as a collection agency when he or it: (a) Engages in the business of collection for others of any account, bill or other indebtedness;
32. Section 4 of the Illinois Collecti on Agency Act, 225 ILCS 425 /4, provides:
6
the Supreme Court of Illinois under Supreme Court Rule 721 and "Exhibit 2 to
Affidavit".
STATUTORY REMEDIES-COUNT I
46. Section 14a of the Illinois Collection Agency Act, 225 ILCS 42511 4a, provides:
§ 14a. Un licensed practice; Injunctions. The practice as a collection agency by any entity not holding a valid and current license under this Act is declared to be inimical to the public welfare , to constitute a public nuisance , and to cause irreparable haml to the public welfare. The Director, the Attorney General, the State's Attorney of any county in the State, or any person may maintain an action in the name of the People of the State of Illinois, and may apply for injunctive relief in any circuit court to enjoin such entity from engaging in such practice. Upon the filing of a verified petition in such court, the court, if satisfied by affidavit or otherwise that such entity has been engaged in such practice without a valid and current license, may enter a temporary restraining order without notice or bond, enjoining the defendant from such further practice. Only the showing of nonlicensure, by affidavit or otherwise, is necessary in order for a temporary injunction to issue .
PRA YER FOR RELIEF
WHEREFORE, PLAINTIFF prays that this Honorable Court enter an Order:
A. Finding that PLAINTIFF has fil ed this action as a verified petition in Cook
County Circuit Court which includes an affidavit stating that KLUEVER has
engaged in the practice as a co llection agency without a valid and current license.
B. Temporarily enjoining KLUEVER from engaging in the practice of a collection
agency without noti ce or bond, enjoining the defendant from such further practice
pursuant to 225 ILCS 42511 4a;
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C. Finding that KLUEVER practiced as a "collection agency" as defined by Section
2 of the ICAA;
D. Finding that KLUEVER is not exempt from the ICAA;
E. Finding that KLUEVER has never held a valid and current license under the
ICAA;
F. Finding that KLUEVER has been in the unlawful practice of a collection agency
without a valid and current license;
G. Permanently enjoining the KLUEVER from engaging in the practice ofa
collection agency as defined in the ICAA;
H. Requiring the KLUEVER to pay all costs for the prosecution and investigation of
this action, including, cost of fi ling the complaint, service of process, witness fees
and expenses, court reporter charges and reasonable attorney fees; and
I. Providing such other and further equitable relief as justice and equity may require.
Respectfully Submitted,
THE PEOPLE OF THE STATE OF ILLINOIS,
By 091 54050180000 LLC I,
~ :=:=:=-By its attorney, ~ ~
Kuroush Khajehhosseini Jul y 11,2012
Attorney No. #49706 Kuroush Khaj ehhosseini (alk/a Cyrus K. Hosseini)
Attorney for Plaintiff 22 W. Washington St. Suite 1500
Chicago, IL 60602 847.830.1369
11
VERIFICA TION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil
Procedure, the undersigned certifies that the statements set forth in the Complaint for Injunctive
and other Relief against Kluever & Platt LLC are true and correct, except as to matters therein
stated to be on information and belief and as to such matters the undersigned certifies as
aforesaid that he verily believes the same to be true.
09154050180000 LLC 1 by: JVJK L.L.C. , MAIL TO, its Manager
Manager
EXHIBIT A
CAROL\~ TAFT GROSBOLL Clerk of lht: (' Cl Ut'l
SUPREME COURT OF ILLINOIS SLPREME COI 'RT BllLDIVi
~oo Ea!;1 Capl:n] .-\\Tnuc SPRI"GrIELD,ILLI~'OIS 6c'nJ·J'eJ
May 16, 2012 FIRST DISTRICT oFfin 1 (,() 'llr1h LaSalk SfTl!e t. :!Oc Floor C hlc ag<l. Jllm(\ l!< A060 1· ~ 10 .'
1':: 1- ) - X:-'::O}) 1.' 12 ) "")9 ) - 13 3: TDD 121"" J5 ?J .)Q': TOO 01 ~ )79~.f.J~5
Joseph S. Varan 22 West Washington , 15 '" Floor Chicago, IL 60602
In Re : Kluever & Platt LLC
Dear Mr . Varan :
Pursuant to your written request received in this office on May 14, 2012, the Clerk's office conducted a search of records maintained pursuant to Supreme Court Rule 721, Said search did not re veal that" Kluever & Platt LLC" is registered with the Supreme Court of Illino is under Supreme Court Rule 7 2 1,
Very truly yours,
Clerk of the Supreme Court
CTG:wb
EXHIBIT B
[N THE CIRCUIT COURT OF COOK COUNTY, ILUNQIS COlNTY DEPARTMENT, CHANCERY DrvISION ..-
U. S BANK NATIONAL ASSOCIATION. AS TRUSTEE, ON BEHALF OF TH E HOLDERS OF THE ADJUSTABLE RATE MORTGAGE TRUST 2007-1 , ADJUSTABLE RATE MORTGAGE-BACKED PASSTHROUGH CERTI FICATES, SERIES 2007-1
PLAINTIFF.
VS. DRAGAN DOBOBROV , LIVIA DOBOBROV, HARRIS ) NA, COOK COUNTY ILLINO IS , MUNICPAL ) DEPARTMENT, UNKNOWN OWNERS, GENERALLY. ) AND NON-RECORD C LAIMANTS . )
DEFENDANTS ) )
NO:
COMPLAINT FOR FORECLOSURE AND OTHER RELIEF
Plaintiff. U.S . Bank Nationa l AssO(;ialion, as trustee, on behalf of the holders of the
Adjustable Rate Mortgage Trust 2007-1 , Adjustable Rate Mortgage-Backed Pass-Through
. :"-
Certificates, Series 2007-1 (U. S. Bank National Association) by its attorneys. Kluever & Platt,
LLC, hereby files its Complaint against thc Defendants. Hnd StHles as follows:
I. Plaintiff files this Complaint to foreclose the mortgage hereinafter described and
joins the following persons as defendants :
a) Dragan Dobobrov;
b) Livia Dobobrov;
c) Harris N A ;
d) Cook County Illinois, MuniCipal Department;
e) Unknown Owners Generall y: and
f) Non-Rpcord Claimants
: \ .
j I j
1
j 1
2. Plaintiff annexes the following Exhibits which are true and correct copies of the
originals thereof:
(a) Exhibit "A" is a true and correct copy of the promissory note ("Note") dated
December 8. 2006 in the principal amount of $1,000,000.00 and;
(b) Exhihit "B" is a true and correct copy of the Mortgage ("Mortgage") dated
December 8, 2006 WIth Mortgage Etcctronic Registration Systems. Inc. as
nominee for Credit Suisse Financial Corporation, as Mortgagee and Defendant,
Dragan Dobobrov and liVIa Dobobrov as Mortgagor securing payment of the
Note (hereinafter the "Mortgage");
(c) Exhibit "C" is a truc and correct copy of the Assignment of Mortgage from
Mortgage Electronic RegistratIon Systems, Inc. as nominee for Credit Suisse
Financial Corporation to U.S. Bank National Association dated June 18,2008.
3. Information concerning the Mortgage:
(a) Nature of 1 nstrumen!:
(b) Date of Mortgage:
(c) Name of Mortgagor:
(d) Name of Mortgagee in the Mortgage:
( e) Date and Place of Recording:
(I) Identification of Recording:
(g) Interest encumbered by the Mortgage
(h) Amount of Original Indebtedness:
Mortgage;
December 8, 2006
Dragan Dobobrov and Li via Dobobrov;
Mortgage Electronic Registration Systems, Inc. as nominee for Credit Suisse Financial Corporation
December 29, 2006, Cook County Recorder's Office
Document No. 0636320092
Fee Simple;
$ 1,000,000.00
(il Legal Description of Premises:
LOT 13 rN BLOCK II IN GLEN-BROOK COUNTRYSIDE A SlBDlVISION OF PART OF THE ~ORTHWEST 1/4 OF SECTION 3. WID PART OF THE NORTH EAST 1/4 OF SECTION 4 ALL IN TOWNSHIP 42 NORTH. RANGE 12 EAST OF THE THIRD PRfNC IP AL \1ERIDIAN. fN COOK COUNTY. ILLINOIS
P.!." . 04-03- 103-023 CO~IMON ADDRESS: 210 Cottonwood Rd., Northbrook, IL 60062
DEFAULTS
Ul Statements as to Default and Amount Now Due:
Mortgagor has defaulted in the payment of principal and interest when due on March 1,
2008 each and every month thereafter.
As a result of the foregoing defaults, Plaintiff has elected under the terms and conditions
of the Note and Mortgage to declarc immediately due and payable the entire principal balance
and other sums secured by th e Mongage. As of June 12,2008 the following amounts were due
and owing ITom Mortgagors to Plai ntiff:
I. Outstanding Principal Bal ance $ 1.000.000.00
2. Accrued Interest $27 ,71 4.62
3. Advances $ I 7,768. 84
4. Late Fees $2,223,90
5, NSF Fees $5000
6, Total-Fees $43 1.35
7, Penalty Interest $76 ,250,00
8. Recoverable Balance $102,85
Total amounl due as of June 12,2008 S 1,124, 541,56
Plus costs and attorneys fees incurred in connect ion herewith,
PER DIEM INTEREST
Interest continues to accrue upon the principal amount at the default rate of $208.90 per
diem as of June 13,2008.
(k) Name of present owner of the premises: Dragan Dobobrov
(I) Name or names of persons. in addition to such owner or owners, but excluding
any non-record claimants as defined in the Illinois Mortgage and Foreclosure Act,
as heretofore and hereafter amended who are joined as defendants and whose
equitable right to redeem is sought to be barred :
(I) Livia Dobobrov by virtue of Mortgage recorded December 29,
2006 as document number 063620092 for the amount of S 1.000,000.00
(2) Harris N.A. by virtue of Junior Mortgage recorded January 25,
2007 as document number 063620092 for the amount of S529, 191.00
(3) Cook County Illinois, Municipal Department by virtue of
Judgment recorded October 29, 2007 as document number 0730218033 for
the amount of $700; recorded February 21. 2008 as document number
0805234060 for the amount of $1 ,610.00; recorded February 27, 2008 as
document number 0805818021 for the amount of 52,310.00; recorded May
12, 2008 as document number 08 13345183 for the amount of $3,399.00
(4) Unknown Owners
(m) Name of person claimed to be personally liable for deficiency: Dragan Dobobrov
(n) Capacity in which Plaintiff brings this suit: Plaintiff is obligee and legal holder of
the indcbtooness secured by the Mortgage and evidenced by the Note; by virtue of
assignment of mortgage
(0) Facts in support of shortened redemption period : None at this time.
(p) Plainti ff seeks inclusion in the decree of Plaintiffs anorney's fees and of the costs
and expenses of th is action in accordance with the terms of the Note and Mortgage;
WHEREFORE. Plaintiff. U.S. Bank National Association, as trustee, on behalf of the
holder.; of the Adjustable Rate Mortgage Trust 2007-1 , Adjustable Rate Mortgage-Backed Pass-
Through Certificates , Series 2007 -I, prays for the following relief:
(a) Foreclosure of its mortgage;
(b) Judicial Sale of the subject property for payment of the lien and costs;
(c) Confirmation of sale and the issuance of a certificate of sale to the purchaser;
(d) A personal deticiency decree;
(e) Its reasonable costs and expenses including, but not limited to, its attorney's fees;
and
(I) Such other further and equitable relief as the Court deems just.
Kluever & Platt , LLC.
65 E. Wack<:r Place. Suite 2300
Chicago, Illinois 6060 I
(312) 201-6679
Attorney No. 38413
Our File #: FBCC.S933
U.S. Bank National Association, as trustee, on behalf of the holders of the Adj ustable Rate Mortgage Trust 2007-I. Adjustable Rate Mortgage-Backed Pass-Through Certificates, Series 2007-1
By: _ _ ~_.:-:-___ _ ____ _ One of its attorneys
EXHIBIT C
EVICTION NOTICE
Case No.{)qCt-l ( lJ C'z~" DefendantC i=! d~u;;t) CH21//2/I[ of Au.. ()7H81?-'S
Address 30 Cf (,J) . &2 -5 !< tJ Apt. _ _ _
BY ORDER OF THE ClRCUIT COURT OF
DUPAGE COUNTY YOU WILL BE EVICTED ON
/ / / /~
C{) @IPM
HAVE EVERYTHING OUT BY THE DATE AND TIME SHOWN OR IT WILL BE REMOVED TO THE PUBLIC RIGHT OF WAY.
YOU MAYBE SUBJECT TO ARREST IF YOU REMAIN ON THE LISTED PREMISES/PROPERTY AFTER THE EXECUTION OF THIS ORDER.
Questions regarding this order Contact DuPage Sheriffs Office (630) 407-2063 Hours 8:00 AM to 4:30 PM T." • . !_....! _ _ n ___ ._ ~ __ _ _ ...
John E. Zaruba, Sheriff
EXHIBIT 0
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - CHANCERY DIVISION
THE PEOPLE OF THE STATE OF ILUNOIS
Plaintiff,
v.
KLUEVER & PLATT LLC
Defendant,
) ) )
) ) ) ) ) )
Affidavit of Kuroush Khajehhosseini
Case No.
I, Kuroush Khajehhosseini , Under penalties as provided by law pursuant to Section 1- 109 of the Code of Ci vi I Procedure, the undersigned certi fies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he verily believes the same to be true.
I. I am an attorney licensed to practice law in the State of Illinois.
2. ] am the attorney for Plaintiff in the above action.
3. On June 26, 20]2 around 1:00 PM , 1 called the DuPage County Sheriffs Office.
a. I asked who initiated an Eviction in Case No. 09 CH 1129-6.
b. 1 was told the Eviction was initiated for 364 W. 63rd Willowbrook, IL by
KLUEVER & PLATT LLC.
4. "Exhibit 2 to the Affidavit" attached to this affidavit is a true and correct copy of
the EVICTION NOTICE fro m Case No. 09 CH 1129-6.
Further, Affiant sayeth not
~ni-t w s acknowledged before me on
I ~ (d?a .......... ~
EXHIBIT 1 TO THE AFFIDA VIT
EVICTION NOTICE
Case No() 0CH UJ C'Z~", Defendant C H II r2 U33 C He // f2ltf + ItkL c) VJt-T&S
Address -)0 Y tj J. '~-5 !<. tJ o Apt. _ _ _
BY ORDER OF THE CIRCUIT COURT OF
DUPAGE COUNTY YOU WILL BE EVICTED ON
JI AT:~:
/] I IJ,
(){)§j); PM
HAVE EVERYTHING OUT BY THE DATE AND TIME SHOWN OR IT WILL BE REMOVED TO THE PUBLIC RIGHT OF WAY.
YOU MAY BE SUBJECT TO ARREST IF YOU REMAIN ON THE LISTED PREMISES/PROPERTY AFTER THE EXECUTION OF THIS ORDER.
Questions regarding this order Contact DuPage Sheriff's Office (630) 407-2063 Hours 8:00 AM to 4:30 PM
John E. Zaruba, Sheriff
By: lZ~=?'2 Deputj'
EXHIBITE
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - CHANCERY DIVISION
THE PEOPLE OF THE STATE OF ILLfNOIS
Plaintiff,
v,
KLUEVER & PLATT LLC
Defendant,
) ) ) ) ) ) ) ) )
Affidavit of Kuroush Kbajehhosseini
Case No, '
I, Kuroush Khajehhosseini , Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he verily believes the same to be true ,
I, r am an attorney licensed to practice law in the State of Illinois,
2, I am the attorney for Plaintiff in the above action,
3. On information and belief, the Illinois Department of Financial & Professional
Regulation is the entity that issues and regulates the licensing of collection
agencies pursuant to the Collection Agency Act.
4, On July II , 2012 at I: II PM , I performed a search from the website of the State
of Illinois, Illinois Department of Financial & Professional Regulation with the
web address of: https: //www.idfpr.com/ licenselookup/ licenselookup.asp by
doing the following:
a, I selected the profession of "col lection agency,"
b, I typed the name "KLUEVER & PLATT LLC" into the section titled
" Last Name or Business Name"
c. I checked the box "Search Similar Names,"
d, I clicked on the "Search" button.
e. I printed out the result of my search, which is attached "Exhibit I to the
Affidavit" to this affidavit.
5, The search that I did in number 4 above showed that KLUEVER & PLATT LLC
does not have a collection agency license issued by the State of Ill inois.
6. I made no change to the material that [ printed out from the above search.
7. "Exhibit 1 to Affidavit" is attached to this affidavit is a true and correct copy of
the search that I did.
Further, Affiant sayeth not.
as acknowledged before me on ------'.+-'-.y..I-==-~---". _ _____ ( date)
EXHIBIT 2 TO THE AFFIDAVIT
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Profession COLLEcnON AGENCY G
Last Name or Business Name , KLUEVER & PLAn LlC Search Similar Names : 7
Firs! Initial: I-bw many row.> per page?
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" '" rf.,-' ' Brent E. Adams, Secretary Pat Quinn, Governor
SUH; a New SearCh pdnter Fdend!y View
SEARCH FOR LICENSEE BY PROFESSION:
Tl-lr;Rr; AR.E 0 R.EeOR.OS WHOSE NAMe CONTAINS : KLUEVER & P LATI LLC
The name, KLUEVER 8. PLATT LLC , was not found
HINT: You might try searching on part of the name; e.g. ··tyre"'nstead o f ··Mcln t'(re "
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