Bank of America, N.A. v. Key

2020 IL App (1st) 182430-U
CourtAppellate Court of Illinois
DecidedMarch 31, 2020
Docket1-18-2430
StatusUnpublished

This text of 2020 IL App (1st) 182430-U (Bank of America, N.A. v. Key) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America, N.A. v. Key, 2020 IL App (1st) 182430-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 182430-U

FIFTH DIVISION March 31, 2020

No. 1-18-2430

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

BANK OF AMERICA, N.A., ) Appeal from the Circuit Court of ) Cook County. Plaintiff-Appellee, ) ) v. ) ) WILLIAM C. KEY; STANDARD BANK AND ) TRUST COMPANY as Trustee under trust dated June ) 20, 1990 and known as Trust No. 8-8989; CITIZENS ) No. 12 CH 30995 FINANCIAL BANK; CITY OF COUNTRY CLUB ) HILLS; UNKNOWN BENEFICIARIES OF ) STANDARD BANK AND TRUST COMPANY as ) Trustee under trust dated June 20, 1990 and known as ) Trust No. 8-8989; UNKNOWN OWNERS; and NON- ) RECORD CLAIMANTS, ) ) Defendants ) Honorable ) Gerald V. Cleary, Jr., (William C. Key, Defendant-Appellant). ) Judge, presiding.

JUSTICE DELORT delivered the judgment of the court. Presiding Justice Hoffman and Justice Rochford concurred in the judgment.

ORDER

¶1 Held: We affirm the circuit court’s judgment in favor of the plaintiff in this mortgage foreclosure case. The defendant failed to raise a genuine issue of material fact in opposition to summary judgment because his argument relied on documents that were not properly authenticated. The circuit court did not err in confirming the judicial sale of the property. 1-18-2430

¶2 In 2001, defendant William C. Key executed a mortgage and note on property located in

Country Club Hills, Illinois with America’s Wholesale Lender. On August 14, 2012, after Key

failed to make timely payments, America’s Wholesale Lender’s successor, Bank of America,

N. A. (the Bank) 1, sued Key and others to foreclose on the mortgage.

¶3 Key filed an answer to the amended complaint which included two affirmative defenses.

The first affirmative defense stated that: (1) Key had signed a second modification of the note

and mortgage; (2) he had complied with the modification’s requirements; (3) he tried to make

payments pursuant to the modification which the Bank refused to accept; and (4) the Bank failed

to return an executed copy of the modification to him. The first affirmative defense concluded

that the doctrine of unclean hands precluded the Bank from obtaining relief. The second

affirmative defense was virtually identical to the first, except that it asserted that the bank was

equitably estopped from obtaining relief. No copy of any modification agreement was attached to

either of the two affirmative defenses.

¶4 The Bank moved to strike both affirmative defenses pursuant to section 2-615 of the Illinois

Code of Civil Procedure (Code) (735 ILCS 5/2-615 (West 2014)). The Bank argued that the

affirmative defenses were flawed because Key failed to include a copy of the alleged modification

as required by section 2-606 of the Code, which provides that “if a claim or defense is founded

upon a written instrument, a copy thereof *** must be attached to the pleading ***”. The circuit

court granted the section 2-615 motion and struck the affirmative defenses without prejudice to

repleading them by a certain date. Key never repleaded the affirmative defenses.

1 The loan changed hands several times during the case’s lifespan and various entities were substituted as plaintiff. For simplicity, we will use the term “the Bank” regardless of whether we are referring to Bank of America, N. A. or any of its predecessors.

2 1-18-2430

¶5 On October 8, 2015, the Bank moved for summary judgment pursuant to section 2-1005

of the Code (735 ILCS 5/2-1005 (West 2014)) or, in the alternative, for a judgment of foreclosure

pursuant to section 15-1506 of the Code (735 ILCS 5/15-1506 (West 2014)) (summary judgment

motion). The Bank’s motion included a standard affidavit from a Bank representative stating that

Key defaulted on the loan by failing to make required payments, and that the amount due as of

March 31, 2015 was $129,266.36. The court entered and continued the motion to permit Key to

submit a Rule 191(b) affidavit, which is used when a party wishes to assert that he needs additional

time to respond to a motion for summary judgment because specified material is unavailable to

him or has not yet been produced in discovery. See Ill. Sup. Ct. R. 191(b) (eff. Jan. 4, 2013). On

October 15, the court entered an order setting a briefing schedule on the Bank’s motion, including

dates for Key to file a response and the Bank to file a reply. The order indicated that “Defendant’s

191(b) affidavit is denied without prejudice.” No proposed Rule 191(b) affidavit appears in the

record.

¶6 The circuit court later granted Key leave to file his response to the Bank’s motion over a

month late. Key’s response included his own affidavit stating: (1) after Key had complied with a

trial repayment plan, the Bank granted a second modification of the loan in March 2012; (2) Key

signed and returned the modification to the Bank “in a timely fashion”; (3) he paid the Bank

$1,092.25 as required by the Bank’s April 5, 2012, telephonic instructions; (4) he made further

payments between April and July, 2012, in accordance with the Bank’s invoices; (5) the Bank did

not notify him that the second modification was “either reversed or even under review”; (6) a Bank

representative told him, on July 16, 2012, that the “second modification was now under review

due to an error that the Bank had made in the figures”; (7) a Bank representative later told him that

the “second modification was being reversed over an approximately $300 miscalculation in the

3 1-18-2430

Bank’s calculation of the modification figures” and (8) the Bank refused his tender of an August,

2012 monthly payment and would only accept a reinstatement amount which exceeded $9,000.

¶7 Based on these assertions, Key argued that there was a material issue of genuine fact

precluding summary judgment. In particular, he contended that there were conflicts between the

Bank’s standard prove-up affidavit and his own affidavit with respect to: (1) payments he made

for April, 2012; (2) “other payments” listed on receipts attached to his affidavit; (3) “transfers of

monies to and from unapplied totals are inaccurate”; and (4) the balance failed to “give credit for

the Second Loan Modification which the Bank has signed and is bound by”. In addition to his own

affidavit, Key relied on various documents which are attached to his affidavit and referenced

therein. Key’s response contains no foundational authentication of these documents other than a

cross-reference to them in his affidavit.

¶8 Key claimed that one of the attached documents, designated as Exhibit 2, was the second

modification agreement in question. The exhibit consists of a four-page cover letter and an attached

loan modification agreement.

¶9 The cover letter, which is dated February 12, 2012, is written in the familiar language of

an offer of contract. The letter begins: “Enclosed is a proposed agreement to modify your loan”.

That sentence, in turn, references a footnote which states: “The enclosed terms are based upon

information you provided to us and may be subject to validation.” The next sentence in the main

text states: “This modification agreement will not be binding or effective unless and until it has

been signed by both you and Bank of America, N.A.” The letter contains a summary of the terms

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Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (1st) 182430-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-na-v-key-illappct-2020.