Illinois Appellate Court
Civil Court
Mortgage Foreclosure
Court, in mortgage foreclosure proceeding, properly granted petition for turnover of surplus funds filed by holder of a junior mortgage. When a party seeks to establish a lien for purpose of distributing surplus proceeds, it is not required that amount of lien be proved up or adjudicated prior to distributing the proceeds. A valid junior lien may be satisfied under Illinois foreclosure law. (CUNNINGHAM and CONNORS, concurring.)