Rudnicki v. WPNA 1490 AM, et al

Filing 200

MOTION by Defendants Alliance Communications, Inc., Polish National Alliance of the US of North America, WPNA 1490 AM for judgment (final) (Fitzpatrick, John)

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IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION RAFAL RUDNICKI Plaintiff, v. WPNA 1490 AM, ALLIANCE COMMUNICATIONS, INC., POLISH NATIONAL ALLIANCE OF THE UNITED STATES OF NORTH AMERICA Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) Case Number: 04 C 5719 Judge Rebecca Pallmeyer Magistrate Judge Nolan DEFENDANTS' MOTION FOR ENTRY OF FINAL JUDGMENT Defendants Alliance Communications, Inc. ("Alliance") and Polish National Alliance of the United States of North America ("PNA") move this Court to enter final judgment in favor of the Defendants and against the Plaintiff on each of Plaintiff's claims and grant whatever further relief the Court deems proper for the reasons set forth in the supporting memorandum. WHEREFORE, Defendants Alliance Communications, Inc. and Polish National Alliance of the United States of North America respectfully request that this Court enter an Order of final judgment in favor of the Defendants and against the Plaintiff on each of Plaintiff's claims and grant whatever further relief the Court deems proper. Respectfully submitted, ALLIANCE COMMUNICATIONS, INC. AND POLISH NATIONAL ALLIANCE OF THE UNITED STATES OF NORTH AMERICA By: /s/ Steven P. Mandell One of Its Attorneys Steven P. Mandell (ARDC #6183729) John D. Fitzpatrick (ARDC #6277475) Mandell Menkes LLC 333 West Wacker Drive Suite 300 Chicago, Illinois 60606 (312) 251-1000 177383v1

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