Redmond v. The City of Chicago et al

Filing 172

AGREED Motion by Plaintiff for entry of judgment re: attorneys fees. (Jackowiak, Lawrence). (Text edited by Clerk's Office.) Modified on 4/1/2009 (ar, ).

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ANDRE REDMOND, Plaintiff, vs. CITY OF CHICAGO, et al., Defendants. ) ) ) ) ) ) ) ) )

No. 06 C 3611 Judge Der-Yeghiayan Magistrate Judge Keys

AGREED MOTION FOR ENTRY OF JUDGMENT Plaintiff Andre Redmond, through counsel, Law Offices of Lawrence V. Jackowiak, respectfully requests that this Honorable Court enter judgment in the amount of $191,943.55 for Plaintiff's attorneys' fees. In support thereof, Plaintiff states as follows: 1. 2. This motion is agreed. On March 4, 2008, the jury returned a verdict in favor of Plaintiff. On March 5,

2008, judgment was entered on the verdict in the amount of $40,500. 3. 4. of $3,152.43. 5. 6. On November 11, 2008, Plaintiff filed a motion for attorneys' fees. Shortly thereafter, the parties entered into settlement negotiations regarding On April 3, 2008, Plaintiff filed a Bill of Costs. On May 16, 2008, the Court entered judgment on the bill of costs in the amount

attorneys' fees. 7. Plaintiff's motion for attorneys' fees was stricken with leave to reinstate on

January 21, 2009, pending the outcome of settlement negotiations. 8. The parties have reached a settlement on the issue of attorneys' fees and have

agreed that an award of $191,943.55 is a fair and reasonable sum for Plaintiff's attorneys' fees. Wherefore, Plaintiff respectfully requests that this Honorable Court enter judgment in the amount of $191,943.55 for Plaintiff's attorneys' fees.

Respectfully submitted, /s/ Lawrence V. Jackowiak Counsel for the Plaintiff

Lawrence V. Jackowiak Louis J. Meyer Law Offices of Lawrence V. Jackowiak 20 North Clark Street, Suite 1700 Chicago, Illinois 60602 [phone]

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