Oasis Imaging Products, Inc. v. T.T.I International, Inc.

Filing 34

MOTION by Plaintiff Oasis Imaging Products, Inc. for judgment (Attachments: # 1 Exhibit Stipulation For Entry Of Judgment, # 2 Exhibit Agreed Order Of Judgment)(Kadison, Steven)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION OASIS IMAGING PRODUCTS, INC., Plaintiff/Counter- Defendant, vs. )
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No. 07 CV 1361 Judge David Coar

T.T.! INTERNATIONAL, INC., Defendant/Counter-Claimant.

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STIPULATION FOR ENTRY OF ORDER OF JUDGMENT
NOW COMES plaintiff OASIS IMAGING PRODUCTS, INC., by its attorney, Steven J. Kadison and T.T.! INTERNATIONAL, INC. defendant herein, by its attorney Jim Pittacora and each hereby stipulate as follows: 1. OASIS IMAGING PRODUCTS, INC., and T.T.! INTERNATIONAL, INC. have executed a Settlement Agreement relative to all matters in controversy in this matter. A true and correct copy of said Settlement Agreement is attached hereto as Exhibit A. 2. Under the terms of the Settlement Agreement by and between the parties hereto, T.T.! INTERNATIONAL, INC. has agreed to execute this Stipulation for Entry of Order of Judgment and an Agreed Order of Judgment to be used in case of default under the Settlement Agreement and a failure to cure that default. 3. NOW THEREFORE, acknow 1edged and agreed: a. in consideration of the foregoing, it is stipulated,

That OASIS sued T.T.1. for $417,182.05, but agreed to settle and compromise its claim for $300,000.00 from TT.1. under the terms of the Settlement Agreement; That TTl. default; is in default under the Settlement Agreement and has not cured the

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That T.T.!. stipulated to the entry of an Order of Judgment against it in favor of OASIS in the amount of $~ ) 7~~'2-; The foregoing figure reflects credit for the fbyments made pursuant to the Settlement Agreement totaling $$05 (I.{.j 13 ;
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That T.T.1. waived and released any and all claims, counterclaims, defenses, affirmative defenses and/or set-offs which it may have to the enforcement of the terms of the Settlement Agreement;

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That T.T.! agreed that an Order of Judgment in the form and substance of the Agreed Order of Judgment, a copy of which is attached hereto as Exhibit B, which has been signed and agreed to by it may be entered by the Court and execution thereof pursued by OASIS That T.T.I. waived any and all of its rights to move, vacate, reconsider, or appeal from said judgment and further waived any and all of its rights to object to or appeal from any interlocutory or final order; and That T.T.I. waived any and all of its rights to object to, interfere with, obstruct, or impede the execution of judgment. T.T.I. agreed that counsel for OASIS shall have the authority to enter the figure representing the actual amount due OASIS, after properly crediting all amounts received prior to the default, upon the Agreed Order of Judgment and within this Stipulation for Entry of Order of Judgment, pursuant to the Settlement Agreement.

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Dated: February 2.'\ , 2008 AGREED AS TO SUBSTANCE AND FORM: TT.T.I.
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By: .~ .

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Jim Pittacora Attorneys for T.T.I. INTERNATIONAL Pittacora & Crotty, LLC 9550 W. Bormet Drive, # 205 Mokena, IL 60448

AGING PRODUCTS, INC.

teven J. Kadison One of its attorneys

Steven J. Kadison Kamenear Kadison Shapiro & Craig 20 North Clark Street Suite 2200 Chicago, illinois 60602 [phone]