Zurich Specialties London Limited v. Village of Bellwood, Illinois et al

Filing 174

MOTION by Plaintiff Zurich Specialties London Limited for judgment on The Pleadings Against St. Paul Mercury and St. Paul Fire and Marine (Osborne, David)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ZURICH SPECIALTIES LONDON LIMITED, Plaintiff, v. VILLAGE OF BELLWOOD, ILLINOIS, a Municipal Corporation, GREGORY MOORE, DONALD LEMM, NICHOLAS NARDUCCI, ST. PAUL MERCURY INSURANCE COMPANY and ST. PAUL FIRE & MARINE INSURANCE COMPANY Defendants. VILLAGE OF BELLWOOD, ILLINOIS, a Municipal Corporation, GREGORY MOORE, and DONALD LEMM, Counterplaintiffs, v. Z URICH SPECIALTIES LONDON LIMITED, Counterdefendant, VILLAGE OF BELLWOOD, ILLINOIS, a Municipal Corporation, GREGORY MOORE, and DONALD LEMM, Cross-Plaintiffs, v. ST. PAUL MERCURY INSURANCE COMPANY and ST. PAUL FIRE & MARINE INSURANCE COMPANY Cross-Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 07 cv 2171 ) ) Hon. Joan Humphrey Lefkow ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ZURICH'S MOTION FOR JUDGMENT ON THE PLEADINGS AGAINST ST. PAUL MERCURY AND ST. PAUL FIRE AND MARINE Now comes the Plaintiff, Zurich Specialties London Limited, by and through its attorneys, Joseph P. Postel, David S. Osborne and Christopher J. Pickett of Lindsay, Rappaport & Postel, LLC, and submits the following Motion for Judgment on the Pleadings against Defendants, St. Paul Fire & Marine Insurance Company and St. Paul Mercury Insurance Company. In support hereof, Zurich submits its Joint Memorandum of Law, leave for which to file is sought contemporaneously herewith by separate motion. WHEREFORE, the Plaintiff, Zurich Specialties London Limited, respectfully prays that this Honorable Court enter an Order, pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, granting judgment on the pleadings in its favor and against Defendants, St. Paul Fire & Marine Insurance Company and St. Paul Mercury Insurance Company as to Counts III, IV, IX and X of its Amended Complaint for Declaratory Judgment. further relief as the Court deems appropriate under the circumstances. Respectfully submitted, LINDSAY, RAPPAPORT & POSTEL, LLC, By: Joseph P. Postel David S. Osborne Christopher J. Pickett LINDSAY, RAPPAPORT & POSTEL, LLC 10 S. LaSalle St., Suite 1301 Chicago, Illinois 60603 Tel: (312) 629-0208 Attorneys for Plaintiff Zurich Specialties London Limited /s/ David S. Osborne David S. Osborne Bar Number: 06237821 In the alternative, Zurich Specialties London Limited respectfully requests that this Honorable Court render such other and -2-

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