Taco v. Chicago Property Services, Inc. et al

Filing 19

MOTION by Plaintiff Pablo Taco, Defendants Chicago Property Services, Inc., Trinacorp, Inc. for judgment (Agreed Motion for Stipulated Judgment) (Attachments: # 1 Exhibit A, # 2 Exhibit B)(McFetridge, Jane)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PABLO TACO, Plaintiff, v. CHICAGO PROPERTY SERVICES, INC. and TRINACORP, INC., Defendants. ) ) ) ) ) ) ) ) )

Case No. 08CV2919 Judge Zagel Magistrate Judge Denlow

AGREED MOTION FOR STIPULATED JUDGMENT AND DISMISSAL Plaintiff Pablo Taco and Defendants Chicago Property Services, Inc. and Trinacorp, Inc. (collectively, "the parties"), hereby move for the entry of a stipulated judgment and dismissal of this case with prejudice. In support of this Motion, the parties state as follows: 1. The parties have entered into an Agreement and General Release which provides for the resolution of this action without further litigation. A copy of this Agreement and General Release is attached as Exhibit A to this Motion. 2. Paragraph 3 of the Agreement and General Release provides that the parties will file with the Court this Agreed Motion for Stipulated Judgment. (Ex. A, ¶ 3.) 3. A proposed Stipulated Judgment is attached as Exhibit B to this Motion. It will be also be contemporaneously submitted to [e-mail]. WHEREFORE, the parties hereby request that the Court: a. Approve the attached Agreement and General Release as a just and fair resolution of this action; b. Enter the attached Stipulated Judgment; and

c. Dismiss this action with prejudice, and without attorneys' fees or costs assessed to any party (except insofar as such fees or costs are provided for in the attached Agreement and General Release).

Dated: November 4, 2008

PABLO TACO By: s/ Marc J. Siegel One of Plaintiff's Attorneys

Marc J. Siegel Jessica Fayerman Caffarelli & Siegel Ltd. 180 N. Stetson, Suite 3150 Chicago, IL 60601

Dated: November 4, 2008

CHICAGO PROPERTY SERVICES, INC. and TRINACORP, INC. By: s/ Jane M. McFetridge One of Defendants' Attorneys

Jane M. McFetridge Neil H. Dishman Jackson Lewis LLP 320 West Ohio Street, Suite 500 Chicago, IL 60610 [phone]

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CERTIFICATE OF SERVICE The undersigned, an attorney, certifies that on November 4, 2008, he caused a true and correct copy of the foregoing Agreed Motion for Stipulated Judgment to be filed with the Court by electronic filing protocols, and that same will therefore be electronically served upon all attorneys of record registered with the Court's ECF/CM system, including: Marc J. Siegel Jessica Fayerman Caffarelli & Siegel Ltd. 180 N. Stetson, Suite 3150 Chicago, IL 60601

s/ Neil H. Dishman Neil H. Dishman

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