Gilbert v. City of Chicago, The et al

Filing 31

MOTION by Plaintiff Homer Gilbert, Defendants City of Chicago, The, B. Chen, B. Velez, Supervising Police Officer, Curtisteen Gilbert for judgment agreed (Scahill, Timothy)

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION HOMER GILBERT, ) ) Plaintiff, ) ) vs. ) ) THE CITY OF CHICAGO, a municipal ) corporation, OFFICER B. CHEN, ) OFFICER B. VELEZ, SUPERVISING ) POLICE OFFICER, OFFICER ) CURTISTEEN GILBERT, ) ) Defendants. )

No.:

08 CV 4698

Honorable Judge John W. Darrah Magistrate Judge Geraldine Soat Brown

AGREED MOTION FOR ENTRY OF JUDGMENT NOW COME the parties, by and through their attorneys of record, and for their agreed motion for entry of judgment, state as follows: 1. The above-captioned matter was filed on August 18, 2008 by plaintiff, HOMER

GILBERT, against defendants THE CITY OF CHICAGO, Chicago Police Officers BRIAN CHEN, BENJAMIN VELEZ, and CURTISTEEN GILBERT. 2. 3. matter. 4. Subsequent to this filing, plaintiff's counsel contacted defendants' counsel and Discovery closed in this matter on September 30, 2009. On November 9, 2009, defendant moved for summary judgment on all counts of this

advised that plaintiff would not be opposing this motion and would consent to entry of judgment in favor of defendants. 5. The parties have contemporaneously submitted a proposed Order of Judgment via this

Court's procedures for submitting such orders via electronic mail. WHEREFORE the parties pray that judgment be entered in this matter as set forth in the proposed order submitted to this Court and that this matter be dismissed with prejudice in it entirety.

Respectfully submitted, BORKAN & SCAHILL, LTD. By: s/ Timothy P. Scahill Timothy P. Scahill Steven B. Borkan (6193463) Timothy P. Scahill (6287296) BORKAN & SCAHILL, LTD. Two First National Plaza 20 South Clark Street Suite 1700 Chicago, Illinois 60603 [phone]