Carradine v. Cortes et al

Filing 96

MOTION by Plaintiff Carolyn Carradine for judgment and Dismissal (Agreed) (Attachments: # 1 Exhibit Proposed Order)(Neslund, Jeffrey)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CAROLYN CARRADINE,

)
)
Plaintiff,
)
)
v.
)
)
CHICAGO POLICE OFFICER JOSE
)
CORTES, STAR NO. 18443 and CHICAGO
)
POLICE OFFICER JOE MARTIN, STAR
)
NO. 7734, individually and as employee/Agents )
of the CITY OF CHICAGO, a municipal
)
Corporation,
)
)
Defendants.
)

No.: 08 C 6507
Judge Dow Jr.
Magistrate Judge Ashman

JURY DEMAND

AGREED MOTION FOR JUDGMENT and DISMISSAL
Now comes the plaintiff, CAROLYN CARRADINE, by and through her attorneys,
JEFFREY J. NESLUND and ROBERT ROBERTSON, and Defendants, CHICAGO POLICE
OFFICER JOSE CORTES, STAR NO. 18443 and CHICAGO POLICE OFFICER JOE
MARTIN, STAR NO. 7734, by their attorneys, SHNEUR NATHAN of Andrew M. Hale &
Associates, LLC, jointly request this Court enter an order for Judgment and dismissal and in
support thereof, states as follows:
1. On February 18, 2011, a jury returned a verdict in Plaintiff’s favor in the amount of
$250,000.00 on her malicious prosecution claim against Defendant Officer Cortes.
2. On March 19, 2011, Defendant Cortes filed a motion for judgment as a matter of law.
3. On June 1, 2011 Defendant Cortes filed a motion for a new trial pursuant to Rule
60(b)(2) in which he claimed newly discovered evidence.

4. The parties have since entered into settlement negotiations and resolved this matter for
$215,000.00
5. Therefore, the parties request this Court enter an order :
(a.) for judgment to be entered in the amount of $215,000.00 in favor of Plaintiff in
complete and total satisfaction of the judgment previously entered on February 18, 2011;
this amount to be paid within 30 days of entry of this order;
(b.) the judgment entered in this case against Chicago Police Officer Jose Cortes is
satisfied upon receipt of the $215,000.00 to Plaintiff and Chicago Police Officer Jose Cortes
is hereby released and all claims against all defendants are dismissed with prejudice.

/s/ Jeffrey J. Neslund
Jeffrey J. Neslund
Attorney for Plaintiff

/s/ Shneur Nathan
Shneur Nathan
One of the Attorneys for Defendants

Jeffrey J. Neslund
Law Offices of Jeffrey J. Neslund
150 N. Wacker Drive, Suite 2460
Chicago, IL 60606
[phone]

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