Grede v. Penson Financial Futures, Inc. et al,
Filing
65
MOTION by Defendants Penson Financial Futures, Inc., Penson Futures f/k/a Penson GHCO for judgment on Counts I Through VII of the Trustee's Second Amended Complaint (Casey, Timothy)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FREDERICK J. GREDE, not individually but as )
Liquidation Trustee of the Sentinel Liquidation )
Trust,
)
)
Plaintiff,
v.
)
)
)
PENSON FINANCIAL FUTURES, INC. and
PENSON FUTURES f/k/a PENSON GHCO,
Defendant.
Honorable Rebecca R. Pallmeyer
Case No. 09-cv-00101
)
)
)
)
PENSON FINANCIAL FUTURES, INC. AND PENSON FUTURES’
MOTION FOR ENTRY OF JUDGMENT ON COUNTS I THROUGH VII OF THE
TRUSTEE’S SECOND AMENDED COMPLAINT
Defendants, Penson Financial Futures, Inc. (“PFFI”) and Penson Futures f/k/a Penson
GHCO (“Penson Futures,” and collectively with PFFI, “Penson”), respectfully submit this
Motion for Entry of Judgment on Counts I through VII of the Trustee’s Second Amended
Complaint. Specifically, PFFI and Penson Futures seek an Order from the Court: (1) entering
judgment in PFFI’s favor and against the Trustee on Counts I, II, V, VI and VII of the Trustee’s
Second Amended Complaint; (2) directing the Trustee to pay PFFI its pro rata share of the SEG
1 Reserve and the 7.20 Disputed Claims Reserve within seven days of this Court’s entry of
judgment on Count V; (3) entering judgment in Penson Futures’ favor and against the Trustee on
Counts III through VII of the Trustee’s Second Amended Complaint; (4) directing the Trustee to
pay Penson Futures its pro rata share of the SEG 1 Reserve, the Section 7.20(b) Disputed Claims
Reserve, the SEG 3/4 Reserve, and the SEG 2 Reserve within seven days of this Court’s entry of
judgment on Count V, and (5) granting all other just relief.
A Memorandum of Law has been submitted herewith.
Accordingly, in view of the arguments in the accompanying memorandum, (i) PFFI
respectfully requests that the Court GRANT the Motion for Entry of Judgment on Counts I, II,
V, VI and VII of the Trustee’s Second Amended Complaint; and (ii) Penson Futures respectfully
requests that the Court GRANT the Motion for Entry of Judgment on Counts III through VII of
the Trustee’s Second Amended Complaint.
Dated: October 16, 2017
Respectfully submitted,
PENSON FINANCIAL FUTURES, INC. and
PENSON FUTURES f/k/a PENSON GHCO
By:/s/Timothy R. Casey
One of their attorneys
Timothy R. Casey, Esq. (ARDC #6180828)
DRINKER BIDDLE & REATH LLP
191 North Wacker Drive, Suite 3700
Chicago, Illinois 60606
Telephone: (312) 569-1000
Fax: (312) 569-3000
timothy.casey@dbr.com
2
90285173.3
CERTIFICATE OF SERVICE
I, Timothy R. Casey, an attorney, hereby certify that on October 16, 2017, I electronically
filed the foregoing PENSON FINANCIAL FUTURES, INC. and PENSON FUTURES’
MOTION FOR ENTRY OF JUDGMENT ON COUNTS I THROUGH VII OF THE
TRUSTEE’S SECOND AMENDED COMPLAINT with the Clerk of the Court using the
CM/ECF system, which caused the same to be served on all counsel of record via the Court’s
ECF system.
By: /s/Timothy R. Casey
90285173.3
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