Grede v. IFX Markets, Inc. et al

Filing 152

MOTION by Defendants IFX Markets, Inc., IPGL, Ltd. for judgment on Counts I-V of the Trustee's Second Amended Complaint (Delnero, John)

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.

)
)
)

IFX MAKRETS, INC., IPGL, LTD. and
HAIN CAPITAL HOLDINGS, LTD.,
Defendant.

Honorable Rebecca R. Pallmeyer

Case No. 09-cv-115

)
)
)

)

IFX MARKETS, INC.'S AND IPGL, LTD'S MOTION FOR ENTRY OF JUDGMENT ON
COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT
Defendants, IFX Markets, Inc. and IPGL, Ltd. (“Defendants”), respectfully submits this
Motion for Entry of Judgment on Counts I through V of the Trustee’s Second Amended
Complaint. Specifically, Defendants seek an Order from the Court: (1) entering judgment in
Defendants’ favor and against the Trustee on Counts I through V of the Trustee’s Second
Amended Complaint; (2) directing the Trustee to pay Defendants their pro rata share of the SEG
1 Reserve, the Section 7.20(b) Disputed Claims Reserve, and the SEG 3/4 Reserve within seven
days of this Court’s entry of judgment on Count III; and (3) granting all other just relief.
A Memorandum of Law has been submitted herewith.
Accordingly, in view of the arguments in the accompanying memorandum, Defendants
respectfully request that the Court GRANT their Motion for Entry of Judgment on Counts I
through V of the Trustee’s Second Amended Complaint.

4812-8594-0305.1

Dated: October 13, 2017

Respectfully submitted,
IFX MARKETS, INC. and IPGL, LTD.
By: /s/John S. Delnero
Pedersen & Houpt
161 North Clark Street
Suite 2700
Chicago, IL 60601-3242
Telephone: [phone]
Facsimile: [phone]

2
4812-8594-0305.1

CERTIFICATE OF SERVICE
I, John S. Delnero, an attorney, hereby certify that on October 13, 2017, I electronically
filed the foregoing IFX MARKETS, INC., IPGL, LTD., AND HAIN CAPITAL HOLDINGS,
LTD.’S MOTION FOR ENTRY OF JUDGMENT ON COUNTS I, II, IV and V with the Clerk
of the Court using the CM/ECF system, which caused the same to be served on all counsel of
record via ECF filing.

By: /s/ John S. Delnero
One of its attorneys

4812-8594-0305.1