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)

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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: (312) 261-2185 Facsimile: (312) 261-1185 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

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