Grede v. Farr Financial, Inc.

Filing 152

MOTION by Defendant Farr Financial, Inc. for judgment (Attachments: # 1 Memorandum of Law, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B, # 4 Exhibit Exhibit C, # 5 Exhibit Exhibit D, # 6 Notice of Filing Notice of Motion)(Becker, Henry)

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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. ) ) ) FARR FINANCIAL, INC., Honorable Rebecca R. Pallmeyer Case No. 09-cv-00120 ) ) Defendant. ) FARR FINANCIAL, INC.’S MOTION FOR ENTRY OF JUDGMENT ON COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT Defendant, Farr Financial, Inc. (“Farr”), respectfully submits this Motion for Entry of Judgment on Counts I through V of the Trustee’s Second Amended Complaint. Specifically, Farr seeks an Order from the Court: (1) entering judgment in Farr’s favor and against the Trustee on Counts I through V of the Trustee’s Second Amended Complaint; (2) directing the Trustee to pay Farr its 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, Farr respectfully requests that the Court GRANT its Motion for Entry of Judgment on Counts I through V of the Trustee’s Second Amended Complaint. Dated: October 16, 2017 Respectfully submitted, FARR FINANCIAL, INC. By: /s/ Henry K. Becker Its Attorney Henry K. Becker, atty at law 227 South Blvd. Oak Park, IL 60302 312-278-3004 hb@hkb-law.com No. 6187414 2 CERTIFICATE OF SERVICE I, Henry K. Becker, hereby certify that on October 16, 2017, I electronically filed the foregoing FARR FINANCIAL, INC.’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/ Henry K. Becker

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