Grede v. Cadent Financial Services et al

Filing 160

MOTION by Defendant Cadent Financial Services for judgment (O'meara, Peter)

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.

)
)
)

CADENT FINANCIAL SERVICES,

Honorable Rebecca R. Pallmeyer

Case No. 09-cv-00127

)
)

Defendant.

)

CADENT FINANCIAL SERVICES’ MOTION FOR ENTRY OF JUDGMENT ON
COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT
Defendant, Cadent Financial Services (“Cadent”), respectfully submits this Motion for
Entry of Judgment on Counts I through V of the Trustee’s Second Amended Complaint.
Specifically, Cadent seeks an Order from the Court: (1) entering judgment in Cadent’s favor and
against the Trustee on Counts I through V of the Trustee’s Second Amended Complaint;
(2) directing the Trustee to pay Cadent its pro rata share of the SEG 1 Reserve and the
Section 7.20(b) Disputed Claims 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, Cadent
respectfully requests that the Court GRANT its Motion for Entry of Judgment on Counts I
through V of the Trustee’s Second Amended Complaint.

4817-4179-5665.3

Dated: October 13, 2017

Respectfully submitted,
CADENT FINANCIAL SERVICES
By: /s/ Geoffrey S. Goodman
Stephen P. Bedell (#3125972)
William J. McKenna (#3124763)
Thomas P. Krebs (#6229634)
Geoffrey S. Goodman (#6272297)
Foley & Lardner LLP
321 North Clark Street, Suite 2800
Chicago, IL 60654-5313
Telephone: [phone]
Facsimile: [phone]

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4817-4179-5665.3

CERTIFICATE OF SERVICE
I, Peter J. O’Meara, an attorney, hereby certify that on October 13 2017, I electronically
filed the foregoing CADENT FINANCIAL SERVICES’ 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/ Peter J. O’Meara
One of its attorneys

4817-4179-5665.3