Grede v. Rand Financial Services, Inc.
Filing
143
MOTION by Defendant Rand Financial Services, Inc. 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.
)
)
)
RAND FINANCIAL SERVICES,
Honorable Rebecca R. Pallmeyer
Case No. 09-cv-00128
)
)
Defendant.
)
RAND FINANCIAL SERVICES’ MOTION FOR ENTRY OF JUDGMENT ON
COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT
Defendant, Rand Financial Services (“Rand”), respectfully submits this Motion for Entry
of Judgment on Counts I through V of the Trustee’s Second Amended Complaint. Specifically,
Rand seeks an Order from the Court: (1) entering judgment in Rand’s favor and against the
Trustee on Counts I through V of the Trustee’s Second Amended Complaint; (2) directing the
Trustee to pay Rand 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, Rand
respectfully requests that the Court GRANT its Motion for Entry of Judgment on Counts I
through V of the Trustee’s Second Amended Complaint.
4836-8239-5217.1
Dated: October 13, 2017
Respectfully submitted,
RAND 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: (312) 832-4500
Facsimile: (312) 832-4700
2
4836-8239-5217.1
CERTIFICATE OF SERVICE
I, Peter J. O’Meara, an attorney, hereby certify that on October 13, 2017, I electronically
filed the foregoing RAND 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
4836-8239-5217.1
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