Grede v. Country Hedging, Inc.

Filing 152

MOTION by Defendant Country Hedging, Inc. for judgment (Coco, Nathan)

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.

)
)
)

COUNTRY HEDGING, INC.,

Honorable Rebecca R. Pallmeyer

Case No. 09-cv-00130

)
)

Defendant.

)

COUNTRY HEDGING, INC.’S MOTION FOR ENTRY OF JUDGMENT ON
COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT
Defendant, Country Hedging, Inc. (“Country Hedging”),1 respectfully submits this
Motion for Entry of Judgment on Counts I through V of the Trustee’s Second Amended
Complaint. Specifically, Country Hedging seeks an Order from the Court: (1) entering judgment
in Country Hedging’s favor and against the Trustee on Counts I through V of the Trustee’s
Second Amended Complaint; (2) directing the Trustee to pay Country Hedging 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, Country
Hedging respectfully requests that the Court GRANT its Motion for Entry of Judgment on
Counts I through V of the Trustee’s Second Amended Complaint.

1

In 2012 (years after this lawsuit was filed), Country Hedging, Inc. changed its name to CHS
Hedging, Inc., and subsequently changed it to CHS Hedging, LLC in 2014.

Dated: October 13, 2017

Respectfully submitted,
COUNTRY HEDGING, INC.
By: /s/ Nathan F. Coco
Nathan F. Coco
Megan Thibert-Ind
McDermott Will & Emery LLP
444 West Lake Street
Suite 4000
Chicago, IL 60606-0029
Tel: [phone]

2

CERTIFICATE OF SERVICE
I, Nathan F. Coco, an attorney, hereby certify that on October 13, 2017, I electronically
filed the foregoing COUNTRY HEDGING, 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/ Nathan F. Coco
One of its attorneys