Grede v. Velocity Futures, LP
MOTION by Defendant Velocity Futures, LP for judgment (O'meara, Peter)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
FREDERICK J. GREDE, not individually but as )
Liquidation Trustee of the Sentinel Liquidation )
VELOCITY FUTURES, LP,
Honorable Rebecca R. Pallmeyer
Case No. 09-cv-00135
VELOCITY FUTURES, LP’S MOTION FOR ENTRY OF JUDGMENT ON
COUNTS I THROUGH V OF THE TRUSTEE’S SECOND AMENDED COMPLAINT
Defendant, Velocity Futures, LP (“Velocity”), respectfully submits this Motion for Entry
of Judgment on Counts I through V of the Trustee’s Second Amended Complaint. Specifically,
Velocity seeks an Order from the Court: (1) entering judgment in Velocity’s favor and against
the Trustee on Counts I through V of the Trustee’s Second Amended Complaint; (2) directing
the Trustee to pay Velocity 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, Velocity
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 13, 2017
VELOCITY FUTURES, LP
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
CERTIFICATE OF SERVICE
I, Peter J. O’Meara, an attorney, hereby certify that on October 13, 2017, I electronically
filed the foregoing VELOCITY FUTURES, LP’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/ Peter J. O’Meara
One of its attorneys
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