Grede v. American National Trading Corp. et al

Filing 171

MOTION by Defendant American National Trading Corp. for judgment (Attachments: # 1 Memorandum of law, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B, # 4 Notice of Filing Notice of Motion)(Becker, Henry)

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.

)
)
)

AMERICAN NATIONAL TRADING CORP.,

Honorable Rebecca R. Pallmeyer
Case No. 09-cv-00137

)
)

Defendant.

)

AMERICAN NATIONAL TRADING CORP.’S MOTION FOR
ENTRY OF JUDGMENT ON COUNTS I THROUGH V OF THE
TRUSTEE’S SECOND AMENDED COMPLAINT
Defendant, American National Trading Corp. (“American National”), respectfully
submits this Motion for Entry of Judgment on Counts I through V of the Trustee’s Second
Amended Complaint. Specifically, American National seeks an Order from the Court: (1)
entering judgment in American National’s favor and against the Trustee on Counts I through V
of the Trustee’s Second Amended Complaint; (2) directing the Trustee to pay American National
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, American
National 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,
AMERICAN NATIONAL TRADING CORP.
By:/s/ Henry K. Becker ]
Its Attorney

Henry K. Becker, atty at law
227 South Blvd.
Oak Park, IL 60302
312-278-3004
[e-mail]
No. 6187414

2

CERTIFICATE OF SERVICE
I, Henry K. Becker, an attorney, hereby certify that on October 16, 2017, I electronically
filed the foregoing AMERICAN NATIONAL TRADING CORP.’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 ]