Rajchel et al v. McHenry County Illinois Sheriff Department et al
Filing
164
MOTION by Plaintiffs Ferdinand H. Rajchel, Jr, Suzanne K. Rajchel for judgment to be entered per Rule 58(a) (Moran, John)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
____________________________________________________________________________
SUZANNE K. RAJCHEL, and
)
FERDINAND H. RAJCHEL, JR.,
)
)
Plaintiffs,
)
Case No. 1:09-cv-03419
)
v.
)
)
Judge Frederick J. Kapala
)
KEITH NYGREN, SHERIFF OF MCHENRY
)
Magistrate Judge P. Michael
COUNTY, ILLINOIS, in his Official Capacity,
)
Mahoney
DEANNA MERRELL, personally, etc., et al.,
)
)
Defendants.
)
MOTION FOR ENTRY OF JUDGMENT
Now the plaintiffs by counsel and move this Honorable Court for entry of final
judgment. Plaintiffs sued defendants for both federal and state claims.
1.
On August 5, 2011, the Court entered an order granted Defendants’ motions
to dismiss on Counts I and III of the Second Amended Complaint with
prejudice.
2.
The same order granted Defendants’ motions to dismiss Count II “without
prejudice to refiling within 30 days. . .” And the remaining Counts IV and
V were also dismissed without prejudice to possibly refiled in state court.
3.
The order also denied Plaintiffs’ motion for leave to file a Third Amended
Complaint.
4.
Plaintiffs request that the judgment be set out promptly in a separate
document as required by Federal Rule of Civil Procedure 58 (a).
5.
Here, Plaintiffs inform the Court that they do not intend to file another
amended complaint or an amended Count II.
6.
No further action other than to enter judgment remains for the Court.
WHEREFORE, Plaintiffs respectfully move the Court to enter judgment pursuant to
Rule 58(a) in a separate document.
Respectfully submitted,
By:
/s/ John Thomas Moran, Jr.
Attorney for Plaintiffs
John Thomas Moran, Jr. (#1954822)
The Moran Law Group
309 West Washington Blvd., Suite 900
Chicago, Illinois 60606
312/630-0200
j.t.moran@moranlawgroup.com
CERTIFICATE OF SERVICE
The undersigned, an attorney, certifies that on September 6, 2011, he served a copy
of the foregoing MOTION FOR ENTRY OF JUDGMENT by means of electronic filing in
accordance with Fed.R.Civ.P. 5, Local Rule 5.5 and the General Order on Electronic Case
Filing (ECF) XI ( C), thereby causing a copy of the foregoing to be served upon all counsel of
record.
By:
/s/ John Thomas Moran, Jr.
Attorney for Plaintiffs.
John Thomas Moran, Jr. (#1954822)
The Moran Law Group
309 West Washington Blvd., Suite 900
Chicago, Illinois 60606
312/630-0200
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