Neace v. Allen & Lewis and Associates

Filing 24

MOTION by Plaintiff Susan Neace for judgment (Hill, Adam)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION SUSAN NEACE, Plaintiff, vs. ALLEN LEWIS & ASSOCIATES, Defendant. ) ) ) ) ) ) ) ) ) Case No. 1:09-cv03907 Judge Harry D. Leinenwber PLAINTIFF'S MOTION TO ENTER JUDGMENT NOW COMES Plaintiff, SUSAN NEACE ("Plaintiff"), through her attorneys, KROHN & MOSS, LTD., and hereby moves this Honorable Court to enter judgment against Defendant, ALLEN LEWIS & ASSOCIATES ("Defendant"), for failure to comply with the terms of the agreement. In support thereof, Plaintiff states as follows: 1. 2. The parties reached a settlement in this matter on October 6, 2009. As a result of Defendant's failure to comply with the terms of the settlement, Plaintiff filed a Motion to Enforce on December 9, 2009. [DE. 18]. 3. On January 21, 2010, this Honorable Court granted Plaintiff's motion, order Defendant to comply with the terms of the settlement within 30 days, or be held in contempt of court, and awarded Plaintiff an additional $150.00 in sanctions. [DE. 23]. 4. As of the date of filing this motion, Defendant has failed to comply with the terms of the settlement agreement. 5. Accordingly, Plaintiff seeks to enter Judgment against Defendant in the settlement amount, plus $150.00 in sanctions. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment against Defendant and in favor of Plaintiff. RESPECTFULLY SUBMITTED, By: /s/ Adam T. Hill Adam T. Hill KROHN & MOSS, LTD. Attorney for Plaintiff 120 W. Madison St., 10th Fl Chicago, Illinois 60602 (312) 578-9428 CERTIFICATE OF SERVICE I, Adam T. Hill, hereby certify that on January 22, 2010, I electronically filed the foregoing with the Clerk of the District Court using the CM/ECF system, which sent notification to all parties of record, and I sent a copy of same to the following via US Mail: Mr. Richard R. Kuritz 200 E. Forsyth St. Jacksonville, FL 32202 By: /s/ Adam T. Hill Adam T. Hill

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