Markel American Insurance Company v. Dolan et al

Filing 126

MOTION by Plaintiff Markel American Insurance Company for judgment (Cano, Christopher)

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS IN ADMIRALTY MARKEL AMERICAN INSURANCE COMPANY, ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, vs. RYAN DOLAN and REGIONS BANK, Defendants/Counterclaim Plaintiffs CASE NO. 09-CV-4431 Judge Hibbler PLAINTIFF’S MOTION ENTRY OF JUDGMENT ON AWARD OF COSTS COMES NOW the Plaintiff, MARKEL AMERICAN INSURANCE COMPANY (hereinafter “MARKEL”), by and through its undersigned attorneys and pursuant to Rule 58(d) of the Federal Rules of Civil Procedure, and the applicable Local Rules for the United State District Court for the Northern District of Illinois, files the present motion to have this Court’s January 18, 2013 award of costs entered as a judgment against the Defendants, RYAN DOLAN, and REGIONS BANK, and states as follows: 1. On January 18, 2013, following this Court’s summary judgment order, as well as a motion by the Plaintiff brought pursuant to Fed. R. Civ. P. 54(d)(1), this Court awarded the Plaintiff $1,549.40 in costs. 2. To date, Defendants have failed to pay the costs awarded to Plaintiff. 3. In order to enforce this Court’s order of January 18, 2013 and to collect the $1,549.40 in costs awarded by the Court, a separate document evidencing the entry of judgment against the Defendants in the amount of $1,549.40 is required to be entered by the Court and Clerk under Rule 58(a) of the Federal Rules of Civil Procedure. 1 4. Because both Defendants are named insureds under the disputed policy of marine insurance, Plaintiff hereby requests that as part of the judgment, this Court enter judgment in the amount of $1,549.40 against both Defendants, jointly and severally, so that Plaintiff may collect the entire award of costs entered by this Court from either Defendant. WHEREFORE, Plaintiff, MARKEL AMERICAN INSURANCE COMPANY, hereby requests that this Court enter judgment against Defendants, RYAN DOLAN and REGIONS BANK, jointly and severally, in the amount of $1,549.40 for the costs awarded to Plaintiff pursuant to this Court’s January 18, 2013 Order, and grant any and all such further relief as may be appropriate. Dated: February 20, 2013 Respectfully submitted, Markel American Insurance Company By: /s/ Christopher M. Cano One of Its Attorneys BOLLINGER, RUBBERY & GARVEY 500 West Madison Street Suite 2300 Chicago, Illinois 60661 (312) 466-8000 GOLDMAN & HELLMAN Attorneys for Plaintiff 800 S.E. 3rd Avenue 4th Floor Ft. Lauderdale, Florida 33316 (954) 356-0460 2 CERTIFICATE OF SERVICE I hereby certify that on this 20th day of February, 2013, the foregoing document was electronically filed with the Clerk of the Court using the CM/ECF system, which sent notification to all counsel of record. /s/ Christopher M. Cano 3

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