North American Salt Company v. L.P.N.D., Inc

Filing 26

MOTION by Plaintiff North American Salt Company for judgment (Attachments: # 1 Exhibit A, # 2 Exhibit B)(McGinnis, F.)

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION NORTH AMERICAN SALT COMPANY ) ) Plaintiff ) ) v ) NO. 09 cv 05180 ) L.P.N.D., INC. ) District Judge: Rebecca R. Pallmeyer ) Defendant ) Magistrate Judge:Geraldine Soat Brown ____________________________________) MOTION FOR ENTRY OF SUMMARY JUDGMENT ORDER Plaintiff North American Salt Company ("NASC"), by and through its attorney F. John McGinnis, moves this Court for entry of summary judgment order pursuant to Fed. R. Civ. P. 56 against L.P.N.D., Inc. and in support thereof states as follows: 1. On March 9, 2010, North American Salt Company filed its motion for

summary judgment against L.P.N.D., Inc., together with its Statement of Undisputed Facts and its Memorandum. 2. On March 11, 2010, this Court entered a briefing schedule on the motion

requiring the response to the motion to be filed on or before April 9, 2010. 3. On March 24, 2010 counsel for North American Salt Company received a

fax from counsel for L.P.N.D. Inc. stating that L.P.N.D. Inc. would not be filing a response to the motion for summary judgment and that North American Salt Company should prepare an agreed judgment order. A copy of the fax is attached hereto as Exhibit A.

4.

On or about March 29, 2010 counsel for North American Salt Company

forwarded to counsel for L.P.N.D., Inc. a copy of the Judgment Order attached hereto as Exhibit B. Counsel for L.P.N.D., Inc. stated that he had no objection to the order. WHEREFORE North American Salt Company prays that this Court enter the Judgment Order attached hereto as Exhibit B on its summary judgment motion against L.P.N.D., Inc. NORTH AMERICAN SALT COMPANY By: _____s/ F. John McGinnis__________ F. John McGinnis 105 West Madison Street Suite 2100 Chicago, IL 60602 312-223-1111 312-223-1112 Fax [e-mail] Illinois Bar No. 1839446 CERTIFICATE OF SERVICE F. John McGinnis, an attorney, certifies that I served this MOTION FOR ENTRY OF SUMMARY JUDGMENT ORDER on the below persons at the below addresses by ECF service. Robert D. Rotman Rotman & Elovitz, Ltd. 180 N. LaSalle St., Ste 2101 Chicago, IL 60601 _____s/ F. John McGinnis__________ F. John McGinnis 105 West Madison Street Suite 2100 Chicago, IL 60602 312-223-1111 312-223-1112 Fax [e-mail] Illinois Bar No. 1839446

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