Medeiros v. Client Services, Inc.

Filing 17

MOTION by Defendant Client Services, Inc. for judgment on the Pleadings (Degen, Daniel)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION LYNAL ³LEONARD “ MEDEIROS Plaint iff, v. CLIENT SERVICES, corporation, Defendant. INC. a ) ) ) ) ) ) ) Missouri ) ) ) )

Case No.: 09-CV-6170 Judge: Hon. John W. Darrah

CLIENT SERVICES, INC. ¶S 12(C) MOTION FOR JUDGMENT ON THE PLEADINGS Defendant, CLIENT SERVICES, INC. ( ³Client Services “), by and through its attorneys, David M. Schultz and Daniel R. Degen, and pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, moves for judgment on the pleadings, enter judgment in its favor as to all relief sought in plaintiff ¶s complaint against Client Services, with prejudice and in support thereof state as follows: 1. On October 2, 2009, plaintiff filed his Complaint alleging violations of the Fair

Debt Collection Practices Act, 15 U.S.C. §1692, et seq. against Client Services. 2. Plaintiff ¶s claims against Client Services fail for the reasons discussed in the

Memorandum of Law filed contemporaneously with this Motion. WHEREFORE, Defendant, Client Services, Inc., respectfully requests that this Court enter an order dismissing plaintiff ¶s Complaint against it with prejudice and for any other relief that this Court deems appropriate and just.

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CLIENT SERVICES, INC. David M. Schultz, ARDC Number 6197596 Daniel R. Degen, ARDC Number 6296199 Hinshaw & Culbertson LLP 222 N. LaSalle Street, Suite 300 Chicago , Illinois 60601 312-704-3000 [e-mail] m [e-mail] m By: s/ Daniel R. Degen Daniel R. Degen

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CERTIFICATE OF SERVICE I hereby certify that on April 26, 2009, I electronically filed the above and foregoing CLIENT SERVICES, INC. ¶S 12(C) MOTION FOR JUDGMENT ON THE PLEADINGS with the Clerk of the U.S. District Court, using the CM/ECF system reflecting service of to be served on all parties of record. HINSHAW & CULBERTSON LLP David M. Schultz, ARDC Number 6197596 Daniel R. Degen, ARDC Number 6296199 Hinshaw & Culbertson LLP 222 N. LaSalle Street, Suite 300 Chicago , Illinois 60601 312-704-3000 [e-mail] m [e-mail] m s/ Daniel R. Degen Daniel R. Degen

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