Persis International, Inc. et al v. Burgett, Inc.
Filing
207
MOTION by Counter Defendants Persis International, Inc., Edward F. Richards, Plaintiffs Persis International, Inc., Edward F. Richards for judgment (Biagi, Richard)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
PERSIS INTERNATIONAL, Cou and
INC.
EDWARD F. RICHARDS,
Plaintiffs,
Civil Action No. 1:09-cv-07451
v.
The Honorable Ronald A. Guzman
United States District Court Judge
BURGETT, INC.,
Defendant.
***
BURGETT, INC.,
Counterclaimant,
v.
PERSIS INTERNATIONAL, INC. and
EDWARD F. RICHARDS,
Counterdefendants.
PLAINTIFFS EDWARD F. RICHARDS’ AND PERSIS INTERNATIONAL, INC.’S
MOTION FOR JUDGMENT AND MOTION TO SET ASIDE THE COURT’S
PREVIOUS ORDER [DOCKET NO. 192] AS MOOT
Pursuant to Rule 56 of the Federal Rules of Civil Procedure, Plaintiffs Edward F.
Richards and Persis International, Inc. (“Plaintiffs”), by and through their counsel, hereby move
this Court to enter judgment against Defendant and Counterclaimant Burgett, Inc. (“Burgett”) on
Counts II and III of Burgett’s Counterclaims. In addition, Plainitffs’ respectfully move the Court
to set aside its its November 1, 2011 Order (Docket No. 192) as moot in light of the facts and law
set forth it their concurrently filed Memorandum of Law in support of this Motion.
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WHEREFORE, Plaintiffs Persis International, Inc. and Edward F. Richards respectfully
request that the Court:
(a)
Enter judgment against Burgett on its remaining counterclaims (Counts II and
III);
(b)
Strike the Court’s Order of November 1, 2011 (Docket No. 192) which reset the
summary judgment briefing schedule;
(c)
Enter an Order reinstating the previously filed briefs in connection with the
parties’ Cross-Motions for Summary Judgment (Docket Nos. 125-126, 161-173)
and disregard the newly filed briefs (Docket Nos. 193-196, 200-206);
(d)
award Plaintiffs their attorneys’ fees and costs in filing this Motion; and
(e)
award Plaintiffs such other and further relief as the Court deems appropriate.
Dated: December 16, 2011
Respectfully submitted,
s/ Richard B. Biagi
Richard B. Biagi, Esq.
Kevin J. McDevitt, Esq.
Lisa A. Iverson, Esq.
Jeremy M. Roe, Esq.
Daniel J. Schaeffer, Esq.
NEAL & MCDEVITT, LLC
1776 Ash Street
Northfield, IL 60093
(847) 441.9100 (Telephone)
(847) 441.0911 (Facsimile)
Counsel for Persis International, Inc.
and Edward F. Richards
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing PLAINTIFFS EDWARD F.
RICHARDS’ AND PERSIS INTERNATIONAL, INC.’S MOTION FOR JUDGMENT AND
MOTION TO SET ASIDE THE COURT’S PREVIOUS ORDER AS MOOT was served on all
counsel of record via CM/ECF on December 16, 2011.
/s/ Richard B. Biagi
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