Scott v. 7-Beauty, Inc. d/b/a 7 Beauty Supply et al

Filing 45

MOTION by Plaintiff Terrell R Scott for judgment Plaintiff's Motion For Entry Of Judgment (Attachments: # 1 Exhibit A, # 2 Draft Order Of Judgment)(Billhorn, John)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TERRELL R. SCOTT on behalf of himself and all other plaintiffs known and unknown, Plaintiff v. 7-BEAUTY, INC. D/B/A 7 BEAUTY SUPPLY, SUHYUN KIM, INDIVIDUALLY, AND JAMES KIM INDIVIDUALLY Defendants ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 10 CV 2225 Honorable Judge Kendall Magistrate Judge Keys JURY DEMAND PLAINTIFF'S MOTION FOR ENTRY OF JUDGMENT NOW COMES Plaintiff, TERRELL R. SCOTT, through his attorney of record, JOHN W. BILLHORN, and for his Motion For Entry Of Judgment, state as follows: 1.) The parties settled and compromised the disputes of this litigation and entered into a written settlement agreement. The settlement agreement is attached hereto as Exhibit A. 2.) The Agreement provides for ten (10) installment payments to be made by the first of each month, starting with October 1, 2011 with due dates certain and penalties for late payments. See paragraph eight (8). Additionally, at paragraph 26, the Agreement provides for a Confession of Judgment should Defendants default on the terms of the installment payments. 1 3) On October 18, 2011, Plaintiff s attorney office received notification that Defendants first payment for October, 2011 was returned NSF. Defendants have failed to cure that NSF check and have also defaulted on the November 1, 2011 payment. 4) Attached is a proposed Judgment Order Plaintiff requests to be entered by the Court. WHEREFORE, Plaintiff requests that Judgment be entered against Defendants, 7BEAUTY, INC. D/B/A 7 BEAUTY SUPPLY, SUHYUN KIM, INDIVIDUALLY, AND JAMES KIM INDIVIDUALLY, and for such other relief as the Court deems appropriate under the circumstances. Respectfully submitted, Electronically Filed 11/14/2011 s/ John W. Billhorn ________________________ John W. Billhorn, attorney for Plaintiff, and all other Plaintiffs similarly situated, known or unknown. BILLHORN LAW FIRM 120 S. State Street, Suite 400 Chicago, IL 60603 (312) 853-1450 2

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