Vazquez et al v. Icosium Kafe Ltd. et al

Filing 60

MOTION by Plaintiffs Svetlana Eckhoff, Fredy Vazquez, Jonatan Vazquez for judgment (Agreed) (Luka, Paul)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FREDY VAZQUEZ,
SVETLANA ECKHOFF and
JONATAN VAZQUEZ on behalf of
themselves and all other employees
similarly situated, known and unknown,
Plaintiffs,

No. 11 CV 415
Judge Feinerman

v.
ICOSIUM KAFE, LTD., a dissolved
Illinois corporation,
BELKACEM ELMETENNANI,
individually, and
NERINGA PUKELIS, individually,

Magistrate Judge Cole

Defendants.
AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT
By and through their attorneys, the plaintiffs state as follows.
1.

The parties participated in a settlement conference conducted by

Magistrate Judge Cole and were able to reach an agreement.
2.

The parties’ settlement agreement has now been reduced to a

confidential, written settlement agreement, which has been fully executed by the
parties as of August 27, 2012.
3.

Among other things, the terms of the parties’ confidential settlement

agreement call for the entry of a consent judgment, a copy of which is attached as
Exhibit A (an additional copy has been submitted to this Court’s proposed order
inbox).

4.

Upon entry of the consent judgment, the captioned case may be

dismissed with prejudice and without costs.
WHEREFORE, the plaintiffs pray that this Court will enter the consent
judgment attached as Exhibit A, and then dismiss the captioned case with prejudce
and without costs.
Respectfully submitted,
/s/Paul Luka
One of the Plaintiffs’ Attorneys
Roy P. Amatore, Esq.
Paul Luka, Esq.
AMATORE & ASSOCIATES, P.C.
120 S. State Street • Suite 400
Chicago, IL 60603
312.236.9825

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EXHIBIT
A

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FREDY VAZQUEZ,
SVETLANA ECKHOFF and
JONATAN VAZQUEZ on behalf of themselves
and all other employees similarly situated,
known and unknown,

)
)
)
)
)
)
Plaintiffs,
)
)
v.
)
)
ICOSIUM KAFE, LTD., a dissolved Illinois
)
corporation, and BELKACEM ELMENTENNAI, )
individually
)
Defendants.
)

No. 11 CV 415
Judge Feinerman
Magistrate Judge Cole

CONSENT JUDGMENT and DISMISSAL
This case coming before the Court for entry of the Consent Judgment entered into by and
between Plaintiffs, Fredy Vazquez, Svetlana Eckhoff and Jonatan Vazquez (collectively,
“Plaintiffs”), and Defendants Icosium Kafe, Ltd., and Belkacem Elmentennai (collectively,
“Defendants”), with respect to the Complaint filed by Plaintiffs, it is hereby ordered as follows:
1.

The entry of Consent Judgment entered into by the Plaintiffs and

Defendants is hereby granted.
2.

Judgment is entered in favor of the plaintiff, Fredy Vazquez, and against

the defendants, Ikosium Kafe, Ltd., and Belkacem Elmentennai, and each of them, in the
amount of $13,039.40. Pursuant to the parties’ agreement, the defendants may withhold
applicable income and employment taxes from this amount.
3.

Judgment is entered in favor of the plaintiff, Jonatan Vazquez, and against

the defendants, Ikosium Kafe, Ltd., and Belkacem Elmentennai, and each of them, in the

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amount of $5,387.80. Pursuant to the parties’ agreement, the defendants may withhold
applicable income and employment taxes from this amount.
4.

Judgment is entered in favor of the plaintiff, Svetlana Eckhoff, and against

the defendants, Ikosium Kafe, Ltd., and Belkacem Elmentennai, and each of them, in the
amount of $301.40. Pursuant to the parties’ agreement, the defendants may withhold
applicable income and employment taxes from this amount.
5.

Judgment is entered in favor of the plaintiff’s attorneys, Amatore &

Associates, P.C., and against the defendants, Ikosium Kafe, Ltd., and Belkacem
Elmentennai, and each of them, in the amount of $3,271.40, as and for disputed
attorneys’ fees and costs. The defendants shall not withhold income and employment
taxes from this amount, but may issue an IRS Form 1099 to Amatore and Associates,
P.C.
6.

Pursuant to the parties’ agreement, this Consent Judgment may not be

enforced for a period of two years from entry hereof.
7.

All claims against defendant Neringa Pukelis are hereby dismissed with

prejudice with each party to bear his or her own costs and attorneys fees.

DATED:

__________, 2012

ENTER,

Hon. Gary Feinerman
United States District Judge
Nancy A. Temple
Joshua Diller
542 S. Dearborn, Suite 1060
Chicago, IL 60605
[phone]
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[e-mail]
[e-mail]

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