Peerless Industries, Inc. v. Crimson AV, LLC

Filing 809

MOTION by Defendant Crimson AV, LLC for judgment for Entry of Satisfaction of Judgment (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Ryndak, Peter)

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PEERLESS INDUSTRIES, INC, Plaintiff, vs. CRIMSON AV, LLC, Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 1:11-cv-1768 Hon. Joan H. Lefkow Magistrate Judge Susan E. Cox MOTION FOR ENTRY OF SATISFACTION OF JUDGMENT Comes now the Defendant/Judgment Debtor, Crimson AV, LLC (“Crimson”), through counsel Miles Sukovic of Sukovic Law Group, a Professional Corporation and Peter Ryndak of Johnson & Bell, Ltd., and moves this Court to enter a satisfaction of judgment in the above titled action. In support thereof, Crimson states as follows: 1. On or about November 27, 2018, this Court granted a final judgment (Dkt. No. 798) in favor of Plaintiff and against Crimson in the amount of $51,419.19, inclusive of pre-judgment interest. 2. On August 7, 2020, Crimson, through counsel, paid to Plaintiff’s counsel the full judgment amount by issuing check No. 7169 in the amount of $51,419.19 (See Exhibit A) satisfying the judgment in full. 3. On August 25, 2020, Crimson, through counsel, paid $2,328.27 in post-judgment interest by issuing to Plaintiff check No. 7188 in the amount of $2,324.51 and cash in the amount of $3.76, (See Exhibit B) satisfying the post judgment interest in full. 4. On September 22, 2020, Crimson’s counsel emailed Plaintiff’s counsel asking him to file a statement of satisfaction of the judgment executed and acknowledged either by the Plaintiff, or by a legal representative or assignee of the Plaintiff pursuant to the District Court of the Northern District of Illinois’ L.R.58.1. (See Exhibit C) Plaintiff’s counsel did not respond. 5. On November 4, 2020, Crimson’s counsel again asked Plaintiff to file an executed statement of satisfaction of the judgment. Plaintiff’s counsel responded that he would get back to Crimson’s counsel. (See Exhibit D) However, Plaintiff’s counsel has not responded. 6. To date, Plaintiff has ignored Crimson’s requests to enter and file an executed statement of satisfaction of the judgment pursuant to NDIL L.R.58.1. 7. Crimson has shown that it has satisfied the judgment in full, and the Plaintiff has failed to file a Notice of Satisfaction. WHEREFORE, the Defendant/Judgment Debtor, Crimson AV, LLC, now moves the Court to order entry of Satisfaction of Judgment that the judgment be vacated pursuant to F.R.C.P. 60(b)(5) and that this action be dismissed with prejudice. Dated: June 3, 2021 Respectfully submitted, /s/ Peter R. Ryndak One of the attorneys for Crimson AV LLC Peter Ryndak JOHNSON & BELL, LTD. 33 W. Monroe St., Suite 2700 Chicago, Illinois 60603 (312) 372-0770 M. Miles Sukovic Sukovic Law Group, a PC 6 Gloucester Court Lincolnshire, Illinois 60069 (312) 810-5123 -2- CERTIFICATE OF SERVICE I hereby certify that on June 3, 2021, I have electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which sent notification of such filing to all parties of record. /s/ Peter R. Ryndak -3-

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