Smith V. Rosebud Farmstand et al

Filing 366

MOTION by Plaintiff Robert Smith for judgment :PLAINTIFF'S MOTION TO EXECUTE AND ENTER MEMORANDUM OF JUDGMENT (Longo, Joseph)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
ROBERT SMITH,
Plaintiff,
v.
ROSEBUD FARM, INC., DBA, ROSEBUD
FARMSTAND, ROCKY MENDOZA,
CARLOS CASTANEDA, PABLO VELASCO,
ORLANDO ALARCON, LUIS ARAMBULA,
MARCOS ROMERO, FREDERICO LOPEZ
JOSÉ G MARTINEZ

Defendants.

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Civil Action No. 11-CV-9147

Honorable Judge Robert M. Dow Jr.
Jury Demand

PLAINTIFF'S MOTION TO EXECUTE AND ENTER MEMORANDUM OF
JUDGMENT
On 14 July 2017, the Honorable Judge Dow entered judgment against the defendants on
all counts and claims and in favor of the plaintiff. This judgment was based upon the jury's
verdict. The jury found in favor of the plaintiff on all claims and against the defendants.
The jury surrendered approximately one one-half weeks of their lives to consider and
analyze the evidence carefully. The plaintiff's attorney has never had such a highly educated jury,
that is, one juror being a PhD clinical psychologist, one juror being a PhD college president, one
juror being a retired school district administrator and so forth. As the jury has made its decision,
some may think and feel that all inferences and inclinations should be given to the plaintiff and
against the defendants from all angles. Effectively, at every stage, all measures should be taken
to protect the jury's verdict and His Honor's judgment.

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Towards that end, the plaintiff has prepared a memorandum of judgment. Attached. The
plaintiff respectfully requests that this Court execute the memorandum of judgment.
Wherefore, the plaintiff prays that this Court will grant the plaintiff's motion to execute
and enter the attached memorandum of judgment.
Respectfully submitted,
______________________________
Joseph Anthony Longo

J.M.J.
LONGO AND ASSOCIATES LTD.
Joseph Anthony Longo
Attorney for Plaintiff
2100 West Haven
Mt. Prospect, IL 60056
[phone]
[e-mail]
Attorney No. 53635
CERTIFICATE OF SERVICE

I, Joseph Anthony Longo, an attorney, certify that I served this PLAINTIFF'S
MOTION TO EXECUTE AND ENTER MEMORANDUM OF JUDGMENT by electronic
filing on 31 August 2017 before 5pm. Under penalties as provided by law pursuant
to 735 ILCS, Sec 5/1-109, I certify that the statements set forth in this Certificate
of Service are true and correct.
____________________________
Joseph Anthony Longo

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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
ROBERT SMITH,

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Plaintiff,
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v.
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ROSEBUD FARM, INC., DBA, ROSEBUD )
FARMSTAND, ROCKY MENDOZA,
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CARLOS CASTANEDA,
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Defendants.
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Honorable Judge Robert M. Dow Jr.
Civil Action No. 11-CV-9147

MEMORANDUM OF JUDGMENT
On 14 July 2017, judgment was entered in this Court and in favor of the plaintiff, Robert Smith,
and against Rosebud Farm Inc. d/b/a Rosebud Farmstand whose address is 525 E. 130th St.,
Chicago, IL 60628. The amount of the judgment is $559,656.57.

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Honorable Judge Robert Michael Dow, Jr.

Date:_______________________
J.M.J.
LONGO AND ASSOCIATES LTD.
Joseph Anthony Longo
Attorney for Plaintiff
2100 West Haven
Mt. Prospect, IL 60056
[phone]
[e-mail]
Attorney No. 53635

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