Innovative Sports Management, Inc. v. Ciepiaszuk et al

Filing 13

MOTION by Plaintiff Innovative Sports Management, Inc.Reinstate , MOTION by Plaintiff Innovative Sports Management, Inc. for judgment against Defendants, EWA A. CIEPIASZUK, indv. and d/b/a SHORTSTOPO, INC. d/b/a JESSES SHORTSTOP INN and SHORTSTOP, INC. d/b/a JESSES SHORTSTOP INN (AMENDED) (Ordeanu, Andre)

I.D. 06184818

File No.: 3900-375
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
Eastern Division

INNOVATIVE SPORTS MANAGEMENT, INC. )
d/b/a INTEGRATED SPORTS MEDIA, INC.,
)
)
Plaintiff,
)
v.
)
)
EWA A. CIEPIASZUK, indv. and d/b/a
)
SHORTSTOP, INC. d/b/a JESSE’S SHORTSTOP)
INN and SHORTSTOP, INC. d/b/a JESSE’S
)
SHORTSTOP INN,
)
Defendants.
)

No. 2012-cv-7774

PLAINTIFF’S AMENDEDMOTION TO REINSTATE AND ENTER AN ORDER OF
JUDGMENT AGAINST THE DEFENDANTS
NOW COME the Plaintiff, INNOVATIVE SPORTS MANAGEMENT, INC. d/b/a
INTEGRATED SPORTS MEDIA, INC., and respectfully requests that this Court Reinstate this
matter against Defendants, EWA A. CIEPIASZUK, indv. and d/b/a SHORTSTOPO, INC. d/b/a
JESSE’S SHORTSTOP INN and SHORTSTOP, INC. d/b/a JESSE’S SHORTSTOP INN, and in
support thereof, states as follows:
1.

That on January 29, 2013, this matter was dismissed without prejudice by this

Honorable Court, with leave to reinstate on or before September 30, 2013.
2.

That a Settlement Agreement was entered into by both parties wherein which the

Defendant would pay a total of $5,000.00 to the Plaintiff. Payments in the amount of $500.00
were to be made on or before the 1st of each month beginning on December 1, 2012 and continuing
through September 1, 2013. See attached Exhibit A.
3.

As of the filing of this motion, Defendant has paid Plaintiff a total of $2,500.00

towards the $5,000.00 settlement. Additionally, Defendant has not made a payments since May
of 2013.
5.

That pursuant to the Settlement Agreement, Defendant currently owes Plaintiff a

total amount of $2,500.00 plus attorney’s fees in the amount of Six Hundred and 00/100 ($600.00).
See attached Affidavit Exhibit B.

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6.

Additionally, pursuant to the Settlement Agreement, Defendants agreed to pay a

$3,000.00 penalty fee should they default in payment. See attached Settlement Agreement.

WHEREFORE, Plaintiff, INNOVATIVE SPORTS MANAGEMENT, INC. d/b/a
INTEGRATED SPORTS MEDIA, INC., prays this Honorable Court enter an order to Reinstate
this case against Defendants, EWA A. CIEPIASZUK, indv. and d/b/a SHORTSTOPO, INC. d/b/a
JESSE’S SHORTSTOP INN and SHORTSTOP, INC. d/b/a JESSE’S SHORTSTOP INN, and
enter an Order for Judgment in the amount of Two Thousand Five Hundred and 00/100
($2,500.00) plus attorney’s fees in the amount of Six Hundred and 00/100 ($600.00) and Three
Thousand and 00/100 ($3,000.00) in penalty fees for a total Judgment in the amount of Six
Thousand and 00/100 ($6,100.00) and for any additional relief for Plaintiff this Honorable Court
deems just.

s/Andre Ordeanu
Andre Ordeanu

CERTIFICATE OF SERVICE
I, Andre Ordeanu, on oath state that a true and correct copy of the Notice of Filing was
electronically filed with the Clerk of the Court on September 25, 2013, using the CM/ECF system
which will send notification of such filing(s) to all attorneys of record. Under the penalties of
perjury, I certify that the above statements set forth herein are true and correct.

s/ Andre Ordeanu
Andre Ordeanu
Zane D. Smith
ZANE D. SMITH & ASSOCIATES, LTD.
415 North LaSalle Street - Suite 501
Chicago, Illinois 60654
[phone]
[phone] - Fax

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