Trinity Industries Leasing Company v. Midwest Gas Storage, Inc. et al

Filing 231

MOTION by Plaintiff Trinity Industries Leasing Company for judgment Agree (Vidal, Dorothea)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TRINITY INDUSTRIES LEASING
COMPANY,
Plaintiff,
v.
MIDWEST GAS STORAGE, INC., et al.,
Defendants.

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Case No. 1:13-cv-00439
Judge Manish S. Shah

AGREED MOTION FOR ENTRY OF JUDGMENT

Plaintiff, Trinity Industries Leasing Company, (“Trinity”) files this Agreed Motion for
Entry of Judgment and in support thereof respectfully shows the following:
1.

The parties to this matter entered into a Settlement Agreement on June 9, 2017.

2.

Part of the Settlement Agreement requires the entry of a judgment against defendants,

Midwest Gas Storage, Inc. (“Midwest Gas”), Putnam Energy, LLC (“Putnam”), and Terrence
O’Malley (“O’Malley”).
3.

The parties agreed to the entry of the attached Agreed Judgment which has been

signed by Midwest Gas, Putnam and O’Malley.
WHEREFORE, Trinity moves that the Agreed Judgment be entered.
Respectfully submitted,
/s/ Dorothea L. Vidal
Dorothea L. Vidal
[e-mail]
Admitted Pro Hac Vice

AGREED MOTION FOR ENTRY OF JUDGMENT

PAGE 1

Texas Bar No. 20578100
GEARY, PORTER & DONOVAN, P.C.
One Bent Tree Tower
16475 Dallas Parkway, Suite 400
Addison, Texas 75001
Telephone: [phone]
Facsimile:
[phone]
Of Counsel:
Eric Macey
[e-mail]
Illinois Bar No. 3122684
Michael Weinberg
[e-mail]
Illinois Bar No. 2963477
NOVACK & MACEY, L.L.P.
100 North Riverside Plaza
Chicago, Illinois 60606-1501
Telephone: [phone]
Facsimile:
[phone]

Certificate of Service
I certify that on July 13, 2017, a copy of the forgoing was filed electronically. Notice
will be sent to the following by operation of the Court’s ECF and can be accessed through the
system:
[e-mail]
[e-mail].

/s/ Dorothea L. Vidal

AGREED MOTION FOR ENTRY OF JUDGMENT

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EXHIBIT A