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)

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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. § § § § § § § § § § 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 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: (972) 931-9901 Facsimile: (972) 931-9208 Of Counsel: Eric Macey Illinois Bar No. 3122684 Michael Weinberg Illinois Bar No. 2963477 NOVACK & MACEY, L.L.P. 100 North Riverside Plaza Chicago, Illinois 60606-1501 Telephone: (312) 419-6900 Facsimile: (312) 419-6928 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: /s/ Dorothea L. Vidal AGREED MOTION FOR ENTRY OF JUDGMENT PAGE 2 EXHIBIT A

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