Diggs v. Linebarger, Goggan, Blair & Sampson, LLP

Filing 33

MOTION by Plaintiff Antionetta Diggs for judgment (Toole, Arnold)

Diggs v. Linebarger, Goggan, Blair & Sampson, LLP

Doc. 33

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ANTIONETTA DIGGS,
Plaintiff,
v.
LINEBARGER, GOGGAN, BLAIR
& SAMPSON, LLP
Defendant

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Case No. 13CV00624
Judge Rebecca R. Pallmeyer

PLAINTIFF’S MOTION FOR FINAL JUDGMENT
NOW COMES Plaintiff, Antionetta Diggs, by and through her undersigned
counsel and moves this Honorable Court for a final and appealable judgment, and in
support of her motion states as follows:
On January 1, 2013, Plaintiff filed a three count complaint against Defendant
for FMLA Interference, FMLA Retaliation, and Pregnancy Discrimination.
On April 02, 2013, Defendant filed its Answer and Affirmative Defenses.
On April 22, Plaintiff filed her motion to Strike Defendant’s Affirmative
Defenses.
On April 23, 2013, Defendant filed a Motion to Compel Arbitration and Motion
to Dismiss for Lack of Jurisdiction.
On April 30, 2013, the Court ruled on Plaintiff’s Motion to Strike Defendants
Affirmative Defenses.
On June 14, 2013, the Court granted Defendant’s Motion to Compel, but
reserved ruling on other relief requested by Plaintiff in her Response to the Motion
until additional information was provided by the parties.
On July 10, 2013, the Court ruled on the remaining issues arising out of
Defendant’s Motion to Compel.

Dockets.Justia.com

Over 28 days have elapsed from the date of entry of the Court’s last order
(07/10/13), and neither party has filed any motion for any post-ruling relief.
There have been several rulings entered in this matter at various stages of the
ligation, but no final judgment. As of the date of the filing of this Motion the case
remains open and the Court retains jurisdiction.
Rule 4 of the Federal Rules of Appellate Procedure require judgment to be
entered prior to any appeal.
WHEREFORE the Court having ruled on all motions and disposed of all
pending issues in the case, Plaintiff requests a final and appealable judgment finally
disposing of the case in its entirety.
Respectfully submitted,
Antionetta Diggs, Plaintiff
/s/ Arnold Toole_________________
Arnold E. Toole, Attorney for Plaintiff
Arnold E. Toole
Toole Law Office, LLC
Attorney for Plaintiff
1525 East 53rd Street, Suite 920
Chicago, IL 60615
[e-mail]
[phone]
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on August 8, 2013, a true and correct
copy of the foregoing Plaintiff’s Motion for Final Judgment was served
electronically on the persons identified below via the Court’s CM/ECF system.
Daniel N. Ramirez
Mario K. Castillo
Monty & Ramirez LLP
150 W. Parker Road, 3rd Flr.
Houston, TX 77076

Andrew J. Purcell
Jeffrey M. Stein
Tressler, LLP
233 S. Wacker Drive, 22nd Flr.
Chicago, IL 60606
_/s/ Arnold Toole______
Arnold E. Toole
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