Cheney v. Standard Insurance Company et al

Filing 101

MOTION by Plaintiff Carole Cheney for judgment (DeBofsky, Mark)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CAROLE CHENEY,
Plaintiff,
v.
STANDARD INSURANCE
COMPANY and LONG TERM
DISABILITY INSURANCE,
Defendants.

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No. 1:13-cv-4269
Hon. Robert W. Gettleman

PLAINTIFF’S MOTION FOR ENTRY OF JUDGMENT
Plaintiff, CAROLE CHENEY, by her attorneys, hereby moves this Court for the entry of
judgment in her favor and against Defendant, STANDARD INSURANCE COMPANY pursuant
to the parties’ prior stipulation on the record to submit this matter for a “trial on the papers”
pursuant to Fed. R. Civ. P. 52(a) and following remand from the United States Court of Appeals
for the Seventh Circuit (Docket No. 74). In support thereof, Plaintiff hereby submits Memoranda
of Law (Docket Nos. 90; 99) and Proposed Findings of Fact (Docket No. 23), which together
establish by a preponderance of the evidence that Plaintiff is entitled to an award of benefits under
the long-term disability policy.
WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against
Defendant, and award her all benefits due to date, prejudgment interest, attorneys’ fees pursuant
to 29 U.S.C. § 1132(g), and her costs of suit.

June 2, 2017

Respectfully Submitted,
/s/ Mark D. DeBofsky____________
One of the Plaintiff’s Attorneys

Mark D. DeBofsky
William T. Reynolds
DeBofsky, Sherman & Casciari, PC
200 West Madison Street, Suite 2670
Chicago, Illinois 60606
Voice [phone]
Fax [phone]
[e-mail]
[e-mail]

CERTIFICATE OF SERVICE
Mark D. DeBofsky, the undersigned attorney, certifies that he served a copy of the
foregoing upon the Clerk of Court and all counsel of record by CM/ECF, on June 2, 2017.

/s/ Mark D. DeBofsky
Mark D. DeBofsky
Attorney for Plaintiff