Synergistic International LLC v. Compell

Filing 17

MOTION by Plaintiff Synergistic International LLC for judgment - Final Judgment and Permanent Injunction by Default (Watters, Zachary)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
SYNERGISTIC INTERNATIONAL LLC,
Plaintiff,
vs.
MIKE COMPELL, individually and d/b/a
GLASS DOCTOR and GLASSDOCTOR
NORTHSHORE
Defendant.

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CIV. NO.: 1:14-cv-01677

PLAINTIFF’S MOTION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT
INJUNCTION BY DEFAULT AGAINST DEFENDANT MIKE COMPELL,
INDIVIDUALLY AND D/B/A “GLASS DOCTOR” AND “GLASSDOCTOR
NORTHSHORE” UNDER FED. R. CIV. P. 55(b)
Plaintiff Synergistic International LLC (“Plaintiff”), pursuant to Rule 55(b)(2) of the
Federal Rules of Civil Procedure, respectfully moves the Court for an Order:
1.

Directing the entry of final judgment by default in favor of Plaintiff and against

Defendant Mike Compell, individually and doing business as “Glass Doctor” and “GlassDoctor
Northshore” (“Defendant”), in this civil action for the legal and equitable relief demanded in the
Complaint;
2.

Determining the amount of Plaintiff’s monetary recovery, in the form of an award

of Plaintiff’s reasonable attorneys’ fees and expenses incurred in connection with this action, as
$28,531.59, and directing the entry of judgment in favor of Plaintiff and against Defendant in
that amount; and
3.

Granting such other and further relief as the Court may deem just and proper.

In support of this Motion, Plaintiff relies on the following materials, either previously
submitted in this action or filed contemporaneously with this Motion (as noted below):

1.

Plaintiff’s Complaint, filed March 11, 2014 (ECF No. 1);

2.

The Return of Service, filed April 30, 2014 (ECF No. 9);

3.

The Clerk’s Order for Entry of Default, dated June 13, 2014, entering Defendant’s

default on the record (ECF No. 15);
4.

The Declaration of Christopher P. Bussert, submitted contemporaneously

herewith;
5.

The Declaration of Zachary J. Watters, submitted contemporaneously herewith;

6.

Plaintiff’s Brief in Support of this Motion, submitted contemporaneously

and

herewith.
Plaintiff also has submitted, together with this Motion, a proposed Order of Final
Judgment and Permanent Injunction by Default Against Defendant, as requested herein.

Respectfully submitted, this 25th day of June 2014.

/s/ Zachary J. Watters
Larry L. Saret (IL Bar No. 2459337)
Zachary J. Watters (IL Bar No. 6310675)
MICHAEL BEST & FRIEDRICH LLP
Two Prudential Plaza
180 North Stetson Avenue, Suite 2000
Chicago, IL 60601
E-mail: [e-mail]
[e-mail]
Telephone: [phone]
Facsimile: [phone]
– and –
Christopher P. Bussert (admitted pro hac vice)
James W. Faris Jr. (admitted pro hac vice)

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KILPATRICK TOWNSEND & STOCKTON LLP
1100 Peachtree Street, Suite 2800
Atlanta, GA 30309
E-mail: [e-mail]
[e-mail]
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Synergistic International LLC

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