Rios v. Colvin

Filing 25

MOTION by Plaintiff Ignacio Rios for judgment in a separate document (Alpert, Beth)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DISTRICT

IGNACIO RIOS
Plaintiff,
v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

)
)
) No. 14-cv-2433
)
) Magistrate Judge Valdez
)
)
)
)

PLAINTIFF’S MOTION FOR ENTRY OF JUDGMENT IN A SEPARATE DOCUMENT
UNDER RULE 58(d)
NOW COMES the Plaintiff and moves this Court set out judgment in a separate document
pursuant to Rule 58(d). In support of his motion, plaintiff states as follows:
1. On May 24, 2016, this court entered an opinion and order granting Plaintiff’s Motion for
Summary Judgment and remanding this matter to Defendant for further proceeding consistent with
the order (Docket Entry 24).
2. Judgement was not entered on a separate document pursuant to Federal Rule of Civil
Procedure (“FRCP”) 58(a).
3. One hundred and fifty days have not yet run from the entry of the order in the civil docket
to fulfil the requirement of Rule 58(c)(2)(B).

WHEREFORE, Plaintiff prays this court set out judgment in a separate document
pursuant to Rule 58.
Respectfully Submitted,

s/Beth A. Alpert
Attorney for Plaintiff

Beth A. Alpert
Beth A. Alpert & Associates
53 W. Jackson, Suite 515
Chicago, Illinois 60604
(312)-427-2611

CERTIFICATE OF SERVICE
To:

Donald R. Lorenzen, Esq.
Assistant U.S. Attorney
Office of the U.S. Attorney
219 S. Dearborn St., #500
Chicago, Illinois 60604
[e-mail]

Brock C. Cima, Esq.
Assistant Regional Counsel
OGC Region VI, SSA
1301 Young Street, Ste. A702
Dallas, Texas 75202
[e-mail]

The undersigned attorney hereby certifies that on August 29, 2016, she electronically
filed the foregoing PLAINTIFF’S MOTION FOR ENTRY OF JUDGMENT IN A SEPARATE
DOCUMENT with the Clerk of the Court using the CMF/ECF filing system, which sent notice
of such filing to Donald R. Lorenzen, Esq., the above named attorney. I also hereby certify that I
have mailed via the United States Postal Service, the document to the following non-CMF/ECF
participants: Brock C. Cima, Esq.
s/ Beth A. Alpert
Beth A. Alpert
Attorney for Plaintiff
Ignacio Rios III
Beth Alpert
Beth Alpert & Associates
The Monadnock Building
53 W. Jackson Blvd., #515
Chicago, Illinois 60604
[phone]
[phone] fax