TDI Global Solutions Inc. v. PCTI Holdings, Inc.

Filing 105

MOTION by Plaintiff TDI Global Solutions Inc. for judgment (Nazarian, Kenneth)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TDI GLOBAL SOLUTIONS, INC.
A Delaware corporation,

)
)
)
Plaintiff,
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v.
)
)
PCTI HOLDINGS, INC.
)
A Wisconsin corporation, d/b/a Pouch Converting )
Technologies, Inc.
)
)
Defendant,
)

Case No. 14-cv-02455
Honorable Judge John Z. Lee
Magistrate Judge Maria Valdez

MOTION FOR ENTRY OF JUDGMENT
NOW COMES Plaintiff, TDI Global Solutions, Inc., by and through its attorneys, Barney
& Karamanis, LLP, and respectfully moves this Honorable Court for entry of of Judgment
against Defendant PCTI Holdings, Inc.’s (“PCTI”). In support of its motion, Plaintiff states as
follows:
1.

On or about August 10, 2016, the parties to this case reached a mutually agreeable

settlement, wherein, inter alia, the individual former owners of Defendant PCTI would pay
Plaintiff the amount of $5,000.00, Defendant PCTI would agree to an entry of judgment for the full
amount of calculated damages, and Defendant PCTI would assign Plaintiff its rights in the
declaratory action filed by their insurance provider, Erie. See Settlement Agreement attached hereto
as Exhibit “A.”

2.

Thus, Plaintiff now prays for an entry of judgment against Defendant PCTI

Holdings, Inc. in the amount of $130,802.10 in damages, plus prejudgment interest in the amount
of $15,369.25 (calculated at 5% per annum), and plus costs in the amount of $3,485.27.
3.

The total amount of the judgment should be $149,656.62.

4.

The itemization of costs are as follows:
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Transcripts of Becky Steirer,
David Dytchkowskyj, and Kevin Riggs:
$1269.20
Transcript of Thomas Wetsch:
$525.00
Transcripts of Jon Hermes and Josh Hermes:
$675.55
Transcript of Chris Hughes:
$300.90
Deposition of Thomas Wetsch:
$175.00
Postage for subpoena:
$14.46
Postage for subpoenas:
$14.46
Witness Fee Kevin Riggs:
$50.00
Witness Fee Becky Steirer:
$50.00
Courier to Fed Court:
$5.35
Courier to Fed Court:
$5.35
Filing Fee:
$400.00
______________________________________________________
TOTAL:
$3485.27

WHEREFORE Plaintiff, TDI Global Solutions, Inc., by and through its attorneys, Barney
& Karamanis, LLP respectfully prays for this Honorable Court to enter a Judgment in the favor
of Plaintiff TDI Global Solutions, Inc., in the amount of $149,656.62, against Defendant PCTI
Holdings, Inc., and award such other relief for Plaintiff as this Court deems just and proper.
Respectfully submitted,
TDI GLOBAL SOLUTIONS, INC.
By: /s/ Kenneth A. Nazarian
One of Its Attorneys
James A. Karamanis (ARDC #6203479)
Kenneth A. Nazarian (ARDC # 6309765)
Barney & Karamanis, LLP
180 N. Stetson, Ste 3050
Chicago, Illinois 60601
Tel.: [phone]
Counsel for Plaintiff

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EXHIBIT A