Pena et al v. Village Of Maywood et al

Filing 97

MOTION by Plaintiffs Concepcion Pena, Jose Natividad Pena, Jose A. Pena for judgment on Costs (Dvorak, Richard)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
JOSE NATIVIDAD PENA,
MARIA G. REYES,
CONCEPCION PENA,
Plaintiffs,
v.
VILLAGE OF MAYWOOD,
a municipal corporation,
OFFICER REILLY, Star #305,
Village of Maywood Police Officer,
Defendants.

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Case No. 14 CV 04214
The Honorable Jeffrey Cole

PLAINTIFFS’ MOTION FOR ENTRY OF JUDGMENT
ON COSTS
The Plaintiffs, JOSE NATIVIDAD PENA, MARIA G. REYES, and CONCEPCION
PENA, by and through their attorneys, DVORAK LAW OFFICES, LLC, respectfully move this
Honorable Court to instruct the Clerk to enter judgment in favor of the Plaintiffs with respect to
their attorneys’ costs, which amount to $2,092.80. In support the Plaintiff state as follows:
1. Judgement was entered in favor of the Plaintiffs on October 13, 2016, pursuant to the
Plaintiffs’ having accepted the Defendants’ Offer of Judgment (Dkt. 93, 94).
2. The Plaintiffs submitted a Bill of Costs seeking TWO-THOUSAND-NINETY-TWO
DOLLARS and EIGHTY CENTS ($2,092.80) October 13, 2016 (Dkt. 95).
3. The Defendants had until October 28, 2016 by which to file a response to the
Plaintiff’s Bill of Costs (Dkt 96).
4. As of the filing of this Motion, the Defendants have not responded to the Plaintiffs’
Bill of Costs.
5. The Plaintiffs therefore ask that they be awarded the full $2,092.80, and any interest

that might accumulate on that principal sum should this Motion be granted and
judgement entered with respect to costs.
WHEREFORE, for all of the reasons stated above, the Plaintiffs respectfully ask that this Court
grant their motion, and that judgment be entered in their favor with respect to costs, in the
amount of $2,092.80.

Date: November 22, 2016
Respectfully submitted,
/s/Richard Dvorak
Richard Dvorak,
Attorney for the Plaintiffs.
Richard Dvorak
DVORAK LAW OFFICES, LLC
6262 Kingery Highway, Suite 305
Willowbrook, IL 60527
[phone] (p)
[e-mail]
CERTIFICATE OF SERVICE
I, Richard Dvorak, an attorney, certify that on November 22, 2016, a copy of the foregoing
motion, was served upon the attorneys for the Defendants through the Court’s electronic filing
system.
/s/Richard Dvorak
Richard Dvorak,
Attorney for the Plaintiffs.

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