Kogan v. SAS Group

Filing 159

MOTION by Plaintiff Ellen Kogan for judgment / entry of final order of judgment in plaintiff's favor on her claim borught under Art. 19 of Montreal Convention pursuant to Rule 58(1) of Fed. R. Civil Procedure (Attachments: # 1 Certificate of Service, # 2 Notice of Filing)(Gorokhovsky, Vladimir)

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THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS ELLEN KOGAN Case No. 1:14-cv-9551 Plaintiff vs. HON. GARY FEINERMAN SCANDINAVIAN AIRLINES SYSTEM Defendant ________________________________________________________________________ PLAINTIFF'S MOTION FOR ENTRY OF JUDGEMENT PURSUANT TO RULE 58(1) OF FED. R. CIVIL PROCEDURE _____________________________________________________________________________ NOW COMES the above-named Plaintiff, ELLEN KOGAN, by and through her counsel of record, Attorney Vladimir M. Gorokhovsky of GOROKHOVSKY LAW OFFICE LLC, and pursuant to Rule 58(1) of Fed. R. Civ. Procedure respectfully moves this Honorable Court for final Order of Entry of Judgment in the sum of $695 in Plaintiff’s favor and against the above-named defendant. FURTHER, in legal and factual support of this motion the above-named Plaintiff by her undersigned counsel of record hereby states as follows: 1. That on May 23, 2017 this Court ruled that the above-named Plaintiff can recover the sum of $695 from the above-named defendant on her claim brought under Art. 19 of the Montreal Convention. Dct. 154. 2. That based on the foregoing the undersigned counsel of record for the above-named Plaintiff is respectfully requesting this court to entry final order of Page 1 of 2 judgment in plaintiff’s favor in the sum of $695 on her claim brought under Art. 19 of Montreal Convention. WHEREFORE the above-named Plaintiff, ELLEN KOGAN by the undersigned counsel of record is respectfully requesting the following relief: (1) Final order of entry of judgment in Plaintiff’s favor in the sum of $695 per Order of this Court dated May 23, 2017; and (2) for any other and further relief deems to be fair and just by this Court. Dated this 15th day of June 2017. Respectfully submitted by GOROKHOVSKY LAW OFFICES, LLC Attorney for Plaintiff BY: /s/ Vladimir M. Gorokhovsky Vladimir M. Gorokhovsky, LL.M. ILND TR. 10994 P.O Business Address: 10919 N. Hedgwood Ln, Mequon, WI 53092 (414)-581-1582 gorlawoffice@yahoo.com CERTIFICATE OF SERVICE The undersigned attorney certifies that on June 15th, 2017, he served the foregoing document by electronically filing the same with the Clerk of the U.S. Federal Court for the Northern District of Illinois, by using the CM/ECF system, which will send notification of such filing to all CM/ECF participants. /s/ Vladimir M. Gorokhovsky, Esq. Page 2 of 2

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