United States of America v. Wholesome Soy Products, Inc. et al

Filing 2

MOTION by Plaintiff United States of America for judgment (Attachments: # 1 Exhibit 1. Consent Decree of Permanent Injunction)(Baeza, Daniel)

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS UNITED STATES OF AMERICA, Plaintiff, Case No. 1:15-cv-2974 MOTION FOR JUDGMENT v. WHOLESOME SOY PRODUCTS, INC., a corporation, and JULIA TRINH and PAUL TRINH, individuals, Defendants The United States of America, Plaintiff, by and through its undersigned counsel, hereby respectfully requests that the Court sign and enter the attached Consent Decree in the abovecaptioned action. Ex. 1. The Consent Decree resolves all claims the United States raises. All parties have agreed to entry of the Consent Decree, as evidenced by their signatures thereon. Accordingly, the United States respectfully requests that the Court sign and enter the Consent Decree as a judicial order. Dated this 3rd day of April, 2015. Respectfully submitted, By: /s/ Daniel M. Baeza DANIEL M. BAEZA Consumer Protection Branch Department of Justice Civil Division 6th Floor South 450 Fifth Street, N.W. Washington, DC 20001 Phone: (202) 616-4916 E-mail: Dan.Baeza@usdoj.gov Of Counsel: WILLIAM B. SCHULTZ General Counsel U.S. Dept. of Health and Human Services ELIZABETH H. DICKINSON Chief Counsel Food and Drug Division PERHAM GORJI Deputy Chief Counsel Food and Drug Division CHARLOTTE HINKLE Assistant Chief Counsel Food and Drug Division 10903 New Hampshire Avenue Silver Spring, MD 20993-0002 Charlotte.Hinkle@fda.hhs.gov 2 CERTIFICATE OF SERVICE I, Daniel M. Baeza, certify that on April 3, 2015, I served a true copy of the Motion for Judgment on all counsel of record via e-mail. /s/ Daniel M. Baeza DANIEL M. BAEZA 3

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