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)

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: [phone]
E-mail: [e-mail]
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
[e-mail]

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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

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