Allen, et al. vs. Greatbanc Trust Company

Filing 30

MOTION by Plaintiffs Lisa Allen, Misty Dalton for judgment (Entry of Final Judgment) (Muench, Patrick)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

LISA ALLEN and MISTY DALTON,
Plaintiffs,

Case No. 1:15-cv-03053
Honorable James B. Zagel

v.
GREATBANC TRUST COMPANY,
Defendant.

PLAINTIFFS’ MOTION TO ENTER FINAL JUDGMENT (UNOPPOSED)
Patrick Muench (BBO #6290298)
BAILEY & GLASSER LLP
3601 McDonough Street
Joliet, IL 60431
Tel: [phone]
[e-mail]
Gregory Y. Porter (pro hac vice)
Ryan T. Jenny
James L. Kauffman (pro hac vice)
BAILEY & GLASSER LLP
1054 31st Street, NW
Suite 230
Washington, DC 20007
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs Lisa Allen and Misty
Dalton

Plaintiffs file this Motion to Enter Final Judgment pursuant to Federal Rule of Civil
Procedure 58, and would show as follows:
1.

On October 1, 2015, the Court issued a memorandum and order dismissing this

case, without prejudice and with leave to amend the complaint, pursuant to Federal Rule of Civil
Procedure 12(b)(6) for failure to state a claim upon which relief can be granted (Memorandum
Opinion and Order, Dkt. 29).
2.

Plaintiffs will not amend their complaint, but will appeal.

3.

Plaintiffs therefore, pursuant to Federal Rule of Civil Procedure 58(d),

respectfully request the Court to order the Court Clerk to enter a final judgment in the proposed
form submitted concurrently with this motion to the Court’s email address at
[e-mail].
4.

Defendant, through counsel, has advised Plaintiffs’ counsel that it does not

oppose entry of judgment as set forth in this motion and its proposed order.
WHEREFORE PREMISES CONSIDERED, Plaintiffs respectfully request that Plaintiffs’
Motion to Enter Final Judgment be granted.
Dated: October 12, 2015

Respectfully submitted,
/s/ Patrick Muench_________________
Patrick Muench (BBO #6290298)
BAILEY & GLASSER LLP
3601 McDonough Street
Joliet, IL 60431
Tel: [phone]
[e-mail]
Gregory Y. Porter (pro hac vice)
Ryan T. Jenny
James L. Kauffman (pro hac vice)
BAILEY & GLASSER LLP
1054 31st Street, NW
Suite 230
1

Washington, DC 20007
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs Lisa Allen and Misty
Dalton

2

CERTIFICATE OF SERVICE
I hereby certify that on October 12, 2015, the foregoing Plaintiffs’ Motion to Enter Final
Judgment has been filed through the ECF system and will be sent electronically to the registered
participants as identified on the Notice of Electronic File (NEF).

/s/ Patrick Muench