A. et al v. Norwood

Filing 160

MOTION by Plaintiffs M. A., F. L., Y. R., H. S., L. T. for judgment (Chapman, Caroline)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
M.A. by and through his parents MIGUEL
AVILA, SR. and HERMINA AVILA,
F.L. by and through his mother, JACQUETTA
PEARSON, Y.R. by and through her mother
CAROLINA BARRANCO, H.S. by and through
his parents RICARDO SORIA and GEORGINA
RIVERA, individually and on behalf of a class,
Plaintiffs,
vs.
PATRICIAL R. BELLOCK, in her official
capacity as Director of the Illinois Department of
Healthcare and Family Services,
Defendant.

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No.

15-3116

Judge:

Joan H. Lefkow

Magistrate:

Sheila M. Finnegan

AGREED MOTION FOR THE ENTRY OF JUDGMENT ORDER
Pursuant to the Settlement Agreement approved by this Court on December 18, 2018
(Dkt. # 159), Plaintiffs and Defendants respectfully move this Court to enter a Judgment Order
for the payment of reasonable attorneys’ fees and costs incurred by Class Counsel, all in
accordance with the express terms of the Decree.
Pursuant to paragraph 28 of the Settlement Agreement, the Defendant shall pay to Class
Counsel the sum of $550,000 in the manner set forth in written instructions provided by Class
Counsel and agreed to by the Parties. The payment of $550,000 shall be set forth in a Judgment
Order to be entered by the Court.
Upon the filing of this Agreed Motion for the Entry of Judgment Order, Class Counsel
will email to this Court, a proposed Judgment Order.

WHEREFORE, Plaintiffs and Defendant respectfully request that this Court enter the
proposed Judgment Order providing for payment of attorneys’ fees and costs in the total amount
of $550,000 (as more fully set forth in the proposed Judgment Order), reflecting the agreed upon
distribution by the parties.

Dated: January 17, 2019

Respectfully submitted,

For Plaintiffs

For Defendant

By: /s/Robert H. Farley, Jr.

By: /s/ R. Douglas Rees

Robert H. Farley, Jr.
Robert H. Farley, Jr. Ltd.
1155 S. Washington St., Suite 201
Naperville, IL 60540

R. Douglas Rees
Office of the Attorney General of the State of
Illinois
100 West Randolph Street, 12th Floor
Chicago, Illinois 60601

Thomas D. Yates
Legal Council for Health Justice
180 N. Michigan Avenue, Suite 2110
Chicago, IL 60601
Mary Denise Cahill
Cahill & Associates Law Group LLC
1155 S. Washington St., Suite 106
Naperville, IL 60540

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CERTIFICATE OF SERVICE

I, Caroline G. Chapman, one of the Attorneys for the Plaintiffs’, deposes and states that
he caused the foregoing Agreed Motion for Entry of Judgment Order to be served by
electronically filing said document with the Clerk of the Court using the CM/ECF system, this
17th day of January, 2019.

/s/ Caroline G. Chapman

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