Riverdale Plating And Heat Treating, LLC v. Andre Corporation et al

Filing 81

MOTION by Plaintiff Riverdale Plating And Heat Treating, LLC for judgment (Attachments: # 1 Exhibit A)(Hayes, Thomas)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
RIVERDALE PLATING AND HEAT
TREATING,LLC,
Case No. 2015 cv 3255
Plaintiff,
Judge Gary Feinerman
v.
ANDRE CORPORATION
Defendant.
AGREED MOTION FOR ENTRY OF JUDGMENT
NOW COMES Plaintiff Riverdale Plating and Heat Treating, LLC ("Riverdale"), by and
through its attorneys, and by agreement with Defendant Andre Corporation ("AC")(collectively,
the "Parties"), for its Agreed Motion for Entry of Judgment, and in further support thereof,
Riverdale states as follows:
1.

On January 6, 2016, Riverdale filed its First Amended Complaint alleging breach

of contract (Count I), account stated (Count II), unjust enrichment (Count III), violation of the
Indiana Uniform Fraudulent Transfer Act(Count IV), and unlawful corporate distribution (Count
V).
2.

On or about July 22, 2016, Count III, Count IV, and Count V of the First

Amended Complaint were dismissed by Order of the Court.
3.

On or about December 7, 2016, the Parties entered into a Confidential Settlement

Agreement and Release (the "Settlement Agreement').
4.

Pursuant to the Settlement Agreement entered into December 7, 2016, a stipulated

judgment on Count I and Count II shall be entered against AC in the amount of $132,244.90. A
copy of the proposed judgment is attached hereto as Exhibit A.

WHEREFORE, Riverdale respectfully requests that the proposed Agreed Judgment in
Favor of Riverdale Plating and Heat Treating, LLC and Against Andre Corporation be entered
by this Court and for such other relief as this Court deems reasonable and just.
Respectfully submitted,

By: /s/ Thomas J. Hayes
Timothy L. Binetti(ARDC 6282534)
Thomas J. Hayes(ARDC 6299995)
DINSMORE & SHOHL LLP
227 W. Monroe Street, Suite 3850
Chicago, IL 60606
P:[phone]
E: [e-mail]
E: [e-mail]
Attorneysfor Riverdale Plating & Heat Treating,
LLC