Bowse v. Portfolio Recovery Associates, LLC

Filing 83

MOTION by Defendant Portfolio Recovery Associates, LLC for judgment Agreed (Mackey, Raven)

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PETER BOWSE Plaintiff, -vPORTFOLIO RECOVERY ASSOCIATES, LLC Defendant. ) ) ) ) ) ) ) ) ) ) Civil Action No.15-cv-04037 Honorable Jorge L. Alonso AGREED MOTION FOR ENTRY OF FINAL JUDGMENT PURSUANT TO PARTIES STIPULATION The Parties, by and through their attorneys, respectfully move this Court, pursuant to Rule 16 of the Federal Rules of Civil Procedure, to enter a final judgment pursuant to the Parties' entered Agreed Stipulation [82], and in support of this motion states as follows: 1. On April 10, 2017, the parties entered an agreed stipulation that Plaintiff is entitled to $1,000, representing the amount of statutory damages for a violation of the FDCPA; and that Defendant reserves the right to appeal the finding that it violated the FDCPA. (Dkt. #82). 2. With the court having already entered summary judgment in favor of Plaintiff and against Defendant on liability (Dkt. # 73), and the parties having stipulated that Plaintiff is entitled to $1,000 in statutory damages, pursuant to 15 U.S.C. ยง 1692k (Dkt. # 82), the parties request that a final judgment be entered pursuant to the parties' stipulation that judgment is entered in favor of plaintiff and against defendant in the amount of $1,000.00. WHEREFORE, the Parties, for the reasons explained above, respectfully moves this Court to enter a final judgment in this matter, and for such other relief as this Court deems proper. 131690402v1 0973668 Respectfully submitted, Bryan Thompson The Thompson Law Firm, P.C. 20 N. Clark St., Suite 3100 Chicago, IL 60602 E-mail: bryan@bryanthompsonlaw.com Phone: 312-300-4167 By: David M. Schultz Raven B. Mackey Hinshaw & Culbertson LLP 222 North LaSalle Street, Suite 300 Chicago, IL 60601-1081 Tel: 312-704-3000 By: /s/ Bryan Thompson Bryan Thompson /s/ Raven B. Mackey Raven B. Mackey 2 131690402v1 0973668

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