Bowse v. Portfolio Recovery Associates, LLC
MOTION by Defendant Portfolio Recovery Associates, LLC for judgment Agreed (Mackey, Raven)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
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 , and in support of this motion states as follows:
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).
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. § 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.
The Thompson Law Firm, P.C.
20 N. Clark St., Suite 3100
Chicago, IL 60602
David M. Schultz
Raven B. Mackey
Hinshaw & Culbertson LLP
222 North LaSalle Street, Suite 300
Chicago, IL 60601-1081
/s/ Bryan Thompson
/s/ Raven B. Mackey
Raven B. Mackey
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