CLEAR SKIES NEVADA, LLC v. DOES 1-30

Filing 131

MOTION by Defendant Renee Hancock for judgment (Attachments: # 1 Exhibit 1 (proposed final judgment))(Clay, Lisa)

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CLEAR SKIES NEVADA, LLC Plaintiff, v. RENEE HANCOCK, Defendant. ) ) ) Case No. 15 cv 6708 ) ) Judge Virginia M. Kendall ) ) Magistrate Judge Susan Cox ) ) MOTION FOR ENTRY OF FINAL JUDGMENT ______________________________________________________________________________ NOW COMES Defendant, Renee Hancock, through her attorneys, and respectfully requests that the Honorable Court, pursuant to Fed. R. Civ. P. 58, enter Final Judgment in this matter, and states as follows in support of same. 1. On April 27, 2017 (Dkt. No. 87) the Court dismissed Plaintiff’s claims against Defendant. 2. On August 23, 2017 the Court ordered that that previous dismissal be “with prejudice” and that Defendant be awarded attorneys’ fees. 3. On January 30, 2018, the Court awarded Defendant Renee Hancock $65,268.31 in attorneys’ fees and costs. 4. Defendant’s counsel attempted to obtain a clerk’s entry pursuant to § FRCP 58(b)(1)(B) but to date no clerk’s entry has been made. 1 5. Defendant therefore respectfully requests entry of the Final Judgment attached hereto as Exhibit 1. A word version of Exhibit 1 has been forwarded to Judge Kendall’s proposed order email for her consideration. Respectfully submitted: /s/ Lisa L. Clay Lisa L. Clay Attorney at Law 345 N. Canal Street, Suite C202 Chicago, IL 60606 312.753.5302 lclayaal@gmail.com ARDC # 5277257 /s/ Curt Edmondson J. Curtis Edmondson, P.E. 601 Main Street, Suite 210 Vancouver, WA 98660 3699 John Olson Place Hillsboro, OR, 97124 503.336.3749 jcedmondson@edmolaw.com Pro Hac admittee CERTIFICATE OF SERVICE I hereby certify that on the 20th day of February, 2018, I caused to be electronically filed the foregoing MOTION FOR ENTRY OF FINAL JUDGMENT with the Clerk of the Court using the CM/ECF system which will send notification of such filing to all parties of record. /s/ Lisa L. Clay 2

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