RehabCare Group East, Inc. d/b/a RehabCare v. CC Care, LLC d/b/a Community Care Center et al

Filing 75

MOTION by Plaintiff RehabCare Group East, Inc. for judgment against SH Care, LLC d/b/a Sycamore Healthcare (Attachments: # 1 Text of Proposed Order)(Martin, Phillip)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
REHABCARE GROUP EAST, INC.
d/b/a REHABCARE
PLAINTIFF
v.
CC CARE, LLC d/b/a COMMUNITY
CARE CENTER, et al.
DEFENDANTS

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Case No. 15-cv-10876
Magistrate Judge Schenkier

MOTION FOR ENTRY OF JUDGMENT
Plaintiff, RehabCare Group East, Inc. d/b/a RehabCare (“RehabCare”), moves the Court
for entry of Judgment against SH Care, LLC d/b/a Sycamore Healthcare (“Sycamore”) in
conformance with the Court’s Order on Plaintiff’s Motion for Summary Judgment (DN 66). The
Court previously ruled that RehabCare was entitled to damages against Sycamore in the principal
amount of $293,558.95, plus interest through May 19, 2017 in the amount of $112,337.43, plus
interest thereafter at the per diem rate of $144.83 until entry of a final Judgment.1 See Order, DN 66.
Entry of a final Judgment was delayed pending a trial on damages as to certain other Defendants.
See id. Those Defendants have now sought bankruptcy protection,2 and there is thus no reason for
further delay, and RehabCare is entitled to Judgment against Sycamore. See FED. R. CIV. P. 54.
A proposed Judgment is attached.

1 There are 171 days between May 19, 2017 and November 6, 2017, thus the interest due to RehabCare has grown to
$137,972.34.
2 RehabCare does not seek any relief against the entities that filed bankruptcy in conformance with the automatic stay.

Dated: November 7, 2017
Respectfully submitted,
LATIMER LEVAY FYOCK, LLC

FULTZ MADDOX DICKENS PLC
Phillip A. Martin
Laura M. Brymer

Richard Saldinger
55 W Monroe St., Ste. 1100
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]

/s/ Phillip A. Martin
101 S. Fifth St., 27th Floor
Louisville, Kentucky 40202
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Counsel for Plaintiff

CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was served in compliance with the Court’s ECF Guidelines
on November 7, 2017 upon: David K. Welch, John H. Redfield, Brian P. Welch, Crane, Heyman,
Simon, Welch & Clar, 135 S. LaSalle, #3705, Chicago, IL 60603.
/s/ Phillip A. Martin
Counsel for Plaintiff
{01693828}

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