Marks v. Worldwide Robotic Automated Parking, LLC et al

Filing 86

MOTION by Plaintiff John Marks for judgment Plaintiff's Motion for Entry of Consent Judgment (Schoaf, Maureen)

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Case: 1:16-cv-08656 Document #: 86 Filed: 12/12/18 Page 1 of 4 PageID #:725 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JOHN MARKS, an individual, ) ) Plaintiff, ) ) v. ) ) WORLDWIDE ROBOTIC AUTOMATED ) PARKING, LLC, and DONALD JAGODA, ) ) Defendants. ) ) Case No. 16-CV-8656 Hon. Robert Dow Jr. Magistrate Judge Young B. Kim PLAINTIFF’S MOTION FOR ENTRY OF CONSENT JUDGMENT Plaintiff John Marks moves for entry of a consent judgment in favor of Plaintiff and against Defendants in the sum of $391,000. In support of his Motion, Plaintiff states as follows: 1. In March 2018, after participating in a settlement conference with Magistrate Judge Young Kim, the parties executed a settlement agreement (“Settlement Agreement”) to resolve the issues raised in Plaintiff’s Complaint. 2. Pursuant to the parties’ Settlement Agreement, in the event that Defendants failed to make any settlement payments required under the Settlement Agreement or otherwise breached the Settlement Agreement, Defendants Worldwide Robotic Automated Parking, LLC and Donald Jagoda agreed to entry of the Consent Judgment attached hereto as “Exhibit A.” 3. On October 1, 2018, Defendants failed to make a settlement payment as required by the parties’ Settlement Agreement. 4. On December 4, 2018, Plaintiff, through his undersigned counsel, notified Defendants’ counsel that Plaintiff intended to seek entry of the Consent Judgment. Case: 1:16-cv-08656 Document #: 86 Filed: 12/12/18 Page 2 of 4 PageID #:726 WHEREFORE, Plaintiff John Marks respectfully requests that this Court enter the Consent Judgment in the amount of $391,000 in the form attached hereto as Exhibit “A,” and grant such other relief that this Court deems just and proper. Respectfully submitted, JOHN MARKS By: /s/ Elias N. Matsakis Maureen Browne Schoaf Lisa M. Kpor HOLLAND & KNIGHT LLP 131 S. Dearborn St., 30th Fl. Chicago, IL 60603 Email: maureen.schoaf@hklaw.com Phone: (312) 578-6697 2 Maureen B. Schoaf One of his attorneys l Case: 1:16-cv-08656 Document #: 86 Filed: 12/12/18 Page 3 of 4 PageID #:727 EXHIBIT A IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JOHN MARKS, an individual, ) ) Plaintiff, ) ) v. ) ) WORLDWIDE ROBOTIC AUTOMATED ) PARKING, LLC, and DONALD JAGODA, ) ) Defendants. ) ) Case No. 16-CV-8656 Hon. Robert Dow Jr. Magistrate Judge Young B. Kim FINAL CONSENT JUDGMENT Pursuant to a settlement agreement between Plaintiff, John Marks, (“Plaintiff”), on the one hand, and Defendants, Donald Jagoda and Worldwide Robotic Automated Parking, LLC, (collectively, “Defendants”), on the other hand, dated March 23, 2018, (the “Settlement Agreement”), and upon due notice to the parties and the Court being fully advised on the premises it is ADJUDGED that judgment is entered in favor of Plaintiff John Marks and against Defendants Donald Jagoda and Worldwide Robotic Automated Parking, LLC in the sum of $400,000.00 less amounts paid and received under the Settlement Agreement of $9,000.00. The total judgment amount being $391,000.00. Jurisdiction of this case is retained to enforce the Final Consent Judgment. SO ORDERED. Dated: Robert M. Dow, Jr. United States District Judge Case: 1:16-cv-08656 Document #: 86 Filed: 12/12/18 Page 4 of 4 PageID #:728 CERTIFICATE OF SERVICE The undersigned attorney certifies that on this 12th day of December 2018, she caused the foregoing Plaintiff’s Motion for Entry of Consent Judgment to be filed with the Clerk of the United States District Court for the Northern District by filing through the CM/ECF system, which served a copy upon counsel of record. /s/ Maureen B. Schoaf

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