Daniliauskas v. Reliance Standard Life Insurance Company
MOTION by Defendant Reliance Standard Life Insurance Company for judgment (Kersting, Edna)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
Case No. 1:16-cv-09278
Hon. Charles R. Norgle, Sr.
Mag. Judge Susan E. Cox
RELIANCE STANDARD LIFE
DEFENDANT’S MOTION FOR JUDGMENT
PURSUANT TO F.R. CIV. P. 52
Defendant Reliance Standard Life Insurance Company (“Reliance Standard”), by its
undersigned counsel, moves this Honorable Court, pursuant to Rule 52 of the Federal Rules of
Civil Procedure, to enter judgment in favor of Reliance Standard and against Plaintiff Jonas
Daniliauskas (“Plaintiff”) for the reasons set forth in its supporting Memorandum of Law filed
WHEREFORE, Reliance Standard respectfully requests that this Court enter an order
granting Judgment in its favor, and awarding Reliance Standard such other and further relief as
the Court deems just and equitable, including an award of their reasonable attorneys fees and
costs pursuant to 29 U.S.C. §1132(g).
RELIANCE STANDARD LIFE INSURANCE
Edna S. Kersting
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
/s/ Edna S. Kersting
One of Its Attorneys
55 West Monroe Street, Suite 3800
Chicago, Illinois 60603
PROOF OF SERVICE
I hereby certify that on June 9, 2017, a copy of the foregoing pleading was filed
electronically. Notice of this filing will be sent by operations of the Court’s electronic filing
systems to all parties indicated on the electronic filing receipt. All other parties will be served by
Regular U.S. Mail. Parties may access this filing through the Court’s System.
/s/ Edna S. Kersting ________
Edna S. Kersting
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