Daniliauskas v. Reliance Standard Life Insurance Company

Filing 34

MOTION by Defendant Reliance Standard Life Insurance Company for judgment (Kersting, Edna)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JONAS DANILIAUSKAS, Plaintiff, Case No. 1:16-cv-09278 v. Hon. Charles R. Norgle, Sr. Mag. Judge Susan E. Cox RELIANCE STANDARD LIFE INSURANCE COMPANY, Defendant. 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 contemporaneously herewith. 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). Respectfully Submitted, RELIANCE STANDARD LIFE INSURANCE COMPANY, Defendant By: Edna S. Kersting WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 2337634v.1 /s/ Edna S. Kersting One of Its Attorneys 55 West Monroe Street, Suite 3800 Chicago, Illinois 60603 (312) 704-0550 (312) 704-1522 2 2337634v.1 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 3 2337634v.1

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