New York Healthcare Insurance Company v. Oak Lawn Respiratory and Rehabilitation Center, LLC et al
Filing
23
MOTION by Plaintiff New York Healthcare Insurance Company for judgment PLAINTIFFS CROSS-MOTION FOR JUDGMENT ON THE PLEADINGS (Attachments: # 1 Certificate of Service Certificate of Service for Plaintiff's Motion for Judgment on Pleadings)(Federman, Jonathan)
077697.0814(691)
JLF
No. 397
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
NEW YORK HEALTHCARE
INSURANCE COMPANY, A RISK
RETENTION GROUP,
)
)
)
)
Plaintiff,
)
)
v.
)
)
OAK LAWN RESPIRATORY AND
)
REHABILITATION CENTER, LLC, an )
Illinois Limited Liability Company and )
HENRY MOORE, as Independent
)
Administrator of the Estate of WILLIAM )
MOORE, Deceased,
)
)
Defendants.
)
No. 1:16-cv-10609
PLAINTIFF’S CROSS-MOTION FOR JUDGMENT ON THE PLEADINGS
Now comes the Plaintiff, New York Healthcare Insurance Company, a Risk
Retention Group, by its attorneys, Pretzel & Stouffer, Chartered, and pursuant to Federal
Rule of Civil Procedure 12(c) for Judgment on the Pleadings, moves this Honorable
Court to enter Judgment in its favor and against Defendant Oak Lawn Respiratory and
Rehabilitation Center, LLC. In support hereof, the Plaintiff submits its Memorandum of
law.
Respectfully submitted:
s/ Jonathan L. Federman
Jonathan L. Federman, Bar Number: 6312779
Richard M. Burgland, Bar Number: 6289146
PRETZEL & STOUFFER, CHARTERED
One South Wacker Drive
Suite 2500
Chicago, Illinois 60606
Telephone: (312) 578-7461
Fax: (312) 346-8242
E-Mail: jfederman@pretzel-stouffer.com
2
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