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)

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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: 2

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