Meyer et al v. Grady et al

Filing 53

MOTION by Plaintiffs Christopher Meyer, Michael Meyer, Meyer Capital Group, LLC for judgment (stipulated) (Attachments: # 1 Exhibit A - Stipulated Judgment)(Tomlinson, Michael)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MICHAEL MEYER, an individual,
CHRISTOPHER MEYER, an individual,
AND MEYER CAPITAL GROUP, LLC, a
Missouri limited liability company,
Plaintiffs,
vs.
EVERETT GRADY, an individual,
KATHRYN GRADY, an individual, and
KAEGEM, CORP., an Illinois corporation,
Defendants.

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Case No. 17-CV-00289

MOTION FOR ENTRY OF STIPULATED JUDGMENT
Plaintiffs Michael Meyer, Christopher Meyer and Meyer Capital Group, LLC (collectively,
the “Plaintiffs”), by and through their attorneys, respectfully move this Court for entry of the
Stipulated Judgment set forth in Exhibit A to this Motion. In support of this motion, the Plaintiffs
state as follows:
1.

As indicated in the Stipulated Judgment, a judgment denying the discharge of the

debtors there (the two individual defendants in this case) – Everett Grady and Kathryn Grady –
was entered on September 10, 2019 in Adversary Case No. 17-07043 within the Chapter 7
Bankruptcy case pending in the Central District of Illinois Bankruptcy Court, Case No. 17-70853.
2.

In light of the judgment in the adversary proceeding denying Mr. and Mrs. Grady

a discharge in bankruptcy, on September 25, 2019, the bankruptcy court closed the bankruptcy
case.
3.

As a result, the bankruptcy case has concluded and there no longer exists an

automatic stay with respect to this matter.

4.

The parties have resolved their claims with respect to this case, which resolution

requires the entry of the Stipulated Judgment attached as Exhibit A.
5.

As evidenced by their signatures on the Stipulated Judgment, the Plaintiffs and the

Defendants, Everett Grady, Kathryn Grady, and Kaegem, Corp. have agreed and stipulated to the
entry of the Stipulated Judgment.
WHEREFORE, the Plaintiffs respectfully requests that this Court: (i) grant this Motion,
(ii) enter the Stipulated Judgment attached as Exhibit A to this Motion, and (iii) grant such other
and further relief as this Court deems just and proper.
Date: October 2, 2019

Respectfully submitted,

By: /s/ Michael P. Tomlinson
Michael P. Tomlinson (IL Bar No. 6279930)
Tomlinson & Shapiro, P.C.
8501 W. Higgins Road, Ste. 420
Chicago, IL 60631
Phone: [phone]
Email: [e-mail]

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CERTIFICATE OF SERVICE
I, Michael P. Tomlinson, an attorney, hereby certify that on October 2, 2019, I caused the
foregoing Motion for Entry of Stipulated Judgment to be served upon all persons and entities
authorized and registered to receive such service through the Court’s Case Management/Electronic
Case Files (CM/ECF) system. I further caused the foregoing Motion for Entry of Stipulated
Judgment to be served on the Defendants via electronic mail at the email addresses set forth below:

Everett Grady
528 Rosedale Blvd.
Jacksonville, IL 62650
[e-mail]
Kathryn Grady
528 Rosedale Blvd.
Jacksonville, IL 62650
[e-mail]

/s/ Michael P. Tomlinson
Michael P. Tomlinson