Bolden v. Pesavento et al.

Filing 75

MOTION by Defendant City Of Chicago for judgment - Motion for Entry of Guaranty of Satisfaction of Judgment (Attachments: #1 Exhibit A)(Shpigel, Elan)

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
EDDIE L. BOLDEN,
Plaintiff,
v.
CITY OF CHICAGO, MICHAEL BAKER,
JOSEPH BARNES, EDWARD HICKS,
MICHAEL KILL, JAMES OLIVER,
ANGELO PESAVENTO, MICHAEL
ROWAN, EDWARD SIWEK,
BARBARA TEMPLE and AS-YET
UNKNOWN CURRENT OR FORMER
EMPLOYEES OF THE CITY OF
CHICAGO,
Defendants.

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Case No. 1:17-cv-00417
Hon. Milton I. Shadur
Magistrate Judge Susan E. Cox

DEFENDANT CITY OF CHICAGO’S GUARANTY OF SATISFACTION OF
JUDGMENT
Defendant City of Chicago (the “City”) hereby guarantees the following:
1.

Should Plaintiff Eddie L. Bolden (“Bolden”) secure judgment against Michael

Baker, Joseph Barnes, Edward Hicks, Michael Kill, James Oliver, Angelo Pesavento, Michael
Rowan, Edward Siwek, or Barbara Temple (the “Defendant Officers”) on his 42 U.S.C. section
1983 claim for any judgment of compensatory damages, including costs and reasonable
attorneys’ fees, then Plaintiff, by operation of this Guarantee, may recover any such judgment
directly from the City. This Guarantee is exclusive of such fees and costs that may be
attributable to an award of punitive damages against the Defendant Officers.
2.

The City also agrees to pay nominal damages (not to exceed one dollar) to which

Plaintiff may be entitled.
3.

This Guarantee is unconditional and irrevocable.

Dated: May 19, 2017

Respectfully submitted,
CITY OF CHICAGO
By: /s/ Elan Shpigel
John F. Gibbons (Attorney No. 06190493)
[e-mail]
Tiffany S. Fordyce (Attorney No. 235063)
[e-mail]
Elan Shpigel (Attorney No. 6321514)
[e-mail]
Greenberg Traurig, LLP
77 West Wacker Drive, Suite 3100
Chicago, Illinois 60601
Tel: [phone]
Attorneys for Defendant City of Chicago

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