Bolden v. City Of Chicago 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)

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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. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 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) gibbonsj@gtlaw.com Tiffany S. Fordyce (Attorney No. 235063) fordycet@gtlaw.com Elan Shpigel (Attorney No. 6321514) shpigele@gtlaw.com Greenberg Traurig, LLP 77 West Wacker Drive, Suite 3100 Chicago, Illinois 60601 Tel: (312) 456-8400 Attorneys for Defendant City of Chicago 2

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