SEVA Beauty, LLC v. Vitalslim Inc. et al

Filing 6

MOTION by Plaintiff SEVA Beauty, LLC for judgment (Agreed Motion for Entry of Consent Judgment) (Attachments: # 1 Exhibit A - Consent Judgment)(Cortez Morris, Marlen)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
SEVA BEAUTY, LLC
Plaintiff,
v.
VITALSLIM INC., RICHARD RAMOS,
and DIANE RAMOS
Defendants.

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No. 1:17-cv-02747

AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT
Plaintiff SEVA Beauty, LLC (“SEVA”) and defendants Vitalslim Inc., Richard Ramos,
and Diane Ramos (collectively, “Defendants”), by and through their respective counsel, have
agreed in a separate written settlement agreement to finally resolve this litigation. Pursuant to
that agreement, SEVA and Defendants stipulate to entry of a Consent Judgment on the terms
provided in the attached Exhibit A.
WHEREFORE, SEVA and Defendants jointly request that the Court enter the Consent
Judgment in the form provided.
Dated: April 13, 2017

Respectfully submitted,
VITALSLIM INC.,
RICHARD RAMOS, and
DIANE RAMOS

SEVA BEAUTY, LLC
By: s/ Marlén Cortez Morris
Fredric A. Cohen (IL #6198606)
Marlén Cortez Morris (IL #6291488)
CHENG COHEN LLC
311 N. Aberdeen Street, Suite 400
Chicago, Illinois 60607
[phone]
[e-mail]
[e-mail]

By: s/ E. Michael Ciesla
E. Michael Ciesla
CIESLA LAW FIRM
1363 Shermer Road, Suite 306
Northbrook, Illinois 60062
[phone]
[e-mail]
Attorney for Defendants

Attorneys for Plaintiff
1

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CERTIFICATE OF SERVICE
I hereby certify that on April 13, 2017, I electronically filed the foregoing AGREED
MOTION FOR ENTRY OF CONSENT JUDGMENT with its attached EXHIBIT A with the
Clerk of the Court by using the CM/ECF system, which will send notice of electronic filing to all
counsel of record who are registered CM/ECF users. I further certify that a true and correct copy
of the foregoing was served via electronic and U.S. mail upon the following:

E. Michael Ciesla
CIESLA LAW FIRM
1363 Shermer Road, Suite 306
Northbrook, Illinois 60062
[phone]
[e-mail]
Attorney for Defendants

s/ Marlén Cortez Morris