United States Securities and Exchange Commission v. Quadrant 4 System Corporation et al

Filing 33

MOTION by Plaintiff United States Securities and Exchange Commission for judgment against Defendant Quadrant 4 Systems Corp. (Attachments: # 1 Exhibit 1 (Final Judgment))(Andrews, Robin)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
Civil Action No. 17-cv-04883
v.
QUADRANT 4 SYSTEM CORP., NANDU
THONDAVADI, and DHRU DESAI,
Defendants.

AGREED MOTION FOR ENTRY OF FINAL JUDGMENT
AS TO DEFENDANT QUADRANT 4 SYSTEM CORPORATION
Plaintiff U.S. Securities and Exchange Commission (“SEC”) has determined not to seek
imposition of disgorgement, prejudgment interest, and a civil penalty as to Defendant Quadrant 4
System Corporation in light of the liquidating Chapter 11 bankruptcy case, In re Quadrant 4
System Corporation, Case No. 17-19689 (Bankr. N.D. Ill.).
The SEC thus submits the Final Judgment as to Defendant Quadrant 4 System
Corporation (Exhibit 1).1 Counsel to Defendant Quadrant 4 System Corporation agrees with the
filing of this Motion.
The SEC respectfully asks the Court to enter this Final Judgment, which fully resolves
the SEC’s claims against Defendant Quadrant 4 System Corporation.

1

An electronic copy will be filed with the Court’s proposed order email inbox.

Respectfully submitted,
s/ Robin Andrews
Robin Andrews (Ill. Bar. No. 6285644)
One of the Attorneys for Plaintiff
UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
175 W. Jackson Blvd., Suite 1450
Chicago, IL 60604
Telephone: [phone]
Facsimile: [phone]
Dated: September 20, 2017

2

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
Civil Action No. 17-cv-04883
v.
QUADRANT 4 SYSTEM CORP., NANDU
THONDAVADI, and DHRU DESAI,
Defendants.

CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that on September 20, 2017, I electronically
submitted the foregoing Agreed Motion for Entry of Final Judgment as to Defendant
Quadrant 4 System Corporation to the Clerk of the Court using the CM/ECF System. The
following persons and entities were served as shown below:

Michael MacPhail (Counsel to Quadrant 4 System Corporation, by email)
[e-mail]
Faegre Baker Daniels LLP
3200 Wells Fargo Center
1700 Lincoln Street
Denver, CO 80203

Theodore T. Poulos (Counsel for Defendant Nandu Thondavadi, by email)
[e-mail]
Terence H. Campbell
Cotsirilos, Tighe & Streicker, LLP
33 North Dearborn Street
Suite 600
Chicago, IL 60602
Jeffrey Stone (Counsel for Defendant Dhru Desai, by email)
[e-mail]
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606
[phone]

Respectfully submitted,
s/ Robin Andrews
Robin Andrews (Ill. Bar. No. 6285644)
One of the Attorneys for Plaintiff
UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
175 W. Jackson Blvd., Suite 1450
Chicago, IL 60604
Telephone: [phone]
Facsimile: [phone]
Dated: September 20, 2017