Mohawk Spring Division of MW Industries, Inc. v. ZD Integrated Circuits, Incorporated

Filing 45

MOTION by Plaintiff Mohawk Spring Division of MW Industries, Inc. for judgment (Maly, Heather)

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MOHAWK SPRING DIVISION OF MW INDUSTRIES, INC., Plaintiff, v. ZD INTEGRATED CIRCUITS, INCORPORATED, Defendant. ) ) ) ) ) ) ) ) ) ) No. 17-cv-9227 Honorable John Robert Blakey AGREED MOTION TO ENTER JUDGMENT Plaintiff Mohawk Spring Division of MW Industries, Inc. (“MWI”), by its attorneys Ice Miller LLP, hereby submits this Agreed Motion to Enter Judgement, and states as follows: 1. The Court granted summary judgment in favor of the Plaintiff on December 10, 2018. (Dkt. #42). In the Order entering summary judgment, the Court stated that it will enter judgment in Plaintiff’s favor in the amount of $960,284.04, plus interest, calculated consistent with the Supply Agreement. The Court instructed the parties to meet and confer and provide the exact amount of interest. 2. Since the Court’s order, the parties have met and conferred and agree and stipulate that the Judgment amount (inclusive of interest, fees, costs, etc.) is $1,071,029.58 and request this Court enter Judgment in the amount of $1,071,029.58 in favor of Plaintiff MOHAWK SPRING DIVISION OF MW INDUSTRIES, INC. 3. A copy of the Proposed Judgment setting forth the above agreed to terms is being filed simultaneously with this motion. 4. Defendant ZD Integrated, Incorporated has reviewed and consented to this motion and entry of the attached Judgment. 1 FOR THE FOREGOING REASONS, Plaintiff Mohawk Spring Division of MW Industries, Inc. requests that the Court enter Judgment in the amount of $1,071,029.58 and provide all further relief that the Court deems just and proper. Dated: January 18, 2019 Respectfully submitted, MOHAWK SPRING DIVISION OF MATTHEW WARREN, INC. dba MW INDUSTRIES, INC. By: Heather L. Maly ICE MILLER LLP 200 West Madison, Suite 3500 Chicago, Illinois 60606 (312) 726-8107 Heather.Maly@icemiller.com Drew Miroff (to be admitted pro hac vice) ICE MILLER LLP One American Square, Suite 2900 Indianapolis IN 46282-0200 (317) 236-2267 Drew.Miroff@icemiller.com 2 /s/ Heather L. Maly One of Its Attorneys CERTIFICATE OF SERVICE The undersigned attorneys, certifies that on January 18, 2019, she caused a true and correct copy of the foregoing to be served via electronic mail upon: Timothy W. Weber (admitted pro hac vice) Weber, Crabb & Wein, P.A. 5999 Central Ave., Suite 203 St. Petersburg, FL 33710 (727) 828-9919 (727) 828-9924 (facsimile) timothy.weber@webercrabb.com Karl W. Roth William P. Floley Roth Law Group LLC 150 N Michigan Ave, #800 Chicago, Illinois 60601 (312) 419-9599 (312) 419-9559 (facsimile) kwr@rothlawgroup.com wpf@rothlawgroup.com /s/ Heather L. Maly Heather L. Maly C\1297335.2

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