Hill v. Consultants in Pathology, S.C.

Filing 41

MOTION by Defendants Consultants in Pathology, S.C., Pathology Consultants, Inc. for judgment UNOPPOSED (Attachments: # 1 Exhibit Exhibit A to Motion for Entry of Judgment in Favor of Defendants)(Phillips, Kristine)

File No. 26524-KSP

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
KALISHA HILL, M.D.,
Plaintiff,
v.
CONSULTANTS IN PATHOLOGY, S.C.
an Illinois medical corporation, and
PATHOLOGY CONSULTANTS, INC.,
Defendants.

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Case No. 18-cv-00881
Judge John Z. Lee
Magistrate Judge Sheila Finnegan

DEFENDANTS’ UNOPPOSED MOTION FOR ENTRY OF JUDGMENT
IN FAVOR OF DEFENDANTS
Defendants, CONSULTANTS IN PATHOLOGY, S.C. (CIP) and PATHOLOGY
CONSULTANTS, INC. (PCI), (collectively the “Defendants”), through their counsel, Kristine S.
Phillips and Kate Kosartes of O’Hagan Meyer, move this Court for entry of judgment in favor of
CIP and PCI pursuant to an arbitration award, and against Plaintiff KALISHA HILL, M.D.
(“Plaintiff”), denying and dismissing Plaintiff’s First Amended Complaint At Law. In support of
their motion, Defendants state as follows:
1.

Plaintiff filed her initial complaint on February 2, 2018 against CIP and PCI

alleging race discrimination under Section 1981 and retaliation under Title VII and Section 1981.
(Doc. 1)
2.

On March 26, 2018, Defendants moved to dismiss the complaint. (Docs. 8, 9, 11,

3.

On November 1, 2018, this Court issued a written memorandum opinion and

12).

order dismissing Plaintiff’s claims against PCI, with leave to replead. (Doc. 32). This Court

further stayed all claims against CIP, and compelled arbitration of those claims with the
American Health Lawyers Association (“AHLA”) pursuant to the parties’ contract. (Doc. 32)
4.

Plaintiff then filed her First Amended Complaint on November 6, 2018 against

CIP and PCI again alleging race discrimination under Section 1981 and retaliation under Title
VII and Section 1981. (Doc. 34)
5.

Thereafter, PCI filed a motion to stay proceedings as the parties agreed to

arbitrate their claims before the AHLA, along with the claims asserted against CIP (Doc. 38),
which this Court granted (Doc. 40).
6.

The parties proceeded to an arbitration hearing held June 10-14, 2019. An

arbitration award was entered on October 29, 2019. Attached hereto as Exhibit A is a true and
accurate copy of the AHLA arbitration award.
7.

Specifically, the arbitrator found that Plaintiff failed to establish her claims of

discrimination and retaliation asserted against both Defendants and as such, entered judgment in
favor of Defendants.
8.

Pursuant to the arbitration award, Defendants move this Court for entry of a

judgment in favor of Defendants CIP and PCI and against Plaintiff, denying and dismissing
Plaintiff’s First Amended Complaint.
9.

Counsel for Plaintiff has no objection to this motion.

WHEREFORE,

Defendants

CONSULTANTS

IN

PATHOLOGY,

S.C.

and

PATHOLOGY CONSULTANTS, INC. move this Court for entry of an order granting judgment
in their favor and against Plaintiff KALISHA HILL, M.D. denying and dismissing Plaintiff’s
First Amended Complaint at Law, and for any further relief this Court deems fair and just.

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Date: November 1, 2019
Respectfully submitted:
CONSULTANTS IN PATHOLOGY, S.C.
and PATHOLOGY CONSULTANTS, INC.

By:/s/ Kristine S. Phillips_________________
One of their attorneys
O’HAGAN MEYER LLC
Kristine S. Phillips
O’HAGAN MEYER LLC
One E. Wacker Dr., Suite 3400
Chicago, Illinois 60601
Telephone: [phone]
Facsimile: 312.422.6110
[e-mail]

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CERTIFICATE OF SERVICE
This is to certify that on this 1st day of November 2019, I electronically filed the
DEFENDANTS’ UNOPPOSED MOTION FOR ENTRY OF JUDGMENT IN FAVOR OF
DEFENDANTS, with the Clerk of Court using the CM/ECF system which will send notification
of such filing to the following:
Attorney for Plaintiff
Gregory T. Mitchell
Law Office of Gregory T. Mitchell, PC
18141 Dixie Highway, Suite 100
Homewood , IL 60430
PH: 708-799-9325
[e-mail]

/s/ Kristine S. Phillips
Kristine S. Phillips
O’HAGAN MEYER LLC
One E. Wacker Dr., Suite 3400
Chicago, Illinois 60601
Telephone: [phone]
Facsimile: 312.422.6110
[e-mail]
ATTORNEY FOR DEFENDANTS
CONSULTANTS IN PATHOLOGY, S.C. and
PATHOLOGY CONSULTANTS, INC.

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