Griffin v. Demark, Inc.

Filing 53

MOTION by Plaintiff John Griffin for judgment Plaintiff's Motion to Enter Judgment with Respect to Four Plaintiffs (Schreiber, Richard)

Case: 1:18-cv-00979 Document #: 53 Filed: 09/12/18 Page 1 of 3 PageID #:453

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
JOHN GRIFFIN, individually and on behalf of
all others similarly situated,
Plaintiff,

Case No. 1:18-cv-00979
Hon. Judge Charles P. Kocoras
Magistrate Judge Sidney I. Schenkier

v.
DEMARK, INC.,
Defendant.

PLAINTIFF’S MOTION TO ENTER JUDGMENT
WITH RESPECT TO FOUR PLAINTIFFS
Demark made offers of judgment to four of the plaintiffs in this matter. See ECF Nos. 29-32.
These four plaintiffs filed notices accepting the offers of judgment. Id. In their notices, each plaintiff
requested judgment be entered in their favor in accordance with the terms of Demark’s offers of
judgment. Id. Under the terms of Rule 68, the filing of “the offer and notice of acceptance, plus proof
of service” mandates that the clerk “then enter judgment.” See FRCP 68(a).
Because all the necessary filings have been made, Plaintiffs respectfully request the Court
enter judgment in favor of:
1. Rem Le in this amount of $29,028;
2. James McClure in the amount of $21,590;
3. Jerry K. Miles in the amount of $50,320;
4. John Griffin in the amount of $191,141.
Once judgment is entered, these plaintiffs will then file a motion for attorney’s fees and costs
in accordance with 29 U.S.C. § 216(b) and N.D. Ill. LR54.3.

Case: 1:18-cv-00979 Document #: 53 Filed: 09/12/18 Page 2 of 3 PageID #:454

Dated: September 12, 2018

Respectfully Submitted,
By:

/s/Richard M. Schreiber
One of Plaintiff’s Attorneys

Michael A. Josephson
Richard M. Schreiber
JOSEPHSON DUNLAP
11 Greenway Plaza, Suite 3050
Houston, Texas 77046
[phone]
Richard (Rex) J. Burch
BRUCKNER BURCH, P.L.L.C.
8 Greenway Plaza, Suite 1500
Houston, Texas 77046
[phone]
Douglas M. Werman
Maureen A. Salas
WERMAN SALAS P.C.
77 West Washington, Suite 1402
Chicago, Illinois 60602
[phone]

Attorneys for Plaintiff and Others Similarly Situated

Case: 1:18-cv-00979 Document #: 53 Filed: 09/12/18 Page 3 of 3 PageID #:455

CERTIFICATE OF SERVICE
The undersigned attorney hereby certifies that on September 12, 2018, the foregoing Motion
(and all supporting documents attached thereto) were filed electronically with the Clerk of Court using
the ECF system which sent notice of the filing to the following:
Gerald L. Maatman, Jr.
Rebecca P. DeGroff
Alex W. Karasik
SEYFARTH SHAW, LLP
233 South Wacker Drive, Suite 8000
Chicago, IL 60606
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
By:

/s/Richard M. Schreiber
One of Plaintiff’s Attorneys