Secura Insurance Company v. Wendy's International, LLC et al

Filing 41

MOTION by Petitioner Secura Insurance Company for judgment SECURA INSURANCE COMPANYS MOTION FOR SUMMARY JUDGMENT ON ITS AMENDED COMPLAINT FOR DECLARATORY JUDGMENT (Ross, Andrea)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
SECURA INSURANCE COMPANY,
Plaintiff,
v.
WENDY’S INTERNATIONAL, LLC,
WENDY’S PROPERTIES, LLC,
Defendant
JIM E. DUBBERKE, JR.,
Necessary Party.

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Case No. 1:24-cv-00862

SECURA INSURANCE COMPANY’S MOTION FOR SUMMARY JUDGMENT ON ITS
AMENDED COMPLAINT FOR DECLARATORY JUDGMENT
Plaintiff, SECURA Insurance Company (“SECURA”) pursuant to Federal Rule of Civil
Procedure 56 and Local Rule 56.1 respectfully requests that this Court grant summary judgment
in its favor on its Amended Complaint for Declaratory Judgment. In support of this motion,
SECURA submits its Memorandum in Support of SECURA’s Motion for Summary Judgment on
its Amended Complaint for Declaratory Judgment and its Local Rule 56.1 Statement of Material
Facts with exhibits, which are incorporated by reference herein.
Respectfully submitted,
STONE & JOHNSON, CHTD.
/s Andrea M. Ross
Attorney for SECURA
Insurance Company
Andrea M. Ross (ARDC No. 6288559)
STONE & JOHNSON, CHTD.
111 W. Washington St., Suite 1800
Chicago, Illinois 60602
[phone]
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on March 6, 2025, I electronically filed the foregoing Motion for
Summary Judgment with the Clerk of the Court using the CM/ECF system, which sends electronic
notification to all registered participants of such filings to all attorneys of record.

/s/ Andrea M. Ross
Andrea M. Ross