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Fuchs Lubricants Co. v. Hudak

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION


May 13, 2008

FUCHS LUBRICANTS CO., A DELAWARE CORPORATION, PLAINTIFF,
v.
NANCY HUDAK, AN INDIVIDUAL, DEFENDANT.

AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT ORDER

The Plaintiff, Fuchs Lubricants Co., by and though its undersigned counsel, and with the agreement of Defendants' counsel, hereby moves for the entry of the Consent Judgment Order attached hereto as "Exhibit A." In support of this Motion, Plaintiff states as follows:

1. The Parties have reached a duly-negotiated settlement of all claims in this lawsuit.

2. The Parties' settlement agreement provides, inter alia, that the Defendant will consent to the jurisdiction of this Court, and agree to the entry of the Consent Judgment Order attached hereto as "Exhibit A."

3. The Parties' settlement agreement further provides, inter alia, that this lawsuit will remain active until July 15, 2008, at which point (but not before), the parties shall petition the Court for the entry of an Agreed Dismissal Order.

WHEREFORE, for the reasons set forth above, the Plaintiff respectfully requests that this Court enter the Consent Judgment Order attached hereto, and schedule a status hearing for a date after July 15, 2008.

20080513

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