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Zurich Specialties London Limited v. Village of Bellwood

May 4, 2010

ZURICH SPECIALTIES LONDON LIMITED, PLAINTIFF,
v.
VILLAGE OF BELLWOOD, ILLINOIS, A MUNICIPAL CORPORATION, GREGORY MOORE, DONALD LEMM, NICHOLAS NARDUCCI, ST. PAUL MERCURY INSURANCE COMPANY AND ST. PAUL FIRE & MARINE INSURANCE COMPANY DEFENDANTS.
VILLAGE OF BELLWOOD, ILLINOIS, A MUNICIPAL CORPORATION, GREGORY MOORE, AND DONALD LEMM, COUNTERPLAINTIFFS,
v.
ZURICH SPECIALTIES LONDON LIMITED, COUNTERDEFENDANT,
VILLAGE OF BELLWOOD, ILLINOIS, A MUNICIPAL CORPORATION, GREGORY MOORE, AND DONALD LEMM, CROSS-PLAINTIFFS,
v.
ST. PAUL MERCURY INSURANCE COMPANY AND ST. PAUL FIRE & MARINE INSURANCE COMPANY CROSS-DEFENDANTS.



The opinion of the court was delivered by: Hon. Joan Humphrey Lefkow

ZURICH'S MOTION FOR JUDGMENT ON THE PLEADINGS AGAINST ST. PAUL MERCURY AND ST. PAUL FIRE AND MARINE

Now comes the Plaintiff, Zurich Specialties London Limited, by and through its attorneys, Joseph P. Postel, David S. Osborne and Christopher J. Pickett of Lindsay, Rappaport & Postel, LLC, and submits the following Motion for Judgment on the Pleadings against Defendants, St. Paul Fire & Marine Insurance Company and St. Paul Mercury Insurance Company. In support hereof, Zurich submits its Joint Memorandum of Law, leave for which to file is sought contemporaneously herewith by separate motion.

WHEREFORE, the Plaintiff, Zurich Specialties London Limited, respectfully prays that this Honorable Court enter an Order, pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, granting judgment on the pleadings in its favor and against Defendants, St. Paul Fire & Marine Insurance Company and St. Paul Mercury Insurance Company as to Counts III, IV, IX and X of its Amended Complaint for Declaratory Judgment. In the alternative, Zurich Specialties London Limited respectfully requests that this Honorable Court render such other and further relief as the Court deems appropriate under the circumstances.

20100504

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