United States District Court, N.D. Illinois, Eastern Division
January 13, 2014
GENERAL ASSOCIATION OF REGULAR BAPTIST CHURCHES an Illinois not-for-profit corporation, Plaintiff,
HUGH SCOTT, a citizen of Texas, UNITED RE AG, a Swiss corporation, VADO AG, a Swiss corporation, TEXCESSRE, INC., a Texas corporation, and JOHN DOES 1-5, Defendants.
Antonio DeBlasio, David M. Gower, DeBlasio & Donnell LLC, GENERAL ASSOCIATION OF REGULAR BAPTIST CHURCHES, Oak Brook, Illinois, Plaintiff,
HUGH SCOTT, Pro Se, San Antonio, Texas, Defendant,
AGREED MOTION FOR ENTRY OF FINAL CONSENT JUDGMENT
ANDREA R. WOOD, District Judge.
Plaintiff, General Association of Regular Baptist Churches ("GARBC"), with the agreement of Defendant, Hugh Scott ("Scott"), hereby moves this Honorable Court for entry of the Final Consent Judgment attached hereto as Exhibit A. In support of this motion, GARBC states:
1. GARBC and Scott have executed a written Full Final Settlement Agreement and Mutual Release ("Settlement Agreement").
2. Pursuant to the Settlement Agreement, Scott has agreed to immediate entry of the attached Final Consent Judgment in the amount of $600, 000, which is signed by Scott and GARBC in counterparts. See Ex. A.
3. The attached Final Consent Judgment includes language dismissing all claims in GARBC's complaint against Scott with prejudice, with the parties to bear their own costs, and with the Court retaining jurisdiction to enforce the terms of the Settlement Agreement.
4. WHEREFORE, GARBC, with the agreement of Scott, respectfully requests that this Honorable Court enter the Final Consent Judgment attached hereto as Exhibit A.
FINAL CONSENT JUDGMENT
This matter coming to be heard on the joint agreement of the Plaintiff, General Association of Regular Baptist Churches ("GARBC"), and Defendant, Hugh Scott ("Scott"), (collectively, the "Parties"), the Court having personal jurisdiction over the Parties and subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(3), and the Court having been advised that the Parties have entered into a confidential Full and Final Settlement Agreement and Mutual Release (the "Settlement Agreement"), the Parties hereby consent to entry of this Final Consent Judgment as follows:
1. A judgment in the amount of $600, 000.00 (six hundred thousand and no/100 U.S. Dollars) is hereby entered against Defendant Hugh Scott in favor of Plaintiff, General Association of Regular Baptist Churches.
2. This matter having been fully resolved and settled between the Parties, it is herby ordered that all claims in Plaintiff's Complaint against Defendant Hugh Scott are herby dismissed with prejudice, each Party to bear their own costs.
3. This Court shall retain jurisdiction to enforce the terms of the Settlement Agreement.
This Final Consent Judgment is Acknowledged and Agreed to By: