Opinion
23 CV 5459
12-19-2024
AMERICAN EAGLE LEESBURG AL, LLC, a Florida limited liability company; and AMERICAN EAGLE LEESBURG MC, LLC, a Florida limited liability company, Plaintiffs, v. ILLUMINATE HC, LLC, an Illinois limited liability company; YAIR ZUCKERMAN, an adult individual; and HARRY SCHAYER, an adult individual, Defendants.
Jerry L. Switzer, Jr. (ARDC No. 6210229) Nathan B. Grzegorek (ARDC No. 6306078) Polsinelli PC AMERICAN EAGLE LEESBURG AL, LLC AND AMERICAN EAGLE LEESBURG MC, LLC One of Its Attorneys
HON. JORGE L. ALONSO, JUDGE
Jerry L. Switzer, Jr. (ARDC No. 6210229)
Nathan B. Grzegorek (ARDC No. 6306078)
Polsinelli PC
AMERICAN EAGLE LEESBURG AL, LLC AND
AMERICAN EAGLE LEESBURG MC, LLC
One of Its Attorneys
MOTION FOR ENTRY OF MEMORANDA OF JUDGMENT
NOW COMES plaintiffs/judgment creditors American Eagle Leesburg AL, LLC and American Eagle Leesburg MC, LLC (collectively, “Plaintiff”) by and through their undersigned attorneys, and pursuant to 735 ILCS 5/12-502, moves this Court for the entry of memoranda relative to the Amended Judgment [Dkt. No. 35] (the “Judgment”) previously entered against defendants/judgment debtors Illuminate HC, LLC (“Illuminate”), Yair Zuckerman (“Zuckerman”), and Harry Schayer (“Schayer” and collectively with Zuckerman, the “Guarantors”) (Illuminate, Zuckerman and Schayer are collectively referred to herein as “Defendants”). In support of said motion, Plaintiff states as follows:
1. On October 29, 2024, the Court entered the Judgment against Defendants. Dkt. No. 35.
2. In relevant part, Section 12-502 of the Illinois Code of Civil Procedure provides that
Upon filing in the office of the recorder in any county of this State of a transcript, certified copy or memorandum of a judgment entered in this State by a court of the United States, such judgment shall be a lien upon the real estate of the person against whom the same is entered, in the county where filed, in like manner as judgments of courts of this State. The term “memorandum” as used in this Section means a memorandum or copy of the judgment signed by a judge of the court entering it and showing the court in which entered, date, amount, case number of the case in which entered, name of the party in whose favor and name of the party against whom entered...735 ILCS 5/12-502
3. In light of the foregoing, Plaintiff respectfully requests entry of the memoranda of judgment attached hereto as Exhibits A (relative to Illuminate), B (relative to Zuckerman), and C (relative to Schayer).
WHEREFORE, Plaintiff respectfully requests the following relief: (1) entry of the memoranda of judgment attached hereto as Exhibits A, B, and C; and (2) such further and additional relief as this Court deems just and appropriate.
EXHIBIT “A”
MEMORANDUM OF JUDGMENT
Recorder's Stamp
Case No. 23 CV 5459
MEMORANDUM OF JUDGMENT
I certify that on October 29, 2024, judgment was entered in this court in favor of the Plaintiffs, American Eagle Leesburg AL, LLC and American Eagle Leesburg MC, LLC, and against the Defendant, Illuminate HC, LLC, whose address is c/o Incorp Services, Inc., Registered Agent, 901 S. 2nd St., Ste. 201, Springfield, IL 62704, in the amount of $631,817.62, plus postjudgment interest, attorneys' fees and costs.
Dated:
Judge
POLSINELLI PC
150 N. Riverside Plaza, Suite 3000
Chicago, IL 60606
(312) 819-1900 - Telephone
(312) 819-1910 - Facsimile
ARDC No. 6306078
EXHIBIT “B”
MEMORANDUM OF JUDGMENT
Recorder's Stamp
Case No. 23 CV 5459
MEMORANDUM OF JUDGMENT
I certify that on October 29, 2024, judgment was entered in this court in favor of the Plaintiffs, American Eagle Leesburg AL, LLC and American Eagle Leesburg MC, LLC, and against the Defendant, Yair Zuckerman, whose address is 2954 W. Fairwell Ave., Chicago, IL 60645, in the amount of $631,817.62, plus post-judgment interest, attorneys' fees and costs.
Dated:
Judge
POLSINELLI PC
150 N. Riverside Plaza, Suite 3000
Chicago, IL 60606
(312) 819-1900 - Telephone
(312) 819-1910 - Facsimile
ARDC No. 6306078
EXHIBIT “C”
MEMORANDUM OF JUDGMENT
Recorder's Stamp
Case No. 23 CV 5459
MEMORANDUM OF JUDGMENT
I certify that on October 29, 2024, judgment was entered in this court in favor of the Plaintiffs, American Eagle Leesburg AL, LLC and American Eagle Leesburg MC, LLC, and against the Defendant, Harry Schayer, whose address is 2902 W. Morse Ave., Chicago, IL 60644, in the amount of $631,817.62, plus post-judgment interest, attorneys' fees and costs.
Dated:
Judge
POLSINELLI PC
150 N. Riverside Plaza, Suite 3000
Chicago, IL 60606
(312) 819-1900 - Telephone
(312) 819-1910 - Facsimile
ARDC No. 6306078