Opinion
21-cv-6592
06-07-2022
JAIRO CHAVEZ, PLAINTIFF, v. MEDICAL BUSINESS BUREAU, LLC DEFENDANT.
Bryan Paul Thompson One of Plaintiff's Attorneys Robert W. Harrer Chicago Consumer Law Center, P.C.
Bryan Paul Thompson
One of Plaintiff's Attorneys
Robert W. Harrer
Chicago Consumer Law Center, P.C.
HON. MARTHA M. PACOLD
PLAINTIFF'S MOTION FOR ENTRY OF JUDGMENT ON OFFER OF JUDGMENT
NOW COMES Plaintiff Jairo Chavez, by and through counsel, who states as follows:
1. On May 20, 2022, Defendant transmitted to Plaintiff an offer to allow judgment to be entered against it and in favor of Plaintiff for $1,001 in statutory damages plus reasonable attorneys' fees and costs. A copy of the Offer of Judgment was docketed as Dkt. # 15-1.
2. On June 3, 2022, Plaintiff accepted Defendant's offer of judgment by filing a notice of acceptance of offer of judgment with this court. (Dkt. # 20).
3. Plaintiff respectfully requests that this court enter judgment in favor of Plaintiff for $1,001 plus attorney's fees and costs, and allow the parties to confer regarding attorney's fees and costs pursuant to Local Rule 54.3.
WHEREFORE, based on the foregoing, Plaintiff requests the Court to enter judgment in the amount of $1,001 in favor of Plaintiff and against Defendant, require the parties to proceed according to local rule 54.3, and for any other or further relief this Court deems just.
Dated: June 7, 2022
Respectfully submitted, By: Bryan Paul Thompson
One of Plaintiff's Attorneys
Bryan Paul Thompson
Robert W. Harrer
Chicago Consumer Law Center, P.C.