Opinion
Case No. 2020 L 010971
12-21-2020
HEATHERWOOD ESTATES CONDO ASSOCIATION, Plaintiff, v. NATIONWIDE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant.
DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
Defendant, NATIONWIDE PROPERTY & CASUALTY INSURANCE COMPANY ("Nationwide"), moves this court pursuant to Rule 56 of the Federal Rules of Civil Procedure, to enter summary judgment in its favor and against the Plaintiff, on Plaintiff's one count complaint for breach of contract, and in support thereof submits the following:
1. Affidavit of Samuel L. Crunkleton, and exhibits cited therein;
2. Statement of Facts pursuant to LR 56.1, and
3. Memorandum of Law.
SUMMARY OF ARGUMENT
I. Plaintiff's action is barred by the policy's suit limitation provision.
WHEREFORE, Defendant Nationwide Property & Casualty Insurance Company prays that this court enter summary judgment in its favor and against the Plaintiff on the Plaintiff's one count complaint for breach of contract, or for such further or additional relief as is just and necessary.
Respectfully submitted, By: /s/ John J. Piegore John J. Piegore (Bar No. 312879)
Edric S. Bautista (Bar No. 6285719)
Sanchez Daniels & Hoffman LLP
333 W. Wacker Drive, Ste. 500
Chicago, Illinois 60606
T (312) 641-1555
F (312) 641-3004
jpiegore@sanchezdh.com
ebautista@sanchezdh.com