Opinion
No. 10 CV 2225
11-14-2011
John W. Billhorn, attorney for Plaintiff, and all other Plaintiffs similarly situated, known or unknown.
Honorable Judge Kendall
Magistrate Judge Keys
JURY DEMAND
PLAINTIFF'S MOTION FOR ENTRY OF JUDGMENT
NOW COMES Plaintiff, TERRELL R. SCOTT, through his attorney of record, JOHN W. BILLHORN, and for his Motion For Entry Of Judgment, state as follows:
1. ) The parties settled and compromised the disputes of this litigation and entered into a written settlement agreement. The settlement agreement is attached hereto as Exhibit A.
2. ) The Agreement provides for ten (10) installment payments to be made by the first of each month, starting with October 1, 2011 with due dates certain and penalties for late payments. See paragraph eight (8). Additionally, at paragraph 26, the Agreement provides for a Confession of Judgment should Defendants default on the terms of the installment payments.
3) On October 18, 2011, Plaintiff's attorney office received notification that Defendants' first payment for October, 2011 was returned NSF. Defendants have failed to cure that NSF check and have also defaulted on the November 1, 2011 payment.
4) Attached is a proposed Judgment Order Plaintiff requests to be entered by the Court.
WHEREFORE, Plaintiff requests that Judgment be entered against Defendants, 7-BEAUTY, INC. D/B/A 7 BEAUTY SUPPLY, SUHYUN KIM,INDIVIDUALLY, AND JAMES KIM INDIVIDUALLY, and for such other relief as the Court deems appropriate under the circumstances.
Respectfully submitted,
John W. Billhorn, attorney for
Plaintiff, and all other Plaintiffs similarly
situated, known or unknown.
BILLHORN LAW FIRM