Opinion
1:24-cv-05836
09-13-2024
VETNIQUE LABS LLC, an Illinois limited liability company, Plaintiff, v. ABUMAYYALEH BROS LLC, an Indiana limited liability company, MOHAMMAD F. ABUMAYYALEH, a natural person, and JOHN DOES 1-10, individually or as corporations/business entities, Defendants.
Daniel C.F. Wucherer VORYS, SATER, SEYMOUR AND PEASE LLP Matthew Jason Singer MATT SINGER LAW, LLC Attorneys for Plaintiff Vetnique Labs LLC Ahad F. Syed SYED LAW P.C. Attorneys for Defendants Abumayyaleh Bros LLC and Mohammad F. Abumayyaleh
Daniel C.F. Wucherer VORYS, SATER, SEYMOUR AND PEASE LLP Matthew Jason Singer MATT SINGER LAW, LLC Attorneys for Plaintiff Vetnique Labs LLC
Ahad F. Syed SYED LAW P.C. Attorneys for Defendants Abumayyaleh Bros LLC and Mohammad F. Abumayyaleh
AGREED MOTION FOR ENTRY OF STIPULATED FINAL JUDGMENT AND PERMANENT INJUNCTION
Hon. Matthew F. Kennelly, Judge
Pursuant to Federal Rule of Civil Procedure 41(a), plaintiff Vetnique Labs LLC (“Plaintiff”) submits this agreed motion for entry of stipulated final judgment and a permanent injunction. In support, Plaintiff states as follows:
1. Plaintiff filed its complaint in this action on July 10, 2024. (Dkt. No. 1.)
2. On July 12, 2024, Plaintiff served defendants Abumayyaleh Bros LLC and Mohammad F. Abumayyaleh (“Defendants”) with a copy of Plaintiff's complaint and the Court's summons. (Dkt. Nos. 7-8.)
3. On August 5, 2024, Plaintiff filed a motion for entry of default against Defendants under Federal Rule of Civil Procedure 55(a) after Defendants did not answer or otherwise respond to Plaintiff's complaint. (Dkt. No. 11.)
4. On August 6, 2024, the Court entered a default against Defendants under Federal Rule of Civil Procedure 55(a). (Dkt. No. 12.) On the same day, Defendants contacted Plaintiff for the first time and discussed a potential settlement.
5. Plaintiff and Defendants (collectively, “the Parties”) have now reached an agreement on settlement terms that will resolve this case in full. The Parties' settlement is conditioned on the Court entering the proposed Stipulated Final Judgment and Permanent Injunction that has been submitted with this motion. Each of the Parties has agreed to the terms in the proposed Stipulated Final Judgment and Permanent Injunction.
6. Accordingly, Plaintiff hereby requests that this Court enter the proposed Stipulated Final Judgment and Permanent Injunction that has been submitted with this Motion and retain jurisdiction over this matter only for the purpose of enforcing and/or adjudicating claims that a party has violated the Stipulated Final Judgment and Permanent Injunction.
7. Through a separate filing, Plaintiff has dismissed Defendants John Does 1-10 from this action without prejudice. Accordingly, entering the proposed Stipulated Final Judgment and Permanent Injunction will resolve all remaining claims and allow for closure of this case.