Vetnique Labs v. Ramirez

Full title: VETNIQUE LABS LLC, an Illinois limited liability company, Plaintiff, v…

Court: United States District Court, Northern District of Illinois

Date published: Aug 22, 2024

1:24-cv-05199 (N.D. Ill. Aug. 22, 2024)

Opinion

1:24-cv-05199

08-22-2024

VETNIQUE LABS LLC, an Illinois limited liability company, Plaintiff, v. DANIEL RAMIREZ, 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 Daniel Ramirez Defendant

Hon. Steven C. Seeger Judge

Daniel C.F. Wucherer VORYS, SATER, SEYMOUR AND PEASE LLP Matthew Jason Singer MATT SINGER LAW, LLC Attorneys for Plaintiff Vetnique Labs LLC

Daniel Ramirez Defendant

AGREED MOTION FOR ENTRY OF STIPULATED FINAL JUDGMENT AND PERMANENT INJUNCTION

Hon. Steven C. Seeger 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 June 21, 2024. (Dkt. No. 1.)

2. On June 26, 2024, Plaintiff served Daniel Ramirez (“Defendant”) with a copy of Plaintiff's complaint and the Court's summons. In the following weeks, Defendant contacted Plaintiff and discussed a potential settlement.

3. Plaintiff and Defendant (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.

4. 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.

5. 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.