Redstone Funding LLC v. Yang et al, No. 1:2012cv07480 - Document 43 (N.D. Ill. 2014)

Court Description: MOTION by Plaintiff Redstone Funding LLC for judgment NOTICE OF AGREEMENT ON ATTORNEYS' FEES AND COSTS AND PLAINTIFF'S MOTION FOR ENTRY OF FINAL JUDGMENT (Hunter, Steven)

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Redstone Funding LLC v. Yang et al Doc. 43 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION BANK OF AMERICA, N.A., a North Carolina corporation, Plaintiff, v. Case No. 12-cv-07480 Honorable Sharon Johnson Coleman CHI CHING YANG, an individual, ANGELA CHIANG, an individual. Magistrate Judge Sheila M. Finnegan Defendants. NOTICE OF AGREEMENT ON ATTORNEYS' FEES AND COSTS AND PLAINTIFF'S MOTION FOR ENTRY OF FINAL JUDGMENT Plaintiff, Redstone Funding, LLC ("Plaintiff), by its attorneys, Leonard S. Shifflett and Steven Y. Hunter of Quarles & Brady LLP, moves this Court to enter final judgment against Defendants, Chi Ching Yang and Angela Chiang (collectively the "Defendants"), jointly and severally, in the total amount of $4,325,903.64. In support of its Motion, Plaintiff states as follows: 1. Pursuant to Local Rule 54.3, Defendants have agreed to pay (and Plaintiff has agreed to accept) $50,000 as payment for all attorneys' fees and costs associated with the instant case. 2. In light of the Parties' agreement to accept $50,000, this Court's May 27, 2014 finding that Defendants defaulted on their Guarantees (Doc. 35) and the express language of the CAKK Loan Documents and CAKK Guarantees, Defendants are responsible to pay Plaintiff the following amounts that were due and owing as of June 11, 2014: QB\28534498.1 Dockets.Justia.com a. $4,228,458.90 principal b. $41,414.65 late fees c. $6,030.09 interest d. $50,000 attorneys fees and costs $4,325,903.64 Total WHEREFORE, Plaintiff prays for entry of a $4,325,903.64 judgment in its favor and against Chi Ching Yang and Angela Chiang. Dated: July 16,2014 Respectfully submitted, Redstone Funding, LLC By: Leonard S. Shifflett (ARDC #2587432) Steven V. Hunter (ARDC #6277695) QUARLES & BRADY LLP 300 North LaSalle Street, Suite 4000 Chicago, IL 60654 (312) 715-5000-Telephone (312) 715-5155-Facsimile QB\28534498.1 /s/ Steven V. Hunter One of Its Attorneys

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