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No. 26 MOTION by Plaintiff Bowcon Company Inc to alter judgment (Donnelly, Craig) (Entered: 08/12/2020)

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 26 (N.D.Ill. Aug. 12, 2020)
59(e) NOW COMES Plaintiff, BOWCON COMPANY, INC., by and through its attorneys, DONNELLY LAW LLC, for its Motion to Alter or Amend Judgment pursuant to Federal Rule of Civil Procedure 59(e), states as follows:
On August 4, 2020, the Court entered an Oder granting the Motion for Default Judgment against Ismail Mohammed [ECF 23].
The August 4, 2020 Order however did not include language of an express finding by the Court required by Fed.R.Civ.P.
Accordingly, Plaintiff requests that this Court enter an Amended Order, nunc pro tunc to August 4, 2020 granting Plaintiff’s Motion for Default Judgment and including language that the court finds no just reason to delay entry of final judgment.
WHEREFORE, Plaintiff, BOWCON COMPANY, INC. respectfully requests that this Court, pursuant to Federal Rule of Civil Procedure 59(e) amend its prior Order dated August 4, 2020 granting Default Judgment to include the language set forth above and award such other and further relief as this Court deems reasonable and just.
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No. 21 MOTION by Plaintiff Bowcon Company Inc for default judgment as to Ismail Mohammed (Attachments: ...

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 21 (N.D.Ill. Jul. 30, 2020)
55(b) NOW COMES Plaintiff, BOWCON COMPANY, INC., a California corporation, by and through its attorneys, DONNELLY LAW LLC, for its Motion for Default Judgment pursuant to Federal Rule of Civil Procedure 55(b), states as follows:
This court entered an Order granting Plaintiff’s Motion for Default against all Defendants on July 13, 2020 [See ECF 19]
18 U.S.C.§1964(c) states (in relevant part) as follows: Any person injured in his business or property by reason of a violation of section 1962 of this chapter may sue therefor in any appropriate United States district court and shall recover threefold the damages he sustains and the cost of the suit, including a reasonable attorney’s fee….
The Declaration of Dennis Bowman (attached hereto as Exhibit A) sets forth compensatory damages payable to Plaintiff in the amount of $627,414.78.
55(b) in the amount of $1,882,244.30, WHEREFORE, Plaintiff, BOWCON COMPANY, INC. respectfully requests that this Court enter Default Judgment against Defendant ISMAIL MOHAMMED, in the amount of $1,882,243.30, plus post-judgment interest pursuant to 28 U.S.C. §1961 and award such other and further relief as this Court deems reasonable and just.
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No. 16 MOTION by Plaintiff Bowcon Company Inc for default judgment as to ALL DEFENDANTS (Attachments: ...

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 16 (N.D.Ill. Jun. 8, 2020)
NOW COMES Plaintiff, BOWCON COMPANY, INC., a California corporation, by and through its attorneys, DONNELLY LAW LLC, for its Motion for Entry of Default, pursuant to Federal Rule of Civil Procedure 55(a), against Defendants ISMAIL MOHAMMED, AXIS CAR WASH LLC, and AXIS AUTO SPA & PATEL TRADING, states as follows:
Accordingly, pursuant to Federal Rule of Civil Procedure 12(a)(1)(A)(i), Defendants ISMAIL MOHAMMED, AXIS CAR WASH LLC, and AXIS AUTO SPA & PATEL TRADING were required to file an appearance, answer, or other responsive pleading/motion 21 days after the date of service, or March 13, 2020.,
To date, Defendants ISMAIL MOHAMMED, AXIS CAR WASH LLC, and AXIS AUTO SPA & PATEL TRADING have not filed an appearance, answer, or motion with this Court, and no Defendants have filed a motion requesting additional time to do so.
Accordingly, pursuant to Federal Rule of Civil Procedure 55(a), Plaintiff requests the Clerk of Court to enter orders of default against Defendants ISMAIL MOHAMMED, AXIS CAR WASH LLC, and AXIS AUTO SPA & PATEL TRADING due to their failure to appear, answer, or file a motion within the time period permitted by Federal Rules of Civil Procedure 12(a).
WHEREFORE, Plaintiff, BOWCON COMPANY, INC. respectfully requests that this Court enter orders of default against Defendants ISMAIL MOHAMMED, AXIS CAR WASH LLC, and AXIS AUTO SPA & PATEL TRADING, set this matter for prove-up on the relief sought in the Complaint on a date to be determined, and award such other and further relief as this Court deems reasonable and just.
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No. 27 BILL of Costs (Donnelly, Craig) (Entered: 08/12/2020)

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 27 (N.D.Ill. Aug. 12, 2020)
ISMAIL MOHAMMED, individually, AXIS CAR WASH, LLC, an Illinois limited liability company; AXIS AUTO SPA & PATEL TRADING, INC., an Illinois Corporation,
NOW COMES Plaintiff, BOWCON COMPANY, INC., a California corporation, by and through its attorneys, DONNELLY LAW LLC, submits the following Bill of Costs: Description of Cost Complaint filing fee
Fees to the Clerk Fees for service of Process of Summons and Complaint Hanrahan Investigations Group -fees for investigation with follow-up, travel, and multiple service attempts upon Ismail Mohammed
$1,212.07 Total: $1,612.07 The undersigned declares under penalty of perjury that the foregoing costs are correct and were necessarily incurred in this action, and that the services for which fees have been charged were actually and necessarily performed.
Dated: August 12, 2020
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No. 1 COMPLAINT filed by Bowcon Company Inc; Jury Demand

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 1 (N.D.Ill. Nov. 27, 2019)
Complaint
Given that these agreements were requested by Defendant MOHAMMED after he had already filed the fraudulent Statement of Information with the California Secretary of State, it is apparent that these amendments were intended, at least in part, to serve the purpose of continuing to divert attention way from his execution of the scheme so as to delay or prevent its eventual discovery.
Upon information and belief, in connection with the sale of Plaintiff BOWCON’s accounts receivable to Biz Fund, Defendant MOHAMMED permitted the recording of a UCC-1 Financing Statement to be filed evidencing the existence of the agreement.
At that time, Defendant MOHAMMED told the Bowmans that the money had been secured by him as additional operating capital for BOWCON following the future anticipated close of the SPA transaction.
Following apparent breach of their agreement by Defendant MOHAMMED, on or about February 12, 2019, Kalamata obtained a “Judgment of Confession” entered in the Supreme Court of the State of New York, County of Ontario in the total amount of $320,481.43 (the “Kalamata Judgment”).
Following apparent breach by Defendant MOHAMMED, on or about August 1, 2019, Westwood obtained a “Judgment (Confessed)” entered in the Supreme Court of the State of New York, County of Westchester in the total amount of $306,933.35 (the “Westwood Judgment”).
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No. 7 AFFIDAVIT of Personal Service Executed by Bowcon Company Inc as to Ismail Mohammed on 2/21/2020, ...

Document Bowcon Company Inc v. Mohammed et al, 1:19-cv-07835, No. 7 (N.D.Ill. Mar. 2, 2020)
ISMAIL MOHAMMED, individually, AXIS CAR WASH, LLC, an Illinois limited liability company; AXIS AUTO SPA & PATEL TRADING, INC., an Illinois Corporation, Defendants.
| personally served a SUMMONSIN A CIVIL CASE and a COMPLAINTupon Ismail Mohammed, by handing a copy of the aforementioned documents to Ismail Mohammed at his residence, 2956 ShamrockCircle, Elgin, IL 60142 on 02/21/2020 at approximately 7:15 PM.
| began speakingwith neighbors in an attempt to learn Mohammed’s whereabouts.| then observed Mohammedstanding on his driveway.
Mohammed would not accept the aforementioned documents and | set them on the groundin front of Mohammedand announced he was served.
Mohammed appeared to be a Middle Eastern male, approximately forty-five (45) years of age, wearing blue jeans and a black jacket with short stubble and dark hair.
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No. 438 ORDER

Document Chicago Import, Inc. v. American States Insurance Company, 1:09-cv-02885, No. 438 (N.D.Ill. Dec. 13, 2016)
This matter having come on Plaintiff, Chicago Import, Inc.’s, Motion to Release Funds Held by Court and the Court being advised that Defendant, American States Insurance Company, does not object to the motion, IT IS HEREBY ORDERED:
Chicago Import Inc.’s Motion it GRANTED.
One check shall be made payable to “Bank of Hope” in the amount of 1,390,585.78.
Bank of Hope’s check will be picked up by Deborah Ashen of the firm, Ashen/Faulkner.
The Clerk of the Court shall issue a check for the balance of the proceeds, including interest the funds have accrued, minus the registry fee charged by the Clerk’s Office, payable to “Chicago Import, Inc.,” to be picked up by Mark Roth of the law firm of Roth Fioretti, LLC.
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No. 426 MEMORANDUM Opinion and Order

Document Chicago Import, Inc. v. Amercan States Insurance Company, 1:09-cv-02885, No. 426 (N.D.Ill. Aug. 16, 2016)
Determining understated workers’ compensation liabilities, which were always calculable by the defendant, id. at *2, is different than the extensive undertaking required to value Chicago Import’s loss, which involved opinion and not mere computation, and which was the subject of competing expert testimony at trial.
Barring Testimony on Chinese Currency and Oil Prices Steve Reed, American States’s forensic accountant expert, testified that he did not credit Chicago Import’s calculation of the cost of goods sold in 2006 and 2007.
To this day, however, American States has never identified where Reed disclosed—either in his expert report or deposition—an opinion, analysis, or schedule relating Chinese currency and oil prices to Chicago Import’s cost of goods sold.
American States argues that the motion in limine was improperly granted, contending that prior fires and insurance claims show motive and lack of accident, not propensity, and would not have prejudiced Chicago Import.
On a motion for judgment as a matter of law under Rule 50,7 “the question is not whether the jury believed the right people, but only whether it was presented with a legally sufficient amount of evidence from which it could reasonably derive its verdict.” Massey v. Blue Cross-Blue Shield of Ill., 226 F.3d 922, 924 (7th Cir. 2000).
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JOLIET STEEL & CONSTRUCTION -VS- JOHN, VRATSINAS COMMERCIAL et al

Docket 2009 L 00000064, Illinois State, Kankakee County (May 22, 2009)
WENZELMAN, KENDALL O, presiding
Case TypeL - LAW >$50,000 - LAW > $50,000
TagsL, Law
PLAINTIFF JOLIET STEEL & CONSTRUCTION
DEFENDANT JOHN, VRATSINAS COMMERCIAL
DEFENDANT CARLO STEEL CORPORATION
...
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Chicago Import, Inc. v. American States Insurance Company

Docket 1:09-cv-02885, Illinois Northern District Court (May 12, 2009)
Honorable Manish S. Shah, presiding
Insurance
DivisionChicago
FlagsMASON, PROTO, TERMED
Demand$1,000,000
Cause28:1332 Diversity-Other Contract
Case Type110 Insurance
Tags110 Insurance, 110 Insurance
Plaintiff Chicago Import, Inc.
Defendant American States Insurance Company
Movant Wolin & Rosen, Ltd.
...
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No. 341 MEMORANDUM Opinion and Order: For the foregoing reasons, each party's motion for summary judgment ...

Document Chicago Import, Inc. v. Amercan States Insurance Company, 1:09-cv-02885, No. 341 (N.D.Ill. May. 8, 2015)
Motion for Summary JudgmentPartial
Nonetheless, the question of whether the insureds actually committed arson, voiding their policy, went to the jury.
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No. 417 MOTION by Defendant American States Insurance Company for new trial and/or judgment notwithstanding ...

Document Chicago Import, Inc. v. American States Insurance Company, 1:09-cv-02885, No. 417 (N.D.Ill. Apr. 11, 2016)
Motion for New Trial
Fisher Kanaris, P.C., move this Honorable Court for a Judgment Notwithstanding the Verdict and/or a New Trial and in support thereof, states as follows:
Chicago Import violated the Court’s ruling that it should not introduce evidence that there have been no charges of arson brought against Mr. Punjabi or any other individual arising out of the fire at the Knox Warehouse; 6.
The Court erred by prohibiting evidence relative to the value of goods in the Knox Warehouse prior to the fire during the cross-examination of Rajesh Prajapati; 7.
Judgment notwithstanding the verdict should be entered based on the misrepresentations made by Chicago Import in its Sworn Statement in Proof of Loss; 9.
The totality of numerous errors made by the Court resulted in a jury trial that was heavily and improperly skewed in favor of Chicago Import and to the severe detriment of American States.
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No. 413 MOTION by Plaintiff Chicago Import, Inc. to amend/correct entered judgment 398 to include prejudgment ...

Document Chicago Import, Inc. v. American States Insurance Company, 1:09-cv-02885, No. 413 (N.D.Ill. Mar. 24, 2016)
Motion to Amend Judgment
Now comes the Plaintiff, Chicago Import, Inc. (“Chicago Import”), through its undersigned attorneys, Orum & Roth, LLC, and for its Motion to Amend Judgment to Include Prejudgment Interest pursuant to Rule 59(e), states:
As established at trial, Chicago Import’s public adjuster and American States’ appraiser conducted a physical inventory of the merchandise destroyed in the fire in January and February 2008.
The proof of loss is dated April 18, 2008, and requests $5 million for damages to Chicago Import’s merchandise located in the Knox warehouse at the time of the fire at issue.
Illinois law is clear that “an insurance policy is a written instrument covered by this statute.” Couch v. State Farm Ins. Co., 279 Ill. App. 3d 1050, 1054, 666 N.E.2d 24, 27 (1996) (citing Ervin v. Sears, Roebuck & Co., 127 Ill.App.3d 982, 991, 469 N.E.2d 243, 250 (1984)); Central Nat’l Chicago Corp. v. Lumbermens Mut.
The Illinois Supreme Court in Wernick explained the basis for an equitable award of prejudgment interest as follows: The goal of proceedings sounding in equity is to make the injured party whole.
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No. 384 MOTION by Plaintiff Chicago Import, Inc. to bar Defendant's Use of Undisclosed Demonstrative ...

Document Chicago Import, Inc. v. Amercan States Insurance Company, 1:09-cv-02885, No. 384 (N.D.Ill. Mar. 4, 2016)
If, due to unforeseen circumstances during trial a party wishes to introduce an exhibit not previously listed, notice should be given as soon as possible to the opposing side and to the Court so that any objections can be discussed.
American States’ exhibit list also seeks to introduce substantively into evidence every single deposition ever taken in the case, as well as an examination under oath taken before trial.
At the pretrial in this matter held on Monday, February 29, 2016, this Court heard argument on the parties’ objections as to each other party’s demonstrative exhibits.
The Standing Order expressly provides, in relevant part, as follows: If, due to unforeseen circumstances during trial a party wishes to introduce an exhibit not previously listed, notice should be given as soon as possible to the opposing side and to the Court so that any objections can be discussed.
In the alternative, Plaintiff requests that this Court bar American States from using demonstrative exhibits 1, 3, 20, 21 and 23 as irrelevant and unduly prejudicial.
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No. 418 MEMORANDUM by American States Insurance Company in support of motion for new trial 417 (Attachments: ...

Document Chicago Import, Inc. v. American States Insurance Company, 1:09-cv-02885, No. 418 (N.D.Ill. Apr. 11, 2016)
Motion for New Trial
Id. at 854 (“the need to check for similarity and recency may be substantially diminished or nonexistent depending on the particular purpose for which the evidence is offered”).
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