MOTION FOR ENTRY OF STIPULATED JUDGMENT

ROBERT M. DOW, JR., District Judge.

Plaintiffs Michael Meyer, Christopher Meyer and Meyer Capital Group, LLC (collectively, the "Plaintiffs"), by and through their attorneys, respectfully move this Court for entry of the Stipulated Judgment set forth in Exhibit A to this Motion. In support of this motion, the Plaintiffs state as follows:

1. As indicated in the Stipulated Judgment, a judgment denying the discharge of the debtors there (the two individual defendants in this case) — Everett Grady and Kathryn Grady — was entered on September 10, 2019 in Adversary Case No. 17-07043 within the Chapter 7 Bankruptcy case pending in the Central District of Illinois Bankruptcy Court, Case No. 17-70853.

2. In light of the judgment in the adversary proceeding denying Mr. and Mrs. Grady a discharge in bankruptcy, on September 25, 2019, the bankruptcy court closed the bankruptcy case.

3. As a result, the bankruptcy case has concluded and there no longer exists an automatic stay with respect to this matter.

4. The parties have resolved their claims with respect to this case, which resolution requires the entry of the Stipulated Judgment attached as Exhibit A.

5. As evidenced by their signatures on the Stipulated Judgment, the Plaintiffs and the Defendants, Everett Grady, Kathryn Grady, and Kaegem, Corp. have agreed and stipulated to the entry of the Stipulated Judgment.

WHEREFORE, the Plaintiffs respectfully requests that this Court: (i) grant this Motion, (ii) enter the Stipulated Judgment attached as Exhibit A to this Motion, and (iii) grant such other and further relief as this Court deems just and proper.

Exhibit A

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

STIPULATED JUDGMENT

Pursuant to the stipulation of the Plaintiffs Michael Meyer, Christopher Meyer, and Meyer Capital Group, LLC (the "Plaintiffs") and Defendants Everett Grady, Kathryn Grady and Kaegem Corporation (the "Defendants"), IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:

1. As a result of the Judgment entered on September 10, 2019 in Adversary Case No. 17-07043 within the Chapter 7 Bankruptcy case involving Defendants Everett Grady and Kathryn Grady, pending in the Central District of Illinois Bankruptcy Court, Case No. 17-70853, the bankruptcy case has concluded and there no longer exists an automatic stay with respect to this matter.

2. By stipulation and agreement of the parties, judgment is hereby entered in favor of the Plaintiffs and against the Defendants, jointly and severally, in the amount of $205,000.00.

3. If the Plaintiffs are required to take and take any action seeking to enforce or execute upon this Stipulated Judgment, then (a) the Plaintiffs shall be entitled to receive their reasonable attorney's fees and costs in taking such action and (b) any unpaid amount of the judgment shall accrue interest calculated at an eight percent (8%) annualized interest rate, and assessed from. January 1, 2017 until the date on which the judgment has been paid in full.

4. The Court shall retain jurisdiction over this matter to enforce the terms of this Stipulated Judgment and any settlement agreement entered into between the Plaintiffs and the Defendants.