JOINT MOTION TO ENTER CONSENT JUDGMENT

ROBERT M. DOW, Jr., District Judge.

Plaintiff Arena Football League Union ("AFFLU") and Defendant Arena Football One, LLC ("AFL"), by and through their attorneys, hereby jointly move for entry of a Consent Judgment. In support, the parties state as follows:

1. The Union seeks confirmation of the Arbitration Award pursuant to Section 301 of the Labor Management Relations Act, Sections 6 and 9 of the Federal Arbitration Act, 9 U.S.C. §§ 6 and 9, and Fed. R. Civ. P. 13(a).

2. The Complaint was filed on August 5, 2016. (Dkt.#1)

3. Defendant was served on August 16, 2016.

4. Defendant has filed a motion to appear pro hac vice for purposes of submitting this motion; Defendant has not yet answered or otherwise pled but agrees to the entry of the Consent Judgement.

5. A draft Consent Judgment is attached as Exhibit A. The parties agree that the arbitration award should be confirmed.

WHEREFORE, the parties jointly request that the Court enter the draft Consent Judgement in this matter.

EXHIBIT A

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

CONSENT JUDGMENT

Upon consent of Plaintiff Arena Football League Players Union ("AFLPU") and Defendant Area Football One, LLC, ("AFL") IT IS ORDERED AND ADJUDGED that:

1. Pursuant Section 301 of the Labor Management Relations Act, Sections 6 and 9 of the Federal Arbitration Act, 9 U.S.C. §§ 6 and 9, and Fed. R. Civ. P. 13(a), the award issued on January 26, 2015, by Arbitrator Peter Meyer in the matter between AFLPU and AFL in Case No. 11, which was attached to AFLPU's Complaint to Confirm Arbitration Award as Exhibit 1 [Docket No. 1] is hereby confirmed in its entirety. The AFL and its teams must comply with the terms of the Award.