JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT IN FAVOR OF PLAINTIFF AND SOLELY AGAINST DEFENDANT INTERFACE PROTEIN TECHNOLOGY INC.

JOHN ROBERT BLAKEY, District Judge.

Plaintiff Citibank, N.A. and Defendant Interface Protein Technology Inc. jointly move for the entry of a Consent Judgment, and in support thereof state as follows:

On January 11, 2017, Plaintiff filed its Complaint (the "Complaint") including a Count for breach of Note and Loan Agreement against Defendant Interface Protein Technology Inc., and a Count for breach of Guarantee against each of Defendant Charles Xiao Qing Han and Mindy Mingxia Liu relating to the Loan more particularly described in the Complaint.

2. Defendants filed their Answer and Defenses to the Complaint on March 7. 2017 reflecting little at issue between the parties respecting the Loan described in the Complaint.

3. On July 5, 2017, during a status hearing before the Court, counsel for Defendants informed Plaintiff and the Court that Defendants wish to resolve this proceeding and their respective obligations on the Loan and Loan Documents described in the Complaint by entry of a Consent Judgment.

4. On July 16, 2017 (the "Petition Date"), Defendants Charles Xiaoqing Han ("Han") and Mindy Mingxia Liu ("Liu") filed a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code (the "Bankruptcy Code"), in the United States Bankruptcy Court for the Northern District of Illinois (Chicago) (the "Bankruptcy Court"), commencing a case designated as In re Charles Xiaoqing Han and Mindy Mingxia Liu, Case No. 17-21154 (the "Bankruptcy Case")

5. In accordance with the provisions of 11 U.S.C. § 362(a), any and all further proceedings in this action are stayed with respect to Mr. Han and Ms. Liu.

6. The parties have agreed to the entry of a Consent Judgment with respect to the Loan, the Note and the Loan Agreement described in the Complaint in favor of Plaintiff and solely against Defendant Interface Protein Technology Inc. in the form attached hereto as Exhibit A. A separate copy of this Consent Judgment is being submitted to the Court concurrently with the filing of this Motion at Proposed_Order_Blakey@ilnd.uscourts.gov in compliance with the Court's standing order.

For these reasons, Plaintiff Citibank, N.A. and Defendant Interface Protein Technology respectfully request that this Court enter the proposed Consent Judgment attached hereto as Exhibit A.

1. At a status conference held in this Case on July 5, 2017, counsel to Defendants proposed entry of a consent judgment against Defendants as the means of resolving this Case.

2. On July 16, 2017 (the "Petition Date"), Defendants Charles Xiaoqing Han ("Han") and Mindy Mingxia Liu ("Liu") filed a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code (the "Bankruptcy Code"), in the United States Bankruptcy Court for the Northern District of Illinois (Chicago) (the "Bankruptcy Court"), commencing a case designated as In re Charles Xiaoqing Han and Mindy Mingxia Liu, Case No. 17-21 154 (the "Bankruptcy Case").

3. In accordance with the provisions of 11 U.S.C. § 362(a), any and all further proceedings in this action are stayed with respect to Mr. Han and Ms. Liu.

4. In consideration of the foregoing, the parties are agreeing to entry of this Order and Judgment in this Case in favor of Plaintiff and solely against Defendant INTERFACE PROTEIN TECHNOLOGY INC., an Illinois corporation, on the terms set forth below.

ACCORDINGLY, IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT judgment is entered against Defendant INTERFACE PROTEIN TECHNOLOGY INC., as follows:

1. Judgment is entered on Count I of the Complaint in favor of Citibank, N.A. and against INTERFACE PROTEIN TECHNOLOGY INC. for $1,587,334.88 (consisting of unpaid principal due pursuant to the Loan Documents executed and delivered by Interface Protein Technology Inc. for the benefit of Plaintiff as described in the Complaint ($1,499,260.76), plus interest accrued thereon through August 9, 2017 ($58,074.12), plus reasonable attorneys' fees and costs ($30,000.00) through June 30, 2017). From and after August 9, 2017, interest shall accrue on the sum of $1,587,334.88 at the applicable federal statutory rate.

2. Defendant INTERFACE PROTEIN TECHNOLOGY INC. understands its rights to appeal this order and judgment pursuant to applicable law. To induce Plaintiff to agree to this Consent Judgment, Defendant INTERFACE PROTEIN TECHNOLOGY INC. understands that such Defendant is waiving its rights to appeal. This is a final order and judgment as regards INTERFACE PROTEIN TECHNOLOGY INC. respecting the Note, the Loan Agreement and the Loan described in the Complaint and there is no just reason for delaying the enforcement of this Consent Judgment as against INTERFACE PROTEIN TECHNOLOGY INC.

3. This Judgment is solely against Interface Protein Technology Inc., and nothing in this Judgment and Order is intended to nor shall constitute an effort to collect or enforce indebtedness against Defendants Han and Liu who are debtors in the Bankruptcy Case.