IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JESSICA SCOTT, ) ) Plaintiff, ) ) Case No.: 1:20-cv-05298 v. ) ) Honorable Charles R. Norgle VILLGE OF DOLTON and OFFICER PHIL ) SHEEHAN, ) Magistrate Judge Heather McShain ) Defendants. ) DEFENDANT VILLAGE OF DOLTON’S MOTION FOR ENTRY OF JUDGMENT NOW COMES the Defendant, Village of Dolton (“Defendant Village”), by and through its attorneys, ShawnTe M. Raines and Jeffrey C. Grossich, of Ancel Glink, P.C., and pursuant to Federal Rule of Civil Procedure 54(b), hereby moves this Honorable Court for entry of final judgment in its favor. In support of said Motion, Defendant Village states as follows: 1. On May 31, 2022, this Honorable Court granted Defendant Village’s Motion to Dismiss and dismissed all of Plaintiff’s claims against Defendant Village. [Dkt. No. 17]. 2. Pursuant to Federal Rule of Civil Procedure 54(b), Defendant Village now moves this Honorable Court for entry of final judgment in its favor. 3. For the purposes of Rule 54(b), a “final judgment” is a decision upon a cognizable claim for relief that is an “an ultimate disposition of an individual claim entered in the course of a multiple claims action.” Curtiss-Wright Corp. v. General Elec. Co.,

(1980). The dismissal of the claims against Defendant Village is such a final judgment. 4. There is no just reason for delay of entry of final judgment in Defendant Village’s favor. 5. A finding of no just reason for delay “take[s] into account judicial administrative interests as well as the equities involved.” Curtiss-Wright Corp.,

. It is proper for this Honorable Court “to consider such factors as whether the claims under review [are] separable from the others remaining to be adjudicated and whether the nature of the claims already determined

[is] such that no appellate court would have to decide the same issues more than once even if there were subsequent appeals.”

. In this case, the equities involved call for this Honorable Court to grant Defendant Village finality and enter judgment in its favor. 7. Furthermore, Plaintiff’s remaining claims against Defendant Officer Phil Sheehan are distinct and separable from the dismissed claims against Defendant Village. The nature of the dismissed claims is such that the appellate court would not have to decide the same issues more than once if there were subsequent appeals. The issue of whether Defendant Officer Sheehan is liable to Plaintiff for the alleged constitutional violations is distinct from the issue of whether Defendant Village is liable pursuant to the factors set forth in Monell v. Dep’t of Soc. Servs. of City

of New York,

(1978). WHEREFORE, Defendant Village of Dolton respectfully requests that this Honorable Court grant the following relief: A. Grant the instant Motion; B. Make an express determination that there is no just reason for delay of entry of final judgment in Defendant Village of Dolton’s favor; C. Direct the Clerk of Court to enter final judgment in favor of Defendant Village of Dolton and against Plaintiff on all of Plaintiff’s claims; and D. Dismiss Defendant Village of Dolton as a party to this case. Respectfully Submitted, VILLAGE OF DOLTON By: s/Jeffrey C. Grossich____________ One of its Attorneys ShawnTe Raines / ARDC #6300634 Jeffrey C. Grossich / ARDC #6316511 Ancel Glink, P.C. Attorneys for Defendants 140 S. Dearborn, 6th Floor Chicago, IL 60603 P: 312-782-7606 [email protected] [email protected] CERTIFICATE OF SERVICE I hereby certify that on June 2, 2022, I electronically filed the foregoing Defendant Village of Dolton’s Motion for Entry of Judgment with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to:

Jessica Scott [email protected]

/s/ Jeffrey C. Grossich JEFFREY C. GROSSICH/ ARDC # 6316511 Attorney for Defendant Village of Dolton ANCEL GLINK, P.C. 140 South Dearborn Street, Sixth Floor Chicago, Illinois 60603 Telephone: (312) 782-7606 Facsimile: (312) 782-0943 E-Mail: [email protected]