1:19-cv-05227 | N.D. Ill. | Oct 1, 2019

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

TCF INVENTORY FINANCE, INC. ) ) Plaintiff, ) ) v. ) No. 1:19-CV-05227 ) HALL MOTOR SPORTS, INC. and ) ROLAND T. HALL )

) Defendants. ) MOTION FOR ENTRY OF ORDER AND CONSENT JUDGMENT Plaintiff TCF Inventory Finance, Inc. (“TCFIF”) moves this Court for entry of a consent judgment in this case. In support thereof, TCFIF states as follows: 1. TCFIF, Hall Motor Sports, Inc., and Roland T. Hall (collectively, the “Parties”) have reached a settlement agreement in this case. 2. Pursuant to the terms of the settlement agreement, TCFIF requests entry of the Order and Consent Judgment agreed to by the Parties and attached hereto as Exhibit A. WHEREFORE, Plaintiff, TCF Inventory Finance, Inc., respectfully requests that the Court enter an Order and Consent Judgment in this case in the form attached hereto as Exhibit A and grant such other and further relief as this Court deems proper.

TCF Inventory Finance, Inc. By: /s/ William R. Bay

One of its Attorneys William R. Bay (6181670) wbay@thompsoncoburn.com Thompson Coburn LLP One US Bank Plaza St. Louis, MO 63101 (314) 552-6000

FAX: (314) 552-7000

Holly H. Campbell (6320395) hcampbell@thompsoncoburn.com Thompson Coburn LLP 55 East Monroe Street 37 th Floor Chicago, IL 60603 (312) 346-7500 Fax: (312) 580-2201 Attorneys for TCF Inventory Finance, Inc.

CERTIFICATE OF SERVICE

The undersigned counsel certifies that a copy of the foregoing was filed with the Court using the CM/ECF system on the 1st day of October, 2019, and a copy of the same was served via U.S. mail upon: Hall Motor Sports, Inc. Roland T. Hall 3051 Walnut Street 1656 Cook Road Portsmouth, OH 45662 Lucasville, Ohio 45648

/s/ William R. Bay - 2 -