UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CHAPMAN ASSOCIATES GENERAL

BUSINESS, INC.,

Plaintiff,

v.

INTEGRATED FREIGHT 

CORPORATION,

Defendant.

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 12-2302 

PLAINTIFF’S MOTION FOR TURNOVER ORDER AGAINST THIRD PARTY

Judgment creditor Chapman Associates General Business, Inc. hereby

requests that this Court enter an Order directing Bank of America to turn over the 

funds held in the bank account held in the name of judgment debtor Integrated 

Freight Corporation (“IFCR”) and that have been frozen pursuant to a Third Party 

Citation to Discover Assets directed to Bank of America. In support of its motion,

Chapman states as follows:

1. On June 12, 2012, Chapman obtained a judgment against Integrated 

Freight Corporation in the amount of $835,907.91. 

2. Thereafter, Chapman initiated supplementary proceedings by issuing 

citations to discover assets, including a citation to Bank of America, attached as 

Exhibit A.
3. On June 23, 2015, this Court entered judgment against Bank of America 

for the $10,828.48 it disclosed that it was holding in a bank account belonging to 

IFCR. Bank of America satisfied that judgment.

4. On July 14, 2015, Bank of America informed counsel for Chapman that 

it froze an additional $17,959.12 in the same account held by Integrated Freight. That 

money was deposited after Bank of America responded to the citation. Since the 

citation had not been dismissed, Bank of America correctly froze the account.

5. Undersigned counsel spoke directly to the CEO of Integrated Freight, 

David Fuselier. Mr. Fuselier consented to the entry of a turnover order for $17,959.12.

6. Pursuant to 735 ILCS 5/2-1402(c), Chapman is entitled to entry of an 

order entering judgment in favor of Chapman Associates General Business, Inc. and 

Against Bank of America for $17,959.12, and directing Bank of America to turn over 

$17,959.12 in partial satisfaction of the judgment against IFCR.

WHEREFORE, Chapman Associates General Business, Inc., respectfully 

requests that this Court enter a judgment against Bank of America and for the 

benefit of Chapman Associates General Business, Inc. in the amount of $17,959.12 

and directing Bank of America to turn over that amount to counsel for Chapman.

Dated: July 16, 2015 Chapman Associates General Business, Inc.

By:/s/ Wesley E. Johnson

One of its attorneys
Wesley E. Johnson (6225257)

Goodman Tovrov Hardy & Johnson LLC 

105 West Madison Street, Suite 1500

Chicago, IL 60602

(312) 752-4828 

Fax: (312) 264-2535

wjohnson@goodtov.com
CERTIFICATE OF SERVICE

The undersigned, an attorney, certifies that on July 16, 2015, I will serve a 

copy of the attached Plaintiff’s Motion for Turnover, on all parties in the 

manner indicated below.

TO: Via Personal Delivery, email and Fax

Bank of America

105 W. Madison, Ste. 101

Chicago, IL 60602

Fax No. 617-310-2751

Tyra.smalls@bankofamerica.com

Reference No.: U060415000519

Via US Mail and email

Integrated Freight Corporation

c/o Henry P. Hoffman

8374 Market Street, #478

Bradenton, FL 34202

Email: c/o David Fuselier, David.Fuselier@fuselierco.com

By:/s/ Wesley E. Johnson