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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINIOIS

EASTERN DIVISION

BOB WINCEK, a Wisconsin citizen, )

and IRINA IVANOVA-WINCEK, a ) Case Number: 1:20-cv-03296

Wisconsin citizen, )

)

Plaintiffs, )

)

v. ) Judge: Honorable Franklin U. Valderrama

)

ARTHUR V. VEAL, IV, an Illinois )

citizen, CHICAGO TITLE AND TRUST ) Magistrate Judge: Susan E. Cox

COMPANY, not individually but as )

Trustee of the Land Trust dated 11/1/06 )

and known by Trust No. 8002348216, an )

Illinois land trust, WE BUY HOUSES )

HOME SERVICES, LLC, an Illinois )

Limited Liability Corporation, and TRUE )

NUMBERS LLC, an Illinois Limited )

Liability Corporation, )

)

Defendants. )

PLAINTIFFS’ MOTION FOR ENTRY OF JUDGMENT

NOW COME Plaintiffs, BOB WINCEK and IRINA IVANOVA-WINCEK (collectively, 

“Plaintiffs” or the “Winceks”), by their attorneys, Weissberg and Associates, Ltd., and as 

Plaintiffs’ Motion for Entry of Judgment, state as follows:

1. On November 21, 2023, at 10:00 a.m., Plaintiffs filed their Motion to Reinstate 

Case and Enforce Settlement Agreement (“Motion to Enforce”). See, Motion to Enforce attached 

hereto as Exhibit 1.

2. On January 23, 2023, this Court granted the Motion to Enforce and set a briefing 

schedule for Plaintiffs to submit a fee petition by February 7, 2023, and for Defendants to object 

to the prove-up affidavit by February 14, 2023. See, Order attached hereto as Exhibit 2.

3. Plaintiffs filed their Fee Petition on February 7, 2023. See, Fee Petition attached 

Case: 1:20-cv-03296 Document #: 95 Filed: 07/28/23 Page 1 of 3 PageID #:755
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hereto as Exhibit 3.

4. Defendants never objected to the Fee Petition.

5. Final judgment was never entered by the Court pursuant to the unopposed Fee 

Petition, and significant time has elapsed since the submission of the Fee Petition, and Plaintiffs 

have reason to believe Defendants are dissipating assets much to Plaintiffs prejudice.

6. Accordingly, Plaintiffs request a final judgment in the amount of $426,445.17, 

comprising of the $380,362.42 this Court granted when it enforced the Settlement Agreement, plus 

the $46,082.75 from the unopposed Fee Petition. 

WHEREFORE, Plaintiffs, BOB WINCEK and IRINA IVANOVA-WINCEK, pray that 

this Court enter final judgment in Plaintiffs’ favor and against Arthur V. Veal, IV individually 

and Chicago Title Land Trust Company, as Trustee of the Land Trust dated 11/1//06 and 

known as Trust No. 8002348216, We Buy Houses Homes Services, LLC , and True Numbers,

LLC, jointly and severally, in the amount of $426,445.17; and for such other and further relief as 

this Court deems just and proper in Plaintiffs’ favor.

BOB WINCEK and IRINA 

IVANOVA-WINCEK, Plaintiffs

By: /s/ Rakesh Khanna 

 One of their attorneys

 

Ariel Weissberg, Esq.

Rakesh Khanna, Esq.

Weissberg and Associates, Ltd.

125 S. Wacker Drive, Suite 300

Chicago, Illinois 60606

T: 312-663-0004

Email: rakesh@weissberglaw.com

Attorney ID No: 6243244

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CERTIFICATE OF SERVICE

I, Rakesh Khanna, certify that on July 28, 2023, I caused to be filed Plaintiffs’ Motion 

for Entry of Judgment. Notice of this filing was sent to all parties registered to receive notice 

in this case by electronic transmission through the court’s CM/ECF system, including to the 

following parties: 

Anthony D. Andrews, Esq. 

Law Firm of Anthony D. Andrews, PC 

18027 Harwood Ave.-Upper Level

Homewood, Illinois 60430 

Email: Tdrews34@yahoo.com 

(on behalf of Arthur V. Veal, IV, Chicago Title and Trust Company-Trust No. 8002348216, We 

Buy Houses Home Services, LLC and True Numbers, LLC) 

Rakesh Khanna 

Rakesh Khanna

Case: 1:20-cv-03296 Document #: 95 Filed: 07/28/23 Page 3 of 3 PageID #:757