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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 for the Purpose of Enforcing Settlement Agreement (DE 89) (“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 (DE 93). See, Order attached hereto as Exhibit 2.

3. In their Motion to Reinstate, Plaintiffs sought $18,956.25 in attorney’s fees which 

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was granted by this Court.

3. Plaintiffs filed their Petition for Attorney’s Fees on February 6, 2023 (DE 94) (“Fee 

Petition”). See, Fee Petition attached hereto as Exhibit 3. Inadvertently, Plaintiffs included in its 

Fee Petition, the same $18,956.25 that this Court previously granted when it granted the Motion 

to Reinstate.

4. Accordingly, Plaintiffs are submitting their Amended Verified Petition for 

Attorneys’ Fees (“Amended Fee Petition”) contemporaneous with this submission, which no 

longer takes into consideration the original $18,956.25 that was previously granted by the Court.

5. Pursuant to paragraph 4 of the Settlement Agreement, Defendant agreed to 

reimburse Plaintiffs for attorney’s fees relating to prosecuting this lawsuit, as well as a foreclosure 

lawsuit involving a property located at 126 Westwood Drive, Park Forest, Illinois (the “Westwood 

Property”). See, Settlement Agreement attached as Exhibit 4. As part of Plaintiffs’ efforts to 

prosecute the Westwood Property foreclosure case (“Westwood Foreclosure Case”), it was 

necessary for Plaintiffs to resolve a Complaint for Abandonment (“Abandonment Complaint”) 

filed by the Village of Park Forest to have the Westwood Property deemed abandoned in the case 

captioned as, Village of Park Forest v. Bob Wincek, et al. that was pending in the Circuit Court of 

Cook County, Illinois, Sixth Municipal District as Case No. 2022-M6-009694. See, Abandonment 

Complaint attached hereto as Exhibit 5. Had the Village of Park Forest been successful in 

obtaining the relief it sought, this would have adversely impacted and made Plaintiffs’ Westwood 

Foreclosure Case moot since the Village of River Forest would obtain title to the Westwood 

Property. Accordingly, it was necessary for Plaintiffs’ counsel to resolve the issues relating to the 

Abandonment Complaint in order to successfully prosecute the Westwood Foreclosure Case, 

which Plaintiffs’ counsel was able to do. Accordingly, Plaintiffs seek its attorney’s fees incurred 

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defending and resolving the Abandonment Complaint. The amount of attorney’s fees and costs

relating to the defense and resolution of the Abandonment Complaint is $937.50.

6. The amount of attorney’s fees and costs incurred by Plaintiffs in prosecuting the 

instant case -- which was not included in the $18,956.25 fees previously awarded by this Court 

(“Initial Fee Award”) -- is $7,206.25, plus an additional $801.00 in court costs that were never 

included in the Initial Fee Award.

7. Plaintiffs’ attorney’s fees and court costs in prosecuting the Westwood Foreclosure 

case were $18,400.00 in fees plus expenses of $438.00 -- for a total of $18,838.00.

8. 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.

9. Accordingly, Plaintiffs request a final judgment in the amount of $408,145.17, 

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

the attorney’s fees and costs incurred by Plaintiffs in prosecuting this case since this Court granted 

the Motion to Reinstate, prosecuting the Westwood Foreclosure case, and defending the 

Abandonment Complaint, which total $27,782.75.

10. However, to the extent this Court does not grant Plaintiffs’ attorney’s fees relating 

to the Abandonment Complaint, Plaintiffs seek a judgment in the amount of $407,207.67, which 

includes only attorney’s fees for prosecuting this lawsuit and the Westwood Foreclosure Case.

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, 

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LLC, jointly and severally, in the amount of $408,145.17; 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 South 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 October 4, 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

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