IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

K.G. a Minor, by and through his Parents and Next 

Friends, CELESTE COLEMAN and ANTHONY 

GILBERT; and CELESTE COLEMAN, individually and 

ANTHONY GILBERT, individually, 

Plaintiff,

v.

THE UNITED STATES OF AMERICA, LAWNDALE 

CHRISTIAN HEALTH CENTER, an Illinois 

Corporation, LINDSAY McCRACKEN, PA-C, BLUE 

ISLAND HOSPITAL COMPANY d/b/a METROSOUTH 

MEDICAL CENTER, an Illinois Corporation, 

EMERGENCY PHYSICIANS OF BLUE ISLAND d/b/a 

MP OF BLUE ISLAND, LLC, an Ohio Limited Liability 

Company; MELISSA O’KEEFE, PA-C and MONICA A. 

BESZKA, M.D.

Defendants.

Case No. 20 cv 02872

Honorable Manish S. Shah

Magistrate Judge Beth W. Jantz

DEFENDANT, METROSOUTH MEDICAL CENTER’S MOTION

FOR ENTRY OF JUDGMENT PURSUANT TO RULE 68 OF

THE FEDERAL RULES OF CIVIL PROCEDURE

NOW COMES the Defendant, BLUE ISLAND HOSPITAL COMPANY, LLC, d/b/a 

METROSOUTH MEDICAL CENTER (“MetroSouth”), by its attorneys, HALL PRANGLE 

& SCHOONVELD, LLC, and pursuant to Rule 68 of the Federal Rules of Civil Procedure, 

respectfully requests that this Honorable Court enter an Order entering judgment against it, and in

favor of Plaintiffs, consistent with its May 13, 2022, Rule 68 Offer of Judgment to Plaintiffs, and 

further directing the clerk to enter the judgment consistent with the terms set forth in its May 13, 

2022 Offer of Judgment. In support thereof, Defendant states as follows:

Case: 1:20-cv-02872 Document #: 99 Filed: 06/28/22 Page 1 of 3 PageID #:459
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1. On May 13, 2022, MetroSouth tendered a Rule 68 Offer of Judgment to Plaintiffs, 

offering to allow judgment to be entered against it on specified terms. (See MetroSouth’s May 13, 

2022 Rule 68 Offer of Judgment attached hereto as Exhibit A). 

2. Consistent with Rule 5 of the Federal Rules of Civil Procedure, MetroSouth served 

a copy of its May 13, 2022 Offer of Judgment on all parties in this litigation via electronic mail 

and U.S. mail on May 13, 2022. (See Copy of MetroSouth’s May 13, 2022 electronic mail to all 

counsel of record enclosing MetroSouth’s May 13, 2022 Rule 68 Offer of Judgment attached 

hereto as Exhibit B). 

3. In accordance with Rule 68, MetroSouth’s Rule 68 Offer of Judgment was tendered 

more than fourteen (14) days prior to the commencement of trial. (Fed. R. Civ. P. 68.).

4. On May 18, 2022, in accordance with Rule 68, Plaintiffs served written notice on 

all parties, accepting MetroSouth’s May 13, 2022 Rule 68 Offer of Judgment. (See Plaintiffs May 

18, 2022 acceptance of MetroSouth’s May 13, 2022 Rule 68 Offer of Judgment attached hereto as 

Exhibit C). 

5. Plaintiffs’ May 18, 2022 written acceptance of MetroSouth’s May 13, 2022 Rule 

68 Offer of Judgment was served via electronic mail on all counsel of record. (See Copy of May 

18, 2022 electronic mail from Plaintiffs’ counsel enclosing Plaintiffs’ acceptance of MetroSouth’s 

Rule 68 Offer of Judgment attached hereto as Exhibit D). 

6. Consistent with Rule 68, MetroSouth now brings this motion for purposes of filing

its May 13, 2022 Offer of Judgment, Plaintiffs’ acceptance of the Offer of Judgment, and 

corresponding proofs of service consistent with Rule 68, and for purposes of having this Court 

enter judgment consistent with MetroSouth’s Offer of Judgment. (Fed. R. Civ. P. 68.; and Exhibit 

A-D.).

Case: 1:20-cv-02872 Document #: 99 Filed: 06/28/22 Page 2 of 3 PageID #:460
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WHEREFORE, Defendant, BLUE ISLAND HOSPITAL COMPANY, LLC, d/b/a 

METROSOUTH MEDICAL CENTER respectfully requests that this Honorable Court enter the 

proposed Order of Judgment, incorporating the terms specified in its May 13, 2022 Rule 68 Offer 

of Judgment, and further directing the clerk to enter the judgment as required by Rule 68 of the 

Federal Rules of Civil Procedure.

Respectfully submitted,

HALL PRANGLE & SCHOONVELD, LLC

One of the Attorneys for Defendant, BLUE ISLAND 

HOSPITAL COMPANY LLC d/b/a 

METROSOUTH MEDICAL CENTER 

Jennifer Ries-Buntain (jries-buntain@hpslaw.com)

Ana C. Cazacu (acazacu@hpslaw.com)

James A. Kearney (jkearney@hpslaw.com)

HALL PRANGLE & SCHOONVELD, LLC

200 South Wacker Drive, Suite 3300

Chicago, Illinois 60606

312-345-9600 | 312-345-9608 | Fax

HPSDocket@hpslaw.com

CERTIFICATE OF SERVICE

I hereby certify that I caused a copy of this document to be transmitted to each counsel of 

record via CM/ECF by filing this document through the CM/ECF system this 28th day of June, 

2022.

HALL PRANGLE & SCHOONVELD, LLC

One of the Attorneys for Defendant, BLUE ISLAND 

HOSPITAL COMPANY LLC d/b/a 

METROSOUTH MEDICAL CENTER 

Case: 1:20-cv-02872 Document #: 99 Filed: 06/28/22 Page 3 of 3 PageID #:461