23-80007, 23-96006
Court granted summary judgment in favor of judgment creditor on cross-motions for summary judgment, finding based on undisputed facts that
the memorandum of judgment that creditor recorded pre-petition satisfied the requirements under Illinois law to create a judgment lien. The Debtor had argued that the memorandum was inaccurate by combining judgment amounts entered on one date for damages and interest and on another date for attorney’s fees and by describing the combined judgment as dated the latter date. The Debtor also argued in the alternative that a subsequent order vacating judgment against a co-defendant made the description of the judgment date in the memorandum inaccurate. The court found under the circumstances that the later vacatur against the co-defendant did not affect the judgment against the Debtor.