Res judicata applied to accepted offer of judgment

Trial Notebook

By Steven P. Garmisa

Hoey & Farina

Posted July 31, 2020 8:17 AM

H.A.L. NY Holdings LLC relied on two 1st District Illinois Appellate Court opinions in asking the 7th U.S. Circuit Court of Appeals to reverse an order that dismissed its $25 million claim against Joseph Michael Guinan Jr. based on res judicata after H.A.L. used a $75,000 offer of judgment, under Federal Rule of Civil Procedure 68, to get rid of a lawsuit Guinan’s company, Advantage Futures LLC., filed in Chicago.Both lawsuits were diversity cases involving the handling of H.A.L.’s trading account.Although …

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