Navigate Power LLC, v. Nick Coffman and Enermark Consulting, LLC

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Navigate Power LLC, Plaintiff Garnishor, v. No. 1:24-CV-05914 NICK COFFMAN and ENERMARK CONSULTING, LLC, Defendants. PLAINTIFF’S MOTION FOR ENTRY OF CONDITIONAL JUDGMENT AGAINST NATIONAL GRID X, LLC Plaintiff and Judgment Creditor Navigate Power LLC (the “Plaintiff”), by and through its undersigned counsel, states as follows for its Motion for Entry of Conditional Judgment (this “Motion”) against Third-Party Citation Respondent National Grid X, LLC (“NGX”): 1. On January 13, 2025, the Court entered a money judgment in favor of Plaintiff and against Defendants and Judgment Debtors Nick Coffman and Enermark Consulting, LLC (the “Debtors”) in the original principal amount of $879,186.82 (the “Judgment”). A true and correct copy of the Judgment is attached hereto and incorporated herein as Exhibit A. 2. The entire Judgment balance remains outstanding and unpaid. 3. On October 17, 2025, Plaintiff caused this Court to issue a Third-Party Citation to Discover Assets to NGX concerning the assets of Debtor (the “Citation”). A true and correct copy of the Citation is attached hereto and incorporated herein as Exhibit B. The return hearing date of the Citation was November 3, 2025. 4. As reflected in the Affidavit of Special Process Server attached hereto and incorporated herein as Exhibit C, NGX was served with the Citation on October 21, 2025. 5. NGX did not answer the Citation or produce any of the requisite responsive document, nor did NGX appear in Court on the November 3, 2025 hearing date for the Citation. 6. To date, NGX has not answered the Citation or produced any of the requisite responsive documentation. NGX has also not made any calls or sent any emails to Plaintiff’s Counsel before asking for an extension, nor communicated with Plaintiff’s Counsel in any way. 7. Therefore, based on NGX’s failure, and pursuant to, inter alia, 735 ILCS §§ 5/2-1402(c) and (k-3), 735 ILCS § 5/12-706 and Illinois Supreme Court Rule 277(h), Plaintiff is entitled to a conditional judgment against NGX. See also Gov’t Exples. Ins. Co. v. Hersey, 397 Ill. App. 3d 551 , 552–55; In re Wasserman, No. 15 B 24318, 2015 WL 8861107 , at *1–3 (Bankr. N.D. Ill. Dec. 16, 2015); Xcel Supply LLC v. Horowitz, 2018 IL App (1st) 162986 , ¶¶ 2 and 41; Matter of Osorio, No. 13-25522, 2017 WL 1194450 , at *1 n.1 (Bankr. E.D. Wis. Mar. 30, 2017). WHEREFORE, for the reasons stated hereinabove, Plaintiff respectfully requests that this Court: (i) enter a conditional judgment against NGX, substantially in the form of the Proposed Conditional Judgment, which was separately submitted to the Court and served on NGX; and (ii) grant Plaintiff any other and/or further relief which this Honorable Court deems appropriate and just. Respectfully submitted, NAVIGATE POWER LLC By: s/ Daniel P. Jackson One of Its Attorneys Daniel P. Jackson, Bar No. 6289813 Jonathon P. Reinisch, Bar No. 6317528 Vedder Price P.C. 222 North LaSalle Street Chicago, Illinois 60601 T: +1 312 609 7500 Dated: November 4, 2025 CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the foregoing document will be served on: National Grid X, LLC c/o Anselm NG 1231 Alabama Rd. Murphy, TX 75094 via process server and by depositing the same for Fedex overnight delivery, at 222 North LaSalle Street, Chicago, Illinois 60601 on or before November 5, 2025. s/ Daniel P. Jackson