Fox Valley Construction Workers Fringe Benefit Funds et al v. Lasswell Masonry, Inc.

Filing 17

MOTION by Plaintiffs Fox Valley Construction Workers Fringe Benefit Funds, Michael T Kucharski for entry of default, MOTION by Plaintiffs Fox Valley Construction Workers Fringe Benefit Funds, Michael T Kucharski for judgment (Attachments: # 1 Exhibit Return of Service)(Scanlon, Cecilia)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FOX VALLEY CONSTRUCTION WORKERS FRINGE BENEFIT FUNDS, et al., Plaintiffs, vs. LASSWELL MASONRY, INC., an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 08 C 4226 JUDGE REBECCA R. PALLMEYER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, LASSWELL MASONRY, INC., an Illinois corporation, in the total amount of $5,546.65, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $3,043.75. On August 17, 2008, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to Mrs. Lasswell) at his residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on September 8, 2008. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Cecilia M. Scanlon

CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion) with the Clerk of Court using the CM/ECF system, and further certifies that I have mailed the above-referenced document by United States Mail to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 10th day of February 2009: Mr. Kevin Lasswell, Registered Agent/President Lasswell Masonry, Inc. 430 Prairie View Lane Hinckley, IL 60520

/s/ Cecilia M. Scanlon

Cecilia M. Scanlon Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6288574 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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