The Hotel Employees and Restaurant Employees International Union Welfare Fund et al v. Pleased to Meat You, Inc.

Filing 16

MOTION by Plaintiffs The Hotel Employees and Restaurant Employees International Union Welfare Fund, H. W. Ward for judgment entry (Attachments: # 1 Exhibit)(Finnegan, Laura)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION THE HOTEL EMPLOYEES AND RESTAURANT EMPLOYEES INTERNATIONAL UNION WELFARE FUND, et al., Plaintiffs, vs. PLEASED TO MEAT YOU, INC., Defendant. ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 08 C 5999 JUDGE JOAN B. GOTTSCHALL

MOTION FOR ENTRY OF JUDGMENT NOW COME Plaintiffs, by their attorneys, default having been entered against the Defendant on June 24, 2009, and move for entry of judgment against Defendant, PLEASED TO MEAT YOU, INC., in the total amount of $6,170.07, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $2,297.82. On May 27, 2009, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to the Florida Department of State Division of Corporations) (a copy of the Summons and Letter Dated June 2, 2009/Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on June 16, 2009. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Laura M. Finnegan

CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion for Entry of Judgment) 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 participants on or before the hour of 5:00 p.m. this 25th day of June 2009: Pleased to Meat You, Inc. c/o Florida Secretary of State PO Box 6327 Tallahassee, FL 32314 Mr. Michael Urbon, Registered Agent Pleased to Meat You, Inc. 609 N. Dudley Avenue Ventnor City, NJ 08406

/s/ Laura M. Finnegan

Laura M. Finnegan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6210637 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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