Carpenters Fringe Benefit Funds of Illinois et al v. APCSC, LLC

Filing 24

MOTION by Plaintiffs Carpenters Fringe Benefit Funds of Illinois, Michael T. Kucharski for entry of default, MOTION by Plaintiffs Carpenters Fringe Benefit Funds of Illinois, Michael T. Kucharski for judgment (Attachments: # 1 Exhibit Return of Service)(Dunitz-Geiringer, Jennifer)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CARPENTERS FRINGE BENEFIT FUNDS OF ILLINOIS, et al., Plaintiffs, vs. APCSC, LLC, an Illinois limited liability company, Defendant. ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 08 C 6454 JUDGE MILTON I. SHADUR

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, APCSC, LLC, an Illinois limited liability company, in the total amount of $32,148.36, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $9,256.25. On November 13, 2008, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to Courtney Hightower, Receptionist, at the registered office of record (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on December 3, 2008. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Jennifer L. Dunitz-Geiringer

CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion for Entry of Default and 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 participant on or before the hour of 5:00 p.m. this 9th day of July 2009: APCSC, LLC c/o National Registered Agents, Inc., n/k/a Premier Corporate Services, Inc. 200 W. Adams Street, Suite 2007 Chicago, IL 60606 Mr. Robert H. Brown Laner Muchin Dombrow Becker Levin & Tominberg, Ltd. 515 N. State Street, 28th Floor Chicago, IL 60654

/s/ Jennifer L. Dunitz-Geiringer

Jennifer L. Dunitz-Geiringer Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6237001 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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