Hancock et al v. L.G.E. Transport, Inc.

Filing 18

MOTION by Plaintiffs William H. Collins, Dale Bolt, Terrence J. Hancock, Joseph Benson, Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731, Local 731, I.B. of T., Excavators and Pavers Pension Trust Fund, David M. Snel ten, John J. Lisner for entry of default, MOTION by Plaintiffs William H. Collins, Dale Bolt, Terrence J. Hancock, Joseph Benson, Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731, Local 731, I.B. of T., Excavators and Pavers Pension Trust Fund, David M. Snelten, John J. Lisner 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 TERRENCE J. HANCOCK, et al., Plaintiffs, vs. L.G.E. TRANSPORT, INC., an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 09 C 0993 CHIEF JUDGE JAMES F. HOLDERMAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, L.G.E. TRANSPORT, INC., an Illinois corporation, in the total amount of $30,451.20, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $3,225.00.

On February 20, 2009, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to him personally at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on March 12, 2009. 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 10th day of September 2009: Mr. George Vasen, Jr., Registered Agent L.G.E. Transport, Inc. 1304 Pennwood Court, Suite A2 Schaumburg, IL 60193

/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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