Local 705 International Brotherhood of Teamsters Health and Welfare Fund et al v. Grajewski

Filing 9

MOTION by Plaintiffs Juan Campos, Gregory R. Foster, John Naughton, William Keenan, Local 705 International Brotherhood of Teamsters Health and Welfare Fund, Stephen E. Pocztowski, Phillip D. Stanoch, Joseph Bakes, Stephen F.G. Bridge for entry of de fault, MOTION by Plaintiffs Juan Campos, Gregory R. Foster, John Naughton, William Keenan, Local 705 International Brotherhood of Teamsters Health and Welfare Fund, Stephen E. Pocztowski, Phillip D. Stanoch, Joseph Bakes, Stephen F.G. Bridge for judgment (Chapman, Catherine)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION LOCAL 705 INTERNATIONAL BROTHERHOOD ) OF TEAMSTERS HEALTH AND WELFARE ) FUND, et al., ) ) Plaintiffs, ) ) v. ) ) ) RONALD M. GRAJEWSKI, ) Defendant. ) )

CIVIL ACTION NO. 09 C 2755 JUDGE MILTON I. SHADUR

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, LOCAL 705 INTERNATIONAL BROTHERHOOD OF TEAMSTERS HEALTH AND WELFARE FUND, et al., by their attorneys, and move for entry of judgment by default against Defendant, RONALD M. GRAJEWSKI, in the total amount of $15,423.87, plus Plaintiffs' costs of action. On May 18, 2009, the Summons and Complaint was served on the Defendant by tendering a copy of said documents to him personally, at his residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on June 8, 2009. Since Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment pursuant to F.R.Civ.P. Rule 55.

/s/ Catherine M. Chapman

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 15th day of June 2009: Mr. Ronald M. Grajewski 5024 W. 122nd Street, #2A Alsip, IL 60803

/s/ Catherine M. Chapman

Catherine M. Chapman Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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