Eastern Savings Bank, FSB

Filing 15

MOTION by Plaintiff Eastern Savings Bank, FSB for judgment (Daday, Stephen)

THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU MAY BE USED FOR THAT PURPOSE. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Eastern Savings Bank, FSB. ) ) Plaintiff, ) ) v. ) ) Annie E. Boston, an individual; ) U.S. Employees Credit Union; Board of Managers ) of Hyde Park Boulevard Condominium; ) ) Defendants. )

No. 09 CV 3591

COMBINED MOTION FOR ORDER OF DEFAULT AND MOTION FOR JUDGMENT OF FORECLOSURE AND SALE NOW COMES the Plaintiff, Eastern Savings Bank, FSB, by and through its attorneys, Stitt, Klein, Daday, Aretos & Giampietro and moves this Court, pursuant to Rule 55 of the Federal Rules of Civil Procedure, for the entry of an Order of Default and Judgment of Foreclosure and Sale against Defendants Annie E. Boston, U.S. Employees Credit Union, and Board of Managers of Hyde Park Boulevard Condominium. In support thereof, Eastern Savings Bank states as follows: 1. That I, Stephen G. Daday, one of the attorneys for Plaintiff in this cause do hereby

certify that on October 13, 2009, I caused the Court file and docket entries to be reviewed with respect to this case, and that proof of service of summons indicates that the following parties have been served as follows:

1

PARTY: Annie E. Boston U.S. Employees Credit Union Bd. of Managers of Hyde Park Blvd. Condo. 2.

DATE OF SERVICE (METHOD) 08-04-09 (Personal) 07-09-09 (Corporate) 11-06-08; 11-13-08; 11-20-08 (Pub.)

That over twenty (20) days have expired since the date of service on all

defendants, and that no defendant has filed an appearance, answer or other responsive pleading. 3. That by virtue of the above defaults, the material factual allegations of the

Complaint herein have not been denied by defendants, and the complaint is therefore confessed against them. WHEREFORE, Plaintiff Eastern Savings Bank, FSB, prays for the entry of an Order of Default, pursuant to Rule 55 of the Federal Rules of Civil Procedure, against Annie E. Boston, U.S. Employees Credit Union, and Board of Managers of Hyde Park Boulevard Condominium, and further prays for a Judgment of Foreclosure and Sale. Respectfully submitted, __s/Stephen G. Daday_____________ Stephen G. Daday (Atty # 3127015) Attorney for Plaintiff Stitt, Klein, Daday, Aretos and Giampietro, LLC 2550 W. Golf Road, Suite 250 Rolling Meadows, IL 60008 847-590-8700

2