Carpenters Fringe Benefit Funds of Illinois et al v. Peterson Woodwork Company

Filing 8

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)(Ryan, Patrick)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CARPENTERS FRINGE BENEFIT FUNDS OF ILLINOIS, et al., Plaintiffs, vs. PETERSON WOODWORK COMPANY, an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 09 C 5883 JUDGE ROBERT M. DOW, JR.

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, PETERSON WOODWORK COMPANY, an Illinois corporation, in the total amount of $30,373.96, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,205.00. On September 29, 2009, the Summons and Complaint was served on the Registered

Agent (by tendering a copy of said documents to Lana Miller) at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on October 19, 2009. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment. /s/ Patrick N. Ryan Patrick N. Ryan Attorney for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6278364 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that he 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 11th day of November 2009: Mr. Jay L. Miller, Registered Agent Peterson Woodwork Company 215 S. Northwest Highway, Suite 201A Barrington, IL 60010-8301 Mr. Myles Olsen, Jr. 337 Oak Grove Circle Wauconda, IL 60084

/s/ Patrick N. Ryan

Patrick N. Ryan Attorney for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6278364 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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