United Central Bank v. Sindhu

Filing 13

MOTION by Plaintiff United Central Bank for judgment (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Roche, Michael)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED CENTRAL BANK, as assignee of Mutual Bank, Plaintiff, v. SAAD SINDHU Defendant. ) ) ) ) ) ) ) ) ) ) ) ) )

Case No.: 10 CV 2878

MOTION FOR ENTRY OF JUDGMENT NOW COMES Plaintiff United Central Bank, as assignee of Mutual Bank, an Illinois banking corporation, ("UCB"), by its attorneys, Schuyler, Roche & Crisham, P.C., and hereby requests that this Court enter Judgment against Defendant Saad Sindhu. In support of this Motion, UCB states as follows: 1. UCB filed its one count Complaint against Defendant Saad Sindhu ("Sindhu") on

May 5, 2010 for breach of a personal guaranty. A true and correct copy of the Complaint is attached as Exhibit A hereto. 2. This Court's Summons and a copy of the Complaint were served upon each

Sindhu on May 25, 2010. A true and correct copy of the Summons and Affidavit of Service are attached hereto as Exhibit B. 3. Sindhu was required to file an appearance, answer or other responsive pleading by

June 15, 2010. As of July 2, 2010, Sindhu had not filed anything. Consequently, on July 8, 2010, UCB filed a Motion for Default Judgment.

4.

The Court granted UCB's Motion and entered a default against Sindhu on July 14,

2010. The Court set a prove up hearing on the Motion for August 4, 2010 at 9:30 a.m. 5. In connection with the prove up hearing, UCB submits the following documents: (a) the Affidavit of Robert Hoholik. Mr. Hoholik was the primary individual at UCB in charge of monitoring the Sindhu guaranty. His Affidavit is attached as Exhibit C. (b) the Affidavit of Michael T. Roche. Mr. Roche served as the principal attorney representing UCB in this matter. Attorney Roche's Affidavit is attached as Exhibit D. (c) a proposed Judgment, which will be submitted electronically per the local rules. WHEREFORE, Plaintiff United Central Bank, respectfully requests that this Court enter Judgment in its favor and against Defendant Saad Sindhu, award United Central Bank all amounts requested in the attached documents, and award such other relief as this Court deems just and equitable.

UNITED CENTRAL BANK,

By: /s/ Michael T. Roche One of the Attorneys for Plaintiff

Daniel V. Kinsella (ARDC No. 1468472) Michael T. Roche (ARDC No. 6278337) Schuyler, Roche & Crisham One Prudential Plaza 130 East Randolph, Suite 3800 Chicago, Illinois 60601 [phone]
737375v1

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