Midwest Operating Engineers Pension Trust Fund et al v. Wright

Filing 6

MOTION by Plaintiffs Steven M Cisco, Angelo A DiPaolo, Marshall Douglas, David Fagan, John E Kenny, Jr., Mike Larson, Local 150, I.U.O.E. Vacation Savings Plan, James McNally, Midwest Operating Engineers Pension Trust Fund, Midwest Operating Engineer s Retirement Enhancement Fund, Midwest Operating Engineers Welfare Fund, Operating Engineers Local 150 Apprenticeship Fund, Mike Piraino, Daniel R Plote, David Rock, David Snelten, James M Sweeney, Martin Turek, Glen Weeks for entry of default, MOTIO N by Plaintiffs Steven M Cisco, Angelo A DiPaolo, Marshall Douglas, David Fagan, John E Kenny, Jr., Mike Larson, Local 150, I.U.O.E. Vacation Savings Plan, James McNally, Midwest Operating Engineers Pension Trust Fund, Midwest Operating Engineers Ret irement Enhancement Fund, Midwest Operating Engineers Welfare Fund, Operating Engineers Local 150 Apprenticeship Fund, Mike Piraino, Daniel R Plote, David Rock, David Snelten, James M Sweeney, Martin Turek, Glen Weeks for judgment (Attachments: # 1 Exhibit Return of Service)(Dunitz-Geiringer, Jennifer)

Midwest Operating Engineers Pension Trust Fund et al v. Wright

Doc. 6

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAMES M. SWEENEY, et al., ) ) Plaintiffs, ) ) vs. ) ) GLEN WRIGHT, d/b/a GLEN WRIGHT` ) EXCAVATING, a/k/a GLEN WRIGHT ) CONSTRUCTION, a/k/a GLEN WRIGHT ) EARTHMOVING, ) ) Defendant. )

CIVIL ACTION NO. 10 C 3321 JUDGE HARRY D. LEINENWEBER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, GLEN WRIGHT, d/b/a GLEN WRIGHT EXCAVATING, a/k/a GLEN WRIGHT CONSTRUCTION, a/k/a GLEN WRIGHT EARTHMOVING, in the total amount of $179,806.76, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $833.25. On June 9, 2010, the Summons and Complaint was served on the Defendant by substitute service (by tendering a copy of said documents to Myrna Wright, Mother) at his residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on June 30, 2010. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Jennifer L. Dunitz-Geiringer

Dockets.Justia.com

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 3rd day of August 2010: Mr. Glen Wright 27625 S. Gougar Road Manhattan, IL 60442

/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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