Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731 et al v. Rock Solid Paving & Excavating, Inc.

Filing 6

MOTION by Plaintiffs Joseph Benson, Dale Bolt, William H Collins, Terrence J Hancock, Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731, John J Lisner, Local 731, I.B. of T., Excavators and Pavers Pension Trust Fund, David M Snelten for entry of default, MOTION by Plaintiffs Joseph Benson, Dale Bolt, William H Collins, Terrence J Hancock, Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731, John J Lisner, Local 731, I.B. of T., Excavators and Pavers Pension Trust Fund, David M Snelten for judgment (Attachments: # 1 Exhibit)(Scanlon, Cecilia)

Health and Welfare Fund of the Excavating, Grading and Asphalt Craft...lid Paving & Excavating, Inc.

Doc. 6

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TERRENCE J. HANCOCK, et al., Plaintiffs, vs. ROCK SOLID PAVING & EXCAVATING, INC., an Indiana corporation, Defendant. ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 10 C 4830 JUDGE WILLIAM J. HIBBLER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, ROCK SOLID PAVING & EXCAVATING, INC., an Indiana corporation, in the total amount of $22,793.33, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $2,085.00. On August 10, 2010, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to him personally at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on August 31, 2010. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Cecilia M. Scanlon

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 1st day of December 2010: Mr. Hugh Graham, Registered Agent Rock Solid Paving & Excavating, Inc. 11003 Thiel Street St. John, IN 46373-8792

/s/ Cecilia M. Scanlon

Cecilia M. Scanlon Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6288574 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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