Local 705 International Brotherhood of Teamsters Pension Fund et al v. A.D. Conner, Inc.

Filing 28

MOTION by Plaintiffs Joseph Bakes, Stephen FG Bridge, Juan Campos, Gregory R Foster, William Keenan, Local 705 International Brotherhood of Teamsters Health and Welfare Fund, Local 705 International Brotherhood of Teamsters Pension Fund, John Naughto n, Stephen E Pocztowski, Phillip D. Stanoch for entry of default, MOTION by Plaintiffs Joseph Bakes, Stephen FG Bridge, Juan Campos, Gregory R Foster, William Keenan, Local 705 International Brotherhood of Teamsters Health and Welfare Fund, Local 705 International Brotherhood of Teamsters Pension Fund, John Naughton, Stephen E Pocztowski, Phillip D. Stanoch for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

LOCAL 705 INTERNATIONAL
BROTHERHOOD OF TEAMSTERS
PENSION FUND, et al.,
Plaintiffs,
vs.
A.D. CONNER, INC., an Illinois
corporation,
Defendant.

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CIVIL ACTION
NO. 10 C 6352
JUDGE RONALD A. GUZMAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default
against Defendant, A.D. CONNER, INC., an Illinois corporation, in the total amount of
$1,329.818.01, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of
$28,517.44.
On October 13, 2010, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to his employee, Catheline Rankovich) at his place of business
(a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer
was due on November 3, 2010.
On January 3, 2011, Defendant filed a motion to consolidate Case No. 10 C 6916 with the
instant case. On January 5, 2011, the Court granted Defendant’s motion to vacate all technical
defaults and granted Defendant to and including February 4, 2011 to answer Plaintiffs’ Complaint.
On May 4, 2011, the Court denied Defendant’s motion to consolidate cases and gave Defendant to

until May 18, 2011 to answer Plaintiffs’ complaint. 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 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 on or before the hour of 5:00
p.m., this 8th day of June 2011, he caused to be electronically filed the foregoing document (Motion
for Entry of Default and Judgment) with the Clerk of Court using the CM/ECF system, which will
send notification of such filing to the following:
L. Steven Platt
Pedersen & Houpt
161 N. Clark Street, Suite 3100
Chicago, IL 60601
[e-mail]

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for 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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