Fox Valley Construction Workers Fringe Benefit Funds et al v. Dantzler

Filing 15

MOTION by Plaintiffs Fox Valley Construction Workers Fringe Benefit Funds, Michael T Kucharski for entry of default, MOTION by Plaintiffs Fox Valley Construction Workers Fringe Benefit Funds, Michael T Kucharski for judgment (Attachments: # 1 Exhibit Return of Service)(Scanlon, Cecilia)

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

FOX VALLEY CONSTRUCTION
WORKERS FRINGE BENEFIT FUNDS,
et al.,
Plaintiffs,
vs.
LONNIE DANTZLER, d/b/a D AND B
CONSTRUCTION,
Defendant.

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CIVIL ACTION
NO. 10 C 7300
JUDGE MATTHEW F. KENNELLY

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default
against Defendant, LONNIE DANTZLER, d/b/a D AND B CONSTRUCDTION, in the total amount
of $12,681.30, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $4,461.00.
On April 9, 2011, the Summons and Complaint was served on the Defendant (by posting and
mailing a copy of said documents to him pursuant to the Court’s Order entered on March 21, 2011)
(a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer
was due on May 2, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs
respectfully request entry of default and judgment.

/s/ Cecilia M. Scanlon

CERTIFICATE OF SERVICE
The undersigned, at attorney of record, hereby certifies that she electronically filed the
foregoing document (Motion) with the Clerk of the Court using the CM/ECF system. In addition,
the undersigned hereby certifies that she mailed the above referenced document by United States
Mail to the following non-CM/ECF participants on or before the hour of 5:00 p.m. this 19th day of
May 2011:
Mr. Lonnie Dantzler
D and B Construction
400 W. 76th Street, Suite 330
Chicago, IL 60620

/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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