Carpenters Fringe Benefit Funds of Illinois et al v. Three In One Construction, Inc.

Filing 8

MOTION by Plaintiffs Carpenters Fringe Benefit Funds of Illinois, Michael T Kucharski for entry of default, MOTION by Plaintiffs Carpenters Fringe Benefit Funds of Illinois, Michael T Kucharski for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

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

CARPENTERS FRINGE BENEFIT
FUNDS OF ILLINOIS, et al.,

)
)
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Plaintiffs,
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vs.
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)
THREE IN ONE CONSTRUCTION, INC., )
an Illinois corporation,
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Defendant.
)

CIVIL ACTION
NO. 11 C 1318
JUDGE RUBEN CASTILLO

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default
against Defendant, THREE IN ONE CONSTRUCTION, INC., an Illinois corporation, in the total
amount of $12,801.87, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of
$1,067.50.

On May 19, 2011, the Summons and Complaint was served on the Defendant (by

tendering a copy of said documents to the corporation’s President, Miguel A. Topete, Sr.,
personally) at his residence (a copy of the Summons and Affidavit of Service is attached hereto).
Therefore, Defendant’s answer was due on June 9, 2011. As Defendant has failed to timely answer
the Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Patrick N. Ryan

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that he electronically filed the
foregoing document (Motion for Entry of Default and Judgment) 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 29th
day of June 2011:
Mr. Miguel A. Topete, Sr., President
Three in One Construction, Inc.
2438 W. Cortland Street, Apt. 1
Chicago, IL 60647-4306

/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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