Carpenters Fringe Benefit Funds of Illinois et al v. KTEL Construction, Inc.

Filing 7

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)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CARPENTERS FRINGE BENEFIT FUNDS OF ILLINOIS, et al., Plaintiffs, vs. KTEL CONSTRUCTION, INC., an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO. 11 C 2623 JUDGE BLANCHE M. MANNING MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, KTEL CONSTRUCTION, INC., an Illinois corporation, in the total amount of $26,733.01, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $988.25. On April 22, 2011, 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 May 13, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default. /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 16th day of June 2011: Mr. Mark C. Johnson, Registered Agent Ktel Construction, Inc. 321 W. State Street, Suite 1200 Rockford, IL 61101 /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: (312) 236-4316 Facsimile: (312) 236-0241 E-Mail: pryan@baumsigman.com I:\Hrccj\Ktel Construction\motion-default judgment.pnr.df.wpd

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