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)
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.
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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
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