Fox Valley & Vicinity Construction Workers Pension Fund et al v. D.L. Anderson Company, Inc.,

Filing 8

MOTION by Plaintiffs Fox Valley & Vicinity Construction Workers Pension Fund, Fox Valley & Vicinity Construction Workers Welfare Fund, Lake County, Illinois, Plasterers & Cement Masons Retirement Savings Fund for entry of default, MOTION by Plaintiffs Fox Valley & Vicinity Construction Workers Pension Fund, Fox Valley & Vicinity Construction Workers Welfare Fund, Lake County, Illinois, Plasterers & Cement Masons Retirement Savings Fund for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

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

FOX VALLEY & VICINITY CONSTRUCTION
WORKERS PENSION FUND, et al.,
Plaintiffs,
vs.
D. L. ANDERSON COMPANY, INC.,
a dissolved Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 11 C 3500
JUDGE GARY FEINERMAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default
against Defendant, D. L. ANDERSON COMPANY, INC., a dissolved Illinois corporation, in the
total amount of $4,360.35, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount
of $903.00.
On June 3, 2011, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Mary Porcar) at his place of business (a copy of the Summons
and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on June 24,
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 14th
day of July 2011:
Mr. Daniel J. Quigley, Registered Agent
D. L. Anderson Company, Inc.
1234 N. Cedar Road
New Lenox, IL 60451

/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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