Sheet Metal Workers Local 265 Welfare Fund et al v. Belle Engineering, Inc.

Filing 6

MOTION by Plaintiffs Sheet Metal Workers Local 265 Educational Fund, Sheet Metal Workers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 Supplemental Retir ement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265, Scott P Wille for entry of default, MOTION by Plaintiffs Sheet Metal Workers Local 265 Educational Fund, Sheet Metal Wor kers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 Supplemental Retirement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265, Scott P Wille for judgment (Attachments: # 1 Exhibit)(Chapman, Catherine)

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

SHEET METAL WORKERS LOCAL 265
WELFARE FUND, et al.,
Plaintiffs,
vs.
BELLE ENGINEERING, INC.,
an Illinois corporation,
Defendant.

)
)
)
)
)
)
)
)
)
)
)

CIVIL ACTION
NO. 11 C 6960
JUDGE HARRY D. LEINENWEBER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default
against Defendant, BELLE ENGINEERING, INC., an Illinois corporation, in the total amount of
$187,141.82, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,742.00.
On October 10, 2011, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to James Welsh) at his place of business (a copy of the
Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on
October 31, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully
request entry of default and judgment.

/s/ Catherine M. Chapman

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she 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 9th day
of November 2011:
Mr. Daniel F. Wagner, Registered Agent
Belle Engineering, Inc.
26W161 Plank Road
Naperville, IL 60563

/s/ Catherine M. Chapman

Catherine M. Chapman
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\265J\Belle Engineering\motion for default judgment.cmc.df.wpd