Painters District Council No. 14 v. LaSalle Glass & Mirror Co.

Filing 5

MOTION by Plaintiff Painters District Council No. 14 for order , MOTION by Plaintiff Painters District Council No. 14 for judgment in Sum Certain (Attachments: # 1 Exhibit A - Affidavit of Michael O'Donnell, # 2 Text of Proposed Order)(Schwartz, Donald)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
PAINTERS DISTRICT COUNCIL NO. 14,
a labor organization,
Plaintiffs,
v.
LASALLE GLASS & MIRROR CO.,
Defendant.

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No. 11 C 9042

Judge Holderman
Magistrate Judge Kim

MOTION FOR ORDER OF DEFAULT AND JuDGMENT IN SUM CERTAIN
Plaintiffs, by one of their attorneys, DONALD D. SCHWARTZ, and ARNOLD AND
KADJAN, pursuant to F.R.C.P. 55, respectfully request this Honorable Court to enter an Order
of Default as to liability and Judgment in favor of Plaintiffs and against Defendant, LASALLE
GLASS & MIRROR CO.
In support thereof, Plaintiffs state:
1.

This case was filed on December 21, 2011.

2.

Defendant was served with Summons and Complaint on January 6, 2012.

3.

In excess of 20 days have expired since Service of Process, however, Defendant

has failed to file an answer or otherwise plead.
4.

Pursuant to the affidavit of Mike O’Donnell, the Glaziers Union Local 27

(affiliated with PDC 14) issued ajoint arbitration board decision on May 31, 2011 against
LaSalle in the amount of $11,540.64. The award was served on defendant, but has not been paid.
(Exhibit A)
WHEREFORE, Plaintiffs pray for:
1.

An order of default against defendant.

2.

Judgment be rendered in the amount of $11,540.64 in favor of plaintiffs and

against defendant.
Respectfully submitted,
PAII4TERS DISTRICT COUNCIL NO. 14

By: s/Donald D. Schwartz
One of their Attorneys
Donald D. Schwartz
ARNOLD AND KADJAN
203 N. LaSalle St., Suite 1650
Chicago, Illinois 60601
[phone]