Iron Workers' Mid-America Pension Plan et al v. J & D Erectors, Inc.

Filing 7

MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for entry of default, MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

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

IRON WORKERS’ MID-AMERICA
PENSION PLAN, et al.,
Plaintiffs,
vs.
J & D ERECTORS, INC., an Illinois
corporation,
Defendant.

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CIVIL ACTION
NO. 12 C 0042
JUDGE REBECCA R. PALLMEYER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, J & D ERECTORS, INC., an Illinois corporation, in the total amount of $25,974.39, plus
Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,455.75.
On January 8, 2012, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Philip Saineghi, the corporation’s president) at the registered
office of record (a copy of the Summons and Affidavit of Service is attached hereto). Therefore,
Defendant’s answer was due on January 30, 2012. 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) 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 February 2012:
Ms. Josephine M. Saineghi, Registered Agent
J & D Erectors, Inc.
7616 West Berwyn Avenue
Chicago, IL 60656

/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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