Iron Workers' Mid-America Pension Plan et al v. Dimensional Technology, Inc.

Filing 7

MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund, Iron Workers' Tri-State Welfare Plan 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, Iron Workers' Tri-State Welfare Plan for judgment (Attachments: # 1 Exhibit Return of Service)(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.
DIMENSIONAL TECHNOLOGY, INC.,
an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 12 C 0077
JUDGE JOAN H. LEFKOW

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, DIMENSIONAL TECHNOLOGY, INC., an Illinois corporation, in the total amount of
$42,449.77, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,317.75.
On January 9, 2012, the Summons and Complaint was served on the Registered Agent by
tendering a copy of said documents to her at her place of business (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
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]

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 7th day of February 2012:
Dena M. Basselen, Registered Agent/President
Dimensional Technology, Inc.
6717 Linden Lane
Huntley, IL 60142

/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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