Unite Here Health et al v. The Pittsburgh Athletic Association

Filing 8

MOTION by Plaintiffs Unite Here Health, Matthew Walker for entry of default , MOTION by Plaintiffs Unite Here Health, Matthew Walker for judgment (Attachments: # 1 Exhibit)(Finnegan, Laura)

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

UNITE HERE HEALTH, et al.,

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Plaintiffs,
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vs.
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THE PITTSBURGH ATHLETIC ASSOCIATION, )
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Defendant.
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CIVIL ACTION
NO. 12 C 6015
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, THE PITTSBURGH ATHLETIC ASSOCIATION, in the total amount of $139,641.88,
plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $991.25.
On August 31, 2012, the Summons and Complaint was served on the Defendant (by
tendering a copy of said documents to employee, Emma Mangis) at the company’s place of business
(a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer
was due on September 21, 2012. As Defendant has failed to timely answer the Complaint, Plaintiffs
respectfully request entry of default and judgment.

/s/ Laura M. Finnegan

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 participants on or before the hour of 5:00 p.m. this 28th
day of September 2012:
The Pittsburgh Athletic Association
4215 5th Avenue
Pittsburgh, PA 15213-3546

/s/ Laura M. Finnegan

Laura M. Finnegan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6210637
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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