Iron Workers' Mid-America Pension Plan et al v. Tefco, Inc.
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
IRON WORKERS’ MID-AMERICA
PENSION PLAN, et al.,
TEFCO, INC., an Indiana corporation,
NO. 12 C 10057
JUDGE JOHN J. THARP, JR.
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, TEFCO, INC., an Indiana corporation, in the total amount of $39,200.19, plus Plaintiffs’
court costs and reasonable attorneys’ fees in the amount of $1,755.50.
On December 28, 2012, the Summons and Complaint was served on the Registered Agent
by tendering a copy of said documents to him personally at his place of business (a copy of the
Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on
January 18, 2013. 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 26th day of March 2013:
Mr. Tharon Freudenberg, Registered Agent/President
11022 Sawmill Road
Elberfeld, IN 47613-9122
/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: (312) 236-4316
Facsimile: (312) 236-0241
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