Carpenters Pension Fund of Illinois et al

Filing 9

MOTION by Plaintiffs Carpenters Pension Fund of Illinois, Carpenters Retirement Savings Funds of Illinois for entry of default , MOTION by Plaintiffs Carpenters Pension Fund of Illinois, Carpenters Retirement Savings Funds of Illinois for judgment (Attachments: # 1 Exhibit)(Chapman, Catherine)

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

CARPENTERS PENSION FUND OF
ILLINOIS, et al.,
Plaintiffs,
vs.
GROOMS & COMPANY
CONSTRUCTION, INC.,
Defendant.

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CIVIL ACTION
NO. 13 C 575
JUDGE EDMOND E. CHANG

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, GROOMS & COMPANY CONSTRUCTION, INC., in the total amount of $16,204.56,
plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $4,903.07.
On February 11, 2013, the Alias Summons and Complaint was served on the Defendant’s
President, Rodney Grooms, 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 March 4, 2013. As Defendant has failed to timely answer the
Complaint, Plaintiffs respectfully request entry of default and judgment.

/s/ Catherine M. Chapman

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that on or before the hour of 5:00
p.m., this 22nd day of April 2013, she electronically filed the foregoing document (Motion) with the
Clerk of Court using the CM/ECF system, which will send notification of such filing to the
following:
Scott Wormsley
Bradshaw, Fowler, Proctor & Fairgrave, P.C.
801 Grand Avenue, Suite 3700
Des Moines, IA 50309-8004
[e-mail]

/s/ Catherine M. Chapman

Catherine M. Chapman
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\CarpsJ\Grooms & Company\motion.cmc.df.wpd

James P. Moody
Attorney for Plaintiffs
CAVANAGH & O’HARA
407 East Adams Street
PO Box 5043
Springfield, IL 62705
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]