Midwest Operating Engineers Pension Trust Fund v. Hart's Tractor Co., Inc.

Filing 7

MOTION by Plaintiff Midwest Operating Engineers Pension Trust Fund for entry of default , MOTION by Plaintiff Midwest Operating Engineers Pension Trust Fund for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MIDWEST OPERATING ENGINEERS PENSION TRUST FUND, Plaintiff, vs. HARTS TRACTOR COMPANY, INC., a dissolved Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO. 13 C 4811 JUDGE MILTON I. SHADUR MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, HARTS TRACTOR COMPANY, INC., a dissolved Illinois corporation, in the total amount of $1,761,110.09, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,191.25. On July 2, 2013, 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 July 24, 2013. 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: (312) 236-4316 Facsimile: (312) 236-0241 E-Mail: pryan@baumsigman.com 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 29th day of July 2013: Mr. Michael E. White, Registered Agent Harts Tractor Company, Inc. 33 W. Jackson Boulevard, Suite 500 Chicago, IL 60604 /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 E-Mail: pryan@baumsigman.com I:\MOEP\Hart's Tractor\motion.pnr.df.wpd

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