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)

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.

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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: [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 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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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