Sheet Metal Workers Local 265 Welfare Fund et al v. Manley

Filing 9

MOTION by Plaintiffs Sheet Metal Workers Local 265 Educational Fund, Sheet Metal Workers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 Supplemental Retir ement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265, Scott P. Wille for entry of default , MOTION by Plaintiffs Sheet Metal Workers Local 265 Educational Fund, Sheet Metal Workers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 Supplemental Retirement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265, Scott P. Wille for judgment (Attachments: # 1 Exhibit)(Chapman, Catherine)

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

SHEET METAL WORKERS LOCAL 265
WELFARE FUND, et al.,
Plaintiffs,
vs.
ROBERT E. MANLEY, d/b/a ROBERT E.
MANLEY,
Defendant.

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CIVIL ACTION
NO. 13 C 5602
JUDGE ROBERT W. GETTLEMAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, ROBERT E. MANLEY, d/b/a ROBERT E. MANLEY, in the total amount of
$39,973.43, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,271.25.
On August 23, 2013, the Summons and Complaint was served on the Defendant by tendering
a copy of said documents to him personally at his residence (a copy of the Summons and Affidavit
of Service is attached hereto). Therefore, Defendant’s answer was due on September 13, 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 she 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 6th day of November 2013:
Mr. Robert E. Manley
803 Woodbrook Court
Shorewood, IL 60404

/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]
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