Unite Here Health et al v. 7 East 54th Street Associates, LLC

Filing 19

MOTION by Plaintiffs Unite Here Health, Matthew Walker for entry of default , MOTION by Plaintiffs Unite Here Health, Matthew Walker for judgment (Attachments: # 1 Exhibit)(Finnegan, Laura)

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

UNITE HERE HEALTH, et al.,
Plaintiffs,
vs.
7 EAST 54TH STREET ASSOCIATES, LLC,
d/b/a BICE RISTORANTE,
Defendant.

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CIVIL ACTION
NO. 13 C 7633
JUDGE ELAINE E. BUCKLO

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, 7 EAST 54TH STREET ASSOCIATES, LLC, d/b/a BICE RISTORANTE, in the total
amount of $261,332.16, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of
$2,418.75.
On November 13, 2013, the Summons and Complaint was served on the Defendant by
tendering a copy of said documents to Bagtha Seddik at the Defendant’s place of business (a copy
of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was
due on December 4, 2013. Defendant filed its answer on January 3, 2014. Defendant’s counsel,
however, withdrew from its representation. Defendant is required to be represented by counsel in
this Court. As Defendant has failed to timely retain counsel to defend its answer to the Complaint,
Plaintiffs respectfully request entry of default and judgment.

/s/ Laura M. Finnegan

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she electronically filed the
foregoing document (Motion for Entry of Default and Judgment) with the Clerk of Court using the
CM/ECF system, and further certifies that I have mailed the above-referenced document by US Mail
to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 19th day of
February 2014:
7 East 54th Street Associates, LLC,
d/b/a Bice Ristorante
7 East 54th Street
New York, NY 10022

/s/ Laura M. Finnegan

Laura M. Finnegan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6210637
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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