Iron Workers' Mid-America Pension Plan et al v. Security Fence Co., Inc.

Filing 8

MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for entry of default , MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) 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 IRON WORKERS’ MID-AMERICA PENSION PLAN, et al., Plaintiffs, vs. SECURITY FENCE CO., INC., an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO. 14 C 18 JUDGE SARA L. ELLIS MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, SECURITY FENCE CO., INC., an Illinois corporation, in the total amount of $42,332.77, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,118.00. On January 15, 2014, 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 February 5, 2014. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment. /s/ Patrick N. Ryan CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that he 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 United States Mail to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 4th day of March 2014: Mr. Jeffrey H. Cole, Registered Agent/President Security Fence Co., Inc. 2022 S. Griswold Peoria, IL 61605 /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:\MIDJ\Security Fence\#24804\motion.pnr.df.wpd

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