Central Laborers' Pension Fund et al v. Elite Seamless Gutters, Inc.

Filing 6

MOTION by Plaintiffs Central Illinois Laborers' Work Dues Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Industry Advancement Fund Illinois Valley, Laborers' Local Union No. 393, North Central I llinois Laborers' Health & Welfare Fund for entry of default , MOTION by Plaintiffs Central Illinois Laborers' Work Dues Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Industry Advancement Fund Illinois Valley, Laborers' Local Union No. 393, North Central Illinois Laborers' Health & Welfare Fund for judgment (Attachments: # 1 Exhibit)(Scanlon, Cecilia)

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

CENTRAL LABORERS’ PENSION FUND,
et al.,
Plaintiffs,
vs.
ELITE SEAMLESS GUTTERS, INC., an Illinois
corporation, f/k/a ELITE CONSTRUCTION OF
IL., INC.,
Defendant.

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CIVIL ACTION
NO. 15 C 3626
JUDGE CHARLES R. NORGLE, SR.

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, ELITE SEAMLESS GUTTERS, INC., an Illinois corporation, f/k/a ELITE CONSTRUCTION OF IL., INC., in the total amount of $1,895.48, plus Plaintiffs’ court costs and reasonable
attorneys’ fees in the amount of $833.00.
On April 29, 2015, 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
May 20, 2015. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully
request entry of default and judgment.

/s/ Cecilia M. Scanlon

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 17th day of June 2015:
Mr. John French, Registered Agent/President
Elite Seamless Gutters, Inc.
1606 26th Street
Peru, IL 61354

/s/ Cecilia M. Scanlon

Cecilia M. Scanlon
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6288574
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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