Central Laborers' Pension Fund et al v. Williams

Filing 12

MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Illinois Laborers and Contractors Joint Apprenticeship & Training Tr ust Fund, Laborers' Local Union No. 165, Laborers' Local Union No. 751, Midwest Region Organizing Committee, North Central Illinois Laborers' Health & Welfare Fund, North Central Market Preservation Fund, Working Dues for entry of defa ult , MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Illinois Laborers and Contractors Joint Apprenticeship & Training Trust Fund, Laborers' Local Union No. 165, Laborers' Local Union No. 751, Midwest Region Organizing Committee, North Central Illinois Laborers' Health & Welfare Fund, North Central Market Preservation Fund, Working Dues 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.
JENNIFER Y. WILLIAMS, individually and
d/b/a J.M. WILLIAMS CONSTRUCTION CO.,
a dissolved Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 16 C 4628
JUDGE REBECCA R. PALLMEYER

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, JENNIFER Y. WILLIAMS, individually and d/b/a J.M. WILLIAMS CONSTRUCTION
CO., dissolved Illinois corporation, in the amount of $999.08, plus Plaintiffs’ court costs and
reasonable attorneys’ fees in the amount of $1,379.00.
On May 6, 2016, the Summons and Complaint was served on the Defendant by tendering a
copy of said documents to her personally at her residence (a copy of the Summons and Affidavit of
Service is attached hereto). Therefore, Defendant’s answer was due on May 27, 2016. 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 15th day of September 2016:
Ms. Jennifer Y. Williams
J.M. Williams Construction Co.
291 Fairway Drive
Beecher, IL 60401

/s/ Cecilia M. Scanlon

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