Iron Workers Mid-America Pension Plan et al v. Krall

Filing 6

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)

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

IRON WORKERS’ MID-AMERICA
PENSION PLAN, et al.,
Plaintiffs,
vs.
CHRISTOPHER KRALL, d/b/a H-H
IRONWORKS, LLC,
Defendant.

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CIVIL ACTION
NO. 17 C 914
JUDGE THOMAS M. DURKIN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, CHRISTOPHER KRALL, d/b/a H-H IRONWORKS, LLC, in the total amount of
$54,413.80, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,541.00.
On February 21, 2017, the Summons and Complaint was served on the Defendant (by
tendering a copy of said documents to his father, William Krall) at his residence (a copy of the
Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on
March 14, 2017. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully
request entry of default and judgment.

/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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

I:\MIDJ\H-H Ironworks\#27055\motion.pnr.df.wpd

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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 24th
day of March 2017:
Mr. Christopher Krall
H-H Ironworks, LLC
124 Zapata Lane
Minooka, IL 60447

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6278364
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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