Bandas v. Nationwide Credit & Collection, Inc.

Filing 12

MOTION by Plaintiff Frank Bandas for judgment (Chatman, Celetha)

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UNITED STATES DISTRICT COURT FOR THE NORTHER DISTRICT OF ILLINOIS EASTERN DIVISION FRANK BANDAS PLAINTIFF, v. NATIONWIDE CREDIT, INC., DEFENDANT. ) ) ) ) ) ) ) ) ) Civil Action No. 17-cv-00987 Hon. Samuel Der-Yeghiayan Magistrate Judge Young B. Kim PLAINTIFF’S MOTION FOR DEFAULT ORDER NOW COMES the Plaintiff, Frank Bandas, by and through his attorneys, and hereby moves this Court to hold the Defendant, Nationwide Credit Inc. in default. In support of this Motion, Plaintiff states as follows: 1. Plaintiff filed his First Amended Complaint on February 14, 2017. (Dkt.#5). 2. The Defendant was served with process on February 27, 2017, and their responsive pleading was due March 20, 2017. (Dkt. #7). 3. Defendant has failed to timely answer or otherwise plead. 4. Plaintiff thus asks that this Court Enter an Order of Default as to Defendant, Nationwide Credit, Inc. pursuant to Fed. R.Civ. P. 55(a) and to set this matter for a future date for entry of default judgment and prove-up. WHEREFORE, Plaintiff Frank Bandas, by and through his attorneys, moves this Honorable Court to enter default at to Defendant, Nationwide Credit, Inc., and for any other relief this Court deems just. Respectfully Submitted, /s/ Celetha C. Chatman Celetha Chatman Celetha Chatman Attorney at Law Community Lawyers Group, Ltd. 73 W. Monroe, Suite 514 Chicago, IL 60603 Ph: 312.757.1880 fax: 312.476.1383 cchatman@communitylawyersgroup.com UNITED STATES DISTRICT COURT FOR THE NORTHER DISTRICT OF ILLINOIS EASTERN DIVISION FRANK BANDAS PLAINTIFF, v. NATIONWIDE CREDIT, INC., DEFENDANT. ) ) ) ) ) ) ) ) ) Civil Action No. 17-cv-00987 Hon. Samuel Der-Yeghiayan Magistrate Judge Young B. Kim CERTIFICATE OF SERVICE I, Celetha C. Chatman, an attorney, certify that I shall cause to be served a copy of the Plaintiff’s Notice of Motion For Default Order & Motion For Default Order upon the following individual(s), as indicated below, this day of March 31, 2017, along with a certified copy of the notice of motion entered in the case referenced above: ___ CM/ECF _ Facsimile ____ Federal Express ____ UPS _x_ USPS Mail _ Messenger Email Nationwide Credit, Inc. c/o Prentice Hall Corporation 222 S. Riverside Plaza, Suite 2310 Chicago, Illinois 60606 By: Celetha Chatman Michael Wood Community Lawyers Group, Ltd. 73 W. Monroe Street, Suite 514 Chicago, IL 60603 (312)757-1880 cchatman@communitylawyersgroup.com mwood@communitylawyersgroup.com /s/Celetha C. Chatman Attorney for Plaintiff

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