Bandas v. Nationwide Credit & Collection, Inc.
Filing
12
MOTION by Plaintiff Frank Bandas for judgment (Chatman, Celetha)
UNITED STATES DISTRICT COURT
FOR THE NORTHER DISTRICT OF ILLINOIS
EASTERN DIVISION
FRANK BANDAS
PLAINTIFF,
v.
NATIONWIDE CREDIT, INC.,
DEFENDANT.
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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:
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CM/ECF
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Facsimile
____ Federal Express
____ UPS
_x_ USPS Mail
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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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