Central Laborers' Pension Fund et al v. Environmental Cleansing Corporation

Filing 11

MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Welfare Fund for entry of default , MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Welfare Fund for judgment (Attachments: # 1 Exhibit Return of Service)(Scanlon, Cecilia)

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

CENTRAL LABORERS’ PENSION FUND,
et al.,
Plaintiffs,
vs.
ENVIRONMENTAL CLEANSING
CORPORATION, an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 17 C 1601
JUDGE JOAN H. LEFKOW

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, ENVIRONMENTAL CLEANSING CORPORATION, an Illinois corporation, in the
total amount of $821.55, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of
$1,430.00.
On March 6, 2017, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Mary Callan) at his place of business (a copy of the Summons
and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on March 27,
2017. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry
of default and judgment.

/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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2

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she 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 9th day
of June 2017:
Mr. Matthew A. Konopko, Registered Agent/President
Environmental Cleansing Corporation
16612 S. Crawford Avenue
Markham, IL 60428

/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]
I:\CLJ\Environmental Cleansing\motion for entry of default and judgment (2).cms.df.wpd