Miscellaneous Warehousemen's Local 781 Health & Welfare Fund v. M and M Glass Service, Inc.

Filing 5

MOTION by Plaintiff Miscellaneous Warehousemen's Local 781 Health & Welfare Fund for entry of default , MOTION by Plaintiff Miscellaneous Warehousemen's Local 781 Health & Welfare Fund for judgment (Attachments: # 1 Exhibit Return of Service)(Ryan, Patrick)

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

MISCELLANEOUS WAREHOUSEMEN’S
LOCAL 781 HEALTH & WELFARE FUND,
Plaintiff,
vs.
M AND M GLASS SERVICE, INC.,
an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 17 C 2932
JUDGE MATTHEW F. KENNELLY

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COMES Plaintiff, by its attorneys, and move for entry of judgment by default against
Defendant, M AND M GLASS SERVICE, INC., an Illinois corporation, in the total amount of
$30,232.73, plus Plaintiff’s court costs and reasonable attorneys’ fees in the amount of $1,069.00.
On May 3, 2017, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Lynne Putz) at his place of business (a copy of the Summons
and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on May 24,
2017. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry
of default and judgment.

/s/ Patrick N. Ryan

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 26th
day of May 2017:
Mr. John H. Putz, Registered Agent/President
M and M Glass Service, Inc.
4047 W. 147th Street
Midlothian, IL 60445

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for Plaintiff
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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