Carpenters Fringe Benefit Funds of Illinois et al v. Cornerstone Carpentry Contractors, Inc.

Filing 6

MOTION by Plaintiffs Angelica B. Ambrose, Carpenters Fringe Benefit Funds of Illinois for entry of default , MOTION by Plaintiffs Angelica B. Ambrose, Carpenters Fringe Benefit Funds of Illinois for judgment (Attachments: # 1 Exhibit)(Scanlon, Cecilia)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CARPENTERS FRINGE BENEFIT FUNDS OF ILLINOIS, et al., Plaintiffs, vs. CORNERSTONE CARPENTRY CONTRACTORS, INC., a Wisconsin corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO. 17 C 4089 JUDGE ELAINE E. BUCKLO MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, CORNERSTONE CARPENTRY CONTRACTORS, INC., a Wisconsin corporation, in the total amount of $1,596.70, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $929.00. On June 12, 2017, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to him personally at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on July 3, 2017. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment. /s/ Cecilia M. Scanlon CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion) 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 21st day of July 2017: Mr. Bruce A. McIlnay, Registered Agent Cornerstone Carpentry Contractors, Inc. 1971 Washington Street, Suite 201 Grafton, WI 53024-2102 /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: (312) 216-2577 Facsimile: (312) 236-0241 E-Mail: cscanlon@baumsigman.com I:\CarpsJ\Cornerstone Carpentry\motion for default judgment.cms.df.wpd

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