Iron Workers' Mid-America Pension Plan et al v. Lakeside Rack Installers, Inc.

Filing 7

MOTION by Plaintiffs Joseph J Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for entry of default , MOTION by Plaintiffs Joseph J Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for judgment (Attachments: # 1 Exhibit)(Ryan, Patrick)

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

IRON WORKERS’ MID-AMERICA
PENSION PLAN, et al.,
Plaintiffs,
vs.
LAKESIDE RACK INSTALLERS, INC.,
a Michigan corporation,
Defendant.

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CIVIL ACTION
NO. 17 C 4291
JUDGE MANISH S. SHAH

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, LAKESIDE RACK INSTALLERS, INC., a Michigan corporation, in the total amount
of $99,945.42, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $4,436.24.
On June 13, 2017, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Jules Palms) at the registered office of record (a copy of the
Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on
July 5, 2017. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request
entry of default and judgment.

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for Plaintiffs
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]
I:\MIDJ\Lakeside Rack Installers\motion.pnr.df.wpd

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CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that he 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 10th day of August 2017:
Legalcorp Solutions, Inc., Registered Agent for
Lakeside Rack Installers, Inc.
13854 Lakeside Circle
Sterling Heights, MI 48313-1316
Mr. Michael Karas, President
Lakeside Rack Installers, Inc.
526 W. 14th Street, Suite 144
Traverse City, MI 49684

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for Plaintiffs
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]
I:\MIDJ\Lakeside Rack Installers\motion.pnr.df.wpd