Iron Workers' Mid-America Pension Plan et al v. Morcom Construction Company

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 (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.
MORCOM CONSTRUCTION
COMPANY, an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 17 C 4768
JUDGE SHARON JOHNSON COLEMAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, MORCOM CONSTRUCTION COMPANY, an Illinois corporation, in the total amount
of $210,624.96, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of
$2,104.00.
On June 27, 2017, a Notice of a Lawsuit and Request to Waive Service of a Summons and
Waiver of the Service of Summons forms were served on Defendant’s counsel. On July 14, 2017,
Defendant’s counsel executed the Waiver of the Service of Summons form. Pursuant to the Waiver
form, Defendant’s answer or motion under Rule 12 was due within 60 days from June 27, 2017, or
by August 28, 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 on or before the hour of 5:00
p.m., this 2nd day of October 2017, he electronically filed the foregoing document (Motion) with
the Clerk of Court using the CM/ECF system, which will send notification of such filing to the
following:
Mr. Brendan Shiller
Shiller Preyar Law Offices, LLC
601 S. California Avenue
Chicago, IL 60612
[e-mail]

/s/ Patrick N. Ryan
Patrick N. Ryan
Attorney for the 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]
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