Central Laborers' Pension Fund et al v. Path Construction Company, Inc.

Filing 5

MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Annuity Supplemental Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Illinois Laborers and Contractors Training Trust Fund, Laborers' Local 538, Market Preservation Fund, North Central Illinois Laborers' Health & Welfare Fund, North Central Laborers-Employers Cooperation Trust, North Central Midwest Region Foundation for Fair Contracting, North Central Vacation Fund, Northern Illinois Laborers' Welfare Fund, Work Dues Fund for entry of default , MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Annuity Supplemental Fund, Centra l Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Illinois Laborers and Contractors Training Trust Fund, Laborers' Local 538, Market Preservation Fund, North Central Illinois La borers' Health & Welfare Fund, North Central Laborers-Employers Cooperation Trust, North Central Midwest Region Foundation for Fair Contracting, North Central Vacation Fund, Northern Illinois Laborers' Welfare Fund, Work Dues 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.
PATH CONSTRUCTION COMPANY,
INC., an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 17 C 5171
JUDGE CHARLES R. NORGLE, SR.

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, PATH CONSTRUCTION COMPANY, INC., an Illinois corporation, in the total amount
of $18,478.74, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $1,587.50.
On July 19, 2017, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Sandy Iga) at his place of business (a copy of the Summons
and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on August 9,
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 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 10th
day of November 2017:
Mr. Richard Krause, Registered Agent for
Path Construction Company, Inc.
125 E. Algonquin Road
Arlington Heights, IL 60005

/s/ Cecilia M. Scanlon

Cecilia M. Scanlon
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
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