Sheet Metal Workers Local 265 Welfare Fund et al v. J & B Mechanical, Inc.

Filing 7

MOTION by Plaintiffs Kevin J. Schell, Sheet Metal Workers Local 265 Educational Fund, Sheet Metal Workers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 S upplemental Retirement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265 for entry of default , MOTION by Plaintiffs Kevin J. Schell, Sheet Metal Workers Local 265 Educa tional Fund, Sheet Metal Workers Local 265 Industry Fund, Sheet Metal Workers Local 265 Pension Fund, Sheet Metal Workers Local 265 Savings Fund, Sheet Metal Workers Local 265 Supplemental Retirement Plan, Sheet Metal Workers Local 265 Welfare Fund, Sheet Metal Workers' International Association, Local Union No. 265 for judgment (Attachments: # 1 Exhibit Return of Service)(Scanlon, Cecilia)

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

SHEET METAL WORKERS LOCAL 265 )
WELFARE FUND, et al.,
)
)
Plaintiffs,
)
)
vs.
)
)
J & B MECHANICAL, INC.,
)
an Illinois corporation,
)
)
Defendant.
)

CIVIL ACTION
NO. 17 C 6700
JUDGE SAMUEL DER-YEGHIAYAN

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, J & B MECHANICAL, INC., an Illinois corporation, in the total amount of $21,580.67,
plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $2,630.25.
On October 2, 2017, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to the Illinois Secretary of State, Department of Business
Services) (a copy of the Summons and Affidavit of Compliance for Service on Secretary of State is
attached hereto). Therefore, Defendant’s answer was due on October 23, 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 participants on or before the hour of 5:00 p.m. this 21st
day of November 2017:
Ms. Jo Slavich, Registered Agent
J & B Mechanical, Inc.
128 West Pratt Boulevard
Schaumburg, IL 60172
Jesse White
Secretary of State
Department of Business Services
Attn: File #59393251
Springfield, IL 62756

/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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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