Fox Valley Laborers Health and Welfare Fund et al v. Brown R Cartage Company

Filing 7

MOTION by Plaintiffs Fox Valley Laborers Health and Welfare Fund, Fox Valley and Vicinity Laborers Pension Fund, Patricia M. Shales for entry of default , MOTION by Plaintiffs Fox Valley Laborers Health and Welfare Fund, Fox Valley and Vicinity Laborers Pension Fund, Patricia M. Shales for judgment (Attachments: # 1 Exhibit Return of Service)(Chapman, Catherine)

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

FOX VALLEY LABORERS HEALTH AND
WELFARE FUND, et al.,
Plaintiffs,
v.
BROWN R CARTAGE COMPANY, an Illinois
corporation, d/b/a TRAFFIC SOLUTIONS,
and d/b/a BROWN R CARTAGE CO.,
Defendant.

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CIVIL ACTION
NO. 17 C 8388
JUDGE VIRGINIA M. KENDALL

MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against
Defendant, BROWN R CARTAGE COMPANY, an Illinois corporation, d/b/a TRAFFIC
SOLUTIONS, and d/b/a BROWN R CARTAGE CO., in the total amount of $142,013.03, plus
Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $3,877.00.
On December 9, 2017, the Summons and Complaint was served on the Registered Agent by
tendering a copy of said documents to him personally at his residence (a copy of the Summons and
Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on January 2, 2018.
As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of
default and judgment.

/s/ Catherine M. Chapman

Catherine M. Chapman
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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 January 2018:
Mr. Jorge Bonilla, Registered Agent/President
Brown R Cartage Company
551 Tollgate Road, Suite C
Elgin, IL 60123-9357
Mr. Jorge Bonilla, Registered Agent/President
Brown R Cartage Company
9N760 Old Millcourt
Elgin, IL 60124-8318

/s/ Catherine M. Chapman
Catherine M. Chapman
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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