Central Laborers' Pension Fund et al v. Viridian Enterprises, Inc.

Filing 23

MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Laborers' of Illinois Vacation Fund for entry of default , MOTION by Plaintiffs Central Laborers' Annuity Fund, Central Laborers' Pension Fund, Central Laborers' Pension Supplemental Fund, Central Laborers' Welfare Fund, Laborers' of Illinois Vacation 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.
VIRIDIAN ENTERPRISES, INC.,
an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 18 C 2033
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, VIRIDIAN ENTERPRISES, INC., an Illinois corporation, in the total amount of
$1,228.04, plus Plaintiffs’ court costs and reasonable attorneys’ fees in the amount of $2,056.25.
On April 3, 2018, the Summons and Complaint was served on the Registered Agent (by
tendering a copy of said documents to Kirsten Moisio) at his place of business (a copy of the
Summons and Affidavit of Service is attached hereto). Therefore, Defendant’s answer was due on
April 24, 2018. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully
request entry of default and judgment.

/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]
I:\CLJ\Viridian Enterprises\#27757\motion(2).cms.df.wpd

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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 5th day
of September 2018:
Mr. Ernest Estela, Registered Agent/President
Viridian Enterprises, Inc.
3810 W. Addison Street
Chicago, IL 60618

/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]
I:\CLJ\Viridian Enterprises\#27757\motion(2).cms.df.wpd