Opinion
CIVIL ACTION NO. 12 C 8570
01-02-2013
SHEET METAL WORKERS LOCAL 265 WELFARE FUND, et al., Plaintiffs, v. AMCO, INC., an Illinois corporation, Defendant.
Jennifer L. Dunitz-Geiringer Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
JUDGE ELAINE E. BUCKLO
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, AMCO, INC., an Illinois corporation, in the total amount of $55,242.63, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,379.75.
On November 1, 2012, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to Tony Cuellar, a person authorized to accept service of process on behalf of Cynthia Schlenker) at her place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on November 23, 2012. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
Jennifer L. Dunitz-Geiringer
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 2nd day of January 2013:
Ms. Cynthia Lynn Schlenker, Registered Agent/Secretary
Amco, Inc.
2422 Millenium Drive
Elgin, IL 60123
Jennifer L. Dunitz-Geiringer Jennifer L. Dunitz-Geiringer
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.