Opinion
NO. 11 C 5357
11-10-2011
CARPENTERS PENSION FUND OF ILLINOIS, et al., Plaintiffs, v. KIMBERLY ANN KURTZ, individually and d/b/a W.C. LANGELAND & CO., INC., a dissolved corporation, Defendant.
Patrick N. Ryan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
CIVIL ACTION
JUDGE MILTON I. SHADUR
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, KIMBERLY ANN KURTZ, individually and d/b/a W.C. LANGELAND & CO., INC., a dissolved corporation, in the total amount of $273,510.47, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $3,253.25.
On August 20, 2011, the Summons, Complaint and Order entered on August 11, 2011 were served on the Defendant by tendering a copy of said documents to her personally at her residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on September 12, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that he 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 2011:
Ms. Kimberly Ann Kurtz
W.C. Langeland & Co., Inc.
202 Heritage
Minooka, IL 60447
Patrick N. Ryan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.