Opinion
CIVIL ACTION NO. 11 C 7632
12-01-2011
CENTRAL LABORERS PENSION FUND; et al., Plaintiffs, v. BRETT BUNGER, an individual, d/b/a MARYOTT EXCAVATING, a/k/a MARYOTT EXCAVATING, INC., a dissolved Illinois corporation, Defendant.
Patrick N. Ryan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
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, BRETT BUNGER, an individual, d/b/a MARYOTT EXCAVATING, a/k/a MARYOTT EXCAVATING, INC., a dissolved Illinois corporation, in the total amount of $6,258.34, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $856.75.
On October 30, 2011, the Summons and Complaint was served on the Defendant by tendering a copy of said documents to his wife, Jennifer L. Bunger, at his residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on November 21, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
Patrick N. Ryan
CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that he electronically filed the foregoing document (Motion) 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 1st day of December 2011:
Mr. Brett Bunger
d/b/a Maryott Excavating
5534 Byers Road
Kirkland, IL 60146
Patrick N. Ryan
Patrick N. Ryan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.