Opinion
CIVIL ACTION NO. 11 C 7633
12-08-2011
CENTRAL LABORERS PENSION FUND, et al., Plaintiffs, v. RC SMITH CONCRETE COMPANY, an Illinois corporation, Defendant.
Patrick N. Ryan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
JUDGE MARVIN E. ASPEN
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, RC SMITH CONCRETE COMPANY, an Illinois corporation, in the total amount of $1,978.87, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $791.25.
On November 1, 2011, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to him personally at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on November 22, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
Patrick N. Ryan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
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 furthe 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 8th day of December 2011:
Mr. David M. Stieper, Registered Agent
RC Smith Concrete Company
Stieper Law Offices, Ltd.
2500 W. Higgins Road, Suite 1200
Hoffman Estates, IL 60169-7243
Patrick N. Ryan
Patrick N. Ryan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6278364
Telephone: (312) 236-4316
Facsimile: (312) 236-0241
E-Mail: pryan@baumsigman.com
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