Opinion
Civil Action 22 C 4073
12-28-2022
CENTRAL PENSION FUND OF THE INTERNATIONAL UNION OF OPERATING ENGINEERS AND PARTICIPATING EMPLOYERS, et al., Plaintiffs, v. ELMAR HOTEL MANAGEMENT, LLC, a Michigan limited liability company, d/b/a INN OF CHICAGO, Defendant.
Laura M. Finnegan BAUM SIGMAN AUERBACH & NEUMAN, LTD.
Laura M. Finnegan
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
THOMAS M. DURKIN, JUDGE
Plaintiffs, by their attorneys, and pursuant to Federal Rule of Civil Procedure Rule 55(b), move for entry of judgment by default against Defendant, ELMAR HOTEL MANAGEMENT, LLC, a Michigan limited liability company, d/b/a INN OF CHICAGO, in the total amount of $129,390.57, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $2,692.00.
On August 10, 2022, the Summons and Complaint was served on the Defendant (by tendering a copy of said documents to Jose Alvarez) at the place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on August 31, 2022. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment pursuant to F.R.Civ.P. Rule 55(b).