Opinion
CASE NUMBER 14 C 3132
07-01-2014
JANICE G. HOLMES, Plaintiff in Pro se, v. HOUSING AUTHORITY OF JOLIET, ET. AL., Defendants.
JANICE G. HOLMES Plaintiff in Pro se
JURY TRIAL DEMANDED
Judge Kocoras
Magistrate Judge Maria Valdez
PLAINTIFF'S FRCP RULE 55(B)(2) MOTION FOR JUDGMENT
BY DEFAULT AGAINST DEFENDANT HENRY MORRIS
INTRODUCTION
NOW COMES the Pro se Plaintiff, JANICE G. HOLMES ("Holmes") and for her frcp rule 55(b)(2) motion for judgment by default against defendant HENRY MORRIS ("Morris") seeking to have this court to enter judgment by default against defendant Morris.
BACKGROUND
On or about the 5th day of June, 2014, this court granted defendant Henry Morris's motion for enlargement of time and allowed defendant Henry Morris to have until the 17 day of June, 2014 in which to submit their frcp rule 8(b) answer to the verified complaint.
ARGUMENT
Plaintiff Holmes contend that this court should grant this frcp rule 55(b)(2) motion for judgment against defendant Morris for the following reason which will serve as a com- plete basis to enter judgment by default.
That as of the date of the filing of this frcp rule 56(b)(2) motion, neither has defendant Morris filed a second motion for enlargement of time, nor has defendant Morris complied with frcp rule 7(a) and submitted his required frcp rule 8(b) answer to the verified complaint by the June 17, 2014 due date. Therefore, this court should grant this frcp rule 55(b)(2) motion and enter judgment by default against defendant Morris.
CONCLUSION
Based upon the aforementioned, the fairest and just decision for this Honorable Court to make, as a Guardian of the Law, would be to grant this motion and enter judgment by default against defendant Henry Morris.
WHEREFORE, the Pro se Plaintiff, JANICE G. HOLMES ("Holmes") respectfully request of this Honorable Court to hand down a decision consistent with the requested relief sought in this frcp rule 55(b)(2).
Respectfully submitted
By __________
JANICE G. HOLMES
Plaintiff in Pro se
Janice Holmes
1856 Asbury Circle Drive, Apt. 208B
City of Joliet/County of Will
State of Illinois 60435
(815) 341-1997
CERTIFICATION OF SERVICE
The undersigned certifies under penalty of perjury under the Laws of the United States of America that a copy of the foregoing was served upon defendant Housing Authority of Joliet's attorney at their office of record as addressed below by placing the same in a sealed envelope with postage fully prepaid thereon and placing the same in a U.S. Post Office Box in the City of Chicago, Illinois, on the 1st day of July, 2014, before the hour of 4:00p.m.
__________
Janice G. Holmes
KOPON AIRDO, LLC
Attn: Attorney Rachel E. Yarch
233 South Wacker Drive, Suite 4450
City of Chicago, Illinois 60606