Opinion
NO. 11 C 4014
08-04-2011
IRON WORKERS' MID-AMERICA PENSION PLAN, et al, Plaintiffs, v. DE PASQUALE STEEL ERECTORS, INC., an Illinois corporation, and DINO J. DEPASQUALE, an individual, Defendants.
Patrick N. Ryan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
CIVIL ACTION
JUDGE RONALD A. GUZMAN
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, DE PASQUALE STEEL ERECTORS, INC., an Illinois corporation, in the amount of $42,724.34, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $2,577.25.
On June 20, 2011, the Summons and Complaint was served on the Registered Agent for Defendant De Pasquale Steel Erectors, Inc. (by tendering a copy of said documents to Stacy Gray) at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on July 11, 2011.
As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
Patrick N. Ryan
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 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 participants on or before the hour of 5:00 p.m. this 4th day of August 2011:
Mr. Scott A. Klein, Registered Agent
De Pasquale Steel Erectors, Inc.
Mr. Dino J. Depasquale
Patrick N. Ryan
Patrick N. Ryan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.