Opinion
Civil Action 21 C 5786
01-07-2022
Patrick N. Ryan, Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
Patrick N. Ryan, Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
MANISH S. SHAH 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, THE ROSS GROUP, INC., an Indiana corporation, in the total amount of $18,768.70, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $3,384.00.
On November 18, 2021, the Alias Summons and Complaint was served on the corporation's President, Ross N. Pangere (by tendering a copy of said documents to him personally) at the corporate address of record (a copy of the Alias Summons and Affidavit for Return of Service is attached hereto). Therefore, Defendant's answer was due on December 9, 2021. 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).