Opinion
CIVIL ACTION NO. 12 C 9606
03-14-2013
MISCELLANEOUS WAREHOUSEMEN'S LOCAL 781 HEALTH & WELFARE FUND, Plaintiff, v. NEMETH GLASS, INC., an Illinois corporation, Defendant.
Patrick N. Ryan Attorney for Plaintiff BAUM SIGMAN AUERBACH & NEUMAN, LTD.
JUDGE SAMUEL DER-YEGHIAYAN
MOTION FOR ENTRY OF JUDGMENT
Plaintiff, by and through its attorneys, default having been entered against the Defendant on February 28, 2013, request this Court enter judgment against Defendant, NEMETH GLASS, INC., an Illinois corporation. In support of that Motion, Plaintiffs state:
1. On February 28, 2013, this Court entered default against Defendant and set this matter for prove-up hearing on March 21, 2013.
2. Based on Defendant's monthly reports for the months of October 2011 through January 2013, and taking into account all payments received to date, Defendant owes Plaintiff contributions of $76,892.00, liquidated damages of $42,704.43, and accrued interest of $12,811.33, for a total of $132,407.76 (See Affidavit of David Dorfman).
3. In addition, Plaintiff has incurred court costs of $520.00 and reasonable attorney's fees of $1,422.75 in efforts to recover the above amounts (See Affidavit of Catherine M. Chapman).
4. Based upon the documents attached hereto, Plaintiff requests entry of judgment in the total amount of $134,350.51.
WHEREFORE, Plaintiff respectfully requests this Court to enter judgment in the amount of $134,350.48.
Patrick N. Ryan Patrick N. Ryan
Attorney for Plaintiff
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 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 participant on or before the hour of 5:00 p.m. this 14th day of March 2013:
Mr. Jerry Nemeth, President
Nemeth Glass, Inc.
5584 N. Northwest Highway
Chicago, IL 60630
Patrick N. Ryan Patrick N. Ryan
Attorney for Plaintiff
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