Opinion
CIVIL ACTION NO. 11 C 1217
08-02-2011
MIKE SHALES, et al, Plaintiffs, v. DIENST SEWER & WATER, INC., an Illinois corporation, Defendant.
Catherine M. Chapman Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
JUDGE
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, DIENST SEWER & WATER, INC., an Illinois corporation, in the total amount of $40,446.18, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $4,619.25.
On May 2, 2011, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to the Illinois Secretary of State because the corporation's registered agent could not, with reasonable diligence, be found at the registered office of record in Illinois. Therefore, Defendant's answer was due on May 23, 2011. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
Catherine M. Chapman
CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she 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 2nd day of August 2011:
Mr. Dale L. Goldsboro, Registered Agent/President
Dienst Sewer & Water
2252 N. 44th Road
Sheridan, IL 60551
Jesse White
Secretary of State
Department of Business Services
Attn: File #6076-5325
Springfield, IL 62756
Catherine M. Chapman
Catherine M. Chapman
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.