Opinion
No. 11 C 4930
08-22-2011
TRUSTEES OF THE GLAZIERS, ARCHITECTURAL METAL AND GLASS WORKERS LOCAL UNION NO. 27 WELFARE AND PENSION FUNDS, Plaintiffs, v. LASALLE GLASS AND MIRROR, CO., an Illinois corporation, and TERRY GOODRICH, Individually, Defendants.
By: Thomas R. Allen One of their Attorneys Donald D. Schwartz Thomas R. Allen ARNOLD AND KADJAN
Judge Norgle
Magistrate Judge Denlow
MOTION FOR ORDER OF DEFAULT AND JUDGMENT IN SUM CERTAIN
Plaintiffs, by one of their attorneys, DONALD D. SCHWARTZ, THOMAS R. ALLEN and ARNOLD AND KADJAN, pursuant to F.R.C.P. 55, respectfully request this Honorable Court to enter an Order of Default as to liability and Judgment in favor of Plaintiffs and against Defendant, LASALLE GLASS AND MIRROR, CO., and TERRY GOODRICH.
In support thereof, Plaintiffs state:
1. This case was filed on July 21, 2011.
2. Defendants were both served with Summons and Complaint on July 29, 2011.
3. In excess of 20 days have expired since Service of Process, however, Defendant has failed to file an answer or otherwise plead.
4. Per affidavit of Carolyn Frederick, Benefits Administrator for Plaintiff's Funds, Defendants LASALLE GLASS AND MIRROR, CO. and TERRY GOODRICH, individually, currently owe the Funds at least $43,583.46. (Exhibit A).
5. Per the affidavit of Thomas R. Allen, attorney for Plaintiffs in legal fees and
expenses have $2,964.00 been incurred in this suit. (Exhibit B)
WHEREFORE, Plaintiffs pray for:
1. An Order of Default against the Defendant.
2. Order Defendant to submit its records for an audit for the period April 1, 2010 through to the present.
3. Judgment be rendered in the amount of $46,547.46.
Respectfully submitted,
TRUSTEES OF THE GLAZIERS,
ARCHITECTURAL METAL AND GLASS
WORKERS LOCAL UNION NO. 27
WELFARE AND PENSION FUNDS
By: Thomas R. Allen
One of their Attorneys
Donald D. Schwartz
Thomas R. Allen
ARNOLD AND KADJAN