IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
February 22, 2007
FOX VALLEY CONSTRUCTION WORKERS FRINGE BENEFIT FUNDS, ET AL., PLAINTIFFS,
PREFERRED CONCRETE & EXCAVATING, INC., A CORPORATION, DEFENDANT.
The opinion of the court was delivered by: Judge James B. Moran
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, PREFERRED CONCRETE & EXCAVATING, INC., a corporation, in the total amount of $83,575.88, plus Plaintiffs' court costs of $382.00 and reasonable attorneys' fees of $1,753.75.
On January 19, 2007, the Summons and Complaint was served on the Registered Agent by tendering a copy of said documents to him personally at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on February 8, 2007. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
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 participant on or before the hour of 5:00 p.m. this 22nd day of February 2007:
Mr. Gerald Hartman, Registered Agent
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