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Terrence J. Hancock, et al v. Di Paolo Company

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION


September 20, 2012

TERRENCE J. HANCOCK, ET AL., PLAINTIFFS,
v.
DI PAOLO COMPANY, AN ILLINOIS CORPORATION, DEFENDANT.

The opinion of the court was delivered by: Judge John Z. Lee

PLAINTIFFS' MOTION FOR ENTRY OF DEFAULT, FOR AN ORDER DIRECTING DEFENDANT TO TURN OVER MONTHLY FRINGE BENEFIT CONTRIBUTION REPORTS AND FOR PARTIAL JUDGMENT

NOW COME Plaintiffs, by their attorneys, and move for entry of default and for an order directing DI PAOLO COMPANY, an Illinois corporation, Defendant herein, to turn over monthly fringe benefit contribution reports due for the months of March 2012 through the present, pursuant to the Agreements and Declarations of Trust to which Defendant is bound, said Defendant having failed to answer or otherwise plead to the Complaint and the monthly contribution reports being required in order to fully liquidate Plaintiffs' claims. Further, Plaintiffs move for entry of a partial judgment by default against Defendant, DI PAOLO COMPANY, an Illinois corporation, in the total amount of $42,417.23, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,745.00.

On August 8, 2012, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to Jane Latter) at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on August 29, 2012. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default.

CERTIFICATE OF SERVICE

The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion) 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 20th day of September 2012: Mr. Angelo Di Paolo, Registered Agent/President Di Paolo Company 4350 DiPaolo Center Glenview, IL 60025 /s/ Jennifer L. Dunitz-Geiringer Jennifer L. Dunitz-Geiringer Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6237001 Telephone: (312) 236-4316 Facsimile: (312) 236-0241 E-Mail: jdunitz.geiringer@baumsigman.com

20120920

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