January 13, 2014
IRON WORKERS' MID-AMERICA PENSION PLAN, et al., Plaintiffs,
CONSOLIDATED STEEL AND SUPPLY CO., a Delaware corporation, Defendant.
MOTION FOR ENTRY OF DEFAULT AND JUDGMENT
CHARLES R. NORGLE, Sr., District Judge.
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, CONSOLIDATED STEEL AND SUPPLY CO., a Delaware corporation, in the total amount of $19, 019.21, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $4, 876.75.
On October 8, 2013, the Alias Summons and Complaint was served on the President by tendering a copy of said documents to him personally at his residence (a copy of the Alias Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on October 29, 2013. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.