Northern Illinois Electrical Joint Apprenticeship & Training Trust Fund et al v. Lee County Electric, Inc.

Northern District of Illinois, ilnd-1:2016-cv-05670

MOTION by Plaintiffs Administrative Maintenance Fund (AMF), Joint Safety Committee, Labor-Management Cooperation Committee, Local Union 364, International Brotherhood of Electrical Workers, NECA-IBEW National Labor-Management Cooperation Committee, N ational Electrical Benefit Fund (NEBF), Northern Illinois Electrical Joint Apprenticeship & Training Trust Fund, Substance Abuse Testing Fund for entry of default, MOTION by Plaintiffs Administrative Maintenance Fund (AMF), Joint Safety Comm ittee, Labor-Management Cooperation Committee, Local Union 364, International Brotherhood of Electrical Workers, NECA-IBEW National Labor-Management Cooperation Committee, National Electrical Benefit Fund (NEBF), Northern Illinois Electrical Joint Apprenticeship & Training Trust Fund, Substance Abuse Testing Fund for judgment

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Case: 1:16-cv-05670 Document #: 11 Filed: 09/01/16 Page 1 of 2 PageID #:20 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION NORTHERN ILLINOIS ELECTRICAL JOINT) APPRENTICESHIP & TRAINING TRUST FUND,) et al.,)) CIVIL ACTION Plaintiffs,)) NO. 16 C 5670 vs.)) JUDGE REBECCA R. PALLMEYER LEE COUNTY ELECTRIC, INC., an Illinois) corporation,)) Defendant.) MOTION FOR ENTRY OF DEFAULT AND JUDGMENT NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, LEE COUNTY ELECTRIC, INC., an Illinois corporation, in the total amount of $21,261.26, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $2,862.00. On June 15, 2016, the Summons and Complaint was served on the Registered Agent/Presi- dent (by tendering a copy of said documents to Lisa Fitzimmons) at his place of business/residence (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on July 6, 2016. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment. /s/ Patrick N. Ryan Case: 1:16-cv-05670 Document #: 11 Filed: 09/01/16 Page 2 of 2 PageID #:21 CERTIFICATE OF SERVICE The undersigned, an attorney of record, hereby certifies that he 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 1st day of September 2016: Mr. Thomas J. Fitzsimmons, Registered Agent Lee County Electric, Inc. 1405 Ann Avenue Dixon, IL 61021 /s/ Patrick N. Ryan Patrick N. Ryan Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD. 200 West Adams Street, Suite 2200 Chicago, IL 60606-5231 Bar No.: 6278364 Telephone: (312) 216-2573 Facsimile: (312) 236-0241 E-Mail: pryan@baumsigman.com I:\364J\Lee County Electric\motion for entry of default and judgment.pnr.df.wpd