MOTION FOR PROVE-UP AND ENTRY OF JUDGMENT

THOMAS M. DURKIN, District Judge.

NOW COMES the Plaintiff, MACKIE CAMPILLO ("Plaintiff"), by the undersigned attorneys, bringing this Motion for Prove-Up and Entry of Judgment against the Defendant, STEVEN J. FINK & ASSOCIATES, P.C. ("Defendant") pursuant to Federal Rule of Civil Procedure 58, and in support there of, stating as follows:

Background

1. On August 23, 2014, Plaintiff filed the instant complaint against Defendant.

2. Plaintiff brings this action against Defendant for violation of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692, et seq. ("FDCPA"). Plaintiff alleges that Defendant violated the FDCPA § 1692i(a)(2) by improperly filing a debt collection lawsuit against Plaintiff in the First Municipal District of Cook County, a location in which Plaintiff neither resides nor signed the underlying contract. The lawsuit seeks statutory and actual damages.

3. Plaintiff seeks entry of a judgment amount against Defendant in the amount of $1,000.00 in statutory damages, plus $5,037.50 in costs and reasonable attorney fees as provided under 15 U.S.C. §1692k See Affidavit of Daniel J. McGarry, attached as Exhibit A.

WHEREFORE, Plaintiff MACKIE CAMPILLO, prays for an entry Judgment against Defendant, in the amount of $1,000.00 in statutory damages and $5,037.50 in costs and reasonable attorney fees.

AFFIDAVIT OF DANIEL J. MCGARRY

I, Daniel J. McGarry, have personal knowledge of the facts and information set forth herein, being first duly sworn on oath:

1. I am over the age of 21, under no legal disability, and if called and sworn as a witness in this cause, would competently testify as to the facts set forth in this Affidavit,

2. I have personal knowledge of the facts set forth in this Affidavit.

3. I graduated from law school in May 2011 and became licensed to practice law in the State of Illinois in 2012.

4. I have been practicing law for the last two (2) years.

5. Plaintiff Mackie Campillo hired my firm to prosecute this lawsuit.

6. I am personally acquainted with the cause of action herein and with the legal services provided by my firm.

7. The time of Daniel J. McGarry and all attorneys working on this matter are maintained in the following manner: at the time services are rendered, time is recorded in an accounting program within the firm's computer system and database.

8. Plaintiffs attorney and his firm completely performed the services reflected above.

9. The services performed were necessary in order for Daniel J. McGarry to properly represent his client

10. The time spent performing the services were reasonable in light of the difficulty of the services performed.

11. The hourly rate for the attorney who worked on this matter is $325.00 per hour. I am familiar with the range of hourly rates charged by attorneys in and around Northern Illinois. The rate charged per hour is fair and reasonable, and within the normal standards of the community for the type of services performed based upon the level of skill, expertise and experience of the attorney who performed the legal services.

12. The total amount of fees and costs incurred by Plaintiff for purposes of the above tasks are $5,037.50.

And further affiant sayeth naught,