Filed: Dec. 28, 2018
Latest Update: Dec. 28, 2018
Summary: MOTION FOR ENTRY OF DEFAULT AND JUDGMENT AND FOR AN ORDER DIRECTING DEFENDANT TO OBTAIN A WAGE AND WELFARE BOND OR CASH BOND JOHN J. THARP, JR. , District Judge . NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, LAW EXCAVATING, INC., an Illinois corporation, in the total amount of $1,882.58, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,818.25. Plaintiffs move for an order directing Defendant, LAW EXCAV
Summary: MOTION FOR ENTRY OF DEFAULT AND JUDGMENT AND FOR AN ORDER DIRECTING DEFENDANT TO OBTAIN A WAGE AND WELFARE BOND OR CASH BOND JOHN J. THARP, JR. , District Judge . NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, LAW EXCAVATING, INC., an Illinois corporation, in the total amount of $1,882.58, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,818.25. Plaintiffs move for an order directing Defendant, LAW EXCAVA..
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MOTION FOR ENTRY OF DEFAULT AND JUDGMENT AND FOR AN ORDER DIRECTING DEFENDANT TO OBTAIN A WAGE AND WELFARE BOND OR CASH BOND
JOHN J. THARP, JR., District Judge.
NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, LAW EXCAVATING, INC., an Illinois corporation, in the total amount of $1,882.58, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $1,818.25.
Plaintiffs move for an order directing Defendant, LAW EXCAVATING, INC., an Illinois corporation, to obtain and furnish to the Plaintiffs a wage and welfare bond or cash bond in the amount of $25,000.00, which has been determined by the Plaintiffs to be consistent with the anticipated future obligations of the Defendant, with reputable surety thereon and the Plaintiffs named as obligees thereunder.
On November 29, 2018, the Summons and Complaint was served on Defendant's Registered Agent (by tendering a copy of said documents to Chrystal R. Bingham, Secretary) at the registered office of record in Illinois (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on December 20, 2018. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default and judgment.
