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1IN THE CIRCUIT COURT

TWENTIETH JUDICIAL CIRCUIT


ST. CLAIR COUNTY, ILLINOIS

Mark R. McCoy, )
)
Plaintiff, )
)
-VS- )
) Case No. 10 L 75
CITY OF FAIRVIEW HEIGHTS, a )
municipal corporation, JOSHUA )
ALEMOND, and AARON NYMAN )
)
Defendants. )

PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT

NOW comes the Plaintiff, Mark R. McCoy, and hereby moves

this court for entry of default against Defendant(s), CITY OF

FAIRVIEW HEIGHTS, a municipal corporation, JOSHUA ALEMOND, AND

AARON NYMAN.

As grounds for this motion, Plaintiff states that

Defendant(s) have not filed an answer or otherwise plead to

Plaintiff’s Amended Complaint in the time required by law.

Attached to this motion is Plaintiff’s supporting affidavit,

which is based on the record in this action.

Mark McCoy, Plaintiff

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Date

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STATE OF ILLINOIS )
) SS
COUNTY OF ST. CLAIR )

CERTIFICATE OF SERVICE

I, the undersigned, on oath state that I served the forgoing PLAINTIFF’S MOTION FOR
DEFAULT JUDGMENT for Case No.: 10 L 75 to the following person(s):

Joshua S. Abern
O’Halloran Kosoff Geitner & Cook, LLC
650 Dundee Road, Suite 475
Northbrook, Illinois 60062
jabern@okgc.com

and

Dawn A. Sallerson
Hinshaw & Culbertson, LLP
P.O. Box 509
521 West Main Street
Belleville, Illinois 62222
dsallerson@hinshawlaw.com

and

Clerk of the Circuit Court


St. Clair County Courthouse
10 Public Square
Belleville, Illinois 62220

via email (courtesy notice) and U.S. Mail by placing true and correct copies of the same in an
envelope(s) addressed as set forth above and entrusting the receipt and care of said envelope(s)
with a desk clerk at the U.S. Post Office in Collinsville, Illinois, 62234 on July 17, 2010.

Mark R. McCoy, Plaintiff

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