LakinChapman lawyer Andrew Kuhlmann seeks class action certification by default in a suit against Pekin Insurance.

Kuhlmann asked for default judgment in a motion for sanctions that he filed with Madison County Circuit Judge Barbara Crowder on Aug. 4.

"Defendants have not provided complete responses to plaintiffs' discovery requests and continue to engage in a pattern of obfuscation and gamesmanship," he wrote.

He asked Crowder to order Pekin to pay for class notice.

He asked her to set a hearing on class damages.

Though he alleged inadequate response, he pleaded excess response.

"Defendant has supplemented its document production to include a 'dump truck' production," he wrote.

"Defendant has purported to produce unlabeled electronic files of every single individual claim file with wholly irrelevant information other than an admission of its ability to identify members of the proposed class," he wrote.

"Furthermore, defendant has provided an unduly burdensome privilege log with over 46,000 unsubstantiated entries," he wrote.

He also claimed that a man Pekin identified as its most knowledgeable person turned out not to be the most knowledgeable.

He submitted exhibits to Crowder, under seal so taxpayers can't see them.

Bradley Lakin and Robert Schmieder II of LakinChapman placed their names on the motion, and so did Timothy Campbell of Godfrey.

Crowder set a hearing on Sept. 4.

Lakin lawyers sued Pekin in 2005, claiming it didn't deliver benefits it promised for joining a preferred provider organization.

LakinChapman clients Frank Bemis, Dale Fischer and Richard Kaltenbronn, all local chiropractors, seek certification as class representatives.

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