Sullivan et al v. Thomas H. Litvin, Co.

Filing 26

MOTION by Plaintiffs James T. Sullivan, Plumbers' Pension Fund, Local 130, U.A., Plumbers' Welfare Fund, Local 130, U.A., Trust Fund for Apprentice and Journeymen Education and Training, Local 130, U.A.,The, Chicago Journeymen Plumbers' ; Local Union 130, U.A.., Group Legal Services Plan Fund, Plumbing Council of Chicagoland, The for judgment (conditional) against Third Party Citation Respondent, Bovis Lend Lease, Inc. (Attachments: # 1 Exhibit A through C)(Bedinghaus, Brian)

EXHIBIT A

EXHIBIT B

EXHIBIT C

Page 1 of 1

Bedinghaus, Brian T.
From: Sent: To: Bedinghaus, Brian T. Tuesday, November 18, 2008 5:05 PM '[e-mail]'

Subject: James T. Sullivan, etc., et al. v. Thomas H. Litvin Co.; Case No. 08 C 2904 Ms. Hatten: As we discussed in our telephone conversation this afternoon, I am an attorney and represent James T. Sullivan, Trustee of the Benefit Funds for the Chicago Journeymen Plumbers' Local Union 130. A judgment was entered in favor of the Benefit Funds and against Thomas H. Litvin Co. in the above captioned lawsuit in the United States District Court for the Northern District of Illinois. The amount of the judgment is $1,036,149.90. Thomas H. Litvin Co. was a subcontractor on several Bovis projects when it went out of business this summer. In an effort to enforce the Benefit Funds' judgment, I issued a Citation to Discover Assets to Bovis Lend Lease. The Citation requests that Bovis produce all documents in its possession that contain information regarding the assets, property, income or any indebtedness due or owed to Thomas H. Litvin Co. The Citation also requests that John Morley appear for a Citation examination after the requested documents are produced. Bovis was served with the Citation on September 11, 2008. After I did not receive a response from Bovis, I sent John Morley a letter on October 27, 2008, requesting a response. However, I still have not heard from Mr. Morley or from anyone else at Bovis. Copies of the Citation and my letter of October 27, 2008, are attached. Please forward the documents to Mr. Morley so that he may contact me directly or refer me to someone at Bovis who can better respond to the Citation. Thank you, Brian T. Bedinghaus Lewis Overbeck & Furman, LLP 20 N. Clark St., Suite 3200 Chicago, IL 60602 [phone] [e-mail]

2/9/2009