Trustees of the Chicago Regional Council of Carpenters Pension Fund et al v. Consolidated Workforce, Inc.

Filing 36

MOTION by Plaintiffs Trustees of the Chicago Regional Council of Carpenters Pension Fund, Chicago Regional Council of Carpenters Welfare Fund, Chicago Regional Council of Carpenters Apprentice & Trainee Program Fund for judgment consent, and Reinstatement (Attachments: # 1 Exhibit A)(Lichtman, David)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Trustees of the Chicago Regional Council Of Carpenters Pension Fund, etc., et al, Plaintiffs, ­ vs ­ Consolidated Workforce, Inc., Defendant. ) ) ) ) ) ) ) ) ) )

08 CV 5689 Judge Manning Magistrate Judge Schenkier

AGREED MOTION FOR REINSTATEMENT AND FOR CONSENT JUDGMENT Plaintiffs, by its attorney, David P. Lichtman, move this Honorable Court to reinstate this case and enter judgment and in support state: 1. 2. 3. This is an ERISA trust fund case for delinquent contributions. On June 4, 2009, this case was dismissed with leave to reinstate. The parties have agreed that the Defendant will turnover the sum of

$33,707.44 to the Plaintiffs and to the entry of judgment against the Defendant and in favor of the Plaintiffs in the amount of $76,875.24 . WHEREFORE, the parties pray that this case be reinstated and that the attached proposed consent judgment (Exhibit A) be entered against the Defendant in the amount of $76,875.24. Respectfully submitted, /s/ David P. Lichtman Attorney for the Plaintiffs David P. Lichtman Attorney No. 6290051 Whitfield McGann & Ketterman 111 E. Wacker Drive Suite 2600 Chicago, IL 60601 [phone] Fax [phone]