Anderson et al v. Metropolitan Glass & Mirror, Inc. et al

Filing 13

MOTION by Plaintiffs Northern Illinois Painters, Decorators and Drywall Finishers Joint Apprenticeship and Training Fund, Donald Steadman, Northern Illinois Painting and Drywall Institute, District Council No. 30 of The International Union of Painters and Allied Trades, AFL-CIO, Charles E. Anderson, Painters' District Council No. 30 Health and Welfare Fund, Painters District Council No. 30 Pension Fund for judgment Joint Motion for Entry of Consent Judgment (Hohimer, Mark)

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CHARLES E. ANDERSON, et. al., Plaintiffs, v. METROPOLITAN GLASS & MIRROR, INC., an Illinois Corporation, and BRADLEY WESTON in his individual capacity, and JENNIFER WESTON in her individual capacity, Defendants. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 09 CV 224 Judge William J. Hibbler

JOINT MOTION FOR ENTRY OF A CONSENT JUDGMENT The parties hereby jointly move this honorable Court for entry of a consent judgment conforming to the terms and conditions stipulated to in the attached Consent Judgment, and state the following in support: 1. Plaintiffs filed this action on January 13, 2009, in order collect delinquent

employee benefit fund contributions, assessments, and Union dues; 2. Defendants were all served on January 14, 2009, and the executed summonses

were filed with the Clerk on January 22, 2009; 3. 4. Defendants' attorney has filed an appearance, but no answer has been filed; The parties have discussed and reached settlement with regards to all outstanding

amounts, including interest, liquidated damages, audit costs, attorneys' fees, and court costs; 5. The agreed terms and conditions of the settlement are provided in the attached

Consent Judgment signed by the parties' attorneys of record. (Ex. A)

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WHEREFORE, the parties respectfully request that this Court enter a consent judgment in favor of Plaintiffs and against Defendants jointly and severally in accordance with the attached Consent Judgment signed by the parties' attorneys of record.

Respectfully submitted, /s/ M. Garrett Hohimer___ M. Garrett Hohimer One of Plaintiff's Attorneys Marisel Hernandez M. Garrett Hohimer Jacobs, Burns, Orlove, Stanton and Hernandez 122 S. Michigan Avenue, Suite 1720 Chicago, IL 60603 [phone]

CERTIFICATE OF SERVICE I certify that on April 6, 2009, I electronically filed the foregoing JOINT MOTION TO ENTER A CONSENT JUDGMENT with the Clerk of the court using the CM/ECF system, which will provide electronic notification to the following attorneys of record:

Todd Abraham Miller Kathleen Marie Cahill

[e-mail] [e-mail]

/s/ M. Garrett Hohimer

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Exhibit A