Administrative District Council 1 of Illinois of the International Union of Bricklayers and Allied Craftworkers, AFL-CIO v. Hagglund Masonry, Inc., et al

Filing 28

MOTION by Plaintiff Administrative District Council 1 of Illinois of the International Union of Bricklayers and Allied Craftworkers, AFL-CIO for judgment Plaintiff's Agreed Motion for Entry of Judgment (Attachments: # 1 Text of Proposed Order, # 2 Certificate of Service)(Bennett, Barry)

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ADMINISTRATIVE DISTRICT COUNCIL 1 OF ILLINOIS OF THE INTERNATIONAL UNION OF BRICKLAYERS AND ALLIED CRAFTWORKERS, AFL-CIO, Plaintiff, v. HAGGLUND MASONRY, INC., et al. Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) No. 09 C 2302 Judge Andersen Magistrate Judge Cox PLAINTIFF'S AGREED MOTION FOR ENTRY OF JUDGMENT Plaintiff Administrative District Council 1 of Illinois of the International Union of Bricklayers and Allied Craftworkers, AFL-CIO ("Union"), respectfully moves this Court for entry of judgment, in the form attached or otherwise, against Defendants Hagglund Masonry, Inc., and Arne Hagglund (together, "Defendants"), and in support states as follows: 1. This matter is a suit to enforce a labor arbitration award, with jurisdiction based on 29 U.S.C. 185. 2. The complaint seeks judgment against the Defendants, jointly and severally, for the damages assessed in the arbitration award, interest on those damages as provided in the arbitration award, and legal fees and costs incurred in the suit as also provided by the arbitration award; and the proposed judgment order provides for that relief. 3. Defendants recognize they are barred by the statute of limitations from challenging the arbitration award or resisting the Union's suit to enforce the award; and therefore Defendants' attorney, Joel D. Groenewold, Esq. has authorized the Union to state that the Defendants agree to this motion and to entry of judgment as requested. WHEREFORE, the Union respectfully asks that its motion be granted and that judgment be entered in its favor and against Defendants Hagglund Masonry, Inc., and Arne Hagglund, in the form attached or otherwise. Respectfully submitted, /s/ Barry M. Bennett Attorney for Administrative District Council 1 of Illinois of the International Union of Bricklayers and Allied Craftworkers, AFL-CIO Barry M. Bennett DOWD, BLOCH & BENNETT 8 South Michigan Avenue, 19th Floor Chicago, IL 60603 (312) 372-1361 F:\B -DC 1\Hagglund Masonry 09-2302\09.29.09 Filing\Agreed Motion FINAL.wpd -2-

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