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

Filing 9

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

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. ANCHOR MASONRY, INC., Defendant. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 09 C 6833 Judge Kocoras

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 Defendant Anchor Masonry, Inc. ("Company"), 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 Company enforcing an arbitration

award that requires it to provide the Union with a $15,000.00 bond in the required form, or to pay $15,000.00 to the Union to serve as a cash bond; to cease all work within the geographic and craft jurisdiction of the Union, regardless of the name or business form under which it performs such work, until it provides the bond or cash bond; and to reimburse the Union's legal fees and costs in enforcing the arbitration award.

3.

The Company realizes it is barred by the statute of limitations from challenging

the arbitration award or resisting the Union's suit to enforce the award; and therefore its attorney, Michael W. Duffee, Esq. has authorized the Union to state that the Company agrees 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 Defendant Anchor Masonry, Inc., 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 [phone]
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