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

Filing 13

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. CHARLES PETERSON, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

No. 09 C 6945 Judge Kennelly

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 move this Court for entry of judgment, in the form attached or otherwise, against Defendant C.J.P. Masonry, Inc. ("CJP"), 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 arbitration award requires CJP to provide the Union with a $30,000.00 bond

in the required form, or to pay the Union $30,000.00 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 fees and costs the Union has incurred in this suit. 3. CJP recognizes the Union is entitled to judgment as requested; and therefore its

attorney, Burr E. Anderson, Esq., has authorized the Union's lawyer to state that CJP 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 C.J.P. 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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