Suburban Teamsters of Northern Illinois Welfare and Pension Funds, The v. Greer Excavating, Inc.

Filing 7

MOTION by Plaintiff Suburban Teamsters of Northern Illinois Welfare and Pension Funds, The for judgment (Attachments: # 1 Affidavit John J. Toomey, # 2 Affidavit Richard Siebert, # 3 Text of Proposed Order Judgment Order)(Toomey, John)

Suburban Teamsters of Northern Illinois Welfare and Pension Funds, The v. Greer Excavating, Inc.

Doc. 7 Att. 2

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TRUSTEES OF THE SUBURBAN TEAMSTERS ) OF NORTHERN ILLINOIS WELFARE AND ) PENSION FUNDS, ) ) Plaintiffs, ) ) Case No.: 2010 C 6844 v. ) ) Judge Sharon Johnson Coleman ) GREER EXCAVATING, INC. ) Magistrate Judge Gilbert an Illinois corporation ) ) Defendant. ) AFFIDAVIT RICHARD SIEBERT, upon being first duly sworn deposes and states as follows: 1. Affiant is employed by the Suburban Teamsters Welfare and Pension Fund

("Funds") as an auditor, is familiar with the Greer Excavating, Inc., an Illinois corporation audit ("Employer"), having examined its books and records to determine what amounts if any were due and owing the Funds, and is also familiar with the parties' agreement concerning contributions, liquidated damages and interest owed. 2. That an audit of Employer's books and records was performed on September 28,

2010 covering the period May, 2010 through August, 2010 and found to be owing: Pension Welfare 3. $13,979.28 $18,638.10

That Employer was given a copy of the audit and given notice of findings and has

made no effort to pay or settle. . 4. 5. That the audit including liquidated damages and interest totals $32,617.38. That Affiant suffers from no disability and can so testify and affirm such facts.

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