Suburban Teamsters of Northern Illinois Welfare and Pension Funds, The v. Veldhuizen Motor Service, Inc.

Filing 6

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

Suburban Teamsters of Northern Illinois Welfare and Pension Funds, The v...izen Motor Service, Inc.

Doc. 6

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 6892 v. ) ) Judge Der-Yeghiayan ) VELDHUIZEN MOTOR SERVICE, INC., ) Magistrate Judge Schenkier an Illinois corporation ) ) Defendant. ) MOTION FOR JUDGMENT IN SUM CERTAIN NOW COMES the Plaintiff, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUND, by and through its attorney, JOHN J. TOOMEY, ARNOLD AND KADJAN, and pursuant to FRCP 55 move for judgment in sum certain as stated in this Complaint and the supporting Affidavits attached hereto. In support of its Motion, Plaintiffs state as follows: 1. Suit was filed on October 26, 2010 for collection of delinquent

contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2). 2. Service upon VELDHUIZEN MOTOR SERVICE, INC., an Illinois

corporation was made on the Defendant on November 11, 2010, and a copy of the proof of service was filed with the court on November 18, 2010. 3. Defendant is now in default as to the Complaint and as supported by the

attached Affidavits the sums due are: $10,997.35 $20,469,80 $925.00 $458.00 $32,850.15 Pension Welfare Attorneys fees Court costs

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WHEREFORE, Plaintiff prays for: 1. Entry of judgment against Defendant, VELDHUIZEN MOTOR SERVICE,

INC., an Illinois corporation, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS in the amount of $32,850.15. TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS s/John J. Toomey ARNOLD AND KADJAN 19 W. Jackson Blvd., Suite 300 Chicago, IL 60604 Telephone No.: [phone] Facsimile No.: [phone] Dated: December 3, 2010

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