Central States, Southeast and Southwest Areas Pension Fund et al v. Wingra Stone Company

Filing 60

MOTION by Plaintiffs Arthur H. Bunte, Jr, Central States, Southeast and Southwest Areas Pension Fund for judgment Agreed (Attachments: # 1 Exhibit 1)(Napoli, Anthony)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CENTRAL STATES, SOUTHEAST AND
SOUTHWEST AREAS PENSION FUND;
and ARTHUR H. BUNTE, JR., as Trustee,
Plaintiffs,
v.
WINGRA STONE COMPANY,
a Wisconsin corporation,
Defendant.

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Case No. 11 C 6263
Honorable Charles P. Kocoras
District Judge

PARTIES’ AGREED MOTION FOR ENTRY OF JUDGMENT
FOR ATTORNEYS’ FEES AND COSTS
Plaintiffs, Central States, Southeast and Southwest Areas Pension Fund and
Arthur H. Bunte, Jr., as trustee, by and through their undersigned counsel, hereby move
the Court to enter a judgment for attorneys’ fees and costs in favor of Plaintiffs and
against Defendant Wingra Stone Company. In support of thereof, Plaintiffs state as
follows:
1.

On February 26, 2013, the Court entered final judgment in favor of

Plaintiffs and against Defendant Wingra Stone Company in the amount of $90,061.87,
plus an award of attorneys’ fees and costs pursuant to 29 U.S.C. §1132(g)(2)(D).
2.

Pursuant to Local Rules 54.1 and 54.3, the parties have consulted on the

reasonableness of the attorneys’ fees and costs sought by Plaintiffs.
3.

Plaintiffs and Defendant have agreed to the entry of a judgment for

attorneys’ fees and costs against Defendant and in favor of Plaintiffs.

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4.

A copy of the proposed Judgment For Attorneys’ Fees and Costs is

attached hereto as Exhibit 1 for the Court’s review, and will also be submitted
electronically to the Court’s e-mail address for proposed orders.
WHEREFORE, Plaintiffs respectfully request that the Court enter the Consent
Judgment attached hereto as Exhibit 1.
Respectfully submitted,
_/s/ Anthony E. Napoli______________
Anthony E. Napoli
Attorney for Central States, Southeast
and Southwest Areas Pension Fund
9377 W. Higgins Road, 10th Floor
Rosemont, Illinois 60018-4938
847/518-9800, Ext. 3702
ARDC # 06210910
[e-mail]

May 3, 2013

Respectfully submitted,
/s/ Robert S. Driscoll
Robert S. Driscoll
Attorney for Defendant
Reinhart Boerner Van Deuren s.c.
1000 North Water Street
Suite 1700
Milwaukee, Wisconsin 53202
[phone]

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CERTIFICATE OF SERVICE
I, Anthony E. Napoli, one of the attorneys for Plaintiffs certify that on May 3,
2013, I caused the foregoing Parties’ Agreed Motion For Entry Of Judgment For
Attorneys’ Fees And Costs to be filed electronically. This filing was served upon all
parties indicated on the electronic filing receipt via the Court’s electronic filing system.

/s/ Anthony E. Napoli______________
Anthony E. Napoli
One of Central States' Attorneys

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