Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731 et al v. J & T Services, Inc.

Filing 24

MOTION by Plaintiffs Joseph Benson, Dale Bolt, William H Collins, Terrence J Hancock, Health and Welfare Fund of the Excavating, Grading and Asphalt Craft Local No. 731, John J Lisner, Local 731, I.B. of T., Excavators and Pavers Pension Trust Fund, David M Snelten for judgment entry (Dunitz-Geiringer, Jennifer)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

TERRENCE J. HANCOCK, et al.,
Plaintiffs,
vs.
J & T SERVICES, INC.,
an Illinois corporation,
Defendant.

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CIVIL ACTION
NO. 11 C 7363
JUDGE JOAN H. LEFKOW

MOTION FOR ENTRY OF JUDGMENT
Plaintiffs, by and through their attorneys, default having been entered against the Defendant
on December 13, 2011, request this Court enter judgment against Defendant, J & T SERVICES,
INC., an Illinois corporation. In support of that Motion, Plaintiffs state:
1.

On December 13, 2011, this Court entered default against Defendant and granted

Plaintiffs’ request for an order directing an audit of the Defendant’s payroll books and records. The
Court also entered an order that judgment would be entered after the completion of the audit.
2.

Plaintiffs’ auditors completed that audit on April 18, 2012. The audit findings show

that the Defendant is delinquent in contributions to the Funds in the amount of $7,102.81. (See
Affidavit of Terrence J. Hancock).
3.

Additionally, the amount of $1,420.57 is due for liquidated damages and $737.89 is

due for interest. (Hancock Aff. Pars. 11, 12). Plaintiffs' auditing firm of Legacy Professionals, LLP
charged Plaintiffs $1,635.60 to perform the audit examination and complete the report (Hancock Aff.
Par. 13).

4.

In addition, Plaintiffs’ firm has expended the total amount of $2,303.75 in attorneys’

fees and $605.00 in costs in this matter. (See Affidavit of Catherine M. Chapman).
5.

Based upon the documents attached hereto, Plaintiffs request entry of judgment in the

total amount of $13,805.62.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of
$13,805.62.

/s/ Jennifer L. Dunitz-Geiringer

Jennifer L. Dunitz-Geiringer
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6237001
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\731exc\J & T Services\#23591\motion-judgment.jdg.df.wpd

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CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she electronically filed the
foregoing document (Motion) with the Clerk of Court using the CM/ECF system, and further
certifies that I have mailed the above-referenced document by United States Mail to the following
non-CM/ECF participant on or before the hour of 5:00 p.m. this 24th day of May 2012:
Mr. Tom Alberto, Registered Agent/President
J & T Services, Inc.
33W644 White Thorne Road
Wayne, IL 60184-2228

/s/ Jennifer L. Dunitz-Geiringer

Jennifer L. Dunitz-Geiringer
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6237001
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\731exc\J & T Services\#23591\motion-judgment.jdg.df.wpd