Trustees of the Suburban Teamsters of Northern Illinois Welfare and Pension Funds v. Castillo Trucking, of Bourbonnais, Inc., an Illinois corporation et al

Filing 9

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

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 FUN]JS,
Plaintiffs,
V.

CAST[LLO TRUCKING, OF BOURBONNAIS,
INC., an Illinois corporation, and
FRANK M. CASTILLO, Individually,
Defendants.

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No. 2012C5097
Judge Bucklo

Magistrate Judge Denlow

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 Castillo Trucking, of Bourbonnais, 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 July 16, 2012

covering the period September, 2010 through April, 2012 and found to be owing:
Pension
Welfare
3.

$13,257.56
$5,892.81

That Employer was given a copy of the records review and given notice of

findings and has made no effort to pay or settle.
4.

That the audit including liquidated damages and interest totals $19,150.37.

5.

That Affiant suffers from no disability and can so testify and affirm such facts.

FURTHER AFFIANT SAYETH NOT.

RICHARD SIEBERT
SUBSCRIBED ANDJSWORN
to before me this
tIy\if
August, 2012.
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Notary

NOTARy P~SL~C - STAlE DF LJNOJ$
MY COMM~S5jQN EXPIRES:O7/20/15

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