Trustees of the Suburban Teamsters Welfare and Pension Funds v. The E Company, an Illinois corporation et al

Filing 7

MOTION by Plaintiff Trustees of the Suburban Teamsters 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 TIlE NORThERN DISTRICT OF ILLINOIS
EASTERN DIVISION
IRUSTEES OFT! IF SUI3URI3AN TEAMSTERS
OF NORTHERN ILLINOIS WELFARE AND
PENSION FUNDS.
Plaintiffs,

)
)

v.

No.2013C810
Judge Lee

II IF B COMPANY.
an Illinois corporation and
WILLIAM EDMIER. individually,

)

Magistrate Judge Cole

)
Defendants.
MOTION FOR DEFAULT 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, 101 IN J. lOOMFY, ARNOLD AND KADJAN, and pursuant to FRCP 55 move
forjudgment in sum certain as stated n this Complaint and the supporting Affidavits
attached hereto. In support of its Motion. Plainti is state as follows:
Suit was flied on February 1,2013 for collection of delinquent contributions
plus attorneys’ fees, costs and interest under 29 U.S.C. II 32
%
2
(g)(
2.

Service upon THEE COMPANY, an Illinois corporation was made on the

Defendant on FebnLary 7,2013. and a copy of the proof of servke was filed with the cowl
on February 14, 2013.
3.

Service upon WILLIAM EDM1ER, Individually was made on the

Defendant on February 7,2013, and a copy of the proof of service was fled with the court
on February 14, 2013.

Defendants

4.

are

now

in

default on the co-siuned installment notes as to the

Complaint Count Ii (corporation) and Ill (inthvidual) and as supported b’ the attached
Aiiida its the

sums

due are:
S9.905.60 Defaulied Pension Fund installment
Sl03X8.36 Defaulted Welihre Fund installment
925.00 Attorneys tees
$414.00 Court costs
52L632.96

note pa’ menis
note payments

WI IIiRFEORE. Plaintiff prays for:
Entry ofjudgmcnt against Defendants. THE! E COMPANY, an Illinois

1.
corporation on

Count II

of the

Complaint and WILLIAM FDMIER. Individually, on Count

III of the Complaint, jointly and severally, and in favorof Plaintiffs, TRUSTEES OF THE
SUBURBAN TEAMSTERS OF NORThERN ILLINOIS WELFARE AND PENSION
FINDS

iii

the amount of $21632.96 as there is no just reason for delay in enforcement

under FRCP 54th).
1

Order Defendant TI IF F COMPANY, an Illinois corporation to produce its

hooks and records lbr the time period August. 2012 through the
da s as

to Count

I ut the Complaint and

at

present

time within DI

such time udgmcnt will he entered in the

amouni sho” n to he due on the audit.
lIu:SIEFS OF THE SLBLRBA\ IFANISTERS
OF NORTHERN IllINOIS \VELFARE ANI)
PENSION FUNDS
john .1. loome
ARNOlD AND KADJA\
203 N. LaSaile Sheet
Suite 1650
(Thicat2o. Illinois 60601
Tdphone No.: 5J2 235-04)5
Facsimile No.: (3 [2) 341-0438
Dated: March 7. 2015