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
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