Unite Here Health et al v. Starlight Events, LLC

Filing 18

MOTION by Plaintiffs Unite Here Health, Matthew Walker for judgment - Amended (Finnegan, Laura)

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

UNITE HERE HEALTH, et al.,
Plaintiffs,
vs.
STARLIGHT EVENTS, LLC, d/b/a SCORES,
at TRUMP TAJ MAHAL,
Defendant.

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CIVIL ACTION
NO. 14 C 9320
JUDGE ROBERT M. DOW, JR.

AMENDED MOTION FOR ENTRY OF JUDGMENT
Plaintiffs, by and through their attorneys, default having been entered against the Defendant
on June 30, 2015, request this Court enter judgment against Defendant, STARLIGHT EVENTS,
LLC, d/b/a SCORES, at TRUMP TAJ MAHAL. In support of that Motion, Plaintiffs state:
1.

On June 30, 2015, this Court entered default against Defendant and set the matter for

prove-up on August 12, 2015.
2.

On August 5, 2015, Plaintiffs filed its Motion for Entry of Judgment and set the

motion for hearing on August 12, 2015.
3.

On August 12, 2015, this Court entered and continued Plaintiffs’ Motion for Entry

of Judgment to September 15, 2015 at 9:15 a.m.
4.

Defendant submitted its monthly fringe benefit contribution reports for June 2015 and

July 2015 but failed to remit the contributions due in the amount of $14,498.69. (See Affidavit of
Dean Dailey).

5.

Defendant remitted its monthly fringe benefit contribution reports for the work

months of March 2015 through July 2015 but untimely remitted payment of the contributions due
thereon and accordingly has incurred accrued interest and liquidated damages calculated through
September 8, 2015 totaling $336.16.
6.

In addition, Plaintiffs’ firm has expended $1,090.00 in costs and $2,815.00 in

attorneys’ fees, for a total of $3,905.00, in this matter. (See Affidavit of Laura M. Finnegan).
7.

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

total amount of $18,739.85.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of
$18,739.85.

/s/ Laura M. Finnegan

Laura M. Finnegan
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6210637
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\HEREW\Starlight Events\motion (2).lmf.df.wpd

CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she electronically filed the
foregoing document (Amended Motion for Entry of Judgment) with the Clerk of Court using the
CM/ECF system, and further certifies that I have served the above-referenced document by facsimile
and US Mail to the following non-CM/ECF participant on or before the hour of 4:00 p.m. this 14th
day of September 2015:
Mr. Mark Yackow
Starlight Events, LLC
d/b/a at Scores at Trump Taj Mahal
1000 Boardwalk, 2nd Floor
Atlantic City, NJ 08401
[e-mail]

/s/ Laura M. Finnegan

Laura M. Finnegan
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6210637
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\HEREW\Starlight Events\motion (2).lmf.df.wpd