Iron Workers' Mid-America Pension Plan et al v. Krall

Filing 21

MOTION by Plaintiffs Joseph J. Burke, Iron Workers' Mid-America Pension Plan, Iron Workers' Mid-America Supplemental Monthly Annuity (SMA) Fund for judgment (Ryan, Patrick)

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

IRON WORKERS’ MID-AMERICA
PENSION PLAN, et al.,
Plaintiffs,
vs.
CHRISTOPHER KRALL, d/b/a H-H
IRONWORKS, LLC,
Defendant.

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CIVIL ACTION
NO. 15 C 3058
JUDGE MILTON I. SHADUR

MOTION FOR ENTRY OF JUDGMENT
Plaintiffs, by and through their attorneys, default having been entered against the Defendant
on May 27, 2015, request this Court enter judgment against Defendant, CHRISTOPHER KRALL,
d/b/a H-H IRONWORKS, LLC. In support of that Motion, Plaintiffs state:
1.

On May 27, 2015, this Court entered default against Defendant and granted Plaintiffs’

request for an order directing Defendant to turn over its monthly fringe benefit contribution reports
for October 2014 forward. The Court also entered an order that judgment would be entered after
Plaintiffs determined the amount due and owing from Defendant.
2.

In early September 2015, Defendant submitted its monthly fringe benefit contribution

reports for October 2014 through August 2015. The contribution reports show that the Defendant
is delinquent in contributions to the Funds for October 2014 through January 2015 and March 2015
through August 2015 in the amount of $62,128.37. (See Affidavit of Joseph J. Burke).

3.

Additionally, the amount of $9,236.77 is due for liquidated damages for the time

period May 2014 through January 2015 and March 2015 through August 2015. (Burke Aff. Paras.
3(b) and 4).
4.

In addition, Plaintiffs’ firm has expended $556.00 for costs and $2,390.25 in

attorneys’ fees 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 $74,311.39.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of
$74,311.39.

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6278364
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that he electronically filed the
foregoing document (Motion for Entry of Judgment) 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 30th day of
November 2015:
Mr. Christopher Krall
H-H Ironworks, LLC
124 Zapata Lane
Minooka, IL 60447

/s/ Patrick N. Ryan

Patrick N. Ryan
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6278364
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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