Trustees of the Suburban Teamsters of Northern Illinois Welfare and Pension Funds v. Dan Jauregui Trucking, Inc.

Filing 26

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 Jose M. Colin, # 3 Text of Proposed Order Judgment Order)(Toomey, John)

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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 FUNDS, ) ) Plaintiffs, ) ) No. 2017 C 3006 v. ) ) Judge Sharon Johnson Coleman ) DAN JAUREGUI TRUCKING, INC., ) Magistrate Finnegan an Illinois corporation, ) ) Defendant. ) MOTION FOR JUDGMENT IN SUM CERTAIN NOW COME the Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUND, by and through its attorney, JOHN J. TOOMEY, ARNOLD AND KADJAN, and pursuant to FRCP 55 move for judgment in sum certain as stated in this Motion and the supporting Affidavits attached hereto. In support of its Motion, Plaintiffs state as follows: 1. Suit was filed on April 21, 2017 for collection of delinquent contributions plus attorneys’ fees, costs and interest under 29 U.S.C. 1132(g)(2). 2. Service was made upon DAN JAUREGUI TRUCKING, INC., an Illinois corporation on May 8, 2017. 3. Defendant is now in default on the Complaint and as supported by the attached Affidavits the sums due are: $45,493.67 $38,054.10 $7,437.50 $916.95 $91,902.22 Welfare Pension Attorneys fees Court costs WHEREFORE, Plaintiffs pray for: 1. Entry of judgment against Defendant, DAN JAUREGUI TRUCKING, INC. an Illinois corporation, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS in the amount of $91,902.22. TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS s/John J. Toomey ARNOLD AND KADJAN, LLP 35 E. Wacker Drive, Suite 600 Chicago, IL 60601 Telephone No.: (312) 236-0415 Facsimile No.: (312) 341-0438 Dated: February 8, 2018 2

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