Trustees of the Suburban Teamsters of Northern Illinois Welfare and Pension Funds v. Dan Jauregui Trucking, Inc.
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)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
TRUSTEES OF THE SUBURBAN TEAMSTERS )
OF NORTHERN ILLINOIS WELFARE AND
) No. 2017 C 3006
) Judge Sharon Johnson Coleman
DAN JAUREGUI TRUCKING, INC.,
) Magistrate Finnegan
an Illinois corporation,
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:
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).
Service was made upon DAN JAUREGUI TRUCKING, INC., an Illinois
corporation on May 8, 2017.
Defendant is now in default on the Complaint and as supported by the
attached Affidavits the sums due are:
WHEREFORE, Plaintiffs pray for:
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
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
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