Fox Valley & Vicinity Construction Workers Welfare Fund et al v. RNR Trucking, Inc. et al

Filing 14

MOTION by Plaintiffs Fox Valley & Vicinity Construction Workers Pension Fund, Fox Valley & Vicinity Construction Workers Welfare Fund, Lake County, Illinois, Plasterers & Cement Masons Retirement Savings Fund for judgment (Chapman, Catherine)

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

FOX VALLEY & VICINITY CONSTRUCTION
WORKERS WELFARE FUND, et al.,
Plaintiffs,
vs.
RNR TRUCKING, INC., an Illinois corporation,
RICK RAMOS, individually,
Defendants.

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CIVIL ACTION
NO. 17 C 3384
JUDGE THOMAS M. DURKIN

MOTION FOR ENTRY OF JUDGMENT
Plaintiffs, by and through their attorneys, default having been entered against
Defendant, RNR TRUCKING, INC., an Illinois corporation, on July 31, 2017, request this Court
enter judgment against Defendant, RNR TRUCKING, INC. In support of its Motion, Plaintiffs state:
1.

On July 31, 2017, this Court entered default against Defendant, RNR Trucking, Inc.,

and granted Plaintiffs’ requests for orders directing an audit of the Defendant’s payroll books and
records for September 2015 through February 2017 and for a wage and welfare bond in the amount
of $25,000. The Court also entered an order that judgment would be entered after the completion
of the audit.
2.

Plaintiffs’ auditors completed the audit on August 22, 2017 and found Defendant,

RNR Trucking, Inc., to be compliant in its reporting obligations. (See Affidavit of David A.
Dorfman).

3.

Defendant submitted its monthly fringe benefit contribution report for June 2016

indicating $3,606.00 in contributions due and owing. Defendant only remitted payment of
$3,171.48, thereby resulting in an underpayment of $434.52.
4.

Plaintiffs no longer require Defendant, RNR Trucking, Inc., to obtain a wage and

welfare bond in the amount of $25,000.00.
5.

Plaintiffs’ firm has expended $695.00 in costs and $2,210.50 in attorneys’ fees to

obtain compliance with Defendant’s audit obligation and payment for contributions due for the
month of June 2016, for a total of $2,905.50, in this matter. (See Affidavit of Catherine M.
Chapman).
6.

Based upon the documents filed herewith, Plaintiffs request entry of judgment in the

total amount of $3,340.02.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of
$3,340.02.

/s/ Catherine M. Chapman

Catherine M. Chapman
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\Fvcwj\RNR Trucking\motion-judgment.cmc.df.wpd

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CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she 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 28th day of
September 2017:
Mr. Rick Ramos, Registered Agent
RNR Trucking, Inc.
3185 S. Hadden Road
Mazon, IL 60444-6074

/s/ Catherine M. Chapman

Catherine M. Chapman
Attorney for the Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6204026
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
I:\Fvcwj\RNR Trucking\motion-judgment.cmc.df.wpd