United Food And Commercial Workers International Union-Industry Pension Fund and its Trustees: et al v. Perkins Management Services Company, Inc. et al

Filing 16

MOTION by Plaintiff United Food And Commercial Workers International Union-Industry Pension Fund and its Trustees: for judgment AGREED MOTION TO ENTER CONSENT JUDGMENT AND ORDER (Attachments: # 1 Exhibit)(Huffman-Gottschling, David)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
__________________________________________
UNITED FOOD AND COMMERCIAL
)
WORKERS INTERNATIONAL UNION)
INDUSTRY PENSION FUND, et al.,
)
) Civil Action No. 17-cv-05839
Plaintiffs,
) District Judge Kocoras
v.
) Magistrate Judge Schenkier
)
PERKINS MANAGEMENT SERVICES
)
COMPANY, INC., et al.,
)
)
Defendants.
)
__________________________________________)
AGREED MOTION TO ENTER CONSENT JUDGMENT AND ORDER
Plaintiffs United Food and Commercial Workers International Union-Industry Pension
Fund and its Trustees (“Plaintiffs”) respectfully request that this Court enter the proposed
Consent Judgment and Order, attached hereto as Exhibit 1, and in support state as follows:
1.

Plaintiffs filed their Complaint against Defendants Perkins Management Services

Company, Inc., Perkins Management Services Operations, LLC, Perkins Restaurant
Development Company, LLC, N.M. Perkins Enterprises, Inc., Bolt Waste Management Services
Company, Perkins Gourmet Food Products, Inc., Perkins Agricultural Corporation, Perkins
Burger Ventures, LLC, PMSC Holdings, and Titan Food and Nutrition Services Company
(“Defendants”) on August 10, 2017.
2.

The parties have reached a settlement of this litigation. Pursuant to the settlement

agreement, Defendants have consented to judgment in the form of the Consent Judgment and
Order executed by the parties. (See Ex. 1. )
3.

Defendants consent to Plaintiffs moving this Court for entry of the Consent

1

Judgment and Order.
WHEREFORE, Plaintiffs respectfully request that the Court enter the attached Consent
Judgment and Order and order judgment against the Defendants, jointly and severally.
/s/ David Huffman-Gottschling
David Huffman-Gottschling, Esq.
[e-mail]
JACOBS, BURNS, ORLOVE & HERNANDEZ
150 North Michigan Avenue, Suite 1000
Chicago, IL 60601
Phone: [phone]
Fax: [phone]
Jeffrey S. Endick, Esq.
[e-mail]
Christopher M. Leins, Esq.
[e-mail]
SLEVIN & HART, P.C.
1625 Massachusetts Ave., N.W.,
Suite 450
Washington, DC 20036
Phone: [phone]
Fax: [phone]
Counsel for Plaintiffs

CERTIFICATE OF SERVICE
I, David Huffman-Gottschling, an attorney, certify that I caused a copy of the foregoing
document to be served upon the following person, who has acted as the representative of all
Defendants, by email and by first-class mail on October 13, 2017:
Fred Lane, Chief Administrative Officer
Perkins Management Services Co.
P.O. Box 35549
Charlotte, NC 28235
[e-mail]
/s/ David Huffman-Gottschling
David Huffman-Gottschling

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