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)

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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. davidhg@jbosh.com JACOBS, BURNS, ORLOVE & HERNANDEZ 150 North Michigan Avenue, Suite 1000 Chicago, IL 60601 Phone: (312) 327-3443 Fax: (312) 726-3887 Jeffrey S. Endick, Esq. jendick@slevinhart.com Christopher M. Leins, Esq. cleins@slevinhart.com SLEVIN & HART, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, DC 20036 Phone: (202) 797-8700 Fax: (202) 234-8231 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 flane@perkinsmanagement.com /s/ David Huffman-Gottschling David Huffman-Gottschling 2

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