Trustees of the Plumbers and Pipefitters Union Local 525 Health and Welfare Trust and Plan et al v. All Seasons Interior & Exterior Maintenance

Filing 13

CONSENT JUDGMENT in favor of Trustees of the Plumbers and Pipefitters Local Union 525 Apprentice and Journeyman Training Trust for Southern Nevada, Trustees of the Plumbers and Pipefitters Union Local 525 Health and Welfare Trust and Plan, Trustees of the Plumbers and Pipefitters Union Local 525 Pension Plan against All Seasons Interior & Exterior Maintenance. Signed by Judge Gloria M. Navarro on 6/4/12. (Copies have been distributed pursuant to the NEF - ECS)

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Adam P. Segal, Esq.
Nevada Bar No. 6120

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Aaron B. Fricke, Esq.
Nevada Bar No. 11129

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BROWNSTE1N HYATT FARBER SCHRECK, LLP
100 N. City Parkway, Suite 1600

Las Vegas, Nevada 89106
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Kg
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TRUSTEES OF THE PLUMBERS AND
PIPEFITTERS UNION LOCAL 525
HEALTH AND WELFARE TRUST AND

CASE NO.

2:12-cv-00620-GMN-RJJ

PLAN; TRUSTEES OF THE PLUMBERS
AND PIPEFITTERS UNION LOCAL 525

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PENSION PLAN; AND THE TRUSTEES

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OF PLUMBERS AND PIPEFITTERS
LOCAL UNION 525 APPRENTICE AND

STIPULATED/CONSENT JUDGMENT

JOURNEYMAN TRAINING TRUST FOR

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SOUTHERN NEVADA,
Plaintiffs,

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£§
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vs.

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ALL SEASONS INTERIOR & EXTERIOR

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PLUMBING, a Nevada corporation,

MAINTENANCE, dba GREAT BASIN

CQ

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Defendant.

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ALL SEASONS INTERIOR & EXTERIOR MAINTENANCE, dba GREAT BASIN
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PLUMBING, a Nevada corporation ("All Seasons"), hereby stipulates and consents to entry of
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judgment in favor of Plaintiffs, Trustees of the Plumbers and Pipefitters Union Local 525 Health
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and Welfare Trust, the Trustees of the Plumbers and Pipefitters Union Local 525 Pension Plan,
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and the Trustees of the Plumbers and Pipefitters Local Union 525 Apprentice and Journeyman
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Training Trust for Southern Nevada (collectively "Trust Funds), and against ALL SEASONS in
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the total sum of $416,506 for delinquent employee benefit contributions and related costs and fees

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owed underthe Employee Retirement Income Security Act of 1974 ("ERISA").

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The parties have stipulated and therefore the Court finds:

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1.

ALL SEASONS is signatory to and bound by the terms of a collective bargaining

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agreement ("CBA") with the Plumbers and Pipefitters Union Local 525 ("Union"), in which ALL

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SEASONS agreed to abide by the trust agreements establishing the respective Trust Funds and

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any amendments thereto ("Trust Agreements").

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2s
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a

Under the CBA and the Trust Agreements, ALL SEASONS is obligated to pay

employee benefit contributions to the Trust Funds on behalf of ALL SEASONS's bargaining unit
employees represented by the Union.

3.

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Based on a contract compliance review of ALL SEASONS conducted for the

ECS

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£**&

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ALL SEASONS for the period of April 1, 2009, through April 30, 2011, ALL SEASONS owes

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period June 1, 2006, through March 31, 2009, and remittance reports prepared and submitted by

the Trust Funds Four Hundred Eleven Thousand Five Hundred Six Dollars ($411,506) in

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employee benefit contributions, fees, interest and liquidated damages to date.
4.

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In addition, in the event this judgment must be executed, the Trust Funds will incur

Wo

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additional fees and costs determined by the parties to be at least $5,000, which are therefore

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included herein.

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This Stipulated/Consent Judgment is entered into by and between ALL SEASONS

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and the Trust Funds for employee benefit contributions and related costs and fees owed to the

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Trust Funds by ERISA.

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June J3 ,,2011.

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fjjL **«««

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»2011.

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BROWNSTEIN HYATT FARBER
SCH1

ALL SEASONS INTERIOR & EXTERIOR

MAINTENANCE, dba GREAT BASIN

[BING*/aNev£da> corporation,

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Adam Pv Segal, Esq.
Nevada Bar No. 6120

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Aaron B. Fricke, Esq.
Nevada Bar No. 11129

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100 N. City Parkway, Suite 1600
Las Vegas, Nevada 89106
Telephone: [phone]
Facsimile: [phone]

Telephone:

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Attorneys for the Trust Funds

PLUMBING, a Nevada corporation,

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Facsimile:

For ALL SEASONS INTERIOR & EXTERIOR

MAINTENANCE, dba GREAT BASIN

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JUDGMENT

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si

**

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Judgment is hereby entered against ALL SEASONS INTERIOR & EXTERIOR

CO

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MAINTENANCE, dba GREAT BASIN PLUMBING, a Nevada corporation, and in favor of the

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Trust Funds in the amount of $416,506.

i—

oi
00

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DATED this 4th day of June, 2012.
Dated this

day of.

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________________________________
Gloria M.DISTRICT COURT JUDGE
U.S. Navarro
United States District Judge

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Case 2:12-cv-00620-GMN -RJJ Document 1

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STATE OF NEVADA

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COUNTY OF

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)
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Hdflw) g KAjQ^S.

,being first duly sworn, deposes and says:

That/he/she is the OujAEGL

of ALL SEASONS INTERIOR & EXTERIOR

MAINTENANCE, dba GREAT BASIN PLUMBING, a Nevada corporation, and is duly

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authorized to execute this document; that he/she has read the foregoing Stipulated/Consent

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Judgment and knows the contents thereof; that the same is true of his/her own knowledge, except

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for those matters therein stated on information and belief, and as to those matters he/she believes

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them to be true.

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QJvo

Sis

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Subscribed and sworn to before me

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this O^ day of ^oki . . 2011.
riM^Mffc***

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mwrnxst

Homy fWMiCi SMi of Mtli-Oi
ug

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My Appt. fxfim Apr 15.261* |

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^^•V*WatV^»*»'

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