Opinion
No. 11 CV 3070
09-13-2011
BOARD OF TRUSTEES OF THE NORTHERN ILLINOIS BENEFIT FUND, BOARD OF TRUSTEES OF THE NORTHERN ILLINOIS PENSION FUND, BOARD OF TRUSTEES OF THE NORTHERN ILLINOIS EDUCATION FUND, BOARD OF TRUSTEES OF THE NORTHERN ILLINOIS RETIREMENT FUND, Plaintiffs, v. GURTNER PLUMBING, INC., an Illinois corporation, Defendant.
Andrew S. Pigott One of their attorneys
Judge
Magistrate Judge Mason
MOTION FOR JUDGMENT IN SUM CERTAIN
Plaintiffs, by their attorneys, DONALD D. SCHWARTZ, ANDREW S. PIGOTT, and ARNOLD & KADJAN, respectfully request this Honorable Court to enter an Order for Judgment in favor of Plaintiffs and against Defendant, Gurtner Plumbing, Inc.
In support thereof, Plaintiffs state:
1. This case was filed on May 9, 2011, including the First Amended Complaint.WHEREFORE, Plaintiffs pray for:
2. Plaintiffs served Defendant with Summons and the First Amended Complaint on July 7, 2011.
3. In excess of 20 days passed after Service of Process without Defendant filing an answer or otherwise pleading, so that this Court entered an Order of Default on August 16, 2011.
4. Per the affidavit of Albert Rinella, auditor for the Northern Illinois Benefit Funds, Defendant owes the Funds $14,263.61, consisting of $12,273.51 in delinquent fringe benefit contributions, $1,227.35 in liquidated damages, and $762.75 in audit costs. (Exhibit A).
5. Per the affidavit of Andrew S. Pigott, attorney for Plaintiffs, Plaintiffs have incurred $6,850.00 in legal fees and costs in this suit. (Exhibit B).
A. Entry of Judgment against Defendant in the amount of $21,113.61.
Respectfully submitted,
TRUSTEES OF THE NORTHERN
ILLINOIS BENEFIT FUNDS
Andrew S. Pigott
One of their attorneys
Donald D. Schwartz
Andrew S. Pigott
ARNOLD & KADJAN