Cent. States v. Moore Jaguar/Aston Martin, Inc.

Full title: CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS PENSION FUND; and HOWARD…

Court: UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Date published: Dec 8, 2011

Case No. 11 CV 2995 (N.D. Ill. Dec. 8, 2011)

Opinion

Case No. 11 CV 2995

12-08-2011

CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS PENSION FUND; and HOWARD McDOUGALL, as Trustee, Plaintiffs, v. MOORE JAGUAR/ASTON MARTIN, INC., a Missouri corporation, Defendant.

Timothy C. Reuter Attorney for Plaintiffs Central States, Southeast and Southwest Areas Pension Fund Rosemont, Illinois 60018-4938

William J. Hibbler

Judge

Magistrate Judge Nolan

AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT

Plaintiffs, the Central States, Southeast and Southwest Areas Pension Fund (the "Pension Fund") and Howard McDougall, one of its present Trustees, hereby move for entry of a consent judgment. In support thereof, Plaintiffs state:

1. On May 5, 2011, Plaintiffs filed this action in accordance with the provisions of the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. §1001 et seq., to recover monthly benefit contributions owed to the Pension Fund, in addition to accrued interest, liquidated damages and attorneys fees and costs.

2. The parties agree to the entry of the Consent Judgment attached hereto as Exhibit A, which has been signed by a representative of each of the parties.

3. On December 8, 2011, Plaintiffs' attorney consulted with, Nicholas Klumb one of the attorneys for Defendant, and he agreed to the filing of this Motion.

4. Therefore, Plaintiffs respectfully request the entry of the Consent Judgment attached hereto.

WHEREFORE, Plaintiffs respectfully request the Court to enter the proposed Consent Judgment.

Respectfully submitted,

Timothy C. Reuter

Attorney for Plaintiffs

Central States, Southeast and

Southwest Areas Pension Fund

Rosemont, Illinois 60018-4938

CERTIFICATE OF SERVICE

I, Timothy C. Reuter, one of the attorneys for the Central States, Southeast and Southwest Areas Pension Fund and Howard McDougall, trustee, certify that on December 8, 2011, I caused the foregoing Agreed Motion for Entry of Consent Judgment to be filed electronically. This filing was served on all parties indicated on the electronic filing receipt via the Court's electronic filing system.

Timothy C. Reuter

One of Central States' Attorneys