Opinion
Civil Action 24 C 120
06-27-2024
CHICAGO AREA JOINT WELFARE COMMITTEE FOR THE POINTING, CLEANING AND CAULKING INDUSTRY, LOCAL 52, et al., Plaintiffs, v. R.E.A. MASONRY, LLC, an Illinois limited liability company, Defendant.
Destiny A. Collins, Attorneys for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
Destiny A. Collins, Attorneys for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
MOTION FOR ENTRY OF JUDGMENT AND FOR AN ORDER DIRECTING DEFENDANT TO TURN OVER ITS MONTHLY FRINGE BENEFIT CONTRIBUTION REPORTS FOR APRIL 2024 FORWARD
JOHN F. KNESS, JUDGE
Plaintiffs, by and through their attorneys, default having been entered against the Defendant on June 17, 2024 [Dkt. No. 12], request this Court enter judgment against Defendant, R.E.A. MASONRY, LLC., an Illinois limited liability company, pursuant to F.R.Civ.P. Rule 55(b). In support of this Motion, Plaintiffs state:
1. On June 17, 2024, this Court entered default against Defendant.
2. Plaintiff Funds' received Defendant's monthly fringe benefit contribution reports for the time period January 2024 through March 2024. These reports indicate Defendant is delinquent in contributions to the Funds in the total amount of $12,897.90. (See Affidavit of John V. Kallianis).
3. Additionally, the amount of $1,289.79 is due for liquidated damages. (Kallianis Aff. Par. 5).
4. Defendant has failed to submit its monthly fringe benefit contribution reports for the months of April 2024 forward.
5. In addition, Plaintiffs' firm has expended $705.00 for costs and $722.75 for attorneys' fees in this matter. (See Affidavit of Catherine M. Chapman).
6. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $15,615.44.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $15,615.44.
Plaintiffs further request that this Court enter an order directing Defendant to submit its monthly fringe benefit contribution reports for the months of April 2024 forward within fourteen (14) days of the entry of the Order, and that the Court enter final judgment against Defendant after Plaintiffs determine all amounts due and owing from Defendant.