Opinion
22 CV 5754
06-14-2023
Michael J. McGuire Attorney for Plaintiffs Marco, McGuire & Arreola, LLC
Michael J. McGuire Attorney for Plaintiffs Marco, McGuire & Arreola, LLC
AGREED MOTION FOR ENTRY OF JUDGMENT ORDER
Seegar, Judge.
Plaintiffs, CHICAGO TILE INSTITUTE WELFARE PLAN, et. al. by and through its attorneys, Michael J. McGuire, and Marco, McGuire & Arreola, LLC move this Honorable Court to enter an Agreed Judgment Order against the Defendant, REGAL BUILDERS I, LLC, and in support states as follows:
1. Plaintiffs filed their First Amended Complaint on March 24, 2023, alleging that the Defendant failed to submit reports and contributions to the Plaintiff Trust Funds for the months of June 2022 through December 2022.
2. As a result of the delinquency, the Defendant owes the Plaintiff Trust Funds $377,910.87 in delinquent contributions, interest, liquidated damages, attorney fees and costs for the time period of June 2022 through December 2022.
3. The Parties have had the benefit of counsel and this matter has been reviewed by all parties, including the principle of the Defendant corporation.
4. Plaintiffs and Defendant have agreed that a Judgment Order should be entered against the Defendant for the total amount due in the amount of $377,910.87 to resolve the litigation. A copy of the executed proposed Agreed Judgment Order is attached to this motion as Exhibit 1.
WHEREFORE, Plaintiffs request that this Court enter an Agreed Judgment Order in the amount of $377,910.87 against the Defendant, REGAL BUILDERS I, LLC.