Opinion
CIVIL ACTION NO. 08 C 6758
11-23-2011
CHICAGO AREA JOINT WELFARE COMMITTEE FOR THE POINTING, CLEANING AND CAULKING INDUSTRY, LOCAL 52, et al., Plaintiffs, v. RAMIREZ CONSTRUCTION COMPANY, an Illinois corporation, Defendant.
Jennifer L. Dunitz-Geiringer Attorney for Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
JUDGE
MOTION FOR ENTRY OF JUDGMENT
Plaintiffs, by and through their attorneys, default having been entered against the Defendant on March 3, 2009, request this Court enter judgment against Defendant, RAMIREZ CONSTRUCTION COMPANY, an Illiniois corporation. In support of that Motion, Plaintiffs state:
1. On December 3, 2008, this Court ordered the Defendant to submit to an audit of its payroll books and records for the time period January 1, 2006 forward.
2. On March 3, 2009, this Court entered default against Defendant.
3. The revised audit findings show that the Defendant is delinquent in contributions to the Funds in the amount of $47,357.64. (See Affidavit of Terry Rocco).
4. Additionally, the amount of $9,471.53 is due for liquidated damages and $13,976.92 is due for interest. (Rocco Aff. Par. 5). Plaintiffs' auditing firm of Cygan Hayes, Ltd. charged Plaintiffs $10,604.69 to perform the audit examination and complete the report (Rocco Aff. Par. 6).
5. In addition, Plaintiffs' firm has incurred costs in the amount of $1,007.56 and attorneys' fees in the amount of $22,074.00 for a total of $23,081.56. (See Affidavit of Catherine M. Chapman).
6. Plaintiffs request entry of judgment in the total amount of $104,492.34. WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $104,492.34.
Jennifer L. Dunitz-Geiringer
Jennifer L. Dunitz-Geiringer
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
I:\52J\Ramirez Construction\2008\motion-judgment.jdg.df.wpd
CERTIFICATE OF SERVICE
The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion for Entry of Judgment) with the Clerk of Court using the CM/ECF system, and further certifies that I have mailed the above-referenced document by United States Mail to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 23rd day of November 2011:
Mr. Eric Brummett, Registered Agent/President
Ramirez Construction Company
2015 W. Fullerton Avenue
Chicago, IL 60647
Jennifer L. Dunitz-Geiringer
Jennifer L. Dunitz-Geiringer
Attorney for Plaintiffs
BAUM SIGMAN AUERBACH & NEUMAN, LTD.
200 West Adams Street, Suite 2200
Chicago, IL 60606-5231
Bar No.: 6237001
Telephone: (312) 236-4316
Facsimile: (312) 236-0241
E-Mail: jdunitz.geiringer@baumsigman.com