Opinion
Case No: 11 C 50096
12-20-2011
District Judge:
Magistrate Judge: P. Michael Mahoney
AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT
1. This Court has personal jurisdiction over the parties to this suit and subject matter jurisdiction over the claims asserted.
2. MCL CARPENTRY CONTRACTORS, LLC, acknowledges that under the terms of the Collective Bargaining Agreements and Trust Agreements referenced in the Complaint filed against it by The Construction Industry Retirement Fund of Rockford, Illinois, and The Construction Welfare Fund of Rockford, Illinois ("the Funds") in Case No. 11 C 50096, that it failed to pay contributions and is liable for additional liquidated damages. MCL CARPENTRY CONTRACTORS, LLC acknowledges owing $8,524.03 in unpaid contributions and liquidated damages.
3. MCL CARPENTRY CONTRACTORS, LLC also acknowledges that under the terms of the Collective Bargaining Agreements and Trust Agreements referenced in the Complaint, it is responsible for the Funds attorney's fees incurred in pursuit of its unpaid contributions. MCL CARPENTRY CONTRACTORS, LLC acknowledges owing $3,578.15 in attorney's fees, which it admits are fair and reasonable under the circumstances.
3. MCL CARPENTRY CONTRACTORS, LLC therefore consents to judgment against it and in favor of the Funds in the total amount of $12,102.18.
WHEREFORE, plaintiff moves that the attached Consent Judgment be entered at this time.
THE CONSTRUCTION INDUSTRY RETIREMENT FUND OF ROCKFORD, ILLINOIS, Plaintiff
By: WilliamsMcCarthy LLP
Joel M. Huotari
WilliamsMcCarthy LLP
P.O. Box 219
Rockford, IL 61105-0219
815/987-8900
CERTIFICATE OF LAWYER
The undersigned hereby certifies that on December 20, 2011, I electronically filed the foregoing instrument with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following:
Todd Abraham Miller
Allocco, Miller & Cahill,P.C.
3409 North Paulina Street
Chicago, IL 60657
Joel M. Huotari
Attorney for Plaintiff
THE CONSTRUCTION INDUSTRY
RETIREMENT FUND OF ROCKFORD,
ILLINOIS
WilliamsMcCarthy LLP
120 W. State St., Suite 400
P.O. Box 219
Rockford, IL 61105-0219
Telephone: (815)987-8900
Facsimile: (815)968-0019
E-mail: jhuotari@wilmac.com