Opinion
Civil Action 21 C 4098
01-14-2022
FOX VALLEY & VICINITY CONSTRUCTION WORKERS WELFARE FUND, et al., Plaintiffs, v. OZOH ENGINEERING & CONSTRUCTION, LLC, an Illinois limited liability company, NNAMDI E. OZOH, an individual, Defendants.
Catherine M. Chapman Attorney for the Plaintiffs
Catherine M. Chapman Attorney for the Plaintiffs
MOTION FOR ENTRY OF JUDGMENT
EDMOND E. CHANG JUDGE
Plaintiffs, by and through their attorneys, default having been entered against the Defendants on September 30, 2021 [Dkt. 12], request this Court enter judgment against Defendants, OZOH ENGINEERING & CONSTRUCTION, LLC, an Illinois limited liability company, and NNAMDI E. OZOH, an individual, pursuant to F.R.Civ.P. Rule 55(b). In support of this Motion, Plaintiffs state:
1. On September 30, 2021, this Court entered default against Defendant and granted Plaintiffs' request for an order directing an audit of Defendant Ozoh Engineering & Construction, LLC's payroll books and records for the time period January 1, 2018 forward. The Court also entered an order that judgment would be entered after the completion of the audit.
2. On or about December 21, 2021, Plaintiffs' auditors completed the audit. The audit findings show that the Defendants are delinquent in contributions to the Funds in the amount of $7,713.93, plus $771.39 for liquidated damages and $2,197.68 for interest. (See Affidavit of David A. Dorfman).
3. Plaintiffs' auditing firm of Calibre CPA Group, PLLC charged Plaintiffs $1,573.82 to perform the audit examination and complete the report and the Funds are entitled to recover said fees under their Trust Agreements (Dorfman Aff. Par. 7).
4. In addition, Plaintiffs' firm has expended $502.00 for costs and $3,202.75 for attorneys' fees in this matter. (See Affidavit of Catherine M. Chapman).
5. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $15,989.25.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $15,989.25.