Opinion
Civil Action 21 C 6907
03-07-2022
Patrick N. Ryan Attorney for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
Patrick N. Ryan Attorney for the Plaintiffs BAUM SIGMAN AUERBACH & NEUMAN, LTD.
MOTION FOR ENTRY OF JUDGMENT
JOAN B. GOTTSCHALL JUDGE
Plaintiffs, by and through their attorneys, default having been entered against the Defendant on February 15, 2022, request this Court enter judgment against Defendant, UNDERLAND ARCHITECTURAL SYSTEMS, INC., an Indiana corporation, pursuant to F.R.Civ.P. Rule 55(b). In support of this Motion, Plaintiffs state:
1. On February 15, 2022, this Court entered default against Defendant and granted Plaintiffs' request for an order directing Defendant to turn over its monthly fringe benefit contribution reports for the time period October 2021 forward [Dkt. 14]. The Court's order also provided that judgment would be entered after Plaintiffs' received the required contribution reports and the amounts due and owing from Defendant could be determined.
2. On or about March 2, 2022, the Plaintiff Funds received Defendant's monthly fringe benefit contribution reports for the time period October 2021 through January 2022. All delinquent contributions due and owing for the above time period were paid by Defendant at that time. 1
3. Due to the late payment of contributions due for the time period July 2021 through January 2022, Defendant was assessed and owes $1, 834.14 for liquidated damages and $840.66 for interest, for a total of $2, 674.80. (See Affidavit of Paul E. Flasch).
4. In addition, Plaintiffs' firm has expended $497.00 for costs and $752.00 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 $3, 923.80.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $3, 923.80. 2