Opinion
Civil Action 22 C 4412
10-19-2022
LOCAL 705 INTERNATIONAL BROTHERHOOD OF TEAMSTERS HEALTH AND WELFARE FUND, et al., Plaintiffs, v. O'HARE VAN LINES, INC., an Illinois corporation, Defendant.
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
EDMOND E. CHANG JUDGE
Plaintiffs, by their attorneys, default having been entered against the Defendant on October 12, 2022, request this Court enter judgment against Defendant, O'HARE VAN LINES, INC., an Illinois corporation, pursuant to F.R.Civ.P. Rule 55(b). In support of this Motion, Plaintiffs state:
1. On October 12, 2022, this Court entered default against Defendant and ordere Plaintiffs to file its motion for entry of judgment on October 19, 2022.
2. In March 2022, Plaintiffs= auditors completed a payroll audit on Defendant's books and records for the time period June 1, 2016 through June 30, 2021. The audit findings show that the Defendant is delinquent in contributions to the Funds in the amount of $19,064.00, plus $1,906.40 for liquidated damages and $5,277.96 for interest, for a total of $26,248.36. (See Affidavit of Jack Witt).
3. Plaintiffs' auditing firm of Graff, Ballauer & Blanski, P.C. charged Plaintiffs $1,252.50 to perform the audit examination and complete the report and the Funds are entitled to recover said fees under their Trust Agreements (Witt Aff. Par. 9).
4. In addition, Plaintiffs= firm has expended $527.00 for costs and $1,773.00 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 $29,800.86.
WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $29,800.86.