Opinion
No. 10 C 3017
06-13-2012
JAMES T. SULLIVAN, etc., et al., Plaintiffs, v. MARK'S TECHNICAL LAYOUT, INC., Defendant.
Judge Blanche M. Manning
Magistrate Judge
Morton Denlow
MOTION FOR ENTRY OF AGREED JUDGMENT
NOW COME Plaintiffs, JAMES T. SULLIVAN, etc., et al., by their attorneys, DOUGLAS A. LINDSAY, JOHN W. LOSEMAN, and BRIAN T. BEDINGHAUS, with Roetzel & Andress, of counsel, move the Court to enter an Agreed Judgment Order. In support hereof, Plaintiffs state:
1. Plaintiffs initiated this action to obtain a compliance audit and to collect all contributions and other damages, if any, owed by Defendant pursuant to the terms of a collective bargaining agreement, ERISA, 29 U.S.C. §1132, and LMRA, 29 U.S.C. §185.
2. The case is set for a bench trial on June 18, 2012, at 10:00 AM and for Final Pre-Trial Conference on June 14, 2012, at 10:30 AM.
3. The parties have agreed to resolve the matter by entry of an Agreed Judgment in favor of Plaintiffs and against Defendant in the amount of $226,273.14.
4. Attached as Exhibit A is the draft Agreed Judgment signed by counsel for each party.
WHEREFORE, Plaintiffs, JAMES T. SULLIVAN, etc., et al., requests that the Court enter the Agreed Judgment in the form attached hereto as Exhibit A.
JAMES T. SULLIVAN, etc., et al., by their
attorneys, DOUGLAS A. LINDSAY, JOHN
W. LOSEMAN, and BRIAN T.
BEDINGHAUS
By: Brian T. Bedinghaus
Chicago, IL 60602
Of Counsel:
ROETZEL & ANDRESS
20 N. Clark Street
Suite 3200
Chicago, IL 60602
312.580.1200
CERTIFICATE OF SERVICE
I certify that I served a copy of the foregoing MOTION FOR ENTRY OF AGREED JUDGMENT on the following person(s):
Joseph P. Berglundthrough the CM/ECF system of the United States District Court for the Northern District of Illinois as a result of electronic filing made this 13th day of June, 2012.
Kenneth M. Masnty
Berglund, Armstrong & Mastny, P.C.
1010 Jorie Blvd., Suite 370
Oak Brook, IL 60523
berglundmastny@aol.com
b erglundniew@aol.com
In accordance with 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true and correct.
____________
BRIAN T. BEDINGHAUS
Roetzel & Andress
20 N. Clark St.
Suite 3200
Chicago, IL 60602
312-580-1200