Opinion
19-cv-6520
12-17-2021
TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS PENSION FUND, TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS WELFARE FUND, TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS DEFERRED SAVFNGS FUND, TRUSTEES OFTHE CHICAGO PAINTERS AND DECORATORS APPRENTICESHIP FUND, TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS SCHOLARSHIP FUND, AND TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS JOINT COOPERATION TRUST FUND, Plaintiffs, v. GANDT BUILDERS INC, a Nevada Corporation.
DECLARATION OF RICHARD J. WOLF
Hon. Heather K. McShain Magistrate Judge
I, Richard J. Wolf, subject to the laws of perjury and pursuant to 28 U.S.C. Section 1746, states as follows:
1. I am the owner and president of Richard J. Wolf & Company, Inc. (the "Company").
2. Plaintiffs have hired the Company to perform employer payroll and record compliance reviews, commonly referred to as fringe benefit contribution compliance audits.
3. We have performed hundreds of such audits for Plaintiffs.
4. The Company completed a compliance audit for the Trustees of the Chicago Painters and Decorators, et. al, of GANDT BUILDERS INC. for the period of June 1, 2018 through June 30, 2021.
5. The audit report found arrears owing to the Trustees of the Chicago Painters and Decorators Pension Fund, et. al., consisting of $4,801.84 in contributions, $4,083.91 in liquidated damages and $1,260 in audit costs.
6. The total due the Plaintiffs under the audit, excluding attorney's fees and court costs, is $10,145.75..
7. I am not suffering any infirmities and am competent to testify to the foregoing facts.