Opinion
23-cv-07190
12-18-2024
Grant R. Piechocinski One of their Attorneys
Grant R. Piechocinski One of their Attorneys
MOTION FOR DEFAULT AND JUDGMENT IN SUM CERTAIN
Hon. Judge Martha M. Pacold
Plaintiffs, TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS PENSION FUND, et al., by their attorneys, Grant R. Piechocinski and ARNOLD AND KADJAN, LLP, pursuant to Federal Rule of Civil Procedure 55, hereby present their Motion for Default and Judgment in Sum Certain. In support thereof, Plaintiffs state as follows:
1. Plaintiffs filed this Complaint alleging the Defendants failed to pay amounts owed on a fringe benefit compliance audit for the period of December 8, 2018 to December 31, 2023.
2. Defendant BLS Construction LLC, was served on September 8, 2023. (Docket Entry 6).
3. More than 21 days have passed and Defendant BLS Construction LLC, has failed to answer or otherwise plead.
4. The Court entered an order of default against Defendant on October 23, 2023. (Docket Entry 12)
5. The audit findings revealed a total of $316,874.35 is owed. (Ex. A - Wolf Affidavit).
6. This amount breaks down as follows: $271,936.39 in contributions; $40,790.46 in liquidated damages on those contributions; and $4,147.50 in audit costs. (Ex A.)
7. Therefore, Defendant, BLS Construction LLC., is liable for a total of $316,874.35
WHEREFORE, the Plaintiffs request that this Court enter a default judgment in favor of the Plaintiffs and against Defendant BLS Construction LLC, in the amount of $316,874.35 or grant such other or further relief that this Court deems appropriate under the circumstances.
Respectfully submitted, TRUSTEES OF THE CHICAGO PAINTERS AND DECORATORS PENSION FUND, et al.,
PAUL M. EGAN GRANT R. PIECHOCINSKI ARNOLD AND KADJAN, LLP