Opinion
23 CV 01139
09-08-2023
TRUSTEES OF THE DISTRICT COUNCIL NO. 14 METAL POLISHERS et al Plaintiffs, v. THE STONE AND METAL GROUP, LLC, a Delaware limited liability company, Defendant.
AFFIDAVIT OF RICHARD WOLF
Chang Judge
I, Richard J. Wolf, upon being first duly sworn, on oath deposes and states:
1. Affiant is President of the auditing firm of Richard J. Wolf & Company, Inc.
2. Our firm completed a compliance audit on or about July 6, 2023 for the Trustees of the Chicago Painters and Decorators, et. al., on The Stone and Metal Group LLC, a Delaware limited liability company for the period of October 1,2022 through May 31,2023, 3. Subsequent to the issuance of the audit report, the Defendant agreed to pay certain amounts pursuant to an Installment Note repayment agreement. None of those amounts are included in the adjusted findings.
3. The audit report found arrears owing to the Trustees
4. The total due and owing to the Funds, not including any attorney's fees or court costs is set forth in the next paragraph below:
| 5. Contributions | $21,382.08 |
| Fifteen percent liquidated damages | $3,184.81 |
| Discrepancies in contributions | $22.79 |
| Prior liquidated damages | $ 1,472.02 |
| Audit costs | $1,076.25 |
| Liquidated damages based on reports paid | $7,734.36 |
| Grand total | $26,987.95 |
5. Affiant is not currently suffering any infirmities and is competent to testify to all the foregoing.
FURTHER AFFIANT SAYETH NOT.