Trs. of the Suburban Teamsters of N. Ill. Welfare & Pension Funds v. AP Transp. 2018

Full title: TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND…

Court: United States District Court, Northern District of Illinois

Date published: Jun 30, 2022

2022 C 1719 (N.D. Ill. Jun. 30, 2022)

Opinion

2022 C 1719

06-30-2022

TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS, Plaintiffs, v. AP TRANSPORTATION 2018, LLC a/k/a CHADWICK TRANSPORTATION L.L.C, dissolved Illinois limited liability corporations and TJ HAULING, LLC., an Illinois limited liability corporation Defendants.

John J. Toomey ARNOLD AND KADJAN, LLP

Jorge L. Alonso Judge

John J. Toomey ARNOLD AND KADJAN, LLP

Jeffrey Cummings Magistrate Judge

MOTION FOR JUDGMENT IN SUM CERTAIN

Jorge L. Alonso Judge

NOW COME the Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUND, by and through its attorney, JOHN J. TOOMEY, ARNOLD AND KADJAN, LLP and pursuant to FRCP 55 move for judgment in sum certain as stated in this Motion and the supporting Affidavits attached hereto. In support of its Motion, Plaintiffs state as follows:

1. Suit was filed on April 4, 2022 for collection of delinquent contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2). Plaintiffs' First Amended Complaint was filed on April 6,2022.

2. Service upon AP TRANSPORTATION 2018, LLC a/k/a CHADWICK TRANSPORTATION L.L.C, dissolved Illinois limited liability corporations, was made on the Secretary of State on May 12, 2022 and a copy of the proof of service was filed with the court on June 2,2022. Defendant has failed to appear, plead or otherwise defend. The time to do so ran June 24, 2022.

3. Defendant, AP TRANSPORTATION 2018, LLC a/k/a CHADWICK TRANSPORTATION L.L.C, dissolved Illinois limited liability corporations, is now in default on the First Amended Complaint and as supported by the attached Affidavits the sums due are:

$44,391.06 Welfare

$79,447.77 Pension

$1,250.00 Attorneys fees

$402.00 Filing Fee

$10.00 Secretary of State (Service of Process)

$109.00 Reliant Services (Service of Process)

$125,609.83

WHEREFORE, Plaintiffs pray for:

1. Entry of judgment against Defendant, AP TRANSPORTATION 2018, LLC a/k/a CHADWICK TRANSPORTATION L.L.C, dissolved Illinois limited liability corporations, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS in the amount of $125,609.83.

TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS