Opinion
Case No.: 2011 C 3966
08-19-2011
TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS, Plaintiffs, v. BOSS TRUCKING OF WATSEKA, INC. an Illinois corporation, Defendant.
Judge
Magistrate Judge Nolan
MOTION FOR JUDGMENT IN SUM CERTAIN
NOW COMES the Plaintiff, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUND, by and through its attorney, JOHN J. TOOMEY, ARNOLD AND KADJAN, and pursuant to FRCP 55 move for judgment in sum certain as stated in this Complaint and the supporting Affidavits attached hereto. In support of its Motion, Plaintiffs state as follows:
1. Suit was filed on June 10,2011 for collection of delinquent contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2).
2. Service was made upon Boss Trucking of Watseka, Inc. an Illinois corporation upon the Secretary of State on July 27, 2011 and a copy of the proof of service was filed with the court on August 1, 2011.
3. Defendant is now in default as to the Complaint and as supported by the attached Affidavits the sums due are:
$17,933.46 Pension
$27,919.32 Welfare
$925.00 Attorneys fees
$360.00 Court costs
$47,137.78
WHEREFORE, Plaintiff prays for:
1. Entry of judgment against Defendant, Boss Trucking of Watseka, Inc., an Illinois corporation, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS in the amount of $47,137.78.
TRUSTEES OF THE SUBURBAN TEAMSTERS
OF NORTHERN ILLINOIS WELFARE AND
PENSION FUNDS
John J. Toomey
ARNOLD AND KADJAN
19 W. Jackson Blvd., Suite 300
Chicago, IL 60604
Telephone No.: (312) 236-0415
Facsimile No.: (312)341-0438
Dated: August 19, 2011