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Fox Valley Construction Workers Fringe Benefit Funds v. Soto

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION


January 11, 2007

FOX VALLEY CONSTRUCTION WORKERS FRINGE BENEFIT FUNDS, ET AL., PLAINTIFFS,
v.
CESAR SOTO, INDIVIDUALLY AND D/B/A CESAR MASONRY, INC., A DISSOLVED CORPORATION, DEFENDANT.

The opinion of the court was delivered by: Judge John W. Darrah

MOTION FOR ENTRY OF JUDGMENT

Plaintiffs, by and through their attorneys, default having been entered against the Defendant on September 6, 2006, request this Court enter judgment against Defendant, CESAR SOTO, individually and d/b/a CESAR MASONRY, INC., a dissolved corporation. In support of that Motion, Plaintiffs state:

1. On September 6, 2006, this Court entered default against Defendant and granted Plaintiffs' request for an order directing an audit of the Defendant's payroll books and records for the period July 14, 2004 forward (a copy of the Order entered on September 6, 2006 is attached hereto as Exhibit A).

2. Plaintiffs' auditors completed that audit on or about December 4, 2006. The audit findings show that the Defendant is delinquent in contributions to the Funds in the amount of $240,944.69. (See Affidavit of Deborah L. French)

3. Additionally, the amount of $24,094.47 is due for liquidated damages. (French Aff. Par. 7). Plaintiffs' auditing firm of Howard Levinson & Associates charged Plaintiffs $2,692.80 to perform the audit examination and complete the report (French Aff. Par. 6) (a copy of the audit report is attached hereto as Exhibit B).

4. In addition, Plaintiffs have incurred court costs totaling $578.50 and reasonable attorneys' fees totaling $3,703.75. (See Affidavit of Catherine M. Chapman).

5. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $272,014.21.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $272,014.21.

CERTIFICATE OF SERVICE

The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion for Entry of Judgment) with the Clerk of Court using the CM/ECF system, and further certifies that I have mailed the above-referenced document by United States Mail to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 11th day of January 2007:

20070111

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