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Illinois District Council No. 1 of the International Union of Bricklayers and Allied Craftworkers v. Ramirez Construction Co.

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


January 31, 2007

ILLINOIS DISTRICT COUNCIL NO. 1 OF THE INTERNATIONAL UNION OF BRICKLAYERS AND ALLIED CRAFTWORKERS, AFL-CIO, PLAINTIFF,
v.
RAMIREZ CONSTRUCTION COMPANY, DEFENDANT.

The opinion of the court was delivered by: Judge Grady

Magistrate Judge Ashman

AGREED MOTION FOR ENTRY OF JUDGMENT

Plaintiff Illinois District Council No. 1 of the International Union of Bricklayers and Allied Craftworkers, AFL-CIO ("Union"), respectfully moves this Court for entry of judgment, in the form attached or otherwise, and states as follows in support of its motion:

1. This matter is a suit to enforce a labor arbitration award, with jurisdiction based on 29 U.S.C. § 185.

2. The parties have agreed to entry of judgment and to the proposed form of judgment, a copy of which is attached.

3. The Union seeks judgment enforcing the arbitration award and ordering the relief provided in that award, specifically that Defendant Ramirez Construction Company ("Company") must provide a bond, letter of credit, or cash bond for $30,000.00 in the approved form, may not perform any work within the geographic or craft jurisdiction of the Union until it does so, and must pay the Union $2,471.25 to reimburse its fees and costs.

4. The Company's attorney, William M. McErlean, Esq., has authorized the Union's lawyer to state that in accord with arrangements previously reached between the parties, the Company agrees to this motion and to the proposed form of judgment.

WHEREFORE, the Union respectfully asks that its motion be granted and that judgment be entered in its favor, in the form attached or otherwise.

Respectfully submitted,

20070131

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