IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
August 6, 2009
CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS PENSION FUND; AND HOWARD MCDOUGALL, TRUSTEE; AND CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS HEALTH AND WELFARE FUND; AND HOWARD MCDOUGALL, TRUSTEE; PLAINTIFFS,
VANGUARD SERVICES, INC., AN INDIANA CORPORATION; DRIVER'S, INC., AN OHIO CORPORATION; VANGUARD SOUTHEAST, INC., A SOUTH CAROLINA CORPORATION; VMT VANGUARD COMPANIES, INC., AN INDIANA CORPORATION; VANGUARD SERVICES (CANADA), INC., A CANADIAN CORPORATION; VANGUARD OF DELAWARE, INC., A DELAWARE CORPORATION; CROSSSTONE, LLC, AN INDIANA LIMITED LIABILITY COMPANY; PINERIDGE INSURANCE COMPANY, INC., A BARBADOS CORPORATION; V.O. FREIGHT SERVICES, INC, A DELAWARE CORPORATION; DEFENDANTS.
The opinion of the court was delivered by: Judge George W. Lindberg
Magistrate Judge Morton Denlow
AGREED MOTION FOR ENTRY OF CONSENT JUDGMENT
Plaintiffs, Central States, Southeast and Southwest Areas Pension Fund, and Howard McDougall, one of its present trustees, and Plaintiffs Central States, Southeast and Southwest Areas Health and Welfare Fund, and Howard McDougall, one of its present trustees, hereby move this Court for entry of a consent judgment in favor of Plaintiffs and against Defendants on the terms as attached hereto as Exhibit A. In support of the Motion,
Plaintiffs state as follows:
1. Plaintiffs filed this action on August 4, 2009, for collection of contributions and withdrawal liability under the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), 29 U.S.C. §1001 et seq. This Court has jurisdiction over this action under sections 502(e), 502(f), and 4301(c) of ERISA, 29 U.S.C. §§ 1132(e), 1132(f) and 1451(c).
2. Plaintiffs and Defendants have agreed to the entry of a consent judgment on the terms attached hereto as Exhibit A.
3. Defendants, by and through their counsel, Jon E. Klinghoffer, have agreed to the granting of this Motion.
WHEREFORE, Plaintiffs request that the Court grant this Motion and enter the Consent Judgment attached hereto as Exhibit A.
CERTIFICATE OF SERVICE I, John J. Franczyk, Jr., one of the attorneys for Plaintiffs, certify that on the 6th day of August, 2009, I caused the foregoing Agreed Motion for Entry of Consent Judgment to be filed electronically. This filing was served on all parties indicated on the electronic filing receipt via the Court's electronic filing system.
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