Trustees of the Suburban Teamsters of Northern Illinois Welfare and Pension Funds v. JP National Transportation Systems, Inc., An Illinois Corporation

Northern District of Illinois, ilnd-1:2016-cv-06453

MOTION by Plaintiff Trustees of the Suburban Teamsters of Northern Illinois Welfare and Pension Funds for judgment

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Case: 1:16-cv-06453 Document #: 5 Filed: 08/03/16 Page 1 of 2 Pageld #:10 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TRUSTEES OF THE SUBURBAN TEAMSTERS) OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS, Plaintiffs, uuuuuuu No. 2016 C 6453 Judge Hart JP NATIONAL TRANSPORTATION SYSTEMS,) INC., an Illinois corporation, Magistrate Judge Mason Defendant. MOTION FOR JUDGMENT IN SUM CERTAIN 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, 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 21, 2016 for collection of delinquent contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2). 2. Corporate service was made upon JP NATIONAL TRANSPORTATION SYSTEMS, INC., an Illinois corporation on the Defendant on June 25, 2016 and a copy of the proof of service was filed with the court on July 18, 2016. 3. Defendant is now in default as to the Complaint and as supported by the attached Affidavits the sums due are: $9,481.72 $12,222.69 $1,250.00 $476.00 $23,430.41 Pension Welfare Attorneys fees Court costs Case: 1:16-CV-06453 Document #: 5 Filed: 08/03/16 Page 2 of 2 PageID#:11 WHEREFORE, Plaintiffs pray for: 1. Entry of judgment against Defendant, JP NATIONAL TRANSPORTATION SYSTEMS, INC. an Illinois corporation, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS in the amount of $23,430.41 TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS s/John J. Toomey ARNOLD AND KADJAN 203 N. LaSalle Street, Suite 1650 Chicago, IL 60601 Telephone No.: (312) 236-0415 Facsimile No.: (312) 341-0438 Dated: August 3, 2016