Trs. of the Suburban Teamsters of N. Il. Pension Fund v. I.N.R. Beatty Lumber Co.

Tharp

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 April 2, 2013 for collection of delinquent contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2).

2. Service upon I.N.R. BEATTY LUMBER CO. a dissolved Illinois corporation was made on the Defendant April 8, 2013, and a copy of the proof of service was filed with the court on April 8, 2013.

3. Service upon FORT POLILAND HOLDING CORPORATION, a dissolved Illinois corporation was made on the Defendant April 8, 2013, and a copy of the proof of service was filed with the court on April 8, 2013.

4. More than 21 days have passed without any response to the Complaint by Defendants, so that Defendants are now in default.

5. As supported by the attached Affidavits, the sums due on the Complaint are:

$171,005.00 Pension
$925.00 Attorneys fees
$424.00
Court costs
$172,354.00

WHEREFORE, Plaintiffs pray for the entry of an order:

A. Finding I.N.R. BEATTY LUMBER CO., a dissolved Illinois corporation and FORT POLILAND HOLDING CORPORATION, a dissolved Illinois corporation in default; and
B. Awarding judgment in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION FUND in the amount of $172,354.00.

TRUSTEES OF THE SUBURBAN TEAMSTERS

OF NORTHERN ILLINOIS PENSION FUND

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