JOINT MOTION FOR ENTRY OF STIPULATED ORDER OF JUDGMENT

JOHN Z. LEE, District Judge.

The Structural Iron Workers Local Union No. 1 Pension Trust Fund (the "Fund") and Harris Davis Rebar, LLC ("Harris Davis"), by and through their respective attorneys, jointly move for the entry of a Stipulated Order of Judgment agreed to pursuant to a Settlement Agreement, and in support, state as follows:

1. On June 30, 2017, the Fund filed a complaint against Harris Davis alleging that Harris Davis is responsible for the same withdrawal liability the Fund had assessed against Old Chicago Steel, LLC ("Old Chicago") and Davis J.D. Steel, LLC ("Davis JD") because Harris Davis was an alter ego and/or successor entity of those entities.

2. The Parties have resolved their dispute through the execution of a Settlement Agreement, which in part, calls for the entry of a Stipulated Order of Judgment, a copy of which is attached to this Motion as Exhibit 1.

3. In addition, the Plaintiffs have sent a word version of the proposed Stipulated Order of Judgment to the Court's proposed order inbox.

WHEREFORE, the Fund and Harris Davis respectfully request that this Court enter the Stipulated Order of Judgment to resolve this matter.

EXHIBIT 1

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

STIPULATED JUDGMENT ORDER

NOW COMES Plaintiff, the STRUCTURAL IRON WORKERS LOCAL UNION NO. 1 PENSION TRUST FUND, and Defendant, HARRIS DAVIS REBAR, LLC, by and through their respective undersigned counsel, and stipulate to the entry of a Judgment in favor of the Defendant, and against the Plaintiff as follows:

WHEREAS, Plaintiff filed its Complaint alleging that the Defendant is the successor and/or alter-ego of Old Chicago Steel, LLC and FKADJDS, LLC initiating the above-captioned matter. NOW, THEREFORE, IT IS HEREBY STIPULATED AND ORDERED AS FOLLOWS: