MOTION FOR ENTRY OF JUDGMENT

EDMOND E. CHANG, District Judge.

Plaintiffs, by and through their attorneys, default having been entered against the Defendant on October 20, 2019, request this Court enter judgment against Defendant, METAL ERECTOR, INC., an Illinois corporation. In support of this Motion, Plaintiffs state:

1. On October 20, 2019, this Court entered default against Defendant and granted Plaintiffs' request for an order directing Defendant to turn over its monthly fringe benefit contribution reports for the time period May 2019 forward. The Court also entered an order that judgment would be entered after Plaintiffs' received the required contribution reports and determined the amounts due and owing from Defendant.

2. On October 16, 2019, Plaintiffs' counsel received Defendant's monthly fringe benefit contribution report for May 2019 and was advised by the Defendant that no additional hours were due after May 2019 because the company was out of business. This report, along with the April 2019 report for which the check for payment of those contributions was returned by the bank indicating "non-sufficient funds" indicate Defendant is delinquent in contributions to the Funds in the amount of $32,704.33. (See Affidavit of Kevin J. Schell).

3. Additionally, the amount of $3,270.44 is due for liquidated damages. (Schell Aff. Par. 5).

4. In addition, Plaintiffs' firm has expended $485.00 for costs and $1,400.75 for attorneys' fees in this matter. (See Affidavit of Catherine M. Chapman).

5. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $37,860.52.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $37,860.52.