Filed: Jun. 12, 2017
Latest Update: Jun. 12, 2017
Summary: AFFIDAVIT IN SUPPORT OF ATTORNEYS' FEES ROBERT W. GETTLEMAN , District Judge . NOW COMES the undersigned, JOHN J. TOOMEY, upon being first duly sworn, deposes and states as follows: 1. The undersigned is counsel of record in Case No. 17 C 3040. 2. Affiant is an attorney licensed to practice law in the State of Illinois since 1978. Affiant is admitted to the trial Bar of the Northern District of Illinois, the Central District of Illinois and the Seventh, Eighth, Second, Eleventh Circuit
Summary: AFFIDAVIT IN SUPPORT OF ATTORNEYS' FEES ROBERT W. GETTLEMAN , District Judge . NOW COMES the undersigned, JOHN J. TOOMEY, upon being first duly sworn, deposes and states as follows: 1. The undersigned is counsel of record in Case No. 17 C 3040. 2. Affiant is an attorney licensed to practice law in the State of Illinois since 1978. Affiant is admitted to the trial Bar of the Northern District of Illinois, the Central District of Illinois and the Seventh, Eighth, Second, Eleventh Circuit C..
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AFFIDAVIT IN SUPPORT OF ATTORNEYS' FEES
ROBERT W. GETTLEMAN, District Judge.
NOW COMES the undersigned, JOHN J. TOOMEY, upon being first duly sworn, deposes and states as follows:
1. The undersigned is counsel of record in Case No. 17 C 3040.
2. Affiant is an attorney licensed to practice law in the State of Illinois since 1978. Affiant is admitted to the trial Bar of the Northern District of Illinois, the Central District of Illinois and the Seventh, Eighth, Second, Eleventh Circuit Courts of Appeal, U. S. Tax Court and the United States Supreme Court.
3. The time spent in the case are as follows, were reasonably necessary in the prosecution of the case, and no paralegals were used:
April 24, 2017 Open file; draft complaint and summons
and file with court 2 hours
May 16, 2017 Return of service filed with the court .5 hours
June 9, 2017 Draft Motion for Judgment in Sum Certain 1.5 hour
Court appearance on Motion for Judgment
in Sum Certain 1.0 hour
4. The costs expended in prosecuting the case are:
Filing fee $400.00
Reliant Agency $59.00
Total $459.00
5. Reasonable value of such services is One Hundred Eighty Five Dollars per hour:
$250.00 × 5 hours $1,250.00
6. The total in fees and costs expended are:
Attorneys' fees $1,250.00
Costs $459.00
Total $1,709.00
FURTHER AFFIANT SAYETH NOT.
AFFIDAVIT
RICHARD SIEBERT, upon being first duly sworn deposes and states as follows:
1. Affiant is employed by the Suburban Teamsters Welfare and Pension Fund ("Funds") as an auditor, is familiar with the T & T CUSTOMS, INC., an Illinois corporation audit ("Employer"), having examined its books and records to determine what amounts if any were due and owing the Funds, and is also familiar with the parties' agreement concerning contributions, liquidated damages and interest owed.
2. That an audit of Employer's books and records was performed on January 7, 2017, covering the period June, 2015 through September, 2016 and found to be owing:
Pension $6,164.82
Welfare $5,372.04
3. That Employer was given a copy of the audit and given notice of findings and has made no effort to pay or settle.
4. That the audit including liquidated damages and interest totals $11,536.86.
5. Affiant is above the age of 21, suffers from no disability and has actual knowledge of the above and could so testify.
FURTHER AFFIANT SAYETH NOT.
ORDER OF JUDGMENT
This matter coming to be heard upon Plaintiff's Motion for Judgment in a sum certain and the court being fully advised in the premises,
IT IS HEREBY ORDERED AS FOLLOWS:
1. That judgment is hereby entered in the reinstated case in favor of the Plaintiffs TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS and against the Defendant, T & T CUSTOMS, INC., an Illinois corporation, as follows
$6,164.82 Pension
$5,372.04 Welfare
$1,250.00 Attorneys fees
$459.00 Court costs
__________
for a total of $13,245.86
Date:
Entered:
_______________________________
JUDGE GETTLEMAN
