MOTION FOR FINAL JUDGMENT IN SUM CERTAIN

AMY J. ST. EVE, District Judge.

Now come Plaintiffs, the PIPE FITTERS RETIREMENT FUND, LOCAL 597, et al., by and through their attorneys, JOHNSON & KROL, LLC, and move this Honorable Court for entry of Final Judgment in favor of Plaintiffs and against Defendant JJ SERVICES BAIER LLC ("JJ SERVICES") and in support thereof, state as follows:

1. On April 6, 2016, Plaintiffs filed their Complaint against Defendant JJ SERVICES in the above-captioned matter. (Docket No. 1).

2. On June 1, 2016, this Honorable Court entered an Order of Default Judgment against Defendant JJ SERVICES. (Docket No. 15).

3. Pursuant to the Order of Default Judgment, Plaintiffs were awarded the aggregate amount of $15,787.37, representing JJ SERVICES' unpaid contributions, liquidated damages, interest, and 401(k) elective deferral deficiencies for the period of December 2015 through February 2016, in addition to attorney's costs and fees. (Docket No. 15).

4. To date, the entirety of the $15,787.37 owed by JJ SERVICES pursuant to the Order of Default Judgment remains outstanding.

5. Pursuant to the Order of Default Judgment, Plaintiffs were granted leave to "petition this Court for entry of a final judgment in sum certain to include any contributions, 401(k) elective deferrals, liquidated damages and interest owed by the Defendant JJ SERVICES for the months of March 2016 and April 2016." (Docket No. 15).

6. In addition to the amounts previously awarded to the Plaintiffs, JJ SERVICES owes the Plaintiffs the aggregate amount of $12,232.89 in unpaid contributions for the period of March 2016 through May 2016. (Affidavit of Michael Maloney is attached as Exhibit 1).

7. As a result of JJ SERVICES' failure to pay contributions for the period of March 2016 through May 2016, JJ SERVICES owes the Plaintiffs liquidated damages in the aggregate amount of $1,193.66 and interest in the amount of $44.34. (Exhibit 1).

8. JJ SERVICES also owes the Plaintiffs the aggregate amount of $998.48 in 401(k) elective deferrals for the period of March 2016 through May 2016. (Exhibit 1).

9. As a result of JJ SERVICES' untimely submission of 401(k) elective deferrals for the period of March 2016 through May 2016, JJ SERVICES owes the Plaintiffs 401(k) liquidated damages in the aggregate amount of $99.55 and 401(k) interest in the aggregate amount of $14.10. (Exhibit 1).

10. Defendant JJ SERVICES is required to pay the Plaintiffs' reasonable attorney's fees and costs pursuant to the Collective Bargaining Agreement, Trust Agreements and 29 U.S.C. §1132(g)(2)(D).

11. Since filing its Motion for Default Judgment, Plaintiffs have incurred an additional $1,810.00 in attorney's fees and costs. (Affidavit of Nicollette L. Khuans is attached as Exhibit 2).

12. A proposed Final Judgment in Sum Certain Order has been submitted to the Court.

WHEREFORE, Plaintiffs request the following:

A. That a Final Judgment be entered in favor of Plaintiffs and against Defendant JJ SERVICES in the aggregate amount of $32,180.39, which is itemized as follows:

B. That Plaintiffs have such other and further relief as the Court may deem just and equitable all at the Defendant's cost, pursuant to 29 U.S.C. §1132(g)(2)(E).

EXHIBIT 1

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

AFFIDAVIT OF MICHAEL MALONEY

I, Michael Maloney, hold the title of Field Representative and Collection Coordinator for the PIPE FITTERS RETIREMENT FUND, LOCAL 597, the PIPE FITTERS WELFARE FUND, LOCAL 597, the PIPE FITTERS TRAINING FUND, LOCAL 597, The CHICAGO AREA MECHANICAL CONTRACTING INDUSTRY IMPROVEMENT TRUST PIPE FITTERS' INDIVIDUAL ACCOUNT and 401(K) PLAN, the PIPE FITTING COUNCIL OF GREATER CHICAGO (collectively "TRUST FUNDS") and the PIPE FITTERS' ASSOCIATION, LOCAL 597 U.A. ("UNION"). Being first duly sworn, on oath state that to the best of my knowledge the following is an accurate statement as to the Defendant's liabilities to the TRUST FUNDS and UNION in the above-captioned matter:

1. Defendant JJ SERVICES BAIER LLC ("JJ SERVICES") has failed to pay the aggregate amount of $12,232.89 in contributions for the period of March 2016 through May 2016.

2. As a result of JJ SERVICES' failure to pay contributions for the period of March 2016 through May 2016, JJ SERVICES owes the Plaintiffs liquidated damages in the aggregate amount of $1,193.66 and interest in the amount of $44.34.

3. JJ SERVICES also failed to pay the aggregate amount of $998.48 in 401(k) elective deferral deficiencies for the period of March 2016 through May 2016.

4. As a result of its failure to timely pay 401(k) elective deferrals for the period of March 2016 through May 2016, Defendant JJ SERVICES owes the Plaintiffs liquidated damages in the aggregate amount of $99.55 and interest in the aggregate amount of $14.10.

EXHIBIT 2

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

AFFIDAVIT OF NICOLLETTE L. KHUANS IN SUPPORT OF ATTORNEY'S FEES AND COSTS

I, Nicollette L. Khuans, hold the title of Associate Attorney at the law firm of Johnson & Krol, LLC. Being first duly sworn; on oath deposes and states that to the best of my knowledge, the following is an accurate statement as to the attorney's fees and costs the Plaintiffs have incurred in the above-captioned matter since filing its Motion for Default Judgment: