[PROPOSED] JUDGMENT GRANTING PLAINTIFFS' MOTION FOR ENTRY OF A DEFAULT JUDGMENT

ANDRÉ BIROTTE, JR., District Judge.

On June 7, 2019, the Court granted the Plaintiffs' Motion for Entry of a Default Judgment. A copy of the Court's June 7, 2019 Order is attached hereto as Exhibit A. On proof being made to the satisfaction of the Court, and good cause appearing therefor,

IT IS HEREBY ORDERED that Plaintiffs are entitled to entry of a default judgment against Defendants, as follows:

1. That Defendant be ordered to pay delinquent contributions in the amount of $7,423.89 to the Security Fund, and $7,936.75 to the Central Pension Fund;

2. That Defendant be ordered to pay liquidated damages and interest in the amount of $2,118.93 to the Security Fund and $2,204.33 to the Central Pension Fund in relation to such unpaid contributions;

3. That Defendant be ordered to pay $5,895.00 for the cost of the audit;

4. That Defendant be ordered to pay actual damages according to proof;

5. That this Court issue an Order directing and permanently enjoining Defendant to submit to the Trust Funds, all reports and contributions due and owing by Defendant, plus interest, attorney's fees, and costs as provided in ERISA sections 502(a)(3) and (g)(2) (29 U.S.C. § 1132(a)(3), (g)(2);

6. That this Court issue an Order permanently enjoining Defendant for so long as it remains obligated to contribute to the Trust Funds, from failing, neglecting, or refusing to timely submit required monthly contributions reports and payments as required by the terms of the collective bargaining agreements, Trust Agreements and ERISA sections 502(a)(3) and (g)(2) (29 U.S.C. § 1132(a)(3), (g)(2));

7. That Defendant be ordered to pay attorneys' fees of $13,347.00;

8. That Defendant be ordered to pay costs of $755.38;

9. That this Court grant such further relief as this Court deems just and proper; and

10. That this Court retain jurisdiction of this matter to enforce the Order compelling an Audit and payment of all amount found due and owing.