[PROPOSED] ORDER AND JUDGMENT ON SUPPLEMENTAL STIPULATION FOR JUDGMENT

STEPHEN V. WILSON, District Judge.

Pursuant to the Stipulation by and between Plaintiffs Board of Trustees of the Sheet Metal Workers' Pension Plan of Southern California, Arizona and Nevada ("Pension Plan"); Board of Trustees of the Sheet Metal Workers' Health Plan of Southern California, Arizona and Nevada ("Health Plan"); Board of Trustees of the Southern California Sheet Metal Joint Apprenticeship and Training Committee ("JATC"); Board of Trustees of the Sheet Metal Workers' Local 105 Retiree Health Plan ("Retirees Plan"); Board of Trustees of the Southern California Sheet Metal Workers' 401(a) Plan ("401(a) Plan"); Sheet Metal Workers' International Association, Local Union No. 105 Union Dues Check-Off and Deferred Savings Fund ("Dues and Savings Fund"); Board of Trustees of the Southern California Labor Management Cooperation Trust ("LMCT"); and Board of Trustees of the Sheet Metal Industry Fund of Orange Empire ("Industry Fund") (collectively the "Plans" or "Trust Funds"), and Defendants, RICHARD DON JUAN AGUILERA; and CONNIE GASTELUM-AGUILERA ("Individual Defendants") and INDEPENDENT AIR GROUP, INC. ("Company"), the Court has considered the matter fully and concluded that good cause exists to approve the parties' Stipulation in its entirety.

Accordingly, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:

1. That the Company and Individual Defendant agree that they are indebted to the Plans in the total amount of $173,930.79 as follows: contributions (including the "Savings Deferral" which are wages deducted from employee paychecks) in the amount of $25,779.76 for the delinquent work months of November 2017, January 2018, December 2018, January 2019, and February 2019; $90,434.02 in liquidated damages for late payment or nonpayment of contributions for the delinquent work months of January 2014 through May 2014, July 2014 through December 2014, January 2015 through December 2015, February through December 2016, January 2017 through August 2017, November through December 2017, January 2018 through December 2018, and January 2019; $45,217.01 in interest for late payment or nonpayment of contributions for the delinquent work months of January 2014 through May 2014, July 2014 through December 2014, January 2015 through December 2015, February through December 2016, January 2017, August 2017, November through December 2017, January 2018 through December 2018, and January 2019; and attorney's fees in the amount of $12,500.00.

2. Judgment is entered in favor of the Plans and against the Company and Individual Defendants, jointly and severally, in the amount of $173,930.79 for delinquent employee benefit plan contributions, audit contributions, accrued liquidated damages, interest, attorney fees and costs, together with post-judgment interest thereon at the rate of 12% per annum as of the date of the Judgment.

3. This Order and Judgment on the Supplemental Stipulation for Judgment does not supersede or replace the prior Stipulation for Judgment entered in this case on September 19, 2013 nor the Order on Stipulation for Judgment entered on October 7, 2013. This Supplemental Stipulation for Judgment only applies to the delinquencies that were accrued for the work months of November 2017, January 2018, December 2018, January 2019, and February 2019, after the initial Order on Stipulation for Judgment was entered.

4. This Court retains jurisdiction over this matter through August 1, 2020 to enforce the terms of any judgment entered hereunder, to order appropriate injunctive and equitable relief, to make appropriate orders of contempt, and to increase the amount of judgment based upon additional sums owed to the Plans by Defendants.

IT IS SO ORDERED.