PLAINTIFFS' MOTION FOR ENTRY OF JUDGMENT

SHARON JOHNSON COLEMAN, District Judge.

NOW COME Plaintiffs, by and through their attorneys, default having been entered against the Defendant on June 14, 2012, request this Court enter judgment against Defendants, MOSLEY CONSTRUCTION, INC., an Illinois corporation, and JOBIE J. MOSLEY, an individual. In support of that Motion, Plaintiffs state:

1. On June 14, 2012, this Court entered default against Defendants and granted Plaintiffs' request for an order directing an audit of the Defendants' payroll books and records. The Court also entered an order that judgment would be entered after the completion of the audit.

2. On August 29, 2012, Plaintiffs' auditors completed the audit. The audit findings show that the Defendants are delinquent in contributions to the Funds in the amount of $7,259.15. (See Affidavit of Tracy White).

3. Additionally, the amount of $1,088.87 is due for liquidated damages and $72.59 is due for interest. (White Aff. Par. 7). Plaintiffs' auditing firm of Levinson Simon Hein & Bilkey, P.C. charged Plaintiffs $1,456.62 to perform the audit examination and complete the report (White Aff. Par. 6).

4. In addition, Plaintiffs' firm has expended the total amount of $1,752.50 in attorneys' fees and $445.00 in costs, for a total of $2,197.50, 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 $12,074.73.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $12,074.73.