MOTION FOR JUDGMENT IN SUM CERTAIN

SARA L. ELLIS, District Judge.

Plaintiffs, by one of their attorneys, DONALD D. SCHWARTZ, JAMES R. ANDERSON, GRANT R. PIECHOCINSKI and ARNOLD and KADJAN, pursuant to F.R.C.P. 55, respectfully request this Honorable Court to enter Judgment in Sum Certain in favor of Plaintiffs and against Defendant, DANIEL DECORATING, INC., an Illinois corporation. In support of their motion, Plaintiffs state as follows:

1. This case was filed on April 22, 2016.

2. The summons was served on April 30, 2016, and the answer was due on May 23, 2016.

3. Defendant has not filed an answer or otherwise plead.

4. According the affidavit of Richard J. Wolf, attached as Exhibit A, Defendant owes $726,103.12 in contributions, $108,915.46 in liquidated damages on the audit, and $1,900.00 in audit costs. Additionally, the Defendant owes $10,625.69 in accumulated unpaid liquidated damages for the period from May 2014 through February 2016.

5. The total due to the Plaintiffs for the audit for the period of January 1, 2013 through December 31, 2015 and for outstanding liquidated damages through February 2016 is $847,544.27.

WHEREFORE, Plaintiffs move this Court to:

A. Enter final judgment in favor of the Plaintiffs and against the Defendant Daniel Decorating, Inc., in the amount of $847,544.27. (A copy of a proposed order is attached as Exhibit B)

EXHIBIT A

AFFIDAVIT OF RICHARD J. WOLF

I, Richard J. Wolf, upon being first duly sworn, on oath deposes and states:

1. Affiant is President of the auditing firm of Richard J. Wolf & Company, Inc.

2. Our firm completed compliance audits for the Trustees of the Chicago Painters and Decorators, et. al., on Daniel Decorating, Inc. for the period of January 1, 2013 to December 31, 2015.

3. The audit report found arrears owing to the Trustees of the Chicago Painters and Decorators, et. al., in the amount of $726,103.12 in contributions, $108,915.46 in liquidated damages, and $1,900.00 in audit costs. The Defendant owes $10,625.69 in accumulated unpaid liquidated damages for the period from May 2014 through February 2016.

4. The total due the Plaintiffs including arrears, and liquidated damages of 15 percent, but excluding attorney's fees and court costs is $847,544.27 for Chicago Painters and Decorators, et. al.

5. Affiant is not currently suffering any infirmities and is competent to testify to all the foregoing.

FURTHER AFFIANT SAYETH NOT.

EXHIBIT B

JUDGMENT ORDER

This cause, coming to be heard upon Plaintiffs' Motion for Judgment in Sum Certain, all parties having notice:

IT IS HEREBY ORDERED THAT: