MOTION FOR JUDGMENT IN SUM CERTAIN

WILLIAM T. HART, District Judge.

NOW COME the Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUND, by and through its attorney, JOHN J. TOOMEY, ARNOLD AND KADJAN, and pursuant to FRCP 55 move for judgment in sum certain as stated in this Complaint and the supporting Affidavits attached hereto. In support of its Motion, Plaintiffs state as follows:

1. Suit was filed on June 21, 2016 for collection of delinquent contributions plus attorneys' fees, costs and interest under 29 U.S.C. 1132(g)(2).

2. Corporate service was made upon JP NATIONAL TRANSPORTATION SYSTEMS, INC., an Illinois corporation on the Defendant on June 25, 2016 and a copy of the proof of service was filed with the court on July 18, 2016.

3. Defendant is now in default as to the Complaint and as supported by the attached Affidavits the sums due are:

WHEREFORE, Plaintiffs pray for:

1. Entry of judgment against Defendant, JP NATIONAL TRANSPORTATION SYSTEMS, INC. an Illinois corporation, and in favor of Plaintiffs, TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS PENSION AND WELFARE FUNDS in the amount of $23,430.41

AFFIDAVIT IN SUPPORT OF ATTORNEYS' FEES

NOW COMES the undersigned, JOHN J. TOOMEY, upon being first duly sworn, deposes and states as follows:

1. The undersigned is counsel of record in Case No. 16 C 2455.

2. Affiant is an attorney licensed to practice law in the State of Illinois since 1978. Affiant is admitted to the trial Bar of the Northern District of Illinois, the Central District of Illinois and the Seventh, Eighth, Second, Eleventh Circuit Courts of Appeal, U. S. Tax Court and the United States Supreme Court.

3. The time spent in the case are as follows, were reasonably necessary in the prosecution of the case, and no paralegals were used:

4. The costs expended in prosecuting the case are:

5. Reasonable value of such services is One Hundred Eighty Five Dollars per hour:

6. The total in fees and costs expended are:

FURTHER AFFIANT SAYETH NOT.

AFFIDAVIT

RICHARD SIEBERT, upon being first duly sworn deposes and states as follows:

1. Affiant is employed by the Suburban Teamsters Welfare and Pension Fund ("Funds") as an auditor, is familiar with the JP National Transport Systems, Inc., an Illinois corporation audit ("Employer"), having examined its books and records to determine what amounts if any were due and owing the Funds, and is also familiar with the parties' agreement concerning contributions, liquidated damages and interest owed.

2. That an audit of Employer's books and records was performed on November 5, 2015, covering the period July, 2014 through September, 2015 and found to be owing:

3. That Employer was given a copy of the audit and given notice of findings and has made no effort to pay or settle.

4. That the audit including liquidated damages and interest totals $21,704.41.

5. Affiant is above the age of 21, suffers from no disability and has actual knowledge of the above and could so testify.

FURTHER AFFIANT SAYETH NOT.

ORDER OF JUDGMENT

This matter coming to be heard upon Plaintiff's Motion for Judgment in a sum certain and the court being fully advised in the premises,

IT IS HEREBY ORDERED AS FOLLOWS:

1. That judgment is hereby entered in the reinstated case in favor of the Plaintiffs TRUSTEES OF THE SUBURBAN TEAMSTERS OF NORTHERN ILLINOIS WELFARE AND PENSION FUNDS and against the Defendant, JP NATIONAL TRANSPORTATION SYSTEMS, NC., an Illinois corporation as follows