MOTION FOR ENTRY OF JUDGMENT

MANISH S. SHAH, District Judge.

Plaintiffs, by and through their attorneys, default having been entered against the Defendant on August 2, 2017, request this Court enter judgment against Defendant, FENCE CONNECTION, INC., an Illinois corporation. In support of that Motion, Plaintiffs state:

1. On August 2, 2017, this Court entered default against Defendant.

2. On November 3, 2015 and March 17, 2016, Plaintiffs' auditors conducted an audit of the Defendant's payroll books and records for the time period April 1, 2014 through December 31, 2015.

3. On or about November 29, 2016, the auditors revised the audit report. The revised audit findings show that the Defendant is delinquent in contributions to the Funds in the amount of $15,976.85. (See Affidavit of Joseph J. Burke).

4. Additionally, the amount of $5,670.32 is due for liquidated damages. (Burke Aff. Par. 6). Plaintiffs' auditing firm of Legacy Professionals, LLP charged Plaintiffs $3,070.76 to perform the audit examination, complete the report and revise the audit findings. (Burke Aff. Par. 7).

5. In addition, the amount of $195.47 is due for liquidated damages for Defendant's untimely payment of the fringe benefit contributions due for the month of March 2017. (Burke Aff. Par. 8).

6. Plaintiffs' firm has expended $485.00 in costs and $1,425.00 in attorneys' fees in this matter. (See Affidavit of Catherine M. Chapman).

7. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $26,823.40.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $26,823.40.