PLAINTIFF'S MOTION FOR ENTRY OF JUDGMENT

ROBERT M. DOW, JR., District Judge.

Plaintiff, Adolfo Bautista Herrera ("Bautista"), by and through his attorneys, Caffarelli & Associates, Ltd., moves this Honorable Court for entry of judgment against Defendants Grand Sports Arena, LLC, d/b/a Chicago Mustangs Pro, Xochitl Meza, individually, and Armando Gamboa, individually, pursuant to the Acceptance of Offer of Judgment filed on March 9, 2018, D.E. 54. In support of his motion, Plaintiff states as follows:

1. On March 5, 2018, Defendants Grand Sports Arena, LLC, d/b/a Chicago Mustangs Pro ("GSA"), Xochitl Meza ("Meza"), individually, and Armando Gamboa ("Gamboa"), individually, served Plaintiff with an Offer of Judgment pursuant to Rule 68 of the Federal Rules of Civil Procedure, attached hereto as Exhibit A.

2. On March 9, 2018, Plaintiff accepted the Offer of Judgment and pursuant to Rule 68(a) of the Federal Rules of Civil Procedure accepted in writing and filed the Acceptance of Offer of Judgment, D.E. 54.

3. Pursuant to Rule 68(a), Plaintiff moves the Court to enter judgment in the amount of $37,600 jointly and severally against Defendants GSA, Meza, and Gamboa. Plaintiff also moves the Court for leave to file a petition for attorneys' fees, costs, and interest pursuant to the Offer of Judgment and the Illinois Wage Payment and Collection Act, 820 ILCS 115/14(a) ("In a civil action, such employee shall also recover costs and all reasonable attorney's fees.").

WHEREFORE, Plaintiff, Adolfo Bautista Herrera, respectfully requests that this Honorable Court enter judgment against Defendants Grand Sports Arena, LLC, d/b/a Chicago Mustangs Pro, Xochitl Meza, individually, and Armando Gamboa, individually, jointly and severally, in the amount of $37,600, as well as an Order granting leave to file a petition for attorneys' fees, costs, and prejudgment interest pursuant to the Offer of Judgment and Illinois Wage Payment and Collection Act,

Exhibit

COME NOW Defendants Grand Sports Arena, LLC, d/b/a Chicago Mustangs Pro ("GSA"), Xochitl Meza ("Meza"), and Armando Gamboa ("Gamboa") (collectively the "GSA Defendants"), by and through their attorney, Mario E. Utreras, Utreras Law Offices, Inc., and pursuant to Federal Rule of Civil Procedure 68, hereby offer to allow judgment to be taken against them, jointly and severally, by Plaintiff Adolfo Bautista Herrera, in the total combined amount of Thirty Seven Thousand Six Hundred Dollars ($37,600.00), exclusive of prejudgment interest, reasonable costs, and attorney's fees accrued by Plaintiff to date, in an amount to be determined by the Court.

This offer of judgment is made for the purposes specified in Fed.R.Civ.P. 68 and is not to be construed either as an admission that the GSA Defendants are liable in this action or that Plaintiff has suffered any damage. This Offer of Judgment shall not be filed with the Court unless (a) accepted or (b) in a proceeding to determine costs.