MOTION FOR ENTRY OF JUDGMENT

ANDREA R. WOOD, District Judge.

Now comes the Plaintiff, CONSTRUCTION WORKERS PENSION TRUST FUND LAKE COUNTY AND VICINITY, by and through its Attorney, Robert B. Greenberg, and moves the Court for entry of judgment against Hooks, AV, LLC, pursuant to Court's Order previously entered and hearing on motion for judgment previously heard, and filing of judgment order, as requested and required by the Court.

1) On February 14, 2019, the Court entered an Order requiring Defendant, Hooks, AV, LLC, to appear through counsel, and advise that in the event Hooks failed to defend the instant case, Plaintiff would be filing a motion for default judgment, which motion would be served on Hooks by certified mail or other method. See Order attached hereto as Plaintiff's Exhibit 1.

2) Plaintiff filed its Notice of Motion for entry of default judgment and set for hearing on March 12, 2019, a copy of which Notice of Motion and Motion for Default Judgment are attached as Plaintiff's Exhibit 2.

3) Plaintiff filed its Judgment Order via delivery to the Court on March 12, 2019, and subsequently delivered its Judgment Order electronically to the Court on April 4, 2019. See Judgment Order attached hereto as Exhibit 3.

4) On March 12, 2019, the Court took Plaintiff's Motion under advisement. See Exhibit 4.

5) As of this date no Judgment Order has yet been entered, and Plaintiff respectfully requests that Judgment Order be entered instanter.

Exhibit "1"

Greenberg, Robert <rbg@ulaw.com>

Activity in Case 1:18-cv-00068 Construction Workers Pension Trust Fund Lake County and Vicinity v. Hooks, AV, LLC terminate deadlines and hearings

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United States District Court

Northern District of Illinois — CM/ECF LIVE, Ver 6.2.2

Notice of Electronic Filing

The following transaction was entered on 2/14/2019 at 4:46 PM CST and filed on 2/13/2019

Case Name: Construction Workers Pension Trust Fund Lake County and Vicinity v. Hooks, AV, LLC

Case Number: 1:18-cv-00068

Filer:

Document Number: 31

Docket Text:

MINUTE entry before the Honorable Andrea R. Wood: Status hearing held. Only counsel for Plaintiff appeared. As stated on the record, Defendant Hooks, AV, LLC is a limited liability corporation and therefore cannot appear pro se. A show cause hearing is set for 3/12/2019 at 9:00 AM. A representative for Defendant Hooks, AV, LLC shall appear before this Honorable Court on 3/12/2019 9:00 a.m. in Courtroom 1925 at the Dirksen Federal Building, 219 South Dearborn Street, Chicago, Illinois 60604, to show cause why default should not be entered against Defendant Hooks, AV, LLC for failure to defend this case. Plaintiff informed the Court that Plaintiff intends to file a motion for entry of default judgment, with supporting materials, prior to the next status hearing. Plaintiff shall provide Defendant Hooks, AV, LLC with a copy of the motion for default judgment by certified mail or other method that provides proof of delivery. Plaintiff may notice its motion for default judgment for the next status hearing. Status hearing set for 3/12/2019 at 9:00 AM. Mailed notice(ef,)

1:18-cv-00068 Notice has been electronically mailed to:

Robert B. Greenberg rbg@ulaw.com

Matthew Scott Jarka msj@ulaw.com

1:18-cv-00068 Notice has been delivered by other means to:

Exhibit "2"

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NOTICE OF MOTION

PLEASE TAKE NOTICE that the undersigned will bring on the annexed motion for hearing at Room 1703, Judge Wood, United States Courthouse, 219 South Dearborn Street, Chicago, Illinois 60604, on the 12th day of March 2019, at 9:00 a.m. of that day or as soon thereafter as counsel can be heard.

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

MOTION FOR DEFAULT JUDGMENT

NOW COMES the Plaintiff and moves this Honorable Court to enter a default judgment on behalf of the Plaintiff and against Defendant, HOOKS, AV, LLC, an Illinois Limited Liability Corporation, on the grounds that the Defendant has failed to defend this action and have counsel appear on its behalf.

WHEREFORE, Plaintiff requests the following relief:

1. That default judgment be entered against the Defendant herein, HOOKS, AV, LLC, an Illinois Limited Liability Corporation, and that the Complaint filed herein be taken as confessed.

2. That judgment be entered forthwith against the Defendant, and in favor of Plaintiff for the period October 1, 2016, through December 31, 2018, in the amount of $20,549.68.

3. That interest and/or liquidated damages be assessed against the Defendant, HOOKS, AV, LLC, an Illinois Limited Liability Corporation, as provided in the Collective Bargaining Agreement and the applicable provisions of the Pension Reform Act.

4. For such other and further relief as the Court may deem just and proper, including reasonable attorney's fees and court costs which are sustained.

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

AFFIDAVIT

ROBERT B. GREENBERG, Attorney for Plaintiff, CONSTRUCTION WORKERS PENSION TRUST FUND LAKE COUNTY AND VICINITY, on oath and duly sworn, states:

1. That I am an Attorney licensed to practice in the State of Illinois for 55 years and a member of the Federal Bar.

2. That I represent the Plaintiff, CONSTRUCTION WORKERS PENSION TRUST FUND LAKE COUNTY AND VICINITY, and my billing rate to Plaintiff Fund is $200.00 per hour.

3. That I have billed my clients a total of $11,540.00 for legal services in the matter of HOOKS, AV, LLC, an Illinois Limited Liability Corporation.

3. That court costs have been calculated in the amount of $836.25.

ROBERT B. GREEN Subscribed and Sworn to before me this 18 day of February 2019. CARLA A MOULTON NOTARY PUBLIC

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

AFFIDAVIT

REGINA M. MOREY, on oath and duly sworn, states:

1. Affiant is the Administrative Assistant in the Audit Department for Construction Workers Pension Trust Fund Lake County and Vicinity.

2. Based upon my examination of Defendant's reports and records, Affiant finds the Defendant, HOOKS, AV, LLC, an Illinois Limited Liability Corporation, is delinquent with respect to contributions to the Plaintiff Fund, in the amount of $20,549.68.

__________________________ REGINA. M. MOREY Subscribed and Sworn to before me this 19th day of February, 2019. BEVERLY A. DENNIS NOTARY PUBLIC

CERTIFICATE OF SERVICE

ROBERT B. GREENBERG, being duly sworn, says that he is an Attorney associated with Asher, Gittler & D'Alba, Ltd., Attorneys for Plaintiff in this action, and that he served the attached Motion upon:

by depositing a copy in the United States mails, postage paid, at 200 West Jackson Boulevard, Chicago, Illinois 60606, on the 19th day of February, 2019.

Service was accomplished pursuant to ECF as to Filing Users, and Counsel shall comply with LR 5.5 as to any party who is not a Filing User or represented by a Filing User.

Exhibit "3"

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JUDGMENT ORDER

This cause coming on to be heard upon motion of the Plaintiff for entry of default order, and the Court being duly advised in the premises,

IT IS NOW THEREFORE ORDERED:

1. That Defendant, HOOKS, AV, LLC, an Illinois Limited Liability Corporation, having failed to appear and plead or otherwise defend in this action is adjudged to be in default and judgment is hereby entered herein.

2. The Complaint filed by the Plaintiff against the Defendant is hereby taken as confessed.

3. That judgment in the amount of THIRTY TWO THOUSAND NINE HUNDRED TWENTY FIVE AND 93/100 DOLLARS ($32,925.93), which amount includes Court costs in the amount of EIGHT HUNDRED THIRTY SIX AND 25/100 DOLLARS ($836.25) and attorney's fees in the amount of ELEVEN THOUSAND FIVE HUNDRED FORTY AND 00/100 DOLLARS ($11,540.00) is entered against HOOKS, AV, LLC, an Illinois Limited Liability Corporation, and in favor of CONSTRUCTION WORKERS PENSION TRUST FUND LAKE COUNTY AND VICINITY.

4. That Defendant shall comply with and perform according to the terms and conditions of his Collective Bargaining Agreement with Local Unions Nos. 81 and 41.

5. The Court reserves jurisdiction with respect to any supplemental proceedings to be instituted by the Plaintiff in order to enforce the judgment entered herein.

Exhibit "4"

Greenberg, Robert <rbg@ulaw.com>

Activity in Case 1:18-cv-00068 Construction Workers Pension Trust Fund Lake County and Vicinity v. Hooks, AV, LLC terminate deadlines

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usdc_ecf_ilnd@ilnd.uscourts.gov <usdc_ecf ilnd@ilnd.uscourts.gov> Tue, Mar 12, 2019 at 3:01 PM

To: ecfmail_ilnd@ilnd.uscourts.gov

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.

***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.

United States District Court

Northern District of Illinois — CM/ECF LIVE, Ver 6.2.2

Notice of Electronic Filing

The following transaction was entered on 3/12/2019 at 3:01 PM CDT and filed on 3/12/2019

Case Name: Construction Workers Pension Trust Fund Lake County and Vicinity v. Hooks, AV, LLC

Case Number: 1:18-cv-00068

Filer:

Document Number: 34

Docket Text:

MINUTE entry before the Honorable Andrea R. Wood: Status hearing held. Plaintiffs motion for default judgment [32] is taken under advisement. Mailed notice(maf)

1:18-cv-00068 Notice has been electronically mailed to:

Robert B. Greenberg rbg@ulaw.com

Matthew Scott Jarka msj@ulaw.com

1:18-cv-00068 Notice has been delivered by other means to: