MOTION FOR ENTRY OF JUDGMENT

EDMOND E. CHANG, District Judge.

Plaintiffs, by and through their attorneys, default having been entered against the Defendant on February 28, 2019, request this Court enter judgment against Defendant, MAJOR HEATING & COOLING, INC., an Illinois corporation. In support of this Motion, Plaintiffs state:

1. On February 28, 2019, this Court entered default against Defendant and granted Plaintiffs' request for an order directing an audit of the Defendant's payroll books and records. The Court also entered an order that judgment would be entered after the completion of the audit.

2. On or about November 22, 2019, Plaintiffs' auditors completed the audit. The audit findings show that the Defendant is delinquent in contributions to the Funds in the amount of $22,510.71, plus $4,502.15 for twenty (20%) percent liquidated damages. (See Affidavit of Kevin J. Schell).

3. Plaintiffs' auditing firm of Calibre CPA Group, PLLC charged Plaintiffs $1,328.75 to perform the audit examination and complete the report and the Funds are entitled to recover said fees under their Trust Agreements (Schell Aff. Par. 7).

4. In addition, Plaintiffs' firm has expended $770.00 for costs and $5,378.75 for attorneys' fees in this matter. (See Affidavit of Catherine M. Chapman).

5. Plaintiffs' counsel was unable to determine if this instant motion was agreed or uncontested due to the fact that Defendant did not obtain counsel to represent it in this matter.

6. Based upon the documents attached hereto, Plaintiffs request entry of judgment in the total amount of $34,490.36.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of $34,490.36.