IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CARPENTERS FRINGE BENEFIT )

FUNDS OF ILLINOIS, et al., )

) CIVIL ACTION

Plaintiffs, )

) NO. 12 C 0207

vs. )

) JUDGE ELAINE E. BUCKLO

PRAIRIE STATE GROUP, INC., )

a Delaware corporation, )

)

Defendant. )

MOTION FOR ENTRY OF JUDGMENT

Plaintiffs, by and through their attorneys, default having been entered against the Defendant

on March 20, 2012, request this Court enter judgment against Defendant, PRAIRIE STATE

GROUP, INC., a Delaware corporation. In support of that Motion, Plaintiffs state:

1. On March 20, 2012, this Court entered default against Defendant and granted

Plaintiffs’ request for an order directing Defendant to turn over its monthly fringe benefit

contribution reports for May 2011 within 14 days of the entry of said Order. The Court also entered

an order that judgment would be entered after Defendant submitted its report and Plaintiffs

determined all amounts due from Defendant.

2. On or about March 30, 2012, Plaintiffs received Defendant’s fringe benefit

contribution report for May 2011 indicating “no work.” 

3. On February 14, 2011, Plaintiffs’ auditors completed an audit of Defendant’s payroll

books and records for the time period May 1, 2007 through December 31, 2010. The audit findings

Case: 1:12-cv-00207 Document #: 14 Filed: 04/24/12 Page 1 of 3 PageID #:26
show that the Defendant is delinquent in contributions to the Funds in the amount of $7,797.63. (See

Affidavit of Deborah L. French).

4. Additionally, the amount of $1,711.92 is due for liquidated damages. (French Aff.

Par. 6). Plaintiffs' auditing firm of Bansley and Kiener, L.L.P. charged Plaintiffs $1,230.00 to

perform the audit examination and complete the report (French Aff. Par. 7). 

5. Pursuant to the Trust Agreements, a liquidated damages surcharge has been assessed

against the Defendant in the amount of one and one-half (1.5%) percent of the total contributions

untimely received, compounded monthly at one and one-half (1.5%) percent, for the period accrued

through March 31, 2012, in the total amount of $555.37.

6. In addition, Plaintiffs’ firm has expended $435.00 in costs and $595.00 in attorneys’

fees in this matter. (See Affidavit of Catherine M. Chapman).

7. Based upon the documents attached hereto, Plaintiffs request entryof judgment in the

total amount of $12,324.92.

WHEREFORE, Plaintiffs respectfully request this Court to enter judgment in the amount of

$12,324.92.

/s/ Cecilia M. Scanlon 

Cecilia M. Scanlon

Attorney for Plaintiffs

BAUM SIGMAN AUERBACH & NEUMAN, LTD.

200 West Adams Street, Suite 2200

Chicago, IL 60606-5231

Bar No.: 6288574

Telephone: (312) 236-4316

Facsimile: (312) 236-0241

E-Mail: cscanlon@baumsigman.com

2

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CERTIFICATE OF SERVICE

The undersigned, an attorney of record, hereby certifies that she electronically filed the

foregoing document (Motion for Entry of Judgment) with the Clerk of Court using the CM/ECF

system, and further certifies that I havemailed the above-referenced document byUnited States Mail

to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 24th day of April

2012:

Mr. Jason Kozlowski, Registered Agent/President

Prairie State Group, Inc.

4590 Mackinac Street

Lake in the Hills, IL 60156

/s/ Cecilia M. Scanlon 

Cecilia M. Scanlon

Attorney for Plaintiffs

BAUM SIGMAN AUERBACH & NEUMAN, LTD.

200 West Adams Street, Suite 2200

Chicago, IL 60606-5231

Bar No.: 6288574

Telephone: (312) 236-4316

Facsimile: (312) 236-0241

E-Mail: cscanlon@baumsigman.com

I:\CarpsJ\Prairie State\motion-judgment.cms.df.wpd

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