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 5367

vs. )

) JUDGE ROBERT M. DOW, JR.

ALCA, INC., an Illinois corporation, )

)

Defendant. )

MOTION FOR ENTRY OF JUDGMENT

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

on August 22, 2012, request this Court enter judgment against Defendant, ALCA, INC., an Illinois

corporation. In support of that Motion, Plaintiffs state:

1. On August 22, 2012, this Court entered default against Defendant and granted

Plaintiffs’ request for an order directing Defendant to submit its monthly fringe benefit contribution

reports for March 2012 forward. The Court also entered an order that judgment would be entered

after Plaintiffs determined the amount due and owing from Defendant.

2. On or about September 16, 2012, Plaintiffs received Defendant’s monthly fringe

benefit contribution reports for March 2012 through July 2012. Plaintiffs previously received

Defendant’s monthly fringe benefit contribution reports for December 2011 and January 2012. The

reports show that the Defendant is delinquent in contributions to the Funds in the amount of

$3,632.90. (See Affidavit of Deborah L. French).

3. The amount of $162.19 is due for liquidated damages. (French Aff. Par. 5). 

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4. Pursuant to the Trust Agreements, a liquidated damagessurcharge 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 September 30, 2012, in the total amount of $1,873.84.

5. In addition, Plaintiffs’ firm has expended $435.00 in costs and $1,335.50 in attorneys’

fees in this matter, for a total of $1,747.50. (See Affidavit of Catherine M. Chapman).

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

total amount of $7,438.93.

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

$7,438.93.

/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

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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 10th day of October

2012:

Mr. Bruno A. Pasquinelli, Registered Agent

ALCA, Inc.

535 Plainfield Road, Suite B

Willowbrook, IL 60527

/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

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