UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

SERVICE EMPLOYEES INTERNATIONAL

UNION NATIONAL INDUSTRY PENSION FUND,

and

STEPHEN ABRECHT, RODERICK S. BASHIR,

CHRISTOPHER BOUVIER, KEVIN J. DOYLE,

DAVID A. STILWELL, THOMAS LaMARTINA, Case No. 15-11999

FRANK A. MAXSON, EDWARD J. MANKO, Honorable David M. Lawson

JOHN J. SHERIDAN, and MYRIAM ESCAMILLA,

TRUSTEES OF THE SERVICE EMPLOYEES

INTERNATIONAL UNION NATIONAL INDUSTRY

PENSION FUND,

Plaintiffs,

v.

SANDERS BUILDING SERVICES, INC., and

SANDERS BUSINESS SERVICES, INC.,

Defendants.

____________________________________________/

CONSENT JUDGMENT

It is hereby ORDERED AND ADJUDGED that the defendants are jointly and severally

liable to the plaintiffs as follows:

1. The defendants shall pay $45,000.00 (the “Settlement Amount”) to the Fund in full

and final settlement of all monies owed to the Fund for Site 2608 and Site 2609 for the months of

April 2008 through June 2015. Payment is to be made as follows: Within fifteen (15) days of the

Effective Date, Sanders shall pay, or cause to be paid, to the Fund the amount of $5,000.00 in a lump

sum settlement payment, followed by twenty (20) monthly installments of $2,000.00 each, due on

or before fifteenth day of the month following the month in which the initial $5,000.00 payment is

made. Settlement checks shall be made payable to SEIU National Industry Pension Fund, and shall

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be sent to the attention of Matthew D. Watts, at Mooney, Green, Saindon, Murphy & Welch, P.C.,

1920 L Street, N.W., Suite 400, Washington, D.C. 20036. 

2. If Sanders fails to make any payment required under the payment plan in a timely

manner or if any payment is denied by reason of insufficient available funds, Sanders shall be

immediately liable to the Fund for the full Total Amount Due of $58,303.56 (which is for

contributions, interest, liquidated damages, attorneys' fees and costs due for Site 2608 for the period

of May 2009 through June 2015 and Site 2609 for the period of April 2008 through May 2011), plus

additional interest that shall accrue on any unpaid amounts at the rate of 10% per annum during

periods of non-payment and/or default (to be determined by the Fund), less payments made over the

course of the above payment plan. The parties further agree that the amounts due shall be

considered delinquent contributions under Section 515 of ERISA and that the Fund is entitled to

recover all of the fees and costs that it may incur in any subsequent collection action.

3. Sanders shall grant to the Fund a security interest in Sanders’s goods, inventory,

chattel paper, accounts, inventory, equipment, monies, deposit accounts, rights to any payments and

proceeds, and other intangibles. The Fund shall be responsible for filing a Uniform Commercial

Code (“UCC”) statement pertaining to this security interest. The security interest shall remain in

effect so long as the Settlement Amount (or Total Amount Due, if applicable) remains unpaid.

4. The Court retains jurisdiction to enforce this Judgment.

s/David M. Lawson 

DAVID M. LAWSON

United States District Judge

Dated: March 3, 2016

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PROOF OF SERVICE

The undersigned certifies that a copy of the foregoing order was served

upon each attorney or party of record herein by electronic means or first

class U.S. mail on March 3, 2016.

s/Susan Pinkowski 

SUSAN PINKOWSKI

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