IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ALYSSA STARK,

Plaintiff,

v.

E COLLECTIVE HOLDINGS, INC., 

ELEMENT COLLECTIVE, INC., 

CHRISTOPHER DEXTER, individually, 

JARED VANCAMP, individually, 

CHRISTOPHER FREEMAN, individually 

and as Plan Administrator,

Defendants.

Case No. 20-cv-02219

Judge Edmond E. Chang

Magistrate Judge Sheila M. 

Finnegan

MOTION FOR ENTRY OF DEFAULT JUDGMENT

Plaintiff, Alyssa Stark, by and through her undersigned counsel, pursuant to the Court’s 

August 11, 2020 Order [Dkt. #22], and pursuant to Fed. R. Civ. P. 55, states as follows as her 

Motion for Entry of Default Judgment:

1. Plaintiff filed her Complaint in this action on April 9, 2020 seeking recovery 

against Defendants E Collective Holdings, Inc., Element Collective, Inc., for violations of 

ERISA, 29 U.S.C. § 1001, et seq. (Count I), breach of fiduciary duty (Count II). Plaintiff also 

seeks recovery from Christopher Dexter, and Jared VanCamp, E Collective Holdings, Inc., and 

Element Collective, Inc., for violations of the Illinois Wage Payment and Collection Act (Count 

III).

2. Defendant Jared VanCamp was served with the Complaint and Summons on July 

7, 2020.

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 1 of 11 PageID #:77
3. Defendant Christopher Dexter was served in his individual capacity on July 9, 

2020.

4. Defendants E Collective Holdings, Inc. and Element Collective, Inc. were served 

through Christopher Dexter, in his capacity as an owner and officer, on July 9, 2020.

5. On July 27, 2020, Defendant VanCamp filed a pro se appearance [Dkt. # 19], but 

has not filed a responsive pleading, which was due on or before July 28, 2020.

6. Neither Defendants Dexter, E Collective Holdings, Inc. or Element Collective, 

Inc. have filed a responsive pleading, which was due on or before July 30, 2020.

7. The Court granted the Defendants until August 24, 2020 to file their responsive 

pleadings [Dkt. #22], but they have not done so.

8. Defendants’ failure to defend and deny the allegations of Plaintiff’s Complaint 

results in those allegations being admitted and Plaintiff therefore moves the Court for the entry 

of Default Judgment. 

9. Pursuant to Counts I and II, Plaintiff is seeking “the amount of money to which 

she was entitled but did not receive under the terms of the Plan, and interest; for her reasonable 

attorneys’ fees and costs.” Compl. at 5, 6.

10. Those damages would overlap with the damages Plaintiff seeks against all four 

remaining Defendants in Count III, where she seeks “her actual and compensatory damages 

arising from Defendants’ violations of the Illinois Wage Payment and Collection Act; 2% of the 

amount of underpayments for each month following the date of payment during which such 

underpayment remains unpaid pursuant to 820 ILCS 115/14; for her reasonable attorneys’ fees 

and costs.” Id. at 8.

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 2 of 11 PageID #:78
11. Plaintiff has calculated her unpaid wages to be $53,628.03. Plaintiff has 

calculated 2% of the amount of underpayments for each month following the date of payment 

during which such underpayment remained to be $23,550.56. See Declaration of Alyssa Stark,

attached hereto as Exhibit A.

12. Counsel for Plaintiff has incurred 12.0 hours and his normal hourly rate is

$425/hour. Plaintiff’s counsel has also incurred $1,198.65 in expenses. See Declaration of 

Ethan White, attached hereto as Exhibit B.

13. Plaintiff therefore seeks $94,265.24 jointly and severally from the four remaining 

Defendants.

14. Plaintiff, through counsel, has attempted to notify Defendants of this Motion as 

detailed in the attached Declaration in Support. See Exhibit B.

WHEREFORE, Plaintiff, Alyssa Stark, respectfully requests that this Court enter an 

Order of Default Judgment against Christopher Dexter, and Jared VanCamp, E Collective 

Holdings, Inc., and Element Collective, Inc., in the amount of $94,265.24.

Dated: August 26, 2020 RESPECTFULLY SUBMITTED,

By: /s/ Ethan E. White

EMERY LAW, LTD.

Ethan E. White

2021 Midwest Road, Suite 200

Oak Brook, Illinois 60523

(630) 984-0339 (direct)

ewhite@emerylawltd.com

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 3 of 11 PageID #:79
CERTIFICATE OF SERVICE

I, the undersigned, being first duly sworn upon oath, depose, and say that I caused to be 

served the foregoing document by electronically filing the same with the Clerk for the U.S. 

District Court for the Northern District of Illinois, Eastern Division, a copy of which was then 

forwarded to each party who has appeared by CM/ECF on August 25, 2020. In addition, 

simultaneous with the filing, I have mailed a copy of this Motion via USPS Registered Mail to 

the following:

E Collective Holdings, Inc.

c/o Christopher Dexter

801 North Pitt Street, Apt. 1207

Alexandria, VA 22314 

Element Collective, Inc.

c/o Christopher Dexter

801 North Pitt Street, Apt. 1207

Alexandria, VA 22314

Christopher Dexter

801 North Pitt Street, Apt. 1207

Alexandria, VA 22314

Jared VanCamp

2328 North Spaulding, Apt 1B

Chicago, IL 60647 

RESPECTFULLY SUBMITTED,

Dated: August 26, 2020 By: /s/ Ethan E. White

 

EMERY LAW, LTD.

Ethan E. White

2021 Midwest Road, Suite 200

Oak Brook, IL 60523

(630) 984-0339 (direct)

ewhite@emerylawltd.com

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 4 of 11 PageID #:80
Exhibit A

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 5 of 11 PageID #:81
Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 6 of 11 PageID #:82
Exhibit 1

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 7 of 11 PageID #:83
Pay Date Gross Payroll Owed

Months Outstanding 

(rounded down) 2% per month outstanding

5/23/18 $2,807.00 27 $1,515.78

6/6/18 $3,807.00 26 $1,979.64

6/20/18 $2,844.03 26 $1,478.90

7/4/18 $3,807.00 25 $1,903.50

7/18/18 $3,807.00 25 $1,903.50

8/1/18 $3,807.00 24 $1,827.36

10/24/18 $3,807.00 22 $1,675.08

11/7/18 $3,807.00 21 $1,598.94

11/21/18 $3,807.00 21 $1,598.94

12/5/18 $3,807.00 20 $1,522.80

12/19/18 $3,807.00 20 $1,522.80

1/2/19 $3,807.00 19 $1,446.66

1/16/19 $3,807.00 19 $1,446.66

1/14/2019 $500.00 19 $190.00

1/21/19 $500.00 19 $190.00

1/28/19 $500.00 19 $190.00

2/4/19 $500.00 18 $180.00

2/11/19 $500.00 18 $180.00

2/18/19 $500.00 18 $180.00

2/26/19 $500.00 18 $180.00

3/4/19 $500.00 17 $170.00

3/13/19 $500.00 17 $170.00

3/18/19 $500.00 17 $170.00

3/25/19 $500.00 17 $170.00

4/1/19 $500.00 16 $160.00

SUBTOTAL $53,528.03 $23,550.56

TOTAL $77,078.59

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 8 of 11 PageID #:84
Exhibit B

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 9 of 11 PageID #:85
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ALYSSA STARK,

Plaintiff,

v.

E COLLECTIVE HOLDINGS, INC., 

ELEMENT COLLECTIVE, INC., 

CHRISTOPHER DEXTER, individually, 

JARED VANCAMP, individually, 

CHRISTOPHER FREEMAN, individually 

and as Plan Administrator,

Defendants.

Case No. 20-cv-02219

Judge Edmond E. Chang

Magistrate Judge Sheila M. 

Finnegan

DECLARATION OF ETHAN WHITE

IN SUPPORT OF PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT

I, Ethan White, declare as follows:

1. I am an attorney at law licensed to practice in Illinois, and admitted in the 

Northern District of Illinois. My business address is 2021 Midwest Road, Suite 200, Oak Brook, 

Illinois 60523. I am counsel of record of Plaintiff in this matter. 

2. To date, I have spent 12.0 hours in litigating this matter. 

3. I am a 2008 cum laude graduate of Northwestern Law School, a member of this 

District’s trial bar, and have litigated more than 80 cases in this District. While I am handling 

this matter on a contingency basis, my normal hourly rate is $425/hour.

4. My firm has incurred the follow case expenses to date:

Description Cost Dated

Filing fee for lawsuit. $400 04/09/2020

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 10 of 11 PageID #:86
Postage fee for Freeman waiver of summons and 

complaint. $10.05 04/27/2020

Postage fee for Van Camp and Dexter waiver of 

summons. $22 04/29/2020

LaSalle Process Server Invoice No. 61207 for service 

attempts on Freeman. $266.50 04/30/2020

Mailing fee for second waiver of summons to Van Camp. $10.05 05/21/2020

USPS postage fee for letter and waivers to C. Dexter 

regarding corporate entities. $10.05 06/01/2020

Invoice for LaSalle Process Servers for service of 

Complaint and Summons on VanCamp ($109), Dexter, E 

Collective, and Element Collective ($371). $480 07/16/2020

TOTAL Expenses: $1,198.65

5. On August 26, 2020, and contemporaneous with the filing of Plaintiff’s Motion for Entry 

of Default Judgment, I caused a copy of that Motion to be sent to Defendants via U.S. 

Postal Registered Mail at the address they were served with the Complaint.

6. I declare upon penalty of perjury that the foregoing is true and correct based on my own 

personal knowledge, except for those matters stated on information and belief, and those 

matters I believe to be true. If called upon to testify, I can and will completely testify as 

set forth above.

Dated: August 26, 2020

Ethan White

Case: 1:20-cv-02219 Document #: 23 Filed: 08/26/20 Page 11 of 11 PageID #:87