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UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF MICHIGAN

EUGENE SCALIA, )
SECRETARY OF LABOR, )
UNITED STATES DEPARTMENT OF LABOR, )
)
Plaintiff, )
)
v. ) Case No. 1:20-cv-9
)
CLEMENTINE’S SALOON, INC., et al. )
)
Defendants. )

MOTION FOR ENTRY OF JUDGMENT

The parties, having reached agreement in this case, respectfully move the Court

for entry of a consent judgment. In support of this motion, the parties state:

1. Plaintiff, the Secretary of Labor, United States Department of Labor

brought this action against Clementine’s Saloon, Inc., Clementine’s Too, Inc., and Alfred

Ruppert, individually (“Defendants”) for violating various provisions of the Fair Labor

Standards Act, 29 U.S.C. §201 et seq.

2. Defendants are represented by Mathew S. Disbrow, who has entered his

appearance in this case on behalf of each Defendant.

3. Defendants’ counsel represents to the Court that he has explained the

allegations of the lawsuit to his clients, and that each desires to settle this matter by

entering into the Consent Judgment, a copy of which is attached hereto, and which

contains the terms of their settlement with the Secretary of Labor.

4. Defendants’ counsel represents to the Court that he has personal

knowledge of Defendants’ signatures, and that the signatures of Defendants contained on

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the Consent Judgment are the true and valid signatures of his clients, Clementine’s

Saloon, Inc., Clementine’s Too, Inc., and Alfred Ruppert, individually (“Defendants”).

The Defendants’ counsel further represents that Defendants signed the Consent Judgment

of their free will after obtaining advice of counsel and with the desire to resolve the

matter expeditiously.

5. Counsel for the Secretary and Defendants represent to the Court that the

Consent Judgment is the result of fully informed and good faith negotiations that

occurred over several months.

WHEREFORE, Defendants having consented to the entry of Judgment against

them, the parties respectfully request that this Court enter the proposed Consent

Judgment submitted concurrently with this Motion.

Respectfully Submitted,

Kate S. O’Scannlain
Solicitor of Labor

Christine Z. Heri
Regional Solicitor
IL Bar No. 6204656

Evert H. Van Wijk

Associate Regional Solicitor

s/Linda Ringstad
Linda Ringstad
Counsel for Wage & Hour
U.S. Department of Labor
Office of the Solicitor
230 S. Dearborn Street, Suite 844
Chicago, IL 60604
(312) 353-3668
(312) 353-5698 (fax)
ringstad.linda@dol.gov

ATTORNEYS FOR PLAINTIFF

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HONIGMAN LLP

s/Mathew S. Disbrow
Mathew S. Disbrow
2290 First National Building
660 Woodward Avenue
(313) 465-7372 telephone
mdisbrow@honigman.com

ATTORNEY FOR DEFENDANTS

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