The Trustees of the Local 138 Pension Trust Fund and The Local 138 Pension Trust Fund v. L&J Trucking, Inc., Lydia Cosme, Tony Cosme, and LJ Delivery, Inc. d/b/a L&J Trucking

CourtDistrict Court, E.D. New York
DecidedNovember 19, 2025
Docket2:24-cv-03188
StatusUnknown

This text of The Trustees of the Local 138 Pension Trust Fund and The Local 138 Pension Trust Fund v. L&J Trucking, Inc., Lydia Cosme, Tony Cosme, and LJ Delivery, Inc. d/b/a L&J Trucking (The Trustees of the Local 138 Pension Trust Fund and The Local 138 Pension Trust Fund v. L&J Trucking, Inc., Lydia Cosme, Tony Cosme, and LJ Delivery, Inc. d/b/a L&J Trucking) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Trustees of the Local 138 Pension Trust Fund and The Local 138 Pension Trust Fund v. L&J Trucking, Inc., Lydia Cosme, Tony Cosme, and LJ Delivery, Inc. d/b/a L&J Trucking, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT CLERK

EASTERN DISTRICT OF NEW YORK 11/19/ 2025 --------------------------------------------------------------X U.S. DISTRICT COURT THE TRUSTEES OF THE LOCAL 138 PENSION EASTERN DISTRICT OF NEW YORK TRUST FUND and THE LOCAL 138 PENSION LONG ISLAND OFFICE TRUST FUND, Plaintiffs, REPORT AND RECOMMENDATION 2:24-cv-03188 (GRB) (JMW) -against- L&J TRUCKING, INC., LYDIA COSME, TONY COSME, and LJ DELIVERY, INC. d/b/a L&J TRUCKING, Defendants. --------------------------------------------------------------X A P P E A R A N C E S: Susan M. Bruno Cary Kane PLLC 1350 Broadway, Suite 1410 New York, NY 10018 Attorney for Plaintiffs No Appearance by Defendants WICKS, Magistrate Judge: Plaintiffs The Trustees of the Local 138 Pension Trust Fund (“Trustees”) and The Local 138 Pension Trust Fund (“Fund”) (collectively, “Plaintiffs”) commenced this action against L&J Trucking, Inc. and principal officers of L&J Trucking, Lydia and Tony Cosme, on April 29, 2024, asserting claims of breach of a collective bargaining agreement (“CBA”) and seeking to enforce the requirements of the Employee Retirement Income Security Act (“ERISA”), §515, 29 U.S.C. § 1145, and §502, 28 U.S.C. §1132, et seq. (See generally ECF No. 1.) Namely, Plaintiffs assert causes of action for: (1) unpaid contributions to the Fund in violation of ERISA §§ 502 and 515, 29 U.S.C. §§1132 and 1145, and §502, 28 U.S.C. §1132(g)(2), et seq.; (2) unpaid withdrawal liability to the Fund pursuant to ERISA § 4219(c)(5), 29 U.S.C. §1399(c)(5), and 502(g)(2) and 4201(b), 29 U.S.C. § 1132(g)(2) and 1451(b); and (3) unpaid contributions from Lydia and Tony Cosme. (Id.) On January 10, 2025, Plaintiffs filed an Amended Complaint asserting the same causes of action but only as against LJ Delivery Inc. d/b/a L&J Trucking

(“L&J”) and Tony Cosme. (ECF No. 12.) On referral from the Honorable Gary R. Brown is Plaintiffs’ motion for default judgment (ECF No. 19) which seeks the following relief: (1) $1,981,042.20 for withdrawal liability and unpaid contributions; (2) interest awarded on withdrawal liability and unpaid contributions at 8.2% per annum from dates due to date of judgment; (3) liquidated damages equal to the amount of interest; (4) $8,450 in attorneys’ fees; and (5) $1,476.02 in costs related to this action. (ECF No. 19-9.) For the following reasons, the undersigned respectfully recommends that the District Judge GRANT Plaintiffs’ motion (ECF No. 19) and award the damages as set forth below. BACKGROUND

A. Factual Background The Fund is a “multiemployer” pension benefit plan that provides benefits to eligible employees and their dependents. (ECF No. 12 at ¶ 6.) The Trustees are the “plan sponsor” of the Fund and serve as “fiduciaries” of the Fund. (Id. at ¶ 7.) L&J was an “employer” and a domestic corporation with its place of business in New York. (Id. at ¶¶ 8-9.) Tony Cosme is the current principal officer of L&J and resides in New York. (Id. at ¶¶ 2, 9-10.) Plaintiffs allege that L&J is required to make contributions to the plan on the employees’ behalf pursuant to the CBA between L&J and Local 138 IBT (the “Union”). (Id. at ¶ 12.) Per the CBA’s terms, L&J was required to remit monthly contributions to the Fund for all eligible employees covered by the CBA. (ECF No. 19-1, McInnis Aff. at ¶¶ 8, 10.) In October of 2023, L&J “ceased operations” at which point L&J “permanently ceased to have an obligation to make contributions to the Fund and/or ceased all covered operations under

the Fund . . . .” (ECF No. 12 at ¶ 12.) At the time of its cessation of operations, L&J “failed to pay contributions owed to the Fund for the months of May 2023 through October 2023 totaling $13,305.60.” (Id. at ¶ 13.) Additionally, Plaintiffs assert that L&J incurred, and thus Plaintiffs were entitled to, withdrawal liability in the amount of $1,977,8391 under ERISA § 4201, 29 U.S.C. § 1381, et seq. (Id. at ¶¶ 14, 15.) Consequently, on February 12, 2024, the Fund sent a demand letter to L&J for withdrawal liability pursuant to ERISA § 4219(b), 29 U.S.C. § 1399(b)(1), outlining the amount L&J owed and explaining the first of many quarterly payment would be due February 15, 2024. (Id. at ¶ 15.) L&J failed to make timely payment. (See id. at ¶ 18.) On February 23, 2024, the Fund sent a notice of default and demand of payment letter to L&J regarding the unpaid

contributions and unpaid withdrawal liability, noting the Fund would institute legal action to recover these outstanding payments if the default was not cured within 60 days. (Id. at ¶ 19.) L&J failed to respond. (See id. at ¶ 20.) To date, L&J has neither paid the unpaid contributions nor made payments towards the withdrawal liability. (Id. at ¶¶ 22.) Plaintiffs further aver that if Tony Cosme, as L&J’s principal, received assets upon L&J’s dissolution, he is liable as an existing creditor for all corporate property distributed to him upon L&J’s dissolution. (Id. at ¶¶ 30-31.)

1 This amount was determined by the Fund’s actuary pursuant to Section 4213 of ERISA, 29 U.S.C. 1393. (ECF No. 12 at ¶ 14; ECF No. 19-1, McInnis Aff. at ¶¶ 11-12.) B. Procedural History The Complaint was filed on April 29, 2024 (ECF No. 1), and service was returned executed on June 24, 2024 and L&J Trucking Inc.’s answer was due on or before July 12, 2024. (ECF No. 6.) L&J Trucking failed to answer or otherwise respond to the complaint. On July 31,

2024, Plaintiffs requested a certificate of default as against L&J (ECF No. 7) which was entered by the Clerk of Court on the same day. (ECF No. 8.) The undersigned then directed Plaintiffs to file their motion for default judgment in accordance with the Hon. Gary R. Brown’s rules on or before August 30, 2024. (Electronic Order dated August 1, 2024). Plaintiffs filed their motion for default judgment against L&J on August 14, 2024 (ECF No. 9) and the following day Judge Brown referred Plaintiffs’ motion to the undersigned for a Report and Recommendation. (Electronic Order dated August 15, 2024.) The Court subsequently indicated that in the Complaint, “express references” were made that the corporate defendant that Plaintiffs sought default judgment against “has been dissolved” but no date of dissolution has been provided. (Electronic Orde dated January 3, 2025) (citing

ECF No. 1 at ¶¶ 31-34.) Critically, according to N.Y. Bus. Corp. Law § 1006(b), “a plaintiff may pursue any remedy available ... against a dissolved corporation ... for any right or claim existing or any liability incurred before such dissolution.” (Id. (emphasis in original)). As such, the parties were directed to “supplement their motion for default judgment by filing a declaration with supporting proof of when the dissolution of the corporate defendant occurred.” (Id.) Plaintiffs, on January 7, 2025, filed their supplemental letter stating that LJ Delivery, Inc. legally succeeded L&J Trucking, Inc., an entity that dissolved in October 2009. (See ECF No.

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The Trustees of the Local 138 Pension Trust Fund and The Local 138 Pension Trust Fund v. L&J Trucking, Inc., Lydia Cosme, Tony Cosme, and LJ Delivery, Inc. d/b/a L&J Trucking, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-trustees-of-the-local-138-pension-trust-fund-and-the-local-138-pension-nyed-2025.