Kardonick v. JP Morgan Chase & Co. et al

Filing 285

Plaintiff's MOTION FOR MISCELLANEOUS RELIEF by David Kardonick. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Text of Proposed Order)(Ku, Brian)

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EXHIBIT “A” EXHIBIT “A” May 31, 2011 Via E-mail Richard Golomb, Esquire GOLOMB & HONIK, P.C. 1515 Market Street Suite 1100 Philadelphia, PA 19102 Re: Via E-mail Randall K. Pulliam, Esquire CARNEY WILLIAMS BATES BOZEMAN & PULLIAM PLLC 11311 Arcade Drive Suite 200 Little Rock, AR 72212 Kardonick, et. al. v. JP Morgan Chase &Co. et. al. Litigation For services rendered and expenses incurred for the period through April 30, 2011, as follows: The following represent items that are billed on a per item basis: 1. Generate the website including electronic claim capability. Maintain and monitor on a monthly basis the website www.kardonicksettlement.com; 2. Establish a toll free telephone system with automated responses (IVR). Maintain and monitor on a monthly basis. Also have live operators available to assist class members; 3. Pick-up of mail at P.O. Box 280 on an as-needed basis. Open and sort the mail received, batch the claims, returns and requests separately, as applicable; 4. Respond to telephone, written and e-mail inquiries concerning status, request for forms and general information; 5. Process returned/undeliverable notices. Re-mail those with updated addresses. Send all others to TransUnion to search for an updated address; 6. Update database for all change of address notifications received; 7. Receive and enter claims into the database. The following represent items that are billed at the hourly rates listed in our proposal: 1. Prepare status reports and activity updates for Counsel on an as needed basis; 2. Prepare affidavit on the notification process; 3. Review Orders and other Court documents, discuss with Counsel; 4. Discussions with Chase’s Counsel on issues with the mailing database. A number of Class Members noted as having the same address in the system. These were determined to be debt assistance companies or law firms; 5. Meetings and conference calls with Counsel on various issues noted in the Notice mailing process and on status issues; 6. IT compliance, security review and on-site inspection to meet Chase standards for matter. INVOICE I. COSTS: A. PROOF OF CLAIM FORMS: Initial set-up of claims system $ 35,000.00 Electronic Claims : 158,628 claims @ $.40 $ 63,451.20 Paper Claims 292 claims @ $.95 277.40 Total invoiced for claims activity this period B. C. D. E. F. $ 63,728.60 IVR / LIVE OPERATOR COSTS: Initial IVR Set-up Initial live operator training & call monitoring IVR Call minutes 194,828 minutes @ $0.23/min. Live Operators 60,960 minutes @ $0.50/min. 1,000.00 1,000.00 44,810.44 30,480.00 WEBSITE MAINTENANCE: Generate the Website Monthly Maintenance (1 @ $750/month) 5,000.00 750.00 CORRESPONDENCE (includes postage): Responses 9,975 @ $0.50/response 4,987.50 RETURNED POSTCARDS 841,280 returns @ $0.05 OTHER OUT-OF-POCKET COSTS: Telephone Open Post Office Box Claim Form Package & Postage1 Locator Service Sales Tax on Original Mailing Sales Tax on Returned Postcard Processing Domain Name Fees Photocopies (214 @ $0.10) 42,064.00 $ 215.27 580.00 7,070.23 297.00 6,365.57 4,520.00 8.17 21.40 19,077.64 TOTAL COSTS 1 $ 247,898.18 7,326 claim form packages were printed and mailed per the requests received by the live operators. II. FEES: Partners 70.75 Hours @ $210.00 - $265.00 $ 17,687.50 Managers / Computer Programmers 36.00 Hours @ $150.00 - $175.00 5,937.50 Senior Accountants / Data Processing Supervisors 15.25 Hours @ $110.00 - $150.00 1,677.50 Staff Accountants & Clerical Supv’r 0.00 Hours @ $50.00 - $90.00 0.00 Clerical/Data Entry Staff 0.00 Hours @ $40.00 - $50.00 0.00 TOTAL FEES TOTAL INVOICE 25,302.50 $ 273,200.68

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