Kardonick v. JP Morgan Chase & Co. et al

Filing 439

Plaintiff's MOTION for Miscellaneous Relief: Release of Settlement Funds by David Kardonick. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Ku, Brian)

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December 2, 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 May 1, 2011 through November 30, 2011, as follows: The following represent items that are billed on a per item basis: 1. Maintain and monitor on a monthly basis the website www.kardonicksettlement.com; 2. Maintain and monitor the toll free telephone system with automated responses (IVR). 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. Scan all documents received. Re-mail those with updated addresses through August. Send all others to TransUnion to search for an updated address. Re-mail all returned by TransUnion with updated address through August; 6. Update database for all change of address notifications received; 7. Receive electronic claims; receive and data enter paper 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. Review Orders and other Court documents, discuss with Counsel; Richard Golumb Randall Pulliam 2 December 2, 2011 3. Meetings and conference calls with Counsel and staff on various issues noted in the Notice mailing process, claims submission and regarding status issues; 4. Monitor and maintain IT compliance and security review; 5. Revisions to website based on issues or requests. Richard Golumb Randall Pulliam December 2, 2011 3 INVOICE I. COSTS: A. PROOF OF CLAIM FORMS: Electronic Claims : 65,599 claims @ $.40 $ 26,239.60 Paper Claims 10,741 claims @ $.95 10,203.95 Total invoiced for claims activity this period B. C. D. E. $ 36,443.55 IVR / LIVE OPERATOR COSTS: IVR Call minutes 169,833 minutes @ $0.23/min. Live Operators 30,900 minutes @ $0.50/min. Internal Operators1 18,015 minutes @ $0.50/min. 39,061.59 15,450.00 9,007.50 WEBSITE MAINTENANCE: Monthly Maintenance (8 @ $750/month) 5,250.00 CORRESPONDENCE: Responses/Deficiency Letters 1,460.50 2,921 @ $0.50/response PROCESS RETURNED POSTCARDS 317,781 returns @ $0.05 661,054 printed notices to re-mail @ $0.039 15,889.05 25,781.11 F. SCANNING OF RETURNED NOTICES & PAPER CLAIM FORMS SUBMITTED (reduced rate) Scans 1,159,061 @ $0.05 57,953.05 G. OTHER OUT-OF-POCKET COSTS: Telephone Claim Form Package & Postage2 Locator Service (NCOA & TransUnion) Postage 3 Post Office Box Renewal Sales Tax on Returns and Remails Photocopies (2,545 @ $0.10) $ 3,348.95 15,830.25 75,505.34 48,195.94 605.00 1,184.08 254.50 144,924.06 TOTAL COSTS 1 $ 351,220.41 Use of external operators terminated on June 14, 2011. Internal operator time only reflects time they spent on Kardonick case calls and messages. 2 21,500 claim form packages were printed as inventory to mail per the requests received by the live operators, correspondence, etc. The amount is net of $4,693.63 in excess postage received in the original advance. 3 This postage relates to additional notices re-mailed that were not covered by the advance postage received of $93,000 received on July 25, 2011. HR&S advanced this additional postage to allow the Notices to be released promptly. Richard Golumb Randall Pulliam II. 4 December 2, 2011 FEES: Partners 21.00 Hours @ $210.00 - $265.00 Managers / Computer Programmers 65.75 Hours @ $150.00 - $175.00 Senior Accountants / Data Processing Supervisors 42.75 Hours @ $110.00 - $150.00 TOTAL FEES TOTAL INVOICE Amount Due from Invoice Dated May 31, 2011 Amount Paid Amount Due TOTAL DUE $ 5,250.00 10,237.50 4,702.50 20,190.00 $ 371,410.41 $ 273,200.68 247,898.18 25,302.50 $ 396,712.91

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