Williams et al v. Blagojevich et al

Filing 504

MOTION by Defendant Bruce Rauner for judgment order re attorney fees and costs (Stratton, Brent)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ETHEL WILLIAMS, et al.,

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Plaintiffs,
v.
BRUCE RAUNER, et al.,
Defendants.

No. 05-cv-4673
Judge Joan H. Lefkow

JOINT MOTION TO ENTER AGREED JUDGMENT ORDER
Pursuant to the approved Consent Decree in this case, Plaintiffs and Defendants
respectfully move that this Court enter an Agreed Judgment Order for payment in the amount of
$126,562.20 in full settlement of all reasonable attorneys’ fees, costs and expenses incurred by
Class Counsel from October 1, 2017 through and including June 30, 2018, and payment in the
amount of $112,952.45 in full settlement of all reasonable attorneys’ fees, costs and expenses
incurred by Class Counsel from July 1, 2018 through and including December 31, 2018.
1.

The Consent Decree (Decree) was approved on September 29, 2010. (Dkt. No.

2.

An Amended Judgment was entered by the Court on November 1, 2010 (Dkt. No.

326.)

335) in favor of Class Counsel and against Defendants in the amount of $1,990,000 representing
attorneys’ fees only. A further Amended Judgment was entered by the Court on February 16,
2011 (Dkt. No. 342) in favor of Class Counsel and against Defendants in the amount of
$401,828.58 representing Class Counsels’ reasonable out-of-pocket costs and expenses.
3.

The Parties have agreed that Defendants will pay to Class Counsel reasonable

attorneys’ fees, costs and expenses in the amount of $126,562.20 incurred from October 1, 2017

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through and including June 30, 2018 and $112,952.45 incurred from July 1, 2018 through and
including December 31, 2018.
4.

The Defendants will cause vouchers for payment in the amounts of $126,562.20

and $112,952.45 to be submitted for processing under the standard vouchering procedures and
they will be processed in accordance with the Comptroller’s requirements.
WHEREFORE, Plaintiffs and Defendants respectfully request that the Court enter the
proposed Agreed Judgment Order in the amounts of $126,562.20 and $112,952.45, reflecting the
agreed amounts of reasonable attorneys’ fees, costs and expenses incurred by Class Counsel
from October 1, 2017 through and including December 31, 2018.

DATED: March 29, 2019

Respectfully submitted,

COUNSEL FOR DEFENDANTS

COUNSEL FOR PLAINTIFFS

KWAME RAOUL
Attorney General for the State of Illinois

/s/ Benjamin S. Wolf
Benjamin S. Wolf
Claire E.W. Stewart
Roger Baldwin Foundation of ACLU, Inc.
150 N. Michigan Ave., Ste. 600
Chicago, IL 60601

/s/ Brent D. Stratton
Brent D. Stratton
Assistant Attorney General
100 W. Randolph St., 12th Floor
Chicago, IL 60601

Barry C. Taylor
Laura J. Miller
Amy F. Peterson
Equip for Equality
20 N. Michigan Ave., Ste. 300
Chicago, IL 60602
Lewis Bossing
Ira Burnim
Jennifer Mathis
Bazelon Center for Mental Health Law
1101 15th St. NW, Ste. 1212
Washington, DC 20005

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CERTIFICATE OF SERVICE
The undersigned, an attorney, certifies that on March 29, 2019, he caused a copy of the
above and foregoing JOINT MOTION TO ENTER AGREED JUDGMENT ORDER to be
served on all counsel of record via the Court’s electronic filing system (CM/ECF).

/s/ Brent D. Stratton

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