Grochocinski v. Mayer Brown Rowe & Maw LLP et al

Filing 249

PETITION by Defendants for Attorneys' Fees and Costs (Attachments: # 1 Exhibit A)(Ciszewski, Steven)

EXHIBIT A

EXHIBIT 1

SUMMARY CHART OF FEES FOR
DEFENDANTS' PETITION FOR ATTORNEYS' FEES AND COSTS
Grochocinski v. Mayer Brown Rowe & Maw, et al., No. 06-5486
Grochocinski Deposition Fees Sought
Invoice Dated January 1, 2009
Attorney Date
Hours
Rate
Subtotal
Marinello
12/22/08
2.6
$495
$1,287.00
Marinello
12/23/08
2.3
$495
$1,138.50
Marinello
12/24/08
1.5
$495
$742.50
$3,168.00
Less 15% Discount
($475.20)
Total (this Invoice)
$2,692.80
Invoice Dated February 1, 2009
Attorney Date
Hours
Rate
Subtotal
Marinello
1/13/09
7
$520
$3,640.00
Paralegal
1/13/09
2
$165
$330.00
Marinello
1/14/09
3.3
$520
$1,716.00
Paralegal
1/14/09
3
$165
$495.00
Marinello
1/15/09
6.5
$520
$3,380.00
Paralegal
1/15/09
2
$165
$330.00
Marinello
1/16/09
3.6
$520
$1,872.00
Paralegal
1/16/09
0.5
$165
$82.50
Marinello
1/17/09
6.1
$520
$3,172.00
Marinello
1/18/09
4.5
$520
$2,340.00
Marinello
1/19/09
9
$520
$4,680.00
$22,037.50
Less 15% Discount
($3,305.63)
Total (this Invoice)
$18,731.88
1/1/09 Invoice
2/1/09 Invoice
TOTAL
50%

$2,692.80
$18,731.88
$21,424.68
$10,712.34

Sanctions Motion Fees Sought
Invoice Dated May 17, 2010
Attorney Date
Hours
Rate
Subtotal
Haarlow
4/1/10
1
$275
$275.00
Novack
4/2/10
1.1
$650
$715.00
Ciszewski
4/2/10
2.7
$395
$1,066.50
Ciszewski
4/5/10
1.7
$395
$671.50
Ciszewski
4/8/10
3.9
$395
$1,540.50
Ciszewski
4/12/10
5.2
$395
$2,054.00
Ciszewski
4/13/10
3.1
$395
$1,224.50
Novack
4/14/10
0.5
$650
$325.00
Ciszewski
4/16/10
2.6
$395
$1,027.00
Novack
4/19/10
0.4
$650
$260.00
Novack
4/20/10
1.8
$650
$1,170.00
Ciszewski
4/20/10
2.9
$395
$1,145.50
Novack
4/21/10
0.1
$650
$65.00
$11,539.50
Less 15% Discount
($1,730.93)
Total (this Invoice)
$9,808.58

Invoice Dated April 22, 2011
Attorney Date
Hours
Novack
3/15/11
Ciszewski
3/15/11
Douglass
3/15/11
Marinello
3/17/11
Douglass
3/17/11
Marinello
3/18/11
Douglass
3/18/11
Douglass
3/19/11
Marinello
3/20/11
Douglass
3/20/11
Ciszewski
3/21/11
Douglass
3/21/11
Ciszewski
3/22/11
Douglass
3/22/11
Marinello
3/23/11
Novack
3/23/11
Ciszewski
3/23/11
Douglass
3/23/11
Marinello
3/24/11
Novack
3/24/11
Ciszewski
3/24/11
Douglass
3/24/11
Douglass
3/25/11
Novack
3/26/11
Novack
3/28/11
Ciszewski
3/28/11
Douglass
3/28/11
Douglass
3/30/11
Douglass
3/31/11

Rate
2.2
3.9
5.3
3.3
5.4
3
6
7.2
7.5
1.3
3.3
4.1
5.6
4.7
2
1
1.4
7.5
5
0.7
1.6
1.9
2.3
0.7
0.9
2.3
1.3
1.4
1

$670
$415
$350
$540
$350
$540
$350
$350
$540
$350
$415
$350
$415
$350
$540
$670
$415
$350
$540
$670
$415
$350
$350
$670
$670
$415
$350
$350
$350

Less 15% Discount
Total (this Invoice)
Invoice Dated May 23, 2011
Attorney Date
Hours
Marinello
4/7/11
Ciszewski
4/7/11
Douglass
4/7/11
Marinello
4/8/11
Novack
4/9/11
Douglass
4/9/11
Novack
4/10/11
Marinello
4/11/11
Novack
4/11/11
Douglass
4/11/11
Marinello
4/12/11
Novack
4/12/11
Douglass
4/12/11
Novack
4/13/11
Haarlow
4/14/11
Paralegal
4/14/11
Haarlow
4/15/11
Novack
4/16/11
Novack
4/18/11

Rate

Subtotal
$1,474.00
$1,618.50
$1,855.00
$1,782.00
$1,890.00
$1,620.00
$2,100.00
$2,520.00
$4,050.00
$455.00
$1,369.50
$1,435.00
$2,324.00
$1,645.00
$1,080.00
$670.00
$581.00
$2,625.00
$2,700.00
$469.00
$664.00
$665.00
$805.00
$469.00
$603.00
$954.50
$455.00
$490.00
$350.00
$39,718.50
($5,957.78)
$33,760.73

Less 15% Discount
Total (this Invoice)

Subtotal
$2,538.00
$1,618.50
$805.00
$1,242.00
$2,948.00
$105.00
$268.00
$648.00
$402.00
$420.00
$1,998.00
$804.00
$280.00
$201.00
$1,416.00
$478.50
$619.50
$871.00
$1,407.00
$19,069.50
($2,860.43)
$16,209.08

5/17/2010 Invoice
4/22/11 Invoice
5/23/11 Invoice
TOTAL
50%

$9,808.58
$33,760.73
$16,209.08
$49,969.80
$24,984.90

4.7
3.9
2.3
2.3
4.4
0.3
0.4
1.2
0.6
1.2
3.7
1.2
0.8
0.3
4.8
2.9
2.1
1.3
2.1

$540
$415
$350
$540
$670
$350
$670
$540
$670
$350
$540
$670
$350
$670
$295
$165
$295
$670
$670

EXHIBIT 2

EXHIBIT 3

Remit to:
Esquire Deposition Solutions
PO Box 934157
Atlanta GA 31193-4157
www.esquiresolutions.com

Esquire Solutions - Chicago
2700 Centennial Tower
101 Marietta Street
Atlanta, GA 30303

Toll Free [phone]
Fax [phone]

Invoice # EQ20314
Invoice Date

02/12/2009

Terms

NET 45

Payment Due
STEVEN CISZEWSKI ,ESQ.
NOVACK & MACEY, LLP - CHICAGO
SUITE 1500
100 NORTH RIVERSIDE PLAZA
CHICAGO, IL 60606

03/14/2009

Date of Loss
Name of Insured
Adjustor
Claim Number

Assignment

Case

Assignment #

Shipped

Shipped Via

01/19/2009

GROCHOCINSKI vs. MAYER BROWN ROWE

16290

02/03/2009

UPS

Description

Amount

Services Provided on 01/19/2009, DAVID GROCHOCINSKI (CHICAGO, IL)
ORIGINAL TRANSCRIPT - VIDEO/WORD INDEX

$ 1,728.50

VIDEO

$ 1,215.00

APPEARANCE FEE

$ 383.00

ETV DISK

$ 49.00
$ 3,375.50

DELIVERY - OTHER

$ 8.00

15% DISCOUNT

$ -506.33
$ -498.33

.

$ 0.00

Paid:

$ 2,877.17

Amount Due On/Before 03/29/2009

$ 0.00

Amount Due After 03/29/2009
Tax Number:

Tax:

$ 0.00

22-3779684
Please detach and return this bottom portion with your payment
or pay online at www.esquireconnect.net
Invoice #:

03/14/2009

Amount Due On/Before 03/29/2009

$ 0.00

Amount Due After 03/29/2009
STEVEN CISZEWSKI ,ESQ.
NOVACK & MACEY, LLP - CHICAGO
SUITE 1500
100 NORTH RIVERSIDE PLAZA
CHICAGO, IL 60606

EQ20314

Payment Due:

$ 0.00

Remit to:
Esquire Deposition Solutions
PO Box 934157
Atlanta GA 31193-4157
www.esquiresolutions.com
Thank you for your business!

Terms and Conditions
GENERAL
1. Parties. "Seller" means Alexander Gallo Holdings, ("AGH") and "Buyer" means AGH's client, attorney and law firm as well as the client that the attorney or law firm is representing, jointly and severely.
2. These terms and conditions (the "Terms and Conditions") supersede all prior representations or arrangements and contain the entire agreement between the parties in connection with Alexander Gallo Holdings
products and services. Seller's acceptance of Buyer's order and sale of the products and services to Buyer are expressly conditioned upon Buyer's assent to these Terms and Conditions of Sale and any and all
other terms and conditions, claimed to be expressed or implied, are excluded. Alexander Gallo Holdings hereby expressly objects to and rejects any and all additional or different terms contained in any other
documents submitted by Buyer in connection with the sale of the products. Any conduct by Buyer which recognizes the existence of a contract between Seller and Buyer, including, without limitation, acceptance of
delivery of or payment for the Products and Services shall be conclusive evidence of Buyer's assent to these Terms and Conditions.
3. No subsequent document, purchase order, or conduct, including acts or verbal statements of any buyer shall purport to modify these Terms and Conditions.
4. For further information regarding our pricing policy go to: www.esquiresolutions.com/services
CREDIT AND PAYMENT TERMS
1. Credit terms, if any, both as to time and amount, may be limited or revoked by Seller at any time without prior notice and thereafter the price of all or any part of Products delivered or to be delivered shall be
payable in accordance with such limited credit terms, or, at Seller's option, in cash before shipment or on or after acceptance of delivery ("COD"). In circumstances described in Section 6(a), all unpaid balances
owing to Seller from Buyer shall become immediately due and payable.
2. The Buyer agrees to pay for all services and products according to the terms established by the creditor in response to his order. No terms and conditions of any invoice or purchase order which differ from the
terms so established by the creditor will govern the relationship between the parties.
3. The client agrees that all amounts payable on or before the due date as shown on each invoice will be paid, and if not paid on or before said date, are then delinquent. Client further agrees that any amount
which is not paid when due shall be subject to an interest charge of 1.5% per month or the highest rate allowed by applicable law, until paid in full.
4. The customer agrees to be responsible for all collections costs and attorney's fees in the event AGH is forced to place the account for collection with an outside agency. If the collection is handled in-house by
AGH, customer agrees to be responsible for the in-house time and costs incurred which will be billed at the rate of $50.00 per hour.
5. A $35 handling fee will be assessed to checks returned for insufficient funds.
SOLVENCY
1. The client represents that, as of the date of its order or scheduled deposition, it is solvent, able to pay its debt as they come due and has not filed, nor is it subject of any petition of bankruptcy or for
reorganization under any federal or state bankruptcy law. Should the foregoing representation become false at any time during the course of a business relationship between the client and the creditor or while the
client owes any amount to the creditor, client agrees to immediately notify AGH of all facts surrounding such occurrences.
2. The client authorizes AGH to obtain a written or oral credit report from any credit reporting agency. In addition, the client further authorizes any bank or commercial business with whom the client is doing or has
done any type business to give any and all necessary information to AGH which will assist the creditor in the investigation. The client further authorizes the creditor to reinvestigate the client's credit status from time
to time as the creditor deems necessary.
GOVERNING LAW
1. The Contract, including, without limitation, these Terms and Conditions, shall be governed by and construed in accordance with law of the State of New Jersey.
2. The Buyer agrees that the jurisdiction and venue for all disputes under this invoice will be New Jersey.
MISCELLANEOUS
1. Buyer may not assign its rights under the contract without Seller's prior written consent.
2. Failure by seller at any time or times to require strict performance of any provision hereof shall not be considered to be a waiver of Seller's rights with respect to such breach or any succeeding breach of such
provision or any other provision of these Terms and Conditions.
3. If any provision of these Terms and Conditions or the application thereof to any person or circumstance shall to any extent be held invalid or unenforceable, the remainder of such Terms and Conditions or the
application of such provision to person or circumstances other than those to which it was held to be invalid or unenforceable shall not be affected thereby and shall be valid and be enforceable to the fullest extent
permitted by law.
4. Except where it is specified that a price stated is "firm", all prices are subject to change and orders will be invoiced at Seller's prices prevailing at the time the deposition is taken. All accounts are payable in U.S.
funds, free of exchange, collection or other charges, in cases where price for Products include shipping costs, any increase in such shipping costs shall be for Buyer's account and Buyer agrees to pay Seller such
increases.
5. All applicable sales and use taxes, or any other taxes or charges imposed now or in the future by any federal, state, foreign or local authority upon the production, sale, or transportation of the Products shall be
for the account Buyer.

Disclaimer
Attorney is responsible for payment of all charges incurred. Payment due by "Payment Due" date shown on invoice. Transcript package typically includes transcript/word index, exhibits, appearance fee,
condensed transcript, litigation support disk, deposition summary, shipping, video charges and may include other service charges based on job or region. Some services and rates may vary by job or region.
Please contact your local office for specific detail and questions.

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