Sullivan et al v. A.M. Mechanical Inc.

Filing 38

MOTION by Plaintiffs Plumbers' Welfare Fund, Local 130, U.A., The Trust Fund for Apprentice and Journeymen Education and Training, Local 130, U.A.,, Chicago Journeymen Plumbers Local Union 130, U.A., Group Legal Services Plan Fund, James T Sullivan, Plumbers' Pension Fund, Local 130, U.A. for judgment (Attachments: # 1 Exhibit A, # 2 Exhibit B, 1 of 2, # 3 Exhibit B, 2 of 2, # 4 Exhibit C, # 5 Exhibit C-1, # 6 Exhibit D - F)(Bedinghaus, Brian)

EXHIBIT C

BTB139686 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAMES T. SULLIVAN, etc., Plaintiff, v. A M MECHANICAL, INC., ) ) ) ) ) ) ) ) ) ) )

65100-1073LIT4685

No. 07 C 2200 Judge Pallmeyer Magistrate Judge Valdez

Defendant.

AFFIDAVIT CONCERNING ATTORNEYS' FEES AND COSTS DOUGLAS A. LINDSAY states that if he were called to testify in the captioned case he would testify as follows: 1. 2. I am an adult and competent. The information contained in this Affidavit is based on my personal knowledge

and the business records of LEWIS, OVERBECK & FURMAN, LLP (Firm). 3. During the course of this litigation, Douglas A. Lindsay, a Partner in Firm,

rendered 9.1 hours of legal services to Plaintiff at a rate of $275.00 per hour, and 8.2 hours at a rate of $300.00 per hour, for a total of $4,962.50. 4. During the course of this litigation, James R. Gannon, a Partner in Firm, rendered

1.4 hours of legal services to Plaintiff, at a rate of $300.00 per hour, and 1.8 hours at a rate of $275.00 per hour, for a total of $915.00. 5. During the course of this litigation, Lisa M. Simioni, a former Associate in Firm,

rendered 30.4 hours of legal services to Plaintiff at a rate of $170.00 per hour, and 30.3 hours at a rate of $185.00, for a total of $10,773.50. 1

6.

During the course of this litigation, Brian T. Bedinghaus, an Associate in Firm,

rendered 5.0 hours of legal services to Plaintiff, at a rate of $170.00 per hour, for a total of $850.00. 7 During the course of this litigation, Albert B. Davis, a paralegal in the Firm,

rendered 0.4 hours of legal services to Plaintiff, at a rate of $70.00 per hour, for a total of $28.00. 8. During the course of this litigation, Robert C. Parizek, a paralegal in the

Firm, rendered 2.7 hours of legal services to Plaintiff, at a rate of $75.00 per hour, for a total of $202.50. 9. 10. The legal professionals' fees incurred by Plaintiff in this matter total $17,731.50. Plaintiff has also incurred $350.00 in court filing fees, $170.00 for service of

process fees, $120.00 for computerized docketing charges, $5.20 in postage fees, $17.50 in facsimile charges, $10.50 in binging charges, $212.16 in photocopy charges, and $17.76 in computerized legal research charges for total costs of $903.12. 11. 12. The total amount due Plaintiff for legal fees and costs is $18,634.62. Attached hereto as Attachment C-1 are true and correct copies of itemized time

records and expense records made and kept in the ordinary course of Firm's business. 13. I have over thirty-two years of ERISA and LMRA litigation experience. I have

been admitted to practice by the following courts: Illinois Supreme Court (1976); United States District Court for the Northern District of Illinois (General Bar, 1976; Trial Bar, 1982); United States District Court for the Eastern District of Wisconsin (1985); United States District Court for the Northern District of Indiana (1990); United States District Court for the Central District of Illinois (1994); United States Court of Appeals for the 7th Circuit (1982); the United States Supreme Court (1999).

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