Sullivan et al v. East West Plumbing, Inc.

Filing 9

MOTION by Plaintiffs Trust Fund for Apprentice and Journeyman Education and Training, Local 130, U.A., The, Chicago Journeymen Plumbers' Local Union 130, U.A., Group Legal Services Plan Fund, James T. Sullivan, Plumbing Council of Chicagoland, Chicagoland, The, Chicago Journeymen Plumbers' Local Union 130, U.A., Plumbers' Pension Fund Local 130, U.A., Plumbers' Welfare Fund Local 130, U.A. for judgment (Attachments: # 1 Exhibit A through D)(Bedinghaus, Brian)

EXHIBIT A

Case 1:08-cv-06510

Document 8

Filed 11/24/2008

Page 1 of 2

Case 1:08-cv-06510

Document 8

Filed 11/24/2008

Page 2 of 2

EXHIBIT B

EXHIBIT C

12-17-08BTB140115 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAMES T. SULLIVAN, etc., et al., Plaintiffs, ) ) ) ) ) ) ) ) ) ) )

65100-1093LIT-4708

No.

08 C 6510

Judge James F. Holderman Magistrate Judge Michael T. Mason

v. EAST WEST PLUMBING, INC., an Illinois corporation, 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, the

business records of LEWIS, OVERBECK & FURMAN, LLP (Firm), and review of public records. 3. During the course of this litigation, Douglas A. Lindsay, a partner in Firm, rendered 3.2

hours of legal services to Plaintiffs at a rate of $300.00 per hour, for a total of $960.00. 4. During the course of this litigation, Brian T. Bedinghaus, an associate in Firm, rendered

2.6 hours of legal services to Plaintiffs, at a rate of $170.00 per hour, for a total of $442.00. 5. During the course of this litigation, Robert C. Parizek, a paralegal in the Firm,

rendered 4.3 hours of legal services to Plaintiffs, at a rate of $85.00 per hour, for a total of $365.50. 6. 7. The legal professionals' fees incurred by Plaintiffs in this matter total $1,767.50. Plaintiffs have also incurred $350.00 in court filing fees, $60.00 for service of process

fees, $60.00 for computerized docketing charges, $15.00 in postage charges, and $69.84 in photocopy 1

EXHIBIT C-1

Report ID: OT2025 - 25344 Thursday, December 18, 2008 Client 65100

Lewis, Overbeck & Furman, LLP Time And Expense Details
Matter 01093 Date [04/23/2008 - 12/16/2008] Matter Reporting Name 4708 East West Plumbing, Inc. Activity Narrative

Client Reporting Name Plumbers 130 Litigation

Billing Timekeeper

Printed By Page

SKOU 1

Unbilled Time Date Timekeeper 12/1/2008 12/2/2008 12/10/2008 12/10/2008 Unbilled Time Totals RCP DAL BTB DAL

Lindsay, Douglas A.

Hours Worked 0.10 0.10 0.10 0.40 0.60 1.30 Amount Exp Code $350.00 MISC $350.00 Hours Worked 0.20 0.10 0.40 0.10 1.00 0.20 0.20 0.20 0.10 0.20 0.40 1.90 2.00

Hours To Bill 0.10 0.10 0.10 0.40 0.60 1.30 Narrative

Rate 85.00 300.00 170.00 300.00 170.00

Amount Task $8.50 $30.00 $17.00 $120.00 $102.00 $277.50

12/16/2008 BTB

Organized file Conference with Funds' Field Representative regarding case status Email to Douglas A. Lindsay regarding next steps Review file; check status of Defendant's response via CM/ECF; email to all concerned regarding motion for judgment Reviewed file; prepared motion for entry of judgment and supporting exhibits

Unbilled Expenses Date Unbilled Expenses Billed Time Date Timekeeper 4/24/2008 DAL 5/13/2008 RCP 7/18/2008 DAL 7/23/2008 7/24/2008 7/24/2008 8/5/2008 8/6/2008 8/11/2008 11/4/2008 11/10/2008 DAL RCP DAL DAL DAL DAL DAL DAL Totals 12/10/2008

Northern District of Illinois - File Lawsuit papers

Hours On Bill 0.20 0.10 0.40 0.10 1.00 0.20 0.20 0.20 0.10 0.20 0.40 1.90 2.00

Rate 300.00 85.00 300.00 300.00 85.00 300.00 300.00 300.00 300.00 300.00 300.00 170.00 85.00

Amount Task $60.00 $8.50 $120.00 $30.00 $85.00 $60.00 $60.00 $60.00 $30.00 $60.00 $120.00 $323.00 $170.00

Activity

Narrative Review file regarding status of Award; telephone conference with JAB Secretary regarding delivery of Award to Contractor; memo to file Organized file Conference with Funds' Field Representative; review file; fax from Funds' Field Representative; determine deadline; memo to paralegal Review file regarding bond claim Worked on pre-suit payment demand letter Finalize pre-suit payment request letter and arrange distribution; diary follow up date Review file; voicemail to Funds' Filed Representative; memo to file Telephone conference with Funds' Field Representative; memo to file Telephone conference with Funds' Field Representative Telephone conference with Funds' Field Representative; review file; memo to file Review documents from Funds' Field Representative and file; corporate data research; email to all concerned Reviewed file; prepared lawsuit papers Worked on preparation of lawsuit papers; organized file; processed vendor invoice; worked on service of process and courtesy copies

11/12/2008 BTB 11/13/2008 RCP

Report ID: OT2025 - 25344 Thursday, December 18, 2008 Billed Time Date Timekeeper 11/13/2008 DAL 11/24/2008 DAL 11/24/2008 RCP Billed Time Hours Worked 0.50 0.20 1.10 Hours On Bill 0.50 0.20 1.10

Lewis, Overbeck & Furman, LLP Time And Expense Details
Date [04/23/2008 - 12/16/2008] Rate 300.00 300.00 85.00 Amount Task $150.00 $60.00 $93.50 Activity Narrative

Printed By Page

SKOU 2

E-file lawsuit papers; conference with paralegal regarding file organization and paper copy of complaint to assigned judge; statutory notice letters to Secretary of Labor and Secretary of Treasury E-notices from court; conference with paralegal regarding file organization and service of process E-Filed court documents; processed vendor invoice; organized file; updated item in Litigation Report; telephone conference with E-Filing clerk regarding case number errors

Billed Expenses Date 7/31/2008 11/24/2008 11/30/2008 11/30/2008 11/30/2008 Totals

Totals

8.80 Amount Exp Code $4.80 $60.00 $15.00 $65.04 $60.00 COPY MISC POST COPY DOCK

8.80 Narrative

$1,490.00

Billed Expenses

Photocopy Charges Constable Services - Service of Process Postage Charges Photocopy Charges DM 2000, Computerized Docket and Case Watch Protection Service

$204.84 Hours Worked 10.10 Hours To Bill 10.10 Fee Amount $1,767.50 Expense Amount $554.84 Total Amount $2,322.34

Report Totals

*** End Of Report ***

EXHIBIT D

65100-1093LIT-4708 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAMES T. SULLIVAN, not individually but as Trustee of PLUMBERS' PENSION FUND, LOCAL 130, U.A., PLUMBERS' WELFARE FUND, LOCAL 130, U.A., THE TRUST FUND FOR APPRENTICE AND JOURNEYMEN EDUCATION AND TRAINING, LOCAL 130, U.A., and CHICAGO JOURNEYMEN PLUMBERS' LOCAL UNION 130, U.A., GROUP LEGAL SERVICES PLAN FUND; and THE PLUMBING COUNCIL OF CHICAGOLAND, an Illinois not-for-profit corporation; and CHICAGO JOURNEYMEN PLUMBERS' LOCAL UNION 130, U.A., Plaintiffs, v. EAST WEST PLUMBING, INC., an Illinois corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No.

08 C 6510

Judge James F. Holderman Magistrate Judge Michael T. Mason

JUDGMENT IN A CIVIL CASE THIS CAUSE coming before the Court for hearing on Plaintiffs' Motion For Entry of Judgment, due notice having been given to all parties entitled thereto, and the Court being fully advised in the premises IT IS HEREBY ORDERED that judgment is entered in favor of Plaintiffs, James T. Sullivan, etc., et al., and against Defendant, EAST WEST PLUMBING, INC., in the amount of $37,801.76; and IT IS HEREBY ORDERED that this judgment is final, and there is no just reason to delay enforcement or appeal.

Date:____________________________

ENTER: ____________________________________ James F. Holderman United States District Court Judge