Central States, Southeast and Southwest Areas Pension Fund et al v. Indiana Earth, Inc.

Filing 17

MOTION by Plaintiffs Central States, Southeast and Southwest Areas Health and Welfare Fund, Central States, Southeast and Southwest Areas Pension Fund, Howard McDougall for judgment and for Prove Up of Damages (Attachments: # 1 Affidavit Beaton, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Affidavit McMahon, # 7 Text of Proposed Order)(McMahon, Rebecca)

Central States, Southeast and Southwest Areas Pension Fund et al v. Indiana Earth, Inc.

Doc. 17 Att. 6

EXHIBIT D

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT

F O R THE NORTHERN DISTRICT OF ILLINOIS
E A S T E R N DIVISION
C E N T R A L STATES, SOUTHEAST AND SOUTHWEST AREAS PENSION FUND, and HOWARD MCDOUGALL, trustee, and CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS HEALTH AND WELFARE FUND and HOWARD McDOUGALL, trustee, Plaintiffs, v. INDIANA EARTH, INC., an Indiana corporation, Defendant.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 10 C 201 Judge Hart Magistrate Judge Mason

AFFIDAVIT OF REBECCA K. MCMAHON State of Illinois County of Cook ) ) SS )

I, Rebecca K. McMahon, having been duly sworn on oath, depose and state as follows: 1. I am an attorney employed by the Central States, Southeast and Southwest

Areas Pension Fund and the Central States, Southeast and Southwest Areas Health and Welfare Fund (the "Funds") and am familiar with the pending litigation. 2. I have reviewed the Plaintiffs' billing records and have determined that the

billable work performed in connection with this case was performed by myself and George

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O. Hansen, a paralegal. 3. I graduated from the Valparaiso University School of Law in 2006. I was

admitted to the bar of the State of Illinois on November 9,2006 and admitted to practice in the United States District Court for the Northern District of Illinois on January 11,2007. 4. 5. George O. Hansen is a litigation paralegal employed by the Pension Fund. The amount of time spent on this case by myself and George O. Hansen,

along with our hourly billable rates, are set forth below: Rebecca K. McMahon George O. Hansen 6. 14 hours x $170.00 2.0 hours x $140.00

Based upon my experience in similar cases, I believe that the above rates

are at or below the market rate charged for similar legal work and therefore, are reasonable. I also believe that the amount of time spent by each individual on this case is reasonable. On that basis. the total of legal fees incurred in this matter is $2.660.00. 7. The legal services are briefly summarized as follows: review file, preparation

of complaint, appearances, 'and summons; review affidavits of service; several court appearances; multiple telephone conferences with Defendant regarding missed payments; and preparation of motion for entry of judgment, including supporting affidavits, exhibits, and proposed judgment order. 8. litigation: Filing Fee Service of Process Total $350.00 170.00 $520.00 Plaintiffs have also incurred the following costs in connection with this

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9.

I believe that the aforementioned legal fees and costs were necessarily

incurred and are reasonable in amount.

FURTHER AFFIANT SAYETH NOT.

Subscribed and sworn to before me, a Notary Public, this " ",~ay of October, 0 O.

~~
Rebecca K. McMahon

N.n~W'II·~.,.",...,...,.V'VV'V~

Official Seal
George Hansen
Notary Public State of Illinois
My Commission Expires 11/10/2012

~~~A~~~~~VV~~

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