Sullivan et al v. Ayyad Plumbing, Inc.

Filing 12

MOTION by Plaintiffs Chicago Journeymen Plumbers' Local 130, U.A. Group Legal Services Plan Fund, Plumbers Pension Fund Local 130 U.A., Plumbers' Welfare Fund, Local 130, U.A., Plumbing Council Of Chicagoland, James T Sullivan, Trust Fund for Apprentice and Journeymen Education and Training, Local 130, U.A, The for judgment (Attachments: # 1 Exhibit B, # 2 Exhibit C, # 3 Exhibit D, # 4 Exhibit E, # 5 Exhibit E-1)(Loseman, John)

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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., etc., ) et al., ) ) Plaintiffs, ) ) v. ) ) AYYAD PLUMBING, INC., ) ) Defendant. )

No. 10 C 1129 Judge Rebecca R. Pallmeyer Magistrate Judge Jeffrey Cole

AFFIDAVIT OF JOHN W. LOSEMAN State of Illinois County of Cook ) ) ss. )

John W. Loseman hereby deposes and states: 1. I am of adult age and otherwise competent to make this Affidavit. All statements

herein are made on my personal knowledge. 2. I am an attorney licensed to practice, inter alia, within the State of Illinois and

before the United States District Court for the Northern District of Illinois. I am one of the attorneys responsible for representing Plaintiffs in the captioned action. 3. I am a partner in the law firm of LEWIS, OVERBECK AND FURMAN, LLP, ("Firm"),

20 N. Clark Street, Suite 3200, Chicago, Illinois. All attorneys and paralegals who represented Plaintiffs in this action were partners in, associated with, or employed by, Firm. 4. In the course of their representation of Plaintiffs, the attorneys and paralegals of

Firm made contemporaneous daily time entries. Attached as Exhibit 1 are true and correct copies of the daily time entries itemizing the time actually spent by attorneys and paralegals of

Exhibit E

Firm in the course of this matter through March 24, 2010, along with certain costs paid for the account of Plaintiffs herein through that date, for which Plaintiffs seek reimbursement. 5. Throughout this case, Firm has charged its normal and customary hourly charges

for legal services rendered to Plaintiffs in this action. Firm's normal and customary hourly charges are reasonable within the Chicago area legal community, and are paid by other clients of Firm. 6. "DAL" in the time entries designates attorney Douglas A. Lindsay, a partner in

Firm. DAL has been licensed to practice law in the State of Illinois since 1976, and is a member of the U.S. Supreme Court, the U.S. Court of Appeals for the Seventh Circuit, and the U.S. District Courts for the N.D. Illinois, C.D. Illinois, E.D. Wisconsin, and N.D. Indiana. DAL has extensive experience in ERISA and LMRA matters, including enforcement of labor arbitration awards under collective bargaining agreements. DAL provided 10.80 hours of legal services to Plaintiffs at the rate of $300.00 per hour, for a total of $3,240.00. 7. "JWL" in the time entries designates Affiant, John W. Loseman. JWL has been

licensed to practice law in the State of Illinois since 1989, and is a member of the U.S. Supreme Court, the U.S. Court of Appeals for the Seventh Circuit, and the U.S. District Courts for the N.D. Illinois, C.D. Illinois, and N.D. Indiana. JWL has considerable experience in ERISA and LMRA matters, including enforcement of labor arbitration awards under collective bargaining agreements. In the course of this matter, JWL provided 0.10 hours of legal services to Plaintiffs at the rate of $255.00 per hour, for a total of $25.50. 8. "BTB" in the time entries designates attorney Brian T. Bedinghaus, an associate

of Firm. BTB has been licensed to practice law in the State of Illinois since 2005, and is a member of the U.S. District Court for the Northern District of Illinois. In the course of this

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Exhibit E

matter, BTB provided 4.80 hours of legal services to Plaintiffs at the rate of $170.00 per hour, for a total of $816.00. 9. "RCP" in the time entries designates Robert C. Parizek, a paralegal

employed by Firm. In the course of this matter, RCP provided 5.50 hours of services to Plaintiffs at the rate of $85.00 per hour, for a total of $467.50. 10. "MEAR" in the time entries designates Margaret Earley, a paralegal

employed by Firm. In the course of this matter, MEAR provided 0.10 hours of services to Plaintiffs at the rate of $75.00 per hour, for a total of $7.50. 11. In addition to attorneys' and paralegals' fees, Plaintiffs incurred charges for the

following: $350.00 for the federal court complaint filing fee; $85.00 for service of process; $60.00 for electronic docket fees; and $61.86 for postage costs and photocopy expenses, for a total of $572.88. Each of these charges was incurred in connection with this case, and is not a usual office overhead expense. These charges are billed separately by Firm to its clients. 12. The sum of the above-described fees is $4,556.50, and the sum of the above-

described costs and expenses is $572.88 for a total of $5,129.38. In accordance with 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true and correct. Dated: March 30, 2010 /s/ John W. Loseman John W. Loseman 20 N. Clark Street Suite 3200 Chicago, IL 60602-5093 312.580.1258

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Exhibit E