Central States, Southeast and Southwest Areas Pension Fund et al v. RINSP, LLC

Filing 55

MOTION by Plaintiffs Arthur H. Bunte, Jr, Central States, Southeast and Southwest Areas Pension Fund for judgment (Attachments: # 1 Exhibit A - Recording Cover Page, # 2 Exhibit B - Connors v. Vick, # 3 Exhibit C - Lee Declaration, # 4 Exhibit D - Proposed Judgment Order)(Lee, Charles)

EXHIBIT C

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CENTRAL STATES, SOUTHEAST AND
SOUTHWEST AREAS PENSION FUND;
and ARTHUR H. BUNTE, JR., as Trustee,

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Plaintiffs,
v.
RINSP, LLC,
a Nevada limited liability company,
Defendant.

Case No. 12 CV 167
Judge Ruben Castillo
Magistrate Judge Arlander Keys

DECLARATION OF CHARLES H. LEE
I, Charles H. Lee, having personal knowledge of the facts stated herein, hereby
declare under penalty of perjury and pursuant to 28 U.S.C. § 1746 as follows:
1.

I am an Associate General Counsel employed by the Central States, Southeast

and Southwest Areas Pension Fund (the “Pension Fund”) and am familiar with the
pending litigation.
2.

I have reviewed the Plaintiffs’ billing records attached hereto as Exhibit 1 and

have determined that the billable work performed in connection with this case was
performed by myself, Emily E. Gleason, and George O. Hansen.
3.

I have been employed by the Pension Fund since July of 2000. I graduated

from the University of Minnesota Law School in 1996. I was admitted to the bar of the State
of Minnesota on October 25, 1996, and to the bar of the State of Illinois on May 7, 1998. I am
admitted to practice in the United States District Court for the Northern District of Illinois

T: 508708 / 11412513 / 9/4/12

-1-

and the United States Court of Appeals for the Seventh Circuit. I am also a member of the
Trial Bar of the United States District Court for the Northern District of Illinois.
4.

Emily E. Gleason has been employed by the Pension Fund as an attorney

since July of 2012. Ms. Gleason graduated from The John Marshall Law School in January
2009, and was admitted to the bar of the State of Illinois on May 7, 2009. She is also
admitted to practice in the United States District Court for the Northern District of Illinois.
Prior to being hired as an attorney for the Pension Fund, Ms. Gleason practiced for three
years as an associate at the law firm Kopon Airdo, LLC.
5.

George O. Hansen is a litigation paralegal employed by the Pension Fund.

6.

The amount of time spent on this case by myself, Emily E. Gleason, and

George O. Hansen, along with our hourly billable rates, are set forth below:
Charles H. Lee
Charles H. Lee

26.8 hours x $300.00

Emily E. Gleason

10.3 hours x $200.00

George O. Hansen
7.

2.7 hours x $275.00

1.0 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 $10,982.50.
8.

Plaintiffs have also incurred the following costs in connection with this

litigation:
Filing Fee
Service of Process
T: 508708 / 11412513 / 9/4/12

$350.00
21.00
-2-

Mileage and Parking
Total
9.

124.63
$495.63

I believe that the aforementioned legal fees and costs were necessarily

incurred and are reasonable in amount.
I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 4, 2012

T: 508708 / 11412513 / 9/4/12

/s/ Charles H. Lee
Charles H. Lee

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EXHIBIT 1

Central States Funds
9377 West Higgins Road
Rosemont, Illinois 60018
Page# 1

9/04/2012
RINSP, LLC

11412513

Description of Services
Description

Hours/Qty

Amount

12/01/2011

Charles H. Lee

Draft Complaint.

0.50

$137.50

12/15/2011

Charles H. Lee

Review Illinois law regarding UFTA; changes to
complaint; forward complaint to John J. Franczyk
for review.

1.00

$275.00

1/03/2012

Charles H. Lee

Revisions to complaint; e-mail Andrew M. Sprau
regarding complaint and incorporate A. Sprau's
changes.

0.50

$137.50

1/11/2012

George 0. Hansen

Telephone conference to Carson Gunty, Sheriff;
corresond with sme.

1.00

$140.00

3/02/2012

Charles H. Lee

Review judge's order regarding status report; draft
status report.

0.70

$192.50

3/05/2012

Charles H. Lee

E-mails with D. Brown regarding joint status
report and conference call; draft joint status report
and e-mail oc.

0.90

$270.00

3/08/2012

Charles H. Lee

E-mails with D. Brown regarding status report and
proposed changes.

0.20

$60.00

3/09/2012

Charles H. Lee

Review defendant's proposed changes to status
report; revise joint status report and prepare for efiling.

0.30

$90.00

3/14/2012

Charles H. Lee

Court appearance on status and travel time.

2.30

$690.00

4/04/2012

Charles H. Lee

Draft Rule 26(a)(1) disclosures.

0.60

$180.00

4/16/2012

Charles H. Lee

E-mails regarding changing settlement confernce
date.

0.10

$30.00

4/23/2012

Charles H. Lee

E-mails with judge's clerk and D. Brown regarding
submitting settlement letter.

0.10

$30.00

5/04/2012

Charles H. Lee

Draft First Set of Interrogatories; admissions and
document requests.

1.90

$570.00

5/07/2012

Charles H. Lee

Draft First Set of Interrogatories; admissions; and
document requests.

0.50

$150.00

Central States Funds
9377 West Higgins Road
Rosemont, Illinois 60018
Page# 2
9/04/2012

RINSP, LLC
11412513

Description of Services
Description

Hours/Qtv

Amount

5/15/2012

Charles H. Lee

E-mails regarding scheduling settlement
conference.

0.20

$60.00

5/29/2012

Charles H. Lee

E-mails with defendants and Pete Priede
regarding scheduling settlement conference date.

0.30

$90.00

6/27/2012

Charles H. Lee

Draft settlement letter.

1.80

$540.00

7/02/2012

Charles H. Lee

Draft and revise settlement letter and serve same.

0.30

$90.00

7/09/2012

Charles H. Lee

Review defendant's settlement letter; draft letter to
Magistrate Judge Keys regarding settlement
letters.

0.40

$120.00

7/11/2012

Charles H. Lee

Review defendant's discovery responses.

0.50

$150.00

7/19/2012

Charles H. Lee

Court appearance on status and travel time.

2.30

$690.00

7/20/2012

Charles H. Lee

Draft and serve deposition notices.

0.70

$210.00

7/27/2012

Charles H. Lee

Telephone conference with D. Brown regarding
discovery responses; discuss offer of judgment
with John J. Franczyk and research regarding offer
of judgment and attorneys' fees.

1.30

$390.00

7/30/2012

Charles H. Lee

Draft letter to D. Brown regarding discovery
conference.

1.10

$330.00

8/01/2012

Charles H. Lee

Draft and revise motion to compel and e-file
same; draft response to motion for protective
order.

3.90

$1,170.00

8/02/2012

Charles H. Lee

Draft response in opposition to motion for
protective order; revisions and e-file same.

2.30

$690.00

8/07/2012

Charles H. Lee

Review Defendant's response to motion to
compel; draft reply to motion to compel; e-file
same.

2.50

$750.00

Central States Funds
9377 West Higgins Road
Rosemont, Illinois 60018
Page# 3
9/04/2012

RINSP, LLC
11412513

Description of Services
Description

Hours/gty

Amount

8/08/2012

Emily E Gleason

Research bench trial issue in preparation for
drafting motion.

1.50

$300.00

8/08/2012

Charles H. Lee

Court appearance on motion to compel and travel
time.

2.30

$690.00

8/10/2012

Emily E Gleason

Research case law in preparation for moving to
strike jury trial.

2.00

$400.00

8/13/2012

Emily E Gleason

Draft motion to strike jury demand; research case
law regaring bench trials for fraudulent transfers
of real estate.

3.00

$600.00

8/14/2012

Emily E Gleason

Draft motion to strike jury demand.

2.50

$500.00

8/16/2012

Emily E Gleason

Draft Motion to Strike Jury Demand.

1.30

$260.00

40.80

$10,982.50

Total:

1/10/2012

Charles H. Lee

U.S. District Court, Northern District of IllinoisComplaint filing fee

1.00

$350.00

1/11/2012

Charles H. Lee

Carson County Sheriff- fee for service of
summons and complaint

1.00

$21.00

3/14/2012

Charles H. Lee

Mileage and parking fees incurred to attend status
hearing in Chicago, Illinois.

1.00

$40.21

7/19/2012

Charles H. Lee

Mileage and parking fees incurred to attend status
hearing in Chicago, Illinois.

1.00

$44.21

8/08/2012

Charles H. Lee

Mileage and parking fees incurred to attend
motion hearing in Chicago, Illinois.

1.00

$40.21

8/21/2012

Charles H. Lee

Mileage and parking fees incurred to attend status
hearing in Chicago, Illinois.

48.21

$0.00

Central States Funds
9377 West Higgins Road
Rosemont, Illinois 60018
Page# 4

9/04/2012
RINSP, LLC

11412513

Description of Services
Hours/Qty

Description
Total:

Amount

53.21

$495.63

Total Amount of This Bill:

$11,478.13