Haywood v. LRA Corporation et al

Filing 29

MOTION by Plaintiff Sarah Jean Haywood for judgment (Attachments: # 1 Exhibit A-Affidavit of Plaintiff, # 2 Exhibit B-Summary of Attorney's Fees, # 3 Exhibit C-Laffey Matrix, # 4 Exhibit D-Consumer Law Attorney Fee Survey)(Marco, David)

EXHIBIT B

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

Apr 16, 2013

David Marco

Review Motion for Judgment and file, travel to and from court, wait for
case to be called, step up and present Motion for Judgment. Receive
and review Judgment order. (Estimated)

1.20

Apr. 5, 2013

David Marco

Review file, review draft Motion for Default Judgment make revisions,
and file motion and exhibits electronically.

0.40

Apr 5, 2013

Paralegal

Receive and review attestation from client and prepare motion for
filing, and mail a copy to defendant. Annotate file with event to receive
order.

0.30

Apr 2, 2013

Paralegal

Review file to confirm lack of appearance from Defendants, review
pleadings and prepare motion for judgment introduction section, review
and revise memorandum of law, prepare client’s claim for damages,
client’s attestation of the facts, pull and prepare attorneys’ fees and
costs, calculate and present, review prove up materials, prepare notice
of motion and proposed order and prepare correspondence to client
advising as to status of proceedings and requesting review and
signature of attestation. Annotate file with event to follow up on client's
attestation.

1.50

Dec 21, 2012

Paralegal

Receive and review Clerk's Entry of Default. Review against file and
annotate file with deadlines for preparing Motion for Judgment. Prepare
correspondence and send to Defendants with Default Order.

0.30

Dec 13, 2012

Ashley Decker

Review file, travel to court, wait for case to be called, step up, inform
court of status of service, obtain default against defendants. Travel
back to office, inform supervising attorney of status of case, annotate
file to reflect need to prepare Motion for Default Judgment.

1.20

Dec 6, 2012

Paralegal

Contact clerk, and prepare notice of motion and motion up default.
Prepare courtesy copy and send to Judge.

0.20

Nov 20, 2012

Ashley Decker

Prepare Motion for Clerk's Entry of Default detailing chronology in this
matter.

0.30

Nov 20, 2012

Paralegal

Prepare draft of clerk's entry of default against defendants for
supervising attorney. Prepare exhibits, motion and order for filing. Send
Defendant copies.

0.40

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

Oct 21, 2012

Ashley Decker

Review file for status of service upon Defendants, update file to reflect
need to re-send Complaint/Summons via regular mail as previously
sent mail was returned to our office.

0.10

Oct 2, 2012

Paralegal

Review order granting motion for alternative service. Prepare
summons and complaint for service. Send regular mail to LRA and
Raybin. Contact process server and prepare correspondence and send
documents for drop service. Annotate file with event to follow up on
service.

0.40

Sep 27, 2012

Ashley Decker

Review file, travel to court, wait for case to be called, step up for
hearing on 3rd Amended Mtn for Alt Service. Travel back to office,
inform supervising attorney of status of case, annotate file to reflect
motion being granted.

1.20

Sep 20, 2012

Paralegal

Prepare 3rd Amended Motion for Alternative Service for filing and file
electronically. Submit proposed order to Judge. Prepare
correspondence and send courtesy copy to the Judge. Annotate file
with hearing on motion.

0.30

Sep 19, 2012

Ashley Decker

Review third amended motion with supervising attorney, make
necessary changes to same, prepare for filing, prepare exhibits for
filing, update file to reflect same.

0.40

Sep 18, 2012

Ashley Decker

Review status of attempts to serve defendant via certified mail, discuss
with supervising attorney how to proceed.

0.10

Sep 18, 2012

Ashley Decker

Prepare third amended motion for alternate service and extension of
time to serve defendants, prepare notice of motion, prepare proposed
order, pull exhibits to attach to motion, prepare to review same with
supervising attorney.

0.80

Aug 24, 2012

Paralegal

Receive and review court order granting our 2nd motion for alternative
service and annotate file.

0.10

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

Aug 23, 2012

Ashley Decker

Review file, travel to court, wait for case to be called, have court enter
order, travel back to office, inform supervising attorney of status of
hearing. Diary up event to serve defendant via certified mail and to
receive court order granting extension of time to serve defendant. Send
documentation out via certified mail and update file to reflect same.

1.20

Aug 17, 2012

Paralegal

Prepare correspondence to Judge and send with a courtesy copy of
Second Motion for Alternative Service.

0.20

Aug 17, 2012

Ashley Decker

Review file for status of service, prepare amended motion for alternate
service, pull all exhibits to attach to same, prepare proposed order on
amended motion. Diary up need to review same with supervising
attorney.

0.90

Aug 17, 2012

Ashley Decker

Review motion for alternate service and proposed order with
supervising attorney, make changes to same, prepare notice of motion,
prepare all exhibits for filing, file same and diary up date to present
motion.

0.40

Jul 31, 2012

Ashley Decker

Receive and review court order granting motion for alternate service,
inform paralegal to follow up with court as no additional time was
granted as allowed in open court. Update file to reflect status of case.
Prepare and send complaint and Summons to Defendants via certified
mail and annotate file to check for status of service on defendants.

0.40

Jul 19, 2012

Ashley Decker

Review file and prepare Plaintiff's Motion for Alternative Service and
file.

1.00

May 10, 2012

Ashley Decker

Review brief and motion with supervising attorney and make necessary
changes, review affidavit with supervising attorney and make changes
to same. Prepare all exhibits to attach to brief and motion. Send
correspondence to process server regarding need to obtain executed
affidavits of nonservice and annotate file to reflect same.

0.60

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

May 10, 2012

Ashley Decker

Receive and review signed affidavits from process server, finalize for
filing, electronically file motion and brief in support of motion, diary up
event to receive court order on same.

0.30

May 9, 2012

Ashley Decker

Prepare brief in support of motion for alternative service upon
defendants. Prepare Affidavit of David Marco, pull all exhibits to attach
to motion, prepare motion and brief to review with supervising attorney
for filing.

1.20

May 8, 2012

Ashley Decker

Receive & review process servers amended affidavit to attach to
motion for alternate service.

0.10

May 7, 2012

Ashley Decker

Review affidavit from process server & determine if contents are
sufficient to attach to motion for alternative service.

0.10

May 7, 2012

Ashley Decker

Prepare motion for alternate service upon Defendants.

0.20

Apr 30, 2012

Ashley Decker

Receive update on status of service of process upon defendant and
discuss with supervising attorney regarding filing motion for alternative
service of process.

0.10

Apr 24, 2012

Ashley Decker

Review file and send correspondence to client answering their
questions on how to proceed given that they are continuing to receive
calls from defendant.

0.20

Apr 23, 2012

Paralegal

Speak to supervising attorney and file amended complaint, speak to
server and send amended complaint.

0.30

Apr 23, 2012

Ashley Decker

Review notes regarding defendant's continued contacts with plaintiff
despite its awareness regarding our representation, review all
correspondence sent between our office and defendant. Prepare first
amended complaint against both defendants. Engage in telephone call
with client to discuss the amended complaint. Prepare correspondence
to client enclosing copy of complaint for her review and update file to
reflect same. Prepare to review first amended complaint with
supervising attorney before filing.

0.90

SmithMarco, P.C.
All Time for Selected File:

Date

Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Review notes regarding defendant's continued contacts with plaintiff
despite its awareness regarding our representation, review all
Client ID: Haywood, Sarah
correspondence sent between our office and defendant. Prepare first
Matter ID: FF-IL-12080
amended complaint against both defendants. Engage in telephone call
with client to discuss the amended complaint. Prepare correspondence
to client enclosing copy of complaint for her review and update file to
Timekeeper
Task / Activity Code &
reflect same. Prepare to review first amended complaint with
Description
supervising attorney before filing.

Time
(hours)

Apr 23, 2012

Ashley Decker

Receive correspondence from client approving contents of first
amended complaint, make notes to file re: same. Review complaint
with supervising attorney and make necessary changes, prepare final
version of first amended complaint. Pull all exhibits to attach to first
amended complaint and have paralegal electronically file.

0.30

Apr 23, 2012

Ashley Decker

Receive correspondence from client informing us at to additional
telephone call she received from defendant, make notes to file re:
same and discuss with supervising attorney how to proceed given that
we just filed first amended complaint.

0.10

Apr 19, 2012

Larry Smith

Received additional documents and information from
client; annotated file with information and determine any
necessary action to be taken.

0.20

Apr 12, 2012

Paralegal

Receive and review filed complaint and summonses from clerk of
court, and have served upon Defendants. Research appropriate
process server and speak to process server regarding service and
what documents are necessary for service. Prepare correspondence
to process server and send documents for service. Annotate file with
server information and prepare event for follow up to confirm proper
service.

0.40

Apr 5, 2012

David Marco

Prepare final draft of Complaint: Receive and review correspondence
from client confirming review of pleading and checking for accuracy,
review file and initial draft of pleading, make amendments to pleading
and prepare final draft, prepare civil cover sheet, prepare appearances
for all counsel of record, prepare all documents for filing, electronically
file pleading and all attachments.

1.20

Apr 5, 2012

David Marco

Telephone call from client requesting additional information relative to
the filing of her complaint. Discuss process of litigation and prepare
notes to file.

0.30

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

Apr 5, 2012

Paralegal

Receive and review filed copies of pleadings and related documents,
update database with case assignment details, finalize summons and
send to the intake desk to be issued and annotate file regarding
service of summons.

0.30

Apr 4, 2012

Ashley Decker

Review complaint with supervising attorney, make necessary changes.
Prepare correspondence to client enclosing copy of complaint for her
review. Update file to reflect same.

0.70

Apr 3, 2012

Ashley Decker

Engage in telephone call with client and review facts of case with her,
make notes to file re: same and make necessary changes to draft of
lawsuit.

0.30

Apr 3, 2012

Ashley Decker

Review correspondence from defendant to our office, review account
statement provided therein & determine if new allegations need to be
amended to complaint, discuss same with supervising attorney.

0.20

Mar 29, 2012

Ashley Decker

Review file and all documents from client and determine specific
violations of the FDCPA, telephone call to client and discuss
allegations with client's husband, make notes to file re: same & advise
client's husband to have client contact time to discuss case. Engage in
research regarding link between Larry Raybin and LRA for purposes of
naming his an individual defendant, discuss pleading with supervising
attorney, conduct research to ascertain correct legal entity to name in
pleading and to ascertain location of Defendant for purposes of
preparing summons, prepare initial draft of pleading and prepare
exhibits to attach to complaint. Prepare to review initial draft of lawsuit
with supervising attorney.
Update file to reflect same.

1.70

Mar 28, 2012

Larry Smith

Received Defendant's Response to Prelitigation letter and reviewed
email and attached documentation. Updated file.

0.30

Mar 26, 2012

Larry Smith

Received and reviewed response to our prelit letter from Defendant
requesting information. Reviewed file and provided

0.20

Mar 23, 2012

Larry Smith

Reviewed Prelitigation letter and edited; re-reviewed and signed.

0.20

SmithMarco, P.C.
All Time for Selected File:
Haywood, Sarah v. LRA Corporation d/b/a LRA Corporation
Debt Collection Services and Larry Raybin
Client ID: Haywood, Sarah
Matter ID: FF-IL-12080

Date

Timekeeper

Task / Activity Code &
Description

Time
(hours)

Mar 23, 2012

Larry Smith

Staff meeting to discuss case - direction, strategy, and evidence
needed; updated file with information; contacted client to advise.

0.20

Mar 23, 2012

David Marco

Attend firm meeting to discuss facts of case and to develop strategy of
how to proceed with litigation. Make determination as to additional
discovery required to substantiate claims and prepare notes to file re:
same.

0.20

Mar 23, 2012

Ashley Decker

Discuss case with supervising attorneys & determine which track to
assign case to. Make notes to file regarding additional evidence
needed from client & engage in discussion regarding theory of case.

0.20

Mar 22, 2012

Larry Smith

Received back signed retainer; Prepared Opening File Instruction
Sheet providing claims to bring and services performed.

0.50

Mar 22, 2012

Paralegal

Prepare Pre-litigation letter to Defendant detailing all violations that
occurred and providing support; made demand for settlement.

0.20

Mar 21, 2012

Larry Smith

Received Call from Potential New Client; initial conversation to
determine legitimacy of case; discussed options and services provided;
sent intake form for completion.

0.40

Mar 21, 2012

Larry Smith

Received back completed intake form; reviewed and made notes for
interview; researched defendant; contacted potential client for
comprehensive interview; discussed claims and retainer agreement sent retainer.

1.90

Mar 21, 2012

Paralegal

Open file in database; diarized events in system; created client file,
checked county and court filing information. Researched Defendant
location information and obtain service address for summons.

0.60

Total
Time:

27.90