Hancock et al v. Union Recycling & Waste Services, Inc. et al

Filing 68

MOTION by Plaintiffs Timothy P. Dunlap, Larry Groot, Terrence J. Hancock, John Lisner, Michael Richardson, Steve Vogrin, Thomas J. Yonker for judgment Plaintiffs' Motion For Supplemental Judgment (Attachments: # 1 Exhibit A to Motion (Affidavit of JMB), # 2 Exhibit 1 to Affidavit of JMB, # 3 Certificate of Service)(Barr, Jeremy)

SUPPLEMENTAL AFFIDAVIT OF JEREMY M. BARR

COUNTY OF COOK
STATE OF ILLINOIS

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) SS
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I, Jeremy M. Barr, of full age, being duly sworn on my oath, hereby depose and say as
follows:
1.

I am an attorney admitted to the General Bar of this Court and the State of

Illinois.
2.

Since February 2010, I have been an associate in the firm Dowd, Bloch & Bennett

(“Firm”), where I practice exclusively in the areas of labor, employment, and employee benefits
law. In my position at the Firm, I represent the Plaintiffs in Case Number 13-cv-2032.
3.

This affidavit is based on my personal knowledge and, if necessary, I could testify

to the facts contained in this affidavit.
4.

The rate which our firm charges the Funds is $240.00 per hour for partners’ work;

$175.00 per hour for work completed by me and other associates; and $90.00 per hour for law
clerks’ work. I believe these rates are extremely reasonable in light of the Firm’s experience and
the nature of the case.
5.

Through December 10, 2013, the Firm has devoted a total of 114.1 billable hours

to the representation of the Local No. 731, I.B. of T., Private Scavengers Health and Welfare
Fund and the Local No. 731, I.B. of T., Private Scavengers and Garage Attendants Pension
(collectively, “Funds”) in connection with this case.
6.

Based on the above rates and 114.1 hours of work through December 10, 2013,

the Funds have incurred attorneys’ fees and $20,483.75 related to this case.

Exhibit A

7.

Through May 15, 2013 the Funds incurred attorneys’ fees for work including

demanding payment, communicating with the Funds and the Defendant regarding the status of
the case, preparing the Complaint and other related documents, arranging for service, preparing
the motion for entry of default, appearing at the hearing on the motion for default,
communicating with the Defendants concerning completion of the contribution reports, and
preparing the prove-up affidavits and proposed judgment order.
8.

Since May 15, 2013 the Funds have incurred attorneys’ fees for work including

preparing three motions for turnover, drafting a motion for a judgment against Armor Recycling
of Indiana, Inc., preparing and litigating a motion for a rule to show cause against the
Defendants’ owner for violating citations to discover assets, litigating which creditor was entitled
to Clune Construction Company’s accounts payable to Union Recycling, and conducting three
citation examinations.
9.

In addition to attorneys’ fees, the Funds have incurred costs in the amount of

$1,190.10, comprised of $350.00 in filing fees, $272.00 in service fees, $51.38 in postage and
shipping costs, $343.10 in photocopying and document production expenses, and $173.62 for
LEXIS research fees.
10.

Attached as Exhibit 1 are invoices for this case through December 10, 2013,

reflecting attorneys’ fees of $20,483.75 and costs of $1,190.10 related to this case, which have
been or will be billed to the Funds.
11.

Since December 10, 2013, the Firm has devoted an additional 1.5 hours to

resolving this case, including reviewing, revising, and supplementing this affidavit, the motion
for a supplemental judgment, and the proposed judgment order, electronically filing those
documents, and submitting the proposed judgment order.