Brown v. Evans et al

Filing 84

MOTION by Plaintiff Alfonso Brown for order and judgment on plaintiff's attorneys' fees, MOTION by Plaintiff Alfonso Brown for judgment (Dymkar, Irene)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

ALFONSO BROWN,
Plaintiff,
v.
GLENN EVANS, et al.,
Defendants.

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Case No. 15 C 2844
Judge Sara L. Ellis

AGREED MOTION FOR ORDER AND JUDGMENT ON PLAINTIFF’S FEE
PETITION
Plaintiff, Alfonso Brown, by and through his attorneys, Irene K. Dymkar,
Shamoyita M. DasGupta, and Daniel H. Regenscheit, hereby moves this Court to enter an
order and judgment on plaintiff’s petition for attorneys’ fees in the amount of $55,000.00. In
support of this motion, plaintiff states:
1.

This action was commenced by the filing of a complaint alleging a cause of
action under the Civil Rights Act of 1871 (42 U.S.C. §1983), to redress
deprivations of the civil rights of plaintiff through acts and/or omissions of
defendants committed under color of law.

2.

On December 12, 2016, plaintiff accepted an offer of judgment on all claims
from all defendants. Doc. 72. Judgment was entered in plaintiff’s favor on
December 13, 2016, for $20,001.00. Doc. 74. The issue of attorneys’ fees up
to $79,999.00, continued, to be resolved.

3.

On February 17, 2017, plaintiff submitted his petition for attorneys’ fees
in the amount of $68,081.50. Doc. 78.

4.

On March 1, 2017, the Court extended the March 3, 2017, deadline for
defendants’ objections to plaintiff’s fee petition to March 7, 2017. Doc. 82.

5.

On March 7, 2017, the parties agreed to the entry of judgment against
defendants GLENN EVANS, RUBEN VARGAS, THERESA A.
WALDBUESSER, CHRIS C. YOUNG, LUIS A. CENTENO, and CITY OF
CHICAGO for all plaintiff’s attorney’s fees in the amount of $55,000.00.
The CITY OF CHICAGO agrees to indemnify GLENN EVANS, RUBEN
VARGAS, THERESA A. WALDBUESSER, CHRIS C. YOUNG, and LUIS
A. CENTENO and the CITY OF CHICAGO will be liable for payment of
the entirety of the attorney’s fees in the amount of $55,000.00.

6.

Plaintiff therefore requests an order and judgment for plaintiff’s
attorneys’ fees in the amount of $55,000.00.

WHEREFORE, plaintiff requests this Court enter an order and judgment for
plaintiff’s attorneys’ fees in the amount of $55,000.00.

Dated: March 7, 2017

/s/ Irene K. Dymkar
Irene K. Dymkar

Plaintiff’s Attorneys:
Irene K. Dymkar
Shamoyita M. DasGupta
Daniel H. Regenscheit
Law Offices of Irene K. Dymkar
53 West Jackson, Suite 733
Chicago, IL 60604
[phone]

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