Woods v. Amazon.com LLC et al

Filing 465

MEMORANDUM OPINION AND ORDER Signed by the Honorable Robert M. Dow, Jr. on 7/1/2020. For the reasons set forth below, Claimant Taxman, Pollock, Murray, Bekkerman, LLC's ("Claimant" or "TPMB") motion to strike 456 is denied, and Plaintiff's motion to adjudicate the Claimant's quantum meruit attorneys' lien 434 is granted. The Court finds that TPMB is entitled to $69,825 in attorneys' fees. Mailed notice(cdh, )

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ANDREW WOODS,
Plaintiff,
v.
AMAZON.COM, LLC, et al.,
Defendants.

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Case No. 17-cv-4339
Judge Robert M. Dow, Jr.

MEMORANDUM OPINION AND ORDER
For the reasons set forth below, Claimant Taxman, Pollock, Murray, Bekkerman, LLC’s
(“Claimant” or “TPMB”) motion to strike [456] is denied, and Plaintiff’s motion to adjudicate the
Claimant’s quantum meruit attorneys’ lien [434] is granted. The Court finds that TPMB is entitled
to $69,825 in attorneys’ fees.
I.

Background
This attorneys’ fees dispute arises from a plaintiff’s change of counsel partway through a

personal injury suit. Plaintiff Andrew Woods, an ironworker participating in construction of a
warehouse for Amazon, was injured when an industrial rack collapsed. See [28, at 3, 5]. Plaintiff
retained the law firm Taxman, Pollock, Murray, Bekkerman, LLC on May 16, 2017, to represent
him in matters related to his injuries under a contingency fee arrangement. TPMB filed a personal
injury suit on Plaintiff’s behalf on June 8, 2017. The case was originally assigned to the Judge St.
Eve, who recused herself, and the case was reassigned to the Chief Judge Castillo. See [30]. TPMB
represented Plaintiff in the matter for the following five or six months. Between June and
November 16, 2017, TPMB filed two amended complaints (see [6] and [28]), submitted status

reports, attended status hearings, and replied to affirmative defenses (see [39-41]). TPMB also
sent attorneys’ liens to defendants. See [434-1, at 2-7]. The parties did not engage in discovery
during that time.
On November 16, 2017, TPMB received a letter from Plaintiff terminating the
representation and directing TPMB to cooperate with his new attorneys, the firm of Anesi, Ozmon,
Rodin, Novak, & Kohn, Ltd (“Anesi”). [450-1, at 34-35.] Marc Taxman, a partner at TPMB,
acknowledged receipt of Plaintiff’s letter that same day. [453-1, at 7-8.] TPMB turned over
Plaintiff’s client file to Anesi on November 17, 2017, though the parties disagree on what the file
contained. See [453-1, at 1-3; 455-1, at 2-3].
On November 28, 2017, Chief Judge Castillo held a status hearing, at which TPMB sought
to have the judge “vet the facts regarding TPMB, LLC’s discharge.” [458-3, at 12.] The Court
declined. TPMB filed a motion to withdraw [72] on December 4, 2017, which the Court granted
on December 11, 2018 [78]. The case proceeded through discovery and dispositive motions
practice to trial, with Anesi representing Plaintiff. The case settled on the fifth day of trial, August
23, 2019.
On September 9, 2019, Plaintiff, through Anesi, filed a motion to adjudicate TPMB’s
quantum meruit attorneys’ liens [434]. Partway through the briefing, the case was transferred to
the undersigned, following Chief Judge Castillo’s retirement. [447.] Lacking contemporaneous
billing records, TPMB submitted a reconstructed chronology of its work on the case. See [458-3,
at 2-13]. TPMB also filed a motion to strike [456] several paragraphs from an affidavit [453-1] in
support of Anesi’s reply brief, submitted by Mark Novak, a partner at Anesi. Neither party’s briefs
requested an evidentiary hearing, and Plaintiff’s reply brief in support of his motion contained
objections to much of the work for which TPMB seeks compensation. Royce v. Michael R. Needle

2

P.C., 950 F.3d 481, 488 (7th Cir. 2020) (“A district court is not required to hold an evidentiary
hearing on attorney’s fees where a party has an opportunity to respond and make specific
objections to the fee petition.”) (citing Small v. Richard Wolf Med. Instruments Corp., 264 F.3d
702, 709 (7th Cir. 2001)). Thus, the issues presented in the motion to adjudicate quantum meruit
attorneys’ liens [434] and the motion to strike [456] are ripe for decision.
II.

Legal Standard
Motions to strike are “disfavored,” because they “potentially serve only to delay,” except

where they “remove unnecessary clutter from the case”). Heller Fin., Inc. v. Midwhey Powder Co.,
Inc., 883 F.2d 1286, 1294 (7th Cir. 1989); Redwood v. Dobson, 476 F.3d 462, 471 (7th Cir. 2007)
(“Motions to strike disserve the interest of judicial economy. The aggravation [they cause one’s
opponent] comes at an unacceptable cost in judicial time.”). A district court’s ruling on a motion
to strike an affidavit or statement of facts is reviewed for an abuse of discretion. Marshall v. Local
701 Int’l Bhd. of Elec. Workers, 387 F. App’x 623, 626 (7th Cir. 2010).
“Quantum meruit is a quasi-contract doctrine that allows the Court to imply the existence
of a contract in order to prevent injustice.” Langone v. Miller, 631 F. Supp. 2d 1067, 1071 (N.D.
Ill. 2009) (citing Hayes Mech., Inc. v. First Indus., 812 N.E.2d 419, 426 (Ill. App. Ct. 2004)).1 To
state a claim for quantum meruit, the plaintiff must plead that (1) he performed a service to the
benefit of the defendant; (2) he did not perform this service gratuitously; (3) the defendant accepted
this service; and (4) no contract existed to prescribe the payment for this service. Langone, 631 F.
Supp. 2d at 1071 (citing Installco, Inc. v. Whiting Corp., 784 N.E.2d 312, 318 (2002); Owen
Wagener & Co. v. U.S. Bank, 697 N.E.2d 902, 908 (1998)). The burden of proof is on the attorney

1

In contractual/quasi-contractual matters such as this, state law is to be applied to the dispute. Dobbs v.
Depuy Orthopaedics, Inc., 885 F.3d 455, 457 (7th Cir. 2018); Production Process Consultants, Inc. v. Wm.
R. Hubbell Street, Corp., 988 F.2d 794, 795-796 (7th Cir. 1993).

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to establish the value of his services. Thompson v. Buncik, 961 N.E.2d 280, 283, as modified on
denial of reh’g (Dec. 29, 2011) (citing McHugh v. Olsen, 545 N.E.2d 379, 382 (1989)).
Under Illinois law, the trial court has broad discretion in matters of attorneys’ fees due to
the advantage of close observation of the attorney’s work and the trial judge’s deeper
understanding of the skill and time required in the case. Royce, 950 F.3d at 487 (citing Kannewurf
v. Johns, 632 N.E.2d 711, 716 (1994)); see also Kovitz Shifrin Nesbit, P.C. v. Rossiello, 911 N.E.2d
1180, 1187 (2009) (“The trial court has broad discretionary powers in awarding reasonable
attorneys’ fees and its determination is based on the evidence presented by the parties.”). The
relevant factors in assessing a fee award include “the time and labor required, the attorney’s skill
and standing, the nature of the cause, the novelty and difficulty of the subject matter, the attorney’s
degree of responsibility in managing the case, the usual and customary charge for that type of work
in the community, and the benefits resulting to the clients.” Kannewurf, 632 N.E.2d at 717
(emphasis omitted). Review of a district court’s award of attorneys’ fees is deferential, for a
number of reasons: “the district court has a more complete picture of the case as a whole; the issues
tend to be factual matters for which appellate review is limited; the accuracy of the ultimate
decision is not likely to be enhanced by frequent and detailed appellate review; and it would be
wasteful to engage in a second major litigation over attorneys’ fees.” Lock Realty Corp. IX v. U.S.
Health, LP, 707 F.3d 764, 773 (7th Cir. 2013) (quotation omitted).
III.

Analysis
A.

Motion to Strike

TPMB argues that paragraphs 5 through 8 of Michael Novak’s affidavit [453-1, at 2] in
support of Plaintiff’s reply should be stricken for lack of personal knowledge, citing Federal Rule
of Evidence 602 (“FRE 602”). Those paragraphs state the date on which Anesi received the client

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file from TPMB, describe the contents of the file (including the number of pages of documents or
categories of documents in the file), and assert that the file did not contain certain memos, emails,
draft discovery responses, or materials produced by the defendants in discovery. [Id.] According
to TPMB, “Novak does not state who from Anesi received the file from TPMB, who reviewed the
file, when the file was reviewed and if an inventory of the file was made,” and therefore Novak
cannot say what documents were or were not in the file when TPMB turned it over to Anesi. [456,
at 2.] TPMB frames this argument as a motion to strike under Federal Rule of Civil Procedure
56(e). [Id. at 1.]
First, it is not clear that Federal Rule of Civil Procedure 56 (“FRCP 56”) applies here.
FRCP 56 deals with summary judgment, a stage this case has long passed. Furthermore, FRCP 56
“allows a party to object to record evidence in a summary judgment proceeding that could not be
presented in an admissible form at trial but does not expressly provide a means to strike material.”
Khungar v. Access Cmty. Health Network, 2020 WL 2219046, at *10 (N.D. Ill. May 7, 2020)
(citing Fed. R. Civ. P. 56(c)(2), (4)). So even if FRCP 56 did apply here, a motion to strike is
probably not an appropriate way for TPMB to proceed, which makes the Court reluctant to grant
TPMB motion.
The motion to strike is essentially an objection that that paragraphs 5 through 8 of the
Novak affidavit do not meet FRE 602’s requirement that testimony be based on personal
knowledge, plus an argument that the Court should not rely on those paragraphs in deciding the
attorneys’ fees question. (This type of objection is what FRCP 56(c)(2) allows, so the Court
understands why TPMB framed the argument as an FRCP 56 issue.) The fact that this issue is an
evidentiary one also counsels against striking portions of the affidavit. “The Court is ‘able to sift
through the evidence and to consider each piece under the applicable federal rules’ without going

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to the additional work of editing and striking out portions of the parties’ declarations.” Luxottica
Grp. S.p.A. v. Light in the Box Ltd., 2016 WL 6092636, at *3 (N.D. Ill. Oct. 19, 2016) (quoting
Martin v. Ft. Wayne Police Dep’t, 2011 WL 781383, at *5 (N.D. Ind. Feb. 28, 2011). For these
reasons, the motion to strike is denied.
The Court next turns to TPMB’s underlying FRE 602 arguments, for two reasons. First,
TPMB loses the FRE 602 argument, which is an alternate ground for denying the motion to strike.
Second, the Court resolves this issue in order to be clear that it did consider the Novak affidavit,
in addition to all the other evidence submitted to the Court, in determining what attorneys’ fees
TPMB is entitled to.
In relevant part, FRE 602 reads, “A witness may testify to a matter only if evidence is
introduced sufficient to support a finding that the witness has personal knowledge of the matter.
Evidence to prove personal knowledge may consist of the witness’s own testimony.” Fed. R. Evid.
602. As several Courts in this district have found, an affiant’s personal knowledge may be inferred
from the affidavit itself, and in determining whether to make such an inference, the Court can
consider a variety of factors, including the position of the affiant as well as his involvement in the
matters he testifies to. Ladenberger v. Gen. Signal Pump Grp./Aurora Pump, 2001 WL 586497, at
*1 (N.D. Ill. May 31, 2001) (citing Barthelemy v. Air Lines Pilots Ass’n, 897 F.2d 999, 1018 (9th
Cir. 1990) (“That Rule 56(e)’s requirements of personal knowledge and competence to testify have
been met may be inferred from the affidavits themselves.”); see also McKay v. Town & Country
Cadillac, Inc., 2002 WL 1285065, at *21 (N.D. Ill. June 7, 2002); Doolin v. United States, 1994
WL 233829, at *1 (N.D. Ill. May 23, 1994). Several other courts of appeals have reached the same
conclusion. See, e.g., Garcia-Garcia v. Costco Wholesale Corp., 878 F.3d 411, 418 (1st Cir. 2017)
(“[A] reading of the affidavits demonstrates that all three affiants did have personal knowledge

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about the facts they were swearing to, despite not explicitly stating so.”); Jacobs v. Wilkinson, 156
F.3d 1230 (6th Cir. 1998) (“Whether an affidavit meets the requirements of personal knowledge
and competence can be inferred from its contents.”); Roberts v. Cessna Aircraft Co., 289 F. App’x
321, 324 (10th Cir. 2008) (“[T]he personal knowledge of the affiant required by Rule 56(e) may
be inferred from the context of the affidavit.”).
A case similar to the one before this Court suggests that the Seventh Circuit also endorses
this perspective. In Lock Realty Corp. IX v. U.S. Health, LP, the plaintiff received a judgment in
its favor and plaintiff’s counsel moved for an award of attorneys’ fees. 707 F.3d 764, 767 (7th Cir.
2013). The motion included an affidavit by plaintiff’s lead attorney in support of awarding fees,
and the defendants moved to strike a paragraph from the affidavit under FRE 602 on the grounds
that the affiant lacked personal knowledge of the contents of that paragraph. Id., at 773. The
district court denied the motion to strike, and the Seventh Circuit affirmed, finding that “the
affidavit taken as a whole amply demonstrated that [the affiant] had personal knowledge of the
facts presented in the affidavit* * *.” Id.
Here, the Court considers the Novak affidavit as a whole, including its exhibits, and
determines that Novak has sufficient personal knowledge to support paragraphs 5 through 8 of his
affidavit. Novak’s affidavit—in fact, the paragraphs TPMB challenges—state when TPMB turned
over the client file to Anesi, describe the contents of the client file in some detail, and note a few
categories of documents that did not appear in the file. [453-1, at 2.] That description suggests at
least some familiarity with the client file. See Barthelemy v. Air Lines Pilots Ass’n, 897 F.2d 999,
1018 (9th Cir.1990) (personal knowledge may be inferred from the affidavit itself). Furthermore,
Novak is a member and Chairman of the law firm Anesi, Ozmon, Rodin, Novak & Kohen, Ltd.
[453-1, at 1]. When Andrew Woods wished to discharge TPMB and substitute Anesi, Novak

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handled Anesi’s communications with TPMB —specifically, with Taxman—about the discharge
and transfer of the client file. [453-1, at 1-2, 4-8.] When the docket showed a filing from a
defendant that was not contained in the client file that TPMB had turned over, Novak contacted
Taxman to ask about it. [Id. at 9-10.] From Novak’s “position[] and the nature of [his] participation
in the matters to which [he] swore,” the Court may also reasonably infer that Novak had personal
knowledge of the contents of the client file that TPMB produced to Anesi. Barthelemy, 897 F.2d
at 1018; Ladenberger v. Gen. Signal Pump Grp./Aurora Pump, 2001 WL 586497, at *1 (N.D. Ill.
May 31, 2001). Accordingly, to the extent that TPMB raises an objection to the Novak affidavit
under FRE 602, the objection is overruled.
B.

Motion to Adjudicate Quantum Meruit Attorneys’ Liens

In Illinois a discharged attorney may recover on a quantum meruit basis a reasonable fee
for services rendered before discharge. Much Shelist Freed Denenberg & Ament, P.C. v. Lison,
696 N.E.2d 1196, 1200 (1998). This rule applies to contingency fee arrangements as well. “When
an attorney-client relationship that was originally established under a contingent fee contract
terminates, the contract no longer exists and neither party can therefore seek to enforce the terms
of the nonexistent contract.” Forest Pres. Dist. of Cook Cty. v. Cont’l Cmty. Bank & Tr. Co., 98
N.E.3d 459, 472 (Ill. App. Ct. 2017). Instead, “when the attorney has withdrawn and the court
finds the attorney justifiably withdrew from the case, then the attorney is entitled to proceed on a
claim to recover fees based on quantum meruit.” Id.; Kannewurf, 632 N.E.2d at 716 (holding
attorney that withdrew from case “was entitled to the reasonable value of his services up to the
date of withdrawal”); Leoris & Cohen, P.C. v. McNiece, 589 N.E.2d 1060, 1065 (1992) (“If the
court finds that the plaintiff justifiably withdrew from the case, then the plaintiff will be allowed
to proceed on its claim for fees on a quantum meruit basis.”). Under a quantum meruit theory, the

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trial court is to award, as the term literally means, “as much as he deserves.” Lee v. Ingalls Mem’l
Hosp., 597 N.E.2d 747, 749 (1992).
The burden of proof is on the attorney to establish the value of his services. Thompson v.
Buncik, 961 N.E.2d 280, 283, as modified on denial of reh’g (Dec. 29, 2011) (citing McHugh v.
Olsen, 545 N.E.2d 379, 382 (1989)). Only those fees which the court finds reasonable will be
awarded to the attorneys. Kaiser v. MEPC Am. Properties, Inc., 518 N.E.2d 424, 427 (1987). The
relevant factors for determining the reasonableness of claimed attorneys’ fees include “the time
and labor required, the attorney’s skill and standing, the nature of the cause, the novelty and
difficulty of the subject matter, the attorney’s degree of responsibility in managing the case, the
usual and customary charge for that type of work in the community, and the benefits resulting to
the clients.” Kannewurf, 632 N.E.2d at 717 (emphasis omitted). The benefit to the client is a key
point in analyzing fees on a quantum meruit basis: “The theory of recovery in quantum meruit is
that a party has received a benefit which would be unjust for him to retain without paying for it.
Therefore, in order to recover in quantum meruit, it is essential that the services performed by the
claimant must be of some measurable benefit to the person from whom recovery is sought.” Bank
of Alton v. Bowman, 555 N.E.2d 997, 998 (1990). In analyzing these factors, the court “is not
limited to the evidence presented in arriving at a reasonable fee but may also use the knowledge it
has acquired in the discharge of professional duties to value legal services rendered.” Johns v.
Klecan, 556 N.E.2d 689, 695 (1990).
In this matter, the Court has reviewed the motion to adjudicate quantum meruit attorneys’
lien [434, 434-1] and related briefs and materials [450, 453, 453-1, 453-2, 453-3, 455, 455-1], the
motion to strike [456], and the TPMB’s amended verification [458], which includes the chronology
of work for which it seeks payment. The Court reviewed each specific claim in the chronology

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that Plaintiff objected to. Though the Court generally disfavors line-by-line assessments of bills
in fee disputes (because that contributes to the matter becoming a “second major litigation” that
the Seventh Circuit has called wasteful (Lock Realty Corp. IX, 707 F.3d at 773)), such a detailed
analysis is warranted here. The undersigned is the third judge to have been assigned this case,
after the first judge recused herself (see [30]) and the second judge shepherded the case to trial and
settlement (see [428]) before he retired (see [447]). Since this Court did not have the chance to
observe the attorneys’ work during the litigation, it must carefully examine the evidence
substantiating that work now. Dobbs v. DePuy Orthopedics, Inc., 842 F.3d 1045, 1050 (7th Cir.
2016) (district court abused its discretion in awarding full contingency fee in quantum meruit claim
because it “did not have firsthand knowledge about the litigation giving rise to [the] claim for
attorneys’ fees” and failed to “to analyze the factors Illinois courts have held are important when
awarding attorneys’ fees under quantum meruit”); see also Shakman v. Democratic Org. of Cook
Cty., 634 F. Supp. 895, 899 (N.D. Ill. 1986) (“In the instances where contemporaneous time
records were not available, plaintiffs’ affidavits provide, by their own representation, conservative
estimates of work done. * * * However, such representations of conservative estimates are no
substitute for well documented time records. Therefore, the Court has conducted an item-by-item
accounting * * * of plaintiffs’ attorneys’ time records.”).
Anesi’s objections focus on whether TPMB actually performed the work listed on the
chronology and whether the work was of benefit to the client, and TPMB’s responses focus on
those issues as well. Anesi and TPMB also disagree on the usual and customary hourly rate for
services in personal injury or tort cases and whether the rates that TPMB requests fall within that
range. TPMB has not suggested that the underlying case contained novel or particularly difficult
legal issues, and the attorneys who worked on the case for TPMB appear to be experienced and

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competent counsel. See [450-1, at 37-46]. Of the fee award factors identified in Illinois law, the
dispute—and therefore the Court’s analysis—centers on the work performed, its benefit to the
client, and the reasonableness of the attorneys’ rates.
1.

Hours Claimed

Anesi challenges many of the time entries TPMB submitted on a variety of grounds, and
the Court reviewed each challenged entry.

The Court addresses the categories of Anesi’s

objections below. A table showing the Court’s conclusions regarding individual time entries and
calculations of compensation is at Appendix A.2
TPMB’s letters to certain defendants
TPMB requests compensation for drafting three letters to defendants on May 22, 2017.
Appendix A, entries 15-17. Anesi argues that these letters are notices of attorneys’ liens, which
benefit TPMB and not the client, and therefore TPMB should not be paid for time spent preparing
these letters. See [434-1, at 2-7]; Bank of Alton, 555 N.E.2d at 998. TPMB argues the letters are
also litigation holds, which are important for preserving evidence, and justify compensation. The
Court’s review of the letters shows that at least half of the content is related to attorneys’ liens,
which benefit TPMB and not the client, so the Court reduces the hours claimed for each of these
entries from 0.5 to 0.25.

2

The table was created from the chronology of work that TPMB submitted. [458-3, at 2-13.] The Court
converted the chronology to a format more conducive to review and made no changes to the content other
than formatting changes. Data in the “Date,” “Attorney,” “Hours Claimed,” and “Description of Work”
columns are taken directly from TPMB’s chronology. The “Hours Substantiated,” “Hourly Rate,” and
“Reasonable Fee” columns are the Court’s determinations. The attorney initial sin the “Attorney” column
are as follows. MAT is Mark A. Taxman. BNP is Bradley N. Pollock. SPM is Sean P. Murray. HAH is
Haig A. Hamidian. LJS is Lindsay J. Scheidt.

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Time spent preparing amended complaints
Anesi argues that the time TPMB spent preparing the first amended complaint (Appendix
A, entries 48 and 49) and the second amended complaint (Appendix A, entries 93 and 94) is
excessive in light of the small changes to each version of the complaint. Beginning with entries
48 and 49, it is true that the changes to the text in the first amended complaint are not large, but
they are in response to an order from the Court [5]. They are also legally significant because they
establish subject matter jurisdiction, which prevented the complaint from being dismissed, an
obvious benefit to the client. The five hours that two attorneys took to research factual and legal
issues in response to a court order could be on the long side, but the Court does not believe that it
was an excessive amount of time, so the Court declines to strike these time entries.
Turning to the second amended complaint, entries 93 and 94, Anesi again argues that the
claimed time (a total of seven hours for two attorneys) is excessive in relation to the minor changes
to the complaint (correcting or adding a defendant corporation’s name in four paragraphs). [453,
at 7-8]. TPMB responds that these time entries include a meet-and-confer with defendants’
counsel, as described in the motion for leave to file [24]. See [455, at 8]. Though the time entry
says nothing about a meet-and-confer, the motion for leave to file does describe such a meeting
and the need to correct the name of one of the defendant corporations. See [24]. TPMB has
established that it did the work described and that the work benefited the client. The Court does
not believe that seven hours across two attorneys is excessive for a meet-and-confer plus revising
and refiling a complaint, so the Court declines to reduce these time entries.
Missing or absent documents
Anesi says that many documents mentioned in TPMB’s chronology were not included in
the client file that TPMB turned over, and that other work that TPMB claims to have performed

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did not generate any work product (or if it did, that work product was not in the client file).
According to Anesi, the work in those entries on the chronology did not benefit the client and
therefore is not compensable.
TPMB’s responses are varied. TPMB moved to strike paragraphs from the affidavit of
Mark Novak, through which Anesi attempted to establish what was and was not contained in the
client file. See [456]. The motion to strike attached many documents in support of TPMB’s
argument that it provided a complete client file, but those attachments did not resolve many of
Anesi’s objections. A few of the attachments are materials Anesi says were not included in the
client file, such as OSHA materials that Marc Taxman says he reviewed on June 9, 2017. [455-1,
at 59.] But some attachments were documents that Anesi agreed were in the file,3 some were
documents that Anesi had not identified as missing,4 and some the Court cannot identify, including
difficult-to-read, handwritten notes.5

Additionally, the attachments did not include certain

documents that Anesi identified as missing.6 TPMB did not provide an index of the attachments,
or descriptions of specific attachments, or—most importantly for TPMB’s burden—any
explanation of how specific attachments answer Anesi’s claims that the client file did not contain
certain documents.

3

E.g., a June 26, 2016 email from an investigator regarding the case [455-1 at 22], and a July 17, 2017
email from Marc Taxman to Patrick Garvey regarding Duke Realty’s full corporate name [455-1, at 21].

4

E.g., Anesi did not allege that the initial joint status report was not contained in the client file. [455-1, at
5-11].
5

E.g., [455-1, at 26, 35].

6

E.g., a May 22, 2017 case status memo (Appendix A, entry 13), Plaintiff’s medical records from the Rush
Copley emergency room (Appendix A, entry 45), and City of Aurora Fire Department EMT records
(Appendix A, entry 46).

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Furthermore, TPMB did not provide any evidence that the attachments (or the remainder
of the absent documents) were actually turned over to Anesi. The relevant portion of Taxman’s
affidavit reads, “I have reviewed my records in this matter. In reviewing my records, I have found
the electronic copies of the documents that were provided to Anesi. I attached the records that
Plaintiff argues were not in the file that was provided to Anesi….”7 [455, at 8.] But the affidavit
does not quite say that TPMB provided those attachments to Anesi on November 17, 2017, as part
of the client file. Strangely, TPMB argues in its surreply that even if the Court considered Novak’s
affidavit and his description of the client file’s contents, “it is impossible to conclude from the
evidence what the file contained at the time it was produced to Anesi.” [455, at 8] (emphasis
added). But TPMB bears the burden of proving that it performed work for the client and that the
work benefited the client. If it is impossible to conclude what documents TPMB turned over to
Anesi, it is far more difficult—if not impossible—for TPMB to meet its burden of proof with
regard to the documents Anesi says were absent.
The Court now turns to specific objections based on a lack of documentation. In several
instances, TPMB failed to meet its burden of proving that it created performed work or documents,
or that it turned them over to Anesi such that the work could benefit the client, and the Court
reduces TPMB’s requested hours and compensation accordingly, as described below.
Entries 1 and 2: “TPMB, LLC retained by Andrew Woods; Travel to meeting at
client’s house in Earlville, IL; Write-up case and interview client; Retainer signed
- contingency fee 33.33%; Medical Authorizations signed.”
Though Anesi objects that the case write-up (which the Court infers is the document at [455-1, at
48-53]) was not in the client file, much of the time in these entries was spent on other activities,
and the write up was likely useful to TPMB during its representation of the client, and therefore

7

The last statement is not entirely accurate; the attachments do not include several documents that Anesi
identified as missing from the client file, such as a May 22, 2017 case status memo (Appendix A, entry 13).

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beneficial to the client. But TPMB does not provide evidence that it turned over the write up to
Anesi. To balance the work Anesi does not challenge with TPMB’s failure to meet its burden
regarding the write up, the Court reduces each attorney’s claimed time in entries 1 and 2 from 8.0
hours to 7.5 hours.
Entries 8 and 9: “Web research on Amazon”
Anesi objects that because the client file contains no notes, assembled documents, or memoranda
regarding this research, TPMB has failed to prove that the work occurred or was beneficial to the
client. The Court agrees that TPMB has failed to substantiate this time entry, and the sparse
description does not allow the Court to assess what work was completed, its difficulty, or the
benefit to the client.8 These entries are reduced to 0 hours.
Entry 13: “SPM prepared a case status Memo (4 pages)”
TPMB has not produced evidence that it created this document or turned it over to Anesi.

Therefore, the Court reduces this entry to 0 hours.
Entry 20: “MAT Memo to file RE; Meeting at Jack Keck’s house in Yorkville, IL
(1Page)”
Entry 21: “Email from SPM RE: Speaking to Andrew Woods on 6/2/17”
TPMB did produce evidence that it created these two documents ([455-1, at 47 and 25]), but not
that it produced the documents to Anesi. Therefore, the Court reduces the hours claimed by half
for each of these entries.
Entry 44: “Researched and reviewed OSHA Standards: OSHA 3220 Warehousing
Worker Safety Services (15 pages), OSHA 2236 Materials Handling and Storage
(41 pages)”

8

“The district court has broad discretion to strike * * * vague or unjustified billing entries.” Montanez, 755
F.3d at 555–56 (affirming district court decision rejecting vague billing entries, such as “call to client”);
see also Pouncy v. City of Chicago, 2017 WL 8205488, at *8 (N.D. Ill. Dec. 11, 2017) (finding that
“[d]escriptions such as ‘draft LTR to client,’” too vague to support award of attorney’s fees).

15

TPMB attached these documents to its surreply (see [455-1, at 59]), but has not identified any
notes or memoranda from its review, much less notes or memoranda that it turned over to Anesi.
Therefore, the Court reduces the hours claimed by half.
Entry 45: “Reviewed RUSH Copley Emergency Room Records (39 pages)”
Entry 46: “Reviewed City of Aurora Fire Department EMT Records”
Anesi objects that because the client file does not contain these documents, or notes or memoranda
about them, TPMB has failed to prove that the work occurred or was beneficial to the client. The
Court agrees that TPMB not substantiated these time entries and reduces their hours to zero.
Entry 47: “Researched and reviewed Steel King ‘Built to Deliver / Designed to
Perform’ (12 pages)”
TPMB attached these documents to its surreply (see [455-1, at 115), but has not identified any
notes or memoranda from its review, much less notes or memoranda that it turned over to Anesi.
Therefore, the Court reduces the hours claimed by half.
Entry 50: “Located, reviewed and downloaded Steel King Videos: ‘About Steel
King Industries’ 2:23; ‘Safety Systems’ 1:23; ‘Time Lapse Installation’ 1:24”
TPMB has produced no evidence that it turned over these videos, or any notes or memoranda from
their review, to Anesi. Taxman’s chronology says he downloaded the videos and his affidavit
asserts that he gave an electronic copy of the client file to Anesi [458, at 2-3], so TPMB’s objection
that “the video could not be in the file” rings hollow. [455, at 7.] For failing to substantiate this
time entry, the Court reduces the claimed hours to 0.
Entries 51 and 52: “Investigation Report reviewed (report contained the following
witnesses): Adam Medlin, Jerry Grygiel, Phil Piel, Brian Elliott”
Entries 81 and 82: “Received and reviewed Development Agreement (12/5/16)
between Duke Realty Limited Partnership and Amzaon.com.dedc.LLL (136
pages)”
Entries 83 and 84: “Received and reviewed Lease Agreement between Duke Realty
Limited Partnership and Amzaon.com.dedc.LLL (121 pages)”
Entries 85 and 86: “Received and reviewed Amazon Documents: Amazon 188
Employee Statement Adam Medlin; Amazon 189 Chris Berardino Foreman’s
16

Report of injury Lakeside Adam Medlin; Amazon 190 Chris Berardino Foreman’s
Report of injury Lakeside Mike Johnson; Amazon 191 Chris Berardino Foreman’s
Report of injury Lakeside Andrew Woods; Amazon 192 Safety Meeting Sign-in
5/15/17”
Entry 90: “Web Research on Duke realty Limited Partnership 4:38pm”
Anesi objects that because the client file does not contain these documents, or notes or memoranda
about them, TPMB has failed to prove that the work occurred or was beneficial to the client. The
Court agrees that TPMB has failed to substantiate these time entries and reduces their hours to 0.
Entry 164: “Email from SPM RE: speaking to Andrew Woods on 10/31/17”
TPMB submitted evidence that it created this document ([455-1, at 23]), but not that it produced
the email to Anesi. Charging thirty minutes for the five-line email at issue also strikes the Court
as excessive. Pouncy v. City of Chicago, 2017 WL 8205488, at *9 (N.D. Ill. Dec. 11, 2017) (“In
determining the reasonable number of hours, a court should exclude hours that are excessive,
redundant or otherwise unnecessary. In exercising this discretion, the court may properly rely on
its own experience to estimate the time reasonably required for the work claimed.”) (citations
omitted). Therefore, the Court reduces the hours claimed by half for this entry.
Entries 169 and 170: “MAT and SPM Worked on the Rule 26(a)(1) Initial
Disclosure and Rule 26(a)(1) Documents”
TPMB’s surreply attached a five-page draft Rule 26(a)(1) disclosure, which TPMB asserts was
created between October 31 and November 16, 2017. [455-1, at 54-58.] Anesi objects that the
draft disclosure was not in the client file, so the client could not have benefited from the work.
TPMB does not appear to have served the disclosures on Plaintiff’s behalf; Anesi was the firm to
file a notice of Plaintiff’s 26(a)(1) disclosures. See [69]. Nor has TPMB produced any evidence
that it turned over the draft disclosures to Anesi or that the work otherwise benefited the client.
TPMB has failed to substantiate these time entries and work’s benefit to the client, so the Court
reduces their hours to 0.
17

Work performed on November 16, 2017, and later
Anesi argues that the client terminated his relationship with TPMB on November 16, 2017,
and TPMB should not be paid for work performed after termination of the relationship, because it
did not benefit the client. TPMB argues that it owed duties to the client until the Court granted its
motion to withdraw, which occurred on December 11, 2017 (see [77]), so it should be paid for
work performed between receiving a termination letter and the Court’s order granting the motion
to withdraw.
TPMB’s argument would be more persuasive if it had performed critical or time-sensitive
work between November 16 and December 11.

Instead, that work was largely reviewing

defendants’ Rule 26(a) disclosures and a “Master Purchase Agreement” between two of the
defendants. See Appendix A, Entries 173-180. TPMB does not explain why its duties to the client
required it to perform this work after receiving a termination letter. Furthermore, three hours of
the claimed time (Appendix A, entry 181) was spent preparing for and delivering an argument that
the Court “should vet the facts regarding TPMB, LLC’s discharge” ([458, at 12]), which is
obviously in TPMB’s interest but not obviously of benefit to the client. Similarly, the time that
two attorneys spent reviewing the Court’s three-line minute entry [78] granting the motion to
withdraw may have benefited TPMB, but TPMB has not explained how it benefits the client.
Therefore, the Court denies the claims for work done on November 16, 2017 and later (Appendix
A, Entries 173-181, and 184-185), with the exception of the time spent preparing the motion to
withdraw, as that was a reasonable charge in the normal course of an attorney’s representation of
the client (Appendix A, entries 182-183).
2.

Attorneys’ Rates

18

In the context of an award of attorneys’ fees, a reasonable hourly rate is one that is “derived
from the market rate for the services rendered.” Pickett v. Sheridan Health Care, 664 F.3d 632,
640 (7th Cir. 2011) (quoting Denius v. Dunlap, 330 F.3d 919, 930 (7th Cir. 2003)). If an attorney
uses contingent fee arrangements, the “next best evidence” of the attorney’s market rate is
“evidence of rates similarly experienced attorneys in the community charge paying clients for
similar work and evidence of fee awards the attorney has received in similar cases.” Spegon v.
Catholic Bishop of Chi., 175 F.3d 544, 555 (7th Cir. 1999); Gibson v. City of Chicago, 873 F.
Supp. 2d 975, 982 (N.D. Ill. 2012). The fee applicant bears the burden of “produc[ing] satisfactory
evidence—in addition to the attorney’s own affidavits—that the requested rates are in line with
those prevailing in the community.” Blum v. Stenson, 465 U.S. 886, 895 n. 11, (1984). If a fee
applicant does not satisfy its burden, the district court has the authority to make its own
determination of a reasonable rate. Pickett, 664 F.3d at 640 (citing Uphoff v. Elegant Bath, Ltd.,
176 F.3d 399, 409 (7th Cir. 1999)).
The Court begins where TPMB does, with Mark Taxman. TPMB seeks a rate of $754.50
per hour for Mark Taxman. Taxman is a partner at TPMB (and former partner at Anesi) who has
been practicing personal injury law for more than thirty years. [450, at 8; 455-1, at 134.] TPMB
supports this hourly rate with two affidavits. The first is a brief statement from Phillip Reed, a
partner and commercial litigator at Patzik, Frank & Samotny Ltd., establishing that his own rate is
$570 per hour. [450-3, at 2.] Mr. Reed is an experienced and capable attorney, but his experience
is in commercial litigation, not personal injury or even other tort cases, and TPMB does not explain
why that experience is comparable to Taxman’s beyond the unsupported assertion that “[t]he work
of a personal injury attorney and a commercial litigator is quite similar.” [455, at 9.] In short, the
affidavit is too disconnected from the relevant facts of this dispute to have much probative value.

19

Montanez v. Simon, 755 F.3d 547, 554 (7th Cir. 2014) (holding that district court properly
disregarded “conclusory affidavit * * * merely opining on the reasonableness of another attorney’s
fees”) (citing Pickett, 664 F.3d. at 647).
The second affidavit is a more detailed statement from Gabriel Aizenberg, a shareholder
and commercial litigator at Greenberg Traurig, LLP, that was originally filed in a state court case.
[450-4, at 2.] The affidavit avers that Aizenberg’s average billing rate for the matter was $682.80
per hour. [450-4, at 5.] Again, although the affiant appears experienced and competent, TPMB
does not explain how Aizenberg’s commercial litigation work supports a $750 per hour billing rate
for Taxman’s personal injury work.
TPMB also submitted as support a version of the Laffey Matrix (see [450-5, at 2-3]) which
is a table of hourly rates published by the U.S. Attorney’s Office for the District of Columbia,
which some circuits use to help determine a reasonable fee under fee-shifting statutes. Montanez,
755 F.3d at 554. The Seventh Circuit has been skeptical of applying the Laffey Matrix outside of
Washington, D.C., (see Pickett, 664 F.3d at 649–51), and in any event Anesi points out that the
version TPMB submitted is unofficial.9 TPMB’s surreply brief says it is not relying on any of the
hourly rates listed on the Laffey Matrix (though it does us the Matrix in another way, described
below). [455, at 10.]
Finally, TPMB’s surreply argues that in 2015, when Taxman was a partner at Anesi, Anesi
argued his hourly rate in a quantum meruit fee petition should be $500 per hour ([455-1, at 143]),
though TPMB does not offer evidence that any court determined that $500 per hour was a
reasonable rate. TPMB also asserts that Anesi in 2018 agreed that $750 per hour for Taxman’s
work was reasonable (see [455-1, at 132.]), though that email contradicts a filing Anesi made in

9

The official version is available here: https://www.justice.gov/usao-dc/page/file/1189846/download

20

the same case asserting that the usual and customary work for an attorney with the experience and
reputation of Taxman is $500 per hour. [455-1, at 140.] These documents undermine Anesi’s
position that Taxman’s work is worth at best $275 per hour (see below), even though they still fall
short of establishing a prevailing rate of similarly experienced attorneys in the field or presenting
evidence of fee awards that Taxman actually received in similar cases. See Spegon, 175 F.3d at
555.
In response, Anesi offered an affidavit from Michael Krause, a partner at Bollinger,
Connolly, Krause, LLC, who has experience in personal injury cases, primarily on the defense
side. [453-3, at 1.] The affidavit states that the normal rate for personal injury work in the Chicago
area ranges from $235 to $275 per hour for a partner and $175 and $200 for an associate. Id. The
affidavit is somewhat light on supporting details, which gives the Court pause in light of Montanez
as noted above, but Krause’s experience is in the relevant area of the law. TPMB argues, without
citation, that the Court should disregard Krause’s figures because “[i]t is well known in the legal
community that insurance defense attorneys have suppressed hourly rates.” [455, at 8-9.] 10
The Court next looks to recent Seventh Circuit and Illinois cases awarding fees to attorneys
in tort or personal injury cases. Two are on point. In 2015, the Seventh Circuit found that a “rate
of $300 for partners and $180 for associates” for work in a personal injury lawsuit was not
unreasonable. Goesel v. Boley Int’l (H.K.) Ltd., 806 F.3d 414, 420 (7th Cir. 2015). More recently,
in Coffman Law Offices, P.C. v. Damore, No. 2-18-0649, 2019 WL 2005921, at *1 (Ill. App. Ct.
May 6, 2019), the Illinois Appellate Court affirmed a fee award in a simple personal injury case to

10

TPMB supported its reliance on commercial litigators’ rates in party by arguing, “if TPMB cannot rely
upon commercial litigators to arrive at a reasonable hourly rate, it would be left with nowhere else to turn.”
[455, at 10.] But TPMB could have turned to fee awards (not just requested rates) in its own cases, as its
allusions to Taxman’s asserted rates in other matters demonstrates. Or TPMB could have turned to fee
awards to any other personal injury lawyers of similar prominence and experience in similar cases.

21

two attorneys: $350 per hour for an attorney with 30 years of experience, and $300 per hour for an
attorney with thirteen years of experience. Id. To be sure, the Court’s experience, both in practice
and on the bench, confirm the common sense notion that not all lawyers of a given experience
level have similar skill sets, and the particular lawyer in question here has been an accomplished
litigator at leading personal injury firms during his career. His rate should be higher than the $300$350 set out in the cases cited above.
Obviously, there is a wide gulf between the $235-$275 per hour suggested by Anesi, the
$300-$350 per hour derived from the cases above, and the more than $750 per hour requested by
TPMB. Lacking a firm basis for setting a rate based on what courts have awarded personal injury
lawyers of similar experience and reputation in similar cases, the most compelling valuation in the
record before the Court is the $500 per hour claim that Anesi itself made on Taxman’s behalf a
few years back when he was working with them. Anesi should not be able to easily walk away
from its representation to another court in a quantum meruit claim asserted for the same kind of
work in the same city during the same year. It seems very unlikely that Taxman’s skills changed
much in the short period of time between February 2017 when the Anesi firm was discharged in
the Richardson litigation and the period later that year when Taxman and his colleagues were
working on this case. Despite the plethora of paper filed by both sides in this case, the Court can
find no better basis for setting the value of Taxman’s work in this case than the asserts of his
erstwhile colleagues—now adversaries—in a court-filed document when the benefits of his work
redounded to their benefit. And for what it is worth, that figure also passes the Court’s “eye” test
for personal injury work in this District. While TPMB does not present compelling evidence
supporting its argument for going any higher, Anesi can hardly cry foul for having been hoist on
its own petard.

22

TPMB uses Taxman’s rate as the basis for calculating the other attorneys’ rates. Basically,
TPMB wants the Court to apply a discount to Taxman’s rate for each attorney who worked on the

case, with larger discounts for less-experienced attorneys. The discount amounts come from
differences between pay rates on the Laffey Matrix.11 Though the method has some intuitive
appeal, TPMB cites no authority supporting such a calculation of rates for attorneys’ fees (or
overcoming the Seventh Circuit’s skepticism for the underlying Matrix). Instead, the Court will
use what appears to be the standard method of awarding fees: determining a reasonable rate for
partners and a reasonable rate for associates. This might be inappropriate if there were clear
distinctions in the ability and experience among the partners who worked on the case, but in this
instance, the three partners are all named partners in the firm and each has almost two decades (or
more) experience practicing law. Accordingly, TPMB partners Mark Taxman, Brad Pollock, and
Sean Murray will be compensated at $500 per hour.
TPMB associates Lindsay Scheidt and Haig Himidian also worked on this matter. The

Court’s experience and recent fee awards in personal injury cases in Illinois suggest that $300 per
hour (or 60% of the partners’ rate) is a reasonable rate for their work. See Goesel, 806 F.3d at 420
(in which reasonable associate rate of $180 per hour was 60% of reasonable partner rate of $300
per hour).
The Court applied these partner and associate hourly rates to the hours that TPMB
substantiated, as detailed in Appendix A. In sum, TPMB is entitled to a quantum meruit award of
$69,825 in attorneys’ fees.
IV.

Conclusion

11

E.g., on the Laffey Matrix, an attorney with 30 years of experience has a rate of $595 per hour, and an
attorney with 20 years of experience has a rate of $566 per hour, which is 95% of the more-senior attorney’s
rate. See [453-2].

23

For the reasons set forth above, TPMB’s motion to strike [456] is denied, and Plaintiff’s
motion to adjudicate the Claimant’s quantum meruit attorneys’ lien [434] is granted. The Court
finds that TPMB is entitled to $69,825 in attorneys’ fees.

Dated: July 1, 2020

____________________________
Robert M. Dow, Jr.
United States District Judge

24

Appendix A

Date

5.16.17

5.16.17

5.16.17
5.16.17
5.17.17
5.17.17
5.18.17
5.18.17
5.18.17

5.22.17

5.22.17

5.22.17

5.22.17
5.22.17
5.22.17
5.22.17

5.23.17

5.23.17

5.25.17
6.1.17
6.2.17

6.5.17

6.5.17

6.5.17
6.5.17

Entry
No.

1

2

3
4
5
6
7
8
9

10

11

12

13
14
15
16

17

18

19
20
21

22

23

24
25

MAT
MAT

SPM

MAT

SPM
MAT
SPM

SPM

MAT

SPM
HAH
HAH
HAH

BNP

MAT

SPM

SPM
HAH
MAT
SPM
HAH
MAT
SPM

LJS

SPM

Attorney

0.25
0.125

0.5

0.5

0.25
1
0.5

1.25

1.25

2
0.5
0.5
0.5

4.5

4.5

4.5

1
1
0.75
0.75
0.75
1.25
1.25

8

8

0.25
0.125

0.5

0.5

0.5
0.25

1.25

1.25

0
0.25
0.25
0.25

4.5

4.5

4.5

1
1
0.75
0.75
0.75
0
0

7.5

7.5

Hours
Hours
Claimed Substantiated

$500
$500

$500

$500

$500
$500
$300

$500

$500

$500
$300
$300
$300

$500

$500

$500

$500
$300
$500
$500
$300
$500
$500

$300

$500

Hourly
Rate

$125
$63

$250

$250

$0
$250
$75

$625

$625

$0
$75
$75
$75

$2,250

$2,250

$2,250

$500
$300
$375
$375
$225
$0
$0

$2,250

$3,750

Reasonable
Fee

1 of 8

Received and reviewed Fax from Copley Memorial Hospital
Received and reviewed Copley Memorial Hospital ER Bills

Received and reviewed Letter from Corrine Rice Sedgwick Claims Management (4 pages)

Call from Corrine Sedgwick, received lien and to discuss case Claim #301-77940587
MAT Memo to file RE; Meeting at Jack Keck's house in Yorkville, IL (1Page)
Email from SPM RE: Speaking to Andrew Woods on 6/2/17
Received and reviewed Letter from Corrine Rice Sedgwick Claims Management (4 pages)

Investigation Report reviewed (report contained the following witnesses): Mike Johnson
(identified as the other injured party), Stu Mosley, Adam Medlin, Randy Wilkerson, Dirk
Enger (on the job and took photos), Jim Tucker, Frank Norman, John Coby

TPMB, LLC retained by Andrew Woods; Travel to meeting at client's house in Earlville,
IL; Write-up case and interview client; Retainer signed - contingency fee 33.33%; Medical
Authorizations signed
TPMB, LLC retained by Andrew Woods; Travel to meeting at client's house in Earlville,
IL; Write-up case and interview client; Retainer signed - contingency fee 33.33%; Medical
Authorizations signed
Opened file in Office and system
Opened file in Office and system
96 Photos of the job obtained, printed and reviewed
96 Photos of the job obtained, printed and reviewed
Prepared and sent Letter to Andrew Woods
Web research on Amazon
Web research on Amazon
Travel to meeting with Andrew Woods and his grandfather, Jack Keck, at Jack Keck's
house in Yorkville, IL
Travel to meeting with Andrew Woods and his grandfather, Jack Keck, at Jack Keck's
house in Yorkville, IL
Travel to meeting with Andrew Woods and his grandfather, Jack Keck, at Jack Keck's
house in Yorkville, IL
SPM prepared a case status Memo (4pages)
Prepared and sent Letter of representation to Amazon IL
Prepared and sent Letter of representation to Washington State
Prepared and sent Letter of representation to Steel King
Investigation Report reviewed (report contained the following witnesses): Mike Johnson
(identified as the other injured party), Stu Mosley, Adam Medlin, Randy Wilkerson, Dirk
Enger (on the job and took photos), Jim Tucker, Frank Norman, John Coby

Description of Work

6.5.17

6.6.17

6.6.17

6.8.17
6.8.17

6.8.17

6.8.17

6.8.17

6.9.17

6.9.17

6.9.17
6.9.17
6.9.17
6.9.17
6.9.19
6.9.19

6.9.17

6.9.17

6.9.17

6.10.17
6.10.17

6.10.17

6.12.17
6.12.17

26

27

28

29
30

31

32

33

34

35

36
37
38
39
40
41

42

43

44

45
46

47

48
49

MAT
SPM

MAT

SPM
SPM

MAT

SPM

MAT

SPM
SPM
MAT
SPM
MAT
SPM

SPM

MAT

SPM

SPM

MAT

MAT
SPM

SPM

MAT

SPM

2.5
2.5

1

1
1

3

0.125

0.125

0.75
0.5
0.5
0.5
0.25
0.25

1.5

1.5

0.5

0.25

0.25

3
3

1.25

1.25

0.125

2.5
2.5

0.5

0
0

1.5

0.125

0.125

0.75
0.5
0.5
0.5
0.25
0.25

1.5

1.5

0.5

0.25

0.25

3
3

1.25

1.25

0.125

$500
$500

$500

$500
$500

$500

$500

$500

$500
$500
$500
$500
$500
$500

$500

$500

$500

$500

$500

$500
$500

$500

$500

$500

$1,250
$1,250

$250

$0
$0

$750

$63

$63

$375
$250
$250
$250
$125
$125

$750

$750

$250

$125

$125

$1,500
$1,500

$625

$625

$63

2 of 8

Prepared Woods First Amended Complaint final Draft
Prepared Woods First Amended Complaint final Draft

Prepared and issued summons: Amazon, Duke, Steel King
Mandatory Initial Discovery Pilot (MIDP) Order and reviewed criteria
Obtained and reviewed Mandatory Initial Discovery Pilot Checklist (3 pages)
Obtained and reviewed Mandatory Initial Discovery Pilot Checklist (3 pages)
Obtained and reviewed Standing Order Regarding Mandatory Initial Discovery Pilot
Obtained and reviewed Standing Order Regarding Mandatory Initial Discovery Pilot
Obtained and reviewed Order entered to Amend Complaint to plead subject matter
jurisdiction
Obtained and reviewed Order entered to Amend Complaint to plead subject matter
jurisdiction
Researched and reviewed OSHA Standards: OSHA 3220 Warehousing Worker Safety
Services (15 pages), OSHA 2236 Materials Handling and Storage (41 pages)
Reviewed RUSH Copley Emergency Room Records (39 pages)
Reviewed City of Aurora Fire Department EMT Records
Researched and reviewed Steel King "Built to Deliver / Designed to Perform" (12 pages)

Researched Identity of Defendants: Amazon.com LLL; Amaxon.com LLC managers;
Amazon.com Washington LLC; Duke Realty Corp; Duke Realty Service, LLC; Duke
Realty Service, LLC Managers; Steel King Industries / Associates (from website); Steel
King locations reviewed (from website); Steel King Industries, Inc. reviewed from the
Wisconsin Department of Finance

Received and reviewed Copley Memorial Hospital ER Bills
Investigation Report reviewed (report contained the following witnesses): John Colby, Eric
Carlin, Jose Aguire, Adam Medlin
Investigation Report reviewed (report contained the following witnesses): John Colby, Eric
Carlin, Jose Aguire, Adam Medlin
Prepared Woods Complaint Final Draft
Prepared Woods Complaint Final Draft
Obtained and reviewed Instructions for Attorney completing Civil Cover sheet and Civil
Cover Sheet Completed
Obtained and reviewed Instructions for Attorney completing Civil Cover sheet and Civil
Cover Sheet Completed
Woods Complaint filed
Researched Identity of Defendants: Amazon.com LLL; Amaxon.com LLC managers;
Amazon.com Washington LLC; Duke Realty Corp; Duke Realty Service, LLC; Duke
Realty Service, LLC Managers; Steel King Industries / Associates (from website); Steel
King locations reviewed (from website); Steel King Industries, Inc. reviewed from the
Wisconsin Department of Finance

6.12.17

6.12.17

6.12.17

6.13.17

6.13.17

6.15.17
6.15.17
6.17.17
6.17.17
6.17.17
6.17.17

6.17.17

6.19.17
6.22.17

6.23.17

6.23.17

6.26.17
6.26.17
6.29.17

6.30.17

7.1.17

7.5.17

7.8.17

7.11.17

50

51

52

53

54

55
56
57
58
59
60

61

62
63

64

65

66
67
68

69

70

71

72

73

MAT

MAT

SPM

MAT

MAT

MAT
SPM
MAT

SPM

MAT

SPM
SPM

SPM

MAT
SPM
MAT
MAT
MAT
MAT

SPM

SPM

SPM

MAT

MAT

0.125

0.5

2

0.25

2

0.5
0.5
0.25

1

1

0.5
0.5

0.75

0.125
0.125
1
1
1
1

1

0.5

1

1

2

0.125

0.5

2

0.25

2

0.5
0.5
0.25

1

1

0.5
0.5

0.75

0.125
0.125
1
1
1
1

1

0.5

0

0

0

$500

$500

$500

$500

$500

$500
$500
$500

$500

$500

$500
$500

$500

$500
$500
$500
$500
$500
$500

$500

$500

$500

$500

$500

$63

$250

$1,000

$125

$1,000

$250
$250
$125

$500

$500

$250
$250

$375

$63
$63
$500
$500
$500
$500

$500

$250

$0

$0

$0

3 of 8

Received and reviewed Steel King Appearance of attorney Steve Mahoney filed; Received
and reviewed Steel King Jury Demand filed
Reviewed Steel king Motion to Extend Time reviewed (1 page); NOF Steel king Motion to
Extend Time

Received and reviewed Amazon Consent Order
Retained Security & Investigation Specialists to serve Duke Realty; Received and reviewed
Proof of service on Duke Realty; Prepared and filed NOF Proof of service Duke Realty

Located, reviewed and downloaded Steel King Videos: "About Steel King Industries" 2:23;
"Safety Systems" 1:23; "Time Lapse Installation" 1:24
Investigation Report reviewed (report contained the following witnesses): Adam Medlin,
Jerry Grygiel, Phil Piel, Brian Elliott
Investigation Report reviewed (report contained the following witnesses): Adam Medlin,
Jerry Grygiel, Phil Piel, Brian Elliott
Woods First Amended Complaint filed; NOF Woods First Amended Complaint filed
John Pennell Private Investigator hired for Corporate service of Amazon LLC and given
First Amended Complaint
Received and reviewed Docket Entry Rule 26F
Received and reviewed Docket Entry Rule 26F
Researched Duke Realty Corp Indianapolis
Web research on Amazon.comLLC 10:38am
Web research on Steel King 10:50am
Web research on Duke Realty 12:21pm
Obtained and reviewed Affidavit of Service Amazon LLC; NOF Affidavit of Service
Amazon LLC
ATG Legal Service/Hollund Shaf retained to serve Steel King in Stevens Point, WI
Obtained and reviewed Affidavit of Service on Steel King 6/20/17
Investigation Report reviewed (report contained the following witnesses): Phil Piel, Jerry
Grygiel, Brian Elliott
Investigation Report reviewed (report contained the following witnesses): Phil Piel, Jerry
Grygiel, Brian Elliott
Received and reviewed Email from investigator about case
Received and reviewed Email from investigator about case
Received and reviewed Email from Phil Fluhr 4:04pm
Conference with Phil Fluhr attorney for Amazon; Received and reviewed Amazon
Appearance of attorney Phil Fluhr filed; Received and reviewed Amazon Consent Motion
for extension of time; Received and reviewed NOF Amazon Consent Motion for extension
of time; Received and reviewed Amazon Appearance of attorney Kimberly Flanigan filed

7.11.17

7.12.17

7.12.17

7.13.17

7.13.17

7.17.17

7.17.17

76

77

78

79

80

81

82

SPM

7.17.18
[sic]

7.17.17

7.17.17

7.17.17

7.17.17

7.18.17

86

87

88

89

90

91

MAT

MAT

MAT

MAT

MAT

MAT

7.17.18
[sic]

SPM

MAT

SPM

MAT

SPM

MAT

SPM

MAT

SPM

MAT

SPM

85

84

7.17.15
[sic]
7.17.15
[sic]

7.11.17

75

83

7.11.17

74

0.5

1

0.25

0.25

2

0.5

0.5

2

2

2.25

2.25

0.75

0.75

1.25

1.25

0.25

1

0.125

0.5

0

0.25

0.25

2

0

0

0

0

0

0

0.75

0.75

1.25

1.25

0.25

1

0.125

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$250

$0

$125

$125

$1,000

$0

$0

$0

$0

$0

$0

$375

$375

$625

$625

$125

$500

$63

4 of 8

Prepared for and attended Conference at TPMB with Patrick Garvey, Steve Mahoney (by
phone) and Phil Fluhr Re: Initial Status Report
MAT Email to Patrick Garvey RE: Duke Realty 12:46pm
MAT Email to Mike Johnson's counsel RE: Initial Status Report, with draft copy of Woods
Complaint and Draft Status Report
Web Research on Duke realty Limited Partnership 4:38pm
Received and reviewed Amazon Motion to Extend time and conference with Phil Fluhr;
Received and reviewed NOM Amazon Motion to Extend time

Received and reviewed Amazon Documents: Amazon 188 Employee Statement Adam
Medlin; Amazon 189 Chris Berardino Foreman's Report of injury Lakeside Adam Medlin;
Amazon 190 Chris Berardino Foreman's Report of injury Lakeside Mike Johnson; Amazon
191 Chris Berardino Foreman's Report of injury Lakeside Andrew Woods; Amazon 192
Safety Meeting Sign-in 5/15/18

Reviewed Steel king Motion to Extend Time reviewed (1 page); NOF Steel king Motion to
Extend Time
Reviewed Duke Realty appearance of attorney Patrick Garvey filed; Conference with
Patrick Garvey
Received and reviewed letter from Accident Fund Holdings, Inc. Lien /Subrogation agent
for EZ Erectors, Inc. Kelly Drummeismith
Investigation Report reviewed (report contained the following witnesses): Jose Aguirre,
Jim Tucker, Tom Wollenweber, Ken Beasley
Investigation Report reviewed (report contained the following witnesses): Jose Aguirre,
Jim Tucker, Tom Wollenweber, Ken Beasley
Received and reviewed the instructions for initial Status Report; Prepared Draft Initial
Status Report; Prepared Service list
Received and reviewed the instructions for initial Status Report; Prepared Draft Initial
Status Report; Prepared Service list
Received and reviewed Development Agreement (12/5/16) between Duke Realty Limited
Partnership and Amzaon.com.dedc.LLL (136 pages)
Received and reviewed Development Agreement (12/5/16) between Duke Realty Limited
Partnership and Amzaon.com.dedc.LLL (136 pages)
Received and reviewed Lease Agreement between Duke Realty Limited Partnership and
Amzaon.com.dedc.LLL (121 pages)
Received and reviewed Lease Agreement between Duke Realty Limited Partnership and
Amzaon.com.dedc.LLL (121 pages)
Received and reviewed Amazon Documents: Amazon 188 Employee Statement Adam
Medlin; Amazon 189 Chris Berardino Foreman's Report of injury Lakeside Adam Medlin;
Amazon 190 Chris Berardino Foreman's Report of injury Lakeside Mike Johnson; Amazon
191 Chris Berardino Foreman's Report of injury Lakeside Andrew Woods; Amazon 192
Safety Meeting Sign-in 5/15/17

7.18.17

7.18.17

7.18.17

7.18.17
7.18.17
7.18.17

7.19.17

7.19.17

7.19.17
7.19.17

7.19.17

7.19.17

7.24.17

7.24.17

7.25.17
7.25.17
7.25.17
7.26.17
7.26.17
7.26.17
7.26.17
7.26.17
7.26.17

92

93

94

95
96
97

98

99

100
101

102

103

104

105

106
107
108
109
110
111
112
113
114

MAT
MAT
SPM
MAT
SPM
MAT
SPM
MAT
SPM

SPM

MAT

SPM

MAT

MAT
SPM

SPM

MAT

MAT
SPM
SPM

SPM

MAT

SPM

2
0.125
0.125
0.125
0.125
0.125
0.125
0.125
0.125

1

1

0.25

0.25

0.25
0.25

0.5

0.5

1.5
1.5
0.25

3.5

3.5

0.5

2
0.125
0.125
0.125
0.125
0.125
0.125
0.125
0.125

1

1

0.25

0.25

0.25
0.25

0.5

0.5

1.5
1.5
0.25

3.5

3.5

0.5

$500
$500
$500
$500
$500
$500
$500
$500
$500

$500

$500

$500

$500

$500
$500

$500

$500

$500
$500
$500

$500

$500

$500

$1,000
$63
$63
$63
$63
$63
$63
$63
$63

$500

$500

$125

$125

$125
$125

$250

$250

$750
$750
$125

$1,750

$1,750

$250

5 of 8

Prepared Initial Rule 16(b) and 26(f) Joint Status Report by MAT and SPM and filed it
Prepared Initial Rule 16(b) and 26(f) Joint Status Report by MAT and SPM and filed it
Prepared NOF Initial Rule 16(b) and 26(f) Joint Status Report filed
Received and reviewed Minute Order - 7.25.17 Status Hearing and leave granted to file
Second Amended Complaint; Second Amended Complaint filed with the Court (16 pages);
Prepared NOF Second Amended Complaint
Received and reviewed Minute Order - 7.25.17 Status Hearing and leave granted to file
Second Amended Complaint; Second Amended Complaint filed with the Court (16 pages);
Prepared NOF Second Amended Complaint
Reviewed Initial Status Report Amendment
Reviewed Initial Status Report Amendment
Reviewed Form "Report of Parties Planning Meeting" pursuant to Fed. R. Civ. P. 26(f) (2
pages)
Reviewed Form "Report of Parties Planning Meeting" pursuant to Fed. R. Civ. P. 26(f) (2
pages)
Investigation Report reviewed (report contained the following witnesses): Jim Tucker, Fran
Norman, Tom Cambier, Kyle Steima
Investigation Report reviewed (report contained the following witnesses): Jim Tucker, Fran
Norman, Tom Cambier, Kyle Steima
Prepared for and attended the Status Hearing before Judge St. Eve
Received and reviewed Minute Order entered from the 7.25.17 Status Hearing
Received and reviewed Minute Order entered from the 7.25.17 Status Hearing
Received and reviewed Judge St. Eve recusal
Received and reviewed Judge St. Eve recusal
Received and reviewed Order entered striking the 9.18.17 status
Received and reviewed Order entered striking the 9.18.17 status
Received and reviewed Judge Castillo docket entry setting 8.16.17 Status
Received and reviewed Judge Castillo docket entry setting 8.16.17 Status

Prepared Second Amended Complaint final Draft; Prepared Motion to file Second
Amended Complaint final draft; Prepared Motion to file Second Amended Complaint filed;
Prepared Consent Motion to file Second Amended Complaint; Prepared NOM Consent
Motion to file Second Amended Complaint; Second Amended Complaint filed w/motion

Received and reviewed Amazon Motion to Extend time and conference with Phil Fluhr;
Received and reviewed NOM Amazon Motion to Extend time
Prepared Second Amended Complaint final Draft; Prepared Motion to file Second
Amended Complaint final draft; Prepared Motion to file Second Amended Complaint filed;
Prepared Consent Motion to file Second Amended Complaint; Prepared NOM Consent
Motion to file Second Amended Complaint; Second Amended Complaint filed w/motion

8.7.17

8.14.17
8.14.17

8.16.17

8.16.17

8.16.17

8.16.17

8.16.17

8.18.17

8.18.17

8.9.17
8.9.17
8.10.17
8.10.17

8.16.17

8.16.17

8.22.217

8.23.17
8.23.17
8.23.17
8.23.17
8.23.17
8.23.17
8.30.17
8.30.17

9.1.17

115

116
117

118

119

120

121

122

123

124

125
126
127
128

129

130

131

132
133
134
135
136
137
138
139

140

MAT

MAT
SPM
MAT
SPM
MAT
SPM
MAT
SPM

MAT

SPM

MAT

MAT
SPM
MAT
SPM

MAT

MAT

SPM

MAT

SPM

SPM

MAT

MAT
SPM

MAT

0.25

0.75
0.75
0.5
0.5
0.5
0.5
0.5
0.5

1.5

0.75

0.75

0.5
0.5
0.5
0.5

3

1

0.125

0.125

2

0.5

0.5

0.25
0.25

1.5

0.25

0.75
0.75
0.5
0.5
0.5
0.5
0.5
0.5

1.5

0.75

0.75

0.5
0.5
0.5
0.5

3

1

0.125

0.125

2

0.5

0.5

0.25
0.25

1.5

$500

$500
$500
$500
$500
$500
$500
$500
$500

$500

$500

$500

$500
$500
$500
$500

$500

$500

$500

$500

$500

$500

$500

$500
$500

$500

$125

$375
$375
$250
$250
$250
$250
$250
$250

$750

$375

$375

$250
$250
$250
$250

$1,500

$500

$63

$63

$1,000

$250

$250

$125
$125

$750

6 of 8

Received and reviewed Duke Initial Status
Received and reviewed Duke Initial Status
Obtained, printed and reviewed Judge Castillo's Rules, Standing Orders and Court Protocol
from Web
Obtained, printed and reviewed Judge Castillo's Rules, Standing Orders and Court Protocol
from Web
Prepared for and attended the Status Hearing before Judge Castillo
Reviewed Docket entry - Minute Order - Next Status 11/9/17, Rule 26(a)(1) disclosures by
11/1/17
Reviewed Docket entry - Minute Order - Next Status 11/9/17, Rule 26(a)(1) disclosures by
11/1/18
Received and reviewed Steel King Complaint for Contribution/counterclaim v. Amazon
and Duke
Prepared Plaintiff Reply to Aff Defs Duke and filed; Prepared Plaintiff Reply to Aff Defs
Steel King and filed; Prepared Plaintiff Reply to Aff Defs Amzon and filed
Received and reviewed First Amended Joint Status Report
Received and reviewed First Amended Joint Status Report
Received and reviewed Duke Realty Initial Status Report reviewed (Patrick Garvey)
Received and reviewed Duke Realty Initial Status Report reviewed (Patrick Garvey)
Investigation Report reviewed (report contained the following witnesses): Tom Cambier,
Kyle Stelma
Investigation Report reviewed (report contained the following witnesses): Tom Cambier,
Kyle Stelma
Received and reviewed Duke Realty Complaint for Contribution/counterclaim v. Steel
King and Amazon
Reviewed Prasan Atluri, MD / Hand to Shoulder Associates Report (8 pages)
Reviewed Prasan Atluri, MD / Hand to Shoulder Associates Report (8 pages)
Received and reviewed Amazon Cross-claim
Received and reviewed Amazon Cross-claim
Received and reviewed Amazon Contribution Action v. Lakeside RackInstallers
Received and reviewed Amazon Contribution Action v. Lakeside RackInstallers
Received and reviewed Duke 3rd Party Complaint v. Lakeside Rack installers
Received and reviewed Duke 3rd Party Complaint v. Lakeside Rack installers
Received and reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records 8/30/17
Note return to work with restrictions

Received and reviewed Amazon Answer and Aff Defs to 2nd Amended Complaint 22
pages, 5 Affirmative Defenses filed and downloaded; Received and reviewed Duke
Answer and Aff Defs to 2nd Amended Complaint 16 pages, 8 Affirmative Defenses filed
and downloaded; Received and reviewed Steel king Answer and Aff Defs to 2nd
Amended Complaint 22 pages, 3 Affirmative Defenses filed and downloaded

9.1.17

9.5.17
9.18.17
9.18.17
9.29.17
10.4.17
10.5.17
10.5.17

10.12.17

10.12.17

10.25.17
10.25.17

10.25.17

10.26.17

10.26.17

10.26.17

10.26.17

10.27.17

10.27.17

10.30.17

10.30.17

10.30.17
10.30.17
10.31.17
10.31.17
10.31.17

141

142
143
144
145
146
147
148

149

150

151
152

153

154

155

156

157

158

159

160

161

162
163
164
165
166

SPM
SPM
SPM
MAT
SPM

SPM

MAT

SPM

MAT

SPM

MAT

SPM

MAT

SPM

MAT
SPM

SPM

MAT

MAT
MAT
MAT
MAT
MAT
MAT
MAT

SPM

0.25
0.25
0.5
0.5
0.5

0.25

0.25

0.25

0.25

0.125

0.125

0.25

0.25

0.25

0.125
0.125

0.25

0.25

0.5
0.5
0.5
0.25
0.25
0.5
0.5

0.25

0.25
0.25
0.25
0.5
0.5

0.25

0.25

0.25

0.25

0.125

0.125

0.25

0.25

0.25

0.125
0.125

0.25

0.25

0.5
0.5
0.5
0.25
0.25
0.5
0.5

0.25

$500
$500
$500
$500
$500

$500

$500

$500

$500

$500

$500

$500

$500

$500

$500
$500

$500

$500

$500
$500
$500
$500
$500
$500
$500

$500

$125
$125
$125
$250
$250

$125

$125

$125

$125

$63

$63

$125

$125

$125

$63
$63

$125

$125

$250
$250
$250
$125
$125
$250
$250

$125

7 of 8

Received and reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records 8/30/17
Note return to work with restrictions
Received and reviewed Duke Answer to Steel King
Received and reviewed Amazon Answer to Duke Counterclaim
Received and reviewed Amazon Answer to Steel King Counterclaim
Received and reviewed Steel King Motion to file Answer
Received and reviewed Order Granting Steel King Answer to Counterclaim
Received and reviewed Steel King Answer to Duke Cross-claim
Received and reviewed Steel King Answer to Amazon Cross-claim
Received and reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records
10/11/17 Note (2 pages)
Received and reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records
10/11/17 Note (2 pages)
Received and reviewed Amazon Motion to Substitute Counsel
Received and reviewed Amazon Motion to Substitute Counsel
Received and reviewed Ordered Aurora Fire Department Records from Record Copy
Service
Received and reviewed Amazon Substitution of Attorneys; Received and reviewed
Amazon Motion for Substitution of Attorneys
Received and reviewed Amazon Substitution of Attorneys; Received and reviewed
Amazon Motion for Substitution of Attorneys
Conference with Kyle Blair and Mike Mullen to extend Amazon time to file Rule 26(a)(1)
disclosures
Conference with Kyle Blair and Mike Mullen to extend Amazon time to file Rule 26(a)(1)
disclosures
Received and reviewed Amazon Motion to Extend time to file Rule 26(a)(1) Disclosures;
Received and reviewed NOM Amazon Motion to Extend time to file Rule 26(a)(1)
Disclosures
Received and reviewed Amazon Motion to Extend time to file Rule 26(a)(1) Disclosures;
Received and reviewed NOM Amazon Motion to Extend time to file Rule 26(a)(1)
Disclosures
Received and reviewed Order to extend Rule 26(a)(1) disclosures granted until 11/22/17,
the 11/9/17 status stricken and next status set for 11/28/2017
Received and reviewed Order to extend Rule 26(a)(1) disclosures granted until 11/22/17,
the 11/9/17 status stricken and next status set for 11/28/2018
SPM letter to Midwest Bone & Joint Institute requesting records
SPM letter to City of Aurora requesting records
Email from SPM RE: speaking to Andrew Woods on 10/31/17
Reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records 21 pages
Reviewed Joshua M. Alpert / Midwest Bone & Joint institute Records 21 pages

11.16.17

11.16.17

11.22.17
11.22.17
11.22.17
11.22.17

11.28.17

12.4.17
12.4.17

12.11.17

12.11.17

175

176

177
178
179
180

181

182
183

184

185

173
174

172

171

170

169

10.31.17
10.31.17
10.31.17
through
11.16.17
10.31.17
through
11.16.17
11.13.17
through
11.16.17
11.13.17
through
11.16.17
11.16.17
11.16.17

167
168

SPM

MAT

MAT
SPM

MAT

MAT
SPM
MAT
SPM

SPM

MAT

MAT
SPM

SPM

MAT

SPM

MAT

MAT
SPM

0.125

0.125

0.75
0.75

3

0.5
0.5
0.5
0.5

3

3

1
1

6

6

4

4

0.5
0.5

0

0

0.75
0.75

0

0
0
0
0

0

0

0
0

6

6

0

0

0.5
0.5

Total:

$500

$500

$500
$500

$500

$500
$500
$500
$500

$500

$500

$500
$500

$500

$500

$500

$500

$500
$500

$69,825

$0

$0

$375
$375

$0

$0
$0
$0
$0

$0

$0

$0
$0

$3,000

$3,000

$0

$0

$250
$250

8 of 8

Received and reviewed Order entered granting MAT, SPM and TPMB, LLC to withdraw

Filed, prepared and served: Interrogatories and Request to Produce to Amazon;
Interrogatories and Request to Produce to Duke Realty Service; Interrogatories and
Request to Produce to Steel King
Filed, prepared and served: Interrogatories and Request to Produce to Amazon;
Interrogatories and Request to Produce to Duke Realty Service; Interrogatories and
Request to Produce to Steel King
Received and reviewed Amazon Rule 26(a)(1) disclosures
Received and reviewed Amazon Rule 26(a)(1) disclosures
Received and reviewed Amazon Fulfillment Services, Inc. and Steel King Industries
Master Purchase Agreement (315 pages)
Received and reviewed Amazon Fulfillment Services, Inc. and Steel King Industries
Master Purchase Agreement (315 pages)
Received and reviewed Steel King Rule 21(a)(1) disclosure
Received and reviewed Steel King Rule 21(a)(1) disclosure
Received and reviewed d[sic] Duke Realty Rule 21(a)(1) disclosure
Received and reviewed d[sic] Duke Realty Rule 21(a)(1) disclosure
MAT prepared for and attended the status before Judge Castillo and requested the Court to
vet the facts regarding TPMB, LLC's discharge and the Court would not hear the dispute
and allowed TPMB, LLC to withdraw and allowed Anesi Ozmon to appear and ordered
TPMB, LLC to withdraw
Prepared and filed TPMB, LLC's Motion to withdraw pursuant to Court Order
Prepared and filed TPMB, LLC's Motion to withdraw pursuant to Court Order
Received and reviewed Order entered granting MAT, SPM and TPMB, LLC to withdraw

MAT and SPM Worked on the Rule 26(a)(1) Initial Disclosure and Rule 26(a)(1)
Documents

Reviewed Richard K. Thomas, MD / Northwestern Medicine Report (3 pages)
Reviewed Richard K. Thomas, MD / Northwestern Medicine Report (3 pages)
MAT and SPM Worked on the Rule 26(a)(1) Initial Disclosure and Rule 26(a)(1)
Documents