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Roofers' Pension Fund, et al. v. Keith A. Pinn

THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION


May 8, 2011

ROOFERS' PENSION FUND, ET AL. PLAINTIFFS,
v.
KEITH A. PINN, A SOLE PROPRIETOR D/B/A KAP ROOFING, INC., A DISSOLVED ILLINOIS CORPORATION DEFENDANT.

The opinion of the court was delivered by: Judge Kennelly

AFFIDAVIT

Librado Arreola, attorney for Plaintiffs, ROOFERS' PENSION FUND, ROOFERS' UNIONS WELFARE TRUST FUND, ROOFERS' RESERVE FUND, CHICAGOLAND ROOFERS' APPRENTICESHIP AND TRAINING FUND, ROOFERS' INDUSTRY ADVANCEMENT and RESEARCH FUND, ROOFERS' LOCAL 11 PROMOTIONAL AND ORGANIZATIONAL FUND and NATIONAL ROOFING INDUSTRY PENSION PLAN ("Funds"), on oath and duly sworn, states:

1. That I am an attorney licensed to practice in the State of Illinois, the Northern District of Illinois and a member of the Federal Trial Bar.

2. That I have in excess of 21 years experience in litigating unfair labor practice and collective bargaining matters, as well as representing trustees of Taft-Hartley employee benefit funds, including the prosecution of ERISA collection matters for the collection of delinquent employer contributions and the counseling of Taft Hartley trust funds.

EXHIBIT B 1

3. That the Collective Bargaining Agreement and the Trust Agreements under which this action is based, provide for the payment of interest, liquidated damages, audit fees and attorney fees and costs incurred for failure of a signatory contractor to pay contributions in accordance with those Agreements.

4. That I represent the Plaintiffs Trust Funds, and my billing rate to Plaintiff Funds is $200.00 per hour.

5. That I have billed the Plaintiff Funds a total of 22 hours at the rate of $200.00 per hour, or $4,400, for legal services in the instant matter.

6. That court costs in the amount of $350.00 and that costs for service of process and other costs in the amount of $110 have been incurred by Plaintiffs.

7. That the total cost to the Funds for legal fees and costs amount to $4,860. Further, Affiant sayeth not.

In accordance with 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true and correct.

s/Librado Arreola

LIBRADO ARREOLA

EXHIBIT B 2

20110508

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