IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
October 31, 2011
JAMES T. SULLIVAN, NOT INDIVIDUALLY BUT AS TRUSTEE OF PLUMBERS' PENSION FUND, LOCAL 130, U.A., ETC., PLAINTIFF,
BROADWAY CONSTRUCTION SERVICES, INC., DEFENDANT.
The opinion of the court was delivered by: Judge Edmond E. Chang
Magistrate Judge Michael T. Mason
AFFIDAVIT OF JOHN W. LOSEMAN State of Illinois County of Cook
John W. Loseman hereby deposes and states:
1. I am of adult age and otherwise competent to make this Affidavit. All statements herein are made on my personal knowledge.
2. I am an attorney licensed to practice, inter alia, within the State of Illinois and before the United States District Court for the Northern District of Illinois. I am responsible for representing Plaintiff, James T. Sullivan, not individually but as Trustee of Plumbers' Pension Fund, Local 130, U.A., etc. ("Funds"), in this action.
3. I am a partner in the law firm of ROETZEL & ANDRESS, LPA, formerly LEWIS, OVERBECK & FURMAN, LLP ("Firm"), 20 N. Clark Street, Suite 3200, Chicago, Illinois. All attorneys and paralegals who represented Funds in this action were partners in, associated with, or employed by, Firm.
4. In the course of their representation of Funds, the attorneys and paralegals of Firm made contemporaneous daily time entries. Attached as Exhibit B.2 are true and correct (redacted) copies of the daily time entries itemizing the time actually spent by attorneys and paralegals of Firm in the course of this matter through September 30, 2011, along with certain costs paid for the account of Funds herein through that date, for which Funds seek reimbursement.
5. Throughout this case, Firm has charged its normal and customary hourly charges for legal services rendered to Funds in this action. Firm's normal and customary hourly charges are reasonable within the Chicago area legal community, and are paid by other clients of Firm.
6. "DAL" in Firm's time entries designates attorney Douglas A. Lindsay, a partner in Firm. DAL has been licensed to practice law in the State of Illinois since 1976, and is a member of the U.S. Supreme Court, the U.S. Court of Appeals for the Seventh Circuit, and the U.S. District Courts for the N.D. Illinois, C.D. Illinois, E.D. Wisconsin, and N.D. Indiana. DAL has extensive experience in ERISA and LMRA matters, including enforcement of contribution rights under collective bargaining agreements. DAL provided 6.9 hours of legal services to Local 130 Funds at the rate of $300.00 per hour, for a total of $2,070.00.
7. "JWL" in Firm's time entries designates attorney John W. Loseman, a partner in Firm. JWL has been licensed to practice law in the State of Illinois since 1989, and is a member of the U.S. Supreme Court, the U.S. Court of Appeals for the Seventh Circuit, and the U.S. District Courts for the N.D. Illinois, C.D. Illinois, and N.D. Indiana. JWL has extensive experience in ERISA and LMRA matters, including enforcement of contribution rights under collective bargaining agreements. In the course of this matter, JWL provided 11.7 hours of legal services to Funds at the rate of $255.00 per hour, for a total of $2,983.50.
8. "BTB" in the time entries designates attorney Brian T. Bedinghaus, an associate of Firm. BTB has been licensed to practice law in the State of Illinois since 2005, and is a member of the U.S. District Court for the Northern District of Illinois. In the course of this matter, BTB provided 2.3 hours of legal services to Funds at the rate of $170.00 per hour, for a total of $391.00.
9. "RCP" in the time entries designates Robert C. Parizek, a paralegal employed by Firm. In the course of this matter, RCP provided 3.6 hours of services to Funds at the rate of $85.00 per hour, for a total of $306.00.
10. In addition to attorneys' and paralegals' fees, Funds incurred charges for the following: $350.00 for federal filing fee; $60.00 for service of process fees; $60.00 for electronic docket fees; $3.68 for computerized Pacer charges; and $59.50 for postage costs and photocopy expenses, for a total of $533.18. Each of these charges was incurred in connection with this case, and is not a usual office overhead expense. These charges are billed separately by Firm to its clients.
11. The sum of the above-described fees is $5,750.50 and the sum of the above-described costs and expenses is $533.18 for a total of $6,283.68.
In accordance with 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true and correct.
/s/ John W. Loseman
John W. Loseman 20 N. Clark Street, Suite 3200 Chicago, IL 60602-5093 312.580.1258
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