IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
November 16, 2011
IN RE: KENTUCKY GRILLED CHICKEN COUPON MARKETING & SALES PRACTICES LITIGATION
The opinion of the court was delivered by: Hon. James F. Holderman
DECLARATION OF CRAIG BORISON REGARDING ATTORNEYS' FEES
I, Craig Borison, the undersigned, being competent to testify, swear under penalty of perjury as provided by 28 U.S.C. § 1746 that the following facts and statements are true and correct, except as to such matters stated to be made on information and belief, and as to such matters, I certify that I believe the same to true:
1. This declaration is made in support of Plaintiffs' Motion for Final Approval of Class Action Settlement, Attorneys' Fees, and Incentive Awards in this matter.
2. I have been involved in this case, the claims in which will be resolved in whole through the instant settlement.
3. I am familiar with (i) the claims, evidence, and legal arguments involved in this settlement, (ii) the terms of the settlement, and (iii) the relevant defenses, evidence, and legal arguments to date.
4. Throughout my involvement in this matter, I did my part to litigate efficiently, without undue duplication of effort, and at minimal expense. Not being paid by the hour and being responsible for advancing all expenses, I had every incentive to avoid the unnecessary expenditure of funds and other resources.
5. I am admitted to practice law before all California state courts, the United States Central District of California and all New York state courts.
6. Between 2006 and the present I have had extensive litigation experience, including consumer claims. As a law clerk and as an attorney my experience includes a prior class action case, several multiple plaintiff matters, California unfair competition law violations, false advertising claims and Truth in Lending Act violations.
7. In this case, I met with and interviewed plaintiffs James Asanuma and Veronica Mora (the "Plaintiffs") on a number of occasions to determine the facts relating to their claims, advise them about potential claims and their duties as class representatives in class action litigation. After these initial meetings, I drafted the initial class action complaint for the Plaintiffs' review as to the facts alleged. After the filing of the complaint, I assisted the Plaintiffs in responding to the discovery requests from the Defendant. I regularly communicated with Plaintiffs with respect to the progress of the case, including meetings to finalize discovery responses and discuss the case status. In addition, I reviewed various filings in case and advised Plaintiffs, addressed their questions regarding filings and orders, reviewed settlement proposals and obtained Plaintiffs' informed consent after all of their questions were addressed.
8. As reflected in the chart below as of November 11, 2011, the total number of attorney hours spent on this matter by me was 77.5 hours. The total lodestar amount for attorney time based on my rate was $29,062.50 as of that same date. The lodestar figure is based on a professional billing rate less than what I currently charge clients, including those that pay for legal services by the hour.
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