IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
September 4, 2012
CENTRAL STATES, SOUTHEAST AND SOUTHWEST AREAS PENSION FUND; AND ARTHUR H. BUNTE, JR., AS TRUSTEE, PLAINTIFFS,
RINSP, LLC, A NEVADA LIMITED LIABILITY COMPANY, DEFENDANT.
The opinion of the court was delivered by: Judge Ruben Castillo
Magistrate Judge Arlander Keys
DECLARATION OF CHARLES H. LEE I, Charles H. Lee, having personal knowledge of the facts stated herein, hereby declare under penalty of perjury and pursuant to 28 U.S.C. § 1746 as follows:
1. I am an Associate General Counsel employed by the Central States, Southeast and Southwest Areas Pension Fund (the "Pension Fund") and am familiar with the pending litigation.
2. I have reviewed the Plaintiffs' billing records attached hereto as Exhibit 1 and have determined that the billable work performed in connection with this case was performed by myself, Emily E. Gleason, and George O. Hansen.
3. I have been employed by the Pension Fund since July of 2000. I graduated from the University of Minnesota Law School in 1996. I was admitted to the bar of the State of Minnesota on October 25, 1996, and to the bar of the State of Illinois on May 7, 1998. I am admitted to practice in the United States District Court for the Northern District of Illinois and the United States Court of Appeals for the Seventh Circuit. I am also a member of the Trial Bar of the United States District Court for the Northern District of Illinois.
4. Emily E. Gleason has been employed by the Pension Fund as an attorney since July of 2012. Ms. Gleason graduated from The John Marshall Law School in January 2009, and was admitted to the bar of the State of Illinois on May 7, 2009. She is also admitted to practice in the United States District Court for the Northern District of Illinois. Prior to being hired as an attorney for the Pension Fund, Ms. Gleason practiced for three years as an associate at the law firm Kopon Airdo, LLC.
5. George O. Hansen is a litigation paralegal employed by the Pension Fund.
6. The amount of time spent on this case by myself, Emily E. Gleason, and George O. Hansen, along with our hourly billable rates, are set forth below:
Charles H. Lee 2.7 hours x $275.00 Charles H. Lee 26.8 hours x $300.00 Emily E. Gleason 10.3 hours x $200.00 George O. Hansen 1.0 hours x $140.00
7. Based upon my experience in similar cases, I believe that the above rates are at or below the market rate charged for similar legal work and therefore, are reasonable. I also believe that the amount of time spent by each individual on this case is reasonable. On that basis, the total of legal fees incurred in this matter is $10,982.50.
8. Plaintiffs have also incurred the following costs in connection with this litigation:
Filing Fee $350.00 Service of Process 21.00 Mileage and Parking 124.63 Total $495.63
9. I believe that the aforementioned legal fees and costs were necessarily incurred and are reasonable in amount.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Charles H. Lee
Charles H. Lee
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