Filed: Oct. 15, 2014
Latest Update: Oct. 15, 2014
Summary: MOTION FOR PROVE-UP AND ENTRY OF JUDGMENT ROBERT M. DOW, Jr., District Judge. NOW COMES the Plaintiff, THOMAS JONES ("Thomas"), by and through his attorneys, SULAIMAN LAW GROUP, LTD., submits this Motion for Prove-Up and Entry of Judgment pursuant to Rule 58 of the Federal Rules of Civil Procedure against the Defendant, LAW OFFICES OF PAUL D. LAWENT ("Lawent"), and in support thereof, stating as follows: 1. Thomas brought this lawsuit against Lawent for damages for Defendant's violations of t
Summary: MOTION FOR PROVE-UP AND ENTRY OF JUDGMENT ROBERT M. DOW, Jr., District Judge. NOW COMES the Plaintiff, THOMAS JONES ("Thomas"), by and through his attorneys, SULAIMAN LAW GROUP, LTD., submits this Motion for Prove-Up and Entry of Judgment pursuant to Rule 58 of the Federal Rules of Civil Procedure against the Defendant, LAW OFFICES OF PAUL D. LAWENT ("Lawent"), and in support thereof, stating as follows: 1. Thomas brought this lawsuit against Lawent for damages for Defendant's violations of th..
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MOTION FOR PROVE-UP AND ENTRY OF JUDGMENT
ROBERT M. DOW, Jr., District Judge.
NOW COMES the Plaintiff, THOMAS JONES ("Thomas"), by and through his attorneys, SULAIMAN LAW GROUP, LTD., submits this Motion for Prove-Up and Entry of Judgment pursuant to Rule 58 of the Federal Rules of Civil Procedure against the Defendant, LAW OFFICES OF PAUL D. LAWENT ("Lawent"), and in support thereof, stating as follows:
1. Thomas brought this lawsuit against Lawent for damages for Defendant's violations of the Fair Debt Collection Practices Act, 15 U.S.C. §1692, et seq. ("FDCPA"). The lawsuit seeks statutory and actual damages.
2. On October 1, 2014, this Court granted Thomas' oral motion for entry of default judgment against Lawent for failure to appear, answer or otherwise plead, and set the matter for prove-up on October 22, 2014 at 9:15 a.m.
3. Thomas seeks entry of a judgment amount against Lawent in the amount of $1,000.00 in statutory damages plus $5,238.75 in costs and reasonable attorney fees as provided under 15 U.S.C. §1692k See Affidavit of Mohammed O. Badwan, attached as Exhibit A.
WHEREFORE, Plaintiff, THOMAS JONES, prays for an entry Judgment against Defendant, LAW OFFICES OF PAUL D. LAWENT, in the amount of $1,000.00 in statutory damages and $5,238.75 in costs and reasonable attorney fees.
EXHIBIT A
AFFIDAVIT OF MOHAMMED O. BADWAN
I, Mohammed O. Badwan, have personal knowledge of the facts and information set forth herein, being first duly sworn on oath:
1. I am over the age of 21, under no legal disability, and if called and sworn as a witness in this cause, would competently testify as to the facts set forth in this Affidavit.
2. I have personal knowledge of the facts set forth in this Affidavit.
3. I graduated from law school in May 2009 and became licensed to practice law in the State of Illinois in 2009.
4. I have been practicing law for the last five (5) years.
5. Plaintiff Thomas Jones hired my firm to prosecute this lawsuit.
6. I am personally acquainted with the cause of action herein and with the legal services provided by my firm.
7. The time of Mohammed O. Badwan and all attorneys working on this matter are maintained in the following manner: at the time services are rendered, time is recorded in an accounting program within the firm's computer system and database.
8. Plaintiffs attorney ands his firm completely performed the services reflected above.
9. The services performed were necessary in order for Mohammed O. Badwan to properly represent his client.
10. The time spent performing the services were reasonable in light of the difficulty of the services performed.
11. The hourly rate for the attorney who worked on this matter is $325.00 per hour. I am familiar with the range of hourly rates charged by attorneys in and around Northern Illinois. The rate charged per hour is fair and reasonable, and within the normal standards of the community for the type of services performed based upon the level of skill, expertise and experience of the attorney who performed the legal services.
12. The total amount of fees and costs incurred by Plaintiff for purposes of the above tasks are $5,238.75.
