PLAINTIFF'S FEE PETITION FOR JUDGMENT OF APPELLATE AND POST-TRIAL ATTORNEY FEES
HARRY D. LEINENWEBER, District Judge.
Plaintiff, Kenneth Baker, by and through his attorneys, Irene K. Dymkar, Torreya L. Hamilton, Daniel H. Regenscheit, and Shamoyita M. DasGupta, hereby petitions the Court for an order granting appellate and post-trial attorneys' fees in the amount of $130,501.50, and submits the following memorandum in support thereof:
I. Introduction
This matter proceeded to jury trial and judgment was entered on October 24, 2014. Doc. 216. Plaintiffs filed a petition for attorneys' fees and costs, and the Court rendered its memorandum opinion and order on April 24, 2015. Doc. 250. Plaintiffs appealed said decision on attorneys' fees and costs in a case entitled Baker v. Ghidotti, Seventh Circuit 15-2203, and the Seventh Circuit rendered its decision on June 1, 2017, remanding the case back to the district court for further proceedings. Doc. 275 (certified copy of opinion).
II. Agreed judgment for trial attorney fees
Plaintiffs made all the necessary calculations and negotiated with defense counsel an agreed judgment that includes the district court's original fee judgment, the additional fees awarded by the Seventh Circuit, and interest. The parties filed a joint stipulation (Doc. 279), and the Court signed the parties' proposed agreed order of judgment for trial attorney fees in the amount of $184,033.25. Doc. 283.
III. Fee petition for appellate and post-trial attorney fees
The law in this Circuit is very clear that when a party prevails in a civil rights appeal as plaintiff did here, the prevailing attorneys are entitled to recover their reasonable lodestar for the services they provided. Plaintiff therefore asks the Court to award the lodestar of $130,501.50, as computed herein.
A. Legal standard for adjudicating plaintiff's' fee petition for appellate and post-trial legal work
Courts in this district have acknowledged that "[a]s tempting as it may be to say, `enough already'" to fee petitions, a plaintiffs' successful appeal encourages attorneys to pursue valid civil rights cases. Pickett v. Sheridan, 07 C 17222, Doc. 240 at 6 (N.D. Ill. Nov. 13, 2014) (Shah, J.).
Even in cases of mixed judgment "plaintiffs may be considered prevailing parties for attorney's fees purposes if they succeed on any significant issue in litigation which achieves some of the benefit the parties sought in bringing suit." Thorncreek Apartments I, LLC v. Vill. of Park Forest, 123 F.Supp.3d 1012, 1017 (N.D. Ill. 2015) (Feinerman, J.), quoting Family PAC v. Ferguson, 745 F.3d 1261, 1268 (9th Cir. 2014); see Wells v. City of Chicago, 925 F.Supp.2d 1036, 1050 (N.D. Ill. 2013) (Kennelly, J.) (awarding plaintiff attorneys' fees in "mixed result" appellate decision).
The amount of the fee award is calculated by multiplying reasonable hours times hourly rate. Hensley v. Eckerhart, 461 U.S. 424, 433 (1983). The lodestar is presumptively an appropriate measure of the fee award. Blum v. Stenson, 465 U.S. 886, 897 (1984). As the Supreme Court has clarified, this "strong presumption that the lodestar figure. . . represents a reasonable fee is wholly consistent with the rationale behind [§1988]." Blanchard v. Bergeron, 489 U.S. 87, 95 (1989).
B. Negotiations about appellate and post-trial attorneys' fees have not been successful
Plaintiff presented a demand of $113,000 based on an initial cursory estimate of appellate and post-trial attorneys' fees for attorneys Irene K. Dymkar, Torreya L. Hamilton, Shamoyita M. DasGupta, and Daniel H. Regenscheit. In a good faith effort to settle this matter, plaintiff reduced the demand to $100,000, and then to $85,000, and said they would consider a further reduction, just to settle the matter. Defendants nevertheless offered only a minimal $9,040.00, which they increased to $15,000,00, before they refused to negotiate any further. Defendants unreasonably maintain that plaintiff's attorney fees should be reduced by 92% of the original demand.
On appeal, defendants hotly contested every calculation, even the mistake made by the Court in the double deduction of fees attributable to work with regard to the Reliable Recovery claims. At oral argument, Justice Rovner, who appeared by video conferencing, was exasperated. See http://media.ca7.uscourts.gov/sound/2016/gw.15-2203.15-2203_12_05_2016.mp3. At 11:23 on the video, Justice Rovner asked the City appellate attorney point blank whether he would concede that a mistake had been made in the double deduction of hours. The City appellate attorney danced around the issue, saying that maybe the district court had some other reason to take off the hours. At 12:35 on the video, Justice Rovner once again asked the City appellate attorney point blank whether he would concede that a mistake was made in the double deduction of hours. When he had no choice but to admit to the miscalculation, the City attorney finally did so, and Justice Rovner audibly gasped in frustration. The audio then cuts out as she is saying "Then why did you . . ." and when the attorney told Justice Rovner that the audio had cut out, she said, "It's probably good that I cut out because I'm just so . . .[audio cuts out again]." At 14:27, the City attorney apologized to Justice Rovner for sounding like he was "trying to equivocate."
Justice Rovner likewise at 14:44 expressed frustration at the City's position regarding the bill of costs. "I am troubled that defendants recovered all of their costs, given that you did lose some of the claims." The Court ultimately ruled that the district court did not abuse its discretion in awarding defendants their entire bill of costs and denying plaintiffs their entire bill of costs. Regardless of the final decision of the Court, when one listens to the entire oral argument, many of the court's questions were favorable to plaintiff. This was not a frivolous appeal by any means, but one which the Court took seriously.
Unfortunately, the parties cannot disclose the substance of the protracted negotiations with the mandatory Seventh Circuit Rule 33 settlement conference mediator prior to the filing of the briefs on appeal. Pursuant to the Court's rules:
The Court requires all participants to keep what is said in these conferences strictly confidential. Communications, oral and written, which take place in the course of Rule 33 proceedings may not be disclosed to anyone other than the litigants, their counsel, and the conference attorney.
Suffice it to say that the settlement conference was a missed opportunity to settle this case without having to brief and argue the appeal.
This Court noted in its 2012 decision in Gilfand v. Planey, 2012 WL 5845530 *16-17 (N.D.Ill. Nov. 19, 2012) that the willingness to engage in reasonable settlement negotiations is an important factor, in that an early settlement keeps litigation from being unduly prolonged and saves court and attorney resources. See Heder v. City of Two Rivers, 255 F.Supp.2d 947, 956 (E.D.Wis.2003) (awarding full lodestar because plaintiff offered to settle on reasonable terms; court concluded: "the City has only itself to blame for the disproportionality between the attorneys' fees incurred and the amount Heder recovered . . . and [plaintiffs should not] be forced to swallow expenses incurred largely as a result of the City's approach to this litigation.");
Negotiations about appellate and post-trial attorneys' fees have not been successful Defendants are being unreasonable in asking plaintiff to settle the attorneys' fees for 8% of the original fee demand. Plaintiff should be granted the lodestar.
C. Plaintiff's lodestar is justified and should be granted
Plaintiff is requesting fees calculated as follows:
Irene K. Dymkar 240.2 hours $465/hour $ 111,693.00
Torreya L. Hamilton 25.1 hours $465/hour $ 11,671.50
Daniel H. Regenscheit 16.8 hours $125/hour $ 2,100.00
(Prior to bar admission)
6.7 hours $230/hour $ 1,541.00
(Post bar admission)
Shamoyita M. DasGupta 15.2 hours $230/hour $ 3,496.00
TOTAL FEES $ 130,501.50
The lodestar is computed by multiplying reasonable attorneys' rates per hour by the reasonable number of hours expended.
i. Plaintiff's attorney's reasonable rates have been set by Court decision
This Court set Irene K. Dymkar's hourly rate at $425. Doc. 250. Since that time, two Courts have set her hourly rate at $465. See Nelson v. Lis, 09 C 883 (Doc. 244 — Opinion March 28, 2017), Pallmeyer, J.; Wilson v. Baptiste, 13 C 7845 (Doc 286 — Order issued July 13, 2017), Shah, J. Of note, the Nelson case involved a case plaintiff lost at trial, but won on appeal. The attorneys' fees award included both trial work commencing in 2009 and appellate work concluding in 2016. Ms. Dymkar asks the Court to apply the $465 hourly rate for work from January 27, 2015, to the present.
This Court set Torreya L. Hamilton's hourly rate at $450. Doc. 250. Since that time, a Court has set her hourly rate at $465. See Bellamy v. Watkins, 15 C 2678 (Doc. 192 — Opinion August 25, 2017), Chang, J. Ms. Hamilton asks the Court to apply the $465 hourly rate.
Two Courts have set Daniel H. Regenscheit and Shamoyita DasGupta's hourly rate at $230. See Nelson (Doc 244), Wilson (Doc 286). Their biographical affidavits are attached as Exhibits A and B respectively. Mr. Regenscheit and Ms DasGupta ask the Court to award them the $230 hourly rate for their attorney time. It must be noted that some of the work performed by Mr. Regenscheit took place prior to his admission to the bar, so for that clearly delineated time, plaintiff is asking for the paralegal rate previously set by the Court, that is, $125/hour.
ii. The hours expended in this case are reasonable and should be approved
Attached are the time and work records for Irene K. Dymkar, totaling 240.2 hours (Exhibit C), for attorney Torreya L. Hamilton, totaling 25.1 hours (Exhibit D), for attorney Daniel H. Regenscheit, totaling 23.5 hours (Exhibit E), and for attorney Shamoyita M. DasGupta, totaling 15.2 hours (Exhibit F).
Ms. Dymkar's hours encompass all post-trial work, including protracted settlement negotiations with the Seventh Circuit, drafting the opening and reply briefs, oral argument, and fee petition issues.
Plaintiff's attorneys' practice is to keep track of time spent on legal work contemporaneously with the work performed. Thus, the time sheets submitted are not reconstructions of what the time might have been for the work performed; it is the actual time. It is also the practice of plaintiff's attorneys to keep track of time spent on legal work in 1/10's of an hour, that is, in 6-minute increments, even though it appears to be the standard practice in this community for attorneys to keep track of time in 1/4 hours. The practice of using 1/10-hour increments enhances the accuracy of the time reporting and eliminates the "rounding-up" that inevitably occurs when the lowest increment of time is 1/4 hour, or 15 minutes.
The hours expended in this case by plaintiff's counsel are reasonable and should be approved by the Court.
VIII. Conclusion
Plaintiff, Kenneth Baker, respectfully requests that the Court grant his attorneys' fees petition and award in full the lodestar of $130,501.50, as set forth herein.
DECLARATION OF DANIEL H. REGENSCHEIT
Pursuant to 28 U.S.C. § 1746, I, DANIEL H. REGENSCHEIT, declare as follows:
1. I am an attorney licensed to practice law in the State of Illinois, and I am a member of the General Bar of the Northern District of Illinois.
2. I graduated magna cum laude from Loyola University Chicago School of Law in May 2016. I graduated cum laude from the University of South Carolina in 2006 with a bachelor's degree in Political Science.
3. I was admitted to the bar of the State of Illinois on November 10, 2016.
4. While attending law school, I was a staff member and senior editor on the Law Journal. I graduated ranked in the top 10% of my class. I earned a CALI award for having the highest grade in my Civil Rights class. I was inducted into Alpha Sigma Nu, a Jesuit honors society for select students ranked in the top 15% of their class. I was on the Dean's List all six semesters. I received a certificate in trial advocacy. In 2015, I was on the board of the Chicago chapter of the National Lawyers Guild as the student representative.
5. While attending law school, I was an extern for Magistrate Judge Young B. Kim in the Northern District of Illinois in the spring of 2015. I drafted settlement recommendations and assisted in drafting judicial opinions. I was an extern for Hon. Ann Claire Williams of the United States Court of Appeals for the Seventh Circuit in the fall of 2015. I drafted bench memos and assisted in drafting judicial opinions.
6. In the summer of 2014, I clerked for the People's Law Office. I performed research, drafted motions and memoranda, and assisted in deposition preparation and discovery review in federal civil rights cases involving police misconduct and prosecutorial misconduct.
7. In the summer of 2015, I clerked for Loevy and Loevy. I drafted dispositive briefs, complaints, and trial memos for federal civil rights cases involving police misconduct and prisoner abuse.
8. In the spring of 2015, I volunteered with the Felony Trial Division of the Office of the Cook County Public Defender, licensed under Illinois Supreme Court Rule 711 to represent clients under the supervision of a licensed attorney. I advised clients and represented clients before the court during initial appearances, guilty pleas and sentencing, status hearings, violation of probation hearings, and 402 conferences.
9. In the spring of 2016, I volunteered with the Illinois Office of the State Appellate Defender. I drafted opening and reply briefs in state criminal appellate proceedings for convicted indigent individuals.
10. From 2013-2014, I volunteered with Cabrini Green Legal Aid, providing criminal records expungement and sealing assistance to homeless and impoverished individuals. In 2013, I volunteered with the Chicago Battered Women's Network as a court observer, documenting proceedings at the domestic violence court.
11. I began working for the Law Offices of Irene K. Dymkar in January 2016 as a law clerk. Upon my admission to the bar in November 2016, I began working as an attorney. I have worked extensively in the field of federal civil rights and police misconduct litigation as a law clerk and attorney. I helped draft numerous motions and briefs, including summary judgment, motions to dismiss, and judgment as a matter of law. I have assisted with exhibit presentation at trial. I have worked on civil rights appeals in federal court. I have appeared as an attorney in 13 civil rights cases in federal district court.
12. My billing rate is $230.00 per hour. I believe this rate to be commensurate with other attorneys in Chicago who have my level of skill and experience.
13. The attached billing records fairly and accurately state the time that I spent working on this case, and they are also reasonable in terms of the time I spent on each task.
Pursuant to U.S.C. § 1746, I declare under penalty of perjury that the foregoing declaration is true and correct to the best of my knowledge.
/s Daniel H. Regenscheit
________________________
Daniel H. Regenscheit
Attorney
The Law Offices of Irene K. Dymkar
53 W. Jackson Blvd., Suite 733
Chicago, IL 60604
312-345-0123
DECLARATION OF SHAMOYITA M. DASGUPTA Pursuant to 28 U.S.C. § 1746, I, SHAMOYITA M. DASGUPTA, declare as follows:
1. I am an attorney licensed to practice law in the State of Illinois. I have been an attorney since November 2015, and am admitted to practice in Illinois and before the Northern District of Illinois.
2. I graduated from the University of Texas in 2011 with a bachelor's degree in Journalism. I graduated from Loyola University Chicago School of Law in 2015.
3. While attending law school, I clerked in the Office of the Honorable Paul P. Biebel Jr., Condon & Cook, LLC, and the Hamilton Law Office, LLC. In addition, from 2014 to 2015, I was licensed under Illinois Supreme Court Rule 711 to represent clients of the Office of the Cook County Public Defender in court under the supervision of a licensed attorney. With my 711 license, I represented low-income defendants in criminal cases who were unable to afford a private criminal defense attorney. On numerous occasions, I was able to obtain favorable dispositions for the clients I was representing. From 2014-2015, I was a student member of the Life After Innocence Clinic, where I worked with the wrongfully convicted after they had been released from incarceration to help provide them with legal and social services. From 2014-2015, I also worked with Dean David Yellen in his appointment as Special Master to review remaining claims of police misconduct by former Chicago Police Commander Jon Burge.
4. When I graduated from law school in 2015, I began working for the Law Office of Tony Thedford, P.C., where I worked for approximately six months, and the Law Offices of Irene K. Dymkar, where I am currently working full-time, as an attorney.
5. While at the Law Office of Tony Thedford, P.C., I worked extensively in the fields of criminal defense and federal civil rights litigation. I have worked on a number of criminal cases both in the Northern District of Illinois and in Cook County. As part of my work in the criminal defense arena, I drafted numerous motions and briefs. I appeared in and worked on two criminal cases pending in the Northern District of Illinois and 10-20 criminal cases pending in Cook County. As an attorney with the Law Office of Tony Thedford, P.C., I worked on four federal civil rights cases in the Northern District of Illinois, and as part of this work, I drafted numerous responses to and requests for written discovery.
6. At the Law Offices of Irene K. Dymkar, I have worked extensively in the field of federal civil rights litigation. I have worked on a number of civil rights cases in the Northern District of Illinois and in Cook County. As part of my work in the civil arena with this office, I have helped draft complaints, motions, briefs, and responses to and requests for written discovery documents. To date, I have worked on eighteen federal civil rights cases pending in the Northern District of Illinois and one civil rights case in state court, which involves a police shooting death. I currently have appearances filed in nine federal civil rights cases pending before the Northern District of Illinois.
7. My billing rate is $230.00 per hour. I believe this rate to be commensurate with other attorneys in Chicago who have my level of skill and experience.
8. The attached billing records fairly and accurately state the time that I spent working on this case, and they are also reasonable in terms of the time I spent on each task. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing declaration is true and correct to the best of my knowledge.
/s/Shamoyita M. DasGupta
___________________________
Shamoyita M. DasGupta
Law Offices of Irene K. Dymkar
53 West Jackson Boulevard, Suite 733
Chicago, IL 60604
(312) 345-0123
Irene K. Dymkar 53 West Jackson, Suite 733 Chicago, IL 60604-3462 (312) 345-0123
ATTORNEY SERVICES (Irene K. Dymkar)
Baker, et al. v. Ghidotti, et al, 11 C 4197, 15-2203 (Seventh Circuit)
Time
expended
Date Service provided (in hours)
1/27/2015 Review defendants' Motion to Strike 0.3
1/28/2015 Court, including travel, and review Order 0.8
1/28/2015 Conference with Attorney Torreya Hamilton 0.4
1/28/2015 Review e-mail from Attorney Caroline Fronczak (2) 0.2
1/28/2015 Review e-mail from Torreya Hamilton (4) 0.2
1/28/2015 E-mail to Attorney Caroline Fronczak 0.1
1/28/2015 E-mail to Attorney Torreya Hamilton (3) 0.1
1/29/2015 Review e-mail from Attorney Caroline Fronczak (2) 0.2
1/29/2015 E-mail to Attorney Torreya Hamilton 0.1
1/29/2015 Review e-mail from Torreya Hamilton 0.1
1/29/2015 Review e-mail from Attorney K. Acuff 0.1
2/17/2015 Draft Joint Statement 0.8
2/17/2015 Conference with Attorney Torreya Hamilton 0.2
2/17/2015 E-mail to defense attorneys 0.1
2/19/2015 Review e-mail from defense attorneys 0.1
2/20/2015 Review defendants' Motion to Reset 0.1
2/21/2015 E-mail to defense attorneys (3) 0.3
2/21/2015 Review e-mail from Attorney Caroline Fronczak 0.1
2/21/2015 Review e-mail from Attorney R. McCoy 0.1
2/23/2015 Review e-mail from defense attorneys 0.1
2/24/2015 Conference with Attorney Torreya Hamilton 0.2
2/24/2015 Court, including travel, and review order 0.9
3/2/2015 Draft revised Joint Statement 1.4
3/3/2015 E-mail to defense attorneys 0.1
3/3/2015 Review e-mail from defense attorneys 0.1
3/3/2015 Draft revised Joint Statement 0.2
3/16/2015 Telephone conference with Attorney Torreya Hamilton 0.3
3/16/2015 E-mail to Attorney Torreya Hamilton 0.1
3/16/2015 Review e-mail from Attorney K. Acuff (2) 0.2
3/16/2015 Review e-mail from Attorney Torreya Hamilton (3) 0.3
3/16/2015 E-mail to Court Deputy (2) 0.2
3/16/2015 Review e-mail from Court Deputy 0.1
3/17/2015 Review e-mail from Attorney Caroline Fronczak (2) 0.2
3/17/2015 E-mail to Attorney Caroline Fronczak (2) 0.2
3/17/2015 Review defendants' Statement of Differences 0.2
3/17/2015 E-mail to Attorney Torreya Hamilton 0.2
3/27/2015 Review defendants' Response to Fee Petition 0.5
3/30/2015 Conference with Attorney Torreya Hamilton 0.2
4/6/2015 Legal research on fee issues presented by defendants 1.6
4/6/2015 Draft Reply to Response 4.4
4/6/2015 Telephone conference with Attorney Torreya Hamilton 0.2
4/7/2015 Conference with client 0.4
4/7/2015 Draft Declaration and Receipt 0.5
4/13/2015 Review Court order 0.1
4/20/2015 Draft Supplement to Motion 0.5
4/23/2015 Review defendants' Response to Supp to Motion 0.3
4/24/2015 Review Court's Memorandum Order and Opinion 2.3
5/4/2015 Conference with Attorney Torreya Hamilton 0.3
5/20/2015 Review Memorandum Opinion and Order 1.2
5/20/2015 Draft Motion to Reconsider 3.3
5/20/2015 Legal research on issues presented by Opinion and Order 2.7
5/21/2015 Draft Motion to Reconsider 5.6
5/21/2015 Legal research on issues presented by Opinion and Order 0.9
5/22/2015 Draft Motion to Reconsider 5.3
5/22/2015 Draft Notice of Motion 0.1
5/22/2015 Legal research on issues presented by Opinion and Order 2.3
5/22/2015 Draft Motion for Leave to File Extra Pages 0.4
5/22/2015 Draft Notice of Motion 0.1
5/27/2015 Court, including travel, and review Order 0.8
6/1/2015 Conference with Attorney Torreya Hamilton 0.3
6/2/2015 Draft Notice of Appeal 0.7
6/2/2015 Draft Docketing Statement 0.7
6/3/2015 Letter to 7th Circuit Settlement Conf. 0.3
6/3/2015 Telephone conf. with District Ct. Clerk 0.2
6/4/2015 E-mail to 7th Circuit Settlement Conf. to set date 0.2
6/4/2015 Review 7th Circuit Court Order re jurisdictional issues 0.2
6/8/2015 Draft Jurisdictional Statement 0.5
6/8/2015 Review e-mail from Mediator Joel Shapiro, 7th Circuit 0.1
6/8/2015 Review Court Orders (2) 0.2
6/9/2015 Telephone conf. with Attorney Ruth McCoy 0.0
6/9/2015 Review Bill of Costs 0.1
6/1/2015 Conference with Attorney Torreya Hamilton 0.2
6/16/2015 Review Court Orders (2) re settlement conf and briefing schedule 0.1
6/25/2015 Telephone conf. with 7th Circuit Settlement Conf. Ofc.(Stephanie) 0.1
7/2/2015 Review 7th Circuit Court Order 0.1
7/28/2015 Review e-mail from Attorney Ruth McCoy 0.0
8/20/2015 Review 7th Circuit Court Order 0.1
9/2/2015 Telephone conf. with Attorney Torreya Hamilton 0.2
9/2/2015 E-mail to Attorney Torreya Hamilton 0.1
9/3/2015 Prepare for Settlement Conf., develop strategy, review fee calculations 1.5
9/3/2015 Conference with Attorney Torreya Hamilton 0.6
9/3/2015 Settlement Conf., including travel 2.4
9/4/2015 Review Court Order suspending briefing 0.1
9/29/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.6
10/9/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.5
10/9/2015 E-mail to Attorney Torreya Hamilton 0.1
10/9/2015 Telephone conf. with Attorney Torreya Hamilton 0.2
10/15/2015 E-mail to Mediator Joel Shapiro, 7th Circuit 0.1
10/28/2015 Legal research of pertinent case law on potential issues on appeal 2.1
10/28/2015 Review file 0.9
10/28/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.3
11/2/2015 Review e-mail from Attorney Ruth McCoy 0.0
11/2/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.4
12/1/2015 Telephone conf. with Attorney Torreya Hamilton 0.3
12/4/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.1
12/14/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.1
12/18/2015 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.4
1/19/2016 Conference with Attorney Torreya Hamilton 0.3
1/27/2016 Review fee calculations to prepare for conf. with Mediator 0.8
1/27/2016 Telephone conf. with Mediator Joel Shapiro, 7th Circuit 0.2
1/28/2016 Review 7th Circuit Court Order 0.1
2/22/2016 Draft Motion Extend Time to File Brief 0.5
2/23/2016 Review 7th Circuit Court Order 0.1
3/1/2016 Legal research of pertinent case law on potential issues on appeal 0.7
3/23/2016 Draft Motion Extend Time to File Brief 0.4
3/23/2016 Review Court Order 0.1
4/22/2016 Draft Motion Extend Time to File Brief 0.6
4/25/2016 Review 7th Circuit Court Order 0.1
5/16/2016 Prepare and file change of address 0.1
5/17/2016 Review Fee Petition, Response to Fee Petition, Reply 2.3
5/18/2016 Legal research of pertinent case law on potential issues on appeal 3.1
5/18/2016 Draft brief, statement of facts and legal argument 9.4
5/19/2016 Draft Motion Extend Time to File Brief 0.9
5/19/2016 Review Release 0.3
5/19/2016 Letter to Attorney Ruth McCoy 0.0
5/19/2016 Draft brief, statement of facts and legal argument 7.6
5/19/2016 Legal research of pertinent case law on potential issues on appeal 3.4
5/20/2016 Conference with 7th Circuit Court Clerk 0.2
5/20/2016 Review 7th Circuit Court Order 0.1
6/11/2016 Legal research of pertinent case law on potential issues on appeal 0.7
6/11/2016 Draft Brief, legal argument 0.7
6/13/2016 Legal research of pertinent case law on potential issues on appeal 2.1
6/13/2016 Draft Brief, legal argument 2.9
6/14/2016 Legal research of pertinent case law on potential issues on appeal 3.3
6/14/2016 Draft Brief, legal argument 3.7
6/15/2016 Legal research of pertinent case law on potential issues on appeal 2.7
6/15/2016 Draft Brief, legal argument 2.4
6/16/2016 Legal research of pertinent case law on potential issues on appeal 2.9
6/16/2016 Draft Brief, legal argument 7.3
6/17/2016 Legal research of pertinent case law on potential issues on appeal 4.1
6/17/2016 Draft Brief 7.2
6/17/2016 Revise Appendix 0.8
6/18/2016 Legal research of pertinent case law on potential issues on appeal 3.7
6/18/2016 Draft Brief 5.1
6/20/2016 Draft Brief 1.5
6/21/2016 Telephone conf. with Mediator Joel Shapiro 7th Cir 0.3
6/21/2016 Draft Brief 2.9
6/21/2016 Telephone conf. with 7th Circuit Court Clerk 0.2
6/21/2016 Legal research of pertinent case law on potential issues on appeal 1.1
6/24/2016 Conference with Attorney Kevin Turckan 0.2
6/24/2016 E-mail to Attorney Torreya Hamilton 0.1
6/27/2016 Draft Motion Voluntary Dismissal 0.3
6/27/2016 E-mail defense attorney Ruth McCoy 0.0
6/28/2016 Review 7th Circuit Court Order 0.1
7/6/2016 Review 7th Circuit Order of Dismissal 0.1
7/14/2016 Review Defendants' Motion to Extend Time to File Brief 0.1
7/14/2016 E-mail to Attorney Jonathon Byrer 0.1
7/14/2016 Review 7th Circuit Court Order 0.1
8/15/2016 Review Defendants' Motion to Extend Time to File Brief 0.1
8/15/2016 Review 7th Circuit Court Order 0.1
9/22/2016 Review Response Brief 1.7
9/22/2016 Draft Letter of Availability after review of other litigation commitments 1.1
9/23/2016 Review defendants' Letter of Availability 0.1
9/24/2016 Draft Motion Extend Time to File Brief 0.7
9/26/2016 Review 7th Circuit Court Order 0.1
9/30/2016 Review 7th Circuit Court Orders (3) transmitting record 0.1
10/20/2016 Review Response Brief 1.6
10/22/2016 Legal research case law and issues presented by defendants 3.3
10/22/2016 Draft Reply Brief 4.7
10/23/2016 Legal research case law and issues presented by defendants 1.8
10/23/2016 Draft Reply Brief 3.2
10/24/2016 Legal research case law and issues presented by defendants 2.0
10/24/2016 Draft Reply Brief 7.3
10/25/2016 Legal research case law and issues presented by defendants 2.3
10/25/2016 Draft Reply Brief 9.7
10/26/2016 Legal research case law and issues presented by defendants 5.4
10/26/2016 Draft Reply Brief 1.2
10/26/2016 Review 7th Circuit Court Order re argument 0.1
10/26/2016 Review defendants' Argument Confirmation 0.1
10/27/2016 Review 7th Circuit Court Order 0.1
11/28/2016 Draft Argument Confirmation 0.1
12/3/2016 Legal research, including updating cited case law 1.1
12/3/2016 Prepare for Oral Argument 4.7
12/4/2016 Prepare for Oral Argument 6.6
12/4/2016 Legal research, reread seminal cases 1.9
12/5/2016 Prepare for Oral Argument 2.0
12/5/2016 Oral Argument, including travel 2.8
12/5/2016 Conference with Attorney Torreya Hamilton 0.2
12/5/2016 Review e-mail from Attorney Torreya Hamilton 0.1
12/6/2016 Draft Rule 28 letter to Court 0.8
12/7/2016 Draft Rule 28 letter to Court 0.4
12/7/2016 Review defendants' Rule 28j letter 0.3
12/7/2016 E-mail to Attorney Torreya Hamilton 0.1
5/10/2017 Review 7th Circuit Decision 2.1
Conference with Attorneys Regenscheit and DasGupta regarding fee
5/17/2017 petition 0.4
6/2/2017 E-mail to Attorney Caroline Fronczak 0.1
6/2/2017 Review of timesheets and compute two judgments 1.3
6/30/2017 Draft Motion to Set Briefing Schedule 0.9
6/30/2017 Draft Notice of Motion 0.1
7/12/2017 Telephone conf with Attorney Caroline Fronczak (left message) 0.1
7/12/2017 Compute two judgments, attorneys' fees, interest 0.7
Court, including travel, conference with Attorney Caroline Fronczak and
7/13/2017 review Order 1.0
7/26/2017 E-mail to Attorney Caroline Fronczak 0.1
7/26/2017 Compute two judgments, attorneys' fees, interest 1.1
7/28/2017 Review e-mail from Attorney Caroline Fronczak (2) 0.2
7/28/2017 E-mail to Attorney Caroline Fronczak 0.1
8/1/2017 Draft Stipulation 0.8
8/1/2017 Draft Proposed Order 0.6
8/1/2017 E-mail to Attorney Caroline Fronczak 0.1
8/1/2017 Telephone conf with Attorney Caroline Fronczak (left message) 0.1
8/2/2017 Review revisions to Stipulation 0.2
8/2/2017 Review revisions to Order 0.2
8/2/2017 E-mail to Attorney Caroline Fronczak 0.1
8/4/2017 Revise Stipulation 0.3
8/4/2017 Revise Order of Judgment 0.2
8/4/2017 E-mail to Attorney Caroline Fronczak 0.2
8/4/2017 E-mail to Attorney Torreya Hamilton 0.2
8/7/2017 E-mail to Attorney Caroline Fronczak (2) 0.3
8/7/2017 Review e-mail from Attorney Caroline Fronczak 0.1
8/8/2017 Telephone conference with Attorney Torreya Hamilton 0.3
8/9/2017 Conference with Attorney Torreya Hamilton 0.3
E-mail to Attorney Caroline Fronczak with Brief and oral argument
8/9/2017 excerpt 0.4
8/9/2017 Review e-mail from Attorney Caroline Fronczak 0.1
8/10/2017 Conference with Attorney Torreya Hamilton 0.4
8/11/2017 Revise Stipulation 0.3
8/11/2017 Revise Order of Judgment 0.3
8/11/2017 Review timesheets for completeness and accuracy 0.6
8/14/2017 Review e-mail from Attorney Caroline Fronczak 0.1
8/14/2017 E-mail to Attorney Caroline Fronczak 0.1
8/14/2017 Review Stipulation filed by defendants 0.1
8/14/2017 Review Order sent to Court by defendants 0.1
8/14/2017 Review timesheets for completeness and accuracy 0.7
8/15/2017 Legal research re judgment and fee petition issues 0.4
8/15/2017 Draft Motion for Judgment and for Fee Petition Ext. 1.1
8/15/2017 Draft Notice of Motion 0.1
8/15/2017 Conference with Attorney Torreya Hamilton 0.5
8/17/2017 Conference with Attorney Torreya Hamilton 0.2
8/17/2017 Review e-mail from Attorney Torreya Hamilton 0.2
8/29/2017 Draft Fee Petition 2.2
8/29/2017 Legal research appellate fee petition issues 1.5
8/29/2017 E-mail to Attorney Torreya Hamilton (2) 0.2
8/29/2017 Draft Motion to Extend Time to File Fee Petition 0.5
8/29/2017 Draft Notice of Motion 0.1
9/1/2017 Review Court Order 0.1
9/3/2017 Review timesheets for completeness and accuracy 1.0
9/3/2017 Draft Fee Petition 2.3
TOTAL HOURS 240.2
TOTAL FEES AT $465/HOUR $ 111,693.00
HAMILTON LAW OFFICE — Billing Record — Torreya Hamilton — Baker v. Ghidotti, et al., 11 CV 4197
Date Description Rate Time Total
01/16/2015 emails (4) with Chris Smith re: updates to his declaration in $465.00 hr 0.20 $93.00
support of my hourly rate
01/16/2015 telephone call with Jeff Neslund re: updates to his declaration $465.00 hr 0.10 $46.50
in support of my hourly rate
01/16/2015 review updated declaration in support of my hourly rate from $465.00 hr 0.10 $46.50
Jeff Neslund
01/16/2015 draft email to ID and Amy re: updated declaration from $465.00 hr 0.10 $46.50
Neslund and Smith
01/16/2015 draft section of brief in support of my hourly rate $465.00 hr 0.40 $186.00
01/16/2015 emails (2) with ID re: making a demand, trying to settle fees, $465.00 hr 0.10 $46.50
no notice of appeal filed by Ds
01/18/2015 emails (3) with IKD re: supporting materials for fee petition, $465.00 hr 0.10 $46.50
my declaration
01/19/2015 emails (3) with IKD re: updated declarations in support of $465.00 hr 0.10 $46.50
hourly rate
01/20/2015 emails (4) btw IKD and defense counsel re: payment of $465.00 hr 0.10 $46.50
judgment, filing fee petition
01/20/2015 emails (2) with IKD re: my final supporting declaration for fee $465.00 hr 0.10 $46.50
petition
01/21/2015 court notification emails (2) re: IKD filed fee petition tonight $465.00 hr 0.10 $46.50
01/21/2015 court notification emails (4) re: filed fee petition, notice and $465.00 hr 0.10 $46.50
motion to file brief in excess of 15 pages
01/21/2015 email from IKD to defense counsel with demand and $465.00 hr 0.10 $46.50
negotiating a settlement
01/27/2015 review Ds' notice & motion to strike our fee petition $465.00 hr 0.10 $46.50
01/28/2015 emails (7) with IKD re: Ds' request for our time sheets in excel, $465.00 hr 0.20 $93.00
how to convert
01/28/2015 appear in Court on Plaintiff's motion for attorneys' fees $465.00 hr 0.60 $279.00
01/28/2015 meeting with ID re: settlement negotiations on fees $465.00 hr 0.40 $186.00
01/28/2015 emails (3) btw defense counsel and IKD re: providing excel $465.00 hr 0.10 $46.50
sheets of our billing
01/29/2015 review Court's minute order of today's date $465.00 hr 0.10 $46.50
01/29/2015 emails (5) with IKD and between her and defense counsel re: $465.00 hr 0.20 $93.00
excel billing sheets
02/17/2015 review email from IKD to defense counsel and attached draft $465.00 hr 0.10 $46.50
joint statement
02/19/2015 email from defense counsel requesting agreement for an $465.00 hr 0.10 $46.50
extension of time to file fee petition response
02/20/2015 review Ds' notice and motion for an extension of time to file $465.00 hr 0.10 $46.50
fee petition response filed today
02/21/2015 email from IKD to defense counsel re: joint statement $465.00 hr 0.10 $46.50
02/23/2015 email from defense counsel re: when City will pay judgment to $465.00 hr 0.10 $46.50
Plaintiff
02/24/2015 review email from Dse counsel and attached joint statement $465.00 hr 0.10 $46.50
with Ds' additions
02/24/2015 confer with ID re: court today $465.00 hr 0.20 $93.00
02/24/2015 court hearing re: fee petition $465.00 hr 0.60 $279.00
02/24/2015 review Court's minute order of today's date $465.00 hr 0.10 $46.50
03/03/2015 emails (3) btw IKD and defense counsel re: final draft of joint $465.00 hr 0.10 $46.50
statement
03/16/2015 VM message for K. Acuff $465.00 hr 0.10 $46.50
03/16/2015 telephone call with Irene re: judge's order on "statement of $465.00 hr 0.30 $139.50
differences" joint statement, possible conf call with defense
counsel today
03/16/2015 emails (7) with defense counsel re: court order from last court $465.00 hr 0.20 $93.00
date, statement of differences, parties' agreement to seek
clarification from the judge
03/16/2015 emails (4) with IKD re: statement of differences from Court $465.00 hr 0.10 $46.50
order, how to proceed
03/17/2015 email from IKD re: contacting court about "statement of $465.00 hr 0.10 $46.50
differences" today
03/17/2015 email from IKD re: Ds' filing today $465.00 hr 0.10 $46.50
03/17/2015 emails (3) with Defense counsel re: settlement of fees $465.00 hr 0.10 $46.50
03/18/2015 review Ds' statement of differences re: fee petition filed $465.00 hr 0.10 $46.50
yesterday
03/20/2015 email from office re: message from defense counsel re: $465.00 hr 0.10 $46.50
settlement of fees
03/30/2015 review Ds' response to Plaintiff's fee petition (17 pages with $465.00 hr 0.50 $232.50
exhibits)
04/01/2015 telephone call with C. Fronczyk re: settling fees $465.00 hr 0.20 $93.00
04/06/2015 telephone call with IKD re: reply brief on fees $465.00 hr 0.20 $93.00
04/07/2015 review Plaintiff's fee petition reply brief filed by IKD yeserday $465.00 hr 0.30 $139.50
04/24/2015 review Court's minute order and memorandum opinion on $465.00 hr 0.30 $139.50
fees (24 pages)
04/27/2015 email from defense counsel re: payment of fee award vs. costs $465.00 hr 0.10 $46.50
award to Ds
04/27/2015 review Court's minute order of today's date $465.00 hr 0.10 $46.50
05/02/2015 review Court's email notifications — IKD filing of notice of $465.00 hr 0.10 $46.50
appeal
05/22/2015 review IKD's motion for reconsideration on fees $465.00 hr 0.30 $139.50
06/01/2015 in person meeting with ID re: appealing fee decision $465.00 hr 0.30 $139.50
06/09/2015 emails (2) with IKD re: 7th circuit mediator email received $465.00 hr 0.10 $46.50
yesterday
06/11/2015 meeting with ID re: mediation in 7th Circuit $465.00 hr 0.20 $93.00
06/23/2015 draft email to IKD re: setting of 7th Circuit mediation $465.00 hr 0.10 $46.50
06/24/2015 review 7th Circuit minute orders re: briefing schedule and Rule $465.00 hr 0.10 $46.50
33 mediation forwarded by IKD today
07/01/2015 review email chain between IKD, city counsel and mediation $465.00 hr 0.10 $46.50
staff re: rescheduling mediation date
07/02/2015 email from IKD's paralegal re: mediation date $465.00 hr 0.10 $46.50
07/02/2015 email from 7th circuit legal assistant re: mediation date and $465.00 hr 0.10 $46.50
adjustment of briefing schedule
08/06/2015 emails (4) with IKD paralegal re: calling 7th Circuit mediator to $465.00 hr 0.10 $46.50
reschedule SC
08/06/2015 telephone call to 7th Circuit mediator's assistant re: SC $465.00 hr 0.10 $46.50
08/17/2015 emails (2) with IKD's paralegal forwarding 7th Circuit legal $465.00 hr 0.10 $46.50
assistant's email re: scheduling 7th Circuit mediation
08/18/2015 emails (2) from 7th Circuit personnel and City re: SC $465.00 hr 0.10 $46.50
08/18/2015 emails (3) with IKD's paralegal, city counsel and 7th Circuit $465.00 hr 0.10 $46.50
mediation clerk re: scheduling 7th Circuit mediation
08/20/2015 email from 7th Circuit legal assistant confirming appellate $465.00 hr 0.10 $46.50
schedule
08/31/2015 email from IKD re: meeting prior to SC this week $465.00 hr 0.10 $46.50
09/01/2015 emails (3) with IKD re: SC $465.00 hr 0.10 $46.50
09/02/2015 emails (6) with IKD re: SC tomorrow $465.00 hr 0.20 $93.00
09/02/2015 preparation for 7th Circuit mediation, read IKD's notes and $465.00 hr 1.20 $558.00
court's memorandum opinion
09/03/2015 7th Circuit mediation & conferring with IKD afterwards $465.00 hr 3.00 $1,395.00
10/09/2015 email from IKD re: settlement negotiations $465.00 hr 0.10 $46.50
10/09/2015 telephone conversation with IKD re: conversations with 7th Cir $465.00 hr 0.20 $93.00
mediator, status of settlement negotiations
10/15/2015 emails (3) with IKD and Joel Shapiro $465.00 hr 0.10 $46.50
06/05/2016 review letter of 6/4/15 date from IKD to 7th Circuit mediators $465.00 hr 0.10 $46.50
requesting settlement confernce
06/05/2016 review letter of 6/4/15 date from IKD to 7th Circuit mediators $465.00 hr 0.10 $46.50
requesting settlement confernce
06/25/2016 review IKD appellate brief on fees $465.00 hr 1.00 $465.00
09/30/2016 court email notifications (2) re: appellate record $465.00 hr 0.10 $46.50
12/01/2016 telephone call with IKD re: Appellate argument on Monday $465.00 hr 0.30 $139.50
12/04/2016 email from IKD re: oral argument tomorrow $465.00 hr 0.10 $46.50
12/05/2016 emails (4) IKD re: question by Justice Hadid during argument $465.00 hr 0.20 $93.00
today, IKD's answer, submitting a Rule 28(e) letter to clarify
point, providing sample 7th Cir post argument supplemental
letters
12/05/2016 attend appeal, make notes for IKD for submitting Rule 28(e) $465.00 hr 0.50 $232.50
letter
12/07/2016 review email and Rule 28(e) letter filed by IKD today $465.00 hr 0.10 $46.50
05/10/2017 review 7th Circuit opinion (18 pages) $465.00 hr 0.30 $139.50
06/01/2017 email notifications (3) from 7th Circuit Clerk re: judgment $465.00 hr 0.10 $46.50
06/02/2017 email from IKD to defense counsel re: calculating fees and $465.00 hr 0.10 $46.50
interest post appeal, settling supplemental fees for appeal
07/01/2017 review notice and motion to set briefing schedule on $465.00 hr 0.10 $46.50
calculating fees post appeal, filed yesterday by IKD
07/05/2017 Email from defense counsel re: no objection to motion for $465.00 hr 0.10 $46.50
briefing schedule, discussing fees
07/12/2017 email from DR re: my hours for supplemental fee demand $465.00 hr 0.10 $46.50
07/13/2017 emails (2) with IKD re: my hours post judgment. for $465.00 hr 0.10 $46.50
supplemental fee petition
07/17/2017 review court's minute order of today's date $465.00 hr 0.10 $46.50
07/26/2017 review IKD email and fee chart for original fee demand and $465.00 hr 0.10 $46.50
supplemental fee demand
07/27/2017 email from defense counsel re: supplement al fee demand $465.00 hr 0.10 $46.50
07/28/2017 emails (4) btw IKD and from defense counsel re: originl fee $465.00 hr 0.20 $93.00
judgment and negotiations on supplemental fees, case law,
arguments
08/01/2017 review email and attachments from IKD to defense counsel $465.00 hr 0.10 $46.50
attaching revised stip and order for first fee judgment
08/02/2017 emails (3) btw IKD and defense counsel re: language of stip $465.00 hr 0.10 $46.50
and order on revised first fee judgment
08/04/2017 email from IKD to defense counsel, further revisions to stip on $465.00 hr 0.10 $46.50
first fee judgment, submitting counter demand on
supplemental fees
08/04/2017 email from IKD re: status of settlement negs on supplemental $465.00 hr 0.10 $46.50
fees
08/07/2017 emails (3) btw IKD and defense counsel re: language of stip $465.00 hr 0.10 $46.50
and settlement of supplemental fees, legal arguments on both
sides
08/07/2017 draft email to IKD re: drafting stipulation for City to issue $465.00 hr 0.10 $46.50
separate checks vs. me providing a fee release
08/08/2017 telephone call with IKD re: settlement negotiations on $465.00 hr 0.30 $139.50
supplemental fee petition
08/08/2017 telephone call with C. Fronczak re: settlement of post verdict $465.00 hr 0.10 $46.50
fees
08/08/2017 emails (2) from defense counsel re: adding me to stip and $465.00 hr 0.10 $46.50
providing a counter off on supplemental fees
08/08/2017 emails (3) with IKD re: settling supplemental fees $465.00 hr 0.10 $46.50
08/08/2017 emails (3) btw IKD and defense counsel re: counter offer, $465.00 hr 0.10 $46.50
further negotiations
08/08/2017 legal research fees on fees recovery, 7th Cir case law, send $465.00 hr 0.50 $232.50
case to IKD
08/09/2017 emails (2) btw IKD and defense counsel re: whether Plaintiff $465.00 hr 0.10 $46.50
was successful on any issue on appeal—
08/09/2017 meeting with IKD and DR re: settling supp fees $465.00 hr 0.30 $139.50
08/10/2017 review City's appellate brief for whether they conceded error $465.00 hr 0.20 $93.00
on successful issue (they did not)
08/10/2017 meeting with IKD re: settling supplemental fees, amount to $465.00 hr 0.40 $186.00
discount fees per 7th Cir caselaw
08/10/2017 emails (8) with IKD re: adding me to the stip and negotiations $465.00 hr 0.30 $139.50
on supplemental fee settlement, evaluation of Defendants'
argument, applicable case law
08/11/2017 email from IKD re: final version of stip and order on original $465.00 hr 0.10 $46.50
fees
08/14/2017 email from defense counsel to Judge L. with agreed orders $465.00 hr 0.10 $46.50
08/14/2017 court email notification re: defense counsel filed stipulation as $465.00 hr 0.10 $46.50
to original fee judgment
08/14/2017 emails (2) with defense counsel re: talking about settlement of $465.00 hr 0.10 $46.50
supplemental fees again before filing of supplemental fee
petition
08/15/2017 review case law excerpts from IKD re: fees for appellate work $465.00 hr 0.20 $93.00
08/15/2017 meeting with IKD re: fee petition due today, asking for more $465.00 hr 0.50 $232.50
time to try and negotiate settlement at 50 percent reduction
08/15/2017 review notice and motion for an extension of time for supp fee $465.00 hr 0.10 $46.50
petition filed last night by IKD
08/17/2017 email from IKD re: motion to extend time granted no one need $465.00 hr 0.10 $46.50
appear in court today
08/17/2017 telephone call with defense counsel trying to settle supp fees $465.00 hr 0.10 $46.50
at 50% reduction
08/17/2017 draft lengthy email to IKD re: settling supp fees, convo with $465.00 hr 0.20 $93.00
defense counsel, making edits, reductions on fees, 50% offer
to settle
08/18/2017 review Court's minute order of today's date $465.00 hr 0.10 $46.50
08/23/2017 emails (7) with defense counsel following up on 50% $465.00 hr 0.10 $46.50
discounted fee settlement offer
08/23/2017 emails (3) with IKD re: settlement negotiations on supp fees, $465.00 hr 0.10 $46.50
having to file petition
08/28/2017 email from defense counsel, will not settle for 50% reduction $465.00 hr 0.10 $46.50
in supp fees, going to have to file supp pet
08/29/2017 emails (4) with IKD re: supp fee petition due today $465.00 hr 0.10 $46.50
08/31/2017 edit and revise billing sheets, remove time for unsuccessful $465.00 hr 1.00 $465.00
post trial issues, all billing related to co-D Reliable Recovery
TOTAL 25.10 $11,671.50
Irene K. Dymkar 53 West Jackson, Suite 733 Chicago, IL 60604-3462 (312) 345-0123
ATTORNEY SERVICES FOR BAKERS (Daniel H. Regenscheit)
Baker, et al. v. Ghidotti, et al, 11 C 4197
Time
expended
Date Service provided (in hours)
6/15/2016 Discuss opening appellate brief with Irene Dymkar 0.50
6/20/2017 Edit and revise opening brief 3.10
6/20/2017 Draft table of authorities 0.40
6/20/2017 Edit and revise opening brief 2.60
6/20/2017 Draft table of contents and headings 0.70
6/20/2017 Edit and revise opening brief 0.70
10/20/2016 Initial draft reply brief 1.10
10/24/2016 Confer with Irene Dymkar re: reply brief 0.10
10/24/2016 Legal Research: preclusion; motions for reconsideration 1.20
10/26/2016 Proofread, revise, and edit reply draft 1.00
10/26/2016 Proofread, revise, and edit reply brief 3.10
10/26/2017 Draft table of contents and headings 0.30
10/26/2017 Draft table of authorities 0.70
10/26/2017 Proofread, revise, and edit reply brief 1.30
TOTAL LAW CLERK HOURS 16.8
TOTAL FEES AT $125/HOUR $ 2,100.00
11/28/2016 Prepare and review documents for oral argument 0.20
5/10/2017 Review appellate decision 0.70
5/17/2017 Confer with Irene Dymkar re: appeal, settlement offer 0.10
5/23/2017 Call court deputy re: remand and scheduling 0.10
5/23/2017 Draft timesheets and review time records for Irene Dymkar 0.80
6/2/2017 Research pre- and post-judgment interest calculations 0.80
6/9/2017 Confer with Irene Dymkar re: memorandum 0.10
6/9/2017 Research post-appeal fee memorandum 1.30
6/9/2017 Draft post-appeal memorandum (initial draft) 1.40
7/12/2017 Confer with attorney re: settlement, fee petition 0.30
7/13/2017 Court, including travel 0.80
7/13/2017 Recalculation of interest for settlement demand 0.10
TOTAL ATTORNEY HOURS 6.7
TOTAL FEES AT $230/HOUR $ 1,541.00
Irene K. Dymkar 53 West Jackson, Suite 733 Chicago, IL 60604-3462 (312) 345-0123
ATTORNEY SERVICES FOR BAKERS (Shamoyita DasGupta)
Baker, et al. v. Ghidotti, et al, 11 C 4197
Time
expended
Date Service provided (in hours)
3/1/2016 Discussing case with attorney Irene K. Dymkar 0.5
3/1/2016 Reviewing case, order re: fee petition 1.0
3/1/2016 Research re: bill of costs, attorneys fees 2.5
3/1/2016 Research re: bill of costs, attorneys fees 1.0
3/8/2016 Research re: bill of costs, attorneys fees 0.9
3/8/2016 Preparing memo re: research 1.5
3/23/2016 Drafting motion for extension of time 0.2
4/20/2016 Drafting motion for extension of time 0.2
6/16/2016 Creating and compiling documents for appendix for appellate brief 0.9
6/16/2016 Proofread, revise, and edit table of authorities 0.8
9/21/2016 Drafting letter of availability (initial draft) 0.5
9/23/2017 Drafting motion for extension of time 0.2
10/25/2016 Discussing case with attorney Irene K. Dymkar 0.1
10/26/2016 Discussing argument strategies with attorney Irene K. Dymkar 0.5
10/28/2016 Telephone conference with attorney Irene K. Dymkar 0.1
11/2/2016 Draft appellant argument confirmation form 0.1
11/7/2016 Discussing argument confirmation with attorney Irene K. Dymkar 0.1
Discussing case with attorneys Irene K. Dymkar and Daniel H.
11/28/2016 Regenscheit 0.1
Discussing case with attorneys Irene K. Dymkar, Daniel H. Regenscheit,
12/5/2016 Torreya L. Hamilton, Kevin T. Turkcan 0.4
12/8/2016 Reviewing appellee letter 0.1
5/10/2017 Reviewing appellate opinion 0.9
Discussing case with attorneys Irene K. Dymkar and Daniel H.
5/11/2017 Regenscheit 0.1
Discussing case with attorneys Irene K. Dymkar, Daniel H. Regenscheit,
5/31/2017 Torreya L. Hamilton, Kevin T. Turkcan 0.1
Discussing case with attorneys Irene K. Dymkar and Daniel H.
6/2/2017 Regenscheit 0.2
Discussing case with attorneys Irene K. Dymkar and Daniel H.
6/12/2017 Regenscheit 0.1
6/12/2017 Compiling hours worked on case 0.6
6/30/2017 Discussing case with attorney Irene K. Dymkar 0.1
6/30/2017 Drafting motion to set briefing schedule 0.7
Discussing case with attorneys Irene K. Dymkar and Daniel H.
7/13/2017 Regenscheit 0.2
Discussing case with attorneys Irene K. Dymkar and Daniel H.
7/28/2017 Regenscheit 0.1
8/2/2017 Discussing case with attorney Irene K. Dymkar 0.2
8/11/2017 Updating fee petition time sheet 0.2
TOTAL HOURS 15.2
TOTAL FEES AT $230/HOUR $ 3,496.00
