Motion for Entry of Judgment
JEFFREY COLE, District Judge.
Plaintiff, by its attorney, Daniel P. McAnally, move this Honorable Court for an entry of judgment and in support Plaintiff state:
1. This is and ERISA trust fund case seeking delinquent contributions, interest, liquidated damages and attorney fees.
2. On September 2, 2014 this Court entered an Agreed Order of Dismissal pursuant to the agreement of the parties. (Exhibit A) Plaintiff's Motion to Reinstate the case was granted and this case was reinstated on February 26, 2016.
3. Pursuant to the agreement of the parties, Defendants agreed to pay $123,435.26 to the Plaintiff in monthly installments. (Exhibit A) This amount was comprised of ERISA contributions, dues, liquidated damages, interest and attorney fees. (Exhibit B, declaration, fund manager, John Libby) If the Defendant defaulted on the payments, Plaintiffs reserved the right to reinstate the case and request a judgment based on the balance due, plus accrued interest, liquidated damages and Plaintiffs' additional attorney fees in enforcing the Order. (Exhibit A, paragraph 3)
4. The Defendant made 4 payments to the Plaintiff totaling $93,944.98. The balance owed on the Agreed Order is $29,490.28. (Exhibit b)
5. Due to the breach, the Defendant owes additional interest on the unpaid ERISA contributions in the amount of $236.41. (Exhibit B)
6. Due to the breach, the Defendant also owes liquidated damages on the unpaid ERISA contributions in the amount of $1,417.71. (Exhibit B)
7. Pursuant to the Agreed Order, the Defendant owes the sum of $3,380.50 for necessary and reasonable attorney fees expended by Plaintiffs in enforcing this Agreed Order and seeking judgment for the balance due. (Exhibit C, declaration, attorney Daniel P. McAnally)
WHEREFORE, Plaintiffs pray that their motion for entry of judgment be granted in the amount of $34,525.00 and that Plaintiff's be awarded their attorney fees and costs incurred in their attempts to collect on this judgment in the post-judgment supplemental proceedings.
EXHIBIT LIST
EXHIBIT A
Agreed Order of Dismissal
EXHIBIT B
Sworn Declaration Pursuant To 28 U.S.C.A. § 1746 John Libby, Manager, Audits & Collections
EXHIBIT C
Sworn Declaration Pursuant To 28 U.S.C.A. § 1746 Daniel P. McAnally, Plaintiffs Attorney
Exhibit A
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TRUSTEES of the CHICAGO REGIONAL
COUNCIL OF CARPENTERS PENSION FUND,
CHICAGO REGIONAL COUNCIL OF
CARPENTERS WELFARE FUND, and CHICAGO Case No. 13 CV 5113
REGIONAL COUNCIL OF CARPENTERS Judge Cole
APPRENTICE & TRAINEE PROGRAM FUND,
Plaintiffs,
v.
RITEWAY-HUGGINS CONSTRUCTION
SERVICES, INC. and LARRY HUGGINS
Defendants.
Agreed Order of Dismissal
The parties hereby agree that this case has been settled and that all issues and controversies have been resolved to their mutual satisfaction.
IT IS HEREBY ORDERED
1. That the Defendant Riteway-Huggins Construction Services, Inc. shall pay to the Plaintiffs One Hundred Twenty-Three Thousand Four Hundred Thirty-Five Dollars and Twenty-Six Cents ($123,435.26) as follows:
$64,454.65 on or before September 2, 2014
$9,830.11 on or before October 1, 2014
$9,830.10 on or before November 1, 2014
$9,830.10 on or before December 1, 2014
$9,830.10 on or before January 1, 2015
$9,830.10 on or before February 1, 2015
$9,830.10 on or before March 1, 2015
2. That the Defendant shall remain current in its ERISA monthly reporting and payment obligations to the Plaintiffs.
3. That if the Defendant defaults on either paragraphs 1 or 2, the Plaintiffs shall have the right to reinstate this case for the sole purpose of entering Judgment for the balance owed pursuant to this Order, plus any additional unpaid ERISA contributions incurred accrued interest, liquidated damages and Plaintiffs' attorney fee, and cost expended in enforcing this order.
4. This case is dismissed without prejudice with leave to reinstate on or before May 1, 2015.
5. In the event a motion to reinstate is not filed on or before May 1, 2015, the case shall be deemed dismissed with prejudice without further order of the Court.
ENTERED: ______________________
Judge Cole
Magistrate Judge
DATED: ________________________
AGREED TO: AGREED TO:
For Plaintiffs: For Defendants
_____________________________ ____________________
John Libby
Manager, Audits & Collections
Exhibit B
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TRUSTEES of the CHICAGO REGIONAL
COUNCIL OF CARPENTERS PENSION
FUND, et al.
Plaintiffs, Case No. 13 C 5113
v. Judge Cole
RITEWAY-HUGGINS CONSTRUCTION
SERVICES, INC.
Defendant.
SWORN DECLARATION PURSUANT TO 28 U.S.C.A. § 1746
John Libby declares as follows:
1. I am the Manager, Audits & Collections for the Chicago Regional Council of Carpenters Pension Fund and the Chicago Regional Council of Carpenters Welfare Fund ("Trust Funds") and in such capacity I am authorized to make this Declaration on behalf of the Trust Funds.
2. The Trust Funds and Riteway-Huggins Construction Services, Inc. ("Riteway") entered into and agreement whereby Riteway agreed to pay to the Trust Funds, $123,435.26 in monthly installments. This agreement was memorialized in an Agreed Order of Dismissal. The amount was comprised of ERISA contributions, dues, liquidated damages, interest and attorney fees. (Tab 1)
3. The Defendant submitted 4 payments to the Trust Funds totaling $93,944.98 but failed to pay the balance due. (Tab 2 "Payments Received") The balance owed on the Agreed Order is $29,490.28.
4. Because of its failure to pay the agreed amount, Riteway owes liquidated damages in the amount of $1,417.71. The liquidated damages calculation was based on the rate set forth in the controlling Trust Agreements, which is 1.5% compounded per month.
5. Because of its failure to pay the agreed amount, Riteway owes interest in the amount of $236.51. The interest calculation is based on the ERISA Section awarding such interest, 29 U.S.C. §1132(g)(2) and the calculation was done pursuant to Section 6621 of the Internal Revenue Code.
6. A summary of the total claim for $31,144.50 is attached hereto and incorporated herein.
I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in this Declaration is true and correct.
Signature: ________________________
John Libby
Manager, Audits & Collections
Dated: 3/11/15
________________________
Tab 1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TRUSTEES of the CHICAGO REGIONAL
COUNCIL OF CARPENTERS PENSION FUND,
CHICAGO REGIONAL COUNCIL OF
CARPENTERS WELFARE FUND, and CHICAGO
REGIONAL COUNCIL OF CARPENTERS
APPRENTICE & TRAINEE PROGRAM FUND, Case 13 CV 5113
Plaintiffs,
v. Judge Cole
RITEWAY-HUGGINS CONSTRUCTION
SERVICES, INC. and LARRY HUGGINS
Defendants.
Agreed Order of Dismissal
The parties hereby agree that this case has been settled and that all issues and controversies have been resolved to their mutual satisfaction.
IT IS HEREBY ORDERED
1. That the Defendant Riteway-Huggins Construction Services, Inc. shall pay to the Plaintiffs One Hundred Twenty-Three Thousand Four Hundred Thirty-Five Dollars and Twenty-Six Cents ($123,435.26) as follows:
$64,454.65 on or before September 2, 2014
$9,830.11 on or before October 1, 2014
$9,830.10 on or before November 1, 2014
$9,830.10 on or before December 1, 2014
$9,830.10 on or before January 1, 2015
$9,830.10 on or before February 1, 2015
$9,830.10 on or before March 1, 2015
2. That the Defendant shall remain current in its ERISA monthly reporting and payment obligations to the Plaintiffs.
3. That if the Defendant defaults on either paragraphs 1 or 2, the Plaintiffs shall have the right to reinstate this case for the sole purpose of entering Judgment for the balance owed pursuant to this Order, plus any additional unpaid ERISA contributions incurred accrued interest, liquidated damages and Plaintiffs' attorney fee, and cost expended in enforcing this order.
4. This case is dismissed without prejudice with leave to reinstate on or before May 1, 2015.
5. In the event a motion to reinstate is not filed on or before May 1, 2015, the case shall be deemed dismissed with prejudice without further order of the Court.
ENTERED: _____________________
Judge Cole
Magistrate Judge
DATED: Sep 2, 2014
_____________________
AGREED TO: AGREED TO:
For Plaintiffs: For Defendants:
John Libby
Manager, Audits & Collections
Acct# 19054 08/14/2014
Riteway Construction Services Inc
1030 E 87th St
Chicago, IL 60619
Amount owed for Collections $ 109,053.16
Amount Owed for Audit $ 14,382.10
Total Owed $ 123,435.26
Agreed Payment Terms
1st Payment - Due 9/2/14 $ 64,454.65
2nd Payment - Due 10/1/14 $ 9,830.11
3rd Payment - Due 11/1/14 $ 9,830.10
4th Payment - Due 12/1/14 $ 9,830.10
5th Payment - Due 1/1/15 $ 9,830.10
6th Payment - Due 2/1/15 $ 9,830.10
7th Payment - Due 3/1/15 $ 9,830.10
Total Payments $ 123,435.26
Acc#(s) 19054 8/14/2014
Riteway Construction Services Inc
1030 E 87th St
Chicago, IL 60619
Acc# 19054
Fringes Dues Ld's Interest Total
Apr-12 $0.00 $0.00 $ 2,181.35 $0.00 $2,181.35
May-12 $0.00 $0.00 $760.37 $0.00 $760.37
Jun-12 $0.00 $0.00 $532.71 $0.00 $532.71
Jul-12 $0.00 $0.00 $1,882.41 $0.00 $1,882.41
Aug-12 $0.00 $0.00 $1,947.67 $0.00 $1,947.67
Sep-12 $0.00 $0.00 $2,121.07 $0.00 $2,121.07
Oct-12 $0.00 $0.00 $1,005.06 $0.00 $1,005.06
Nov-12 $0.00 $0.00 $2,435.77 $0.00 $2,435.77
Dec-12 $0.00 $0.00 $1,555.87 $0.00 $1,555.87
Jan-13 $0.00 $0.00 $921.94 $0.00 $921.94
Feb-13 $0.00 $0.00 $899.05 $0.00 $899.05
Mar-13 $0.00 $0.00 $1,524.00 $188.94 $1,712.94
Apr-13 $0.00 $0.00 $1,665.49 $209.22 $1,864.71
May-13 $0.00 $0.00 $2,611.77 $322.56 $2,934.33
Jun-13 $0.00 $0.00 $1,222.16 $153.95 $1,376.11
Jul-13 $0.00 $0.00 $1,216.67 $148.50 $1,365.17
Aug-13 $0.00 $0.00 $1,133.82 $129.16 $1,262.98
Sep-13 $0.00 $0.00 $1,121.86 $147.77 $1,269.63
Oct-13 $0.00 $0.00 $694.27 $88.04 $782.31
Nov-13 $0.00 $0.00 $1,156.78 $149.87 $1,306.65
Dec-13 $0.00 $0.00 $545.54 $66.56 $612.10
Jan-14 $0.00 $0.00 $721.51 $94.31 $815.82
Feb-14 $0.00 $0.00 $387.64 $48.73 $436.37
Mar-14 $0.00 $0.00 $457.68 $58.72 $516.40
Apr-14 $0.00 $0.00 $320.64 $36.06 $356.70
May-14 $27,380.53 $2,009.32 $825.11 $91.33 $30,306.29
Jun-14 $32,689.50 $2,375.30 $484.58 $29.00 $35,578.38
______________________________________________________________________
Total $60,070.03 $4,384.62 $32,322.79 $1,962.72 $98,740.16
Attorney Fees & costs $10,313.00
___________
Total Amount Due $109,053.16
===========
Riteway Construction Services Inc
Account 19054
Audit Period (1/10 - 6/11)
Findings in Adjusted Audit Report
A American Contractors $ 1,076.94
Red Flooring $ 814.68
Clerical Errors $ 10,105.80
Total Audit Discrepancies $ 11,997.42
=============
Audit Discrepancies $ 11,997.42
Liquidated Damages $ 2,399.50
Interest $ 1,416.48
Audit Fees $ 3,672.00
Attorney Fess thru 7/14 $ 5,002.50
Payment Received 7/11/14 $ (10,105.80)
Total Due $ 14,382.10
=============
Tab 2
Riteway Construction Services Inc 03/11/2015
Account 19054
Amounts owed for Agreed Order that is in Default
August 2014 Agreed Order
Amount owed for Collections (4/12-6/14) $ 109,053.16
Amount owed for Audit (1/10-6/11) $ 14,382.10
_____________
Total owed and agreed to $ 123,435.26
Payments Received
09/02/2014 $ 64,454.65
10/14/2014 $ 9,830.11
11/20/2014 $ 9,830.11
12/17/2014 $ 9,830.11
____________
Total Paid $ 93,944.98
Currently Owed
Balance of Agreed Order $ 29,490.28
Additional Collection Liquidated Damages $ 1,417.71
Additional Audit LDs/Interest $ 236.51
____________
Total Owed* $ 31,144.50
* Additional Attorney Fees to be included on Attorney's Affidavit
Exhibit C
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TRUSTEES of the CHICAGO REGIONAL
COUNCIL OF CARPENTERS PENSION
FUND, et al.
Plaintiffs, Case No. 13 C 5113
v. Judge Cole
RITEWAY-HUGGINS CONSTRUCTION
SERVICES, INC.
Defendant.
SWORN DECLARATION PURSUANT TO 28 U.S.C.A. § 1746
Daniel P. McAnally declares as follows:
1. I am an associate of the law firm of Whitfield McGann & Ketterman and am licensed to practice law in the State of Illinois and in the U.S. Dist. Court for Northern District of Illinois, Eastern Division.
2. I have personal knowledge of the facts stated herein and if called to testify in this matter, I can competently testify to such facts from my own such knowledge.
3. I have in excess of 22 years experience representing trustees of employee benefit plans, including the prosecution of Federal Court litigation to collect delinquent employer contributions.
4. The Agreed Order of Dismissal entered in this case allows for an award of Plaintiffs attorney fees if the Defendant breached the agreement and Plaintiffs sought to enforce the Order.
5. Attorneys of this law firm have devoted 17.00 hours in connection with the settlement of this case, breach of the agreement and enforcement of the Order. The attorneys' billings in this case were charged at the rate of $195.00, $200.00 and $225.00 per hour. The total attorney fees billings is $3,380.50.
6. I have spoken with four other lawyers from four different labor law firms who practice this type of ERISA trust fund litigation. Based on my knowledge and experience, the rates charged by the hour in this case are less than or equal to the usual and customary rates charged by other law firms doing similar work in the United States District Court for the Northen District of Illinois.
7. I certify that the attached detailed attorney fees and costs totaling $3,380.50 were necessary and reasonable.
I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in this Declaration is true and correct.
Date: March 11, 2015
s/DANIEL P. McANALLY
_____________________
Attorney for the Trustees of the Chicago
Regional Council of Carpenters Pension Fund,
et al.
Slip ID ATTORNEY Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Case Est. Time Bill Status
Description Reference Variance
49555 TIME DPM 0.50 195.00 97.50
9/27/2014 Billable 0.00 T@7
Billed G:93845 10/1/2014 CTF-C./N9605/19054 0.00
Review correspondence from the fund office 0.00
regarding the monthly litigation status report;
update status of the case and future steps to be
taken; review the attorney fees and update since
the last report
496236 TIME TJK 0.25 225.00 56.25
10/10/2014 Billable 0.00 T@7
Billed G:94139 11/3/2014 CTC-C./N9605/19054 0.00
Draft status report and legal recommendation as to 0.00
the settlement payment status. Forward
recommendation to Audit and Collections Manager
John Libby and Collections Representative Harold
Boswell.
496422 TIME DPM 0.25 195.00 48.75
10/9/2014 Billable 0.00 T@7
Billed G:91439 11/3/2014 CTF-C./N9605/19054 0.00
Review correspondence from Earl E. Oliver, Field 0.00
Representative, trust fund office regarding the
payment due; review correspondence from the
defendant/signatory employer same.
497173 TIME DPM 0.25 195.00 48.75
10/28/2014 Billable 0.00 T@7
Billed G:94139 11/3/2014 CRF-C./N9605/19054 0.00
Telephone conference with Earl E. Oliver, Field 0.00
Representative, trust fund office regarding status of
compliance with the settlement agreement;
delinquent July 2014 thorough October 2014; not to
file regarding same.
497174 TIME DPM 0.10 195.00 19.50
10/29/2014 Billable 0.00 T@7
Billed G:94139 11/3/2014 CTC-C./N9605/19054 0.00
Telephone conference with Earl E. Oliver, Field 0.00
Representative, trust found office regarding
proceeding with motion to reinstate.
497176 TIME DPM 0.50 195.00 97.50
10/29/2014 Billable 0.00 T@7
Billed G:94139 11/3/2014 CTC-C./N9605/19054 0.00
Review file for current status; review the court 0.00
docket; correspondence to attorney Bormes
regarding compliance with the settlement
agreement and breach.
498447 TIME TJK 0.25 225.00 56.25
11/11/2014 Billable 0.00 T@7
Billed G:94436 12/1/2014 CTF-C./N9605/19054 0.00
Review settlement agreement payment plan 0.00
spreadsheet and draft recommendation to Audit
and Collections Manager John Libby and
collections Representative Harold Boswell after
consulting with primary attorney.
499080 TIME DPM 0.40 195.00 78.00
11/24/2014 Billable 0.00 T@7
Billed G:94436 12/1/2014 CTC-C./N9605/19054 0.00
Review correspondence from the fund office 0.00
regarding the monthly litigation status report;
update status of the case and future steps to be
taken; review the attorney fees and update since
the last report.
500056 TIME DPM 2.50 195.00 487.50
12/15/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Prepare motion to reinstate; prepare notice, 0.00
Certificate of Service and proposed court order;
Prepare the document for electronic filing;
electronically file the document with the U.S. Dist.
Court clerk's office; prepare courtesy copy for the
assigned Judge Cole.
500130 TIME DPM 0.50 195.00 97.50
12/17/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Prepare for court status/motion hearing; review file
for current status and most recent activity;
telephone conversation with trust fund regarding
status of the litigation review court docket to
confirm that the case will be called for status.
500132 TIME DPM 0.20 195.00 39.00
12/6/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Review correspondence from the fund office 0.00
regarding payments submitted; note to file
regarding same.
500133 TIME DPM 0.25 195.00 48.75
12/12/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Review correspondence from Earl E. Oilver, Field 0.00
Representative trust fund office regarding the trust
funds' claim of ERISA contributions, liquidated
damages, interest and dues; note to file regarding
same.
500146 TIME DPM 1.00 195.00 195.00
12/8/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Attend court appearance at the U.S. District Court 0.00
for the Northern District of Illinois before Judge
Cole.
500744 TIME DPM 0.10 195.00 19.50
1/5/2015 Billable 0.00 T@7
Billed G:94884 2/2/2015 CTC-C./N9605/19054 0.00
Telephone conversation with Earl E. Oliver, 0.00
employer contributions, Chicago District Council of
Carpenters' Trust funds regarding status of the
litigation.
500795 TIME DPM 0.25 195.00 48.75
12/29/2014 Billable 0.00 T@7
Billed G:94666 1/5/2015 CTC-C./N9605/19054 0.00
Review e-mail sent by the U.S. Dist. Court for the 0.00
northern Dist. of Illinois regarding MINUTE entry
before the Honorable Jeffrey Cole: Motion hearing
held. Plaintiffs' motion to reinstate is entered and
continued to 1/28/2015 at 08:30 AM; download
documents to the file folder; print document and
enclose in file.
502394 TIME NEK 0.60 200.00 120.00
1/27/2015 Billable 0.00 T@7
Billed G:94884 2/2/2015 CTC-C./N9605/19054 0.00
Correspondence with Daniel P McAnally on matter 0.00
as well as review of docket and file for court
appearance in case.
502398 TIME NEK 1.00 200.00 200.00
1/28/2015 Billable 0.00 T@7
Billed G:94884 2/2/2015 CTC-C./N9605/19054 0.00
Court appearance in matter. 0.00
502496 TIME DPM 0.50 195.00 97.50
1/27/2015 Billable 0.00 T@7
Billed G:94884 2/2/2015 CTC-C./N9605/19054 0.00
Prepare for court status/motion hearing; review file 0.00
for current status and most recent activity;
telephone conversation with trust fund regarding
status of the litigation; review court docket to
confirm that the case will be called for status;
confer with attorney Travis J. Ketterman regarding
same; confer with attorney Nicholas Kasmer
regarding same.
502535 TIME DPM 0.20 195.00 39.00
1/23/2015 Billable 0.00 T@7
Billed G:94884 2/2/2015 CTC-C./N9605/19054 0.00
Review correspondence from the fund office 0.00
regarding the monthly litigation status report;
update status of the case and future steps to be
taken; review the attorney fees and update since
the last report.
504248 TIME DPM 0.20 195.00 39.00
2/1/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Review e-mail sent by the U.S. Dist. Court for the 0.00
Northern Dist. of Illinois regarding MINUTE entry
before the Honorable Jeffrey Cole: Status hearing
held and continued to 2/26/2015 at 08:30 AM.
Motion hearing held. Plaintiffs' motion to reinstate
and for entry of judgment is entered and continued
to 2/26/2015 at 8:30 am.; download documents to
the file folder; print document and enclose in file.
504275 TIME DPM 0.50 195.00 97.50
2/17/2015 Billable 0.00 T@7
Billed G:94884 3/2/2015 CTC-C./N9605/19054 0.00
Review correspondence from trust fund audit 0.00
coordinator, Nathaniel Lagalo regarding the trust
funds' claim of ERISA contributions, liquidated
damages, interest and dues; correspondence to
attorney Bormes regarding same.
504279 TIME DPM 0.10 195.00 19.50
2/23/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Telephone conference with Ear E. Oliver, Field 0.00
Representative, trust fund office regarding what
attorney fees are outstanding and what was paid;
individual was not available to take my call; left
detailed message regarding the substance of my
call and requested that my call be returned.
504295 TIME DPM 0.10 195.00 19.50
2/23/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Telephone conference with Earl E. Oliver Field 0.00
Representative, trust fund office regarding the
attorney fees contained in the settlement.
504547 TIME TJK 1.00 225.00 225.00
2/26/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Court appearance for entry of the motion to 0.00
reinstate.
504548 TIME TJK 0.25 225.00 56.25
2/25/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Conference with Daniel P McAnally regarding 0.00
status. Review updated numbers owed and
prepare for court appearance.
504586 TIME DPM 0.50 195.00 97.50
2/25/2015 Billable 0.00 T@7
Billed G:95117 3/2/2015 CTC-C./N9605/19054 0.00
Prepare for Court status/motion hearing; review file 0.00
for current status and most recent activity;
telephone conversation with trust fund regarding
status of the litigation; review court docket to
confirm that the case will be called for status.
3/12/15 Court Appearance 1.0 200.00 200.00
prepare and travel
Review correspondence from 2.75 @195.00 536.75
fund office regarding the
claim; prepare Libby affidavit
attorney affidavit; motion
for entry of judgment
Travel to/from court 3/18 1.0 @195 195.00
court appearance 17.0 #3,300.50
