232556 05/13/14 �a u,�C.Iq*f!
CITY OF CARMEL, INDIANA VENDOR: 00353406
® i. ONE CIVIC SQUARE KRIEG DEVAULT CHECK AMOUNT: $****79,282.99*
?� CARMEL, INDIANA 46032 ONE INDIANA SQUARE,STE 2800 CHECK NUMBER: 232556
�,,,�ro��. INDIANAPOLIS IN 46204 CHECK DATE: 05/13/14
DEPARTMENT ACCOUNT PO NUMBER INVOICE NUMBER AMOUNT DESCRIPTION
902 4460807 379030 47,515.37 PERFORMING ARTS CENTE
902 4460807 381190 31,767.62 PERFORMING ARTS CENTE
One Indiana Square
KX21 E � D VAULT® Suite 2800
®® lndinapolis,IN 46204-2079
T:317,636.11341
F:317.636.1507
Fed.EIN 1135-1055087
Carmel Redevelopment Commission
ExecutiveLes Olds,AIA, Di
30 West Main Street, Su't ��tor 04_78-1PQ(r .09 RCVi)
Carmel,IN 46032
April 28,2014
Invoice plumber 381190
Our File#: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH March 31, 2014
03/03/.14 RSS Follow up with Court on matters related to CMP;follow up with WPM on discovery
matters; analyze the same.
2.50 415.00/hr 1,037.50
03/03/14 TJC Follow up on open items from court conference; communications regarding submission of
proposed case management plan to the court;email communications with WPM. Receipt
of court's order extending deadline to respond to SSE's motion for partial summary
judgment. Participated in strategy conference with WPM.
3.10 495.00/hr 1,534.50
03/04/14 BPH Update and revise Second Requests for Production to SS&E. Update and revise First Set
of Interrogatories to SS&E in preparation to propound upon SS&E.
0.70 230.00/hr 161.00
03/04/14 BSS Strategy, correspondence, and teleconferences.regarding
damages i, Correspondence and strategy
regarding case. management plan.
0.50 275.00/hr 137.50
03/04/14 TJC Addressed issues related to strategy in connection with foregoing the ability to present
evidence of in order to expedite trial setting. Communications among
client tearn, court staff, WPM and opposing counsel. Receipt and review of court's case
management order.
1.50 495.00/hr 742.50
P a
CRML 00001 Page 2
Invoice#381190
03/05/14 BSS Receipt and analysis of Court's Order regarding case management deadlines and strategy
regarding the same. Teleconferences regarding issues contained within case management
plan and strategized.regarding effects thereof. Strategized regarding Walter P Moore's
supplemental findings. Correspondence and strategy regarding selection
1.00 275.00/hr 275.00
03/06/14 RSS Review and analyze issues related to summary judgment and hearing on CMO.
2.00 415.00/hr 830.00
03/07/14 BSS Strategized and analyzed issues related to s denoted
by Walter P Moore,and conferred regarding pros/cons of
setting. Strategized regarding March 7 telephonic
hearing with the Court. Worked on preparing for drafting response to SSE's Motion for
Partial Summary Judgment and researched issues for responding to the Motion.
0.75 275.00/hr 206.25
03/07/14 RSS Review and analyze issues related to Summary Judgment matters and CMO;telephonic
hearing on CMO with Judge Nation; follow up on matters related to the same.
3.00 415.00/hr 1,245.00
03/07/14 TJC Participated in conference call with court related to case management and discovery
issues. Addressed issues related to SSE's motion for partial summary judgment.
1.50 495.00/hr 742.50
03/09/14 RSS Review and analysis of SSE's Summary Judgment Motion;review of exhibits and
evidence in support of the same.
3.00 415.00/hr 1,245.00
03/10/14 BSS Worked on preparing Response to SSE's Motion for Partial Summary Judgment and
strategy/analysis of issues for raising therein. Analysis of deposition of _ for
Response.
2.50 275.00/hr 687.50
03/10/14 RSS Strategize on Response and Cross Motion for Summary Judgment;review and analysis of
issues for the same.
3.25 415.00/hr 1,348.75
03/10/14 TJC Review and analysis of SSE's motion for summary judgment. Status and strategy meeting
regarding.response to SSE's motion and a cross.rnotion by CRC.
2.70 495.00/hr 1,336.50
03/11/14 RSS .Review and analyze matters involving summary judgment.
1.00 415.00/hr 415.00
03/12/14 RSS Analysis of issues related to claims asserted in summary judgment matter.
0.50 415.00/hr 207.50
I
CRML 00001 Page 3
Invoice#381190
03/13/14 BSS Worked on preparing discovery requests SSE and NINVII, nd strategized
regarding the same.
0.25 275.00/hr 68.75
03/13/14 RSS Analysis of discovery and depositions.
1.50 415.00/hr 622.50
03/13/14 TJC Addressed SSE's request to depose Walter P Moore representatives. Worked on
WPM -2eport for materials in support of CRC's position on summary
judgment.
2.40 495.00/hr 1,188.00
03/14/14 BPH Update and revise Requests for Production to be served upon Update
and revise First Set of.Interrogatories to SS&E. Update and revise Second Set of Requests.
for Production to SS&E in preparation to serve.
1.40 230.00/hr 322.00
03/14/14 BSS Correspondence to/from opposing counsel regarding depositions of additional Walter P
Moore personnel. Strategy regarding the same.
0.25 275.00/hr 68.75
03/14/14 RSS Review and analyze issues related to depositions and summary judgment.
1.00 415.00/hr 415.00
03/14/14 TJC Completed Walter P Moore reports for materials to be used in support of
srunmary judgment.
2.30 495.00/hr 1,138.50
03/16/14 BSS Analysis of deposition transcripts and worked on preparing materials from such transcripts
in support of arguments that there exists
and strategized regarding the same.
1.00 275.00/hr 275.00
03/17/14 BSS Extensive analysis 6f deposition testimony of dr d prepared summary
of items therein in support of CRC's Response to SSE's Motion for Partial Summary
Judgment and strategized regarding the same.
2.75 275.00/hr 756.25
03/17/14 RSS Review of issues involving summary judgment and strategize on the same.
0.50 415.00/hr 207.50
03/17/14 TJC Attention to issues related to WPM expert reports.
0.50 495.00/hr 247.50
03/18/14 DPH Receipt and analysis of February invoices from Walter P Moore. Update and revise
comprehensive spreadsheet of damages to reflect new invoices received.
0.25 230.00 Air 57.50
03/18/14 BSS Analysis of deposition transcripts and worked on preparing substantive response to SSE's
CRML 00001 Page 4
Invoice#381190
Motion for Partial Summary Judgment to evidence questions of fact with deposition
testimony. Correspondence and strategy regarding the same.
3.25 275.00/hr 893.75
03/18/14 RSS Analysis of matters related to summary judgment;follow up on the same.
0.75 415.00/hr "311.25
03/19/14 BSS Analysis of deposition of p in support of preparing Response to SSE's
Motion.for Partial Summary Judgment. Strategized regarding response brief and analysis
of SSE's Motion.
0.75 275.00/hr 206.25
03/19/14 .KSS Summary judgment analysis of issues related to delegation arguments by SSE.
0.50 415.00/hr 207.50
03/20/14 BSS Worked on preparing Response to Steel Supply's Motion for Partial Summary Judgment.
1.25 275.00/hr 343.75
03/20/14 RSS Call with WPM on matters related Summary Judgment and Depositions;analyze issues
going forward.
1.00 415.00/hr 415.00
03/20/14 TJC Receipt and review of order from court setting certain deadlines and parameters related to
the trial setting. Follow up on open items. Began review and analysis of:
to be used in support of.summary judgment. Strategy and analysis on summary judgment
issues.
1.90 495.00/hr 940.50
03/21/14 BPH Receipt and analysis of discovery deficiency letter from counsel for SS&E. Analyze
specific provision of discovery responses answered in April of 2012 for alleged
deficiencies in preparation to respond to same. Review and analyze damages
documentation in conjunction with request to supplement same.
0.90 230.00/hr 207.00
03/21/14 .BSS Analysis of depositions of and prepared excerpts
therefrom for the CRC's Response to SSE's Motion for Partial Summary Judgment and
worked on drafting and revising the same. Strategized regarding issues for Response and
potential inclusion of . Receipt and analysis of requests for supplementation
of discovery responses and production by SSE and strategized regarding the same.
4.25 275.00/hr 1,168.75
03/2:1/14 RSS Work on issues related to summary judgment and matters involving the same;analysis of
issues related to the same;call with WPM on matters related to case and discovery
matters.
1.50 415.00/hr 622.50
03/21/14 TJC Completed review and analysis of all exist in&QMrqports for materials to he used in
support of CRC's argument on summary judgment. Attention to SSE's request for
supplementation of damages discovery.
CRN/11,00001 Page 5
Invoice#381190
1.30 495.00/hr 643.50
03/24/_14 BPH Analyze deficiency letter sent pursuant to Rule 26(F) by opposing counsel regarding
requested supplementation of prior interrogatory responses and prior responses to requests
for production. Draft plan of action for response thereto and strategize regarding same.
Compile updated damages documentation and update spreadsheets regarding same in
preparation to produce.
2.20 230.00/hr 506.00
03/24/14 BSS Drafted and revised Second Notice ofExpert.Disclosures to be filed with the Court
pursuant to updated Case Management Order; strategized regarding expert to be identified
and additions/revisions of the same. Worked on drafting and revising Response to.Motion
for Partial Summary Judgment and Cross-Motion for Summary Judgment.
Correspondence to/from WPM.regarding summary judgment issues. Strategized
regarding experts for 4 . 0 1 garding the same.
4.25 275.00/hr 1,168.75
03/24/14 RSS WPM matters; call with on discovery matters and Summary Judgment.
0.50 415.00/hr 207.50
03/24/14 TJC Reviewed and commented on draft of disclosure of expert witnesses. Communications
with WPM regarding summary judgment issues.
0.50 495.00/hr 247.50
03/25/14 BPH Analyze Walter P Moore documents previously produced to SUE in preparation to
respond to discovery supplementation request.
1.00 230.00/hr 230.00
03/25/14 RSS Analysis of issues related to Summary Judgment and follow up on matters related to the
same;;call with elated to depositions dates,discovery and WPM matters.
1.50 415.00/hr 622.50
03/26/14 RSS Analysis of issues related to SSE Dispositive Motion.
'-0.75 415.00/hr 311.25
03/26/14 TJC Addressed issues related to deposition scheduling. Prepared for conference call with
Walter P. Moore.
0.20 495.00/hr 99.00
03/27/14 BSS Teleconference with experts from Walter P Moore to discuss Steel Supply's motion for
partial summary judgment and responding to the same, including
Correspondence to/from opposing counsel regarding expert
depositions and discovery supplementation. Revisions to expert disclosure information.
1.25 275.00/hr 343.75
03/27/14 RSS Review and analyze issues related to WPM report and'discovery matters; prepare for
issues related to Summary,Judgment;analysis of issues on the same;call with WPM on
matters related to Summary Judgment;.follow up on issues related to the same.
3.50 415.00/hr 1,452.50
CRML 00001 Page 6
Invoice#381190
03/27/14 TJC Communications with SSE counsel related to scheduling of depositions of experts.
Strategized regarding designate for deposition,timing and
location. Status and strategy regarding summary judgment briefing.
1.00 495.00/hr 495.00
03/28/14 BPH Strategize with litigation support regarding supplemental discovery responses and
documents necessary to review to.respond thereto.
0.30 230.00/hr 69.00
03/28/14 BSS Correspondence to and from opposing counsel regarding scheduling the depositions of
Walter P Moore. Worked on preparing supplemental answers to discovery requests
estimated by counsel for defendants. Worked on preparing response to Steel Supply's
motion for summary judgment and counter motion seeking summary judgment in favor of
the CRC.
1.00 275.00/hr 275.00
03/28/14 GTS Process electronic data and prepare for attorney review.
1.50 195.00/hr 292.50
03/28/14 RSS Analysis of issues related to WPM depositions; analysis of issues related to Summary
Judgment;analysis of issues related to expert disclosures;call with WPM on matters
related to the same;correspond with SSE counsel on deposition matters;review and
follow up on discovery matter.
2.00 415.00/hr 830.00
03/3.1/14 .BPH Coordinate with litigation support regarding preparation for review of communications
from Walter P Moore and Krieg DeVault.
0.25 230.00/hr 57.50
03/31/14 BSS Teleconference with experts from Walter P Moore regarding arguments and issues to be
addressed in the CRC's response to Steel Supply's motion for partial summary judgment.
Worked on preparing response to motion for partial summaryjudgment and cross-motion
thereto. Worked on drafting/revising.supplemental discovery requests to SSE and Steel
Supply. Strategized regarding serving discovery OF
2.75 275.00/hr 756.25
03/31/14 GTS .Prepare documents for attorney review.
0.50 195.00/hr 97.50
03/31/14 RSS Follow up on matters related to summary judginent and issues on the sarne.
0.50 415.00/hr 207.50
Total Fees:for this Matter: 86.40 $ 31,748.00
TJC Costakis,Thomas J. 18.90 hrs 495.00/hr 9,355.50
BPH Holler,Blake P. 7.00 hrs 230.00/hr 1,610.00
RSS Schein, Robert S. 30.75 hrs 415.00/hr 12,761.25
CRM L.00001 Page 7
invoice#3811.90
GTS Smith, Gary'1'. 2.00 hrs 195.00/hr 390.00
BSS Strawbridge, Bryan S. 27.75 hrs 275.00/hr 7,631.25
Total: 86.40 hrs $ 31,748.00
Federal Express 9.02
Photocopies 10.60
Total Disbursements for this Matter: $ 19.62
TOTAL FEES: $ 31,748.00
TOTAL DISBURSEMENTS: $ 19.62
TOTAL CI-]A:RGES FORTHIS BILL: $ 31,767.62
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
One Indiana Square
K R I E G I D E VnU LT India ZR°°
Indianapolis,1N 46204-207I
T:317.636.4341
F:317.636.1507
Fcd.EIN#35-1055087
Carmel Redevelopment Commission
Les Olds,AIA,Executive Director
30 West Main Street, Suite 220
Carmel,IN 46032 04-28-1 4.P06 : 18 f V
March 31,2014
Invoice Number 379030
Our File#: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH February 28,2014
01/27/14 TJC Addressed settlement discussions/issues related to LHB; addressed issues related to
0.75 495.00/hr 371.25
02/03/14 BSS Receipt and analysis of SSE's Motion for Summary Judgment,supporting Memorandum
of Law and Designation of Evidence, as well as Motion for hearing on Motion for
Summary Judgment. Strategized regarding response to the same. Correspondence and
strategy regarding responses to supplemental interrogatories. Strategized regarding and
correspondence with opposing counsel regarding Walter P Moore's documentation.
1.75 275.00/hr 481.25
02/03/14 RSS --Analysis of issues related to discovery requests; -- 7-5-41------- --
0..75 415.00/hrr 311.25
02/03/14 RSS Review and analyze issues related to Summary Judgment filed by SSE: follow up on
issues related to the same;
0.50 415.00/hr 207.50
02/03/14 TJC Addressed communication from SSE counsel related to Walter P. Moore files produced.
Receipt and review of SSE's motion for oral argu►nem on partial summary judgment
motion.
0.50 495.00/hr 247.50
�
CRML 00001 Page 2
Invoicefi 379030
02/04/14 BSS Worked on preparing Response to SSE's Partial Motion for Summary Judgment. Worked
on preparing discovery requests to SSE and ' Strategized
regarding theories and arguments in response to SSE's Partial Motion for Summary
Judgment.
1.00 275.00/hr 275.00
02/04/14 RSS Follow up on matters related to summary judgment and discovery;
0.50 415.00/hr 207.50
02/04/14 TJC Detailed review and analysis of SSE's motion for partial summary judgment on the issue
of Worked on outline of evidence to be
designated that refutes SSE's position.
1.50 495.00/hr 742.50
02/05/14 BSS Strategized regarding SSE's Motion for Partial Summary Judgment. Correspondence
regarding SSE's request for document
production.
0.25 275.00/hr 68.75
02/05/14 RSS Correspond and follow up on SSE Discovery matters;review of requests and analyze
issues on the same;
0.50 415.00/hr 207.50
02/06/14 BPH Plan and prepare to draft non-party subpoena duces tecum and non-party requests for
production to=I W&MM Draft Non-Party Subpoena Duces Teeum to
1.75 230.00/hr 402.50
02/06/14 BSS Drafted and revised discovery responses. Strategized regarding supplemental
interrogatories. Analysis of revised damage calculations. Worked on discovery to be
propounded by the CRC to SSE and
0.75 275.00/hr 206.25
02/06/14 RSS Correspond with counsel on matters related to discovery;follow up on the same;
-_`_0_.5 07 41_5.00/hr^ 207.50
02/06/14 TJC Communications with counsel for SSE related to calculations. Detailed review of
deposition excerpts,drawings, photographs and other materials designated and submitted
as evidence in support of SSE's motion for partial summary judgment.
1.70 495.00/hr 841.50
02/07/14 BPH Plan and prepare to draft requests for production to IDraft
and revise requests for production to IM Revise subpoena duces tecum
to 4M SM
2.20 230.00/hr 506.00
02/07/14 BSS Worked on preparing responses to Supplemental Interrogatories prupounded by SSE.
Teleconference with Walter P Moore regarding the draft discovery responses.
0.50 275.00/hr 137.50
CRML 00001 Page 3
Invoice#379030
02/07/14 RSS Call with WPM on matters related to Summary Judgment and Discovery; follow up on
issues related to the same;
0.50 415.00/hr 207.50
02/07/14 RSS Review and analyze issues related WPM discovery and strategy; follow up on issues
related to Summary Judgment and issues on the same;
1.00 415.00/hr 415.00
02/07/14 TJC Receipt of notice of hearing on SSE's motion for partial summary judgment; analysis of
necessary and appropriate extension of time to file response on behalf of CRC,given
hearing date.
0.30 495.00/hr 148.50
02/08/14 RSS Analysis of issues related to strategy and Summary Judgment matters;
0.50 415.00/hr r 207.50
02/09/14 BSS Strategized regarding discovery requests to SSE and revisions to the same. Worked on
response to SSE's Motion for Summary Judgment.
0.50 275.00/hr 137.50
02/09/14 RSS Analysis of matters involving Summary Judgment and discovery;
0.50 415.00/hr 207.50
02/09/14 TJC Worked on open issues related to pending discovery requests,need for a case management
plan and content and timing of our response to SSE's pending motion for partial summary
judgment.
0.50 495.00/hr 247.50
02/10/14 BSS Worked on drafting and revising Motion for Extension of Time to Respond to SSE's
Motion for Partial Summary Judgment and proposed Order. Analysis and strategy related
to SSE's Motion for Summary Judgment. Strategized and corresponded regarding answers
to SSE's Supplemental Interrogatories.
0.50 275.00/hr 137.50
02/10/14 RSS_ Analysis of issues related to matters involvingdiscovery and Motion for Summary
Judgment; follow up on matters related to the same;
1.00 415.00/hr 415.00
02/10/14 TJC Addressed issues related to discovery from SSE,preparation for status conference
(including working on a case management plan) and outlining response and support for
opposition to SSE's motion for partial summary judgment. Coin mun[cations with Walter
1'. Moore on open issues.
0.80 495.00/hr 396.00
02/11/14 BSS Strategized regarding SSC;'s Motion for Summary Judgment,and worked on drafting and
revising Motion for Enlargement of Time to Respond to such Motion and proposed Order
granting the same. Teleconference regarding these issues. Strategized regarding
supplemental discovery requests and seeking additional time for Walter P Moore to work
CRML 00001 Page 4
Invoice#379030
on responses to the same.
0.50 275.00/hr 137.50
02/11/14 RSS Strategize on issues related to matters involving summary judgment and discovery.
0.50 415.00/hr 207.50
02/11/14 RSS Analyze settlement matters with LHB; correspond with Bob Hoffman on the same;
0.50 415.00/hr 207.50
02/11/14 TJC Addressed issues related to settlement discussion with LHB and edited draft settlement
demand on LHB. Receipt of order from court related to case management issues.
Attention to motion for enlargement of time to respond to SSE'motion for partial
summary judgment-including potential effect on case management plan and ultimately
trial date.
1.00 495.00/hr 495.00
02/13/14 GTS Call with Walter P. Moore.
0.25 195.00/hr 48.75
02/13/14 RSS Review and follow up on matters related to discovery and WPM matters;
0.50 415.00/hr 207.50
02/13/14 TJC Communications with Walter P. Moore regarding interrogatory requests related to WPM's
work.
0.40 495.00/hr 198.00
02/14/14 BPH Plan and prepare to draft First Set of Interrogatories to SS&E. Plan and prepare to draft
Second Requests for Production of documents to SS&E. Begin drafting same.
1.25 230.00/hr 287.50
02/14/14 BSS Teleconference with Walter P Moore personnel regarding SSE's Supplemental
Interrogatories and worked on preparing responses to the same. Drafted and revised
Motion for Enlargement of Time to Respond to Motion for Partial Summary Judgment.
0.75 275.00/hr 206.25
02/14/14 RSS Review and follow up on matters related to discovery and WPM matters;
0.50 415.00/hr 207.50
02/14/14 TJC Reviewed, revised and edited draft of motion for enlargement of time to respond to SSE's
motion for partial summary judgment. Participated in lengthy teleconference with Walter
P Moore related to discovery responses, SSE's request for calculation information.
Receipt and response to request for information from SSE.
1.60 495.00/hr 792.00
02/16/14 RSS Review and analyze issues related to W11M discovery and responses to the same; follow
up on issues related to the same;
1.00 415.00/hr 415.00
02/16/14 TJC Addressed issues related to case management plan, pending discovery request for
CRM1.00001 Page 5
Invoice#379030
information from Walter P. Moore and strategy going forward.
0.50 495.00/hr 247.50
02/17/14 BPH Update and revise Non-Party Requests for Production to NAMENIMContinue to
draft Interrogatories and Second Request for Production ofDocuments to SS&E.
1.25 230.00/hr 287.50
02/17/14 BSS Analysis of Walter P Moore documents related to SSE's Second Set of Interrogatories and
worked on preparing and revising written responses to discovery requests. Strategized
regarding 411111MISMssues related to responding to SSE's Second Set of Interrogatories.
Teleconferences with opposing counsel. Strategized regarding WPM's
in support of discovery requests. Teleconferences with Walter P Moore regarding
documents to be identified in discovery responses.
2.75 275.00/hr 756.25
02/17/14 GTS Assist n the preparation of documents in response to interrogatories.
3.75 195.00/hr 731.25
02/17/14 RSS Review and work on WPM discovery; analyze issues on the same;call with WPM on the
same;review and analyze issues related to Interrogatories;call to SSE on the same;
4.50 415.00/hr 1,867.50
02/18/14 BPH Update and revise Request for Production to Analyze
Second Amended Complaint in preparation to update Second Requests for Production to
SS&E. Update and revise Second Requests for Production to SS&E. Strategize regarding
Interrogatories to SS&E in preparation to draft same.
2.25 230.00/hr 517.50
02/18/14 BSS Revisions to Answers to Second Set of Interrogatories and strategized regarding written
answers to the same based prepared
objections based upon these items to be interposed in Answers. Correspondence and
teleconferences with Walter P Moore regarding documents responses to Answers to
Interrogatories. Analysis of Walter P Moore's supplemental report and documents
included therewith.
_ -_ ------_.________------_-.- 2.00 275.00/hr — 550.00
02/18/14 GTS Call with Walter P. Moore. Assist Walter P.Moore with preparing documents in response
to interrogatories.
5.50 195.00/hr 1,072.50
02/18/14 RSS Work on discovery and CMP matters; review and analyze issues related to SJ and matters
on the same; call on matters related to WPM discovery; follow up on the same;
3.00 415.00/hr 1,245.00
02/18/14 TJC Addressed communications from counsel for SSE related to proposed case management
plan.
0.70 495.00/hr 346.50
02/19/14 BPH Draft, edit and revise First Set of Interrogatories to propound upon Defendant SS&E
CRML 00001 Page 6
Invoicet0 379030
relating to defenses made and claims made
1.80 230.00/hr 414.00
02/19/14 BSS Analysis of records responsive to SSE's Second Interrogatories and coordinated with
litigation support personnel and Walter P Moore to prepare production of documents and
facilitated the same to include documents and Bates ranges in written Interrogatory
Answers. Correspondence and strategy regarding these items.
0.75 275.00/hr 206.25
02/19/14 MQ Review and analysis of expert discovery issue.
0.25 440.00/hr 110.00
02/19/14 RSS Follow up on matters related to WPM production and CMP;review and analyze i
supplement production and matters related to report; call to WPM on matters related to the
same;analyze issues related to Summary Judgment and strategy going forward;
3.00 415.00/hr 1,245.00
02/19/14 TJC Status and strategy on production of Walter P. Moore file materials and correlation of case
management conference.
0.20 495.00/hr 99.00
02/20/14 BSS Drafted and revised discovery requests to M Wand Steel Supply and
Engineering. Worked on drafting and revising Motion or Enlargement to Respond to
Motion for Summary Judgment. Worked on preparing documents responsive to SSE's
Second Interrogatories and coordinated with Litigation Support team and Walter P Moore
to produce documents responsive to SSE's requests.
1.25 275.00/hr 343.75
02/20/14 GTS Update responses to Second Set of Interrogatories. Prepare documents for production.
2.25 195.00/hr 438.75
02/20/14 RSS Review and analyze WPM discovery matters related to Supplemental Production and
matters asserted by SSE follow up with WPM on matters related to the
same;review and work on matters related to hearing on Case Management Plan and
-- -- - -- -discovery; -_-._._
3.50 415.00/hr 1,452.50
02/20/14 TJC Status and strategy,prepared for hearing, addressed discovery and summary judgment
issues. Teleconference with Walter P. Moore.
2.50 495.00/hr 1,237.50
02/21/14 BSS Revised Answers to SSE's Second Set of Interrogatories. Extensive communications and
teleconferences with Walter'P Moore. Analysis of documents provided by Walter P
Moore to be produced. Coordinated production of documents responsive to Second Set of
Interrogatories. Teleconference with opposing counsel regarding discovery issues.
Worked on preparing response to SSE's Motion for Partial Summary Judgment.
3.00 275.00/hr 825.00
02/21/14 GTS Calls with Walter P. Moore. Prepare documents for production.
CRML 00001 Page 7
Invoice 379030
4.75 195.00/ht 926.25
02/21/14 RSS Several calls with WPM related to discovery and matters related to the same; review and
analyze issues related to findings,production and issues on Supplemental Report;review
and analyze strategy related to hearing next week; work on the same;
7.00 415.00/hr 2,905.00
02/21/14 TJC Revised and edited draft of discovery response. Addressed issues related to SSE's request
for
Reviewed and analyzed 221MIMaprovided
by Walter P.Moore.
1.20 495.00/hr 594.00
02/24/14 BSS Revised and finalized Motion for Enlargement of Time to Respond to SSE's Motion for
Summary Judgment and proposed Order and filed the same with the Court;strategized and
corresponded regardinglom VNEIIII Drafted and revised supplemental
discovery production to SSE to enclose additional Walter P Moore analysis to articulate
Correspondence and and teleconferences with Walter P Moore regarding analyses and
discovery supplementation. Analysis of Walter P Moore analyses and supporting
documentation;produced the same to opposing counsel for.SSE,, _
Strategized and prepared for hearing before the Court, Correspondence regarding case
management plans proposed by each parties and disputes associated with the same.
2.25 275.00/hr 618.75
02/24/14 GTS Call with Walter P. Moore. Prepare production of documents in support of Interrogatory
response.
1.50 195.00/hr 292.50
02/24/14 RSS Calls with WPM on supplemental discovery responses; review and analyze matters in
preparation of disclosure and production of the same;;prepare supplemental discovery to
SSE,igNIZENOM follow up on matters related to hearing with Judge Nation;
2.50 415.00/hr 1,037.50
02/24/14 TJC Review and analysis of Walter P.Moore's calculations provided for production to SSE and
evaluated impact on arguments to be made at status with court regarding establishment of
a case management plan. Addressed issues related to open discovery and case
management issues.
0.60 495.00/hr 297.00
02/25/14 BSS Teleconference with SSE's counsel regarding discovery issues and items necessary to
proceed with trial setting along with preparing the parties for renewed settlement
disclosures. Strategized regarding SSE's potential for adding
SSE's counsel regarding the same. Revised, finalized, and filed documents with Court to
extend summary judgment deadlines, and confirmed Court's receipt of the same. Prepared
supplemental discovery materials and correspondence to be provided to counsel for LHB
and Shiel Sexton; analysis of issues related to providing materials to such parties.
Strategized regarding settlement discussions with 1,1113.
0.75 275.00/hr 206.25
CRML 00001 Page 8
Invoice#379030
02/25/14 RSS Correspond and follow up with SSE on matters related to ; calls with WPM on
matters related to discovery,production and strategy related to
review and analyze report and matters in preparation of hearing with SSE;
3.50 415.00/hr 1,452.50
02/25/14 TJC Email communications with counsel for SSE and Creviston related to case management
deadlines and issues to be addressed at court conference on Friday. Conference call with
WPM regarding discovery issues and needed support in anticipation of court conference.
Prepared fot court conference.
3.50 495.00/hr 1,732.50
02/26/14 BSS Extensive teleconference with counsel for Steel Supply and Creviston,Inc. to address
myriad discovery disputes associated with Walter P Moore's calculations supporting
deficiencies as well as proposed Case Management Plan. Correspondence and strategy
regarding these issues. Receipt and analysis of supplemental records from Walter P
Moore and prepared production of the same to opposing counsel;drafted correspondence
to such counsel enclosing supplemental documents. Analysis of issues associated with
potential and review of Walter P Moore's report
associated iffillIMM
2.75 275.00/hr 756.25
02/26/14 GTS Prepare documents for production in response to Interrogatories.
1.00 195.00/hr 195.00
02/26/14 RSS Review and analyze matters involving WPM supplemental production; call with WPM on
the same; call with opposing counsel, SSE and Creviston,on matters related to discovery
and CMP;follow up on matters on the same;
3.50 415.00/hr 1,452.50
02/26/14 TJC Teleconference with counsel for SSE and Creviston as required by Court in an effort to
resolve issues related to a case management plan. Attention to issues arising out of
conference call to prepare for Court hearing.
1.10 495.00/hr 544.50
02/27/14 BSS Prepared for February 28 hearing. Analysis of WPM's supplemental report related to
IBM Correspondence and teleconference with opposing counsel regarding
supplemental document production questions.
1.50 275.00/hr 412.50
02/27/14 RSS Analysis of issues for hearing; call with WPM on matters related to hearing; review of
CMP and correspond with SSE on matters related to the same;prepare for hearing; review
and analyze issues on WPM;
4.00 415.00/hr 1,660.00
02/27/14 TJC Prepared for court conference. Strategy on limiting time for SSE
Prepared demonstrative exhibit for use with court to show that SSL;has had
Review and analysis of SSE's proposed CMP. Prepared a redline mark up of defendants'
� jg,IiZZII
- a __
CRML 00001 Pale 9
Invoice#379030
proposed CMP. Communications with Court confirming hearing.
2.30 495.00/fir 1,138.50
02/28/14 BSS Prepared for hearing with Judge Nation regarding case managment plan and discovery
disputes. Analysis of Walter P Moore's supplemental report and corresponding
calculations and documents. Strategized regarding developments at hearing. Revised case
management plan. Correspondence with opposing counsel regarding these issues.
Strategized regarding SSE
1.25 275.00/hr 343.75
02/28/14 RSS Hearing preparation;Review and analyze issues related to matters involving hearing and
issues on the same;calls with WPM on matters related to the same;attend hearing related
to CMP and discovery matters;review and follow up on issues related to hearing and
going forward strategy;
8.00 415.00/hr 3,320.00
02/28/14 SJR Prepare documents for attorney review.
A101 0.80 185.00/hr 148.00
02/28/14 TJC Prepared for court hearing. Teleconference with Walter P.Moore. Participated in court
hearing. Addressed issues raised by Court regarding
identified by Walter P. Moore.
5.10 495.00/hr 2,524.50
Total Fees for this Matter: 133.80 $ 47,901.75
TJC Costakis,Thomas J. 26.75 firs 495.00/hr 13,241.25
BPH Holler, Blake P. 10.50 firs 230.00/hr 2,415.00
MQ Quigley,Marc T. 0.25 firs 440.00/hr 110.00
SJR Roberts, Steven J. 0.80 firs 185.00/hr 148.00
RSS Schein, Robert S. 51.75 firs 415.00/hr 21,476.25
GTS Smith,Gary T. 19.00 firs 195.00/hr 3,705.00
BSS Strawbridge,Bryan S. .24.75 firs 275.00/hr 6,806.25
Total: 133.80 hrs $ 47,901.75
Color Copies 287.00
Federal Express 55.99
Photocopies 12.60
Postage -Express Mail 8.03
"Total Disbursements for this Matter: $ 363.62
TOTAL. FEES: $ 47,901.75
TOTAL..DISBURSEMENTS: $ 363.62
TOTAL CHARGES FOR THIS BILL: $ 48,265.37
CRML 00001 Page 10
Invoice//379030
Less Fee Reduction: $ (750.00)
PLEASE PAY THIS AMOUNT $ 47,515.37
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
:f
Prescribed by State Board of Accounts City Form No.201(Rev.1995)
ACCOUNTS PAYABLE VOUCHER
CITY OF CARMEL
An invoice or.bill to be properly itemized must show: kind of service, where performed, dates service rendered, by
whom, rates per day, number of hours, rate per hour, number of units, price per unit, etc.
Payee
Vl(& Purchase Order No.
Ohe .x- hd/t�h�( s�,Ll�6e . 3q[ �C 2100 Terms
Date Due
Invoice Invoice Description Amount
Date Number (or note attached invoice(s) or bill(s))
4-4-14 381h le ser ` eS ". I' L114, 317 7.
4-29A 379030 IY4 wvieef-ro C dAw 475/S 37
Total
I hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have audited same in accor-
dance with IC 5-11-10-1.6.
20
Clerk-Treasurer
VOUCHER NO. WARRANT NO.
ALLOWED 20
I F
IN $
d he Tndidn4 ,udrP . Suife 2 00
Ihdfdnihi1is: 11Y 41204r 2079
$�.282`�g
ON ACCOUNT OF APPROPRIATION FOR
02-Z 6 0107
Board Members
PO#or INVOICE NO. ACCT#/TITLE AMOUNT
DEPT.# I hereby certify that the attached invoice(s),
la '5811% 4446 07 '3j['76 7 6Z or bill(s) is (are) true and correct and that
1-750,30 U47 t 55-15,'7 the materials or services itemized thereon
for which charge is made were ordered and
received except
5-9 —
S' na u
Cost distribution ledger classification if Title
claim paid motor vehicle highway fund