HomeMy WebLinkAbout071614 PAC claims (7-16-14)DISBURSEMENT OF PAC FUNDS
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Approved July 16, 2014
Approved July 16, 2014
Approved July 16, 2014
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Jeff Worrell, Member
MEMORANDUM
TO: Corrie Meyer, Carmel Redevelopment Commission
FROM: Douglas C. Haney, Carmel City Att
RE: Kreig DeVault Invoice No. 383062
Performing Arts Center Claims
DATE: July 1, 2014
Dear Corrie:
I have personally reviewed the referenced invoice in the amount of $34,401.29 regarding
Performing Arts Center claims. I recommend the Carmel Redevelopment Commission prepare a purchase
order to Kreig DeVault in the amount of $34,401.29 in payment of this invoice as a necessary and proper
expense.
Please let me know IMMEDIATELY if you have any questions regarding this memorandum or
payment of the attached invoice.
Thanks.
DCH /ab
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RIEG I DEVAULT.
Carmel Redevelopment Commission
Les Olds, AIA, Executive Director
30 West Main Street, Suite 220
Carmel, IN 46032
May 22, 2014
Invoice Number 383062
Performing Arts Center Claims
One Indiana Siloam
Suite 2800
Indianapolis, IN 46204-2079
T: 3 I 7.636.4341
17: 317.636.1507
Fed. EIN 11 35-1055087
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Our File #: CRML 00001 ABB
FOR PROFESSIONAL SERVICES RENDERED TI-IROUCIH April 30, 2014
04/01/14 BPI-I Analyze prior discovery requests to Creviston in preparation to draft new discovery
requests. Analyze third party complaint against Creviston, Analyze affirmative defenses
of Creviston in preparation to draft additionally discovery requests. Draft and revise First
Set of Interrogatories to Creviston.
2.30 230.00 /hr 529.00
04/01/14 BSS Worked on drafting and revising Response to Defendants' motion for partial summary
judgment as well as cross-motion for partial suminary judgment. Researched case law and
issues for inclusion therein. Worked on preparing designation of evidence and exhibits for
inclusion in cross-motion.
3.00 275.00 /hr 825.00
04/01/14 RSS Follow up with WPM on matters related to summary judgment.
0.25 415.00 /hr 103.75
04/02/14 BSS Teleconferences with expert for Walter P Moore. Research regarding Response to Motion
for Summary judgment. worked on drafting argument section for the Cross-Motion for
Summary Judgment. Analysis of Walter P .Moore's findings and support related to
Response brief and Cross-Motion.
3.25 275.00 /hr 89175
04/02/14 RSS Analysis of discovery related matters.
0.50 415. /hi 207.50
INDIANA GEOROLA FLOID k MINT,IESO'r*A
CRNLOVOO|
Invoicell 383062
04/03/14 BSS
Page 2
Worked on drailing and rcvising Statement of Facts, Surnmary of Argument, Summary
Judgrnent Standard, and Argument sections to Mernorandurn ofLaw in Support of Cross
Motion for Partial Sumrnary Juclgment. Researched various issues and argurnenls in
support of thereof Worked on preparingpesignation of Evidence and exhibits to be
attached thereto in support of Cross-Motion. Correspondence and strategy regardrng these
issues. Teleconferences with experts from Walter P Moore regarding arguments in
support of Cross-Motion. Prepared affidavit of
7.50 275,00 /hr
2,062.50
04/04/14 BP1-1 Strategize regarding diseovery responses and necessary to
supplement prior dinxovory responses.
04/04/14 BSS
04/04/14 TJC
04/07/14 BSS
04/07/14 RSS
04/07/14 RSS
04/07/14 TJC
04/08/14 BSS
0.30 230,00 /hr 69.00
Worked on preparing oou-yady discovery requests requests t Drafted and
revised discovery recluests 10 Creviston and Steel Supply. Worked on drafti and revising
argument section to Memorandum in Support of Cross Motion for Summary Judgment
and Response Response to Defendants MnonrondumofIazvioSoppuriof1bnirModnoIbmPmdiu]
Summary Judgment. Prepared exhibits and Designation ofEvidence in Support ofthe
CRC's Cross Motion for Partial Summary Judgment. Teleconferences with Walter P
Moore regarding draft response to SSE's Motion for Partial Summary Judgment.
5.50 275.00 /hr 1'512.50
Attention to scheduling of Walter P Moore depositions. depositions. Revicw and analysis of materials
ided by WPM to be used in summary judgment briefing.
1.00 495.00 /hr
Extended teleconference with Walter P Moore regardi to the partial motion
for summary judgment as wclI as arguments to be asserted in cross motion for partial
summary judgment. Worked on drafting and revising argument section for cross motion
for surnrnary judgrnent. Researched issues regarding 10 arliculate in
brief. Correspondence and strategy regarding adjusting the timeline for hearing on cross
000doun for summary judgment as well as deadlines for briefing ofthe same.
4.75 275.00 /hr 1,30625
Call with Bob Hallman onmatters related to settlement and summary judgment
allegations by SSE; rcvicw and follow up on issues on the sarne.
1.00 415.00 /lir
415.00
Revicw and analyze issues related to WPM rnatters on Summary Judgment and issues on
the same, follow up on rnattcrs related to the same; calI with WPM on Summary Judgment
matters, strategy and deposition matters; review and analyze issues related to the sarne.
4.00 415,00 /fir 1.660.00
Addressed issues related to scheduling of 'Walter P Moore depositions and preparation of
summary judgment pleadings. Participated in conference call with Walter PMoore
regarding status and strakgy. FoUowup strategy sosoiwo,
VVorked on dratling and revising response hnef in support of COSS molion for partial
CRML, 00001
Invoice# 383062
Page 3
summary judgment. Analysis of materials provided by Walter P Moore in support thereof.
Research of various issues regarding steel construction statutory provisions.
2,25 275.00 /hr 618.75
04/08/14 RSS Correspond with counsel on SSE Motion for Summary Judgment.
1.50 415.00 /hr 622.50
04/08/14 `LTC Attention to issues related to summary judgment hearing and timing of depositions of
WPM representatives.
0.40 495.00 /hr 198.00
04/09/14 BSS Teleconference with experts from Walter P. Moore regarding additional arguments and
materials for response brief. Revised and drafted additional arguments for argument
section to cross motion for partial summary judgment. Analysis of
1.25 275.00 /hr 343.75
04/09/14 RSS Call with SSE counsel on Summary Judgment and deposition matters; review and analyze
issues related to Summary Judgment; follow up on the same.
1.50 415.00 /hr 622.50
04/10/14 BSS Drafted and revised Designation of Evidence, Motion for Partial Summary Judgment,
Affidavit of and supporting documentation. Worked on drafting and revising
argument section to Memorandum of Law in Support of Motion for Partial Summary
Judgment. Analysis of and onstruction provided by Walter
P Moore.
2.75 275,00 /hr 756.25
04/10/14 RSS Analysis of issues on Summary Judgment and arguments related to Code; review and
work on strategy for Summary Judgment; analysis of issues related to Protective Order
and matters related to Discovery.
2.50 415.00 /hr 1,037,50
04/10/14 TIC Addresses issues rclated to summary judgment briefing, hearing and WPM depositions.
0.20 495.00 /hr 99.00
04/11/14 BSS Drafted and revised argument section of brief in support of cross motion .for irtial
summary judgment, specifically addressing issue of SSEs
Prepared exhibits to designation of evidence in support
cross-motion. Strategized regarding inclusion of arguments related to
2.75 275.00 /hr 756.25
04/11/14 MQ Review and analysis of issues regarding protection of expert -witness data and computer
programs. Provided samples of possible protective order regarding same.
0.50 440.00 !hr 220,00
04/11/14 RSS Analysis of issues related to Summary Judgment; call with counsel on matters related to
the same; analysis [4' issues related to Protective order.
2.50 415.00 /hr 1.037.50
CRML 00001
Invoicell 383062
04/11/14 TJC Communications with SSE and Creviston counsel related to summary judgment
proceedings and depositions of WPM representatives.
Page 4
0.20 495,00 /hr 99.00
04/14/14 BP1-1 Review and analyze for privileged and confidential information and redact the same in
preparation for production of invoices related to attorneys fees as a part of total damages.
0.70 230.00 /hr 161.00
04/14/14 BSS Drafted and revised Motion for Extension of Time to Respond to SSE's Motion for Partial
Summary Judgment and proposed Order and strategized and corresponded regarding the
same. Analysis of Court's docket and conferred with Court staff.
0.50 275.00 /hr 137.50
04/14/14 RSS Analysis of issues related to depositions and WPM matters; follow up on the same with
SSE; analysis of issues related to Summary Judgment and hearing matters; review of
matters related to the same.
1.50 415.00 /hr 622.50
04/14/14 TJC Addressed issues related to summary judgment and deposition of Walter P Moore,
Communications with counsel for SSE and Creviston.
0.50 495.00 /hr 247.50
04/15/14 BPI-1 Perform review of invoices for privileged and confidential attorney client communications
and attorney work product in preparation to produce the same in conjunction with
supplemental discovery requests. Perform review of communications between firm
personnel and Walter P Moore for privileged communications in preparation for the same.
Consult with litigation support regarding preparations for production.
6.20 230.00 /hr 1,426.00
04/15/14 RSS Analysis of issues related to Summary Judgment; follow up on the same; review of
discovery matters; review and analyze depositions and follow up with WPM on same.
2.00 415.00 /hr 830.00
04/15/14 TJC Addressed issues related to potential need for protective order for software used by Walter
P Moore to perform calculations. Communications with opposing counsel regarding
scheduling issues.
0.50 495.00 /hr 247.50
04/16/14 BPH Perform review of invoices for privileged and confidential attorney client communications
and attorney work product in preparation to produce the same in conjunction with
upplemental discovery requests Perform review of communications between firm
personnel and Walter P .Moore for privi leged communications in preparation for the same.
Coordinate preparation for productions of documents. Strategize regarding formal written
responses to supplementary discovery requests.
6.90 230,00 /hr 1,587.00
04/1 6/14 RSS Work on matters related to Summary Judgment; call with opposing co unsel on disco-very
matters related 10 VVPM; analysis of issues on the same.
OWL, 00001
Invoice# 383062
Page 5
2.25 415.00 /hr 933.75
04/16/14 TJC Receipt and review of motion filed by SSE to continue summary judgment hearing.
Follow
on open discovery issues.
0.20 495.00 /hr 99.00
04/17/14 BPH Stratcgize regarding privileged and confidential attorney/client correspondence in
conjunction with certain enrails and attachments with Walter P Moore in preparation for
supplemental production of documents. Review and analyze invoices for attorney work
product information and attorney client information in preparation to produce same.
Strategize regarding written responses to supplemental requests and prepare to draft same.
3.50 230.00 /hr 805.00
04/17/14 BSS Strategized regarding discovery responses. Worked on memorandum of law in support of
cross-motion for partial summary judgment.
1.00 275.00 /hr 275.00
04/17/14 RSS Review and analyze matters involving discovery to SSE; review and work on deposition
matters; review and draft Agreed Protective Order motion; follow up on depositions with
opposing counsel; analyze strategy matters.
2.50 415.00 /hr 1,037.50
04/17/14 TJC Addressed issues related to need for a protective order, potential privilege claim on
materials prepared by Walter P Moore and deposition scheduling. Revised and edited
draft of motion to extend deadline by which to implement a protective order.
1.00 495.00 /hr 495.00
04/18/14 BPH Draft Carinel's response to Defendants' supplement requests for production pertaining to
Walter P Moore communications and and darnages documentation. Finalize review of
invoices for attorney work product information and privileged information and prepare to
redact same. Update and finalize damages calculations spreadsheets in preparation for
production. Coordinate addition of all documents onto electronic database in preparation
to redact privileged information and produce the same.
4.90 230.00 /hr 1,127.00
04/18/14 RSS Follow up on Protective Order matters and discovery; analyze issues on the same; file
Motion with Judge Nation on Protective Order matters.
1.00 415.00 /hr 415.00
04/18/14 SJR Prepare documents and upload into Relativity database for attorney review.
A101 1.00 185.00 /hr 185.00
04/2I/14 .B11 I Update and revise responses to SS&E's supplemental requests for production and
interrogatories. Review responsive documents and redact privileged and work product
information in .preparation to produce same. Coordinate production of responsive
documents with litigation support. VIuIiipIc correspondence regarding same. Produce
responses and responsive documents to opposing counsel.
4.30 230.00 /hr 989.00
CRML 00001
lavoiceti 383062
Page 6
04/21/14 BSS Worked on revising supplemental discovery responses pursuant to Steel Supply's request.
Arialysis of and revisions to written discovery responses. Correspondence Corrcspondencc 10 opposing
counsel. Coorclination of discovery document supplementation. Analysis and review to
_________g���ug and revisions
1.25 275.00 /hr 343.75
04/2184 GTS Prepare production of docurnents in Response to Request for production.
3.25 195.00 /fir 633.75
04/21/14 RSS 'Rcview of CRC Discovery; analyze the same; correspond with Bill 'Hammer on the same.
1.00 415.00 thr 415.00
04{21/}4 TJC Reviewed draft of supplemental interrogatory answers, including current damages
oalculation.
0.30 495.0O 8u 148,50
04/22/14 BSS Receipt and analysis of orders from court extending briefing deadiiiies on the motions For
summary judgment as well as rescheduling the hearing on the same. Worked on drafting
memorandum of Law in support of cross motion for partial summary judgment and
strategized/corresponded regarding issues and arguments for inelusion therein.
2'00 275.00 /hr 550.00
04/22/14 TJC Receipt and review of court order re-setting deadlines for response and hearing related to
SSEs motion for partial summaryjudgment.
0.20 495.00 /hr 99.00
04/22/14 BSS Worked on preparing supplemental discovery requests to Sieel Supply and
Analysis of supplemental document production and responses to Steel Supply in response
to their requests for discovery supplernentation. Strategized regarding written responses
and worked on revising the same.
0.75 275,00 /hr 206.25
04/25/14 BSS Analysis of supplemental discove responses and strategized regarding the same.
Researched issues related to for memorandum of law iosupport of cross-
motion
04/25/14 RSS Fol!ow up on matters rclated to depositions und discovery.
0.75 275.00 /hr 206.25
0.25 415.00 /hr 103,75
04/28/\4 BSS Drafted and revised argument section to memorandum of Law in supy..)ort of cross motion
for partial summary judgment Prepared exhibits and appendices |o designation of
evidence. Correspondence with opposing uzunxc regarding document production issues
and confidential nature o[ certain documents; analysis o{yuppbmcmNlpn/dumtionnJu\u]
to the same.
0e1/28/1 RSS Analysis of issues related to summary judgment 'natters.
I50 275.00 /hr 962.50
0.50 415.00 /hr 207.50
CRML 00001
Invoice 383062
Page 7
04/29/14 Bill Attention to discovery issue regarding documents recently produced and correspondence
regarding SEI Me.
0.25 230,00 /hr 57.50
04/29/14 BSS 'Teleconference and emails with Steel Supply's counsel regarding supplemental production
by Carmel and strategized regarding certain documents addressed therein. Worked on
drafting and revising memorandum of law in support of cross motion for partial summary
judgment. Strategized regarding discovery supplementation.
1.00 275.00 /hr 275.00
04/29/14 RSS .Review and follow up on deposition matters; analyze issues raised by SSE regarding
discovery; follow up on the same.
0.50 415.00 /hr 207.50
04/29/14 TJC Receipt and review of amended witness and exhibit lists filed by SSE.
0.30 495.00 /hr
04/30/14 RSS Strategize for summary judgment response.
1.00 415,00 /hr 415.00
04/30/14 TJC Analysis of impact of SSE's decision to not name s additional third
party defendants.
TJC Costakis, Thomas J.
BPLI Holler, Blake P.
MQ Quigley, Marc T.
SJR Roberts, Steven J.
RSS Schein, Robert S.
GTS Smith, Gary T.
BSS Strawbridge, Bryan S.
Federal Express
Photocopies
0.20 495.00 /hr 99.00
Total Fees for this Matter: 111 .50 $ 34,377.25
7.40 hrs 495.00 /hr 3,663.00
29.35 hrs 230.00 /hr 6,750.50
0.50 hrs 440.00 /hr 220.00
1.00 hrs 185.00 /In' 185.00
26.25 hrs 415.00 /hr 10,893.75
3.25 hrs 195.00 /hr 633,75
43.75 hrs 275.00 /hr 12,031.25
Tota l: 111.50 hrs $ 34,377.25
18.04
6.00
'otc Disbursements for tInv. Matter:
.FOFAL FEES: 34,377.25
TOTAL DISBURSEMENTS: 24.04
e1 UrAL IARGES 1 OR TI118 BILL: 34.401.29