HomeMy WebLinkAbout235142 07/22/14 +pr.C.1A'4
�� CITY OF CARMEL, INDIANA VENDOR: 00353406
" ONE CIVIC SQUARE KRIEG DEVAULT CHECK AMOUNT: $****34,401.29*
CARMEL, INDIANA 46032 ONE INDIANA SQUARE,STE 2800 CHECK NUMBER: 235142
9.H[,.__.: r INDIANAPOLIS IN 46204 CHECK DATE: 07/22/14
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DEPARTMENT ACCOUNT PO NUMBER INVOICE NUMBER AMOUNT DESCRIPTION
902 4460807 383062 34,401.29 PERFORMING ARTS CENTE
One Indiana SgUarc
I�R I EG D E VAU LT Suile 2R00
Indianapolis,IN 46204-2079
T:317.636.4341
(::317.636.1507
Fcd.r1N 9 35-1055087
IMNO
Carmel Redevelopment Commission
Les Olds,ATA,Executive Director
30 West Main Street,Suite 220
Carmel,Il*1 46032 0 6-3-"-'1 4 P 0 7: 3 4 R VD
May 22,2014 _I
Invoice Number 383062
Our Dile#:C"RML 00001 .ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH April 30,2014
04/01/14 BPH 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 summary 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 Air 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 Cruss-Motion for
Summary Judgment. Analysis of Walter 1'Moore's findings and support related to
Response brief and Cross-Motion.
3.25 275.00/hr 893.75
04/02/14 RSS Analysis of disco•very.related matters.
0.50 415.00!hr 207.50
TNIDIANA ILLINOIS GEORGIA
CRML 00001 Page 2
lnvoicet!383062
04/03/14 BSS Worked on drafting and revising Statement of Facts,Summary of Argument,Summary
Judgment Standard,and Argument sections to Memorandum of Law in Support of Cross
Motion for Partial Summary Judgment.Researched various issues and arguments in
support of thereof. Worked on preparing Designation of Evidence and exhibits to be
attached thereto in support of Cross-Motion. Correspondence and strategy regarding these
issues. Teleconferences with experts from Walter P Moore regarding arguments in
support of Cross-Motion.Prepared affidavit ofd.
7.50 '275.00/hr 2,062.50
04/04/14 BPI=1 Strategize.regarding discovery responses and damages documentation necessary to
supplement prior discovery responses.
0.30 230.00/hr 69.00
04/04/14 BSS Worked on preparing non-party discovery requests to OwDrafted and
revised discovery requests to Creviston and Steel Supply.Worked on drafting and revising
argument section to Memorandum in.Support of Cross Motion for Summary Judgment
and Response to Defendants'Memorandinn of Law in Support of their Motion for Partial
Summary Judgment. Prepared exhibits and Designation of Evidence in Support of-the
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
04/04/14 TJC Attention to scheduling of Walter P Moore depositions. Review and analysis of materials
provided by WPM to be used in summary judgment briefing.
1.00 495.00/hr 495.00
04707/14 BSS Extended teleconference with Walter P Moore regarding responding to the partial motion
for summary judgment as well as arguments to be asserted in cross motion for partial
summary judgment. Worked on drafting and revising argument section for cross motion
for summary judgment. Researched issues regarding to articulate in
brief. Correspondence and strategy regarding adjusting the timeline for hearing on cross
motions for summary judgment as well as deadlines for briefing of the same.
4.75 275.00/hr 1,306.25
04/07/14 RSS Call with Bob Hoffman on matters related to settlement and summary judgment
allegations by SSE;review and follow up on issues on the same.
1.00 415.00/hr 415.00
04/07/14 RSS Review and analyze issues related to WPM matters on Summary Judgment and issues on
the same;follow up on matters related to the same;call with WPM on Summary Judgment
matters,strategy and deposition matters; review and analyze issues related to the same.
11.00 415.00/hr 1,660.00
04/07714 TX Addressed issues.related to scheduling of Walter P Moore depositions and preparation of
sumrrrcu•y Judgment pleadings. Parlicipated in conference callwith Walter P.Moore
regarding stain%and stralegy. Follow up strategy session.
2.40 495.00/hr 1,188.00
04/08/14 BSS Worked on drafting and revising response brief in support of cross motion'for partial
CRML 00001 Page 3
Invoiced 383062
summary judgment.Analysis o#: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 VC Attention to issues related to summary judgment hearing and tinning 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 Surninary 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 of4610and 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 toProtective Order
and matters related to Discovery.
2.50 415.00/hr 1,037.50
04/10/14 TJC Addresses issues related 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 partial
summary judgment,specifically addressing issue of SSEs
Prepared exhibits to designation of evidence in support of
cross-motion. Strategized regarding inclusion of arguments related to�
2.75 27.5.00/hr 756.25
04/11114 MQ Rt^view and analysis of issues regrading protection of expert witness data and computer
progrrrrrs. Provided samples of possible protective order regarding same.
0.50 440.00 Air 2.20.00
04/11/14 RSS Analysis of issues related to Summary Judgment;call with counsel on mattmrs related to
the carne; analysis orf issues related to Protective order.
2.50 415.00/hr 1.037.50
C'RML 00001 Paige 4
Invoicc!!383062
04/11/14 TIC Communications with SSL-'and Creviston counsel related to summary judgment
proceedings and depositions of WPM representatives.
0.20 495.00/hr 99.00
04/14/14 BPH 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 SSEs'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 41.5.00/hr 622.50
04/14/14 TIC 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 BPH Perform Yeview ufinvoices 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 TIC 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
supplemental discovery requests. Perform review of communications between-firm
personnel and Walter Y Mo'ore for privileged communications in preparation for the same.
Coordinate preparation for productions ofdoculrrcnts. Strategize regarding fbrmal written
responses to supplementary discovery requests.
6.90 230.00/hr 1,587;00
04/16/14 RSS Work on fnatter:s related to Summary Judgrnclll, call with opposing counsel on discovery
matters related to WPM; analysis of issues on the same.
CRML 00001 Page 5
invoice#383062
2.25 415.00/hr 933.75
04/16/14 TJC Receipt and review of motion tiled by SSE to continue summary judgment hearing.
Follow upup_.on open discovery issues. _
0.20 495.00/hr 99.00
04/17/14 BPH Strategize regarding privileged and confidential attorney/client correspondence in
conjunction with certain emails 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 27s:o0
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
Walter.P Moore and de . Revised and edited deposition scheduling,materials prepared by P g
ct'
draft of motion to extend deadline by-which to.implement a protective order.
1.00 495.00/lu• 495.00
04/18/14 BPH Draft Carmelfs response'to Defendants supplement requests for
reduction pertaining
to
Walter P Moore communications and and damages 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.O0/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.
A t 0 i 1.00 185.00/hr 185.00
04121/14 .BP11 Update incl revise responses to SS& "s supplemental.requests-for production and
.interrogatories. Review responsive documents and redact privileged and work product
inforination in preparation to produce same. Coordinate production of responsive
documents with Iiiigation support. 1Vlultiple correspondence regarding same. Produce
responses and-responsive documents to opposing counsel.
4.30 230.O0/hr 989.00
CRML 00001 Page 6
Invoice#383062
04/21/14 BSS Worked on revising supplemental discovery responses pursuant to Steel Supply's request.
Analysis of and revisions to written discovery responses. Correspondence to opposing
counsel. Coordination of discovery document supplementation. Analysis and review to
damages calculations and revisions thereto.
� 1.25 275.00/hr 343.75
04/21/14 GTS Prepare production of documents in Response to Request-for production.
3.25 195.00/1-ir 633.75
04/21/14 RSS Review.of CRC Discovery;analyze the same;correspond with Bill l-lammer on the same.
1.00 415.00/hr 415.00
04/21/14 TIC Reviewed draft of supplemental interrogatory answers,including current damages
calculations.
0.30 495.00/hr 148.50
04/22/14 BSS Receipt and analysis of orders from court extending briefing deadlines on the motions for
summary judgment as well as rescheduling the hearing on the same.Worked on draflsng
memorandum of Law in support of cross motion for partial summary judgment and
strategized/corresponded regarding issues and arguments for.inclusion therein.
2.00 275.00/hr 550.00
04/22/14 TIC Receipt and review of court order re-setting deadlines formsponse and hearing related to
SSE's motion for partial summary judgment.
0.20 495.00/hr 99.00
04/23/14 BSS Worked on preparing supplemental discovery requests to Steel Supply and non_parties.
Analysis of supplemental document production and responses-to Steel Supply in response
to their requests for discovery supplementation. Strategized regarding written responses
and worked on revising the same.
0.75 275.00/hr 206.25
04/25/14 BSS Analysis of supplemental discovery responses and strategized regarding the same.
Researched issues related to for memorandum of law in support or cross-
motion for summary judgment.
0.75 275.00/hr 206.25
04/25/14 RSS Follow up on matters related to depositions and discovery.
0.25 415.00/hr 103.75
014/28/14 1.355 Drafted and revised argument section to memorandum- of Law:in support of cross motion
for partial summary judgme.nt. Prepared exhibits and appendices to designation of
evidencr.. Correspondence with opposing counsel regarding document production issues
and confidential nature of certain documents;analysis of supplemental production related
to the same.
3.50 275.00/1ir 962.50
Ott/28/14 RSS Analysis of issues related to sumniary judgment matters.
0.50 415.00/hr 207.50
CRML 00001 Page 7
Invoiced 383062
04/29/14 BP1l Attention to discovery issue regarding documents recently produced and correspondence
regarding same.
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
and revising memorandum of law in support of cross motion for partial summary
drafting g P"P
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/fir 207.50
04/29/14 TJC Receipt and review of amended witness and exhibit lists filed by SSE.
0.30 495.00/hr 148.50
04/30/14 RSS Strategize for summary judgment response,
1.00 415.00/fir 415..00
04/30/14 TJC analysis of impact of SSE's decision to not name was additional third
party defendants.
0.20 495.00/hr 99.00
Total Fees for this Matter: 111.50 $ 34,377.25
TJC Costakis,'fhomas J. 7.40 hrs 495.00/hr, 3,663.00
BPH Holler,Blake P. 29.35 hrs 230.00/hr 6,750.50
MQ Quigley,Marc T. 0.50 hrs 440.00/hr 220.00
SJR Roberts,Steven J. 1.00 hrs 185.00/lir 185.00
RSS Schein,Robert S. 26.25 hrs 415.00/hr 10,893.75
GTS Smith,Gary T. 3.25 hrs 195.00/1u• 633.75
BSS Strawbridge,Bryan S. 43.75 hrs 275.00/hr '12,031.25
"Total: 111.50 hrs $ 34,377.25
Federal Express 18.04
Photocopies 6.00
'total Disbursements for this Matter:
TOTAL FEES: $ 34,377.25
TOTAL DISBURSI-MENTS: $ 24.04
TOTAL CHARGES FOR THIS BILL: $� 34,401.29
r
Prescribed by State Board of Accounts ACCOUNTS PAYABLE VOUCHER City Forth No.201(Rev.1995)
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
Kri C 9 be 4A Purchase Order No.
J
dne IndunA 3!1'ure , Sul�e 2900 Terms
A kn a l i s 4 6 zo q -2079 Date Due
Invoice Invoice Description Amount
Date Number (or note attached invoice(s) or bill(s))
5-22 I93 0 6Z 3
Total ya 9
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
Kki,
�9 Pe " IN SUM OF $
nP InIikhS -Mr-e : 5�6f�
ON ACCOUNT OF APPROPRIATION FOR
Board Members
Po#or INVOICE NO. ACCT#/TITLE AMOUNT
DEPT.# ee I hereby certify that the attached invoice(s),
6Z 67024 1029 or bill(s) is (are) true and correct and that
the materials or services itemized thereon
for which charge is made were ordered and
received except
7-2f 201
Si atupO
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Cost distribution ledger classification if Title
claim paid motor vehicle highway fund