HomeMy WebLinkAbout237439 09/23/14 CITY OF CARMEL, INDIANA VENDOR: 00353406
ONE CIVIC SQUARE KRIEG DEVAULT CHECK AMOUNT: $***161,648.02*
CARMEL, INDIANA 46032 ONE INDIANA SQUARE,STE 2800 CHECK NUMBER: 237439
INDIANAPOLIS IN 46204 CHECK DATE: 09/23/14
DEPARTMENT ACCOUNT PO NUMBER INVOICE NUMBER AMOUNT DESCRIPTION
902 4460807 384593 92,228.63 PERFORMING ARTS CENTE
902 4460807 388098 103.75 PERFORMING ARTS CENTE
902 4460807 388114 69,315.64 PERFORMING ARTS CENTE
• One Indiana Square
KMIEGDEVAULT Suite 2800
Indianapolis,IN 46204-2079
T:317.636.4341
F:317.636.1507
Fed.EIN#35-1055087
WWW.KRIEGDEVAULT.CO1M
Carmel Redevelopment Commission
Les Olds,AIA,Executive Director
30 West Main Street, Suite 220
Carmel,IN 46032 0II-20-14PQ5'03 RCVG
-2�
July 25,2014
Invoice Number 388114
Our File#: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH June 30,2014
06/02/14 BPH Strategize with Mr. Schein regarding discovery issues in light of expert depositions. Draft
Notice to Court regarding Agreed Protective Order in conjunction with deadline for the
same.
0.90 230.00/hr 207.00
06/02/14 RSS Follow up on matters related to discovery and issues involving summary judgment;
analysis of issues on the same;
0.75 415.00/hr 311.25
06/02/14 TJC Addressed open items following depositions and in preparation for summary judgment
hearing. Receipt and review of communications from SSE counsel regarding
demonstrative exhibit to be used at summary judgment hearing. Finalized_notice to court
regarding protective order deadline.
0.70 495.00/hr 346.50
06/03/14 RSS Analysis of legal strategy and matters going forward; call with Corrie Meyer related to the
same; follow up with Bill Hammer as well related to the depositions; follow up on matters
related to summary judgment and strategy on the same;call with WPM on matters related
to case;
2.00 415.00/hr 830.00
06/06/14 GTS Analyze data received from SSE in preparation for expert review.
0.50 195.00/hr 97.50
ILLINOISINDIANA • FLORIDAMINNESOTA
CRML 00001 Page 2
Invoice#388114
06/06/14 RSS Review and analysis of issues related to matters involving summary judgment and
arguments related to it; follow up on issues related to claims by SSE and review of the
same;calls with WPM on matters related to strategy;
2.50 415.00/hr 1,037.50
06/06/14 TJC Teleconference with WPM. Reviewed SSE's demonstrative mock up of the tension ring
connection.
1.00 495.00/hr 495.00
06/08/14 GTS Review and index documents from SSE in preparation for attorney review.
1.00 195.00/hr 195.00
06/09/14 BPH Analyze deposition transcript of Mr.Bouadi regarding. Strategize regarding discovery to
propound upon SSE regarding same. Draft and revise Interrogatories to SS&E. Draft and
Revise Re uests for production to SSE. Draft Requests for Admission to SSE relating to
1.70 230.00/hr 391.00
06/09/14 GTS Prepare documents for attorney review.
0.25 195.00/hr 48.75
06/09/14 RSS Analysis of issues related to summary judgment, strategy and matters going forward; call
with Matt Hinkle regarding LHB matters; call with Mike Anderson regarding matters
involving case; calls with WPM on matters related to issues discovery and summary
judgment claims; strategize on issues related to summary judgment;
2.50 415.00/hr 1,037.50
06/09/14 TJC Attention to issues related to discovery,'
0.50 495.00/hr 247.50
06/10/14 BPH Strategize with Litigation Support regarding production documents 4941
0.50 230.00/hr 115.00
06/10/14 GTS Review and analyze drawing disc from SSE.
0.25 195.00/hr 48.75
06/10/14 RSS Calls with WPM on matters related to summary judgment and discovery;review of issues
related to the same; call with SSE counsel on discovery matters; analysis of issues on the
same;
3.00 415.00/hr 1,245.00
06/10/14 TJC Communications with SSE counsel regarding "released for fabrication" shop drawings.
0.20 495.00/hr 99.00
06/11/14 BPH Coordinate review of documents relating to
CRIAL 00001 Page 3
Invoice#388114
0.80 230.00/hr 184.00
06/11/14 GTS Plan and prepare for review of documents received from SSE.
0.75 195.00/hr 146.25
06/16/14 RSS Work on matters related to summary judgment; analysis of issues on the same;strategize
on arguments and matters going forward;review and analyze SSE filings and matters on
the same;
3.50 415.00/hr 1,452.50
06/16/14 TJC Prepared for summary judgment. Status and strategy on discovery and expert matters.
1.00 495.00/hr 495.00
06/17/14 BPH Revise discovery requests to propound upon SSE in response to depositions of Mr.Bouadi
and Mr. Griffis.
0.30 230.00/hr 69.00
06/17/14 RSS Call with WPM on matters related to Summary Judgment hearing;review and analyze
issues on the same; strategize regarding matters going forward and preparation of
Summary Judgment;
3.50 415.00/hr 1,452.50
06/17/14 TJC Lengthy teleconference with Walter P Moore representatives in preparation for summary
judgment hearing.
2.00 495.00/hr 990.00
06/18/14 MQ Review and analysis of summary judgment issues including designation and possible
additions for reply.
0.25 440.00/hr 110.00
06/18/14 RSS Call with SSE counsel on matters related to case, Summary Judgment and settlement
matters;analyze issues on the same;review of matters related to Summary Judgment;
correspond with Corrie Meyer on matters related to case; call with WPM on matters
related to Summary Judgment and issues going forward;
3.00 415.00/hr 1,245.00
06/18/14 TJC Addressed issues related to settlement discussions and summary judgment. Worked on
status report to client.
0.70 495.00/hr 346.50
06/19/14 RSS Analyze strategy matters; work on matters related to summary judgment and hearing;
prepare for the same;
1.50 415.00/hr 622.50
06/20/14 RSS Review of matters related to summary judgment hearing; analysis of issues on the same;
review and strategize on legal arguments for summary judgment hearing;prepare for the
same;
4.50 415.00/hr 1,867.50
I
CRML 00001 Page 4
Invoice#388114
06/21/14 RSS Strategize and work on summary judgment matters;analysis of issues and review of
matters on the same;
3.00 415.00/hr 1,245.00
06/22/14 RSS Work on summary judgment brief and arguments for the same;
2.50 415.00/hr 1,037.50
06/23/14 MQ Review and analysis of summary judgment reply brief.
0.25 440.00/hr 110.00
06/23/14 RSS Review and work on summaryjudgment matters; call with WPM on matters related to
Summary Judgment; analysis of issues on the same;review of SSE's Response Brief and
Reply Brief and analyze issues on the same;review and analyze issues related to Motion
and Brief to Strike Larry Griffis'affidavit; analyze issues on the same;
8.50 415.00/hr 3,527.50
06/23/14 TJC Review and analysis of SSE's brief in further support of its motion for partial summary
judgment and in opposition to Carmel's motion for partial summary judgment. Outlined
portion of argument to address SSE's points.
1.40 495.00/hr 693.00
06/24/14 BPH Analyze SSE's Reply in Support of Motion for Partial Summary Judgment in preparation
for summaryjudgment hearing. Receipt and analysis of Motion to Strike Affidavit of
Griffis in preparation to respond to same. Strategize regarding arguments in response with
Mr. Schein. Perform legal research regarding cases cited in motion to strike and reply
brief in preparation to draft responses to same.
2.50 230.00/hr 575.00
06/24/14 MJM Address issues for SJ Motion-challenges to expert affidavit. Analysis of claims and
strategy.
1.00 495.00/hr 495.00
06/24/14 MQ Review and analysis of summary judgment issues, including possible reply brief.
Analyzed response to Motion to Strike Expert Report. Worked on strategy for responding
to same.
1.50 440.00/hr 660.00
06/24/14 RSS Non-charge: Review and analyze issues related to Motion to Strike Affidavits and work on
the same;
2.00 415.00/hr 0.00
06/24/14 RSS Analysis of issues related to Reply Brief and Motion to Strike Affidavits; review and work
on responses to the same; prepare arguments for summary judgment;review and analyze
issues raised by SSE;prepare for the same; calls with WPM on matters related to the
same; strategize for hearing;
10.50 415.00/hr 4,357.50
06/24/14 TJC Review and analysis of SSE's Motion to Strike Affidavit of Griffis, Brief in Support and
Supplemental Designation of Evidence. Worked on outline of summary judgment
CRML 00001 Page 5
Invoice#388114
argument and response to motion to strike affidavit of Larry Griffis. Prepared for hearing
on summary judgment motions.
4.00 495.00/hr 1,980.00
06/25/14 BPH Analyze SSE's response in opposition to our Motion for Summary Judgment. Analyze
SSE's motion to strike affidavit of Larry Griffis. Strategize regarding potential responses
to the same. Strategize regarding designation of additional evidence in support of
summary judgment motion and response to motion to strike Griffis affidavit. Draft
Supplemental Affidavit of Larry Griffis. Draft Supplemental Designation of Evidence in
Support of Motion of Summary Judgment. Review and revise Response to Motion to
Strike.Perform legal research regardin
Id
strategize regarding various summary Judgment motion
issues.
5.80 230.00/hr 1,334.00
06/25/14 DAMA Review motion to strike expert's affidavit and brief in support; analyze and strategize
regarding arguments for response to motion to strike
1.50 435.00/hr 652.50
06/25/14 MJM Address new affidavit submitted by opposing party-potential Motion to Strike.
Analysis of strategy for hearing on summary judgment.
0.50 495.00/hr 247.50
06/25/14 MQ Review and analysis of possible Motion to Strike Defendant's Supplemental Expert
Affidavit.
0.50 440.00/hr 220.00
06/25/14 RSS Draft and prepare response to Motion to Strike portions of Larry Griffis Affidavit and
response in support of Motion for Summary Judgment; analyze issues on the same;review
and follow up on matters related to summary judgment hearing;analyze legal issues
related to Motion to Strike SSE's affidavit;review and strategize on issues related to
arguments on
10.00 415.00/hr 4,150.00
06/25/14 RSS Non-charge:Analysis of issues related to Designation of Evidence and matters on the
same; follow up on matters for the same;
2.00 415.00/hr 0.00
06/25/14 TJC Formulated argument in response to SSE's motion to strike Larry Griffis'affidavit.
Analysis of bases to strike affidavit of SSE's expert. Worked on draft of response to
motion to strike Griffis'affidavit.
2.50 495.00/hr 1,237.50
06/26/14 BPH Review and revise res onse t SSE's Motion to Strike Griffis Affidavit. Perform legal
research regarding Perform legal research
regarding Perform legal research
regarding Perform legal research regarding ►
Strategize regarding
CRML 00001 Page 6
Invoice#388114
�pdate response with findings regarding the same in preparation for filing.
5.80 230.00/hr 1,334.00
06/26/14 GTS Analyze and respond to request regarding document production.
0.25 195.00/hr 48.75
06/26/14 RSS Review and analyze issues related to Summary Judgment and arguments related to the
same; analyze matters involving Affidavits and Motion to Strike Exhibits;follow up on
issues related to the same; calls with WPM on matters related to Summary Judgment;
review and work on strategy and arguments for hearing;
8.00 415.00/hr 3,320.00
06/26/14 RSS Review and work on arguments for Summary Judgment; analyze Defendants'response to
Summary Judgment and strategize on the same; calls with WPM on matters related to the
same;
4.00 415.00/hr 1,660.00
06/26/14 RSS Non-charge: Work on outline and matters in preparation for summary judgment hearing;
1.50 415.00/hr 0.00
06/26/14 TJC Worked on draft of response to motion to strike and supplemental affidavit of Larry
Griffis. Addressed use of exhibits at summary judgment hearing. Prepared for hearing.
Strategy regarding ensuring Ow
Conference call with Walter P Moore representatives.
2.50 495.00/hr 1,237.50
06/27/14 BPH Update and revise Response to SSE's Motion to Strike Affidavit of Larry Griffis. Perform
legal research regarding . Provide
summary of findings regarding same. Make final revisions to Supplemental Affidavit,
Supplemental Designation of Evidence and Response Motion in preparation to file same.
4.80 230.00/hr 1,104.00
06/27/14 RSS Preparation for Summary Judgment hearing; calls with WPM on matters related to the
same;
4.50 415.00/hr 1,867.50
06/27/14 TJC Finalized response to SSE's motion to strike affidavit of Larry Griffis. Finalized
supplemental affidavit of Griffis. Worked on draft of outline of oral argument for
Summary Judgment hearing. Prepared for hearing.
1.50 495.00/hr 742.50
06/28/14 MQ Worked nn ar �mentsfor summar�ju✓d�ment brie£ Analyzed submission of additional
authority and arguments related thereto. Analyzed arguments regarding
1.00 440.00/hr 440.00
06/28/14 RSS Preparation for Summary Judgment;review and strategize on issues related to SSE's
arguments and defense to the same;review and analyze issues related to the record and
follow up on the same; analyze matters involving
�I
�I
CRML 00001 Page 7
Invoice##388114
8.00 415.00/hr 3,320.00
06/28/14 RSS Non-charge: Preparation for summary judgment matters;
2.50 415.00/hr 0.00
06/28/14 TJC Prepared for summary judgment hearing.
1.00 495.00/hr 495.00
06/29/14 MQ Analysis of Correspondence to RSS regarding recent case law
Q
arding nd limits on
0.50 440.00/hr 220.00
06/29/14 RSS Non-charge: Work on matters related toand follow up on the
same;
2.00 415.00/hr 0.00
06/29/14 RSS Preparation for Summary Judgment;review and work on matters related to SSE's
arguments and defenses to the same;prepare and work on arguments related to WPM's
analysis and conclusions on the same; analyze issues involving matters related to
modification of Code; strategize on the same;
10.50 415.00/hr 4,357.50
06/29/14 RSS Prepare for Summary Judgment hearing;
1.00 415.00/hr 415.00
06/29/14 TJC Addressed issue related to omplaint.
Prepared for hearing.
0.70 495.00/hr 346.50
06/30/14 MGB Research regarding
IL
Additional research regarding
rovided cases with examples of
documents relied upon.
3.00 215.00/hr 645.00
06/30/14 MQ Assisted with final preparations for hearing.
0.50 440.00/hr 220.00
06/30/14 RSS Prepare for summary judgment hearing;review and prepare argument;work on the same;
call with WPM on matters related to hearing; analyze issues on the same;
12.00 415.00/hr 4,980.00
06/30/14 RSS Non-charge: Calls on matters related to hearing and strategize on issues for the same;
review of cases and matters cited by SSE;
CRML 00001 Page 8
Invoice#388114
2.00 415.00/hr 0.00
06/30/14 TJC Prepared for summary judgment hearing.
1.00 495.00/hr 495.00
Total Fees for this Matter: 166.55 $ 65,503.25
TJC Costakis,Thomas J. 20.70 hrs 495.00/hr 10,246.50
MGB Gaston-Bell,Michael A. 3.00 hrs 215.00/hr 645.00
BPH Holler,Blake P. 23.10 hrs 230.00/hr 5,313.00
DAMA Mastrian,Debbie A. 1.50 hrs 435.00/hr 652.50
MJM Merkle,Mark J.R. 1.50 hrs 495.00/hr 742.50
MQ Quigley,Marc T. 4.50 hrs 440.00/hr 1,980.00
RSS Schein,Robert S. 109.25 hrs 415.00/hr 45,338.75
GTS Smith, Gary T. 3.00 hrs 195.00/hr 585.00
Total: 166.55 hrs $ 65,503.25
Color Copies 1,146.00
Photocopies 83.00
Postage-Express Mail 7.40
05/21/14 VENDOR: Robert S. Schein; INVOICE#: EX071614;DATE: V3gn' _ 69. ,
5/21/2014; Travel-Airfare to Houston,TX JJ�y`"'``�
05/21/14 VENDOR:Robert S. Schein; INVOICE#:EX071614;DATE:
5/21/2014; Travel-Airfare to Houston,TX(Tom Costakis)
05/27/14 VENDOR:Robert S. Schein; INVOICE#:EX071614;DATE: 10.44
5/27/2014;Meals in Houston,TX
05/27/14 VENDOR: Robert S. Schein;INVOICE#:EX071614;DATE: ,10 1n�0' 72.00
5/27/2014; Travel -Cab from airport to hotel
05/28/14 VENDOR: Robert S. Schein; INVOICE#:EX071614;DATE: 43.83
5/28/2014;Meals-Houston,TX
05/28/14 VENDOR: Robert S. Schein;INVOICE#: EX071614;DATE: 44.81'
5/28/2014;Meals-Houston,TX
05/29/14 VENDOR:Robert S. Schein; INVOICE#:EX071614;DATE: 418.86
5/29/2014;,Lodging in Houston,TX
05/29/14 VENDOR: Robert S. Schein;INVOICE#:EX071614;DATE: Awe 64.53
5/29/2014;Meals -Houston,TX
05/29/14 VENDOR: Robert S. Schein; INVOICE#:EX071614;DATE: 25.00
5/29/2014;Travel -Baggage Fee for Houston,TX
05/30/14 VENDOR:Thomas J. Costakis; INVOICE#: EX063014; 418.86
DATE: 6/30/2014; Lodging Houston
05/30/14 VENDOR: Robert S. Schein;INVOICE#:EX071614;DATE: 54.00
5/30/2014;Parking-Indianapolis International Airport
05/30/14 VENDOR: Thomas J. Costakis; INVOICE#: EX063014; 92.94
DATE: 6/30/2014;Travel Houston
05/31/14 VENDOR: Robert S. Schein;INVOICE#:EX071614;DATE: 25.00
5/31/2014;Travel -Baggage Fee for Houston,TX to
CRML 00001 Page 9
Invoice#388114
Indianapolis, IN
05/31/14 VENDOR: Robert S. Schein; INVOICE#: EX071614;DATE: 200.01
5/31/2014;Travel -Airfare change fee 2
05/31/14 VENDOR: Robert S. Schein;INVOICE#: EX071614; DATE: 200.00
5/31/2014;Travel -Airfare change fee(Tom Costakis)
06/06/14 VENDOR: O`Neal Probst Wells; INVOICE#: 12477;DATE: 463.76
6/6/2014; Deposition
06/06/14 VENDOR: ONeal Probst Wells;INVOICE#: 12480; DATE: 440.70
6/6/2014;Deposition
06/27/14 Computerized Research-Westlaw 265.85
06/27/14 VENDOR: Jones&Webb Associates, Inc.; INVOICE#: 91.66
22852;DATE: 7/1/2014; Outside Photocopy
06/28/14 VENDOR: Robert S. Schein; INVOICE#:EX071614;DATE: 20.00
6/28/2014;Travel -cab from hotel to deposition
06/28/14 VENDOR:Robert S. Schein; INVOICE#:EX071614; DATE: 18.00
6/28/2014;Travel-cab from deposition to hotel
06/29/14 VENDOR:Robert S. Schein;INVOICE#:EX071614;DATE: 18.00
6/29/2014;Travel -cab from hotel to deposition
06/30/14 Computerized Research-Westlaw 356.61
Total Disbursements for this Matter: $ 5,779.25
TOTAL FEES: $ 65,503.25
TOTAL DISBURSEMENTS: $ 5,779.25
TOTAL CHARGES FOR THIS BILL: $ 71,282.50
Less Fee Reduction: $ (750.00)
PLEASE PAY THIS AMOUNT $ 7 , 2.50
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 EVAU LT Suite 2800
Indianapolis,IN 46204-2079
T:317.636.4341
F:317.636.1507
Fed.EIN#35-1055087
•
Carmel Redevelopment Commission
Les Olds,AIA, Executive Director
30 West Main Street, Suite 220
Carmel, IN 46032 08-20-14 i'05:01 n CVD
June 13,2014
Invoice Number 384593
Our File#: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH May 31,2014
05/01/14 RSS Analysis of issues related to deposition matters;follow up on the same;
1.00 415.00/hr 415.00
05/02/14 RSS Follow up on discovery matters;
0.25 415.00/hr 103.75
05/05/14 BSS Drafted and revised arguments seeking partial summary judgment in Motion wherein CRC
contends that SSE was liable to design the connections in their entirety and prepared
excerpts from depositions and evidence in support of Cross-Motion. Strategized regarding
the same.
2.25 275.00/hr 618.75
05/05/14 RSS Follow up on Summary Judgment and deposition matters;
0.50 415.00/hr 207.50
05/05/14 TJC Receipt and review of Creviston's Witness and Exhibit Lists. Preliminary research on
identified expert witnesses. Addressed issues related to Creviston and SSE unwillingness
to commit to WPM depositions on agreed upon dates.
1.00 495.00/hr 495.00
05/07/14 RSS Deposition follow up; analysis of issues of matters related to summary judgment;
0.75 415.00/hr 311.25
05/08/14 BPH Review and analyze draft of opposition to SS&E's motion for partial summary summary
INDIANA • FLORIDA •
CRML 00001 Page 2
Invoice#384593
judgment and memorandum of support of CRC's cross-motion for partial summary
judgment. Strategize with Mr. Strawbridge regarding revisions to the same.
1.20 230.00/hr 276.00
05/08/14 BSS Worked on drafting and revising Memorandum in Response to SSE's Motion for Partial
Summary Judgment as well as Cross-Motion for Partial Summary Judgment and
strategized regarding the same.
3.75 275.00/hr 1,031.25
05/08/14 RSS Analysis of issues involving summary judgment;review of issues on the same;
0.50 415.00/hr 207.50
05/09/14 BSS Worked on drafting and revising designation of evidence in support of motion for partial
summary judgment as well as revising and supplementing argument sections of
memorandum of Law in support of motion for partial summary judgment. Correspondence
and strategy regarding the same. Worked on compiling exhibits for motion.
1.75 275.00/hr 481.25
05/09/14 RSS Work on summary judgment matters; analysis of issues on the same;follow up on matters
related to depositions with SSE and WPM;
1.00 415.00/hr 415.00
05/09/14 TJC Review and analysis of cross motion for summary judgment. Review and analysis of
designation of evidence in support of cross motion for summary judgment. Began review
and analysis of brief in opposition to SSE's motion and in support of CRC motion,for
summary judgment.
1.00 495.00/hr 495.00
05/12/14 RSS Analysis of issues related to summary judgment; follow up on the same;review of issues
related to deposition matters and follow up on the same;
2.50 415.00/hr 1,037.50
05/12/14 TJC Worked on response to SSE motion for summary judgment and CRC cross motion for
summary judgment. Addressed issues related to depositions of Walter P Moore.
1.00 495.00/hr 495.00
05/13/14 RSS Analysis of issues related to summary judgment and matters involving the same;
3.50 415.00/hr 1,452.50
05/13/14 TJC Revised and edited draft of brief in support of motion for partial summary judgment.
1.50 495.00/hr 742.50
05/14/14 RSS Work on summary judgment brief;calls with WPM on matters related to summary
judgment and deposition matters;
7.50 415.00/hr 3,112.50
05/14/14 TJC Completed revisions to brief in support of cross motion for summary judgment.
Teleconference with Walter P Moore to prepared for depositions. Strategy related to
summary judgment and depositions.
CRML 00001 Page 3
Invoice##384593
3.50 495.00/hr 1,732.50
05/15/14 BSS Worked on drafting and revising Designation of Evidence and Cross-Motion for Partial
Summary Judgment.
4.25 275.00/hr 1,168.75
05/15/14 MQ Review and analysis of expert witness issues at summary judgment stage. Provided
sample affidavits to Rob Schein for his briefing.
0.75 440.00/hr 330.00
05/15/14 RSS Draft and revise summary judgment brief matters;analyze issues on the same;calls on the
same;follow up on WPM deposition matters; analyze issues raised and work on the same;
8.50 415.00/hr 3,527.50
05/15/14 TJC Worked on summary judgment materials-revised and edited brief,addressed affidavits
and other evidence to be designated to the Court. Conference call with Walter P Moore.
Prepared drafts of exhibits for Griffis affidavit. Revised and edited draft of Griffis
affidavit. Analysis of SSE's request for additional time to serve its expert report and
counsel's comments regarding Creviston's responsibility for truss issues.
3.50 495.00/hr 1,732.50
05/16/14 BSS Worked on preparing Affidavit of Larry Griffis and myriad exhibits to the same in support
of Cross-Motion for Partial Summary Judgment. Revisions to Memorandum of Law in
Support of Cross-Motion for Summary Judgment.
3.50 275.00/hr 962.50
05/16/14 RSS Draft and work on matters related to Summary Judgment brief;analyze issues related to
WPM affidavit;review of legal issues related to the SJ Brief; analyze matters on the same;
work on matters related to WPM depositions; follow up on issues for the same; analyze
strategy matters related to case; calls on the same;
3.00 415.00/hr 1,245.00
05/16/14 TJC Substantial revisions to draft of affidavit of Larry Griffis. Follow up on open matters
related to summary judgment and depositions. Receipt and review of SSE's expert
disclosures. Reviewed and revised draft of brief in opposition to SSE's motion for partial
summary judgment and in support of CRC's motion for partial summary judgment.
Attention to deposition issues.
4.00 495.00/hr 1,980.00
05/19/14 BSS Drafted and revised Cross-Motion for Partial Summary Judgment, Memorandum in
Support of the same, along with Designation of Evidence. Strategized and researched
issues in support of Cross-Motion.
2.50 275.00/hr 687.50
I�
05/19/14 RSS Review and work on Summary Judgment brief, analyze issues on the same;draft and
revise legal arguments; follow up with WPM on matters related to the same;analysis of
strategyand work on the same;
,
8.00 415.00/hr 3,320.00
CRML 00001 Page 4
Invoice#384593
05/19/14 TJC Attention to issues related to summary judgment briefing and WPM depositions. Multiple
lengthy teleconferences with Mark Holland of Walter P Moore to address issues related to
draft affidavit, brief and depositions. Revised and edited draft of affidavit and worked on
exhibits to affidavit. Worked on deposition preparation.
3.50 495.00/hr 1,732.50
05/20/14 BPH Strategize regarding response brief for summary judgment. Analyze issues relating to
exhibits to use and coordinating designations of evidence thereto.
0.75 230.00/hr 172.50
05/20/14 BSS Drafted and revised Affidavit of Larry Griffis and worked on preparing exhibits to the
same. Extensive preparation of exhibits in support of Affidavit and Designation of
Evidence. Worked on revising Memorandum of Law in Support of Cross-Motion for
Summary Judgment.
3.50 275.00/hr 962.50
05/20/14 RSS Work on Summary Judgment matters; draft and revise legal arguments related to SSE
claims; analysis of issues related to the SSE claims; analysis of strategy related to
summary judgment;follow up on matters related to WPM depositions;analyze issues on
the same;
5.50 415.00/hr 2,282.50
05/20/14 TJC Reviewed and revised summary judgment materials. Prepared for depositions of Walter P
Moore representatives.
1.00 495.00/hr 495.00
05/21/14 BPH Receipt and analysis of deposition notices and subpoenas for Mr. Griffis and Mr.Bouadi.
Strategize with Mr. Costakis regarding deposition specifics and location. Perform legal
research regarding
Perform legal research regarding the
. Review and revise Response and
Cross Motion for Summary Judgment. Perform legal research regarding all legal authority
cited in Response Motion for Summary Judgment for accurate citations and currentness
of the law cited therein. Review and revise Second Request for Production to SSE.
Review and Revise First Set of Interrogatories to SSE. Strategize regarding revisions to
designation of evidence in conjunction with the Motion for Summary Judgment.
4.10 230.00/hr 943.00
05/21/14 BSS Revisions and research of issues and arguments in support of Cross-Motion for Partial
Summary Judgment and Response to SSE's Motion for Partial Summary Judgment and
worked on incorporating the same and drafting issues/arguments in support of
Memorandum of Law for Cross-Motion. Correspondence/strategy regarding Cross-
Motion. Extensive revisions to Affidavit of Larry Griffis.
3.75 275.00/hr 1,031.25
05/21/14 RSS Work on summary judgment brief, analyze issues on deposition request; draft and revise
changes to Summary Judgment Brief, follow up on matters related to WPM affidavit;
analysis of issues on the same; calls with WPM on matters related to depositions and
CRML 00001 Page 5
invoice#384593
summary judgment; work on the same;
9.50 415.00/hr 3,942.50
05/21/14 TJC Addressed issues related to SSE's desire to take WPM representatives depositions at their
offices, with access to their files. Worked on summary judgment issues, including
designation of evidence, affidavit of Larry Griffis and brief in support of summary
judgment.
3.20 495.00/hr 1,584.00
05/22/14 BPH Review and revise affidavit of Larry Griffis in preparation to attach to Cross Motion for
Summary Judgment. Review and revise designation of evidence materials for congruity
with the Cross Motion in preparation to attach to the same. Analyze, review and revise
Cross Motion for Summary Judgment in preparation to file with the Court.
3.90 230.00/hr 897.00
05/22/14 BSS Finalized drafting and revising of Memorandum of Law in Support of Cross-Motion for
Partial Summary Judgment, Designation of Evidence, Cross-Motion itself, and prepared
extensive submissions and exhibits in support of Cross-Motion. Correspondence and
strategy regarding the same. Teleconference with opposing counsel regarding Cross-
Motion,Response to SSE's Motion for Partial Summary Judgment and related issues.
4.50 275.00/hr 1,237.50
05/22/14 RSS Work on Summary Judgment Brief and finalize the same;follow up with WPM on matters
related to the same; calls with WPM on deposition matters; follow up on reports,
discovery and strategy to matters on the same; review of issues on the same;
6.00 415.00/hr 2,490.00
05/22/14 TJC Revised, edited and finalized summary judgment materials. Teleconference with WPM
representatives to prepare for depositions.
2.00 495.00/hr 990.00
05/23/14 BPH Update and revise Second Set of Requests for Production to SSE. Update and revise First
Set of Interrogatories to SSE in preparation to serve upon opposing counsel. Update and
revise Non-Party Requests for Production to Dave Ruby. Update and revise
Interrogatories to Creviston. Plan and prepare for upcorning defense of depositions of Mr.
Griffis and Mr.Bouadi.
4.10 230.00/hr 943.00
05/23/14 GTS Assist in preparation for deposition.
0.75 195.00/hr 146.25
05/23/14 KDV Assisted in revisions to discovery requests to include requests regarding
0.20 270.00/hr 54.00
05/23/14 RSS Review and analysis of issues related to depositions; work on the same; prepare for
depositions; work on discovery responses and matters on the same;
5.00 415.00/hr 2,075.00
CRML 00001 Page 6
Invoice#384593
05/23/14 RSS NC: Follow up on matters with client related to strategy and analysis of issues related to
summary judgment, depositions, discovery and matters going froward;
1.00 0.00/hr 0.00
05/23/14 TJC Conference call with WPM representatives in preparation for their depositions.
2.00 495.00/hr 990.00
05/24/14 GTS Prepare Walter P. Moore documents for production in preparation for deposition.
1.25 195.00/hr 243.75
05/25/14 BPH Perform review of documents received from WPM for privilege and responsiveness in
preparation for upcoming depositions of WPM personnel.
1.10 230.00/hr 253.00
05/26/14 MQ Review and analysis of objections to demand to inspect expert witness computer data.
0.25 440.00/hr 110.00
05/26/14 RSS Review and work on matters related to depositions of WPM; prepare for the same;
1.50 415.00/hr 622.50
05/27/14 BPH Coordinate production of most recent batch of WPM files to opposing counsel prior to
upcoming depositions of Griffis and Bouadi. Coordinate transmittal of same to Houston.
Plan and prepare for upcoming depositions of Griffis and Bouadi with compilation of
relevant docs for preparation of witnesses. Perform review of documents received from
WPM in preparation to produce ahead of upcoming depositions.
4.70 230.00/hr 1,081.00
05/27/14 GTS Assist in research for deposition. Prepare documents for attorney review. Prepare
production of documents.
5.50 195.00/hr 1,072.50
05/27/14 RSS Travel to Houston for WPM depositions;meetings with WPM regarding depositions;
analysis of issues on the same;prepare for depositions and analyze strategy;work on the
same;
12.00 415.00/hr 4,980.00
05/27/14 RSS Noncharge: Travel to Houston for deposition preparation;
2.00 0.00/hr 0.00
05/27/14
TJC Travel to Houston. Long meeting with Hakim Bouadi and Larry Griffis to prepare them
for their depositions. Final preparation for depositions. Receipt and review of SSE's
motion for extension of time to file expert reports.
12.00 495.00/hr 5,940.00
05/27/14 TJC NON-CHARGE: Downtime during travel.
2.00 0.00/hr 0.00
05/28/14 BPH Coordinate with Litigation Support regarding relevant productions and time frames to
procure documents necessary for depositions of Mr. Griffis and Mr.Bouadi. Perform
CRML 00001 Page 7
Invoice#384593
legal research regarding
Perform legal research regarding the
1.60 230.00/hr 368.00
05/28/14 GTS Assist in research for deposition. Review documents and prepare for attorney and expert
review.
6.00 195.00/hr 1,170.00
05/28/14 RSS Work on matters related to WPM deposition; analyze issues related to��
matters;defend Hakim's deposition;analysis of issues on the same(8.5);meeting with
Larry Griffis related to matters involving deposition (1.0); strategize relating to matters
involving deposition and summary judgment(1.0);
10.50 415.00/hr 4,357.50
05/28/14 RSS Noncharge: Strategize regarding deposition matters;follow up on the same;
1.50 0.00/hr 0.00
05/28/14 TJC Pre-deposition meeting with Hakim Bouadi and Larry Griffis. Defended deposition of
Hakim. Follow up meeting with Larry Griffis. Prepared for second day of depositions.
10.50 495.00/hr 5,197.50
05/28/14 TJC NON-CHARGE: Down time during day of depositions;working lunch with Larry Griffis
and Hakim Bouadi.
1.50 0.00/hr 0.00
05/29/14 BPH Teleconference with litigation support regarding production documents necessary for
depositions. Review documents received from WPM for privilege and attorney work
product in preparation to produce to SSE for ongoing use at depositions.
1.30 230.00/hr 299.00
05/29/14 GTS Telephone call with Mark Holland. Download documents from Walter P. Moore and
prepare documents for production.
1.00 195.00/hr 195.00
05/29/14 RSS Prepare for depositions and meeting with expert; defend and attend,deposition;
10.00 415.00/hr 4,150.00
05/29/14 RSS Noncharge: Travel to airport and back to Indianapolis;
7.00 415.00/hr 2,905.00
05/29/14 TJC NON-CHARGE: Down time during deposition and return travel to Indianapolis.
7.00 0.00/hr 0.00
05/29/14 TJC Pre-deposition meeting with Larry Griffis. Defended Larry Griffis deposition. Follow up
meeting with Mr. Griffis. Return travel to Indianapolis.
10.00 495.00/hr 4,950.00
CRML 00001 Page 8
Invoice#384593
05/30/14 GTS Process and prepare doculnents for production. Prepare documents for attorney and expert
review.
3.25 195.00/hr 63335
05/30/14 RSS Follow up on deposition matters; analyze issues related to the same;
2.50 415.00/hr 1,037.50
05/30/14 TJC Teleconference with Walter P.Moore; strategy in follow up to depositions and in
anticipation of summary judgment hearing.
1.00 495.00/hr 495.00
Total Fees for this Matter: 253.65 $ 91,613.00
KDV Baird,Kay Dee 0.20 hrs 270.00/hr 54.00
TJC Costakis,Thomas J. 71.20 hrs 422.00/hr 30,046.50
BPH Holler,Blake P. 22.75 hrs 230.00/hr 5,232.50
MQ Quigley,Marc T. 1.00 hrs 440.00/hr 440.00
RSS Schein,Robert S. 111.00 hrs 398.18/hr 44,197.50
GTS Smith, Gary T. 17.75 hrs 195.00/hr 3,461.25
BSS Strawbridge, Bryan S. 29.75 hrs 275.00/hr 8,181.25
Total: 253.65 hrs $ 91,613.00
Federal Express 20.61
Photocopies 17.00
Postage-Express Mail 15.22
05/16/14 VENDOR: Joseph Beutel; INVOICE#: EX052714;DATE: 14.11
5/16/2014;Travel to Hamilton Cty. Courthouse
05/22/14 VENDOR: Joseph Beutel; INVOICE#:EX052714;DATE: 14.11
5/22/2014;Travel to Hamilton County Courthouse
05/27/14 VENDOR:Thomas J. Costakis;INVOICE#:EX060214; 59.76
DATE: 5/27/2014; Meals-Dinner for TJC and RSS in
Houston
05/27/14 VENDOR: Thomas J. Costakis;INVOICE#: EX060214; 25.00
DATE: 5/27/2014;Travel -Bag Fee i/c/w flight to Houston for
depositions
05/28/14 Computerized Research - Westlaw 449.82
Total Disbursements for this Matter: $ 615.63
TOTAL FEES: $ 91,613.00
TOTAL DISBURSEMENTS: $ 615.63
TOTAL CHARGES FOR THIS BILL: $ 92,228.63
One Indiana Square
K R I EG DEVAULT. India o
® Indianapap olis.IN 46204-2079
T:317.630.4341
F:317.636.1507
Fed.EIN#35-1055087
Carmel Redevelopment Commission
Corrie Meyer, Executive Director
20 West Main Street, Suite 220 0 8-2 0-1 4 P 0 4:4 6 R C V D
Carmel,IN 46032
July 18 2014
Invoice Number 388098
Our File#: CRML 00003 RSS
Hagerman/Crider
FOR PROFESSIONAL SERVICES RENDERED THROUGH June 30,2014
06/1.6/14 RSS Follow up on matters related to Stipulation of Dismissal;correspond with Steve
Strawbridge on the same;
0.25 415.00/hr 103.75
Total Fees for this Matter: 0.25 $ 103.75
RSS Schein, Robert S. 0.25 hrs 415.00/hr 103.75
Total: 0.25 hrs $ 103.75
TOTAL FEES: $ 103.75
TOTAL, CHARGES FOR THIS BILL: $ 103.75
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
NAI-NINESOTA
Prescribed by State Board of Accounts City Form No.201(Rev.1995)
ACCOUNTS PAYABLE-VOUCHER
CITY OF CARMEL`
An invoice.oi bill to be properly itemized must show: kind of service, where performed, dates service rendered, by
whom"Fates per day, number of hours, rate per hour, number of-units- price per unit, etc.
Payee
Purchase Order No.
One IAN JgLt rc Sui�'a 2$�0 Terms
T nd� An 7S', -207 Date`Due
Invoice Invoice Description :. Amount
Date :Number (or note attached invoice(s) or bill(s))
-ZS-I� :3 l �' I'/I < 11.11 M s — j 0 h 2`01 61,315, 6f
2 22.E 63
-ii-I 3 geOil ha2trmVi l(ril er d4w' J14he 2n 3.75
Total
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.
1/ t� ALLOWED 20
11t �i�9 U e �llk IN SUM OF $
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fir, i cln alis `'20 —2
ON ACCOUNT OF APPROPRIATION FOR
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Board Members
PO#or
D PT.# INVOICE NO. ACCT#/TITLE AMOUNT. I hereby certify that the attached invoice(s),
3��1( 4440107 61315. �. or bill(s) is (are) true and correct and that
Z 3 k4 3j 4`'t160 f d7 1
912263 ' the materials or services itemized thereon
Z 3 018 4q69807 7 103, -1 for,which charge is made were ordered and
received except
Si nat re
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Title
Cost distribution ledger classification if .
claim paid motor vehicle highway fund