221121 06/18/2013 CITY OF CARMEL, INDIANA VENDOR: 00353406 Page 1 of 1
ONE CIVIC SQUARE KRIEG DEVAULT
CARMEL, INDIANA 46032 ONE INDIANA SQUARE,STE 2800 CHECK AMOUNT: $88,260.82
INDIANAPOLIS IN 46204
CHECK NUMBER: 221121
CHECK DATE: 6/18/2013
DEPARTMENT ACCOUNT PO NUMBER INVOICE NUMBER AMOUNT DESCRIPTION
902 4460807 352935 88, 260 . 82 PERFORMING ARTS CENTE
Onc Indiana Square
K `1EG DEV ULT Suite 2800
vt'�` ® Indianapolis,IN 46204-2079
T:317.636.4341
F:317.636.1507
Fed. EIN 4 35-1055087
WWW.KREEGDEVAULT.COM
Carmel Redevelopment Commission
Les Olds, AIA, Executive Director
30 West Main Street, Suite 220
Carmel,IN 46032
May 31,2013
Invoice Number 352935
Our File#: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH April 30, 2013
04/01/13 ATD Obtain copy of docket sheet and forward to Strawbridge.
0.25 205.00/hr 51.25
04/01/13 BPH Review invoices for privileged and confidential information and redact same in
preparation for production of invoices related to attorney's fees claims. Meet with Mr.
Schein and Mr. Strawbridge regarding case and trial status, updates to final witness and
exhibit lists and action items in preparation for upcoming hearing and trial.
6.30 215.00/hr 1,354.50
04/01/13 BSS Prepared for hearing before Court and strategized regarding presentation of status with
regard to truss investigation and other ongoing issues, including discovery and deposition.
Traveled to and attended hearing to address these issues. Multiple emails and calls with
opposing counsel for SSE regarding these and other issues, including SSE's insurance
coverage and policy. Strategized regarding Final Witness and Exhibit Lists.
Correspondence regarding depositions. Strategized regarding witnesses necessary for
trial. Correspondence/strategy related to production of privilege log.
5.75 250.00 /hr 1,437.50
04/01/13 RSS Prepare for hearing; analyze issues on the same; attend hearing; follow up on the same;
strategize on the same.
8.50 385.00 /hr 3,272.50
04/01/13 RSS Call with WPM on matters related to trial strategy, upcoming depositions, witness
preparation and issues related to the same; review and analyze Creviston docurnents and
t A' �'
CRML 00001 Page 2
Invoice#352935
SSE production related to the same.
2.75 385.00/hr 1,058.75
04/01/13 TJC Worked on trial strategy.
0.50 475.00/hr 237.50
04/02/13 BPH Review invoices for privileged and confidential information and redact same in
preparation for production of invoices related to attorney's fees claims.
3.30 215.00/hr 709.50
04/02/13 BSS Teleconference with counsel for Creviston regarding scheduling deposition of Jack
Creviston and perhaps other Creviston personnel; correspondence regarding the same;
prepared summary of call. Analysis of Creviston hand calculations produced by SSE and
Creviston and reviewed the same. Multiple emails and calls with counsel for SSE
regarding deposition and production of various documents, incl. SSE's insurance policies.
Researched issues related to Creviston. Analysis of issues related to news coverage of
truss issues and media press release.
3.25 250.00/hr 812.50
04/02/13 GTS Run searches against document database. Prepare invoices, Creviston documents, emails
of interest of last SSE production, and Arcan e-mails for deposition.
5.20 175.00/hr 910.00
04/02/13 RSS Several calls with WPM on matter related to strategy and truss issues; calls with Les Olds
on trial matters; analyze the same; review of issues for the same; follow up on deposition
matters; review of issues related to discovery; calls with Les Olds on matters related to
truss and fix issues; call with Mayor Brainard on the same.
3.00 385.00/hr 1,155.00
04/02/13 TJC Review and analysis of issues related to Creviston apparently no longer being in business.
Attention to issues related to publicity of retrofit of truss connections.
1.20 475.00/hr 570.00
04/03/13 BPH Review invoices for privileged and confidential information and redact same in
preparation for production of invoices related to attorney's fees claims. Review and revise
final witness and exhibit lists in preparation to file same pursuant to case management
plan.
3.60 215.00/hr 774.00
04/03/13 BSS Worked on drafting/revising Final Witness and Exhibit Lists. Analysis of issues related to
Creviston. Analysis of Arcan documents. Analysis/revisions to proposed press release.
Analysis of materials to provide to WPM. Analysis and redactions to invoices for
production to SSE.
2.25 250.00 /hr 562.50
04/03/13 RSS Calls related to additional matters involving truss work and public relations with Les Olds,
Mayor Brainard and others; analysis of issues related to the same; calls with WPM on
matters related to litigation strategy and issues on the same; call with Mike Anderson on
timing of bids and work related matters; review and analyze issues related to the same;
CRML 00001 Page 3
Invoice#352935
work on outstanding matters related to witness and exhibits lists.
3.50 385.00/hr 1,347.50
04/03/13 TJC Addressed litigation related issues i/c/w press release on truss issues. Receipt and review
of court order re-setting status conference for late April. Trial preparation matters.
1.00 475.00/hr 475.00
04/04/13 BPH Research and analyze regarding rights and remedies of insured party who was not insured
in violation of construction contract. Review all depositions taken in this matter for
exhibits in preparation to update and revise final witness and exhibit lists. Update and
revise final witness and exhibit lists in preparation to file with court.
4.60 215.00/hr 989.00
04/04/13 BSS Drafted correspondence to WPM personnel regarding SSE email production and issues of
interest therein. Teleconferences with counsel for SSE regarding depositions of D. Ruby,
J. Creviston, SSE personnel and others. Review and redactions to CRC's invoices for
production to SSE. Redacted CRC invoices and prepared for production to SSE; drafted
letter re: the same to SSE's counsel. Revisions to Final Witness List to include deposition
exhibits.
3.75 250.00/hr 937.50
04/04/13 GTS Call with Bryan Strawbridge.
0.20 175.00/hr 35.00
04/04/13 RSS Review and analyze issues related to Press Release and latest developments; review of
Performing Arts Center suggested approach; analyze issues related to litigation matters
and going forward on the same; call with Les Olds on issues related to the same; call with
Mike Anderson on bid work and truss work timing; call with WPM on issues related to the
same; call with Mayor Brainard, Les Olds, Nancy Heck and others related to matters
involving truss issues; follow up on matters related to the same.
3.00 385.00/hr 1,155.00
04/04/13 RSS Review and analyze issues related to matters involving trial strategy and outstanding
issues; follow up on the same.
1.00 385.00/hr 385.00
04/04/13 TJC Addressed the affect on litigation by the press release and related issues.
0.50 475.00 /hr 237.50
04/05/13 BSS Analysis of depositions and exhibits thereto. Worked on drafting/revising Final Witness
and Exhibit Lists to incorporate deposition exhibit numbers. Strategized regarding use of
the same for exhibit stipulations at trial to facilitate ease of presenting case and testimony.
Correspondence regarding these issues. Analysis of documents produced by SSE for
issues related to Arcan and Creviston. Correspondence with WPM regarding SSE ernails.
1.50 250.00/hr 375.00
04/05/13 RSS Follow up on depositions matters, witness and exhibit lists and issues related to litigation;
review and analyze issues related to the same.
1.00 385.00/hr 385.00
CRML 00001 Page 4
Invoice#352935
04/06/13 RSS Analysis of issues related to construction agreement for Truss work; follow up on the
same.
0.75 385.00/hr 288.75
04/06/13 RSS Analysis of issues for trial; review of matters related to witness and exhibit list; follow up
on the same.
1.00 385.00/hr 385.00
04/06/13 TJC Communications with Walter P. Moore regarding truss drawings and forensic analysis.
Communications related to form of contracts for retrofit work.
0.40 475.00/hr 190.00
04/07/13 TJC Reviewed and edited draft witness and exhibit lists due 4.10.13.
0.40 475.00/hr 190.00
04/08/13 BSS Analysis of issues related to retainage, setoff, and remediation costs. Revisions to Final
Witness and Exhibit List.
0.25 250.00/hr 62.50
04/08/13 RSS Analyze issues related to Final Witness and Exhibit list; work on the same.
0.50 385.00/hr 192.50
04/08/13 TJC Analysis of funding of truss retrofit issues, including affect on litigation and trial date.
0.30 475.00/hr 142.50
04/09/13 BSS Correspondence to/from counsel for SSE regarding depositions of D. Ruby and SSE
personnel; strategized regarding issues to address prior to closure of discovery deadline.
Analysis of Arcan documents/emails.
0.50 250.00/hr 125.00
04/10/13 BSS Finalized Final Witness and Exhibit Lists and prepared correspondence to the Court
regarding the same. Multiple calls with counsel for SSE regarding insurance coverage and
related documents as well as trial matters, claims, and various other issues. Analysis of
document production issues. Review of Creviston and SSE's calculations. Strategized
regarding attorney fee records for production to document claims of damages.
Teleconference with Walter P Moore experts regarding trial preparation matters.
Strategized regarding deposition issues and scheduling of depositions for SSE, Ruby and
Creviston. Correspondence to/from Creviston's counsel regarding depositions.
Correspondence with SSE's Counsel regarding insurance policies, depositions, and other
issues. Researched service of discovery upon Arcan; analysis of the same.
3.00 250.00/hr 750.00
04/10/13 GTS Prepare production of documents in Summation database format to replace PDF provided
to opposing counsel prior to deposition.
1.10 175.00/hr 192.50
04/10/13 RSS Calls with WPM on matters related to depositions, trial matters and issues going forward;
work and review of the same; analyze and finalize Final Witness and Exhibit Lists for
i
CRML 00001 Page 5
Invoice#352935
filing; analyze further matters related to damages and issues on the same.
5.75 385.00/hr 2,213.75
04/10/13 TJC Final review of witness and exhibit lists. Attention to issue related to deposition of Dave
Ruby. Analysis of SSE's conduct in connection with scheduling depositions and devised
plan and strategy related to preservation of June trial date.
1.10 475.00/hr 522.50
04/11/13 BPH Analysis of issues regarding calculation documents from Creviston and SSE and potential
request for supplementation of discovery regarding same.
0.50 215.00/hr 107.50
04/11/13 BSS Teleconference with counsel for SSE related to mediation and deposition scheduling as
well as various substantive issues. Strategized regarding truss issues and implications as
we approach April 26 hearing before Judge Nation. Analysis of correspondence from
CRC and City Council. Strategized regarding trial setting and prepared actions items of
issues to address pending trial scheduling and April 26 hearing. Analysis of Jack
Creviston's calculations and SSE and Creviston's document production of the same.
Extended teleconferences with experts, WPM, regarding the same. Analysis of attorney
fee records to produce in support of damages claims. Analysis of contractual provisions
and strategized regarding use of contracts at trial; contemplated enlargement of various
provisions. Review and revisions to privilege log.
4.00 250.00/hr 1,000.00
04/11/13 RSS Analyze issues related to depositions and matters on the same; analyze Creviston
documents and matters related to trial and depositions; follow up on the same; call with
Les Olds on matters related to the same;call with WPM on matters related to meeting on
Truss issues and issuance of plans; follow up on the same.
6.00 385.00/hr 2,310.00
04/11/13 TJC Review and analysis of revised truss drawings. Analysis of delegation issue. Reviewed
literature on design responsibility under AISC. Attention to completion of discovery
issues.
1.20 475.00/hr 570.00
04/12/13 BPH Review documents produced by Creviston and SSE for duplicative productions as well as
calculation documentation.
1.20 215.00/hr 258.00
04/12/13 BSS Drafted letter counsel for SSE regarding deposition dates for Ruby, SSE personnel, and
Jack Creviston as well as setting forth issues related SSE and Creviston's production of
documents related to Jack Creviston's calculations prepared for the connections. Drafted
correspondence to counsel for Creviston regarding deposition of Jack Ruby as well as
issues with Creviston's document production and demanded confirmation that all
responsive documents have been produced. Receipt and analysis of SSE's Final Witness
and Exhibit List. Prepared summary of applicable contractual provisions in anticipation
for trial presentation.
3.00 250.00/hr 750.00
CRML 00001 Page 6
Invoice#352935
04/12/13 RSS Analyze issues related to trial matters; work on depositions; follow up on scheduling and
issues related to the same; follow up on matters related to mediation; call with SSE
counsel, Pfenne Cantrell, regarding discovery and trial matters; follow up on the same.
3.00 385.00/hr 1,155.00
04/12/13 TJC Review and analysis of SSE's final witness and exhibit lists. Addressed mediation issues,
responded to inquiries by SSE and mediator in terms of timing and scheduling. Attention
to needed depositions and worked on expedited scheduling to accommodate June trial date
and corresponding May 10 discovery cut off date. Prepared for mediation and impending
discovery depositions.
2.10 475.00/hr 997.50
04113113 BSS Revisions to letters to SSE and Creviston regarding mediation, discovery issues, and
depositions; correspondence regarding outstanding issues.
0.25 250.00/hr 62.50
04/13/13 TJC Reviewed, revised and edited communication with SSE counsel regarding timely
deposition of Ruby, SSE's expert, timely depositions of SSE employees (current and
former), mediation scheduling and confirmation of production of all of Creviston's hand
calculations - all intended to maintain June trial date.
0.30 475.00/hr 142.50
04/15/13 BPH Review documents produced by Creviston and SSE for duplicative productions as well as
calculation documentation.
1.80 215.00/hr 387.00
04/15/13 BSS Teleconferences with counsel for SSE and internal strategy related to scheduling of the
depositions of SSE personal, three individuals, who are no longer employed by SSE and
are located outside the jurisdiction. Analysis of privilege log issues. Worked on
drafting/revising correspondence to counsel for SSE and separate correspondence to
counsel for Creviston. Correspondence with mediator's office regarding scheduling May
mediation. Analysis of Creviston's hand calculations. Various phone calls and emails to
address these issues and other matters ongoing in preparation for trial.
2.00 250.00/hr 500.00
04/15/13 RSS Analyze issues related to the mediation and issues going forward; follow up on the same;
correspond with SSE counsel on discovery matters, depositions and mediation; analyze
the same; correspond with Creviston counsel on depositions and discovery matters; follow
up on matters related to client meeting; call with Les Olds on the same.
2.75 385.00/hr 1,058.75
04/15/13 TJC Prepared for depositions of SSE and Creviston representatives.
0.50 475.00/hr 237.50
04/16/13 BPH Research and analyze issues regarding comparative fault in negligence claims and
potential effect on concurrent breach of contract claim. Draft summary of findings.
1.00 215.00/hr 215.00
04/16/13 BSS Strategized and prepared for depositions of SSE personnel, i.e., Dieter Kohn, John Stamm
CRML 00001 Page 7
Invoice#352935
and Christian Crosby, and worked on preparing/drafting outlines for their testimony.
Drafted outline and strategized regarding issues for deposition of David Ruby, SSE's
expert. Researched various issues related to no damage for delay clauses and elections of
remedies. Analysis of documents exchanged between CRC and CPS (Andy Engelhart)
and worked on preparing production of documents to SSE; coordinated with litigation
support personnel regarding the same. Correspondence to/from SSE's counsel regarding
depositions. Strategized regarding truss issues and presentation of claims and evidence of
the same at trial. Strategized regarding trial timeline issues and determination of the same
by the CRC. Correspondence to/from SSE's counsel.
4.00 250.00/hr 1,000.00
04/16/13 GTS Prepare CPS documents for production.
1.10 175.00/hr 192.50
04/16/13 RSS Analysis of issues related to depositions and witnesses; follow up on the same; analysis of
issues related to damages and no damages for delay provisions related to case; review of
damages provisions for production and trial; follow up on the same; call with Les Olds on
matters related to meetings; work on documents for production related to damages and
proof of the same; analyze issues on the same.
5.00 385.00/hr 1,925.00
04/16/13 TJC Receipt and review of mediation correspondence from Pete Schroeder, agreed upon
mediator. Addressed issues related to pending requests for discovery depositions of Ruby
and Creviston; likely interviews of former employees of SSE; and preparation for status
conference.
0.90 475.00/hr 427.50
04/17/13 ATD Prepare Notice of Deposition and Subpoena re: Creviston deposition. Obtain services of
court reporter. Communications with Strawbridge re: same.
0.75 205.00/hr 153.75
04/17/13 BPH Strategize legal issues regarding damages claims, economic loss doctrine and pleading in
the alternative.
1.25 215.00/hr 268.75
04/17/13 BSS Multiple emails and calls with counsel for Creviston regarding scheduling of deposition of
Jack Creviston and issues with Creviston's document production. Conference calls with
court reporters and videographers re: Creviston Deposition. Coordinated preparation of
subpoenas and notices of deposition. Researched issues related to double recovery of
damages, election of certain claims for recovery, economic loss doctrine, and no damage
for delay clauses. Worked on preparing/drafting witness/deposition outlines. Strategized
regarding trial timeline issues. Phone conferences with SSE"s counsel regarding
contacting SSE employees, motion to extend certain deadlines filed by SSE, and other
matters. Drafted correspondence to counsel for SSE and Creviston.
3.75 250.00/hr 937.50
04/17/13 GTS Prepare CPS documents for production. Prepare Krieg DeVault invoices for production
Prepare doCUments referenced in Rob Schein's 4/15/2013 letter to Mr. Creviston's counsel.
3.10 175.00/hr 542.50
CRML 00001 Page 8
Invoice#352935
04/17/13 MQ Review and analysis of damages issue regarding alternative counts in the Complaint.
Analyzed causation and comparative fault reductions to damages.
1.25 415.00/hr 518.75
04/17/13 RSS Review and analyze issues related to Jack Creviston Deposition; work and analyze issues
related to the same; review and analyze issues related to additional SSE depositions;
follow up on the same; analyze issues related to WPM matters and follow up on the same;
call with WPM on matters related to trial; follow up on additional issues related to
damages and trial strategy on the same; work on the same; work on strategy matters for
trial and hearing on the same.
7.00 385.00/hr 2,695.00
04/17/13 TJC Preparation for deposition of Creviston. Analysis of issues related to pros and cons of
proceeding to trial on alternate theories of breach of contract and negligence.
Consideration of effect of economic loss doctrine and comparative fault.
1.60 475.00 /hr 760.00
04/18/13 ALA Draft Preliminary Witness and Exhibit Lists (0.50); redact invoices (0.50).
1.00 95.00/hr 95.00
04/18/13 ATD Letter to Drew Seaman -witness and mileage fee check re: Creviston deposition.
0.25 205.00/hr 51.25
04/18/13 BPH Perform legal research regarding the economic loss doctrine and its effect on negligence
claim damages resulting from construction contract.
1.10 215.00/hr 236.50
04/18/13 BSS Researched issues related to election of claims and comparative fault impact thereof.
Worked on redactions to attorneys fee records and coordinated production of supplemental
documents in response to requests for production for transmittal to SSE's counsel.
Coordinated deposition scheduling issues and correspondence regarding the same.
Worked on preparing damage exhibits for trial.
2.75 250.00/hr 687.50
04/18/13 RSS Analyze damages and trial matters; review of strategy and issues related to the same;
review of correspondence from SSE related to depositions and matters on the same; follow
up on mediation and deposition matters; analyze witness and exhibit matters for trial;
review of documents and potential exhibit matters.
6.50 385.00/hr 2,502.50
04/18/13 TJC Worked on preparation for deposition of Creviston. Addressed issues related to going to
trial on breach of contract and warranty claims only (not the negligence claim). Prepared
for status conference. Participated in conference call with Walter P. Moore.
2.10 475.00/hr 997.50
04/19/13 ALA Redact Invoices (3.25).
3.25 95.00/hr 308.75
CRML 00001 Page 9
Invoice#352935
04/19/13 BSS Worked on preparing supplemental production of documents, including privilege log,
damage documents to/from CPS, and attorney fee records and worked on redacting parts
of the same. Coordinated production of document issues with litigation support personnel.
Researched various issues related to election of remedies and impact on damages pursuant
to economic loss doctrine, Trial Rule 8(E) and other matters; strategized and memorialized
research relating to the same. Extensive teleconferences with WPM personnel to discuss
deposition and trial preparations. Drafted enclosure letter to SSE counsel enclosing
discovery materials. Worked on drafting examination outline of Jack Creviston.
5.25 250.00/hr 1,312.50
04/19/13 GTS Prepare production of CPS documents, Krieg DeVault invoices, and privilege log.
1.60 175.00/hr 280.00
04/19/13 RSS Analyze issues related to damages; work on the same; call with WPM on matters related
to Creviston issues; analyze trial matters related to witnesses, direct examination of
potential witnesses and issues related to trial; analyze matters related to outstanding issues
for depositions and witness preparation; strategize related to trial.
4.50 385.00/hr 1,732.50
04/19/13 TJC Conference call with Walter P. Moore. Prepared for deposition of Creviston.
3.50 475.00/hr 1,662.50
04/22/13 BPH Perform legal research regarding election of remedies and economic loss doctrine and
analyze issues related to the same.
1.25 215.00/hr 268.75
04/22/13 BSS Researched numerous issues related to presentation of claims and issues for trial, and
potential dismissal of negligence claim; analysis and preparation of summary thereof,
extended teleconferences regarding the same. Worked on preparing deposition outlines
for SSE employee Stamm and Creviston president Jack Creviston; strategized regarding
issues for inclusion therein.
2.50 250.00/hr 625.00
04/22/13 GTS Prepare documents for attorney review.
1.00 175.00/hr 175.00
04/22/13 RSS Review and analyze Shiel witnesses; call with Mike Anderson on matters related to trial;
call with Kris Altice on matters related to trial; call with Dave Brewer on matters related
to trial; review and analyze issues related to the same.
5.50 385.00/hr 2,1 17.50
04/22/13 TJC Analysis of whether to proceed to trial only on breach of contract (and not on negligence
theory). Prepared for depositions of former SSE employees.
0.70 475.00 /hr 332.50
04/23/13 BPF1 Perform legal research regarding economic loss doctrine, preclusion of tort claims and
apportionment of damages in breach of contract claim. Strategize with Mr. Strawbridge
regarding same. Draft comprehensive memorandum summarizing findings. Revise
memorandum.
CRML 00001 Page 10
Invoice#352935
5.20 215.00/hr 1,1 18.00
04/23/13 BSS Researched issues related to economic loss doctrine to detennine applicability as to
negligence count and strategy related to such research; extensive communications and
emails regarding the same; analysis of various memoranda.
1.50 250.00/hr 375.00
04/23/13 GTS Run searches and prepare documents for attorney review.
0.90 175.00/hr 157.50
04/23/13 RSS Analysis of legal issues related to depositions, exhibits, witnesses and trial matters; follow
up on the same; analyze trial strategy on depositions and related matters; analyze damages
matters; deposition strategy and preparation.
5.00 385.00/hr 1,925.00
04/23/13 TJC Addressed issues related to deposition of Jim Stamm, former employee of SSE. Analysis
of whether to withdraw negligence claim and only proceed to trial on breach of contract
and breach of warranty counts. Analysis of economic loss doctrine.
2.10 475.00/hr 997.50
04/24/13 ATD Prepare Subpoena and Notice of Deposition - James Stamm. Arrange for court reporter.
Order witness and mileage fee check. Communications with Strawbridge re: same.
0.75 205.00/hr 153.75
04/24/13 BPH Strategy teleconference with Mr. Schein, Mr. Costakis and Mr. Strawbridge in preparation
for upcoming hearing before Judge Nation.
1.00 21 5.00/hr 215.00
04/24/13 BSS Worked on revising, supplementing and researched issues for memorandum addressing
the relevant theories and issues associated with election of remedies, effects of fault
allocation on contractual claims, and economic loss doctrine, and prepared enclosures and
appendices regarding the same; multiple teleconferences regarding the same. Conference
call to determine whether to proceed with negligence count. Prepared deposition notice
and subpoena for former SSE employee, James Stamm; corresponded with SSE's counsel
regarding the same; teleconferences regarding scheduling of Stamm's deposition along
with SSE personnel Dieter Kohn and Christian Crosby. Teleconference with J. Stamm,
former employee of SSE, regarding deposition and case generally. Revised Notices of
Deposition and Subpoenas.
5.25 250.00/hr 1,312.50
04/24/13 GTS Prepare documents for attorney review. Run searches for additional documents per
attorney request.
1.70 175.00 /hr 297.50
04/24/13 MQ Analyzed issue regarding deposition of out of state witnesses. Researched material
regarding Uniform Deposition and Discovery Act.
0.50 415.00/hr 207.50
04/24/13 RSS Review and analyze issues related to trial; analyze strategy related to witnesses and
CRML 00001 Page 1 1
Invoice#352935
exhibits and rebuttal matters; work on the same; analyze issues related to hearing on
Friday and trial matters; review of discovery related issues; follow up on issues related to
WPM and related matters; follow up on matters related to depositions and related issues;
analyze the same; analyze legal strategy related to economic loss doctrine and matters on
the same.
7.00 385.00/hr 2,695.00
04/24/13 TJC Analysis of pros and cons of withdrawing negligence claim. Prepared for status
conference with the court. Addressed deposition issues.
1.40 475.00/hr 665.00
04/25/13 BSS Extended teleconference with WPM regarding depositions of SSE personnel, D. Ruby, J.
Creviston and other personnel. Prepared for hearing on 4/26 with Judge Nation to address
trial setting and truss damage issues and admissibility of evidence related to the same.
Worked on preparing deposition outlines.
3.25 250.00/hr 812.50
04/25/13 GTS Run searches for documents in response to Rob Schein's request and in preparing of
Creviston deposition.
0.40 175.00/hr 70.00
04/25/13 JCM Analyzed issues regarding issues relating to upcoming pretrial conference. Analysis of
strategies relating to possible request by defense for continuance of trial or exclusion of
evidence.
0.75 475.00/hr 356.25
04/25/13 RSS Review and analyze issues related to liability and matters for trial; analyze WPM analysis
and issues on the same; follow up on matters related to the same; follow up on issues
related to SSE deposition and information needed for the same; analyze documents related
to the same; analyze matters for hearing on trial issues and potential truss matters; review
of matters for the same; call with WPM on matters related to trial.
5.00 385.00/hr 1,925.00
04/26/13 BPH Meet with Mr. Strawbridge regarding trial strategy. Draft and revise deposition outline of
Mr. Stamm of SSE in preparation for upcoming deposition.,
2.50 215.00/hr 537.50
04/26/13 BSS Prepared for hearing with Court to address case scheduling, orders on motions in
limine/motions to exclude, and summary judgment briefings, among other things.
Attended such hearing and argued these issues. Strategized regarding filing Objection to
Motion for Leave to File Summary Judgment as well as revisions to order on motion in
limine/motion to exclude. Researched issues in support of these filings. Worked on
drafting such Objection. Review of emails from Arcan and Creviston.
6.50 250.00/hr 1,625.00
04/26/13 MQ Follow up regarding status of hearing and analyzed issue regarding breach of contract
claim.
0.25 415.00/hr 103.75
CRML 00001 Page 12
Invoice#352935
04/26/13 RSS Review and analysis of matters in anticipation of hearing with Judge Nation; analyze
issues related to matters needing completed by discovery deadline; analysis of issues
related to SSE depositions and exhibits; review of the same; attend hearing related to trial
matters; follow up on issues going forward and objection to related procedural matters;
analyze issues related to claims and strategy for trial.
7.00 385.00/hr 2,695.00
04/26/13 TJC Prepared for court conference. Attended pretrial hearing. Strategy following up and
based on hearing.
5.00 475.00/hr 2,375.00
04/29/13 ATD Contact court reporter and advise them of change of time for Stamm deposition.
0.25 205.00/hr 51.25
04/29/13 BPH Compile and manage discovery requests sent and received to and from Steel Supply and
Engineering in preparation for trial. Review exhibits from Walter P. Moore in preparation
to include in trial materials. Review and revise Objection to Defendants' Motion to
Continue Dispositive Motion Deadline.
1.90 215.00/hr 408.50
04/29/13 BSS Worked on drafting Objection to Motion to Continue Dispositive Motion Deadline filed
by SSE's counsel and strategized regarding the same. Strategized regarding moving for
summary judgment and responding to SSE's attempts to do the same at this belated hour.
Researched and analyzed contractual provisions in voluminous Contract Documents and
outlined legal arguments and theories for trial presentation to demonstrate SSE's breaches
thereof. Analysis of Ruby's expert report as well as WPM's report. Prepared deposition
outline for J. Stamm for May 2 deposition and coordinated with Court Reporter regarding
the same. Strategized regarding deposition of J. Creviston. Correspondence with SSE's
counsel regarding depositions of Klohn, Crosby, and Ruby; and strategized regarding the
same. Coordinated with litigation support personnel regarding review of SSE's emails.
Drafted memoranda addressing trial strategies.
7.50 250.00/hr 1,875.00
04/29/13 GTS Prepare documents in response to Rob Schein's request regarding Crevistion deposition.
Call with Bryan Strawbridge documents searches.
1.20 175.00/hr 210.00
04/29/13 RSS Review and analyze issues related to Order from hearing; provided comments to the same;
correspond with Les Olds, Karl Haas and Ryan Wilmering on the same; follow up on
issues related to Summary Judgment matters, objection to the same; and going forward
trial matters; review of those issues; call to CPS related to trial matters.
4.50 385.00/hr 1,732.50
04/29/13 TJC Receipt and reviewed court's draft order on pending matters discussed at status
conference. Worked on response to motion for leave to file belated motion for summary
judgment. Analysis of likely motion for summary judgment arguments of SSE. Analysis
of mediation and trial issues. Attention to bases for objecting to SSE's motion for leave to
file a motion for summary judgment. Revised and edited draft of objection.
1.90 475.00/hr 902.50
CRML 00001 Page 13
Invoice#352935
04/30/13 BSS Worked on drafting, revising, finalizing, and filing Objection to Defendants' Motion to
Extend Deadline to File Dispositive Motion and prepared proposed Order regarding the
same. Teleconferences with opposing counsel as well as correspondence regarding the
same. Correspondence to/from the Court regarding this Objection and Defendants' change
of opinion as to whether they will file such a dispositive motion. Analysis of SSE's
document production, specifically emails, in preparation for depositions of Stamm, Ruby,
and Creviston. Prepared deposition outlines for these individuals. Coordinated service of
deposition notice on counsel for Ruby. Researched contractual provisions in support of
breach of contract count and outlined provisions contained within General Conditions, Bid
Package, Specifications, Instructions to Bidders, and other Contract Documents, as
defined, to set forth theories for trial; prepared memorandum on the same. Numerous
correspondence regarding these issues.
6.75 250.00/hr 1,687.50
04/30/13 RSS Analysis of issues related to Jim Stamm deposition; analysis of issues related to objection
to summary judgment; correspond with Les Olds, Karl Haas and Ryan Wilmering on the
same; analysis of issues related to Ruby deposition; follow up on with SSE counsel on the
same; analysis of issues related to additional matters for trial and summary judgment;
analysis of issues related to damages; follow up with CPS on matters related to trial;
follow up with WPM on matters related to depositions and trial; prepare for Stamm
deposition; analysis of documents in preparation for the same.
6.50 385.00/hr 2,502.50
04/30/13 TJC Receipt and review of court order following status conference. Analysis of impact of SSE
deciding not to file a summary judgment motion. Receipt and review of Order excluding
claims related to Truss damages.
1.10 475.00/hr 522.50
Total Fees for this Matter: 277.55 $ 87,551.25
ALA Aldridge, April L. 4.25 hrs 95.00/hr 403.75
TJC Costakis, Thomas J. 29.80 hrs 475.00/hr 14,155.00
ATD Deibert, Andrew T. 2.25 hrs 205.00/hr 461.25
BPH Holler, Blake P. 36.50 hrs 215.00/hr 7,847.50
JCM McDermott, Jeffrey C. 0.75 hrs 475.00 /hr 356.25
MQ Quigley, Marc T. 2.00 hrs 415.00/hr 830.00
RSS Schein, Robert S. 106.00 hrs 385.00/hr 40,810.00
GTS Smith, Gary T. 17.50 hrs 175.00/hr 3,062.50
BSS Strawbridge, Bryan S. 78.50 hrs 250.00/hr 19,625.00
Total: 277.55 hrs $ 87,551.25
Color Copies 4.00
Photocopies 16.60
04/01/13 VENDOR: Bryan Strawbridge; INVOICE#: EX040413; 14.00
DATE: 4/1/2013; Travel to/from Hamilton Couty for hearing
CRML 00001 Page 14
Invoice#352935
04/04/13 Computerized Research - Westlaw 121.72
04/16/13 Computerized Research - Westlaw 73.18
04/17/13 PAYEE: Jack Creviston; REQUEST#: 16608; DATE: 75.00
4/18/2013. - Witness and Mileage Fee
04/19/13 Computerized Research - Westlaw 73.18
04/23/13 Computerized Research - Westlaw 195.32
04/24/13 Computerized Research - Westlaw 73.18
04/24/13 PAYEE: James Stamm; REQUEST#: 16737; DATE: 22.00
4/24/2013. - Witness and mileage fees
04/26/13 Computerized Research - Westlaw 24.39
04/30/13 VENDOR: Bryan Strawbridge; INVOICE#: EX043013; 17.00
DATE: 4/26/2013; Travel to/from Hamilton County Court
Total Disbursements for this Matter: $ 709.57
TOTAL FEES: $ 87,551.25
TOTAL DISBURSEMENTS: $ 709.57
TOTAL CHARGES FOR THIS BILL: $ 88,260.82
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
Prescribed by State Board of Accounts ACCOUNTS PAYABLE VOUCHER City Form 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
f��J e�� Purchase Order No.
Terms
Date Due
Invoice Invoice Description Amount
Date Number (or note attached invoice(s) or bill(s))
5 3}-13 1 'm 000012- 82
Total 8b Z �9 it
1 hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have audited same in accordance
with IC 5-11-10-1.6.
20
Clerk-Treasurer
VOUCHER NO. WARRANT NO.
ALLOWED 20
t' C
V14Y IN SUM OF $
$ fig, 26(x, gZ
ON ACCOUNT OF APPROPRIATION FOR
022/ 4Y�0967
Board Members
PO#or INVOICE NO. ACCT#/TITLE AMOUNT
DEPT.# I hereby certify that the attached invoice(s), or
QZ 351935 *466907 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
6-17- 2013
Title
Cost distribution ledger classification if
claim paid motor vehicle highway fund AKrC-11 S- � °°"