HomeMy WebLinkAboutKRIEG DEVAULT LLP- 002962- 6/21/2012 , CARMEL REDEVELOPMENT COMMISSION
002962
Krieg Devault LLP
One Indiana Square Check: 2962
Suite 2800 Date: 6/21/2012
Indianapolis, IN 46204-2079 Vendor: KRIEGDE1
I voice P.O. Num. rior
322651 Invoi-_ .Amt Balance Retention
' 81,067.85 81,057,85 Discount.0 Amt.Legal services Feb 2012 0.00
0.00 81,067..
322652 37,502.84
. legal services March 2012 37,502.84 0.00 O.OD 37,502.F
118,570.69 118,570.69 0.00
0.00 118,570.e
•
•
,,V fa-,:t SECURITY%HEATACT1VATEpITHUMS PRINT ADDITIONAL SECURITY FEATURES INCLUDED7•,!SEE BACK iFOR DETAILS ??_!
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Visa oe,,_4 Carmel Redevelopment Commission ^' '
I r i 7°
® ,L 30 West Main Street A REGIONS 002962
a ° '^ Suite 220 xo-1,2inao
o` ""4'3 Cannel, IN 46032
Arnie
•
DATE 2962
AMOUNT
6/21/2012 "***** 118,570.89
PAY THE SUM OF ONE HUNDRED EIGHTEEN THOUSAND FIVE HUNDRED SEVENTY DOLLARS AND 69 CENTS """
TO THE
ORDER
OF Krieg Devault LLP
One Indiana Square
Suite 2800
Indianapolis, IN 46204-2079
m
11'002962+1' 1:074014213,.
' 0087504i1i�1'
One Indiana Square
". KRIEG I �EVAULT Suite 2800
I Indianapolis,IN 46204-2079
T:317.636.4341
F:317.636.1507
Fed, FAN tt 35-1055087
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• Cannel Redevelopment Commission
Les Olds, AIA, Executive Director
30 West Main Street, Suite 220
Carmel, IN 46032
• May 7, 2012
Invoice Number 322652
Our File #: CRIME 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH March 31, 2012
03/01/12 ATD Finalize and file Disclosure Statements re: Strawbridge, Schein and Costakis with 7th
Circuit Court of Appeals. communications with Clerk re: same.
1.25 195.00/hr 243.75
03/01/12 BB Review and analysis of documents for production.
A104 4.30 230.00/hr 989.00
03/01/12 BSS Worked on revising responses to SSE's discovery requests and strategized regarding the
same. Researched issues related to Disclosure Statement. Strategized regarding
documents supplied by WPM and analysis of the same. Analyzed documents to be
produced. Researched Seventh Circuit appellate rules related to record and disclosure
statements.
2.75 230.00/hr 632.50
03/01/12 GTS Prepare ESI from Walter P. Moore for processing. Search database for documents
responsive to attorney request.
3.00 175.00 /hr 525.00
03/01/12 RSS SSE: Review and analyze issues related to discovery matters; drali and work on the same;
review of documents and work on the same.
6.75 360.00 /hr 2.430.00
03/01/12 TJC Addressed issues related to initial corporate disclosure for seventh circuit. Revised and
edited craft discovery responses. Reviewed and analyzed email communications between
'�' • ,`M,h .-.. i {•. .
,rINUTANAr', •s - ILI INOIS GEORGIA 'n ' ° ;, R i s rI ORID MC' MINNESOTA a
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CRML 00001 Page 2
Invoicet/ 322652
CRC and WPM. Addressed issues related to Walter P. Moore documents to be produced
to SSE.i
2.25 455.00 /hr 1,023.75
• 03/02/12 BB Review and analysis of documents for production.
A104 4.00 230.00/hr 920.00
03/02/12 BSS Worked on revising written discovery responses to SSE's Set of Interrogatories.
Significant correspondence and multiple teleconferences regarding the same. Analyzed
documents to be produced.
1.75 230.00/hr 402.50
03/02/12 RSS SSE: Analyze issues related to discovery matters; calls to WPM on matters related to the
same.
0.50 360.00 /hr 180.00
03/02/12 TX Prepared for settlement conference on appeal by SSE of award of attorneys fees.
Addressed discovery issues related to SSE.
1.00 455.00 /hr 455.00
03/03/12 BB Review and analysis of documents for production.
A104 1.60 230.00/hr 368.00
03/03/12 RSS SSG: Analyze issues related to strategy of case.
0.25 360.00/hr 90.00
03/03/12 RSS SSE Mediation: Review and prepare on matters related to 7th Cir. mutters; work and
prepare on the same.
1.00 360.00/hr 360.00
03/04/12 T.IC Reviewed Circuit Rule 33 and related directives from the seventh circuit related to
settlement conference. Prepared for conference both as it relates to narrow issue, and the
broader issues, to the extent that is direction sought by SSE and/or the mediator.
1.00 455.00/hr 455.00
03/05/12 AID Update and place on system all items which have been filed with 7th Circuit Court of
Appeals.
0.50 195.00/hr 97.50
03/05/12 1355 Non-Charge: Settlement Conference with Seventh Circuit regarding resolution of appeal.
Conferences with Les Olds, T. Costakis, and R. Schein regarding settlement of appeal.
Worked on and researched various matters related to appeal.
3.90 0.00/hr 0.00
03/05/12 GfS Call with Walter P. Moore regarding resending data from two corrupted discs. E-mails
regarding issues with corrupted disks from Walter P. Moore and replacements.
1 .25 175.00/hr 218.75
03/05/12 RSS SSG 7th Circ matters: Review and work on matters related to appeal and mediation; attend
•
•
CRML 00001 Page 3
Invoice,/ 322652
mediation; analyze issues on the same.
9.50 360.00 /hr 3,420.00
03/05/12 TJC Prepared for and participated in settlement conference conducted by seventh circuit related
to SSE appeal. Addressed issues related to Walter P. Moore's document production.
5.50 455.00/hr 2,502.50
03/06/12 BSS Strategized regarding discovery production and written responses.
0.50 230.00/hr 115.00
03/06/12 RSS SSE: Analyze issues related to discovery matters; work on the same; review of answers
and review of documents.
2.75 360.00/hr 990.00
03/06/12 TPS Analysis/review of emails for privilege/responsiveness.
2.00 230,00 /hr 460.00
03/07/12 BSS Meeting with SSE's counsel and Shiel Sexton to review documents are produced by Shiel
Sexton in response to nonparty requests for production and subpoena duces tecum.
Strategized regarding discovery issues. Correspondence and analysis related to settlement
discussions of appeal with SSE.
2.50 230.00/hr 575.00
03/07/12 GTS Prepare electronic data received from Shiel Sexton for processing.
1.75 175.00 /hr 306.25
03/07/12 RSS SSE. Discovery: Review and analyze issues; review of documents; work on the same;
meeting at Shiel to review non-party requests by SSE; analyze issues on the same.
4.25 360.00/hr 1,530.00
03/07/12 TJC Addressed discovery issues related to CRC's electronic production, Shiel's production, and
LHB's production.
0.50 455.00/hr 227.50
03/07/12 TPS Continued review/analysis of CRC entails.
1.25 230.00 /hr 287.50
03/08/12 BSS Strategized and reviewed documents to he produced in response to discovery matters and
analysis of documents supplied by LH13 and Shiel Sexton.
0.75 230.00 /hr 172.50
03/08/12 GTS Prepare electronic data from Walter P. Moore for processing. Begin processing data.
2.35 175.00 /lir 411.25
03/08/12 RSS LI-1B meeting at office for Discovery review with SSE counsel; follow up and analyze
issues related to the same.
5.00 360.00 /hr 1,800.00
03/08/12 TIC Attention to issues of discovery related to LI-1B production.
•
•
CRML 00001 Page 4
Invoicel 322652
0.50 455.00/hr 227.50
03/08/12 TPS Review/analysis of CRC discovery.
3.00 230.00/hr 690.00
03/09/12 BSS Correspondence and analysis related to Seventh Circuit appeal settlement.
0.25 230.00/hr 57.50
. 03/09/12 GTS Load electronic data to database and prepare for attorney review.
1.53 175.00/hr 267.75
' 03/09/12 RSS SSE 7th circuit matters; Analyze issues related to settlement; call with Mediator on the
same; follow up with Les Olds on the same.
0.50 360.00 /hr 180.00
03/09/12 RSS SSE discovery; review of documents and issues to discovery.
0.50 360.00/hr 180.00
• 03/10/12 TPS Review/analysis of CRC email discovery.
2.00 230.00/hr 460.00
03/12/12 BSS Research issues regarding stipulation dismissal of appeal before the Seventh Circuit Court
of Appeals. Strategized regarding production of documents responsive to SSE's discovery
requests. Coordinated document review analysis for privilege.
0.75 230.00 /hr 172.50
03/12/12 GTS Import electronic data into database for attorney review.
2.53 175.00 /hr 442.75
03/12/12 RSS SSE: Analyze issues related to discovery matters; work on the same.
0.50 360.00/hr .180.00
03/12/12 RSS 7th Circuit: Analyze issues related settlement amount; call to 7th Circuit Mediator; follow
up with Les on the same.
0.25 360.00 /hr 90.00
03/12/12 TPS Analysis/review of emails for CRC discovery.
2.50 230.00 /hr 575.00
03/13/12 TJC Review and analysis of portions of documents produced by Walter P. Moore in response
to SSE's subpoena, with special attention to any emails between WPM and the CRC.
0.50 455.00/hr 227.50
03/13/12 TPS Analysis/review of emails for CRC discovery.
1.75 230.00/hr 402.50
03/14/12 BSS Analyzed documents for responsive/privilege from CRC's email and prepared production
in response to SSE's discovery requests. Worked on written discovery requests.
Coordinated review of documents supplied by CSO, LHB, WPM and Shiel; analyzed the
CRML 00001 Page 5
Invoice# 322652
same. Strategized regarding various discovery matters.
1.50 230.00/hr 345.00
03/14/12 GTS Process electronic data in preparation for export to database. Conference call regarding
WPM, CSO, and Shiel Sexton third party electronic data to be processed.
3.03 175,00/hr 530.25
03/14/12 RSS SSE: Review and analyze issues related to discovery matters; work on strategy and
matters going forward,
1.25 360.00 /hr 450.00
03/14/12 TiC Reviewed proposals and communications from opposing counsel and counsel for Shiel
and LEIB related to use of a third party vendor to stage and produce electronically search
able databases.
0.50 455.00 /hr 227.50
03/14/12 TI'S Analysis/review of emails for CRC discovery.
1.00 230.00 /hr 230.00
03/15/12 BSS Strategized and worked on document production issues. Coordinated with litigation
support personnel regarding the same.
0.30 230.00 /hr 69.00
03/15/12 GTS Prepare electronic data for processing.
0.92 175.00 /hr 161.00
03/15/12 RSS SSE: Review of discovery matters for CSO; review and analyze issues related to SSE
discovery; work on the same.
1.25 360.00/hr 450.00
03/15/12 TJC Addressed issues related to timing and cost of completion of non-party discovery from
CSO and Shiel.
1.00 455.00/hr 455.00
• 03/15/12 ITS Analysis/review of emails for CRC discovery.
3.50 230.00/hr 805.00
03/16/12 GTS Prepare data for import into Summation database.
3.90 175.00/hr 682.50
03/16/12 RSS SSE: Analyze issues related to discovery matters and issues on production of CRC
documents; call with SSE counsel on matters related to the same; correspond with SSE on
issues related to CRC discovery; follow up on issues related to Walter P Moore discovery.
1 .75 360.00 /hr 630.00
03/16/12 TPS Analysis/review of emails for CRC discovery.
2.00 230.00/hr 460.00
03/19/12 BSS Analyzed and worked on discovery responses.
•
CRML 00001 Page 7
Invoice#322652
03/26/12 RSS SSE: Work on outstanding matters related to discovery.
0.75 360.00/hr 270.00
03/28/12 RSS SSE: Work on discovery related matters; analyze issues on the same.
0.50 360.00 /hr 180.00
03/28/12 TJC Outlined time line for completion of 3rd party discovery, completion of Walter P. Moore
liability report, initiation of arbitration against LIMB, and potential global mediation.
0.40 455.00 /hr 182.00
' 03/29/12 RSS SSE: Analyze SSE discovery related matters.
0.50 360.00 /hr 180.00
03/30/12 RSS SSE: Follow up on matters related to outstanding discovery and issues on the same.
0.50 360.00 /hr 180.00
Total Fees for this Matter: 139.41 $ 37,462.50
BB Billingsley, Birk K. 9.90 hrs 230.00/hr 2,277.00
TJC Costakis, Thomas J. 13.15 hrs 455.00 /hr 5,983.25
ATD Deibert, Andrew T. 1.75 hrs 195.00/hr 341.25
RSS Schein, Robert S. 40.25 hrs 360.00 /hr 14,490.00
GTS Smith, Gary T. 33.36 hrs 175.00 /hr 5,838.00
TPS Stafford, Thomas P. 24.75 hrs 230.00/hr 5,692.50
BSS Strawbridge, Bryan S. 16.25 hrs 174.80 /hr 2,840.50
Total: 139.41 hrs $ 37,462.50
03/01/12 VENDOR: Sonia Ray; INVOICE#: ER030112; DATE: 16.35
3/1/2012; Travel by Messengers (Oce)
03/18/12 VENDOR: Now Courier & Messenger; INVOICE.#: 63643; 23.99
DATE: 3/18/2012; Courier Services
Total Disbursements for this Matter: $ 40.34
TOTAL FEES: $ 37,462.50
TOTAL DISBURSEMENTS: $ 40.34
TOTAL CHARGES FOR THIS BILL: $ 37,502.84
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
'b I<RIEG I :EVAULT WWW,KRIEGIDEVAUIT.com
May 7, 2012 Robert S.Schein
Direct Dial: (317)23S-6278
E-mail: rschein.kdlega I,cuni
Delivered via Entail and U.S. Mai/
Les A. Olds AIA
Carmel Redevelopment Commission
30 West Main Street._ Suite 220
Carmel IN 46032
Re: Krieg DeVault Summary of Invoices for February and March, 2012
Dear Les:
Enclosed are Krieg DeVault's attorney fee statements for the months of February
and March, 2012. As discussed, I have separated matters related to the SS&E litigation and
the Crider/Hagerman litigation and will itemize them below for you.
As discussed with the SSE litigation, we have incurred significant costs relating to
the discovery review and analysis served by SSE. We utilized several attorneys for this
review process that have higher billing rates than Bryan's (5230/hour). Accordingly, we
have billed the rates for those attorneys reviewing discovery at Bryan's rates. This
accounted For an approximate 57,200.00 savings.
In addition to the discovery, we incurred costs related to the Seventh Circuit appeal
and Mediation. We provided Bryan's time participating in the Seventh.Circuit Mediation
on a Non-Charge basis.• This was 5897.00. Further. we should receive the 531 ,000
settlement check from counsel to SSE this week and will follow up.
Additionally, we utilized the services of our Litigation Specialist. Gary Smith, in-
house to process in excess of 140 GB of discovery rather than a 3`a party company in an
effort to save the CRC costs related to the discovery production. Gary provided this
service on a Non-Charge basis. If we were to outsource this processing, we would have
incurred anywhere from 5275-5400/GB in additional expense to the CRC. As a result, we
saved the CRC between 538,775-556,400 in processing changes for the discovery.
As you know. we arc working with Walter P. Moore through this discovery process
so that we may obtain their expert report as expeditiously and cause effective as possible
and will continue to follow up with them in that. regard.
12800 NORTH MERIDIAN STREET, SUITE 300, CARREL, IN 46032-5406 T 317.S66.I 110 F 317,636.1507
Ifi MERITRS LAW FlRM11fi WORLDWIDE
It KRIEG I DEVAULTM WWW.NRIEGDEVAULT.CGM
Les A. Olds AIA
May 7; 2012
Page 2
With respect to the Crider/Hagerman litigation, we incurred fees related to
• Mediation with Bill 13aten on the Crider piece and potential settlement of the lawsuit tiled
in Fort Wayne, Indiana. We will continue to pursue those settlement discussions as
• indicated with Crider and work aggressively to address the venue issue with Hagerman.
Again we are mindful of the costs of the litigation and are working diligently
towards moving this case forward. Should you have any questions, please do not hesitate
to contact me anytime.
• Summary of Litigation matters below
SSE Litigation CRML l :
February: $81,1I8.00
March: $37,502.84
Total: $118.620.84
2. Crider/Hagerman Litigation CRML-3:
February: $13,941.25 " Pa
March: $ 540.00 -P1
$14,481.25
Sincerely,
Reber S. Sche
RSS:crg
Enclosures
Cc: Karl Haas (Delivered via Entail only)
Ryan Wilmering (Delivered via Email only)
Thomas J. Costakis, Esq.
Andrew B. 13uroker, Esq.
hn 4I5541i7 .DOCX
LI .y.. One Indiana Square
KRIEG I DEVAULI Suite 2800
g„ Indianapolis,IN 46204-2079
'F:317.636.4341
F:317.636.1507
Fed. EIN N 35-1055087
11.4I127,,s�lA i ' ' wi§i t 1 y., t 7 t _ ry G3 R n.` 'J' I i "%147 "Y 91_
rW1VW Klill GDI VAULT COM ''. .
• Carmel Redevelopment Commission
Les Olds, ALA, Executive Director
. 30 West Main Street, Suite 220
Carmel, IN 46032
• May 7, 2012
Invoice Number 322651
Our File #: CRML 00001 ABI3
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH February 29, 2012
02/01/12 BSS Conducted document review of emails supplied by CRC and reviewed privileged search
terms analyzed in documents.
4.00 230.00 /hr 920.00
02/01/12 CiTS Conference call regarding document review.
0.75 175.00 /hr 131.25
02/01/12 GTS Prepare CRC ESI for attorney review.
2.25 175.00/hr 393.75
02/01/12 KDV Began preparations to begin document review.
0.10 230.00/hr 23.00
02/01/12 RSS SSE: Work on matters related to ediscovery; call with Shiel Sexton on matters related to
litigation and discovery; follow up on the same; calls on eDiscovery and matters received
from CRC; analyze issues related to the same.
1.50 360.00/hr 540.00
02/01/12 TJC Worked on plan of action for processing electronically stored information, including
culling for privilege and relevancy via search terms.
0.50 455.00/hr 227.50
02/02/12 BSS Worked on analyzing documents for responsiveness and privilege in preparing responses
to SSE's discovery requests. Drafted memorandum for document reviewers to utilize in
11 4t i N� i -`.`6tr 4 - r....
' INDIANA''* ILLINOIS GEORGIA ` .rLO1tIDAy � MINNESOTA
CRML 00001 Page 2
Invoice#322651
analyzing documents.
4.50 230.00 /hr 1,035.00
02/02/12 GTS Strategize and prepare for document review. Prepare database for attorney review of
documents.
6.00 175.00 /hr 1,050.00
02/02/12 KDV Strategized and began preparing for document review process.
2.00 230.00/hr 460.00
02/02/12 RBE Analysis of discovery strategy pertaining to electronically stored documents.
2.00 230.00/hr 460.00
02/02/12 RSS SSE: Analysis of SSE. discovery responses; review and work on issues related to
production and eDiscovery matters; review and analyze issues related to discovery; call on
the same.
4.50 360.00/hr 1,620.00
02/02/12 TJC Strategy meeting on discovery and liability issues. Receipt of communication from
counsel for SSE regarding CSO discovery responses. Reviewed and revised
memorandum summarizing case for electronic review team. Addressed issues related to
staging of rolling production. Addressed issues related to use of a joint agreement
regarding confidentiality of discovery, that will not be problematic for the City in terms of
open records.
3.00 455.00 /hr 1,365.00
02/03/12 BSS Analyzed discovery responses for privileged and responsiveness in emails provided by
CRC to respond to Requests for Production.
2.20 230.00 /hr 506.00
02/03/12 KDV Continued preparing for document review of emails in response to discovery requests.
0.30 230.00 /hr 69.00
02/06/12 BSS Analyzed documents provided by the CRC for responsiveness and privilege as it relates to
SSE's Requests for Production.
5.90 230.00 /hr 1,357.00
02/06/12 KDV Continued document review.
1.30 230.00 /hr 299.00
02/06/12 RBE Analysis of documents for production.
5.25 230.00 /hr 1,207.50
02/06/12 RSS SSE discovery matters: Work and analyze issues related to discovery matters.
0.50 360.00 /hr 1 30.00
02/06/12 DC Attended to logistics of review of LI-1B document production as a function of coordination
with SSE. Prepared for conference call with counsel for SSE.
0.75 455.00 /hr 341.25
CR IL 00001 Page 3
Invoice#322651
02/07/12 BB Review and analysis of documents for production.
A 1 04 1.20 230,00/hr 276.00
- 02/07/12 BSS Analyzed documents provided by the CRC for responsiveness and privilege as it relates to
SSE's Requests for Production.
8.00 230.00/hr 1,840,00
02/07/12 KDV Continued document review.
2.40 230.00 /hr 552.00
02/07/12 RBE Analysis of documents for production.
6.25 230.00 /hr 1,437.50
02/07/12 RSS SSE Litigation: Work on discovery matters for call; discovery call with opposing counsel;
follow up on issues related to the same; correspond with Karl Haas and Ryan Wilmering
on matters related to the same.
3.25 360.00 (hr 1,170.00
02/08/12 1313 Review and analysis of documents for production.
4.104 140 230.00 /hr 322.00
02/08/12 BSS Analyzed documents provided by the CRC for responsiveness and privilege as it relates to
SSE's Requests for Production. Analyzed Notice of Appeal filed by SSE and strategized
regarding the same.
2.25 230.00 /hr 517.50
02/08/12 GTS Run additional privilege searches across electronic data.
1 .10 175.00/hr 192.50
02/08/12 KDV Continued document review.
0.20 230.00/hr 46.00
02/08/12 KBE Analysis of documents for production; drafted confidential claw-hack agreement.
5.50 230.00/hr 1,265.00
02/08/12 RSS SSE: Review and analyze issues related to discovery matters; review and analyze issues
related to appeal of District Court's ruling on Remand issues.
1.25 360.00 /hr 450.00
02/08/12 TIC Attention to efforts to ensure complete culling (electronically) of potentially privileged
materials. Receipt, review and analysis of notice of appeal filed by SSE in connection
with order to pay fees on removal. Analysis of SSE's strategy in doing so. Revised and
edited draft of claw-back agreement.
1.75 455.00/hr 796.25
02/09/12 'BB Review and analysis of documents for production.
A104 7.00 230.00 /hr 1.610.00
CItML 00001 Page 4
Invoice#322651
02/09/12 B55 Analyzed appellate documents transmitted by Clerk of Southern District of Indiana to
Seventh Circuit Court of Appeals and researched applicable deadlines and tasks
implicated by filing of Notice of Appeal. Strategized regarding appellate issues raised by
SSE and researched the same. Worked on preparing documents responsive to SSE's
Request for Production in analyzing for responsiveness and privileged.
5.75 230.00/hr 1,322,50
02/09/12 RUE Analysis of documents for production.
3.50 230.00/hr 805.00
02/09/12 TJC Receipt and review of appellate pleadings filed on behalf of SSE. Strategy and planning
in connection with the appeal.
1.00 455.00/hr 455.00
02/10/12 BB Review and analysis ol'documents for production.
A 104 5.30 230.00 /1w 1,219.00
02/10/12 BSS Analyze electronic documents, e-mails, and hard copies provided by CRC to determine
responsiveness to SSE's discovery requests and analyzed for privilege.
4.75 230.00 /1r 1,092.50
02/10/12 JDH Work on review and analysis of electronic discovery.
4.00 230.00/hr 920.00
02/11/12 BSS Analyzed electronic documents, e-mails, and hard copies provided by CRC to determine
responsiveness to SSE's discovery requests and analyzed for privilege.
1.25 230.00/hr 287.50
02/11/12 KDV Continued document review in order to prepare discovery responses.
1.60 230.00 /hr 368.00
02/12/12 BSS Worked en analyzing electronic documents, e-mails, and hard copies provided by CRC to
determine responsiveness to SSE's discovery requests and analyzed for privilege.
1.40 230.00 /hr 322.00
02/13/12 BB Review and analysis of documents for production. •
A104 7.30 230.00/hr 1,679.00
02/13/12 BSS Correspondence and teleconferences regarding discovery matters. Worked on analyzing
and preparing production of documents responsive to SSE's discovery requests.
2.50 230.00/hr 575.00
02/13/12 JDI-1 Work on review of electronic discovery.
5.00 230.00 /hr 1,150.00
02/13/12 RBE Analysis of documents for production.
5.75 230.00 /hr 1,322.50
02/13/12 TIC Attention to series ofdates and deadlines for both SSE and CRC related to the appeal by
CRML 00001 Page 5
Invoice# 322651
SSE of the order by the federal district court regarding payment of CRC's fees as a result
of the improper removal.
0.25 455.00 /hr 113.75
02/14/12 BSS Worked on drafting written discovery responses to SSE's discovery requests. Analyze
documents, primarily.e-mails, produced by CRC for responsiveness privilege.
2.00 230.00/hr 460.00
02/14/12 GTS Load documents to database for attorney review.
0.60 175.00 /hr 105.00
' 02/14/12 RBE Analysis of documents for production.
4.50 230.00/hr 1,035.00
02/15/12 BSS Analyzed documents, primarily e-mails, produced by CRC for responsiveness privilege.
Worked on drafting written discovery responses to SSE's discovery requests.
2.20 230.00 /hr 506.00
02/15/12 CES Hagerman: Analysis and review of Indiana case law regarding Indiana Rules of Trial
Procedure 75 "Preferred Venue" and 12(B)(3) Motion to Dismiss for Incorrect Venue to
determine whether the actions of prior counsel for the City of Carmel effectively waived
or served to estop Carmel from contesting the issue of venue.
1.00 210.00/hr 210.00
02/15/12 GTS Load documents to Summation database for attorney review.
0.25 175.00 /hr 43.75
02/I5/12 GTS Communications regarding documents for review.
0.50 175.00 /hr 87.50
02/15/12 RBE Analysis of documents for production.
0.25 230.00/hr 57.50
02/15/12 RSS SSE: Analysis of discovery related matters; call to Shicl on matters related to the same.
0.50 360.00 /hr 180.00
02/16/12 GTS Communications regarding documents for review and documents to be produced.
0.25 175.00 /hr 43.75
02/16/12 RBE Analysis of documents for production.
4.50 230.00/hr 1,035.00
02/16/12 RSS SSE: Analyze issues related to discovery; work on discovery responses; review of the
same; follow up on issues related to Shicl discovery; follow up on issues related to
Nonparty discovery.
2.25 360.00 /hr 810.00
02/16/12 TiC Addressed issues related to discovery, production of CRC's documents, receipt of SSE's
documents, the claw back agreement and rolling production.
•
CRML 00001 Page 6
Invoice/; 322651
1.00 455.00/hr 455.00
02/17/12 BSS Analyzed draft claw back agreement and suggested revisions. Coordinated electronic
production of documents responsive to SSE's discovery requests. Worked on reviewing
documents for responsiveness.
1.40 230.00 /hr 322.00
02/17/12 RSS SSE: Analyze issues related to discovery matters; review and follow up on matters related
to the same; work on responses to the same.
0.75 360.00 /hr 270.00
• 02/17/12 RSS Hagerman: Analyze issues related to mediation matters.
0.25 360.00/hr • 90.00
02/17/12 'I'JC Final review of draft claw back agreement. Communications with counsel related to
discovery issues - production by CRC, Claw Back procedures and timing of production by
Walter P. Moore.
1.25 455.00/hr 568.75
02/18/12 BSS Correspondence regarding discovery matters. Analyzed discovery production.
0.50 230.00 /hr 115.00
02/19/12 BB Review and analysis of documents for production.
A104 3.80 230.00/hr 874.00
02/19/12 RBE Analysis of documents for production.
2.75 230.00 /hr 632.50
02/20/12 BSS Analyzed correspondence from Seventh Circuit Court of Appeals regarding appellate
mediation to be had on March 5. Researched issues regarding mediation, prepared
summary of the same, and drafted correspondence. Receipt and analysis of briefing order
from Court of Appeals altering briefing schedule and calendared responsive deadlines.
Strategizcd regarding appellate deadlines, including due date to file joint designation of
record, and researched local rules and appellate rules regarding designation of record.
(2.75) worked on review analysis of documents potentially responsive to SSE's discovery
requests; analyze for privilege. Worked on drafting and revising the CRC's responses to
Request for Production and Set of Interrogatories.
6.50 230.00 /hr 1,495.00
02/20/12 GTS Plan and prepare for electronic of documents in response to REP.
4.25 175.00 /hr 743.75
02/20/12 RBE Analysis of documents for production.
1.00 230.00 /hr 230.00
02/20/12 RSS 5512 Appeal: Analyze issues related to appeal matters and discovery related issues;
analysis of Claw-Back Agreement; follow up on matters related to the same.
2.00 360.00/hr 720.00
1
r
Page 7
CRML 00001
Invoice# 322651
02/20/12 RSS SSE Discovery matters; Analyze issues related to relevancy, privileges and defenses;work
on the same. 0.50 360.00 /hr
' 02/20/12 TJC Review and analysis of notices from seventh circuit related to settlement conference in the
SSE attorneys tees appeal. Reviewed notice related to supplementing of the record and
0 identified additional pleadings which we will want to be submitted. Directed associate
regarding follow up. 1.00 455.00 /hr 455.00
02/20/12 TPS Conf. with 1355; review of case memo; document review. 5.90 230.00 ihr 1,357.00
• 02/21/12 BSS Worked on revising responses to SSE's Interrogatories. Analyzed CRC entails for
responsiveness and privliege in response to SSE's requests for production.
Correspondence to SSE's counsel and strategy regarding preparing of Designation of
Additional Material to Seventh Circuit. 2.20 230.00/hr 506.00 unjust
02/21/12 CES Hagerman: brought byta subcontract against Indiana
`a property owner; drafted memorandum to
Rob Schein and Tom Costakis regarding Hagerman's unjust enrichment claim and whether
CRC has grounds to request dismissal of that claim. 2.00 210.00 /hr 420.00
02/21/12 GTS Run searches across electronic data and prepare results for attorney
1.20 17r�review.�. 210.00
02/21/12 RBE Analysis of documents for production. 3.00 230.00 /hr 690.00
02/21/12 RSS SSE: Analyze issues related to discovery matte's.
0.75 360.00 /hr 270.00
02/21/12 TPS CRML document review. S,80 230.00 /hr 1,334.00
02/22/12 B13 Review and analysis of documents for production. 7.30 230.00 /hr 1,679.00
A104 esignation of
02/22/12 BSS Materials be submitted onlappeal to counsel nthlCigrci t; worked onldaft
i ng/revi ing of
the same. Worked on revising discovery responses, specifically Interrogatories.
Strategized regarding document production. 1.10 230.00 /hr 253.00
02/22/12 GTS Communications regarding production of documents.
0.25 175.00 /hr 43.75
I
CRAM 00001 • Page 11
Invoice# 322651
Total: 326.10 hrs $ 80,118.00
Photocopies 1.80
02/15/12 Computerized Research - Westlaw 948.05
'total Disbursements for this Matter: $ 949.85
TOTAL FEES: $ 80,118.00
TOTAL DISBURSEMENTS: $ 949.85
TOTAL CHARGES FOR THIS BILL: $ 81,067.85
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 City Form No.201(Rev.1985)
ACCOUNTS PAYABLE VOUCHER
CITY OF CARMEL
An invoice or bill to be properly itemized must show: kind of service, where performed, dales service rendered, by
whom, rates per day, number of hours, rate per hour, number of units, price per unit, etc.
n Payee
r or I/O // /f Purchase Order No.
d/.o 4jo g17 .sgvqre 5c,IK" 2bt Terms
?n,1/4w5.4O/iS. /4J 4/620 i • 2079 Date Due
Invoice Invoice Description Amount
Date Number (or note attached invoice(s) or bill(s))
57—/2 322652 1/4'r4 2C/2 A€7 3750221
a•
C
I
Total 377 Sot b 7
I hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have audited same in accor-
dance with IC 5-11-10-1.6.
-Lo , 20 t Z---
s
- . =Treasurer
Prescribed by State Board of Accounts City Form No.201(Rev.1995)
ACCOUNTS PAYABLE VOUCHER
CITY OF CARMEL
An invoice or bill to be properly itemized must show: kind of service, where performed, dates service rendered, by
whom, rates per day, number of hours, rate per hour, number of units, price per unit, etc.
• n Payee
Kr:Py — / M- /* - Purchase Order No.
-9c ' zgeo Terms
�/i. ,7o,o/s /42 6205 - 2c 7Y Date Due
• Invoice Invoice Description Amount
Date Number (or note``attached invoice(s) or bill(s))
Ch/(2 32zb5/ GP�j '6-Q C 19,-;c5 5,7 vi; rs �/ 067��
}
7
1,
Total V/ 66 7-83-
t.
I hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have audited same in accor- :.
dance with IC 5-11-10-1.6.
ea—zo , 20 IZ_ c.
C1erK-Treasurer