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HomeMy WebLinkAboutKRIEG DEVAULT LLP- 002828- 4/19/2012 CARMEL REDEVELOPMENT COMMISSION 002828 Krieg Devault LLP Check: 2828 One Indiana Square Date: 4/1912012 Suite 2800 Vendor: KRIEGDE1 Indianapolis, IN 46204-2079 Prior • Invoice P.Q. Num. Invoice Amt Balance Retention Discount Amt. Paid 316190 43,412.00 43,412.00 0.00 0.00 43,412.00 legal fees . 43,412.00 43412.00 0.00 000 . -43,412.00 • • I.),A7 THE KEY,JTOIUOCUMEN7,SECURIrldHEAT ACTNATED THUMB PR1NT TADOITd ONAIISECURIT.YFEATURES INCLUDECC SEE@ACK,FOR DETAILSKedai ' T�tye"tic Carmel Redevelopment Commission � =� 002.828 , w 30 West Main Street REGIONS •Suite 220 t zo i zii�4o - •cm,mrc' Carmel, IN 46032 --.h 2828 , .DATE . • AMOUNT . 4/19/2012 fl** **843,412:00 PAY THE.SUM!OF_FORTY THREE THOUSAND FOUR HUNDRED TWELVE DOLLARS AND NO CENTS .,, ORDER - - OF ‘ Krieg De`vault,LLP, - One lndiana Square' - Suite 2800 r'. :I "' . - ('c� - Indianapolis, IN 46204-2079 ___ _._. -__-- — _ _._ IJ°DO 28 2811° I:0 7 4 0 l 4 2 l 3 t: 008 7 504 l l l II° -- _.--- --------"--------- __ CARMEL REDEVELOPMENT COMMISSION 002823 Krieg Devault LLP Check: 2828 One Indiana Square Date: 4119/2012 Suite 2800 Vendor: KRIEGDE1 Indianapolis, IN 46204-2079 Prior Invoice P.O. Num. Invoice Amt Balance Retention Discount Amt. Paid 316190 43,412.00 43,412.00 0.00 0,00 43,412.00 legal fees 43,412.00 43,412.00 0.00 0.00 43,412.00 • • (11.52 COMPUTEREASE FORMS DIVISION 4977)577.5791 1-37229 - J`'2)) It) KRIEG I DEVAULT Odiandoiis.I 46 Suite zxoo Indianapolis.IN 46204-2079 317.636.4341 F:317.636.1507 Fed. FIN#35-1055087 W WW.KRIEGDEVAUCLCOM Carmel Redevelopment Commission Les Olds, ALA, Executive Director 30 West Main Street, Suite 220 Carmel, IN 46032 February 13, 2012 Invoice Number 316190 Our File #: CRML 00001 ABI3 Performing Arts Center Claims FOR PROFESSIONAL SERVICES RENDERED THROUGH January 31, 2012 01/02/12 BSS Teleconference with City Attorney, city employees, and counsel regarding 3.25 hrs electronic discovery issues. Worked on analyzing documents for responsiveness and privilege in response to Requests for Production. 01/02/12 GTS Prepare discovery electronic data for review. 2.00 hrs 01/02/12 RSS Analyze issues related to discovery matters. 0.50 hrs p 01/03/12 BSS Worked on analyzing documents for responsiveness and privilege in 2.00 hrs \1r response to Requests for Production. 01/03/12 GTS Prepare discovery electronic data for attorney review. 2.00 hrs 01/03/12 RSS SSE: Follow up on discovery matters. 0.25 hrs 01/03/12 TiC Receipt and review of Chubb tile on builder's risk policy, including 1.00 hrs reservation of rights letter and follow up communications. Analysis of coverage issues. 01/04/12 BSS Correspondence and teleconferences with opposing counsel regarding 1.50 hrs discovery issues. Worked on preparing discovery production. 01/04/12 RSS SSE Litigation: analyze issues related to matters on discovery; follow up 1.75 hrs on the same. INDIANA ILLINOIS GEORGIA FLORIDA MINNESOTA CRML 0000 k Page 2 lnvoiceN 316;90 01/04/12 TJC Addressed issues related to discovery by SSE. Analysis of bases for 1.00 hrs motion to dismiss in Crider matter. O1/05/12 BSS Correspondence and teleconference with counsel of record to address status 3.25 hrs of discovery and issues regarding scope of production. Worked on reviewing/preparing documents in response to Requests for Production. 01/05/12 RSS SSE: Analyze issues on strategy and discovery; work on the same; call with 3.75 hrs SSE counsel on issues related to the same. 01/05/12 RSS Crider: Analyze issues related to matters associated with venue issues. 1.25 hrs 01/05/12 TJC Status and strategy on Crider and Hagerman claims. Prepared for 4.00 hrs conference with counsel for SSE. Reviewed summaries of opinions of Walter P. Moore. Participated in lengthy conference call with counsel for SSE. Follow up meeting and strategy session to address discovery and case management issues. 01/06/12 BSS Correspondence with opposing counsel regarding discovery matters. 0.50 hrs Teleconference strategizing regarding discovery matters. 01/06/12 RSS SSE Litigation matters: Work on discovery matters; follow up with Shiel 1.00 hrs on matters related to the same. 01/06/12 TJC Addressed SSE counsel's request for additional time to respond to 0.25 hrs discovery requests. 01/09/12 BSS Teleconference and email correspondence with opposing counsel regarding 0.50 hrs discovery review and production. Correspondence with City of Carmel regarding discovery matters. Worked on discovery production review. 01/09/12 RSS SSE litigation: Work on matters related to discovery; calls with Shiel and 1.75 hrs others on the same; analyze issues related to the same. 01/09/12 RSS Hagerman: Analyze issues related to claim and litigation matters; call with 1.50 hrs Les Olds on issues related to the same; follow up on strategy related to the same. 01/09/12 TJC Analysis of pros and cons of mediating with Crider separately from 1.50 hrs Iiagetman; addressed discovery issues related to documents in possession of Shiel and electronic data from client. Analysis of timing of assertion of venue and preservation thereof in event of mediation. 01/10/12 BSS Worked on drafting discovery responses and reviewing production of 1.25 hrs documents. Strategized regarding SSE's counsel's discovery correspondence. Receipt/analysis/strategy related to Court's Order affirming grant of attorneys' Ices in favor of CRC. Calendared SSE's due date to file objection to reasonableness of fees. CRM L 00001 Page 3 Invoicelr 316190 01/10/12 RSS SSE litigation matters: Review of correspondence from Kevin Gleeson on 1.75 hrs discovery matters; review of Order regarding Federal court case; analyze issues related to the same; call with Kevin Gleeson on discovery matters; follow up on the same. 01/10/12 RSS f-lagemian: Call to Bill Baten on matters related to settlement; call to Tom 0.25 hrs Pastore on matters related to claim; follow up on the same. 01/10/12 TJC Addressed inquiry by counsel for SSE to share in costs of scanning and 1.25 hrs bates stamping documents to be produced by SSE. Receipt and review of federal court's order confirming award of attorneys' fees. Strategy i/c/w making sure that additional time spent since original entry is accounted for in any dispute on reasonableness before Judge Nation. 01/11/12 1355 Teleconference with City of Carmel regarding discovery matters. Worked 0.50 hrs on preparing responses to Requests for Production. 01/11/12 RSS Crider: Analyze issues related to claim; call with Tom Pastore on matters 1.25 hrs related to the same. 01/11/12 RSS SSE: Follow up on issues related to discovery; calls on matters related to 0.75 hrs the same. 01/12/12 BSS Correspondence to/from opposing counsel regarding non-party discovery 0.50 hrs requests and analyzed the same. 01/12/12 RSS SSE: Analyze issues related to discovery matters; calls on the same; follow 2.75 hrs up on matters with Shiel Sexton on discovery related matters; review of matters received from SSE related to nonparty discovery matters. 01/12/12 RSS Hagerman: Analyze issues related to potential mediation and settlement; 0.50 hrs call with Mediator on issues related to the same. 01/12/12 TX Receipt and review of non-party discovery requests from SSE directed to 2.00 hrs Walter P. Moore, Shiel, Creviston. I..IHIB, and CSO. 01/13/12 13SS Correspondence to/from SSE's counsel regarding discovery requests 0.50 hrs propounded on non-parties and issues related to service of requests on consulting expert Walter P. Moore. Strategized regarding the same. 01/13/12 RSS Hagerman: Call with Steve Strawbridge on matters related to Allen County 0.50 hrs litigation and potential mediation; follow up on issues related to the same. 01/13/12 RSS SSE: Analyze nonparty discovery provided by SSE; correspond with SSE 2.50 hrs counsel on issues related to the same: review and analyze issues related to process and follow up on the same; calls on the same. 01/13/12 TiC Attention to communication with counsel for SSE related to non party 1.50 hrs CRML 00001 - Page 4 Invoice# 316190 discovery, including Walter P. Moore. Analysis of issues related to Walter P. Moore - which documents will be subject to a claim of privilege. Addressed SSE's request to share in cost of electronic production. 01/16/12 BSS Worked on preparing documents responsive to discovery requests. Worked 1.00 hrs on drafting/revising discovery responses. Strategized regarding electronic discovery concerns. Strategized regarding Defendants request for cost- sharing agreement. 01/16/12 C'I'S Conference call with Rob Schein and Bryan Strawbridge to plan and 1.25 hrs prepare for discovery. 01/16/12 RSS Hagerman: Call with Jim Stephenson on matters related to litigation; 0.50 hrs analyze issues related to the same. 01/16/12 RSS SSE: Analyze issues related to strategy of matters; correspond with SSE 6.75 hrs counsel on discovery related issues; analyze matters on the same; call with Walter P. Moore on discovery related matters; analyze strategy matters on the same; review of discovery matters; call with Nick Nizamoff on matters related to discovery. 01/16/12 TJC Addressed issues related to SSE's request for documents from Walter P. 3.25 hrs Moore and SSE's demands regarding cost sharing on electronic production. Addressed discovery issues related to Shiel and CSO. Conference call with Walter P. Moore. Review and analysis of critical documents provided by Shiel. 01/17/12 BSS Correspondence with IT for Carmel regarding discovery responses. 0.25 hrs Strategized regarding discovery. 01/17/12 RSS SSE Litigation: work on discovery related issues. 0.50 hrs 01/18/12 BSS Receipt and analysis of nonparty discovery requests served upon various 0.25 hrs entities and strategized regarding the same. 01/18/12 RSS Crider: Review of matters related to stay of litigation; analyze issues 1.00 hrs related to the same; follow up with Les Olds and Karl Haas on the same. 01/18/12 RSS SSE: Call with Shiel on discovery related matters; follow up and analyze 1.25 hrs issues related to the same; call with Les Olds on status of the same; review of correspondence and matters on the same. 01/18/12 TJC Receipt and review of appearance filed in state court action by SSE, as well 1.50 hrs as non party discovery served by SSE on CSO, Shiel and Creviston. Analysis of I Iagerman's waiver argument on venue issue. 01/19/12 BSS Worked on preparing discovery responses and corresponded with IT for 0.25 hrs Carmel on same. Receipt and analysis of additional nonparty requests served by opposing counsel. Analyzed correspondence with Walter P. CR M 1.00001 Page 5 Invoiccu 316190 Moore regarding discovery responses. 01/19/12 GTS Process discovery electronic data from Shiel Sexton. 1.75 hrs 01/19/12 MQ Analyzed issue regarding stay to proceedings and impact on venue 0.25 hrs challenge. 01/19/12 RSS SSE: analyze issues related to strategy and discovery matters; call and 1.25 hrs follow up on the same; review of nonparty requests and analyze issues on the same. 01/19/12 RSS Crider: analyze issues related to stay of litigation; correspond with Les 3.50 hrs Olds and Karl Haas on matter related to stay; analyze issues related to stay of litigation and venue matters; call with Tom Pastore on matters related to mediation and stay of litigation; follow up on the same; correspond with Tom Pastore and Steve Strawbridge on matters related to the same; call with Jim Stephenson on matters related to the same. 01/19/12 TJC Addressed waiver of venue and stay issues related to Hagerman matter. 0.50 hrs 01/20/12 1355 Worked on discovery responses and strategized regarding E --discovery 0.25 hrs issues. 01/20/12 RSS SSE litigation: Analyze case matters, strategy and issues going forward; 2.50 hrs review and follow up on discovery related matters; meeting with Ryan Wilmering on matters related to the same. 01/20/12 RSS 1-lagerman/Crider: Analyze issues related to venue matters and stay of 0.75 hrs issues for the same. 01/20/12 TJC In Hagerman matter, addressed suggestion by Jim Stephenson to file 1.00 hrs unilateral withdrawal of demand for jury trial. Articulated bases for same. Receipt and review of communication from Hagerman counsel. 01/23/12 BSS Worked on preparing documents and analyzing for responsiveness and 0.75 hrs privilege in response to SSE's requests for production. 01/23/12 GTS Begin processing of CRC PST files. 0.75 hrs 01/23/12 RSS SSE: Analyze litigation and discovery matters; call and follow tip on the 3.75 hrs same; review of the same; work on responses to the same. 01/23/12 RSS Hagerman: Analyze issues related to mediation and stay of matters. 0.50 hrs 01/23/12 DC Attention to issues related to Crider stay. SSE discovery and possible 0.50 hrs mediation. 01/24/12 BSS Teleconference with opposing counsel regarding discovery related issues 1.50 hrs and production concerns. Worked on preparing discovery responses and CR611-00001 Page 6 Invoiced 316190 analyzing documents to be produced. 01/24/12 GTS Strategize regarding additional paper documents received, volume of ESI, 1.00 hrs costs of processing, and plan for production. 01/24/12 RSS SSE: Work on discovery natters; review and analyze issues related to non- 3.25 hrs party request, privilege matters, production issues and matters on the same; analyze strategy and issues related to SSE discovery requests. 01/24/12 TJC Attention to communication with counsel for SSE regarding discovery 1.50 hrs issues, including apportionment and/or responsibility for costs. Several conference calls with counsel for SSE. Addressed electronic discovery issues. 01/25/12 BSS Correspondence and analysis of issues relating to discovery production. 0.75 hrs 01/25/12 RSS SSE matters: Review and analyze non-party discovery requests; review and 2.50 hrs analyze issues related to production of documents from the CRC; follow up on the same; correspond with Les Olds, Ryan Wilmering and Karl Haas on status of matters related to discovery; call to Shiel on matters related to discovery; follow up with Walter P. Moore on discovery matters; analyze issues and strategy matters; work on the same. 01/25/12 RSS Flagerman: Analyze issues related to mediation matters; analyze venue and 1.00 hrs mediation issues; correspond with Les Olds. Karl Haas and Ryan Wilmering on matters related to venue and mediation. 01/25/12 TiC Receipt and review of draft of Crider stay. Attention to third party 1.00 hrs discovery issues related to SSE. LHB. Receipt and review of email communications from counsel for Hagerman and Crider. 01/26/12 13SS Worked on preparing/analyzing documents to be produced in response to 1.75 hrs discovery requests. Worked on drafting written discovery responses. 01/26/12 GTS Strategize and discuss plan regarding volume of BSI. 1.25 hrs 01/26/12 RSS Crider: Work on issues related mediation; correspond with mediator and 1.50 hrs follow up on the same; analyze motion to stay and follow up on the same; review of issues related to arguments involving Waiver of Venue; analyze issues related to unjust enrichment claims and assertions on the same; analyze issues related to potential indemnity matters; strategize on the same; follow up on issues related to mediation. 01/26/12 RSS SSE: Analyze issues related to discovery from SSE: strategize and work on 4.25 hrs the same; review oldiscovery and work on the same: review of issues related to non-party discovery and work on the same: analyze issues related to privilege natters; analyze outstanding matters. 01/26/12 TiC Addressed issues related to Hagerman mediation. Crider stay and SSE 1.50 hrs MIL 00001 Page 7 Invoice#316190 discovery. 01/27/12 CES Hagerman: Analysis and review of documents and correspondence 1.00 hrs regarding Crider's bid and Hagerman's invitation to bid and Indiana case law regarding unjust enrichment. 01/27/12 GTS Load medical records to summation database. 0.25 hrs 01/27/12 RSS SSE: Analyze issues related to discovery matters; call to Shiel on matters 0.50 hrs related to discovery; review and analyze issues on the same. 01/27/12 RSS Hagerman/Crider: Review and analyze claims and matters on the same; 2.25 hrs review and work on strategy for litigation and mediation matters; review of claim assertions by Crider; analyze issues on the same. 01/27/12 TJC Analysis of waiver of venue argument espoused by Crider and Hagerman. 1.50 hrs Evaluation and analysis of legal issues for mediation of Hagerman and Crider claims. Addressed issues related to electronic records provided by City and potential filters and/or search terms. Receipt and review of non- party request for production served by 5513 on LI-LB. 01/28/12 GTS Prepare CRC electronic and paper data for attorney review. 3.75 hrs 01/30/12 BSS Strategized regarding and worked on discovery responses. 0.50 hrs 01/30/12 CES Hagerman: Analysis and review of case law cited by counsel for Hagerman 2.50 hrs regarding waiver of ability to contest venue; analysis of the Carmel's defenses to Hagerman's assertions; review of Indiana case law regarding venue selection provisions in contracts and Indiana Trial Rule 75(A)(6); analysis of defenses to claims of unjust enrichment in cases where a party refused to provide or sign a written contract. 01/30/12 GTS Prepare electronic data for attorney review. 2.50 hrs 01/30/12 RSS SSE: Review and analyze issues related to discovery matters; work and 0.75 hrs review of the same: review of issues related to production, privileges and ediscovery matters. 01/30/12 TiC Evaluated options in connection with roughly 20,000 documents (paper 1.00 hrs copies plus electronic data) in terms of privilege. date range and other relevancy qualities. 01/31/12 BSS Analyzed issues related to and worked on discovery matters. Prepared 2.25 hrs documents for production in response to discovery requests and reviewed for responsiveness and privilege. 01/31/12 us Prepare electronic data for attorney review. 4.00 hrs 01/31/12 RSS SSE: Analyze issues related to discovery production and e-discovery 1.00 hrs CRMI.00001 Page 8 Invoiceti 316190 matters; work on the same; call on matters related to issues for the same. 01/31/12 RSS Hagerman: Analyze issues related to motion to stay; follow up on the same. 0.25 hrs 01/31/12 TJC Addressed most efficacious way to cull enormous volume of electronically 0.50 hrs stored information. Total Fees for this Matter: $43,787.50 TJC Costakis,Thomas J. 26.30 hrs 455.00/hr 11,966.50 MQ Quigley, Marc T. 0.25 hrs 395.00/hr 98.75 CES Sabatine, Catherine E. 3.50 hrs 210.00/hr 735.00 RSS Schein; Robert S. 61.50 hrs 360.00/hr 22,140.00 GTS Smith, Gary T. 20.06 hrs 175.00/hr 3,510.50 13SS Strawbridge, Bryan S. 23.25 hrs 230.00/hr 5.282.50 Total: 134.86 hrs $ 43,733.25 Photocopies 1.40 01/23/12 VENDOR: Sonia Ray; INVOICE#: EX012312; DATE: 3.75 1/23/2012; Travel by Messengers (Oce) for Rob Schein 01/23/12 VENDOR: Sonia Ray; INVOICE#: EX012312A; DATE: 3.75 1/23/2012; Travel by Messengers (Oce) 01/30/12 Computerized Research - Westlaw 201.79 Total Disbursements for this Matter: $ 210.69 TOTAL FEES: $ 43,787.50 TO'T'AL DISBURSEMENTS: $ 210.69 TOTAL CHARGES FOR THIS BILL: $ 43,998.19 Atntunt: q3 /-112.00 This invoice is due upon receipt. Please make checks payable to Krieg DeVault LLP and reference the invoice number. Prescribed by State©pool 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. Payee .} Purchase Order No. Terms Date Due Invoice Invoice Description Amount Date Number (or note attached invoice(s) or bill(s)) 2-V5-12 Nca[9i Ie9011 S�Y�c�ceS�r cIsn�ur9 2a2 • Total 't39-12.,". I hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have a Iced same in accor- dance with . 5-11-10-1.6. Lt^1 , 20t�- k-Treasurer