HomeMy WebLinkAboutKRIEG DEVAULT LLP- 002764- 3/22/2012 CARMEL REDEVELOPMENT COMMISSION 002764
Krieg Devault LLP Check: 2764
One Indiana Square Date: 3/22/2012
Suite 2800 Vendor: KRIEGDE1
Indianapolis, IN 46204-2079
Prior
Invoice •P.O. Num. Invoice Amt Balance Retention Discount Amt. Paid
314824 27,567.23 27,567.23 0.00 0.00 27,567.23
legal services
27,567.23 27,567.23 0.00 0.00 27,567.23
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`,"THE KEY TO DOCUMENT SECURITY•:HEAT ACTIVATED THUMB PRINT•ADDITIONAL SECURITY FEATURES INCLUDED SEE BACK FOR DETAILS,
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DATE - AMOUNT
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•
CARMEL REDEVELOPMENT COMMISSION 002764
Krieg Devault LLP Check: 2764
One Indiana Square Date: 3/22/2012
Suite 2800 • Vendor: KRIEGDE1
Indianapolis, IN 46204-2079
Prior
Invoice P.O. Num. Invoice Amt Balance Retention Discount Amt. Paid
314824 27,567.23 27,567.23 0.00 0.00 27,567.23
legal services
27,567.23 27,567.23 0.00 0.00 27,567.23
■
I-tb 52 COMPUTEREASE FORMS DIVISION(877)577.8781 T.37228 • 1,f2)1
It) One Indiana Square
I
KRIEG I EVAULT Suite 2800
Indianapolis,IN 46204-2079
T:317.636.4341
F:317.636.1507
Fed. GIN#35-1055087
W W W.KRIEGDE VAULT.COM
Carmel Redevelopment Commission
Les Olds, ALA, Executive Director
30 West Main Street, Suite 220
Carmel, IN 46032
January 17,2012
Invoice Number 314824
Our File N: CRML 00001 ABB
Performing Arts Center Claims
FOR PROFESSIONAL SERVICES RENDERED THROUGH December 31,2011
12/01/11 BSS Strategized regarding electronic discovery issues; coordinated with Cannel 0.50 hrs
IT personnel related to the same. Analyzed and worked on responses to
discovery requests.
12/01/11 TJC Addressed issues to document preservation, discovery responses and likely 0.50 hrs
substitution of counsel in Crider case.
12/02/11 BSS Worked on Response Brief revisions in support of maintaining attorney fee 0.25 hrs
award.
12/02/11 RSS Hagerman: Correspond on matters related to Hagerman and Crider claims; 1.00 hrs
review and analyze the same; calls and follow up on the same.
12/02/11 TJC Receipt and review of communication from counsel for Crider and 0.50 hrs
Hagerman. Analysis of issues related to dirt pile.
12/05/11 CES Hagerman: Analysis and review of Indiana case law regarding venue 1.50 hrs
stipulations in contract provisions.
12/05/11 RSS Hagerman: Review and analyze issues relating to allegations in complaint; 2.50 hrs
follow up with Les Olds and Karl Haas on the same; analyze tactical
matters related to claims and related issues; strategize on the same.
12/05/11 T.IC Attention to issues related to Crider, insurance coverage, potential motion 1.25 hrs
INDIANA ILLINOIS GEORGIA - FLORIDA MINNESOTA
•
CRML 00001 Page 2
Invoice$314824
to dismiss Crider claims and motion to transfer claims of Hagerman.
Analysis of spoliation claim related to dirt pile.
12/06/11 BSS Strategized regarding and worked on revising Response in Opposition to 0.25 hrs
Motion to Alter or Amend Judgment.
12/06/11 CES Hagerman: Analysis and review of Indiana case law and Indiana published L50 hrs
treatises regarding preferred venue provisions and the enforceability of
such provisions as determined by the Indiana Courts; drafted a summary of
the analysis.
12/06/11 RSS SSE matters: Review and analyze issues related to motion to reconsider. 0.25 hrs
12/06/11 RSS Hagerman: Review and analyze issues relating to complaint, defenses and 5.25 hrs
strategy on the same; review and analyze issues related to soil issues;
correspond and respond on the same.
12/06/11 TJC Worked on draft correspondence to counsel for Crider and Hagerman. 1.50 hrs
Addressed issues related to spoliation claims. Addressed issues related to
underlying substantive claims.
12/07/11 BSS Teleconference with Math Worthley and Terry Crockett regarding 1.50 hrs
electronic and hard discovery issues. Worked on discovery responses.
12/07/1 I CES Hagerman: Analysis of Indiana case law regarding procedural and 1.00 hrs
substantive requirements regarding preferred venue and "flow down"
provisions in construction contracts, and the enforceability of such
provisions as determined by the Indiana Courts; analysis of whether the
venue provision in the contract between Hagerman and the CRC may be
enforced against Crider.
12/07/11 GTS Conference call with Matt Worthley and Terry Crockett Co discuss,plan, 1.50 hrs
and prepare for preservation of electronically stored information.
12/07/11 RSS SSE: Review and analyze issues related to discovery matters; meeting on 2.50 hrs
matters related to the same; analyze strategy and going forward matters;
review and analyze issues related to Motion to Amend Judgment.
12/07/11 RSS Hagerman: Analyze issues; calls on the same; follow up on the same; 2.25 hrs
analyze venue matters; call with Les Olds on strategy and issues related to
the same.
12/07/11 TIC. Hagerman: Reviewed and analyzed case law on venue. Outlined bases for 2.25 hrs
motion to dismiss claim by Crider against CRC, and bases for motion to
transfer venue of claim by I-lagerman against CRC, as well as motion to
enlarge or stay response time for responding to Crider.
12/08/11 BSS Worked on drafting/revising/finalizing Response in Opposition to Motion 1.00 hrs
to Alter or Amend. Worked on preparing responses to SSE's discovery
CRML 00001 Page 3
Invoice/314824
requests.
12/08/11 RSS SSE: Follow up on filing of Response to Attorney fees; analyze issues 1.50 hrs
related to discovery matters; work on the same.
12/08/11 RSS Hagerman/Crider: Review and analyze issues related to dirt pile, 1.25 hrs
preservation of evidence and related issues; follow up on the same; calls to
Les Olds on the same.
12/08/11 TJC Hagerman: Addressed spoliation issue in light of client's decision to move 0.50 hrs
forward with removal of dirt pile. Charted path for defense of position that
are not spoliation.
12/09/11 BSS Worked on responses to discovery requests. Teleconference with opposing 1.00 hrs
counsel regarding SSE's extension to discovery requests.
12/09/11 RSS Hagerman: Meeting with Jim Stephenson and Wayne Uhl regarding 3.50 hrs
lawsuit and matters related thereto; analyze issues related to the same;
review of matters in preparation of the same; follow up on discovery
related matters.
12/09/11 RSS SSI3: Review and analyze issues related to discovery matters; work on the 1.50 hrs
same; analyze strategy of the same.
12/09/11 TJC Addressed issues related to preservation of ESI on individual computers. 0.75 hrs
Communication from counsel for SSE regarding discovery response
extension.
12/12/11 BSS Worked on drafting/preparing responses to discovery requests. Strategized 1.00 hrs
regarding discovery production issues, including electronically stored
entails.
12/12/11 GTS Plan and preparation for preservation of electronically stored information. 0.75 hrs
12/12/11 RSS SSE: Review and analyze matters related to discovery; prepare for the 2.00 hrs
same; call with Les Olds on matters related to the same.
12/12/11 RSS Hagerman/Crider: Analyze venue issues; call with Les Olds on soil issues; 0.75 hrs
call to Tom Pastore on the same; correspond with Tom Pastore and Steve
Strawbridge on matters related to the same.
12/12/11 TJC ' Crider and Hagerman: Receipt and review of communication from Crider 0.25 hrs
counsel related to geotech testing of soil.
12/12/11 TJC Receipt and review of additional appearance and motion for extension of 1.00 hrs
time filed in state court action. Addressed issues related to correspondence
to Chubb confirming that RD is counsel to the CRC and that, therefore,
Chubb can communicate directly with KO. Addressed issues related to
preservation of electronically stored information.
•
CRML 00001 Page 4
Invoice#314824
12/13/11 BSS Analyzed Builder's Risk Policy and strategized regarding issues related 0.50 hrs
thereto. Strategized and worked on discovery matters.
12/13/11 GTS Communicate with Terry Crockett regarding ESI. 0.50 hrs
12/13/11 RSS SSE: Analyze issues related to discovery matters; follow up on the same; 1.50 hrs
call with Chubb Insurance on matters related to policy.
12/14/11 BSS Worked on preparing discovery production of documents. 0.25 hrs
12/14/11 RSS SSE Litigation: Analyze issues related to discovery matters; call with Matt 0.75 hrs
Worthley on matters related to the same.
12/14/11 TJC Receipt and review of motion to enlarge time to object to award (amount) 0.50 hrs
of fees filed in Hamilton County. Attention to issue related to custodian
and chain of custody on ESI.
12/15/11 1355 Receipt/analysis of SSE's Motion for Enlargement of Time to Challenge 5.00 hrs
Reasonableness of Attorneys' Fees in state court. Worked on preparing
written responses to SSE and its surety's discovery requests. Worked on
preparing documents to produce in response to discovery requests.
Strategized regarding privileged document concerns. Receipt/analysis of
SSE's Reply in Support of Motion to Alter or Amend Judgment.
12/15/11 RSS SSE: Analyze issues related to discovery matters and response to the same; 0.75 hrs
work on discovery matters.
12/15/11 TJC Analysis of data, strategy in connection with review for relevance and 1.50 hrs
privilege. Devised plan for electronic staging and assimilation. Review
and analysis of reply filed by SSE in federal court in further support of
motion to reconsider award of attorneys fees.
12/16/11 BSS Worked on preparing electronic documents for production and analyzed for 1.75 hrs
privileged and responsiveness issues. Worked on drafting/revising
responses to SSE's discovery requests.
12/16/11 RSS SSE: work on matters related to discovery responses; analyze strategy and 0.50 hrs
issues on the same.
12/18/11 BSS Drafted/revised discovery responses. 0.50 hrs
12/19/11 BSS Drafted/revised discovery responses. Analyzed documents responsive to 2.75 hrs
discovery requests and worked on production. Analyzed privileged issues.
Numerous communications regarding discovery matters.
12/19/11 GTS Prepare electronic documents for attorney review. 1.00 hrs
12/19/11 RSS SSE: Work on discovery responses; analyze issues related to the same. 1.25 hrs
•
•
CRMI.00001 Page 5
Invoice)?314824
12/20/11 BSS Analyzed documents to be produced to SSE for privilege and 1.00 hrs
responsiveness to Requests for Production. Worked on drafting substantive
responses to Interrogatories and stratcgized regarding responses.
12/20/11 GTS Process electronic documents. 2.25 hrs
12/20/11 RSS Hagerman: Analyze issues related to claim and venue issues; follow up on 0.50 hrs
the same.
12/20/11 RSS SSE: Follow up on discovery matters; analyze issues related to the same; 1.50 hrs
reveiw and analyze responses to discovery and matters going forward.
12/20/11 TJC Crider/Hagerman: Attention to spoliation and venue issues. 0.50 hrs
12/20/11 TJC Addressed issues related to privilege and case management in SSE matter. 0.75 hrs
12/21/11 BSS Teleconference with SSE's counsel regarding discovery matters. Analyzed 1.50 hrs
documents to be produced for responsiveness to discovery requests.
Correspondence with City's IT personnel and City Attorney regarding e-
discovery issues.
12/21/11 GTS Prepare electronic data for attorney review. 3.00 hrs
12/21/11 RSS SSE: Review and analyze issues related to strategy, status of matters and 0.50 hrs
responses to discovery matters.
12/21/11 TJC Communications related to privilege and electronically stored information. 0.50 hrs
Prepared for conference call with client.
12/22/11 BSS Teleconference regarding e-discovery production issues. Worked on 3.25 hrs
analyzing documents to be produced for responsiveness and privilege.
Correspondence regarding e-discovery matters.
12/22/11 GTS Conference call regarding electronic data. 0.25 hrs
12/22/11 RSS SSE: Call on discovery matters; review and analyze issues related to the 1.50 hrs
same; follow up on matters related to discovery.
12/22/11 TJC Attention to electronically stored information issues; teleconference with 0.75 hrs
client representatives. Considered responsiveness issue in connection with
tolling agreements with certain non-claimant entities.
12/23/11 BSS Analyzed documents to potentially be produced for responsiveness and 1.25 hrs
privilege issues. Worked on preparing documents in response to SSE's
Requests for Production.
12/27/11 BSS Analyzed documents for privilege and responsiveness in preparing 5.50 hrs
responses to SSE's Requests for Production.
•
CRML 00001 Page 6
Invoice/314824
12/28/11 BSS Analyzed documents to be produced in response to SSE/Ohio Farmers' 5.25 hrs
Requests for Production for responsiveness and/or privilege.
12/29/11 GTS Conference call with Crockett, Haney, and Worthley regarding 0.501us
electronically stored information.
12/29/11 RSS SSE: Work on discovery matters; conference call on matters related to the 2.00 hrs
same; review and analyze strategy and matters related to the same.
12/29/11 TJC Conference call related to status, strategy and legal hold issues. Follow up 1.00 hrs
on open items.
Total Fees for this Matter: $27,275.00
TJC Costakis, Thomas J. 13.90 hrs 435.00/hr 6,046.50
CES Sabatine, Catherine E. 4.00 hrs 195.00/hr 780.00
RSS Schein, Robert S. 35.00 hrs 340.00/hr 11,900.00
GTS Smith, Gary T. 9.75 hrs 140.00/hr 1,365.00
BSS Strawbridge, Bryan S. 34.40 hrs 210.00/hr 7,224.00
Total: 97.05 hrs $ 27,315.50
Photocopies 3.80
12/06/11 Computerized Research - Westlaw 288.43
Total Disbursements for this Matter: $ 292.23
TOTAL FEES: $ 27,275.00
TOTAL DISBURSEMENTS: $ 292.23
TOTAL CHARGES FOR THIS BILL: $ 27,567.23
This invoice is due upon receipt.
Please make checks payable to Krieg DeVault LLP and reference the invoice number.
It) I« IEG I :EVI\ULT[] WWW.KRIEGOEVAULT.GOM
January 25, 2012 Andrew B. Buroker
Direct Dial: (317)238-6242
E-mail: aburoker(akdlegal.com
Les A. Olds,AIA
Carmel Redevelopment Commission
30 West Main Street
Suite 220
Carmel, IN 46032
Re: Performing Arts Center Invoice
Dear Les:
I am enclosing for your review and processing for payment Our invoice for legal services
to the Carmel Redevelopment Commission through December, 2011. 1 do not have any invoices
for claims assessment services by Construction Process Solutions, Ltd. for this period.
]f have any questions regarding the enclosed, please feel free to call me directly at 238-
6242. Thank you for allowing us to be of service to the Carmel Redevelopment Commission.
Very truly yours,
Andrew B. Buroker
Enclosures
cc: Karl P. Haas, Esq. Ow/ends.)
Robert S. Schein, Esq. (w/ends.)
KD:19158001.DOC.
•
•
12600 NORTH MERIDIAN STREET. SUITE 300. CARMEL. IN 4603?-5406 T 317.566.1110 F 317-636.1507
III MEP IYM LAW FIRMS WORLDWIDE
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.
Payee
!\ri-e. p rvgt/$ Purchase Order No.
On Terms
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Invoice Invoice Description Amount
Date Number (or note attached invoice(s) or bill(s))
9/'/327 L.59/ jr--s;- .'f re' 077iiiss 2? 5-6 27
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Total 27,56747
I hereby certify that the attached invoice(s), or bill(s), is (are) true and correct and I have . -• ..me in accor-
dance
with IC 5-11-10-1.6. '
3-Z1 , 2o ) 2 -
-Treasurer