Janna Dutton Petitions For Attorney Fees

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT - PROBATE DIVISION

ESTATE OF
JOSEPH L. ZIARNIK
No. 08 P 8140
A Disabled Person
Advocacy Guardianship Services, NFP,

as Limited Guardian of the Person
of Joseph L. Ziarnik and individually, Josh Mitzen
as Director, Advocacy Guardianship Services NFP
and individually; Devon Bank, as agent for
Joseph L. Ziarnik under Power of Attorney
for Property dated April 1, 2008, as Trustee of the
Joseph Ziarnik Trust dated April 1, 2008
and individually, and Janna Dutton, as attorney
for the Estate of Joseph Ziarnik and individually,
Plaintiffs,
V.
Tammi Goldman,
Defendant.
PETITION FOR ATTORNEYS' FEES AND
AFFIDAVIT OF VICTOR J. PIOLI
In support of the Plaintiffs' Petition for Attorneys' Fees and Expenses, Victor J. Pioli, being
first duly sworn on oath, deposes and states that I have knowledge of the facts set forth in this
Petition, and if sworn as a witness I can competently testify to the following facts:
1.
Victor J. Pioli is an attorney licensed to practice by the Supreme Court of Illinois
since 1998 and is a shareholder with the firm of Johnson & Bell, Ltd., which represents the
Plaintiffs in these proceedings.
2.
On June 19, 2014, the Court entered its order granting Defendant's motion to vacate.
As part of the Court's order, Plaintiffs were awarded their reasonable attorney's fees and costs
incurred between January 28, 2014 and June 19, 2014. Plaintiffs submit this fee petition pursuant to
the Court's June 19, 2014 order.
3.
Affiant has personal knowledge as to the office procedures of Johnson & Bell, Ltd.,
concerning the recoding of daily time, its entry on the computer system, and the general operation
of the software, together with the record retention procedures of the firm. The firm of Johnson &
Bell, Ltd. has throughout its representation pertinent to this matter, employed a time-keeping system
under which each attorney makes daily notations as to his efforts and activities on behalf of clients.
The information set forth in those daily notations are, under procedures established by Johnson &
Bell, Ltd., entered onto a computer system.
4.
Both the computer hardware and the software utilized by Johnson & Bell, Ltd. are
generally recognized and employed in the business and legal community.

5.
According to the records of Johnson & Bell, Ltd., kept and maintained as aforesaid,
the attorneys designated below have devoted hours in the representation of the Plaintiffs in this
matter from January 28, 2014 to June 19, 2014, allocated between such attorneys and paralegals as
follows:
RECAP OF HOURS:
Fee
Attorney
No. of Hours
Rate/Hr.
Victor J. Pioli
5.6 hours
$225 per hour
$1,260.00
Alan W. Succari
4.3 hours
$200 per hour
$860.00
TOTAL:
$2,120.00
The time entries set forth and depicted on the attached Schedule A are true and accurate
depictions of the time entries and actually reflect the time devoted to the representation of the
Plaintiff, including the out-of-pocket expenses.
2
7.
On information and belief, based on Affiant's knowledge of the general legal
community in the Chicago area regarding billing practices and rates, and having contracted for legal
services with attorneys in such community, Affiant suggests and it is his opinion that the following
hourly rates are fair and reasonable for the following individuals:
8.
A.
Victor J. Pioli - $225.00 per hour
B.
Alan W. Succari - $200.00 per hour
Affiant was aware and personally participated in this matter. Affiant has reviewed all
the pleadings, correspondence and time slip entries relating to this matter. It is Affiant's opinion that
the time was necessary and appropriate for the proper representation of the Plaintiff's claims
between January 28, 2014 and June 19, 2014.
FURTHER, AFFIANT SAYETH NAUGHT.
Victor J. Pioli
JOHNSON & BELL, LTD.
33 W. Monroe St.
Suite 2700
Chicago, IL 60603
312-372-0770
Firm I.D. 06347
Attorneys for Plaintiffs
CERTIFICATE OF SERVICE
I hereby certify that a true copy of Petition for Attorney's Fees and Affidavit of Victor J.
Pioli was served via United States Mail (postage prepaid) upon all counsel of record, identified
th
below this 28 day of July, 2014.
Edwin J. Belz
4407 N. Elston Ave.
Chicago, IL 60630
Tami Goldmann
3939 N. Kostner Ave.
Chicago, IL 60641

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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION

Advocacy Guardianship Services, NFP,

Victor J. Pioli is an attorney licensed to practice by the Supreme Court of Illinois

generally recognized and employed in the business and legal community.

$225 per hour

$200 per hour

On information and belief, based on Affiant's knowledge of the general legal

Victor J. Pioli - $225.00 per hour

Alan W. Succari - $200.00 per hour

below this 28 day of July, 2014.

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