United States District Court

Northern District Of Illinois

Local Rules

Appendix to Local Rule 54.3

SAMPLE JOINT STATEMENT

Pursuant to section (e) of LR54.3, the parties submit the following Joint Statement with respect to the motion for fees and expenses filed by [name of movant]:

  1. [name of movant] claims attorney’s fees of $102,425 and related nontaxable expenses of $12,578.40. [name of movant] calculates this claim as follows:

Lawyer Hours Rate Totals

Smith   300 $245 73,500
Jones   175 $110 19,250
Johnson     65 $95 6,175
Wilson (paralegal) 70 $50 3,500
Total $102,425
  1. The position of [name of respondent] is that fees should be awarded on the following basis:

Lawyer Hours Rate Totals

Smith   200   $200   40,000
Jones   175   $110   19,250
Johnson   40   $95   3,800
Wilson   70   $50   3,500
   Total    $ 66,550

Respondent’s position is that related nontaxable expenses of $11,380.00 should be awarded.

  1. The specific disputes remaining between the parties are the following:

(a) The appropriate hourly rate for Smith;

(b) Whether 100 hours spent by Smith and 25 hours spent by Johnson on the state claim should be compensated;

(c) Whether $1,198.40 spent on deposition transcripts of four specific witnesses (Banks, Davis, George, and Penny) should be compensable.

  1. The underlying judgment in the case will not be appealed and the only remaining dispute in the litigation is the appropriate fee award.