Hill v. Harrington

Full title: Charles Hill and Donna Hill, Plaintiffs, v. Parole Agent C. Harrington…

Court: United States District Court, Northern District of Illinois

Date published: Sep 28, 2024

1:18-CV-05592 (N.D. Ill. Sep. 28, 2024)

Opinion

1:18-CV-05592

09-28-2024

Charles Hill and Donna Hill, Plaintiffs, v. Parole Agent C. Harrington, Parole Agent Walls, Elena McKenna, Scott Liebhaber, Robert Purvis, Matthew Pufpaf, John Gartner, David Rodriguez, Alan Lasch, Kevin Geyer, Steven Suvada, and the City of Chicago, Defendants. X X X X X X X X X X X X X X X X X X X X X X X X X x X X X X X X X X

HONORABLE EDMOND E. CHANG, UNITED STATES DISTRICT JUDGE

MEMORANDUM OPINION AND ORDER

HONORABLE EDMOND E. CHANG, UNITED STATES DISTRICT JUDGE

Charles and Donna Hill brought this case against 11 law enforcement officers (a mix of parole agents and police officers, including Christopher Harrington) and the City of Chicago, alleging that the Defendants violated the Hills' constitutional rights during a search of their home in August 2016. R. 1., Compl.¹ The jury returned a verdict for the Hills on two out of three counts against Harrington.² The Hills have filed a bill of a costs, Fed.R.Civ.P. 54(d), and a motion for attorneys' fees, 42 U.S.C. § 1988(b). R. 362, Bill of Costs; R. 376, Fees Pet. As explained below, the Hills are awarded $14,677.25 in costs, and $685,363 in fees.

1 The Court has federal question jurisdiction over this case. 28 U.S.C. § 1331. Citations to the docket are “R.” followed by the docket entry number and, if needed, a page or paragraph number.

2 The remaining claims against Harrington and against the other 11 Defendants were dismissed on the Defendants' motion for summary judgment. R. 241, Order 03/31/21.

I. Background

Only a limited recitation of the facts and procedural background is necessary for this Opinion. The Hills sued Harrington, an Illinois Department of Corrections parole agent, asserting violations of their Fourth and Fourteenth Amendment rights during a search of their home in August 2016. Compl.³ After Harrington's motion for partial summary judgment was granted in part and denied in part, the Hills went to trial against Harrington on three claims: unlawful entry, unlawful search, and unlawful seizure and retention. R. 241, Order 03/31/2021; R. 356, Order 07/01/2022. The jury found for the Hills on both the unlawful entry and unlawful search claims, awarding Charles Hill $11,000 and Donna Hill $20,000 in damages on the first claim, and $22,000 for Charles Hill and $15,000 for Donna Hill on the second. Order 07/01/2022. The damages award totaled $68,000. Order 07/01/2022.

3 Because this Opinion only concerns the jury verdict against Harrington, the procedural background of the claims against the other 11 Defendants is not addressed here.

The Hills have now filed a bill of costs and motion for attorneys' fees under Federal Rule of Civil Procedure 54(d) and 42 U.S.C. § 1988(b). The Hills seek to recover $16,795.08 in costs and $819,907.50 in fees. Bill of Costs; Fees Pet. at 1; R. 383, Pls.' Mot.⁴ Harrington objects to the amount of both the costs and the fees. R. 364, Def.'s Costs Resp.; R. 381, Def.'s Fees Resp.; R. 384, Def.'s Correction Resp.

4 As addressed below, the Hills filed a motion to correct their attorneys' fees calculation, from the initially requested $767,765 to $819,907.50. R. 383, Pls.' Mot.; Fees Pet. at 1.

II. Legal Standard

Federal Rule of Civil Procedure 54(d)(1) allows a prevailing party to recover costs (other than attorneys' fees) unless a federal statute, federal rule, or court order says otherwise, with a strong presumption in favor of awarding costs. See Montanez v. Simon, 755 F.3d 547, 557 (7th Cir. 2014). Under 28 U.S.C. § 1920, a federal court may tax as costs: (1) fees of the clerk and marshal; (2) fees for printed or electronically recorded transcripts necessarily obtained for use in the case; (3) fees and disbursements for printing and witnesses; (4) fees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case; (5) docket fees under 28 U.S.C. § 1923; and (6) compensation of court-appointed experts, compensation of interpreters, and salaries, fees, expenses, and costs of special interpretation services under 28 U.S.C. § 1828.

Under 42 U.S.C. § 1988(b), “the court, in its discretion, may allow the prevailing party [in a § 1983 action] ... a reasonable attorney's fee as part of the costs.” “The appropriate fee under § 1988 is the market rate for the legal services reasonably devoted to the successful portion of the litigation.” Richardson v. City of Chicago, 740 F.3d 1099, 1103 (7th Cir. 2014). District courts use the lodestar method, “multiplying the number of hours reasonably expended on the litigation...by a reasonable hourly rate.” Pickett v. Sheridan Health Care Ctr., 664 F.3d 632, 639 (7th Cir. 2011) (cleaned up).⁵ The Court may adjust that figure based on the factors set forth in Hensley v. Eckerhart, such as the time and labor required, the novelty or difficulty of the case, the degree of the success achieved, the experience and ability of the attorneys, the adequacy of the documentation of the hours, and whether appropriate billing judgment was used. Hensley, 461 U.S. 424, 429-30 & n.3 (1983); see Richardson, 740 F.3d at 1103.

5 This Opinion uses (cleaned up) to indicate that internal quotation marks, alterations, and citations have been omitted from quotations. See Jack Metzler, Cleaning Up Quotations, 18 Journal of Appellate Practice and Process 143 (2017).

III. Analysis

A. Bill of Costs

The Hills seek $16,795.08 in total costs: $400 for clerk fees, $1,050 for summons and subpoena fees, $11,272.89 for transcript fees, $990 for witness fees, $2,259.55 for copying fees, and $822.64 for other costs. Bill of Costs at 1. The parties agree that the Hills are the prevailing party and thus entitled to costs. See Def.'s Costs Resp. at 2. But the parties dispute $67.27 in postage costs, $12.56 in travel costs to serve the summons and complaint, and some of the copy costs (Harrington did not add up the total disputed amount in copy costs). See id. at 3-5; R. 368, Pls.' Costs Reply at 2 (agreeing to deduct some requested costs objected to by Harrington). Considering Harrington's objections, and on the Court's own review,⁶ the Hills are entitled to $14,677.25 in costs as explained below.

6 Where the Court makes an adjustment that was not the result of an objection from Harrington, the Hills must have a chance to respond, and may flag any disagreement with the Court in a motion for reconsideration. See Spellan v. Bd. of Educ. for Dist. 111, 59 F.3d 642, 646 (7th Cir. 1995) (“[B]ecause the reductions in question are the product of independent judicial scrutiny of the record, the district court must afford the plaintiffs an adequate opportunity to respond to the district court's critique of the submitted petition.”).

The Hills are awarded the full $400 for clerk fees. This cost is statutorily allowable, 28 U.S.C. § 1920(1), reasonable and necessary.

The Hills are awarded $845 for service of summons and subpoena fees. Such costs are ordinarily recoverable, though they cannot “exceed the marshal's fees, no matter who actually effected service.” Collins v. Gorman, 96 F.3d 1057, 1060 (7th Cir. 1996). The marshal's fee is $65 for service, but the Hills seek to recover $75 per service, except for Cornesha Rice, for whom they seek $150 (due to a Saturday pickup and rush fee). R. 362-6, Bill of Costs, Exh. D; R. 362-7, Bill of Costs, Exh. D-1. Although Harrington did not object to this cost, the fees are reduced to $65 per service, totaling $845.

The Hills are awarded $10,194.14 in transcript fees. Money spent to obtain a copy of a transcript is recoverable, 28 U.S.C. § 1920(2), so long as the transcript was “necessarily obtained” and the cost of the transcript did not exceed the “regular copy rate as established by the Judicial Conference of the United States and in effect at the time the transcript ... was filed.” L.R. 54.1(b). Harrington does not object to these costs, but the Hills seek to recover more than is allowed: a court reporter attendance fee cannot exceed $110 for a half day (four hours or less), and $220 for a full day. The hourly attendance fees for notary publics included on the court reporter bills submitted by the Hills regularly exceed these limits. R. 362-3, Fees Pet., Exh. B-1. The Hills' costs are accordingly reduced for notary public attendance at Harrington, Alexander, Davis, Gartner, Hansen, Liebhaber, Martinez, McKenna, Noble, Nowak, Parker, Purvis, Rixey, Rodriguez, Suvada, and Johnson's depositions, as well as Walls's August deposition, totaling $2,810 in attendance fees.

The Hills are awarded $880 for witness fees. Under 28 U.S.C. § 1821, a witness attending federal court is entitled to a fee of $40 per day of attendance, as well as travel expenses. The Hills have requested $45 per witness per day, without providing information about travel expenses. R. 362-4, Exh. C; R. 362-5, Exh. C-1. Each of these charges is thus reduced by $5 ($110 total), though Harrington did not object to this cost.

The Hills are awarded the full $2,259.55 for copy costs. Harrington objects to all copy costs described as “for reference at trial” or “for use at trial” on the Hills' itemized list. Def.'s Costs Resp. at 5; R. 364-1, Def.'s Costs Resp., Exh. A. The Seventh Circuit has held that two sets of copies for use by lawyers at trial may be taxed as costs (though five or six copies would be excessive). See Kulumani v. Blue Cross Blue Shield Ass'n, 224 F.3d 681, 685 (7th Cir. 2000). Because the objected-to copies are mostly for one copy (and in only one case for two copies) for use at trial, the Hills may recover this cost.

Of the costs listed as “other costs,” Harrington objects to $62.27 in postage costs and a $12.56 travel charge incurred to serve the summonses and complaint when the lawsuit was first filed. Def.'s Costs Resp. at 4-5. Postage costs are not listed under 28 U.S.C. § 1920, but the Seventh Circuit has allowed reimbursement for postage. Tchemkou v. Mukasey, 517 F.3d 506, 512 (7th Cir. 2008) (citing Burda v. M. Ecker Co., 2 F.3d 769, 778 (7th Cir. 1993)). Because this Court is bound by Seventh Circuit precedent, and despite the lack of support in either the statute or by analysis, the Hills are awarded $62.27 in postage costs. See id. Harrington objects to the travel costs as generally not reimbursable, but because the costs are associated with service, the Hills have explained that this charge is separate from the $1,050 summons request, Pls.' Costs Reply at 3-4, and it is less than the fee charged by the marshal, the $12.56 charge is allowed.

The Hills prudently agreed to withdraw their “other costs” requests for Westlaw costs ($85), a stopwatch for use at trial ($9.91), preparation of video clips ($600), and transportation costs to meet with a witness ($29.17). Pls.' Costs Reply at 2-4. The Hills are thus awarded $14,677.25 in total costs.

B. Fees Petition

The Hills seek $819,907.50 in attorneys' fees for the work of three attorneys- Irene Dymkar, Shamoyita DasGupta, and Daniel Regenscheit-and one paralegal, Sophia Darugar. Again, the parties agree that the Hills are the prevailing party and entitled to attorneys' fees. Def.'s Fees Resp. at 1. But Harrington objects to the hourly rates charged by Dymkar, DasGupta, and Darugar, and objects to the hours charged by Dymkar, DasGupta, and Regenscheit. Id. at 2-7. Harrington also objects to the Hills' motion to correct its calculations, which increased the Hills' originally requested fees of $767,765 to $819,907.50. Def.'s Correction Resp. Because the Hills explain that the discrepancy was due to a purely mathematical calculation error and do not seek to add any new entries in their motion to correct-and because Harrington does not actually challenge the math of the corrected calculation-the Court will allow the motion to correct. See Pls.' Mot.; Def.'s Correction Resp. As explained below, after considering the reasonable hourly rates and reasonable number of hours for the Hills' attorneys, the Hills are awarded $685,363 in fees.

1. Hourly Rate

A reasonable hourly rate is “derived from the market rate for the services rendered.” Denius v. Dunlap, 330 F.3d 919, 930 (7th Cir. 2003). For attorneys who bill using contingent fee agreements, where there is no actual billing rate, district courts consider “evidence of rates similarly experienced attorneys in the community charge paying clients for similar work and evidence of fee awards the attorney has received in similar cases.” Pickett, 664 F.3d at 640 (cleaned up). “The fee applicant bears the burden of ‘produc[ing] satisfactory evidence-in addition to the attorney's own affi-davits-that the requested rates are in line with those prevailing in the community.'” Id. (quoting Blum v. Stenson, 465 U.S. 886, 895 n.11 (1984)). If the applicant satisfies this burden, then it “shifts to the other party to offer evidence that sets forth a good reason why a lower rate is essential.” Id. (cleaned up).

The Hills seek an hourly rate of $525 for Dymkar. The Hills submit an affidavit from Dymkar, who has been a trial attorney since 1977, along with affidavits from four other civil rights attorneys familiar with her work, in support of her requested rate. R. 376-6, Dymkar Decl.; R. 376-7, Neslund Aff.; R. 376-8, Foutris Aff.; R. 376-9, Hoft Decl.; R. 376-10, Power Decl.⁷ Harrington argues that Dymkar's rate should be $475 per hour, the rate last set for Dymkar in 2019. Def.'s Fees Resp. at 2-4; see Teague v. Miehle, 2019 WL 1253985, at *4 (N.D. Ill. Mar. 19, 2019); Wilbon v. Plovanich, 2019 WL 417309, at *2 (N.D. Ill. Feb. 1, 2019). More recently, in 2023, Dymkar's rate was set at $495 in another case. Boatman v. Muhammad, 2023 WL 4533260, at *8 (N.D. Ill. July 13, 2023). The Hills respond that that this rate should be increased in light of Dymkar's additional experience, as well as for inflation. Fees Pet. at 5; R. 387, Pls.' Fees Reply at 13. It is true that Dymkar has gained experience since 2017 (though at some point in a lawyer's career, more experience may not justify still higher rates). Given that Harrington concedes that $475 was a reasonable rate in 2019, and considering inflation, $525 is a reasonable hourly rate for Dymkar.⁸

7 These are of limited value, because only Hoft and Neslund aver to their own hourly rates awarded by courts-they are in a similar range to the $525 requested by the Hills for Dymkar, though at least in one case there was a much higher damages amount-and none describe actual fees for comparable attorneys in any detail. See Montanez, 755 F.3d at 554 (“[C]onclusory affidavits from attorneys merely opining on the reasonableness of another attorney's fee-unlike affidavits describing what comparable attorneys charge for similar services-have little probative value.” (cleaned up)).

8 The U.S. Department of Labor's CPI Inflation Calculator calculates that $475 in March 2019 had the same buying power as $553.62 as of July 2022, when the jury trial was held, and $587.75 as of July 2024. CPI Inflation Calculator, Bureau of Lab. Stat., https://data.bls.gov/cgi-bin/cpicalc.pl (last accessed Sept. 28, 2024). Inflation is not, on its own, a reliable metric for adjusting attorneys' rates from previously decided cases, see Pickett, 664 F.3d at 649, but it still is relevant in deciding the appropriate rate increase, also taking into account market rates, and an attorney's experience.

The Hills seek an hourly rate of $325 for DasGupta. The Hills submit an affidavit from DasGupta, who was admitted to the Illinois bar in 2015, along with affidavits from two other civil rights attorneys, in support of her requested rate. R. 376- 11, DasGupta Decl.; R. 376-12, Meyer Decl.; R. 376-13, Bowers Decl.⁹ Harrington argues that DasGupta's hourly rate should be $230, as last set by courts in this district in 2019. Def.'s Fees Resp. at 4-5; see Teague, 2019 WL 1253985, at *4; Wilbon, 2019 WL 417309, at *2 (adopting DasGupta's rate set in 2017). Like Dymkar, DasGupta's rate should reflect her increase in experience and the effect of inflation on market rates. But $325 is an unreasonable increase, even taking into account the additional experience and inflation.¹⁰ Instead, an appropriate rate is $250 per hour to factor in the three years of additional experience and inflation.

9 Meyer avers that he has charged an hourly rate of $350 and his rate has been set by courts between $350 and $400; Bowers does not provide any specifics on hourly rates. Meyer Decl. ¶¶ 10, 12-13; see Bowers Decl. For the same reason as the declarations in support of Dymkar's rate, these declarations are of limited value.

10 The U.S. Department of Labor's CPI Inflation Calculator calculates that $230 in March 2019 had the same buying power as $268.07 as of July 2022 (when the trial was held), and $284.59 as of July 2024. CPI Inflation Calculator, Bureau of Labor Statistics, https://data.bls.gov/cgi-bin/cpicalc.pl (last accessed Sept. 28, 2024).

The Hills seek an hourly rate of $135 for Darugar, citing cases litigated by Dymkar setting the paralegal rate at $125 per hour, and arguing for a rate increase given the passage of time since it was set. Fees Pet. at 13; see Wilbon, 2019 WL 417309, at *2; Teague, 2019 WL 1253985, at *5. Given the reasonableness of a $125 hourly paralegal rate in 2019, and considering inflation,¹¹ $135 is an appropriate rate for Darguar. Regenscheit's requested hourly rate of $230 is not contested, and is appropriate considering his experience and the rate previously set for him in this district. See Teague, 2019 WL 1253985, at *5.

11 The U.S. Department of Labor's CPI Inflation Calculator calculates that $125 in March 2019 had the same buying power as $145.69 as of July 2022 (when the trial was held), and $154.67 as of July 2024. CPI Inflation Calculator, Bureau of Labor Statistics, https://data.bls.gov/cgi-bin/cpicalc.pl (last accessed Sept. 28, 2024).

2. Number of Hours

Harrington objects to six categories of entries in the Hills' attorneys' time-sheets: (1) entries that are vague, (2) partner entries for work that should have been done by an associate, (3) attorney entries for work that is administrative or clerical work, (4) entries that are duplicative or excessive, (5) entries for unreasonable issues, and (6) entries for work related to the City of Chicago defendants or unrelated to this case. Def.'s Fees Resp. at 9-12.¹² Each argument is addressed in turn.

12 In addition to briefing these arguments (though not all in great detail), Harrington submitted a timesheet marking his objections. Def.'s Fees Resp. at 9-12; R. 381-1, R. 381-2, R. 381-3. The Court attaches the same documents marked up with the decisions explained in this Opinion.

“[W]hen a fee petition is vague or inadequately documented, a district court may either strike the problematic entries or (in recognition of the impracticalities of requiring courts to do an item-by-item accounting) reduce the proposed fee by a reasonable percentage.” Harper v. City of Chicago Heights, 223 F.3d 593, 605 (7th Cir. 2000). Harrington objects to billing entries stating “discuss case and strategy” and “legal research” as too vague. Def.'s Fees Resp. at 9-10. Entries must be specific enough for the Court to determine whether the time spent was reasonable and actually related to the case, especially in a case such as this one where there were many defendants but the Hills are a prevailing party (for purposes of fees) against only Harrington. See Montanez, 755 F.3d at 555-56. The Court agrees that the entries stating merely “discuss case and strategy” with another attorney, or “legal research,” without more detail are too vague. Any concerns about confidentiality, see Pls.' Fees Reply at 19, could be addressed by describing the activities at a more-general level (but still reviewable level), or submitting redacted and non-redacted timesheet versions to the Court. For example, legal-research entries could have described “legal research into liability of failure to intervene during search-warrant execution.” That description would not disclose attorney-client communications or attorney work product, especially at the end of the case. Dymkar's hours are thus reduced by 98.6 hours, DasGupta's are reduced by 66.3 hours, and Regenscheit's are reduced by 2.4 hours. Entries omitted for vagueness are marked with a red “X” in the attached timesheet.

Harrington argues that some entries should have been billed at an associate rate instead of a partner rate, and others should have been billed at a paralegal rate instead of an associate or partner rate. Def.'s Fees Resp. at 10-11. For the partner entries, Harrington argues that Dymkar should not have conducted legal research, because this is an associate task. Id. But especially in a case with low-lawyer staffing such as this one (one partner and one associate), there is nothing unusual with a partner taking on legal research at times, especially when partners might very well be speedier and more efficient at research than an associate. For the allegedly nonlawyer tasks, the Hills have made a reasonable argument that preparing exhibits and deposition notices, contacting witnesses, filing briefs, and other similar tasks required attorney time. Pls.' Fees Reply at 28-29. No hours will be reduced or billed at a different rate because an associate or non-attorney should have completed the task.

Harrington objects to entries that are unreasonably duplicative or excessive. Def.'s Fees Resp. at 10-11. The Court agrees with Harrington that it was unreasonable for two attorneys to bill for non-party depositions (though this is not to discourage attorneys from attending depositions for their own learning and training if a partner decides to conduct the deposition). Four hours are reduced from Dymkar's hours for attending Donna Rixey's deposition, as marked with a green “X” on the attached timesheet.¹³ Under this umbrella, Harrington also argues that some entries are excessive, citing DasGupta's 28.2 hours spent drafting the Rule 56.1 statement of facts, though many other entries are marked with an “E” on the timesheet. Id. at 11. It was reasonable for DasGupta to spend this time preparing the voluminous statement of facts, and Harrington has not otherwise explained why the entries are excessive, so no further hours will be reduced for this reason.

13 Harrington argues that 70 hours are unreasonably duplicative or excessive, Def.'s Fees Resp. at 10, but the Court only identified one deposition of a non-party, Donna Rixey, marked “D” by Harrington in the timesheet, so only this entry has been reduced for this reason. Other entries are marked as “D,” but Harrington did not explain why those entries were duplicative, and thus they have not been reduced.

Harrington objects to 34 hours of entries for “unreasonable issues,” including a motion on discovery and three motions leading up to trial that were denied. Def.'s Fees Resp. at 12. Just because a party is not successful on a motion does not mean that it was unreasonable for the party to pursue it, so the hours should not be reduced on this ground. That said, there is one unreasonable request: DasGupta's 0.8 hour entry on November 1, 2018 for drafting a motion for default order, when Harrington's deadline to answer the Complaint was not until December 17, 2018. See R. 51, Minute Entry 12/07/2018. The Court is all for advance preparation and timeliness, but that was a waste of time.

Lastly, Harrington objects to 4 hours of work related to the City of Chicago Defendants or to time that was unrelated to this case, but Harrington does not explain why the specific entries are contested. These include time spent reviewing COVID-19 orders issued in this case, presence in the courthouse during jury deliberations, and various discovery activities. Because Harrington does not explain his objections to these entries, and the reason to reduce them is not obvious on its face to the Court, these entries will stand.

All told, Dymkar's allowed hours are 889.8 (reduced from the requested 992.4), DasGupta's are 777.6 (reduced from 844.7), Regenscheit's are 18.8 (reduced from 21.2), and Darugar's are 144.4 (Harrington did not object to any of her hours).

3. Lodestar Adjustment

With the rates and hours established, the lodestar is as follows: $467,145 for Dymkar, $194,400 for DasGupta, $4,324 for Regenscheit, and $19,494 for Darugar, totaling $685,363. Harrington next argues that the lodestar should be reduced by 50%, because-according to him-the Hills had only “minimal” success in the lawsuit. Def.'s Fees Resp. at 13. In support of this request, Harrington argues that the Hills took a scattershot approach to the lawsuit, the jury award was less than what the Hills sought at trial, the fee request is disproportionate to the judgment, and Harrington made a substantial settlement offer. Def.'s Fees Resp. at 13-17.

When setting a reasonable fee, the Court “must determine whether the plaintiff achieved a level of success that makes the hours reasonably expended a satisfactory basis for making a fee award.” Montanez, 755 F.3d at 556 (cleaned up). “A plaintiff who achieves ‘excellent results' should receive the entire lodestar, but where ‘a plaintiff has achieved only partial or limited success,' the lodestar ‘may be an excessive amount.'” Id. (quoting Hensley, 461 U.S. at 435-36).

A lodestar adjustment is not warranted in this case. The Hills went to trial against Harrington on three claims, and the jury reached a liability verdict on two of those claims, awarding the Hills $68,000 in total damages. This was a substantial damages award. The Hills repeatedly offered settlement terms to Harrington for between $30,000 and $40,000 per plaintiff, which is close to the amount that they won at trial. See Fees Pet. at 16-18. The Court takes Harrington's point that these offers did not always include attorneys' fees. Def.'s Fees Resp. at 16-17. But when Harrington offered $150,000 (inclusive of attorneys' fees) as his best and final offer before trial, he did not make use of the offer-of-judgment mechanism in Civil Rule 68(a). Harrington could even have offered the Hills something south of $68,000 (if he now thinks that the sum is so paltry). This would have frozen the accrual of fees had the Hills rejected the offer, gone to trial, and failed to obtain a more favorable result. Harrington cannot now shift all of the risk that both parties took in going to trial onto the plaintiffs: Harrington, just like the Hills, chose to go to trial, and should not be surprised that the result is a significant fee award post-trial. The Hills are entitled to the entire lodestar, as calculated by the Court.

Lastly, the Hills seek prejudgment interest at a rate of 7% on their award of attorneys' fees. Fees Pet. at 19-21. “Since payment for services in civil rights litigation often comes by court order years after the services were performed, the court must account for the delay in payment of attorney's fees” and may do so either by calculating “the fee award for services rendered in prior years using the attorney's current hourly billing rate” or by “using the hourly rate the lawyer charged at the time the lawyer performed the services for the client (the ‘historical rate') and add[ing] interest to that amount.” Pickett v. Sheridan Health Care Ctr., 813 F.3d 640, 647 (7th Cir. 2016). Because the Court already accounted for the passage of time in setting the attorneys' rates as explained above, the Hills are not entitled to prejudgment interest.

IV. Conclusion

The Hills' bill of costs and fees petition are granted in part and denied in part. The Hills are awarded $14,677.25 in taxable costs and $685,363 in attorneys' fees.

ATTORNEY SERVICES FOR PLAINTIFFS, CHARLES HILL AND DONNA HILL

Irene K. Dymkar

Hill v. Harrington, 18 C 5592

Date Service provided Time expended (in hours) City time (in hours) 2/6/2017 Review attorney Shamoyita DasGupta notes from initial telephone interview 0.3 2/6/2017 Conference with attorney Shamoyita DasGupta 0.2 2/15/2017 Initial conference with clients 1.7 2/15/2017 Draft retainer agreement for Charles Hill, and review with client 0.2 2/15/2017 Draft retainer agreement for Donna Hill, and review with client 0.2 2/15/2017 Review client intake sheet with Charles Hill 0.2 2/15/2017 Review client intake sheet with Donna Hill 0.2 2/15/2017 Review documents from clients 0.2 2/15/2017 Set up investigatory file and determine need for records 0.3 2/15/2017 Develop litigation strategy and plan for case, tracking for criminal case resolution 0.3 2/15/2017 Conference with staff to determine task assignment 0.3 3/7/2017 Draft letter to clients 0.2 3/14/2017 Review Chicago police reports 0.6 3/15/2017 Review photos taken by client, Charles Hill 0.3 3/15/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.2 4/13/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.1 5/9/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.5 5/12/2017 Conference with clients, Charles Hill and Donna Hill 1.1 5/17/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.2 8/9/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.3 10/16/2017 Discuss case and strategy with attorneys Shamoyita DasGupta and Daniel Regenscheit X 0.3 6/26/2018 Review file, Chicago police and IDOC documents 0.4 8/13/2018 Draft email to attorney Shamoyita DasGupta 0.3 8/13/2018 Review draft and revise complaint 0.3 8/15/2018 Review file, Chicago police and IDOC documents 0.9 8/15/2018 Review draft and revise complaint 2.7 8/15/2018 Legal research X 0.4 8/15/2018 Draft attorney appearance 0.2 8/15/2018 Draft cover sheet 0.1 8/16/2018 Review court order and assignment order 0.1 18 8/16/2018 Review MIDP notice, standing order, and requirements 0.3 8/23/3018 Review summonses 0.3 9/7/2018 Review affidavits of service 0.2 9/10/2018 Review attorney appearance and modify email and mail groups 0.1 9/10/2018 Review agreed motion to extend time 0.2 9/12/2018 Review court order 0.1 9/12/2018 Review DasGupta email to court deputy 0.1 10/10/2018 Review attorney appearances and modify email and mail groups 0.1 10/25/2018 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 10/29/2018 Review answer to complaint and affirmative defenses 0.3 11/1/2018 Review and revise initial joint status report 0.6 11/2/2018 Review attorney appearances and modify email and mail groups 0.2 11/2/2018 Review agreed motion to extend time 0.2 11/2/2018 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 11/2/2018 Review and revise status report 0.5 11/5/2018 Review and revise status report 0.5 11/5/2018 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 11/5/2018 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/6/2018 Review court order 0.1 11/7/2018 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 11/7/2018 Prepare for court 0.3 11/8/2018 Court appearance, including travel 0.9 11/8/2018 Review court order and calendar all dates 0.2 11/8/2018 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 11/16/2018 Conference with clients, Charles Hill and Donna Hill 0.6 11/16/2018 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 11/27/2018 Review MDIL disclosures 0.8 11/28/2018 Review MDIL disclosures 0.3 11/28/2018 Review plaintiffs' notice of service of MDIL disclosures 0.1 11/28/2018 Review defendants' notice of service of MDIL disclosures 0.1 11/28/2018 Review defendants' MDIL disclosures vague as to which defe ।dant 0.2 11/28/2018 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 11/29/2018 Review agreed motion to extend time 0.1 11/29/2018 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 11/30/2018 Review motion for protective order 0.2 11/30/2018 Review proposed protective order 0.6 12/6/2018 Review DasGupta email to court deputy 0.1 12/7/2018 Review order and confidentiality order 0.2 12/17/2018 Review defendants' motion to dismiss complaint 0.7 12/17/2018 Review answers to complaint 0.7 12/18/2018 Review court order 0.1 1/7/2019 Review defendants' notice of service of MDIL disclosures 0.1 1/7/2019 Review MDIL disclosures 0.6 1/17/2019 Legal research X 0.5 1/18/2019 Legal research X 2.4 1/18/2019 Draft response to IDOC motion to dismiss 2.7 1/18/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 1/21/2019 Draft interrogatories to City of Chicago defendants for Charles Hill 0.7 19 1/21/2019 Draft interrogatories to City of Chicago defendants for Donna Hill 0.3 1/21/2019 Draft interrogatories to IDOC defendants for Charles Hill 0.7 1/21/2019 Draft interrogatories to IDOC defendants for Donna Hill 0.3 1/21/2019 Draft requests to produce to City of Chicago defendants 0.5 1/21/2019 Draft requests to produce to IDOC defendants 0.5 1/22/2019 Draft interrogatories to City of Chicago defendants for Charles Hill 0.5 1/22/2019 Court appearance, including travel 0.7 1/22/2019 Conference with IDOC attorney, Kelly Bauer, after court 0.1 1/22/2019 Review court order and calendar all dates 0.2 1/22/2019 Draft interrogatories to IDOC defendants for Charles Hill 0.5 1/23/2019 Draft requests to produce to City of Chicago defendants 1.3 1/23/2019 Draft interrogatories to IDOC defendants for Donna Hill 1.0 1/23/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/24/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/25/2019 Draft email to defense attorneys 0.1 1/25/2019 Draft email to City attorney Jessica Griff 0.1 1/28/2019 Review and revise motion to extend time 0.9 1/28/2019 Draft notice of motion 0.1 1/28/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 1/28/2019 Review emails sent to defendants' attorneys 0.1 2/1/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 2/1/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 2/4/2019 Review IDOC reply to motion to dismiss 0.8 2/5/2019 Review court order and calendar all dates 0.1 2/18/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/27/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 3/28/2019 Draft answers to IDOC Harrington interrogatories for Charles Hill 1.0 3/28/2019 Draft answers to IDOC Harrington interrogatories for Donna Hill 0.9 3/28/2019 Draft answers to City McKenna interrogatories for Charles Hill 1.7 3/28/2019 Draft answers to City McKenna interrogatories for Donna Hill 1.6 3/28/2019 Draft answers to City Liebhaber interrogatories for Charles Hill 0.9 3/28/2019 Draft answers to City Liebhaber interrogatories for Donna Hill 0.9 3/28/2019 Draft answers to City Gartner interrogatories for Charles Hill 0.8 3/28/2019 Draft answers to City Gartner interrogatories for Donna Hill 0.8 3/28/2019 Draft response to City request to produce for Charles Hill 1.1 3/28/2019 Draft response to City request to produce for Donna Hill 1.1 3/28/2019 Draft response to IDOC request to produce 0.7 3/28/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 3/29/2019 Conference with clients, Charles Hill and Donna Hill 1.5 3/29/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/29/2019 Revise 11 discovery responses 5.7 4/2/2019 Draft email to court deputy 0.1 4/3/2019 Court appearance, including travel 0.9 4/3/2019 Review court order 0.1 4/5/2019 Review additional IDOC MIDP discovery 0.4 4/15/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/2/2019 Review email and deposition notice from attorney Kelly Bauer 0.2 20 5/6/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/10/2019 Draft email to IDOC attorney Kelly Bauer 0.1 5/14/2019 Review DasGupta email to defendants' attorneys 0.1 5/14/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/15/2019 Review defendants' deposition notice for plaintiffs 0.1 5/17/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/17/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 5/17/2019 Review discovery documents 0.2 5/21/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/22/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/23/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/23/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 5/24/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/24/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 5/29/2029 Review attorney appearance 0.1 5/30/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 6/3/2019 Draft and prepare additional MDIP disclosure 0.2 6/3/2019 Prepare questions for clients' deposition 0.9 6/3/2019 Conference with clients, Charles Hill and Donna Hill 1.7 6/4/2019 Prepare Charles Hill for deposition 2.1 6/4/2019 Deposition of Charles Hill, including travel and wait 6.1 6/4/2019 Conference with clients, Charles Hill and Donna Hill 0.8 6/4/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 6/5/2019 Prepare Donna Hill for deposition 1.1 6/5/2019 Deposition of Donna Hill, including travel amd wait 6.0 6/5/2019 Conference with clients, Charles Hill and Donna Hill 0.5 6/5/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 6/6/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/6/2019 Review subpoena response from Mega Sports re firearm purchase 0.2 6/12/2019 Review Keitrion Lewis parole records 1.3 6/12/2019 Prepare for telephone conference with Keitrion Lewis in prison 0.6 6/12/2019 Telephone conference with Keitrion Lewis in prison 0.7 6/12/2019 Draft email to defendants' attorneys 0.2 6/12/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/13/2019 Draft email to defendants' attorneys 0.1 6/13/2019 Legal research X 6.1 6/13/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 6/14/2019 Review Keitrion Lewis parole records, master file 2.0 6/14/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 6/15/2019 Telephone conference with Lawrence Corr. Center 0.2 6/17/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/17/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/18/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/20/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 6/20/2019 Review deposition scheduling report and determining conflicts 0.8 21 6/20/2019 Review and revise deposition notice 0.4 6/20/2019 Review email from IDOC attorney, Kelly Bauer (2) 0.2 6/20/2019 Review email from City attorney (2) 0.2 6/20/2019 Review defendants' joint alternate scheduling report 0.2 6/21/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/24/2019 Review email from IDOC attorney, Kelly Bauer 0.1 6/24/2019 Review email from attorney Shamoyita DasGupta 0.1 6/25/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 6/25/2019 Draft email to IDOC attorney Kelly Bauer 0.1 6/25/2019 Telephone conference with witness Shatrion Hill 0.8 6/25/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/25/2019 Review IDOC motion to take Keitrion Lewis deposition in prison 0.4 6/26/2019 Draft email to court deputy 0.1 6/26/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/26/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/26/2019 Review court order 0.1 6/27/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/27/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/28/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/28/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/1/2019 Prepare for telephone conference with Keitrion Lewis in prison 1.0 7/1/2019 Telephone conference with Keitrion Lewis in prison 0.7 7/1/2019 Review discovery documents and file 4.2 7/1/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.3 7/1/2019 Draft email to defendants' attorneys 0.2 7/1/2019 Telephone conference with client, Charles Hill 0.5 7/1/2019 Telephone conference with client, Donna Hill 0.6 7/1/2019 Draft email, Local Rule 37.2, to defense attorneys 0.2 7/2/2019 Telephone conference with client, Charles Hill 0.7 7/2/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.6 7/2/2019 Review email from IDOC attorney, Kelly Bauer 0.1 7/2/2019 Review email from City attorney, Emily Dory 0.1 7/2/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/2/2019 Select and review exhibits for deposition 0.3 7/2/2019 Draft MIDP supplemental disclosures 0.4 7/2/2019 Telephone conference with witness Jada Hill 0.6 7/2/2019 Review email from City attorney, Jessica Griff 0.1 7/2/2019 Draft email to City attorney Jessica Griff 0.1 7/2/2019 Review attorney appearance and modify email and mail groups 0.1 7/3/2019 Prepare for deposition, review parole documents, prepare questions 2.2 7/3/2019 Deposition of Keitrion Lewis in prison, including wait 4.9 7/3/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 7/3/2019 Rule 37.2 conference with defendants' attorneys 0.5 7/5/2019 Review email from IDOC attoreny Kelly Bauer 0.2 7/5/2019 Draft email to IDOC attorney Kelly Bauer 0.3 22 7/5/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/6/2019 Telephone conference with witness Odell Dollerson 0.7 7/8/2019 Telephone conference with client, Charles Hill 0.6 7/8/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 7/8/2019 Draft emails to defendants' attorneys (2) 0.3 7/8/2019 Review email from City attorney, Michele McGee 0.1 7/8/2019 Prepare for deposition, prepare questions 1.1 7/8/2019 Deposition of Odell Dollerson, including travel and wait 2.5 7/9/2019 Prepare for Donna Rixey deposition, prepare questons 1.8 7/9/2019 Prepare for Rixie Davis deposition, prepare questions 1.5 7/9/2019 Deposition of Donna Rixey 4.0 7/9/2019 Deposition of Rixie Davis 2.9 7/10/2019 Court appearance, including travel 0.7 7/10/2019 Conference with defendants' attorneys after court 0.3 7/10/2019 Review court order 0.1 7/10/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 7/11/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 1.1 7/11/2019 Review deposition questions with attorney Shamoyita DasGupta 0.6 7/12/2019 Review emails from IDOC attorney Kelly Bauer (2) 0.3 7/12/2019 Conference with attorney Shamoyital DasGupta to prepare and review Rodney Alexander and Tamika Johnson deposition questions (2) 0.9 7/12/2019 Draft email to IDOC attorney Kelly Bauer (2) 0.3 7/12/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 7/15/2019 Draft email to City attorney Michele McGee 0.4 7/15/2019 Telephone conference with client, Charles Hill 0.7 7/16/2019 Draft email to defense attorneys 0.2 7/16/2019 Draft demand letter to defense attorneys 0.6 7/16/2019 Discuss case and strategy with attorney Shamoyita DasGupta (3) X 0.9 7/16/2019 Prepare for deposition 3.9 7/16/2019 Review new discovery re canine involvement 0.3 7/17/2019 Prepare for deposition 1.0 7/17/2019 Deposition of Christopher Harrington, including travel 8.3 7/17/2019 Conference with clients, Charles Hill and Donna Hill (2) 0.4 7/17/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 7/18/2019 Telephone confernce with client, Donna Hill 0.6 7/18/2019 Draft email to defense attorneys (2) 0.3 7/18/2019 Review emails from defense attorneys (2) 0.3 7/18/2019 Revise demand letter 0.3 7/18/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 7/19/2019 Draft email to City attorneys Jonathan Green and Andrea Campbell 0.2 7/19/2019 Review email from City attorneys Jonathan Green and Andrea Campbell 0.1 7/19/2019 Draft email to IDOC attorney Kelly Bauer (2) 0.4 7/19/2019 Review email from IDOC attorney Kelly Bauer 0.2 23 7/19/2019 Review projected deposition schedule, and resolve conflicts 0.7 7/22/2019 Draft emails to defendants' attorneys (3) 0.5 7/22/2019 Draft requests to admit 3.1 7/22/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 7/22/2019 Review email from IDOC attorney Kelly Bauer 0.2 7/22/2019 Draft letter to defendants' attorneys 0.4 7/23/2019 Telephone conference with City attorney Jonathan Green 0.3 7/23/2019 Review email from City attorney Michele McGee 0.2 7/23/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.8 7/23/2019 Draft email to defendants' attorneys 0.2 7/23/2019 Prepare for deposition of Scott Liebhaber 1.0 7/23/2019 Prepare for deposition of Steven Suvada 0.9 7/24/2019 Prepare for deposition of Scott Liebhaber 2.1 7/24/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 7/24/2019 Prepare for deposition of Steven Suvada 1.9 7/24/2019 Deposition of Scott Liebhaber 3.1 7/24/2019 Deposition of Steven Suvada 3.7 7/25/2019 Review email from City attorney Jessica Griff 0.2 7/25/2019 Conference with attorney Shamoyital DasGupta to prepare and review Kevin Bond and Marcus Cotton depositions (2) 0.6 7/25/2019 Telephone conference with City attorney Jennifer Bagby 0.3 7/25/2019 Rule 37.2 conference with defendants' attorneys 0.8 7/26/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 7/26/2019 Prepare for deposition 2.0 7/26/2019 Deposition of Elena McKenna 2.9 7/29/2019 Conference with attorney Shamoyital DasGupta to prepare and review David Rodriguez deposition questions (2) 0.5 7/30/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/31/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 8/2/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.4 8/5/2019 Review photographs 0.5 8/5/2019 Draft response to request to produce 0.6 8/5/2019 Letter to defendants' attorneys 0.2 8/5/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 8/6/2019 Review email from City attorney, Michele McGee (2) 0.2 8/6/2019 Review email from IDOC attorney, C. Desmond 0.1 8/6/2019 Draft email to defendants' attorneys 0.1 8/6/2019 Prepare for deposition of James Noble 1.2 8/6/2019 Prepare for deposition of Danjwan Johnson 0.7 8/6/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 8/6/2019 Review court order and assignment order 0.1 8/7/2019 Review magistrate judge court order 0.1 8/7/2019 Draft discovery status report 0.5 8/7/2019 Draft email to defendants' attorneys 0.1 8/7/2019 Prepare for deposition of James Noble 0.8 24 8/7/2019 Prepare for deposition of Danjwan Johnson 0.7 8/7/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 8/7/2019 Prepare exhibits for Noble deposition ,2 8/7/2019 Prepare exhibits for Johnson deposition 0.2 8/7/2019 Deposition of IDOC agent, James Noble 3.8 8/7/2019 Deposition of IDOC agent, Danjwan Johnson 0.8 8/8/2019 Conference with attorney Shamoyital DasGupta to prepare and review Robert Purvis and Simon Mbi depositions (2) 0.5 8/8/2019 Rule 26(f) conference with defendants' attorneys 0.2 8/9/2019 Review Dept. Children and Family Services license and daycare documents 0.4 8/9/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 8/9/2019 Revise MDIP Rule 26(f) report 0.6 8/12/2019 Review motion to compel 0.5 8/12/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 8/13/2019 Telephone conference with client, Charles Hill 1.0 8/13/2019 Telephone conference with attorney J Bagley 0.5 8/13/2019 Telephone conference with witness, Shatrion Hill 1.1 8/13/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 8/13/2019 Court appearance, motion hearing, including travel 0.9 8/13/2019 Review witness John Gartner's answers to interrogatories 0.3 8/13/2019 Review magistrate judge court order 0.2 8/14/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 8/14/2019 Review email from City attorney, Michele McGee (2) 0.2 8/14/2019 Draft email to City attorney, Michele McGee (3) 0.2 8/14/2019 Review letter from City attorney Michele McGee to Judge Cox 0.2 8/14/2019 Prepare for deposition of Shatrion Hill 1.3 8/14/2019 Deposition of Shatrion Hill, including travel 3.8 8/14/2019 Review defendants' letter to court 0.1 8/14/2019 Review court order 0.1 8/14/2019 Telephone conference with client, Charles Hill 0.4 8/14/2019 Draft email to defendants' attorneys re late disclosures 0.3 8/15/2019 Prepare for deposition 1.7 8/15/2019 Deposition of witness, John Gartner 3.5 8/15/2019 Telephone conference with client, Charles Hill 0.5 8/15/2019 Review email from IDOC attorney Kelly Bauer 0.1 8/15/2019 Draft email to IDOC attorney Kelly Bauer 0.1 8/16/2019 Draft motion to extend time 1.5 8/16/2019 Draft email to defendants' attorneys 0.1 8/16/2019 Review emails from attorney Shamoyita DasGupta to defendants' attorneys (3) 0.3 8/16/2019 Review emails from defendants' attorneys to attorney Shamoyita DasGupta (3) 0.3 8/16/2019 Draft memorandum re witnesses Chicago officers Ciolli, Campbell per court order 1.8 8/16/2019 Review attorney Shamoyita DasGupta declaration re photographs 0.3 25 8/16/2019 Review photographs taken by Shatrion Hill of her home 0.3 8/16/2019 Discuss case and strategy with attorney Shamoyita DasGupta (4) X 1.2 8/19/2019 Review attorney Shamoyita DasGupta email to defendants' attorneys 0.1 8/19/2019 Review attorney Shamoyita DasGupta letter to Keitrion Lewis 0.1 8/20/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 8/20/2019 Review Shamoyita DasGupta emails to defendants' attorneys 0.1 8/21/2019 Review screenshots of witnesses to use as evidence 0.2 8/21/2019 Revew motion to extend time 0.1 8/21/2019 Review magistrate judge court decision and order, and consider whether to object to district court 0.4 8/21/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 8/21/2019 Review defendants' responses to requests to admit 0.5 8/21/2019 Revew City motion to extend time 0.2 8/22/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/23/2019 Review magistrate judge court order 0.1 8/23/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 8/25/2019 Review opinion and order on motion to dismiss. 0.8 8/26/2019 Prepare for deposition of Jacob Walls 2.0 8/26/2019 Deposition of IDOC agent, Jacob Walls 2.5 8/26/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 8/26/2019 Review Shamoyita DasGupta email to court deputy 0.1 8/26/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/27/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/27/2019 Review email from defendants' attorneys 0.1 8/27/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 8/28/2019 Court appearance, including travel 0.9 8/28/2019 Conference with defendants' attorneys after court 0.2 8/28/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 8/28/2019 Review magistrate judge court order 0.1 8/28/2019 Review discovery documents from IDOC 0.2 8/28/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/29/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 8/30/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/30/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/3/2019 Letter to defense attorneys re Walls and ammunition 0.6 9/3/2019 Draft email to defendants' attorneys 0.1 9/3/2019 Review email from City attorney, Jonathan Green 0.1 9/3/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/3/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/4/2019 Review letter from IDOC attorney, Kelly Bauer 0.3 9/4/2019 Revise and finalize motion to set aside magistrate judge order barring plaintiffs from taking depositions and allowing Jacob Walls to disclose withheld evidence 3.1 26 9/4/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 9/4/2019 Legal research X 0.7 9/4/2019 Draft notice of motion 0.1 9/4/2019 Review court order 0.1 9/5/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/6/2019 Review court order 0.1 9/6/2019 Draft email to court deputy 0.3 9/6/2019 Draft notice of motion 0.1 9/6/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/6/2019 Review 8/28/2019 court hearing transcript 0.1 9/6/2019 Draft email to defendants' attorneys 0.2 9/6/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/6/2019 Draft motion for settlement conference 0.8 9/6/2019 Draft notice of motion and correcton notice (2) 0.1 9/9/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 9/9/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/10/2019 Telephone conference with witness Corneshia Rice 0.8 9/10/2019 Review court order 0.1 9/10/2019 Prepare for three depositions, of Erin Hansen, Thomas Nowak, and Cornesha Rice 2.3 9/10/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.8 9/10/2019 Review motion to withdraw 0.1 9/10/2019 Review court transcript of 8/13/2019 0.2 9/10/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/11/2019 Prepare for deposition of Erin Hansen 1.8 9/11/2019 Prepare exhibits for deposition of Erin Hansen 0.2 9/11/2019 Prepare for deposition of Thomas Nowak 1.3 9/11/2019 Prepare exhibits for deposition of Thomas Nowak 0.2 9/11/2019 Prepare for deposition of Corneshia Rice 1.0 9/11/2019 Deposition of witness Erin Hansen 2.8 9/11/2019 Deposition of Thomas Nowak 2.0 9/11/2019 Telephone conference with witness Corneshia Rice (2) 0.4 9/11/2019 Deposition (incomplete) of Corneshia Rice, including travel and wait 1.2 9/11/2019 Conference with witness Corneshia Rice 0.3 9/11/2019 Conference with defendants' attorneys 0.4 9/11/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.4 9/12/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 9/13/2019 Review court transcript 8/13/2019 0.8 9/13/2019 Review court order and revise mail and email groups 0.1 9/13/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.4 9/13/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/16/2019 Telephone conference with City attorney, Jennifer Bagby 0.1 9/16/2019 Telephone conference with witness, Corneshia Rice 0.1 9/16/2019 Prepare for deposition of Steven Martinez 1.0 9/16/2019 Prepare for deposition of Corneshia Rice 0.8 27 9/16/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 9/16/2019 Prepare exhibits for Martinez video deposition 0.3 9/16/2019 Deposition of witness, Steven Martinez, including travel 4.3 9/16/2019 Telephone conference with witness, Gertrude Brady 0.5 9/16/2019 Deposition of witness, Corneshia Rice, including travel 2.0 9/17/2019 Review IDOC motion to withdraw 0.1 9/17/2019 Conference with attorney Shamoyital DasGupta to prepare and review Gertrude Brady deposition questions (2) 0.4 9/17/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.8 9/17/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/17/2019 Draft email to witness Martinez's employment litigation attorney (2) 0.2 9/17/2019 Review IDOC MDIP notice and additional discovery 0.2 9/17/2019 Review email from witness Martinez's employment attorney about lawsuit againt City 0.2 9/17/2019 Draft motion to reassign magistrate judge for motion to reconsider, per court's direction 0.7 9/18/2019 Telephone conference with IDOC attorney, Kelly Bauer 0.1 9/18/2019 Telephone conference with City attorney, Andrea Campbell 0.1 9/18/2019 Review magistrate judge court order 0.1 9/18/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/18/2019 Review supplemental MIDP disclosures 0.1 9/18/2019 Review IDOC motion for rule to show cause and to bar plaintiffs' witnesses 0.6 9/18/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 9/18/2019 Review email from IDOC attorney, Kelly Bauer 0.1 9/18/2019 Review email from City attorney, Michele McGee 0.1 9/19/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 9/19/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/19/2019 Review magistrate judge court order 0.1 9/20/2019 Review district court orders (2) 0.1 9/20/2019 Review court transcript 8/28/2019 0.2 9/20/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/20/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/20/2019 Review email to court deputy 0.1 9/21/2019 Draft response to rule to show cause and to bar plaintiffs' witnesses 1.0 9/21/2019 Draft motion for reconsideration re protective order 1.6 9/21/2019 Review exhibits for motion 0.2 9/23/2019 Review magistrate judge court order 0.1 9/23/2019 Review Shamoyita DasGupta email to magistrate judge court deputy 0.1 9/26/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 9/27/2019 Review IDOC response to motion for reconsideration 0.8 9/27/2019 Review City response to motion for reconsideration 0.7 9/27/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 9/28/2019 Review court transcript 8/29/2019 0.7 10/1/2019 Review magistrate judge court order and order to show cause 0.2 10/1/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 28 10/1/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/1/2019 Draft reply to response to motion for reconsideration 1.9 10/2/2019 Review Shamoyita DasGupta email to court deputy 0.1 10/2/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/3/2019 Review court order 0.1 10/3/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/4/2019 Review affidavit of service on Gertha Brady of order to show cause 0.2 10/4/2019 Review supplemental MIDP disclosures 0.1 10/4/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 10/4/2019 Review magistrate judge court order 0.1 10/8/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/8/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 10/9/2019 Court appearance, including travel 0.9 10/9/2019 Discuss case with defendants' attorneys and Gertha Brady after court 0.2 10/9/2019 Review email from attorney Shamoyita DasGupta 0.1 10/9/2019 Review magistrate judge court order 0.1 10/10/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/14/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/14/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/15/2019 Prepare for court 0.3 10/15/2019 Court appearance, including travel 1.0 10/16/2019 Review court order 0.1 10/15/2019 Conference with IDOC attorney, Kelly Bauer 0.2 10/18/2019 Draft motion to set aside magistrate judge order (Rule 72) 3.6 10/18/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 10/19/2019 Conference with attorney Shamoyital DasGupta to prepare and review Gertrude Brady deposition (2) 0.9 10/22/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 10/22/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/24/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/24/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/25/2019 Prepare for limited deposition of Jacob Walls 1.5 10/25/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 10/25/2019 Second deposition of Jacob Walls 1.3 10/29/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/4/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/5/2019 Review email from defendants' attorneys 0.1 11/5/2019 Review defendants' motion to file excess pages (all defendants) 0.2 11/5/2019 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 11/6/2019 Review court order 0.1 11/7/2019 Review IDOC response to motion for reconsideration 0.9 11/12/2019 Review magistrate judge court order 0.1 11/14/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 29 11/18/2019 Draft motion to extend time 0.6 11/20/2019 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/20/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 11/20/2019 Review court order 0.1 12/12/2019 Legal research X 0.8 12/12/2019 Draft reply to IDOC response to motion for reconsideration 1.2 12/13/2019 Review history of motion filings, orders 1.5 12/13/2019 Draft reply to IDOC response to motion for reconsideration 3.8 12/13/2019 Legal research X 0.7 12/13/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 12/30/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/2/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/9/2020 Review court order 0.1 1/9/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/20/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/30/2020 Review court order 0.1 2/17/2020 Review file and notes, to develop trial plan and determine if defendants should be dismissed 0.7 2/20/2020 Review court decisions and orders 0.8 2/21/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 2/24/2020 Review IDOC motion to limit time of Harrington deposition 0.5 2/26/2020 Review court order 0.1 2/26/2020 Draft motion to extend time limit to take Harrington deposition 0.7 2/26/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.3 2/26/2020 Draft notice of motion 0.1 2/26/2020 Draft response to motion to limit deposition to one hour 0.7 2/26/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 2/26/2020 Review Shamoyita DasGupta email to court deputy 0.1 2/27/2020 Review court order 0.1 2/27/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 3/6/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 3/6/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/10/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/16/2020 Review court general order re COVID (2) 0.1 3/16/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/16/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 3/17/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/23/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 3/30/2020 Review court general order re COVID 0.1 3/31/2020 Research and annotate IDOC administrative directives (multiple) 2.6 4/1/2020 Research and annotate IDOC administrative directives (multiple) 1.3 4/2/2020 Review detailed court order 0.2 4/2/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 4/2/2020 Review Shamoyita DasGupta emails to defendants' attorneys (multiple) 0.1 4/3/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 30 4/3/2020 Draft motion to amend court order 0.5 4/3/2020 Draft notice of motion 0.1 4/14/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 4/15/2020 Review status report drafted by attorney Shamoyita DasGupta 0.2 4/15/2020 Review defendants' proposed revisions to status report 0.2 4/16/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.4 4/16/2020 Review multiple emails and revisons of status report by defendants 0.2 4/17/2020 Review detailed court order and calendar all dates 0.3 4/17/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/23/2019 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/23/2019 Review Shamoyita DasGupta email to court deputy 0.1 4/24/2020 Review court general order re COVID 0.1 4/27/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/18/2020 Review Shamoyita DasGupta email to court deputy 0.1 5/18/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/26/2020 Review court general order re COVID 0.1 5/27/2020 Review email to court deputy from attorney Shamoyita DasGupta and defense attorneys 0.2 5/27/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/27/2020 Review email from court deputy 0.1 5/28/2020 Review email from attorney Shamoyita DasGupta 0.1 5/28/2020 Review Shamoyita DasGupta email to court deputy 0.1 5/28/2020 Draft email to attorney Shamoyita DasGupta 0.1 6/2/2020 Review court order 0.1 6/15/2020 Review email from attorney Shamoyita DasGupta 0.1 6/15/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 6/15/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/15/2020 Draft motion to extend time to take Harrington deposition 0.4 6/15/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 6/16/2020 Review court order 0.1 6/18/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/25/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/26/2020 Review email from attorney Shamoyita DasGupta 0.1 6/26/2020 Review status report drafted by Shamoyita DasGupta, and revisions by defendants' attorneys 0.2 7/8/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/8/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/10/2020 Review court order re COVID 0.1 7/13/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/13/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/14/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 7/14/2020 Review email from attorney Shamoyita DasGupta 0.1 7/14/2020 Review email from defendants' attorneys (2) 0.2 7/17.2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/17.2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/21/2020 Review email from attorney Shamoyita DasGupta 0.1 31 7/21/2020 Review email from IDOC attorney, Kelly Bauer 0.1 7/21/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/22/2020 Review deposition notice 0.2 7/22/2020 Draft email to attorney Shamoyita DasGupta 0.1 7/22/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/22/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/23/2020 Review email from attorney Shamoyita DasGupta 7/23/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/23/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/27/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 7/28/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 7/28/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 7/28/2020 Review and revise deposition notice 0.2 7/28/2020 Review email from attorney Shamoyita DasGupta 0.1 7/29/2020 Prepare for deposition (review prior deposition transcripts, exhibits, abstracts of depositions,discovery documents) 6.1 7/29/2020 Telephone conference and tutorial with court reporter 1.0 7/29/2020 Prepare questions for Harrington for limited deposition 2.1 7/29/2020 Review and study exhibits for deposition 1.1 7/29/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 7/29/2020 Review multiple emails to/from attorney Shamoyita DasGupta to/from defendants' attorneys re inspecting box of ammunition 0.3 7/29/2020 Draft emails to attorney Shamoyita DasGupta (2) 0.3 7/29/2020 Review email from attorney Shamoyita DasGupta 0.1 7/30/2020 Prepare for deposition, including reviewing chart of seized firearms and ammunition 1.7 7/30/2020 Second deposition of Christopher Harrington, extended time because of techinical difficulties with Zoom 1.8 7/30/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.6 8/5/2020 Review email from attorney Shamoyita DasGupta and status report 0.2 8/5/2020 Draft email to attorney Shamoyita DasGupta (2) 0.5 8/5/2020 Review email from attorney Shamoyita DasGupta 0.1 8/5/2020 Review to do list and case plan 0.8 8/10/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 8/10/2020 Review IDOC motion for summary judgment, and memorandum of law 1.2 8/10/2020 Review IDOC statement of undisputed material facts 1.0 8/10/2020 Review City motion for summary judgment, and memorandum of law 1.3 8/10/2020 Review City statement of undisputed material facts 1.1 8/11/2020 Review court order 0.1 8/11/2020 Review email from attorney Shamoyita DasGupta 0.1 8/11/2020 Review City motion to strike exhibit 0.4 8/13/2020 Review court order 0.1 8/13/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 8/13/2020 Review email from attorney Shamoyita DasGupta 0.1 8/19/2020 Review email from attorney Shamoyita DasGupta 0.1 32 8/20/2020 Review email from attorney Shamoyita DasGupta 0.1 8/20/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/20/2020 Review email from attorney Shamoyita DasGupta 0.1 8/20/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 8/21/2020 Review email from IDOC attorney, Kelly Bauer (2) 0.2 8/21/2020 Draft email to IDOC attorney, Kelly Bauer (2) 0.2 8/26/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 8/26/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/2/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 9/2/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/10/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 9/11/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 9/11/2020 Review email from attorney Shamoyita DasGupta 0.1 9/11/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/28/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 10/5/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/5/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 10/6/2020 Review email from attorney Shamoyita DasGupta 0.1 10/6/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 10/6/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 10/8/2020 Review draft of motion to extend time 0.2 10/8/2020 Review draft of motion to reopen discovery to view and photograph ammunition in evidence 0.3 10/8/2020 Review motion to withdraw 0.1 10/9/2020 Review court order 0.1 11/2/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/2/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 11/5/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 11/5/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/9/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 11/9/2020 Prepare for Zoom call inspecton of ammunition 0.5 11/9/2020 Zoom call inspection and photographing of ammunition in IDOC custody 0.8 11/9/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/13/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 11/16/2020 Review email from attorney Shamoyita DasGupta 0.1 11/17/2020 Review email from attorney Shamoyita DasGupta 0.1 11/17/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 11/18/2020 Review notices to change address (3) and revise email and mail groups 0.1 11/18/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 11/19/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 11/20/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 11/22/2020 Review email from attorney Shamoyita DasGupta 0.1 11/22/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 11/23/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 33 11/23/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 11/24/2020 Review draft by Shamoyita DasGupta of response to IDOC Rule 56.1 statement of facts 0.9 11/24/2020 Review draft of motion to extend time 0.2 11/24/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 11/24/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 1.1 11/25/2020 Review court order 0.1 11/25/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 12/1/2020 Review email from attorney Shamoyita DasGupta 0.1 12/1/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 12/2/2020 Review and revise statement of additional facts to IDOC motion for summary judgment 1.5 12/2/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 1.0 12/2/2020 Review email from attorney Shamoyita DasGupta 0.1 12/3/2020 Review email from attorney Shamoyita DasGupta 0.1 12/4/2020 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 12/6/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 12/6/2020 Review email from attorney Shamoyita DasGupta 0.1 12/7/2020 Review emails from attorney Shamoyita DasGupta (multiple) 0.2 12/7/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 12/8/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 1.8 12/8/2020 Revise and complete plaintiffs' Rule 56.1 statement of facts 3.7 12/8/2020 Draft plaintiff's memorandum of law in support of plaintiffs' summary judgment motion 3.2 12/8/2020 Legal research X 5.7 12/8/2020 Review email from attorney Shamoyita DasGupta 0.1 12/9/2020 Draft plaintiff's memorandum of law in support of plaintiffs' summary judgment motion 1.7 12/9/2020 Review and revise plaintiffs' Rule 56.1 statement of facts 1.1 12/9/2020 Revise and complete response to IDOC Rule 56.1 statement of facts 2.3 12/9/2020 Draft response to IDOC memorandum of law 2.7 12/9/2020 Revise and complete statement of additional facts to IDOC motion for summary judgment 2.6 12/9/2020 Legal research 2.6 12/9/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 1.5 12/9/2020 Select and review exhibits for summary judgment motions 1.3 12/10/2020 Legal research 2.4 12/10/2020 Discuss case and strategy with attorney Shamoyita DasGupta 1.4 12/10/2020 Draft response to IDOC memorandum of law 2.9 12/10/2020 Review and revise response to IDOC Rule 56.1 statement of facts, check citations to record 2.3 12/10/2020 Review and revise plaintiffs' addl facts to IDOC motion, check citations to record 1.4 12/10/2020 Review email from attorney Shamoyita DasGupta 0.1 12/10/2020 Draft response to City memorandum of law 1.0 12/11/2020 Draft response to City memorandum of law 3.3 12/11/2020 Draft statement of additional facts to City motion for summary judgment 2.3 34 12/11/2020 Draft response to City's Rule 56.1 statement of facts 2.7 12/11/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 12/11/2020 Review court order 0.1 12/14/2020 Draft motion to withdraw and replace document 0.3 12/14/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 12/14/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 12/16/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 12/16/2020 Review Shamoyita DasGupta email to defendants' attorneys 0.1 12/17/2020 Review email from IDOC attorney Kelly Bauer 0.1 12/17/2020 Draft email to IDOC attorney, Kelly Bauer 0.1 12/18/2020 Review motion to withdraw 0.1 12/21/2020 Review court order (2) 0.1 12/21/2020 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/5/2021 Review IDOC reply in support of IDOC motion for summary judgment, and response to plaintiff's statement of additional facts 1.0 1/5/2021 Review IDOC response to plaintiffs' motion for summary judgment, response to plaintiffs' statement of facts, and statement of additional facts 1.7 1/5/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 1/5/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 1/6/2021 Review City's motion to extend time 0.2 1/6/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/7/2021 Review and revise motion to dismiss defendants Walls and Suvada 0.5 1/8/2021 Review and revise motion to dismiss defendants Walls and Suvada 0.4 1/8/2021 Review court order 0.1 1/8/2021 Review email from attorney Shamoyita DasGupta 0.1 1/8/2021 Review Shamoyita DasGupta email to court deputy 0.1 1/8/2021 Draft email to attorney Shamoyita DasGupta 0.1 1/8/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/11/2021 Review court orders (2) 0.1 1/11/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 1/12/2021 Draft email to defendants' attorneys 0.1 1/12/2021 Review email from IDOC attorney Kelly Bauer 0.1 1/12/2021 Review email from City attorney Emily Dory 0.1 1/12/2021 Draft email to attorney Shamoyita DasGupta 0.1 1/12/2021 Review email from attorney Shamoyita DasGupta 0.1 1/12/2021 Telephone conference with defendants' attorneys 0.4 1/12/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 1/13/2021 Review and revise court-ordered supplement to motion to dismiss 1.4 1/13/2021 Review City response in opposition to motion to dismiss 0.6 1/13/2021 Review email from attorney Shamoyita DasGupta 0.1 1/13/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 1/14/2021 Review IDOC response to additional facts 1.2 1/14/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.7 35 1/15/2021 Review defendants' response to plaintiffs' motion for summary judgment 1.2 1/15/2021 Review court order 0.1 1/15/2021 Draft reply to IDOC response to plaintiffs' motion for summary judgment 0.7 1/15/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.5 1/16/2021 Draft reply to response to motion for summary judgment 1.8 1/16/2021 Legal research X 1.1 1/17/2021 Draft reply to response to motion for summary judgment 2.1 1/17/2021 Legal research 1.3 1/18/2021 Review email from attorney Shamoyita DasGupta 0.1 1/18/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.4 1/18/2021 Legal research X 3.1 1/18/2021 Draft response to IDOC statement of add'l facts in motion for summary judgment 2.3 1/18/2021 Draft response to IDOC memorandum of law in motion for summary judgment 4.4 1/27/2021 Review emails from defense attorneys (2) 0.2 1/28/2021 Draft email to defendants' attorneys 0.1 1/28/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 1/29/2021 Review and revise motion to extend time 0.2 2/1/2021 Review court order 0.1 2/8/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 2/8/2021 Review email from attorney Shamoyita DasGupta 0.1 2/9/2021 Legal research 0.9 2/9/2021 Draft reply to response to motion to dismiss 0.7 2/9/2021 Review email from attorney Shamoyita DasGupta 0.1 2/9/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 2/10/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.4 2/16/2021 Review court order 0.2 3/8/2021 Review email from attorney Shamoyita DasGupta 0.1 3/9/2021 Review motion for excess pages 0.2 3/9/2021 Review City response to plaintiffs' statement of add'l facts 1.1 3/9/2021 Review City response to plaintiffs' statement of facts 1.2 3/9/2021 Review City's statement of add'l facts 1.2 3/9/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 3/9/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/11/2021 Review City's memorandum of law in reply to City's motion for summary judgment and in response to plaintiffs' motion for summary judgment 2.3 3/11/2021 Review court order 0.1 3/16/2021 Review email from attorney Shamoyita DasGupta 0.1 3/18/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 3/22/2021 Review defendants' response and reply re motions for summary judgment 1.3 3/22/2021 Legal research 1.2 3/22/2021 Draft response to City's statement of add'l facts 2.8 3/23/2021 Draft motion to extend time 0.8 36 3/23/2021 Draft response to City's statement of add'l facts 1.7 3/23/2021 Legal research 2.2 3/23/2021 Draft reply to response to motion for summary judgment 0.8 3/23/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 3/23/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 3/24/2021 Legal research 2.3 3/24/2021 Draft reply to response to motion for summary judgment 1.3 3/24/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 3/25/2021 Select and review exhibits 1.2 3/25/2021 Review court order 0.1 3/25/2021 Draft reply to response to motion for summary judgment 7.1 3/25/2021 Legal research 3.8 3/25/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.5 3/26/2021 Draft correction to plaintiff's response to statement of add'l facts 0.3 3/26/2021 Draft exhibit list 0.3 3/26/2021 Draft motion to accept corrected response 0.3 3/31/2021 Review opinion and order in motions for summary judgment 1.6 4/1/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/2/2021 Draft email to defendants' attorneys 0.2 4/6/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/7/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/8/2021 Review and revise status report 0.3 4/8/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.2 4/8/2021 Telephone conference with IDOC attorney, Kelly Bauer 0.1 4/8/2021 Review email from IDOC attorney, Kelly Bauer 0.1 4/8/2021 Draft email to IDOC attorney, Kelly Bauer 0.1 4/9/2021 Review email from IDOC attorney, Kelly Bauer (2) 0.2 4/9/2021 Review defense revisions to status report 0.1 4/9/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 4/9/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 4/9/2021 Draft email (demand) to IDOC attorney, Kelly Bauer 0.2 4/9/2021 Revise status report 0.3 4/30/2021 Review motion by City for costs, memorandum of law 0.9 5/3/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/4/2021 Review court order 0.1 5/4/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/6/2021 Review court order 0.1 5/6/2021 Review order of referral for settlement 0.1 5/6/2021 Consult with civil rights colleagues regarding legal issues 0.3 5/6/2021 Review standing order regarding settlement negotiations 0.4 5/6/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 5/7/2021 Review Magistrate Judge court order 0.1 5/7/2021 Draft email to attorney Shamoyita DasGupta 0.1 5/7/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 5/7/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 5/7/2021 Review Shamoyita DasGupta email to court deputy 0.1 37 5/13/2021 Review order and decision to prepare for hearing 1.2 5/14/2021 Prepare for hearing with Magistrate Judge, review standing order 0.7 5/14/2021 "Off the record status hearing" with Magistrate Judge 0.7 5/14/2021 Draft email to court deputy 0.1 5/14/2021 Draft email to attorney Shamoyita DasGupta 0.1 5/14/2021 Review Magistrate Judge court order 0.1 5/17/2021 Review email from attorney Shamoyita DasGupta 0.1 5/18/2021 Review email from attorney Shamoyita DasGupta 0.1 5/20/2021 Review court order 0.1 5/20/2021 Review email from attorney Shamoyita DasGupta 0.1 5/21/2021 Review email from attorney Shamoyita DasGupta 0.1 6/15/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/22/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 6/23/2021 Telephone conference with attorney Shamoyita DasGupta 0.2 6/23/2021 Draft email to attorney Shamoyita DasGupta 0.1 6/23/2021 Review email from attorney Shamoyita DasGupta 0.1 6/23/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/23/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 7/6/2021 Telephone conference with clients, Charles Hill and Donna Hill 0.7 7/7/2021 Review and consider offer 0.2 7/7/2021 Telephone conference with clients, Charles Hill and Donna Hill 0.4 7/14/2021 Review email from Magistrate Judge 0.1 7/14/2021 Review email from attorney Shamoyita DasGupta to Magistrate Judge 0.1 7/15/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/16/2021 Review email from attorney Shamoyita DasGupta 0.1 7/16/2021 Draft email to attorney Shamoyita DasGupta 0.1 7/16/2021 Review Shamoyita DasGupta email to court deputy 0.1 7/19/2021 Prepare for telephone conference with Magistrate Judge 0.5 7/19/2021 Telephone conference with Magistrate Judge re settlement 0.5 7/19/2021 Discuss case and strategy with attorney Shamoyita DasGupta 0.3 7/19/2021 Review email from attorney Shamoyita DasGupta 0.1 7/20/2021 Review Magistrate Judge court order 0.1 7/20/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 7/20/2021 Review email from attorney Shamoyita DasGupta 0.1 7/21/2021 Review court order 0.1 7/26/2021 Review email from attorney Shamoyita DasGupta 0.1 7/27/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 7/27/2021 Review email from attorney Shamoyita DasGupta 0.1 7/28/2021 Draft status report re jury trial 0.3 7/28/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 7/28/2021 Review email from attorney Shamoyita DasGupta 0.1 7/28/2021 Draft email to IDOC attorney, Kelly Bauer 0.1 7/29/2021 Draft and revise status report 0.4 7/29/2021 Draft email to IDOC attorney, Kelly Bauer 0.1 38 7/29/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 7/29/2021 Review email from IDOC attorney, Kelly Bauer 0.1 8/4/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 8/4/2021 Review court order 0.1 8/10/2021 Review email from attorney Shamoyita DasGupta 0.1 8/12/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 8/12/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/13/2021 Review email from attorney Shamoyita DasGupta 0.1 8/13/2021 Review and revise status report 0.2 8/13/2021 Telephone conference with attorney Shamoyita DasGupta 0.2 8/16/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 8/19/2021 Review detailed court order and calendar dates 0.2 8/23/2021 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 9/2/2021 Review email from attorney Shamoyita DasGupta 0.1 11/12/2021 Review email from attorney Shamoyita DasGupta 0.1 1/4/2022 Review email from attorney Shamoyita DasGupta 0.1 1/12/2022 Review email from attorney Shamoyita DasGupta 0.1 1/12/2022 Discuss case and strategy with attorney Shamoyita DasGupta 0.1 1/18/2022 Review motion to withdraw and substitute lead attorney 0.1 1/18/2022 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 1/20/2022 Review email from attorney Shamoyita DasGupta (2) 0.2 1/21/2022 Review email from attorney Shamoyita DasGupta 0.1 1/28/2021 Review email from attorney Shamoyita DasGupta 0.1 2/1/2022 Review status report 0.2 2/1/2022 Draft email to attorney Shamoyita DasGupta (2) 0.2 2/1/2022 Review email from attorney Shamoyita DasGupta 0.1 2/1/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 2/2/2022 Review revisions to status report 0.1 2/2/2022 Review attorney appearance, revise email and mail groups 0.1 2/2/2022 Review motion to withdraw and substitute lead attorney, revise email and mail groups 0.1 2/2/2022 Review email from IDOC attorney, Hal Dworkin (2) 0.2 2/2/2022 Draft email to IDOC attorney, Hal Dworkin 0.1 2/4/2022 Review court order 0.1 2/4/2022 Discuss case and strategy with attorney Shamoyita DasGupta X 0.1 2/11/2022 Discuss case and strategy with attorney Shamoyita DasGupta X 0.3 2/22/2022 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 2/24/2022 Discuss case and strategy with attorney Shamoyita DasGupta X 0.2 3/10/2022 Review email from attorney Shamoyita DasGupta (2) 0.2 3/10/2022 Draft email to attorney Shamoyita DasGupta 0.1 3/10/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.3 3/10/2022 Review Shamoyita DasGupta email to Shatrion Hill 0.1 3/15/2022 Review email from attorney Shamoyita DasGupta 0.1 4/7/2021 Review court order 0.1 4/7/2021 Review emails from attorney Shamoyita DasGupta (2) 0.2 4/8/2021 Trial planning meeting with attorney Shamoyita DasGupta 0.4 4/8/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 39 4/8/2021 Review email from attorney Shamoyita DasGupta 0.1 4/14/2022 Draft email to IDOC attorneys (2) 0.2 4/14/2022 Review email from IDOC attorneys 0.1 4/15/2022 Review email from IDOC attorney, Hal Dworkin (2) 0.2 4/15/2022 Draft email to IDOC attorney, Hal Dworkin 0.2 4/18/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.4 4/20/2021 Trial planning meeting with attorney Shamoyita DasGupta 0.3 4/20/2021 Review Shamoyita DasGupta email to defendants' attorneys 0.1 4/22/2021 Review email from attorney Shamoyita DasGupta 0.1 4/22/2022 Draft subpoenas (multiple) 0.8 4/22/2022 Review witness list 0.5 4/25/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 4/25/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 4/25/2022 Draft trial stipulations with citations to record 2.0 4/25/2022 Review requests to admit, motions for summary judgment, statements of facts, deposition transcripts, answers to interrogatories 5.4 4/25/2022 Review witness subpoenas and explanatory letters 0.3 4/25/2022 Review discovery documents pertaining to Suvada as a witness 0.8 4/25/2022 Review emails from attorney Shamoyita DasGupta (3) 0.2 4/26/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 4/26/2022 Review deposition transcripts for Christopher Harrington (2) 2.2 4/26/2022 Draft trial stipulations with citations to record 4.8 4/26/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.5 4/26/2022 Review email from attorney Shamoyita DasGupta 0.1 4/27/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 4/27/2022 Review emails from defendants' attorneys (2) 0.2 4/27/2022 Review statements of facts from motions for summary judgment 0.8 4/27/2022 Review court decision re motions for summary judgment 0.7 4/27/2022 Draft trial stipulations with citations to record 7.6 4/27/2022 Review attorney appearance, revise email and mail groups 0.1 4/27/2022 Review emails from attorney Shamoyita DasGupta (2) 0.2 4/28/2022 Review court's standing orders 0.4 4/28/2022 Telephone conference with attorney Shamoyita DasGupta (2) 0.4 4/28/2022 Telephone conference with IDOC attorney, Hal Dworkin 0.3 4/28/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.8 4/28/2022 Revise and review status report 0.4 4/28/2022 Draft pre-trial order 1.0 4/28/2022 Review email from attorney Shamoyita DasGupta 0.1 4/28/2022 Review and revise plaintiffs' witness list 1.2 4/28/2022 Draft email to defendants' attorneys (2) 0.3 4/29/2022 Draft email to attorney Shamoyita DasGupta 0.1 4/29/2022 Review email from attorney Shamoyita DasGupta 0.1 5/2/2022 Draft email to defendants' attorneys 0.1 5/2/2022 Review defense redlining of trial stipulations 0.6 40 5/11/2022 Draft email to IDOC attorneys re conference 0.1 5/11/2022 Draft email to IDOC attorneys with additional motion in limine topics 0.3 5/11/2022 Prepare for telephone conferene with IDOC attorneys 0.6 5/11/2022 Zoom conference with IDOC attorneys re pre-trial order 1.2 5/11/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.9 5/11/2022 Draft motions in limine 1.4 5/11/2022 Revise pre-trial order 0.2 5/11/2022 Draft email to IDOC attorneys re pre-trial order 0.1 5/11/2022 Draft email to IDOC attorneys re judicial admission consent 0.3 5/11/2022 Review email from IDOC attorneys re defendants' motions in limine 0.3 5/11/2022 Draft email to IDOC attorneys re defendants' motions in limine 0.4 5/11/2022 Review Shamoyita DasGupta email to court deputy 0.1 5/11/2022 Review email from attorney Shamoyita DasGupta 0.1 5/12/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 5/12/2022 Review and revise exhibit list 5.1 5/12/2022 Review exhibits, deposition transcripts 4.1 5/12/2022 Draft verdict sheet 0.9 5/12/2022 Draft email to IDOC attorneys 0.3 5/12/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.4 5/12/2022 Review photographs of disarray for selection and use at trial 0.4 5/12/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 5/13/2022 Draft statement of the case 0.7 5/13/2022 Draft emails to IDOC attorneys (3) 0.3 5/13/2022 Review defendant's statement of the case 0.2 5/13/2022 Review email from attorney Shamoyita DasGupta 0.1 5/13/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 5/13/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 5/13/2022 Review email from IDOC attorney, Hal Dworkin 0.1 5/13/2022 Draft email to IDOC attorney, Hal Dworkin 0.1 5/13/2022 Draft voir dire 1.2 5/13/2022 Draft jury instructions 1.4 5/14/2022 Draft jury instructions 7.2 5/14/2022 Legal research 0.4 5/15/2022 Draft jury instructions 1.0 5/15/2022 Draft email to IDOC attorneys 0.2 5/15/2022 Review photos for demonstrative diagram preparation 0.5 5/15/2022 Demonstrative diagram preparation and creation 2.5 5/15/2022 Review deposition transcipt and track designations for Odell Dollerson's testimony 5.1 5/15/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.2 5/16/2022 Review deposition transcript and track designations for Steve Martinez's testimony 6.2 5/16/2022 Revise trial stipulations 2.8 5/16/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.2 41 5/16/2022 Trial planning meeting with attorney Shamoyita DasGupta (3) 0.8 5/16/2022 Review IDOC offer of settlement 0.1 5/16/2022 Draft email to IDOC attorneys (2) 0.2 5/16/2022 Review list of stipulations objected to 0.3 5/16/2022 Review, revise, and complete demonstrative chart of guns, ammunition seized 0.3 5/16/2022 Review and select photographs of ammunition box in custody of Jacob Walls, and review attorney Dhamoyita DasGupta email to IDOC attorneys 0.6 5/16/2022 Review EEOC Erin Hansen deposition transcipt 1.0 5/16/2022 Draft stipulation of Erin Hansen testimony 1.1 5/17/2022 Draft stipulation of Erin Hansen testimony 0.9 5/17/2022 Draft email to IDOC attorneys (5) 0.5 5/17/2022 Trial planning meeting with attorney Shamoyita DasGupta (4) 1.2 5/17/2022 Revise witness list, selecting witnesses to eliminate 1.0 5/17/2022 Revise exhibit list, selecting exhibits to eliminate 1.3 5/17/2022 Review defendant's voir dire 0.6 5/17/2022 Review defendant's jury instruction objections 0.9 5/17/2022 Legal research 2.5 5/17/2022 Draft response to defendant's objections to plaintiffs' jury instructions and draft objections to defendant's jury instructions 1.9 5/17/2022 Review emails from IDOC attorneys (4) 0.4 5/17/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 5/17/2022 Review attorney appearance, revise email and mail groups 0.1 5/17/2022 Review and select exterior and interior demonstrative photographs for trial, and review attorney Shamoyita DasGupta email to IDOC attorneys 0.8 5/17/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 5/18/2022 Revise pre-trial order 0.2 5/18/2022 Review defendant's pre-trial order additions 0.2 5/18/2022 Revise and complete demonstrative diagram 0.7 5/18/2022 Draft objections to defendant's exhibits 1.8 5/18/2022 Review revised stipulations 0.2 5/18/2022 Trial planning meeting with attorney Shamoyita DasGupta (5) 0.7 5/18/2022 Review additional objectons to plaintiffs' witness list 0.2 5/18/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 5/18/2022 Draft email to attorney Shamoyita DasGupta (3) 0.5 5/18/2022 Review Shamoyita DasGupta emails to IDOC attorneys (multiple) 0.3 5/18/2022 Review and discuss final Martinez and Dollerson deposition designations with attorney Shamoyita DasGupta 0.7 5/18/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 5/18/2022 Draft motions in limine 6.7 5/18/2022 Legal research X 2.3 5/18/2022 Finalizing entire pre-trial order, with attachments 0.6 5/19/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 5/19/2022 Draft email to IDOC attorney (2) 0.3 42 5/19/2022 Review email from IDOC attorneys (2) 0.3 5/19/2022 Draft motion re request to admit admissions 5.9 5/19/2022 Review emails from attorney Shamoyita DasGupta (2) 0.2 5/19/2022 Review Shamoyita DasGupta email to court deputy 0.1 5/20/2022 Draft motion re request to admit admissions 4.7 5/20/2022 Legal research X 2.3 5/20/2022 Draft motion for leave to file additional motions in limine 1.0 5/20/2022 Trial planning meeting with attorney Shamoyita DasGupta (3) 0.8 5/20/2022 Review email from attorney Shamoyita DasGupta 0.1 5/20/2022 Review response to motion for leave to file 0.3 5/21/2022 Review defendant's motions In limine 0.8 5/21/2022 Draft additional motions in limine 1.0 5/22/2022 Legal research X 1.1 5/22/2022 Draft additional motions in limine (#13-#15) 2.5 5/23/2022 Draft additional motions in limine (#13-#15) 10.1 5/23/2022 Legal research 2.4 5/23/2022 Draft motion to supplement motion for leave to file 0.5 5/23/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.3 5/23/2022 Review email from attorney Shamoyita DasGupta 0.1 5/24/2022 Draft response to defendant's motions in limine 7.2 5/24/2022 Legal research X 0.8 5/24/2022 Review email from attorney Shamoyita DasGupta 0.1 5/25/2022 Draft emails to attorney Shamoyita DasGupta (6) 0.6 5/25/2022 Review emails from attorney Shamoyita DasGupta (6) 0.6 5/25/2022 Review Shamoyita DasGupta email to court deputy 0.1 5/25/2022 Review exhibits with errors 0.4 5/26/2022 Review motion for leave to file corrected exhibit 0.2 5/26/2022 Review Shamoyita DasGupta emails to IDOC agent witnesses 0.3 5/26/2022 Review Shamoyita DasGupta email to IDOC attorneys re deposition exhibits (3) 0.3 5/26/2022 Review email from attorney Shamoyita DasGupta 0.1 5/26/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.5 5/27/2022 Review court order 0.1 5/27/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.6 5/27/2022 Review email from attorney Shamoyita DasGupta 0.1 5/31/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 5/31/2022 Draft reply to motions in limine #1 and #2 9.2 5/31/2022 Review email from attorney Shamoyita DasGupta 0.1 5/31/2022 Legal research X 0.9 6/1/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 6/1/2022 Legal research X 1.0 6/1/2022 Draft reply to defendants' motions in limine 9.8 6/1/2022 Review defendants' reply to plaintiffs' motions in limine 1.7 6/1/2022 Review email from attorney Shamoyita DasGupta 0.1 6/2/2022 Review multiple subpoenas to City police witnesses 0.3 6/2/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 43 6/2/2022 Review all motions in limine, responses, and replies 1.2 6/2/2022 Trial planning meeting with attorney Shamoyita DasGupta (3) 0.6 6/2/2022 Review court order 0.1 6/3/2022 Draft demand email to IDOC attorneys 0.3 6/3/2022 Review deposition transcripts for witnesses (multiple) 2.5 6/3/2022 Draft emails to paralegal Sophia Darugar (2) 0.2 6/3/2022 Review email from paralegal Sophia Darugar 0.1 6/3/2022 Review court order 0.1 6/4/2022 Prepare for trial/pre-trial conference by reading multiple depositiion transcripts and abstracts 3.6 6/5/2022 Prepare for trial/pre-trial conference by reading multiple depositiion transcripts and abstracts 5.9 6/6/2022 Trial planning meeting with attorney Shamoyita DasGupta 1.3 6/6/2022 Review email from Tammie Howard 0.1 6/6/2022 Review email from court deputy re COVID restrictions 0.1 6/6/2022 Draft email to Longaria attorney, conspiracy case ahead of Hill case for trial, to determine if will proceed (2) 0.4 6/6/2022 Review email from Longaria attorney 0.2 6/6/2022 Review response to motion in limine #13-#15, and to motion to read admissions made through requests to admit 0.7 6/6/2022 Prepare for trial/pre-trial conference by reading multiple depositiion transcripts and abstracts 8.4 6/6/2022 Draft motion to remove witnesses from witness list 0.6 6/6/2022 Draft email to IDOC attorneys 0.1 6/6/2022 Review email from attorney Shamoyita DasGupta 0.1 6/6/2022 Draft email to paralegal Sophia Darugar (2) 0.2 6/6/2022 Legal research X 2.2 6/7/2022 Zoom conference with IDOC attorneys 0.5 6/7/2022 Trial planning meeting with attorney Shamoyita DasGupta (2) 1.2 6/7/2022 Review response to motion in limine #13-#15, and to motion to read admissions made through requests to admit 0.9 6/7/2022 Draft email to IDOC attorneys 0.1 6/7/2022 Review email from attorney Shamoyita DasGupta 0.1 6/7/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/7/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/7/2022 Prepare for trial/pre-trial conference by reading multiple depositiion transcripts and abstracts, motions, and court decisions 6.1 6/7/2022 Review court order 0.1 6/8/2022 Prepare for pre-trial conference by review of pre-trial order, witness lists, exhibit lists, motions in limine, jury instructions 3.2 6/8/2022 Pre-trial conference, including travel 3.5 6/8/2022 Trial planning meeting with attorney Shamoyita DasGupta 1.3 6/8/2022 Review deposition videos of Harrington 0.9 6/8/2022 Review Decision and Order re plaintiffs' motions in limine 0.5 6/8/2022 Review Decision and Order re defendant's motions in limine 0.4 6/8/2022 Review email from attorney Shamoyita DasGupta 0.1 6/8/2022 Review motion for leave to file additional exhibit 0.3 44 6/8/2022 Review court order re pre-trial conference rulings 0.2 6/9/2022 Draft emails to IDOC attorneys (3) 0.3 6/9/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 6/9/2022 Draft emails to attorney Shamoyita DasGupta (multiple) 0.2 6/9/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 6/9/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.9 6/9/2022 Review email from IDOC attorneys (2) 0.2 6/9/2022 Draft reply to plaintiffs' motion re admissions in requests to admit 1.3 6/9/2022 Legal research X 1.2 6/9/2022 Review court order 0.1 6/10/2022 Telephone conference with client, Charles Hill (2) 1.4 6/10/2022 Telephone conference with attorney Shamoyita DasGupta re video clips (2) 0.4 6/10/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 6/10/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/10/2022 Draft reply to plaintiffs' motion re admissions in requests to admit 0.3 6/10/2022 Draft reply to response to motions in limine #13-14 0.7 6/10/2022 Review motion for extension to file reply to motion in limine #15 0.2 6/10/2022 Telephone conference with witness Shatrion Hill 0.3 6/10/2022 Review notes by atttorney Shamoyita DasGupta re video clips 0.2 6/10/2022 Draft email to paralegal Sophia Darugar 0.2 6/10/2022 Trial planning meeting with attorney Shamoyita DasGupta 1.5 6/10/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/10/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 6/10/2022 Telephone conference with paralegal Sophia Darugar 0.7 6/11/2022 Draft reply to motion in limine #15 2.8 6/11/2022 Legal research 1.7 6/12/2022 Draft email to paralegal Sophia Darugar 0.2 6/12/2022 Draft trial plan (schedule) and final trial to do list 0.5 6/12/2022 Draft emails to attorney Shamoyita DasGupta (2) 0.5 6/12/2022 Review email from attorney Shamoyita DasGupta 0.1 6/12/2022 Draft reply to motion in limine #15 5.6 6/12/2022 Legal research X 3.0 6/12/2022 Review court order (2) including pre-trial conference rulings explanation 0.3 6/12/2022 Draft email to court deputy 0.1 6/12/2022 Review email from court deputy 0.1 6/13/2022 Review plaintiffs' deposition transcripts 2.1 6/13/2022 Trial preparation of clients, Charles Hill and Donna Hill, with visit to courtroom for orientation 4.1 6/13/2022 Draft supplement to motion in limine #2 per court order 4.6 6/13/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.8 6/13/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.1 6/13/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/13/2022 Draft email to attorney Shamoyita DasGupta (multiple) 0.3 45 6/13/2022 Legal research 2.1 6/13/2022 Review Kietrion Lewis deposition transcript 0.8 6/14/2022 Trial planning meeting with attorney Shamoyita DasGupta (2) 1.3 6/14/2022 Prepare for Keitrion Lewis meeting 1.7 6/14/2022 Draft emails to IDOC attorneys (5) 0.7 6/14/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/14/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.1 6/14/2022 Review Shamoyita DasGupta email to attorney Michele McGee re appearance of CPD witnesses at trial 0.1 6/14/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/14/2022 Trial preparation of Keitrion Lewis, with visit to courtroom for orientation 2.5 6/14/2022 Draft motion to add Donna Rixey photograph to exhibit list 0.8 6/14/2022 Review emails from IDOC attorneys (3) 0.3 6/14/2022 Draft proposed sur-sur reply to motion in limine #15 2.5 6/14/2022 Draft motion for leave to file sur-sur-reply to motion in limine #15 0.5 6/14/2022 Draft motion for leave to submit Gertha Brady designations because of COVID illness 0.8 6/14/2022 Review and revise motion to reconsider ruling re Cornesha Rice and for leave to add her to plaintiffs' witness list 1.0 6/15/2022 Conference with witness Shatrion Hill 0.4 6/15/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.8 6/15/2022 Review email from witness James Noble 0.1 6/15/2022 Draft email to IDOC attorneys 0.2 6/15/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.2 6/15/2022 Review email from attorney Hal Dworkin 0.1 6/15/2022 Telephone conference with staff at video company re clips (2) 0.4 6/15/2022 Telephone conference with Ian Davidson, video technician 0.2 6/15/2022 Draft email to Ian Davidson, video technician 0.2 6/15/2022 Draft motion to add video clips to exhibit list and to play video clips in lieu of reading admissions 1.3 6/15/2022 Review defense motion to supplement exhibit list 0.2 6/15/2022 Prepare questions for Charles Hill at trial 0.7 6/16/2022 Draft motion re criminal charge stipulations 0.9 6/16/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.9 6/16/2022 Review response to motion re curtilage 0.6 6/16/2022 Draft motion to amend motion re video clips 1.0 6/16/2022 Telephone conference with Ian Davidson, video technician 0.2 6/16/2022 Draft email to Ian Davidson, video technician 0.1 6/16/2022 Review email from Ian Davidson, video technician 0.1 6/16/2022 Review Shamoyita DasGupta email to IDOC witnesses 0.1 6/16/2022 Review email from attorney Shamoyita DasGupta 0.1 6/16/2022 Review prepared video clips for accuracy 0.6 6/16/2022 Draft motion to allow stipulations #37, #38 0.8 6/17/2022 Draft reply to response to motion in limine re curtilage 2.7 6/17/2022 Review court order re parties' proposed voir dire 0.3 6/17/2022 Review Gertha Brady deposition for designations 1.1 46 6/17/2022 Zoom trial planning meeting with attorney Shamoyita DasGupta 1.0 6/17/2022 Zoom meeting with paralegal Sophia Darugar and attorney Shamoyita DasGupta re witness contact and coordination, trial logistics 0.7 6/17/2022 Draft email to IDOC attoneys 0.1 6/17/2022 Prepare trial questions for Shatrion Hill 1.2 6/17/2022 Prepare trial questions for client, Charles Hill 1.3 6/18/2022 Prepare trial questions for client, Charles Hill 2.0 6/18/2022 Trial preparation of clients, Charles Hill and Donna Hill, in person 3.8 6/18/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.4 6/18/2022 Review Gertha Brady deposition for designations 2.5 6/19/2022 Review Gertha Brady deposition for designations 1.8 6/19/2022 Draft emails to IDOC attorneys (2) 0.2 6/19/2022 Review email from IDOC attorneys 0.1 6/19/2022 Draft email to court deputy 0.1 6/19/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.7 6/19/2022 Prepare trial questions for client, Charles Hill 1.4 6/19/2022 Prepare opening statement 1.1 6/20/2022 Draft emails to IDOC attorneys 0.2 6/20/2022 Telephone conference with witness Keitrion Lewis 0.4 6/20/2022 Trial planning meeting with attorney Shamoyita DasGupta 1.2 6/20/2022 Review court orders (2) 0.2 6/20/2022 Review email from attorney Shamoyita DasGupta 0.1 6/20/2022 Review Shamoyita DasGupta email to paralegal Sophia Darugar 0.1 6/20/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/20/2022 Review defendants' objections and counterdesignations to Gertha Brady's deposition 1.8 6/20/2022 Review Keitrion Lewis's deposition transcript 2.2 6/20/2022 Prepare trial questions for witness Keitrion Lewis 3.1 6/20/2022 Review court orders (4) re Brady designations, exhibits, stipulations,mandatory release of firearms, time limits to testimony 0.7 6/20/2022 Review email from IDOC attorneys 0.2 6/20/2022 Review notes by atttorney Shamoyita DasGupta of Steven Suvada testimony 0.4 6/20/2022 Prepare trial questions for Christopher Harrington 1.6 6/20/2022 Review Scott Liebhaber abstract and notes by attorney Shamoyita DasGupta 0.7 6/20/2022 Draft opening statement 0.8 6/21/2022 Take mandatory COVID test, including travel 1.4 6/21/2022 Conference with paralegal Sophia Darugar to plan trial logistics 0.9 6/21/2022 Trial preparation of clients, Charles Hill and Donna Hill 2.3 6/21/2022 Trial planning meeting with attorney Shamoyita DasGupta 0.9 6/21/2022 Prepare trial questions for witness Keitrion Lewis 1.0 6/21/2022 Telephone conference with witness Keitrion Lewis (3) 1.3 6/21/2022 Prepare trial questions for client, Charles Hill 1.8 6/21/2022 Draft opening statement 0.8 6/21/2022 Review Shamoyita DasGupta email to court deputy 0.1 47 6/21/2022 Review Shamoyita DasGupta email to paralegal Sophia Darugar 0.1 6/21/2022 Review email from attorney Shamoyita DasGupta 0.1 6/21/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/21/2022 Prepare trial questions for Christopher Harrington 1.7 6/21/2022 Review email from City attorney Michele McGee re subpoenaed City witnesses 0.2 6/21/2022 Draft email to City attorney Michele McGee 0.2 6/21/2022 Draft email to IDOC attorneys re offer 0.2 6/21/2022 Revise trial plan (schedule) and witness order 0.7 6/21/2022 Draft email to defendant's attorneys with list of trial witnesses for first trial day 0.1 6/22/2022 Draft email to defendant's attorneys with list of trial witnesses for 6/24/2022 0.2 6/22/2022 Draft email to IDOC attorneys 0.1 6/22/2022 Review emails from IDOC attorneys (3) 0.3 6/22/2022 Review emails to court deputy (3) 0.3 6/22/2022 Review emails from court deputy (3) 0.3 6/22/2022 Review Shamoyita DasGupta emails to paralegal Sophia Darugar (2) 0.1 6/22/2022 Review email from attorney Shamoyita DasGupta 0.1 6/22/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 6/22/2022 Prepare trial questions for Christopher Harrington 1.3 6/22/2022 Telephone conference with attorney James Bowers re arrangement for reading two witness depositions 0.5 6/22/2022 Draft motion to add photograph as exhibit and stipulation 0.4 6/22/2022 Draft motion to clarify ruling on "emply chair" defense 0.9 6/22/2022 Review detailed court orders (11) re City obstacles to return of firearms, explaining jury instruction decisions, preliminary jury instructions, adding exhibit to list, adding stipulation, use of request to admit admissions, denial of Cornesha Rice reconsideration motion, allowed use of video clips, decision on Odell Dollarsion designations, deicsion on Gertha Brady deisgnations, decision on Steven Martinez designations, motion to clarify ruling on "emply chair" defense 2.1 6/22/2022 Review final revised court jury instructions 0.5 6/22/2022 Telephone conference with paralegal Sophia Darugar 0.5 6/22/2022 Telephone conference with witness Corneshia Rice 0.5 6/22/2022 Trial planning meeting with attorney Shamoyita DasGupta (multiple) 1.0 6/22/2022 Review trial questions by attorney Shamoyita DasGupta for witness Shatrion Hill 0.8 6/22/2022 Prepare trial questions for Charles Hill 2.2 6/22/2022 Prepare trial questions for Donna Hill 1.0 6/22/2022 Review motion in limine rulings and review motion in limine chart 1.9 6/22/2022 Review Bateson v. Kentucky law, procedure for challenge 0.7 6/23/2022 Final review of opening statement, questions for Charles Hill 2.1 6/23/2022 Day One of trial, including travel, set-up 8.0 6/23/2022 Conference with clients, Charles Hill and Donna Hill (multiple) 0.7 6/23/2022 Trial strategy meetings with attorney Shamoyita DasGupta (multiple) 0.6 6/23/2022 Conference with paralegal Sophia Darugar (multiple) 0.7 48 6/23/2022 Review trial questions by attorney Shamoyita DasGupta for witness Tammie Howard 0.5 6/23/2022 Review trial questions by attorney Shamoyita DasGupta for witness Tamika Johnson 0.5 6/23/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/23/2022 Review Shamoyita DasGupta email to defendant's attorneys 0.1 6/23/2022 Review email from court deputy 0.1 6/23/2022 Prepare trial questons for witness Scott Liebhaber 1.3 6/23/2022 Draft email to defendant's attorneys 0.1 6/23/2022 Review court order 0.1 6/24/2022 Conference with clients, Charles Hill and Donna Hill (multiple) 0.9 6/24/2022 Day Two of trial, including travel, set up 7.6 6/24/2022 Draft email to court deputy (2) 0.2 6/24/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/24/2022 Review email from defendant's attorney Daniel Berkowitz 0.1 6/24/2022 Revise and strategize trial plan and witness order 1.1 6/24/2022 Telephone conferences with witnesses (multiple) 1.2 6/24/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.3 6/24/2022 Conference with paralegal Sophia Darugar (multiple) 0.4 6/24/2022 Review court orders (2) 0.2 6/25/2022 Telephone conferences with witness Corneshia Rice 0.9 6/25/2022 Trial strategy meetings with attorney Shamoyita DasGupta (multiple) 1.2 6/25/2022 Draft emails to attorney Shamoyita DasGupta and paralegal Sophia Darugar (2) 0.4 6/25/2022 Trial preparation - prepare trial questions, review jury instructions, review court's rulings in motions in limine, etc. 6.9 6/25/2022 Draft email to court deputy 0.1 6/25/2022 Review email from court deputy 0.1 6/25/2022 Draft motion to bar Harrington from testifying about his family values 1.0 6/26/2022 Conference with clients, Charles Hill and Donna Hill, in person 2.6 6/26/2022 Draft email to defendant's attorneys with list of trial witnesses for next trial day 0.2 6/26/2022 Trial preparation - prepare trial questions, review jury instructions, review court's prior rulings, prepare summation 4.7 6/26/2022 Draft and revise questions for Christopher Harrington 2.2 6/26/2022 Review trial questions by attorney Shamoyita DasGupta for witness Felisha Parker 0.4 6/26/2022 Review trial questions by attorney Shamoyita DasGupta for witness Jacob Walls 0.5 6/26/2022 Review trial questions by attorney Shamoyita DasGupta for witness Rodney Alexander 0.4 6/26/2022 Review video clips 0.8 6/26/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/26/2022 Review emails from attorney Shamoyita DasGupta (multiple) 0.4 6/26/2022 Draft email to attorney Shamoyita DasGupta 0.1 6/26/2022 Draft email to video technician 0.2 6/27/2022 Telephone conference with paralegal Sophia Darugar (2) 0.5 6/27/2022 Review email from City attorney Michele McGee re witness availability 0.1 6/27/2022 Review email from defendant's attorney Hal Dworkin 0.1 6/27/2022 Review Shamoyita DasGupta emails to court law clerk (multiple) 0.1 49 6/27/2022 Review and revise response to motion to bar Harrington from testifying about his family values 0.3 6/27/2022 Review and revise motion to bar IDOC witnesses from making derogatory statements about the Hill home 0.3 6/27/2022 Review supplement to motion to bar Harrington 0.2 6/27/2022 Trial strategy meeting with attorney Shamoyita DasGupta 1.8 6/27/2022 Trial preparation - prepare trial questions, review jury instructions, review court's prior rulings, prepare summation 7.8 6/27/2022 Discuss case and strategy with paralegal Sophia Darugar 0.5 6/27/2022 Draft email to witness Cornesha Rice 0.1 6/27/2022 Review email from attorney Shamoyita DasGupta 0.1 6/27/2022 Review Cornesha Rice deposition to select designations 2.3 6/27/2022 Telephone conference with witness Corneshia Rice 0.6 6/27/2022 Review court orders (2) with rulings on plaintiffs' two motions 0.5 6/27/2022 Draft email to defendant's attorneys with list of trial witnesses for next trial day 0.2 6/28/2022 Draft email to defendant's attorneys with list of trial witnesses for next trial day 0.1 6/28/2022 Conference with clients, Charles Hill and Donna Hill 1.1 6/28/2022 Day Three of trial, including travel 7.9 6/28/2022 Discuss case and strategy with paralegal Sophia Darugar 0.6 6/28/2022 Trial preparation - prepare trial questions, review jury instructions, review court's prior rulings, prepare summation 6.4 6/28/2022 Trial strategy meeting with attorney Shamoyita DasGupta 0.2 6/28/2022 Revise trial plan and witness order 0.5 6/28/2022 Telephone conference with attorney James Bowers 0.3 6/28/2022 Draft motion allowing additional time 0.5 6/28/2022 Review court order(4) re Cornesha Rice designations, trial, revised verdict form, and time consumption 0.7 6/28/2022 Review email from court re WebEx link for Donna Hill testimony 0.1 6/28/2022 Review emails from court deputy (2) 0.2 6/29/2022 Day Four of trial, including travel and set up 8.5 6/29/2022 Trial preparation - prepare trial questions, prepare summation 6.0 6/29/2022 Discuss case and strategy with paralegal Sophia Darugar 0.6 6/29/2022 Trial strategy meeting with attorney Shamoyita DasGupta 0.6 6/29/2022 Review email from attorney Shamoyita DasGupta 0.1 6/30/2022 Prepare summation 1.7 6/30/2022 Trial strategy meeting with attorney Shamoyita DasGupta 0.2 6/30/2022 Discuss case and strategy with paralegal Sophia Darugar 0.4 6/30/2022 Review final jury instructions (Set 3) 0.4 6/30/2022 Day Five of trial, including travel and set up 6.2 6/30/2022 Remain in courtroom area until released for day 2.2 6/30/2022 Review Shamoyita DasGupta email to court deputy 0.1 6/30/2022 Review email from court deputy 0.1 7/1/2022 Review Shamoyita DasGupta email to court deputy 0.1 7/1/2022 Day Six of trial, including travel, on call, receive verdict 4.4 7/1/2022 Telephone conference with clients, Charles Hill and Donna Hill 0.8 7/1/2022 Review order re post trial motions 0.2 7/1/2022 Review Shamoyita DasGupta emails to court deputy and law clerk 0.1 7/1/2022 Review email from court deputy with exhibit and stipulation list 0.2 7/1/2022 Review judgment, verdict documents, and legal research into judgment and payment issues 0.3 50 7/5/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.3 7/5/2022 Review email from attorney Shamoyita DasGupta 0.1 7/6/2022 Conference with attorney Shamoyita DasGupta re post trial plan 0.2 7/7/2022 Draft email to court deputy 0.2 7/7/2022 Review email from court deputy 0.1 7/7/2022 Telephone conference with Sophia Darugar re her hours, declaration, and fee peition 0.3 7/11/2022 Review email, fee documents, and biographical statement from Sophia Darugar 0.5 7/11/2022 Draft emails to Sophia Darugar (2) 0.2 7/12/2022 Review email from attorney Shamoyita DasGupta 0.1 7/14/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/15/2022 Draft email to attorney Shamoyita DasGupta 0.2 7/15/2022 Review judgment, verdict documents, and legal research into judgment and payment issues 0.2 7/18/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/19/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.1 7/20/2022 Review email from attorney Shamoyita DasGupta 0.1 7/21/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/25/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/25/2022 Review email from attorney Shamoyita DasGupta 0.1 7/26/2022 Review email from attorney Shamoyita DasGupta 0.1 7/26/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/27/2022 Review Shamoyita DasGupta email to IDOC attorneys 0.1 7/27/2022 Review email from attorney Shamoyita DasGupta 0.1 7/27/2022 Review and revise motion to extend time for bill of costs 0.3 7/27/2022 Discuss post-trial matters with attorney Shamoyita DasGupta, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 8/2/2022 Review court order 0.1 8/2/2022 Telephone conference with attorney Shamoyita DasGupta 0.1 8/3/2022 Telephone conference with attorney Shamoyita DasGupta 0.2 8/3/2022 Review and revise bill of costs 0.7 8/3/2022 Obtain additional documentation for bill of costs 0.8 8/4/2022 Obtain additional documentation for bill of costs 0.4 8/4/2022 Telephone conference with attorney Shamoyita DasGupta 0.3 8/5/2022 Review and edit timesheets for fee petition for accuracy and completeness, and for redactions for work product and attorneyclient privilege 1.2 8/9/2022 Telephone conference with attorney Shamoyita DasGupta 0.2 51 8/12/2022 Review and edit timesheets for fee petition for accuracy and completeness, and for redactions for work product and attorneyclient privilege 2.2 8/16/2022 Draft email to IDOC attorneys 0.1 8/19/2022 Draft email to IDOC attorneys 0.1 8/23/2022 Review email from IDOC attorneys 0.1 8/23/2022 Draft email to IDOC attorneys 0.1 8/24/2022 Review court order 0.1 8/25/2022 Telephone conference with attorney Shamoyita DasGupta X 0.3 8/25/2022 Review email from attorney Shamoyita DasGupta 0.1 8/27/2022 Legal research, attorneys' fees 0.8 8/29/2022 Telephone conference with attorney Shamoyita DasGupta 0.3 8/29/2022 Review and edit timesheets for fee petition for accuracy and completeness, and determine reductions for case against City 2.1 8/30/2022 Telephone conference with attorney Shamoyita DasGupta X 0.2 8/31/2022 Review email from attorney Shamoyita DasGupta 0.1 8/31/2022 Draft email to IDOC attorneys 0.1 9/1/2022 Draft email to IDOC attorneys 0.1 9/1/2022 Draft email to colleague attorney for fee petition declaration 0.2 9/1/2022 Review and revise draft joint statement 0.2 9/1/2022 Draft emails to attorney Shamoyita DasGupta (2) 0.2 9/1/2022 Review emails from attorney Shamoyita DasGupta (2) 0.2 9/1/2022 Telephone conference with attorney Shamoyita DasGupta X 0.2 9/6/2022 Review W-9s from clients, prepare W-9 for firm 0.2 9/6/2022 Conference with clients, Charles Hill and Donna Hill 0.9 9/6/2022 Draft fee petition 1.7 9/7/2022 Review defendant's objections to bill of costs 0.5 9/8/2022 Telephone conference with attorney Shamoyita DasGupta 0.2 9/8/2022 Review and edit timesheets for fee petition for accuracy and completeness, and determine reductions for case against City 2.0 9/9/2022 Telephone conference with attorney Shamoyita DasGupta 0.3 9/9/2022 Draft email to attorney Shamoyita DasGupta 0.1 9/9/2022 Draft email to defendants' attorneys 0.3 9/9/2022 Review email from defendants' attorney (2) 0.1 9/11/2022 Draft email to defendants' attorneys 0.1 9/13/2022 Review email from attorney Shamoyita DasGupta 0.1 9/13/2022 Telephone conference with attorney Shamoyita DasGupta 0.1 9/16/2022 Telephone conference with attorney Shamoyita DasGupta 0.1 9/17/2022 Review and edit timesheets for fee petition for accuracy and completeness, and determine reductions for case against City 1.8 9/19/2022 Draft emails to defendants' attorney, Susan Newman (2) 0.2 9/19/2022 Review and revise motion to extend time for reply to bill of costs 0.1 9/19/2022 Review emails from defendants' attorney, Maggie Jones (2) 0.2 9/19/2022 Review Shamoyita DasGupta email to court deputy 0.1 9/19/2022 Review Shamoyita DasGupta email to defendants' attorneys 0.1 9/19/2022 Telephone conference with attorney Shamoyita DasGupta 0.3 9/19/2022 Review and edit timesheets for fee petition for accuracy and completeness, and determine reductions for case against City 1.6 9/19/2022 Review email from attorney Shamoyita DasGupta 0.1 9/20/2022 Review court order 0.1 52 9/20/2022 Telephone conference with attorney Shamoyita DasGupta X 0.1 9/21/2022 Telephone conference with attorney Shamoyita DasGupta X 0.4 9/21/2022 Review email from attorney Shamoyita DasGupta 0.1 9/22/2022 Telephone conference with attorney Shamoyita DasGupta X 0.1 9/22/2022 Draft motion for fee petition briefing schedule 0.4 9/22/2022 Draft email to defendants' attorneys 0.1 9/22/2022 Review and edit Shamoyita DasGupta, Daniel Regensheit, and Sophia Darugar timesheets for fee petition for accuracy and completeness, and determine reductions for case against City 2.1 9/22/2022 Review email from defendants' attorney Hal Dworkin 0.1 9/22/2022 Telephone conference with defendants' attorney Hal Dworkin 0.2 9/22/2022 Conference with attorney Shamoyita DasGupta 0.1 9/22/2022 Legal research, attorneys' fees 0.7 9/23/2022 Review email from attorney Shamoyita DasGupta 0.1 9/23/2022 Review email from defendants' attorney, Hal Dworkin (2) 0.3 9/23/2022 Telephone conference with attorney Shamoyita DasGupta re scheduling 0.4 9/23/2022 Draft emails to defendants' attorney Hal Dworkin (2) 0.1 9/23/2022 Conference call with defendant's attorneys Hal Dworkin, Maggie Jones, and attorney Shamoyita DasGupta 0.4 TOTAL HOURS 992.4 TOTAL CITY HOURS 66.2 ADJUSTED TOTAL HOURS 926.2 TOTAL FEES AT $525/HOUR $ 486,255.00 53 Date Service provided Time expended (in hours) City time (in hours) 2/6/2017 Initial telephone interview with clients, Charles Hill and Donna Hill 0.7 2/15/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.3 3/15/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.2 4/13/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.1 5/17/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.2 6/6/2017 Telephone conference with Charles Hill 0.1 8/9/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.3 10/16/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Daniel H. Regenscheit X 0.3 8/2/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 8/6/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 8/13/2018 Draft initial draft of complaint 2.5 8/21/2018 Review final version of complaint and insert judges' names, review court orders, calendar target dates 0.3 8/22/2018 Draft attorney appearance 0.2 8/22/2018 Draft summonses and email to Northern District of Illinois intake for issuance 0.5 8/23/2018 Review stamped summonses 0.2 8/24/2018 Prepare summonses and complaints for service on defendants 0.4 8/24/2018 Serve summonses and complaints on defendant City of Chicago 0.5 8/25/2018 Review standing order on Mandatory Initial Discovery Pilot Program ("MIDP") 0.2 8/25/2018 Serve summonses and complaints on individual Chicago police officer defendants 1.0 8/25/2018 Prepare affidavits of service to file for defendant City of Chicago and individual Chicago police officer defendants 0.4 8/25/2018 File, review, and download summonses for defendant City of Chicago and individual Chicago police officer defendants 0.5 8/28/2018 Prepare MIDP disclosures for delivery to City 0.6 8/29/2018 File, review, and download executed summons for defendant City of Chicago 0.1 9/5/2018 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 54 9/7/2018 Serve summonses and complaint on Illinois Department of Corrections ("IDOC") defendants 1.1 9/7/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 9/7/2018 Prepare, file, review, and download summonses and complaints for IDOC defendants 0.6 9/7/2018 Telephone conference with attorney for defendant City of Chicago, Jonathan Green 0.1 9/10/2018 Review and download attorney appearance by Jonathan Green, City of Chicago's Agreed Motion for Extension of Time to Answer or Otherwise Plead 0.1 9/12/2018 Draft and send email to Judge Chang's courtroom deputy 0.1 9/12/2018 Review Judge Chang order, update calendar 0.1 9/28/2018 Review attorney appearance by Andrea Campbell 0.1 10/10/2018 Review attorney appearances by Melissa Gold 0.1 10/25/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/25/2018 Draft initial status report 2.0 10/31/2018 Review and download attorney appearance by Jessica Griff 0.1 11/1/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 11/1/2018 Draft motion for default order X 0.8 11/1/2018 Edit initial status report and email to defendants' attorneys 0.7 11/1/2018 Draft and send email to attorneys for defendant City of Chicago and individual Chicago police officer defendants regarding status report 0.1 11/2/2018 Review attorney appearance by Kelly Bauer, Defendants Harrington and Walls' Agreed Motion for an Extension of Time to Answer, update calendar 0.2 11/2/2018 Review edited status report with edits from attorneys for defendant City of Chicago and individual Chicago police officer defendants 0.1 11/2/2018 Edit initial status report 0.2 11/2/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/2/2018 Draft and send email to attorney for IDOC defendants 0.2 11/5/2018 Review and download attorney appearance by Michael Stephenson 0.1 11/5/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 11/5/2018 Draft and send emails to defendants' attorneys regarding status report 0.2 11/5/2018 Edit initial status report 1.5 11/5/2018 Telephone conference with Judge Chang's courtroom deputy 0.1 11/5/2018 Leave voicemail messages with defendants' attorneys 0.1 11/5/2018 Final review of status report 0.2 11/6/2018 Review Judge Chang order, update calendar 0.1 11/6/2018 Draft and send email to Judge Chang's courtroom deputy 0.1 11/6/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/7/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/8/2018 Review complaint and file to prepare for court appearance 0.1 11/8/2018 Court appearance, including travel 0.9 11/8/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 11/8/2018 Review Judge Chang order, update calendar 0.1 11/12/2018 Telephone conference with client, Charles Hill 0.2 11/12/2018 Draft MIDP disclosures 0.7 11/13/2018 Telephone conference with client, Charles Hill 0.1 11/14/2018 Draft MIDP disclosures 0.5 55 11/15/2018 Telephone conference with client, Charles Hill 0.1 11/15/2018 Edit MIDP disclosures 0.4 11/15/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 11/16/2018 Prepare certifications for MIDP disclosures 0.2 11/16/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.2 11/16/2018 Office meeting with clients 0.6 11/16/2018 Review notes from meeting and signed certifications for MIDP disclosures 0.1 11/19/2018 Edit MIDP disclosures 0.3 11/20/2018 Edit MIDP disclosures 1.5 11/21/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 11/21/2018 Finalize MIDP disclosures 0.5 11/21/2018 Draft and send email to clients 0.1 11/21/2018 Telephone conference with clients 0.1 11/26/2018 Telephone conference with client, Charles Hill 0.1 11/26/2018 Review MIDP disclosures 0.3 11/27/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.2 11/27/2018 Draft MIDP notice of service 0.2 11/27/2018 Compile discovery documents for MIDP disclosure 0.7 11/28/2018 Compile and review discovery documents for MIDP disclosures 1.1 11/28/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 11/28/2018 Finalize and email MIDP disclosure, file notice of service of MIDP disclosures 0.5 11/28/2018 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 11/28/2018 Review defendant City of Chicago's proposed confidentiality order 0.2 11/28/2018 Review and download MIDP disclosures from defendant City of Chicago and individual Chicago police officer defendants 0.2 11/29/2018 Review defendants' proposed confidentiality order 0.6 11/29/2018 Discuss case and strategy with attorney Irene K. Dymkar 0.1 11/29/2018 Draft and send email to defendants' attorneys regarding confidentiality order 0.1 11/29/2018 Review Defendant City of Chicago and Defendant Officers' Joint Notice of Service of Responses to Mandatory Initial Discovery and Certificate of Service, Defendant Parole Agents Harrington and Walls' Agreed Motion for an Extension of Time to Answer, update calendar 0.1 11/30/2018 Review and download Defendant City of Chicago's Unopposed Motion for Entry of Confidentiality Order, update calendar 0.1 12/6/2018 Draft and send email to Judge Chang's courtroom deputy 0.1 12/7/2018 Review and download Judge Chang orders, update calendar 0.2 12/17/2018 Review and download Defendant Parole Agents Harrington and Walls' Partial Motion to Dismiss Plaintiffs' Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6), update calendar 0.3 12/18/2018 Review Defendant Parole Agent Harrington's Answer to Plaintiffs' Complaint, Defendant Parole Agent Walls' Answer to Plaintiffs' Complaint, Judge Lee order, update calendar 0.4 12/31/2018 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/4/2019 Draft interrogatories 0.6 56 1/4/2019 Review and download letter from attorney Mark Haines 0.1 1/7/2019 Draft and send email to defendants' attorney 0.1 1/7/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/8/2019 Review and download Defendant's Notice of Service of Defendants' Responses to Mandatory Initial Discovery and Certification of Service by IDOC defendants 0.1 1/10/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/15/2019 Draft and send email to defendants' attorneys 0.1 1/16/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/17/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/17/2019 Review and download letter from attorney Mark Haines 0.1 1/17/2019 Draft written discovery requests (vague as to which defend; i nt) 2.5 1/18/2019 Draft written discovery requests (vague as to which defend; i nt) 1.2 1/18/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 1/18/2019 Review discovery documents 0.1 1/18/2019 Review and download Plaintiffs' Response to Defendant Parole Agent Harrington and Walls' Partial Motion to Dismiss Plaintiffs' Complaint Pursuant to Rule 12(b)(6) 0.2 1/21/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 1/21/2019 Review and download discovery from defendants 0.1 1/21/2019 Prepare for court appearance 0.2 1/21/2019 Draft and send email to Judge Chang's courtroom deputy 0.1 1/22/2019 Court appearance, including travel 0.7 1/22/2019 Discussion with IDOC attorney Kelly Bauer after court appearance 0.1 1/23/2019 Review Judge Chang order, update calendar 0.1 1/23/2019 Discuss case and strategy with attorney Irene K. Dymkar x 0.1 1/23/2019 Draft and send email to defendants' attorneys 0.2 1/24/2019 Review deposition notice for client, Charles Hill 0.1 1/24/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/28/2019 Draft and send emails to defendants' attorneys 0.3 1/28/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 1/28/2019 Review discovery documents to determine deficiencies 0.7 1/28/2019 Draft Plaintiffs' Unopposed Motion to Extend Discovery Deadlines 1.2 1/28/2019 Review and download Plaintiffs' Unopposed Motion to Extend Discovery Deadlines, update calendar 0.1 2/1/2019 Draft and send email to defendants' attorneys 0.2 2/4/2019 Review and download Defendant Parole Agents Harrington and Walls' Reply in Support of their Partial Motion to Dismiss Plaintiffs' Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6) 0.1 2/5/2019 Review Judge Chang order, letter from Mark Haines, defendants' written discovery requests, update calendar 0.3 2/5/2019 Review defendants Liebhaber and McKenna's written discovery requests to plaintiffs 0.7 2/18/2019 Draft and send email to defendants' attorneys regarding depositions 0.1 3/25/2019 Review and download interrogatories from defendant John Gartner 0.1 3/25/2019 Telephone conference with client, Charles Hill 0.8 3/25/2019 Review defendants' written discovery requests 0.2 3/26/2019 Draft answers to plaintiffs' interrogatories 3.4 (vagi e as to wh 3/26/2019 Telephone conference with client, Donna Hill 0.6 3/26/2019 Draft responses to defendants' requests to produce 2.0 (vagu e as to wh 57 3/27/2019 Telephone conference with client, Charles Hill 0.1 3/27/2019 Draft responses to defendants' requests to produce 0.2 3/27/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 3/28/2019 Telephone conference with client, Charles Hill 0.3 3/28/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 3/29/2019 Review FOID and PERC cards for client, Charles Hill 0.1 3/29/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 3/29/2019 Review plaintiffs' discovery documents for disclosure 0.1 3/29/2019 Draft and send email to defendants' attorneys 0.1 4/3/2019 Court appearance, including travel 0.9 4/5/2019 Review Judge Chang order, update calendar 0.1 4/5/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 4/15/2019 Review defendants' multiple responses to plaintiffs' written discovery requests 1.4 4/15/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/6/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 5/6/2019 Review and scan deposition notice for clients, update calendar 0.1 5/7/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 5/9/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 5/10/2019 Review attorney Irene K. Dymkar email to attorney Kelly Bauer 0.1 5/14/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 5/14/2019 Draft and send email to defendants' attorneys 0.2 5/15/2019 Review deposition notice for clients, update calendar 0.1 5/17/2019 Review and download Notice of Withdrawal and Substitution of Counsel Within the Same Firm Pursuant to Local Rule 83.17 0.1 5/17/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/17/2019 Telephone conference with client, Charles Hill 0.1 5/17/2019 Telephone conference with client, Donna Hill 0.1 5/17/2019 Draft and send email to defendants' attorneys 0.1 5/20/2019 Telephone conference with client, Donna Hill 0.2 5/20/2019 Telephone conference with client, Charles Hill 0.1 5/21/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/21/2019 Telephone conference with clients 0.2 5/21/2019 Draft and send email to defendants' attorneys 0.1 5/21/2019 Draft subpoenas to non-party witnesses 0.7 5/21/2019 Telephone conference with client, Charles Hill 0.2 5/22/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/22/2019 Review and analyze discovery documents 2.0 5/22/2019 Prepare for telephone conference with witness, Odell Dollerson 0.3 5/22/2019 Telephone conference with witness, Odell Dollerson 0.3 5/22/2019 Organize notes from telephone conference with witness, Odell Dollerson 0.2 5/23/2019 Telephone conference with client, Donna Hill 0.1 5/23/2019 Review discovery documents 1.0 5/23/2019 Draft and send email to defendants' attorneys 0.1 5/23/2019 Prepare subpoenas to serve on non-party witnesses 1.2 5/23/2019 Draft letters to send to non-party IDOC witnesses 0.3 5/23/2019 Attempt to contact Cornesha Rice and Tierra White 0.1 5/23/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/24/2019 Serve deposition subpoenas on non-party IDOC witnesses 0.6 5/24/2019 Telephone conference with client, Donna Hill 0.2 58 5/24/2019 Telephone conference with witness, Gertha Brady 0.4 5/24/2019 Complete affidavits for subpoenas to non-party IDOC witnesses 0.8 5/24/2019 Draft client and witness contact list with updated information 0.1 5/24/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.3 5/24/2019 Telephone conference with witness, Shatrion Hill 0.3 5/24/2019 Draft supplemental MIDP disclosures 0.3 5/24/2019 Telephone conference with Mega Sports regarding subpoena for firearms records 0.1 5/24/2019 Edit subpoena to Mega Sports 0.1 5/24/2019 Draft fax transmission for Mega Sports subpoena 0.1 5/24/2019 Draft and send email to defendants' attorneys with Mega Sports subpoena 0.1 5/24/2019 Draft and send email to defendants' attorneys with supplemental MIDP disclosures 0.1 5/29/2019 Review and download attorney appearance for Michele McGee 0.1 5/29/2019 Telephone conference with attorney for individual Chicago police officer defendants, Emily Dory 0.1 5/30/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 5/31/2019 Telephone conference with witness, Odell Dollerson 0.1 5/31/2019 Telephone conference with witness, Shatrion Hill 0.1 5/31/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 5/31/2019 Review and download deposition subpoenas from defendant City of Chicago, update calendar 0.3 5/31/2019 Telephone conference with client, Charles Hill 0.1 6/3/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/3/2019 Update MIDP disclosures 0.3 6/3/2019 Review and scan signed MIDP certifications from clients 0.1 6/3/2019 Draft and send email to defendants' attorneys 0.1 6/3/2019 Draft and file notice of service of MIDP disclosures 0.2 6/3/2019 Prepare copies of supplemental MIDP disclosures to mail 0.1 6/4/2019 Deposition of plaintiff, Charles Hill, including travel and wait 6.1 6/4/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 6/4/2019 Telephone conference with clients 0.1 6/5/2019 Draft letters to send to clients' employers regarding time off for depositions 0.6 6/5/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 6/5/2019 Collect, organize, and Bates-stamp discovery documents, and draft email to defendants' attorneys 0.4 6/5/2019 Telephone conference with client, Charles Hill 0.1 6/5/2019 Telephone conference with defendants' attorney, Kelly Bauer 0.1 6/6/2019 Telephone conference with Lawrence Correctional Center 0.2 6/6/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 6/6/2019 Draft and send letter to Lawrence Correctional Center to arrange for telephone conference with witness, Keitrion Lewis 0.3 6/6/2019 Review subpoena response from Mega Sports 0.2 6/6/2019 Telephone conference with witness Gertha Brady 0.1 6/7/2019 Telephone conference with witness Gertha Brady 0.1 6/11/2019 Telephone conference with witness Gertha Brady 0.1 6/12/2019 Telephone conference with witness Keitrion Lewis 0.6 59 6/12/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/13/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 6/14/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/14/2019 Draft and send letter to Lawrence Correctional Center to arrange for telephone conference with witness Keitrion Lewis 0.2 6/14/2019 Review and download telephone conference confirmation from Lawrence Correctional Center regarding telephone conference with witness, Keitrion Lewis, update calendar 0.1 6/17/2019 Draft deposition notice with multiple dates and update calendar 0.4 6/17/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/17/2019 Draft and send email to defendants' attorneys 0.1 6/18/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/18/2019 Review and download deposition notice for Shatrion Hill, update calendar 0.1 6/19/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 6/19/2019 Telephone conference with Lawrence Correctional Center 0.1 6/19/2019 Telephone conference with witness Keitrion Lewis 0.6 6/20/2019 Review Judge Chang website and standing orders 0.3 6/20/2019 Discuss case and strategy with attorney Irene K. Dymkar 1.2 6/20/2019 Revise deposition notices 0.2 6/20/2019 Draft and send email to defendants' attorneys 0.4 6/20/2019 Draft scheduling report 1.7 6/20/2019 Review defendants' alternative proposed deposition scheduling report 0.1 6/20/2019 Review email from attorney for defendant City of Chicago Andrea Campbell 0.1 6/20/2019 Review discovery documents 0.4 6/20/2019 File plaintiffs' deposition scheduling report 0.1 6/21/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 6/21/2019 Draft and send email to defendants' attorneys 0.1 6/21/2019 Draft and send letter to witness Keitrion Lewis 0.4 6/24/2019 Telphone conference with witness Shatrion Hill 0.2 6/24/2019 Draft and send email to attorney Irene K. Dymkar 0.1 6/24/2019 Review and download subpoena for deposition of witness Keitrion Lewis from IDOC defendants, update calendar 0.1 6/25/2019 Review and download Defendant Parole Agents' Motion for Court Order Allowing Third-Party Witness' Deposition to Proceed, update calendar 0.1 6/25/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/26/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/26/2019 Draft and send letter to Lawrence Correctional Center to arrange for telephone conference with witness Keitrion Lewis 0.2 6/26/2019 Review Defendant Parole Agents' Motion for Court Order Allowing Third-Party Witness' Deposition to Proceed 0.1 6/26/2019 Draft and send email to Judge Chang's courtroom deputy 0.1 6/26/2019 Draft and send email to defendants' attorneys 0.2 6/26/2019 Review Judge Chang order, update calendar 0.1 6/27/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/27/2019 Draft and send email to defendants' attorneys 0.1 6/28/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/28/2019 Review deposition transcript of plaintiff Donna Hill 0.1 60 6/28/2019 Review signed IDOC Authorization for Release of Offender Medical Health Information from witness Keitrion Lewis 0.1 6/28/2019 Draft and send email to defendants' attorneys 0.1 7/1/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.3 7/1/2019 Telephone conference with Urlaub Bowen reporting to discuss issues with remote demposition in prison 0.1 7/1/2019 Prepare exhibits for deposition of witness Keitrion Lewis 0.2 7/2/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.6 7/2/2019 Draft and send email to defendants' attorneys 0.2 7/2/2019 Draft and send email to Dayna Urlaub at Urlaub Bowen Reporting 0.1 7/2/2019 Edit MIDP disclosures 0.5 7/2/2019 Review and redact plaintiffs' discovery documents 0.4 7/2/2019 Prepare MIDP certifications to mail to plaintiffs 0.2 7/3/2019 Telephone conference with plaintiff, Charles Hill 0.1 7/3/2019 Review attorney appearance for Conor Desmond 0.1 7/3/2019 Select and prepare exhibits for deposition of witness Keitrion Lewis 0.3 7/3/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/3/2019 Deposition of witness Keitrion Lewis, including wait 4.9 7/3/2019 Rule 37.2 conference with defendants' attorneys 0.5 7/3/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting regarding deposition scheduling 0.2 7/5/2019 Review notes from deposition of witness Keitrion Lewis 0.1 7/5/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/5/2019 Review deposition subpoena from IDOC defendants, update calendar 0.1 7/8/2019 Review emails from Irene K. Dymkar and defense attorneys regarding Jada Hill deposition rescheduling 0.2 7/8/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting regarding deposition scheduling and issues 0.1 7/8/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 7/8/2019 Prepare exhibits for deposition of witness Odell Dollerson 0.1 7/8/2019 Review updated deposition notice from defendant City of Chicago, update calendar 0.1 7/8/2019 Prepare exhibits for deposition of witness Donna Rixey 0.3 7/9/2019 Telephone conference with Gary Maninfort, court reporter 0.1 7/9/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 7/9/2019 Prepare exhibits for deposition of witness Donna Rixey 0.9 7/9/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting regarding deposition scheduling 0.1 7/9/2019 Review updated deposition subpoena from IDOC defendants, update calendar 0.1 7/9/2019 Deposition of witness Donna Rixey 3.8 7/9/2019 Prepare chart of status of discovery depositions, and plan completion of depositions and abstracting 0.3 7/10/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.5 7/10/2019 Court appearance, including travel 0.7 7/10/2019 Discuss case with defendants' attorneys after court 0.3 7/10/2019 Review file in preparation of depositions of Rodney Alexander and Tamika Johnson 2.0 7/10/2019 Review Judge Chang order, update calendar 0.1 7/11/2019 Discuss case and strategy with attorney Irene K. Dymkar 1.1 61 7/11/2019 Prepare deposition questions for deposition of Rodney Alexander 1.5 7/11/2019 Prepare deposition questions for deposition of Tamika Johnson 1.7 7/11/2019 Review deposition questions with attorney Irene K. Dymkar 0.6 7/11/2019 Prepare exhibits for depositions of Rodney Alexander and Tamika Johnson 0.2 7/12/2019 Prepare deposition questions for deposition of Rodney Alexander 1.2 7/12/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.6 7/12/2019 Deposition of witness Rodney Alexander 2.0 7/12/2019 Prepare deposition questions for deposition of Tamika Johnson 0.3 7/12/2019 Prepare notes on observations of deposition of Rodney Alexander and important admissions made 0.2 7/12/2019 Deposition of witness Tamika Johnson 1.2 7/12/2019 Discuss case with defense attorneys after deposition of Tamika Johnson 0.2 7/12/2019 Prepare notes on observations of deposition of Tamika Johnson and important admissions made 0.2 7/16/2019 Prepare depositon questions for deposition of Felisha Parker 0.9 7/16/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.9 7/16/2019 Prepare exhibits for deposition of Felisha Parker 0.1 7/16/2019 Prepare depositon questions for deposition of Tammie Howard 0.3 7/16/2019 Deposition of witness Felisha Parker 1.3 7/16/2019 Prepare notes on observations of deposition of Felisha Parker and important admissions made 0.1 7/16/2019 Deposition of witness Tammie Howard 1.3 7/16/2019 Prepare notes on observations of deposition of Tammie Howard and important admissions made 0.1 7/16/2019 Select and prepare exhibits for deposition of Christopher Harrington 1.0 7/16/2019 Review notice of deposition from defendant City of Chicago 0.1 7/17/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 7/17/2019 Deposition of defendant Christopher Harrington 8.3 7/17/2019 Meeting with client, Charles Hill, after deposition of defendant Christopher Harrington 0.1 7/18/2019 Prepare notes on observations of deposition of defendant Christopher Harrington and important admissions made 0.5 7/18/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 7/18/2019 Draft updated MIDP disclosures 0.3 7/18/2019 Telephone conference with witness, Gertha Brady 0.1 7/18/2019 Review emails from defense attorneys regarding deposition scheduling 0.1 7/19/2019 Discuss case and strategy with attorney Irene K. Dymkar X 1.4 7/19/2019 Draft and send letter to Lawrence Correctional Center to arrange for telephone conference with witness, Keitrion Lewis 0.3 7/19/2019 Telephone conferences with Mike Lieschke and Marta Wojtulewicz from In Demand Court Reporting regarding deposition scheduling and exhbiit handling 0.2 62 7/19/2019 Draft and send email to Danyiel Long at Lawrence Correctional Center to schedule telephone conference with witness, Keitrion Lewis 0.1 7/22/2019 Discuss case and strategy with attorney Irene K. Dymkar x 0.2 7/22/2019 Draft and send letter to witness Keitrion Lewis 0.3 7/22/2019 Prepare screenshot from videos of IDOC agents for Keitrion Lewis 0.8 7/22/2019 Telephone conference with client, Charles Hill 0.1 7/22/2019 Draft and send email to defendants' attorneys 0.1 7/22/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting 0.1 7/23/2019 Telephone conference with client, Charles Hill 0.1 7/23/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.8 7/23/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting regarding deposition scheduling and exhibit handling 0.1 7/23/2019 Draft plaintiffs' Answers to Interrogatories 0.4 vague as to whic 7/23/2019 Prepare for office meeting with client, Charles Hill 0.1 7/23/2019 Office meeting with client, Charles Hill 1.3 7/23/2019 Telephone conference with defendants' attorneys, Emily Dory and Michele McGee 0.2 7/23/2019 Prepare exhibits for depositions of Scott Liebhaber and Steven Suvada 0.5 7/23/2019 Review and download discovery documents from defendant City of Chicago 0.5 7/24/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.6 7/24/2019 Prepare exhibits for deposition of Scott Liebhaber 0.3 7/24/2019 Prepare exhibits for deposition of Steven Suvada 0.3 7/24/2019 Prepare for deposition of Kevin Bond 0.8 7/24/2019 Deposition of defendant Scott Liebhaber 1.8 7/24/2019 Prepare notes on observations of deposition of Scott Liebhaber and important admissions made 0.2 7/24/2019 Prepare exhibits for deposition of Steven Suvada 0.1 7/24/2019 Prepare questions for deposition of Marcus Cotton 0.4 7/24/2019 Prepare for deposition of Kevin Bond 0.7 7/25/2019 Prepare for deposition of Marcus Cotton 0.8 7/25/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.6 7/25/2019 Deposition of witness Kevin Bond 1.2 7/25/2019 Prepare notes on observations of deposition of Kevin Bond and important admissions made 0.2 7/25/2019 Deposition of witness Marcus Cotton 0.8 7/25/2019 Prepare notes on observations of deposition of Marcus Cotton and important admissions made 0.2 7/25/2019 Edit chart of status of discovery depositions taken and to be taken, determine transcipts needed 0.2 7/25/2019 Rule 37.2 conference with defendants' attorneys 0.8 7/25/2019 Review additional discovery documents from defendant City of Chicago 0.2 7/25/2019 Prepare subpoenas for depositions of Danjwan Johnson and Alexsei Norton 0.2 7/25/2019 Draft and send email to defendants' attorneys 0.1 7/25/2019 Prepare deposition notice for deposition of Thomas Nowak 0.1 7/26/2019 Serve subpoenas for depositions of Danjwan Johnson and Alexsei Norton 0.5 7/26/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 63 7/26/2019 Prepare exhibits for deposition of defendant Elena McKenna 0.2 7/26/2019 Telephone conference with attorney for IDOC defendants, Conor Desmond 0.1 7/26/2019 Review file to prepare for deposition of defendant David Rodriguez 1.2 7/26/2019 Prepare deposition questions for deposition of defendant David Rodriguez 0.5 7/29/2019 Prepare exhibits for deposition of defendant David Rodriguez 0.5 7/29/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.5 7/29/2019 Prepare deposition questions for deposition of defendant David Rodriguez 0.7 7/29/2019 Review Defendants' Notice of Service of Defendants' Second Amended Responses to Mandatory Initial Discovery and Certification of Service 0.1 7/29/2019 Deposition of defendant David Rodriguez 1.5 7/29/2019 Prepare notes on observations of deposition of David Rodriguez and important admissions made 0.2 7/29/2019 Draft subpoena to Assistant State's Attorney's Office 0.2 7/29/2019 Draft subpoena to Department of Children and Family Services 0.5 7/30/2019 Serve subpoena on Department of Children and Family Services and draft affidavit of service 0.4 7/30/2019 Serve subpoena on Assistant State's Attorney's Office and draft affidavit of service 0.4 7/30/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 7/31/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 7/31/2019 Draft subpoena to Illinois Department of Financial and Professional Regulation 0.2 7/31/2019 Telephone conference with client, Charles Hill 0.1 8/1/2019 Draft answers to interrogatories for plaintiff, Charles Hill 0.2 8/1/2019 Draft and send email with plaintiffs' answers to interrogatories to defendants' attorneys 0.2 8/2/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 8/2/2019 Take screenshots of photographs of plaintiffs' home with metadata, to resolve IDOC defendants' objections 0.7 8/2/2019 Prepare screenshots of photographs of plaintiffs' home with metadata to Bates stamp, and Bates stamp documents to resolve IDOC defendants' objections 0.6 8/2/2019 Draft responses to defendants' requests to produce 0.2 8/2/2019 Draft letter to defendants' attorneys regarding photographs of plaintiffs' back porch 0.2 8/2/2019 Review defendants' joint motion for protective order 0.3 8/5/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 8/5/2019 Draft response to motion for a protective order 2.8 8/5/2019 Disclose plaintiffs' additional discovery documents to produce to defendants by DropBox 0.2 8/5/2019 Draft responses to defendants' requests to produce 0.2 8/5/2019 Telephone conference with attorney for IDOC defendants, Conor Desmond 0.1 8/6/2019 Review and download Judge Chang orders, update calendar 0.1 8/6/2019 Telephone conference with Judge Chang's courtroom deputy 0.1 64 8/6/2019 Discuss case and strategy with attorney Irene K. Dymkar x 0.2 8/7/2019 Prepare exhibits for deposition of James Noble 0.2 8/7/2019 Prepare exhibits for deposition of Danjwan Johnson 0.2 8/7/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.5 8/7/2019 Prepare DVDs of plaintiffs' discovery documents to produce to defendants 0.2 8/7/2019 Review discovery documents from defendant City of Chicago 0.1 8/7/2019 Review and download Judge Cox order, update calendar 0.1 8/7/2019 Telephone conference with client, Charles Hill 0.1 8/7/2019 Draft Report of Conference of Parties pursuant to Judge Cox order 0.5 8/7/2019 Draft deposition notice for deposition of Erin Hansen 0.1 8/7/2019 Review file to prepare for deposition of defendant Robert Purvis 0.3 8/7/2019 Prepare deposition questions for deposition of defendant Robert Purvis 0.6 8/7/2019 Prepare questions for deposition of Simon Mbi 0.4 8/7/2019 Prepare exhibits for deposition of Robert Purvis 8/7/2019 Prepare exhibits for deposition of Simon Mbi 0.5 8/8/2019 Prepare deposition questions for deposition of defendant Robert Purvis 0.5 8/8/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.5 8/8/2019 Rule 26(f) meeting with defendants' attorneys 0.2 8/8/2019 Deposition of defendant Robert Purvis 1.0 8/8/2019 Prepare notes on observations of deposition of Robert Purvis and important admissions made 0.2 8/8/2019 Prepare questions for deposition of Simon Mbi 0.3 8/8/2019 Deposition of witness Simon Mbi 1.9 8/8/2019 Prepare notes on observations of deposition of Simon Mbi and important admissions made 0.2 8/9/2019 Draft and send email to defendants' attorneys 0.1 8/9/2019 Review defendants' edits to Report of Conference of Parties 0.1 8/9/2019 Edit Report of Conference of Parties 0.7 8/9/2019 Telephone conference with attorney for IDOC defendants, Conor Desmond 0.1 8/9/2019 Telephone conference with client, Charles Hill 0.1 8/9/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 8/12/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/12/2019 Review and download Defendant Officers' and Defendant City of Chicago's Motion to Compel, update calendar 0.1 8/13/2019 Prepare for court appearance 0.3 8/13/2019 Court appearance, including travel 0.9 8/13/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.6 8/13/2019 Review and download discovery documents from defendant City of Chicago 0.1 8/13/2019 Draft declaration regarding photographs taken by client, Charles Hill 1.0 8/13/2019 Draft memorandum regarding witnesses Ciolli and Campbell, pursuant to Judge Cox order 0.7 8/14/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 8/14/2019 Review Judge Cox order, update calendar 0.1 8/14/2019 Telephone conference with witness Shatrion Hill 0.1 8/14/2019 Prepare exhibits for deposition of Shatrion Hill 0.4 65 8/14/2019 Review letter from attorney Michele M. McGee to Judge Cox 0.1 8/14/2019 Review emails from attorney Irene K. Dymkar 0.1 8/14/2019 Telephone conference with client, Charles Hill 0.1 8/14/2019 Numerous attempts to contact Dept. of Children and Family Services, then telephone conference with Rocell Cyrus from DCFS 0.6 8/14/2019 Draft and send email to Rocell Cyrus 0.1 8/14/2019 Telephone conference with Beth Solomon from Department of Children and Family Services 0.1 8/14/2019 Prepare exhibits for deposition of defendant John Gartner 0.5 8/15/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 8/15/2019 Prepare exhibits for deposition of defendant John Gartner 0.5 8/15/2019 Revise chart of discovery depositions, determine necessary remaining depositions 0.2 8/15/2019 Deposition of defendant John Gartner 3.3 8/16/2019 Review and download letter from attorney Kelly Bauer 0.1 8/16/2019 Prepare notes on observations of deposition of John Gartner and important admissions made 0.3 8/16/2019 Discuss case and strategy with attorney Irene K. Dymkar (4) X 1.2 8/16/2019 Telephone conference with Frank Derango from Home Detention Technicians of Illinois 0.2 8/16/2019 Telphone conference with John Ontiveros from Home Detention Technicians of Illinois 0.2 8/16/2019 Telephone conference with attorney for defendant City of Chicago, Jonathan Green 0.2 8/16/2019 Telphone conference with attorney for individual Chicago police officer defendants, Michele McGee 0.3 8/16/2019 Telephone conference with attorney for IDOC defendants, Kelly Bauer 0.2 8/16/2019 Draft and send deposition notice for deposition of Agent Stanback 0.1 8/16/2019 Draft motion for extension of time to complete discovery 0.7 8/16/2019 Draft and send letter to Lawrence Correctional Center to arrange for telephone conference with witness, Keitrion Lewis 0.1 8/16/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting re deposition of incarcerated person 0.1 8/19/2019 Review motion for extension 0.1 8/19/2019 Review Plaintiffs' Memorandum Regarding Witnesses Matthew M. Conway (Misidentified as John H. Ciolli) and Joe H. Campbell 0.2 8/19/2019 Draft and send email to defendants' attorneys 0.2 8/19/2019 Review and download deposition videos for possible screenshots 0.5 8/19/2019 Prepare, save, and print screenshots ot witnesses from deposition videos 0.3 8/19/2019 Draft letter to witness, Keitrion Lewis 0.1 8/20/2019 Draft and send emails to defendants' attorneys 0.3 8/20/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.5 8/21/2019 Review, finalize, and file motion for extension of time to complete discovery 1.0 8/21/2019 Draft questions for deposition of witness Cornesha Rice 1.3 66 8/21/2019 Telephone conference with attorney for individual Chicago police officer defendants, Emily Dory, re Cornesha Rice deposition 0.1 8/21/2019 Leave voicemail messages for attorney for defendant City of Chicago, Michele McGee, and attorney for individual Chicago police officer defendants, Jessica Griff, re Cornesha Rice deposition 0.1 8/21/2019 Telephone conference with client, Charles Hill 0.2 8/21/2019 Telephone conference with client, Donna Hill 0.2 8/21/2019 Prepare exhibits for deposition of witness Cornesha Rice 0.2 8/21/2019 Cancelled deposition of witness Cornesha Rice, witness arrived late, to be rescheduled, including travel 1.8 8/21/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.6 8/21/2019 Review, finalize, and email declaration regarding photographs taken by client, Charles Hill, to defendants' attorneys 0.2 8/21/2019 Review defendants' responses to plaintiffs' requests to admit 0.2 8/21/2019 Prepare screenshots of witnesses to mail to witness Keitrion Lewis 0.3 8/22/2019 Review Judge Cox website on standing orders regarding Rule 37.2 conferences 0.1 8/22/2019 Draft and file Plaintiffs' Certification of Compliance with Local Rule 37.2 0.5 8/22/2019 Review Defendants Robert W. Purvis, and Scott P. Liebhaber's Motion for Extension of Time to Respond to Plaintiffs' Requests to Admit to All Defendants and Plaintiffs' Certification of Compliance with Local Rule 37.2, update calendar 0.1 8/22/2019 Telephone conference with witness Cornesha Rice 0.1 8/22/2019 Telephone conference with client, Charles Hill 0.4 8/22/2019 Draft and send subpoenas to electronic monitoring technician witnesses 0.4 8/22/2019 Draft and send email to defendants 0.1 8/22/2019 Telephone conference with paralegal in Assistant State's Attorney's office regarding subpoena 0.1 8/22/2019 Review defendants' responses to plaintiffs' requests to admit 0.6 8/22/2019 Review and download photographs from witness Shatrion Hill 0.1 8/23/2019 Telephone conference with Frank Derango from Home Detention Technicians of Illinois 0.1 8/23/2019 Prepare for telephone conference with witness Keitrion Lewis 0.1 8/23/2019 Telephone conference with witness Keitrion Lewis 0.4 8/23/2019 Review and download Judge Cox order, update calendar 0.1 8/23/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 8/26/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 8/26/2019 Review Judge Chang Memorandum Opinion and Order on IDOC defendants' motion to dismiss 0.4 8/26/2019 Prepare exhibits for deposition of defendant Jacob Walls 0.6 8/26/2019 Draft and send email to Judge Cox's courtroom deputy 0.2 8/26/2019 Review, select, and prepare disclosure of photographs from witness Shatrion Hill 0.3 8/26/2019 Draft and send email to defendants' attorneys 0.1 67 8/27/2019 Discuss case and strategy with attorney Irene K. Dymkar x 0.5 8/27/2019 Draft and send emails to defendants' attorneys 0.2 8/27/2019 Review Defendants Robert W. Purvis, and Scott P. Liebhaber's Motion for Extension of Time to Respond to Plaintiffs' Requests to Admit to All Defendants 0.1 8/27/2019 Review and download affidavits from defendants Kevin S. Geyer, Alan P. Lasch, and Matthew M. Pufpaf 0.4 8/27/2019 Prepare for court appearance 0.5 8/28/2019 Prepare for court appearance 0.1 8/28/2019 Court appearance, including travel 0.9 8/28/2019 Discuss case with defendants' attorneys after court 0.2 8/28/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/28/2019 Review and download discovery documents from IDOC defendants 0.3 8/28/2019 Draft and send email to defendants' attorneys 0.1 8/29/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/29/2019 Draft plaintiffs' motion to set aside Magistrate Judge's order 1.5 8/30/2019 Draft plaintiffs' motion to set aside Magistrate Judge's order 0.4 8/30/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/30/2019 Draft and send email to defendants' attorneys 0.1 8/30/2019 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 9/3/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/3/2019 Draft and send email to defendants' attorneys 0.1 9/4/2019 Review and download discovery documents from IDOC defendants 0.2 P 9/4/2019 Select and prepare exhibits for motion to set aside Magistrate Judge's order 0.1 9/4/2019 Review and download Judge Chang order, update calendar 0.1 9/4/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/4/2019 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 9/5/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/6/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/6/2019 Review Judge Chang order and final version of Plaintiffs' Motion for Settlement Conference, update calendar 0.1 9/6/2019 Draft and send email to defendants' attorneys 0.1 9/6/2019 Review and download 8/28/2019 court hearing transcript 0.2 9/9/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.4 9/9/2019 Draft and send email to defendants' attorneys 0.2 9/9/2019 Draft motion to reconsider 0.6 9/9/2019 Attempt to locate and contact witness Cornesha Rice 0.1 9/10/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.8 9/10/2019 Telephone conference with client, Charles Hill 0.1 9/10/2019 Review transcript of 8/13/2019 hearing 0.6 9/10/2019 Draft and send email to defendants' attorneys 0.1 9/10/2019 Draft motion for order regarding referral to Magistrate Judge 0.1 9/10/2019 Prepare exhibits for depositions of Thomas Nowak and Erin Hansen 0.6 9/11/2019 Review Motion for Leave to Withdraw as Attorney for Defendants, update calendar 0.1 9/11/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 68 9/11/2019 Prepare exhibits for depositions of Thomas Nowak and Erin Hansen 0.2 9/11/2019 Draft motion for order regarding referral to Magistrate Judge 0.5 9/11/2019 Telephone conference with witness Cornesha Rice 0.1 9/12/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.3 9/12/2019 Search police websites for and download photographs of K9 Squiggy 0.5 9/13/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 9/13/2019 Draft and send email to defendants' attorneys 0.1 9/13/2019 Telephone conference with attorney for individual Chicago police officer defendant, Michele McGee 0.1 9/13/2019 Review and download discovery documents from defendant City of Chicago 0.1 9/16/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.5 9/16/2019 Select and prepare exhibits for deposition of witness Steve Martinez 0.7 9/16/2019 Draft and send email with deposition exhibits to Urlaub Bowen for video deposition 0.2 9/16/2019 Telephone conference with witness Gertha Brady 0.2 9/16/2019 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 9/16/2019 Telephone conference with Urlaub Bowen reporting re video deposition 0.1 9/16/2019 Telephone conference with witness Cornesha Rice 0.1 9/17/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.8 9/17/2019 Draft and send email to defendants' attorneys 0.1 9/17/2019 Review Motion for Leave to Withdraw as Attorney for Defendants, Defendants' Notice of Service of Defendants' Second Amended Responses to Mandatory Initial Discovery and Certification of Service, and Plaintiffs' Motion for Order Reassigning Magistrate Judge for Discovery Supervision or Deciding Motion to Set Aside Orders Taking Into Account New Information, update calendar 0.1 9/17/2019 Prepare for deposition of Gertha Brady 0.9 9/17/2019 Deposition (incomplete) of Gertha Brady, including travel and wait 1.5 9/17/2019 Telphone conference with attorney for individual Chicago police officer defendants, Michele McGee 0.1 9/18/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 9/18/2019 Review and download Judge Cox order, update calendar 0.1 9/18/2019 Draft email to defendants' attorneys with discovery documents 0.1 9/18/2019 Telephone conference with attorney for IDOC defendants, Kelly Bauer 0.1 9/18/2019 Telephone conference with Roberto Cornejo from Clerk's office 0.1 9/18/2019 Draft supplemental MIDP disclosures 0.1 9/18/2019 Review and download audio recording of 8/28/2019 hearing 1.4 9/19/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 9/19/2019 Draft and send email to defendants' attorney and prepare Dropbox folder of 8/28/2019 hearing audio to produce to defendants' attorneys 0.5 69 9/19/2019 Review IDOC Defendant Parole Agents Harrington and Walls' Joint Motion for a Rule to Show Cause, or in the Alternative Bar, Plaintiffs' Witnesses Pursuant to Federal Rule of Civil Procedure 45(G), 26(A)(1)(A), and 37(C)(1), Judge Cox order, update calendar 0.3 9/19/2019 Prepare discs of audio of 8/28/2019 hearing for defendants' attorneys, per attorneys' request 0.2 9/20/2019 Telephone conference with clients, Charles Hill and Donna Hill 0.3 9/20/2019 Review transcript of 8/28/2019 hearing 0.4 9/20/2019 Draft and send email to defendants' attorneys 0.1 9/20/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.2 9/20/2019 Review and download Judge Chang orders, update calendar 0.1 9/20/2019 Review IDOC motion for rule to show cause 0.2 9/20/2019 Draft and send email to Judge Chang's courtroom deputy 0.1 9/20/2019 Draft response to IDOC motion for rule to show cause 0.6 9/23/2019 Select and prepare exhibits to file with motions, file exhibits 0.4 9/23/2019 Review final versions of Plaintiffs' Response in Opposition to IDOC Defendant Parole Agents Harrington and Walls' Joint Motion for a Rule to Show Cause, or in the Alternative Bar, Plaintiffs' Witnesses Pursuant to Federal Rule of Civil Procedure 45(G), 26(a)(1)(A), and 37(c)(1) and Plaintiffs' Motion to Reconsider Magistrate Judge's Orders Barring Plaintiffs from Taking Certain Depositions and Granting Defendant Walls Leave to Disclose Withheld Evidence, and to Consider the Additional Evidence 0.1 9/23/2019 Draft and send email to Judge Cox's courtroom deputy 0.1 9/26/2019 Discuss case and strategy with attorney Irene K. Dymkar 0.1 9/26/2019 Review edits to transcript of 8/28/2019 hearing 0.4 9/26/2019 Draft and send email to court report Lisa Breiter 0.1 9/27/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 9/27/2019 Review and download Defendant Parole Agents Harrington and Walls' Response to Plaintiffs' Motion to Reconsider Magistrate Judge Cox's Orders and Defendant Officers' and Defendant City of Chicago's Reply to Plaintiffs' Motion to Reconsider Magistrate Judge Susan Cox's August 21,2019, Order Barring Plaintiffs from Taking Certain Depositions 0.9 9/27/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 9/30/2019 Draft reply in support of motion to reconsider 1.2 10/1/2019 Review and download Judge Cox order, update calendar 0.1 10/1/2019 Draft and send email to defendants' attorneys 0.1 10/1/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/2/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/2/2019 Telephone conference with client, Charles Hill 0.1 10/2/2019 Telephone conference with client, Donna Hill 0.1 10/2/2019 Draft and sent email to Judge Chang's courtroom deputy 0.1 10/3/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/4/2019 Draft supplemental MIDP disclosures 0.1 10/4/2019 Review Affidavit of Service of Rule to Show Cause on Gertha Brady, Judge Cox order 0.2 10/4/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/4/2019 Review deposition transcript of witness Simon Mbi 0.1 70 10/4/2019 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 10/8/2019 Draft and send email to defendants 0.1 10/8/2019 Review motions and prepare for motion hearing 0.7 10/8/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/9/2019 Court appearance, including travel 0.9 10/9/2019 Discuss case with defendants' attorneys and Gertha Brady after court 0.2 10/9/2019 Draft and send emails to attorney Irene K. Dymkar X 0.3 10/9/2019 Review Judge Cox order, update calendar 0.1 10/10/2019 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 10/14/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/14/2019 Draft and send email to defendants' attorneys 0.1 10/15/2019 Court appearance, including travel 1.0 10/17/2019 Telephone conference with Kenneth Pointer, Gertha Brady's grandson 0.1 10/17/2019 Draft motion to set aside magistrate judge's order 1.6 10/17/2019 Telephone conference with Gertha Brady 0.1 10/17/2019 Review and download Judge Chang order, update calendar 0.1 10/18/2019 Prepare for Gertha Brady deposition 0.2 10/18/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 10/18/2019 Deposition of witness Gertha Brady 3.3 10/21/2019 Review and scan notes from deposition of witness Gertha Brady, decide on next steps 0.2 10/21/2019 Review final version of Plaintiffs' Motion to Set Aside Magistrate Judge's Order Barring Plaintiffs from Taking Certain Depositions and Allowing the Late Disclosure by Defendant Walls of Withheld Evidence 0.1 10/22/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 10/22/2019 Draft and send email to defendants' attorneys 0.1 10/23/2019 Telephone conference with plaintiff, Charles Hill 0.1 10/24/2019 Draft and send email to defendants' attorneys 0.1 10/24/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/24/2019 Review deposition transcript of defendant Steven Suvada 0.1 10/24/2019 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 10/25/2019 Review deposition transcript of defendant Christopher Harrington 0.3 10/25/2019 Select and prepare exhibits for continuation deposition of defendant Jacob Walls 0.1 10/25/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 10/29/2019 Telephone conference with attorney for defendant City of Chicago, Andrea Campbell 0.1 10/29/2019 Draft and send email to defendants' attorneys 0.3 10/31/2019 Review and download discovery documents from defendant City of Chicago 0.4 11/4/2019 Draft and send email to defendants' attorneys 0.1 11/5/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/5/2019 Review Defendants' Opposed Motion for Leave to File Their Response to Plaintiffs' Third Motion to Reconsider in Excess of Page Limits, update calendar 0.2 11/6/2019 Draft response to defendants' motion for leave to file 0.2 11/6/2019 Review Judge Chang order, update calendar 0.1 71 11/7/2019 Review Defendant Parole Agents Harrington and Walls' Response and Defendant Officers and City of Chicago's Joint Response to Plaintiffs' Second Motion to Set Aside Magistrate Judge Cox's Orders 0.6 11/13/2019 Review and download Judge Cox order, update calendar 0.1 11/14/2019 Draft and send email to defendants' attorneys 0.1 11/15/2019 Draft motion for extension of time to file reply in support of motion to set aside Magistrate Judge's order 0.7 11/20/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 11/20/2019 Draft and send email to defendants 0.2 11/20/2019 Review and download Judge Chang order, update calendar 0.1 11/26/2019 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 12/5/2019 Review Defendant Parole Agents Harrington and Walls' Response and Defendant Officers and City of Chicago's Joint Response to Plaintiffs' Second Motion to Set Aside Magistrate Judge Cox's Orders 0.3 12/6/2019 Review Defendant Parole Agents Harrington and Walls' Response and Defendant Officers and City of Chicago's Joint Response to Plaintiffs' Second Motion to Set Aside Magistrate Judge Cox's Orders 0.6 12/12/2019 Telephone conference with plaintiff, Charles Hill 0.1 12/12/2019 Draft reply in support of motion to set aside Magistrate Judge's order 0.7 12/13/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 12/13/2019 Draft and send email to Mike Lieschke from In Demand Court Reporting about deposition transcripts, requesting nondamaged condensed transcript 0.1 12/13/2019 Review and download non-damaged condensed transcript for defendant Christopher Harrington 0.1 12/16/2019 Review final version of Plaintiffs' Reply in Support of Plaintiffs' Motion to Set Aside Magistrate Judge's Order Barring Plaintiffs from Taking Certain Depositions and Allowing the Late Disclosure by Defendant Walls of Withheld Evidence 0.1 12/20/2019 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 12/30/2019 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/2/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/9/2020 Review and download Judge Chang order, update calendar 0.1 1/9/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/30/2020 Review and download Judge Chang order, update calendar 0.1 2/4/2020 Telephone conference with plaintiff, Charles Hill 0.1 2/20/2020 Review and download Judge Chang order, update calendar 0.1 2/21/2020 Telephone conference with attorney for IDOC defendants, Kelly Bauer 0.1 2/21/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 2/25/2020 Review Defendant Parole Agents' Motion for Entry of Protective Order 0.1 2/26/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 2/26/2020 Review IDOC defendants' motion for entry of protective order 0.3 2/26/2020 Telephone conference with IDOC defendants' attorney Kelly Bauer 0.1 2/26/2020 Draft and send email to defendants' attorneys 0.1 72 2/26/2020 Draft and send email to Judge Chang's courtroom deputy 0.1 2/26/2020 Draft response to IDOC defendants' motion for entry of protective order 0.6 2/26/2020 Draft motion for extension of time to take follow up deposition of defendant Harrington 0.6 2/26/2020 Review and download Judge Chang order, Plaintiffs' Response in Opposition to Defendant Parole Agents' Motion for Entry of Protective Order, Plaintiffs' Unopposed Motion to Extend Deadline to take Follow-Up Deposition of Defendant Parole Agent Christopher Harrington, update calendar 0.1 2/26/2020 Prepare for court appearance 0.3 2/27/2020 Court appearance 0.5 2/27/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 2/27/2020 Review and download Judge Chang order, update calendar 0.1 3/6/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 3/6/2020 Draft and send email to defendants' attorneys 0.1 3/10/2020 Draft and send email to defendants' attorneys 0.1 3/10/2020 Draft and send deposition notice for continuation deposition of defendant Harrington 0.3 3/11/2020 Telephone conference with plaintiff, Charles Hill 0.1 3/16/2020 Draft and send email to defendants' attorneys 0.1 3/16/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 3/17/2020 Review and download COVID-19 general order 0.1 3/17/2020 Draft and send email to defendants' attorneys 0.1 3/23/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 4/1/2020 Review and download COVID-19 general order 0.1 4/2/2020 Review and download Judge Chang order, update calendar 0.1 4/2/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.2 4/2/2020 Draft and send emails to defendants' attorneys 0.4 4/2/2020 Draft motion to amend order 0.5 4/3/2020 Draft and send email to defendants' attorneys 0.1 4/6/2020 Review and download Plaintiffs' Motion to Amend April 2, 2020 Order, Document 162, update calendar 0.1 4/13/2020 Draft status report 0.9 4/14/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 4/14/2020 Draft status report 0.3 4/15/2020 Draft and send email to defendants' attorneys 0.1 4/16/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.4 4/16/2020 Draft and send emails to defendants' attorneys regarding status report (multiple) 0.5 4/16/2020 Review status report with defendants' edits, and draft revisions 1.1 4/16/2020 Review emails from defendants' attorneys regarding status report (multiple) 0.2 4/17/2020 Review and download detailed Judge Chang order, update calendar 0.2 4/17/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 4/23/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 4/23/2020 Draft and send email to Judge Chang's courtroom deputy 0.2 4/28/2020 Review and download COVID-19 general order 0.2 5/18/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 5/18/2020 Draft and send email to Judge Chang's courtroom deputy 0.2 5/27/2020 Review and download COVID-19 general order 0.1 5/27/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 73 5/27/2020 Draft and send email to Judge Chang's courtroom deputy 0.2 5/28/2020 Draft and send email to attorney Irene K. Dymkar 0.1 5/28/2020 Draft and send email to Judge Chang's courtroom deputy 0.1 6/2/2020 Review and download Judge Chang order, update calendar 0.1 6/15/2020 Draft and send email to attorney Irene K. Dymkar 0.1 6/15/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 6/15/2020 Draft and send email to defendants' attorneys 0.1 6/15/2020 Draft motion for extension of time to take follow up deposition of defendant Harrington 0.7 6/15/2020 Edit, finalize, and file motion for extension of time to take follow up deposition of defendant Harrington 0.4 6/18/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 6/19/2020 Telephone conference with plaintiff, Charles Hill 0.2 6/25/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/25/2020 Draft status report 0.5 6/26/2020 Draft and send email to defendants' attorneys regarding status report 0.1 6/26/2020 Update and finalize status report 0.2 6/26/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 6/29/2020 Review Judge Chang order, update calendar 0.1 7/8/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 7/8/2020 Draft and send email to defendants' attorneys 0.1 7/13/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 7/13/2020 Draft and send email to defendants' attorneys 0.1 7/14/2020 Review and download COVID-19 general order 0.1 7/14/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 7/14/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 7/17/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 7/17/2020 Draft and send email to defendants' attorneys 0.1 7/21/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 7/21/2020 Draft and send email to defendants' attorneys 0.1 7/21/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 7/22/2020 Draft and send email to defendants' attorneys 0.2 7/22/2020 Draft deposition notice for continuation deposition of defendant Christopher Harrington 0.3 7/22/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/23/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 7/23/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/23/2020 Finalize deposition notice for continuation deposition of defendant Christopher Harrington 0.1 7/23/2020 Draft and send email to defendants' attorneys 0.1 7/27/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 7/27/2020 Prepare exhibits for continuation deposition of defendant Christopher Harrington 0.8 7/28/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.6 7/28/2020 Edit deposition notice for continuation deposition of defendant Christopher Harrington 0.2 7/28/2020 Draft and send email to defendants' attorneys 0.1 7/28/2020 Telephone conference with attorney for IDOC defendants, Kelly Bauer 0.1 7/28/2020 Draft and send email to attorney Irene K. Dymkar 0.1 7/28/2020 Telephone conference with attorney for IDOC defendants Kelly Bauer 0.2 7/28/2020 Draft and send email to attorney Irene K. Dymkar regarding telephone conference with attorney Kelly Bauer 0.2 74 7/29/2020 Discuss case and strategy with attorney Irene K. Dymkar x 0.5 7/29/2020 Test Zoom deposition link with Mike Lieschke and Marta Wojtulewicz from In Demand Court Reporting 0.5 7/29/2020 Draft and send email to attorney Irene K. Dymkar 0.1 7/29/2020 Review IDOC administrative directives 0.3 7/29/2020 Review multiple emails with defendants' attorneys regarding inspecting box of ammunition 0.4 7/29/2020 Create chart of seized firearms and ammunition 1.0 7/29/2020 Select and prepare exhibits for continuation deposition of defendant Christopher Harrington 0.9 7/30/2020 Review exhibits for continuation deposition of defendant Christopher Harrington 0.4 7/30/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.6 7/30/2020 Re-test Zoom link for deposition 0.3 7/30/2020 Continuation deposition of defendant Christopher Harrington, including multiple technical difficulties 1.8 7/30/2020 Draft and send email to Mike Lieschke from In Demand Court Reporting re technical difficulties 0.1 8/4/2020 Draft status report 0.2 8/5/2020 Prepare Dropbox link of exhibits from continuation deposition of defendant Christopher Harrington for Mike Lieschke 0.3 8/5/2020 Draft and send email to Mike Lieschke from In Demand Court Reporting re issues at continuation depostion of Christopher Harrington 0.1 8/5/2020 Draft and send email to attorney Irene K. Dymkar X 0.2 8/5/2020 Draft and send status report to defendants' attorneys 0.1 8/5/2020 Revise status report 0.3 8/10/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/11/2020 Review IDOC motion for summary judgment 0.6 8/11/2020 Review City and Chicago police officer defendants' motion for summary judgment 0.6 8/11/2020 Review Judge Chang prior orders 0.2 8/11/2020 Draft and send email to attorney Irene K. Dymkar X 0.2 8/11/2020 Review and download Judge Chang order, update calendar 0.1 8/12/2020 Review and download Motion to Strike ECF Dkt. No. 179, Exhibit G and Substitute with Exhibit G Attached Hereto 0.1 8/12/2020 Draft and send email to paralegal Sophia Darugar with instruction for abstracting transcripts 0.1 8/13/2020 Draft and send email to attorney Irene K. Dymkar 0.1 8/13/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 8/13/2020 Review and download Judge Chang order 0.1 8/18/2020 Draft Freedom of Information Act ("FOIA") request to IDOC 0.3 8/18/2020 Draft and send email to IDOC FOIA officer 0.1 8/19/2020 Review IDOC summary judgment filings 0.8 8/19/2020 Review summary judgment filings by individual Chicago police officers and City of Chicago 1.0 8/19/2020 Draft and send email to attorney Irene K. Dymkar 0.2 8/19/2020 Review abstract of deposition transcript for plaintiff Donna Hill 1.0 8/19/2020 Review abstract of deposition transcript for witness Keitrion Lewis 1.0 8/20/2020 Draft and send email to attorney Irene K. Dymkar 0.1 8/20/2020 Draft and send email to defendants' attorneys 0.2 75 8/20/2020 Review file and update deposition chart, with depositions taken, depositions to be taken, transcripts obtained,transcripts to obtain, abstracts completed, abstracts to be completed 1.8 8/20/2020 Draft and send email to attorney Irene K. Dymkar 0.3 8/20/2020 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.3 8/20/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 8/26/2020 Review IDOC FOIA response 0.1 8/26/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 8/26/2020 Draft and send email to defendants' attorneys 0.1 8/27/2020 Draft motion to reopen discovery to photograph ammunition 1.2 9/2/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 9/2/2020 Draft and send email to defendants' attorneys 0.1 9/9/2020 Review deposition abstract for witness Rixie Davis 0.4 9/10/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.1 9/11/2020 Unsuccessful attempt to download discovery documents from defendant City of Chicago 0.3 9/11/2020 Draft and send email to defendants' attorneys 0.2 9/11/2020 Review and download discovery documents from defendant City of Chicago 0.4 9/11/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/11/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 9/14/2020 Review deposition abstract for witness Erin Hansen 0.3 9/15/2020 Review deposition abstract for continuation deposition of defendant Christopher Harrington 0.3 9/21/2020 Review deposition abstracts for depositions of defendant John Gartner and Donna Rixey 0.3 9/28/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/5/2020 Draft and send email to defendants' attorneys 0.1 10/5/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/6/2020 Review Judge Chang standing orders 0.1 10/6/2020 Draft motion for extension of time to file motion for summary judgment and responses to defendants' motions for summary judgment 0.9 10/6/2020 Draft and send email to attorney Irene K. Dymkar 0.1 10/6/2020 Draft and send email to defendants' attorneys 0.1 10/6/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/9/2020 Review Plaintiffs' Motion to Extend Deadline to File Plaintiffs' Motion for Summary Judgment and to Respond to Defendants' Two Motions for Summary Judgment, Plaintiffs' Unopposed Motion for Order Reopening Discovery for Limited Purpose of Photographing Ammunition, Notice of Withdrawal and Substitution of Counsel Within the Same Firm Pursuant to Local Rule 83.17 0.1 10/12/2020 Review and download Judge Chang order, update calendar 0.1 10/28/2020 Draft initial draft of plantiffs' motion for summary judgment 0.5 11/2/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 11/2/2020 Draft and send email to defendants' attorneys 0.3 11/3/2020 Draft response to Rule 56.1 statement from IDOC defendants 0.8 11/3/2020 Draft response to Rule 56.1 statement from City defendants 0.7 76 11/4/2020 Review multiple deposition transcripts and deposition abstracts 3.0 11/5/2020 Discuss case and strategy with attorney Irene K. Dymkar x 0.2 11/5/2020 Review multiple deposition transcripts and deposition abstracts 1.4 11/5/2020 Draft and send email to defendants' attorneys 0.1 11/9/2020 Take test screenshots through Zoom, to prepare for court-ordered production of missing ammuntion box by Zoom 0.2 11/9/2020 Review multiple deposition transcripts and deposition abstracts 0.8 11/9/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.3 11/9/2020 Draft and send email to defendants' attorneys 0.1 11/9/2020 Inspection of bullets and ammunition via Zoom with IDOC investigator 0.8 11/12/2020 Telephone conference with clients, Charles Hill and Donna Hill 0.2 11/13/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/16/2020 Review and download Notification of Change of Attorney Address or Name for attorney Emily Dory 0.1 11/16/2020 Review multiple deposition transcripts and deposition abstracts 2.2 11/16/2020 Draft response to Rule 56.1 statement of fact from IDOC defendants 0.5 11/16/2020 Draft response to Rule 56.1 statement of fact from City defendants 0.4 11/16/2020 Draft and send email to attorney Irene K. Dymkar 0.1 11/17/2020 Review and download Notification of Change of Attorney Address or Name for attorney Michele McGee 0.1 11/17/2020 Draft and send email to attorney Irene K. Dymkar 0.3 11/17/2020 Telephone conference with Urlaub Bowen Reporting 0.2 11/17/2020 Telephone conference with Bridges Court Reporting 0.2 11/17/2020 Review deposition transcript of witness Odell Dollerson 0.3 11/17/2020 Review defendants' summary judgment exhibits 0.5 11/17/2020 Draft and send email to defendants' attorneys 0.1 11/17/2020 Review deposition transcript of witness Gertha Brady 0.3 11/17/2020 Draft and send emails to LA Reporting regarding deposition of witness Cornesha Rice 0.3 11/17/2020 Telephone conference with LA Reporting regarding deposition of witness Cornesha Rice 0.1 11/17/2020 Draft response to Rule 56.1 statement of facts from IDOC defendants 0.6 11/17/2020 Draft response to Rule 56.1 statement of facts from City defendants 0.8 11/17/2020 Review deposition transcript of witness Shatrion Hill 0.3 11/17/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 11/17/2020 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.3 11/17/2020 Telephone conference with Lexitas Court Reporting regarding deposition of Cornesha Rice 0.1 11/17/2020 Review deposition transcript of witness Cornesha Rice 0.3 11/18/2020 Review deposition transcripts of witnesses Danjwan Johnson and Felisha Parker 0.3 11/18/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 11/18/2020 Draft initial draft of response to Rule 56.1 statement of facts from IDOC defendants 2.6 77 11/18/2020 Draft initial draft of response to Rule 56.1 statement of facts from City defendants 2.0 11/18/2020 Draft initail draft of response to City defendants' motion for summary judgment 0.4 11/19/2020 Draft response to City defendants' motion for summary judgment 4.0 11/19/2020 Draft intial draft of response to IDOC defendants' motion for summary judgment 2.3 11/20/2020 Review multiple deposition transcripts and deposition abstracts 2.6 11/20/2020 Draft response to City defendants' motion for summary judgment 1.6 11/20/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 11/20/2020 Review deposition abstract of defendant Steven Suvada 0.8 11/21/2020 Draft response to City defendants' motion for summary judgment 1.7 11/21/2020 Draft initial draft of plaintiffs' Rule 56.1 statement of facts 4.6 11/22/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 11/22/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.5 11/22/2020 Draft initial draft of plaintiffs' Rule 56.1 statement of facts 4.0 11/22/2020 Review deposition transcript of witness Danjwan Johnson 0.3 11/23/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 11/23/2020 Draft initial draft of plaintiffs' Rule 56.1 statement of facts 4.7 11/23/2020 Draft response to IDOC defendants' motion for summary judgment 0.1 11/24/2020 Draft initial draft of plaintiffs' Rule 56.1 statement of facts 3.5 11/24/2020 Discuss case and strategy with attorney Irene K. Dymkar X 1.1 11/24/2020 Draft and send email to defendants' attorneys 0.2 11/24/2020 Draft motion for extension of time to file plaintiffs' motion for summary judgment and responses to defendants' motions for summary judgment 0.9 11/25/2020 Review multiple deposition transcripts and deposition abstracts 2.0 11/25/2020 Draft plaintiffs' Rule 56.1 statement of facts 2.5 11/25/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 11/25/2020 Review and download Judge Chang order, update calendar 0.1 11/25/2020 Draft response to IDOC memorandum of law in support of motion for summary judgment 0.7 11/30/2020 Draft response to IDOC defendants' motion for summary judgment 3.7 12/1/2020 Draft response to IDOC defendants' Rule 56.1 statement 2.2 12/1/2020 Draft response to City defendants' Rule 56.1 statement 1.7 12/1/2020 Draft and send email to attorney Irene K. Dymkar 0.1 12/1/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 12/1/2020 Draft response to IDOC memorandum of law in support of motion for summary judgment 1.3 12/2/2020 Review summary judgment filings by City defendants 0.8 12/2/2020 Discuss case and strategy with attorney Irene K. Dymkar X 1.0 12/2/2020 Review and download Notification of Change of Attorney Address or name for attorney Jessica Griff 0.1 12/2/2020 Telephone conference with plaintiff, Donna Hill 0.2 12/2/2020 Draft and send email to plaintiff, Donna Hill 0.1 12/2/2020 Draft and send text to plaintiff, Charles Hill 0.1 12/2/2020 Telephone conference with plaintiff, Charles Hill 0.2 12/2/2020 Draft and send email to attorney Irene K. Dymkar X 0.2 78 12/2/2020 Draft plaintiffs' Rule 56.1 statement of facts 2.0 12/2/2020 Draft declarations of plaintiffs, Charles Hill and Donna Hill 1.6 12/3/2020 Draft declarations of plaintiffs, Charles Hill and Donna Hill 0.4 12/3/2020 Review IDOC administrative directives 0.8 12/3/2020 Draft plaintiffs' Rule 56.1 statement of facts 3.0 12/3/2020 Telephone conference with plaintiffs, Charles Hill and Donna Hill 0.1 12/3/2020 Review multiple deposition transcripts and deposition abstracts 0.8 12/3/2020 Draft and send email to attorney Irene K. Dymkar X 0.1 12/4/2020 Draft response to IDOC defendants' memorandum of law in support of motion for summary judgment 2.2 12/4/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 12/4/2020 Draft plaintiffs' Rule 56.1 statement of facts 0.2 12/4/2020 Conduct legal research for summary judgment responses 0.5 12/5/2020 Draft plaintiffs' Rule 56.1 statement of facts 0.3 12/5/2020 Draft response to IDOC defendants' memorandum of law in support of motion for summary judgment 4.0 12/5/2020 Conduct legal research for response to IDOC summary judgment motion 0.8 12/5/2020 Draft statement of additional facts in response to IDOC motion for summary judgment 0.8 12/5/2020 Draft and send email to Urlaub Bowen reporting 0.1 12/5/2020 Draft and send email to Bridges Court Reporting 0.1 12/5/2020 Prepare exhibits for summary judgment motion and responses 0.3 12/6/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.2 12/6/2020 Draft statement of additional facts in response to IDOC motion for summary judgment 3.6 12/6/2020 Draft plaintiffs' Rule 56.1 statement of facts 0.3 12/6/2020 Draft statement of additional facts in response to City motion for summary judgment 1.5 12/6/2020 Draft and send email to attorney Irene K. Dymkar 0.1 12/7/2020 Draft and send emails to attorney Irene K. Dymkar (multiple) 0.4 12/7/2020 Draft statement of additional facts in response to City motion for summary judgment 1.0 12/7/2020 Review deposition transcript of witness Odell Dollerson, without attachments, for filing 0.1 12/7/2020 Test file all exhibits 0.3 12/7/2020 Draft and send emails to Bridges Court Reporting 0.2 12/7/2020 Draft statement of additional facts in response to IDOC motion for summary judgment 0.2 12/7/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.2 12/7/2020 Draft memorandum of law in response to City motion for summary judgment 2.7 12/7/2020 Review declarations of plaintiffs, Charles Hill and Donna Hill 0.3 12/7/2020 Telephone conference with plaintiffs, Charles Hill and Donna Hill 0.3 12/7/2020 Prepare table of contents for exhibits in support of motion for summary judgment 0.7 12/7/2020 Prepare exhibits for summary judgment motion and responses 0.2 12/7/2020 Add certificates of service to all summary judgment filings 0.5 79 12/7/2020 Draft memorandum of law in support of plaintiffs' motion for summary judgment 0.4 12/8/2020 Draft memorandum of law in response to IDOC motion for summary judgment 0.1 12/8/2020 Draft memorandum of law in support of plaintiffs' motion for summary judgment 2.3 12/8/2020 Telephone conference with Urlaub Bowen Reporting re problems with transcripts (encumbered with attachments) 0.1 12/8/2020 Draft and send emails to Urlaub Bowen Reporting 0.2 12/8/2020 Discuss case and strategy with attorney Irene K. Dymkar 1.8 12/8/2020 Select, redact, and prepare exhibits for summary judgment motion and responses 0.4 12/8/2020 Prepare table of contents for exhibits in support of motion for summary judgment 0.6 12/8/2020 Conduct legal research regarding failure to intervene 0.7 12/8/2020 Review and download deposition transcripts, without attachments, for filing 0.1 12/8/2020 Test file exhibits 0.3 12/8/2020 Telephone conference with plaintiff, Charles Hill 0.1 12/8/2020 Final edits to declarations of plaintiffs 0.7 12/8/2020 Meet with plaintiffs at site of incident, including travel 1.7 12/8/2020 Draft response to City defendants' Rule 56.1 statement 1.0 12/8/2020 Draft plaintiffs' Rule 56.1 statement of facts 1.7 12/8/2020 Draft and send email to attorney Irene K. Dymkar X 0.2 12/9/2020 Draft and send email to attorney Irene K. Dymkar X 0.3 12/9/2020 Draft plaintiffs' Rule 56.1 statement of facts 1.0 12/9/2020 Select, redact, and prepare exhibits for summary judgment motion and responses 0.9 12/9/2020 Discuss case and strategy with attorney Irene K. Dymkar X 1.5 12/9/2020 Correct citations in plaintiffs' Rule 56.1 statement of facts 1.7 12/9/2020 Draft statement of additional facts in response to IDOC motion for summary judgment 1.6 12/9/2020 Edit citations in plaintiffs' memorandum of law in support of motion for summary judgment 0.8 12/9/2020 Draft response to IDOC defendants' Rule 56.1 statement 1.2 12/9/2020 Draft statement of additional facts in response to City motion for summary judgment 1.0 12/9/2020 Proofread and edit plaintiffs' Rule 56.1 statement of facts 0.4 12/9/2020 Edit citations in memorandum of law in response to IDOC motion for summary judgment 0.6 12/9/2020 File plaintiffs' motion for summary judgment, table of contents and exhibits, Rule 56.1 statement of facts, and memorandum of law in support of plaintiffs' motion for summary judgment 0.8 12/9/2020 Draft motion for extension of time to file responses to defendants' motions for summary judgment 0.2 12/9/2020 Draft response to City defendants' Rule 56.1 statement 1.0 12/9/2020 File motion for extension of time to file responses to defendants' motions for summary judgment 0.1 12/9/2020 Draft memorandum of law in response to City motion for summary judgment 0.7 12/10/2020 Discuss case and strategy with attorney Irene K. Dymkar 1.4 12/10/2020 Draft response to City defendants' Rule 56.1 statement 2.3 12/10/2020 Draft and send email to attorney Irene K. Dymkar 0.1 80 12/10/2020 Draft statement of additional facts in response to City motion for summary judgment 0.3 12/10/2020 Draft memorandum of law in response to City motion for summary judgment 0.2 12/11/2020 Discuss case and strategy with attorney Irene K. Dymkar 0.4 12/11/2020 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 12/11/2020 Edit citations in memorandum of law in response to City defendants' motion for summary judgment 0.7 12/11/2020 Edit citations in response to City defendants' Rule 56.1 statement of facts 0.3 12/14/2020 Review Judge Chang's order, update calendar 0.1 12/14/2020 Review deposition transcripts for birth dates to redact 0.4 12/14/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 12/14/2020 Draft and send email to defendants' attorneys 0.1 12/14/2020 Draft and finalize motion to strike deposition transcript of defendant Christopher Harrington 0.6 12/14/2020 Draft and send email to paralegal Sophia Darugar with instructions for abstracting transcripts 0.1 12/16/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 12/16/2020 Draft and send email to defendants' attorneys 0.1 12/16/2020 Draft motion to dismiss 0.5 12/16/2020 Redact deposition transcript of defendant Christopher Harrington 0.1 12/21/2020 Review and download Motion to Withdraw Former Assistant Attorney General Michael Charles Stephenson, Judge Chang orders, redacted transcript of defendant Christopher Harrington 0.1 12/21/2020 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 12/24/2020 Review and download Notification of Change of Attorney Address or Name for attorney Andrea Campbell 0.1 1/5/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 1/5/2021 Draft and send email to defendants' attorneys 0.1 1/6/2021 Review IDOC defendants' reply in support of their motion for summary judgment 0.3 1/6/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/7/2021 Review and download Defendant City of Chicago and Indvidual Defendant Chicago Police Officers Opposed First Motion for Extension of Time to Reply in Further Support of their Motion for Summary Judgment and to Respond to Plaintiff's Motion for Summary Judgment 0.1 1/8/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/8/2021 Draft and send email to attorney Irene K. Dymkar X 0.1 1/8/2021 Review email from attorney Irene K. Dymkar 0.1 1/8/2021 Draft and send email to Judge Chang's courtroom deputy 0.1 1/11/2021 Review Judge Chang orders 0.1 1/11/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 1/11/2021 Review IDOC defendants' response to plaintiffs' motion for summary judgment 1.2 1/11/2021 Draft supplement to motion to dismiss 0.6 1/12/2021 Draft response to IDOC defendants' statement of additional facts 4.1 1/12/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 1/12/2021 Telephone conference with defendants' attorneys 0.3 1/12/2021 Draft and send email to attorney Irene K. Dymkar 0.1 81 1/13/2021 Draft response to IDOC defendants' statement of additional facts 1.3 1/13/2021 Draft and send email to attorney Irene K. Dymkar 0.1 1/13/2021 Draft reply in support of plaintiffs' motion for summary judgment 1.8 1/13/2021 Review IDOC defendants' response to plaintiffs' motion for summary judgment 0.3 1/13/2021 Review plaintiffs' memorandum of law in support of motion for summary judgment 0.3 1/13/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.4 1/13/2021 Conduct legal research for summary judgment reply 0.2 1/14/2021 Review and download Defendant City of Chicago and Individual Defendant Chicago Police Officers Response to Plaintiff's Supplement to Plaintiff's Motion to Voluntarily Dismiss Defendants Jacob Walls and Steven E. Suvada from the Case, Without Costs 0.2 1/14/2021 Draft reply in support of plaintiffs' motion for summary judgment 3.9 1/14/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.7 1/14/2021 Review multiple deposition transcripts and deposition abstracts 0.5 1/14/2021 Conduct legal research for summary judgment reply 0.2 1/14/2021 Draft response to IDOC defendants' statement of additional facts 0.5 1/15/2021 Draft response to IDOC defendants' statement of additional facts 2.0 1/15/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.5 1/15/2021 Draft reply in support of plaintiffs' motion for summary judgment 2.0 1/15/2021 Conduct legal research for summary judgment reply 0.3 1/18/2021 Review Judge Chang order, update calendar 0.1 1/18/2021 Review IDOC defendants' reply in support of their motion for summary judgment 0.3 1/18/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 1/18/2021 Review plaintiffs' memorandum of law in support of motion for summary judgment 0.4 1/18/2021 Review IDOC defendants' response to plaintiffs' motion for summary judgment 0.3 1/18/2021 Draft and send email to attorney Irene K. Dymkar 0.1 1/19/2021 Review Plaintiffs' Response to Defendant Parole Agents Harrington and Walls' Local Rule 56.1(b)(3)(C) Statement of Additional Facts and Plaintiffs' Memorandum of Law in Reply to Defendant Parole Agents Harrington and Walls' Response in Opposition to Plaintiffs' Motion for Summary Judgment 0.4 1/28/2021 Draft and send email to defendants' attorneys 0.1 1/28/2021 Draft motion for extension of time to file reply in support of plaintiffs' motion to dismiss 0.7 1/29/2021 Edit and finalize motion for extension of time to file reply in support of plaintiffs' motion to dismiss 0.3 2/1/2021 Review Judge Chang order, update calendar 0.1 2/8/2021 Draft reply in support of plaintiffs' motion to dismiss 0.9 2/8/2021 Conduct legal research regarding dismissed parties and costs 0.7 2/8/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.3 82 2/8/2021 Draft and send email to attorney Irene K. Dymkar 0.3 2/9/2021 Conduct legal research regarding dismissed parties and costs 1.3 2/9/2021 Draft and send email to attorney Irene K. Dymkar 0.3 2/9/2021 Discuss case and strategy with attorney Irene K. Dymkar x 0.1 2/10/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.4 2/10/2021 Select, prepare, and redact exhibits for reply in support of plaintiffs' motion to dismiss 0.6 2/10/2021 Review and download invoice for deposition of defendant Walls' continuation deposition 0.1 2/11/2021 Review and download Plaintiffs' Reply in Support of Plaintiffs' Motion to Voluntarily Dismiss Defendants Jacob Walls and Steven E. Suvada from the Case, Without Costs 0.1 3/8/2021 Draft and send email to attorney Irene K. Dymkar 0.1 3/9/2021 Draft reply in support of plaintiffs' motion for summary judgment as to City defendants 0.4 3/9/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.2 3/9/2021 Draft and send email to defendants' attorneys 0.1 3/10/2021 Draft response to City defendants' statement of additional facts 2.8 3/11/2021 Review Judge Chang order 0.1 3/12/2021 Review City Defendants' Combined Reply in Support of Their Motion for Summary Judgment and Response in Opposition to Plaintiffs' Motion for Summary Judgment 0.4 3/15/2021 Draft response to City defendants' statement of additional facts 2.0 3/16/2021 Draft response to City defendants' statement of additional facts 2.9 3/16/2021 Draft and send email to attorney Irene K. Dymkar 0.1 3/16/2021 Review City defendants' response to plaintiffs' motion for summary judgment and reply in support of their motion for summary judgment 0.3 3/18/2021 Review City defendants' response to plaintiffs' motion for summary judgment and reply in support of their motion for summary judgment 0.4 3/18/2021 Review plaintiffs' response to City defendants' motion for summary judgment 0.1 3/18/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.2 3/19/2021 Review plaintiffs' response to City defendants' motion for summary judgment 0.4 3/19/2021 Review plaintiffs' memorandum of law in support of motion for summary judgment 0.4 3/19/2021 Conduct legal research for reply in support of plaintiffs' motion for summary judgment as to City defendants 0.3 3/19/2021 Draft plaintiffs' reply in support of plaintiffs' motion for summary judgment as to City defendants 1.6 3/22/2021 Draft plaintiffs' reply in support of plaintiffs' motion for summary judgment as to City defendants 0.3 3/23/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.2 3/23/2021 Draft and send email to defendants' attorneys 0.1 3/23/2021 Draft motion for extension of time to file reply in support of plaintiffs' motion for summary judgment as to City defendants 0.9 3/24/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 83 3/25/2021 Review Judge Chang order, update calendar 0.1 3/25/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.5 3/25/2021 Draft motion to correct plaintiffs' response to City defendants' statement of additional facts 0.3 3/25/2021 Prepare exhibits and table of contents for plaintiffs' reply in support of motion for summary judgment as to City defendants 1.2 3/25/2021 Draft and send email to attorney Irene K. Dymkar 0.1 4/1/2021 Review Memorandum Opinion and Order, update calendar 0.4 4/1/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 4/6/2021 Discuss case and strategy with attorney Irene K. Dymkar x 0.1 4/7/2021 Review Judge Chang order 0.1 4/7/2021 Draft status report 0.3 4/7/2021 Perform legal research re evidence preservation motion 0.6 4/7/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 4/7/2021 Perform legal research re evidence preservation motion 0.7 4/8/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 4/8/2021 Review emails from attorney Irene K. Dymkar to defendant's counsel 0.1 4/9/2021 Telephone conference with attorney for defendant, Kelly Bauer 0.1 4/9/2021 Draft and send email to defendant's attorney 0.1 4/9/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 4/9/2021 Review status report with defendant's edits 0.1 4/9/2021 Edit status report 0.2 5/3/2021 Review City Defendants' Bill of Costs and Defendants' Memorandum in Support of Their Bill of Costs 0.1 5/3/2021 Review Memorandum Opinion and Order regarding summary judgment 0.7 5/3/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 5/4/2021 Review Judge Chang orders, update calendar 0.1 5/4/2021 Conduct legal research regarding costs 0.2 5/4/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 5/6/2021 Review Judge Chang Order Referring a Civil Case to the Designated Magistrate Judge, Transfer of Case to the Executive Committee for a Referral to Magistrate Judge 0.1 5/6/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.2 5/7/2021 Review Judge Cox order, update calendar 0.1 5/7/2021 Draft and send email to attorney Irene K. Dymkar 0.1 5/7/2021 Draft and send email to Judge Cox's courtroom deputy 0.1 5/7/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 5/17/2021 Draft and send email to attorney Irene K. Dymkar 0.1 5/17/2021 Review Judge Cox order, update calendar 0.1 5/18/2021 Review Judge Cox website on standing orders regarding settlement conferences 0.2 5/18/2021 Draft and send email to attorney Irene K. Dymkar 0.1 5/20/2021 Review Judge Chang order, update calendar 0.1 5/20/2021 Draft and send email to attorney Irene K. Dymkar 0.1 5/21/2021 Telephone conference with plaintiff, Charles Hill 0.1 5/21/2021 Draft and send email to attorney Irene K. Dymkar 0.1 5/25/2021 Telephone conference with plaintiff, Donna Hill 0.1 6/15/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/22/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 6/23/2021 Draft and send email to attorney Irene K. Dymkar 0.2 84 6/23/2021 Contact Illinois Attorney General's Officer to determine new email address for defendant's attorney, Kelly Bauer 0.1 6/23/2021 Draft and send email to defendant's attorney Kelly Bauer 0.1 6/23/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/12/2021 Review settlement offer from defendant 0.1 7/14/2021 Review Judge Cox's standing order on settlement 0.2 7/14/2021 Draft and send email to Judge Cox's courtroom deputy 0.1 7/15/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/16/2021 Draft and send email to Judge Cox's courtroom deputy 0.1 7/19/2021 Plaintiffs' counsel's telephone conference with Judge Cox regarding settlement 0.5 7/19/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.3 7/19/2021 Telephone conference with plaintiff, Charles Hill 0.1 7/19/2021 Draft and send email to attorney Irene K. Dymkar 0.1 7/20/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 7/20/2021 Telephone conference with plaintiff, Charles Hill 0.1 7/20/2021 Review and download Judge Cox order, update calendar 0.1 7/20/2021 Draft and send email to attorney Irene K. Dymkar 0.1 7/21/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/22/2021 Review and download Judge Chang order, update calendar 0.1 7/22/2021 Draft status report 0.1 7/26/2021 Draft and send email to attorney Irene K. Dymkar 0.1 7/27/2021 Draft and send email to attorney Irene K. Dymkar 0.2 7/27/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 7/28/2021 Draft and send email to attorney Irene K. Dymkar 0.1 7/28/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 7/29/2021 Draft and send email to defendant's attorney 0.2 7/29/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.2 7/29/2021 Telephone conference with plaintiff, Charles Hill 0.1 8/4/2021 Review Judge Chang order, update calendar 0.1 8/4/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 8/10/2021 Draft status report 0.4 8/10/2021 Draft and send email to attorney Irene K. Dymkar 0.1 8/12/2021 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 8/12/2021 Edit status report 0.1 8/12/2021 Draft and send email to defendant's attorney 0.1 8/13/2021 Review status report with defendant's edits 0.1 8/13/2021 Draft and send emails to attorney Irene K. Dymkar X 0.2 8/13/2021 Edit status report 0.2 8/16/2021 Draft and send email to defendant's attorney 0.1 8/16/2021 Telephone conference with plaintiff, Charles Hill 0.1 8/16/2021 Finalize status report 0.1 8/19/2021 Review Judge Chang order, update calendar 0.1 8/23/2021 Discuss case and strategy with attorney Irene K. Dymkar 0.1 9/2/2021 Draft trial witness list, review file regarding possible witnesses 0.8 9/2/2021 Draft and send email to attorney Irene K. Dymkar 0.2 11/12/2021 Draft and send email to attorney Irene K. Dymkar 0.1 11/22/2021 Review Judge Chang's standing order on pretrial orders 0.3 11/22/2021 Draft pretrial order and attachments to pretrial order 2.2 11/29/2021 Draft pretrial order and attachments to pretrial order 2.0 1/4/2022 Draft and send email to attorney Irene K. Dymkar 0.1 1/12/2022 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 1/12/2022 Telephone conference with plaintiff, Charles Hill 0.2 1/12/2022 Telephone conference with plaintiff, Donna Hill 0.1 85 1/12/2022 Draft and send email to attorney Irene K. Dymkar 0.1 1/18/2022 Review Notice of Substitution of Counsel Within the Same Agency Pursuant to Local Rule 83.17 0.1 1/18/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.1 1/19/2022 Review deposition transcript of witness Steve Martinez 0.8 1/20/2022 Review deposition transcript of witness Steve Martinez 1.4 1/20/2022 Draft and send email to attorney Irene K. Dymkar regarding witness Steve Martinez 0.3 1/20/2022 Review deposition transcript of witness Thomas Nowak 1.2 1/20/2022 Draft and send email to attorney Irene K. Dymkar regarding witness Thomas Nowak 0.1 1/21/2022 Review deposition transcript of witness Thomas Nowak 0.3 1/21/2022 Draft and send email to attorney Irene K. Dymkar regarding witness Thomas Nowak 0.1 1/24/2022 Draft status report 0.2 1/28/2022 Draft and send email to attorney Irene K. Dymkar 0.1 2/1/2022 Draft and send email to attorney Irene K. Dymkar 0.2 2/1/2022 Edit status report 0.1 2/1/2022 Draft and send email to defendant's attorneys 0.1 2/2/2022 Review attorney appearance for defendant's attorney Hal Dworkin, Notice of Substitution of Counsel Within the Same Agency Pursuant to Local Rule 83.17 0.1 2/3/2022 Review and download status report with defendant's edits 0.1 2/3/2022 Edit status report 0.2 2/4/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.1 2/7/2022 Review Judge Chang order, update calendar 0.1 2/11/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.3 2/17/2022 Draft verdict form 0.4 2/17/2022 Review Memorandum Opinion and Order regarding summary judgment 0.2 2/18/2022 Review deposition transcript of witness Rodney Alexander, take notes on transcript 2.3 2/18/2022 Review deposition transcript of witness Kevin Bond, take notes on transcript 1.0 2/18/2022 Review deposition transcript of witness Marcus Cotton, take notes on transcript 0.8 2/18/2022 Review deposition transcript of witness Tammie Howard, take notes on transcript 0.8 2/21/2022 Review deposition transcript of witness Danjwan Johnson, take notes on transcript 0.3 2/22/2022 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 2/24/2022 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 3/3/2022 Telephone conference with plaintiff, Charles Hill 0.1 3/3/2022 Telephone conference with witness Shatrion Hill 0.1 3/4/2022 Review deposition transcript of witness Danjwan Johnson, take notes on transcript 0.9 3/4/2022 Review deposition transcript of witness Tamika Johnson, take notes on transcript 0.6 3/7/2022 Review deposition transcript of witness Tamika Johnson, take notes on transcript 1.3 3/7/2022 Review deposition abstract of witness Simon Mbi, take notes on abstract 0.1 3/8/2022 Review deposition abstract of witness Simon Mbi, take notes on abstract 1.2 86 3/9/2022 Review deposition transcript of witness James Noble, take notes on transcript 3.7 3/9/2022 Review deposition transcript of witness Felisha Parker, take notes on transcript 1.6 3/9/2022 Review deposition abstract of witness Donna Rixey, take notes on abstract 1.4 3/10/2022 Review deposition abstract of witness Rixie Davis, take notes on abstract 0.7 3/10/2022 Draft and send emails to attorney Irene K. Dymkar (2) 0.3 3/10/2022 Telephone conference with witness Shatrion Hill 0.1 3/10/2022 Telephone conference with plaintiff, Donna Hill 0.1 3/10/2022 Telephone conference with witness Keitrion Lewis 0.1 3/10/2022 Draft letter to witness, Keitrion Lewis, with enclosures 0.3 3/10/2022 Trial planning meeting with attorney Irene K. Dymkar 0.3 3/10/2022 Telephone conference with witness Shatrion Hill 0.1 3/10/2022 Telephone conference with plaintiff, Charles Hill 0.1 3/10/2022 Draft and send email to witness Shatrion Hill 0.1 3/11/2022 Review Judge Chang's standing order on pretrial orders 0.3 3/11/2022 Draft jury instructions 0.5 3/15/2022 Draft and send email to attorney Irene K. Dymkar 0.1 4/5/2022 Review Judge Chang's standing order on pretrial orders 0.1 4/5/2022 Draft exhibit list to pretrial order 1.8 4/7/2022 Draft and send emails to attorney Irene K. Dymkar (2) 0.2 4/7/2022 Draft exhibit list to pretrial order 0.8 4/7/2022 Review Judge Chang order, update calendar 0.1 4/7/2022 Draft witness list to pretrial order 0.8 4/7/2022 Review draft verdict form 0.1 4/7/2022 Draft jury instructions 0.4 4/8/2022 Draft jury instructions 2.0 4/8/2022 Trial planning meeting with attorney Irene K. Dymkar 0.4 4/8/2022 Draft and send email to process server Lynn Bagley 0.1 4/8/2022 Draft and send email to defendant's attorneys 0.1 4/8/2022 Draft and send email to attorney Irene K. Dymkar 0.1 4/18/2022 Trial planning meeting with attorney Irene K. Dymkar 0.4 4/19/2022 Telephone conference with plaintiff, Donna Hill 0.1 4/20/2022 Trial planning meeting with attorney Irene K. Dymkar 0.3 4/20/2022 Draft and send email to defendant's attorneys 0.1 4/20/2022 Draft and send email to IDOC legal counsel, Delcine Thompson, regarding serving trial subpoenas 0.1 4/20/2022 Confer with civil rights colleagues regarding serving trial subpoenas on IDOC witnesses 0.2 4/20/2022 Draft stipulations for pretrial order 1.4 4/21/2022 Draft stipulations for pretrial order 2.3 4/21/2022 Draft and send email to process server Lynn Bagley 0.1 4/22/2022 Draft stipulations for pretrial order 0.6 4/22/2022 Draft and send email to attorney Irene K. Dymkar 0.1 4/22/2022 Prepare list of IDOC witnesses to subpoena for trial 0.1 4/25/2022 Draft trial subpoenas for witnesses (multiple) 1.2 4/25/2022 Draft letters to trial witnesses (multiple) 0.8 4/25/2022 Draft and send email to defendant's attorneys 0.1 4/25/2022 Draft and send emails to attorney Irene K. Dymkar 0.3 4/25/2022 Draft jury instructions 1.8 4/25/2022 Edit witness list for pretrial order 0.4 4/25/2022 Trial planning meeting with attorney Irene K. Dymkar 0.7 4/25/2022 Draft and send email to process server Lynn Bagley 0.1 87 4/25/2022 Review trial subpoenas and letters to witnesses (multiple) 0.8 4/26/2022 Draft and send email to process server Lynn Bagley 0.2 4/26/2022 Draft and send email to defendant's attorneys 0.1 4/26/2022 Telephone conference with plaintiff, Donna Hill 0.1 4/26/2022 Telephone conference with defendant's attorney, Hal Dworkin 0.1 4/26/2022 Trial planning meeting with attorney Irene K. Dymkar 0.3 4/26/2022 Telephone conference with witness Shatrion Hill 0.1 4/26/2022 Prepare trial subpoenas for witnesses Steven Suvada and John Gartner 0.2 4/26/2022 Telephone conference with process server Lynn Bagley 0.2 4/26/2022 Edit witness list for pretrial order 0.4 4/26/2022 Draft and send email to attorney Irene K. Dymkar 0.1 4/26/2022 Edit exhibit list for pretrial order 1.0 4/26/2022 Draft and send email to IDOC legal counsel, Gwendolyn Drake, regarding serving trial subpoenas on IDOC witnesses 0.1 4/26/2022 Telephone conference with plaintiff, Donna Hill 0.1 4/27/2022 Draft status report 0.3 4/27/2022 Draft and send emails to attorney Irene K. Dymkar (3) 0.4 4/27/2022 Draft and send email to defendant's attorneys 0.1 4/27/2022 Review attorney appearance for defendant's attorney Maggie Jones 0.1 4/27/2022 Draft motions in limine 0.8 4/28/2022 Draft and send email to process server Lynn Bagley 0.2 4/28/2022 Trial planning meeting with attorney Irene K. Dymkar 0.8 4/28/2022 Draft status report 0.1 4/28/2022 Confer with civil rights colleagues regarding recovering evidence from Evidence Recovery and Property Section ("ERPS") 0.2 4/28/2022 Telephone conference with witness Felisha Parker 0.1 4/28/2022 Telephone conference with witness Keitrion Lewis 0.2 4/28/2022 Draft and send email to attorney Irene K. Dymkar 0.1 4/28/2022 Edit witness list for pretrial order 0.1 4/28/2022 Review and designate deposition for deceased witness, Odell Dollerson 0.5 4/29/2022 Review emails from attorney Irene K. Dymkar 0.1 4/29/2022 Review and designate deposition for deceased witness, Odell Dollerson 1.7 4/29/2022 Edit and finalize status report 0.2 4/29/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/2/2022 Trial planning meeting with attorney Irene K. Dymkar 0.5 5/2/2022 Meet and confer with defendant's attorneys for pretrial order 1.0 5/3/2022 Draft motions in limine 0.2 5/3/2022 Telephone conference with IDOC witness Marcus Cotton 0.1 5/4/2022 Review Judge Chang order, update calendar 0.1 5/4/2022 Draft and send emails to attorney Irene K. Dymkar (3) 0.3 5/4/2022 Draft motions in limine 0.5 5/4/2022 Trial planning meeting with attorney Irene K. Dymkar 0.5 5/4/2022 Review stipulations with defendant's edits 0.1 5/4/2022 Draft motion for extension of time to file pretrial order 0.8 5/4/2022 Review emails from attorney Irene K. Dymkar and defendant's attorneys regarding motion for extension 0.2 5/4/2022 Finalize motion for extension 0.1 88 5/5/2022 Review Judge Chang order, update calendar 0.1 5/5/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.3 5/5/2022 Telephone court status hearing 0.5 5/6/2022 Review Judge Chang order, update calendar 0.1 5/6/2022 Draft and send email to IDOC legal counsel Gwendolyn Drake regarding serving subpoenas on IDOC witnesses 0.1 5/6/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.3 5/6/2022 Draft and send emails to attorney Irene K. Dymkar (2) 0.2 5/6/2022 Review emails from Irene K. Dymkar and defendant's attorneys regarding technical issues with hearing (multiple) 0.1 5/6/2022 Prepare chart of status of issuance and services of non-party trial subpoenas 0.7 5/6/2022 Prepare chart of IDOC administrative and institutional directives for use in preparing pre-trial order 1.5 5/6/2022 Draft and send email to process server Lynn Bagley 0.1 5/9/2022 Draft motions in limine 1.0 5/9/2022 Trial planning meeting with attorney Irene K. Dymkar 1.0 5/9/2022 Draft and send emails to attorney Irene K. Dymkar regarding trial exhibits, motion in limine research (multiple) 0.9 5/9/2022 Review Judge Chang order 0.1 5/9/2022 Review deposition abstract of plaintiff Charles Hill 0.9 5/9/2022 Review draft demonstrative diagram of plaintiffs' house 0.2 5/9/2022 Review deposition abstract of witness Shatrion Hill 0.7 5/9/2022 Review emails from attorney Irene K. Dymkar regarding pretrial order 0.1 5/9/2022 Conduct legal research regarding curtilage 0.5 5/10/2022 Review emails from attorney Irene K. Dymkar regarding pretrial order 0.1 5/10/2022 Draft and send email to defendant's attorneys 0.1 5/10/2022 Review deposition abstract of plaintiff Charles Hill 0.4 5/10/2022 Review deposition abstract of witness Shatrion Hill 0.2 5/10/2022 Draft and send emails to attorney Irene K. Dymkar regarding trial exhibits (multiple) 0.6 5/10/2022 Edit demonstrative chart of seized guns and ammunition by cross-referencing depositions, inventory reports, and incident/arrest reports 2.4 5/10/2022 Trial planning meeting with attorney Irene K. Dymkar 0.8 5/10/2022 Edit verdict sheet 0.2 5/11/2022 Review plaintiffs' witness list with defendant's objections 0.4 5/11/2022 Attempts to contact IDOC witness Felisha Parker 0.1 5/11/2022 Attempts to contact IDOC witness Tamika Johnson 0.1 5/11/2022 Review emails from attorney Irene K. Dymkar and defendant's attorneys regarding pretrial order 0.1 5/11/2022 Zoom meeting with defendant's attorneys 1.2 5/11/2022 Discuss case and strategy with attorney Irene K. Dymkar 0.9 5/11/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/11/2022 Telephone conference with IDOC witness Simon Mbi 0.2 5/11/2022 Telephone conference with plaintiff, Donna Hill 0.1 5/11/2022 Draft and send email to process server Lynn Bagley 0.1 5/11/2022 Draft motions in limine 1.2 5/11/2022 Review Judge Chang's standing order on pretrial orders 0.1 5/11/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 5/12/2022 Review deposition transcript of witness Gertha Brady 0.1 89 5/12/2022 Draft and send email to process server Lynn Bagley 0.1 5/12/2022 Telephone conference with Office of Emergency Management and Communications regarding witness Erin Hansen 0.1 5/12/2022 Trial planning meeting with attorney Irene K. Dymkar 0.4 5/12/2022 Draft additional trial subpoenas 0.1 5/12/2022 Draft and send email to attorney Michele McGee regarding securing appearance of CPD trial witnesses 0.1 5/12/2022 Draft jury instructions 0.4 5/12/2022 Print color photographs of disarray in plaintiffs' home 0.1 5/12/2022 Draft and send email to defendant's attorneys 0.1 5/12/2022 Telephone conference with IDOC witness Felisha Parker 0.1 5/12/2022 Telephone conference with plaintiff, Charles Hill 0.1 5/12/2022 Review, organize by room, and select photographs of disarray to use at trial, with attorney Irene K. Dymkar 0.6 5/12/2022 Letter to client, Charles Hill, with copies of photographs of disarray, for correct identification 0.5 5/13/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/13/2022 Draft jury instructions 1.3 5/13/2022 Conduct legal research regarding illegal seizure 0.7 5/13/2022 Review Memorandum Opinion and Order regarding summary judgment 0.5 5/13/2022 Review Memorandum Opinion and Order regarding motion to dismiss 0.2 5/13/2022 Trial planning meeting with attorney Irene K. Dymkar 0.7 5/13/2022 Draft and send email to attorney Michele McGee regarding securing attendance of CPD trial witnesses 0.2 5/13/2022 Review plaintiffs' proposed statement of the case with defendant's edits 0.1 5/13/2022 Review and designate deposition for deceased witness Erin Hansen 0.8 5/13/2022 Telephone conference with plaintiff, Charles Hill 0.2 5/15/2022 Review and designate deposition for deceased witness Erin Hansen 2.8 5/15/2022 Review and revise plaintiffs' exhibit list 0.1 5/15/2022 Telephone conference with plaintiff, Charles Hill 0.8 5/15/2022 Draft and send emails to attorney Irene K. Dymkar 0.3 5/16/2022 Draft motions in limine 4.1 5/16/2022 Conduct legal research regarding motions in limine 0.4 5/16/2022 Draft and send emails to attorney Irene K. Dymkar (multiple) 0.3 5/16/2022 Trial planning meeting with attorney Irene K. Dymkar (3) 0.8 5/16/2022 Review file regarding multiple photographs of ammunition box 0.2 5/16/2022 Review information about plaintiffs' home on Cook County Recorder website 0.2 5/16/2022 Conduct legal research regarding curtilage 0.5 5/16/2022 Update demonstrative chart of seized guns and ammunition 0.2 5/17/2022 Draft and send multiple emails to attorney Irene K. Dymkar regarding pretrial order, trial exhibits, trial witnesses, research for jury instructions and motions in limine, and trial subpoenas 1.0 5/17/2022 Edit chart of status of trial subpoenas regarding issuance and service and witness response 0.3 90 5/17/2022 Draft and send email to defendant's attorneys regarding Zoom inspection photos, and organize and Bates-stamp photos 0.4 5/17/2022 Review defendant's proposed exhibit list, defendant's additions to jury instructions 0.2 5/17/2022 Telephone conference with IDOC witness Donna Rixey 0.1 5/17/2022 Trial planning meeting with attorney Irene K. Dymkar (4) 1.2 5/17/2022 Telephone conference with witness Keitrion Lewis 0.1 5/17/2022 Telephone conference with plaintiff, Charles Hill 0.4 5/17/2022 Review demonstrative photographs of outside of plaintiffs' home received from plaintiff Charles Hill 0.4 5/17/2022 Draft and send email to defendant's attorneys regarding photographs of plaintiffs' home and witness Gertha Brady's home and Bates-stamp photos 0.2 5/17/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.1 5/17/2022 Conduct legal research regarding curtilage 0.5 5/17/2022 Telephone conference with IDOC witness Rixie Davis 0.1 5/17/2022 Draft and send email to defendant's attorneys regarding voir dire 0.1 5/17/2022 Review deposition transcript of defendant Christopher Harrington 0.4 5/17/2022 Review and revise chart of seized guns and ammunition 0.1 5/17/2022 Review defendant's proposed voir dire 0.2 5/17/2022 Edit and revise motions in limine 0.2 5/18/2022 Review and revise plaintiffs' exhibit list 0.2 5/18/2022 Draft and send emails to attorney Irene K. Dymkar regarding pretrial order, deposition designations for witness Steve Martinez and witness Odell Dollerson 0.4 5/18/2022 Review defendant's counter designations and objections to Martinez and Dollerson designations, defendant's final edits to stipulations, plaintiffs' witness list with defendant's objections 0.4 5/18/2022 Trial planning meeting with attorney Irene K. Dymkar (5) 0.7 5/18/2022 Edit plaintiffs' exhibit list 0.1 5/18/2022 Draft and send email to defendants regarding exhibit list 0.1 5/18/2022 Review Judge Chang's standard voir dire 0.1 5/18/2022 Review plaintiffs' proposed voir dire 0.3 5/18/2022 Edit pretrial order 0.3 5/18/2022 Prepare final proposed voir dire 0.6 5/18/2022 Telephone conference with attorney Daniel Berkowitz regarding voir dire 0.2 5/18/2022 Draft and send email to defendant's attorneys regarding voir dire 0.1 5/18/2022 Edit trial stipulations 0.1 5/18/2022 Edit plaintiffs' witness list 0.2 5/18/2022 Draft and send email to defendant's attorneys regarding stipulations and witness lists 0.1 5/18/2022 Edit jury instructions 0.2 5/18/2022 Draft and send email to defendant's attorneys regarding jury instructions 0.1 5/18/2022 Finalize chart of seized weapons and ammunition 0.2 5/18/2022 Draft and send email to defendant's attorneys regarding demonstrative exhibits 0.1 5/18/2022 Finalize voir dire 0.2 91 5/18/2022 Finalize exhibit list 0.3 5/18/2022 Draft and send email to defendant's attorneys regarding final pretrial order exhibits 0.2 5/18/2022 Draft and send email to defendant's attorneys regarding motions in limine 0.1 5/18/2022 Review deposition transcript of witness Erin Hansen 0.3 5/18/2022 Draft and send email to defendant's attorneys regarding stipulation of witness Erin Hansen's testimony 0.1 5/18/2022 Draft objections to defendant's counter designations for deposition of witness Steve Martinez 0.7 5/18/2022 Draft objections to defendant's counter designations for deposition of witness Odell Dollerson 0.4 5/18/2022 Discuss Martinez and Dollerson deposition designations with attorney Irene K. Dymkar 0.7 5/18/2022 Finalize deposition designations 0.4 5/18/2022 Draft and send email to defendant's attorneys regarding deposition designations 0.1 5/18/2022 Organize for filing and file final pretrial order, with all attached exhibits 0.4 5/19/2022 Discuss case and strategy with attorney Irene K. Dymkar X 0.7 5/19/2022 Telephone conference with Officer McKinney at ERPS 0.1 5/19/2022 Draft and send emails to attorney Irene K. Dymkar 0.3 5/19/2022 Draft motion for leave to file additional motions in limine 1.6 5/19/2022 Review defendant's motions in limine 0.4 5/19/2022 Draft responses to defendant's motions in limine 0.6 5/19/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 5/20/2022 Conduct legal research regarding responses to defendant's motions in limine 0.6 5/20/2022 Draft responses to defendant's motions in limine 2.0 5/20/2022 Trial planning meeting with attorney Irene K. Dymkar (3) 0.8 5/20/2022 Edit motion for leave to file additional motions in limine 0.6 5/20/2022 Prepare exhibits of admissions for motion in limine regarding Requests to Admit 0.4 5/20/2022 Conduct legal research regarding emotional damages 0.3 5/20/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/23/2022 Draft responses to defendant's motions in limine 0.3 5/23/2022 Analyze reports and transcripts to prepare chart of where "L13" and "Harrington" appear in record 3.8 5/23/2022 Trial planning meeting with attorney Irene K. Dymkar 0.3 5/23/2022 Review deposition transcript of defendant Christopher Harrington 0.1 5/23/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/23/2022 Select and prepare exhibits for additional motions in limine 0.1 5/23/2022 Review deposition transcript of witness Scott Liebhaber 0.9 5/23/2022 Draft supplement to motion for leave to file additonal motions in limine 0.2 5/24/2022 Review deposition transcript of witness Scott Liebhaber 0.5 5/24/2022 Prepare chart of where "L13" and "Harrington" appear in record 0.5 5/24/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/25/2022 Review defendant's motions in limine 0.2 5/25/2022 Draft and send emails to attorney Irene K. Dymkar regarding motions in limine, exhibits, witnesses, exhibit transcripts, deposition designations 0.8 92 5/25/2022 Review plaintiffs' responses to defendant's motions in limine 0.4 5/25/2022 Review Judge Chang's standing order on JERS system 0.1 5/25/2022 Update chart of status of trial subpoenas, issuance and service and witness response 0.2 5/25/2022 Review plaintiffs' exhibit list 0.1 5/25/2022 Prepare exhibit book for Judge Chang, including organizing photographs and adding exhibit labels 4.1 5/25/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 5/25/2022 Finalize responses to defendant's motions in limine 0.1 5/25/2022 Draft and send email to In Demand Reporting regarding problems with deposition transcript of IDOC witness Simon Mbi 0.1 5/26/2022 Review Defendant's Responses to Plaintiffs' Motions in Limine 0.5 5/26/2022 Review Judge Chang's standing order on pretrial orders 0.1 5/26/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/26/2022 Prepare exhibit book for Judge Chang, including organizing photographs and adding exhibit labels 1.5 5/26/2022 Review defendant's exhibit list 0.1 5/26/2022 Draft and send email to IDOC witness Simon Mbi 0.1 5/26/2022 Draft and send email to IDOC witness Donna Rixey 0.1 5/26/2022 Leave voicemail message for IDOC witness Tamika Johnson re trial testimony 0.1 5/26/2022 Prepare binder of objected-to exhibits for Judge Chang 1.5 5/26/2022 Trial planning meeting with attorney Irene K. Dymkar 0.5 5/26/2022 Draft motion to substitute exhibit list 0.8 5/26/2022 Telephone conference with IDOC witness Jacob Walls 0.1 5/26/2022 Update chart of status of trial subpoenas, issuance and service and witness response 0.1 5/26/2022 Edit plaintiffs' substitute exhibit list 0.6 5/27/2022 Prepare exhibit book for Judge Chang, including organizing photographs and adding exhibit labels, and prepare electronic copies of exhibit book 1.2 5/27/2022 Review defendant's responses to plaintiffs' motions in limine 0.4 5/27/2022 Trial planning meeting with attorney Irene K. Dymkar 0.6 5/27/2022 Draft reply in support of plaintiffs' motions in limine 0.5 5/27/2022 Edit additional motions in limine to refile 0.3 5/27/2022 Review deposition abstract of IDOC witness Donna Rixey 0.4 5/31/2022 Prepare exhibit book for Judge Chang, including organizing photographs and adding exhibit labels, and prepare electronic copies of exhibit book 1.3 5/31/2022 Trial planning meeting with attorney Irene K. Dymkar 0.7 5/31/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 5/31/2022 Telephone conference with IDOC witness Felisha Parker 0.1 5/31/2022 Draft reply in support of plaintiffs' motions in limine 1.2 5/31/2022 Review deposition abstract of IDOC witness Donna Rixey 0.2 5/31/2022 Review deposition abstract of defendant Christopher Harrington 0.2 5/31/2022 Review defendant's responses to plaintiffs' motions in limine 0.3 5/31/2022 Research armed habitual criminal statute 0.2 5/31/2022 Draft and send email to attorney Irene K. Dymkar 0.1 5/31/2022 Telephone conference with IDOC withess Rixie Davis 0.1 93 6/1/2022 Draft reply in support of plaintiffs' motions in limine 2.5 6/1/2022 Review deposition abstract of IDOC witness Rixie Davis 0.5 6/1/2022 Trial planning meeting with attorney Irene K. Dymkar 0.7 6/1/2022 Draft and send emails to attorney Irene K. Dymkar 0.2 6/1/2022 Prepare exhibits for plaintiffs' reply in support of motions in limine 0.1 6/1/2022 Telephone conference with plaintiff, Charles Hill 0.1 6/2/2022 Review Judge Chang order, update calendar 0.1 6/2/2022 Review defendant's reply in support of his motions in limine 0.2 6/2/2022 Trial planning meeting with attorney Irene K. Dymkar (3) 0.6 6/2/2022 Telephone conference with Judge Lefkow's courtroom deputy regarding other conflicting cases scheduled for trial 0.1 6/2/2022 Telephone conference with Judge Chang's courtroom deputy 0.1 6/2/2022 Review deposition abstract of witness Gertha Brady 0.2 6/2/2022 Prepare trial subpoenas for witnesses Thomas Nowak, Scott Liebhaber, and Elena McKenna 0.6 6/2/2022 Draft and send email to attorney Michele McGee regarding appearances of CPD trial witnesses 0.1 6/3/2022 Review emails from attorney Irene K. Dymkar to Sophia Darugar 0.1 6/3/2022 Review deposition abstract of witness Gertha Brady 0.2 6/6/2022 Review Judge Chang order 0.1 6/6/2022 Review deposition abstract of Thomas Nowak 0.1 6/6/2022 Review emails from attorney Irene K. Dymkar 0.1 6/6/2022 Trial planning meeting with attorney Irene K. Dymkar 1.3 6/6/2022 Update chart of status of trial subpoenas, issuance and service and witness response 0.1 6/6/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/6/2022 Review deposition abstract of witness Keitrion Lewis 2.0 6/6/2022 Review deposition abstract of plaintiff Donna Hill 0.1 6/7/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/7/2022 Review deposition videos of witnesses Erin Hansen and Scott Liebhaber for possible use at trial 0.3 6/7/2022 Review affidavits of service of subpoenas 0.1 6/7/2022 Review emails from attorney Irene K. Dymkar 0.1 6/7/2022 Trial planning meeting with attorney Irene K. Dymkar 1.2 6/7/2022 Draft and send email to defendant's attorneys 0.1 6/7/2022 Prepare documents for pretrial conference 2.4 6/7/2022 Telephone conference with IDOC witness Tammie Howard 0.1 6/7/2022 Zoom meeting with defendant's attorneys 0.5 6/7/2022 Update chart of status of trial subpoenas 0.1 6/7/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.1 6/7/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/7/2022 Telephone conference with witness Shatrion Hill 0.2 6/7/2022 Draft and send email to witness Shatrion Hill 0.1 6/7/2022 Telephone conference with witness Keitrion Lewis 0.1 6/7/2022 Prepare chart of motions in limine and rulings 0.3 6/8/2022 Review Judge Chang order 0.1 6/8/2022 Draft motion for leave to add exhibit 0.5 6/8/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/8/2022 Review Judge Chang's order on plaintiffs' motions in limine 0.3 94 6/8/2022 Review deposition designations for witness Odell Dollerson 0.5 6/8/2022 Trial planning meeting with attorney Irene K. Dymkar 1.3 6/8/2022 Review Judge Chang's order on defendant's motions in limine 0.3 6/8/2022 Review deposition designations for witness Steve Martinez 0.7 6/8/2022 Prepare for pretrial conference 1.2 6/8/2022 Pretrial conference 3.5 6/8/2022 Telephone conference with plaintiff, Charles Hill 0.2 6/8/2022 Leave voicemail message for plaintiff, Donna Hill 0.1 6/8/2022 Confer with civil rights colleagues regarding recovering evidence from Evidence Recovery and Property Section ("ERPS") 0.2 6/9/2022 Review Judge Chang orders, update calendar 0.1 6/9/2022 Draft and send emails to attorney Irene K. Dymkar regarding recovering plaintiff Charles Hill's weapons, research, witnesses 0.6 6/9/2022 Review notes from pretrial conference, determine action items 0.3 6/9/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.2 6/9/2022 Conduct legal research regarding hearsay 0.4 6/9/2022 Review deposition abstract of IDOC witness Rodney Alexander 0.1 6/9/2022 Review deposition video of defendant Christopher Harrington 1.8 6/9/2022 Trial planning meeting with attorney Irene K. Dymkar 0.9 6/9/2022 Draft and send email to Mike Lieschke from In Demand Court Reporting regarding preparing video clips 0.1 6/9/2022 Review emails from attorney Irene K. Dymkar 0.1 6/9/2022 Review deposition transcript of witness Cornesha Rice 0.8 6/10/2022 Draft and send email to Michael Ko from Groundwork Trial Consulting regarding preparing video clips 0.1 6/10/2022 Draft and send emails to attorney Irene K. Dymkar regarding recovering plaintiff Charles Hill's weapons, research, witnesses, video clips 0.6 6/10/2022 Prepare subpoenas for CPD trial witnesses to send to CPD Office of Legal Affairs because of difficulties obtaining assurances that witnesses would appear at trial 1.1 6/10/2022 Telephone conference with plaintiff, Donna Hill 0.1 6/10/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/10/2022 Telephone conference with Officers McKinney and Hampton at ERPS 0.3 6/10/2022 Leave voicemail message for Debra Glasper from City of Chicago Department of Law 0.1 6/10/2022 Discuss case and strategy with attorney Irene K. Dymkar 1.5 6/10/2022 Draft motion to add screenshot of IDOC witness Donna Rixey to plaintiffs' exhibit list 0.2 6/10/2022 Telephone conference with witness Keitrion Lewis 0.1 6/10/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.1 6/10/2022 Draft and send email to defendant's attorneys 0.1 6/10/2022 Draft and send email to IDOC legal counsel Gwendolyn Drake 0.1 6/10/2022 Telephone conference with Teri from True Productions 0.1 95 6/10/2022 Review deposition transcripts 0.7 6/12/2022 Draft motion for reconsideration regarding testimony of witness Cornesha Rice 0.9 6/12/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/12/2022 Review deposition transcripts of IDOC witnesses 0.4 6/12/2022 Review deposition transcript of witness Shatrion Hill 2.0 6/13/2022 Draft email to Judge Chang's courtroom deputy 0.1 6/13/2022 Review emails from attorney Irene K. Dymkar 0.1 6/13/2022 Review Judge Chang's standing order on pretrial orders 0.1 6/13/2022 Telephone conference with daughter of witness Gertha Brady 0.1 6/13/2022 Trial planning meeting with attorney Irene K. Dymkar 0.8 6/13/2022 Prepare for meeting with plaintiffs Charles Hill and Donna Hill 0.3 6/13/2022 Office meeting with plaintiffs Charles Hill and Donna Hill 2.1 6/13/2022 Draft letters to plaintiffs' employers regarding trial attendance 0.5 6/13/2022 Draft and send email to defendant's attorneys 0.1 6/13/2022 Review deposition abstract of IDOC witness Simon Mbi 0.6 6/13/2022 Draft and send emails to attorney Irene K. Dymkar 0.2 6/13/2022 Telephone conference with IDOC witness Tamika Johnson 0.1 6/13/2022 Update chart of status of trial subpoenas 0.1 6/13/2022 Review deposition abstract of witness Gertha Brady 0.4 6/13/2022 Update chart of motions in limine and rulings 1.0 6/14/2022 Draft and send email to Judge Chang's courtroom deputy 0.2 6/14/2022 Prepare final trial exhibits 0.3 6/14/2022 Leave voicemail message for IDOC witness Rodney Alexander 0.1 6/14/2022 Draft and send email to IDOC witness Rodney Alexander 0.3 6/14/2022 Draft and send emails to attorney Irene K. Dymkar 0.2 6/14/2022 Update chart of status of trial subpoenas 0.1 6/14/2022 Draft and send email to Alexander Zeier 0.1 6/14/2022 Prepare for meeting with witness Keitrion Lewis 0.2 6/14/2022 Trial planning meeting with attorney Irene K. Dymkar (2) 1.3 6/14/2022 Edit motion to add screenshot of IDOC witness Donna Rixey to exhibit list 0.3 6/14/2022 Prepare new trial subpoena for IDOC witness Rodney Alexander 0.1 6/14/2022 Office meeting with witness Keitrion Lewis 0.4 6/14/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.1 6/14/2022 Draft motion regarding playing video clips of defendant Christopher Harrington 0.6 6/14/2022 Draft and send email to defendant's attorneys 0.1 6/14/2022 Telephone conference with witness Shatrion Hill 0.1 6/14/2022 Draft motion for leave to designate deposition transcript of witness Gertha Brady 0.4 6/14/2022 Telephone conference with IDOC witness Rixie Davis 0.1 6/14/2022 Prepare exhibit books and electronic copies of exhibits for Judge Chang and defendant's attorneys 1.5 6/14/2022 Review deposition transcript of witness Shatrion Hill and prepare for meeting 2.3 6/15/2022 Review emails from attorney Irene K. Dymkar 0.1 6/15/2022 Prepare Dropbox link of deposition transcripts and videos of defendant Christopher Harrington 0.1 96 6/15/2022 Draft and send emails to attorney Irene K. Dymkar 0.2 6/15/2022 Telephone conference with IDOC witness James Noble 0.1 6/15/2022 Telephone conference with Officer Smith from the Chicago Police Department 0.1 6/15/2022 Prepare exhibit books and electronic copies of exhibits for Judge Chang and defendant's attorneys 1.8 6/15/2022 Trial planning meeting with attorney Irene K. Dymkar 0.8 6/15/2022 Office meeting with witness Shatrion Hill 2.1 6/15/2022 Draft and send email to witness Shatrion Hill 0.1 6/15/2022 Leave voicemail message for IDOC witness Rodney Alexander 0.1 6/15/2022 Draft motion regarding stipulation 0.5 6/15/2022 Draft and send email to Teri at True Productions 0.2 6/15/2022 Review and designate deposition transcript of witness Gertha Brady 1.7 6/16/2022 Review Defendant's Motion for Leave to Add Plaintiffs' Copy of the Chicago Police Department Inventory Report as Exhibit #43 to Defendant's Trial Exhibit List, and Defendant's Response to Plaintiffs' Supplement to their Motion in Limine No. 2 0.3 6/16/2022 Prepare exhibit books and electronic copies of exhibits for Judge Chang and defendant's attorneys 2.4 6/16/2022 Draft and send email to Sophia Darugar 0.1 6/16/2022 Trial planning meeting with attorney Irene K. Dymkar 0.9 6/16/2022 Draft and send email to Ian Davidson regarding video clips of deposition video of defendant Christopher Harrington 0.1 6/16/2022 Draft and send email to IDOC witness Kevin Bond 0.1 6/16/2022 Draft and send email to IDOC witness Marcus Cotton 0.1 6/16/2022 Telephone conference with IDOC witness Kevin Bond 0.1 6/16/2022 Telephone conference with Ian Davidson 0.2 6/16/2022 Telephone conference with IDOC witness Rodney Alexander 0.1 6/16/2022 Draft correction to motion regarding designations of deposition video of defendant Christopher Harrington 0.3 6/16/2022 Review video clips of deposition of defendant Christopher Harrington 0.1 6/16/2022 Prepare USB drives of plaintiffs' final trial exhibits for Judge Chang and defendant 0.7 6/16/2022 Review and designate deposition transcript of witness Gertha Brady 2.3 6/16/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/16/2022 Draft and send emails to IDOC agent witnesses regarding trial schedule and contact with Sophia Darugar (multiple) 0.4 6/17/2022 Telephone conference with process server Lynn Bagley 0.1 6/17/2022 Trial planning meeting with attorney Irene K. Dymkar 1.0 6/17/2022 Draft and send emails to IDOC witnesses regarding trial schedule and contact with Sophia Darugar (multiple) 0.5 6/17/2022 Zoom meeting with paralegal Sophia Darugar 0.6 6/17/2022 Update chart of status of trial subpoenas 0.2 6/17/2022 Prepare direct examination questions for witness Shatrion Hill 2.4 6/17/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/18/2022 Prepare subpoena and copy of deposition transcript for witness Cornesha Rice 0.5 6/18/2022 Draft and send email to witness Shatrion Hill 0.2 97 6/18/2022 Trial planning meeting with attorney Irene K. Dymkar 0.4 6/18/2022 Prepare direct examination questions for witness Shatrion Hill 1.5 6/18/2022 Drop off subpoena and deposition transcript for witness Cornesha Rice to process server Lynn Bagley 0.1 6/18/2022 Zoom meeting with witness Shatrion Hill 1.5 6/18/2022 Office meeting with plaintiffs Charles Hill and Donna Hill 0.1 6/18/2022 Review Judge Chang order on voir dire 0.1 6/18/2022 Prepare detailed trial contact information list, including court, court personnel, defense counsel, plaintiffs' counsel and paralegal, and all witnesses 0.5 6/18/2022 Draft and send email to attorney Irene K. Dymkar and Sophia Darugar 0.1 6/19/2022 Review plaintiffs' witness list 0.1 6/19/2022 Draft and send emails to attorney Irene K. Dymkar 0.3 6/19/2022 Draft and send email to attorney James Bowers regarding deposition designations for witnesses Odell Dollerson and Steve Martinez, and instructions for reading 0.2 6/19/2022 Review Judge Chang trial orders 0.1 6/19/2022 Review deposition abstract of witness John Gartner 0.9 6/19/2022 Trial planning meeting with attorney Irene K. Dymkar 0.7 6/19/2022 Draft and send email to IDOC witness Tammie Howard 0.1 6/19/2022 Review deposition transcript of IDOC witness Tammie Howard 1.2 6/19/2022 Draft cross-examination questions for IDOC witness Tammie Howard 0.5 6/19/2022 Review stipulation of testimony of witness Erin Hansen, with exhibits 0.3 6/19/2022 Edit direct examination questions for witness Shatrion Hill 0.9 6/20/2022 Review and download deposition abstract of Scott Liebhaber 0.1 6/20/2022 Update detailed trial contact information list 0.2 6/20/2022 Draft and send emails to attorney Irene K. Dymkar and Sophia Darugar 0.3 6/20/2022 Trial planning meeting with attorney Irene K. Dymkar 1.2 6/20/2022 Draft and send emails to IDOC witnesses regarding trial schedule and contact with Sophia Darugar (multiple) 0.5 6/20/2022 Update chart of status of trial subpoenas 0.1 6/20/2022 Review Judge Chang orders on exhibits, deposition designations for witness Gertha Brady, plaintiff Charles Hill's firearms, and time limits 0.2 6/20/2022 Telephone conference with plaintiff, Charles Hill 0.2 6/20/2022 Telephone conference with plaintiff, Donna Hill 0.1 6/20/2022 Review Judge Chang's order on exhibits 0.2 6/20/2022 Prepare binder of defendant's final trial exhibits 0.6 6/20/2022 Update list of all trial stipulations 0.2 6/20/2022 Draft and send emails to attorney Irene K. Dymkar regarding trial witnesses and stipulations 0.4 6/20/2022 Review deposition transcript of IDOC witness Tamika Johnson 0.4 6/20/2022 Prepare cross-examination questions of IDOC witness Tamika Johnson 0.7 6/20/2022 Telephone conference with IDOC witness Tamika Johnson 0.2 6/20/2022 Conduct legal research regarding conferring with witnesses 0.4 98 6/20/2022 Draft and send email to defendant's attorneys 0.1 6/20/2022 Draft objections to defendant's counter-designations for witness Gertha Brady 1.4 6/20/2022 Draft and send email to process server Lynn Bagley 0.1 6/20/2022 Review deposition abstract of witness Steven Suvada 0.5 6/20/2022 Review deposition abstract of witness Scott Liebhaber 0.5 6/21/2022 Fill out Northern District COVID-19 Test Consent Forms 0.1 6/21/2022 Take pre-trial COVID-19 tests at court building, including travel 1.0 6/21/2022 Telephone conference with plaintiff, Charles Hill 0.3 6/21/2022 Office meeting with paralegal Sophia Darugar 0.9 6/21/2022 Trial planning meeting with attorney Irene K. Dymkar 0.9 6/21/2022 Office meeting with plaintiffs Charles Hill and Donna Hill 0.8 6/21/2022 Draft and send email to attorney Michele McGee regarding CPD trial witnesses 0.2 6/21/2022 Finalize deposition designations of witness Gertha Brady to file 0.2 6/21/2022 Draft and send email to Judge Chang and Judge Chang's courtroom deputy with deposition designations of witness Gertha Brady 0.1 6/21/2022 Update trial contact information list 0.1 6/21/2022 Prepare for meeting with court technician, Alexander Zeier 0.1 6/21/2022 Compile exhibits for witness Shatrion Hill's trial testimony 0.2 6/21/2022 Review deposition of witness Odell Dollerson 1.0 6/21/2022 Meet with court technician, Alexander Zeier, including travel 0.5 6/21/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/21/2022 Draft and send email to Sophia Darugar 0.1 6/21/2022 Prepare voir dire chart for use at trial 0.3 6/21/2022 Draft and send emails to attorney Irene K. Dymkar 0.3 6/21/2022 Draft and send email to defendant's attorneys 0.2 6/21/2022 Leave voicemail message for IDOC witness Tammie Howard 0.1 6/21/2022 Sign on and check COVID-19 test results for self and for plaintiffs 0.1 6/21/2022 Draft and send email to attorney James Bowers regarding deposition designations for witnesses Odell Dollerson and Steve Martinez 0.1 6/21/2022 Highlight deposition transcript of witness Odell Dollerson with designated testimony for use at trial 0.9 6/21/2022 Highlight deposition transcript of witness Gertha Brady with designated testimony for use at trial 0.5 6/21/2022 Highlight deposition transcript of witness Steve Martinez with designated testimony for use at trial 0.6 6/22/2022 Telephone conference with IDOC witness Tammie Howard 0.2 6/22/2022 Review Judge Chang detailed orders on plaintiff Charles Hill's firearms, jury instructions, motions in limine, preliminary instructions, plaintiffs' motion for leave to read judicial admissions, witness Cornesha Rice, video clips, deposition designations, and stipulations 0.6 6/22/2022 Update trial contact information list 0.1 6/22/2022 Draft and send emails to attorney Irene K. Dymkar and Sophia Darugar (2) 0.2 6/22/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/22/2022 Review deposition transcript of witness Steve Martinez 0.1 99 6/22/2022 Trial planning meeting with attorney Irene K. Dymkar 1.0 6/22/2022 Draft and send email to Ian Davidson regarding video clips of deposition video of defendant Christopher Harrington 0.1 6/22/2022 Draft and send email to attorney James Bowers regarding deposition designations for witnesses Odell Dollerson and Steve Martinez, and instructions for reading at trial 0.1 6/22/2022 Telephone conference with plaintiff, Charles Hill 0.1 6/22/2022 Draft and send emails to Judge Chang's courtroom deputy 0.2 6/22/2022 Draft and send email to defendant's attorneys 0.2 6/22/2022 Draft and send email to witness Shatrion Hill 0.1 6/22/2022 Draft motion regarding adding screenshot of defendant Christopher Harrington to exhibit list 0.5 6/22/2022 Review deposition transcript of IDOC witness Tamika Johnson 0.8 6/22/2022 Draft cross-examination questions for IDOC witness Tamika Johnson 0.4 6/22/2022 Review stipulation of testimony of witness Erin Hansen, with exhibits 0.5 6/22/2022 Prepare trial exhibit of screenshot of defendant Christopher Harrington 0.1 6/22/2022 Telephone conference with witness Cornesha Rice 0.1 6/22/2022 Review direct examination questions for witness Shatrion Hill 1.0 6/22/2022 Prepare hard copy of plaintiffs' trial exhibit #68 for delivery to court 0.2 6/22/2022 Telephone conference with witness Shatrion Hill 0.3 6/22/2022 Prepare reference copies of motions and orders for use at trial 0.6 6/22/2022 Finalize designated transcript of witness Odell Dollerson 0.7 6/22/2022 Draft and send email to attorney James Bowers regarding deposition designations for witnesses Odell Dollerson and Steve Martinez 0.2 6/22/2022 Copy case file to trial laptop 0.3 6/22/2022 Telephone conference with IDOC witness Tamika Johnson 0.1 6/22/2022 Finalize designated transcript of witness Gertha Brady 1.0 6/22/2022 Finalize designated transcript of witness Steve Martinez 1.0 6/23/2022 Draft and send email to attorney James Bowers regarding deposition designations for witnesses Odell Dollerson and Steve Martinez 0.1 6/23/2022 Day One of trial 7.6 6/23/2022 Conference with plaintiffs after trial 0.7 6/23/2022 Meet with attorney Irene K. Dymkar and Sophia Darugar after trial to discuss case and strategy 0.5 6/23/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/23/2022 Review deposition transcript of witness Steve Martinez 0.2 6/23/2022 Draft and send email to defendant's attorneys 0.2 6/23/2022 Draft and send email to witness Shatrion Hill 0.1 6/23/2022 Telephone conference with Jacqueline Brady, daughter of witness Gertha Brady 0.1 6/23/2022 Draft and send email to IDOC witness Rixie Davis 0.1 6/23/2022 Edit plaintiffs' exhibit list 0.2 6/23/2022 Trial planning meeting with attorney Irene K. Dymkar 0.4 6/23/2022 Edit cross-examination questions for IDOC witness Tammie Howard 0.1 100 6/23/2022 Edit cross-examination questions for IDOC witness Tamika Johnson 0.1 6/23/2022 Review direct examination questions for witness Shatrion Hill 0.7 6/24/2022 Review direct examination questions for witness Shatrion Hill 0.7 6/24/2022 Review deposition transcript of witness Shatrion Hill 0.3 6/24/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/24/2022 Telephone conference with witness Shatrion Hill 0.3 6/24/2022 Telephone conference with plaintiff, Charles Hill 0.1 6/24/2022 Day Two of trial 7.6 6/24/2022 Strategy meeting with attorney Irene K. Dymkar and Sophia Darugar after trial 0.2 6/24/2022 Order transcript of defendant's opening statement 0.1 6/24/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/25/2022 Review emails from attorney Irene K. Dymkar 0.2 6/25/2022 Draft and send emails to attorney Irene K. Dymkar regarding trial plan, motions, witnesses (multiple) 1.1 6/25/2022 Draft motion for additional trial time 0.5 6/25/2022 Review Judge Chang orders 0.1 6/25/2022 Review deposition abstract of IDOC witness James Noble 0.1 6/25/2022 Trial planning meeting with attorney Irene K. Dymkar 1.2 6/25/2022 Research federal rules of evidence 0.2 6/25/2022 Draft and send email to Judge Chang's law clerk 0.1 6/25/2022 Review notes from defendant's opening statement 0.1 6/25/2022 Draft motion to bar testimony by defendant Christopher Harrington 0.7 6/25/2022 Draft and send email to Ian Davidson regarding video clips of deposition video of defendant Christopher Harrington 0.1 6/25/2022 Review deposition abstract for witness Thomas Nowak 0.4 6/25/2022 Review deposition designations for witness Steve Martinez 0.8 6/25/2022 Draft and send email to attorney James Bowers regarding deposition designations for witness Steve Martinez 0.1 6/25/2022 Review deposition abstract of IDOC witness Rodney Alexander 0.8 6/25/2022 Review deposition video of IDOC witness Rodney Alexander 0.1 6/25/2022 Review deposition abstract of IDOC witness Rixie Davis 0.5 6/26/2022 Review deposition abstract of IDOC witness Jacob Walls 0.9 6/26/2022 Draft and send emails to attorney Irene K. Dymkar regarding jury instructions, exhibit list, stipulations, witnesses (multiple) 0.7 6/26/2022 Review emails from attorney Irene K. Dymkar 0.1 6/26/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 6/26/2022 Review Plaintiffs' Motion for Order Barring Defendant Harrington from Testifying About His Family Values, His Upbringing, and the Dedication of His Life to Public Service, in Violation of Federal Rule of Evidence 404 0.1 6/26/2022 Review continuation deposition abstract of IDOC witness Jacob Walls 0.5 6/26/2022 Review deposition transcript of IDOC witness Felisha Parker 1.0 6/26/2022 Draft cross-examination questions for IDOC witness Felisha Parker 0.5 101 6/26/2022 Review deposition transcript of IDOC witness Rodney Alexander 1.4 6/26/2022 Draft cross-examination questions for IDOC witness Rodney Alexander 0.5 6/26/2022 Review deposition transcript of IDOC witness Jacob Walls 1.3 6/26/2022 Draft cross-examination questions for IDOC witness Jacob Walls 0.6 6/26/2022 Review continuation deposition transcript of IDOC witness Jacob Walls 1.0 6/27/2022 Review Defendant's Response in Opposition to Plaintiffs' Motion for an Order Barring Defendant Harrington from Testifying About His Family Values, His Upbringing, and the Dedication of His Life to Public Service, in Violation of Federal Rule of Evidence 404, Supplement to Plaintiffs' Motion for Order Barring Defendant Harrington from Testifying About His Family Values, His Upbringing, and the Dedication of His Life to Public Service, in Violation of Federal Rule of Evidence 404, and Plaintiffs' Motion to Bar Illinois Department of Corrections Witnesses from Making Inflammatory, Derogatory, and Speculative Statements About Alleged Condition of Plaintiffs' Home 0.2 6/27/2022 Draft emails to defendant's attorneys regarding deposition designations and stipulations (multiple) 0.5 6/27/2022 Draft motion to bar inflammatory statements 0.7 6/27/2022 Trial planning meeting with attorney Irene K. Dymkar, including discussing which IDOC witnesses to call 1.8 6/27/2022 Review and highlight stipulation of testimony of witness Erin Hansen 0.3 6/27/2022 Discuss case and strategy with Sophia Darugar and attorney Irene K. Dymkar 0.5 6/27/2022 Edit supplement to motion to bar testimony of defendant Christopher Harrington 0.4 6/27/2022 Telephone conference with Sophia Darugar 0.1 6/27/2022 Draft and send emails to Judge Chang's law clerk (multiple) 0.4 6/27/2022 Telephone conference with plaintiff, Charles Hill 0.1 6/27/2022 Designate deposition transcript of witness Cornesha Rice 1.4 6/27/2022 Prepare designation deposition chart for deposition transcript of witness Cornesha Rice 0.6 6/27/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/27/2022 Review deposition transcript of IDOC witness Rixie Davis 0.8 6/27/2022 Draft cross-examination questions for IDOC witness Rixie Davis 0.3 6/27/2022 Telephone conference with defendant's attorney, Hal Dworkin 0.1 6/27/2022 Edit deposition designations of witness Steve Martinez 0.2 6/27/2022 Draft and send email to attorney James Bowers regarding deposition designations of witness Steve Martinez 0.1 6/27/2022 Draft cross-examination questions for IDOC witness Jacob Walls 0.5 6/27/2022 Review video clips of deposition of defendant Christopher Harrington 0.2 6/27/2022 Draft objections to defendant's counter-designations for witness Cornesha Rice 0.7 102 6/27/2022 Edit cross-examination questions for IDOC witness Rodney Alexander 0.1 6/27/2022 Edit cross-examination questions for IDOC witness Felisha Parker 0.1 6/27/2022 Transfer files to trial laptop 0.1 6/28/2022 Review cross-examination questions for IDOC witness Felisha Parker 0.1 6/28/2022 Review stipulation of testimony of witness Erin Hansen, with exhibits 0.2 6/28/2022 Review cross-examination questions for IDOC witness Rodney Alexander 0.3 6/28/2022 Transfer files to trial laptop 0.1 6/28/2022 Prepare exhibits for witnesses 0.2 6/28/2022 Review cross-examination questions for IDOC witness Jacob Walls 0.3 6/28/2022 Day Three of trial 7.9 6/28/2022 Prepare final deposition designations for witness Cornesha Rice 0.1 6/28/2022 Meet with attorney Irene K. Dymkar and Sophia Darugar after trial to discuss case and strategy 0.6 6/28/2022 Trial planning meeting with attorney Irene K. Dymkar 0.2 6/28/2022 Telephone conference with plaintiffs Charles Hill and Donna Hill 0.2 6/28/2022 Draft and send email to Judge Chang's law clerk 0.2 6/28/2022 Review deposition transcript of IDOC witness Rixie Davis 1.3 6/28/2022 Edit motion for additional trial time 0.1 6/28/2022 Draft cross-examination questions for IDOC witness Rixie Davis 0.4 6/28/2022 Review deposition transcript of witness John Gartner 1.6 6/28/2022 Review deposition transcript of witness Thomas Nowak 0.8 6/28/2022 Highlight deposition transcript of witness Cornesha Rice with designations 0.8 6/29/2022 Review final deposition designations for witness Cornesha Rice 0.3 6/29/2022 Prepare for trial Day Four of trial 0.5 6/29/2022 Day Four of trial, including travel and set up 8.5 6/29/2022 Meet with attorney Irene K. Dymkar and Sophia Darugar after trial to discuss case and strategy 0.6 6/29/2022 Trial planning meeting with attorney Irene K. Dymkar 0.6 6/29/2022 Review deposition transcript of witness John Gartner 1.4 6/29/2022 Review deposition transcript of witness Thomas Nowak 0.9 6/29/2022 Draft and send email to attorney Irene K. Dymkar 0.1 6/30/2022 Review Judge Chang orders on verdict form, trial days, jury instructions 0.2 6/30/2022 Review final jury instructions 0.2 6/30/2022 Prepare presentation of exhibits for summation 0.4 6/30/2022 Telephone conference with plaintiff, Charles Hill 0.2 6/30/2022 Trial planning meeting with attorney Irene K. Dymkar 0.2 6/30/2022 Meet with attorney Irene K. Dymkar and Sophia Darugar after trial to discuss case and strategy 0.4 6/30/2022 Day Five of trial, including travel 6.2 6/30/2022 Remain in courtroom area until released for day 2.2 6/30/2022 Telephone conference with plaintiff, Donna Hill 0.1 6/30/2022 Draft and send email to Ian Davidson 0.1 6/30/2022 Draft and send email to courtroom deputy 0.1 103 7/1/2022 Review and download Judge Chang order 0.1 7/1/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 7/1/2022 Review, download, and save copies of exhibit list and stipulations sent to jury, for record on appeal 0.1 7/1/2022 Draft and send email to Judge Chang's law clerk 0.1 7/1/2022 Day Six of trial, including travel, on call, receive verdict 4.4 7/1/2022 Telephone conference with plaintiffs 0.1 7/5/2022 Review Judge Chang order, filed jury notes, filed jury verdict, judgment, update calendar 0.2 7/5/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/5/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.3 7/6/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/7/2022 Telephone conference with attorney Irene K. Dymkar and Sophia Darugar 0.3 7/8/2022 Prepare bill of costs and attachments, and obtain, organize, and validate invoices and receipts 2.2 7/11/2022 Review emails from attorney Irene K. Dymkar and Sophia Darugar, and documentation provided 0.3 7/12/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/13/2022 Prepare bill of costs and attachments, and obtain, organize, and validate invoices and receipts 1.1 7/14/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/15/2022 Review email from attorney Irene K. Dymkar 0.1 7/15/2022 Conduct legal research regarding judgment and payment issues 0.4 7/18/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/19/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.1 7/20/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/20/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 2.1 7/21/2022 Prepare bill of costs and attachments, and obtain, organize, and validate invoices and receipts 1.2 7/21/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/22/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 0.8 7/25/2022 Prepare itemization of copy costs that are limited to bill of costs 1.3 104 7/25/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/25/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/26/2022 Draft and send letters to plaintiffs, Charles Hill and Donna Hill 0.4 7/26/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/26/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/26/2022 Compile list of costs not recoverable, and to be deleted, from bill of costs 0.2 7/26/2022 Draft and send email to defendant's attorneys 0.1 7/27/2022 Draft and send email to defendant's attorneys 0.1 7/27/2022 Draft motion for extension of time to file bill of costs 0.4 7/27/2022 Draft and send email to attorney Irene K. Dymkar 0.1 7/27/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.2 7/27/2022 Finalize motion for extension of time to file bill of costs 0.1 7/28/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 0.7 8/2/2022 Telephone conference with attorney Irene K. Dymkar 0.1 8/2/2022 Review Judge Chang order, update calendar 0.1 8/3/2022 Telephone conference with attorney Irene K. Dymkar 0.2 8/3/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 0.4 8/3/2022 Telephone conference with colleague attorney for fee petition declaration 0.1 8/3/2022 Telephone conference with second colleague attorney for fee petition declaration 0.1 8/4/2022 Finalize bill of costs and exhibits to bill of costs 1.8 8/4/2022 Telephone conference with attorney Irene K. Dymkar 0.3 8/9/2022 Telephone conference with attorney Irene K. Dymkar 0.2 8/9/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 0.7 8/10/2022 Telephone conference with attorney Irene K. Dymkar X 0.1 8/10/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 1.5 8/16/2022 Telephone conference with attorney Irene K. Dymkar 0.1 8/17/2022 Telephone conference with attorney Irene K. Dymkar X 0.1 8/17/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 1.2 8/24/2022 Review Judge Chang order, update calendar 0.1 105 8/25/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 2.1 8/25/2022 Telephone conference with attorney Irene K. Dymkar 0.3 8/25/2022 Draft and send email to attorney Irene K. Dymkar 0.2 8/26/2022 Draft and send email to attorney colleague for fee petition declaration 0.2 8/26/2022 Draft and send email to second attorney colleague for fee petition declaration 0.1 8/29/2022 Telephone conference with attorney Irene K. Dymkar 0.3 8/30/2022 Telephone conference with attorney Irene K. Dymkar 0.2 8/31/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 2.5 8/31/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/1/2022 Review email from attorney Irene K. Dymkar 0.1 9/1/2022 Draft joint statement for fee petition 0.9 9/1/2022 Draft and send emails to attorney Irene K. Dymkar (2) 0.2 9/1/2022 Telephone conference with attorney Irene K. Dymkar 0.2 9/1/2022 Telephone conference with plaintiff, Charles Hill 0.2 9/1/2022 Prepare W-9 forms for plaintiffs for payment of judgments 0.2 9/1/2022 Telephone conference with plaintiff, Donna Hill 0.1 9/1/2022 Telephone conference with colleague attorney for fee petition declaration 0.1 9/8/2022 Review defendant's objections to plaintiffs' Bill of Costs 0.2 9/8/2022 Telephone conference with attorney Irene K. Dymkar 0.2 9/8/2022 Review fee petition declaration from colleague attorney 0.1 9/8/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/9/2022 Telephone conference with attorney Irene K. Dymkar 0.2 9/9/2022 Review email from attorney Irene K. Dymkar 0.1 9/13/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/13/2022 Telephone conference with attorney Irene K. Dymkar 0.1 9/15/2022 Review defendant's objections to plaintiffs' Bill of Costs and exhibits 0.4 9/15/2022 Perform legal research on case law and previous rulings on Bill of Costs in plaintiffs' counsel's previous cases 0.9 9/15/2022 Draft reply in support of plaintiffs' Bill of Costs 1.7 9/16/2022 Telephone conference with attorney Irene K. Dymkar 0.1 9/19/2022 Telephone conference with attorney Irene K. Dymkar 0.3 9/19/2022 Draft and send email to Judge Chang's courtroom deputy 0.1 9/19/2022 Draft reply in support of plaintiffs' Bill of Costs 0.6 9/19/2022 Conduct legal research regarding Bill of Costs 0.2 9/19/2022 Draft and send email to defendant's attorneys 0.1 9/19/2022 Draft motion for extension of time to file reply in support of plaintiffs' Bill of Costs 0.5 9/19/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/19/2022 Review declaration for colleague attorney 0.1 9/20/2022 Telephone conference with attorney Irene K. Dymkar 0.1 9/21/2022 Review Judge Chang order, update calendar 0.1 9/21/2022 Telephone conference with attorney Irene K. Dymkar 0.4 9/21/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/21/2022 Draft motion to set briefing schedule on fee petition 0.6 9/22/2022 Telephone conference with attorney Irene K. Dymkar 0.1 106 9/23/2022 Review timesheets for attorney Shamoyita M. DasGupta for fee petition for accuracy and completeness, and for possible redactions for work product and attorney-client privilege 0.4 9/23/2022 Draft and send email to attorney Irene K. Dymkar 0.1 9/23/2022 Review declaration from second colleague attorney 0.1 9/23/2022 Discuss post-trial matters with attorney Irene K. Dymkar, including post-trial motions, appeal, fee petition, bill of costs, payment and collection 0.4 9/23/2022 Review email from defendant's attorney Hal Dworkin (2) 0.1 9/23/2022 Conference call with attorney Irene K. Dymkar and defendant's attorneys Hal Dworkin and Margaret Jones regarding briefing schedule for plaintiffs' fee petition 0.4 TOTAL HOURS 844.7 TOTAL CITY HOURS 53.5 ADJUSTED TOTAL HOURS 791.2 TOTAL ADJUSTED FEES AT $325/HOUR $ 257,140.00 107 Date Service provided Time expended (in hours) 2/6/2017 Initial intake telephone call and initial interview of plaintiff, Charles Hill 0.6 2/7/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 2/7/2017 Telephone conference with Shiller Preyar Law Offices regarding their preliminary investigation 0.4 2/7/2017 Telephone conference with plaintiff, Charles Hill 0.1 2/8/2017 Draft and send letter to plaintiffs 0.2 2/15/2017 Initial intake office meeting with plaintiffs 1.7 2/15/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 2/15/2017 Create list of potential witnesses from law enforcement, the family, eye witnesses 0.3 2/17/2017 Telephone conference with plaintiff, Charles Hill 0.3 3/7/2017 Discuss case and strategy with attorney Irene K. Dymkar 0.1 3/7/2017 Draft letter to plaintiffs 0.2 3/13/2017 Telephone conference with plaintiff, Charles Hill 0.2 3/14/2017 Prepare for office meeting with plaintiffs, Charles Hill and Donna Hill 0.4 3/15/2017 Office meeting with plaintiffs, Charles Hill and Donna Hill 0.3 3/15/2017 Review police reports obtained 0.3 3/15/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Shamoyita M. DasGupta X 0.2 3/16/2017 Telephone conference with plaintiff, Charles Hill 0.1 3/22/2017 Telephone conference with plaintiff, Donna Hill 0.2 3/31/2017 Draft and send letter to plaintiff, Donna Hill 0.2 4/4/2017 Telephone conference with plaintiff, Charles Hill 0.1 4/27/2017 Telephone conference with plaintiff, Charles Hill 0.2 5/4/2017 Telephone conference with plaintiff, Charles Hill 0.2 5/10/2017 Telephone conference with plaintiff, Charles Hill 0.1 5/12/2017 Office meeting with plaintiffs, Charles and Donna Hill 1.1 5/13/2017 Determine need for records and develop plan to obtain records 0.4 5/16/2017 Telephone conference with Naomi Bank, public defender for witness Keitrion Lewis, regarding criminal case 0.2 5/16/2017 Draft and send letter to Naomi Bank, public defender for witness Keitrion Lewis 0.6 5/17/2017 Draft and send Freedom of Information Act ("FOIA") Request to the Office of Emergency Management and Communications ("OEMC") 0.3 108 5/17/2017 Telephone conference with Naomi Bank, public defender for witness Keitrion Lewis 0.2 5/17/2017 Discuss case and strategy with attorney Irene K. Dymkar 0.2 5/18/2017 Telephone conference with Naomi Bank, public defender for witness Keitrion Lewis 0.2 5/20/2017 Obtain and review criminal court records for Keitrion Lewis 0.8 5/30/2017 Contact Cook County Jail regarding visitation (2) 0.3 5/31/2017 Draft Authorization for Release and Copying of Illinois Department of Corrections Parole Records for witness Keitrion Lewis 0.8 5/31/2017 Prepare for visit with Keitrion Lewis, review file and select documents to review with Mr. Lewis 0.7 6/1/2017 Draft and finalize Authorization for Release and Copying of Illinois Department of Corrections Parole Records for witness Keitrion Lewis 0.4 6/1/2017 Meeting with witness Keitrion Lewis at Cook County Jail 1.6 6/1/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.3 6/2/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 6/8/2017 Draft and send letter to plaintiffs 0.3 6/8/2017 Telephone conference with plaintiff, Charles Hill 0.2 6/12/2017 Discuss case and stategy with attorney Irene K. Dymkar 0.1 6/13/2017 Review OEMC FOIA response 0.2 6/13/2017 Draft and send additional FOIA request to OEMC 0.2 6/15/2017 Review OEMC FOIA response 0.1 6/20/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 8/9/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Shamoyita M. DasGupta X 0.3 8/16/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.2 9/20/2017 Draft and send letter to plaintiffs 0.3 9/20/2017 Draft initial draft of complaint 0.7 9/20/2017 Legal research regarding elements of claims to be brought 0.7 9/21/2017 Draft and send FOIA request to the Chicago Police Department 0.3 9/21/2017 Draft and send FOIA request to the Illinois State Police 0.3 9/21/2017 Telephone conference with the Illinois State Police 0.2 9/22/2017 Discuss case and strategy with attorney Irene K. Dymkar X 0.1 10/12/2017 Draft initial draft of complaint 0.6 10/16/2017 Discuss case and strategy with attorneys Irene K. Dymkar and Shamoyita M. DasGupta X 0.3 10/18/2017 Telephone conference with eyewitnesses Odell Dollerson and Shatrion Hill 0.6 10/18/2017 Draft and send email to Chicago Police Department FOIA regarding prior request 0.2 TOTAL HOURS 21.2 TOTAL FEES AT S230/HOUR $ 4,876.00