Opinion
Civil Action 19-CV-02625
03-10-2021
Teamsters Local Union No. 727 Pension Fund, by and through its Board of Trustees, John T. Coli, Jr., Zachary Frankenbach, Michael DeGard, Nicholas Micaletti, John McCarthy, Gregory T. Youmans, Carl S. Tominberg, and Robert Sheehy, 1300 W. Higgins Road, Suite 103, Park Ridge, IL 60068, and Teamsters Local Union No. 727 Health & Welfare Fund, by and through its Board of Trustees, John T. Coli, Jr., Zachary Frankenbach, Michael DeGard, Nicholas Micaletti, John McCarthy, Gregory T. Youmans, Carl S. Tominberg, and Robert Sheehy, 1300 W. Higgins Road, Suite 103, Park Ridge, IL 60068, and Teamsters Local Union No. 727 Legal & Educational Assistance Fund, by and through its Board of Trustees, John T. Coli, Jr., Zachary Frankenbach, Michael DeGard, Nicholas Micaletti, John McCarthy, Gregory T. Youmans, Carl S. Tominberg, and Robert Sheehv, 1300 W. Higgins Road, Suite 103, Park Ridge, IL 60068, Plaintiffs, v. Nathan Tamayo Defendant.
Cara M. Anthaney, Esq., CTM Legal Group.
Cara M. Anthaney, Esq., CTM Legal Group.
DECLARATION OF CARA MARIE ANTHANEY
HON. JEFFREY T. GILBERT JUDGE.
I, Cara Marie Anthaney, make this declaration in support of the the Plaintiffs Teamsters Local Union No. 727 Pension Fund, Teamsters Local Union No. 727 Health & Welfare Fund, Teamsters Local Union No. 727 Legal and Educational Assistance Fund and Parking Industry Labor Management Committee ("Plaintiff Funds") Motion for Entry of Default Judgment.
I, Cara Marie Anthaney, being duly sworn, do hereby depose and say as follows:
1. I am an attorney at the law firm Illinois Advocates, LLC d/b/a CTM Legal Group ("CTM"). I joined CTM in August 2014.
2. am one of the attorneys representing the Plaintiffs in the above-captioned matter.
3. I am a member in good standing of the bar of the State of Illinois, admitted 2011.
4. 1 am also a member in good standing of the United States District Court for the Northern District of Illinois, admitted 2015.
5. My practice is focused on representing union members and union benefits funds in civil litigation matters and as an ERISA collections attorney. 1 am experienced in commercial litigation and collections for wide range of private clients including multinational banks, credit unions, healthcare providers, mercantile establishments, finance companies, and debt buyers. 1 also focus on general civil litigation, landlord/ tenant litigation, and consumer rights.
6. CTM attorneys bill at the rate of S375.00 an hour for work performed on behalf of the Plaintiff Funds.
7. CTM administrative staff bills at the rate of $95.00 per hour for work performed on behalf of the Plaintiff Funds.
8. Upon review of billing records, Plaintiff Funds' counsel performed work related to the instant lawsuit and that Plaintiff Funds' attorneys' fees for this work totals S17, 698.05 plus S712.50 in costs. Attached hereto as Exhibit A is breakdown of the hours billed and costs expended.
9. I have personal knowledge of the matters stated in this declaration and affidavit and could testify competently to them.
10. I affirm and attest that the foregoing statements made by me are true.