1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

Luis Enrique Juarez, ) Judge Reed C. O’Connor

Plaintiff, )

v. ) No. 4:22-cv-00169-O

)

H & K Steel Erectors Enterprises, LLC, H & K Steel )

 Building, LLC, and Jason Soliz )

Defendants. )

SUPPLEMENTAL PETITION FOR ATTORNEY’S FEES, TIME AND TASKS

James M. Dore, having been first duly sworn on oath, states:

1. Plaintiff Luis Enrique Juarez retained me and my firm, to represent him in the above captioned

lawsuit against the named Defendant(s). The above captioned lawsuit involves claims under the 

Fair Labor Standards Act to collect unpaid wages and overtime from Defendant(s), their former 

employer.

2. I am the primary attorney responsible for handling this matter. My Texas Bar number is

24128272. The administrative work on the file is performed by our employee, Derian Geovanni 

Palacios Morales, also referred to as “Gio” in our time keeping records. We do not bill any hourly 

time for work performed by Gio.

3. Our billable hourly rate is $400.00 per hour for matters of this kind.

4. Our $400.00 hourly rate is reasonable and comparable to rates charged by attorneys and staff 

of a comparative level, serving the same legal market. 

5. The Court has previously granted Plaintiff’s Petition for Attorney’s Fees, but allowed leave to 

file a supplemental petition relating to the attorney time and costs incurred since the prior 

petition’s filing. Dckt. 36. 

6. The following list specifies an accurate statement of the subjects and the professional time spent 

since Plaintiff’s prior petition for attorney’s fees [Dckt. 31] and to be spent in the prosecution of 

the claim(s) of Plaintiff against the Defendants. The list represents the coincidental or reasonably 

current preparation of the subject matters and the time assigned as reflected in the records of the 

attorneys for Plaintiff:

Case 4:22-cv-00169-O Document 37 Filed 03/31/23 Page 1 of 5 PageID 198
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Date Atty Hours Description of Activity

9/6/2023 JMD 0.10 REVIEW ORDER SETTING SUPPLEMENTAL BRIEFING

9/13 JMD 1.25 DRAFT SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION FOR DEFAULT 

 JUDGMENT

11/3 JMD 0.50 REVIEW REPORT AND RECOMMENDATIONS OF MAGISTRATE JUDGE

11/15 JMD 3.50 REVIEW CASE LAW CITED IN REPORT AND RECOMMENDATIONS; DRAFT

 OBJECTIONS TO THE SAME

3/23/23 JMD 0.25 REVIEW COURT ORDER RE: OBJECTIONS

3/31 JMD 0.50 DRAFT SUPPLEMENTAL PETITION FOR ATTORNEYS FEES

Total Hours: JMD 6.10 hrs X $400.00 = $2,440.00

Total Attorneys Fees = $2,440.00

6. These records identify the work that we did each day, the amount of time that we devoted to 

this matter on that day (including separate entries for each task), and a description of the work 

performed. The time entries on these invoices were entered by me personally, at or near the time 

of performing the work in the ordinary course of our daily practice. These billing records are kept 

in the ordinary course of our regularly conducted business activities. Some entries may have been 

redacted in part for the purpose of protecting attorney-client communications or work product 

privilege.

7. The tasks performed and the costs incurred were all reasonably and necessarily incurred in the 

case. The fees and costs incurred reflect tasks that were performed competently and efficiently.

8. Accordingly, the total amount of attorney’s fees and costs being sought are $2,440.00.

9. I have personal knowledge of the facts set forth in this Affidavit and can testify in accordance 

therewith.

Verification

I declare under penalty of perjury that the foregoing is true and correct.

Executed: March 31, 2023 /s/ James M. Dore

Case 4:22-cv-00169-O Document 37 Filed 03/31/23 Page 2 of 5 PageID 199
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Justicia Laboral LLC

James M. Dore (Texas Bar No. 24128272)

Attorneys for Plaintiffs

6232 N. Pulaski, Suite 300

Chicago, IL 60646

P: 773-415-4898

E: jdore@justicialaboral.com

Case 4:22-cv-00169-O Document 37 Filed 03/31/23 Page 3 of 5 PageID 200
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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

Luis Enrique Juarez, ) Judge Reed C. O’Connor

Plaintiff, )

v. ) No. 4:22-cv-00169-O

)

H & K Steel Erectors Enterprises, LLC, H & K Steel )

 Building, LLC, and Jason Soliz )

Defendants. )

Notice of Filing

TO: H & K Steel Building, LLC H & K Steel Erectors Enterprises, LLC

 c/o Jason Soliz c/o Jason Soliz

Defendant Defendant

6804 Eagle Heights Drive 6804 Eagle Heights Drive

Fort Worth, TX 76135 Fort Worth, TX 76135

Jason Soliz

 Defendant

6804 Eagle Heights Drive

Fort Worth, TX 76135

PLEASE TAKE NOTICE that on March 23, 2023, I caused to be filed the attached 

Plaintiff’s Supplemental Petition for Attorney’s Fees, copies of which are hereby served upon 

you. 

/s/ James M. Dore 

Justicia Laboral LLC

James M. Dore (Texas Bar No. 24128272)

Attorneys for Plaintiffs

6232 N. Pulaski, Suite 300

Chicago, IL 60646

P: 773-415-4898

E: jdore@justicialaboral.com

Case 4:22-cv-00169-O Document 37 Filed 03/31/23 Page 4 of 5 PageID 201
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Certificate of Service

I, James M. Dore, an attorney, certify that I caused this Notice and Plaintiff’s 

Supplemental Petition for Attorney’s Fees to be filed with the Clerk of the Court on March 23, 

2023 and I certify that I served this notice and documents by sending via regular mail to the 

attorneys/parties of record at their listed addresses below, and depositing the same in the U.S. 

Mail in Chicago on March 23, 2023, with proper postage prepaid:

H & K Steel Building, LLC H & K Steel Erectors Enterprises, LLC

 c/o Jason Soliz c/o Jason Soliz

Defendant Defendant

6804 Eagle Heights Drive 6804 Eagle Heights Drive

Fort Worth, TX 76135 Fort Worth, TX 76135

Jason Soliz

 Defendant

6804 Eagle Heights Drive

Fort Worth, TX 76135

/s/ James M. Dore 

Justicia Laboral LLC

James M. Dore (Texas Bar No. 24128272)

Attorneys for Plaintiffs

6232 N. Pulaski, Suite 300

Chicago, IL 60646

P: 773-415-4898

E: jdore@justicialaboral.com

Case 4:22-cv-00169-O Document 37 Filed 03/31/23 Page 5 of 5 PageID 202