~ oTM

7 .The court has reviewed thoroughly defendant’s timesheets that were attached to its
motion for attorney’s fees and finds no reason to reduce the fees requested. Certainly, plaintiff
has failed to specify any reason to reach a different conclusion. Accordingly, defendant’s motion
for attorney’s fees is granted, and the court awards defendant the sum of $54,613.50 in attorney’s
fees. In addition, the court awards defendant taxable costs in the sum of $14,435.95, as specified

in defendants bill of costs filed pursuant to Fed. R. Civ. P. 54(d)(1)?

ENTER: October 25, 2004

“ashe ta

Robert W. Gettleman
United States District Judge

3Although plaintiff objects to defendant’s bill of costs in response to defendant’s petition
for fees, plaintiff failed to file an objection as specified by Rule 54(d)(1). Accordingly, the costs
requested are automatically taxed by the clerk.


fn co”

Plaintiffs continued attack on the subpoenas to the telephone company and the
jurisdiction of this court have previously been raised and rejected. Greviskes I. The latest
attacks represent nothing less than continued evidence of the failure of plaintiff and her lawyer to
understand their obligations in these proceedings. Plaintiff has every right to appeal this court’s
dismissal of her case, as she has, but until and unless that appeal is decided in her favor, plaintiff
has an obligation to obey the instructions of this court and the requirements of the local rules.
This she has failed to do.

Perhaps most egregiously, plaintiff has failed to identify a single time entry that she
claims is improper', has failed to cooperate in the preparation of a joint statement as required by
LR 54.3(e), and has failed to suggest what a reasonable fee would be for preparing and
prosecuting the motion to dismiss.? LR 54.3(d). Instead, plaintiff continues to demand that no
fee be imposed -- a demand that this court has already rejected when it granted defendant’s
request for fees in Greviskes I. Defendant was put to the burden of discovering plaintiff's
dishonesty and exposing it to the court, despite plaintiff's repeated attempts to conceal her
activities, as described in Greviskes I. After extensive discovery, in which plaintiff threw up
every roadblock she and her lawyer could think of, the court held an evidentiary hearing which
resulted in its ruling that plaintiff's unlawful and dishonest conduct required dismissal of her

action.

‘LR 54.3(d) requires the opposing party to identify those portions of a proposed fee
petition that the opposing party finds objectionable.

?This court has recently had occasion to criticize another party responding to a petition for
attorney’s fees without suggesting a proper fee award. Zaghloul v. DaimlerChrysler Services.
LLC, 2004 W.L. 2203427 at *2 (N.D. Ill. 2004).

3


le Order Form (06/97) an Nn
United S.ates District Court, Northern District of Illinois

Name of igned Jud; Sitting Judge if Othe
or Magistrate Judge | Obert W.Gettleman | “iranassigned Judge
CASE NUMBER 03 C 257 DATE Oct. 25, 2004
CASE Angelita Greviskes v Universities Research Asscn.
TITLE

[In the following box (a) indicate the party filing the motion, e.g., plaintiff, defendant, 3rd party plaintiff, and (b) state briefly the nature
of the motion being presented,]

f4OTION:
YOCKET ENTRY:
+3) ia} Filed motion of [ use listing in “Motion” box above.]
2) a Brief in support of motion due
3) Q Answer brief to motion due___. Reply to answer briefdue__.
4) a Hearing
5) Qo Status hearing
6) oO Pretrial conference[held/continued to] [set for/re-set for]on__——ssetfor_—sat__
7) Qo Trial[set for/re-set for]on___at.
8) oO ({Bench/Jury trial] [Hearing] held/continuedto___— at
o

This case is dismissed [with/without] prejudice and without costs[by/agreement/pursuant to]

OFRCP4(m) General Rule21 OO FRCP41(a\(1) OO FRCP41({a)(2).

10) @_— [Other docket entry]

Memorandum opinion and order entered. Accordingly, defendant’s
motion for attorney’s fees is granted and the court awards defendant the
sum of $54,613.50 in attorney’s fees. In addition the court awards
defendant taxable costs in the sum of $14,435.95.

ali @ [For further detail see order attached to the original minute order.]

No notices required, advised in open court.

noti ‘ired.
No notices requires number of notices

Notices mailed by judge's staff. .
Notified counsel by telephone. CC: 2 Ai) 28

fy, y initials

Docketing to mail notices.

Mail AO 450 form.

Copy to judge/magistrate judge. mand faniicia sa
courtroom .
ss deputy’s CENA Sz tog hon
initials =

Date/time received in - ;
central Clerk’s Office roaiing depuly inials



ia mm

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
ANGELITA GREVISKES, )
. ) DOCKETED
Plaintiff ) ocr 9
) No, 03 € 0257 6 2004
v. )
) Judge Robert W. Gettleman
UNIVERSITIES RESEARCH ASSOCIATION, ) neevctey
INC., d/b/a Fermilab, ) -
) uct 2 6 2004
Defendant. )

MEMORANDUM OPINION AND ORDER

In the fee petition currently pending before this court, plaintiff Angelita Greviskes and her
attorney, John Dore, demonstrate a continued inability or unwillingness to follow the directions
and the rules of the court, opting instead to prolong unnecessarily this rather unpleasant
litigation. Plaintiffs response to defendant’s court-directed motion for attorney’s fees is as
incoherent and ineffective as her behavior throughout this case. For the reasons discussed below,
defendant’s motion is granted in its entirety.

By Memorandum Opinion and Order dated June 16, 2004, this court dismissed plaintiff's
Title VII action as the “ultimate sanction” for numerous improprieties and unlawful conduct in

this case, including obstruction of justice and wire fraud. Angelita Greviskes v. Universities

Research Associates, Inc., _ F. Supp.2d ___, 2004 WL 1385834 (N.D. Il. 2004) (“Greviskes 1”).

The court also granted defendant’s request for an award of attorney’s fees incurred in connection
with the motion to dismiss, and directed the parties to comply with Local Rule 54.3. That rule
requires the parties to “confer and attempt in good faith to agree on the amount of fees or related

non-taxable expenses that should be awarded prior to filing a fee petition.”


. Defendant’s counsel at Seyfarth, Shaw LLP (“Seyfarth”) complied with their LR 54.3
obligations by submitting a fee request to plaintiff's attorney, Mr. Dore, along with copies of
their relevant timesheets/invoices and a summary of the monthly billing of each Seyfarth attorney
who worked on the motion to dismiss. In addition, defendant agreed to remove from the amount
actually charged by Seyfarth to defendant the sum of $10,317.50, representing all the time
charged by two attorneys and part of the time charged by another, resulting in a net fee request of
$54,613.50. Seyfarth informed Mr. Dore that its attorneys charged defendant a “blended rate” of
$230 an hour for all attorneys, partners and associates (and provided documentation to verify this
arrangement). Defendant also filed a bill of costs with the clerk pursuant to Fed. R. Civ. P.
54(d)(1), to which no objection has been filed.

Plaintiff responds to defendant’s motion for attorney’s fees by inaccurately claiming that
defendant failed to comply with LR 54.3, questioning certain redactions in Seyfarth’s time
records, attacking the subpoenas issued by defendant that exposed plaintiff's misconduct
(described in Greviskes 1), and attacking this court’s jurisdiction. All of these arguments are
patently frivolous.

The timesheets and other documentation provided by Seyfarth more than fulfilled
defendant’s LR 54.3 obligations. They gave plaintiff and Mr. Dore everything they needed to
respond in the constructive, professional manner envisioned by the local rule. Seyfarth provided
documentation to support the fee arrangement for a flat fee for all attorneys, redacted only those
portions of its timesheets that were irrelevant to the fee petition, and voluntarily reduced the fees
actually charged to defendant by more than $10,000 in order to accommodate any possible

objections by plaintiff.