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 UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

COURT FILE NO.: 2:08-cv-14241 

ROBERT LEVANDER 

 Plaintiff, 

-vsI.C. SYSTEM, INC., and 

JOHN DOE, 

 Defendants 

PLAINTIFFS’ FEE APPLICATION

 [ORAL ARGUMENT REQUESTED] 

FEE APPLICATION OF 

PLAINTIFF’S COUNSEL 

NOW COME Rex C. Anderson, Attorney for Plaintiff in the above entitled action and 

hereby state his petition for allowance of fees and costs as follows: 

1. That Plaintiff’s attorney seek approval of fees in the amount of $62,12.25 

encompassing 187.52 hours for Plaintiff’s attorney time at the rate of $300.00 per hour for a total 

of $56,256.00 and; 47 hours for paralegal time at the rate of $125.00 per hour for a total of 

$5876.25. In addition, Plaintiff’s counsel seeks costs in the amount of $2732.34 including 

milelage. No retainer in this matter has been received by counsel. 

2. Services were rendered in this case from July 23, 2008 through the present date. 

3. Applicant have represented the Plaintiff for purposes of enforcing 15 USC 1692 

et seq., as a private attorney general against Defendant's unlawful, false, deceptive, harassing, 

oppressive and abusive practices. Applicants prepared and filed an complaint under 15 USC 

1692 et seq.,. Counsel prepared and responded to numerous discovery requests, attended several 

hearings in this matter and addressed issues relating to same. 

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4. Applicant spent much time attempting to obtain discovery which would not 

otherwise been spent but for Defendant's refusal to comply with the discovery rules. 

5. Defendant took its chances by submitting an ineffective offer of judgment on or 

about February 3, 2009, four months after the complaint was filed and after significant hours 

were already spent by Applicant. 

6. Despite being apprised of plaintiff's bankruptcy case on December 1, 2008, 

defendant did not bring its Motion to Limit Damages until March 6, 2009 and did so despite case 

law clearly showing that attorney fees on pre-petition FDCPA claims are not included in the 

bankruptcy estate. 

7. Defendant aggressively defended this case, as was its right. This defense produced 

a large amount of litigation, and significantly increased the number of hours Plaintiff’s attorney 

committed to this case . 

8. On June 10, 2009, applicant provided documentation of time entries and costs upon 

Defense counsel’s request and indicated a willingness to discuss (which still holds true) but has 

not heard back. 

9. Plaintiff’s counsel has documented total fees and costs of $64,855.59 but is 

discounting this total amount by 20% ($12,971.12) and requests this court to award $51,884.47. 

WHEREFORE Applicants respectfully request this Honorable Court allow fees and costs 

in the amount of $51,884.47. 

Monday, June 15, 2009 /s/ Rex C. Anderson__________ 

Rex C. Anderson (P47068) 

9459 Lapeer Rd 

Davison, MI 48423 

Tel. (810) 653 3300 

Fax. (810) 658 2510 

Eml. rex@rexandersonpc.com

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CERTIFICATE OF SERVICE 

 I certify that on June 15, 2009, the foregoing papers were electronically filed with the 

Clerk of the Court using the Court’s electronic filing system which will send notification of such 

filing to the following: 

Daniel J. Ammon Gregory R. Neidle Brian P. Parker

30150 Telegraph Rd. 30150 Telegraph Rd. 30700 Telegraph Rd. 

Suite 410 Suite 410 Suite 1580 

Bingham Farms, MI 48025 Bingham Farms, MI 48025 Bingham Farms, MI 48025 

 __/s/ Rex C. Anderson__________ 

 Rex C. Anderson, Esq. (P47068) 

 Attorney for Plaintiff 

 9459 Lapeer Rd, Suite 101 

 Davison MI 48423 

 Telephone: (810) 653-3300 

 rex@rexandersonpc.com

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