IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - PROBATE DIVISION

ESTATE OF

JOSEPH L. ZIARNIK,

A Disabled Person,

No. 08 P 8140

Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services NFP and individually; Devon Bank as agent for Joseph Ludwig Ziarnik under Power of Attorney, dated April 1, 2008, as Trustee of Joseph Ziarnik Trust, dated April 1, 2008, and individually and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually.

Plaintiffs, v.

Tammy Goldmann, Google, Inc. Defendants.

ANSWER AND OBJECTION TO PETITION FOR ATTORNEY'S FEES AND AFFIDAVIT OF VICOTR J. PIOLI

Now comes Edwin J. Belz and objects to Petition for Attorney's Fees and

Affidavit of Victor Pioli and objects to same, pursuant to Illinois Section 2-615 and 2-

619, as follows:

COUNT I OBJECTION TO PETITION FOR FEES AND AFFIDAVIT

PURSUANT TO SECTION 2-615 AND 2-619

AS TO 2-615

1) Petition is not in conformity with the rules of Court and outstanding case law

regarding petition for fees in that it fails to set forth the experience of the

attorneys involved, the difficulty of the subject issues, and whether said time

expended was reasonable and necessary in regards to the amount charged;

2) The petition is not a petition but in the nature of a motion with a computation

attached;

3) If in fact the fee petition is to be considered by this court as a petition, it is

without merit in that the hours alleged and amounts for work done is predicated

upon conclusionary statements without any indication as to what services were

specifically rendered;

4) Petitioner is seeking attorney's fees for hours clocked after Edwin J. Belz

withdrew as an attorney to this cause on March 28, 2014;

5) Certain hours indicated on Petitioner's computation sheet are only for status

dates;

Wherefore Edwin J. Belz prays Petition for Attorney's Fees be dismissed with

1) Edwin J. Belz admits is Mr. Pioli is an attorney to licensed to practice law in

the State of Illinois;

2) Edwin J. Belz admits said order referenced in paragraph 2 was entered;

3) Edwin J. Belz neither admit nor deny as respondent has insufficient

knowledge of the procedures of Johnson and Bell and require strict proof of

the same

AS TO 2-619

prejudice.

Edwin J. Belz COUNT II ANSWER

4) Edwin J. Belz denies the allegations contained in paragraph 4;

5) Edwin J. Belz denies the fees are reasonable and are without basis for costs

incurred, nor labor performed, nor what the experience of Victor Pioli or Alan

Succari is; and further denies the schedule is true and accurate. The schedule

setting forth fees is vague and indefinite, redundant and without specificity;

6) Edwin J. Belz makes no response to paragraph 6 as there is no such

paragraph;

7) Without elaboration on work done, Edwin J. Belz denies that services

performed should be remunerated at rate indicated;

8) Edwin J. Belz neither admits or denies allegations contained in paragraph 8 as

he does not know what actions were performed by Victor Pioli

Wherefore Edwin J. Belz prays Petition for Attorney's fees be denied.

Edwin J. Belz 4407 N. Elston Ave. Chicago, Illinois 60630 773-282-9129 Atty. No. 25663

Edwin J. Belz

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - PROBATE DIVISION

ESTATE OF

JOSEPH L. ZIARNIK,

A Disabled Person,

No. 08 P 8140

Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services NFP and individually; Devon Bank as agent for Joseph Ludwig Ziarnik under Power of Attorney, dated April 1, 2008, as Trustee of Joseph Ziarnik Trust, dated April 1, 2008, and individually and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually.

Plaintiffs, v.

Tammy Goldmann, Google, Inc. Defendants.

NOTICE OF FILING

To: Tammy Goldmann 3939 N. Kostner Avenue Chicago, Illinois 60641

Victor Pioli Johnson and Bell 33 W. Monroe Street Suite 2700 Chicago, IL 60603

Janna Dutton Dutton and Casey 79 W. Monroe Street Suite 1320 Chicago, IL 60603

Please take notice that on 7 t h day of October, 2014,I filed with the Circuit Court of Cook County, Illinois, an Objection and Answer to Petition for Attorney's Fees, a copy of which is attached hereto.

Edwin J. Belz, Atty. 4407 N. Elston Ave. Chicago, IL 60630 773-282-9129 Atty. No. 25663