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 L. Ziarnik under Power of Attorney for Property dated April 1, 2008, as Trustee of the Joseph Ziarnik Trust dated April 1, 2008 and individually, and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually,

Plaintiffs,

V.

Tammi Goldman,

Defendant.

PETITION FOR ATTORNEYS' FEES AND AFFIDAVIT OF VICTOR J. PIOLI

In support of the Plaintiffs' Petition for Attorneys' Fees and Expenses, Victor J. Pioli, being

first duly sworn on oath, deposes and states that I have knowledge of the facts set forth in this

Petition, and if sworn as a witness I can competently testify to the following facts:

1. Victor J. Pioli is an attorney licensed to practice by the Supreme Court of Illinois

since 1998 and is a shareholder with the firm of Johnson & Bell, Ltd., which represents the

Plaintiffs in these proceedings.

2. On June 19, 2014, the Court entered its order granting Defendant's motion to vacate.

As part of the Court's order, Plaintiffs were awarded their reasonable attorney's fees and costs

incurred between January 28, 2014 and June 19, 2014. Plaintiffs submit this fee petition pursuant to

the Court's June 19, 2014 order.

3. Affiant has personal knowledge as to the office procedures of Johnson & Bell, Ltd.,

concerning the recoding of daily time, its entry on the computer system, and the general operation

of the software, together with the record retention procedures of the firm. The firm of Johnson &

Bell, Ltd. has throughout its representation pertinent to this matter, employed a time-keeping system

under which each attorney makes daily notations as to his efforts and activities on behalf of clients.

The information set forth in those daily notations are, under procedures established by Johnson &

Bell, Ltd., entered onto a computer system.

4. Both the computer hardware and the software utilized by Johnson & Bell, Ltd. are

generally recognized and employed in the business and legal community.

5. According to the records of Johnson & Bell, Ltd., kept and maintained as aforesaid,

the attorneys designated below have devoted hours in the representation of the Plaintiffs in this

matter from January 28, 2014 to June 19, 2014, allocated between such attorneys and paralegals as

follows:

RECAP OF HOURS:

Attorney No. of Hours Rate/Hr. Fee

Victor J. Pioli 5.6 hours $225 per hour $1,260.00

Alan W. Succari 4.3 hours $200 per hour $860.00

TOTAL: $2,120.00

The time entries set forth and depicted on the attached Schedule A are true and accurate

depictions of the time entries and actually reflect the time devoted to the representation of the

Plaintiff, including the out-of-pocket expenses.

2

Victor J. Pioli JOHNSON & BELL, LTD.

33 W. Monroe St. Suite 2700 Chicago, IL 60603 312-372-0770 Firm I .D. 06347

Attorneys for Plaintiffs

7. On information and belief, based on Affiant's knowledge of the general legal

community in the Chicago area regarding billing practices and rates, and having contracted for legal

services with attorneys in such community, Affiant suggests and it is his opinion that the following

hourly rates are fair and reasonable for the following individuals:

A. Victor J. Pioli - $225.00 per hour

B. Alan W. Succari - $200.00 per hour

8. Affiant was aware and personally participated in this matter. Affiant has reviewed all

the pleadings, correspondence and time slip entries relating to this matter. It is Affiant's opinion that

the time was necessary and appropriate for the proper representation of the Plaintiff's claims

between January 28, 2014 and June 19, 2014.

FURTHER, AFFIANT SAYETH NAUGHT.

CERTIFICATE OF SERVICE

I hereby certify that a true copy of Petition for Attorney's Fees and Affidavit of Victor J.

Pioli was served via United States Mail (postage prepaid) upon all counsel of record, identified

below this 28 t h day of July, 2014.

Edwin J. Belz 4407 N. Elston Ave. Chicago, IL 60630

Tami Goldmann 3939 N. Kostner Ave. Chicago, IL 60641