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PAYIETTIVISE ARKANSAS 72701
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January 17, 1990
Mr. Ernie Lancaster
300 West 15th Street
Fayetteville, AR 72701
RE: Statement - N.W. Arkansas Resource Recovery Authority
Dear Mr. Lancaster:
Enclosed herewith is my statement for legal services from the
period December 21, 1989 through January 16, 1990. I am mailing
this statement to you in your position as Chairman of the Board of
Directors of the Authority and hOpe you will present this to the
rest of the Board members as addressed to the entire Board.
As I stated to you and the Beard when I appeared before you on
December 21st, my fees for representation of the Authority in the
Robson lawsuit'and matters related to the lawsuit will be billed
on basically a monthly basis at .my usually hourly fee rate of $100
per hour. Please note that the initial research done by me during
the first few days after the Boatd hired me as your attorney,
concern my reading and digesting of the memos, pleadings and other
documents which had already been accomplished prior to December
21st and which were in the hands Of Er. Walter Niblock, as well as
the City of Fayetteville custodian of records for the Fayetteville
City Counsel.
If you or any other Board member have any questions or comments
concerning my time spent, the legal work accomplished or any other
matter concerning this statement, please do not hesitate to let me
know.
Sincerely,
6)1?"ItCROse III
Enclosure
III/pbs
11.02
at- ot
4▪ 1. - -
Date
12/21/89
12/22/89
12/23/89
12/26/89
12/27/89
12/27/89
12/28/89
1/03/90
1/06/90
1/09/90
1/10/90
1/11/90
•
1/12/90
1/14/90
1/15/90
1/16/90
Legal Services Performed/Expenses
Meeting with Authority; draft,
prepare and filing Of Motion to
Dismiss and Third Party Complaint
Conference w/Walter Niblock & K.
Gay; research and reading of file
Research & reading of file
Research & reading of file
Draft, prepare & filing of
Affidavit
FOI Hearing, Judge 'Butt -
Chancery Court
Hours
Amount
2 hours $200.00
4 hours
3 hours
1 hour
$400.00
$300.00
$100.00
1 hour $100.00
3/4 hour
Review of McCord T011ing Agreement;
review of letter from Springdale News
dated 12/27; conference w/W. Niblock
& K. Gay 1 hour
Conference w/L. Froelich;
conference w/S. Davis.; review
& filing Return of Service
(re: A.G. Edwards)
1/2 hour
Research - Nixon Hargrave Report 3 hours
Research - FOIA 2 hours
Prepare for Fayetteville City
Board Emergency Session 2 1/2 hours
Appearance before Fayetteville
City Board
Hearing, Circuit Court
(re: Motion to Quash Subpoena) 1 1/4 hours
Prepare for Motions Hearing
(re: Robson)
75.00
$100.00
$ 50.00
$300.00
$200.00
$250.00
1 hour $100.00
3 1/2 hours
Conference w/T. Burke; conference
w/W. Niblock & K. Gay;
Prepare for Motions Rearing
Motions Hearing
Copies: 270 @ .20
TOTAL (12/21/89 - 1/16/90)
$125.00
$350.00
6 hours $600.00
3 hours $300.00
$ 54.00
$3,604.00
11.03
•
JIM ROSE III
ATTORNEY
SUITE 310
CENTER COURT ROUARE
31 tar Comm
roorrrIEVILLIE. ARKANSAS 7E701
lsoi) patron
February 15, 1990
Mr. Ernie Lancaster
300 W. 15th Street
Fayetteville, AR 72701
RE: Northwest Arkansas Resource Recovery Authority
Dear Mr. Lancaster:
I have not asked you to call any meetings of the Authority Board
of Directors up to this point in time because I did not think there
was anything from the legarmaneuvering standpoint to report to the
Authority, nor were there any things I needed to get your penis-
sion or advice concerning what has been done from the day I was
hired up until this point. Additionally, I did not feel that what
I have been doing -on behalf of the Authority warranted calling a.
meeting to keep you advised, and Charge a fee for attending the
meeting and making a report. However, I believe the time has come
for the Board to be called for a meeting so I can give everyone an
update as to where we stand and what has been going on to this
point. •
The reason I feel we need to have a meeting at this point is
because I expect to receive service of the amended Robson complaint
within the next few days, and I would like to be in a position to
go over that complaint and advise the Board as to where we stand
at this point in time, in view of the new complaint being filed.
Since our hearing in Judge AdamCOurt concerning the motions to
dismiss and add parties, I have done quite a bit of research
concerning our position under the new amended complaint as I expect
it to be worded. In addition, 1 have been in close contact with
Walter and Kitty as to the various positions of the defendants with
respect to new defendants being added to the complaint by order of
Judge Adams. I expect, after talking with Larry Froelich, one of
the attorneys for Robson, that the amended complaint will be worded
differently and present softie new positions on behalf of Robson,
because there are other defendantS being added. Also, since the
hearings in Judge Adam's Court, the new attorney for the Union
National Bank has filed a brief in support of his motion for
summary judgment that brings up some different positions and
theories which 1 think 1 need to discuss with the Authority.
11.04
Mr. Ernie Lancaster
February 15, 1990
Page No
I may already be served by the amended petition by the time you get
this letter or by the time the Authority Board has a meeting and
since we will have twenty (20) days in which to respond to the
amended complaint, I want to be ahead of the game by getting a
meeting scheduled with the Authority Board as soon as possible.
I have also included an updated statement which outlines my time
and services from the date of my last statement to the present.
I an also enclosing a copy of my last statement so you will have
a comprehensive, chronological statement from the date the Board
hired me to the present. That way, the Board will be able to ask
me any questions concerning my statement at our meeting. We will
also need to discuss the means and/or manner in which I am to be
paid because as we are all aware, the Authority does not have much
of a bank account at this point in time, and although my attorney's
fees do not appear to be much when compared with other expenses of
this lawsuit, I still need to get paid on a regular basis. I might
add that there is a very good, logical reason why my fees are lower
than other fees, and that is because I have not had to do the
extensive research that the other law firms or attorneys have been
required to do in order to properly protect the interests of their
clients. As you all know, I was brought in as attorney to the
Authority much later than the other attorneys involved and because
of that, most of the initial research and preparing for what we are
in the middle of at the present time, had already been done by the
other law firms. The Authority, as well as myself as your
attorney, greatly benefited from all the work they did and I was
not required to do the actual in-depth research that they had to
do, but merely had to get myself, as I like to put it, "up to
speed" by reading, studying and understanding all of the work they
had already done.
Please let me know when you want to call the meeting and we can all
get together at that time to discuss all of the things I have
mentioned in this letter.
Sincerely,
im ose III
I/pbs
Enclosures
11.05
DATE
Legal Services Performed/Expenses
1/23/90
1/23/90
1/27/90
1/30/90
2/05/90
2/08/90
2/09/90
Wash. Co.
Review of
Review of
Circuit Ct.-FOI Hearing
Niblock precedent
Hirsch precedent
FOI Hearing; conf. w/Judge Smith,
W. NiblockK. Gay, D. Olive
Review of revised precedent
Conf. w/L. Froelich
Review of Cummings and Hirsch
affidavits
2/12/90 Conf. w/K. Gay; review of Union
National reply brief; research re;
Union National reply brief; ltr to
L. Burks
Balance from prior statement '(attached)
Hours Amount
3 Hours $300.00
1/2 Hour $ 50.00
1/2 Hour $ 50.00
11/2 Hour
1/2 Hour
1/2 Hour
1 Hour
31/2 Hour
$150.00
$ 50.00
$ 50.00
$100.00
$350.00
TOTAL: $1100.00
$3604.00
$4704.00
TOTAD DUE:
11.06
•
JIM ROSE 111
Arthistrary
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FAVETTIVILIS.ARKAUSAIII 72701
WOO 1511.401.8
March 5, 1990
Mr. Ernie Lancaster
_300 W. 15th Street
Fayetteville, AR. 72701
RE: Northwest Arkansas Resource Recovery Authority
Dear Mr. Lancaster:
Pursuant to my last letter to you dated February 15, 1990, our
follow-up telephone conversation subsequent to my letter, and
in anticipation of your settingah meeting of the Authority
Board of Directors shortly, I have brought my statement up to
date for presentation to the Board.
I know the majority of the Authority Board has been very busy
with City Board business the last couple of weeks, but as I
said in my last letter to you, I Sincerely believe that the
Authority Board needs to meet so I :Can bring you up to date
on what the statue of the Robson suit is with respect to the
Authority. Additionally, it looks like things are starting to
"heat up" in the Robson suit and I teed to advise the Autho-
rity Board as to where we go from here.
Please give me a call as soon as you get this letter so we can
discuss getting a meetin set, hopefUlly prior to this coming
Friday as I am going to North Carolina for my oldest daughter's
wedding and will be flying•out Friday afternoon.
11.07
•
DATE LEGAL SERVICES PERFORMED/EXPENSES _ HOURS AMOUNT
(Balance forward previously billed - 12/21/89 thru
2/21/90
2/23/90
2/28/90
, 3/01/90
3/02/90
2/12/90)
Review of City's Renewed Motion for
Protective Order and Memorandum of Law
re: motion 1/2 Hour
1 Hour
Review of Motion to Intervene and
Brief in Support; Motion for Exten-
sion of Time; Motion to Withdraw
Review of City's Memorandum in
Response to Motion to Intervene and
Motion to Withdraw; Research re:
City's Memo
Review of Plaintiff's Supplemental
BrieftinlResponse to Motion for
Summary Judgment by Union 'National;
Research re: Supplenental Brief
Research
Judgment
Response
Brief)
re: Motion for SUMmary
by Union National and
to Motion (supplemental
2 Hours
21/2 Hours
31/2 Hours
TOTAL DUE:
11.08
$4704.00
50.00
100.00
200.00
250.00
350.00
. $5654.00
RESOLUTION NO. 45-90
A RESOLUTION AUTHORIZING PAYMENT OF LEGAL FEES
TO JIM ROSE FOR THE NORTHWEST ARKANSAS
RESOURCE RECOVERY AUTHORITY AND TO APPROVE A
BUDGET ADJUSTMENT IN THE AMOUNT OF $5,098.00.
BE IT RESOLVED BY THE 30ARD OF DIRECTORS OF THE CITY OF
FAYETTEVILLE, ARKANSAS:
Section 1. That the Board of Directors hereby authorize
payment to Jim Rose in the amount of $5,098.00 for services
rendered in the incinerator disengagement lawsuit. A copy of the
statment authorized for execution, hereby is attached hereto marked
Exhibit "A" and made a part hereof.
Section 2.
of $5,098.00 as
attached hereto
And approves a budget adjustment in the amount
more fully,arctAut in the budget adjustment form
and made paA.i4erkof., .
4 '
.y20-th,
PASSED AND APPROVED :Chit day of March
4 I
• 444
APPROVED
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