Case 1:20-cv-01008-PLM-RSK ECF No. 132, PageID.

4462 Filed 12/16/21 Page 1 of 2

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MICHIGAN

WINERIES OF THE OLD MISSION

PENINSULA (WOMP) ASSOC., a Michigan
Nonprofit Corporation, BOWERS HARBOR
VINEYARD & WINERY, INC, BRYS WINERY, Case No: 1:20-cv-01008
LLC, CHATEAU GRAND TRAVERSE, LTD,
CHATEAU OPERATIONS, LTD, GRAPE
HARBOR, INC., MONTAGUE Honorable Paul L. Maloney
DEVELOPMENT, LLC, OV THE FARM, LLC, Magistrate Judge Ray S. Kent
TABONE VINEYARDS, LLC., TWO LADS,
LLC, VILLA MARI LLC, WINERY AT BLACK
STAR FARMS, L.L.C.,

Plaintiffs,
v

PENINSULA TOWNSHIP, Michigan Municipal

Corporation,
Defendant.

PLAINTIFFS’ PETITION FOR REIMBURSEMENT OF ATTORNEY FEES AND

COSTS PURSUANT TO ECF NO. 127

Plaintiffs, through their counsel Miller, Canfield, Paddock and Stone, PLC, petition the

Court to award them $17,362.48 in attorney fees and costs. This Petition is filed pursuant to the

Court’s written order following the December 2, 2021 hearing (ECF No. 127), which awarded

Plaintiffs their costs and attorney fees for the period between September 14, 2021 and October 6,

2021. Plaintiffs request $16,486.80 in attorney fees based on:

a) $15,620.00 for Attorney Infante (39.5 hours @ $400.00/hour).

b) $0.00 for Attorney DeJong (0.5 hours @ $580.00/hour).

c) $220.00 for Attorney Eldridge (0.55 hours @ $400.00/hour)

d) $585.20 for Attorney Ragatzki (2.09 hours @ $280.00/hour)

e) $61.60 for Attorney Gartman (0.22 hours @ $280.00/hour)

TOTAL fees requested: $16,486.80

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Plaintiffs also request $875.68 in costs for the period from September 14 to October 6.

For the reasons set forth in the accompanying Brief in Support and Declaration of Joseph

M. Infante, Plaintiffs move the Court for an order that Defendant Peninsula Township reimburse

Plaintiffs $17,362.48 for their reasonable costs and attorney fees. In addition, the Wineries pray

that the Court consider awarding the Wineries a portion of the attorneys’ fees they incurred in

bringing their motion to enforce the settlement agreement and for sanctions, which total

$11,780.40.

Respectfully submitted,

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.

By: /s/ Joseph M. Infante

Joseph M. Infante (P68719)
Stephen M. Ragatzki (P81952)
Christopher J. Gartman (P83286)
99 Monroe Avenue NW, Suite 1200
Grand Rapids, MI 49503
(616) 776-6333
Dated: December 16, 2021

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