IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION

ESTATE OF
JOSEPH L. ZIARNIK

No. 08 P 8140

A Disabled Person

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.
PLAINTIFFS' REPLY IN SUPPORT OF PETITION FOR ATTORNEY'S FEES
Plaintiffs, 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, by and through their attorneys,

JOHNSON & BELL, LTD.,

following as their reply in support their petition for attorney's fees.

hereby submits the

1.

Edwin Belz ("Belz") has filed his objection to Plaintiffs' petition for attorney's

fees. Belz's objection cites to no authority and summarily states that Plaintiffs' petition does
not conform to the "rules of Court and outstanding case law." However, Belz does not
identify the alleged "rules" or "case law."
2.

Belz also takes issue with the fact that attorney time was billed to attend status

conferences. It is not clear what Belz's gripe in this regard is as the Court specifically invited
a petition for attorney's fees incurred by Plaintiffs to attend the Court's mandated status
conferences that Belz failed to appear for.
3.

In the end, Belz states no real objection to Plaintiffs' petition.

Plaintiffs'

petition bills only for time spent attending status conferences and in preparing Plaintiffs'
response to Plaintiffs' motion to vacate as directed by the Court in June 19, 2014 order. See
June 19, 2014 Order, at p. 4. None of the time billed by Plaintiffs' attorney is excessive.
Indeed, Belz makes no such argument in his objection.
4.

Plaintiffs' petition should be granted in its entirety and Plaintiffs should be

awarded their $2,120.00 incurred as a result of Belz's dilatory conduct.

WHEREFORE,

Plaintiffs,

DEVON

BANK,

ADVOCACY

GUARDIANSHIP

SERVICES NFP, JOSH MITZEN, and JANNA DUTTON, respectfully request that this
Honorable Court enter an order granting their petition for attorney's fees and for such other
relief as the Court deems just and proper.