Rupa Marya v. Warner Chappell Music Inc

Filing 332

In Opposition re: NOTICE OF MOTION AND MOTION for Attorney Fees Plaintiffs' Notice of Motion and Motion for Award of Attorneys' Fees and Expenses and for Incentive Compensation Awards; Memorandum of Points and Authorities in Support Thereof 323 /Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses filed by Defendant Warner Chappell Music Inc. (Attachments: # 1 Declaration Of Kelly M. Klaus In Support Of Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses, # 2 Exhibit 1 to Declaration of Kelly M. Klaus In Support Of Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses, # 3 Exhibit 2 to Declaration of Kelly M. Klaus In Support Of Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses, # 4 Exhibit 3 to Declaration of Kelly M. Klaus In Support Of Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses, # 5 Exhibit 4 to Declaration of Kelly M. Klaus In Support Of Defendants' Opposition To Plaintiffs' Motion For Award Of Attorneys' Fees And Expenses)(Klaus, Kelly)

Exhibit 1

Ex. 1
6

CLASS COUNSEL’S CLAIMED HOURS AND LODESTAR
AMOUNTS

TOTAL TIME – ALL PHASES OF LITIGATION
Firm

Hours
Worked

Lodestar

Wolf Haldenstein
Fitzgerald Donahue
Glancy Prongay
Newman PC

5,472.50
894.04
493.25
2,193.00

$3,164,121.00
$351,570.80
$257,385.00
$1,403,520.00

Total

9,052.79

$5,176,596.80

Ex. 1
7

INITIAL COMPLAINT
Hours
Worked

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC
Total

Lodestar

365.90
234.80
39.00
928.30

$192,732.50
$101,239.00
$20,820.00
$594,112.00

1,568.00

Law Firm

$908,903.50

AMENDED COMPLAINT
Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

377.20
41.50
49.90
56.50

$223,932.50
$18,026.50
$26,908.00
$36,160.00

Total

525.10

$305,027.00

Firm

OPPOSITION TO MOTION TO DISMISS
Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

196.50
108.20
63.70
101.10

$131,019.00
$46,266.50
$31,757.75
$64,704.00

Total

469.50

$273,747.25

Firm

Ex. 1
8

DISCOVERY
Firm

Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

2,076.90
123.30
115.45
435.60

$1,092,102.50
$46,555.00
$61,909.251
$278,784.00

Total

2,751.25

$1,479,350.75

SUMMARY JUDGMENT
Firm

Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

1,675.40
283.54
203.65
337.80

$981,584.50
$96,687.30
$102,705.25
$216,192.00

Total

2,500.39

$1,397,169.05

TRIAL PREPARATION
Hours
Worked

Lodestar

Wolf Haldenstein
Newman PC

281.40
142.00

$172,170.50
$90,880.00

Total

423.40

$263,050.50

Firm

1

This corrects an apparent error in Thomas Kennedy’s lodestar for the discovery period:
12.3 x 525 = 6,457.50—not 4,858.50, the amount listed at ¶ 16 of the Wolke Declaration.

Ex. 1
9

SETTLEMENT NEGOTIATION
Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

259.10
38.60
13.05
106.40

$212,489.50
$15,654.00
$8,027.25
$68,096.00

Total

417.15

$304,266.75

Firm

SETTLEMENT APPROVAL/ADMINISTRATION
Hours
Worked

Lodestar

Wolf Haldenstein
Donahue Fitzgerald
Glancy Prongay
Newman PC

240.10
64.10
8.50
85.30

$158,090.00
$27,142.50
$5,257.50
$54,592.00

Total

398.00

$245,082.00

Firm

Ex. 1
10