In re National Security Agency Telecommunications Records Litigation

Filing 746

Memorandum in Opposition re 738 MOTION for Attorney Fees Defendants' Opposition to Plaintiffs' Motion for Attorney's Fees (Al-Haramain v Obama) (09-cv-109-VRW) filed byUnited States. (Attachments: # 1 Appendix, # 2 Appendix, # 3 Appendix, # 4 Appendix, # 5 Appendix, # 6 Appendix, # 7 Appendix)(Coppolino, Anthony) (Filed on 8/5/2010)

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In re National Security Agency Telecommunications Records Litigation Doc. 746 Att. 3 Defendants' Opposition to Plaintiffs' Motion for Attorney Fees Al-Haramain Islamic Found. Oregon et al. v. Obama et al. (07-cv-109-VRW) (3:06-md-1791-VRW) Appendix 3 BLOCK BILLING HOURS BY COUNSEL Dockets.Justia.com Appendix 3 - Block Billing by Counsel Block Billing: Defendants applied the following criteria to determine "serial or "block" billing entries. Entries that describe hours spent on more than one identifiable subject area, discrete work product, or distinct type of activity (including reference to "related tasks") are counted as block billed. In applying this rule, entries indicating solely that counsel reviewed, analyzed, and prepared a filing on one particular subject matter (e.g. opposition to a motion to dismiss) were not counted as serial/block billed. Entries indicating that counsel prepared for and attended a hearing were treated as serial/block billed because they do not distinguish the time spent on each activity. In light of the numerous references to "consultations" with co-counsel in the declarations, Defendants have attempted to calculate an amount of hours for such "consultations" and have set forth a separate reduction for those hours. See Appendix 4. Thus, where a consultation with co-counsel was listed with what Defendants judged to be a single subject activity, the entry was not treated as block billed. Using the foregoing criteria, the following lists the "bullet point" entries in the respective counsel's declaration that are treated as serial/block billed. These block billed hours are totaled and subjected to a 30% reduction. Note: Page references in the chart are to the page numbers indicated in the ECF generated header at the top of the declaration cited. 1. Year 2006 Eisenberg - Serial/Block Billed Hours Reduction Page/Line of Declaration 5:20-22 6:10-11 6:12-14 6:15-16 6:17-19 6:20-21 6:23-24 6:26-7:1 7:5-6 7:10 7:11-14 7:17-18 7:23-25 7:26-27 8:16-18 8:25-27 9:2-3 9:6-7 9:13-14 9:17-18 9:19-20 9:27-28 10:6 10:20-21 10:23-25 10:26-11:1 11:2-4 11:7-10 11:11-12 11:25-26 12:4-5 12:1-3 12:1-3 12:21-22 12:24-25 13:11-12 Hours in Block 26.5 10.9 5.0 41.6 2.0 71.2 44.3 7.7 8.8 4.5 9.1 4.5 12.1 21.3 121.1 30.1 62.1 5.5 29.0 72.9 12.5 27.1 10.4 11.5 4.6 22.4 29.4 39.7 15.9 23.5 7.0 4.62 (2009 share) 3.08 (2010 share) 10.0 14.7 12.7 Total Block Hours/Year 236.1 30% Reduction (70.8) 2007 184.6 (55.4) 2008 209 (62.7) 2009 169 (50.7) 2010 40.5 (12.1) 2. Year 2006 Goldberg - Serial/Block Billed Hours Reduction Page/Line of Declaration ALL HOURS ON PAGE EXCEPT AS NOTED Hours in Block ALL HOURS Except 5:2 12.2 5:5-6 3.4 5:20 2.0 5:23-27 18.0 5:28 2.0 6:1-3: 22.5 60.1 Total Block Hours/Year 204.2 -60.1 = 144.1 30% Reduction (42.23) 2007 2008 2009 2010 ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS 109 168 112.9 88.1 (32.7) (50.4) (33.9) (26.4) 3. Year 2006 2007 2008 2009 2010 Serial/Block Billed Hours Reduction - Nelson Data Page/Line of Declaration ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS Hours in Block ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS Total Block Hours/Year 561 200.8 34 85 28 30% Reduction (168.6) (60.2) (10.2) (25.5) (8.4) 4. Year 2006 Albies - Serial/Block Billed Hours Reduction Page/Line of Declaration ALL HOURS ON PAGE EXCEPT AS NOTED Hours in Block ALL HOURS Except 3:9-11 = 18.3 3:25-26 = 1.0 ALL HOURS ALL HOURS ALL HOURS ALL HOURS Total Block Hours/Year 308.5 -19.3 289.2 37.2 45.7 54.7 21.4 30% Reduction (86.8) 2007 2008 2009 2010 ALL HOURS ALL HOURS ALL HOURS ALL HOURS (11.2) (13.7) (16.4) (6.4) 5. Year 2006 Hassan - Serial/Block Billed Hours Reduction Page/Line of Declaration ALL HOURS ON PAGE EXCEPT AS NOTED Hours in Block ALL HOURS Except 4:14-16 = 7.1 4:26-27 = 5.4 12.5 ALL HOURS ALL HOURS ALL HOURS ALL HOURS Total Block Hours/Year 159.5 -12.5 = 147 30% Reduction (44.1) 2007 2008 2009 2010 ALL HOURS ALL HOURS ALL HOURS ALL HOURS 80.86 52.79 10.73 39.62 (24.3) (15.8) (3.2) (11.9) 6. Year 2006 Jaskol - Serial/Block Billed Hours Reduction Page/Line of Declaration 4:19-21 4:22-24 4:25-28 5:1-4 5:5-8 5:9-13 6:1-4 6:11-16 7:1-3 7:7-10 7:14-16 Hours in Block 16.5 32.9 21.5 7.3 9.9 26.3 1.5 29 3.1 8.1 5.2 Total Block Hours/Year 115.9 30% Reduction (34.8) 2007 2008 2009 2010 29 11.2 5.2 (8.7) (3.4) (1.6) 7. Year 2006 Hancock - Serial/Block Billed Hours Reduction Page/Line of Declaration ALL HOURS ON PAGE EXCEPT AS NOTED Hours in Block ALL HOURS Except 4:3 3 76.7 59.5 48.4 39.2 (23) (17.8) (14.5) (11.8) Total Block Hours/Year 11.3 -3.0= 8.3 30% Reduction (2.5) 2007 2008 2009 2010 ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS ALL HOURS

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