Vanginderen v. Cornell University

Filing 40

DECLARATION re 38 MOTION for Attorney Fees of Clifford S. Davidson by Defendant Cornell University. (Attachments: # 1 Exhibit A through C)(Davidson, Clifford) (vet).

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Vanginderen v. Cornell University Doc. 40 1 NELSON E. ROTH, SBN 67350 2 CORNELL UNIVERSITY 3 Garden Avenue 4 Telephone: 5 6 7 8 9 10 11 12 14 15 17 18 19 20 21 22 23 24 25 26 27 28 v. 300 CCC Building Ithaca, New York 14853-2601 (607)255-5124 Facsimile: (607)255-2794 ner3@cornell.edu BERT H. DEIXLER, SBN 70614 bdeixler@proskauer.com CLIFFORD S. DAVIDSON, SBN 246119 cdavidson@proskauer.com PROSKAUER ROSE LLP 2049 Century Park East, 32nd Floor Los Angeles, CA 90067-3206 Telephone: (310) 557-2900 Facsimile: (310) 557-2193 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07-CV-2045 BTM(JMA) Hon. Barry T. Moskowitz DECLARATION OF CLIFFORD S. DAVIDSON IN SUPPORT OF CORNELL'S MOTION FOR ATTORNEYS' FEES [Per chambers, no oral argument unless requested by the Court] [Notice of Motion and Motion and Deixler Declaration filed concurrently herewith] Hearing Date: August 22, 2008 Time: 11:00 a.m. Place: Courtroom 15 Action Filed: October 1, 2007 13 KEVIN VANGINDEREN, Plaintiff, 16 CORNELL UNIVERSITY, Defendant. Dockets.Justia.com 1 3 1. DECLARATION OF CLIFFORD S. DAVIDSON 2 I, Clifford S. Davidson, declare as follows: I am an associate at Proskauer Rose LLP ("Proskauer"), counsel of record for 4 defendant Cornell University ("Cornell"). I am admitted to practice before this Court. The facts 5 stated herein are personally known to me and I could and would testify competently thereto if 6 called upon as a witness. 7 2. I was primarily responsible for the drafting and research performed in connection 8 with Cornell's Special Motion to Strike Plaintiff's Complaint Pursuant to Section 425.16 of the 9 California Code of Civil Procedure, which Cornell filed on November 2, 2007 (the "Anti-SLAPP 10 Motion"). 11 3. Attached collectively hereto as Exhibit A are true and correct copies of the bills 12 Proskauer submitted for payment to Cornell for work performed from October 3, 2007 to 13 December 28, 2007. The bills contained in Exhibit A reflect the time entries inputted by 14 Proskauer attorneys and legal assistants into the DTE billing system on a daily basis reflecting the 15 hours spent on this matter and a description of the work those attorneys and legal assistants 16 performed. I redacted and annotated Exhibit A so that it reflects only time spent on activities 17 directly related to the Anti-SLAPP Motion. For example, I have redacted, subtracted and 18 interlineated entries related to removal of Plaintiff's complaint to this Court, as such activity 19 arguably is not related to the Anti-SLAPP Motion. The time entries I removed and redacted from 20 Exhibit A resulted in a reduction of $6,912.50 from the amount billed to Cornell. 21 4. Attached hereto as Exhibit B is a chart reflecting the hours worked per month on 22 the Anti-SLAPP Motion from October 3, 2007 to June 2, 2008 and the total fees related to the 23 Anti-SLAPP Motion incurred in each of those months. 24 5. Attached hereto as Exhibit C is a chart summarizing the hours I worked preparing 25 and filing the Bill of Costs and Cornell's Motion for Attorneys' Fees. Those hours have not yet 26 been submitted to Cornell for payment and therefore are not reflected in Exhibit A. I compiled 27 Exhibit C based on the raw DTE entries I have made since June 3, 2008. I will provide to the 28 1 07-cv-2045 BTM(JMA)

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