Alexander et al v. Cahill et al

Filing 56

REPLY to Response to Motion re 50 MOTION for Attorney Fees and Costs filed by James L. Alexander, Alexander & Catalano LLC, Public Citizen, Inc.. (Attachments: # 1 Second Declaration of Gregory A. Beck# 2 Second Declaration of Brian Wolfman)(Beck, Gregory)

Alexander et al v. Cahill et al

Doc. 56 Att. 1

Case 5:07-cv-00117-FJS-GHL

Document 56-2

Filed 10/01/2007

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK JAMES L. ALEXANDER, et al., ) ) ) Plaintiffs, ) ) v. ) ) THOMAS J. CAHILL, et al., ) ) Defendants. _______________________________________ )

Civil Action No. 5:07-cv-00117-FJS-GHL

SECOND DECLARATION OF GREGORY A. BECK I, Gregory A. Beck, declare as follows: 1. I am an attorney at Public Citizen Litigation Group (PCLG), a nonprofit public-

interest law firm in Washington, DC. I am submitting this declaration in further support of plaintiffs' motion for attorneys' fees and costs to reflect additional time spent drafting plaintiffs' reply memorandum in support of their motion for fees and costs. 2. I spent a total of 11.7 hours researching and drafting the reply memorandum and

this declaration. Mr. Wolfman spent a total of .9 hours reading and editing the memorandum and preparing his own affidavit. A detailed description of the hours claimed by plaintiffs' counsel is attached as Exhibit 1. All the entries on Exhibit 1 were contemporaneously recorded and copied from electronic time records kept by counsel. 3. Attorney Gregory A. Beck Brian Wolfman Total: The additional fees claimed by plaintiffs are summarized as follows: Requested Hours 11.7 .9 12.6 Requested Rate $215/hour $440/hour Total Fee $2515.50 $396.00 $2911.50

-1Dockets.Justia.com

Case 5:07-cv-00117-FJS-GHL

Document 56-2

Filed 10/01/2007

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4.

Plaintiffs previously requested $59,255.50 in fees and $1856.04 in costs.

Including the $2911.50 in fees for time spent drafting the reply memorandum, plaintiffs request total fees of $62,167 and total costs of $1856.04. Pursuant to 28 U.S.C. § 1746, I certify under penalty of perjury that the foregoing is true and correct. Executed on: October 1, 2007

/s/Gregory A. Beck Gregory A. Beck

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Case 5:07-cv-00117-FJS-GHL

Document 56-2

Filed 10/01/2007

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Exhibit 1

Case 5:07-cv-00117-FJS-GHL

Document 56-2

Filed 10/01/2007

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Time Record Report - All Staff
STAFF
Beck, Greg Beck, Greg Beck, Greg Beck, Greg Beck, Greg

DATE
9/25/2007 9/26/2007 9/28/2007 9/30/2007 10/1/2007

CASENAME
Alexander v. Cahill Alexander v. Cahill Alexander v. Cahill Alexander v. Cahill Alexander v. Cahill

TIME (hr) DESCRIPTION
0.2 3 6 1.5 1 11.7 0.7 0.2 0.9 Draft declaration in reply to defendants' fee opposition Read and edit GB's reply regarding atty's fees Review response to fee application Research issues for reply on fee application Research/draft reply brief in support of fees Research/draft reply brief on fees. Edit/revise reply

Summary for 'Staffer' = Beck, Greg (5 detail records) Wolfman, Brian Wolfman, Brian 10/1/2007 10/1/2007 Alexander v. Cahill Alexander v. Cahill

Summary for 'Staffer' = Wolfman, Brian (2 detail records)

Grand total for all staff:

12.6

Printed on: 10/1/2007 7:14:49 PM

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