Schoolcraft v. The City Of New York et al

Filing 560

DECLARATION of Joshua P. Fitch (Master Declaration) in Support re: 559 MOTION for Attorney Fees , Costs and Disbursements.. Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit A - Declaration of Jon L. Norinsberg, Esq., # 2 Exhibit B - Declaration of Nathaniel Smith, Esq., # 3 Exhibit C - Declaration of Joshua P. Fitch, Esq., # 4 Exhibit D - Declaration of Gerald M. Cohen, Esq., # 5 Exhibit E - Declaration of John Lenoir, Esq., # 6 Exhibit F - Declaration of Howard A. Suckle, Esq., # 7 Exhibit G - Declaration of Magdalena Bauza, # 8 Exhibit H - Billing Entries and Costs for Jon L. Norinsberg, Esq., # 9 Exhibit I - Billing Entries and Costs for Nathaniel Smith, Esq., # 10 Exhibit J - Billing Entries for Joshua P. Fitch, Esq., # 11 Exhibit K - Billing Entries and Costs for Gerald M. Cohen, Esq., # 12 Exhibit L - Billing Entries for John Lenoir, Esq., # 13 Exhibit M - Billing Entries for Howard A. Suckle, Esq., # 14 Exhibit N - Billing Entries for Magdalena Bauza, # 15 Exhibit O - Declaration of Jonathan Abady, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 16 Exhibit P - Declaration of Christopher Galiardo, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 17 Exhibit Q - Declaration of Afsaan Saleem, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 18 Exhibit R - Declaration of Michael L. Spiegel, Esq. in support of the hourly rate of Nathaniel Smith, Esq., # 19 Exhibit S - Declaration of Zachary Margulis-Ohnuma, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 20 Exhibit T - Declaration of Irving Cohen, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 21 Exhibit U - Declaration of Katherine Smith, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 22 Exhibit V - Declaration of Hugh M. Mo, Esq. in support of the hourly rate of John Lenoir, Esq., # 23 Exhibit W - Declaration of Jeffrey Schlanger, Esq. in support of the hourly rate of John Lenoir, Esq., # 24 Exhibit X - Declaration of David Finkler, Esq. in support of the hourly rate of Howard A. Suckle, Esq., # 25 Exhibit Y - Declaration of Mitchell Bloch, Esq. in support of the hourly rate of Howard A. Suckle, Esq., # 26 Exhibit Z - 2013-2014 National Law Journal Billing Survey of Large Firm Billing Rates, # 27 Exhibit AA - 2013-2014 New York City Law Department Year in Review for the Special Federal Litigation Division, # 28 Exhibit BB - New York City Law Department Special Federal Litigation Homepage, # 29 Exhibit CC - Verdict Search's Top Verdicts of 2013, # 30 Exhibit DD - Super Lawyers 2015 Annual List of Top Lawyers in the New York Metro Area, # 31 Exhibit EE - Order in Bernabe v. City of New York, 13 CV 5531 (LGS) relating to Mr. Norinsberg's hourly rate)(Fitch, Joshua)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------X
ADRIAN SCHOOLCRAFT,
Plaintiff,
-againstMASTER DECLARATION IN
SUPPORT OF MOTION FOR
ATTORNEY'S FEES

10 CV 06005
(RWS)
THE CITY OF NEW YORK, et al.,
Defendants.
----------------------------------------------------------------X
JOSHUA P. FITCH, declares pursuant to 28 U.S.C. §1746, under penalty of perjury,
that the following is true and correct:
1.

I am a partner with the law firm of Cohen & Fitch LLP, the co-counsel of record

for plaintiff ADRIAN SCHOOLCRAFT. As such, I am familiar with the facts stated below, and
I submit this Declaration to place on the record the relevant documents in support of plaintiff’s
motion for attorney's fees, costs and disbursements pursuant to Rule 54(d) of the Federal Rules
of Civil Procedure and 42 U.S.C. § 1988:
2.

Attached as Exhibit A is a copy of the Declaration of Jon L. Norinsberg, Esq. in

support of motion for attorneys fees and costs.
3.

Attached as Exhibit B is a copy of the Declaration of Nathaniel Smith, Esq. in

support of motion for attorneys fees and costs.
4.

Attached as Exhibit C is a copy of the Declaration of Joshua P. Fitch, Esq. in
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support of motion for attorneys fees and costs. 1
5.

Attached as Exhibit D is a copy of the Declaration of Gerald M. Cohen, Esq. in

support of motion for attorneys fees and costs. 2
6.

Attached as Exhibit E is a copy of the Declaration of John Lenoir, Esq. in support

of motion for attorneys fees and costs.
7.

Attached as Exhibit F is a copy of the Declaration of Howard A. Suckle, Esq. in

support of motion for attorneys fees and costs.
8.

Attached as Exhibit G is a copy of the Declaration of Magdalena Bauza in

support of motion for attorneys fees and costs.
9.

Attached as Exhibit H is a copy of the itemized hourly billing entries and costs

for Jon L. Norinsberg, Esq. 3
10.

Attached as Exhibit I is a copy of the itemized hourly billing entries and costs for

Nathaniel Smith, Esq. 4
11.

Attached as Exhibit J is a copy of the itemized hourly billing entries and costs for

Joshua P. Fitch, Esq.
12.

Attached as Exhibit K is a copy of the itemized hourly billing entries and costs

for Gerald M. Cohen, Esq.
13.

Attached as Exhibit L is a copy of the itemized hourly billing entries and costs

for John Lenoir, Esq.
14.

Attached as Exhibit M is a copy of the itemized hourly billing entries and costs

1

Joshua P. Fitch is one of the partners of Cohen & Fitch LLP.
Gerald M. Cohen is one of the partners of Cohen & Fitch LLP.
3
Contained within this bill are also the entries for Mr. Norinsberg's Associate John Meehan, Esq. and paralegal Nicole
Burzstyn.
4
Contained within this bill are also the entries for Mr. Smith's colleague James McCutcheon, Esq. and paralegals Lysia
Smejika, Jeanette Lenoir, and Jeremy Smith. Howard A. Suckle, Esq. and Magdalena Bauza also worked on this matter at
the request of Mr. Smith, and they have submitted individual declarations and billing records for their time.
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2

for Howard A. Suckle, Esq.
15.

Attached as Exhibit N is a copy of the itemized hourly billing entries and costs

for Magdalena Bauza.
16.

Attached as Exhibit O is a copy of the Declaration of Jonathan Abady, Esq. in

support of the hourly rate of Jon L. Norinsberg, Esq.
17.

Attached as Exhibit P is a copy of the Declaration of Christopher Galiardo, Esq.,

in support of the hourly rate of Jon L. Norinsberg, Esq.
18.

Attached as Exhibit Q is a copy of the Declaration of Afsaan Saleem, Esq. in

support of the hourly rate of Jon L. Norinsberg, Esq.
19.

Attached as Exhibit R is a copy of the Declaration of Michael L. Spiegel, Esq. in

support of the hourly rate of Nathaniel B. Smith, Esq.
20.

Attached as Exhibit S is a copy of the Declaration of Zachary Margulis-Ohnuma,

Esq. in support of the hourly rate of Joshua P. Fitch and Gerald M. Cohen, partners of Cohen &
Fitch LLP.
21.

Attached as Exhibit T is a copy of the Declaration of Irving Cohen, Esq. in

support of the hourly rate of Joshua P. Fitch and Gerald M. Cohen, partners of Cohen & Fitch
LLP.
22.

Attached as Exhibit U is a copy of the Declaration of Katherine Smith, Esq. in

support of the hourly rate of Joshua P. Fitch and Gerald M. Cohen, partners of Cohen & Fitch
LLP.
23.

Attached as Exhibit V is a copy of the Declaration of Hugh H. Mo, Esq. in

support of the hourly rate of John Lenoir, Esq.
24.

Attached as Exhibit W is a copy of the Declaration of Jeffrey Schlanger, Esq. in

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support of the hourly rate of John Lenoir, Esq.
25.

Attached as Exhibit X is a copy of the Declaration of David Finkler, Esq. in

support of the hourly rate of Howard A. Suckle, Esq.
26.

Attached as Exhibit Y is a copy of the Declaration of Mitchell Bloch, Esq. in

support of the hourly rate of Howard A. Suckle, Esq.
27.

Attached as Exhibit Z is a copy of the 2013-2014 National Law Journal Billing

Survey of Large Firm Billing Rates.
28.

Attached as Exhibit AA is a copy of the relevant pages from the 2013-2014 New

York City Law Department Year in Review pertaining to the Special Federal Litigation Division.
29.

Attached as Exhibit BB is a copy of the New York City Law Department Special

Federal Litigation website page at http://www.nyc.gov/html/law/html/divisions/special-federallitigation.shtml (accessed December 14, 2015).
30.

Attached as Exhibit CC is a copy of the relevant pages from Verdict Search's

Top Verdicts of 2013.
31.

Attached as Exhibit DD is a copy of the relevant pages from Super Lawyers 2015

Annual List of Top Lawyers in the New York Metro Area.
32.

Attached as Exhibit EE is a copy of the Order in Bernabe v.City of New York, 13

CV 5531 (LGS) relating to Mr. Norinsberg's hourly rate.

Dated: New York, New York
December 16, 2015
Respectfully submitted,

_________/S_____________
JOSHUA P. FITCH
COHEN & FITCH LLP
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Attorneys for Plaintiff
233 Broadway, Suite 1800
New York, N.Y. 10279
[phone]

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