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)
EXHIBIT
“J”
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
DATE
March 8, 2015
August 9, 2012
November 23, 2010
February 21, 2015
March 1, 2015
April 2, 2015
December 5, 2010
February 19, 2015
November 18, 2010
January 10, 2012
June 19, 2012
December 6, 2010
February 16, 2015
February 22, 2015
November 22, 2010
December 3, 2010
April 24, 2012
March 4, 2015
July 21, 2010
September 15, 2012
March 27, 2015
April 10, 2012
February 18, 2015
March 30, 2015
November 26, 2010
December 4, 2010
April 3, 2015
July 12, 2010
ACTION
TIME
Review of Deposition of AS with
Exhibiits
Meeting w/ AS in Albany
Draft of Argument
Review of Schoolcraft discovery/deps Caughey
Review of Schoolcraft discovery/deps Broschart/Sawyer
Draft motion in lim
Edit and Incorporate changes on argument
Review of deposition exhibits &
depositions - Lauderborn
Draft of argument
Meeting with AS, JN and GC
Meeting w/ Schoolcraft in Johnstown
Review and edit argument
Review of deposition exhibits &
depositions
Review of Schoolcraft discovery/deps Gough
Draft of Argument
Draft of argument
Research on 1st Amendment claims for
motion
Review of Schoolcraft discovery/deps Duncan
Review of Schoolcraft documents & tapes
Reviewed/listened to IAB recordings
provided by the City re: investigation into
Schoolcraft matter
Draft motion in lim
Meeting w/ AS
Review of deposition exhibits &
depositions - Marino
Draft motion in lim
Draft of Argument
Review and edit argument for brief
Review and edit motion in lim
Review of Schoolcraft tapes
1
ATTY
6.25
5.75
5.60
JPF
JPF
JPF
5.60
JPF
5.50
5.25
JPF
JPF
5.25
JPF
5.25
4.90
4.90
4.80
4.80
JPF
JPF
JPF
JPF
JPF
4.80
JPF
4.80
4.75
4.75
JPF
JPF
JPF
4.75
JPF
4.75
JPF
4.75
JPF
4.75
4.60
4.60
JPF
JPF
JPF
4.50
4.40
4.40
4.40
4.40
4.40
JPF
JPF
JPF
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 25, 2015
March 17, 2015
November 10, 2010
February 24, 2015
July 3, 2010
July 17, 2010
March 14, 2015
November 18, 2010
November 20, 2010
March 11, 2015
October 10, 2012
March 31, 2015
December 4, 2010
November 19, 2010
February 15, 2015
July 18, 2010
November 24, 2010
November 21, 2010
February 23, 2015
April 1, 2015
July 2, 2010
November 11, 2010
February 17, 2015
August 17, 2010
Review of Schoolcraft discovery/deps Lamstein/Sanganetti/Marquez
Draft motion in lim
Research on hospital confinement
constituting state action under any of the
three tests
Review of Schoolcraft discovery/deps Huffman
Review of Schoolcraft recordings
Review of Schoolcraft tapes
Draft motion in lim
Research on joint action w/ private parties
and police in the context of false arrest
claims
Research on state action - use of private
facilities to imprison
Review of Discovery and Dpeositions Weiss
Review of IAB recordings
Draft motion in lim
Draft of argument
Research on joint action w/ private parties
and police in the context of false arrest
claims
Review of deposition exhibits &
depositions
Review of Schoolcraft tapes
Draft of Argument
Research on joint action where state
coerces private action
Review of Schoolcraft discovery/deps Larry Schoolcraft
Draft motion in lim
Research of Labor Law 215-a for potential
claim
Research on state action standard for
private parties - joint action test
Review of deposition exhibits &
depositions - Mauriello
Review of new documents and recording
CD from AS
2
4.30
4.25
JPF
JPF
4.25
JPF
4.25
4.25
4.25
4.20
JPF
JPF
JPF
JPF
4.10
JPF
4.10
JPF
4.10
4.10
3.90
3.90
JPF
JPF
JPF
JPF
3.90
JPF
3.90
3.90
3.80
JPF
JPF
JPF
3.80
JPF
3.80
3.75
JPF
JPF
3.75
JPF
3.75
JPF
3.75
JPF
3.75
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 28, 2015
March 2, 2015
March 14, 2015
April 22, 2012
November 8, 2010
March 9, 2015
July 14, 2010
June 17, 2012
February 10, 2015
February 20, 2015
November 15, 2010
November 19, 2010
February 7, 2012
November 20, 2010
February 26, 2015
July 15, 2010
August 1, 2010
March 19, 2015
October 17, 2012
March 27, 2015
April 4, 2015
September 20, 2010
Review of Schoolcraft discovery/deps Boston
Review of Schoolcraft discovery/deps Sawyer/Duncan
Draft motion in lim
Research on 1st Amendment claim
Research on involuntary confinement &
state action
Review of reply memo & supporting docs
filed by all defendants
Review of Schoolcraft tapes
Draft motion for reconsideration
Meeting w/ GC & JN regarding global
trial strategy, witnesses to be called (or not
called), exhibits to use, Rule 68 offer and
next steps for moving forward.
Meeting w/ TEAM to discuss trial
strategy, division of labor, motions
Research on conspiracy under §1983
versus state action
Draft of argument
Read and review of JHMC medicals (full
set from hospital)
Research on joint action where state
coerces private action
Review of Schoolcraft discovery/deps James
Review of Schoolcraft tapes
Review of Schoolcraft tapes & timeline
Draft motion in lim
Meeting w/JN & GC re: City's privilege
claims and possible arguments/motions to
defeat such claims highlights of
Lauterborn interview & inconsistencies
w/Marino & home invasion recording
Research on motion in lim re IAB doc
admission & opinions in them
Review and edit motion in lim
Review of deposition of Mauriello from
Floyd case
3
3.75
JPF
3.75
3.60
3.60
JPF
JPF
JPF
3.60
JPF
3.60
3.60
3.50
JPF
JPF
JPF
3.50
JPF
3.50
JPF
3.50
3.40
JPF
JPF
3.40
JPF
3.40
JPF
3.40
3.40
3.40
3.30
JPF
JPF
JPF
JPF
3.30
JPF
3.30
3.30
JPF
JPF
3.30
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 12, 2015
March 28, 2015
April 24, 2012
August 31, 2010
August 27, 2010
September 27, 2010
June 25, 2010
July 30, 2010
May 5, 2015
November 15, 2010
March 7, 2015
July 23, 2012
March 10, 2015
February 25, 2015
July 31, 2010
September 22, 2010
October 26, 2010
June 14, 2012
November 21, 2010
Review of Memo of Law in Opp to
plaintiff’s motion for SJ
Draft motion in lim
Draft of motion to Amend 1st Amendment
claim
Interview with GC of "DH" and "EB"
former NYPD, reviewed materials,
recordings re: quotas, downgrading
Interview with GC of Walter Lipscomb,
former PO confirms quotas - wants to help
Schoolcraft
Meeting w/AS with JN, GC to prep for
discussion with US attorneys office
EDNY
Meeting w/JN and GC re: scope of
Schoolcraft materials that need to be
reviewed for complaint
Meeting with JN, GC, Polanco &
Raymond re: Schoolcraft & Monell claim
Read and review Ct’s Opinion on SJ
Research on close nexus test and private
parties
Research on press & statements made by
counsel
Research on prior restrain, retaliation, and
protected speech/law enforcement under
Tachler
Research on ultimate issue, bolstering w/
prior litigation for Bernier
Review of Schoolcraft discovery/deps Valenti
Meeting with Polanco, Raymond, JN, GC
re: quotas and Monell Claim
Meeting with DOJ EDNY
Meeting with GC and "RC" to discuss
experience with quotas in a Brooklyn
North precinct
Research on 1st Amendment cases cited in
judge’s opinion
Research on hospital state action where
EDPs are involved
4
3.30
3.25
JPF
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.25
3.25
JPF
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.25
JPF
3.20
3.10
JPF
JPF
3.10
JPF
3.10
JPF
3.10
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
March 5, 2015
June 18, 2012
December 5, 2010
December 2, 2010
July 22, 2010
July 31, 2010
June 26, 2010
September 27, 2010
April 23, 2012
September 25, 2012
October 8, 2012
July 6, 2010
July 24, 2015
June 18, 2012
July 28, 2012
June 17, 2012
July 31, 2010
June 15, 2012
July 9, 2012
May 14, 2011
September 3, 2010
August 25, 2010
March 9, 2015
July 22, 2012
July 20, 2012
November 11, 2010
August 23, 2012
August 5, 2010
Research on prior litigiousness exclusion
Review and edit and incorporate additions
suggested by JN and GC on Motion for
Reconsideration
Review of argument
Review of Memo of Law argument
Review of Schoolcraft documents & tapes
Review of Schoolcraft tapes & timeline
Review of Schoolcraft’s medical records
Schoolcraft interview with Civil Rights
Division JN, GC, DOJ
Draft of letter on 1st Amendment claims
Meeting w/ AS & GC & JN re dep prep
Prep w/ AS for dep
Research Labor Law issue
Schoolcraft team meeting
Draft motion for reconsideration
Draft of motion to amend
Research on prior restraint
Revision of Complaint
Draft motion for reconsideration
Draft reply motion for reconsideration
Meeting with GC reviewing Requests For
Admission's (RFA's)
Meeting with GC with PO from 81st
precinct "MG" re: corruption
Meeting with GC, PO from 81st precinct
"PF" re: corruption
Research on IAB conclusions &
admissibility
Research on prior restrain
Research on retaliation and protected
speech issue
Research on traditional function state
action test “hospital used as jail”
Review of disocvery provided by City
defendants
Review of transcribed tape recording from
August & March 2009 from Legal
Language
5
3.10
JPF
3.10
3.10
3.10
JPF
JPF
JPF
3.10
3.10
3.10
JPF
JPF
JPF
3.10
2.90
2.90
2.90
2.90
2.90
2.80
2.80
2.80
2.80
2.75
2.75
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
2.75
JPF
2.75
JPF
2.75
JPF
2.75
2.75
JPF
JPF
2.75
JPF
2.75
JPF
2.75
JPF
2.75
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 6, 2010
September 27, 2011
April 6, 2015
July 30, 2012
May 8, 2012
July 30, 2010
September 20, 2010
June 25, 2010
August 28, 2015
March 12, 2015
October 7, 2012
June 15, 2012
May 23, 2011
August 17, 2011
September 17, 2010
April 25, 2012
November 4, 2010
September 24, 2012
January 26, 2011
March 4, 2015
March 9, 2012
February 12, 2015
Review of transcripts from Legal
Language re June 2009 roll calls,
Halloween Night, & visits to Johnston
Research re law enforcement privilege
Review and edit motion in lim
Review and edit motion to amend
Review and prep response to defendant’s
1st Amendment letter
Revision of Complaint
Meeting with GC with PO "JB" re: NYPD
quotas and downgrading
Review of Schoolcraft’s Patrolmen's
Benevolent Associtation ("PBA") contract
Draft additional sections to motions in lim
re rifle pictues, Queens DA & prior
complaints made by AS
Meting w/ GC, JN, NS, and Jon Lenoir
("JL") re trial, motions
QAD interview review
Research on prior restraint and Carcetti
progeny
Review and Edit discovery demands and
rogs against all defendants
Review of responses to requests &
discovery demands from hospital
defendants
Reviewed documents and depositions
from the Floyd litigation for purposes of
Monell claim
Final review & edit 1st Amendment letter
Meeting with GC and police officer "BP"
re: quotas, downgrading, and NYPD
corruption
Prep AS fro his dep
Prep for oral argument
Research of racial comments & exclusion
for motion in lim
Research on 1st Amendment claims
Review of 56.1 counter statements from
JHMC, City, Mauriello, & Isacov
6
2.75
2.60
2.60
2.60
JPF
JPF
JPF
JPF
2.60
2.60
JPF
JPF
2.50
JPF
2.50
JPF
2.40
JPF
2.40
2.40
JPF
JPF
2.40
JPF
2.40
JPF
2.40
JPF
2.40
2.30
JPF
JPF
2.30
2.30
2.30
JPF
JPF
JPF
2.30
2.30
JPF
JPF
2.30
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
September 21, 2010
August 3, 2010
November 20, 2010
October 30, 2010
September 23, 2010
June 14, 2012
June 16, 2012
February 13, 2011
March 27, 2015
August 15, 2011
July 9, 2010
July 23, 2012
July 29, 2012
July 26, 2010
May 11, 2012
June 20, 2010
July 8, 2012
March 6, 2015
March 28, 2015
May 8, 2012
August 5, 2010
March 19, 2015
August 31, 2010
Review of Angel Heran depo from Floyd
Review of Complaint edits by JN
Draft of argument
Meeting with GC & JN re: information
provided by MR, MG RC whistleblower
cops and movie and book publicist
contacting AS for information
Meeting with GC, JN and Center for
Constitutional Rights (CCR) re
Schoolcraft
Read and review Opinion and Order on 1st
Amendment and Motion to Quash and
notes on same
Research on prior restraint
Review and Edit letter brief opposing stay
Review of Draft Direct Examination of AS
from GC
Review of responses to Bernier & Jamaica
discovery demands
Review of Schoolcraft timeline prepared
by JN
Draft motion to amend
Draft of motion to amend
Meeting with JN & GC re case & updates
on Brendan Delpozo
Read and review of defendant’s letter to
quash and discussion w/ GC & JN
Reading Village Voice articles on
Schoolcraft and Halloween night
Research cases cited in defendant’s brief
in opp in preparation of reply
Research on limitations of witness
examinations
Research on motion in lim conclusions re
credibility admissibility
Review caselaw in defendant’s letter
Review of Complaint with client’s chain
of events & corrections
Review of James Cross outline
Drafting Amended Complaint
7
2.30
2.30
2.25
JPF
JPF
JPF
2.25
JPF
2.25
JPF
2.25
2.25
JPF
JPF
2.25
JPF
2.25
JPF
2.25
JPF
2.25
2.10
2.10
JPF
JPF
JPF
2.10
JPF
2.10
JPF
2.10
JPF
2.10
JPF
2.10
JPF
2.10
2.10
JPF
JPF
2.10
2.10
1.90
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
April 2, 2015
November 21, 2010
September 21, 2010
October 4, 2010
September 1, 2010
October 7, 2010
May 9, 2012
August 4, 2010
August 3, 2010
July 8, 2011
September 24, 2010
December 1, 2010
June 16, 2012
August 25, 2010
September 24, 2012
May 9, 2011
July 6, 2010
December 6, 2010
June 18, 2012
March 16, 2015
Meeting with JN and NS team
Research on joint action
Review of Donald McHugh depo from
Floyd
Meeting w/ GC and "JR" retired police
officer re: quotas, downgrading, NYPD
corruption
Meeting w/JN and GC re: discuss
anonymous POs contacting and how they
can help Schoolcraft
Meeting with GC and "EB" retired police
officer re: quotas, downgrading, NYPD
corruption
Review of cases & letter in prep of
argument
Review of client’s chain of events for
Complaint
Revise and edit of Complaint
Discussion with GC and JN re: meeting
with Jim Leander and AS about
investigation
Discussion with JN and GC re: first
meeting with the DOJ and upcoming
meeting with the DOJ and AS
Draft factual section of opp
Draft motion for reconsideration
Meeting w/JN and GC re: ACC assigned,
Schoolcraft initial disclosures
Meeting w/JN and GC to discuss City
deficiency letter and AS dep prep
Meeting with JN and GC re: neccesary
disclosures under Rule 26 for plaitniff
Meeting with JN/GC re:
progress/developments on the case,
meeting in NYC on Wednesday and filing
of lawsuit
Review and edit brief
Review and edit Motion for
Reconsideration
Review of Direct Examinaiton Outline for
AS
8
1.90
1.90
JPF
JPF
1.90
JPF
1.80
JPF
1.80
JPF
1.80
JPF
1.80
JPF
1.80
1.80
JPF
JPF
1.75
JPF
1.75
1.75
1.75
JPF
JPF
JPF
1.75
JPF
1.75
JPF
1.75
JPF
1.75
1.75
JPF
JPF
1.75
JPF
1.75
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
June 19, 2012
June 19, 2012
February 10, 2012
August 9, 2010
March 14, 2012
August 8, 2010
November 11, 2010
January 20, 2012
May 19, 2011
May 20, 2011
March 10, 2015
July 7, 2010
August 9, 2010
May 12, 2015
January 10, 2011
Travel back to NYC from Johnstown (3.5)
Travel to Johnstown (3.5)
Discussion w/ JN & GC re additional
items of discovery
Edit/Revise Complaint
Editing Amended Complaint to add 1st
Amendment facts & law
Editing Complaint with additional
allegations
Meeting with GC and "JW" cop to discuss
quotas/retaliation
Phone call with Larry Schoolcraft re
discovery & EBTs
1.75
1.75
JPF
JPF
1.60
1.60
JPF
JPF
1.60
JPF
1.60
JPF
1.60
JPF
1.60
JPF
Review & edit demands & interrogatories
Discussion w/ GC & JN re request to
admit corrections/additions
Discussion with GC to help outline AS
direct exmaination
Meeting w/ only with AS
Meeting w/JN and GC re: Schoolcraft
website to support Monell threory
1.60
JPF
1.50
JPF
1.50
1.50
JPF
JPF
1.50
JPF
1.50
JPF
1.50
JPF
1.50
JPF
Meeting w/NS team JN and GC pre-conf
Meeting with GC & JN re interrogatories
and demands
1.50
JPF
October 12, 2010
Meeting with GC and JN re: interview of
PO from 81st precinct "PF" re: corruption
Meeting with JN and Rocco P – Daily
News re Schoolcraft and evidence of
quotas for Monell claim
Review of Motion to Dismiss by Jamaica
Hosp.
1.50
JPF
August 9, 2012
August 9, 2012
July 22, 2010
September 4, 2010
Traveled from Albany back to NYC (3.0)
Traveled to Albany to meet Client (3.0)
Discussed causes of action w/GC
Drafting Amended Complaint
1.50
1.50
1.40
1.40
JPF
JPF
JPF
JPF
August 26, 2010
July 29, 2010
9
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
June 25, 2010
October 27, 2010
May 10, 2011
October 10, 2010
September 3, 2010
November 21, 2010
April 5, 2012
June 23, 2011
February 11, 2015
July 26, 2010
March 23, 2015
August 4, 2010
February 2, 2015
March 16, 2015
May 10, 2012
July 9, 2012
December 7, 2010
May 20, 2011
July 6, 2010
Meeting with GC & JN re: possible
discovery demands after suit is filed
Meeting with GC and David Velez re:
arbitration, quotas, Michael Marino
Meeting with JN and GC re: edits to Intial
disclosures and discussion regarding
requests to admit
Meeting with JN and GC re: infromatoin
provided by MV, NB, EB whistleblower
cops
Meeting with JN and GC to discuss
infromation provided by DH, MG, EB
whistleblower cops in furtherance of the
Monell claim
Research on supplement jurisdiction
Review & edit response to City’s interogs
Review of answers to interrogatories by
Isacov
Review of declarations from City,
Berniers, Isacov, & JHMC w/
accompanying exhibits
Review of draft of Complaint prepared by
GC
Review of Sawyer cross examaintion
outline
Revise and edit Complaint
Discussion w/ GC & JN re representing
AS again for trial
Discussion with GC re: AS direct
examination and points to cover, strategy
Draft letter providing supplemental
authority in response to defendant’s opp
Edit reply
Final review & edit of brief
Finalize interrogatories & discuss EBTs
w/ JN & GC
Meeting w/JN and GC re: new
whistleblower contacted JN re:
Schoolcraft
10
1.40
JPF
1.40
JPF
1.40
JPF
1.40
JPF
1.40
1.40
JPF
JPF
1.40
JPF
1.40
JPF
1.40
JPF
1.40
JPF
1.40
1.40
JPF
JPF
1.30
JPF
1.30
JPF
1.30
1.30
1.30
JPF
JPF
JPF
1.30
JPF
1.30
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 8, 2012
September 17, 2010
July 5, 2012
July 22, 2012
December 1, 2010
December 8, 2010
February 11, 2015
August 17, 2011
May 19, 2011
September 28, 2011
April 23, 2012
August 19, 2010
March 9, 2012
June 28, 2010
October 13, 2010
December 4, 2010
July 10, 2012
June 20, 2012
April 8, 2015
Meeting w/ JN & GC re meeting w/ AS in
Albany for prep
Meeting with JN and GC regarding
infromation obtained from Floyd litigation
and its impact on Schoolcrafts Monell and
Retaliation claims
Read and review of defendant’s opp to
plaintiff’s motion for reconsideration
Review of complaint for allegations
conforming to plaintiff’s 2nd motion to
amend
Review of Complaint for facts
Review of NYPD Memos re anti quota
legislation
Review of witness/exhibit list from JN and
discuss with GC
Discuss confidentiality stip w/ GC & JN
b/c of plaintiff’s objections
Discuss w/ JN & GC edits & topic areas
that should be explored on interrogatories
Discussion w/ JN and GC re law
enforcement privilege & motion to compel
Discussion w/ Larry Schoolcraft re
amendments to complaint
Discussion with GC and JN re: new
recordings and documents provided by AS
Discussion with JN & GC re reinstating
1st Amendment claims in this case based
on Carcetti & actions after the fact
Discussion with JN and GC re retainer &
meeting with Schoolcrafts
Discussion with JN re: arguments to make
in response to JHMC motion
Draft section on supplement jurisdiction
Edit reply final
Final edit and review of Motion for
Reconsideration
Final edits and corrections to motion in
Lim
11
1.30
JPF
1.30
JPF
1.30
JPF
1.30
1.30
JPF
JPF
1.30
JPF
1.30
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
1.25
1.25
JPF
JPF
JPF
1.25
JPF
1.25
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
July 30, 2010
July 14, 2010
July 27, 2010
March 1, 2011
August 30, 2010
July 22, 2012
September 10, 2015
March 8, 2012
April 11, 2011
January 25, 2011
July 20, 2012
September 10, 2012
June 29, 2010
March 20, 2012
August 6, 2010
December 2, 2010
December 3, 2010
August 16, 2011
February 24, 2015
June 26, 2010
August 6, 2010
February 26, 2015
Meet with GC and JN re: changes and
additions to complaint
Meeting w/JN and GC re: Schoolcraft
complaint
Meeting w/JN and GC to discuss
Complaint
Meeting with anonymous cops from T34
w/ GC and JN - provided recordings of Lt.
Janice Williams
Meeting with JN & GC re Garcia cop
from 81 who knows Schoolcraft & has
info on quotas
Phone call w/ Larry Schoolcraft re
meeting and outstanding discovery issues
and depositions
Phone Call with AS re: settlement
Phone call with client re article and
whether confidential info had been
disclosed
Phone convo w/ AS re representation on
his suspension & internal hearing
Prep for oral argument on JHMC motion
Read and review judge’s decision denying
reconsideration
Read and review Opinion & Order from
Sweet on plaintiff’s motion to amend
Receipt & review of Weinstein arbitration
decision in PBA case
Research on 1st Amendment Second
Circuit decisions following Carcetti
Review and edit Complaint after
clarification
Review of Amended Answer filed by City
Review of argument
Review of confidentiality stip from City
Review of Huffman cross examination
outline
Review of PBA contract
Review of revised Complaint from JN
Review of Valenti exmanination
12
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
1.25
JPF
JPF
1.25
JPF
1.25
1.25
JPF
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
JPF
1.25
1.25
1.25
JPF
JPF
JPF
1.25
1.25
1.25
1.25
JPF
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
May 12, 2015
October 18, 2012
October 15, 2012
July 15, 2010
July 9, 2010
February 26, 2015
September 30, 2010
May 18, 2011
September 22, 2010
October 9, 2012
May 20, 2011
August 30, 2015
February 13, 2012
March 13, 2015
April 7, 2015
July 24, 2015
April 6, 2015
January 26, 2011
March 28, 2012
September 28, 2011
May 9, 2012
April 13, 2015
May 12, 2015
September 5, 2010
July 26, 2010
Team meeting following conf.
Meeting w/JN & GC re: City's
Deliberative Process and Grand Jury
privilege claims and best strategy for
defeating same.
Meeting w/JN & GC re: Marino's IAB
interview & inconsitencies w/claims in UF
49 & Halloween Night recording
Discussion with GC and JN re tapes
Discussion with JN re timeline
Meeting w/JN and GC re: outstanding
items we need from trial from NS
Meeting with GC and JN re: anonymous
cop interviews VM and EF
Meeting with GC to discuss documents
that must be requested in our demands
Meeting with JN to prepare for EDNY
DOJ
Prep w/ AS for AS dep
Review & edits request for admissions
Review and edit motion in lim
Review and edit revised demands for City
Review jury instructions from NS team
Review motion in lim based on comments
Review of draft witness list from NS:
notes taken
Review of NS comments
Appearance for motion to dismiss in
Schoolcraft
Attend oral Argument on City motion
Attend oral argument on motion to compel
Attended Argument on 1st Amendment
claim
Conf. on trial date – case adjourned
Conf. trial adjourned to Oct. 19
Editing Amended Complaint
Meeting GC and JN re issues for
Schoolcraft complaint
13
1.25
JPF
1.20
JPF
1.20
1.10
1.10
JPF
JPF
JPF
1.10
JPF
1.10
JPF
1.10
JPF
1.10
1.10
1.10
1.10
JPF
JPF
JPF
JPF
1.10
1.10
1.10
JPF
JPF
JPF
1.10
1.10
JPF
JPF
1.00
1.00
JPF
JPF
1.00
JPF
1.00
1.00
1.00
1.00
JPF
JPF
JPF
JPF
1.00
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
October 12, 2010
February 20, 2015
May 15, 2011
November 12, 2010
March 27, 2015
May 23, 2012
February 8, 2012
June 23, 2011
September 12, 2015
December 19, 2011
June 28, 2010
February 12, 2011
August 1, 2012
May 31, 2012
August 25, 2010
February 4, 2015
October 6, 2010
September 11, 2011
August 11, 2011
April 6, 2015
February 11, 2015
Meeting w/ GC and JN re:
Schoolcraftjustice.com calls from POs
Meeting w/ JN and GC before meeting
with Nat Smith to discuss how we are
going to proceed at meeting
Meeting with JN and GC re: edits to
RFA's
Meeting with JN and GC re: issues on our
motion opposition and GC's meeting with
JW anonymous cop
Phone conference with JN, GC, NS, JL
Prep for argument w/ GC & JN
Pre-trial conference before Judge Sweet
Review of response to doc demands
Isacov
Adding a new section on Bernier’s naval
yard disaster testimony
Convo w/ Larry Schoolcraft re discovery
issues, avenues to pursue with defendants
Discussion with JN re meeting with P.O.
Velasquez re policy of quotas
Discussion with JN re; motion to stay and
arguments in opposition
Final review of motion to amend
Meeting w/JN and GC re: City conf. Stips
Meeting with JN & GC re more
whistleblower email & meeting with P.O.
Fioranelli
Phone call w JN and GC re: pending trial
strategy and misc.evidentiary issues, and
setting up meetng to discuss same in
greater detail
Review of Answer to Complaint by
Jamaica
Review of plaintiff’s motion to compel
discovery
Review of responses to Isacov discovery
demands
Review of revised SK jury instructions
Berniers counter 56.1 statement
14
1.00
JPF
1.00
JPF
1.00
JPF
1.00
1.00
1.00
1.00
JPF
JPF
JPF
JPF
1.00
JPF
0.90
JPF
0.90
JPF
0.90
JPF
0.90
0.90
JPF
JPF
0.90
JPF
0.90
JPF
0.90
JPF
0.90
JPF
0.90
JPF
0.90
0.90
0.80
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
December 6, 2010
Call w/GC and JN about taking over case
again
Conf. re confidentiality stip & Village
Voice article
Conf. re NY Times letter to undo the
confidentiality stip
Discussion w/ AS and Larry Schoolcraft
re financial issues and possibly locating
donors
Discussion w/ GC & JN re decision and
impact on trial and motion in lim
Discussion with GC & JN re final
corrections
June 22, 2010
Discussion with Gerald Cohen (GC) and
JN re Schoolcraft case & causes of action
January 23, 2015
March 28, 2012
April 4, 2012
July 2, 2012
May 8, 2015
July 7, 2010
June 18, 2010
Discussion with JN re Labor Law research
Discussions with Jon Norinsberg ("JN") re
Schoolcraft case
Discussions with Jon Norinsberg (JN) re
Schoolcraft case
Draft of prelim statement in opp to Motion
to Dimiss
Listening to This American Life interview
with client
Meeting w/JN and Gerald Cohen ("GC")
re: Schoolcraft coming to our office and
retaining for lawsuit
August 12, 2010
Meeting w/JN and GC re: legal strategies
on Monell and whistleblower cop contacts
June 6, 2010
June 20, 2010
November 18, 2010
September 20, 2010
August 22, 2010
August 29, 2012
Meeting with JN & GC re whistleblowers
reaching out through the website
Meeting. w/ JN & GC re: City's Suppl.
Disclosure & the need for us to depose at
least 5 of the 9 new witnesses identified
by City & other gen.strategy issues for
advancing discovery
15
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
November 8, 2010
July 25, 2012
May 22, 2012
August 27, 2010
April 5, 2012
September 30, 2010
November 8, 2010
March 6, 2015
November 11, 2010
June 30, 2010
March 29, 2012
February 12, 2015
May 3, 2012
August 16, 2012
May 17, 2012
February 8, 2012
February 24, 2015
March 19, 2015
March 8, 2012
April 25, 2012
June 14, 2012
Met with GC and police officer "MC" re:
quotas
Phone call w/ Larry Schoolcraft
Phone call w/ Larry Schoolcraft re
Vallone and 1st Amendment
Reading articles written by Eterno &
Silverman re Compstat & numbers game
Review and discuss w/ JN & GC
plaintiff’s responses to City demands
Review of Answer to Complaint by
Bernier
Review of Doc Demands/Interrogatories
by Isacov
Review of email from AS w/ witness
suggestions
Review of Interrogatories & Demands
Bernier
Review of PBA website internal access for
P.O.s with AS
Revised and help draft proposed AEO stip
w/JN and GC for City
Affidavit of Mauriello
Discussion w/ GC & JN re Affidavits and
conf. stip AEO
Discussion w/ JN & GC re City’s
suggestion on multiple dates for deps
Discussion w/JN and GC re: AS breach
affidavit
Discussion with GC and JN re: conference
and discovery and stratedgy moving
forward
Discussion with GC re: Huffman cross
Discussion with GC re: James cross
examinaiton
Discussion with JN & GC re VV article
and the confidential report
Discussion with JN re: edits/changes to 1st
Amendment letter
Meet with JN and GC to discuss motion
for reconsideration on 1st amendment
claim
16
0.80
0.80
JPF
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
JPF
0.80
0.75
JPF
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
0.75
JPF
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
October 4, 2010
June 23, 2010
July 7, 2010
February 27, 2012
August 25, 2010
April 8, 2015
January 23, 2012
April 20, 2012
May 3, 2012
October 18, 2012
October 19, 2012
September 7, 2010
May 10, 2011
October 28, 2011
August 13, 2010
June 23, 2011
July 28, 2015
September 28, 2010
Meeting w/ GC and JN to discuss
infromation from "JR" retired police
officer re: quotas, downgrading, NYPD
corruption
Meeting w/JN and GC re: JN's upcoming
meeting w/ Schoolcrafts
Meeting with AS, LS, GC & JN
Meeting with GC and JN re: documents
received from Johnstown PD for plaintiff's
subpoena
Meeting with JN & GC re: Whitehead
Meeting.
Phone call with GC and JN regarding trial
adjournment, proposed filings, various
strategies for trying to make sure trial goes
on April 20
Phone call with Larry Schoolcraft re
plaintiff salary and benefits and work
suspension status
Phone discussion w/ AS
Receipt and review of email from City re
revised confidentiality AEO and
Affidavits
Review and edit letter to Ct. re ASO issue
& AS ability to see the QAD report
Review of Answer to Amended Complaint
from Isacov
Review of Answer to Complaint from
Jamaica Hosp.
Review of Intial disclosures and
discussion with GC
Review of operations order 10/17/11 sent
from client
Review of PBA regulations
Review of requests for discovery from
Isacov
Review of updated jury instructions
"Rich" anonymous cop discussion with
GC
17
0.75
JPF
0.75
0.75
JPF
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
0.75
JPF
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
JPF
0.75
0.75
JPF
JPF
0.75
0.75
JPF
JPF
0.60
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 20, 2012
May 23, 2012
May 22, 2012
July 28, 2012
March 6, 2015
May 8, 2012
May 16, 2012
July 26, 2010
August 27, 2010
January 26, 2011
June 23, 2011
March 23, 2015
April 13, 2012
July 2, 2010
March 16, 2012
March 20, 2012
September 26, 2012
March 30, 2012
February 19, 2011
Discussion w/ JN & GC re additional
amendment of the complaint to add
Hanlon
Discussion w/ JN & GC re defendant’s
letter re subpoena
Discussion w/ JN & GC re defendant’s
letter re Vallone subpoena
Discussion w/ JN & GC re motion to
amend to add prior restraint
Discussion w/ JN & GC re proposed
witnesses
Discussion w/ JN and GC re argument on
1st Amendment claim
Discussion w/ JN and GC re opp to
defendant’s motion to quash
Discussion with GC & JN re Complaint &
drafts going forward
Discussion with GC & JN re having
Eterno & Silverman as experts
Discussion with GC & JN re oral
arguments
Discussion with GC & JN re responses &
requests from Isacov
Discussion with GC re: Sawyer points for
cross examination
Discussion with JN and GC re: Matthews
decision
Discussion with JN re AS’ ability to
pursue claim under Labor Law 215-a
Draft of opp that defendants request
plaintiff be ordered to appear @ 3/28/12
conf.
Incorporating language into Amended
Complaint
Meeting w/ JN & GC & AS re adjorning
dep due to father’s medical emergency
Meeting w/ JN & GC re AEO changes
Meeting with GC re: getting transcript for
Bryant v. City verdict finding quotas
existed
18
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
0.60
JPF
JPF
0.60
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
March 12, 2012
April 13, 2012
Meeting with JN & GC re letter from City
Meeting with JN and GC re NYTimes
story about quotas & Schoolcraft
Meeting with JN and GC re proposed
Amended Complaint
Phone call w/ rest of trial team regarding
City' proposal for mediation and best
strategy for responding
Phone call with JN & GC recapping
discussion with defense counsel and
clients over the weekend
Phone call with JN regarding following up
with Smith, IAB v. DAT transcripts,
calling additional witness's like Nelson
and Valenti and Yeager
Phone call with NS, GC and JN regarding
best strategy for handlng settlement
discussions with the City
Read & review the decision & order
written disposing of the motion to dismiss
Review and edit letter to Ct opposing an
additional day for AS dep for Mauriello
lawyer
Review and edit plaintiff’s opp to
defendant’s motion to quash
Review of agency agreement for client on
book/movie deals he does
Review of Amended Complaint by
Bernier
Review of Answer to Amended Complaint
Isacov
Review of articles sent by Schoolcraft on
Gerald Nelson
Review of decision in Floyd on summary
judgment & its relevance to Schoolcraft
tapes and Monell claim
Review of Decision in Matthews 1st
Amendment case from Judge Jones
January 20, 2011
Review of defendants’ reply memo of law
August 15, 2010
March 15, 2012
April 17, 2015
September 8, 2015
February 27, 2015
September 8, 2015
May 6, 2011
October 18, 2012
May 17, 2012
May 12, 2011
October 22, 2012
October 27, 2010
June 21, 2010
September 1, 2011
19
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
0.60
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
May 10, 2012
April 17, 2015
December 19, 2011
December 9, 2010
March 25, 2015
May 5, 2015
July 28, 2010
February 26, 2015
June 30, 2010
March 28, 2012
March 30, 2012
September 27, 2010
March 19, 2012
August 21, 2012
September 17, 2012
March 12, 2015
September 24, 2012
August 12, 2010
April 13, 2015
September 25, 2010
Review, edit & submit supplemental letter
Conference call with team re: best strategy
for responding to City latest "offer"
Discussion w/ GC & JN re plaintiff's
thoughts on discovery
Discussion w/ JN & GC re discovery
responses & timing
Discussion w/ SK re motions in lim
Discussion w/JN and GC re SMJ
Discussion with GC and JN re: Adhyl
Polanco and other whistlblowers
Discussion with GC re: Valenti
exmanination
Discussion with JN & GC re FOIL
requests for 911’s & how to proceed
Discussion with JN and GC re: court's
order on City's motion for breach of
confidentiality agreement
Discussion with JN and GC re: filing
motion to amend and discovery issues
Discussion with JN re location &
witnesses from This American Life
interview
Discussions w/ JN re corrections
Amended Complaint
Draft Amended Complaint adding Hanlon
Draft of letter to amend to add Hanlon to
complaint
Email from AS re additional witnesses for
trial
Email from City re service of amended
complaint, Lauderborn dep, & discovery
deficiencies
Meeting w/GC and JN re: legal strategies
+ next steps for moving forward
Meeting w/JN and GC re new trial date
Meeting with GC & JN re AS interview
with feds
20
0.60
JPF
0.50
JPF
0.50
JPF
0.50
0.50
0.50
JPF
JPF
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
0.50
JPF
JPF
0.50
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
July 15, 2011
October 11, 2012
July 24, 2015
April 2, 2015
September 25, 2012
May 22, 2012
March 29, 2012
July 19, 2011
November 11, 2010
February 27, 2012
October 12, 2010
October 17, 2012
May 12, 2011
July 6, 2011
August 20, 2012
December 1, 2010
August 13, 2010
August 17, 2010
August 9, 2010
June 29, 2010
Meeting with GC an JN re: discovery plan
and issues to raise
Meeting with JN, GC, AS before depo
Phone call with JN & GC regarding issues
to discuss at meeting today with rest of
trial team
Phone call with JN regarding several
issues in motion in limine and
admissibility of Marino's steroid
investigation under R. 608 (b)
Phone call with Larry Schoolcraft re AS
dep
Read and review of defendant’s letter re
Vallone subpoena
Review of AEO
Review of agency agreement for AS book
deals
Review of Answer to Amended Complaint
Bernier
Review of docs from Johnstown PD re
plaintiff's subpoena
Review of JHMC Dec. for motion to
dismiss
Dicussion w/ GC & JN re City’s refusal to
allow AS to see QAD file
Discussion w/ GC & JN re agency
agreement
Discussion w/ JN & GC re changing to
case management plan
Discussion w/ JN re AS dep prep
Discussion with GC & JN re affidavit
from Schoolcraft
Discussion with GC & JN re Jonathan
Moore issue – cease & desist letter
Discussion with GC and JN re anonymous
e-mails that we got as a result of the email
Discussion with GC re website content
Discussion with JN & GC re decision on
PBA arbitration case
21
0.50
0.50
JPF
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
0.50
JPF
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.50
JPF
0.40
JPF
0.40
JPF
0.40
0.40
JPF
JPF
0.40
JPF
0.40
JPF
0.40
0.40
JPF
JPF
0.40
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
September 6, 2010
September 3, 2010
July 28, 2010
August 8, 2010
September 20, 2010
September 7, 2010
August 3, 2010
May 1, 2012
August 6, 2010
March 12, 2012
February 25, 2015
August 3, 2010
March 15, 2012
August 22, 2012
March 28, 2012
August 30, 2010
January 31, 2011
January 20, 2011
April 7, 2015
April 17, 2015
Discussion with JN re Amended
Complaint
Discussion with JN re AS interview with
This American Life
Discussion with JN re Complaint
Discussion with JN re edits to Complaint
Discussion with JN re meeting with
Department of Justice ("DOJ") on AS case
Discussion with Mark Toor re article in
Chief about Amended Complaint
Discussion with Rocco re Schoolcraft
recordings
Discussions w/ JN and GC re City’s
request for affidavits & deposition for
confidentiality breach
Discussions with JN about quotes to add
to complaint from trnascribed recordings
Draft Response to defendants letter re:
breach of protective order
Email from AS re counterclaim
E-mail from JN re Revised Complaint
Incorporating corrections from JN to
Amended Complaint
Meeting w/ GC & JN re Kretz’s request to
have an additional day to depose plaintiff
Meeting w/ JN & GC prior to conference
to prep
Meeting with JN & GC re Labor &
Employment case & 12(b)(6) motion
Meeting with JN & GC re send documents
& authorizations to Queens DA office
Meeting with JN, GC to discuss JHMC's
reply memo of law
Phone call w/ SK re final corrections to
motion in lim
Phone call with GC & JN following up on
phone call and discussing settlement
position vs. going to trial
22
0.40
JPF
0.40
0.40
0.40
JPF
JPF
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
0.40
0.40
JPF
JPF
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
March 8, 2012
March 12, 2012
March 23, 2015
April 7, 2015
March 12, 2012
May 17, 2012
April 7, 2015
March 21, 2012
April 7, 2015
September 3, 2010
November 13, 2012
September 18, 2010
April 6, 2012
July 23, 2012
February 8, 2011
April 18, 2011
April 30, 2012
August 9, 2010
August 11, 2010
June 27, 2011
August 3, 2010
Read Voice article on QAD report
Read/review of letter from defendant City
on breach of confidentiality stip
Reciept and review of Kretz's demands re:
the student "movie" about AS
Response email to team re comments on
motion in lim
Review & edit response to City's letter re
protective order
Review and discuss City New York Times
opp letter w/ JN & GC
Review of JL’s comments
Review of NY Times letter to court re
confidentiality
Review of SK’s comments
Composing post to get more cops to talk
to us about Schoolcraft & Monell claim
Confirming with GC w/ AS on the phone
that he is terminating representation
Conversation with GC & JN re new
whistleblower cop
Correspondence w/ NY Times about
amendments to Schoolcraft protective
order
Discussion w/ GC & JN re meeting w/
Schoolcrafts in Albany
Discussion w/ JN & GC re letter to court
to schedule discovery
Discussion w/ JN & GC re prep of letter re
NYPD hearing & PBA representation
Discussion w/ JN and GC re NY Times
alteration to protective order
Discussion with GC and JN re Adrian
interview
Discussion with GC re JN re anonymous
P.O.
Discussion with JN and GC re City’s
failure to response to discovery requests
Discussion with JN re corrections to
complaint
23
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
JPF
0.40
0.40
JPF
JPF
0.40
0.40
JPF
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
October 12, 2010
September 23, 2010
June 28, 2010
March 11, 2012
August 16, 2010
May 29, 2012
August 9, 2010
August 8, 2010
July 6, 2012
September 12, 2011
April 2, 2015
April 30, 2012
March 3, 2015
April 7, 2015
November 1, 2010
June 25, 2012
March 30, 2015
March 30, 2015
Discussion with JN re Motion to Dismiss
schedule
Discussion with JN re new post for RANT
for more whistleblower POs
Discussion with JN, GC & Adrian
Schoolcraft ("AS") re: prior counsel
Jonathan Moore
Draft email to defendants re amending
complaint to add 1st Amendment claims
E-mail article from “Gman” re
downgrading stats & PBA admission
about quotas from 1994
Email from GC w/ proposed
confidentiality stips
E-mail from JN re negligent ret. claim
E-mail from JN with additional allegations
for Complaint
Email to City re relevancy redaction
portion of AEO & stip
Final review & edit motion to compel
Follow up phone call with JN locating
does relevant for motion in Limine,
including plaintiff IAB/CCRB transcripts,
Affidavits for spoilation, and Eterno
deposition testimony
Letter from City requesting affidavits &
dep of client re confidentiality breach
Letter to Ct. from Kretz correcting 56.1
statement errors
Making corrections to motion in lim
Meeting with JN and GC re: updating
Schoolcraft website
Phone call w/ Frank Serpico re meeting w/
Schoolcrafts
Phone call with JN & GC regarding
admissibility of tape recorded statements
of persons interviewed by IAB
Phone call with JN regarding motion
limine issues and recent filings by NS
regarding striking affidavit and request for
conference
24
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
0.30
JPF
JPF
0.30
JPF
0.30
0.30
JPF
JPF
0.30
JPF
0.30
JPF
0.30
0.30
JPF
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 11, 2010
August 31, 2010
April 12, 2011
October 18, 2012
May 11, 2012
May 11, 2012
February 9, 2011
September 18, 2012
July 5, 2011
May 24, 2012
November 16, 2010
December 11, 2010
August 10, 2010
June 30, 2010
March 22, 2015
September 6, 2011
August 17, 2010
August 31, 2010
September 2, 2015
September 1, 2010
December 14, 2010
Phone call with Mark Toor re article in
Chief
Phone call with Mark Toor re new article
Phone convo w/ JN re suspension issue &
our response to the NYPD
Read and review Answer to Amended
Complaint from City
Read and review NY Times letter re
confidentiality stip
Read and review of defendant’s response
to plaintiff’s supplemental letter
Review & edit letter to court re discover
schedule
Review and edit amended complaint
Review discovery plan w/ JN & GC
Review letter by GC in response to
Vallone subpoena issue
Review of affidavit for AS for CCR case
Review of article from Eterno &
Silverman re manipulation of crime stats
Review of articles about Schoolcraft
Complaint
Review of FOIL requests for 911 calls
made by AS to NYPD and discuss with JN
Review of plaintiff’s response letter to
defendants opp to plainitff’s motion to
strike & re adjourning trial
Review, edit, discuss confidentiality stip
language re related matters
Conversation with Adhyl Polanco re
article, website, status of the case
Conversation with JN and GC re: topics to
be discussed/disclosed with Mark Toor in
Chief article
Corrections from SK
Correspondence from Donna Canfield re
extension of time to response
Correspondence with Darius Charney re
affidavit for AS
25
0.30
0.30
JPF
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
0.30
0.30
JPF
JPF
JPF
0.30
0.30
JPF
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.30
JPF
0.25
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
March 7, 2012
September 20, 2010
July 15, 2011
February 4, 2015
August 10, 2010
June 29, 2010
August 3, 2010
August 18, 2010
February 20, 2015
January 3, 2011
March 30, 2012
April 5, 2012
May 20, 2011
December 15, 2010
January 5, 2011
August 4, 2011
July 9, 2012
March 20, 2012
February 10, 2012
April 5, 2015
Discussed adding 1st amendment claim
with JN and GC
Discussion & review with GC & JN re
media to upload to website
Discussion of time limit for plaintiff’s
EBT as part of discovery plan
Discussion w/ JN & GC re scheduling a
meeting w/ Nat Smith ("NS") to discuss
case status and trial prep
Discussion with JN & GC re articles and
possible typo in Complaint
Discussion with JN & GC re substitution
of counsel Moore
Discussion with JN re corrections
Discussion with JN re Rocco’s story in
Daily News
Email from AS re indemnification issue w/
Mauriello
E-mail from Chris Whitehead re
Compstate DVDs & NYPD summons
quota
Email from City re IAB docs & extending
time to produce
Email from City stating reasons why they
oppose amendment to Complaint
Email from client re article on “Collars for
Dollars”
E-mail from GC re article involving
Marino
E-mail from GC re NBC news coverage
on Schoolcraft
Email from GC re Polanco charges and
specs for retaliation for whistleblowing
Email from GC w/ draft for Schoolcraft
donation page
Email from hospital defendant & City re
proposed Amended Complaint
E-mail from JN re additional items of
discovery from City & subpoenas for
Johnstown records
Email from JN re edits to motion
26
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
0.25
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 24, 2015
March 7, 2012
February 7, 2012
August 17, 2010
May 21, 2015
September 16, 2010
June 8, 2012
September 22, 2010
April 24, 2012
August 6, 2010
August 7, 2010
August 5, 2010
September 28, 2011
December 7, 2010
March 22, 2012
July 11, 2011
July 18, 2011
February 10, 2012
May 17, 2012
May 25, 2012
March 20, 2015
April 25, 2012
May 22, 2012
April 7, 2015
Email from JN re motion in lim issues to
be covered
Email from John Eterno re QAD report
Email from Lee re outstanding
authorizations
E-mail from Mark Toor re Chief article
Email from NS re City’s overture on
discussing settlement
E-mail from other hospital defendant re
Amended Complaint
Email to AS re discovery VV affidavit and
1st Amendment issues
E-mail to DOJ with medical records
Email to hospital defendants re
amendment Gough issue
E-mail to JN & from JN re community
visits
E-mail to JN & from re explanation of
community visits
E-mail to JN re clarification of some
factual issues in the Complaint
Email to JN re law enforcement privilege
File final brief
Final edits on Amended Complaint w/ JN
Final review of discovery plan w/ JN &
GC
Final/final review of discovery plan w/
time limits
Phone call with client cancelling meeting
because of eviction issues
Read and review letter from City re NY
Times response
Read and review NY Times response to
Pubichas letter
Research on the “movie” project
referenced in Kretz’s email
Response emails
Review and sign Affidavit re VV article
Review edit NS to Ct. re our opp to
defendant’s letter
27
0.25
0.25
JPF
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
0.25
0.25
0.25
JPF
JPF
JPF
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
0.25
0.25
JPF
JPF
JPF
0.25
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
October 8, 2010
September 28, 2011
September 7, 2010
October 18, 2010
June 25, 2010
March 12, 2012
September 10, 2010
August 11, 2010
September 28, 2011
February 8, 2012
January 26, 2011
May 9, 2012
May 12, 2015
April 13, 2015
March 28, 2012
September 28, 2011
February 8, 2012
January 26, 2011
May 9, 2012
May 12, 2015
April 13, 2015
March 28, 2012
April 3, 2015
Review of article from Associate Press on
Schoolcraft
Review of changes to confidentiality stip
& disc. plan
Review of Chief article on AS
Review of letter to court re briefing sched.
Review of Schoolcraft retainer
Review of So Ordered Protective Order re
doc produced by City
Review of Times article points with GC
Review post of anonymous P.O. who
contacted website re recording Mauriello
Travel from SDNY - motion to compel
(.5)
Travel from SDNY - motion to compel
(.5)
Travel from SDNY for appearance for
motion to dismiss in Schoolcraft (.5)
Travel from SDNY for Argument on 1st
Amendment claim (.5)
Travel from SDNY for conf. (.5)
Travel from SDNY for conference re: trial
date (.5)
Travel from SDNY for Oral Argument on
City motion (.5)
Travel to SDNY - motion to compel (.5)
Travel to SDNY - motion to compel (.5)
Travel to SDNY for appearance for
motion to dismiss in Schoolcraft (.5)
Travel to SDNY for Argument on 1st
Amendment claim (.5)
Travel to SDNY for conf. (.5)
Travel to SDNY for conference re: trial
date (.5)
Travel to SDNY for Oral Argument on
City motion (.5)
Phone call with JN regarding progress on
motion in limine and clarification of
certain factual issues
28
0.25
JPF
0.25
0.25
JPF
JPF
0.25
0.25
JPF
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
0.25
0.25
JPF
JPF
JPF
0.25
JPF
0.25
0.25
JPF
JPF
0.25
JPF
0.25
JPF
0.20
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 11, 2015
October 24, 2010
April 30, 2012
May 7, 2012
December 1, 2010
November 13, 2012
January 10, 2012
April 4, 2012
June 19, 2012
October 13, 2010
August 29, 2012
April 11, 2012
December 29, 2010
February 4, 2015
April 19, 2012
August 31, 2015
November 29, 2010
February 10, 2015
August 15, 2012
December 9, 2010
August 15, 2012
April 2, 2012
August 21, 2012
August 14, 2012
August 23, 2012
August 21, 2012
2nd confirmation email from AS that we
have been officially retained again to
represent AS in this case
Article from the “L” re Schoolcraft
City e-mail request to adjourn amendment
conf.
City’s response keeping the 5/9 date
Correspondence from CCR re affidavit
Correspondence from City re rep of AS
Correspondence mail from medical
defendant Isacov re plaintiff EBT
Correspondence to JHMC re Amended
Complaint
Correspondence w/ Adhyl Polanco
Discussion with JN re agreement on
briefing sched. w/ defendant Jamaica
Hosp.
Email 2 & 3 from JN re discovery to
defendants
Email Amended Complaint to defendants
E-mail article from GC by Len Levitt re
AS case
Email AS confirming our rep w/ current
counsel
Email correspondence to City correcting
Lt. Gough for Amended Complaint
Email final motion to team
E-mail from AS re CCR affidavit
Email from AS re thoughts on
adjournment
Email from B Brady re plaintiff’s dep
E-mail from B. Lee defendants re late
responses to interrogatories
Email from B. Lee re plaintiff’s dep
Email from Bernier consenting to
amendment
Email from Brady consenting to
Amendment
Email from Brady re deps
Email from Brady re plaintiff’s dep date
Email from Brady re scheduling AS dep
29
0.10
0.10
JPF
JPF
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
JPF
JPF
JPF
0.10
0.10
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 13, 2012
Email from Brian Lee re deposition
0.10
JPF
August 15, 2012
April 20, 2012
September 24, 2012
0.10
0.10
0.10
JPF
JPF
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
JPF
February 10, 2012
Email from Brian Lee re subpoenaed docs
Email from City
Email from City
Email from City defendants re moving the
trial date back two weeks
Email from City on relevancy redaction
issue
Email from City on Vallone subpoena
extension
Email from City re Amendment
opposition
Email from City re AS dep date
Email from City re confidentiality stip
Email from City re fax # confirmation
Email from City re motion to amend
Email from City re moving argument
Email from City re plaintiff’s dep
Email from City regarding tax return
authorizations
Email from City requesting copy of
complaint
Email from Ct. re inventory on NY Times
issue
E-mail from Darius Charney re
Schoolcraft affidavit
Email from defendants re inventory
E-mail from French journalist Marie
Brunerie re documentary on whistle
blowing and Schoolcraft case
Email from GC & NS re IAB file
E-mail from GC on Cts decision on
motion
E-mail from GC on new cop
whistleblower from the 75th precinct
E-mail from GC re additional discovery
items to seek
0.10
JPF
October 20, 2010
September 28, 2010
E-mail from GC re another article AMNY
E-mail from GC re article on AS
0.10
0.10
JPF
JPF
February 10, 2015
July 9, 2012
April 25, 2012
March 30, 2012
August 22, 2012
August 3, 2012
September 13, 2012
August 1, 2012
May 18, 2012
August 16, 2012
July 13, 2012
August 21, 2012
June 5, 2012
November 16, 2010
June 6, 2012
November 19, 2010
February 23, 2015
May 6, 2011
May 24, 2011
30
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
February 24, 2011
December 16, 2010
February 19, 2011
August 28, 2012
March 8, 2011
December 2, 2010
October 22, 2010
February 23, 2012
August 15, 2010
May 3, 2011
November 3, 2011
January 25, 2011
September 24, 2010
August 10, 2012
November 21, 2010
August 16, 2010
November 15, 2010
March 7, 2012
September 25, 2012
August 22, 2012
December 8, 2010
March 3, 2011
April 2, 2012
September 15, 2010
April 4, 2012
April 4, 2012
Email from GC re article re Marino
misconduct
E-mail from GC re AS affidavit
E-mail from GC re Bryant v. City verdict
finding quotas existed
Email from GC re Chief article
Email from GC re medical defendants’
article
E-mail from GC re new whistleblower cop
on the website
E-mail from GC re NY Times article
E-mail from GC re NYCLU lawsuit for
POs faced with quotas
E-mail from GC re NYPD blog picking up
case
Email from GC re P.O. Hicks, Bronx
quota cop
Email from GC re plaintiff’s financials
Email from GC re statements from
Jamaica Hospital to Village Voice
E-mail from GC re The RANT
Email from GC re VV affidavit
E-mail from GC re Wall Street Times
article
E-mail from GC re website update for
articles on case
E-mail from GC re whistleblower cop
Email from GC re: conversation with
Larry and Adrian
Email from Greg R re Lauderborn dep
Email from Greg Rad re AS dep
E-mail from Hospital defendants re
docketing error on ECF
Email from HV re article re Lt. Williams
Email from Isacov consenting to
amendment
E-mail from Isacov’s attorney re Amended
Complaint
Email from JHMC
Email from JHMC
31
0.10
0.10
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
0.10
0.10
JPF
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
0.10
0.10
JPF
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
0.10
JPF
JPF
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
April 4, 2012
January 10, 2012
September 26, 2012
September 10, 2012
September 28, 2010
March 12, 2012
August 22, 2012
August 10, 2012
September 25, 2010
August 14, 2012
October 11, 2010
July 28, 2010
October 12, 2012
August 10, 2012
August 14, 2012
August 16, 2012
January 1, 2011
October 2, 2010
April 30, 2012
October 12, 2012
August 29, 2012
August 28, 2012
August 22, 2012
September 26, 2012
August 21, 2012
August 23, 2012
August 22, 2012
June 8, 2012
Email from JHMC re change in amended
language
Email from JMH re outstanding discovery
from plaintiff
Email from JN adjourning dep of AS re:
medical issues he was having
Email from JN re 120 extension of
discovery
E-mail from JN re article in Russian news
Email from JN re corrections
Email from JN re dep dates
Email from JN re extension of discovery
E-mail from JN re fed meeting
Email from JN re letter to City w/ tax
authorizations
E-mail from JN re Lewis whistleblower
cop
E-mail from JN re meeting with
Polanco/Graham Raymond & Rocco P.
Email from JN re photos used @ AS dep
Email from JN re plaintiff’s dep
Email from JN re plaintiff’s dep
Email from JN re plaintiff’s dep
E-mail from JN re Wall Street Journal
article about case
E-mail from JN re whistleblower cop
Email from JN to City re additions to
protective order
Email from JN to City re allowing AS
access to QAD report
Email from JN to defendants enclosing
discovery
Email from JN to defendants enclosing
responses to discovery
Email from Kretz re AS dep date
Email from Kretz re Launderborn dep
Email from Lee consenting
Email from Lee on plaintiff’s dep dates
Email from Lee re AS dep datr
Email from Lee re docs in response to
subpoenas outstanding
32
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
0.10
JPF
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
August 21, 2012
Email from Lee re scheduling AS dep
0.10
JPF
August 23, 2012
Email from Lee re second day for AS dep
Email from Nat Smith re logistics of
representation
Email from Nic re doc in connection w/
Schoolcraft meeting
Email from NS adjusting motion in lim
filing deadline to 9/21/15
Email from NS re a movie about AS that
Kretz wants discovery on
Email from NS wanting to schedule team
meeting prior to 5/12/15 conf.
Email from NY Times in response
Email from NY Times re inventory
Email from PBS producer Weinrich on
documentary of Schoolcraft
Email from plaintiff re 1st Amendment
claim
Email from Publichas re Schoolcraft Aff.
Email from Scott Korenbaum ("SK") re
motion in lim prep
E-mail JN & GC re edited Complaint
Email letter to City re amendment
Email motion to team for review
Email of Amended Complaint to City
E-mail re whistleblower cop from JN
Email response from Brady
Email response from City
Email response from Greg Rad
Email response from Kretz
Email response from Lee
Email response re tax authorizations
Email Response to GC re statements from
Jamaica Hospital to Village Voice
Email response to Kretz & City
Email rough draft of Mot. In Lim. to JN
for review
Email team w/ revisions to motion in lim
E-mail to AS with opp to Jamaica’s
motion
0.10
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
JPF
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
0.10
0.10
JPF
JPF
0.10
0.10
JPF
JPF
0.10
JPF
February 4, 2015
March 14, 2012
September 4, 2015
March 20, 2015
May 8, 2015
June 5, 2012
June 7, 2012
March 13, 2012
April 13, 2012
May 17, 2012
February 23, 2015
July 31, 2010
March 12, 2012
April 6, 2015
March 23, 2012
October 2, 2010
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
July 13, 2012
January 25, 2011
September 24, 2012
April 3, 2015
April 7, 2015
December 17, 2010
33
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
September 10, 2012
July 9, 2012
April 4, 2012
March 31, 2012
August 21, 2012
June 5, 2012
September 24, 2012
April 4, 2012
July 24, 2012
December 17, 2010
August 4, 2010
August 6, 2010
August 9, 2010
July 7, 2010
March 12, 2012
August 3, 2010
Email to City re Hanlon amend
Email to City re redaction issue
Email to City re updated version of
proposed Amended Complaint
Email to City requesting clarification on
reason for refusal
Email to City w/ Amended Complaint
Email to Ct. re proposed amended
complaint
Email to defendants re service of amended
complaint
Email to JHMC
Email to JN re Albany meeting w/
Schoolcrafts
E-mail to JN re AS benefits
E-mail to JN re Complaint
E-mail to JN re Complaint revised
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
JPF
0.10
0.10
JPF
JPF
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
May 2, 2012
June 4, 2012
E-mail to JN re Final version of Complaint
E-mail to JN re Labor Law research
Email to JN re proposed email
E-mail to JN re Revised Complaint
Email to JN re: revision of Schoolcraft
complaint
Email to JN with proposed Amended
Complaint
Email to plaintiff re letter to amend on 1st
Amendment claim
Email to team final motion
Email w/ draft to GC & JN
E-mail with Mark Toor – Chief
E-mail with Mark Toor – Chief
E-mail with Mark Toor – Chief
E-mail with Mark Toor – Chief
E-mail with Mark Toor – Chief
Enmail from JN to City re confidentiality
and discovery issues
Letter from Kretz re discovery
0.10
0.10
JPF
JPF
April 2, 2015
Phone call with JN regarding area of
expertise and scope of testimoy for Eterno
0.10
JPF
August 8, 2010
March 14, 2012
April 25, 2012
April 8, 2015
June 18, 2012
August 11, 2010
August 11, 2010
August 11, 2010
August 11, 2010
August 11, 2010
34
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
December 17, 2010
June 8, 2012
September 26, 2012
August 10, 2012
August 1, 2012
March 20, 2015
April 24, 2012
September 24, 2012
September 26, 2012
April 25, 2012
September 27, 2012
September 10, 2012
September 27, 2012
September 24, 2012
September 24, 2012
September 24, 2012
September 26, 2012
April 30, 2012
April 5, 2015
September 28, 2010
October 18, 2012
August 20, 2012
October 29, 2010
November 4, 2010
November 8, 2010
December 7, 2011
Phone convo with Larry Schoolcraft re
NYPD benefits & suspension status
Read and review of Times letter re
inventory
Response email from B Brady re service
of amended complaint
Response email re deposition from Greg
R.
Response email to City re motion to
amend
Response email to NS
Response emails
Response from B Lee
Response from B Lee
Response from City
Response from City
Response from City on Hanlon amend
Response from Greg R
Response from Greg R.
Response from Kretz
Response from Kretz
Response from Kretz
Response to email
Response to email
Review of article from Rocco & Daily
News
Review of email from B Lee asking that
plaintiff withdraw opp to extra day of dep
for AS
Review of email from JN to City re
amendment adding Hanlon
Review of letter from City extending
Answer time for Amended Complaint
Review of letter re Bernier’s extension to
answer Amended Complaint
Review of letter to Sweet extending
motion time
Review order adjourning conf.
TOTAL HOURS
0.10
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
JPF
0.10
0.10
JPF
JPF
894.75
35
SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005
Hours for Joshua P. Fitch, Cohen & Fitch LLP
TOTAL BILL
894.75 x $500.00
$447,375.00
36