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)

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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

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