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
“K”

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

DATE

June 18, 2010
June 20, 2010
June 21, 2010
June 23, 2010
June 24, 2010
June 25, 2010
June 25, 2010
June 25, 2010
June 25, 2010
June 26, 2010

June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 30, 2010
June 30, 2010

ACTION
Meeting w/Jon Norinsberg (JN) and Joshua Fitch
(JF) re: Schoolcraft coming to our office and
retaining for lawsuit
Email from Adrian Schoolcraft (AS) re: meeting
with JN
Email from AS re: Gerald Nelson
Meeting w/JN and JF re: JN's upcoming meeting
w/ Schoolcrafts
PC with JN re: meeting w/Schoolcraft
Meeting w/JN and JF re: scope of Schoolcraft
materials that need to be reviewed for complaint
Review of AS medical records
Meeting with JF & JN re: possible discovery
demands after suit is filed
Drafted retainer for Schoolcraft
Reviewed transcript of Polanco tapes
Online search of PBA Arbitration decision and
phone call w/Bonnie Siber Weinstock (arbitrator)
Discussion with JN and JF re retainer & meeting
with Schoolcrafts
Discussion with JN, JF & Adrian Schoolcraft
(AS) re: prior counsel Jonathan Moore
Review of interview memo re: Eddie Velasquez
Review of correspondence w/Jonathan Moore re:
AS
Meeting w/JN and JF re: PBA matters and how
they can be used in Schoolcraft
Review of David Velez arbitration decision
Discussion with JN & JF re decision on PBA
arbitration case
Correspondence w/JN re: Jonathan Moore
Discussion with JN & JF re substitution of
counsel Moore
Email from JN re: Stop and Frisk case
Email to JN re: Stop and Frisk case
Review of email from JN re: Schoolcraft matter
Sent email to JN re: Schoolcraft matter
Discussion with JN & JF re FOIL requests for
911’s & how to proceed
Review of email from AS

1

TIME

ATTY

0.80

GMC

0.10
0.25

GMC
GMC

0.75
0.40

GMC
GMC

3.25
1.75

GMC
GMC

1.40
0.60
0.75

GMC
GMC
GMC

2.10

GMC

1.25

GMC

0.30
0.30

GMC
GMC

0.10

GMC

1.25
0.50

GMC
GMC

0.40
0.25

GMC
GMC

0.25
0.10
0.10
0.10
0.10

GMC
GMC
GMC
GMC
GMC

0.50
0.10

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

July 2, 2010

July 6, 2010
July 6, 2010

July 7, 2010
July 7, 2010
July 7, 2010
July 7, 2010
July 9, 2010
July 12, 2010

July 13, 2010
July 14, 2010
July 15, 2010
July 15, 2010
July 16, 2010

July 17, 2010
July 19, 2010
July 20, 2010
July 21, 2010
July 22, 2010
July 23, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010

Phone call w/Eric Schneiderman staff re:
Schoolcraft
Meeting with JN/JF re: progress/developments on
the case, meeting in NYC on Wednesday and
filing of lawsuit
Meeting w/JN and JF re: new whistleblower
contacted JN re: Schoolcraft
Reviewed of Schoolcraft documents, evals,
photos, memos, UF49s, letters to PBA, letters to
Mauriello...
Listened to Schoolcraft recordings
Meeting w/ only Schoolcraft
Meeting with AS, Larry Schoolcraft (LS), JF &
JN
Reviewed AS timeline of events
Draft Schoolcraft complaint
Reviewed Schoolcraft materials, listened to
recording, made notes for further drafting of
complaint
Meeting w/JN and JF re: Schoolcraft complaint
Draft Schoolcraft complaint
Discussion with JF and JN re tapes
Meeting with JN re: Schoolcraft issues and
complaint
Reviewed of Schoolcraft documents, evals,
photos, memos, UF49s, letters to PBA, letters to
Mauriello...
Review of Village Voice Articles re: Schoolcraft
Researched case law for complaint and continued
drafting complaint
Drafted complaint
Discussed causes of action w/JF
Drafted and revised complaint
Review and revised Schoolcraft materials and
complaint
Meeting with JN & JF re case & updates on
Brendan Delpozo
Meeting JF and JN re issues for Schoolcraft
complaint
Discussion with JF & JN re Complaint & drafts
going forward
Discussion w/JN re Brandon del Pozo
Review of email from JN re: Del Pozo

2

0.30

GMC

1.75

GMC

1.30

GMC

2.90
1.80
1.50

GMC
GMC
GMC

0.75
1.40
2.30

GMC
GMC
GMC

1.75
1.25
2.10
1.10

GMC
GMC
GMC
GMC

1.25

GMC

2.10
1.25

GMC
GMC

2.10
1.50
1.40
1.25

GMC
GMC
GMC
GMC

3.10

GMC

2.10

GMC

1.00

GMC

0.60
0.30
0.10

GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

July 27, 2010
July 27, 2010
July 27, 2010
July 28, 2010
July 28, 2010
July 28, 2010
July 28, 2010
July 29, 2010
July 30, 2010
July 30, 2010
July 30, 2010
July 31, 2010
July 31, 2010
August 2, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 5, 2010
August 5, 2010
August 6, 2010
August 6, 2010
August 6, 2010
August 8, 2010
August 9, 2010

Review and revise Complaint
Meeting w/JN and JF to discuss Complaint
Mtg JN re draft of complaint and proposed
revisions
Listen to AS recordings, locate quotes, add to
complaint
Review of David Velez Arbitration Decision
Discussion with JF and JN re: Adhyl Polanco and
other whistlblowers
Review of email re: meeting with press
Review and Revise AS complaint
Meeting with JN, JF, Polanco & Graham
Raymond (GR) re: Schoolcraft & Monell claim
Review and revise complaint, transcribed partial
recordings, research case law
Meet with JF and JN re: changes and additions to
complaint
Meeting with Polanco + GR, JN, JF re: quotas
and Monell Claim
E-mail from JF re edited Complaint
Review and revise AS complaint
Review of 1st amendment case law
Review of JN's revised Schoolcraft complaint
Read and reviewed certain transcribed AS
recordings
Meeting w/JN re: Schoolcraft complaint and
other whistleblower police officers
Phone call with Jim Hoffer (ABC News) re:
Schoolcraft
Email correspondence re: media coverage of
filing Schoolcraft complaint
Read and reviewed certain transcribed AS
recordings
Review and revise AS complaint
Read and reviewed certain transcribed AS
recordings
Review of Schoolcraft complaint for typos
Review of transcribed call from LS to FBI
Review of email re: revision of Schoolcraft
complaint
Meeting w/JN and JF re: Schoolcraft website to
support Monell theory

3

2.00
1.25

GMC
GMC

0.75

GMC

3.80
0.75

GMC
GMC

0.50
0.10
3.10

GMC
GMC
GMC

3.25

GMC

2.40

GMC

1.25

GMC

3.20
0.10
1.25
1.10
1.00

GMC
GMC
GMC
GMC
GMC

0.80

GMC

0.50

GMC

0.30

GMC

0.25

GMC

2.40
0.80

GMC
GMC

2.75
1.10
0.25

GMC
GMC
GMC

0.10

GMC

1.50

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 10, 2010
August 10, 2010
August 10, 2010

August 10, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 11, 2010
August 11, 2010
August 11, 2010
August 11, 2010
August 12, 2010
August 12, 2010
August 12, 2010
August 13, 2010
August 13, 2010
August 15, 2010
August 15, 2010
August 15, 2010
August 16, 2010

Read and reviewed certain transcribed AS
recordings
Review of final draft of AS complaint to be filed
Discussion with JF re website content
Discussion with JF and JN re Adrian interview
Review of legal issues re: Negligent hiring claim
Meeting with AS to finalize for complaint filing,
news coverage, and prep for website launch
Draft Schoolcraft website content
Compiled news articles, stories, and formatted for
website
Phone and email correspondence with Off the
Page Creations to discuss deign of Schoolcraft
Justice website
Discussion with JN & JF re articles and possible
typo in Complaint
Reviewed and signed contract for website hosting
Schoolcraft complaint prepared for filing
Emailed draft of Schoolcraft website content to
JF and JN for review
Review and revise Schoolcraft website content
Discussion with JF re JN re anonymous P.O.
Review of email from whistleblower "JF" from
81st precinct - info on Mauriello
Review of San Francisco Chronicle coverage
Meeting w/JN and JF re: legal strategies on
Monell and whistleblower cop contacts
Email of docs from potential whistleblower PO
"KR"
Meeting w/JF and JN re: legal strategies + next
steps for moving forward
Discussion with JF & JN re Jonathan Moore issue
– cease & desist letter
Review of Bloomberg coverage of AS complaint
Meeting with JN and JF re NYTimes story about
quotas & Schoolcraft
Email w/JN re: NY Times to run Schoolcraft
story
E-mail to JF re NYPD blog picking up case
Email re: updates to Schoolcraftjustice.com

4

1.40
0.50
0.40
0.30
0.30

GMC
GMC
GMC
GMC
GMC

2.75
2.25

GMC
GMC

2.10

GMC

1.25

GMC

0.25

GMC

0.25
0.25

GMC
GMC

0.10
1.40
0.30

GMC
GMC
GMC

0.25
0.10

GMC
GMC

0.80

GMC

0.75

GMC

0.50

GMC

0.40

GMC

0.25

GMC

0.60

GMC

0.25
0.10
0.10

GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 17, 2010
August 17, 2010
August 17, 2010
August 18, 2010
August 19, 2010
August 22, 2010
August 22, 2010
August 22, 2010
August 23, 2010
August 23, 2010
August 23, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 26, 2010
August 26, 2010
August 26, 2010
August 27, 2010
August 27, 2010
August 27, 2010
August 27, 2010

Discussion with JF and JN re anonymous e-mails
that we got as a result of the e-mail
Review of Mark Toor article - JF interview
Updated AS website added new articles
Email correspondence w/website designer re:
Schoolcraftjustice.com
Discussion with JF and JN re: new recordings
and documents provided by AS
Meeting with JN & JF re whistleblowers reaching
out through the website
Phone call w/ "DM" former police officer re:
Schoolcraft
Review of Schoolcraftjustice posts
Phone call with Isakoff Attorney - Brian Lee
Review of Schoolcraftjustice posts
Email correspondence w/JN re:
Schoolcraftjustice posts
Meeting with JF, PO from 81st precinct "PF" re:
corruption
Drafted interview memo of "PF"
Meeting w/JN and JF re: ACC assigned,
Schoolcraft initial disclosures
Meeting with JN & JF re more whistleblower
email & meeting with P.O. "PF"
Meeting with JN & JF re: Whitehead
Review of email correspondence w/ Len Levitt
re: WSJ police correspondence
Review of email correspondence w/"DM"
(former PO) re: Schoolcraft
Emailed former anonymous PO re: Schoolcraft
post
Meeting with JF and JN re: interview of PO from
81st precinct "PF" re: corruption
Correspondence w/JN re: Frank Serpico
Email correspondence with Frank Serpico
Interview with JF of Walter Lipscomb, former
PO confirms quotas - wants to help Schoolcraft
Drafted interview memo of Walter Lipscomb
Discussion with JF & JN re having Eterno &
Silverman as experts
Discussion w/Jim Hoffer re: story on 81st
precinct

5

0.40
0.25
0.25

GMC
GMC
GMC

0.25

GMC

1.25

GMC

0.80

GMC

0.30
0.30
0.80
0.40

GMC
GMC
GMC
GMC

0.25

GMC

2.75
2.10

GMC
GMC

1.75

GMC

0.90
0.75

GMC
GMC

0.25

GMC

0.25

GMC

0.10

GMC

1.50
0.25
0.10

GMC
GMC
GMC

3.25
2.00

GMC
GMC

0.60

GMC

0.50

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 27, 2010
August 27, 2010
August 29, 2010
August 29, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010

August 31, 2010
August 31, 2010
August 31, 2010

August 31, 2010
August 31, 2010

September 1, 2010
September 1, 2010
September 1, 2010
September 2, 2010
September 2, 2010
September 3, 2010

September 3, 2010
September 3, 2010
September 3, 2010

Email to website designer with updates for
Schoolcrafjustice website
Review of Schoolcraftjustice posts
Discussion with JN re: Lipscomb interview
Phone call w/former PO re: Schoolcraft
Meeting with JN & JF re "MG" cop from 81 who
knows Schoolcraft & has info on quotas
Meeting with JN & JF re Labor & Employment
case & 12(b)(6) motion
Email correspondence w/JN re: "MG" (PO in
81st precinct)
Email w/JN re: ACC Donna Cannfield (DC)
Review of Donna Canfield (DC) Notice of
Appearance
Review of AOS prior to filing
Interview with JF of "DH" and "EB" former
NYPD, reviewed materials, recordings re: quotas,
downgrading
Interview of "ER" NYPD officer re: quotas,
downgrading
Email of docs from potential whistleblower PO
"KR"
Conversation with JN and JF re: topics to be
discussed/disclosed with Mark Toor in Chief
article
Email correspondence w/Jim Hoffer re:
Schoolcraft
Meeting w/JN and JF re: discuss anonymous POs
contacting and how they can help Schoolcraft
Drafted interview memo of "ER" meeting
Review of DC extension letter
Drafted interview memo of "EB" meeting
Drafted interview memo of "DH" meeting
Meeting with PO from 81st precinct "MG" re:
corruption
Meeting with JN and JF to discuss infromation
provided by DH, MG, EB whistleblower cops in
furtherance of the Monell claim
Review and revised JF draft of Rant post
Meeting w/JN re: THEE RANT post to get
officers to contact us on Schoolcraftjustice.com

6

0.30
0.25
0.50
0.40

GMC
GMC
GMC
GMC

1.25

GMC

0.40

GMC

0.10
0.10

GMC
GMC

0.10
0.10

GMC
GMC

3.25

GMC

1.80

GMC

0.90

GMC

0.25

GMC

0.10

GMC

1.80
1.50
0.10
2.40
1.10

GMC
GMC
GMC
GMC
GMC

2.75

GMC

1.40
0.60

GMC
GMC

0.50

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

September 3, 2010
September 3, 2010
September 7, 2010
September 7, 2010
September 7, 2010
September 10, 2010
September 10, 2010
September 10, 2010
September 13, 2010
September 13, 2010
September 13, 2010
September 15, 2010
September 15, 2010
September 15, 2010
September 17, 2010

September 17, 2010
September 18, 2010
September 18, 2010
September 20, 2010
September 20, 2010
September 20, 2010
September 20, 2010
September 20, 2010
September 20, 2010
September 21, 2010
September 23, 2010
September 23, 2010

September 24, 2010

Email correspondence w/JN re: THEE RANT
post
Email correspondence w/JN re: This American
Life Radio show
Review of JHMC Answer
Review of Media coverage NYTimes
Review of JHMC corporate disclosure
Listened to AS NPR radio show
Review of Times article points with JF
Review of Judge Sweet's endorsement of
extension
Drafted interview memo of "MG" meeting
Review of Amended complaint
Email correspondence w/ "WJC" former NYPD
Review of Eddie Velasquez depo from Floyd
Email correspondence re: Amended Complaint
with medical defendants
Review of stip extending time for Benier answer
Reviewed and cataloged Schoolcraftjustice.com
posts
Meeting with JN and JF regarding infromation
obtained from Floyd litigation and its impact on
Schoolcrafts Monell and Retaliation claims
Conversation with JF & JN re new whistleblower
cop
Correspondence w/JN re: anonymous Schoolcraft
post
Meeting with JF with PO "JB" re: NYPD quotas
and downgrading
Review of Angel Heran depo from Floyd
Review of Steve Mauriello depo from Floyd
Review of Donald McHugh depo from Floyd
Updated Schoolcraft Justice media page with
Radio interview
Discussion & review with JF & JN re media to
upload to website
Drafted interview memo of "JB" meeting
Meeting with JF, JN and Center for
Constitutional Rights (CCR) re Schoolcraft
Reviewed and finalized THEE RANT post
Discussion with JN and JF re: first meeting with
the DOJ and upcoming meeting with the DOJ and
AS

7

0.25

GMC

0.10
0.30
0.25
0.10
1.00
0.25

GMC
GMC
GMC
GMC
GMC
GMC

0.10
2.10
0.50
0.25
1.10

GMC
GMC
GMC
GMC
GMC

0.10
0.10

GMC
GMC

2.80

GMC

1.30

GMC

0.30

GMC

0.25

GMC

2.50
1.75
1.50
1.10

GMC
GMC
GMC
GMC

0.50

GMC

0.25
1.50

GMC
GMC

2.25
0.25

GMC
GMC

1.75

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

September 24, 2010
September 25, 2010
September 25, 2010
September 25, 2010
September 27, 2010
September 27, 2010
September 28, 2010
September 28, 2010
September 28, 2010
September 29, 2010
September 29, 2010
September 29, 2010
September 30, 2010
September 30, 2010
October 1, 2010
October 2, 2010
October 2, 2010
October 4, 2010
October 4, 2010

October 4, 2010
October 4, 2010
October 5, 2010
October 5, 2010
October 5, 2010
October 6, 2010
October 7, 2010
October 8, 2010

Drafted email and sent post to anonymous PO to
post on THEE RANT
Meeting with JF & JN re AS interview with feds
Email re: Schoolcraft visit to meet with Feds, NY
Times, ABC news
Email to Jim Hoffer re: Schoolcraft visit
Schoolcraft interview with Civil Rights Division
DOJ (pre and post), NY Times, ABC news
Meeting w/AS with JN, JF to prep for discussion
with US attorneys office EDNY
"Rich" anonymous cop discussion with JF
Review of Schoolcraftjustice.com posts
Review of Daily News article re: Schoolcraft
Phone interview of PO "VM" re quotas and
downgrading
Phone interview of PO "EF" re quotas and
downgrading
Review of Schoolcraftjustice.com posts
Meeting with JF and JN re: anonymous cop
interviews VM and EF
Review of Bernier answer
Review of Schoolcraftjustice.com posts
Email correspondence w/JN re: whistleblower
cops
Phone call with former PO "BS"
Meeting w/ JF and "JR" retired police officer re:
quotas, downgrading, NYPD corruption
Met with potential whistleblower PO "MF" re:
Schoolcraft, quotas, corruption
Meeting w/ JF and JN to discuss infromation
from "JR" retired police officer re: quotas,
downgrading, NYPD corruption
Emailed w/anonymous NYPD Captain re:
Schoolcraft allegations
Drafted interview memo of "MF" meeting
Reviewed Schoolcraftjustice posts, made calls,
returned emails and set up appointments
Drafted interview memo of "JR" meeting
Phone interview w/"PR" former 81st precinct PO
Meeting with JF and "EB" retired police officer
re: quotas, downgrading, NYPD corruption
Drafted interview memo of "EB" meeting

8

0.25
0.50

GMC
GMC

0.25
0.10

GMC
GMC

5.25

GMC

3.25
0.60
0.25
0.10

GMC
GMC
GMC
GMC

1.30

GMC

0.80
0.30

GMC
GMC

1.10
0.30
0.10

GMC
GMC
GMC

0.40
0.30

GMC
GMC

1.80

GMC

1.10

GMC

0.75

GMC

0.40
1.25

GMC
GMC

1.25
0.80

GMC
GMC

0.40

GMC

1.80
1.50

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

October 8, 2010
October 8, 2010
October 8, 2010
October 9, 2010
October 10, 2010
October 10, 2010
October 11, 2010
October 11, 2010
October 11, 2010
October 12, 2010
October 12, 2010
October 12, 2010
October 12, 2010
October 12, 2010
October 12, 2010
October 13, 2010

October 14, 2010
October 14, 2010
October 15, 2010
October 16, 2010
October 18, 2010
October 18, 2010
October 19, 2010
October 20, 2010
October 22, 2010
October 23, 2010
October 24, 2010

Phone interview with "MV" retired PO re:
quotas, retaliation, downgrading
Email correspondence w "NB" re: more
recordings
Review of AP story re: Schoolcraft case
Review of Schoolcraft post from former PO
"WN"
Meeting with JN and JF re: infromatoin provided
by MV, NB, EB whistleblower cops
Review of Schoolcraft posts
Review of Schoolcraft posts
Email correspondence w/JN re: Posts
Review of email from a police practices expert
Phone interview police officer "RL" re: quotas,
retaliation, downgrading
Meeting w/ JF and JN re: Schoolcraftjustice.com
calls from POs
Phone interview police officer "PL" re: quotas,
retaliation, downgrading
Review of JHMC motion to dismiss
Phone call and email w/ CUNY professor who
has info re: Schoolcraft
Review of Schoolcraft posts
Spoke to police officer "PL" re: quotas,
retaliation, downgrading
Meeting with JN re: information provided by PL
and RL whistleblower cops to support Monell
claim
Email to web designer updating
Schoolcraftjustice.com
Review of order setting deadlines for Motion to
Dismiss
Review of Schoolcraft posts
Phone call w/ "MG" re: quotas at 81st precinct
Review of letter requesting additional time to
respond to Motion to Dismiss
Review of Schoolcraft posts
Meeting with technician to reduce size of
Schoolcraft audio files
Phone call with police officer "MR" re: NYPD
quotas, downgrading, corruption
Left VM for JN re: Schoolcraft
Phone call with David Velez

9

1.30

GMC

0.25
0.25

GMC
GMC

0.10

GMC

1.40
0.40
0.30
0.25
0.25

GMC
GMC
GMC
GMC
GMC

1.10

GMC

1.00

GMC

0.75
0.75

GMC
GMC

0.25
0.25

GMC
GMC

0.40

GMC

0.75

GMC

0.40

GMC

0.10
0.25
0.75

GMC
GMC
GMC

0.25
0.25

GMC
GMC

0.40

GMC

1.25
0.10
0.30

GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

October 24, 2010
October 25, 2010
October 25, 2010
October 26, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 28, 2010
October 29, 2010

October 30, 2010
October 30, 2010

October 30, 2010
November 1, 2010
November 1, 2010
November 1, 2010
November 1, 2010
November 2, 2010
November 3, 2010
November 4, 2010
November 4, 2010
November 5, 2010
November 8, 2010
November 8, 2010
November 8, 2010

Review of Schoolcraft posts
Phone call with retired PO "RC" re: meeting to
discuss quotas provide evidence
Phone call with DC re: City Answer
Meeting with JF and "RC" to discuss experience
with quotas in a Brooklyn North precinct
Drafted interview memo of meeting w/"RC"
Meeting with JF and David Velez re: arbitration,
quotas, Michael Marino

0.25

GMC

0.60
0.25

GMC
GMC

3.10
1.75

GMC
GMC

1.40

GMC

Review of Isakov Answer to Amended complaint
Interview memo for meeting with David Velez
Review of City's request for an extension of time
to Answer to amended complaint

0.25
1.40

GMC
GMC

0.25

GMC

2.25
0.40

GMC
GMC

0.30

GMC

1.75

GMC

0.30
0.25

GMC
GMC

0.10

GMC

0.75

GMC

0.30

GMC

2.30

GMC

0.25
1.40
0.80

GMC
GMC
GMC

0.50

GMC

0.25

GMC

Meeting with JF & JN re: information provided
by MR, MG RC whistleblower cops and movie
and book publicist contacting AS for information
Phone call with entertainment lawyer
Email correspondence re: selling Schoolcraft life
rights for movie or book so that Adrian can
support himself while case proceeds
Reviewed Schoolcraftjustice posts made calls,
returned emails and set up appointments
Meeting with JN and JF re: updating Schoolcraft
website
Drafted content to update website
Review of Judge Sweet's order granting City
more time to file Answer
Email and phone correspondence with web
designer re: updates to Schoolcraftjustice.com
Review of mark ups from entertainment lawyer
re: Schoolcraft entertainment contracts
Meeting with JF and police officer "BP" re:
quotas, downgrading, and NYPD corruption
Review of letter and stipulation re: extension of
time to Answer Amended Complaint
Interview memo for "BP"
Met with JF and police officer "MC" re: quotas
Review of Document Demands and
Interrogatories filed by Isakov
Review of letter requesting additional time to
oppose motion to dismiss

10

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

November 9, 2010
November 9, 2010
November 10, 2010
November 10, 2010
November 11, 2010
November 11, 2010
November 11, 2010
November 11, 2010
November 12, 2010

November 12, 2010
November 13, 2010
November 16, 2010
November 16, 2010
November 16, 2010
November 16, 2010
November 16, 2010

November 17, 2010
November 18, 2010
November 19, 2010
November 19, 2010
November 20, 2010
November 21, 2010
November 29, 2010
November 29, 2010
November 30, 2010
December 1, 2010
December 1, 2010

Spoke to anonymous police officer CW re:
quotas in the 81st precinct
Meeting with JN about interviews with CW and
MC whistleblower cops regarding Monell claim
Phone call w/ police officer "JW" re: quotas and
retaliation in a Brooklyn precinct
Review of Schoolcraftjustice.com posts
Meeting with JF and "JW" cop to discuss
quotas/retaliation
Review of discovery demands from Bernier
Review of draft of plaintiff's first set of
interrogatories
Review of amended answer from Bernier
Interview memo for meeting with "JW"
Meeting with JN and JF re: issues on our motion
opposition and about infromation provided by
JW anonymous cop
Review of Schoolcraftjustice.com posts
Phone call with Charney re: Schoolcraft affidavit
Review of affidavit Darius Charney wants
Schoolcraft to sign for Floyd case
Emailed JN re: changes to Schoolcraft Floyd
affidavit
Left voice message for Charney re: affidavit
Review of Schoolcraftjustice.com posts
Reviewed and revised Discovery Demands and
Requests to Admit to be served on City
Defendants
Review of Schoolcraftjustice.com posts
Email correspondence with French
documentarian
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of WSJ article re: Schoolcraft case
Review of AS's changes to Floyd affidavit
Phone call w/AS re: Floyd affidavit
Implemented AS's changes to Floyd affidavit for
final review by Charney
Email and phone correspondence w/Charney re
Floyd affidavit
Discussion with JF & JN re affidavit from
Schoolcraft

11

0.75

GMC

0.60

GMC

0.50
0.10

GMC
GMC

1.60
0.40

GMC
GMC

0.30
0.25
1.10

GMC
GMC
GMC

1.00
0.10
0.40

GMC
GMC
GMC

0.40

GMC

0.10
0.10
0.10

GMC
GMC
GMC

3.80
0.10

GMC
GMC

0.10
0.10
0.10
0.25
0.50
0.30

GMC
GMC
GMC
GMC
GMC
GMC

3.40

GMC

0.80

GMC

0.40

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

December 2, 2010
December 2, 2010
December 6, 2010
December 6, 2010
December 6, 2010
December 8, 2010
December 8, 2010
December 8, 2010
December 8, 2010
December 9, 2010
December 9, 2010
December 9, 2010
December 10, 2010
December 12, 2010
December 14, 2010
December 24, 2010
December 26, 2010
January 3, 2011
January 10, 2011
January 20, 2011
January 20, 2011
January 26, 2011
January 26, 2011
January 26, 2011
January 26, 2011
January 31, 2011
January 31, 2011

Review of City Defendants answer to Amended
Complaint
Review of Schoolcraftjustice.com posts
Revise and review opposition to JHMC motion to
dismiss
Discussion with JF & JN re final corrections
Drafted letter response to premature discovery
demands for Bernier and Isakov
Review of NYPD re: new quota bill
Email correspondence from Lee re: Docket sheet
Review of email correspondence w/Graham
Raymond
Review of Schoolcraftjustice.com posts
Discussion w/ JN & JF re discovery responses &
timing
Review of email re: Discovery from Isakov
Review of Schoolcraftjustice.com posts
Email w/JN re: HIPAAs
Review of Daily News article w/memo showing
proof of quota
Correspondence w/Charney and Schoolcraft re:
Floyd affidavit
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of email correspondence from police
officer "CW" re: Marino and quotas
Meeting with JF & JN re interrogatories and
demands
Review of JHMC reply memo in support of
motion to dismiss
Meeting with JN, JF to discuss JHMC's reply
memo of law
Appearance for motion to dismiss in Schoolcraft
Discussion with JF & JN re oral arguments
Travel from SDNY for appearance for motion to
dismiss in Schoolcraft (.5)
Travel to SDNY for appearance for motion to
dismiss in Schoolcraft (.5)
Discussion w/JN re: requesting Queens DA to
investigate Halloween night
Meeting with JN & JF re send documents &
authorizations to Queens DA office

12

0.40
0.10

GMC
GMC

1.25
0.80

GMC
GMC

0.40
0.40

GMC
GMC

0.10

GMC

0.10
0.10

GMC
GMC

0.50
0.10
0.10
0.10

GMC
GMC
GMC
GMC

0.25

GMC

0.40
0.10
0.10

GMC
GMC
GMC

0.25

GMC

1.50

GMC

0.50

GMC

0.40
1.00
0.60

GMC
GMC
GMC

0.25

GMC

0.25

GMC

0.40

GMC

0.40

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

January 31, 2011
February 8, 2011
February 10, 2011
February 11, 2011
February 14, 2011
February 17, 2011
February 19, 2011
February 19, 2011
February 19, 2011
February 19, 2011

March 1, 2011
March 3, 2011
March 3, 2011
March 13, 2011
March 16, 2011
April 11, 2011
April 12, 2011
April 14, 2011
April 15, 2011
April 18, 2011
April 20, 2011
April 26, 2011
May 6, 2011
May 6, 2011
May 9, 2011

May 10, 2011

Review of materials sent to Queens DA to start
investigation
Discussion w/ JN & JF re letter to court to
schedule discovery
Review of JHMC motion to stay discovery
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Meeting with JF re: getting transcript for Bryant
v. City verdict finding quotas existed
Phone call with former NYPD officer "SS"
Email correspondence w/JN re: Seth Harris
verdict finding quota
Review of Schoolcraftjustice.com posts
Meeting with anonymous cops from T34 w/ JF
and JN - provided recordings of Lt. Janice
Williams
Email correspondence with former NYPD PO PK
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Phone call with Adrian and Larry Schoolcraft re:
Letter from NYPD charges and specs
Review of email re: Adrian charges
Review of email from WME re: Schoolcraft life
rights
Meeting w/Harry Levine Queens College re:
Schoolcraft, quota study
Discussion w/ JN & JF re prep of letter re NYPD
hearing & PBA representation
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Judge Sweet's opinion re: JHMC
motion to dismiss
Email correspondence w/JN and JF re: motion to
dismiss decision
Meeting with JN and JF re: neccesary disclosures
under Rule 26 for plaitniff
Meeting with JN and JF re: edits to Intial
disclosures and discussion regarding requests to
admit

13

0.25

GMC

0.30
0.25
0.10
0.10
0.10

GMC
GMC
GMC
GMC
GMC

0.60
0.30

GMC
GMC

0.10
0.10

GMC
GMC

1.25

GMC

0.10
0.10
0.10
0.10

GMC
GMC
GMC
GMC

0.75
0.25

GMC
GMC

0.10

GMC

0.50

GMC

0.30
0.10
0.10

GMC
GMC
GMC

0.60

GMC

0.25

GMC

1.75

GMC

1.40

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

May 10, 2011
May 10, 2011
May 12, 2011
May 12, 2011
May 13, 2011
May 14, 2011
May 15, 2011
May 18, 2011
May 18, 2011
May 19, 2011
May 19, 2011
May 19, 2011
May 20, 2011
May 20, 2011
May 20, 2011
May 20, 2011
May 20, 2011
May 24, 2011
May 30, 2011
June 13, 2011
June 19, 2011
June 23, 2011
June 23, 2011
June 23, 2011
June 27, 2011
June 27, 2011
July 5, 2011
July 6, 2011

Review of Intial disclosures and discussion with
JF
Review of Schoolcraftjustice.com posts
Discussion w/ JF & JN re agency agreement
Review of Book deal agreement for Adrian
Schoolcraft
Review of Schoolcraftjustice.com posts
Meeting with JF reviewing RFA's
Meeting with JN and JF re: edits to RFA's
Drafted outline and notes for neccesary discovery
demands for JN
Meeting with JF to discuss documents that must
be requested in our demands
Discuss w/ JN & JF edits & topic areas that
should be explored on interrogatories
Review of JN's draft document demands
Email from JN re: dep notices to be served
Discussion w/ JF & JN re request to admit
corrections/additions
Discuss interrogatories & discuss EBTs w/ JN &
JF
Review of JN's request for admission
Review of JN's revised draft document demands
Email from Adrian Schoolcraft
Review of email and correspondence w/JN re
anonymous PO from 81st precinct
Review of Schoolcraftjustice.com posts
Email correspondence with anonymous PO re:
Schoolcraft matter
Review of Schoolcraftjustice.com posts
Discussion with JF & JN re responses & requests
from Isacov
Review of Isakov response to Discovery
Demands
Review of Schoolcraftjustice.com posts
Discussion with JN and JF re City’s failure to
response to discovery requests
Review of email correspondence with DC
Review of Discovery plan and correspondence
regarding same
Discussion w/ JN & JF re changing to case
management plan

14

0.75
0.10
0.40

GMC
GMC
GMC

0.25
0.10
2.75
1.00

GMC
GMC
GMC
GMC

1.30

GMC

1.10

GMC

1.25
0.75
0.10

GMC
GMC
GMC

1.50

GMC

1.30
0.30

GMC
GMC

0.30
0.10

GMC
GMC

0.40
0.10

GMC
GMC

0.25
0.10

GMC
GMC

0.60

GMC

0.60
0.10

GMC
GMC

0.30
0.30

GMC
GMC

0.75

GMC

0.40

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

July 8, 2011
July 8, 2011
July 11, 2011
July 15, 2011
July 15, 2011
July 15, 2011
July 18, 2011
July 18, 2011
July 19, 2011
July 25, 2011
July 26, 2011
July 27, 2011
August 4, 2011
August 8, 2011
August 9, 2011
August 9, 2011
August 10, 2011
August 11, 2011

August 14, 2011
August 15, 2011
August 16, 2011
August 17, 2011
August 17, 2011

August 18, 2011
August 23, 2011

Discussion with JF and JN re: meeting with Jim
Leander and AS about investigation
Review of pretrial order for conference
Final review of discovery plan w/ JN & JF
Meeting with JF an JN re: discovery plan and
issues to raise
Review revised discovery plan
Review of JN email re: objections to discovery
plan
Review of changes to discovery plan made by
Lee
Review of email by JN to DC re changes
Review of Literary Agency agreement for
Schoolcraft
Review of email from Brian Lee re: Discovery
plan dispute
Review of email correspondence between parties
finalizing language of discovery plan
Executed discovery plan email
Fully executed discovery plan
Review and revised responses to Bernier
Discovery demands
Drafted responses to JHMC discovery demands
Review of Schoolcraftjustice.com posts
Review of JN comments to JHMC responses
Review of Isakov demands
Drafted responses to all discovery demands for
medical defendants and emailed to JN for his
review
Review of email correspondence re: delay in
discovery production
Review of City protective order stipulation
Discuss confidentiality stip w/ JF & JN b/c of
plaintiff’s objections
Review of Brian Lee objections to protective
order stip
Drafted letters accompanying responses to
Discovery Demands and prepared thumb drives
that included responsive documents
Review of email from Gregory Radmosli re:
Protective order stip

15

1.75
0.10
0.25

GMC
GMC
GMC

0.50
0.40

GMC
GMC

0.10

GMC

0.25
0.10

GMC
GMC

0.10

GMC

0.25

GMC

0.40
0.10
0.25

GMC
GMC
GMC

0.50

GMC

1.80
0.10
0.25
0.25

GMC
GMC
GMC
GMC

4.75

GMC

0.25
0.40

GMC
GMC

1.25

GMC

0.25

GMC

1.10

GMC

0.10

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 30, 2011
August 31, 2011
September 1, 2011
September 2, 2011
September 12, 2011
September 28, 2011
September 28, 2011
September 28, 2011
September 28, 2011
September 29, 2011
September 30, 2011
October 12, 2011
October 12, 2011
October 17, 2011
October 21, 2011
October 22, 2011
October 23, 2011
October 24, 2011
October 25, 2011
October 26, 2011
October 27, 2011
October 28, 2011
October 29, 2011
November 2, 2011
November 3, 2011
November 4, 2011
November 5, 2011
November 12, 2011
November 13, 2011
November 17, 2011
November 29, 2011
November 29, 2011
December 6, 2011
December 7, 2011
December 13, 2011
December 13, 2011

Review of email correspondence from Brian Lee
re: protective order stip changes
Email response from DC re stip
Review of email from Darius Charney enclosing
Floyd decision
Review of Schoolcraftjustice.com posts
Review and revise motion to compel City to
produce discovery
Discussion w/ JN and JF re law enforcement
privilege & motion to compel
Attend oral argument on motion to compel
Travel from SDNY - motion to compel (.5)
Travel to SDNY - motion to compel (.5)
Review, revised, and executed amended
discovery plan
Email from all parties re: executed amended
discovery plan
Receipt and review defendants first discovery
responses
Review of motion to approve protective order
Review of pre-trial order
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of email re: discovery from Brian Lee
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Review of order re: pretrial conference
Phone call with Larry and Adrian Schoolcraft
Review of Schoolcraftjustice.com posts

16

0.30
0.10

GMC
GMC

0.50
0.10

GMC
GMC

0.40

GMC

1.25
1.00
0.25
0.25

GMC
GMC
GMC
GMC

0.30

GMC

0.25

GMC

2.00
0.25
0.10
0.10
0.30
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
0.10
0.10
0.10
0.80
0.10

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

December 15, 2011
December 19, 2011
January 5, 2012
January 10, 2012
January 12, 2012
January 20, 2012
January 24, 2012
January 24, 2012
February 7, 2012
February 7, 2012
February 7, 2012
February 7, 2012
February 8, 2012

Review of Schoolcraftjustice.com posts
Discussion w/ JF & JN re plaintiff's thoughts on
discovery
Review of letter from Bernier's attorneys
Meeting with AS, JN and JF
Review of City Defendants first Discovery
Demands
Phone call with Adrian and Larry
Spoke to JN re: AS salary
Email copy of NOC with salary included
Review of email demanding authorizations from
Brian Lee
Emai from JN re: supplemental demands
Email correspondence re: pretrial conference

February 27, 2012

Review notice of appearance for City Defendants
Pre-trial conference before Judge Sweet
Discussion with JF and JN re: conference and
discovery and stratedgy moving forward
Travel from SDNY - motion to compel (.5)
Travel to SDNY - motion to compel (.5)
Drafted proposed supplemental demands for the
City and emailed to JN for review
Discussion w/ JN & JF re additional items of
discovery
Review of email from JN re discovery we need to
follow up with city
Email from JN re: Cancellation of Adrian and
Larry trip to NYC
Review of email to Jeremy (Meridian
Investigations) re: subpoena of Schoolcraft
records
Review of final supplemental discovery demands
for NYC
Review of email correspondence w/Chris Dunn
Meeting with JF and JN re: documents received
from Johnstown PD for plaintiff's subpoena

February 27, 2012
February 28, 2012
February 29, 2012
February 29, 2012
February 29, 2012

Review of subpoena response from Johstown PD
Review of email from AS's former partner
Phone call with AS's formaer partner
Phone call w/Adrian re former partner
Email to AS's former partner

February 8, 2012
February 8, 2012
February 8, 2012
February 10, 2012
February 10, 2012
February 10, 2012
February 10, 2012

February 10, 2012
February 13, 2012
February 24, 2012

17

0.10

GMC

0.50
0.25
4.90

GMC
GMC
GMC

0.50
0.75
0.25
0.10

GMC
GMC
GMC
GMC

0.25
0.10
0.10

GMC
GMC
GMC

0.10
1.00

GMC
GMC

0.75
0.25
0.25

GMC
GMC
GMC

1.80

GMC

1.60

GMC

0.25

GMC

0.10

GMC

0.10

GMC

0.30
0.25

GMC
GMC

0.75

GMC

0.75
0.10
0.75
0.40
0.10

GMC
GMC
GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

March 1, 2012
March 6, 2012
March 7, 2012
March 7, 2012
March 7, 2012
March 7, 2012
March 7, 2012
March 8, 2012
March 8, 2012
March 8, 2012
March 8, 2012

March 9, 2012
March 9, 2012
March 10, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 13, 2012
March 13, 2012
March 13, 2012
March 14, 2012
March 14, 2012
March 14, 2012
March 14, 2012
March 15, 2012
March 15, 2012
March 16, 2012

Phone call with AS re: former partner
Review of Village Voice Article re QAD
investigation
Discussed adding 1st amendment claim with JN
and JF
Phone call with Larry and Adrian Schoolcraft
Email to JN an JF re: conversation with Larry
and Adrian
Review of NOA by Suzanna Publicker ("SP")
Review of Schoolcraftjustice.com posts
Discussion with JN & JF re VV article and the
confidential report
Email from Jim Hoffer
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Discussion with JN & JF re reinstating 1st
Amendment claims in this case based on Garcetti
& actions after the fact
Review of Schoolcraftjustice.com posts
Review of Schoolcraftjustice.com posts
Meeting with JN & JF re letter from City
Review of SP letter re "leaked" QAD report
Email correspondence with defendants re
Amendment
Review & edit response to City's letter re
protective order
Review of Schoolcraftjustice.com posts
Review of signed protective order
Email correspondence with Mark Toor
Email from PBS producer Weinrich on
documentary of Schoolcraft
Review of Schoolcraftjustice.com posts
Review and revise of amended complaint adding
1st amendment claim
Email correspondence w/Nic re docs in
connection w/ Schoolcraft meeting
Review of NY Times article on Schoolcraft
Review order on City motion re QAD
Meeting with JN and JF re proposed Amended
Complaint
Email correspondence from anonymous "MD"
PO re: 81st precinct
Radio interview re: Schoolcraft

18

0.30

GMC

0.30

GMC

0.25
0.25

GMC
GMC

0.10
0.10
0.10

GMC
GMC
GMC

0.75
0.10
0.10
0.10

GMC
GMC
GMC
GMC

1.25
0.10
0.10
0.60
0.40

GMC
GMC
GMC
GMC
GMC

0.25

GMC

0.25
0.10
0.10
0.10

GMC
GMC
GMC
GMC

0.10
0.10

GMC
GMC

0.50

GMC

0.25
0.10
0.10

GMC
GMC
GMC

0.60

GMC

0.10
0.40

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

March 20, 2012
March 21, 2012
March 21, 2012
March 22, 2012
March 24, 2012
March 28, 2012

March 28, 2012
March 28, 2012
March 28, 2012
March 28, 2012
March 28, 2012
March 29, 2012

March 30, 2012
March 30, 2012
March 30, 2012
March 30, 2012
March 30, 2012
April 5, 2012
April 5, 2012
April 5, 2012
April 6, 2012
April 9, 2012
April 10, 2012
April 10, 2012

Review of Schoolcraftjustice.com posts
Review of NY Times motion to unseal
Schoolcraft records
Email correspondence w/JN re: NY Times
motion
Review of Schoolcraftjustice.com posts
Email correspondence w/Defendants re Amended
complaint
Oral Argument on City motion
Discussion with JN and JF re: court's order on
City's motion for breach of confidentiality
agreement
Legal research: review of Garcetti and progeny to
discuss Amendment issues
Meeting w/ JN & JF prior to conference to prep
Travel from SDNY for Oral Argument on City
motion (.5)
Travel to SDNY for Oral Argument on City
motion (.5)
Revised and help draft proposed AEO stip w/JN
and JF for City
Email correspondence w/SP re Discovery
extension and opposition to amendment of
Complaint
Meeting w/ JN & JF re AEO changes
Discussion with JN and JF re: filing motion to
amend and discovery issues
Final review of proposed AEO stip
Emailed proposed AEO stip to the City
Reviewed and revised responses to City
defendants discovery requests
Review & discuss w/ JN & JF plaintiff’s
responses to City demands
Review of basis for City's opposition to
Amendment
Correspondence w/ NY Times counsel re:
protective order
Email correspondence w/JN re: discovery
responses
Meeting w/ AS
Email enclosing discovery responses to City
demands

19

0.10

GMC

0.40

GMC

0.10
0.10

GMC
GMC

0.25
1.00

GMC
GMC

0.50

GMC

0.40

GMC

0.40

GMC

0.25

GMC

0.25

GMC

0.80

GMC

0.60
0.60

GMC
GMC

0.50
0.30
0.10

GMC
GMC
GMC

1.80

GMC

0.80

GMC

0.25

GMC

0.30

GMC

0.10
4.60

GMC
GMC

0.10

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

April 10, 2012

Email re: Schoolcraft arrival to NYC

0.10

GMC

April 13, 2012
April 13, 2012
April 13, 2012

Discussion with JN and JF re: Matthews decision
Review of Matthews decision
Email from plaintiff re 1st Amendment claim
Review and revise JF motion to Amend 1st
Amendment claim
Email correspondence to City correcting Lt.
Gough for Amended Complaint

0.60
0.60
0.10

GMC
GMC
GMC

0.75

GMC

0.10

GMC

Email from City re: Vallone and Vans subpoenas
Review NY Times proposed language to
protective order and email sent to City
Defendants
Discussion w/ JN and JF re NY Times alteration
to protective order
Review of correspondence with SP re: adjourning
oral argument on Amendment
Discussions w/ JN and JF re City’s request for
affidavits & deposition for confidentiality breach
Email to City re: failure to provide discovery or
respond to proposed AEO
Review of defendants proposed AEO stip and
declaration re: "leak"
Discussion w/ JF & JN re Affidavits and conf.
stip AEO
Review of correspondence with SP re: adjourning
oral argument on Amendment again
Discussion w/ JN and JF re argument on 1st
Amendment claim
Review of NOA William Fraenkel
Attended Oral Argument on 1st Amendment
claim
Travel from SDNY for Argument on 1st
Amendment claim (.5)
Travel to SDNY for Argument on 1st
Amendment claim (.5)
Read and review of defendant’s letter to quash
and discussion w/ JF & JN

0.10

GMC

0.40

GMC

0.30

GMC

0.25

GMC

0.40

GMC

0.25

GMC

1.25

GMC

0.75

GMC

0.10

GMC

0.60
0.10

GMC
GMC

1.00

GMC

0.25

GMC

0.25

GMC

2.10

GMC

0.10

GMC

0.60

GMC

April 24, 2012
April 24, 2012
April 25, 2012

April 30, 2012
April 30, 2012
April 30, 2012
May 1, 2012
May 2, 2012
May 3, 2012
May 3, 2012
May 3, 2012
May 8, 2012
May 8, 2012
May 9, 2012
May 9, 2012
May 9, 2012
May 11, 2012
May 15, 2012
May 16, 2012

Email correspondence w/SP re: Breach Affidavit
Discussion w/ JN and JF re opp to defendant’s
motion to quash

20

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

May 16, 2012

May 17, 2012
May 17, 2012
May 17, 2012
May 17, 2012
May 17, 2012
May 18, 2012
May 18, 2012
May 22, 2012
May 23, 2012
May 23, 2012
May 23, 2012
May 23, 2012
May 23, 2012

May 24, 2012
May 24, 2012
May 25, 2012
May 29, 2012
May 30, 2012
May 31, 2012
June 4, 2012
June 5, 2012
June 6, 2012
June 7, 2012
June 7, 2012
June 8, 2012

Email correspondence w/Darius Charney
Review and edit plaintiff’s opp to defendant’s
motion to quash Vallone and Vans motion to
quash
Discussion w/JN and JF re: AS breach affidavit
Review and discuss City New York Times opp
letter w/ JN & JF
Phone call with NY Times counsel re: Stip
language
Email re: AS breach affidavit
Meet and confer w/SP re: Stips
Email correspondence w/SP re: scheduling oral
argument on motion to quash
Discussion w/ JN & JF re defendant’s letter re
Vallone subpoena
Attend and argue against motion to quash
Prep for argument w/ JF & JN
Discussion w/ JN & JF re defendant’s letter re
subpoena
Travel from SDNY for motion to quash (.5)
Travel to SDNY for motion to quash (.5)
Drafted and submitted supplemental evidence to
support our opposition to quash Vans and
Vallone subpoena
Review of NOA - Walter Kretz ("WK")
Read and review NY Times response to SP letter
Revised City proposed AEO and Conf Stips
incorporating NY Times requests
Email correspondence w/JN re City stips and
revisions
Meeting w/JN and JF re: City conf. Stips
Review of WK correspondence re: discovery
Review of email correspondence between SP and
Times
Review of email correspondence between SP and
Times
Revised AEO and Conf stips to send back to the
City and emailed to JN for final review
Review of email correspondence between SP and
Times
Email re: subpoenaed docs

21

0.25

GMC

0.80
0.75

GMC
GMC

0.40

GMC

0.30
0.10
0.60

GMC
GMC
GMC

0.10

GMC

0.60
1.00
1.00

GMC
GMC
GMC

0.60
0.25
0.25

GMC
GMC
GMC

0.50
0.10

GMC
GMC

0.25

GMC

0.50

GMC

0.30
0.90
0.10

GMC
GMC
GMC

0.10

GMC

0.10

GMC

1.40

GMC

0.10
0.10

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

June 8, 2012
June 8, 2012
June 14, 2012
June 14, 2012
June 14, 2012
June 14, 2012
June 18, 2012
June 19, 2012
June 19, 2012
June 19, 2012
June 19, 2012
June 20, 2012
June 20, 2012
June 21, 2012
June 30, 2012
July 2, 2012
July 6, 2012
July 9, 2012
July 9, 2012
July 10, 2012
July 17, 2012
July 20, 2012
July 23, 2012
July 23, 2012
July 26, 2012
July 28, 2012
August 1, 2012

Emailed stip to SP with revisions in track
changes
Review of correspondence with NY Times and
SP re: Schoolcraft materials
Meet with JN and JF to discuss motion for
reconsideration on 1st amendment claim
Review of Judge Sweet re: motion to amend and
motion quash subpoena
Phone call with Adrian and Larry re; decision
Email correspondence with JN re: decision
Review of JF motion for reconsideration on
motion to amend
Meeting w/ Schoolcraft in Johnstown
Travel back to NYC from Johnstown (3.5)
Travel to Johnstown (3.5)
Email and phone correspondence with Adhyl
Polanco re: Schoolcraft issues
Final edit and review of Motion for
Reconsideration
Reviewed SP response to Stip proposal
Email correspondence w/JN and JF re
Schoolcraft issues
Review of Schoolcraftjustice.com posts
Discussion w/ AS and Larry Schoolcraft re
financial issues
Review of email from JF re Stips
Researched donations to individuals
Drafted proposed language for Donate button on
website
Review of City response re Stips
Email w/JN re: meeting in Albany with
Schoolcrafts
Review of opinion on Plaintiff's motion to
reconsider
Discussion w/ JF & JN re meeting w/
Schoolcrafts in Albany
Correspondence re: visiting Schoolcrafts in
Albany
Review of Schoolcraftjustice.com posts
Discussion w/ JN & JF re motion to amend to add
prior restraint
Review and revise motion to amend

22

0.10

GMC

0.10

GMC

0.75

GMC

0.60
0.50
0.25

GMC
GMC
GMC

0.75
4.80
1.75
1.75

GMC
GMC
GMC
GMC

0.10

GMC

0.30
0.30

GMC
GMC

0.25
0.10

GMC
GMC

0.40
0.10
0.50

GMC
GMC
GMC

0.40
0.10

GMC
GMC

0.10

GMC

0.30

GMC

0.30

GMC

0.25
0.10

GMC
GMC

0.60
0.40

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 8, 2012
August 8, 2012
August 8, 2012
August 9, 2012
August 9, 2012
August 9, 2012
August 10, 2012

Email correspondence w/SP re: document
production
Review of Schoolcraftjustice.com posts
Email re: meeting with Schoolcrafts
Email correspondence re: authorizations
Meeting w/ JN & JF re meeting w/ AS in Albany
for prep
Review of final stips
Printed out docs to go over with Adrian
Meeting w/AS in Albany
Traveled from Albany back to NYC (3.0)
Traveled to Albany to meet Client (3.0)
Email correspondence re: extension of disco

August 10, 2012
August 10, 2012
August 12, 2012

Email correspondence re: Schoolcraft deposition
Email w/JN re Schoolcraft breach affidavit
Review of Schoolcraftjustice.com posts

0.25
0.10
0.10

GMC
GMC
GMC

August 13, 2012

Review of email from SP re: scheduling AS depo
Email web designers re: donation for
Schoolcrafts button on website
Review of correspondence re Tax returns
Email correspondence with all defendants re:
subpoenaed docs

0.10

GMC

0.25
0.10

GMC
GMC

0.25

GMC

0.10

GMC

0.75

GMC

0.10

GMC

0.60
0.50
0.10
0.10
0.10
0.10
0.10
0.10

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

0.40
0.10
0.10

GMC
GMC
GMC

August 3, 2012
August 4, 2012
August 6, 2012
August 7, 2012

August 14, 2012
August 14, 2012
August 15, 2012
August 15, 2012
August 16, 2012
August 16, 2012
August 20, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 22, 2012
August 22, 2012
August 22, 2012

Email correspondence re: Schoolcraft deposition
Discussion w/ JN & JF re City’s suggestion on
multiple dates for deps
Email correspondence re: Schoolcraft deposition
Discussion w/ JN & JF re additional amendment
of the complaint to add Hanlon
Review of Amended Complaint adding Hanlon
Email from Brady consenting to Amendment
Email from Brady re scheduling AS dep
Email from City requesting copy of complaint
Email from Lee consenting
Email from Lee re scheduling AS dep
Email to City w/ Amended Complaint
Meeting w/ JF & JN re Kretz’s request to have an
additional day to depose plaintiff
Email from City re AS dep date
Email from Greg Rad re AS dep

23

0.25
0.10
0.10
0.25

GMC
GMC
GMC
GMC

1.30
0.50
0.25
5.75
1.50
1.50
0.25

GMC
GMC
GMC
GMC
GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 22, 2012
August 22, 2012
August 22, 2012

Email from JN re dep dates
Email from Kretz re AS dep date
Email from Lee re AS dep date

0.10
0.10
0.10

GMC
GMC
GMC

August 23, 2012
August 23, 2012
August 23, 2012
August 23, 2012

3.50
0.10
0.10
0.10

GMC
GMC
GMC
GMC

0.10
0.10

GMC
GMC

August 28, 2012

Review of disocvery provided by City defendants
Email from Brady re plaintiff’s dep date
Email from Lee on plaintiff’s dep dates
Email from Lee re second day for AS dep
Email from JN to defendants enclosing responses
to discovery
Email JN and JF re Chief article
Review of correspondence sending out Fulton
County records

0.10

GMC

August 29, 2012
August 29, 2012

Meeting w/ JF & JN 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
Email 2 & 3 from JN re discovery to defendants

0.80
0.10

GMC
GMC

0.10

GMC

0.75
0.40
0.10

GMC
GMC
GMC

0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
3.80

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

0.25
0.10
0.10

GMC
GMC
GMC

0.25

GMC

1.75

GMC

August 28, 2012
August 28, 2012

August 29, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 15, 2012
September 17, 2012
September 18, 2012
September 19, 2012
September 21, 2012
September 24, 2012

Email from JN to defendants enclosing discovery
Read and review Opinion & Order from Sweet on
plaintiff’s motion to amend
Phone call with PO "FP" re Schoolcraft
Email from City re fax # confirmation
Email from JN re 120 day extension of discovery
Email response from Brady
Email response from City
Email response from Greg Rad
Email response from Kretz
Email response from Lee
Email to City re Hanlon amend
Response from City on Hanlon amend
Reviewed IAB recordings provided by the City
Review of draft letter to amend to add Hanlon to
complaint
Review of order granting ext. of disco deadline
Received final Stips
Email correspondence w/Darius Charney re:
Floyd
Meeting w/JN and JF to discuss City deficiency
letter and AS dep prep

24

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

September 24, 2012
September 24, 2012
September 24, 2012
September 25, 2012
September 25, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 27, 2012
September 28, 2012
October 2, 2012
October 3, 2012
October 4, 2012
October 4, 2012
October 4, 2012
October 10, 2012
October 10, 2012
October 11, 2012
October 11, 2012
October 12, 2012

October 15, 2012
October 15, 2012

October 17, 2012
October 17, 2012
October 17, 2012

Email from City re service of amended
complaint, Lauderborn dep, & discovery
deficiencies
Email correspondence w/Darius Charney re:
Floyd
Email correspondence re service of amended
complaint
Prep AS for his dep
Meeting w/ AS & JF & JN re dep prep
Meeting w/ JN & JF & AS re adjorning dep due
to father’s medical emergency
Brady email re: service of process
Review of email from JN adjourning AS dep
Reviewed and signed stips
Reviewed and resigned stips
Review of QAD interview of AS
Received AS new email address
Review of IAB recordings
Phone call and email correspondence w/Darius
Charney
Review of plaintiff's responses to defendants
interrogatories
Prep Adrian for deposition
Review amended complaint
Attended AS deposition and meeting afterwards
Meeting with JN, JF, AS before depo
Correspondence to SP re: color photos and QAD
file review by AS
Meeting w/JN & JF re: Marino's IAB interview &
inconsitencies w/claims in UF 49 & Halloween
Night recording
Read and reviewed Kretz motion to have extra
day to depose AS
Meeting w/JN & JF re: City's privilege claims
and possible arguments/motions to defeat such
claims highlights of Lauterborn interview &
inconsistencies w/Marino & home invasion
recording
Dicussion w/ JF & JN re City’s refusal to allow
AS to see QAD file
Email from SP re: QAD file

25

0.50

GMC

0.25

GMC

0.10
3.50
2.90

GMC
GMC
GMC

0.60
0.10
0.10
0.25
0.10
2.25
0.10
2.75

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

0.75

GMC

0.40
4.60
0.75
8.90
0.50

GMC
GMC
GMC
GMC
GMC

0.25

GMC

1.20

GMC

0.30

GMC

3.30

GMC

0.40
0.10

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

October 18, 2012
October 18, 2012

October 18, 2012
October 18, 2012
October 18, 2012

October 20, 2012
October 22, 2012

October 23, 2012
October 24, 2012
October 24, 2012
October 24, 2012
November 2, 2012
November 2, 2012
November 7, 2012
November 7, 2012
November 7, 2012
November 7, 2012
November 7, 2012
November 13, 2012
November 13, 2012

Meeting w/JF & JN re: City's Deliberative
Process and Grand Jury privilege claims and best
strategy for defeating same.
Read and review Answer to Amended Complaint
from City
Review and revised of JN Motion permitting AS
to review QAD material and opposing 3 days of
depositions for AS
Email from SP re: service of newly named City
defendants
Review of email from B Lee asking that plaintiff
withdraw opp to extra day of dep for AS
Phone call w/JN & JF re: P.O. Nowacki
acknowledging quota (15 c's per month) at 81 &
possibly serving non-party subpoeana on her for
dep and discovering other possible w's at 81 re
summons quota
Review of City request to enlarge Hanlon time to
respond
Drafted responses and compiled responsive docs
for City defendants second request for discovery
sent to JN for review
Hearing on issue of extra dep time for AS
Travel from SDNY for conference re: trial date
(.5)
Travel from SDNY for conference re: trial date
(.5)
Review of case law sent by Lee re: medical
defendants liability
Email from JN re: Schoolcraft phone numbers
Hearing on issue of AS able to review QAD file
Review of letter by SP relieving City as counsel
for Mauriello
Travel from SDNY for conference re: trial date
(.5)
Travel from SDNY for conference re: trial date
(.5)
Email w/JN re: service of newly named
defendants
Confirming with JF w/AS on the phone that he is
terminating representation
Various correspondence confirming termination
of representation with the parties

26

1.20

GMC

0.75

GMC

0.50

GMC

0.10

GMC

0.10

GMC

0.90

GMC

0.10

GMC

3.40
0.80

GMC
GMC

0.25

GMC

0.25

GMC

0.40
0.10
0.80

GMC
GMC
GMC

0.30

GMC

0.25

GMC

0.25

GMC

0.10

GMC

0.30

GMC

0.25

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

November 13, 2012
November 14, 2012
November 15, 2012
November 19, 2012
November 26, 2012
January 23, 2015
February 2, 2015
February 2, 2015

February 4, 2015
February 4, 2015
February 4, 2015
February 4, 2015
February 4, 2015
February 5, 2015

February 5, 2015
February 8, 2015
February 8, 2015
February 9, 2015

February 9, 2015

February 10, 2015
February 10, 2015
February 11, 2015

Correspondence from City re rep of AS
Receipt and review of letter terminating our
representation of AS
Review and signed letter to court informing we
no longer represent AS
Review of court order prohibiting providing AS
AEO material
Review of correspondence to AS enclosing files
Call w/JN and JF about taking over case again
Discussion w/ JF & JN re representing AS again
for trial
Phone conversation w/JN re AS wants to rehire
us
Phone call w JN and JF re: pending trial strategy
and misc.evidentiary issues, and setting up
meetng to discuss same in greater detail
Review of email from AS re: QAD memo from
Sgt. Scott
Read and reviewed email from AS re: rehiring us
Discussion w/ JN & JF re scheduling a meeting
w/ NS to discuss case status and trial prep
Review of email from Nat Smith ("NS")
acknowledging and logistics of represetation
Read and reviewed AS deposition
Phone call w. JN re: updates on discussion with
Nat Smith, records and transcripts provided by
Adrian and goal to streamline case for trial
Read and reviewed AS deposition
Email correspondence re: videos of deps
Read and reviewed Larry Schoolcraft Deposition
Phone call JN re: issues that came up in Adrian's
Dep and Larry's Dep and possible Miotions in
Limine
Meeting w/ JN & JF regarding global trial
strategy, witnesses to be called (or not called),
exhibits to use, Rule 68 offer and next steps for
moving forward.
Email correspondence w/AS, JN re: Defendants
request to adjourn trial
Review of deposition exhibits

27

0.10

GMC

0.10

GMC

0.25

GMC

0.10
0.25
0.80

GMC
GMC
GMC

1.30

GMC

0.30

GMC

0.90

GMC

0.40

GMC

0.30

GMC

0.25

GMC

0.10
2.25

GMC
GMC

0.50
3.25
0.25

GMC
GMC
GMC

2.75

GMC

0.40

GMC

3.50

GMC

0.25
3.10

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

February 11, 2015
February 11, 2015
February 11, 2015
February 12, 2015
February 12, 2015

February 13, 2015
February 13, 2015

February 13, 2015
February 13, 2015
February 15, 2015
February 16, 2015
February 17, 2015
February 17, 2015
February 18, 2015
February 18, 2015

February 18, 2015
February 19, 2015
February 19, 2015
February 19, 2015

February 19, 2015
February 19, 2015

Review of summary judgment motions and
exhibits
Review of witness/exhibit list from JN and
discuss with JF
Review of email from AS
Review of deposition exhibits
Review of NOA for Howard Scheiner
Review of all evidence we have and what we are
missing, drafted a list for JN to discuss, prepared
items to put in binder, organized critical evidence
for trial prep
Meeting w/JN to discuss which witnesses I would
be responsible for at trial
Review of letter by Ryan Shaffer requesting more
time for reply and 2 week adjournment of trial
Review of order setting trial date to April 20,
2015
Review of deposition exhibits
Review of summary judgment motions and
exhibits
Review of deposition exhibits
Listened and took notes of PAA Boston IAB
interviews and reviewed Scott inteview memos
Began cross examination draft of PAA Boston
Read, reviewed and took notes of PAA Boston
deposition
Phone call JN regarding meeting for Friday,
important testimony from PAA Boston and issues
to cover in the plaintiffs direct (re: downgrading
and MIL regarding Johnstown Social Services
Drafted Boston Cross outline
Reviewed Mauriello's motion for SMJ and
opposition to plaintiff's motion for SMJ
Retrieved a portion of AS deposition for JN
Phone call JN regarding best and worst PTS from
Huffman, Adrian's handling of downgrading
issue at his deposition, fit for duty reports, and
general issues that might come up at tomorrows
meeting
Emailed JN summary of deposition section and
noted it for prep of AS at trial

28

2.50

GMC

1.30
0.10
4.40
0.10

GMC
GMC
GMC
GMC

5.25

GMC

1.30

GMC

0.10

GMC

0.10
4.80

GMC
GMC

3.10
3.75

GMC
GMC

1.60
2.30

GMC
GMC

2.25

GMC

0.60
2.30

GMC
GMC

1.40
1.25

GMC
GMC

0.50

GMC

0.30

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

February 20, 2015
February 20, 2015

February 20, 2015
February 20, 2015
February 20, 2015
February 23, 2015
February 23, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 26, 2015
February 26, 2015
February 26, 2015
February 26, 2015
February 26, 2015

February 26, 2015
February 26, 2015

Meeting w/ TEAM to discuss trial strategy,
division of labor, motions
Drafted Boston cross outline
Meeting w/ JN and JF before meeting with Nat
Smith to discuss how we are going to proceed at
meeting
Phone call JN regarding summary of todays
meeting
Review of letter AS wishes to send to Zachary
Carter re indemnification from Mauriello claim
Read, reviewed and took notes on Huffman
deposition
Follow-up email with NS re: meeting
Drafted Huffman cross examination outline
Review of John Eterno Deposition
Listened and isolated points of 10/31 day tour
recording from cross outline
Listened to Huffman IAB interviews and
reviewed Scott memo re same
Discussion with JF re: Huffman cross
Email correspondence w/NS re confidentiality
Review of email from JN to NS re missing docs
needed for crosses
Drafted Huffman cross examination outline
Drafted Valenti examination outline
Review of Valenti deposition
Review of patrol guide procedures re sick leave
and AWOL
Review of email from AS re timeline
Email correspondence re: major points to hit with
Valenti
Drafted Valenti examination
Review of all recordings inventory and
identifying recordings that are missing
Meeting w/JN and JF re: outstanding items we
need from trial from NS
Discussion with JF re: Valenti exmanination
Email w/NS team re: missing recordings
Phone call with JN regarding plaintiff's
conversation with Huffman, recording of same
and making transcripts of other recordings.
Phone call w/JN and Merry Soeto re: IAB and
DAO recording

29

3.50
1.50

GMC
GMC

1.00

GMC

0.20

GMC

0.10

GMC

3.00
0.25
3.40
1.90

GMC
GMC
GMC
GMC

1.25

GMC

1.10
0.75
0.25

GMC
GMC
GMC

0.25
3.40
2.40
1.50

GMC
GMC
GMC
GMC

0.90
0.40

GMC
GMC

0.30
3.40

GMC
GMC

1.80

GMC

1.10
0.50
0.40

GMC
GMC
GMC

0.40

GMC

0.30

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

February 26, 2015
February 27, 2015
February 27, 2015

February 27, 2015
February 27, 2015
March 2, 2015
March 3, 2015

March 3, 2015
March 4, 2015

March 4, 2015
March 4, 2015
March 4, 2015
March 4, 2015
March 4, 2015
March 5, 2015
March 6, 2015
March 6, 2015
March 6, 2015
March 9, 2015
March 9, 2015
March 9, 2015

March 9, 2015
March 9, 2015
March 10, 2015

Email correspondence w/NS and JN re: IAB
recorded interviews
Review of deposition summaries by NS team
Email and phone correspondence w/Veritext re:
transcribing IAB recordings
Email correspondence with NS and JN re: dep
summaries, index of all exhibits, potential trial
exhibits
Emailed confidentiality stip to Veritext for
transcribers to sign
Review of deposition summaries by NS team
Review and revise Huffman cross examination
outline
Phone call JN regarding IAB tapes, strategy for
plaintiff direct and for use of home invasion
audio in opening
Review and revise Huffman cross examination
outline
Phone call with JN regarding Huffman cross-x
points, and using Valenti deposition testimony to
refute same and reassigning Sgt. James cross and
obtaining a draft of direct for plaintiff from NS
Phone and email call w/JN re: witness list
E-mail exchange JN regarding Velez PBA
transcript, copy of same
E-mail exchange with JN regarding identity of
other IAB investigator
E-mail froim JN with revised witness list
Received and reviewed (for accuracy)
transcribed IAB recordings from Veritext
Review of defendants Reply memorandums for
SMJ
Discussion w/ JN & JF re proposed witnesses
Review of AS proposed witness list
Review of plaintiff's consolidated 56.1
Review of Marino deposition
Phone call w/NS re consolidated 56.1
Phone call w. JN regarding E-mails sent to Smith
and setting up meeting with him and his trial
team
Review of Lamstein depostion errata sheet
Began drafting AS direct examination

30

0.25
3.80

GMC
GMC

1.25

GMC

0.40

GMC

0.25
1.40

GMC
GMC

1.80

GMC

0.50

GMC

2.30

GMC

0.50
0.30

GMC
GMC

0.10

GMC

0.10
0.10

GMC
GMC

2.75

GMC

2.25
0.60
0.30
1.00
0.80
0.40

GMC
GMC
GMC
GMC
GMC
GMC

0.30
0.30
4.80

GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

March 10, 2015
March 10, 2015
March 11, 2015
March 11, 2015

Discussion with JF to help outline AS direct
exmaination
Email and phone correspondence w/NS team re
Schoolcraft recordings of 10/31

1.50

GMC

0.60

GMC

5.50
0.10

GMC
GMC

March 12, 2015

Draft AS direct examination, review deps, audios
Email w/NS and JN re: exhibits and meeting
Meeting w/ JF, JN, NS, and Jon L re trial,
motions

2.40

GMC

March 12, 2015
March 12, 2015

Draft AS direct examination, review deps, audios
Email from AS re: witness list

2.25
0.10

GMC
GMC

March 13, 2015

Draft AS direct examination, review deps, audios
Review of proposed jury instructions drafted by
NS team
Review of email from JN re:
Draft AS direct examination, spoke to AS on
phone, developed ideas re points to cover
Review of production index and evidence to
assess documents still missing and needed for
review and incorporation into examinations
Discussion with JF re: AS direct examination and
points to cover, strategy
Drafted and sent email to NS team re: missing
documents
Draft AS direct examination, reviewed docs,
memos, recordings
Review of interview memo of Stretmoyers
Began Draft James cross examination, reviewed
docs, memos, hospital records
Drafted and emailed subpoenas of City
defendants to NS
Email w/JN re Schoolcraft direct
Review of NS striking Lamstein report
Draft James cross examination, reviewed docs,
memos, hospital records
Discussion with JF re: James cross examinaiton
Review of NS verdict sheet
Began Draft Sawyer cross examination, reviewed
docs, memos, hospital records, audio
Email re Kretz finding Schoolcraft

4.30

GMC

0.40
0.25

GMC
GMC

3.40

GMC

1.40

GMC

1.30

GMC

0.30

GMC

6.25
0.30

GMC
GMC

5.40

GMC

0.75
0.25
0.25

GMC
GMC
GMC

3.90
0.75
0.25

GMC
GMC
GMC

4.80
0.25

GMC
GMC

March 13, 2015
March 13, 2015
March 16, 2015

March 16, 2015
March 16, 2015
March 16, 2015
March 17, 2015
March 17, 2015
March 18, 2015
March 18, 2015
March 18, 2015
March 18, 2015
March 19, 2015
March 19, 2015
March 19, 2015
March 20, 2015
March 20, 2015

31

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

March 22, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 24, 2015

March 24, 2015
March 24, 2015
March 25, 2015
March 25, 2015
March 26, 2015
March 26, 2015
March 26, 2015
March 26, 2015
March 26, 2015

Review of NS letter re Lamstein and emailed
comments
Draft Sawyer cross examination, reviewed docs,
memos, hospital records, audio
Discussion with JF re: Sawyer points for cross
examination
Various email correspondence w/NS re: verdict
sheet, Lamstein letter and exhibit list/chart
Meeting with JN regarding important points of
Sgt/ James and Sgt. Sawyer's testimony
Phone call w/JN re: James call to Lauterborn
Phone correspondence w/ JN re: AS discussion of
Home Invasion
Email correspondence re: Schoolcraft short film
Email to NS team re: PO Miller IAB tape
Locate and send AS deposition testimony to help
with JN crosses
Review of Kretz supplemental interrogatories re
Schoolcraft movie
Email from JN w/portion of Lauterborn cross re
James
Email to NS re: Sawyer memo book
Updated Huffman cross examination w/roll call
recordings, QAD findings
Meeting w/ JN discussing role of Sadowsky,
Miller and Sawyer; Also, QAD Huffman
interview and relation to Mauriello and general
trial strategy
Email and phone correspondence w/JN re:
Huffman QAD connection
Drafted email to NS team re: locating points of
AS Audio recordings
Email correspondence w/JN and NS regarding
regular meetings
Updated AS direct examination
Review of AS medical records from JHMC, Sure,
Luell, Forrest Hills
Email correspondence w/AS re Kretz letter
Email from JN re: medical records
Review of Kretz letter re film

32

0.40

GMC

2.75

GMC

0.60

GMC

0.50

GMC

0.40
0.40

GMC
GMC

0.30
0.25
0.25

GMC
GMC
GMC

0.25

GMC

0.25

GMC

0.10
0.10

GMC
GMC

1.75

GMC

0.60

GMC

0.30

GMC

0.25

GMC

0.25
3.25

GMC
GMC

2.30
0.10
0.10
0.10

GMC
GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015

March 27, 2015
March 28, 2015
March 29, 2015
March 30, 2015

March 30, 2015
March 30, 2015
March 30, 2015
March 30, 2015
March 31, 2015
March 31, 2015
April 1, 2015

April 1, 2015
April 1, 2015
April 2, 2015
April 2, 2015

Phone call with NS, JL and JN regarding multiple
issues related to prepping for trial, including
exhibits, experts, jury charges, voir dire, speaking
to landlord, prepping client and comp stat clips
Phone conference with JN, NS, JF, John Lenoir
("JL")
Review of documents produced by Graham
Raymond
Various email correspondence JN and NS re:
Meeting missing IAB Lauterborn recording
Review of Sgt. Chu and Scott memo
Review of emails w/City re subpoenas
Email correspondence w/ Merry Soetano re: AS
audio clips
Phone call JN regarding preparing for conference
call with NS today and using Veritext software
Emailed JN and NS rough draft of AS direct
Review of AS email, timeline, records
Began Draft Broschart cross examination,
reviewed docs, memos, audio
Phone call JN & JF regarding admissibility of
tape recorded statements of persons interviewed
by IAB
Phone call w/JN re: Citys request to adjourn
Review of AS letter requesting conference
Email from JN w/IAB report
Draft Broschart cross examination, reviewed
docs, memos, audio
Email correspondence w/NS and JN re trial
witnesses and exhibits
Reviewed and revised Broschart cross
examination
Phone Call with JN regarding important points
from Valenti and Broschart and additional
grounds for impeaching Huffman and difference
between Administrative leave and lost time
Email re: meeting w/JN, and NS team
Meeting with JN and NS team
Drafted and sent follow up emails w/NS team and
JN after meeting re: exhibits

33

1.90

GMC

1.00

GMC

0.50

GMC

0.40
0.30
0.25

GMC
GMC
GMC

0.10

GMC

0.10
0.10
0.40

GMC
GMC
GMC

4.50

GMC

0.30
0.30
0.25
0.10

GMC
GMC
GMC
GMC

3.50

GMC

0.25

GMC

3.90

GMC

0.50
0.10
1.90

GMC
GMC
GMC

0.50

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

April 2, 2015
April 2, 2015
April 2, 2015

April 2, 2015
April 3, 2015

April 3, 2015
April 3, 2015
April 3, 2015
April 4, 2015
April 4, 2015
April 5, 2015
April 5, 2015
April 6, 2015

April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 7, 2015
April 7, 2015
April 7, 2015

Review of SK jury instructions along with email
re: same
Email and phone correspondence with veritext re:
Lauterborn audio
Phone call w/NS re IAB transcripts
Phone call with JN regarding Lauterborn's second
PG in September 2010 and getting recordings of
same
Updated revised and drafted Broschart cross
examination outline
Phone call JN regarding important point from
Broschart testimony and defendants' of obsession
to suspend and real reason for entering apartment
(illegal search and destroy evidence)
Review of revised Scott Korenbaum ("SK") jury
instructions along with email re: same
Review email from JN including AS performance
report
Email from NS re: revised exhibit list
Review of revised verdict sheet from NS
Email correspondence w/JN and NS re revised
exhibit list
Review email from JN including AS W2s
Review and revised JF MIL
Phone call with NS & JN regarding exhibit list,
verdict sheet, important points for opening
regarding Bernier and Isakov and failure of med
departments to speak with IAB
Phone call w/JN and NS re: trial exhibits
Review of audio clips from NS
Review of revised SK jury instructions along
with email re: same
Email from NS re Audio clips
Review of City letter request for extension
Review of email correspondence re Alan
Scheiner ("AS") request for adjournment
Began Draft Duncan cross examination, reviewed
docs, memos, audio
Review of revised JF MIL
Review and discuss NS letter to court re: delay of
trial and announcing our rehiring w/JN

34

0.30

GMC

0.25
0.25

GMC
GMC

0.10

GMC

5.50

GMC

0.30

GMC

0.25

GMC

0.10
0.25
0.10

GMC
GMC
GMC

0.25
0.10
1.25

GMC
GMC
GMC

1.00
0.50
0.40

GMC
GMC
GMC

0.25
0.10
0.10

GMC
GMC
GMC

0.10

GMC

3.50
0.50

GMC
GMC

0.30

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 8, 2015

April 8, 2015

April 8, 2015
April 8, 2015

April 8, 2015
April 8, 2015
April 9, 2015
April 9, 2015
April 9, 2015
April 11, 2015
April 11, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 14, 2015

Review of Jury Instructions from Magdelena
Bauza ("MB')
Phone call JN & NS regarding best strategy for
handling City's request for adjournment
Phone call with JN regarding City's application
for adjournment
Review of SK comments on JF MIL draft
Draft Duncan cross examination, reviewed docs,
memos, audio
Phone call with JN and JF regarding trial
adjournment, proposed filings, various strategies
for trying to make sure trial goes on April 20
Email and phone correspondence re: pushing
trial back a week to avoid delay of trial post
summer
Final review of MIL
Phone call JN regarding points from Duncan
deposition regarding ESU, meat cleaver and
travelling to Johnstown
Phone call NS and JN re writing a supplemental
letter to Court regarding trial date issues
Draft Duncan cross examination, reviewed docs,
memos, audio
Emailed JN a portion of Duncan cross
Emailed NS for BNIU exhibits for inclusion on
JPTO
Email correspondence w/JN and NS re: trial date
and schedule
Email w/NS re Home Invasion Transcript
Update and revise Duncan cross examination,
Conf. on trial date – case adjourned
Meeting w/JN and JF re new trial date
Email w/veritext re: changes to Home Invasion
transcript
Travel from SDNY for conference re: trial date
(.5)
Travel to SDNY for conference re: trial date (.5)
Email correspondence w/RS and NS re:
Lauterborn interview
Email correspondence with SK re: Jury
instructions

35

0.30

GMC

0.20

GMC

0.10
0.10

GMC
GMC

3.80

GMC

0.75

GMC

0.60
0.30

GMC
GMC

0.20

GMC

0.20

GMC

4.10
0.10

GMC
GMC

0.10

GMC

0.25
0.10
2.10
1.00
0.50

GMC
GMC
GMC
GMC
GMC

0.25

GMC

0.25

GMC

0.25

GMC

0.10

GMC

0.10

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015

April 17, 2015
April 17, 2015

April 17, 2015
April 17, 2015
April 21, 2015
April 27, 2015
April 29, 2015
May 5, 2015
May 5, 2015
May 5, 2015
May 8, 2015
May 12, 2015
May 12, 2015
May 12, 2015
May 12, 2015
May 12, 2015
May 13, 2015
May 14, 2015
May 15, 2015
May 18, 2015
May 21, 2015
May 28, 2015
May 29, 2015
May 29, 2015

Reviewed and revised Boston outline for
deposition read ins
Review of newly produced Lamstein notes
Emailed w/JN and NS re mediation offer from
the City
Phone call w/JN re Boston unavailability
Review of correspondence re: PAA Boston
Phone call w/ rest of trial team regarding City'
proposal for mediation and best strategy for
responding
Conference call with team re: best strategy for
responding to City latest "offer"
Phone call with JN & JF following up on phone
call and discussing settlement position vs. going
to trial
Email from RS re Lauterborn audios
Review of letter from City requesting more time
for MIL
Email correspondence with City re: Lauterborn
Audio
Email with NS re trial issues and AS
Read and review Ct’s Opinion on SJ
Discussion w/JN and JF re SMJ
Email w/JN re SMJ opinion
Discussion w/ JF & JN re decision and impact on
trial and motion in lim
Meeting w/NS team JN and JF pre-conf
Team meeting following conf.
Conf. trial adjourned to Oct. 19
Travel from SDNY for conf. (.5)
Travel to SDNY for conf. (.5)
Email correspondence w/SK re conference
Email correspondence all parties re: pretrial
submissions schedule
Email correspondence all parties re: pretrial
submissions schedule
Review of letter motion filed by City re JPTO
dates
Email NS re settlement offer from City
Email JN re Veritext bill
Email w/JN and NS re: City bifurcation request
Email correspondence all parties re: pretrial
submissions schedule

36

2.25
0.25

GMC
GMC

0.10
0.10
0.10

GMC
GMC
GMC

0.60

GMC

0.50

GMC

0.40
0.10

GMC
GMC

0.25

GMC

0.25
0.25
1.40
0.50
0.10

GMC
GMC
GMC
GMC
GMC

0.80
1.50
1.25
1.00
0.25
0.25
0.10

GMC
GMC
GMC
GMC
GMC
GMC
GMC

0.10

GMC

0.10

GMC

0.10
0.10
0.10
0.25

GMC
GMC
GMC
GMC

0.10

GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

June 1, 2015
June 2, 2015
June 3, 2015
June 4, 2015
June 10, 2015
June 22, 2015
June 23, 2015
June 23, 2015
June 24, 2015
June 24, 2015
June 29, 2015
July 6, 2015
July 6, 2015
July 7, 2015
July 7, 2015
July 8, 2015
July 13, 2015
July 15, 2015
July 17, 2015
July 20, 2015
July 23, 2015
July 23, 2015
July 24, 2015
July 24, 2015
July 24, 2015

Review and comment on NS draft
reconsideration
Review of citys motion to bifurcate
Review of email correspondence w/court re
motions
Review of Mauriello's motion for reconsideration
Phone call with Schoolcrafts and JN
Review of email correspondence re: opposition to
reconsideration motions
Review of email correspondence re: opposition to
reconsideration motions
Review of email correspondence re: opposition to
reconsideration motions
Review of email correspondence re: opposition to
reconsideration motions
Review of email correspondence w SK re:
motion schedules
Review of NS motion opposing bifurcation
Review of opposition motions to defendants
reconsideration motions
Review of email correspondence between all
parties
Review of email correspondence between NS
team re Eterno
Review of email correspondence re: opposition to
reconsideration motions
Review of email correspondence between all
parties
Review of JHMC to NS motion for recon
Review of email correspondence between all
parties
Review of Email correspondence between JL
and NS re: John Eterno
Review of Email correspondence between JN
and NS re: John Eterno
Review of reply memo for AS
Review of City Defendants reply affirmations
recon motions
Schoolcraft team meeting
Phone call with JN & JF regarding issues to
discuss at meeting today with rest of trial team
Follow up email Schoolcraft team re trial docs

37

0.40
0.25

GMC
GMC

0.25

GMC

0.50
0.80

GMC
GMC

0.25

GMC

0.10

GMC

0.10

GMC

0.10

GMC

0.10
0.25

GMC
GMC

0.75

GMC

0.10

GMC

0.10

GMC

0.10

GMC

0.10
0.30

GMC
GMC

0.10

GMC

0.25

GMC

0.10
0.75

GMC
GMC

0.50
2.90

GMC
GMC

0.50
0.30

GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

July 27, 2015
July 27, 2015
July 28, 2015
July 29, 2015

July 30, 2015
July 30, 2015
July 30, 2015
July 31, 2015
August 3, 2015
August 3, 2015
August 3, 2015
August 4, 2015
August 4, 2015
August 5, 2015
August 7, 2015
August 7, 2015
August 9, 2015
August 10, 2015
August 11, 2015
August 11, 2015
August 11, 2015
August 12, 2015
August 12, 2015
August 13, 2015
August 13, 2015
August 13, 2015
August 14, 2015
August 14, 2015
August 14, 2015
August 14, 2015
August 18, 2015
August 21, 2015
August 21, 2015

Email JN re Polanco as witness
Email w MS re: master exhibit list
Review of updated jury instructions
Emails with Schoolcraft team re: settlement
Phone call JN regarding settlement position &
response to City's settlement position and
response to City's settlement overtures
Phone call w/JN and NS re settlement
Emails with Schoolcraft team re: settlement
Emails with Schoolcraft team re: settlement
Review and revise Gough cross
Review and revise Duncan cross
Email w/NS re Gough deposition
Phone call w/JN re: witness list and exhibit list
Review of NS revised witness and exhibit list
Phone calls with JN and NS re: exhibit and
witness list
Phone call with JN, JL & NS regarding multiple
issues in defendants'respective JPTO's
Review of Bernier and Isakov proposed JPTO
sections
Review of email correspondence re: JPTO and
motion deadlines
Review of email correspondence re: JPTO and
motion deadlines
Draft Yeager examination - review records, listen
to audio and work of transcription
Review of City defendants JPTO
Review of new discovery served by City
Add to and revise Yeager examination
Update and revise Gough examination
Reviewed and updated Sawyer examination
Update and revise James cross examination
Review of correspondence all parties re: JPTO
Review and update cross examination drafts to
date and emailed all to team
Review of Lauterborn transcribed audio
interview and emailed to team
Review of City's email re JPTO
Email re: City filing JPTO without our input
Phone call and email w/JN re Huffman
Sent updated crosses to team
Email all parties re MIL due date

38

0.10
0.10
0.40
0.10

GMC
GMC
GMC
GMC

0.40
0.40
0.10
0.10
3.30
2.75
0.10
0.40
0.30

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

1.00

GMC

1.00

GMC

0.50

GMC

0.10

GMC

0.10

GMC

2.40
0.75
0.25
3.40
2.50
3.75
2.90
0.10

GMC
GMC
GMC
GMC
GMC
GMC
GMC
GMC

4.80

GMC

0.60
0.25
0.10
0.30
0.25
0.10

GMC
GMC
GMC
GMC
GMC
GMC

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

August 22, 2015

September 15, 2015
September 16, 2015
September 16, 2015
September 16, 2015

Updated AS examination and sent to team
Reviewed JN cross outlines and updated witness
examinations
Drafted points to discuss w/JN
Review of NS email re upstate visits to AS
Received JN cross examinations
Reviewed JN cross outlines and updated my own
witness examinations
Drafted points to discuss w/JN
Reviewed JN cross outlines and updated my own
witness examinations
Review of JF MIL with additional points
Reviewed JN cross outlines and updated my own
witness examinations
Drafted points to discuss w/JN
Review of City letter re: JPTO schedule
Update and revise Schoolraft direct examination
Phone call with Adrian Schoolcraft re: trial
Phone call with JN & JF recapping discussion
with defense counsel and clients over the
weekend
Phone call with NS, JF and JN regarding best
strategy for handlng settlement discussions with
the City
Phone call w/JN re Schoolcrafts
Review and update Valenti deposition
Update Huffman cross examination
Review of email time line from Schoolcraft
Phone calls with NS and JN re City settlement
offer
Email w/JN re Schoolcraft timeline
Reviewed JN cross outlines and updated my own
witness examinations
Review of NS cross examination outlines
Phone call w/Schoolcraft re settlement
Review of new Rule 68 offer

September 16, 2015
September 16, 2015
September 16, 2015

Review of NS memo to Schoolcraft re settlement
Email w NS re memo and settlement
Review of NS email to Schoolcraft re settlement

August 24, 2015
August 24, 2015
August 24, 2015
August 24, 2015
August 26, 2015
August 26, 2015
August 27, 2015
August 31, 2015
September 1, 2015
September 2, 2015
September 3, 2015
September 8, 2015
September 8, 2015

September 8, 2015

September 8, 2015
September 8, 2015
September 9, 2015
September 10, 2015
September 11, 2015
September 11, 2015
September 11, 2015

TOTAL HOURS

2.90

GMC

1.75
0.40
0.25
0.10

GMC
GMC
GMC
GMC

3.30
0.75

GMC
GMC

2.50
0.50

GMC
GMC

2.80
1.40
0.25
3.40
0.75

GMC
GMC
GMC
GMC
GMC

0.60

GMC

0.60
0.30
1.25
2.75
0.90

GMC
GMC
GMC
GMC
GMC

0.80
0.10

GMC
GMC

2.30
3.60
0.80
0.50

GMC
GMC
GMC
GMC

0.30
0.25
0.10

GMC
GMC
GMC

806.70

39

SCHOOLCRAFT v. COTY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Gerald M. Cohen, Cohen & Fitch LLP

TOTAL BILL

806.70 x $500.00

$403,350.00

40

12:35 PM

Cohen and Fitch LLP

12/16/15

Custom Transaction Detail Report
May 1 through September 16, 2015

Cash Basis
Type
May 1 - Sep 16, 15
Check
May 1 - Sep 16, 15

Date
6/22/2015

Name
Schoolcraft, Adrian

Memo
Veritext Transcription Fees

Account
Advanced Client Costs

Original Amount
3,800.87

Paid Amount
3,800.87
3,800.87

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