Schoolcraft v. The City Of New York et al
Filing
575
AFFIRMATION of Peter J. Gleason in Support re: 570 FINAL MOTION for Attorney Fees Declaration of Peter J. Gleason In Support of Attorneys Fee application for Levine & Gilbert and Peter J. Gleason, Esq... Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit Peter Gleason time records, # 2 Exhibit investigator's time records, # 3 Exhibit proof of disbursements)(Gilbert, Richard)
EXHIBIT A
Peter
J.
Gleason
PC
115
Christopher
Street
Suite
2
New
York,
NY
10014
DATE
11/16/12
11/18/12
11/19/12
11/19/12
11/19/12
11/20/12
11/20/12
11/22/12
SCHOOLCRAFT
v.
CITY
OF
NEW
YORK
ITEMIZED
SERVICES
DESCRIPTION
Hrs/Rate
AMOUNT
Meeting
with
my
colleague
Richard
Gilbert,
Esq.
(RG),
6
hrs/
Retired
NYPD
2nd
grade
Detective
(D2)
and
Larry
$500
Schoolcraft
(LS)
to
discuss
Adrian
Schoolcraft’s
(AS)
claim
against
the
City
of
New
York.
Travel
to
and
from
NYC
Office
to
Catskill,
NY.
Upon
8
hrs/
Return
to
NYC
Office
review
of
documents
provided
$250
by
LS.
(Travel
at
½
hr.
rate)
Internet
review
of
news
articles
relating
to
AS.
5.5hrs.
$500
Meeting
with
RG
to
discuss
news
articles
and
our
1.5hrs.
strategy
to
follow
up
with
AS
and
LS.
$500
$3,000
Meeting
with
RG,
and
follow
phone
conversation
with
AS
to
discuss
strategy
of
case,
drafting
of
the
retainer
and
setting
up
next
meeting
with
AS.
1.5hrs.
$500
$750
Phone
conv.
with
Nathaniel
Smith,
Esq.
(NS)
to
discuss
.5hrs
potentially
working
on
this
matter.
$500
$250
Meeting
with
investigator
Vincent
Parco
(VP)
regarding
working
on
this
matter.
Gave
VP
an
over-‐
view
of
the
matter
and
the
scope
of
work
of
which
he
would
perform
at
a
rate
of
$150
per
hr.
2hrs.
$500
$1,000
Phone
conv.
with
D2,
regarding
his
insight
into
one
of
the
named
defendants.
.25hrs
$500
$125
Multiple
phone
conversation
with
RG,
AS,
and
LS
regarding
setting
up
a
meeting
the
following
day.
.75hrs.
$500
$375
$2,000
$2,750
$750
11/23/12
11/26/12
11/27/12
11/27/12
11/27/12
11/28/12
11/29/12
11/29/12
11/30/12
11/30/12
12/1/12
12/1/12
12/2/12
Meeting
with
AS,
LS,
RG
in
Albany
to
discuss
strategy
scope
of
work,
investigations
needed.
Travel
to
and
from
NYC
.
(Travel
at
½
hr.
rate)
Meeting
with
RG
regarding
obtaining
and
scheduling
picking
up
Schoolcraft
file
from
prior
counsel.
4hrs.
/
$500
$2,000
8
hrs/
$250
.25hrs.
$500
$2,000
E-‐mail
from
RG
and
follow
up
phone
conversation
with
RG
regarding
the
Schoolcraft
file.
.25hrs
$500
$125
E-‐mail
from
AS
regarding
the
preferred
method
of
communications.
.125hrs
$500
$62.50
$125
Meeting
with
VP
regarding
update
on
his
investigation
1.5hr.
$500
$750
Phone
conv.
with
AS
regarding
Nov.
12,
2012
news
report
and
possible
sources
of
media
leaks.
1.5hrs.
$500
$750
Phone
conv.
with
AS
regarding
status
of
obtaining
his
file
from
previous
counsel
and
strategy
moving
forward.
.75hr.
$500
$375
Phone
conv.
with
RG
for
update
on
obtaining
file.
.25hr.
$500
$125
Phone
conv.
with
RG
discussing
strategy
and
focus
on
the
investigation
of
the
named
defendants
1hr.
$500
$500
Meeting
with
D2,
to
discuss
Schoolcraft
matter
and
backgrounds
of
named
defendants.
2.5hrs.
$500
$1,250
Phone
conv.
with
VP
regarding
meeting
of
previous
night.
.5hr.
$500
$250
Phone
conv.
with
AS
regarding
update
of
the
investigations.
.75hr.
$500
$375
.5hr.
$500
$250
Phone
conv.
with
RG
regarding
correspondence
to
and
conversation
with
AS’s
previous
counsel.
12/2/12
12/3/12
12/3/12
12/3/12
12/4/12
12/5/12
12/5/12
12/5/12
12/6/12
12/6/12
12/6/12
12/7/12
12/7/12
12/9/12
Phone
conv.
with
AS
regarding
status
of
investigations.
.5hr.
$500
$250
Phone
conv.
with
RG
regarding
e-‐mail
from
AS’s
previous
counsel.
.25hr.
$500
$125
Phone
conv.
with
AS
regarding
e-‐mail
from
his
.5hr.
previous
counsel,
investigation
and
setting
up
another
$500
meeting.
$250
Phone
conv.
with
VP
regarding
investigation.
.125hr.
$500
$62.50
Phone
conv.
with
AS
regarding
all
aspects
of
his
representation.
.75hr.
$500
$375
E-‐mail
and
phone
conversation
with
AS
regarding
Frank
Serpico
(FS)
and
his
assistance
through
support
and
institutional
knowledge
of
the
NYPD.
Phone
conv.
with
VP
with
an
update
on
one
of
the
targets
of
the
investigation.
.75hr.
$500
$375
.5hr.
$500
$250
E-‐mail
from
AS
regarding
previous
counsel,
phone
conv.
with
RG
and
AS
1.25hr.
$500
$625
Phone
conv.
with
RG
with
update
regarding
VP
investigation,
memo
to
file.
1.25hr.
$500
$625
Phone
conv.
with
AS
regarding
investigation
.75hr.
$500
$375
Legal
research,
re:
Civil
Service
Law,
NYPD
employment
rights.
2.25hr.
$500
$1,125
Meeting
with
RG,
re:
strategy
NYPD
employment
issue,
disciplinary
charges.
1hr.
$500
$500
Phone
conv.
with
AS
re:
NYPD
employment
issues
.75hr.
$500
$375
Phone
conv.
with
VP,
re:
update
on
investigation
of
named
defendants.
.125hr.
$500
$62.50
12/9/12
12/10/12
12/10/12
12/10/12
12/11/12
12/12/12
12/12/12
12/13/12
12/13/12
12/13/12
12/13/12
Phone
conv.
with
FS,
re:
his
overview
of
the
matter
and
scheduling
a
time
to
meet
to
discuss
same
in
person
.25hr.
$500
$125
E-‐mail
and
follow
up
phone
conv.
with
RG,
re:
follow
up
with
AS’s
prior
counsel.
.5hr.
$500
$250
Phone
conv.
with
FS
to
set
up
the
following
days
meeting
with
FS,
AS,
LS.
.125hr.
$500
$62.50
Meeting
with
VP,
re:
update
on
named
defendant’s
investigation.
1.25hr.
$500
$625
Meeting
in
Albany
with
AS,
LS,
FS.
Re:
Status
of
investigations,
NYPD
employment
issues,
concerns
regarding
Queens
DA,
concerns
regarding
Jamaica
Hospital
and
concerns
regarding
FDNY
EMS
Follow
up
conv.
with
RG
upon
return
to
NYC
office,
memo
to
file.
(Travel
at
½
hr.
rate)
6hrs.
$500
$3,000
8hrs
$250
$2,000
1
Police
Plaza,
to
discuss
Schoolcraft
matter
with
NYPD
Department
Advocate’s
Office.
1.5hr.
$500
$750
Meeting
with
FS’s
attorney
to
discuss
FS
involvement
in
the
Schoolcraft
matter.
4hr.
$500
$2,000
Follow
up
e-‐mail
to
FS’s
attorney
.125hr.
$500
$62.50
E-‐mail
from
AS
containing
review
/
discussion
of
12/4/12
Press
Release
from
QCDA
with
the
conclusion
that
there
was
no
criminality
in
the
manner
that
Plaintiff
was
taken
from
his
home
and
placed
in
a
psychiatric
facility.
Extensive
Follow
up
phone
conv.
with
AS
and
RG.
4.5hr.
$500
$2,250
Phone
conv.
with
FS
re:
Queens
DA
press
release.
.5hr.
$500
$250
Meeting
with
VP,
Re:
Investigation
1.5hr.
$500
$750
12/14/12
12/14/12
12/14/12
12/14/12
12/15/12
12/15/12
12/16/12
12/16/12
12/17/12
12/17/12
12/17/12
12/17/12
E-‐mail
to
NYPD
Asst.
Comm.
Kearns,
re:
Schoolcraft
NYPD
employment
issues.
.125hr.
$500
$62.50
9
Metro
Tech
re:
FDNY
EMS
report
for
AS
and
(Travel
at
½
hr.
rate)
$375
.75hr.
$500
.75hr.
$250
.5hr.
$500
$250
.125hr.
$500
$62.50
Phone
conv.
With
RG,
re:
1PP’s
position
on
AS.
E-‐mail
to
NYPD
Asst.
Comm.
Kearns,
re:
Schoolcraft
NYPD
employment
issues.
$187.5
Phone
conv.
With
FS,
re,
his
conversation
with
1.5hr.
first
hand
witnesses
to
the
manner
in
which
the
NYPD
$500
maintains
crime
stats
and
subsequent
memo
to
file.
$750
Legal
research,
re:
prosecutorial
misconduct
as
a
bar
to
overcome
immunity.
2.25hrs.
$500
$1,125
E-‐mail
from
FS’s
atty.
.125hr.
$500
$62.50
1.75hrs.
$500
$875
E-‐mail
to
NYPD
Asst.
Comm.
Kearns,
re:
Schoolcraft
NYPD
employment
issues.
.125hr.
$500
$62.50
Meeting
with
VP
re:
investigation
update.
1.25hr.
$500
$625
Meeting
with
RG,
Re:
procuring
file
from
previous
counsel,
NYPD
employment
issues,
status
of
investigation.
2hr.
$500
$1,000
Phone
conv.
with
FS,
follow
up
on
conv.
of
12/15/12
.5hr.
$500
$250
Legal
research,
re:
NYS
PL
kidnapping.
12/18/12
12/19/12
12/20/12
12/20/12
12/21/12
12/21/12
12/21/12
12/22/12
12/22/12
Meeting
with
RG
to
facilitate
picking
up
file
from
previous
counsel,
picked
up
file
(6+
banker
boxes)
from
previous
counsel
with
RG
and
initial
cursory
review
of
once
secured
in
office.
6hr.
$500
Albany
meeting
with
D2
and
AS.
Updated
AS
as
to
status
of
his
claims.
Discussed
with
AS
means
for
providing
AS
and
LS
the
ability
to
communicate
with
his
attorneys.
(Travel
at
½
hr.
rate)
7hrs.
$500
8hrs.
$3,000
$3,500
$1500
Expenses:
Provided
AS
with
Apple
laptop,
printer/scanner
and
two
iPhones.
Set
up
Verizon
cell
phone
service
for
two
iphones
for
12
month
contract
at
$114.97
per
line
per
month.
$1718
$108
$900
$2,759
expenses
E-‐mail
and
phone
conv.
with
Professor
from
John
Jay
College.
1.25hrs.
$500
$625
Phone
conv.
with
John
Lenoir,
Esq.
(JL)
discussing
his
potential
involvement
in
the
Schoolcraft
matter
.75hrs.
$500
$375
Phone
conv.
with
AS
regarding,
status,
strategy,
contents
of
file
and
investigation
status.
.75hrs.
$500
$375
Meeting
with
VP
regarding
investigation
on
one
of
the
named
defendants.
1.5hrs.
$500
$750
Organize
and
review
case
files.
2.5hrs.
$500
$1,250
E-‐mail
to
RG,
re,
amended
complaint
.125hrs.
$500
$62.50
Phone
conv.
with
FS,
re:
complaint
.25hrs.
$500
$125
12/23/12
12/23/12
12/23/12
12/24/12
12/26/12
12/26/12
12/27/12
12/28/12
12/31/12
1/2/13
1/2/13
1/2/13
Review
of
amended
complaint,
memo
to
file.
1.5hrs.
$500
$750
Phone
conv.
with
AS,
re
update
on
Queens
DA
.5hrs.
$500
$250
E-‐mail
correspondence
and
phone
conv.
with
JL
Re:
Queens
DA’s
investigation
of
the
Schoolcraft
matter.
.75hrs.
$500
$375
Draft
and
hand
deliver
a
notice
of
appearance
that
NYPD
Asst.
Comm.
Kearns
demanded
before
she
would
communicate
with
my
office
regarding
AS.
2hrs.
$500
$1,000
E-‐mail
to
and
from
from
NYPD
Asst.
Comm.
Kearns.
.25hrs.
$500
$125
E-‐mail
and
follow
up
phone
conversation
with
Prof.
from
John
Jay
College.
.5hrs.
$500
$250
Review
of
part
of
Schoolcraft
file:
Partial
review
of
“Attorney’s
eyes
only”
File.
Phone
call
from
D2,
re:
Information
on
Schoolcraft
matter.
3.5hrs.
$500
$1,750
.125hrs.
$500
$62.50
E-‐mail
from
and
follow
up
conversation
with
JL,
Re:
his
potential
involvement
in
the
Schoolcraft
matter,
Queens
DA’s
investigation,
scheduling
a
time
we
can
meet.
1.5hrs
$500
$750
Phone
conv.
with
LS,
re:
Update
on
matter.
.25hrs.
$500
$125
E-‐mails
back
and
forth
to
JL
re:
meeting.
.25hrs.
$500
$125
3.25hrs.
$500
$1,625
Meeting
at
law
office
of
Levine
&
Gilbert
and
continued
review
of
“Attorney’s
eyes
Only,”
file.
1/3/13
1/3/13
1/4/13
1/4/13
1/5/13
1/6/13
1/7/13
1/8/13
Meeting
with
JL,
Re:
Queens
DA,
the
amended
complaint,
and
aspects
of
the
Schoolcraft
file.
2.5hrs.
$500
$1,250
Several
phone
calls
with
LS,
Re:
update
.75hrs.
$500
$375
Meeting
with
RG
and
continued
review
of
File.
4.25hrs.
$500
$2,125
E-‐mail
and
phone
conv.
with
PBA
counsel,
Re:
Union’s
.5hrs.
position
on
Schoolcraft
matter.
$500
$250
Continued
review
of
the
file
4.5hrs.
$500
$2,250
Completion
of
review
of
file
from
previous
counsel,
Memo
to
file.
6.5hrs.
$500
$3,250
Meeting
with
VP,
Re:
update
on
investigation.
1.5hrs.
$500
$750
3.5hrs.
$500
$1,750
1/8/13
1/9/13
1/9/13
1/10/13
1/10/13
Meeting
with
RG
to
review
and
discuss
the
review
of
the
parts
of
the
file
reviewed
by
Levine
&
Gilbert
and
by
PG.
Phone
conv.
with
AS,
Re;
update
as
to
complete
review
.75hrs
of
file
(excluding
review
of
recordings)
and
discussion
$500
on
need
for
investigator
to
verify
identity
of
certain
individuals
who
were
present
at
the,
“home
invasion.”
$375
Phone
conv.
with
LS,
Re:
status
of
case.
.5hrs
$500
$250
.75hrs
$500
$375
E-‐mail,
fax
and
phone
conv.
with
PBA
legal
counsel.
1.25hrs.
$500
$625
Multiple
phone
conv.
and
e-‐mails
back
and
forth
with
AS,
re:
PBA
and
AS’s
recordings.
2.5hrs.
$500
$1,250
Meeting
with
RG
Re:
investigation
strategy.
1/11/13
1/11/13
1/12/13
1/12/13
1/13/13
1/13/13
1/14/13
1/14/13
1/15/13
1/16/13
1/17/13
1/18/13
1/19/13
1/19/13
Meeting
with
RG,
re:
PBA
matter.
.75hrs.
$500
$375
.75hrs.
$500
$375
Phone
conv.
with
JL,
re:
viability
of
DOJ
involvement.
.5hrs.
$500
$250
Phone
conv.
with
NS
re:
updating
him
on
veracity
of
matter.
.75hrs.
$500
$375
E-‐mail
to
Pat
Lynch,
PBA
President.
.125hrs.
$500
$62.50
Multiple
e-‐mails
from
AS
and
follow
up
phone
conv.
with
AS.
Re:
PBA,
NYPD,
employment
status
and
investigation.
3.25hrs.
$500
$1,625
E-‐mail
from
JL,
Re:
Schoolcraft
matter.
.125hrs.
$500
$62.50
Meeting
with
RG,
re:
Queens
DA.
.75hrs.
$500
$375
Phone
conv.
with
AS
re:
Queens
DA.
.5hrs
$500
$250
Phone
conv.
with
VP
re:
update,
meeting
to
follow.
.125hrs.
$500
$62.50
Meeting
with
VP,
re:
“Home
Invasion,”
participants.
.75hrs.
$500
$375
E-‐mail
to
PBA.
re:
their
assistance
in
the
matter.
.125hrs.
$500
$62.50
Several
e-‐mails
back
and
forth
with
RG,
re:
draft
letter
to
NYPD.
.5hrs.
$500
$250
Review
of
Schoolcraft
audio
recordings,
notes
to
file.
4.75hrs.
$500
$2,375
Meeting
with
VP,
re:
individuals
present
at,
“Home
invasion.”
1/20/13
1/21/13
1/21/13
1/21/13
1/22/13
1/22/13
1/23/13
1/23/13
1/25/13
1/25/13
1/26/13
1/28/13
1/29/13
1/29/13
Continued
review
of
Schoolcraft
recordings,
notes
to
file.
4.5hrs.
$500
$2,250
Phone
conv.
with
FS,
re:
NYPD’s
handling
of
Schoolcraft
matter.
.75hrs.
$500
$375
Phone
conv.
with
NS,
re:
the
status
of
the
Schoolcraft
matter.
.75hrs.
$500
$375
E-‐mail
to
and
from
RG,
re:
NYPD
letter.
.25hrs.
$500
$125
Phone
conv.
with
AS,
re,
NYPD
issues,
scheduling
his
travel
to
meet
with
counsel
in
NYC,
update
on
progress
of
investigation.
2.25hrs.
$500
$1,125
Meeting
with
RG,
Re:
NYPD
letter.
1.25hrs.
$500
$625
Phone
conv.
with
RG,
Re:
NYPD
letter
.125hrs.
$500
$62.50
E-‐mail
to
NYPD
Asst.
Comm.
Kearns,
re:
Schoolcraft
position
on
employment
matter.
.125hrs.
$500
$62.50
E-‐mail
from
NYPD
Asst.
Comm.
Kearns,
outlining
her
position/demand
that
she
will
not
accept
e-‐mail
correspondence
regarding
this
matter.
.125hrs.
$500
$62.50
Meeting
with
RG
to
discuss
NYPD’s
refusal
to
acknowledge
e-‐mail
communications.
.5hrs.
$500
$250
Phone
conv.
with
LS,
re:
status
update.
.5hrs.
$500
$250
Edit
and
hand
deliver
letter
to
NYPD
Asst.
Comm.
Kearns.
2hrs.
$500
$1,750
Meeting
with
VP,
re:
update
on
investigation.
1.25hrs.
$500
$625
.5hrs.
$500
$250
E-‐mail
from
Center
for
Constitutional
Rights
(CCR)
review
of
enclosed
affidavit.
1/29/13
1/30/13
2/1/12
2/1/12
2/2/13
2/3/13
2/4/13
2/5/13
2/5/13
2/7/13
2/8/13
2/8/13
Meeting
with
RG,
FS
atty.
1.5hrs.
$500
$750
Phone
conv.
with
AS,
update.
.25hrs.
$500
$125
E-‐mail
from
RG,
re:
e-‐mail
from
CCR.
scheduling
a
phone
conv.
this
date.
.125hrs.
$500
$62.50
Phone
conv.
with
CCR,
re:
Schoolcraft
affidavit
.75hrs.
$500
$375
E-‐mail
from
AS
and
review
of
documents
attached,
re:
NYPD
mediation.
.75hrs.
$500
$375
Phone
conv.
with
NS,
re:
decision.
.75hrs.
$500
$375
Phone
conv.
with
AS,
re:
travel
to
NYC
on
2/7/13,
e-‐mail
AS,
round
trip
Amtrak
tickets
for
AS
&
LS.
.5hrs.
$500
$250
E-‐mail
from
AS
re:
Authorization,
print
out
and
distribute
same.
.25hrs.
$500
$125
E-‐mail
to
NYPD
Asst.
Comm.
Kearns.
.125hrs.
$500
$62.50
Meeting
with
AS,
NS,
&
JL,
re:
adding
lawyers
to
the
legal
team.
2.5hrs.
$500
$1,250
E-‐mail
from,
Elisha
B.
Barron
Law
Clerk
to
the
Hon.
Shira
A.
Scheindlin,
re:
Deposition.
Phone
conv.
with
NS,
re:
joining
legal
team.
.125hrs.
$500
$62.50
.5hrs.
$500
$250
2/9/13
2/10/13
2/11/13
2/11/13
2/11/13
2/11/13
2/12/13
2/13/13
2/14/13
2/15/13
E-‐mail
and
phone
conv.
with
AS
re:
upcoming
deposition
on
2/12/13,
purchase
train
ticket
1hrs.
$500
$500
E-‐mail
to
NS,
re:
deposition
.125hrs.
$500
$62.50
.125hrs.
$500
$62.50
.5hrs.
$500
$250
E-‐mail
from
RG,
re:
deposition/conf.
Phone
conv.
with
NS,
re:
Floyd
case.
Conf.
call
with
Elisha
B.
Barron
Law
Clerk
2hrs.
to
the
Hon.
Shira
A.
Scheindlin
re:
ground-‐rules
$500
for
tomorrow’s
deposition
and
follow
up
call
with
NS,
&
RG
Meeting
with
AS,
review
of
case,
discussion
of
4.5hrs
strategy
and
updated
AS
in
investigation,
Purchase
$500
of
business
attire
for
AS.
+$638
expense
Meetings
throughout
day
with
AS
in
NYC,
12hrs.
brought
him
up
to
speed
regarding
$500
aspects
of
his
claims.
Defended
his
deposition
in
the
Floyd
matter
before
MJ
Freeman.
Attended
public
meeting,
to
discuss
matter
with
Public
Advocate
DeBlasio.
Follow
up
meeting
with
AS.
Review
amended
discovery
plan.
$1,000
Meetings
with
AS,
meeting
with
RG
and
NS.
Meeting
with
VP,
review
of
file
with
AS.
$2,250
$6,000
7.5hrs.
$500
$3,750
Transport
file
from
Levine
&
Gilbert
to
Law
office
of
Nat
Smith.
Meeting
with
NS
to
discuss
how
file
is
formatted.
Meeting
with
AS
and
legal
team.
3.5hrs.
$500
$1,750
Phone
conv.
with
NS,
re:
NYS
CPL
&
file
.25hrs.
$500
$125
2/17/13
2/18/13
2/26/13
2/27/13
.25hrs.
$500
$125
E-‐mail
from
JL,
re:
internet
posting
pertaining
to
AS,
review
of
same.
.5hrs.
$500
$250
Meeting
with
NS,
JL.
Re:
Queens
DA
subpoena
.75hrs.
$500
$375
E-‐mail
to
legal
team,
re:
Sunday’s
meeting.
.125hrs.
$500
$62.50
E-‐mail
from
AS,
re:
Sunday’s
meeting.
.125hrs.
$500
$62.50
E-‐mail
from
RG,
re:
evidence
preservation.
.25hrs.
$500
$125
Review
of
e-‐mails
from
JL
&
NS,
re:
DOJ.
E-‐mail
to
NS
&
JL
re:
Agenda
for
Sunday’s
meeting.
.75hrs.
$500
$375
E-‐mail
to
Pub.
Advocate,
re:
follow
up
meeting.
.125hrs.
$500
$62.50
E-‐mails
to
JL
&
NS.
re:
update
from
JL.
.125hrs.
$500
$62.50
meeting
in
Saugerties
NY
with
NS,
JL
AS,
LS.
Travel
to
and
from
Saugerties
3.5hrs.
$500
8.5hrs
$250
$1,750
2/20/13
2/20/13
2/21/13
2/21/13
2/22/13
2/22/13
2/23/13
2/24/13
E-‐mail
correspondence
between
NS
&
JL,
re:
Queens
DA.
E-‐mail
from
Magdalena
Bauza
(MB),
re:
resume
and
her
interest
in
working
on
matter.
.125hrs.
$500
$62.50
Review
of
e-‐mail
from
Corp.
Counsel
containing
additional
“Attorney’s
eyes
only”
documents
and
discussion
with
RG
&
NS.
1.25hrs.
$500
$625
$2,125
2/27/13
2/27/13
2/28/13
2/28/13
2/28/13
2/28/13
3/1/13
3/1/13
3/4/13
3/4/13
3/4/13
3/5/13
3/5/13
3/5/13
Phone
conv.
with
NS,
re:
service
upon
5
defendants.
Travel
to
1PP
to
serve
summonses
after
law
dept.
refuses
to
accept.
2.25hrs.
$500
$1125
E-‐mail
from
MB,
re:
scheduling
a
meeting.
.125hrs.
$500
$62.50
Prepared
and
file
notice
of
appearance.
.25hrs.
$500
$125
Review
Deposition.
1.5hrs.
$500
$750
Review
ECF
notice.
.125hrs.
$500
$62.50
Queens
DA’s
office
to
serve
subpoena.
(travel)
2hrs.
$250
$500
E-‐mail
from
and
to
Brian
Lee,
Esq.
.25hrs.
$500
$125
ECF
notices.
.125hrs.
$500
$62.50
E-‐mails
back
and
forth
with
MB,
to
set
up
meeting
later
that
day.
.25hrs.
$500
$125
E-‐mail
with
enclosed
letter
from
Suzanna
Publicker,
Esq.,
review
of
same.
.25hrs.
$500
$125
E-‐mail
from
Brain
Lee,
Esq.,
re:
scheduling
order.
.25hrs.
$500
$125
E-‐mails
to
and
from
AS
re:
trip
to
city,
purchase
train
ticket.
.5hrs
$500
$250
E-‐mail
from
AS,
with
attachment
outlining
examples
of
.25hrs.
NYPD
retaliation.
$500
$125
Review
e-‐mail
from
Suzanna
Publicker,
Esq.
$62.50
.125hrs.
$500
3/6/13
3/6/13
3/7/13
3/9/13
3/8/13
3/10/13
3/11/13
3/13/13
3/14/13
3/14/13
3/15/13
3/16/13
3/18/13
3/18/13
E-‐mail
from
JL,
re:
DOJ
.125hrs.
$500
$62.50
Review
fax
from
Suzanna
Publicker,
Esq.
.25hrs.
$500
$125
Meeting
with
AS
&
NS
3.5hrs.
$500
$1,750
Meeting
with
NS
at
his
office,
re;
strategy/status.
3hrs.
$500
$1,500
ECF
notice,
re:
Court
order.
.125hrs.
$500
$62.50
E-‐mail
to
Council
Member
Williams
.25hrs.
$500
$125
E-‐mail
from
AS,
review
attachment
(transcription)
forward
same
to
NS.
.75hrs.
$500
$375
ECF
notice
and
review
of
same.
(letter
to
Judge
from
City.)
.5hrs
$500
$250
E-‐mail
from
NS,
re:
Queens
DA
.125hrs.
$500
$62.50
(3)
ECF
notices
and
review
of
same.
(Defendant’s
motion
to
Quash)
and
follow
up
discussion
with
NS
1.25hrs.
$500
$375
ECF
notice,
re:
Plaintiff
letter
to
Judge.
.125hrs.
$500
$67.50
E-‐mail
from
JL,
re:
Letter
to
DOJ
and
strategy.
.5hrs.
$500
$250
ECF
notice,
re:
Order
setting
date
for
hearing.
.125hrs.
$500
$67.50
E-‐mail
from
NS,
re:
edits
to
letter
to
DOJ.
.25hrs.
$500
$125
3/18/13
3/19/13
3/20/13
3/20/13
3/20/13
3/20/13
3/21/13
3/21/13
3/22/13
3/22/13
3/23/13
3/24/13
3/25/13
3/25/13
E-‐mail
from
JL,
re:
Schoolcraft
media
report.
.25hrs.
$500
$125
E-‐mail
from
NS,
re:
Home
invasion
recording.
.125hrs.
$500
$67.50
Phone
conv.
with
NS,
re:
correspondence.
.25hrs.
$500
$125
ECF
notice,
re:
amended
answer.
.50hrs.
$500
$250
E-‐mail
from
NS,
re:
final
draft
of
DOJ
letter.
.125hrs.
$500
$67.50
Phone
conv.
with
NS,
.25hrs.
$500
$125
E-‐mail
from
JL,
re:
Schoolcraft
tapes
in
WSJ.
.125hrs.
$500
$67.50
E-‐mail
from
JL,
re:
status
update.
.125hrs.
$500
$67.50
Monitor
Floyd
trial,
re:
named
defendant’s
testimony.
4hrs.
$500
$1,000
E-‐mail
from
NS
&
JL,
re:
Notice
to
Produce.
.25hrs.
$500
$125
E-‐mail
from
AS,
re:
recording
of
Lt.
Mascol.
.5hrs.
$500
$250
E-‐mail
from
NS,
re:
recording
of
Lt.
Mascol.
.125hrs.
$500
$67.50
E-‐mail
from
NS,
re:
Letter
from
Dept.
Advocates
Office
dated
April
5,
2011.
.25hrs.
$500
$125
E-‐mail
from
JL,
re:
Schoolcraft
Google
alert,
review
of
links.
.75hrs.
$500
$375
3/26/13
3/27/13
3/27/13
3/27/13
3/27/13
3/28/13
3/28/13
3/28/13
3/28/13
3/29/13
3/29/13
3/29/13
3/30/13
4/1/13
Phone
conv.
with
NS,
re:
motion.
.5hrs.
$500
$250
Meeting
with
NS,
MB,
re:
demonstrative
evidence
to
be
used
at
trial.
3.5hrs.
$500
$1,750
E-‐mail
from
NS,
re:
final
draft
of
reply.
.25hrs.
$500
$125
ECF
notice,
re:
Schoolcraft
declaration
.125hrs.
$500
$67.50
ECF
notice,
re:
Plaintiff’s
Memo
of
Law.
.125hrs.
$500
$67.50
E-‐mail
from
JL,
re:
next
meeting
upstate.
.125hrs.
$500
$67.50
E-‐mail
from
NS,
re:
Photos
of
Plaintiff’s
residence,
print
and
review
of
same.
.5hrs.
$500
$250
E-‐mail
from
JL,
re:
confirming
meeting
with
AS
.125hrs.
$500
$67.50
ECF
notice,
re:
Memo
of
Law.
.125hrs.
$500
$67.50
Phone
conv.
with
NS,
re:
gag
order.
.5hrs.
$500
$250
Meeting
with
VP,
re:
photos
and
update.
1.5hrs.
$500
$750
E-‐mail
from
NS,
re:
enclosed
letter
from
Hosp.
Defendant
to
Judge
concerning
press,
review
of
same
.5hrs.
$500
$250
Meeting
with
legal
team
at
NS
office,
re:
update
investigation,
Deft.
Ans.
To
amended
complaint.
1.25hrs.
$500
$750
E-‐mails
between
City,
Hosp.
&
Plaintiff,
re:
discovery
issues.
.5hrs
$500
$500
4/1/13
4/2/13
4/2/13
4/2/13
4/3/13
4/4/13
4/4/13
4/5/13
4/5/13
4/5/13
5/5/13
4/7/13
4/8/13
E-‐mail
from
sound
engineer
containing
filtered
home
invasion
tape,
review
of
same.
.75hrs.
$500
$375
Monitor
Floyd
trial,
re:
Mauriello
testimony.
3.5hrs.
$500
$1,750
ECF
notice,
re:
Hospital
letter
to
Judge
.125hrs.
$500
$67.50
Press
inquiry,
re:
AS
.125hrs.
$500
$67.50
.125hrs.
$500
$67.50
E-‐mail
to
and
from
Rae
Koshetz,
Esq.,
re:
NYPD
employment
issues.
.25hrs.
$500
$125
(2)
ECF
notices,
re:
City’s
motion
to
quash
.25hrs.
$500
$125
Review
Plaintiff’s
Opposition
to
City’s
motion
to
Quash,
e-‐mails
between
NS.
JL
re,
edits.
.75hrs.
$500
$750
ECF
notice,
re:
motion
to
quash.
.125hrs.
$500
$67.50
.125hrs.
$500
$67.50
E-‐mail
to
and
from
Rae
Koshetz,
Esq,
re:
scheduling
meeting.
.125hrs.
$500
$67.50
Meeting
in
Saugerties
with
AS,
LS
and
legal
team.
(Travel
at
½
hr.
rate)
6
hrs.
$3,000
$500
8
hrs/
$250
1.5hrs.
$500
$2,000
$750
E-‐mail
from
AS,
re:
NYPD
employment
issues.
E-‐mails
from/to
City/Hospital
re:
scheduled
conference
4/10/13.
Meeting
with
AS
&
NS,
re:
trial
prep.
4/8/13
4/9/13
4/9/13
4/10/13
4/10/13
4/11/13
4/12/13
ECF
notice,
re:
Hospital
filing
re
motion
to
quash
and
letter
motion
re
media.
.25hrs.
$500
$125
E-‐mail
with
invoice
from
sound
engineer.
.25hrs.
$125
Review
Google
alert,
Re:
AS
Court
Appearance,
and
subsq.
Meeting
with
legal
team.
.125hrs.
$500
$67.50
3.5hrs.
$500
$1,750
Letter
from
NYPD
Department
Advocates
Office,
review
of
same.
.25hrs.
$500
$125
Consultation
with
AS,
Meeting
with
legal
team
and
Rae
Kosheck,
Esq.,
Follow
up
e-‐mail
to
Rae
Kosheck,
Esq.,
re:
issues
discussed
at
meeting.
Draft
response
letter
to
NYPD
re:
letter
received
on
4/10/13.
Discussed
strategy
with
AS.
8hrs.
$500
$4,000
Consultation
with
AS
discussing
matter
purchased
return
ticket
to
Albany,
meeting
with
VP.
4.5hrs.
$500
$2250
.5hrs.
$500
$250
4/14/13
Phone
conv.
with
NS,
re:
status.
Total
of
285.125
Hrs.
@
$500
per
hour
$
142,562.50
Travel:
51.25
Hrs.
@
250
per
hour
$
12,812.50
+
expenses
$
6,123.00
+Investigation
$
3,581.25
Total
$
165,079.25
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