Schoolcraft v. The City Of New York et al

Filing 644

MOTION for Reconsideration . Document filed by Adrian Schoolcraft. (Attachments: # 1 Affidavit, # 2 Exhibit Exh. 1 - Chart of Hours, # 3 Exhibit Exh. 2 - Expert Report Excerpts, # 4 Exhibit Exh. 3 - City Proposed Rates Chart)(Smith, Nathaniel)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,

10-cv-6005 (RWS)

Plaintiff,
AFFIRMATION OF
NATHANIEL B. SMITH IN
SUPPORT OF PLAINTIFF’S
APPLICATION FOR
RECONSIDERATION
-vCITY OF NEW YORK, et al.,
Defendants.
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Nathaniel B. Smith, being an attorney admitted to practice law in this State and
before this Court, hereby states and declares under the penalties of perjury that the
foregoing is true and correct.
1. As one of the attorneys for the plaintiff in the above-referenced action, I
am submitting this affirmation in support of the plaintiff’s application for
reconsideration.
2. For the two-year period from February 1, 2013 through January 31,
2015, I billed 1,775.60 hours, and from February 1, 2015 through September 16,
2015, I billed 470.40 hours in this action. John Lenoir billed 937 hours for that same
two-year period and 324 hours for the second period. Magdalena Bauza billed
1,011.22 hours for the two-year period and 294.42 for the second period. Howard

Suckle billed 107.65 hours during the two-year period and 1.25 hours for the second.
James McCutcheon billed all of his 23.38 hours within the two-year period. These
calculations are based on the time records we previously submitted to the Court and
these calculations reflect the period of time when the Smith Team was working
exclusively on this action and the period of time when we were working with the
Norinsberg Team. See Dkt. Nos. 560-9, 560-12, 560-13 & 560-14 (Smith Team
time records).
3. Attached hereto as Exhibit 1 is a chart reflecting the hours spent by each
Smith Team attorney for the two periods of time from February 1, 2013 through
January 31, 2015 and from February 1, 2015 through September 16, 2016.
4. Attached as Exhibit 2 are excerpts of the expert report submitted by the City
in opposition to the fee motion.
5. Attached as Exhibit 3 is City Opposition Exhibit DD, which was also
submitted by the City in opposing the fee motion.
Dated: September 16, 2016
s/NBS
________________________
NATHANIEL B. SMITH
Attorneys for Plaintiff
100 Wall Street – 23rd Floor
New York, New York 10006
[phone]
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