Schoolcraft v. The City Of New York et al

Filing 662

DECLARATION of Alan H. Scheiner in Opposition re: 641 MOTION for Reconsideration re; 638 Memorandum & Opinion,,,, THE COURTS ORDER ON ATTORNEYS FEES.. Document filed by The City Of New York. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C)(Scheiner, Alan)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,
Plaintiff,
-againstTHE CITY OF NEW YORK, et al.,

10-CV-6005 (RWS)
DECLARATION OF
ALAN H. SCHEINER IN
SUPPORT OF THE CITY’S
OPPOSITION TO
PLAINTIF’S MOTION FOR
RECONSIDERATION OF
THE COURT’S FEE AWARD

Defendants.
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I, ALAN H. SCHEINER, declare pursuant to 28 U.S.C. § 1746, under penalty of
perjury, that the following is true and correct:
1. I am a Senior Counsel in the office of Zachary W. Carter, Corporation Counsel
of the City of New York, attorney for the motion-respondent the City of New York (the “City”).
As such, I am familiar with the facts stated below and submit this declaration to place on the
record the relevant facts and documents in support of City’s opposition to plaintiff’s motion for
reconsideration of the Court’s fee award.
2. Exhibit A to this Declaration is a recent printout of the “Shepard’s” results for
Arbor Hill Concerned Citizens Neighborhood Ass’n v. Cnty. of Albany, 522 F.3d 182 (2d Cir.
2008).
3. Exhibit B to this Declaration is a compilation of the time entries that
Accountability Services, Inc. (“ASI”) identified as general or non-specific time entries in
connection with depositions.
4. Exhibit C to this Declaration is a compilation of the time entries identified by
ASI as being in connection with the specific depositions listed in the Audit Report.

5. The time entries in Exhibits B and C are in the same form and format as the
time entries in Exhibit A to the City’s Opposition to Plaintiff’s Motion for Fees (Docket No. 6002).
Dated: New York, New York
October 21, 2016
ZACHARY W. CARTER
Corporation Counsel of the
City of New York
Attorney for City Defendants
100 Church Street, Room 3-174
New York, New York 10007
[phone]
By:

cc:

All counsel by ECF

2

/s/ Alan H. Scheiner___________
Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division