Citizens For Community Values, Inc v. Upper Arlington Public Library Board of Trustees

Filing 30

AFFIDAVIT re 26 Brief in Support of Plaintiff's Motion for Attorneys' Fees and Non-Taxable Expenses - David R. Langdon by Plaintiff Citizens For Community Values, Inc. (Attachments: # 1 Exhibit A) (Langdon, David)

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Citizens For Community Values, Inc v. Upper Arlington Public Library Board of Trustees Doc. 30 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION CITIZENS FOR COMMUNITY VALUES, INC., Plaintiff, vs. UPPER ARLINGTON PUBLIC LIBRARY BOARD OF TRUSTEES, Defendant. : : : : : : : : : : : Case No. 2:08-cv-00223-GCS-NMK Judge George C. Smith Magistrate Judge Norah McCann King DECLARATION OF DAVID R. LANGDON IN SUPPORT OF PLAINTIFF'S MOTION FOR ATTORNEYS FEES AND NON-TAXABLE COSTS Pursuant to 28 U.S.C. 1746, I, David R. Langdon, Esq., declare the following: 1. 2. The matters declared herein are based upon my own personal knowledge. I am the founder and President of the law firm of LANGDON LAW LLC, formerly known as LANGDON & HARTMAN LLC. I have served as Plaintiff's general counsel for the past 9 years. My firm is co-counsel for Plaintiff in the captioned matter with the ALLIANCE DEFENSE FUND. 3. This Declaration is filed to demonstrate the reasonableness of the total number of hours incurred by my firm on behalf of Plaintiff in this matter. 4. My participation in the captioned case included researching and drafting pleadings, motions, memoranda, discovery-related documents and correspondence, as well as working on Plaintiff's fee application. . 5. As reflected on the attached timesheet, I personally spent a total of 59.4 hours in furtherance of the excellent results obtained in this litigation on behalf of our client. My timesheet is based on contemporaneous time records that I kept as I worked on each task. However, after reviewing my timesheet and coordinating with my co-counsel as part of my firm's regular practice of exercising billing judgment (to attempt to ensure that we do not overbill our clients for administrative tasks, excessive research or drafting, or duplicative work), I have omitted from my timesheet 6.5 hours worth of work performed, and reduced the total number of hours for which my firm seeks compensation to 52.9 hours. 6. When multiplied by my hourly rate of $285.00, the total amount of attorney fees for which I personally seek recovery is $15,076.50. A true and accurate copy of my timesheet is attached as Exhibit A and made a part hereof. 7. In addition to attorney fees, our firm has incurred out-of-pocket litigation expenses in the amount of $144.46. (See Exhibit A.) Our firm charges $.20 for all copies. Our firm pays a flat rate for computerized legal research through Lexis, and regularly invoices our clients for usage based on the proportionate amount of time utilized on a particular case or matter per month. All of the litigation expenses for which my firm seeks reimbursement are expenses that we normally bill to our clients, and are not a part of our firm overhead. I declare under penalty of perjury that the foregoing is true and correct. 2 Executed this 25th day of September, 2008. /s/ David R. Langdon David R. Langdon (0067046) LANGDON LAW LLC 11175 Reading Road, Ste. 104 Cincinnati, Ohio 45241 Telephone: (513) 733-1038 Facsimile: (513) 577-7383 Email: 3

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