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)

EXHIBIT A

LANGDON LAW LLC Timesheet for David R. Langdon CCV v. Upper Arlington Public Library
Professional Services: Date 18-Feb 20-Feb 22-Feb Work Performed Meeting with David Miller regarding potential case against Library (.1) Meeting with David M. regarding Upper Arlington situation (.1) Correspond with Tim Chandler regarding UA and UT lawsuits (timing, etc.) (.2); telephone conference with Tim regarding same (.6); correspond with David M. regarding same and review denial letter from UA (.2) Meetings with David regarding library lawsuit (.2); review file and draft correspondence to Tim Chandler regarding same (.3) Review correspondence from Tim regarding draft of pleadings, etc. (.1); review Complaint (.8) Telephone conference with ADF counsel regarding case (.2); correspond with Tim (numerous) regarding timing of filing, phv motions, PI motion, etc. (.4)); several meetings with client (David) regarding complaint, timing of filing, etc. (.4); review and revise complaint (2.4); telephone conference with Barry (and David) regarding complaint (discussions with Library, etc.) (.1) Continue to review and revise complaint; correspond and telephone conference (.6) with Tim throughout the day regarding same (my proposed changes, EC claim, compensatory or just nominal damages, timing of filing, etc.); correspond with Doug Napier of ADF regarding review of complaint on behalf of ADF, etc.; correspond and telephone conferences with Jeff Shafer of ADF regarding complaint (Est. Cl. issues); meeting with David regarding complaint; correspond with Barry regarding complaint; dinner meeting with David and Doug (1.5) Review Shafer email regarding EC issues (.1); correspond with BMP regarding same (.1); telephone conference with Barry regarding complaint (correction) (.1); draft correspondence to Tim and KT and Doug regarding status of complaint, timing, etc. (.1); review correspondence in response to same (several) (.1); review correspondence from ADF media and review draft press release (.1) Correspond with Doug, et al., regarding complaint, timing of filing, etc. (.2); review and revise PI memorandum (1.5); correspond with Tim regarding same (multiple) (.3); meeting with David regarding timing of filing, etc. (.2) Correspond with Tim regarding complaint (.1); continue with final revisions to complaint, PI mtn/memo (2.9); correspond with Barry regarding complaint (.1) Draft final revisions to complaint and telephone conference with Barry regarding same (2.2); draft final revisions to PI motion and memo (1.1) Time 0.1 0.1

1.0 0.5 0.9

25-Feb 26-Feb 27-Feb

3.5

28-Feb

7.6

29-Feb

0.6

3-Mar

2.2

4-Mar

3.1 3.3

5-Mar

EXHIBIT A

6-Mar

Contemplate strategic issues for complaint and PI memo (religious speech/conduct distinction and religious meeting/service distinction) and correspond with Tim regarding same (1.8); meeting with David regarding same and status of complaint (.2); telephone conference with Tim regarding same (.8); review and revise complaint/memo (.5); online training for ECF filing of complaint (.3); finalize complaint and prepare same for overnight filing (1.2); correspond with co-counsel regarding same (.3) Review docket (.1); correspond with client regarding filing (.1); correspond with co-counsel regarding same and Judge Smith (.2); correspond with Tim regarding other filings (PHV motions, PI motion, etc.) (.2); correspond (throughout the day) w/ Michele regarding same, service issues, etc. (.6); telephone conference with David M. (x2) regarding Judge Smith and possible local (Columbus) counsel (.3) Telephone conference with Patrick Picinnini re representation of UA (.3); correspond with Barry regarding contact from Bryce Kurfees (.1); review media reports re complaint filing (.1); correspond with Michele regarding initial filing (.1); meeting with David regarding Kurfees (.1) Research Judge Smith's webpage (.1); review local rules regarding preliminary conference for PI (.1) Correspond with Barry regarding contact initiated by Bryce Kurfees Telephone conference with JAS regarding status of case, etc. (.2) Correspond with Barry regarding email to Bryce Kurfees (.1); draft correspondence to Tim regarding same and radio silence from Library (.1) Telephone conference with David and Barry regarding Ch. 10 interview; follow up telephone conference with Barry regarding same; correspond with Tim and media dept regarding same (.3 for all media); telephone conference with Stephanie at Judge Smith's chambers regarding status and preliminary telephone conference (.2); correspond with Tim regarding same (.1) Review Order regarding telephone conference (.1); correspond with Tim regarding contacting defendant (.1) Correspond with Tim regarding service issues (.2) Telephone conference with Tim regarding conference call on Thursday, service issues (.1) Correspond with Tim regarding service Telephone conference with Tim re preparation for conference call w/ court and follow up email to Tim (.3); telephone conference with court re scheduling for PI (.3); meeting with client re same and discovery, etc. (1.5) Review Library's discovery requests (.2) and correspond with Tim regarding same (.2) Telephone conference with Tim Chandler regarding discovery responses and PI (timing) strategy (.3)

5.1

7-Mar

1.5

10-Mar

0.6 0.2 0.1 0.2 0.2

11-Mar 14-Mar 17-Mar 19-Mar 25-Mar

0.3 0.2 0.0 0.1 0.0

3-Apr 4-Apr 7-Apr 8-Apr 10-Apr

2.1 0.4 0.3

11-Apr 16-Apr

21-Apr 22-Apr 23-Apr

Review correspondence from Tim regarding discovery responses (x2) (.1); draft correspondence to Tim and David regarding same (.1) Correspond with Tim regarding discovery responses (.1) Correspond with David (multiple times throughout the day) regarding discovery responses (.4); correspond with Tim regarding same (.1); review and revise draft of discovery responses (.5) and draft correspondence to Tim regarding same (.1); correspond with Bruce Purdy regarding same (.2); review and revise discovery responses per changes from Bruce and David (.3) Meeting with client regarding discovery responses (1.0); review and finalize same (.1); draft correspondence to counsel regarding same (.1) Correspond with Tim regarding PI posture, etc. (.1) Review ECF entry re Notice of Pretrial conference Review Defendant's Memo in Opposition to Motion for PI Correspond with Tim regarding reply brief (.1) Review Reply Memorandum and correspond with Tim regarding same Telephone conference with Barry regarding status, when to expect decision, etc. (.2) Correspond with Tim regarding meet and confer conference with opposing counsel Telephone conference with Tim in preparation for conference call with opposing counsel (.4) and follow up call regarding same (.1) Telephone conference with Tim regarding discovery schedule Review correspondence from Tim regarding 26(f) report, review same and draft correspondence to Tim re same (.2) Meeting with David regarding call from reporter Correspond with Tim and Kevin regarding UA preliminary pretrial conference on Weds (.1) Review correspondence from Tim regarding pretrial conference (.1) Review vm from Chelsea at Judge Smith's court; review correspondence from Michele regarding same and left vm for Chelsea (.2) Telephone conference with Chelsea at Judge Smith's chambers re consolidation of PI motion with trial on merits (.2); correspond with Kevin and Tim regarding same (.3); meeting with David Miller regarding same (.5) Correspond with Tim regarding consolidation Telephone conference with Tim regarding status/strategy, initial disclosures (.2); review correspondence from Tim and Angel's response re same (.1); review correspondence from Tim re initial disclosures, and Angel's response (.1)

0.2 0.1

1.6 1.2 0.1 0.1 0.4 0.1 0.3 0.2 0.1 0.5 0.1 0.2 0.0 0.1 0.1 0.2

24-Apr 8-May 9-May 13-May 22-May 27-May 29-May 2-Jun 4-Jun 10-Jun 12-Jun 23-Jun 24-Jun 25-Jun 16-Jul 17-Jul

1.0 0.1

22-Jul 12-Aug

0.4

13-Aug 14-Aug

Review correspondence from Tim re decision expected soon (.1) Meeting with BMP to discuss case, strategy, etc. (.1); review decision and opinion granting preliminary and permanent injunction and correspond with clients and co-counsel regarding same (1.0); media re same (.4) Review and respond to correspondence from Michele re fee application issues (.2) Correspond with KT regarding postpone fee application until after appeal (.1) Meeting with David regarding event on the 25th (.1); correspond with Tim regarding fee application (reasonable rate for him, etc.) (.2) Draft correspondence to Sue and Angel regarding CCV event and appeal (.4); review correspondence from Angel in response and draft correspondence to co-counsel regarding same and attorney fee application (.1); forward Angel's email to clients (.1); correspond with Tim, Michele and Kevin re attorney fee application, expert witness for rates, etc. (.9); correspond with WMT regarding serving as expert witness (.4); correspond with clients re event (.1) Correspond with Tim re attorney fee motion and reasonable rates (.2.) Telephone conference with Tim regarding attorney fee motion, proposed order re final judgment (.1) Review our Attorney Fee motion and draft correspondence to opposing counsel regarding their interest in discussing settlement of same (.2); review response and correspond with Tim regarding same (.2) Research attorney fee issues (reasonableness of rates - evidentiary or legal issue?) (.2); draft correspondence to opposing counsel re same and draft correspondence to Tim re same (.2); correspond with WMT re status of fee motion/expert testimony, schedule (.1); review correspondence from WMT re same (.1) Correspond with Tim re brief and evidence in support of fee motion (.2); correspond with WMT re expert testimony (.1) Review correspondence from Angel re settlement (.1); draft correspondence to Tim re same (.1); telephone conference with Chelsea re extension of time to file brief in support of mtn for atty fees (.2); draft correspondence to WMT re same (.1); draft correspondence to Angel re stipulation (.1) Correspond with Tim re stipulation, message from Sue and Angel (.1) Correspond with Tim re Library's fee offer, rates, expert, etc. (.2); telephone conference re expert affidavit (.2) Review Library's objections to proposed final judgment order (.1); review settlement proposal letter from opposing counsel (.1) Draft Declaration of DRL in support of fees (reasonableness of rate) and correspond with Tim re same (1.5) Correspond with Tim re fees (response to settlement offer, potential stipulation re rates) (.1)

0.1

1.5 0.2 0.1 0.2

19-Aug 20-Aug 21-Aug 25-Aug

1.8 0.2 0.1

27-Aug 28-Aug 29-Aug

0.4

2-Sep

0.6 0.3

4-Sep 5-Sep

0.6 0.1 0.4 0.2 1.5 0.1

9-Sep 12-Sep 16-Sep 17-Sep 18-Sep

19-Sep 23-Sep 24-Sep

Correspond with WMT re expert declaration in support of motion for fees (.1) Review correspondence from Angel re fee settlement, stipulation (.1); correspond with Tim re same and fee memorandum, declarations, etc. (.2) Review draft of memo in support of fees and correspond with Tim re comments to same (.5); correspond with Tim and Kevin re same (.1); review proposed stipulation and draft proposed edits to same, and correspond with Tim re same (.3) Correspond with Tim re fee memorandum, declaration, etc. (.2); prepare declaration in support of same and correspond with Tim re same (1.7)

0.1 0.3

0.9 1.9 _____ 52.9

25-Sep

Summary: DRL Langdon, David R. 52.9 hrs. @ $285.00 / hr. $15,076.50

Disbursements: Copies (324 x $.20) Computerized legal research Long distance charges Federal Express Total disbursements 64.80 52.00 7.34 20.32 $144.46

TOTAL FOR PROFESSIONAL SERVICES TOTAL DISBURSEMENTS TOTAL OF NEW CHARGES FOR THIS INVOICE

$15,076.50 $144.46 $15,220.96