Rothman Attorney Fees Declaration in Civil Rights Suit Against NYPD

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ____________________________________ ANDREW ROSA, 11 Civ. 2942 (LBS) GABY DAY, 11 Civ. 2956 (LBS) MIRSAD ISUFI, 11 Civ. 4159 (LBS) ALLEN RUBIN, 11 Civ. 4160 (LBS) PLAINTIFFS vs THE CITY OF NEW YORK, a municipal entity, et al., DEFENDANTS _____________________________________

DECLARATION OF JEFFREY A. ROTHMAN IN SUPPORT OF MOTION FOR ATTORNEYS’ FEES AND OTHER DISCRETIONARY COSTS PURSUANT TO 42 U.S.C. § 1988 AND FED.R.CIV.P. 54(d)(2)

JEFFREY A. ROTHMAN, declares, pursuant to 28 U.S.C. § 1746 and under penalty of

perjury, as follows:

1. I, along with James I. Meyerson, represent the plaintiffs in these four related

actions. As such, I am fully familiar with the facts and circumstances concerning the prosecution

of this action. I respectfully submit this declaration in support of plaintiffs’ application, pursuant

to 42 U.S.C. § 1988 and Fed.R.Civ.P. 54(d), for an order awarding plaintiffs attorneys’ fees and

costs as the prevailing party in this litigation.

2. Mr. Meyerson and I made efforts to avoid redundant work in this matter. Mr.

Meyerson dealt primarily with the fact and damages circumstances particular to Plaintiffs Rosa

and Day, and I dealt primarily with the fact and damages circumstances particular to Plaintiffs

Isufi and Rubin.

Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 1 of 32

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3. For example, only one of us - myself - spent the large amount of time necessary to

read through the transcript of the criminal trial of two of the dancers who were also arrested as

part of the same mass arrest of the Plaintiffs at the Hot Lap Dance club. With information

garnered from these transcripts, Mr. Meyerson and I were able to determine who should be

named as defendants in these actions, and we were able to make important factual allegations

and legal claims concerning the impropriety of the NYPD’s investigative activities, and arrests

and prosecutions, in these cases.

4. Despite our attempts to avoid redundant work, some overlap was of course

necessary so that we both were apprised of the important factual and procedural matters that

affected the litigation of the case.

5. It was also necessary for us to exchange drafts of documents, such as pleadings

and discovery requests, and to collaboratively edit each others’ work, which enabled us to both

be up to speed on the essential facts and procedural circumstances of the case, and to create an

optimal final product.

6. Mr. Meyerson’s Declaration, which is respectfully incorporated herein by

reference, also sets forth a description of our work together on this case.

7. A major problem in the litigation of this case was counsel for Defendants’

unwillingness to do anything. It took repeated requests - including requests for court

intervention, and telephone conferences with the court – to get materials, such as Defendants’

answers and responses to discovery requests, that should have been produced as a matter of

course.

8. Indeed, despite counsel for Defendants’ expression of his desire to negotiate the


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amount of our fees and costs, and his statement to the Court during our telephone conference on

May 16, 2012 that he needed a week’s time from provision of our time and expense sheets to

then substantively discuss settlement of our fees and costs - and despite our provision of our time

and expense sheets to him on May 21, 2012, and his promises to me in subsequent telephone

conversations that he would promptly see authority to settle the fees and costs - no offer of any

kind has been made, thus necessitating the instant fee and cost application.

ATTORNEY BACKGROUND AND EXPERIENCE

9. I am a solo practitioner, concentrating in the area of civil rights litigation, mostly

involving claims of police misconduct. My office is located at 315 Broadway, Suite 200, New

York, NY 10007. I have operated my own solo civil rights practice since 2004. Prior to that I

worked for a year in New York City for Michael Spiegel, Esq., also doing primarily police

misconduct litigation and related civil rights work, and criminal defense work. Prior to that I

worked for the Defender Association of Philadelphia, representing indigent defendants in

criminal cases. I graduated from the University of Pennsylvania Law School in 2001, where I

was a research assistant for Professor David Rudovsky, one of leading police misconduct

practitioners in the country and a co-author of Michael Avery, David Rudovsky & Karen Blum,

Police Misconduct: Law & Litigation, one of the leading treatises in the field. During my second

summer of law school, in 2000, I worked as a summer associate for the Law Office of Ronald L.

Kuby, assisting primarily with police misconduct matters. See, June 6, 2012 Declaration of

Ronald L. Kuby, Esq., annexed hereto as Exhibit A.

10. I am a member of the bars of the State of New York, the State of Pennsylvania

(inactive status), the United States District Courts for the Southern, Eastern, and Northern


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Districts of New York, and the United States Court of Appeals for the Second Circuit.

11. I am or have been counsel for the plaintiff or plaintiffs in 87 civil rights cases in

this district, most of which center upon claims of police misconduct. When potential plaintiffs

come to me with police misconduct matters raising complex issues or difficult facts that would

deter many lawyers from accepting the case, but where I believe that there has been a

deprivation of rights in need of redress, I will in many circumstances take the case where other

lawyers might decline. This has led me to become involved in police and other governmental

misconduct cases involving significant complexity, through which I have developed

considerable sophistication and skill in the field of police / governmental misconduct litigation.

A decision in one of my cases, Forbes v. City of New York, et al., 05 Civ. 7331 (NRB), 2008

WL 3539936 (2008), addressing the issue of state action by private parties, was discussed in the

New York Law Journal as one of two significant, then-recent cases that “illustrate a significant

option for enforcing constitutional rights against nongovernmental actors.” Applying

Constitutional Obligations To Private Actors, by Christopher Dunn, Esq., 4/28/2009 N.Y.L.J. at

page 3 (2009). That action settled on confidential terms.

12. I have been one of the lead attorneys in the ongoing complex consolidated

litigation stemming from the mass arrests by the NYPD during the 2004 Republican National

Convention (RNC), that has generated a number of important decisions in the police misconduct

field, and which web of related and consolidated cases remain pending before Judge Sullivan and

Magistrate Judge Francis.

13. Within the past few years I have also been heavily litigating, as lead counsel, a

putative class action against the New York State Division of Parole and the New York State


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Department of Correctional Services on behalf of a putative class of returned parole violators

whose concurrent sentences were unconstitutionally transformed into consecutive sentences,

resulting in their being held past their lawful maximum expiration dates in prison. That action has

generated two important decisions holding that the defendants violated the constitutional rights of

thousands of returned parole violators. See, e.g., Sudler v. Goord / Batthany v. Horn, 2010 WL

4273277 (S.D.N.Y. October 6, 2010)(Peck, M.J.); See also, Sudler v. Goord / Batthany v. Horn,

2011 WL 691239 (S.D.N.Y. February 23, 2011)(Daniels, J.). Those cases are presently pending

before the Second Circuit on the question of the defendants’ qualified immunity. See also, the

Declaration of Matthew D. Brinkerhoff, Esq., annexed hereto as Exhibit B.

14. In a number of the civil rights cases in which I have co-counsel (including some

who have practiced for decades), I am lead counsel. In these matters, my colleagues entrust me to

serve as lead counsel because they know that I have attained considerable skill and experience in

the field of police / governmental misconduct litigation, and that I approach these matters

zealously and diligently. See, e.g., the Declarations of Ronald Kuby, Esq. and Matthew D.

Brinkerhoff, Esq., annexed hereto as Exhibits A and B, respectively.

15. Civil rights cases are all inherently risky endeavors, and involve arcane issues of

law and law-enforcement practices. “Congress recognized that civil rights litigation is a

specialized and complex field. For this reason, the amount of the fees awarded in a civil rights

case should be governed by ‘the same standards which prevail in other types of equally complex

federal litigation, such as antitrust cases’.” Michael Avery, David Rudovsky & Karen Blum,

Police Misconduct: Law & Litigation, § 14:7 (3d ed.), quoting S. Rep. 6.


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16. As a result of this specialization, and the expertise I have developed in this field, I

am routinely contacted by my colleagues seeking advice on how to prosecute police misconduct

cases. I am an active member of the National Police Accountability Project (NPAP), an

organization of over 400 plaintiffs’ attorneys across the country who work on police misconduct

cases, and which provides training and support for attorneys and other legal workers, as well as

public education and information on issues related to police misconduct and accountability. On

January 21, 2011, I was a presenter at an NPAP CLE as part of a panel discussion entitled “The

Public as ‘Client’ in Police Misconduct Litigation,” and I have been asked to - and will be -

again presenting at NPAP’s upcoming CLE, to be held on June 29, 2012. The topic I will be

presenting on at this summer’s CLE is “Discovery Issues, including Electronic Discovery and

Protective Orders.”

17. I am also a member of the Advisory Board of the New York City Policing

Roundtable (NYCPR), a non-profit organization of over 70 members that nurtures relationships

between civil rights and public interest attorneys, community organizers, advocates, policy

analysts, academics, and others who work to end police misconduct in New York City, and

which provides legal training and technical support, and advocates for systemic reforms.

18. The people I represent in civil rights cases cannot afford the services of a lawyer

on an hourly basis. Almost none can make more than a small contribution to litigation expenses.

I take civil rights cases on a contingency basis, and I am compensated based on a portion of any

judgment or settlement, or through the payment of fees by the defendants.

19. Because the inherent risk in any police misconduct case is high, and because of

the risk that any civil rights case can become protracted with multiple, time and expense


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consuming layers of substantive and procedural complexity, civil rights lawyers like myself

depend on the availability of a full lodestar recovery in the event that we do prevail.

HOURS EXPENDED AND APPLICABLE RATE

20. I have to the date of the acceptance of Defendants’ Rule 68 offer spent 83.7 total

hours of work on this matter. At my hourly rate of $475 per hour, my lodestar is $39,757.50. I

also seek out of pocket expenses in the amount of $840.45. See, the undersigned’s time and

expense sheets, annexed hereto as Exhibit C.

21. Plaintiffs’ counsel should therefore be awarded our full lodestar by this Court.

Mr. Meyerson and myself worked hard on this case, and developed it well and pressed it

diligently. Any reduction in hours beyond that would be unjust and contrary to the principles

underlying 42 U.S.C. § 1988.

22. As referenced above, annexed hereto in support of my hourly rates are the June 6,

2012 Declaration of Ronald L. Kuby, annexed hereto as Exhibit A and the June 6, 2012

Declaration of Matthew D. Brinkerhoff, annexed hereto as Exhibit B. In addition to these

statements by my colleagues as to the reasonableness of my rates, $475 per hour is the actual rate

that I am paid by privately paying clients who wish to retain me for criminal defense or other

work (see, e.g., Kuby Declaration annexed hereto as Exhibit A).

23. In further support of our rates, annexed hereto as Exhibit D please find the

National Law Journal’s December 19, 2011 “nationwide sampling of law firm billing rates” and

certain firms’ “report [of] their billing rates by associate class,” which indicate that associates,

with similar or less experience than I command more than my hourly rate in many New York

City firms [e.g., a 5th year associate at DLA Piper billed at $520, and partners billed as high as


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$1,120; at Epstein Becker & Green associates billed as high as $550, and partners billed as high

as $850; at Fitzpatrick, Cella, Harper & Scinto an 8th year associate billed at $420, and partners

billed as high as $730 per hour; at Hughes Hubbard & Reed a third year associate billed at $510,

and partners billed as high as $990; at Kaye Scholer a third year associate billed at $475, and

partners billed as high as $1,080; at Kelley Drye & Warren an eigth year associate billed at

$500, and partners billed as high as $925; at Schulte, Roth, & Zabel a third year associate billed

at $515, and partners billed as high as $935. As I am a solo practitioner and often act as lead

counsel, and take on myself the economic risk (in terms of the expenditure of both time and

money) of civil rights cases, compared against these significantly higher rates enumerated above,

my rates are certainly within a reasonable range of rates for lawyers of like skill and experience.

24. By Report and Recommendation dated March 9, 2010 it was determined by

Magistrate Judge Dolinger that my work done in calendar year 2009 be compensated at the rate

of $350 per hour (when my rate was actually $400 per hour). That rate was endorsed by Judge

Victor Marrero in his Decision and Order dated March 25, 2010. See, Tucker v. City of New

York, et al., 704 F.Supp.2d 347, 361 (S.D.N.Y. 2010). On January 1, 2011 I raised my rate from

$400 to $475, and it has remained at that rate until the present.

25. The fees and costs set forth herein do not include those for work done on this fee

application, which was rendered necessary by counsel for Defendants’ failure to make any offer

at all concerning our fees and costs, despite repeated invitations and exhortations to him to do so,

and despite the transmittal of our billing records to him on May 21, 2012. Our cover letter to

Mr. Pollack of May 21, 2012 – providing him with our time and expense sheets – is annexed

hereto as Exhibit E. Plaintiffs will supplement their request for fees and costs to reflect all work


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done on this fee and cost application along with the submission of their reply papers, once the

amount of work expended on this matter is completed.

Dated: New York, New York June 7, 2012 Respectfully submitted,

__/S/ Jeffrey A. Rothman_____

JEFFREY A. ROTHMAN, Esq. 315 Broadway, Suite 200 New York, NY 10007 Tel.: 212 - 227 – 2980 Attorney for Plaintiff


Exhibit A


IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

ANDREW ROSA, GABY DAY, MIRSAD !SUFI, ALLEN RUBIN,

PLAINTIFFS

vs

THE CITY OF NEW YORK, a municipal entity, et al.,

DEFENDANTS

11 Civ. 2942 (LBS) 11 Civ. 2956 (LBS) 11 Civ. 4159 (LBS) 11 Civ. 4160 (LBS)

DECLARATION OF RONALD L. KUBY IN SUPPORT OF MOTION FOR ATTORNEYS' FEES AND OTHER DISCRETIONARY COSTS PURSUANT TO 42 U.S.C. § 1988 AND FED.R.CIV.P. 54(d)(2)

RONALD L. KUBY, declares, pursuant to 28 U.S.C. § 1746 and under penalty of

perjury, as follows:

1. I respectfully submit this declaration in support of plaintiffs' application, pursuant

to 42 U.S.C. § 1988 and Fed.R.Civ.P. 54(d)(2), for an order awarding plaintiffs' counsel

attorneys' fees as the prevailing party in this litigation.

2. I am the principal of a small law office located at 119 West 23rd Street, Suite 900,

New York, NY 10011.

3. I graduated from the Cornell Law School in 1983. Thereafter I worked with the late

William Kunstler, from 1983 untill995. From 1995 to present I have mostly operated a solo

practice, and for a few of those years was in partnership with Daniel Perez, Esq.

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4. My practice concentrates in the areas of criminal defense and civil rights

litigation. During the course of my career I, along with lawyers working with me, have

represented individuals in a number of high profile cases, including individuals accused of

bombing the World Trade Center; Colin Ferguson, the Long Island Railroad gunman; renowned

photographer Spencer Tunick; the Hells Angels Motorcycle Club; prominent labor unions;

accused airplane hijackers; The All-Mighty Latin King and Queen Nation; Malcolm X's

daughter, charged with conspiracy to murder Minister Louis Farrakahn; Jesse Friedman, whose

story is featured in the acclaimed film Capturing the Friedrnans; David Hampton, whose life

story formed the inspiration for John Guare's Six Degrees of Separation; dozens of

conscientious objectors; plaintiffs in two United States Supreme Court cases establishing First

Amendment protection for flag-burning; several wrongfully convicted inmates.

5. I have known one of plaintiff's counsel, Jeffrey Rothman, for approximately

twelve years, since he worked for me as a summer associate during his second summer of law

school in 2000, assisting me primarily with police misconduct matters. Since that time we have

maintained our relationship and worked together on a number of matters. Mr. Rothman and I

have been, and are, co-counsel in a number of police misconduct actions.

6. In those actions in which we are co-counsel, I entrust Mr. Rothman to be lead

counsel due to my confidence in him and what I know to be his diligence, and the considerable

knowledge and skill that he has developed in litigating police misconduct actions in the course of

his practice. I can therefore express a reasonable and fair opinion about the propriety of the

hourly rate which he should be accorded by this Court.

7. Mr. Rothman's rate of $475 per hour is certainly in keeping with prevailing

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market rates for lawyers of comparable skill and experience in the field. Mr. Rothman has

accumulated considerable knowledge and skill in the field of police misconduct litigation, which

has been and remains the focus of his practice, and this represents an entirely fair and reasonable

rate for an attorney with Mr. Rothman's experience, skills, knowledge, and competence.

8. $475 per hour is also Mr. Rothman's rate that he charges when he is retained by

private clients for criminal defense or other matters.

Dated: New York, New York JuneL, 2012

RONALD L. KUBY, Esq.

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Exhibit B


IN THE UNITED STATES D-ISTRr-CT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

ANDREW ROSA, GABY DAY, MIRSAD ISUFI, ALLEN RUBIN,

PLAINTIFFS

VS

THE CITY OF NEW YORK, a municipal entity, et al.,

DEFENDANTS

11 Civ. 1 1 Civ. 11 Civ. 11 Civ.

DECLARATION OF MATTHEW D. BRINCKERHOFF

2942 (LBS) 2956 (LBS) 4159 (LBS) 4160 (LBS)

MATTHEW D. BRINCKERHOFF, an attorney admitted to practice in the State

ofNew York, declares under penalty ofperjury as follows:

1. I am a partner of the law firm of Emery Celli Brinckerhoff & Abady LLP

("ECBA"). I submit this declaration in support of the attorneys' fee application

submitted in the above-captioned matters by one of plaintiffs' counsel, Jeffrey A.

Rothman.

2. Based upon more than twenty years of experience as a lawyer practicing in this

field in the New York area and across the country, based on my many observations and

interactions with Mr. Rothman, and based upon my knowledge of prevailing rates for

attorneys ofMr. Rothman's high caliber and outstanding reputation in the New York area,

I fully support Mr. Rothman's application for fees in all respects.


3. My firm, ECBA, specializes in civil rights and commercial litigation. In both

contexts, we regularly litigate along side and against some of the best known firms and

lawyers in New York. Almost all of our work is compensated either through traditional

hourly fee arrangements or in cases where fee-shifting is available.

4. Accordingly, based on my experience practicing law in New York for decades, I

am fully aware of the prevailing hourly rates charged by New York law firms, especially

those firms, like Mr. Rothman's, that specialize in federal court civil rights litigation.

Indeed, since ECBA submits Section 1988 fee requests and applications in connection

with its own cases, it is incumbent upon me to be knowledgeable about prevailing rates .

5. In Rodriguez v. Pressler & Pressler, L.L.P., No. CV-06-5103 (BMC), 2009 WL

689056 (E.D.N.Y. Mar. 16, 2009), an Eastern District case, Judge Cogan awarded

fees for my time at my 2007 hourly rate of $450 per hour.

6. In Vilkhu v. City ofNew York, No. 06-CV-2095, 2009 WL 1851019 (E.D.N.Y.

Jun. 26, 2009), affd in part, vacated and remanded in part, 372 Fed. Appx. 222, 2010

WL 1571616 (2d Cir. Apr. 21, 2010), Judge Sifton awarded fees to one of my partners,

Jonathan S. Abady, who like me, graduated from law school in 1990, at the rate of $525

per hour- which reflected the hourly rate ECBA billed for my time as of2009.

7. In Wise v. Kelly, 620 F.Supp.2d 435, 445 (S.D.N.Y. 2008), the court awarded fees

for my time at an hourly rate of $425 per hour, and took "judicial notice of

ECBA's high reputation, finding it to be one of the most competent, successful,

and reputable civil rights firms practicing in this Court." !d.

8. Because Mr. Rothman and I have worked closely together, I know his work well.


Mr. Rothman -and I are co-courisel in two pending consolidated actions, Sudler -v. Goard,

eta!., 08 Civ. 11389 (GBD)(AJP) and Batthany v. City of New York, eta!., 09 Civ. 6510

(GBD)(AJP). The case is a complex putative class action on behalf of parole violators

whose concurrent parole violation and misdemeanor sentences were unconstitutionally

transformed by the New York State Division of Parole and New York State Department

of Correctional Services into consecutive sentences. Mr. Rothman has served as lead

counsel, and we have engaged in intensive discovery practice, including the taking of

approximately 40 depositions in the case, and litigated a voluminous and complex

summary judgment motion before Magistrate Judge Peck, as well as Fed.R.Civ.P. Rule

72 Objections before Judge Daniels, and an appeal before the Second Circuit, which is

pending.

9. Mr. Rothman is a formidable, diligent, highly experienced, skilled practitioner

with a reputation for excellence in the New York legal community.

10. Mr. Rothman's rate of $4 75 per hour is eminently reasonable, and is in line with

prevailing market rates for lawyers of comparable skill and experience in the field. Mr.

Rothman is an extremely diligent attorney, and has accumulated considerable knowledge

and skill in the field of constitutional litigation, which has been and remains the focus of

his practice, and this represents an entirely fair and reasonable rate for an attorney with

Mr. Rothman's experience, skills, knowledge, diligence, and competence.

11. I swear under penalty of perjury that the foregoing is true and correct.


Dated: June£_, 2012 New York, New York

lttt0A2n~


Exhibit C


Jeffrey A. Rothman Attorney at Law

315 Broadway, Suite 200 New York, NY 10007

Tel.: (212) 227-2980; Cell: (516) 455-6873 Fax: (212) 591-6343

rothman.jeffrey@gmail. com

Rosa. Day. lsuti Rubin Time for Rothman

Date Time Spent Activity (hours)

12/31/10 .5 Met with JIM and referring attorney to discuss case and get files

2.0 Reviewed files re arrestees, and email to JIM and referring attorney

2/14/11 1.5 Met with referring attorney at his office and partial file revtew

3/4/11 .5 Spoke to AI Rubin and tried other arrestee #s; further review of files and email to referring attorney and JIM

3/6/11 .3 Emails with JIM re the case 3/7/11 .4 Reviewed and emailed Rosa's materials to JIM

2.5 Review of file materials and emails with JIM re Rosa and Day.

.3 Email to Isufi; and message from him and spoke with him 1.5 Edits to JIM draft Rosa complaint

3/8/11 .2 Call from other attorney re Asian and Johansson 2.0 Met with AI Rubin - intake

3/10/11 1.8 Review of crim court records, and the warrants and warrant apps; emails to JIM re Day

3/11/11 .2 Email of releases to Rubin .3 Emails with JIM and with Gaby Day

3/13/11 6.5 Review ofDD 5s; scanned DD 5s re Day, re higher ups involved in raid planning; re other ones of note; and emailed to JIM with explanatory email

3/14/11 .7 Review of file documents, and emailed to JIM; spoke to JIM re other arrestees

.1 Email with JIM 3/16/11 .4 Work re complaint allegations and defendants

3.2 Met with Mirsad lsufi - intake and releases .3 Further emails with JIM re Day and Rosa; email with Isufi

4/28/11 5.0 Review of first 1/2 of criminal court tnscpt ofMalandri and


Rodriguez, made notes 4/29/11 8.5 Finished review of transcript; final edits to Rosa and Day

complaints and emails and talks with JIM 4/30/11 .1 Email with JIM 5/2/11 .3 Talk with JIM re assignment of Judge Sand and MJ Katz in

Rosa, and review of the statement of relatedness in Day 5/6/11 .2 Emails with JIM

6/2/11 .I Emails with JIM 6/3/11 .3 Review of JIM draft initial disclosures in Rosa and Day,

and emails with him re initial disclosures 6/12/11 5.0 Reviewed files and drafted Isufi and Rubin complaints;

tried to reach Isufi and spoke with Rubin 6/13/11 .5 Went to crim court and obtained Rubin information

.2 Call and email to Rubin

.2 Text and letter to Isufi 6/16/11 .3 Spoke with Isufi

1.0 Made summonses and civil cover sheets; printed and copied complaints and statements of relatedness in Isufi and Rubin and prepared for filing

6/17/11 .2 Filed Rubin and Isufi complaints at the clerk .2 Made pdfs of the complaints and related case statements,

and emailed to case openings .6 Organized service addresses, and email to JIM

6/20/11 .3 Emails from JIM to ACC Richards; emailed PDF of Isufi and Rubin complaints to Richards, and request for Braille and Conroy service addresses; emails with Richards and JIM re service issues

6/23/11 .2 Received Notices of Assignments in Isufi and Rubin, and emailed to opposing counsel

6/26/11 .4 Spoke with other arrestee .4 Email with other arrestee

6/27/11 .6 Work re follow-up svce by mail upon Costello, Koch, Kong, and UC 293, and re proofs of svce on them and on the City; notarized intern proofs of svce and e-filed.

7/14/11 .2 Talk to JIM re svce on Braille and Conroy, andre initial disclosures

.2 Read emails btwn JIM and ACC re svce address for Braille and Conroy

7/15/11 .2 Review of emails btwn JIM and ACC Richards re svce addresses for Conroy and Braille, and emails with JIM

.1 Review of ACC Pollack letters to J in Isufi and Rubin for ext to answer

.2 Review of JIM's initial disclosures in Rosa and Day 7/18/11 .1 Correspondence with JIM re svce on Conroy and Braille

2


8/411 I .2 Emails btwn JIM and law dept re service location for Braille

8/25/11 1.2 Prepared svce on Braille and Conroy in Isufi and Rubin for

8/26/11 .5 svce at 1 PP and for follow-up mailing Served Braille at 1 PP Legal Division in Isufi and Rubin

.3 Issues trying to serve Conroy at OCCB - no longer there; _got new address at School Safety in LIC

.3 Made new summonses for Conroy at School Safety, and _gave to J>rocess server in Isufi and Rubin

.3 Made proofs of service for Braille in Isufi and Rubin, made pdfs, and e-filed via ECF

.1 Email to ACC Richards and Pollack re Conroy service issue

9/12/11 .2 Call from process server, and email to ACCs re Conroy servtce

.2 Talk to JIM 9/14/11 .2 Emails with JIM I Pollack 9/15/12 .2 Emails with JIM 9/19/11 .1 Talk to Rubin

.1 Tried to call and email to Isufi 9/20/11 .1 Spoke with JIM

.2 Email to Gaby Day 9/22/I 1 . I Emails with Gaby Day

.1 Email to Pollack and Richard with settlement demand I 0/1/11 .1 Email with JIM 10/3/11 .1 Talk to JIM I0/4/11 .1 Read JIM email to Pollack re their discussion

.2 Talk with JIM I0/11/11 .3 Calls with JIM and with ACC Pollack re service on Conroy

and case status

.1 Email with JIM 10/14/11 .6 Call with process server re Conroy svce; emails to ACCs re

svce on Conroy; scanned prfs of svce on Conroy in Isufi and Rubin and e-filed

I0/17/11 .1 Call from JIM re writing J Sand .1 Read JIM letter to J Sand re having a conference

10/18/11 .3 Received Ds' answer in Day; read JIM email to Pollack; email to JIM

.2 Call from JIM 10/21/11 .2 Emails with Isufi 10/24/11 .2 Talks with JIM 11/2/11 .3 Read JIM email to Pollack re late answers; talk with JIM

.2 Found and scanned and emailed 160.50 releases to ACCs for Isufi and Rubin

3


Il/4/II .3 Emails from JIM to Pollack, and letter to him re I60.50s and otherwise; email with JIM

.I Talk with JIM

.5 Marked Isufi and Rubin complaints from Ds' answers I2/5/I I .2 Talk with JIM re con£ tomorrow with J Sand

.3 Made proposed CMO and email to opposing counsel I2/6/II 1.5 Review of file in prep for int'l conference

.8 Initial conference with J Sand, and discussion with JIM I2/7/12 .5 Review ofDs' Initial Disclosures I2/I2/II .1 Read JIM email to Gaby Day

.1 Rec' d call from AI Rubin 12/21/11 .2 Email from JIM to Pollack~ spoke with JIM 12/26/11 5.0 Sorted through, scanned and bates #ed documents and put

on disc, and made supplemental initial disclosures and sent to Pollack and JIM

12/27/1I .2 Emails with llM 1/10/12 .4 Spoke to JIM 1/11/12 .I Email with JIM 1/30/12 .2 Emails with JIM 1/31/12 .2 Emails with JIM

2/7/12 2.5 Made 2"0 set of discov req' s, and letter to ACC Pollack re case status I potential settlement I discovery arrears

2/14112 .1 Call to ACC Pollack and discusses potential settlement .1 Email to Jimmy re talk with Pollack

2/28/12 .1 Lm for Pollack re his promised offer

3/1/12 .1 Lm for Pollack again re his promised offer 3/8/12 .1 Lm for, and spoke with, Pollack

3/9/12 .3 Call from JIM; checked Betty Posner docket sheet re activity; lm for Hazen w/ JIM

3/16/12 .2 Call from JIM

.1 Tried to call ACC Hazan; email to Hazan

.I Call from Hazan

.1 Email to JIM re talk with Hazan 3/19/12 .1 Spoke with ACC Pollack re absence of settlement offer

.I Email with JIM 3/22/12 .1 Lm for ACC Pollack re absence of settlement offer 3/27/12 .5 Drafted letter to Judge Sand; scanned and emailed to

counsel .4 Hand-delivered letter at SDNY

3/28/I2 .1 Call from ACC Pollack re our demand .I Email to JIM re my talk with Pollack

3/29/12 .3 Received Pollack letter to J Sand; email and spoke with JIM

4


4/3/12 .1 Call from JIM 4/4/12 .I Spoke with Pollack

.1 Lm for chambers re scheduling conference

.1 Email to JIM 4/5112 .4 Reviewed Ds' initial disclosures and drafted notice of

deposition and cover letter .4 Hand-delivered notice of dep at law dept. .1 Scanned notice of dep and email to Pollack, Hazan, and

JIM .2 Spoke with JIM

4/9/12 .1 Email from David Hazan re consolidated deps 4/10/I2 .1 Email from JIM

.I Lm with J Sand Deputy Jose Lopez, and email to JIM re same

.2 Call from Mr. Lopez, and email to other counsel re scheduling phone conference

4/11/I2 .2 Spoke with Pollack re tel conf w/ Judge, and re dep scheduling

.2 Lm for chambers and email to opposing counsel re same

.I Spoke with JIM re discovery considerations 4/12/12 .I Email re phone conference with Chambers

.I Tried to call chambers deputy re the problem with multi-person conference call (he's out today)

4/13/I2 .I Spoke with Jose Lopez at chambers re Monday conference call

.I Call to freeconferencecall.com for mon. call

.I Email to all counsel re logistics for Monday call

.I Call from Pollack re offers

.I Email from Pollack re offers and email to JIM re same 4/I4112 .2 Spoke and email with JIM 4/I5112 .I Spoke with Rubin

.I Spoke with Isufi

.3 Spoke with JIM 4/I6/12 .I Tried to call Pollack with JIM

.6 Conf call with J Sand and other counsel, and negotiations with Pollack and JIM

.I Spoke with JIM

.I Call from JIM

.2 Emails with Pollack 4/23/I2 .I Email to Pollack re status of discov responses

.I Spoke with JIM 4/25/12 .I Email to Pollack re status of discov responses 4/30/12 .2 Call from JIM re Pollack, and conf call message to Pollack

5


5/l/I2 .I Conf call with JIM and Pollack . 2 Discussed with JIM, and call with J Sand's deputy Mr .

Lopez .1 Read JIM letter to J Sand

5/3/I2 .3 Read JIM emails with Pollack, and spoke with JIM .I Read Hazan letter to J Sand re discov I answer arrears in

the Posner case 5/7/12 .1 Spoke with JIM

.1 Lm for ACC Pollack to call me re outstanding matters 5/9/I2 .2 Calls from JIM

.8 Review ofDs' supplemental disclosures 5/12/I2 .2 Read JIM email to Pollack re inadequate discov responses,

etc. 5/14/12 .9 Received and reviewed Ds' inadequate discov responses

.1 Email with JIM 5/I5/12 .2 Talk to JIM

.I Email to JIM and other counsel re the call in # for the conf call tomorrow

.I Call from Pollack re discov and re the R 68s

.1 Call to JIM and relayed my discussion with Pollack (Pollack hadn't wanted to have a conference call)

= 83.7 hours

83.7 hours X $475 per hour= $39,757.50 in Rothman fees

Expenses

Date expense Activity

6/16/II 4.00 Copies of lsufi and Rubin complaints and statements of relatedness and cover sheets for filing at SDNY

6/17/1I 700 Filing fees at SDNY for lsufi and Rubin complaints 6/23/II 37.73 Kinkos copies of complaints for service in Isufi and Rubin 6/27/11 8.I6 Postage for follow-up mailing of service to Costello, UC

293, Kong, and Koch 8/25/11 I3.60 Copies of Isufi and Rubin complaints and stmnts of

relatedness for svce on Braille and Conroy 8/26/I1 2.96 Follow-up svce by mail on Braille in Isufi and Rubin I1/2I/Il 74 Svce on Conroy in lsufi and Rubin

= $840.45 in Rothman expenses

6


Exhibit D


THE NATIONAL LAW JOURNAIJWWW.NU.CIIM I DECEMBER 19. 2011

I BilliNG SURVEY

A nationwide sampling of law firm billing rates The National Law Journal asked the respondents to its 2011 survey of the nation's 250 largest law firms to provide a

range of hourly billing rates. Firms that supplied the information are listed in alphabetical order.

ll.Jktr, Donci>On.l!<>r""'n, Cald~~ll & lltrkowitz

ll<>t Best & Krieger

llriW and Morgan

Broad and Cassel

SryanC.1~

Outz<ll.ong

c..ltonfidtls

Coztn O'Connor

Dar Pitney

Dickin$0n Wright

Dickslein Shapiro

Dinsmore & Sl1ohl

Dl.A Pip<r

Dor><y & Whillle)'

Duanl'"Morris

Dyk<ma Gosse II

llutein 1\eckr & Grt'Cn

Fitzp:llrick. C<lla.l!orper & S<into

t:O~r. Rothschild

FrwtllrownlO.Id

G•rdcn: II)'Tir>< Sc"dl

Gibbons

llarrislk'a(h

Hiscock & Oarclay

IJodgson Russ

l!ollaod & Knight

flughos flubbonl & R..~

HU><h 81adwdl

lackson Kelly

K•r•Schokr

1\:dley IJryt & \\'arr<n

Knobbl-. Mart('ns, Olson 8: Bear

lan< Po~>dl

lathrup&G>g<

~~~i~ Ric< & Fingmh

low<nslcin S3ndlu

M•n•n. Phclf'>&Pbillips

McElror. D<uts<h, Mulvan<y & C.rpent<r

McK<nnalong & AWridge

Micbad B<St & Fri<drich

~liU•r & M~rtin

N<hon Mullins Ril<y & Scarborough

Ncxscn Pruet

Meolpllis, Tenn.

ltim$ide, Calif.

Nio,..pol~

Odaodo, Fla.

Stlouis

Detroit

Tampa. Fla.

Phita.Jetp~ia

Paosippa.,. NJ.

Delr~t

Washinlltn

Minneapolis

Philadelphia

Phitadelpllia

Cit~tinnali

Dallas

tlew.lri.NJ.

Rochester, N.Y

S)racuso,N.Y.

Buffalo. N.Y.

Wasllineton

Stlouis

Cllarleston. W.Va.

NewYort

New YOlk

IMne,Carrl.

Seattle

l(ansasCil)',lllo.

SI.I.O<Jis

Rostland, NJ.

losAnteles

Morrislown,NJ.

Allan Ia

Milwaukee

CllaHa1100p, Tenn.

Columbia, S.C.

Corum,ia, S.C.

5t1

195

185

160

908

116

270

504

324

n9

l35

407

3~48

567

629

Jl3

300

"8 450

401

265

199

116

174

199

910

300

551

170

425

321

26a

180

2&1

162

249

322

2n

m

208

1&4

399

178

$311 $310 $5!15 $250

$35& $360 $575 $215

$625 $325

$377 $350 $575 ~5

sm S460 $795 $375

$700 $325

$397 $400 $815 $320

sm S4ro $900 $305

$447 $450 $960 $380

$600 $325

$560 $550 $1.000 $540

$3118 $295 suo $150

$585 U15 $1.120 $~

$426 $405 $810 $295

m1 $500 u15 $375

$406 $400 $665 $310

$42& $425 $350 $350

sm S4GO

$413 S42ll $125 $325

$296 st95 sm s2o5

$435 $450 $815 $380

m5 $450 $125 s.roo

$390 $275

$269 $240 $750 $1!15

$685 $240

$445 $455 $195 $300

1633 16rs S990 ms

$341 $340 $1150 $225

$275 $275 $505 $2$5

$661 $665 $1,080 $6&5

$474 $400 $925 $480

$439 sm $735 $415

$405 $425 $645 $340

$337 $340 $135 $275

U75 $470 $270

$478 $480 $8!15 $435

U02 $620 $850 $540

$245 $275 $575 ~5

$472 $455 $800 $405

$321 $310 $650 $US

sm S32s uro Sl40

$318 $310 $850 $220

$550 $235

$357

$411

$435

$565

$440

$470

$510

$531

uao $373

$747

$526

$575

$482

$519

$41!6

$340

$550

$M3

$304

$378

$531)

$82&

$395

$319

$831

$~4

$525

$460

$390

$613

U76

$350

$562

$4U

$369

$412

$345

$420

$395

$S53

$410

$490

ms

$670

$310

$730

$525

$570

$485

$500

$525

$483

$340

$550

$505

$295

$~

$520

$800

$390

$325

$835

sm $5110

$450

$390

$595

$670

$375

$540

$375

$400

$315

$375

$305

$350

$540

$425

$380

$550

$470

$320

$545

$310

$730

$465

$530

$395

$550

$440

$4S5

$265

$500

$475

$260

$350

$420

$495

$695

$425

$260

$705

$595

$495

$360

$410

$320

$660

$550

$325

$510

$310

$275

$350

$265

$160 $228

$205 $265

$230

$180 $265

$200 $356

$225 $274

$195 $262

$225 $330

$2)5 $317

$200

$12$ $4)5

$130 $217

$310 $508

$190 ~4

$225 U65

$260 $309

$195 $341

sm $190 ~7

$150 $100

$125 $325

Sla5 $380

$160

$150 $2t7

$180 $234

$175 $2!15

wo ss.n $175 $22&

$155 $208

$310 $519

$275 $425

$2!15 $3~

$225 $295

$2tS $246

$150

$250 $400

$215 $-1&4

$185 $250

$215 $374

$205 $241

$181 Ul5

$170 $255

$170

$225

$240

$265

$360

$265

$330

$315

$461

$220

$510

$275

$365

$305

$325

$325

$295

$200

$320

$320

$195

$125

$290

$~0

$210

$205

$525

$420

$345

$285

$245

$390

$500

$23.1

$375

$215

$250


THE NATIC'lNAL lAW JOURNAUWWW.IIUCOM I D£CEMB£R 19.2011 t3

BILUNG SURVEY I

SAMPUMS1 FRal.l ~CE 1 Z

ElM 11&11 I.IW i AVWSE l MlDWI Mill ! LIW i lVWSE l MElWI : :

- - I · ·-• •-•;-•••-••••• ;•·•-•· •--•

P..ttton Boggs Was.lliac1on SL2 $546 $540 $990 $410 j ~59 j S64S $570 f $2:411 j $410 ! $415

~pp<r Ham~ton PMade~hia : 45il S825 $380 l $557 l • $460 j $.235 ~ $344 ! . : ~ I . i

Pcrkir~S Cole SeatUe 693 $462 $875 $285 l $5SO j $545 $590 i $2:15 ! $lS1l i j • •

Phelps Dunbar New Orlem 280 ms $225 $465 $190 ! $281 j W5 $245 j $150 t $1&9 ! $100 : . :

P<llsmdli Shughart lla11$8S Ciij, Mo. 46fi $b3il $275 ! j $335 J $205 : : ! .

Saul Ewing Philadelphia 220 $431 $400 $7~ $3.50 1 $502 ! $490 $495 i $245 I $326 1 $!00 . . . . S<hulte Roth & Zabel New York 406 $6!5 $630 $935 $770 ! $346 ! $840 $675 ; $2S5 ! $608 ~ $580 i ; . ~ ~

! : ! i i ~cyfanh Sh~w Chlca~ 702 $437 $425 $790 $355 ~ $528 ~ $515 $5tl5 ! ms l $341 ! $340

t [ I Sheppard. M\tltiu. Rfchtcr & H~mptoo los Angdes 465 $800 $:505 1 f $$35 : $275

lihun);rrn. Loop & KenJrick T~. Ob., 203 $3.45 $365 $555 $26S I $364 ! $375 $320 ! $195 : $252 ! $250 • J • • l . : . -

S1ocl Rives Po«11and .. Or~. 373 $385 $395 $625 $320 j $451 1 $456 $SOO t $195 1 $:292 l $275 : ! .. i : '

SlrJ,burger & Price Dallas 181 $303 $362 $63(1 SZll : $395 j $397 $332 i $199 ! $2~ : $238

nl(>mpson & Knighl Dallas 319 $520 t520 $875 $440 • $594 $5~ $460 ! $250 1 $358 : $350

Tht,mpsoir Coburn st. Louis 325 $750 $315 ! I $445 ; $19-S

l:~me-r & lk-me Cln'lifatld 179 $316 $5-8& mo $405 $390 $200 1 $2ro l

Vedder Pncc ClttaiO 246 $445 $445 $735 $295 $500 $490 $520 $265 ! $345 f $335

Wmstead Oallas 265 Wl6 $WI $365 $4n $4!0 $115 $301

~Vinston & Slmwn Clllcaao 863 $m $55.0 1

$l,l30 SSSO $7l3 S700 S600 S3SO $~34 $4J3

Wynu. T:~rnJll & Combs l ooi$viDe, l(y. ' 181 $312 $.350 1

S500 $240 $325 $375 $275 $180 $220 ~ $235

• ~ftome, n11111i:ers afe hllRIIIU 250 pub~Bt!ei~ll> _. .. 201l


lHE NATIONAl lAW .JOIJRNAlJWWWJIU.COII I OECEM8U 19. 2011

BILLING SURVEY

Firms report their billing rates by associate class Belo'w is a sampling of hourly rates charged by law firms that establish billing rates based on associate class.

Firms that supplied this information are listed in alphabetical order.

BryanCa\~

lluudl.of~S

C.rllon Fi<lds

Cozen O'Connor

na)·Pitn"r

Dickinson WriJho

Dicksldn sn.piro

Dinsmore & Shohl

I)LII'iper

Dors.:y & W11i1ncy

F~zpolri<k, C<U•. ~brp<r & Scinto

l'ox Rothschild

Frosl Drown Todd

Gankrc Wynn<: S<wdl

li>rrisllnch

Hiscock& O.rday

1-lugb.:> linbb;lrd & Reed

lodson Kdly

Kay< S<hol<r

Kdkyllr)-<& 1\ .. m.,.

1\nobbt, M.ntcns. Otson & Bear

l.olhrop&Gage

,\kFJroy. O.ucsch. Muh .. ncy & c..p.m.r

Mc!;en.,.long& Aldridge

Michaellksl & J~l<drich

N<l•on Mullins Rll<y & Scarborough

Potion 8"88'

Schuh< Roth & Zabel

S""''l"'rd. Mullin. Richo<r & Haonpton

Shu.W.:r.loop & l:endricl<

Stro>i>urs<r& Prkt

l110mpson & Knigho

Vcddtr Price

Win$1~.ad

Wy.act.Tarrant&Combs

St loois

Tampa. Fla.

Philadelphia

Parsippany. NJ.

Wa.bingiGO

Cinelnoali

New York

Minneapolis

Philadelphia

Cincinnatr

Oallas

S,..Case, N.Y.

Hew Yen

Charleslon. W.Va.

lrviot.Colil.

Milwouqe

Columbia, S.C.

Stante

Philadelphia

NewYorl

losMgolts

Oallas

Oallas

t.trimlo, Ky.

• Fu•·lillooqoriYoltotanomey...,bm '" f10111111J lSOpublishetl ioApri120ll.

908

176

210

324

m

33S

407

3.348

567

168

450

401

265

116

174

300

110

425

321

268

180

281

272

425

20$

399

m 693

l20

406

46S

1&1

319

246

181

$200-$36S

$225

$225·$420

$19S-$210 $210·$225 $210-$225 $225-$240

$22>$290 SlZS-$290 $l35-$320 $245·$360

$244 $215 $295 $291

$195 $205 s21o mo $22S-$Z90 $21S-$3aS $l30·$440 $345-$46S

$185 $195 $210 $225

$345 $~5 $455 $520

$238

$280

$215

$221).$235

$150

$22S

$160

$115

$350

$180

$320

$30S

$295

$250

$20S

$185

$27S

$210

$170·$265

$300

$264

$285·$390

$21S-$340

$205

$221

szso.mo $255

$215

$350

$181)

$253

$305 S320

SlGO $325

$230-$265 $240-$285

$165-$185 SI1S·S11!S

$260 $290

$115 SlOO

$115 $195

$450 $510

$195

$410

~

$320

$260

$210

$195

$l80

$205

$475

$350

$345

$260-$340

$220

$215

$317

$l10·$250

$215·$295

sm $284

$297

$335

$350

$240-$285

$180·$23S

$320

sm $195

$540

$215

$525

$380

$310

$260-SJOS

$l30

sm $346

$220.$300

SZ2S-$325

$385

$291

$205·$230

$210-$345

$325

$213

$24S-$255 $250-$280 $27S-$300

$46S

Sl40.$440

$234

$315

$265

$215

$37S

$SIS

$380·$490

$221

$350

$280

$240

$400

$560

$410·$525

$238

$385

$300

$260

$435

$300-$430 $280-$485 $350-$510

$250-$26S SlS5-$315 $275·$365 $300·$380

$24S-$.l40 $265·USO $285-$380 $290-$395

$34 I $335 $360 $351

$235 $24S $tsS $265

$360·$4~ $390-$S10 $425-$530 $43S.SS4S

$235 $245 $255 $26S

$S80 $620 $650 $675

$305

$350

$310

$24S·$JOO

$190-$230

$350

sm $205

SS70

ms $510

$420

$395

$26Q.$3l5

$250

$235

$354

$225-$260

$195-$335

$415

S3ll

SllS·$340

SS80

$4354SSS

SlSI

$405

$320

$290

$470

$336

$310

$385

$210-S4S5

$190-$240

$370

$235

$20S

$600

$240

$595

$450

$26S-S340

$255

$250

$371

$240·$295

SZOS·$350

$445

$331

$275-$310

$605

$460-$580

$2$9

$425

$335

$31S

$SOO

$370

$380 $420

$40S $420

$190-$410 $26Q.$42S

$185-$260 $200-$265

$38S $400

$23S $260

$205 $220

$615 $630

$620

$410

$34S-$330

$210

$265

$386

$220-$265

$24S-$325

S46S

$359

$295-$3l5

$630

$48S-$610

$284

ws $35S

$335

$525

$640

$500

$300.S360

$280

$275

$408

$230·$305

$2SS.Sl10

$490

$378

$320·$450

$650

$50S.S635

$215

$460

$370

$lliCI

ssso


Exhibit E


Jeffrey A. Rothman Attorney at Law

315 Broadway, Suite 200 New York, NY 10007

Tel.: (212) 227-2980; Cell: (516) 455-6873 Fax: (212) 591-6343

rothman.jeffrey@gmail. com

By Email David Pollack, Esq. Assistant Corporation Counsel NYC Law Department Special Federal Litigation Division 1 00 Church Street New York, NY 10007

May 21, 2012

Re: Andrew Rosa vs The City ofNew York. et al, 11 Civ 2942 (LBS) Gaby Day vs The City of New York. et al., 11 Civ 2956 (LBS) Mirsad lsufi vs The City ofNew York. et al.,11 Civ 4159 (LBS) Allen Rubin vs The City ofNew York. et al.. 11 Civ 4160 (LBS)

Dear David:

I write concerning the attorneys' fees and costs that will accompany the accepted Rule 68 Offers made in the above-captioned cases. Enclosed please find my and Mr. Meyerson's time sheets, and an itemization of our out-of-pocket expenses. Please contact us to see if we can negotiate a stipulation as to the attorneys' fees and costs that would avoid the need for a formal fee application. Mr. Meyerson's time is billed at the rate of$650.00 per hour. My time is billed at the rate of$475.00 per hour.

The breakdown is as follows:

64.2 Meyerson hours X $650 per hour= $41,730.00 Me_yerson Expenses $2175.84 83.7 Rothman hours X $4 75.00 per hour= $39,757.50 Rothman Expenses $840.45

Total= $84,503.79

Please note that if it is necessary to litigate a fee application, we will also bill for any time necessary to prepare and litigate the fee application itself.

When you have a chance to review the enclosed time and expense sheets, please give us a call to discuss. Please turn to this as soon as possible, so that we can bring this matter expeditiously to a close.


HP_Administrator

Typewritten Text

encs.

Thank you for your consideration in this matter.

2

Jeffrey Rothman Jimmy Meyerson


Rothman Attorney Fees Declaration in Civil Rights Suit Against NYPD

Documents

goord batthany

returned parole

david rudovsky

civil rights

accumulated

inadequate

year associate

civil rights