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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.
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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 NYPDs 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. Meyersons 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 weeks 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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k

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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 NPAPs upcoming CLE, to be held on June 29, 2012. The topic I will be
presenting on at this summers 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 undersigneds 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 Journals 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 5
th
year associate at DLA Piper billed at $520, and partners billed as high as
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Page 8 of 9
$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 8
th
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



Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 9 of 32











Exhibit A
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 10 of 32
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.
Page 1 of I
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 11 of 32
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
Page 2 of2
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 12 of 32
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.
Page 3 of3
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Exhibit B
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 14 of 32
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.
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 15 of 32
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.
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 16 of 32
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.
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 17 of 32
Dated: June_, 2012
New York, New York
l t t t 0 A 2 n ~
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 18 of 32











Exhibit C
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 19 of 32
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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 20 of 32
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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 21 of 32
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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 22 of 32
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 P o l l a c k ~ 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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 23 of 32
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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 24 of 32
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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 25 of 32











Exhibit D
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 26 of 32
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, & lltrkowitz
ll<>t Best & Krieger
llriW and Morgan
Broad and Cassel

Outz<ll.ong
c..ltonfidtls
Coztn O'Connor
Dar Pitney
Dickin$0n Wright
Dickslein Shapiro
Dinsmore & Sl1ohl
Dl.A Pip<r
Dor><y & Whillle)'
Duanl'"Morris
Dyk<ma Gosse II
llutein 1\eckr & Grt'Cn
Fitzp:llrick. C<lla.l!orper & S<into
Rothschild
FrwtllrownlO.Id
Grdcn: II)'Tir>< Sc"dl
Gibbons
llarrislk'a(h
Hiscock & Oarclay
IJodgson Russ
l!ollaod & Knight
flughos flubbonl &
HU><h 81adwdl
lackson Kelly
KrSchokr
1\:dley IJryt & \\'arr<n
Knobbl-. Mart('ns, Olson 8: Bear
lan<
lathrup&G>g<
Ric< & Fingmh
low<nslcin S3ndlu
Mnn. Phclf'>&Pbillips
McElror. D<uts<h, Mulvan<y & C.rpent<r
McK<nnalong & AWridge
Micbad B<St & Fri<drich
&
N<hon Mullins Ril<y & Scarborough
Ncxscn Pruet
Meolpllis, Tenn.
ltim$ide, Calif.

Odaodo, Fla.
Stlouis
Detroit
Tampa. Fla.

Paosippa.,. NJ.

Washinlltn
Minneapolis
Philadelphia
Phitadelpllia

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

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
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
$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

$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
$225 U65
$260 $309
$195 $341
sm
$190
$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
$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

$210
$205
$525
$420
$345
$285
$245
$390
$500
$23.1
$375
$215
$250
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 27 of 32
THE NATIC'lNAL lAW JOURNAUWWW.IIUCOM I DCEMBR 19.2011
t3
BILUNG SURVEY I
SAMPUMS1 FRal.l 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 j S64S $570 f $2:411 j $410 ! $415
: 45il S825 $380 l $557 l $460 j $.235 $344 !
. : I . i
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 $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
702 $437 $425 $790 $355 $528 $515 $5tl5 ! ms l $341 ! $340
t [ I
Sheppard. M\tltiu. Rfchtcr & los Angdes 465 $800 $:505 1 f $$35 : $275
lihun);rrn. Loop & KenJrick Ob., 203 $3.45 $365 $555 $26S I $364 ! $375 $320 ! $195 : $252 ! $250
J
l . : . -
S1ocl Rives Po11and .. 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 ! : $238
nl(>mpson & Knighl Dallas 319 $520 t520 $875 $440 $594 $460 ! $250 1 $358 : $350
Tht,mpsoir Coburn st. Louis 325 $750 $315 ! I $445 ; $19-S
& 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
& Slmwn Clllcaao 863 $m $55.0
1
$l,l30 SSSO $7l3 S700 S600 S3SO $4J3
Wynu. & Combs l ooi$viDe, l(y. ' 181 $312 $.350
1
S500 $240 $325 $375 $275 $180 $220 $235
n11111i:ers afe hllRIIIU 250 _. .. 201l
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 28 of 32
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.


C.rllon Fi<lds
Cozen O'Connor
na)Pitn"r
Dickinson WriJho
Dicksldn sn.piro
Dinsmore & Shohl
I)LII'iper
Dors.:y & W11i1ncy
C<U. & 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 &
N<lon 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

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.
FulillooqoriYoltotanomey...,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 $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 SI1SS11!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 $265USO $285-$380 $290-$395
$34 I $335 $360 $351
$235 $24S $tsS $265
$390-$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
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 29 of 32











Exhibit E
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 30 of 32
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.
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 31 of 32
encs.
Thank you for your consideration in this matter.
2
Jeffrey Rothman
Jimmy Meyerson
Case 1:11-cv-02942-LBS Document 14 Filed 06/08/12 Page 32 of 32