Supplemental Motion for an Award of Attorney's Fees and Costs; Memorandum in Support of Supplemental Motion for an Award of Attorney's Fees and Costs

     [||68ce9340-88e6-4c04-a3f0-601685b8aefc||] 15 7/ {Ol Jer. / 1 | 

IN THE UNITED STATES DISTRICT COURT   
FOR THE NORTHERN DISTRICT OF MISSISSIPPI 

WESTERN DIVISION 

    

DELORES NORWOOD, et al., | 

Plaintiffs, 

v. NO. WC 70-53-K 

D, I. HARRISON, 8SR., et al., | | 

Defendants. 

  

SUPPLEMENTAL MO 

OF ATTORNEY'S 

3 
be 

i ON FOR AN AWARD 

ND COSTS 

Pursuant to the opinion of the Fifth Circuit of October 5, 

determination of appropriate compensati on for work performed since 

2 onl ™ Sod pe. " Toms ey yy oy gm de om Y § 1617, plaintiffs Delores Norwood, et al., request a supplemental 

| 
2 . . 2 » “ : 

award of reasonable attorney's fees and costs for legal wo NEI- 

eg A yep ow A my ~ =z 3 I OF aE PEE ; ITV ov formed by plaintiffs' counsel in the amount of $7,635.00, (This 

- “ ‘ Pu ie RE or 1 or po PAE Pe NT - ye ~ fee N ! amount is in addition to tihnis Court's previous award of attorney's 

fees of March 2, 1976, with interest, affirmed by the Fifth Cir- 

cult, October 35, 1978.) 

The motion should he granted for the reasons set forth in 

ompanying memorandum in support and affidavits of counsel. 
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Respectfully submitted, p 

  

py GREENBERG 

BILL LANN LEE 

Suite 2030 

10 Columbus Circle 

New York, New York 10019 

  
 



  

FRED L. BANKS, JR. 

318 East Pearl Street 

Jackson, Mississippi 39205   Attorneys for Plaintiffs     CERTIFICATE OF SERVICE 
  

| Undersigned counsel certifies that copies of the foregoing 

supplemental motion for an award of attorney's fees and follow- 

| ing supporting memorandum and affidavits were served on counsel 

of record by placing copies in the United States mail, postage 

prepaid, first class mail, this 20th day of October, 1978, 

| addressed to: | 

Hon, Peter 

% Office of 

i State of M 
Post Office 

H Jackson, Mi 

  

  

Attorney for Plaintiffs 

      
 



  

  
I DELORES NORWOOD, et al., 

  
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF MISSISSIPPI   
WESTERN DIVISION 

  

Plaintiffs, . 

NT 
Ve i 

| D. L. HARRISON, SR., et al., | 

  

  

ANTI TINT TR ——— ONT TT TY PNT 

MEMORANDUM IN SUPPOR QTD SHY STI CeTTY 
te I gl ; p 

Ta T 
FAS ROTY Wf LW FAS 3 J WE ee Ne iv 3 en) ght IF Ld 

1 

MOYTYT { dH AS AWATR Ty mMMEIRPATR EQ | MOTION FOR AN AWARD OF ATTORNEY'S 

FEES AND COSTS 

The supplemental motion for an award of fees should be 

granted for the following reasons: 

Ti 4 Voir pn 7 Wolk £8 3 3 Ly : H l. This Court previously denied the prior supplemental 
lu 

| request for post-~March 2, 1976, legal services "without prejudice" 
I 

. 1f the March 238 order was upheld on appeal and if the Court of 

' Appeals mandates an award for additional s: 

  

since March 2, { H
 < | 
a
 

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- 

1976, Order of January 10, 1978. & 

authority and amount for pre-March 2, 1976, legal services. As 

to the post-March 2 legal services, the Court of Appeals ruled 

that "[t]lhe plaintiffs should, however, be compensated for any 

time their attorneys spent on the matter after March 2, 1976." 

Because the record does not disclose the amount of time counsel 

  
 



  

    

    

have devoted to this case to date, "the case is remanded to the 

district judge for a determination of appropriate compensation   for work performed since its March 2 order." 

3. The supplemental award sought includes the following 

legal services: 

a. Melvyn R. Leventhal, 52.75 hours at $100 per hour 

iv 
or $5,275 in fees for the first appeal, and 

2/ 
$410.10 costs. : | 

b. Bill Lann Lee, 24.1 hours at $75 per hour or 

$1,807.50 in fees for the appeal decided October 5, 

3/ 
~ / 

1978, and $143.40 in costs. 

The total of fees is $7,082.50; the total for costs is $553.50; 

  

4/ 1, 
kJ — kw, | W te c — ~~ Fa ~~ 3. T o fe 

and the grand total is $7,635.00 through this date. 

by ooih id 4 
CONCLUSION 

! 

For the above reasons, the supplemental motion for an award For the rea sc a pplemental motion for an Y 

Respectfully submitted, 
4 7} 7 7 f 4 

yf & { op 

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i pin, ” 

f A ay 
4 

  

JACK GREENBERG 
BILL LANN LEE 

Suite 2030 

10 Columbus Circle 

New York, New York 10019 

  

+ Poe 1 t 3 a“ -. ve b) - oy a » ®; 

l/ Defendants' original appeal from the March 2, 1976, order was 
8ismissed for lack of an appezalable final order pursuant to 28 

- ; < 3 x f = 1 83 lv El ry 

H.3.0.:8 1291,.563 F.24 722 453th - Civ. 1977), 

0) otion to Amend Judgment, filed January 

attached hereto as Attachment 1. 

3/ See Affidavit of Bill Lann Lee, attached hereto as Attachment 2. 

4/ The number of hours and amount of costs are based on contem- 
poraneously maintained records, which plaintiffs' counsel will be 

happy to supply defendants' counsel on request. | 

  

 



  

  
  

    

FRED L. BANKS, JR. 

318 East Pearl Street 

Jackson, Mississippi 39205 

Attorneys for Plaintiffs [||68ce9340-88e6-4c04-a3f0-601685b8aefc||]