Statement of Time Spent, Expenses Incurred and Fees Received by Plaintiffs' Counsel

     [||6767d896-6492-4974-a03b-baf0d7d62735||] UNITED STATES DISTRICT COURT 

FOR THE 

WESTERN DISTRICT OF NORTH CAROLINA 

CHARLOTTE DIVISION 

  

  

JAMES E. SWANN, et al., 

Plaintiffs, 

CIVIL ACTION 

v. NO. 1974 

THE CHARLOTTE-MECKLENBURG 

BOARD OF EDUCATION, et al., 

Defendants. 

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STATEMENT OF TIME SPENT, EXPENSES 
INCURRED AND FEES RECEIVED 
BY PLAINTIFFS' COUNSEL | 
  

Plaintiffs, .by their undersigned counsel, hereby submit 

a statement of time spent, expenses incurred and fees received 

! by plaintiffs’ counsel in support of their pending motions that 

counsel fees and litigation expenses be taxed as costs in con- | 

| nection with the above-styled case. 

i 1. Introduction. 
  

This document is filed in support of plaintiffs' pre-   
' vious motions that counsel fees be taxed against the defendants 

as costs. The following sections set out in detail the amount 

of time spent, the expenses incurred and the fees received by 

plaintiffs' counsel. This section explains who the lawyers have 

been, the effect of this litigation on their practice while the 

case was in active litigation and the sources of information con- 

tained tn. the following section. 

Julius LeVonne Chambers has been the chief counsel for 

the plaintiffs from the time suit was filed in 1965; he continues 

to be plaintiffs' chief counsel at the present. 

 



  

When the suit was first filed Chambers practiced alone 

in Charlotte, North Carolina. He received some assistance with 

the case from attorneys employed by the NAACP Legal Defense and 

Educational Fund, Inc. in New York City during the initial trial 

and appeal in 1965 and 1966. 

Chambers organized the law firm of Chambers, Stein, 

Ferguson & Lanning at about the time the Motion for Further 

Relief was filed in this case in September, 1968. Each of his 

partners has worked on the case at one time or another since 

then and has regularly consulted with him Eomuoviing the case. 

Since May, 1969, Adam Stein, a partner in the firm of 

Chambers, Stein, Ferguson & Lanning, has actively participated 

in all subsequent phases of the case. 

During several periods, Chambers and Stein have devoted 

almost all of their time to the ma For AborE six veoks in 

March and April of 1969, Chambers worked nearly exclusively on 

| the case. For another six weeks extending through June, July and 

August of 1969, Chambers and Stein spent nearly all of their time 

with the case. From February, 1970, until the case was argued 

in the United States Supreme Court in October, 1970, Clianbers and 

Stein worked on the case almost to the exclusion of all other 

matters. 

James M. Nabrit III, the associate general counsel of 

the NAACP Legal Defense and Educational Fund, Inc. of New York 

City, began assisting Chambers and Stein with the case on a nearly 

fulltime basis beginning in March, 1970. The actual work on the 

case has thus been performed by Chambers, Stein and Nabrit and, to 

a lesser extent, by other members of the Chambers, Stein,Ferguson 

& Lanning firm. However, other lawyers knowledgeable in civil 

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‘rights and school desegregation litigation were consulted from 

time to time about various aspects of the case. This has included 

Tack Greerberd, the Director-Counsel of the NAACP Legal Defense 

and ddiastrional Fund, Inc., Charles Stephen Ralston, the Assist- 

ant Counsel and Norman Chachkin, who supervises the Fund's school 

desegregation program. Also, during the Supreme Court phase of 

the case, they consulted at some length with Professor Anthony 

G. Amsterdam of the Stanford Law School, an expert in constitu- 

tional litigation. 

The following section indicates a statement of the 

amount of time spent by plaintiffs' counsel on this case. The 

"time assigned for each aspect of the work done represents our 

best estimate. No time sheets were kept because the fee arrange- 

ments between the Legal Defense Fund and Chambers, Stein, Ferguson 

& Lanning are not on an hourly basis and because Nabrit is on 

salary with the Legal Defense Fund and does not regularly maintain 

time sheets. The estimates are based upon our review of our files, 

calendars and the bookkeeping records maintained by Chambers, Stein, 

Ferguson & Lanning and by the Legal Defense Fund. The time shown 

does not reflect the very many hours spent on the case consulting 

with individuals and groups in the community, in person and on 

the telephone. It does not reflect the many formal and informal 

conferences among plaintiffs' counsel. It does not reflect all of 

the many conferences conducted by the court with counsel for all 

the parties. It is, therefore, for the most part, an estimate of 

time spent in the more formal legal matters involved with the case 

and excludes the enormous demands on the lawyers' time in less 

of the class of black parents and students in this case. 

 



  

  

Spent Fee Received 
  

  

1X1. Attorneys' time and fees received.’ 

Date Tim 

l. 8-4-68 Conferences with Charles 
thru Green concerning demo- 

8-26-68 graphic study of Mecklen- 
burg County; collection of 
information concerning zon- 

ing, city planning, govern- 
mentally-assisted housing, 
and information concerning 
the racial distribution of 
students and teachers in the 
schools, student assignment 
plans, the kinds of programs 
and facilities at the various 
schools; and preparation of 
Motion for Further Relief 
filed on September 8, 1968 

2. 9-8-6858 Preparation of plaintiffs’ 
thru interrogatories 

. 9=10=-68 

3. 10-4-68 Preparation of response to 
defendants' motion for ex- 
tension of time 

4. 11-15, Preparation of plaintiffs’ 
12-9,10, Answer to Defendants' In- 

11,17,18,terrogatories filed on 

1968; January 9, 1969 
1-6,7,.8, 
1969 

5... 1-21-69 Hearing on motion by plain- 
tiffs for an order to take 

depositions of officials and 
officers of the school board 

6. 1-22 thru Conferences with Drs. Finger, 
22,27,28,-Passey and Larsen concerning 

1969 development of desegregation 
proposals and analysis of the 
school system. 

7. 1-22,25, Preparation for and depositions 
26,27,28,0f school board employees filed 
29-1969 on March 10, 1965. 

8. 1-31-68 Preparation of interrogatories 
thru addressed to defendants. 
2—-3-69 

1/ The "fees received" are from the NAACP Le 

~ Educational Fund, Inc. This applies only 
Cha rs, Stein, Ferguson & Lanning; Jame 
is .a salaried employee of the Legal Defen 

$125.00 80 hrs. 

8 hrs. 

l ar. 

8 hrs. 

3 hrs. 125.00 

24 hrs. 50.00 

22 ‘hrs. 250.00 

5 hrs. 

gal Defense and 

to work done by 
Ss MM. Babrit III 

se Fund. 

 



  

Date Time 

  

Spent Fee Received 
  

9. 2-20 thru Trip to New York to confer 

2-22-69 with educational experts 

concerning additional testi- 

mony about the effects of 

segregation, an analysis of 

the Charlotte-Mecklenburg 

school system and desegrega- 

tion proposals in preparation 

for trial. 

10, 2-27,28 Preparation of plaintiffs’ 

and answer to defendants' in- 

3-3-69 terrogatories filed on 

3-3-69. 

Preparation of plaintiffs’ 
further interrogatories 

to defendants. 

Il. 3-669 Preparation of plaintiffs’ 

further answer to defendants’ 

interrogatories. 

12. 3-7 thru Preparation for trial including 

3-9-69 conferences with Charles Green, 

Daniel Hennigan, Paul Leonard, 

Jack Larsen, John Finger and 

Robert Pasey. iy Es 

13. 3-10-69 Beginning of hearing on plain- 

tiffs' Motion for Further Re- 

lief and preparation for fol- 

lowing day's hearing. 

14. 3-11-69 Continuation of hearing and 

preparation for hearing the 

following day 

15. 3-12-69 " » 

16. 3-13-69 Continuation of hearing. 

. 3-15,16-Tour of the city with and con- 

1969 ferences with City Planner, 

Yale Rabin. 

18. 3-17-69 Case re-opened for the testi- 

mony of Yale Rabin. 

19. 3-18 thru 
21,1969 Preparation of plaintiffs’ 

proposed findings of facts, 

conclusions of law and brief. 

20. 3-26-69 Hearing re-opened for the 

testimony of William McIntyre. 

14 

22 

2 

12 

12 

12 

12 

18 

hrs. $100.00 

hrs. 

hrs. 

hrs. 

hrs. 75.00 

hrs. 325.00 

hrs. 125.00 

hrs. 125.00 

hrs. 125.00 

hrs. 

hrs. 

hrs. 

hrs. 125.00 

 



  

1 

22. 

23, 

24. 

1.25, 

26. 

27. 

28. 

  

6-10-69 

6-9 thru 

6-12-69 

fG=13+69 

6-16-69 

6-14,15- 
1969 

Time Spent Fee Received 
  

Preparation of motion for 
temporary order restraining 
the school board from ini- 
tiating or continuing con- 
struction of new schools with- 
out prior approval of the court 
because of the failure of the 
board to comply with the pre- 
vious order of the court and 
the pendency of new construction 
plans. 4 hrs. 

Hearing on motion with respect 

to production of documents. 4 hrs. 

Preparation of plaintiffs’ 

response and objections to de- 
fendants' desegregation plan 
as entirely inadequate and 
motion for civil contempt on 
the ground that the board had 
disobeyed the order of April 
23, 1969. ; 8 hrs. 

Conference in chambers with 

court. 4 hrs. 

Preparation of response to de- 
fendants' motions to strike  ° 
additional parties defendant. a - NES. 

Preparation for hearing and 

conference on desegregation 
plan. 8 hrs. 

6-16 thru Hearing on desegregation plan 
6- ~18~ 1969 and motion of individual board 

members to set aside order en- 
joining them as additional de- 
fendants, including conferences 
and preparation on the evenings 
of June 16 and 17. 30 hrs. 

7-14 thru Preparation of motion for leave 
7-21-1969%to file supplemental complaint, 

to add additional defendants 
and for temporary restraining 
order, and brief, and proposed 
supplemental complaint attack- 
ing as unconstitutional and 
obstructive of previous orders 
in the case of the recently en- 

acted Anti-Bussing Law. 24 hrs, 

$5125.00 

125,00 

500.00 

375.00 

 



  

Date 

  

Time Spent Fee Received 
  
  

79, 7-29 thru Analysis of defendants’ 

30. 

31. 

32. 

33. 

35. 

36. 

8-4-69 

8~-5,6~ 

69 

8-13 

thru 

8-15-69 

8-30,9-1, 

2-69 

9-10,11- 
1969 

10-29,30, 
li~-1,2~- 

69 

11-19 

thru 

11-21-69 

amended desegregation 

plan and report filed in 

connection therewith and 

preparation for hearing. 10 hrs. 

Hearing on amended plan. 12 hrs, £250.00 

Preparation of plaintiffs’ 

response to intervene filed 

by Paw Creek patrons.’ 5 hrs. 

Preparation of Motion. for 

Further Relief and for an 

order directing the defendants 

to show cause why they should 

not be held in contempt for 

failing to implement. the order 

of the court of August 15,1969, 

approving the board's amended 

desegregation plan. 8 hrs. 

Conference in New York with 

educational consultant and 

Yale Rabin regarding addi- 

tional evidence needed in 

preparation for case for 

further hearing. ni ; eg 6 hrs. 

Preparation of plaintiffs’ 

response and objections to 

defendants' motion for an ex- 

tension of time to file the 

desegregation plan and a re- 

quest by plaintiffs that the 

court appoint an educational 

consultant to prepare an ade- 

quate desegregation plan be= 

cause of the default by the 

defendants in preparing one 

of their own. 4 hrs. 

Conference and preparation of 

plaintiffs’ response and ob- 

jection to defendants’ motion 

for an extension of time and 

motion for further relief. 4 hrs. 

Preparation of and research 

for plaintiffs' response and 

objection to defendants’ 

amendment to plan for further 

desegregation of schools, claim- 

ing total default by the school 

board in obeying previous orders 

of the cout and requesting that 

the court reject the defendants’ 

plan, appoint an expert to pre- 

pare a plan at t 

v
O
 e 

+ 

 



  

Date Time Spent Fee Received 
    

the defendants, enjoining 
further school construction, 
order each of the defendants 
to show cause why he should 
not be held in contempt and 
award plaintiffs costs in- 
cluding attorney fees. 8 hrs. 

37. 1-15,16, Preparation of motion for the 
18 thru immediate desegregation of the : 
1-20-70 public schools requesting that 

the Finger plan be filed 
promptly and be implemented at 
once in conformity with decisions 
of the United States Supreme 
Court and the United States 
Court of Appeals for the Fourth 
Circuit. 6 hrs. $125.00 

38. 1-29 Conferences in preparation 
thru for hearing on the Finger 
1-31-70 plan. 5 hrs. 

32. 2=2-70 Hearing on plaintiffs' motion 
: for immediate desegregaton 

and conferences with the 
court. ed 12 hrs.* 125.00 

i 40. 2-4-70 Preparation for hearing on 
I desegregation plans. 7 hrs.* 

i 41. 2-5-70 Hearing on desegregation 
1 plans. 6 hrs. * 200.00 

42. 2-9 thru Preparation of motion to 
2-13-70 add Tom B. Harris and others 

who were plaintiffs in a state 
court proceeding, their attor- 

ney, William J. Booe, and Super- 
ior Court Judge McLean who had 
entered an order on their behalf 
enjoining the school board from 
spending money to operate a 
transportation system as directed 

by this court; to add the Governor, 
and the controller of the State 
Department of Public Instruction 
as defendants and because they 
had threatened to withhold state 

sary to implement 
f this court and for 
training them and all 

cdants from interfering 
rs of the court and 

the orders 

a motion 

other defe OI 

  

*This represents time spent by Chambers and Stein. The additional 
work done by more than cne lawyer prior to this time has not been 
stated. Hereafter, where Chambers and Stein both were involved 
with work on the case and the time of both of them is counted, 

an asterisk will appear after the number of hours shown. 

 



  

Date Time Spent Fee Received 

  

  

failing to implement the 
orders of the court, 12 hrs.* 

43. 2-20-70 Trip to Raleigh to take the 

deposition of officials of 
the State Board of Education. 7 hrs. $125.00 

44, 2-23 thru 
2-25-70 Preparation for and taking of 

depositions of Morgan, Self, 
and E. D. McMillan, Jr. 14 hrs.* 

45, 2-26,27- Preparation of motion to add: 
70 as parties defendant Mrs. 

Robert Lee Moore and other 
plaintiffs in a suit brought . 
in the Superior Court of 
Mecklenburg County, attorney 

Whiteford S. Blakeney and 
Superior Court Judge Frank 
Snepp, who entered an ex party 
order on Sunday evening, Febru- 
ary 22, purporting to enjoin 
the school board from putting 
into effect the prior orders of 
this court and moving that the 
state court order be. set aside, 
and seeking further relief from 
efforts by these persons and 
other defendants from continued 
interference with the orders 
of this court. 8 hrs.* 125.00 

46. 2-27-70 Preparation of motion for tem- 
porary restraining order and 
for contempt and affidavit in 
support thereof, further seek- 
ing orders protecting the rights 
of the plaintiffs as previously 
declared by the court. 6 hrs.* 

47. 2-27-70 Preparation of plaintiffs' re- 
quests for admissions. 4 hrs.* 

48. 2-29-70 to 
3-2-70 Preparation of proposed find- 

ings of fact, conclusions of 
law and brief with respect 
to the North Carolina Anti- 

Bussing Statute. 12 hirs. 

49. 3=1 §& 2, i is 12 hrs. 

1970 

50. 3-2 & 3, Preparation of plaintiffs' op- 

1970 position to defendants' ap- 
rlication for stay addressed 
to Judge Craven. 12 hrs.* 125.00 

 



  

Date Time Spent Fee Received 

  

  

51. 3-370 Preparation of plaintiffs’ 
opposition to defendants’ 
application for stay ad- 
dressed to Judge.Craven. 6 hrs. 

(Nabrit) 

52. 3=2=70 Preparation of plaintiffs’ 
brief in support of their 
motion for temporary re- 
straining order and for con- 
tempt and attorneys' con- 
ference with court. 6 hrs.* 

53. 3=4~70 Preparation of plaintiffs’ 
list of additional exhibits 
and proposed evidence. 6 hys.* 

54. 3-6 thru Preparation of application to 
3-99-70 the United States Supreme 

Court to vacate partial stay 
order entered by the Court 
of Appeals on March 5, 1970. 35 hrs. * $400.00 

55. 3-4-70 n n 18 hrs. 
(Nabrit) 

56. 3-9-70 Preparation of notice of, 
deposition of James H..Car- 

son, Dr. Finger and J. D.~ 
Morgan. : 1 hr. 

57. 3-11-70 Preparation of plaintiffs’ 
response to defendants' motion 
to quash subpoena and taking 
J. D. Morgan's deposition and 
hearing. 4 hrs. 

58. 3-11-70 Taking of deposition of J. D. 
Morgan. 4 hrs. 125.00 

59. 3-11-70 Taking of deposition of John 
A. Finger. 5 hrs.* 

60. 3-11-70 Taking of deposition of James 

HE. Carson, Jr. 4 hrs.* 

61. 3-12-70 Negotiation for and preparation 
of stipulations by the plain- 
tiffs and State Superintendent 
of Public Instruction, 4 hrs. 

po
 

3-13 thru 

3-16-70 Plaintiffs' prepara 
submission of additional data 

and exhibits and at 

conferences with t 

aN
 

he court. 32 hrs. * 250.00 

53. N ” " 18 hrs. 

- 
-10- 

 



  

64. 

65, 

66. 

67, 

68. 

69. 

70. 

fot. 

72. 

73. 

74. 

J
 

(8
) 

* 

Date Time Spent Fee Received 
  

3-18-70 Preparation of a list of 
additional exhibits and 
hearing on defendants’ 
objections thereto. 

3-18,19, 
1970 

Preparation for and taking 
deposition of J. D. Morgan 
with respect to the school 
board's transportation 
estimates. 

3-22 thru Preparation of plaintiffs’ 
3-24-70 memorandum of additional 

points of authority for hear- 
ing on the constitutionality 
of the Anti-Bussing Statute, 
preparation for hearing and 
hearing, and attorneys' con- 
ferences with the court. 

(Nabrit) 

Conference in chambers with 
opposing counsel, District : 
Court Judge and Judge Craven. 

3-25-70 # " 

3-26-70 Preparation of opposition 
to defendants' renewed 
motion for stay of District 
Court order. 

3-26-70 Preparation of notice of 
appeal from District Court's 
stay order. 

3-27-70 Preparation of motion in the 
Court of Appeals to strike 
defendants' appeals from all 
orders prior to February 5, 
1970. 

3-27,28- 
1970 

Preparation and conferences 
concerning appendix on 
appeal. 

3-30 f£hru 
4-6-70 Preparation of plaintiffs" 

brief on appeal in the 
United States Court of 
Appeals. 

n" n 

Preparation for and argument 
in the United States Court 
of Appeals in Richmond. 

6 hrs.* $100.00 

20 hrs.* 

50. hrs.* 375.00 

18 hrs. 

6 hrs.* 

6 hrs. 

(Nabrit) 

12 hrs.* 150.00 

1 hr, 

3 hrs, 

6 nrs. 125.00 

110 hrs.* 1,000.00 

48 hrs. 
(Nabrit) 

40 hrs.* 400.00 

 



  

37. 

78. 

79. 

80. 

81. 

82. 

83. 

84. 

85. 

86. 

  

6-2 and 

6-33-70 

6-1 thru 

6-33-70 

6-8 thru 

6-12-70 

6-11 thru 

6-15-70 

6-16 and 

6-17-70 

‘6-8 thru 

6-17-70 

7-6 and 
7-70 

7-8 and 

7-10-70 

7-15 thru 

7-17-70 

7-20 thru 

F=24=70 

Time Spent Fee Received 
  

Preparation for and argument 

in the United States Court 
of Appeals in Richmond. 18 hrs. 

(Nabrit) 

Preparation on petition 
for writ of certiorari. 16 hrs. 

mn n 

18 hrs. 
(Nabrit) 

y Ji : 44 hrs. 

(Chambers) 

" y 40 hrs. 

(Stein) 

y n 16 hrs. 
(Stein) 

+ 3 80 hrs. 
(Nabrit) 

Preparation of plaintiffs’ i 
response to the defendants’ 
submission pursuant to the 
order of the Court of 
Appeals. : 8 hrs. 

Preparation for and taking 

of deposition of John P. 
Cross and Henry L. Kemp, 

author of the HEW plan; of 
Dr. Carleton Watkins, author 
of the board minority plan; 
of William E. Poe, chairman 

Of the school board; of J. D, 
Morgan, the official respon- 
sible for bus transportation; 
and of Dr. William Self, the 
superintendent of schools. 40 hrs.* 

Preparation of appendix for 
Supreme Court. 16 hrs. 

: (Nabrit) 

" n i4 hrs. 

(Nabrit) 

lans. 72 hrs. 

(Chambers) 

20. hrs, 

(Stein) 

50 hrs. 

(Nabrit) 

-12- 

paratlior xX 

on desegregation plans. 20 hrs.* 

$125.00 

300.00 

250.00 

250.00 

50.00 

350.00 

700.00 

 



  

99. 

91. 

92. 

23. 

94. 

95, 

96. 

i 97. 

98. 

99; 

100. 

101, 

102. 

Date 

  

7-25 thru 

7-31-70 

7-28 thru 
7-31-70 

8-14 and 

8-15-70 

8-20,21- 
70 

8-21 thru 

8-23-70 

§=22 & 
8-23-70 

9-8 thru 

9-10-70 

9-10 thru 

9-28-70 

§~23:thiy 
9=25=70 

8-21 thru 

9-28-70 

9-24,25- 
70 

Preparation of brief on 
the merits for United 

States Supreme Court. 

Preparation of brief on 
the merits for United 
tates Supreme Court. 

Preparation and filing of 
motion in opposition to 
defendants' application for 
stay in the United States 
Court of Appeals. 

Examination of the record in 

the Supreme Court and con- 
ferences with the Clerk with 

reference to order and time 

for argument. 

Preparation of memorandum 
in opposition to defendants’ 
application for stay in the 
United States Supreme Court. 

n n 

Preparation of motion to 
affirm or dismiss in North 

Carolina State Board of 

Education v. Swann (the Anti- 

Bussing Statute case) 

Preparation of reply brief 

in the United States Supreme 
Court. 

Preparation of reply brief 
and preparation for argu- 

ment. 

Preparation of plaintiffs? 
response to board's interim 
report 

-13- 

Time Spent Fee Received 
  

60 hrs. 

(Nabrit) 

64 hrs.* 

30 hrs. 

16 hrs. 

2 hrs. 

6 hrs. 

(Nabrit) 

18 hrs. 

16 hrs. 

(Nabrit) 

20 hrs. 

(Nabrit) 

48 hrs. 

(Nabrit) 
30 hrs. 

(Chambers) 

45 hrs. 

(Stein) 

4 hrs.* 

$375.00 

600.00 

250.00 

200.00 

400.00 

300.00 

  

 



  

Date Time Spent Fee Received 
  

  

103.9~-30 thru 

10-4+0 Preparation for argument in 

109.10-9 thru Assisting Chambers and Nabrit 

10-13-70 in preparation for argument in 

the United States Supreme 

Court. 

110.4-15-71 Preparation of plaintiffs! 

interrogatories. 

111.5-5. & 6, Preparation of motion for 

-71 further relief. 

112.5-12 to Preparation and investigation 

5-14-70 for hearing on June 2, 1971 

5=17: Lo 

5-20-70 
5-25 &. 
26,1970 

113.6-2-71 Conference 

ld 

the Supreme Court. 50 hrs. 625.00 

104.9-30 thru 

10~2~70 Preparation of reply brief 27 hrs. 700.00 

(Stein) 

105.9-28 thru 

10~5~-70 "Preparation of brlef on 

the merits - North Caro- 

lina Board of Education 

v. Swann. 60 hrs. 
(Nabrit) 

106.10-6 thru 

10-9-70 Preparation for argument in 

the Supreme Court in .North 

Carolina Board of Education 

v. Swann. 30 hrs. 
(Nabrit) 

107.10-7 thru Preparation for agument and 

10-13-70 argument in the Supreme 

Court in Swann v. Charlotte- 

Mecklenburg Board of Educa- 

tion. 60 hrs. 
(Chambers) 

' 108.10-9 thru Preparation for argument; 

10-13-70 argument in the United States 

Supreme Court in Swann V. 

Charlotte-Mecklenburg Board 

of Education and North Caro- 

lina Board of Education Vv. 

Swann. 50 hrs. 
(Nabrit) 

56 hrs. 300.00 

(Stein) 

3hrs.* 

3 hrs.* 

18 hrs.* 

3 hrs. 

 



  

Date 

114.6-10 thru 
6-17-71 

115.6=-17¢% 
6-18-71 

116.6-21 thru 

6-24-71 

117.6-28-71 

118.10-20-71 

thru 

10-22-71 

119.11-1 thru 
11-13-71 

120.12-29,30- 
71 and 

1-3 thru 
1-5-72 

Time Spent Fee Received 
  

  

15 
po Sea J 

a 
to board's proposed plan. 12 hrs.* 

Hearing on board's proposed 
plan. 18 hrs.* 

Review and preparation for 
hearing on amended plan. 12 hrs.* 

Hearing. 6-hrs.* 

Trip to New York for prepara- 
tion of brief on appeal to 
the United States Court of 
Appeals for the Fourth 
Clrouit., + 10-hrs.* 

Preparation of brief on : 
appeal. 40 hrs.* 

Preparation for argument 
and trip to Richmond for 
argument in Fourth Circuit 
Court of Appeals. 18 hrs. 

Total a 2,340 hrs. 

  

$300.00 

200.00 
  

$12,750.00 

 



  

  

Fee for Charles Green to conduct 

demographic study of Charlotte 

Fee for expert witness, Yale 

Rabin, City Planner, for his 

analysis of the city and his 

testimony in the case. 

Travel expenses for Yale Rabin. 

Fee for educational consultant 

and witness, Dr. Jack Larsen, 

for analysis of the school sys- 

tem, development of desegregation 

proposals and testifying at hear- 

ing. ; 

Travel expenses for Dr. Jack 

Fee for educational consultant 

and witness, Dr. Robert Passey, 

for analysis of the school sys- 

tem, development .of desegregation 

proposals and testifying at hear- 

Travel expenses for Dr. Robert 

III. Litigation Expenses. * 

l1. 7-10/68 

2. 1968-1969 

3. 1968-1969 

4, 1-3/69 

5. 1-3/69 

Larsen. 

6. 1=3/69 

ing. 

7 1-3/69 

Passey. 

8. 1-3/6%9, 3/70 

11, 

12. 

& 7/70 

1/22-24/69 

3/9/69 

3/9/69 

3/12-13/69 

Fee for educational consultant, 

and witness, Dr. John Finger, 

for analysis of the school system 

development of desegregation pro- 
posals and testifying at hearing. 

Travel expenses for Dr. Finger. 

Travel expenses for educational 

experts in Charlotte. 

Travel expenses for educational 

experts in Charlotte. 

Duplicating expenses for exhibits 

Duplicating costs for exhibits. 

  

or 

$ 2,400.00 

400.00 

161.71 

1,875.00 

333.05 

1,475.00 

427.60 

2,200.00 

1,240.30 

17.40 

14.68 

17.60 

28.32 

All of the expenses shown in this section were either paid by 
reimbursed by the NAACP Legal Defense and Educational Fund, Inc. 

-16=- 

  

 



  

14. 3/9-13/69 Expenses for conducting tour of 

the schools for educational | 

consultants. 75.92 

15. 3/15-16/69 Expenses in touring Charlotte 

with City Planner, Yale Robin 20.67 

16. 3/21/69 Rental of calculator to prepare 

exhibits and briefs in connection 

with hearing. 19.76 

17. 3/21/69 Payment to Court Reporter for 

depositions taken in connection 

with hearing. 522.90 

18. 4/30/69 Payment to Court Reporter for 

transcript of hearing.’ 509.25 

19, 6-11-69 Witness fees paid for hearing 

on that date. 180.00 

20. 6-12-69 Witness fees paid for hearing 

on that date. 140.00 

21. 6/16-19/69 Xerox costs for plaintiff's sub- 
missions filed with the Court. 24.00 

22. 7/9-10/69 Trip to New York (Chambers) con- 
ferences concerning preparation 

of supplemental complaint attack- 

ing anti-busing statute. 113.59 

23. 6/22/69 Payment to Marshal for service 
of subpoenas. 31.40 

24. 71/25/69 Payment to Court Reporter for 

transcript of hearing in June, 
1969. 482.80 

25... 8/11/69 Payment to Marshal for service 
of subpoenas in connection with 

hearings in August, 1969. 16.00 

26. 9/11/69 Payment made to Court Reporter 
for transcript of August, 1969 

hearing. 72.75 

27. “1/15/70 Xeroxing of material in connec- 

tion with hearing. 10.00 

28. 2/13/70 Xeroxing of state law suit brought 

by Concerned Parents Association. 23.50 

 



  

°9, 

30, 

31, 

32. 

33. 

34. 

35. 

36. 

I 37. 

38. 

39. 

40. 

41. 

42. 

2/20/70 

2/20/70 

3/1/70 

3/3-4/70 

3/3/70 

3/5/70 

3/6-9/70 

3/9/70 

3/10-15/70 

3/10-15/70 

3/10-15/70 

3/16/70 

3/16/70 

3/17-18/70 

Travel expenses in connection 

with trip to Raleigh to depose 

Mr. Dark concerning transportation. 

Air fare to Raleigh. 

Air fare New York - Charlotte, 

Nabrit. 

Expenses incurred in trip to 

Richmond, Virginia, to file re- 

sponse in opposition to defend- 

ants' application for stay. 

Xeroxing of opposition to appli- 

cation for stay. 

Payment to Court Reporter for 
transcripts of depositions taken 

for and introduced at February 

1970 hearings. 

Travel expenses in connection with 

trip to New York to prepare appli- 
cation for vacation of stay, 

Chambers and Stein. 

Witness fees paid for depositions 
taken on March 11. 

Xerox costs for preparation of 

charts and exhibits for hearing. 

Additional secretarial assistance. 

Purchase of maps from city. 

Payment to Marshal for service of 
subpoenas. 

Payment to Court Reporter for trans- 

cripts of depositions used at 

hearing. 

Transportation costs in connection 

with trip to Chapel Hill to secure 

information from library concerning 

state and national school trans- 

portation statistics. 

-18- 

60.02 

35,70 

96.60 

120.00 

520.00 

300.20 

357.05 

48.00 

300.00 

105.00 

249.00 

57.84 

 



  

43. 3/16-19/70 Reproduction of exhibits supplied 

by the state board of education 

introduced at hearing. 600.00 

24. 3/23-25/70 Xeroxing of submissions to the 

Court. ; 20.00 

a5... 3/26/70 Xeroxing of opposition of motion 

for stay. 
30.00 

46, 3/27-4/6/70 Additional secretarial expenses 

for preparation of expedited brief 

in Court of Appeal. 204.85 

a7. 4/1/70 Charlotte - New York air fare - 

Nabrit. : : 107.10 

48. 4/1/70 Air fare Charlotte to Richmond - 

Chambers. 
25.20 

49, 4/7/70 Air fare New York to Richmond - 

Nabrit. 
54.60 

50. 4/9/70 Air fare Richmond to New York 

City - Nabrit. ° 54.60 

51. 4/7-9/70 Travel and hotel expenses in 

Richmond in connection with argu- |] 

ment in the Court of Appeals, 2 

Chambers and Stein. 283.04 ; 

52. 4/13/70 Payment to Court Report for 

transcript of deposition for 

March hearing. 40.60 

53. 4/13/70 Payment to Marshal for service of 

subpoenas for March hearing. 12.00 

54, 4/14/70 Payment to Court Reporter for trans- 

cript of depositions taken in con- 

nection with March hearing. 249.10 

555 6/1/70 Air fare Charlotte to New York, 

Chambers, for petition for Writ . 

of Certiorari to the U. S. Supreme 

Court. 86.10 

56. 6/1-3/70 Expenses for meals and lodging 

in New York - Chambers. 120.76 

 



  

57. 

58. 

59. 

60. 

1601 

62. 

63. 

64. 

65. 

67. 

6,/8-12/70 

6/11-15/70 

6/16-=17/70 

7/8/70 

7/13/70 

7/13-17/70 

7/13/70 

7/28-31/70 

7/30/70 

8/4-8/70 

8/11-12/70 

Air fare, meals and lodging in 

New York in connection with pre- 

paring petition of Writ of 

Certiorari - Stein. 

Air fare, meals and lodging in 

Yew York in connection with pre- 

paring Petition for Writ of 

Certiorari - Chambers. 

Air fare, meals and lodging in 

New York in connection with pre- 

paring Petition for Writ of 

Certiorari - Stein. 

Xeroxing of exhibits for. July 

hearing. 

Payment to Dr. Finger for travel 

expenses to attend deposition. 

Xeroxing costs of additional 

exhibits for hearing. 

Air fare New York. - Charlotte, 

Nabrit. % 

Air fare, meals and lodging in 

New York in connection with pre- 

paration of brief for the United 

States Supreme Court - Chambers, 

Stein. 

Payment to Court Reporter for 

transcripts of depositions used 

at July hearing. 

Air fare, meals and lodging in 

New York in connection with pre-~ 

paration of brief for United 

States Supreme Court, Chambers, 

Stein. 

Air fare, meals and lodging in 

New York in connection with pre- 

paration of brief for the United 

States Supreme Court, Stein. 

-20- 

170.80 

187.10 

650.50 

116.03 

136.00 

48.53 

90.00 

350.87 

354.20 

798.36 

498.76 

 



  

69. 

70, 

71. 

22. 

73. 

74. 

75. 

76. 

78. 

8/20-23/70 

8/20-23/70 

9/23-25/70 

9/23-25/70 

9/21-28/70 

9/28/70 

9/30-10/4/70 

9/30-10/2/70 

10/7-14/70 

10/9-14/70 

10/9-14/70 

Air fare, meals and lodging in 

New York in connection with pre- 

paration of memorandum in oppo- 

sition to stay in the United 
States Supreme Court (Stein), 

Meals and lodging, Chambers. 

Air fare to New York - Chambers. 

Trip to New York for preparation 

of reply brief for the U. S. 

Sux eme Court - Chambers. 

Air fare to New York - Chambers. 

Air fare, meals and lodging, New 

York, for preparation of reply 

brief in Swann v Charlotte-Meck- 

lenburg and respondent's brief 

in N. C. State Board of Education 
v Swann, Stein. 

Payment to Court Reporter for 

transcript of proceedings of 

July hearings. : 

Trip to New York in preparation 
for arguments in Supreme Court, 
air fare, meals and lodging, 
Chambers. 

Trip to New York in connection 
with work on briefs and arguments, 
air fare, lodging, Stein. 

Trip to Washington, D. C. for 

preparation of arguments in the 

U. S. Supreme Court, air fare, 

meals and lodging - Chambers. 

Trip to Washington, D. C. in 

preparation for arguments in the 

U. S. Supreme Court, Nabrit, 

air fare 

Trip to Washington, D, C. to 

assist Chambers and Nabrit in pre- 
paration of arguments in the U. S. 

Supreme Court - Stein. 

-21- 

251.08 

86.10 

252.63 

86.10 

563.28 

945,20 

197.10 

247.88 

614.22 

48.00 

338.69 

B
T
 

—
—
—
—
 

  

 



  

79, 5-20 thru Costs for duplication and 
6-22-71 preparation of exhibits. S$. 86.96 

80. 11-6 thru Printing of record and brief and 
11-14-71 docketing fee in the Fourth Cir- 

cuit and cost bond con appeal. 1,527.08 

81. " Fee for certification of record 
to United States Supreme Court. 215.80 

82. 3-1 to 3-3,Travel by James M. Nabrit III 
3-14 to to and from Charlotte. 126.69 

3-16 and 
3=22 to 
3-24-70 

83. 4-1 to 4-6,Travel by James M. Nabrit III 
4-8 to 4-9,from Charlotte to Richmond   

  

1970 and return. : 216.64 

i! 84. 4-3 to 
4-7-70 Travel by James M. Nabrit III 

to and from Charlotte. B7.82 

85. 7-13 to Travel by James M. Nabrit III 
7-17-70 to and from Charlotte. 380.67 

7=19 to : 
7-24-70 2 

86. 8-21 thru Travel by James M. Nabrit III 
8-24-70 to Washington, D. C. 15.00 

| B87. 10-9 thru Travel by James M, Nabrit 111 
10-12-70 to and from Washington, D. C. 69.00 

| B88. 9=11~70 Travel by James M. Nabrit III | 
to Washington, D. C. 25.00 : 

Total $26,262.88 

Respectfully submitted, 

        

  

LeVonne Chambers 
Chambers, Stein, Ferguson 

& Lanning 
237 West Trade Street 

Charlotte, North Carolina 

-22- 

 



  

  

VERIFICATION 
  

Julius LeVonne Chambers, being first duly sworn, deposes 

and says that he has read the foregoing Statement of Time Spent, 

Expenses Incurred and Fees Received by Plaintiffs' Counsel; that 

he knows the contents thereof and that the same are true except 

as to those matters alleged on information and belief, and as to 

those, he believes them to be true. 

EM ATE 
/ Arfiant 
  

Subscribed and sworn to before me this #7]. day of 

January, 1972. 

My commission expires: LE ad gl /2ZS . 
  

  

4 i ¢/ 4 vd ) A 
oO 

 



  
  

VERIFICATION 
  

Adam Stein, being first duly sworn, deposes and says 

| that he has read the foregoing Statement of Time Spent, Expenses 

Incurred and Fees Received by Plaintiffs' Counsel; that he knows 

the contents thereof and that the same are true except as to 

those matters alleged on information and belief, and as to those, 

he believes them to be true. 

  

~~xTriant 

Subscribed and sworn to before me this ///7day of 

January, 19172. 

  
My commission expires: Loietisrud ZL . 

Ll il 
Notary Public 
  

 



  

CERTIFICATE OF SERVICE 
  

The undersigned hereby certifies that he has this 

‘day served a copy of the foregoing Statement of Time Spent, 

Expenses Incurred and Fees Received by Plaintiffs' Counsel 

upon counsel for the defendant by depositing a copy of same 

in the United States mail, postage prepaid, addressed to Mr. 

William J. Waggoner, Waggoner, Hasty & Kratt, 723 Law Building, 

Charlotte, North Carolina. 

This 7th day of January, 1972. 

  

/ "Attorney for Plaintiff [||6767d896-6492-4974-a03b-baf0d7d62735||]