Plaintiffs' Proposed Stipulation of Fact
Public Court Documents
January 1, 1984
Cite this item
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Case Files, Major v. Treen Hardbacks. Plaintiffs' Proposed Stipulation of Fact, 1984. 5a8a07d6-c803-ef11-a1fd-6045bddc4804. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/5df5fd33-5afa-479d-95af-0aaddf43e3a3/plaintiffs-proposed-stipulation-of-fact. Accessed November 05, 2025.
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IN THE UNITED STATES DISTRILT COURY FOR THE
FOR THE EASTERN DISTRICT OF LOUISIANA
BARBARA MAJOR, et al.,
Plaintiffs,
Civil Action No.82-1192
Section §£
DAVID C. TREEN. otc., 61 al.
Defendants.
PLAINTIFFS' PROPOSED STIPULATION OF FACT
Plaintiffs and defendants, through their undersigned counsel
hereby enter into the following stipulation of facts. This
agreed stipulation of facts is entered into solely for the
purposes of this litigation to conserve the resources of the
parties and the Court. The parties hereto stipulate as follows:
1. Both sides could present credible testimony that a
non-contingent hourly rate for an attorney with the experience
and reputation of Mr.Stan Halpin, handling litigation of similar
complexity and novelty as the present, would range from $100 to
$175 per hour in New Orleans, Louisiana.
2. Both sides could present credible testimony that a
non-contingent hourly rate for an attorney with the experience
and reputation of Ms.Lani Guinier, handling litigation of similar
complexity and novelty as the present, would range from $100 to
$175 per hour in New York City.
3. Both sides could present credible testimony that a
non-contingent hourly rate for an attorney with the experience
and reputation of Mr.James Kellogg, Steven Scheckman, and William
Quigley, handling litigation of similar complexity and novelty as
the present, would range from $85 to $150 per hour in New
Orleans, Louisiana.
4. Both sides could present credible testimony that a
non-contingent hourly rate for an attorney with the experience
and reputation of Mr.Armand Derfner, handling litigation of
similar complexity and novelty as the present, would range from
$100 to $250 per hour in Washington, D.C.
5. The parties agree that credible evidence could be
presented which would show that customary legal fees for
attorneys handling cases on a contingent basis in New Orleans,
Louisiana, provide that an attorney for a prevailing plaintiff
should recover from 33% to 50% of the plaintiffs' judgment. The
higher percentage traditionally reflects the increased risk and
complexity of the litigation. Attorneys for prevailing
plaintiffs in contingent litigation not infrequently effective
hourly fees of $20U to $400 per hour and these fees are
considered reasonable in New Orleans, Louisiana for contingent
¥itigasion.
6. The parties hereto agree that the following hours claimed
by the attorneys for the plaintiffs are undisputed:
Attorneys
Stanley Halpin
Lani Guinier
James Kellogg
Steven Scheckman
William Quigley
Armand Derfner
7. The parties hereto agree that the following expenses as
claimed by the plaintiffs in their motion for an award of
attorneys' fees and expenses are undisputed.
Halpin Affidavit:
Guiner Affidavit:
Scheckman Affidavit:
Respectfully submitted this day of October, 1984.
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PLACKSHER, MENFFEE 4 STEIN,
405 Van Antwerp Bldg.
P. 8. Box 105}
Mobile, Alabama 36633
(205) 433-2000
BY:
LARRY T. MENEFEE
Attorney for Plaintiffs
ASSISTANT ATTORNEY GENERAL
234 Loyola Avenue
New Orleans, Louisiana 70112
{504) 568-5675
BY:
PATRICIA BOWERS
Attorney for Defendants
P A.