Correspondence from Winter to Bailey Re: Appellant's Bill of Costs

    egal efenseF■ H u n d NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 
10 Columbus Circle, Now York, N Y 10019 • (212) 586-8397

June 27, 1979

Walter L. Bailey, Jr.
Bailey, Higgs & Bailey 
161 Jefferson Avenue 
Memphis, Tenn. 38103
Re: Garner v . Memphis Police Department
Dear Walter:

Please find enclosed a copy of the Bill of Costs in the 
above noted case. Please contact me as soon as anything de­
velops in the district court on this case. I will be in contact 
with you about any further strategy decisions in the case.

Best regards.
Sincerely,

Steven L. Winter

enclosures 
SW: cw

Cont i  ih i i l ion s  m r  t i r i l i i c t ib i r  fo r  U .S .  in ro n i r  ln\ in i i lu is r s



L i  egal efenseE! NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 
U n d  10 Columbus Circle, New York, N Y. 10019 • (212) 586-8397

June 27, 1979

The Honorable John P. Hehman 
Clerk, United States Court of Appeals 
for the Sixth Circuit 

Cincinnati, Ohio 45202
Re: Garner v. Memphis Police Dept., et. al. Case No. 77-1089
Dear Mr. Hehman:

Please find enclosed a Bill of Costs in the above titled 
case pursuant to the court's opinion of June 18, 1979, and 
Fed. R. App. P. 39(a).

Sincerely,

X.j m i-.- - A l t /  '

Steven L. Winter

enclosure 
SW: cw

Conlrihulions are deductible for U.S. income lax /mr/m.ses



L  egal efenseIf! NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 
V in d  10 Columbus Circle, New York, N Y 10019 • (212) 585-8397

June 27, 1979

Henry L. Klein, Esq.
100 North Main Building 
Suite 3500
Memphis, Tenn. 38103
Re: Garner v. Memphis Police Dept., Case No. 77-1089
Dear Mr. Klein:

Please find enclosed a copy of Appellant's Bill of Costs 
in the above noted case.

enclosures

SW: cw

Sincerely,

-4 ■
Steven L. Winter

( niiliihiilions arr ileiliirlihlr for 11.S. im ontr ta\



IN THE UNITED STATES COURT OF APPEALS 
FOR THE SIXTH CIRCUIT 

No. 77-1089

CLEAMTEE GARNER, ET AL.,
Plaintiff-Appellant, 

VS.
MEMPHIS POLICE DEPARTMENT, ET AL., 

Defendants-Appellees.

On Appeal from the United States District Court for the
Western District of Tennessee 

Western Division

BILL OF COSTS

Appellant, by his undersigned counsel, pursuant to the 
judgment of the court entered on June 18, 1979, and pursuant 
to Fed. R. App. P. 39(a) submits the following as his verified 
Bill of Costs for this appeal.

1. DOCKETING FEE - $50.00
2. COST OF PREPARING APPENDIX - $1,344.72

(The Appendix was reproduced on copying equipment at 
the office of counsel for appellant. The cost per page, 
including the cost of the xerox machine and labor is 
13<:. The Appendix was 862 pages long. Ten copies were 
prepared for the court; two other copies were prepared 
for use of counsel for appellant and for service on the 
appellees. Total cost of these twelve appendices, 862 
pages long at ll^ per page is $1,344.72.)

3. COST OF PREPARING BRIEF - $175.50
(The Brief for appellant was reproduced on copying equip­
ment at the office of counsel for appellant. The orief 
was 45 pages long. Thirty copies were prepared; twenty 
five for the court, two for service upon counsel for 
appellees, and the remainder for use by appellant's 
counsel. Total cost of the thirty briefs, 45 pages long



COST OF PREPARING SUPPLEMENTAL BRIEF - $124.80 
(The Suppiemental Brief for Appellant: was reproduced 
on copying equipment at the office of counsel for 
appellant. The brief was necessary in light of 
the fact that the Supreme Court had decided Monell 
V. New York City Dept, of Social Services, 56 L. Ed. 
2nd 611 (197 8) , under which, in fact, the instant 
case was decided. The motion for leave to file a 
supplemental brief was granted on February 1, 1979. 
Thirty copies were prepared; twenty five for use of 
the court, two for service upon counsel for appellees, 
and the remainder for use of counsel for appellants. 
Total cost of the thirty briefs, 32 pages long, at 
13<: per page is $124.80.)
TOTAL COST - $1,695.02

at 13<: per page is $175.50.)

By
Respectfully submitted

•i . f i  :____r

JACK GREENBERG 
JAMES M. NABRIT, III 
CHARLES STEPHEN RALSTON 
STEVEN L. WINTER 
Suite 2030 
10 Columbus Circle 
New York, New York 10019
WALTER L. BAILEY, JR. 
Bailey, Higgs & Bailey 
161 Jefferson Avenue 
Memphis, Tenn. 38103
AVON N. WILLIAMS, JR. 
1414 Parkway Towers 
Nashville, Tenn. 37219
Counsel for Plaintiff-Appellant



CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Bill of Costs 
has been served by United States Mail, postage prepaid, to 
Henry L. Klein, Esq., 100 North Main Building, Suite 3500, 
Memphis, Tenn. 38103

This 27th day of June, 1979.

>/-.6T’ ( V. r
Steven L. Winter