Plaintiffs' Motion for Award of Attorneys' Fees and Expenses; Affidavits of Blacksher; of Menefee; of Cochran; of Kirkland; of Fins; of Maranan

Public Court Documents
November 20, 1986

Plaintiffs' Motion for Award of Attorneys' Fees and Expenses; Affidavits of Blacksher; of Menefee; of Cochran; of Kirkland; of Fins; of Maranan preview

73 pages

Plaintiffs' Motion for Award of Attorneys' Fees and Expenses; Affidavits of James Blacksher; of Larry Menefee; of Wanda J. Cochran; of Reo Kirkland, Jr.; of Deborah Fins; of Paola Gayle Maranan

Cite this item

  • Case Files, Dillard v. Crenshaw County Hardbacks. Plaintiffs' Motion for Award of Attorneys' Fees and Expenses; Affidavits of Blacksher; of Menefee; of Cochran; of Kirkland; of Fins; of Maranan, 1986. 11ebef8a-b7d8-ef11-a730-7c1e527e6da9. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/6a82105d-a1b6-40e9-8d05-2450eb664c67/plaintiffs-motion-for-award-of-attorneys-fees-and-expenses-affidavits-of-blacksher-of-menefee-of-cochran-of-kirkland-of-fins-of-maranan. Accessed May 17, 2025.

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IN THE UNITED STATES DISTRICT COURT FOR THE ~ nT x 

MIDDLE DISTRICT OF ALABMA bse He & 
NORTHERN DIVISION Ke ph 

77 2% 
=) I 

JOHN DILLARD, et al., ) 2 i 

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Plaintiffs, ) & ih 22 

Ame {> ly 

vs. ) C.A. No. 85-T=133 RR 
® : < EN Ney 

CRENSHAW COUNTY, ALABAMA, et al., ) Arial te 7 iu 
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Defendants. ) ff A 250 U2, 

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2 Fa + 2 

PLAINTIFFS’ MOTION FOR AWARD of ly ) 
OF ATTORNEYS' FEES AND EXPENSES wil PR ®_ 

Plaintiffs and the plaintiff class and subclasses move the 

Court for an award of attorneys’ fees and expenses, pursuant to 

this Court's order dated October 21, 1986. As grounds for their 

motion, Plaintiffs would show as follows: 

1. Plaintiffs are the prevailing parties in this action and 

in each subpart of this action. Accordingly, they are entitled 

to recover their attorneys’ fees and expenses pursuant to 42 

U.S.C. Sections 19731(e) and 1988. 

2. Attached hereto are the affidavits of Larry T. Menefee, 

James U. Blacksher, Gregory B. Stein, Wanda J. Cochran, Reo 

Kirkland, Jr., W. Edward Still, Deborah Fins and Paola Maranan, 

seven of the attorneys who represented the plaintiffs and 

 



  

plaintiff class in this action and one paralegal. 

3. Consistent with the legislative history of the attorneys’ 

fees provision cited above and guidelines in Johnson v. Georgia 

Highway Express, 488 F.2d 714 (5th Cir. 1974), the Court should 

consider the following factors in determining a reasonable fee. 

Plaintiffs contend that those factors support the requested 

relief. 

4. The time and labor required is set forth on the 

accompanying affidavits of plaintiffs’ counsel. 

5. The time expended is not only reasonable, 1t represents a 

uniquely efficient use of lawyer time in that, for approximately 

the same amount of lawyer work ordinarily required to challenge 

at-large elections in a single jurisdiction, plaintiffs obtained 

enforcement of the Voting Rights Act in eight separate counties. 

6. Most of plaintiffs’ counsel already had extensive 

experience in voting rights and/or civil rights litigation. 

Three of them have written scholarly articles concerning 

enforcement of voting rights, one of which has been relied upon 

by the Supreme Court of the United States. Accordingly, the skill 

required to perform the services and the experience, reputation 

and ability of the attorneys support the fees requested herein, 

as do the preclusion of other employment due to the acceptance of 

this case and the lack of any prior professional relationship 

with these named plaintiffs. 

 



  

7. Plaintiffs obtained all the relief they had sought 

originally in this action plus additional relief that was 

warranted by further developments of events and legal theory. 

8. Plaintiffs’ counsel conducted this litigation on a 

contingent fee basis, thereby undertaking substantial risk that 

they would recover no fees or only partial fees for their work. 

Because of the contingency nature of the litigation and because 

of political and social factors in the State of Alabama, most 

members of the Bar of Alabama would view undertaking such 

litigation as highly undesirable. 

9. Although the commands of the Voting Rights Act are clear, 

this litigation presented many novel legal and procedural 

questions, for example, the appropriateness of preliminary 

injunctive relief based on proof of racial motives on the part of 

central state government, the availability of relief against 

several separate jurisdictions, and the lawfulness of mixed 

at-large and single-member district county commissions in a 

remedy for Section 2 violations. 

10. Plaintiffs contend that a customary hourly fee for 

attorneys in Alabama of similar experience in similarly complex, 

specialized litigation, taking into account all of the Johnson 

factors, in particular, the contingent nature of the fee, the 

results obtained, the delay in obtaining payment, and the novelty 

of the questions involved, support a rate of $340 per hour to 

 



  

Messrs. Menefee, Blacksher, Stein and Still, $250 per hour for 

Ms. Fins, $200 per hour for Mr. Kirkland, and $150 per hour for 

Ms. Cochran. 

11. Awards in similar cases in prior years support the 

plaintiffs’ requested fees. In the Southern District of Alabama, 

the Court awarded Messrs. Blacksher, Menefee and Stein fees at an 

effective hourly rate of $180 per hour in Bolden v. City of 

Mobile, No. 75-297-P (S.D. Ala., Dec. 12, 1983), and at an hourly 

rate of $165 per hour in Brown v. Board of School Commissioners, 

No. 75-208-P. In a case that it considered not to be novel, this 

court recently awarded fees to Mr. Blacksher at the rate of 

$172.50 per hour, to Mr. Stein at the rate of $142.50 per hour, 

and to Ms. Cochran at the rate of $112.50 per hour. York v. 

Alabama State Board of Education, C.A. No. 83-T-421-N (M.D. Ala., 

Feb. 26, 1986). 

12. Plaintiffs also request compensation for their 

reasonable expenses incurred in this litigation. Those expenses 

are set forth in an attachment to the affidavit of James U. 

Blacksher. Such expenses are reasonable and should be "completely 

recoverable." Fairley v. Patterson, 493 F.2d 5988, 607 n.1l%? (5th 

Cir. 1984): Dowdell v. City of Apopka. Fla.,, 698 F.2d 1181 (11th 

Cir. 1981). 

WHEREFORE, plaintiffs pray that the Court will enter an 

award of attorneys’ fees and expenses as follows: 

 



  

    

Total Hourly 

Attorneys Hours Rate Total 

James U. Blacksher 377.50 $240 $90,600.00 

Larry T. Menefee 458.20 $240 109,968.00 

Gregory B. Stein 3.50 $240 840.00 

Wanda J. Cochran 185.00 $180 27,750.00 

Reo Kirkland, Jr. 52.10 $200 10,420.00 

¥. Edward Still 122.78 $240 29,460.00 

Deborah Fins 55.10 $250 13,775.00 

Total: 1,284.15 $282,813.00 

Fees requested by plaintiffs for the period ending October 

29, 1986 (except for Mr. Blacksher, whose hours are current 

through November 5, 1988): $282,813.00 

Expenses incurred from November 8, 1985, through November 

10, 1986: $ 73,063.74 

Total fees and expenses for the above periods: $355,876.74 

Plaintiffs further pray that the Court will establish an 

expedited schedule according to which defendants, and each of 

them, shall be required to file in writing their particular 

objections to the time, hourly rates and expenses claimed by 

plaintiffs’ attorneys, followed by a short period for discovery 

concerning disputed issues, followed by an evidentiary hearing 

and final disposition of this fee petition. 

 



  

Respectfully submitted this 28day of November, 1988. 

BLACKSHER, MENEFEE & STEIN, P.A. 
405 Van Antwerp Bldg. 
P. O. Box 1051 
Mobile, Alabama 36633 
(205) 433-2000 

   

  

BY: Xl . 
ARRY . MENEFEE 

AMES U. BLACKSHER 

WANDA J. COCHRAN 

   

  

TERRY G. DAVIS 
Seay & Davis 
732 Carter Hill Road 
P. O. Box 6215 
Montgomery, Alabama 36106 
(205) 834-2000 

DEBORAH FINS 
JULIUS L. CHAMBERS 

NAACP Legal Defense Fund 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

EDWARD STILL 

REEVES & STILL 

714 South 29th Street 
Birmingham, Alabama 35233-2810 
(205) 322-6631 

REO KIRKLAND, Jr. 
307 Evergreen Avenue 
P. O. Box 646 
Brewton, Alabama 36427 

(205) 887-5711 

Attorneys for Plaintiffs 

 



  

CERTIFICATE OF SERVICE 

I do hereby certify that on this 0 day of November, 1986, 

a copy of the foregoing PLAINTIFFS’ MOTION FOR AWARD OF 

ATTORNEYS' FEES AND EXPENSES was served upon the following 

counsel of record: 

H. R. Burnham, Esq. 
Burnham, Klinefelter, Halsey, 

Jones & Carter 
P. O. Box 1818 
Anniston, AL 36202 
(CALHOUN COUNTY) 

Jack Floyd, Esq. 
Floyd, Keener & Cusimano 
816 Chestnut Street 
Gadsden, AL 35999 
(ETOWAH COUNTY) 

David R. Boyd, Esq. 
Balch and Bingham 
P. O. Box 78 
Montgomery, AL 36101 

(LAWRENCE COUNTY, SMITH & LIGON) 

¥. 0. Rirk, d>., Esq. 
Curry & Kirk 
P. O. Box A-B 
Carrollton, AL 35447 
(PICKENS COUNTY) 

John A. Nichols, Esq. 
Lightfoot, Nichols & Smith 
P. O. Box 215 
Luverne, AL 36049 

(CRENSHAW COUNTY) 

Robert C. Black, Esq. 
Hill, Hill, Carter, Franco, 

Cole & Black 

P. OO. Box 116 
Montgomery, AL 36195 
(CRENSHAW COUNTY) 

Warren Rowe, Esq. 
Rowe & Sawyer 
P. O. Box~180 
Enterprise, AL 36331 
(COFFEE COUNTY) 

D. L. Martin, Esq. 
215 South Main Street 

Moulton, AL 35650 

(LAWRENCE COUNTY, SMITH & LIGON) 

James G. Speake, Esq. 
Speake, Speake & Reich 
P. O. Box 5B 

Moulton, AL 385680 

(PROCTOR OF LAWRENCE COUNTY) 

Barry D. Vaughn, Esq. 
Proctor & Vaughn 
121 North Norton Avenue 

Sylacauga, AL 35150 
(TALLADEGA COUNTY) 

Rick Harris, Esq. 
Moore, Kendrick, Glassroth, 
Harris, Bush & White 

P. O. Box 910 
Montgomery, AL 36102 
(CRENSHAW COUNTY) 

James W. Webb, Esq. 
Webb, Crumpton, & McGregor 
P. O. Box 238 
Montgomery, AL 36101 
(ESCAMBIA COUNTY) 

 



  

: by depositing same in the United States Mall, postage prepaid. 

  

     TORNEY FOR PLAINTIFFS 

 



  

AFFIDAVIT OF JAMES U. BLACKSHER 

STATE OF ALABAMA ) 

MOBILE COUNTY ) 

James U. Blacksher, after being duly sworn, deposes and says 

as follows: 

l. I am one of the attorneys for plaintiffs in this action 

and have been since the beginning of the litigation. 

2. I was admitted to practice in 1971. I clerked for one 

year as a law clerk to the Hon.Frank H. McFadden, United States 

District Judge for the Northern District of Alabama. I am engaged 

in the private practice of law under the firm name of Blacksher, 

Menefee ¥ Stein, P.A., in Mobile, Alabama. The entirety of my 

practice consists of federal civil litigation in the areas of 

voting rights and civil rights law. 

3. I am a member of the Bar in the State of Alabama, the 

supreme Court of the United States, the Fifth and Eleventh 

Circuit Courts of Appeal, the Northern, Middle and Southern 

Districts of Alabama. 

4. My current noncontingent hourly billing rate for federal 

civil litigation is $120 per hour, and I have been charging that 

rate for approximately two years. This rate is consistent with 

 



  

the noncontingent rates charged by other attorneys in this area 

with comparable experience and specialization. 

5. Attached hereto are summaries of time logs which have 

been maintained by me on a daily basis. They reflect the work 

that I have performed in this litigation which has not yet been 

compensated. I believe that the time reflected in these 

summaries is both reasonable and necessary to properly meet my 

professional responsibilities to the named plaintiffs and the 

plaintiff class. 

6. I undertook the representation of the plaintiffs in this 

natter on an entirely contingent fee basis, that is to say, 

whatever fee I am to recover would be by way of court award. 

7. Also attached hereto is a statement of expenses incurred 

by our firm in the handling of this litigation. TI believe these 

expenses are reasonable and of the type regularly billed by 

attorneys in private practice. 

  

Subscribed and sworn to 

before me on this 2¢%day 
of November, 1986. 

() | 

es < the Oats 
NOTARY PUBLIC % 
  

NOTARY PUBLIC STATE OF ALABAMA 
My Commission Expires January 11, 1857 

 



  

Page No. 

11/10/86 

DATE 

12/17/88 

12/19/85 

12/26/85 

¥X%* Total 

  

* %k X 

l TIME OF J.U. Blacksher 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 11/08/85 TO 12/31/85 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Confs Menefee, Cochran re discovery, strategy 

Study file 

Research venue, joinder 

HOURS 

0.80 

0.50 

0.60 

1.90



  

Page No. 

11/10/86 

DATE 

01/03/86 

01/08/86 

01/08/86 

01/09/86 

01/10/86 

01/10/86 

01/14/86 

01/15/86 

01/16/86 

01/17/86 

01/20/86 

01/21/86 

01/22/86 

01/23/86 

01/24/86 

01/27/86 

01/28/86 

01/28/86 

1 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Meetings McCrary, Menefee, Cochran re historical 
evidence, discovery 

Foncon Vaughn re Talladega 

Study record/conf Menefee re overall preparation 

Foncons Maranan, Gray re investigation, evidence 

Foncon Jones re Calhoun county 

Foncon Kirk re Pickens 

Conf Menefee, Cochran re motions to dismiss, change 
venue/foncon McCrary 

Research venue issues 

Foncon Menefee re discovery, investigation 

Conf Menefee re prep evidence/foncon Lawrence Co. 
Comm. Pres./research 

Study new pleadings 

Foncons McCrary, Gray, Martin, Vaughn, Still re 
settle, evid/study new pleadings/research 

Analyze statutes 

Conference Gray re settlement, prep evidence 

Foncons Maranan, Still, Kirkland, Gray, 
Advertiser/conference Cochran, McCrary re settle, 
trial prep 

Foncons Reed, Gray, Still re settlements/conf 

Cochran re briefs 

Prepare pleadings, brief/conf Cochran, Fins/foncons 
Gray, Wilson, Teal, Samford, Fielding, (cont.) 

(cont) Wyatt, Elbrecht 

HOURS 

.00 

. 30 

.00 

.00 

 



  

Page No. 

11/10/86 

DATE 

01/29/86 

01/30/86 

01/31/86 

02/02/86 

02/03/86 

02/04/86 

02/04/86 

02/04/86 

02/05/86 

02/05/86 

02/05/86 

02/05/86 

02/06/86 

02/06/86 

02/07/86 

02/07/86 

02/07/86 

2 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Confs McCrary, Fins/foncons Still, Gray re brief, 
motions dismiss, preliminary injunction 

Research/foncons Gray, Wilson, Still/confs Cochran, 
Fins re brief, settle, discovery, etc. 

Analyze statutes/conf Cochran, Fins/foncons Gray, 
Maranan, Turner, Rowe, Jones re settle, etc. 

Conf McCrary/analyze statutes/research 

Foncons Still, Kirk, Kirkland re settlement/foncon 
Maranan re disc/prep brief 

Prepare brief re motions dismiss, preliminary 
injunction 

Travel to/from Brewton 

Meetings with cocounsel, clients, defendants’ 
counsel re settlement Escambia County 

Foncons Maranan, Still, Gray, Reed re settlement, 

discovery 

Draft letter to Samford re Lee County settlement 

Study Pickens County answers to interrogatories 

Prepare brief opposing motions dismiss, supporting 
preliminary injunction 

Conf Cochran, prepare hearing on motions 

Travel Montgomery/conf Cochran 

Prep hearing/conf Reed, Gray, Wilson, Cochran re 
settle/attend hearing on motions 

Settlement conf Lawrence County 

Settlement conf Talladega 

HOURS 

0.40 

0.60 

1.50 

3.50 

3.00 

 



  

Page No. 

11/10/86 

DATE 

02/07/86 

02/07/86 

02/07/86 

02/12/86 

02/12/86 

02/12/86 

02/13/86 

02/13/86 

02/14/86 

02/14/86 

02/14/86 

02/14/86 

02/17/86 

02/18/86 

02/18/86 

02/18/86 

02/18/86 

02/19/86 

02/19/86 

3 TIME OF J.U. Blacksher 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Settlement conf Calhoun 

Settlement confs and foncons Webb re Escambia 

Travel Mobile/conf Cochran re trial prep 

Prep prelim inj hearing/foncons McCrary, Gray, 
Maranan, Hebert/conf Cochran 

Foncon America re Escambia plan 

Study materials from Whatley 

Prep hearing, settlement offers/foncons Reed, Gray, 
Still, McCrary 

Foncon Turner (Crenshaw)/draft proposed consent 
decree 

Foncon Jones (Calhoun) re settlement 

Foncons Webb, Kirkland re settlement (Escambia) 

Foncon Kirk (Pickens) re settlement 

Prep proposed consent decrees/foncons Still, Maranan 

re settlement, prep hearing 

Prepare consent decrees, interrogatories/foncon Gray 

Prep settlement, hearing/conf McCrary/foncons Gray, 
Reed, Maranan, Henderson 

Foncons Kirkland, Webb re settlement (Escambia) 

Foncon Samford/prepare Lee County pleadings 

Foncon Turner re settlement (Crenshaw) 

Foncons Turner, Reed re settlement (Crenshaw) 

Foncons Maranan, McCrary/conf McCrary, 

Cochran/prepare hearing 

O
O
 

MW
 

+70 

70 

. 30 

 



  

Page No. 

11/10/86 

DATE 

02/20/86 

02/20/86 

02/20/86 

02/21/86 

02/21/86 

02/22/86 

02/24/86 

02/24/86 

02/25/86 

02/25/86 

02/26/86 

02/26/86 

02/26/86 

02/26/86 

02/27/86 

0R/27/86 

02/28/86 

02/28/86 

02/28/86 

4 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Foncon Samford re settlement (Lee) 

Foncons Reed, Turner re settlement (Crenshaw) 

Foncons Still, Cochran, Gray, Maranan/prepare 
hearing 

Prepare hearing/foncon Still 

Prepare Crenshaw County settlement papers 

Attend Ala. Voting Rights Project meeting Montgomery 

Prepare hearing, FOF/COL/ research/conf Menefee, 
McCrary, Cochran 

Prepare Crenshaw County settlement papers 

Travel to/fm Montgomery/confs judge, lawyers, Gray 
re Lee County 

Conf McCrary/prepare FOF/foncon Still 

Foncon Turner, Jjudge/prepare settlement papers 
Crenshaw County 

Prepare Lee County settlement papers 

Foncons Kirkland, Still re Escambia County 
settlement, evidence 

Prepare FOF/conf McCrary 

Foncon Samford re settlement papers Lee 

Foncons Gray, Still/prep FOF-COL 

Foncons Kirkland, Still, Webb/draft settlement 

papers Escambia 

Foncon Stan Martin/draft settlement papers Lee 

Foncon Turner, Reed re Crenshaw settlement 

 



  

Page No. 

11/10/86 

DATE 

02/28/86 

03/01/86 

03/03/86 

03/04/86 

03/05/86 

03/05/86 

03/06/86 

03/06/86 

03/10/86 

03/11/86 

03/13/86 

03/19/86 

03/25/86 

03/26/86 

03/27/86 

03/28/86 

03/31/86 

5 TIME OF J.U. Blacksher 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Prep FOF/COL, P/I, hearing/research 

Prep FOF/COL 

Prepare hearing/foncons lawyers, law clerk/prep 
exhibit 

Prepare hearing on preliminary injunction/confs 
lawyers, McCrary/travel Montgomery 

Prepare hearing 

Attend Hearing on preliminary injunction 

Travel Mobile 

Foncons Webb, Kirkland re Escambia settlement 

Foncons Gray/conf Menefee re Escambia, Crenshaw, 
Talladega settlements and plans/litigation planning 

Foncon Reed re settlement position remaining 
counties 

Conf Menefee/foncon Gray re Crenshaw, Escambia and 
general settlement position 

Research liability theories/conf Menefee/draft 
letter to Judge 

Confs Cochran, McCrary/prep new exhibits in response 
to letter from Judge 

Review exhibits, tables, research/foncon judge, 
lawyers/prep letter, new exhs, etc. 

Foncons law clerk, lawyers, Gray, Still/conf Menefee 
re P/I proceedings 

Foncons lawyers/conf Menefee re P/I proceedings 

Foncons law clerk, Boyd, Still, Gray, 
Maranan/research majority vote requirement 

12. 

.50 

. 50 

.00 

. 80 

.40 

.80 

.30 

. 50 

.80 

.80 

00 

.00 

.80 

.80 

 



  

Page No. 

11/10/86 

DATE 

04/01/86 

04/08/86 

04/09/86 

04/10/86 

04/25/86 

05/05/86 

05/05/86 

05/00/86 

05/12/86 

05/22/86 

05/29/86 

05/30/86 

06/03/86 

06/04/86 

06/05/86 

06/09/86 

06/12/86 

6 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE &® STEIN, P. A. 

DESCRIPTION OF SERVICES 

Foncons Judge Thompson, law clerk, Boyd, Maranan, 
Gray, Still/conf Menefee/research P/I issues 

Foncon Tanner re preclearance Escambia and others 

Foncons Gray, Maranan, Clark re districting plans 

Foncons Fins re Calhoun offer of judgment 

Foncons Gray, Still re evidence prep 

Foncons Maranan, Kirk re discovery (Pickens) 

Conf Menefee/research Section 2 cases 

Conf Menefee re case status, Judge's letter/foncon 
Rowe/conf Dr. Walters re historical background 

Foncons Still, news reporter re pending cases 

Research dilution issues 

Study dist ct opinion/foncons Gray, Maranan, Fins, 
Reed, reporters re opinion, trial prep 

Foncons Caley, Kendrick, ACLU, news reporter re dist 
ct opinion 

Conf Menefee/foncons Menefee, Still, Ricketts re 

trial prep/study dist ct opinion 

Foncons Weidler, Maranan, Still, Menefee re trial 

prep/draft settle ltr/prep discovery 

Review discovery/draft discovery motions/foncon 
Still 

Conf Menefee/foncons Still, Maranan, Henderson re 

trial prep/review documents 

Conf Menefee/foncons Reed, Gray, Maranan/prepare 
trial, discovery/draft letters 

HOURS 

. 50 

.00 

.00 

.10 

. 80 

 



  

Page No. 

11/10/86 

DATE 

06/13/86 

06/16/86 

06/17/86 

06/18/86 

06/19/86 

06/20/86 

08/23/86 

06/24/86 

06/25/86 

06/26/86 

06/27/86 

06/30/86 

07/01/86 

07/01/86 

07/03/86 

7 TIME OF J.U. Blacksher 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Conf Menefee/Foncons Still, Maranan, Gray re trial 
prep/draft letters 

Foncon Still re Etowah offer of judgment/study Defs’ 
ltrs, Henderson rpt/conf Menefee/study data 

Conf Menefee/research, prepare for hearing/foncons 
Maranan, Reed, Knight 

Foncons Maranan, Still, Gray/conf Menefee/prep 
hearing/travel Montgomery/hearing/conf lawyers, 
clien 

Travel Mobile/confs Menefee, Cochran/foncons Still, 

Gray, Maranan, Reed/draft stipulation 

Foncons Wilson, Rowe, Still/conf Menefee/prep trial, 
settlement 

Foncon Boyd re trial stipulation, settlement 

Foncons Vaughn, Still, Maranan re trial prep, 
settlement 

Foncons Wilson, Sawyer, Still, Gray re trial prep, 
settlement/research recent cases 

Foncons Wilson, Gray, Maranan, Still, Kirk, Sawyer, 
clients, Boyd re trial prep, settlement 

Foncons Jones, Maranan/confs Menefee, Still re trial 

prep, settlement 

Travel to/from Coffee County/settlement confs 
defendants, plaintiffs 

Prepare Coffee County settlement papers 

Foncons Judge Thompson, Kirk, SRC/study Thornburg v. 
Gingles 

Foncons Boyd, dJones/study responses to 
interogs/draft ltr to Henderson 

HOURS 

10. 

10. 

.80 

.80 

00 

.00 

.80 

.20 

.20 

.00 

.00 

.00 

50 

.10 

.80 

.50 

 



  

Page No. 

11/10/86 

DATE 

07/08/86 

07/11/86 

07/14/86 

07/15/86 

07/16/86 

07/17/86 

07/18/86 

07/18/86 

07/21/86 

07/22/86 

07/24/86 

07/24/86 

07/25/86 

07/25/86 

07/28/86 

07/31/86 

8 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Conf Menefee/foncon Still/study new 
pleadings/prepare trial 

Conf Menefee/foncons Reed, Kirk, Henderson re trial 

prep/study Davis v. Bandemer 

Foncon Menefee/prepare trial 

Prep trial/confs Menefee, Cochran/foncons Kirk, 
Derfner, Henderson 

Travel to/from Montgomery/confs clients, experts, 
lawyers/attend pretrial conference 

Foncons Kirk, clerk, Jones, Wilson/conf Menefee re 

trial prep 

Conf Menefee re remedy issues/conf witness (Lawrence 
Co.)/foncon Wilson re remedial plans 

Research, prep brief re at-large chair 

Prep brief re at-large chair/foncon Still/prep 
election data 

Travel to/fm Montgomery and confs Menefee/confs 
Henderson, Gray, Reed, Maranan, clients 

Foncons Vaughn, Gray/prep Talladega settlement 
papers 

Foncon Gray/research 

Foncon Gray re remedy issues 

Prep Talladega settlement papers 

Research Thornburg issues/foncons Maranan, Wilson, 

Vaughn, Wood re district boundaries, trial prep 

Foncons Proctor, Vaughn, Gray re Talladega 
settlement 

HOURS 

14. 

12. 

=
O
 

T
O
 

.00 

. 50 

.00 

.50 

00 

.30 

.30 

.50 

.00 

00 

.70 

.00 

.20 

.30 

.50 

.80 

 



  

Page No. 

11/10/86 

DATE 

08/01/86 

09/12/86 

09/30/86 

10/02/86 

10/06/86 

10/09/86 

10/10/86 

10/21/86 

10/22/86 

10/24/86 

10/27/86 

10/28/86 

10/30/86 

10/31/86 

11/03/86 

11/04/86 

11/05/86 

9 TIME OF J.U. Blacksher 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Foncons Gray, Proctor re Talladega settlement 

Foncon Menefee re pending issues 

Foncon Menefee re Crenshaw motion contempt 

Review plaintiffs’ brief/foncon Menefee re pending 
issues 

Research recent voting cases 

Confs Menefee re pending issues 

Foncon Menefee/research pending issues 

Foncons Menefee, Guinier re district court ruling, 
attorney fees 

Study opinion and order of district court/foncon 
Menefee 

Research, prepare brief re Crenshaw election 
enforcement motion 

Foncon Menefee re pending issues/study new orders, 
pleadings 

Foncon Menefee, conf bookkeeper re pending issues, 
fees, expenses 

Foncon Menefee re pending issues/study Crenshaw 
opinion and order 

Conf Guinier, Parker, et al. re pending issues 

Foncons Menefee, Kirkland re pending issues, fee 
petition 

Foncons Menefee re fees, Lawrence election problems 

Study new pleadings, Crenshaw opinion/foncons Boyd, 
Still, Gray, Reed, Judge re Lawrence problems 

. 20 

.30 

. 50 

.80 

.80 

.60 

. 50 

. 850 

 



  

Page No. 10 TIME OF J.U. Blacksher 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 11/05/86 
11/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

 % Xk Total X X Xk 

375.60 

 



  

Page No. 1 
11/19/86 

DILLARD, et al. v. CRENSHAW COUNTY, ALABAMA, et al. 
EXPENSES INCURRED FROM 11/08/85 THRU 11/10/86 

  

  

  

  

EXPENSES INCURRED AMOUNT 

BLACKSHER, MENEFEE & STEIN, P.A. 
Photocopying $3,044.60 
Postage 514.14 
Telephone (long distance) 969.30 
American Express (meals, airfare, lodging, auto) 2,215.88 
Attorney travel (personal auto) 1,003.72 
LEXIS (legal research) 232.02 
Research assistants 5,010.93 
Paralegals at $35/hr 13,370.00 
Experts 43,111.96 
Professional copying 236.05 
Court costs (filing fees, copies) 138.50 
Court reporter 1,236.95 
Package express 682.10 

Subtotal for Blacksher, Menefee & Stein....... $71,766.15 

LEGAL DEFENSE FUND 
DEBORAH FINS 199.00 

SUBLOLal £01 LDP... vo visins tone nn cnnnsnins viedsiss $ 199.00 

REO KIRKLAND 33.77 

Subtotal for Reo Kirkland .... ci. atc cervmns $ 233.77 

¥. EDWARD STILL 864.82 

Subtotal £0r W. Edward SEill cheer cnrvs dans $ 864.82 

TOTAL EXPENSES: $73,063.74 

 



  

STATE OF ALABAMA ) 

COUNTY OF JEFFERSON ) 

AFFIDAVIT OF LARRY T. MENEFEE 

DILLARD V. CRENSHAW COUNTY   

Larry T. Menefee, after being duly sworn, deposes and 

54ys as follows: 

1. My name is Larry T. Fenefee. 1 am counsel of record 

for plaintiffs in this action. 

A 

2. 1 was ‘admitted to practice in 1971 and am currently 

admitted to practice in the three federal district courts in 

Alabama, the Northern District of Florida, the Fifth and Eleventh 

Circuit Courts of Appeals, the United States Supreme Court and 

the Supreme Court of Alabama. I am in private practice with the 

firm of Blacksher, Menefee & Stein in the Birmingham office of 

that firn. ] am a former law clerk to United States District 

Judge Daniel H. Thomas in Mobile. My private practice consists of 

full-time federal civil litigation in the areas of constitutional 

and civitrrights. 

3. I am a member of the American Bar Association and 

the Alabama Bar Association. I have received an "A-V" rating in 

MMartindale-Hubble Legal Directory. 1 have several publications in 

 



  

the area of voting rights. I have conducted continuing education 

seminars for several organizations in various aspects of civil 

rights litigation, 

4. Though the large part of my work is taken on a 

contingent fee basis, I have a number of clients who pay on an 

hourly basis. Wy customary non-contingent hourly rate for 

litigation or any other type of contested matter is $120 per 

hour. . 1 charge no other rate for practice except Tor in-office 

consultation which I occasionally charge at $90 per hour. 

5. Attached hereto are my time logs. These time 104s 

$. 

are maintained on a daily basis by me and enter directly into our 

computer. I believe ‘that the time reflected in these records is 

accurate. Furthermore, I believe the time is both reasonable and 

necessary for the proper representation of the plaintiffs’ 

interest in this. 1itigation. 

  

Sworn to and subscribed before ne 

this [8° day of \Jgpomligq 
  

Re le lp 

“Aaa der A 
  

NOTARY PUBLIC ¢/ 

iy Commission Expires: 7/15/90 
  

 



  

Page No. 

11/10/86 

DATE 

11/21/85 

11/22/85 

11/25/85 

11/26/85 

12/02/85 

12/05/85 

12/06/85 

12/09/85 

12/10/85 

12/11/85 

12/12/85 

12/13/85 

12/16/85 

12/17/85 

1 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 11/08/85 TO 12/31/85 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research re historical issues and review joinder and 
defendant class issues, confer research assistants 
and experts re polarized vote analysis 

research re joinder issues and polarized vote 
analysis problems, confer with McCrary letters to 
Hanks and Davidson 

t/ with co-counsel Fins, defense atty and meet with 
McCrary re preparation of intent case. 

research re discovery, confer with client re 
settlement, research joinder issues 

research re joinder issues and prep discovery 

t w/ defensae atty, research re ammended complaint, 
travel to Montgomery for status conference 

confer with defense counsel re status conference and 
settlement, attend status conference, research re 
amended complaint and district plan,ret. to Mob 

research and draft discovery and amended complaint, 
confer with Still re Pickens 

research and draft complaint and discovery 

research and draft amended complaint, t w/ various 
co. officials, 
tw/ Kirkland re Escambia Co 

research and draft amended complaint, research at 
co. law library re local statutes, confer with 
plaintiffs 

final proof of motion and amended pleading, confer 
with clients and research re local forms of govt. 

confer with client Thomas re Etowah and research 

confer with co-counsel and outline work/testimony 
for experts 

HOURS 

2. 

(62
) 

30 

. 30 

. 20 

.60 

.80 

.80 

.60 

.30 

.30 

.40 

.60 

.10 

.80 

.60 

 



  

Page No. 2 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 11/08/85 TO 12/31/85 
11/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

12/18/85 confer with clients, research re legislative 1.90 
history, research and prepare service of summons, 
complaint and discovery 

12/19/85 prepare and mail summons and service copies, confer 1.40 
with clerk 

12/20/85 t w/ clerk re service and research same 0.80 

12/26/85 research re historical evidence and respond to 1.90 
client inquiry 

12/27/85 historical research 1.20 

* ok Xk Total X Xk X 

41.90 

 



  

Page No. 

11/10/88 

DATE 

01/02/86 

01/03/86 

01/08/86 

01/13/86 

01/14/86 

01/13/86 

01/14/86 

01/15/86 

01/16/86 

02/24/86 

02/25/86 

02/26/86 

02/27/86 

03/03/86 

03/03/86 

03/04/86 

03/05/86 

1 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

review defense answer and answer to interrogs 

research re historical and meet and confer wtih 

expert witness McCrary 

telephone conference with expert and researcher. 

research and draft re Lawrence's motioon to dismiss 

research and draft motion to correct pleading, 
research draft response to Lawrence 

research and draft re Lawrence’'x motioon to dismiss 

research and draft motion to correct pleading, 
research draft response to Lawrence and Pickens 

t w/ Latiner and Cotter, research, draft motion to 

convert parties 

confer with G. Henderson re testimony, research 

review pleadings and research re polarized vote, 
exhibits 

research and trial prep 

trial prep and research 

trial prep and research 

attend settlement conference in chambers (Crenshaw 

Ot 2 et 

trial prep and research in Montgomery 

trial prep re polarized vote analysis and plan 
analysis 

prep and attend hearing on preliminary injunction, 
meet with clients and travel 

13. 

. 30 

.50 

.80 

.60 

.80 

.40 

. 20 

.80 

.00 

00 

 



  

Page No. 

11/10/86 

DATE 

03/06/86 

03/07/86 

03/10/86 

03/10/86 

03/12/86 

03/13/86 

03/13/86 

03/13/86 

03/14/86 

03/14/86 

03/14/86 

03/17/86 

03/18/86 

03/19/86 

03/19/86 

03/20/86 

2 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and confer re settlement and further 
discovery 

t w/ A. Turner and J. Wilson re settlement plan 

t w/ Turner, Voyles and Wilson re plan 

research and draft settlement letter to def. counsel 

travel to Montgomery (3hrs) meet with defense atty 
and consultant, Kirkland and Gray re settlement 

draft settlement documents for Escambia County 

confer with Turner and Voyles and client re 
prepration of plan 

draft letter re settlement to remaining defendants 
and confer with co-counsel re same 

confer with Etowah Co clients re settlement offers 

confer with defense counsel,co-counsel and prep 
settlement documents 

draft settlement documents for Escambia County 

travel to Montgomery and present Escambia County to 
Court, confer with co-counsel and defense 
counsel--charge only 1/2 travel time 

t w/ Alton Turner and Burt Jones 

proof and re-draft settlement papers, confer with 
Turner(3), client (3) and court re hearing schedule, 
review map of proposed districts 

confer with Burt Jones re settlement proposal and 
client re meeting for settlement discussion 

proof and draft final settlement documents for 
(Crenshaw Co). 

HOURS 

2 
HR
 

Th 
SE
N 

0 

.80 

.40 

.40 

.90 

.30 

.60 

. 20 

.90 

. 20 

 



  

Page No. 

11/10/86 

DATE 

03/21/86 

03/24/86 

03/24/86 

03/24/86 

03/24/86 

03/28/86 

03/28/86 

03/31/86 

04/14/86 

04/14/86 

04/15/86 

04/15/86 

04/16/86 

04/23/86 

04/29/86 

05/05/86 

05/06/86 

05/07/86 

o TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, 

FOR 01/01/86 TO 10/29/86 
et al 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

t w/ Calhoun Co clients re meeting 

travel and return to Montgomery for meetings/court 
re Calhoun 

travel and return to Montgomery for meetings/court 
re (Crenshaw Co) 

meet with clients,defense counsel and court re 

settlement of (Crenshaw County) 

meet with clients, review plan, meet with 
defendants, negotiate settlement of Calhoun County 

confer with clients and Burt Jones, letter to Jones 

re settlemnt of Calhoun Co case 

research re supplemnetal historical information and 
election schedule 

research re supplemental historical information 

t w/ court re proposed order for Escambia County 

t w/ court re proposed order for (Crenshaw Co) 

draft proposed order for (Crenshaw County) 

draft proposed order for Escambia County 

confer with Still and JUB re demographic proof 

research re demographic data and confer wtih clients 
re election plans 

confer with client 

letter to court and confer with client 

t w/ Justice Department re relief, research re Ft 
Lauderdale 

t/ with clients. 

"HOURS 

.00 

70 

.80 

.90 

.30 

.70 

.20 

. 20 

20 

.70 

.20 

.90 

.40 

.80 

.60 

.70 

 



  

Page No. 

11/10/86 

DATE 

05/09/86 

05/31/86 

06/03/86 

06/04/86 

06/06/86 

06/09/86 

06/10/86 

06/11/86 

06/12/88 

06/13/86 

06/17/86 

06/18/86 

06/19/86 

06/20/86 

06/26/86 

07/03/86 

07/07/86 

4 TIME OF LARRY T. MENEFEE 

IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

review letter from court, confer with client and 

co-counsel, letter to clients 

read and research Court’s opinion, confer with 
co-counsel 

research and confer re Court’s opinion 

conference cass with co-counsel , plan trail and 
settlement strategy 

t/w Rowe, Wilson and client re settlement. 

research and trail preparation 

confer with defense counsel and clients re 

settlement, research 

confer with defense counsel re settlementconfer w/ 

client, draft, research 

confer with defense counsel and clients, research 

and draft 

confer with co-counsel and defense counsel, research 

re liability and remedy issues 

research and trial prep, t w/ clients, review 
defendant letters tocourt and offer of judgment 

research re settlemnt issues, confer wtih 

co-counsel, research re effects evidencde. 

research and prep re settlement and remedy issues 

research and confer re settlemtn and remedy issues 
withclients and defense attys 

research and confer re settlment 

research and confer re Gingles and McCord 

confer with clients, review defendant proposals and 
research 

HOURS 

2.50 

2.30 

 



  

Page No. 

11/10/86 

DATE 

07/08/86 

07/08/86 

07/09/86 

07/09/86 

07/10/86 

07/11/86 

07/14/86 

07/15/86 

07/17/86 

07/18/86 

07/22/86 

07/24/86 

07/25/86 

07/30/86 

08/13/86 

08/14/86 

5 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and trial prep 
confer withclients re settlemtn 

research and prepre interrogatories, proposed 
stipulation and motionto limit testimony 

t with defense counsel, research re defendant 
experts and demographics, t with court. 

t w/ clients and Wilson re deistrict plans, research 
re settlement, letter to counsel. 

trail prep, confer with defense counsel re 
settlement and pre-trial document, prep witness and 
exhibit list, confer with expert witness re plans 

confer with defense attorney re settlement, research 
and perp pre-trail document, interview witnesses. 

pre-trial prep 

travel to and from Montgomery(6.0) meet with defense 
attorneys, experts, and witnesses, pre-trial 
conference 

t w/ Maranan, Gray and Henderson research 

research and prep for hearing 

travel to Montgomery, meet with clients and experts 
and negotiate 

confer with Henderson and Wilson, research res 
remedy, t w defense counsel 

t/w defense counsel and clients, research and confer 

re settlement 

confer with clients and experts, research 

t w/ defense counsel and research 

research and t with defense counsel 

HOURS 

®)
) 

12. 

10. 

.60 

.40 

.70 

.60 

.90 

.70 

.80 

.60 

.90 

 



  

Page No. 

11/10/86 

DATE 

08/15/86 

08/18/86 

08/19/86 

08/20/86 

08/21/86 

08/22/86 

08/25/86 

08/26/86 

08/27/86 

08/28/86 

08/31/86 

09/01/86 

09/02/86 

09/03/86 

09/04/86 

09/05/86 

09/08/86 

6 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and confer with defense counsel, study 
Section five submissions 

research and confer re section five submissions 

t with defense counsel and expert, research and prep 

t with defense counsel, witnesses and research 

confer with clients,research and prep for conference 

travel to Montgomery, interview witnesses and 
research, confer wtih defense counsel 
attend pre-trial conference,attend Coffee Co. 

settlement 

trial prep, research and draft pre-trial 
brief ,document research 

trialprep,research and draft brief 

trial prep, confer with Etowah clients re 
settlement, interview witnesses, meet with R. Clark 
re Lawrence Co.,t w/ defense counsel 

trial perp, draft brief, confer re settlement 

trial prep, research discovery production etc 

documemt prep and research, trial prep 

research and trial prep, travelto Montgomery and 
confer with witnesses and court 

trial prep and take depositions 

trial prep and trial 

trial and prep 

confer with clients and research, letters to 

clients and court, motion to show cause 

10. 

11. 

 



  

Page No. 

11/10/86 

DATE 

08/09/86 

09/10/86 

09/11/86 

09/12/86 

09/15/86 

09/16/86 

09/17/86 

09/18/86 

09/19/86 

09/20/86 

09/22/86 

09/23/86 

00/24/86 

00/25/86 

09/26/86 

09/29/86 

09/30/86 

10/01/8386 

7 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and draft re remedy issues, t w/ Justice 
and clients. 

t w/ clients and research 

research and draft letter re remedy and document 
investigation re crenshaw contempt 

t w/ court and research re crenshaw 

research and draft Section 5 commments and briefs 

same 

same 

same, work on contempt issues 

same, confer with DOJ 

research and draft Section 5 comment and brief 

t w/ Harris and research re contempt issues, 
research re brief andelection schedule problems, 
final proof and mail Section 5 comments 

t w/ Hylind, research and draft re remedy and 
contempt issues 

prepare and research re contempt 

travel to Montgomery, take deposition of Crenshaw 
Co.,confer wtih defense counsel and clients 

research re contempt and remedy issues, t w/ Justice 
Dept 

research documents at Demo. Hdq. 

draft brief, research state election laws re voter 

lists and precinct boundaries 

travel to Montgomery, research contempt and meet 
with counsel and conference with court. 

HOURS 

 



Page No. 

11/10/86 

DATE 

10/02/86 

10/03/86 

10/07/86 

10/08/86 

10/09/86 

10/10/86 

10/22/86 

10/23/86 

10/24/86 

10/27/86 

10/28/86 

10/29/86 

*** Total Xk Xk Xx 

TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/29/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and draft brief and motion for injunction, 
research re Section 5 issues, confer wtih clients 
and defense attorneys 

research re section 5, supplemental submissioin re 
Pickens Co., t w/ Justice and court, meet with Boyd 
and Proctor 

confer with Floyd and clients re settlemnet hearing, 
t with Harris 

t with B Jones and Gray and research 

travel to Montgomery, prep and attend settlement 
hearings for Etowah and Talladega Co and meet with 
clients and research 

t with DOJ, draft interim prders, reserach same 

t with counsel and client, research 

t with counsel and research re remedies 

research and draft and t with counsel and confernce 

with court 

research and draft, t with counsel 

research and draft findings and conclusions 

confer with defense attorneys, Judge Lang, Wilson, 
Marannan, Harris, research and draft brief 

 



  

AFFIDAVIT OF GREGORY B. STEIN 

STATE OF ALABAMA ) 

MOBILE COUNTY ) 

Gregory B. Stein, being duly sworn on oath, deposes and says 

as follows: 

I was admitted to the practice of law in September, 1975, 

and have been engaged in private practice in Mobile, Alabama, 

since that time. The vast majority of my practice (over 90%) has 

been in the fields of civil rights and constitutional law. 

Attached hereto is a description of time expended by me in 

connection with the Dillard v. Crenshaw County action. There 

was only one occasion when I expended a significant amount of 

time in connection with this action and for which I will claim 

fees. The entry of time was extracted from time logs I have 

maintained on a daily basis of work done. To the best of my 

knowledge, information and belief, the time logs and the 

description of time attached hereto accurately reflect the time I 

expended in connection with this litigation for which I will 

claim compensation. 

 



  

Subscribed and sworn to 

before me on this 27™ day   

of Medd 1986. 
  

vi 

/ 1 
Tn 
lf 

/ Aaa / he (Aan § / 

NOTARY PUBLIC 

  

NOTARY PUBL IC STATE OF ALABAMA 
My Commission Expires January 11, 1987 

  

4é 1, re / CN 14 

GRESORS B. STEIN 
| | 

f 

 



  

Page No. 1 TIME OF GREGORY B. STEIN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/30/86 
11/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

02/28/86 Research for pre-hearing brief. 3.50 

X Xx X Total XX Xk 

 



  

ANDA J. COCHRAN 

  

STATE OF ALABAMA ) 

MOBILE COUNTY ) 

Wanda J. Cochran, being duly sworn on oath, deposes and says 

as follows: 

I am one of the counsel of record for plaintiffs in this 

action. I was admitted to the practice of law in October, 1984, 

and I have been engaged in the practice of law in Mobile, 

Alabama, since that time. Over 90 percent of my practice has 

been devoted to civil rights and constitutional law. 

I have attached a description of time expended by me in 

connection with this case. This summary has been compiled from 

time logs I have maintained of work done in this action from 

November 8, 1985, through and including September 5, 1986. I 

recorded the time I spent in connection with this case on a daily 

basis. To the best of my knowledge, information and belief, 

these time logs accurately reflect the time I have expended in 

connection with this litigation. 

al ~ , 
il 5 SN ir 

ff - a 

A A 7 

/ f ~~ ~ lf ~~ 

CO DI 00 aw 
WANDA J., COCHRAN 

T
N
 

  

Subscribed and sworn, to 
before me on this A" day 
of Xascsslditn, __, 1986. 

  

    7 CAAT 

NOTARY PUBLIC 

 



  

XX Xk 

Page No. 

11/10/86 

DATE 

11/08/85 

11/11/88 

11/12/85 

11/20/85 

11/26/85 

12/06/85 

12/09/85 

12/00/85 

12/10/85 

12/11/85 

12/12/85 

12/13/85 

12/17/85 

12/19/85 

12/20/85 

12/27/85 

Total **»x 

1 TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 11/08/85 TO 12/31/85 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Research-Senate Committee findings(.5) confer with 
LTM, JG (.8) edit complaint(.?). 

Research interrogatories. 

Draft Planitff’'s First Discovery Request. 

Draft interrogatories. 

Conference with LTM. 

Draft interrogatories. 

Edit amended complaint(.4) review answer(.5). 

Draft, edit interrogatories. 

Edit interrogatories. 

Edit interrogatories. 

Telephone conference Jerome Gray re plaintiffs. 

Edit amended complaint. 

Conference with LTM and JUB. 

Edit interrogatories, draft letter. 

Review files research legislative history. 

Telephone conference Peyton McCrary re legislative 
histories. 

HOURS 

oO
 

[AS
 

pt
 

oO
 

14. 

Q
O
 

0
 

0
 

OO
. 

0 
OO
 

O 

30 

 



  

Page No. 

11/10/86 

DATE 

01/02/86 

01/03/86 

01/08/86 

01/13/86 

01/13/86 

01/14/86 

01/15/86 

01/15/86 

01/15/86 

01/17/86 

01/21/86 

01/22/86 

01/23/86 

01/24/86 

01/25/86 

01/27/86 

01/27/86 

01/28/86 

01/31/86 

1 TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 09/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Review answers. 

Conference with LTM, JUB and expert witness. 

Conference with expert ree legislative history. 

Conf w/LTM re certification draft motion for class 

certification draft brief. 

Review Pickens Co. motion to dismiss, etc, draft 

response, t ¢/ expert re status. 

Conf LTM & JUB re motion, research issues in 
Lawrence County’s Motion to Dismiss. 

Research Venure Issue. 

Research service issue on non-ans parties, t conf 
Clerk of Ct. 

T conf W. Rowe(Coffee Co.) re service. 

Research venure. 

T ¢/ D. Fins re motion. 

Conf JUB, Fins re briefing schedule. 

Review order,motions, doc, etc. 

T conf JUB, paralegal, conf JUB re prel inj, conf 
historian. 

Draft prel inj motion, research. 

Research, draft pettion for pre inj. 

Research, draft motion for preliminary injunction 

and class certification. 

Research class and motion to dismiss issues. 

Review new pleadings, t conf paralegal re election 
returns. 

.90 

.40 

.80 

.60 

. 20 

.80 

.20 

. 20 

.70 

.90 

.20 

.50 

.60 

.00 

.¥0 

 



  

Page No. pd TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 09/10/86 

11/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

02/03/86 Research class certification issue, draft brief. 5.70 

02/04/86 Draft, research brief, edit brief and motion. 4.10 

02/05/86 Edit brief. 2.30 

02/06/86 T/conf Thompson's clerk re hearing, travel to 2.70 
Montgomery. 

02/07/86 Attend hearing and settlement talks, travel to 7.40 
Mobile. 

02/11/86 Conf JUB re P. J. prep assignments. 0.50 

02/13/86 T/conf co-counsel re schedule, conf JUB re 1.00 
settlement. 

02/14/86 Draft letter to expert. 0.20 

02/17/86 Research findings and conclusions. 0.70 

02/18/88 Draft interrogatories, motion to shorten time, 2.60 
t/conf opposing counsel re ans to interrogatories. 

02/18/86 Research legislative history, research re findings 0.30 
and conclusions. 

02/19/86 Draft witness list, draft exhibit list, conf with 0.580 
historian re exhibits. 

02/20/86 Prepare exhibits. 1.80 

02/24/86 Prepare exhibit list. 6.40 

02/24/86 Review witness list, review notes on prior hearing. 0.50 

02/24/86 Review defendants witness list, ans to request for 0.60 
admission, t/conf expert re returns. 

02/24/86 Proof exhibit and witness list, add addit’'l exhibits 0.80 
and witnesses. 

02/26/86 Dictate ltr to plaintiffs, conf LTM/JUB re cross of 0.70 
defendants witnesses. 

 



  

Page No. 

11/10/86 

DATE 

02/26/86 

02/27/86 

03/03/86 

03/03/86 

03/04/86 

03/04/86 

03/05/86 

03/06/86 

03/06/86 

03/17/86 

03/18/86 

03/19/86 

03/24/86 

03/25/86 

03/26/86 

03/26/86 

03/26/86 

03/27/86 

04/23/86 

05/06/86 

06/04/86 

3 TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 09/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Research appointment issue, revise exhibit list. 

Research legislative history. 

T/conf LTM re hearing. 

T/conf LTM re hearing. 

Prep for preliminary injunction. 

Travel to Montogmery, prep exhibits for hearing. 

Attend preliminary injunction hearing. 

Travel to Mobile. 

T/conf with JUB and DEB Fins. 

T/conf re documents, T/conf re historical documents. 

T/conf Alton Turner, conf LTM. 

Draft letter to Court re treaties. 

Conf w/JUB re exhibits, t/conf law clerk re 

scheduled conf call, t/conf historian re sane. 

Research state History re exhibit 187 

Research state history, conf JUB. 

Conference call Judge Thompson and all lawyers. 

Research legislative history 

research legislative hyistory. 

Review order 

Review order approving settlement 

Review order 

HOURS 

O
F
 

OO
 

OO
 

OO
 

&
&
.
,
.
O
 

Oo
 

No
» 

2 
OO

 
OO

 
O
O
 

QO
 
O
Q
 
WW
 

.90 

.00 

.20 

. 20 

. 80 

.80 

.00 

. 50 

.30 

.30 

.30 

.20 

.40 

.80 

.30 

.80 

.20 

. 50 

10 

. 20 

.70 

 



  

Page No. 

11/10/86 

DATE 

06/16/86 

06/17/86 

06/19/86 

06/20/86 

06/23/86 

06/23/86 

06/24/86 

06/30/86 

07/07/86 

07/08/86 

07/15/86 

07/16/86 

07/17/86 

08/05/86 

08/12/86 

08/19/86 

08/20/86 

08/21/86 

08/21/86 

08/26/86 

08/27/86 

4 TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 09/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Review documents 

Research admission 

Conf JUB, receive and review corresp and order 

Research county chair issue 

Review orders, correspondance 

Review orders, correspondance 

Review interrogatories answers 

T/ conf law clerk re conf call 

Review GINGLES opinion 

Review motions, correspondance by defendants 

Conf LTM and JUB, research. 

Research statue re chair 

Research 

Recieve and review motions, correspondence, t/conf 
LTM 

T/conf LTM 

Review file, Section 5 submissions 

Prep trial exhibits 

Travel to Montgomenry, prep for pre-trial conf 

Conf with clients, paralegals, attend status 
conference and settlement hearing 

Prep for trial 

Interview witnesses, prep for trial 

HOURS 

ft
 

So
 
O
O
 

C
C
 

No
 

& 
O
O
 

OO
 

©
.
.
.
 

©
 

©
 

 



  

Page No. 8 TIME OF WANDA J. COCHRAN 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 09/10/86 
11/10/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

08/28/88 Prep for trail, interview witnesses 5.80 

08/29/86 Prep for trial 5.10 

09/01/86 Interview witnesses, T/ conf expert and client 1.60 

09/02/86 T/ conf re witnesses 0.20 

09/02/86 Travel to Montgomery 3.00 

09/03/86 Prep for trial, attend depositions 4.60 

08/04/86 Meet with witnesses, attend trial 8.00 

09/05/86 Attend trial, travel to Mobile 10.50 

* kk Total * Xk k 

170.70 

 



  

STATE OF ALABAMA ) 

ESCAMBIA COUNTY ) 

AFFIDAVIT OF REO KIRKLAND, JR. 
  

Reo Kirkland, Jr., after being duly sworn deposes and 

says as follows: 

"l. I am one of the attorneys for plaintiffs in this 

action. 

2. I was admitted to practice in 1977 and have been 

engaged in the private practice of law continuously as a 

sole practitioner. 

3. I am a member of the Escambia County and Alabama 

Bar Associations. I am licensed to practice before all state 

courts in Alabama and the United States District Court for 

the Southern and Middle Districts. 

4. My current hourly rate for federal civil litigation 

is $100.00 per hour. 

5. Attached hereto is a compilation of the time sheets 

which I maintained during my participation in this case. They 

reflect the work that I have performed for which I have not 

been compensated. 

6. I believe the time reflected by the attached compila- 

tion 1s both reasonable and necessary to properly meet my 

professional responsibilities to the plaintiffs and the plaintiff 

class. 

7. 1 undertook the representation of the plaintiffs 

 



  

in this cause on a contingent fee basis understanding that any 

fee I recover will be by court—award."- 

  

S——— = gl of 
” oo 

py Mo w—— 
  

REO KIRKLAND, JR. 

   

    

  

Sworn to and gulpscribed before 
me this the *fay of November, | os 

%pires 2/17/90 

  

    
   

NOTARY PI 
My CommissiO 

 



REO KIRKLAND, JR. 
ATTORNEY AT LAW 

BREWTON, ALABAMA 
TELEPHONE AREA CODE 205 MAILING ADDRESS 

OFFICE: 867-5711 P.O. BOX 646 
HOME: 867-3384 November 4 P 1 9 8 6 BREWTON, ALABAMA 36427 

FOR PROFESSIONAL SERVICES RENDERED RE: A JOHN DILLARD, ET AL 

V. CRENSHAW COUNTY, ETC., ET AL CIVIL ACTION NO. 85-T7-1332-N 

IN THE DISTRICT COURT OF THE UNITED STATES POR THE MIDDLE 

DISTRICT OF ALABAMA, NORTHERN DIVISION 

  

  

  

  

12/11/85 Phone conference with Larry Menefee & Jerome 
Gray 

12/11/85 Phone conference with Larry Menefee 

12/11/88 Phone conference with Ulysesses McBride 

12/11/85 Phone conference with Jerome Gray 

12/23/85 Receipt & review amended complaint, plaintiff's 
first discovery request and appearance of 
counsel notice 

1/2/86 Receipt & review Of letter to all plaintiffs 
from Larry Menefee 

1/6/86 Receipt & review of letter from J. Blacksher 
to all Probate Judges re: settlement 

1/13/86 Receipt & review Pickens County Motion 
to Dismiss 

1/13/86 Receipt & review Lawrence County request 
for briefing schedule and oral argument 
and motion to dismiss or transfer or sever 
and transfer or to dismiss class action 
allegations 

1/13/86 Receipt and review Etowah County Motion 

to Dismiss 

1/14/86 Receipt and review Lawrence County answer 
for Clerk, Larry Smith 

1/16/86 Receipt and review motion for leave to 
amend complaint and amended complaint  



  

Page Two 

November 4, 1986 

1/16/86 Receipt and review Etowah County motion 

to sever and amended motion to dismiss 

and motion to transfer +4 hr. 

1/16/86 Receipt and review Calhoun County motion 

to dismiss RIEL ya 

1/16/86 Receipt and review Coffee County motion 

to dismiss PIV SL 

1/16/86 Receipt and review of plaintiff's response 

to Pickens County motion to dismiss and 
motion to change identification of parties +L hr. 

1/17/86 Receipt and review of letter brief on 
res judicata raised by Pickens County defendant «15 hr. 

1/20/86 Receipt and review of Pickens County request 

for briefing schedule and oral argument 
on motion to dismiss ‘1: hr. 

1/22/86 Receipt and review of Order of court 

setting motions for hearing «1 hr. 

1/22/86 Receipt and review of Pickens County answer 
to plaintiff's response to Pickens County 
motion to dismiss 2 NL. 

1/24/86 Phone conference w/J. Blacksher re: Escambia 

County settlement “5 hr. 

1/24/86 Receipt & review of nonfiling discovery 

requirement from Clerk of Court «1 hr. 

1/24/86 Receipt & review of plaintiff's request 
for admissions 1.0 hr. 

1/27/86 Receipt & review of Ed Still explanation 
on plaintiff's request for admissions +1 hr. 

1/28/86 Receipt & review of Etowah County redgeust 
for admissions «75 hr, 

1/28/86 Receipt & review of Escambia County brief 
in support of motion to dismiss and/or 

sever and/or transfer «75 hr. 

1/28/86 Receipt & review of amended notice of 

appearance from Lawrence County defendants «1 Are 

1/28/86 Phone conference w/Lee Otts, Escambia 

County attorney «25 hr. 

 



  

Page Three 
November 4, 

1/28/86 

1/29/86 

1/30/86 

1/31/86 

1/31/86 

1/31/86 

2/3/86 

2/4/86 

2/4/86 

2/6/86 

2/10/86 

2/11/86 

2/13/86 

2/14/86 

2/14/86 

1986 

Phone conference w/Jim Webb's secretary 1: AL, 

Receipt & review Pickens County brief in 
support of motion for summary judgment .4 hr. 

Phone conferences w/J. Webb and Blacksher 

firm to set up settlement meeting +25 hr. 

Receipt & review of Lawrence County memorandum 

brief in support of motion to dismiss or 

transfer “5:hr. 

Receipt & review memo in support of Coffee 
County motion to dismiss «2 ht. 

Receipt & review Pickens County substitute 
Of page 1 of brief changing toc motion to 

dismiss «Lhe, 

Phone conference w/Jim Blacksher re: 

settlement meeting +2 DL. 

Receipt & review answer to plaintiff's 
interrogatories and motion to produce by 
Pickens County Probate Judge W.H. Lang, et al 3.0 hr. 

Settlement meeting with J. Blacksher, Lee 

Otts, J. Webb and Escambia County plaintiffs 3.0 hrs. 

Receipt & review of plaintiff's petition 
for preliminary injunction and class certifica~ 
tion order and receipt & review plaintiff's 
brief in response to defendant's motion to 
dismiss and/or sever and/or transfer and in 
support of plaintiff's motion for preliminary 
injunction and class certification with 
attachments +5 BL, 

Receipt & review address correction from 
Deborah Fins +1 hr, 

Receipt & review Order of Court dated 
2/10/86 setting motion hearing for March 
4, 1986 +1shy. 

Receipt & review Etowah County defendant's 
amended answer «3 hr. 

Receipt & review proposed consent decree 

Crenshaw County +15 hr, 

Phone conference w/Jim Blacksher re: preliminary 
injunction and settlement +25 hr. 

 



  

Page Four 

November 4, 

2/17/86 

2/17/86 

2/18/86 

2/18/86 

2/19/86 

2/20/86 

2/21/86 

2/21/86 

2/21/86 

2/24/86 

2/24/86 

2/24/86 

2/25/86 

2/25/86 

1986 

Receipt & review three settlement proposals 
submitted to Lawrence County defendants and 
Etowah County settlement proposal 

Receipt & review motion of Crenshaw County 
Probate Judge to be excused from active 
participation in hearings 

Receipt & review proposed consent decrees 
for the following counties: Escambia, Calhoun, 
Coffee, Crenshaw, Pickens and proposed settle- 
ment with Crenshaw County 

Phone conference w/J. Blacksher re: election 
return evidence and possible settlement 
proposals 

Receipt & review plaintiff's motion to 
shorten time and plaintiff's second discovery 
request 

Receipt & review motion to join Lee County as 
defendant proposed amended complaint and 
proposed consent decree 

Receipt & review proposed consent decrees 
for Talladega County 

Receipt & review Lawrence County defendant's 
Yesponse to plaintiff's first discovery request 

Receipt & review Pickens County answer to 
plaintiff's request for admissions 

Phone conference w/J. Webb re: settlement 
and memo to file 

Receipt & review Order of court dated 2/21/86 
and receipt & review Etowah County answers 
to plaintiff's interrogatories and motion to 
produce 

Receipt & review Escambia County defendant's 
response to request for admissions and responses 
to interrogatories by all Escambia County 
defendants 

Receipt & review offer from Escambia County 
defendants attorney J. Webb 

Receipt & review plaintiff's witness list 
and plaintiff's list of exhibits 

+5 hr. 

+25 hrs, 

 



a 
2/25/86 Receipt & review Lawrence County defendants 

witness list and response to request for 
admissions 

Page Five 
November 4, 1986 

2/26/86 Receipt & review proposed settlement with 
Crenshaw County 

2/26/86 Receipt & review Escambia County's witness 
and document list and Lawrence County supple- 
ment witness list and exhibit list and 
Etoway County witness list 

2/26/86 Phone conference w/J. Blacksher, Larry 

Menefee and Ed Still 

2/26/86 Phone conference w/Jerome Gray 

2/27/86 Receipt & review of plaintiff's additional 
list of exhibits, letter From J. Webb re: 

settlement, and amendment to Escambia County 

defendants designation of documents and 
plaintiff's request for judicial notice 

2/27/86 Phone conferences w/J. Reed, J. Webb, E. 

Still re: settlement negotiations 

2/28/86 Phone conference w/J. Blacksher, J. Webb 

and J. Gray 

2/28/86 Phone conference w/L. Menefee and E. Still 

3/3/86 Receipt & review plaintiff's proposed findings 
of fact and conclusions of law and preliminary 
injunction 

3/3/86 Conference w/J. Blacksher re: Escambia County 

settlement documents 

3/4/86 Phone conference w/J. Webb 

3/4/86 Phone conference w/J. Gray 

3/6/86 Phone conference w/J. Blacksher re: change 
in wording of settlement document 

3/7/86 Phone conference w/J. Gray and J. Webb re: 
district lines meeting 

3/12/86 Travel----Brewton to Montgomery to Brewton 
Conference to agree on district lines w/J. 
Webb, IL. Meneff and J. Gray  



  

Page Six 

“ a 

  

November 4, 1986 

  

3/14/86 Phone conference w/L. Menefee's secretary 
re: Converence w/Judge Thompson +1 hr. 

3/17/86 Travel--Brewton to Montgomery to Brewton 

Settlement converence w/Judge Thompson 6.0 hrs 

3/26/86 Receipt & review letter to Justice Department 
from J. Webb re: preclearance of plan for 
districts and elections in Escambia County +2 hy. 

4/1/86 Receipt & review letter from L. Menefee to 
Justice Department re: preclearance of 

Escambia County plan | fa 

4/16/86 Phone conference w/L. Menefee «2 hr. 

4/17/86 Review file on Crenshaw and Escambia County 

cases 1.0:-hr. 

4/17/86 Receipt & review Escambia and Crenshaw County 
interim orders «25 ht 

4/18/86 Phone conference w/J. Gray +1"hr. 

4/18/86 Travel--Brewton to Montgomery to Brewton 6.5 "hi. 

4/29/86 Phone conference w/L. Menefee re: final order .1 hr. 

5/1/86 Receipt & reveiw proposed final order approving 
settlement and consent decree for Escambai 
County +25 hr. 

5/5/86 Receipt & review final order approving settlement 
and final consent decree for Escambia County .4 hr. 

5/29/86 Receipt & review notice of pretrial hearing, 
order denying Escambia County defendant's motion 
to dismiss, and order and injunction as to Calhoun, 
Coffee, Etowah, Lawrence and Talladega Counties 

and memorandum opinion of the court «15 hE. 

TOTAL HOURS=====—=—==momme=. 52.10 - hrs. 

52.10 hours at $100.00 per hour--=—====mme————— $5,210.00 

Long Distance Phone Charges — rrr mom mon mum unm mo 83.12 

POSE EI CHE we wnm ss i vu pr it ee to ue oot 0 se 30 se wu A te rs st Spm fm 3.45 

Travel 3/12/86 220 miles; Trave. 3/17/86 220 miles; 
Travel 4/18/86 220 miles at $.22 per mile-—-=-==——-—- 145.20 

PATR IG mer wm sri ve v's se ve rc ow se ve 0 6 0 et ee ea de ee 2.00   

TOTAL DUE---85,443.77 

 



® 
EDWARD STILL’S CASE TIME SUMMARY FOR DILLARD V CRENSHAW co 

date 

01/15/86 

01/15/86 

01/16/86 

01/20/86 

01/21/86 

01/21/86 

01/24/86 

01/29/86 

01/30/86 

01/30/86 

02/03/86 

02/03/86 

02/04/86 

02/05/86 

02/05/86 

02/06/86 

02/07/86 

hours 

1.75 

work performed 

Telephone to Menefee re: division of work in 
preparation of case; Starting Peter Kitrell to 
work 

Research on res judicata (Pickens) 

Preparing discovery to defendants; reviewing 
census data 

Received motion to dismiss; Telephone to 
Blacksher re: response to it 

Preparing request to admit 

conferences with Blacksher re: 
and Lawerence Co. 

telephone 
Talladega 

Trip to Talladega to discuss settlement; 
Telephone to Blacksher; work on Settlement 

Telephone to Blacksher re: Pickens brief; 
finding relevant Pickens orders; Letter to 
Blacksher 

Checking old court file on Talladega case 

Telephone from Blacksher re: authority to 
settle 

Telephone from Blacksher re: settlements 

Prep for Lawrence Co. meeting 

Trip to Lawrence Co. 

Telephone from Blacksher re: Lawrence Co. 

Etowah Co. 

research 
Telephone to Floyd, Reed; 

Received Talladega 1970 order; Telephone to 
Blacksher 

trip to Montgomery; settlement discussions 
with various defendants; oral orgument; 
conference with Blacksher, Cochran, Grey, 
Wilson  



02/10/86 

02/11/86 

02/13/86 

02/14/86 

02/14/86 

02/20/86 

02/20/86 

02/21/86 

02/24/86 

02/25/86 

02/26/86 

02/27/86 

02/28/86 

02/28/86 

03/03/86 

03/04/86 

03/05/86 

03/18/86 

03/28/86 

03/31/86 

11.50 

® 
Reading our brief 

Research on Talladega Co; Letter to Blacksher 

Conference with Blacksher re: setlements 

Telephone to, Letter from settlement 
in Etowah 

Floyd re: 

Telephone from Martin re: settlement in 
Lawerence; Telephone from Boyd 

Telephone to, Letter to Vaughan re: Talladega 

Review all settlement offers; Conference with 

Blacksher and Cochran 

Preparing motion for judicial notice; 
Reviewing defendants’ position 

Telephone from Cochran re: exhibits; reading 
Escambia answers to discovery 

Telephone to Blacksher; review of Henderson v 
Graddick 

work on statement of facts; prep for trial 

Escambia: Telephone from Jim Webb re: 
settlement discussions: telephone to Reo 
Kirkland; telephone from Blacksher 

Escambia: telephone conf with Blacksher and 
Kirkland re: settlement 

Trial preparation 

Reviewing proposed findings of facts and 
conclusions of law; telephone calls re: 
tomorrow’s conference with judge 

Trial preparation; conference with judge and 
opposing counsel 

Trial; return trip to Birmingham 

Telephone from Ernie Jones 

reviewing materials Blacksher sent to Judge 

telephone from Blacksher re another request 

2  



  

04/01/86 

04/02/86 

04/03/86 

04/10/86 

04/14/86 

04/15/86 

04/18/86 

04/21/86 

04/24/86 

04/25/86 

04/28/86 

05/12/86 

05/22/86 

06/02/86 

06/03/86 

06/04/86 

06/05/86 

.40 

.40 

«20 

.20 

.20 

«25 

.70 

+50 

«30 

75 

.00 

25 

.80 

.70 

+75 

«2B 

.50 

  

P Jas 
from Judge Thompson; research on primary 
election laws 

telephone to Blacksher re any preparations we 
need to make in anticipation of possible 
rulings by Judge Thompson 

received Calhoun offer of judgment; compared 
to our proposed settlement 

telephone from Blacksher re our response, if 
any, to Calhoun’s offer of judgment 

telephone from Fins re Rule 68 from Calhoun 
Co. 

telephone to Menefee re trial preparation 

telephone to Menefee re trial preparation 

telephone from Menefee; telephone to Maranan; 
telephone to Henderson 

telephone conference w/Maranan re getting 
demographic data needed by Henderson; 
reviewing census reports; telephone to 
Henderson 

telephone to Maranan re maps and statistics 

conference w/Blacksher re Russell Co. 

research 

letter from Judge Thompson; telephone to 
Blacksher re letter 

analysis of Ft. Lauderdale case; letter to 
Blacksher 

received and read orders and opinions 

conference w/Blacksher and Menefee re 
likelihood of appeal by defendants and 
preparation for 23 July hearing 

preparation for hearing; telephone to 
Henderson, Maranan, Blacksher; letter to 

Henderson 

checking Corder file for material to be used 
in trial (Pickens Co.) 

3 

 



  

06/09/86 

06/12/86 

06/13/86 

06/13/86 

06/16/86 

06/16/86 

06/17/86 

06/17/86 

06/19/86 

06/19/86 

06/19/86 

06/23/86 

06/24/86 

06/26/86 

07/07/86 

07/08/86 

08/22/86 3.00 

  

® 
letter from and to Henderson re materials he 

needs for trial, theory of defense, etc.; 
telephone from Blacksher re judge’s request 
for status letter; preparing for Henderson 
testimony 

letter from Jones, 

Calhoun and Pickens 
telephone to Blacksher re 

received statements from Lawrence, Etowah, and 
Talladega counties; telephone to Blacksher and 
Menefee; 

preparing letter to Floyd re offer of judgment 
(Etowah) 

preparing letters to Floyd re offer of 
judgment and settlement; telephone to 
Blacksher (Etowah); letter to clients 

letter from and letter to Henderson 

telephone to Blacksher re settlement 
discussions with defendants 

(Etowah County): telephone to Gray 

conf with Blacksher and Menefee re settlement, 
hearing, etc.; letter from and telephone to 
Henderson re missing data 

(Etowah) reviewing plans of county 

(Lawrence) reviewing county scheduling 
proposal 

telephone to Burnim re work being done by 
assistants at Voting Rights Project 

telephone from Maranan; telephone to Blacksher 
re preparation for trial and stipulation 

telephone to Blacksher 

analysis of Thornburg v Gingles 

reading many documents received from 
defendants in last 2 days; telephone to 
Blacksher 

attending pretrial conference; conference with 

4 

 



  

08/24/86 

08/25/86 

09/02/86 

09/03/86 

09/08/86 

09/10/86 

09/11/86 

09/26/86 

09/30/86 

10/02/86 

10/22/86 

TOTAL 

  

o 139 
Menefee and Cochran re research needed in. case 

1.00 research on Jesse Owens statute in Lawrence 

County 

0.50 conference with Menefee re Pickens probate 
judgeship 

0.20 reading Lawrence Co memo 

0.25 reading our brief 

1.25 conference with Menefee re trial and timing 
problems on elections 

0.10 telephone to Menefee 

3.00 conf w/Menefee re problems in special 
elections; drafting letters to counsel 

0.25 telephone to Menefee re responses from 
counties on election preparations and from 
Justice Dept 

0.75 Crenshaw Co: conference with Menefee re 
election problem; research on state election 
laws 

0.25 Reading our post-trial brief 

0.75 quick review of opinion and orders; conf with 
Menefee 

122.75 hours 

 



a 
STILL LIST OF EXPENSES IN DILLARD 

    
date expense description 

01/21/86 16.05 Postmaster 
01/31/86 10.00 Federal Record Center--Talladega Co case 
02/05/86 75.60 Xerox 
02/12/86 19.55 Telephone 
03/11/86 0.90 Law Library 
03/14/86 115.65 Xerox 
03/14/86 29.24 Telephone 
03/31/86 1.50 xerox 
02/04/86 30.00 travel - 150 miles 
02/07/86 40.40 travel - 202 miles 
02/22/86 40.20 travel - 201 miles 
04/29/86 3.15 xerox 
04/30/86 11.00 Federal Express 
04/30/86 17.24 phone 
01/21/86 16.05 U.S. Postmaster 
01/31/86 10.00 Federal Record Center 
02/05/86 75.60 xerox 
02/02/86 19.55 phone 
03/11/86 0.90 Law library 
03/14/86 113.65 xerox 
03/14/86 29.24 phone 
03/31/86 1.50 xerox 
05/30/86 20.64 phone 
07/08/86 23.00 Federal Express 
07/08/86 31.25 Federal Express 
07/31/86 6.15 xerox 
07/31/86 71.45 phone 
08/28/86 27.00 xerox 
09/30/86 8.36 phone 

TOTAL 864.82 

 



    

® gl 

IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

mn ME ie —  gY 

JOHN DILLARD, et al., 

Plaintiffs, 

Vv. : Civil Action No. CV 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 
et al., 

Defendants. 

REEMA Lo, Lng Sle Sy RE 

AFFIDAVIT 
  

STATE OF NEW YORK ) 

COUNTY OF NEW YORK ) 

DEBORAH FINS, being duly sworn, deposes and says: 

i. I am one of the attorneys for the plaintiffs in this 

case, and I am employed as Assistant Counsel of the NAACP Legal 

Defense and Educational Fund, Inc. ("Legal Defense Fund"). I 

submit this affidavit in support of plaintiffs' application for 

an award of attorneys' fees, costs and expenses. 

2. The Legal Defense Fund is a non-profit organization 

which was founded in 1940 and which has since furnished legal 

assistance in cases involving claims of racial discrimination and 

deprivation of constitutional rights before state and federal 

courts throughout the nation. See NAACP v. Button, 371 U.S. 415, 
  

421 n.5 (1963). The Legal Defense Fund has been approved by the 

 



  

¢ S00. 

  

Appellate Division of the State of New York to function as a 

legal aid organization, and it has been cited. by the United 

States Supreme Court as having a "corporate reputation for 

expertness in presenting and arguing the difficult questions of 

  

law that frequently arise in civil rights litigation." NAACP v. 

Button, supra, 371 U.S. at 422. In the area of voting rights in   

particular, attorneys affiliated with the Legal Defense Fund have 

litigated important cases decided by the Supreme Court (e.g., 

Gingles v. Thornburg, U.S. _ _, 106 S. Ct. 2752 (1988); United 
  

Jewish Organizations v. Carey, 430 U.S. 144 (1977); Allen v. 
  

  

Board of Elections, 393 U.S. 544 (19668); Smith v. Allwright, 321 
  

  

U.S. 649 (1944); Nixon v. Condon, 286 U.S. 73 (1932); as well as 
  

the Circuit courts or three-judge courts (e.g., Brown v. Bd. of 
  

Sch. Com'rs of Mobile County, Ala., 706 F.2d 1103 (11th Cir. 
  

1983); Loalition for Ed. in Dist. 1 v, Board of Elec,, City of 
  

N.Y., 495 P.24 1090 (24 Cir. 1974); Major v. Treen, 574 P. Supp. 
  

325 (E.D. La. 1983) (three-judge court)). 

3. Neither I nor any other attorney on the staff of the 

Legal Defense Fund has accepted or expects to receive any 

compensation or reimbursement from the plaintiffs in this case. 

No counsel fees, costs or expenses will be obtained for work done 

or money spent on this case by the Legal Defense Fund or its 

staff attorneys unless the Court awards such fees, costs and 

expenses against the defendants. Any such award to attorneys 

employed by the Legal Defense Fund will be paid over to the Legal 

Defense Fund. 

 



    

¢ ga 

4. I am admitted to practice law before the following 

courts: the Supreme Court of the United States, the United 

States Courts of Appeals for the Fifth, Sixth and Eleventh 

Circuits; the United States District Court for the Southern 

District of New York; and the New York Court of Appeals. I have 

appeared pro hac vice in numerous other courts. 

5. I graduated with honors from Barnard College in 1975 

and Columbia Law School in 1978. 1 began working for the Legal 

Defense Fund in August, 1978. 

6. Between August, 1978 and April, 1983, I was responsible 

for the Fund's death penalty litigation in the State of Florida, 

the state with the largest death row population in the nation. I 

was also involved as co-counsel in capital cases from other 

jurisdictions. Among the cases in which I was counsel are 

Barclay v. Florida, 463 U.S. 939 (1983); Enmund v. Florida, 458   
  

U.S. 782 (1982); Proffitt v. Wainwright, 685 F.24. 1227 (11th Cir. 
  

  1982), on reh. 706 F.2d 311 (11th Cir. 1983); Washington v. 

Watkins, 655 F.2d 1346 (5th Cir. 1981); Prejean v. Blackburn, 570   

F. Supp. 985 (W.D. La. 1983); State v. McDowell, 310 N.C. 61, 310   

S.E. 2d 301 (1984); Brown, et al. v. Wainwright, 392 So.2d4 1327 
  

(Fla. 1981). There are also countless other death cases in which 

I played a major role in the drafting of briefs, habeas corpus 

petitions and stay applications, but did not serve as counsel of 

record, e.g., Songer v. Wainwright, 769 F.2d 1488 (11th Cir.     

1985) (en banc); Hall v. Wainwright, 733 F.2d 766 (11th Cir. 
  

1984); Reddix v. Thigpen, 728 F.2d 705 (5th Cir. 1984); Dobbert 
  

 



      

® 

v. Wainwright, 718 F.2d 1518 (11th Cir. 1983); Witt v. 
  

  

Wainwright, 714 F.2d 1069 (11th Cir. 1983); Williams v. Maggio, 
  

679 F.24 381 (5th Cir. 1982): Ford v. Strickland, 675 F.24 434 
  

(11th Cir. 1982); 696 F.2d 804 (11th Cir. 1983) (en banc); Palmes 

v. Wainwright, No. 82-583-Civ-J-M (M.D. Fla.); Jones v. 
    

Wainwright, 446 So.2d 1059 (Fla. 1984); and Knight v. Wainwright, 
    

394 So.2d4 997 (Fla. 1981). In numerous other cases I served as a 

consultant on capital trials, direct appeals, clemency or post- 

conviction proceedings, editing briefs, stay papers, clemency 

memos or petitions for writ of certiorari, and researching and 

advising on the formulation of federal constitutional issues, 

e.g. Eddings v. Oklahoma, 455 U.S. 104 (1982); Goode v. 
    

Wainwright, 704 F.2d 593 (11th Cir. 1983); Zeigler v. Wainwright, 
    

473 So.2d 203 (Fla. 1985); Jacobs v. Wainwright, 450 So.2d 200 
  

(Fla. 1984); Demps v. Wainwright, 416 So.2d 808 (Fla. 1982). 4 
  

edited a manual for clemency proceedings in Florida which was 

prepared under my supervision by Columbia Law School students, 

and assisted in the preparation of a manual on post-conviction 

proceedings in capital cases. 

7. In addition to my work in death penalty litigation, I 

have served as counsel in a variety of other cases, all of which 

involved issues related to civil rights, e.g., Martin v. Allain,   

No. J84-0708 (L) (S.D. Miss.) (voting rights suit involving at- 

large election of state court judges); Webb v. County Bd. of   

Educ. of Dyer County, 715 F.2d 254 (6th Cir. 1983) (attorneys' 
  

fees for state administrative work under 42 U.S.C. § 1988); Jones 

 



® i % 

v. Hutto, No. PB-74-C-173 (E.D. Ark.) (employment discrimination 

    
  

class action by employees of the Arkansas Department of 

Corrections); Hubert v. Ward, No. C-C-80-414-M (W.D.N.C.) (North 
  

Carolina multi-institution prison conditions lawsuit); Small v. 
  

Martin, No. 85-987-CRT (E.D. N.C.) (multi-institution prison 

conditions lawsuit); Feamster v. Brierton, No. 79-132-CIV-J-C 
  

(M.D. Fla.) (Florida death row conditions lawsuit); Moran v. 
  

NARF, No.73-702-Civ.-J-S (M.D. Fla.) (employment discrimination 

class action by employees of Naval Air Rework Facility); Jenkins 

v. Missouri, 593 F. Supp. 1485 (W.D. Mo. 1984) (suit to 
  

desegregate the public schools of Kansas City, Missouri, and 

surrounding suburbs); United States v. Charleston County 
  

Consolidated School Board, No. 81-50-8 (D.S.C.) (suit to 
  

desegregate the public schools of Charleston County, South 

Carolina). 

8. I have served on the faculty of the National College 

for Criminal Defense at programs in Charleston, South Carolina 

and Ft. Lauderdale, Florida, and have spoken at similar programs 

presented by the National Legal Aid and Defender Association in 

Atlanta, Georgia and Boston, Massachusetts; by the Florida Public 

Defender Association in St. Augustine and Sarasota, Florida: and 

by a coalition of groups in Richmond, Virginia. I organized and 

spoke at a number of conferences co-sponsored by the Legal 

Defense Fund, the Southern Poverty Law Center and other 

organizations, in Warrenton, Virginia. I have been a trial 

practice seminar leader and appeared as a guest speaker at 

 



    

classes at several law schools, including Yale, Columbia, New 

York University and Hawaii. In 1982 I received the Nelson 

Poynter Award for my work in the defense of capital cases from 

the American Civil Liberties Union. 

9. My hourly rate is $135 per hour. I recently received 

$125 an hour for work performed between 1983 and 1985 (the bulk 

of which was in the summer and fall of 1984) on settlement of 

Hubert v. Ward, No. C-C-80-414-M (W.D.N.C.). Attached as   

Appendix A to this affidavit is a schedule of the hours I have 

spent on this case from my initial involvement in October, 1985 

to the present. These hours were compiled from contemporaneous 

time records which I maintained throughout this period. The 

Legal Defense Fund additionally requests compensation for 

attorney travel expenses in the sum of $199.00, paid by the 

Fund in this case. 

10. In addition to the hours listed in Appendix A, other 

attorneys employed by the Legal Defense Fund have reviewed 

documents filed in this case and have conferred with me from time 

to time concerning this case. These attorneys include Director- 

Counsel Julius L. Chambers, First Assistant Counsel Charles 

Stephen Ralston and Assistant Counsel C. Lani Guinier and Penda 

Hair. In order to provide a conservative statement of the time 

spent on this case and to eliminate any hours which might 

conceivably constitute a duplication of effort, the Legal Defense 

Fund is not requesting fees for the services of attorneys 

Chambers, Ralston, Guinier or Hair. 

 



  

/ 
  

Subscribed and sworn to before 

DEBORAH FINS 

me this 7/ day of November, 1986. 

  

Notary Public 

 



  

DILLARD V. CRENSHAW COUNTY 
  

Attorney Time 

DEBORAH FINS 

From October 1985 to October 1986 

  

Date Services Rendered Hours 

10-23-85 Memo re: proposal to take case «5B 

11-4-85 Draft, proof letter to co-counsel «5 
confirming involvement; retainer letter 

11-25-85 Confer with co counsel re: status, 5 

strategy 

12—-4-85 Confer with co-counsel re: schedule, 3 

strategy, etc. 

1-13-86 Review (scan) mail from 12/20 | 

1-14-86 Review pleadings - Lawrence and 2 
Pickens Counties 

1-21-86 Review Coffee County motion to dismiss; .5 
plaintiffs' response to Pickens County 
motion to dismiss; motion to change name 
of parties; Calhoun County motion to 
dismiss or transfer; confer with co- 
counsel re: orders, scheduling 

1-22-86 Review Pickens County request for .3 
briefing and oral argument; Escambia 
County motion to dismiss; confer with 

co-counsel 

1-23-86 Travel arrangements to Mobile; confer .5 
with co-counsel; review Pickens 
County response 

1-24-86 Confer with co-counsel, prepare .5 
for trip to Mobile 

1-27-86 Travel to Mobile (aborted flight, 12.5 

drive from Birmingham) 

1-28-86 Confer with co-counsel re: status 9.2 

of settlement, strategy, work 

distribution; review pleadings received 
in Mobile (and not New York); consult 

with experts; legal research for brief 

 



  

1-29-86 Research re: joinder, etc. - motion 5.6 

to dismiss; consult with co-counsel, 

witness calls; Pickens County - 
review motion, reread Corder cases, 

consult Ed Still; confer with expert 

1-30-86 Draft portion of brief re: joinder, 6.5 
venue, intro.; review Lawrence County 
motion to dismiss; confer with 
co-counsel re: settlement progress 

1-31-86 Draft transfer section of brief; memos 5.6 

to co-counsel re: research for their 

sections; cite check, proof 

1-31-86 Travel time - return to New York 1.9 

(rest of travel time used for work 

on other cases) 

2—-3-86 Review Etowah County response to «3 

admissions request; scan Pickens 
and Coffee County briefs; letter to 
clerk; review court order, 
Escambia County brief, Pickens 
County page substitution 

2-4-86 Review Escambia County motion to sever; ol 
calls re: brief; cite checking cases in 

brief 

2—-5-86 Confer with co-counsel re: brief; .4 

additional research 

2-10-86 Review Judge's class certification ig ) 
order in Diggs v. Henry County 

2-10-86 Review Pickens County answers 2 
to interrogatories, Lawrence 

County appearance, brief re: motion 
to dismiss 

2-13-86 Review letter to Lee County; motion 5 
for injunction and final of brief; 
confer with co-counsel re: hearing 

2-21-86 Review motion, Etowah County answers 4 
to request to admit; Court scheduling 

order; proposed decrees 

2 

 



  

N 2-26-86 Review pleadings: Crenshaw County «5 
consent, Pickens County answers to 

request for admissions, motion to dismiss; 
Lee County; Lawrence County answers 
to interrogatories; Etowah County answers 
to interrogatories and motion to produce; 
Talledega consent; Judge's order 
2/21; Escambia County response to request 
for admissions; request to shorten time 

3-5-86 Scan Lawrence and Coffee County proposed v2 

3-6-86 

3-10-86 

3-20-86 

3-24-86 

3-27-86 

3-31-86 

4-2-86 

4-4-86 

4-9-86 

4-10-86 

4-17-86 

findings and other pleadings 

Review Lawrence County memo on pre- 

liminary injunction; Etowah County 
adoption of Lawrence County motion; 
confer with co-counsel re: hearing and 
strategy 

Review order re: Lee County, missing 
page from findings of fact 

Review Escambia County notice 

Review court's letters and orders: 
co-counsel letter to court: confer 
with co-counsel; review pre-trial 
orders in Diggs 

Scan motion (duplicate) 

Review court order; review letter 

co-counsel to court re: corrected 

exhibits 

Confer with co-counsel re: status 

Review Escambia County designations of 
documents; offer of judgment Calhoun 
County; call co-counsel 

Confer with co-counsel re: status, 

strategy 

Review mail from Calhoun County, offer 
of judgment; confer with co-counsel 
re: response; draft response; review 
response with co-counsel 

Review court order approving Lee 

County settlement; billing 

3 

 



  

4-29-86 

5-5-86 

5-9-86 

5-12-86 

10-28-86 

11-3-86 

11-4-86 

11-5-86 

Process billing, expenses 

Review court order re: Lee County 

Review co-counsel letter to court; 

Escambia County Order 

Letter to co-counsel 

Prepare attorney's fee affidavit and 
statement of hours 

Proof of affidavit and hours 

Additions to affidavit; calls to 
co-counsel re: expenses, deadlines 

Additions to affidavit; add preparation 
of affidavit and statement of hours to 

statement of hours 

Total: 

 



  

AFFIDAVIT 

Dillard v. Crenshaw 
  

State of Alabama ) 

County of Montgomery ) 

I, Paola Gayle Maranan, being hereby sworn do depose and 
say: 

That from October 1, 1984 to September 30, 1986, 1 served as 
Project Coordinator of the Alabama Voting Rights Project, a 
project of the Civil Liberties Union of Alabama. I served as 
the statewide Project Coordinator throughout the Project's 
duration. The Project was a coalition of attorneys, 
activists, professionals and educators committed to securing 
equal voting rights for all of Alabama's citizens by seeking 
enforcement of the Voting Rights Act of 1965. 

That I am on voluntary leave of absence from Harvard and 
Radcliffe Colleges in Cambridge, Massachusetts where I am a 
student majoring in American Government. I lack one semester 
necessary to complete my B.A. degree. Since October 1, 1984 
I have worked full-time in the field of voting rights. 

That Melinda Guzman-Moore served as a legal intern to the 
Alabama Votng Rights Project during June and July of 1986. 
She 1s a second-year law student at Martin Luther King, Jr. 
Hall. at the University of California at Davis. Noah 
Arceneuax served as an intern to the Alabama Voting Rights 
Project from June to Septmeber of 1986. He is a student at 
the University of Georgia. 

That the Alabama Voting Rights Project of the Civil Liberties 
Union of Alabama expended three-hundred and eighty~-two (382) 
hours of its time working on the above-styled case. As 
Project Coordinator, I expended two-hundred and ninety-nine 
and one-half (299.5) hours working on this litigation; 
Melinda Guzman-Moore and Noah Arceneaux, interns who assisted 
with the litigation and were under my direct supervision, 
expended the remainder of eighty-two and one-half hours 
(82.5). The hours are divisible as such: 

 



    

   

  

Affidavit of Paol 

Dillard v. Crensh 
Page Two 

ayle Maranan , » 

Regarding the remedy hearing for Lawrence, Pickens and 
Calhoun counties: 
Paola Gayle Maranan - thirty-seven (37) hours 
Melinda Guzman-Moore - five (5) hours 

  

These hours were spent preparing a survey regarding the 
methods of election used to elect county chairpersons in each 
of Alabama's sixty-seven (67) counties. 

Regarding the settlement hearing for Etowah and Talladega 
counties: 

Paola Gayle Maranan - eleven (11) hours 

These hours were spent contacting the client group, 
contacting and preparing witnesses for the hearing, and 
attending the hearing. 

Regarding the matter of Pickens County: 
Paola Gayle Maranan - seventy-nine (79) hours 

Melinda Guzman-Moore - fifty-four and one-half (54.5) hours 

These hours were spent gathering election returns and census 
information, developing and drawing redistricting plans, 
conducting a house count of selected areas of the county, 
interviewing potential witnesses and preparing legal memos. 

Regarding the matter of Lawrence County: 

Paola Gayle Maranan - nineteen (19) hours 

Regarding the matter of Talladega County: 
Paola Gayle Maranan - seventeen (17) hours 

Noah Arceneaux - two (2) hours 

Regarding the matter of Calhoun County: 
Paola Gayle Maranan - nineteen and one-half (19.5) hours 

Regarding the matter of Lee County: 
Paola Gayle Maranan - nine (9) hours 

In each county, the time was spent gathering election 
returns, preparing redistricting plans and gathering 
demographic information. 

 



  

Affadavit of pao fifayle Maranan | 
Dillard v. Crensh? ow 

Page Three 
  

Regarding the matter of Crenshaw County: 

Paola Gayle Maranan - twenty-six and one-half (26.5) hours 

These hours were spent gathering election returns and 
demographic information, performing historical research at 
the State Department of Archives, preparing copies of the 
proposed redistricting plan, and preparing for the hearing on 
the motion of contempt regarding the June 1986 primaries. 

Regarding the matter of Etowah County: 
Paola Gayle Maranan - twenty-two (22) hours 

Regarding the matter of Coffee County: 
Paola Gayle Maranan - fifty-six (56) hours 
Melinda Guzman-Moore - eighteen (18) hours 
Noah Arceneaux - three (3) hours 

In each county, the time was spent gathering election 
returns, performing historical ' research at the State 

Department of Archives and History, interviewing potential 
witnesses, gathering demographic information and preparing 
copies of the redistricting plan. 

——— ———— — — ——— {— — — —— — ———— — — ——_  ——— — — —._ o— — ——— — — —— — — — ——— — — — — — ——— —— —— — — — — — o— — 

Regarding the matter of Escambia County: 
Paola Gayle Maranan - three and one-half (3.5) hours 

These hours were spent performing historical research at the 
State Department of Archives and History. 

 



  

Affidavit of pac @cayie Maranan _ i 
Dillard v. Crenshaw 
Page Four 

  

That the contents of this affidavit accurately and truthfully 
reflect the time and task expended by the Alabama Voting 
Rights Project on the above-styled case. 

  

  

Sworn before me this 

fifth, day of November, 1986 
J 

ri We EN 

7 L Qrit 7). TER   
Notary PglRes State of Alabama 

f vif 

My commission expires 67/90

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