Attachments A and B (Time Sheets and Affidavits)

    Attorneys 

Larry T. Menefee 

James U. Blacksher 

Gregory B. Stein 

Wanda J. Cochran 

Reo Kirkland, Jr. 

¥W. Edward Still 

Deborah Fins 

Paola Maranan 

(paralegal) 

ATTORNEYS’ 

Hours 

398.10 

55.10 

382.0 

TOTAL FEES 

FEES 

Fees 

$47,772. 

$44,028. 

350. 

$12,950. 

5,210. 

$14,730. 

$ 6,887. 

$11,460. 

ATTACHMENT A 

00 

00 

00 

00 

00 

00 

50 

00 

19,425. 

7.815. 

22,095. 

10, 331. 

17,190. 00 

$215,081.00 

 



  

Page No. 

10/28/86 

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 

12/11/88 

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 

 



  

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

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

10/28/86 

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 

X Xk X Total Xx ¥ X% 

41.90 

 



  

Page No. 1 TIME OF LARRY T. MENEFEE 
IN DILLARD vs CRENSHAW COUNTY, et al 

FOR 01/01/86 TO 10/27/86 

10/28/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES 

  

HOURS 

356.20



  

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

FOR 01/01/86 TO 10/27/86 

10/28/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

xk Xx Total *** 

365.00 

 



  

Page No. 

10/28/86 

DATE 

12/17/85 

12/19/85 

12/26/85 

*x% Total 

  

¥ Xk X 

1 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



  

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 

  

  

Nagin ; 7 OY ; 7 { 

iT “7. Lea A ry / 
/ 7.) {Al I 4 / \ OL. A {2/0 

NOTARY PUBLIC 
  

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My Cummission Expires January | 

Yor #2 
EY PI 

  

GREGORY B. STEIN 
| 

| 

 



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

FOR 01/01/86 TO 10/27/86 

  

10/28/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DATE DESCRIPTION OF SERVICES HOURS 

 



  

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. 1 believe the time reflected by the attached compila- 

tion is both reasonable and necessary to properly meet my 

professional responsibilities to the plaintiffs and the plaintiff 

class. 

7. I undertook the representation of the plaintiffs 

 



  

in this cause ‘on a contingent fee basis understanding that any 

fee I recover will be by courtaward." 

   

  

  

   

  

me this the & gay of November, 
1986. , 

     

  

My Commissil xpires 2/17/90 

 



  

TELEPHONE AREA CODE 205 

OFFICE. 867-5711 

HOME: 867.3384 

REO KIRKLAND, JR. 
ATTORNEY AT LAW 
307 EVERGREEN AVENUE 

BREWTON, ALABAMA 
MAILING ADDRESS 

P.O. BOX 6486 

November 4 , 1 9 8 6 BREWTON, ALABAMA 36427 

FOR PROFESSIONAL SERVICES RENDERED RE: JOHN DILLARD, ET AL 
  

V. CRENSHAW COUNTY, ETC., ET AL CIVIL ACTION NO. 85-7-1332-N 
  

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE MIDDLE 
  

DISTRICT OF ALABAMA, NORTHERN DIVISION 
  

12/11/85 

12/11/88 

12/11/85 

12/23/85 

1/2/86 

1/6/86 

1/13/86 

1/13/86 

1/13/86 

1/16/86 

Phone conference with Larry Menefee & Jerome 
Gray 

Phone conference with Larry Menefee 

Phone conference with Ulysesses McBride 

Phone conference with Jerome Gray 

Receipt & review amended complaint, plaintiff's 
first discovery request and appearance of 

counsel notice 1 

Receipt & review of letter to all plaintiffs 
from Larry Menefee 

Receipt & review of letter from J. Blacksher 

to all Probate Judges re: settlement 

Receipt & review Pickens County Motion 
to Dismiss 

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 

Receipt and review Etowah County Motion 
to Dismiss 

Receipt and review Lawrence County answer 

for Clerk, Larry Smith 

Receipt and review motion for leave to 
amend complaint and amended complaint 

0 hr. 

+31 hr. 

 



  

Page Two 

November 4, 

1/16/86 

1/16/86 

1/16/86 

1/16/86 

1/17/86 

1/20/86 

1/22/86 

1722/86 

1/24/86 

1/24/86 

1/24/86 

1/27/86 

1/28/86 

1/28/86 

1/28/86 

1/28/86 

1986 

Receipt and review Etowah County motion 
to sever and amended motion to dismiss 

and motion to transfer «4 1, 

Receipt and review Calhoun County motion 
to dismiss «1 hl 

Receipt and review Coffee County motion 
to dismiss v2 DY. 

Receipt and review of plaintiff's response 
to Pickens County motion to dismiss and 

motion to change identification of parties «lhy, 

Receipt and review of letter brief on 
res judicata raised by Pickens County defendant «+5 ‘Hr. 

Receipt and review of Pickens County request 
for briefing schedule and oral argument 
on motion to dismiss «Ahr. 

Receipt and review of Order of court 
setting motions for hearing «1 hr. 

Receipt and review of Pickens County answer 
to plaintiff's response to Pickens County 
motion to dismiss «2 hr. 

Phone conference w/J. Blacksher re: Escambia 
County settlement TC od 

Receipt & review of nonfiling discovery 
requirement from Clerk of Court «1 hr, 

Receipt & review of plaintiff's reques 
for admissions 1.0. hr. 

Receipt & review of Ed Still explanation 
on plaintirf's request for admissions «l:hy. 

Receipt & review of Etowah County regeust 
for admissions «75 hr. 

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

sever and/or transfer «75 hr. 

Receipt & review of amended notice of 
appearance from Lawrence County defendants «1 hr, 

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 

Receipt & review Pickens County brief in 

support of motion for summary judgment 

Phone conferences w/J. Webb and Black 

firm to set up settlement meeting 
sher 

Receipt & review of Lawrence County memorandum 
brief in support of motion to dismiss 
transfer 

oY 

Receipt & review memo in support of Coffee 

County motion to dismiss 

Receipt & review Pickens County subst 
of page 1 of brief changing to motion 

dismiss 

Phone conference w/Jim Blacksher re: 

settlement meeting 

Receipt & review answer to plaintiff’ 
interrogatories and motion to produce 
Pickens County Probate Judge W.H. Lan 

Settlement meeting with J. Blacksher, 

Otts, J. Webb and Escambia County pla 

Receipt & review of plaintiff's petit 
for preliminary injunction and class 
tion order and receipt & review plain 

ltute 

to 

S 

by 
g, et al 

Lee 

intiffs 

ion 

certifica- 

tiffs 

brief in response to defendant's motion to 
dismiss and/or sever and/or transfer 

support of plaintiff's motion for pre 
injunction and class certification wi 
attachments 

Receipt & review address correction f 

Deborah Fins 

Receipt & review Order of Court dated 
2/10/86 setting motion hearing for Ma 

4, 1986 

Receipt & review Etowah County defend 
amended answer 

Receipt & review proposed consent dec 

Crenshaw County 

Phone conference w/Jim Blacksher re: 

injunction and settlement 

and in 
liminary 
th 

rom 

ch 

ant's 

ree 

preliminary 

“2 hy, 

1.0 hr. 

3.0. hrs. 

«Shir. 

“3 "hr. 

 



  

Page Four 

November 4, 1986 

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 

Receipt & review three settlement proposals 

submitted to Lawrence County defendants and 
Etowah County settlement proposal .57hr. 

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

participation in hearings v2 hr. 

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 5 hr, 

Receipt & review plaintiff's motion to 
shorten time and plaintiff's second discovery 
request 25 hy 

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

Receipt & review proposed consent decrees 
for Talladega County «2.-hr. 

Receipt & review Lawrence County defendant's 
response to plaintiff's first discovery request <5 hr. 

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

settlement Phone conference w/J. Webb re: 

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 «2 Dr. 

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 web hr. 

vi NX 

 



Page Five 
November 4, 1986 

  

2/25/86 Receipt & review Lawrence County defendants 
witness list and response to request for 

admissions .25 hr. 

2/26/86 Receipt & review proposed settlement with 

Crenshaw County +25 hr. 

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 +5 hr. 

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

Menefee and Ed Still +5 Nr. 

2/26/86 Phone conference w/Jerome Gray +54hyr., 

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 1.0 hr. 

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

Still re: settlement negotiations 2.0 hrs, 

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

and J. Gray AL 

2/28/86 Phone conference w/L. Menefee and E. Still «25 hr. 

3/3/86 Receipt & review plaintiff's proposed findings 
of fact and conclusions of law and preliminary 
injunction 1.5 hr. 

3/3/86 Conference w/J. Blacksher re: Escambia County 
settlement documents +25 hr. 

3/4/86 Phone conference w/J. Webb «25 hr. 

3/4/86 Phone conference w/J. Gray v25 hr. 

3/6/86 Phone conference w/J. Blacksher re: change 
in wording of settlement document «25 hr. 

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

district lines meeting «25 hr. 

3/12/86 Travel----Brewton to Montgomery to Brewton 
Conference to agree on district lines w/J. 

Webb, L. Meneff and J. Gray 6.0 hr. 

 



  

Page Six 
November 4, 1986 

3/14/86 Phone conference w/L. Menefee's secretary 

re: Converence w/Judge Thompson +1 Rr. 

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

Settlement converence w/Judge Thompson 6.0 hrs. 

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

4/1/86 Receipt & review letter from L. Menefee to 
Justice Department re: preclearance of 
Escambia County plan 1-ht, 

4/16/86 Phone conference w/L. Menefee v2 Ar. 

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:hr. 

4/18/86 Phone conference w/J. Gray hy. 

4/18/86 Travel--Brewton to Montgomery to Brewton 6+5. hr. 

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 hy. 

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 «45 hr. 

TOTAL HOURS—=—===———mm=———— 52.10 hrs. 

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

Long Distance Phone Charges———=—=====m meer em ———————— 83.12 

POS LAGE vr wr cr me set tr sw oe st son we se 1 we ie cs aw or sor vet pr we penn or or pw es 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 

PATK LIIC mm sviom tr tr mr vt son ro rr mtr ene wr a ce sr ms gn 2.00 

  

  

TOTAL DUE---855,443.77 

 



  

EDWARD STILL’S CASE TIME SUMMARY FOR DILLARD V CRENSHAW CO 

date hours 

01/15/86 1.75 

01/15/86 1.50 

01/16/86 5.00 

01/20/86 0.25 

01/21/86 1.75 

01/21/86 0.50 

01/24/86 6.75 

01/29/86 1.00 

01/30/86 0.75 

01/30/86 0.25 

02/03/86 0.40 

02/03/86 0.60 

02/04/86 5.00 

02/05/86 0.25 

02/05/86 1.75 

02/06/86 0.25 

02/07/86 7.75 

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 

telephone conferences with Blacksher re: 
Talladega and Lawerence Co. 

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 tc 
settle 

Telephone from Blacksher re: settlements 

Prep for Lawrence Co. meeting 

Trip to Lawrence Co. 

Telephone from Blacksher re: Lawrence Co. 

Etowah Co. : Telephone to Floyd, Reed; 
research 

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. 

10. 

.40 

.80 

.50 

«10 

«20 

.60 

.40 

«50 

.70 

«50 

«75 

.60 

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 

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 

.60 

.30 

.00 

+25 

«70 

.25 

+25 

.20 

+30 

.10 

.00 

.80 

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, telephone to Blacksher re 
Calhoun and Pickens 

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 

0.25 

Menefee and Cochran re research needed in .case 

research on Jesse Owens statute in Lawrence 

County 

conference with Menefee re Pickens probate 
judgeship 

reading Lawrence Co memo 

reading our brief 

conference with Menefee re trial and timing 
problems on elections 

telephone to Menefee 

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

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

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

Reading our post-trial brief 

0.75 quick review of opinion and orders; conf with 
Menefee 

122.75 hours 

 



  

Page No. 

10/28/86 

DATE 

11/08/85 

11/11/85 

11/12/85 

11/20/85 

11/26/85 

12/06/85 

12/09/85 

12/09/85 

12/10/85 

12/11/85 

12/12/85 

12/13/85 

12/17/85 

12/19/85 

12/20/85 

12/27/85 

* XX Total X XX 

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

FOR 11/08/85 TO 12/31/88 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

Research-Senate Committee findings(.5) confer with 
LTM, JG (.8) edit complaint(.7). 

Research interrogatories. 

Draft Planitff's First Discovery Request. 

Draft interrogatories. 

Conference with LTH. 

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 

S
v
 

D
0
 

oO
 

O
L
)
 

14. 

.00 

.70 

.70 

.70 

.30 

.80 

.90 

. 50 

.50 

.60 

. 80 

.60 

. 30 

.40 

. 80 

. 20 

30 

 



  

Page NO. 

10/28/86 

DATE 

* kX Total * %k % 

  

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

FOR 01/01/86 TO 10/27/86 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES HOURS 

170.70



  

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 
65/30/86 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 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

RISE WSS, al a Na RE 

JOHN DILLARD, et al., 

Plaintiffs, 

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

CRENSHAW COUNTY, ALABAMA, 

et al., 

Defendants. 

JIT CY IIR oS A Ea LS ERT 

AFFIDAVIT   

STATE OF NEW YORK ) 
: 8S. 

COUNTY OF NEW YORK ) 

DEBORAH FINS, being duly sworn, deposes and says: 

, 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 

 



  

® 

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 (1986); United 
  

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

Board of Elections, 393 U.S. 544 (1966); 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); Coalition for Ed. in Dist, 1 Vv, Board of ‘Flec., City of 
  

  

N.Y., 495 F.2d 1090 (2d Cir. 1974); Major v. Treen, 574 F. 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. 

 



  

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. I 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.2d 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.2d 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.2d 381 (5th Cir. 1982); Ford v. Strickland, 675 F.2d 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.2d 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 Vv.   

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). I   

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. 

1. 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 

 



  

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 wv.   

artin, 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 

me this */ day of November, 1986. 

  

Notary Public 

7 

  

DEBORAH FINS



  

10-23-85 

11-4-85 

11-28-85 

12-4-85 

1-13-86 

1-14-86 

1-21-86 

1-22-86 

1-23-86 

1-24-86 

1-27-86 

1-28-86 

DILLARD V. CRENSHAW COUNTY 
  

Attorney Time 

DEBORAH FINS 

From October 1985 to October 1986 

  

Services Rendered Hours 

Memo re: proposal to take case -5 

Draft, proof letter to co-counsel 5 
confirming involvement; retainer letter 

Confer with co counsel re: status, 5 

strategy 

Confer with co-counsel re: schedule, + 3 

strategy, etc. 

Review (scan) mail from 12/20 3 

Review pleadings - Lawrence and “2 
Pickens Counties 

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 

Review Pickens County request for «3 

briefing and oral argument; Escambia 

County motion to dismiss; confer with 
co-counsel 

. On
 Travel arrangements to Mobile; confer 

with co-counsel; review Pickens 
County response 

on
 Confer with co-counsel, prepare 

for trip to Mobile 

(6
) Travel to Mobile (aborted flight, 12. 

drive from Birmingham) 

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 

1-30-86 

1-31-86 

1-31-86 

2-3-86 

2-4-86 

2—-5-86 

2-10-86 

2-10-86 

2-21-86 

joinder, etc. - motion 
consult with co-counsel, 

witness calls; Pickens County - 

review motion, reread Corder cases, 

consult Ed Still; confer with expert 

Research re: 

to dismiss; 

Draft portion of brief re: joinder, 

venue, intro.; review Lawrence County 

motion to dismiss; confer with 

co-counsel re: settlement progress 

Draft transfer section of brief; memos 

to co-counsel re: research for their 

sections; cite check, proof 

Travel time - return to New York 

(rest of travel time used for work 

on other cases) 

Review Etowah County response to 

admissions request; scan Pickens 

and Coffee County briefs; letter to 

clerk; review court order, 

Escambia County brief, Pickens 

County page substitution 

Review Escambia County motion to sever; 

calls re: brief; 

brief 

Confer with co-counsel re: brief; 

additional research 

Review Judge's class certification 

order in Diggs v. Henry County 

Review Pickens County answers 
to interrogatories, Lawrence 

County appearance, brief re: motion 

to dismiss 

Review letter to Lee County; motion 

for injunction and final of brief; 

confer with co-counsel re: hearing 

Review motion, 

to request to admit; 

order; 

Etowah County answers 

Court scheduling 

proposed decrees 

cite checking cases in 

(61
1 

w
 

 



  

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 2 

findings and other pleadings 

3-6-86 Review Lawrence County memo on pre- J 
liminary injunction; Etowah County 
adoption of Lawrence County motion; 
confer with co-counsel re: hearing and 
strategy 

3-10-86 Review order re: Lee County, missing 1 
page from findings of fact 

3-20-86 Review Escambia County notice «id 

3-24-86 Review court's letters and orders; 3 

co-counsel letter to court; confer 

with co-counsel; review pre-trial 
orders in Diggs 

3-27-86 Scan motion (duplicate) ig 

3-31-86 Review court order; review letter v2 

co-counsel to court re: corrected 

exhibits 

4-2-86 Confer with co-counsel re: status “| 

4-4-86 Review Escambia County designations of 4 
documents; offer of judgment Calhoun 

County; call co-counsel 

4-99-86 Confer with co-counsel re: status, «2 

strategy 

4-10-86 Review mail from Calhoun County, offer 1.0 

of judgment; confer with co-counsel 
re: response; draft response; review 

response with co-counsel 

4-17-86 Review court order approving Lee «5 

County settlement; billing 

3 

 



  

4-29-86 Process billing, expenses 4 

5-5-86 Review court order re: Lee County «l 

5-9-86 Review co-counsel letter to court; | 

Escambia County Order 

5-12-86 Letter to co-counsel “3 

10-28-86 Prepare attorney's fee affidavit and 1.0 
statement of hours 

11-3—-86 Proof of affidavit and hours “1 

11-4-86 Additions to affidavit; calls to 5 
co-counsel re: expenses, deadlines 

11-5-86 Additions to affidavit; add preparation 4 
of affidavit and statement of hours to 

statement of hours 

Total: 
BE io" 

 



  

AFFIDAVIT 

Dillard Vv. 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. 1 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 elghty-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 Pao Q® Mar.anan 

Dillard Vv. Ct enshaw 

Page Two 

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 Paol ay le Maranan 

Dillard v. Crensl 

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, per forming historical research at the State 

Department of Archives and History, interviewing potential 

wltnesses, gathering demographic information and fr pant dni 

copies of the redistricting plan. 

p—— aad 

—~ — 3 5 ( oun / * 
madttar of Escamnpla ~ 
maces + 

thre and one-half 
(3.5) hours 

Regarding the 

paola Gayle Maranan 

ata 

ng historical 
researc 

e 

i erforml 
spent Pp a History. 

These hours were 

state Departmen 

   



  

Affidavit of Paola cdayle Maranan 

Dillard Ve Crensfilly 

p age 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 

vd a2 / 7] leas 
Notary Publ; c, State of Alabama 

My commission expires 4 0/% 

  

  

(OTA ARN reer earners SSD Ay EERE TEE EEE EERE. 

 



  

% * 
ATTACHMENT B 

Page No. 1 
10/30/86 

DILLARD,ET. AL. vs CRENSHAW COUNTY, ALABAMA, ET. AL. 
EXPENSES INCURRED FROM 11/08/85 THRU 10/30/86 

EXPENSES INCURRED AMOUNT 

Americian Express-meals,airfare, lodging,auto 2201.08 

Attorney Travel-personal auto 1003.72 

Court Costs-filing fees, copies 138.50 

Court Reporter 1236.95 

Experts 43111.96 

Lexis-legal research 232.02 

Paralegals : 5010.93 

Photocopying 3044.60 

Postage 514.14 

Professional Copying 235.05 

Telephone-long distance 069.30 

Xk%x Total *** 

57698.25 

W. Edward Still 864.82 

Reo Kirkland, Jr. 233.77 

Deborah Fins 199.00 

ALL TOTAL EXPENSES $58995.84