Plaintiff's Supplemental Motion for an Award of Attorneys' Fees and Expenses; Affidavit of Larry T. Menefee and Attached Exhibits

    LARRY T. MENEFEE 

ATTORNEY AT LAW 

FIFTH FLOOR TITLE BUILDING 

300 NORTH TWENTY-FIRST STREET 

BIRMINGHAM, ALABAMA 35203 

(205) 322-7300 

April 19,4938 

Ms. Loretta G. Whyte 

Clerk, United States Courthouse 

500 Camp Street 

New Orleans, Louisiana 70130 

RE: Major v. Treen 
Eivil Action No. 82-1192 

Dear Ms. Whyte: 

  

Please find enclosed the original of Plaintiffs Supplemental 

Motion for Award of Attorneys' Fees and-Expenses and an original 

copy of Plaintiffs' Memorandum in Support of Plaintiffs 

Supplemental Motion for Award of Attorneys! Fees and Expenses. 

The original motion for award of attorneys fees and expenses is 

currently under submission to Judge Collins. If you have any 

questions about this filing please contact me or, locally Wr. 

Bill Quigley at (504) 524-0016. 

Thank you for your attention to this. 

Sincerely, 

LTM:mp]l 

PEL Se 

enclosure 

cc: R. James Kellogg Lani Guinier 

Steven Scheckman Kendall Vick 

Armand Derfner William P. Quigley 

Stanley Halpin  



IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF LOUISIANA 
  

BARBARA MAJOR, ET AL., 

Plaintiffs, 

CIVIL ACTION NO. 82-1192 
SECTION C 

Ve. 

DAVID C. TREEN, ETC., ET AL., 

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Defendants. 

PLAINTIFF'S SUPPLEMENTAL MOTION FOR AN AWARD OF ATTORNEYS' 
FEES AND EXPENSES 
  

  

Plaintiffs move the court for an award of attorney fees and 

expenses against the defendants, David C. Teen et. al. Plaintiffs 

are entitled to recover their reasonable attorneys fees and 

expenses pursuant to the provisions of 42 U.S.C Sections 19731 (e) 

and 1988. This motion is supplemental to plaintiffs' pending 

motion filed in September 1984. This motion requests 

compensation, as detailed below, for time and expenses for the 

three year period from May 1985 to the present. 

1. Attached hereto as exhibits are affidavits of plaintiffs 

attorneys detailing the time and expenses incurred by the 

plaintiffs in this litigation. In summary those affidavits 

reflect the following:  



ATTORNEY FEES: 

Attorney Hours Rate/hr Fee Requested 

Larry T. Menefee 295.7 $3002 $88,710 
Julius L. Chambers 15.0 $3002 4,500 

  

Subtotal $93,210 

EXPENSES: 

Attorney Amount 

Larry T. Menefee $2,247.25 
Julius L. Chambers 732.35 

Subtotal $2,979.60 

TOTAL FEES AND EXPENSES $96,189.60 

2. Additionally, plaintiffs request compensation for two 

expert witness for their time responding to the discovery request 

of the defendants. The defendants noticed and took the discovery 

depositions of Frank Parker and Robert Weil. The subpoenas issued 

by the defendants required the deponents to gather substantial 

documents and conduct research in preparation for the deposition. 

Mr. Weil expended a total of 9.9 hours responding to the discovery 

request of the defendants; 2.0 hours in deposition and 7.9 hours 

in preparation. Mr. Parker expended at total of 5.5 hours 

responding to the discovery request of the defendants; 1.4 hours 

in deposition and 4.1 hours in preparation. Plaintiffs are 

entitled to recover these expenses under the same authority that 

  

t This represents Mr. Menefee's current non-contingent hourly 
billing rate of $150/hr. doubled because of the contingency as 
described in the first attached affidavit. 

2 This represents Mr. Chambers standard non-contingent hourly 
billing rate without enhancement. See the second attached 
affidavit.  



allows recovery of all other expenses in this action and based on 

the provisions of Fed.R.Civ.P. 26(b) (4) (C) which allows recovery 

of the cost of responding to discovery. This matter was not ruled 

upon by the magistrate and these expenses are not part of 

plaintiffs' prior motion for award of fees and expenses. The 

defendant sought this discovery and should pay the expense for 

obtaining it. Please see the third attachment for a description 

of these expenses. The total of these expenses is $2,607. 

3. This action was taken a totally contingent fee basis. 

Plaintiffs attorneys will not recover fees unless they are awarded 

by the court. There has been a considerable delay in the 

recovery of fees and expenses. Plaintiffs' attorneys have lost 

the value of the use of the money and the risk of nonrecovery is 

heightened. 

WHEREFORE, plaintiffs pray that this court will award 

plaintiffs their attorneys fees and expenses as described above. 

Respectfully submitted this 17 day of April, 1988. 

eh Cw 
  

~LARRY T|. MENEFEE 
Fifth Floor Title Building 
300 North 21st Street 

Birmingham, AL 35203 
(205) 592-6227 

R. JAMES KELLOGG 
130 Jane Street #4-5 
New York, NY 10014 

STEVEN SCHECKMAN 
700 Camp Street 
New Orleans, LA 70130 

(504) 528-9500 

ARMAND DERFNER 

Box 608 

Charleston, SC 29402 

WILLIAM P. QUIGLEY 

631 St. Charles Avenue 
New Orleans, LA 70130 

(504) 524-0016 

STANLEY HALPIN 
2206 W. St. Mary 
Lafayette, LA 70506 
{318) 367-2207 

LANI GUINIER 
Legal Defense Fund 
99 Hudson Street 

16th Floor 
New York, NY - 10013 
(212) 219-1900  



CERTIFICATE OF SERVICE 
  

I hereby certify that the foregoing brief has been 

served upon the following by mailing a copy thereof by first class 

United States mail, properly addressed and postage prepaid on this 

wy 3 » 2 
the )J day of pr / 198% : 

bed 
Kendall Vick, Esq. 
Assistant Attorney General 
State of Louisiana 
Department of Justice 
7th Floor, 234 Loyola Building 
New Orleans, LA 70112-2096 

  

/ 

  

Larry J earee) 

 



1st Attachment 

Affidavit of Larry T. Menefee 

STATE OF ALABAMA ) 

COUNTY OF JEFFERSON ) 

Larry T. Menefee being duly sworn deposes and says as 

follows: 

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

action. I was admitted to practice in 1971. TI served for one 

year as a law clerk to the Hon. Daniel H. Thomas, United States 

Distirct Judge for the Southern District of Alabama. I am engaged 

in the private practice of law. I was.previously associated with 

firms Crawford Blacksher Figures & Brown and subsequently 

Blacksher Menefee & Stein, P.A. in Mobile, Alabama. Virtually my 

entire practice is in the area of constitutional and civil rights 

litigation in federal courts. In the past eight years most of my 

work has been in the area of voting rights. I have also 

represented a number of plaintiffs and their attorneys in claims 

for court awarded fees. A copy of my curriculum vitae is 

attached. 

2. I am a member of the bar of 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, and the Northern District of Florida. I am a member of 

the American and Alabama Bar Associations and have received and 

"a-v" rating in Martindale-Hubbell. 
   



3. Attached hereto are copies of my time records. These 

records are maintained by me on a contemporaneous basis and 

reflect the work that I performed on this litigation through the 

dates indicated. I have reviewed these records and, in my 

professional judgment, the time reflected is both reasonable and 

necessary to represent the interests of my clients. I have 

exercised some billing judgment and on occasion excluded time 

which, though expended by me, I did not think should be charged to 

the opposing party in this case. These time records reflect 

several major expenditures of time which, even in retrospect I 

believe to be reasonable and fully justified in this litigation. 

a. Between May 5 and May 31, 1985 the records reflect 

about 85 hours. That time included four full days of hearings and 

a conference with the magistrate; probably 30 to 40 hours of time 

in court. Additionally there were telephone conferences with the 

magistrate, post-hearing responses to defendants' discovery and 

substantial document preparation. As the record reflects the 

hearings involved a number of witnesses, depositions and exhibits. 

b. A second major expenditure of time (approximately 40 

hours, 6/4/85 to 6/13/85) was preparing proposed findings and 

conclusions. Considering the issues raised by the defendants and 

allowed by the court and the record developed I believe that time 

was reasoable. 

c. A third major expenditure of time (approximately 45 

hours, 7/17/85 to 8/23/85) was preparing plaintiffs' reply brief. 

The defendants filed a draft and then a final set of proposed 

findings and conclusions each approximately 300 pages long. The  



attachments and exhibts to them even longer. Because it was filed 

initially in draft form and was of such volume I was forced to 

expend somewhat more time than I would normally expect. Those 

three areas account for virutally all of the 193.7 hours I 

expended in from May 5, 1985 to the end of the year. Virtually 

all of that time was expended by August 23, 1985; within three 

months from the begining of the hearings on attorney fees. 

d. For the two year period of 1986 and 1987 I expended 

a total of 97.3 hours. Most of that time was expended in 1986 

briefing and presenting objections to the recommendation of the 

magistrate. Also, some substantial effort was expended 

researching and briefing the Supreme Court opinion in Delaware 

Valley. With the case pending so long it has necessarily required 

more time to keep up with intervening events. 

4. Attached hereto is a statement of expenses incurred by me 

in connection with this litigation. I have reviewed these 

expenses and believe they are reasonable and necessary to 

represent the plaintiffs in this litigation. Furthermore they are 

the type of expenses traditionally billed by an attorney in 

private practice to their clients. That is to emphasize that the 

hourly rates discussed below are not expected by lawyers in 

private practice to compensate the lawyer for the kind of expenses 

shown in the attachment hereto. 

5. My current non-contingent hourly rates that I am 

presently charging clients are $125 to $150 per hour. I have made 

a considered study of attorney fees in this area and believe that 

this non-contingent hourly rate is consistant with the market for  



attorneys in this geographical area of similiar experience and 

ability handling specialized federal civil litigation. However 

this case was taken on an entirely contingent fee basis. I have 

been paid nothing for my legal services to date. Attorneys in 

private practice handling litigation on a contigent fee basis 

generally receive when successful fees that range from two to 

eight times the non-contingent hourly rates. 

6. There are few if any experienced attorneys in this part 

of the country who would have undertaken this litigation on a 

contingent fee basis. Attorneys who represent plaintiffs in 

civil rights cases with any regularity are quickly stigmatized by 

the bar and public and are largely excluded from the relatively 

few fee generating clients.: Although a number of attorneys have 

attempted it, very few attorneys have been able to develop a 

private practice which included a substantial component of civil 

rights litigation. In spite of several congressionally enacted 

fee-shifting statutes a stable and experienced plaintiffs' civil 

rights bar has not developed. This is contrasted with other 

contingent fee litigation in the areas of personal injury, 

antitrust and securities litigation which have developed 

plaintiffs' bars which are experienced and highly skilled. I do 

not believe that it is possible to maintain a private practice and 

  

1 The undesirability of handling civil rights litigation is 
discussed in such cases as Yates v.Mobile County Personnel Bd., 
719 F.2d 1530 (llth Cir. 1983) and York v. Alabama State Bd. of 
Ed., 631 F.Supp. 78 (M.D. Ala. 1986) relative to my own practice. 
More generally see Heinz & Laumann, Chicago Lawyers: The Social 
Structure of the Bar, New York, 1982 an ABA supported study at 
Chapter 4. 

  

  

  

   



handle substantial civil rights litigation. I am closing my 

practice this summer. I believe that it is absolutely essential 

that enhancements of at least two to four times the non-contingent 

hourly rates must be awarded if attorneys in private practice are 

going to be attracted to represent plaintiffs in civil rights 

cases. 

7. This case presents an unfortunate example of the most 

serious problems I discussed in the preceding paragraph. 

Plaintiffs won a very important and fiercely constested victory 

more than four years ago yet have received none of their expenses 

or any fees as of this date. During the pendency of the fee 

application all of the plaintiffs' attorneyswhowere in private 

practice changed their professional associations. This is further 

evidence of the instability of the plaintiffs' civil rights bar. 

The economic stress on the plaintiffs's attorneys have been 

severe. 

8. I deeply regret the number of hours expended on the 

attorney fee issues in this case. I undertook representation to 

recover fees in this case at the request of the attorneys who had 

handled the merits of the litigation as a professional courtesy 

because; 1) I had experience in both voting rights and attorney 

fee applications, 2) would bring a more detached view to these 

issues since I had not handled the merits, and 3) could help 

mediate if any conflicts developed in the presentation of 

plaintiffs' claim. I have handled a number of fee applications 

for other attorneys. They normally require 20 to 50 hours of my 

time and never more than 100 hours. I believe that refering this  



matter to the magistrate caused significantly more time to be 

expended than otherwise. In order to have a full record developed 

for the District Judge the Magistrate allowed all issues and 

facts to be raised and fully contested. The litigation process 

thus served to expand issues and factual disputes rather than 

narrow them. Unfortunately this was consistant with the interests 

of the defendants to delay a decision as long as possible. I used 

every procedural device I knew to narrow facts and issues in 

dispute but because of the procedural posture of the case and 

goals of the defendant such efforts were unsuccessful. I have 

been in other protracted and hard fought litigation. This fee 

application is however the most intractable litigation I have ever 

been involved in. Even with hindsight I do not believe this fee 

litigation could reasonably have been handled with less time. It 

was certainly in my financial, personal and professional interest 

to handle it with less time if it was possible. I note that the 

Magistrate who observed the fee litigation allowed all time 

claimed by me to the date of the fee hearing except travel time. 

    

Date: 44 4 17.1988 Har fimton Ta 

Larry T. Menefee 

Sworn to subscribed before me 

this _ | day of dl “08 2. 
7 

CF 
Twa No ofiimix 
NGTARY PUBLIC Y , 

My commission expires: 7/15/9¢ 

  

  

   



 



 



 



 



 



Page No. 

06/26/87 

DATE 

05/05/85 

05/06/85 

05/07/85 

05/08/85 

05/09/85 

05/10/85 

05/13/85 

05/14/85 

05/15/85 

05/16/85 

05/20/85 

05/21/85 

05/22/85 

05/23/85 

TIME OF LARRY T. MENEFEE 
IN MAJOR v. TREEN 

FOR 05/05/85 TO 05/18/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

travel to N.0O. and trial .prep 

trial and trial prep 

trial and trial prep 

return travel to Mobile, research and document 

preparatioin 

telephone conference with magistrate and defense 
counsel re supplemental statements, confer with 
clients re same 

document and witness prep for resumption of hearing, 
draft and proof motion for preliminary 
recommendation 

witness and document preparation, confer re motion 

for preliminary recommentdatien 

travel and return, prepare for and attend hearing 
before magistrate 

research and post-trial prep, telephone conference 
with magistrate and co-counsel 

research re post-trial matters and prep for depo of 
Barham 

research and prep for Barham and other post-trial 

matters 

research and prepare re settlement issues before 
magistrate, confer with clients re same and re 
post-trial supplemental statments 

research and draft answers to defendant 
interrogatories, research re further post-trial 
submissions 

research and draft answers for def interrogatories 
and re supplemental submissions to court  



Page NO. 

06/26/87 

DATE 

05/28/85 

05/29/85 

05/30/85 

05/31/85 

06/03/85 

06/04/85 

06/05/85 

06/06/85 

06/07/85 

06/10/85 

06/11/85 

06/12/85 

06/13/85 

06/27/85 

06/28/85 

07/02/85 

TIME OF LARRY T. MENEFEE 

IN MAJOR v. TREEN 

FOR 05/05/83 TO 05/18/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research and prepare summary of all claims for 
purposes of settlement conference with magistrate 

travel to N.O. and return, prepare for and take 

depostion of Mack Barham, prepare for and attend 

settlement conference with Magis., confer with 
client 

research and confer with clients re settlement offer 

confer with client and def. counsel re settlement 
offer, draft letter to magis. re same and consult 

with clients re post-trial submissions. 

proof and sign letter to magistrate, confer with 
client re settlement and research re post-Blum 
enhancement cases 

research and draft post trial -findings 

research and draft post trial findings 

research and draft post trial findings 

research and draft post trial findings 

research and draft post trial findings 

research and draft post trial findings 

research and draft post trial findings 

research and draft post trial findings 

t w/ magistrate's clerk re briefing schedule 

t. w/ magistrate's clerk re briefing schedule, 
research re Bower's refusal to pay for expert 
deposition 

research re defendant refusal to pay experts for 
deposition  



Page No. 

06/26/87 

DATE 

07/08/85 

07/09/85 

07/10/85 

07/12/85 

07/17/85 

07/24/85 

07/25/85 

07/30/85 

07/31/85 

08/01/85 

08/05/85 

08/06/85 

08/07/85 

08/13/85 

08/14/85 

08/15/85 

08/16/85 

08/21/85 

08/22/85 

08/23/85 

TIME OF LARRY T. MENEFEE 

IN MAJOR v. TREEN 

FOR 05/05/85 TO 05/18/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

t. from magistrate's office requesting authority for 
costs of experts, research re same 

research and draft letter to magistrate 

draft and proof letter to magistrate 

review court orders 

research re reply brief issues 

read preliminary copy of defendant brief and draft 
letter to magistrate 

research and draft reply brief 

research and draft reply brief 

research and draft reply brief- 

research re defense brief and draft 

research and draft re reply brief 

research and draft reply letter on expert fees 

confer with defense counsel why brief has not been 
filed, confer with co-counsel 

confer with client/co-counsel re brief 

read defendant submission 

research and draft brief 

research and draft brief 

research and draft brief 

research and draft reply brief and cover letter 

research, draft and proof reply brief  



Page No. 

06/26/87 

DATE 

10/23/85 

10/29/85 

01/17/86 

02/26/86 

04/01/86 

04/18/86 

04/25/86 

04/29/86 

07/17/86 

07/18/86 

07/21/86 

07/23/86 

07/24/86 

07/30/86 

08/21/86 

08/27/86 

08/28/86 

08/29/86 

09/08/86 

09/10/86 

TIME OF LARRY T. MENEFEE 

IN MAJOR v. TREEN 

FOR 05/05/85 TO 05/18/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OF SERVICES 

research re letter from Finn 

research and draft letter to magistrate re 
supplemental cases 

research and draft letter to magistrate and 

co-counsel 

review Arriolla decision and draft letter to 

magistrate _ 

confer with client and research re mandamus 

research letter to Magistrate, t with Scheckman and 
Kellogg 

research and draft letter to .court 

draft and confer re letter to Judges 

read recomendation, research and confer with clients 

conference call and research 

research and drft 

research and draft 

research and draft 

research 

read and proof final draft of brief 

read defense objection and t with court 

confer with Scheckman and Quigley 

letter to court 

confer with court and client 

confer with court and co-counsel re argument 
schedule  



Page No. 

06/26/87 

DATE 

09/19/86 

09/26/86 

09/30/86 

10/03/86 

10/06/86 

10/07/86 

10/10/86 

10/21/86 

10/23/86 

10/29/86 

11/04/86 

11/05/86 

11/06/86 

12/04/86 

12/09/86 

12/10/86 

12/18/86 

05/07/87 

05/15/87 

05/18/87 

*x% Subtotal 

TIME OF LARRY T. MENEFEE 

IN MAJOR v. TREEN 

FOR 05/05/85 TO 05/18/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

DESCRIPTION OP SERVICES 

draft reply brief and letter to court 

t w/ court and Guinier 

2'tw/ court> 

t with court 

t with Bowers 

t to Bowers and with court 

t to Bowers and court draft reply brief 

t with LDF and research and draft reply brief, 
motion for uncontested fees and brief 

t with court and research and draft 

confer with LDF, research and draft for oral argment 

research and prep for argument in New Orleans, 
confer with Chambers 

travel to New Orleans (5.0) research, prep and confer 

with Chambers 

Prepare, attend court (5.0), and travel (3.0) 

t w/ Quigley and court 

t w/ court and Quigley 

t w/ Quigley and LDF re bond requirements 

t with Quigley re bond 

research and draft letter to court, analyze four 

recent cases. 

review Quigley letter. 

letter to Collins. 

05/05/85 to 05/18/87 ***  



PAGE NO. 

DATE 

06/25/87 

06/26/87 

07/06/87 

08/06/87 

08/10/87 

08/12/87 

09/02/87 

09/03/87 

09/04/87 

09/05/87 

09/08/87 

09/09/87 

09/11/87 

02/09/88 

02/10/88 

02/12/88 

6 

TIME OF LARRY T. MENEFEE 
IN MAJOR v. TREEN 

FOR 05/19/87 TO 02/23/88 

DESCRIPTION OF SERVICES 

T w/ Quigley, Ralston and research 

T and research re:Champion and Delaware 
Valley. 

Research re:Del.Valley opinion 

Research and draft. 

Research re:supplemental brief. 

Research 

Research & draft supplemental brief 
on Delaware Valley. 

Research & draft supplemental brief. 

Research and draft brief 

Research and draft brief 

Research and draft brief. 

Research and draft brief 

Draft, proof and mail brief 

tw/ clerk 

research & draft brief, letter to court 

research and draft supp. brief 

***Subtotal 05/19/87 to 02/23/88 *** 

***Total 05/07/85 to 02/23/88 *** 

 



Page No. 

07/02/87 
MAJOR vs TREEN 

EXPENSES INCURRED FROM 05/85 TO 06/87 

BLACKSHER, MENEFEE & STEIN, P. A. 

EXPENSE ITEM AMOUNT 

Photocopying at $.25 per page 784.50 

Postage 96.90 

Professional Copying 50.04 

Telephone - long distance 555,50 

Package Experss 147.98 

Meals, Airfare, Lodging, Auto, - 516.16 

*#%% Subtotal 5/85 to 6/87 *** 
2151.08 

 



v Subtotal 7/31/87 to 12/31/87 **x 

 



Subtotal 1/1/88 to 3/5/88 *** 

* % *% 
oe Total 5/85 to 3/5/88 2.247.325 

et 2 

 



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< v of Supper 8 Copy of fas aetvt wor Rather rkrmanon 
sd . Federal Express Corp. Employes No, 

  
i bo PRIORITY 1 xe YEERinent HOLD FOR PICR-UP Give the Faces | remy 

YOUR DECLARED VALVE   
  
  

          

  

CONSEQUENTIAL DAMAGES PART 
ad SATURDAY PICK-UP OR SATURDAY 080P-09F VA wa ct 10 ONSNE C0 RIS I WY 049 OF Bar #2041733900 

rere shes | u q F 2 Sigil br ERECT rR OTS FAR A Sra ran A RE THT Erb tees n+ r= FT ee 
            

USE THIS AIRBILL FOR DOMESTIC SHIPMENTS AND FOR SHIPMENTS FROM PUERTO RICO TO THE USA 
FILL OUT FUATLE AREAS. FOR ASSISTANCE, CALL 800-238-5355 TOLL FREE. 

: ks Ta : . > SEE BACK OF FGAM SEY FOR COMPLETE PREPARATION INSTRUCTIONS. 2 SC 

oxrest | SENDER'S FEDERAL Lk peed NUMBER | |[oare : 3] FY. “ 18 or ZL 

i ik pee 1036-8240-1 | 7-24886 
rom freur Tima] $e Your Phong Number (Very Imp utant) To (Recipient's Haine) Peopants Phone * w ter 1 wry rend 

iL T. Menefes, Eagq .. [(_ _.)... _Williom Quigley, Esq : ) 
Depart ait/f oor No Company , Deonamant/ Flee No 

Blanksns Az, Henafaa & Stein, P.A.Rm 403 Quiglay and Scheckmnan - 
| Stréet Address 5 Exact Street Address (Use of £.0. Sores or P.0.® Zip Codes Wil Ociny Seltvery And Aust in Ema Faye 

1103 Dauphin Btzest ap .. 631 St. Charles Avenua 
City 

Al New Oxleana, : 1A 
ZIP ® 74 Coddn osquinesd | on Correct Inver ng ZIP Shrunt Adress Zip Reni (ve 22. dar ¥ 1p cov 

36833 ; 70130 
~z PILLING REFERENCE INFORMATION priv 24 CHARACTERS WILL APPEAR ON INVOICE.) i NOLD FOR P:SX-UP RT THIS FEDERAL EXPRESS STATICH: Federal Express Ua 
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PLEASE REMIT TO: BOX 76041, — AL 35253 

INVOICE/ITINERARY 2912 SANDERSON RD. - 7 KNOXVILLE, TN 37921 
(615) 673-0667 

  

| pace | voice na. 

3400 INDEPENDENCE DR. 5339 AIRPORT HIGHWAY 
BIRMINGHAM, AL 35209 BIRMINGHAM, AL 35212 

(205) 879-4825 (205) 595-8746   NATIONWIDE 1-800-325-4290 * ALABAMA 1-800-325-2283 

100 ST. JOSEPH ST. 19488 OAKRIDGE TURNPIKE 
MOBILE, AL 36602 OAKRIDGE, TN 37830 

(205) 432-8656 

All invoices are due and payable upon receipt. 

(615) 482-1177 
All unpaid invoices are subject to a 1%% per month 
interest charge on the remaining balance after 15 
days. 

SOLD TO DELIVER TO 
  
  

    

  
  

  

    
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UNIVERSITY PLACE * NEW ORLEANS, LOUISIANA 70140 

(504) 529-7111 

  
  

RATES DO NOT INCLUDE APPLICABLE TAXES 

wv OCPARE TIME 

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REFERENCE CHARGES BALANCE DUE 

  

  

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| 
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Establishment agrees to trensmit to American Express Travel Related Services os Misc or 

Co., Inc. or Authorized Representative for payment. Merchandise andlor ser- § 39) 

vice purcriased on this card shad not be resold or returned for casn refund. | 

1 
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| agree that my ability for this bill is not waived and agree to be held personally able in the event that the indicated person, company or association fails to pay for 

any or the full amount of these charges. | also agree that all charges contained in this account are correct and any disputes of requests for copies of charges must be 

made within five days after my deparure. 

Signature X   

FOR INFORMATION AT ANY FAIRMONT 

HOTEL CALL YOUR TRAVEL PLANNER Company Name 

OR CALL TOLL FREE Address 

800-527-4727 City 

  

  

  
     



  

USE THIS AIRBILL FOR DOMESTIC SHIPMENTS WITHIN THE CONTINENTAL U.S.A. ALASKA AND HAVAN. 

is L COMPLETE PUSPLE AREAS. FOR ASSISTANCE, CALL £30-238-5355 TOLL FREE. 

2 = a SEE BACK OF FOAM “IR COMPLETE PREPARATION INSTRUCTIONS. 
-—t K 

zx PRES ST [SOT STEOERALGGRESSAC  TNUMBER | |oaTE 
= 1 3249-1 8/26/36 

  

  

rom (Your Name) i Your Phone Number Very important) To (Recicient's Name) Recipwent's Phone Humber (Very important 

Larry T. Yenefee, Fag. | 205 223-7300 bya bag ae 
Company Cepartment/Fioor No. | Company Deparmiint/ "dr Mo. 

    
  

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logal DofenzaDund 
Exact Slret Aacress [Use af PJ. Boxes or 0. 2g Todes Will Delay Delivery Aad Assit in £xira Charge.| 

49 Hudson Stroet, 16th Floor 
State 

  

    
  Birmingaam, Alabama ne New York 

a9 @® Zp Code or Cc i ZIP Street Address Zip Required (Re 2.0. Sex © Zip Coss) 

AIRBILL wa 781353 : : g 10C13 

YOUR BILLING REFERENCE INFGRAMATICN (FIRST 24 CHARACTERS WILL APPEAR ON INYGICE.) | HOLD FOR PICK-UP AT THIS FEDERAL EXPRESS STATION: | Federal Exoress Use 

3d : ee {IB Sireet Address (See Service Guide or Cail 800-238-5355) (mmm 

Maj CY Vv, .Tasn 
| Base Charges 

paYMenT i] Bi Shioper 0 Bill Recipient s FegEx Acct No ) Sill 2rd Party Fe0Ex Acct No Bill Craant Cara | 
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hid FegEx Acct No or Major Creat Card No   
    

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CHECK ONLY ONE 20X CHECK SERVICES REQUIRED | size . sli! 

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| PRIORITY 1 OVERNIGHT | + — 4010 FOR PICK-UP Give ma Fevers Exormss | 

1 
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OVERNIGHT ostiveAy * Sem. YOUR DECLARED VALUE 

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GAMAGE OR LOSS 

20 Cones aw Cen Enwone FL 

add Oyermwnt Box A Wi 3 [T] DELIVER SATURDAY +x crave access. 

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STANDARD AIR Extra charge app ws | Reseed A, «Door | y 

second Ci id bins 8 a ORY ICE lbs Z Reqular Stop bers 
= On-Call Stop Thera 13 aways a nsx of ale Owvery Of NON-dedvery in 

SERVICE COMMITMENT 7] orwen speciar service _ Feat A Canine aor 

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CONSEQUENTIAL DAMAGES PART 
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Date/ Time For Federal Express Use IrOpt AS NOW DOW NS ICRANS 038 Of Sans, REVISION DATE 
WOME deed [OBS Omens lew ANG OMe CLmdA 10. 85 

DOES NOL Irion] Be Ie Ss 100 DUK DN OMTORYS 200 Cassa) 

ONSEQUBNtE! UHTA0ES 
PRINTED U.S.A. NCR 

    
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| rat Of DING ol 6 OF (RHTLRRE IMIS vou ll 0) 

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218 SHOWN ON Ne C20 "x 13 113 SADDEY S CODY Of INS BND T 
Ne Make NO ExpIESS Of NMDu] WaITANNES. otal Charges       

  

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INS RT ER YA a TI RS YY) pose) - it LARS 

Bo _ ones or | SENDEW S FENFRAL Fx v 

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HIT NUMBER 
) 

J 
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ree te TA RE Ta PRICE | 

E84 802 577.213 317 
Canrtioent/ Floor Ho 

RP Ved ~ i X34 VIC : a2 ; y ; : 3 r—— A ¥ a TIMER, SORA RS ——d LL MetClain 
AE tel Ane 

    

  

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9402 
FEDERAL EXPRESS STATION: 
»ande or Cail BOO- 218-5355) 

  5 ER Toru ; 

AIRGILL 0. ER 193843k% 36633 
ATION (FIRST 24 CHARACTERS WILL APPEAR OM 

      
YOUR BILLING AEFERENCE INFOR.     INVOICE.) 

Faqei Expioss (ism 

  
Base Charges 

| MOLD FOR PICY-UIP AT T 
Wen Aron, as ern 

BY 

Hop Croan i 
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DELIVERY AND SPECIAL HANDLING 

Dev:iaraa Vaive Charge 
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CHECK ONLY 31iE BOX 

PRIORITY | GVERNIGHT 

rou Freanea | I 
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127% 19%" 

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(Exira charge applies | 

PART 
#2041738900 
FEC-S-750-25 

REVISION DATE 
2:35 
PRINTED U.S.A. NCR 

  THE GL JON RT AT DSS (4 XHTA08 
ALO TI TR RETIN 

AIRLLINES CIEL 3 

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Oates T   ime Fur Feaerai (xpress Use 

  
      

USE THIS AIRBILL FOR 0OMESTIC SHIPMENTS AND FOR SHIPMENTS com sueATD RICO ro THE usa 

FHL NUT PURPLE AREAS FOR ASSISTANCE CALL 360-233-5355. [DLL FREF 
SEE ACK DF FORM SIT FOR COMPLETE PREPARATION INSTRUCTIONS 

  

1036-2240-1 
From (Your Nar oy Bip i Wn ey Foe wen ok 

Lary Menefee, Esq, 205 423- sR000) 2 
Company i 

Blaocksher, lfcnafea & nar | 
Slreet Address | [IER oT 

Be Box 1051 - 29. Iudson-3txe 

  

  

  
  —Steve RzIsTon miment. i L 

Legal Dofansg--F; 
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3 YOUR BILLING REFERENCE 11 [HENRMATION (FIRST 23 CHARACTLAS WILL APPEAR ON INVOICE 

= gi       
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PELE A TRL) 

  

    Code a TapI08s Lue 

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Base Charges 

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PAYMENT x Dectarnd Value Chivoe 

J Cae AL Chiara ‘ie : = 

SERVICES DELIVERY ann In SPECIAL HANDLING 

CHECX ONLY ONE BUX CHECK SERVICES IEQIIRED 

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ry Tous Hn Age) 

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| | ras vats) ALIGHT | \ \/ 

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V.[ nprrnravar 1 ! YOUR DECLARED VALUE 
Section H Al nght 

KR OFLIVER WEIAOAY 

(J ortiven sarunnay np agian: 

  

OVERNIGHT DELIVERY 
USING OUR PACHAGING 

NiMaLi UR LOSS 

  

  

        

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= [T|NESTRICTED ARTICLES SERVICE iv 
? bs a CLANS UG Av Pwr nes a aon 

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(3 Reguiar “00 

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Comes | 

STANDARD AIR 

sO: 3 oar rer mnvary oO me tn 
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SERVICE COMMITMENT 
  

Corn Employee Mo 
  

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O CONSEAUENTIAL DAMAGES 

cpa a re Se BS ree { dd wa ‘ ris Sane 

on y d SATURDAY PICK-UP 08 SATURDAY CROP GFF | ates Tima For + coer t MEL 
«Ta CGE Anoka | | a ig i ern ler ay 

— 

PART 
#2041738900 
FEC~5-750-25 

REVISION DATE 
10 84 
PRINTED U.3 A. NCR 

  

PUR 

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dct SALA UF FUNM IN LUMPLE IE FHEFANATIUN INDI AULIIUND. 1) - = His me 

ZxrreS | SENDER'S FEDERAL NN JTNUMBER | | DATE | bo Oo 

\ \ 
. 

rom (Your Name) Your Phone Number (Very important) : To (Recipient's Name) Recipient's Phone Number (Very important) 

  

1036-8249- 9/26/36 

  

    Larry T. Memefee, Fsqg. 205 323-7300|® Xani Guinier Ese has bag ap 2 0.0. 

Company Depanment/ Floor No. Company ’ fs 77. Déparmint/ Mode No. <= JU 

Blacksher, Menefee & Stein 1 Tund 
Street Address Exact Sré8t Address (Use of P.0. 3oxes or £.0.® Jig L00d3 Will Delay Detivery And Result in Extra Charge. 

300 Twenty First Street North 99 Hudson Street, 16th Floor 
City State City State 

Birmingham, Alabama New York, New York 
e oo: | ZIP ®Zip Code Required For Correct Invoicing ZIP Street Address Zip Required (Me 7.0. Sex © Zip Code) 

eS Eons 35203 10013 
E YOUR BILLING REFERENCE INFORMATION (FIRST 24 CHARACTERS WILL APPEAR ON INVOICE.) or FOR PICK-UP AT THIS FEDERAL EXPRESS STATION: 

. Street Address (See Service Guide or Call 800-238-5355) 

Major v. Treen 
PAYMENT (] Bil Shipper 0 Bill Recipient's FedEx Acct i 0 Bil 3rd Party FeoEx Acct No. Bill Creat Cara 

    

    

  

    
            

  

    

Fill in line below Fill in line below Fill in line below City State : 

O Cash 
| Deciareq “alue Charge 

FedEx Acct No. or Major Credit Card No. 

SERVICES DELIVERY AND SPECIAL HANDLING OE DECLARED ZIP 22 Coos oi Sen Addiess Hamre | 
CHECK ONLY ONE BOX CHECK SERVICES REQUIRED — / 4 0 0 hh, 

PRIORITY 1 OVERNIGHT | 1 — youd FoR PICK-UP Give 1 Federal Ex 
1 CJ Qremon: otuen 6 LETTER i a Tao | 

ul Package Packagng "x Section N at 
OVERNIGHT DELIVERY ron | YOUR DECLARED VALUE 

2 [[] couner-pak Ovemignt Envelope ZR] DELIVER WEEKDAY DAMAGE OR LOSS 
12" 15%" 

Overmignt 80; RDAY | 3d Overont Sox A 1 3] DELIVER saTu Exva charge aooees) A 

Overnignt Tube o | 
PRED Win EY I 4 [] RESTRICTED ARTICLES SERVICE 1 wa : 3100 - 

5 {} CONSTANT Suv SERWICE (CSS) lr : ai 

Shicoer's Door sUlowrwe ue = Sequiar Stop nah : 
- S 1S aways a nsk non-gelvery. In 

SERVICE COMMITMENT 7] orwen secur service Sy SS0-Cal S150 the event Of 2 ale Geivery Faceral Express wi. a your 
3.» Ouivery o8 3c ativied RAL — fFedExloC request. refund all transportation charges pal. See back 

may Py 0 Federal Exoress Corp. Zmpioyee NO. of Stwpper's Copy of ts awd for further informanon. 
PART 

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  Important Information — Please retain in your possession 
Datos Importantes — Manténganse en su poder 

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Information Importante — Gardez cet avis ~-/22 

  

  
Note Your Taxi Number 

  
Tome Nota Del Numero De Su Taxi 

  
Notez Votre Numero De Taxi 

The taxicab fare to or from New Orleans International Airport to or from 

downtown New Orleans, and all other destinations within Orleans Parish on the 

cast bank of the Mississippi River and west of the Elysian Fields boundary line 

is $18.00 total fare for one or two passengers, and for three or more passengers 

riding in the same vehicle the fare is 36.00 per passenger. This is the za! fare 

that can be charged regardless of whether the passengers are in the same party. 

or are going to different destinations within the area identified. 

For information on airport fares to and from locations other than the above, 

please refer to the rate sheets which are required by law to be posted within each 

taxi. 

Some rules and regulations regarding the operation of taxis within Orleans Parish 

are summarized on the reverse side of this sheet. 

Within Orleans Parish, taxis are licensed bv The Taxicab Bureau, which may 

be reached by writing Room 2W14, City Hall, New Orleans, LA. 70112 or by 

phoning (504) 586-4621, or at New Orleans Internacional Airport, please call 

(504) 464-0831.  



2nd Attachment 

UNITED STATES DISTRICT COURT 

Eastern District of louisiana 

BARBARA MAJOR, et al., 

Plaintiffs, 

Civil Action No. 82-1192 

Section C 

Ve. 

DAVID C. TREEN, etc., 

Defendants, 

AFFIDAVIT OF JULIUS LEVONNE CHAMBERS 
  

State of New York ) 
SS. 

County of New York ) 

Julius LeVonne Chambers, Esq., under penalty of perjury 

declares and says: 

1. I am the Director-Counsel of the NAACP Legal Defense and 

Educational Fund ("the Fund" or "LDF"). The LDF is a nonprofit 

corporation 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). Attorneys affiliated with 

the LDF have represented the plaintiffs in landmark cases  



involving constitutional and civil rights issues which have been 

decided by the Supreme Court, the Fifth Circuit, and other 

circuits. A large part of the Fund’s civil docket consists of 

cases brought under the Voting Rights Act to rectify voting 

discrimination. 

2. I have spent most of the last 20 years of my profes- 

sional life litigating claims of racial discrimination across the 

country. I have also been active in numerous bar activities 

related to my work. 

3. I am a founding partner of a-North Carolina law firm, 

which bore my name for nearly twenty years. Prior to leaving the 

firm in July 1984, I devoted a significant portion of my time to 

civil rights litigation. During my tenure, I participated in 

scores of cases in the United States Court of Appeals for the 

Fourth Circuit and in several cases in the United States Supreme 

Court. TI have been involved in trial and on the appellate level 

in, among other cases, the following: Albemarle Paper Company Vv. 
  

Moody, (which I argued in the United States Supreme Court): Swann 

v. Charlotte-Mecklenburg Board of Education (which I argued in 
  

the United States Supreme Court); Griggs v. Duke Power Company; 
  

McBroom v. Western Electric Company; Robinson v. Lorillard 
  

Corporation; and Russell v. American Tobacco Company; as well as 
    

many other civil rights cases. I have been called to testify 

before Congressional Committees, and have taught (and continue to  



teach) courses in civil rights law at Harvard, Columbia, and the 

University of Pennsylvania Schools of Law. In December 1985 I 

presented oral argument for plaintiffs in the United States 

Supreme Court in Gingles v. Thornburg, the first Supreme Court   

case to interpret Section 2 of the Voting Rights Act as amended 

in 1982. 

4. Attached to this affidavit as Appendix A is a copy of my 

resume, which accurately summarizes my educational and profes- 

sional background. 

5. Attached to this affidavit as Appendix B is a memorandum 

dated November 13, 1986 which accurately and contemporaneously 

reflects the number of hours I worked and expenses I incurred in 

the instant case preparing for and arguing the plaintiffs’ motion 

for reconsideration of the magistrate’s recommendation. 

6. My current non-contingent hourly rate is $300.00. This 

rate is consistent with 1988 rates typically charged by the 

senior partner in major New York law firms. Because of the 

nature and timing of my participation in this lawsuit, I do not 

request that the court enhance this non-contingent rate. 

 



I verify under penalty of perjury that the foregoing is true 

and accurate. Executed this 15th day of April 1988. 

lel 
Jullius LeVonne Chambers 

CP Legal Defense and 
Educational Fund, Inc. 

9 Hudson Street 
New York, New York 10013 

  

Sworn to and subscribed before 
me this /§ day Lepil , 1988. 

: lf 

IP Blk 
NQTARY PUBLIC ¢/ 
  

 



APPENDIX A 

BIOGRAPHICAL SKETCH 
OF 

JULIUS L. CHAMBERS 

  

ADDRESS : 

Director-Counsel 

NAACP Legal Defense and Educational Fund, Inc. 

99 Hudson Street - 16th Floor 

New York, New York 10013 

PLACE OF BIRTH: 
  

Mt. Gilead, North Carolina 

EDUCATION: 

Attended elementary and secondary school in Mt. 
Gilead, North Carolina. 

Completed undergraduate work at North Carolina 
College, Durham, North Carolina (now North Carolina 
Central University); B.A. Degree in history in 1958; 

graduated summa cum laude. 

Received Woodrow Wilson Scholarship to study at the 
University of Michigan, 1952-59, where he received 
his M.A. Degree in history. 

Received John Hay Whitney Fellowship to study law at 
the University of North Carolina at Chapel Hill 
(1959-62) where he received a Juris Doctor degree in 
1962. 

Received LL.M. Degree from Columbia University School 
of Law in 1963. 

During the 1961-62 school year at UNC-CH, Mr. 
Chambers was Editor-in-Chief of the North Carolina 
Law Review. He was selected to the Order of the Coif 
(legal honor society) (1962), and the Order of the 
Golden Fleece (1962) (highest honor society at the 
University of North Carolina).  



Following graduation from the University of North 

Carolina School of Law, he was appointed as a 
teaching associate and taught first year law classes 
at Columbia University School of Law where he also 
completed his work and received a Master of Laws 
Degree. 

Mr. Chambers became the first legal intern with the 
NAACP Legal Defense and Educational Fund, Inc., in 
1963 and worked principally in civil rights cases in 
Virginia, North Carolina, Georgia and Alabama. 

HONORS : 

Honorary LL.D. Degree, Northeastern University, 

Boston, Massachusetts - 1986 

Honorary ....D. Degree, North Carolina Central 

University, Durham, North Carolina - 1872 

Bonorary . LL.D. Degree, St. Augustine College, 

Raleigh, North Carolina - 197r 

Honorary L1.D. Degree, Johnson C. Smith University, 
Charlotte, North Carolina - 1971 

Distinguished Alumni Award, The University of North 
Carolina at Chapel Hill - 1983 

1971 Honorary Fellow of the University of 
Pennsylvania Law School 

1971 Columbia University Medal for Excellence 

MEMBERSHIP IN SOCIAL AND HONORARY ORGANIZATIONS: 
  

Order of the Golden Fleece (UNC Honorary Society) 
Prince Hall Masonic Lodge 
Alpha Phi Alpha Fraternity 
Sigma Pi Phi Fraternity  



PAST MEMBER: 
  

Board of Trustees of North Carolina Central University 

Member of the Board of Governors of the University of 
North Carolina (the governing agency of all state 
supported colleges and universities in ‘North 
Carolina) 

President and Board member of the NAACP Legal Defense 

and Educational Fund, Inc. (until June 30, 1984) 

PRESENT MEMBER: 
  

American Bar Association 
National Bar Association 
New York State Bar Association 
North Carolina State Bar Association 

North Carolina Association of Black Lawyers 
Board of Directors, Legal Aid Society of New York 
Board of Editors, American Bar Association Journal 
Mecklenburg County Bar Association 
Board of Trustees of the Center for Law and Social 
Policy 7 
Board of Directors of the Children's Defense Fund 
Board of Overseers at the University of Pennsylvania 
School of Law 
Board oI Visitors at Columbia University School of Law 
Board of Visitors at Harvard University 

FAMILY: 

Mr. Chambers is married to the former Vivian Giles of 
Kannapolis, North Carolina. They have two children, 
Derrick LeVonne and Judy Levern. 

Mr. Chambers entered private law practice in 
Charlotte, North Carolina in 1964, and has worked 
primarily with civil rights cases. He was formerly 
senior partner of the law firm of Chambers, Ferguson, 
Watt, Wallas & Adkins, P.A. He became Director- 
Counsel of the NAACP Legal Defense and Educational 
Fund, Inc., on July 1, 1984 and continues to lecture 
at the University of Pennsylvania School of Law and 
Columbia University School of Law.  



MEMORANDUM 

November 13, 1986 

Lani Guinier 
Julius L. Chambers 
Hearing an ObjectioA”to Recommendation of Magistrate 

  

For purposes of any supplemental statement with respect to Major v. Treen, 
| am itemizing below the expenses | incurred along with the time spent in 
preparation and the hearing. 

$352.00 
192.80 

Airline: 

Hotel: 

Taxi: 

Meal: 

Meal: 

TOTAL $732, 

40.00 
21.20 

25 26. 

35 

Preparation and hearing - 15 hours. 

 



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Approval Code 

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3rd Attachment 

Major v. Treen 
  

Re: Plaintiffs claim for expenses incurred in responding to the 

discovery of the defendants. 

On April 24, 1985 the defendants took the deposition of 

Robert Weil in Philadelphia and on the following day took the 

deposition of Frank Parker in Washington, D.C. Both deponents had 

been listed by plaintiffs as potential expert witnesses for the 

hearing on attorney fees. During the same trip the plaintiffs 

took the deposition of the defendants' expert, Mr. Leonard. 

The parties had agreed to the mutual deposition of expert 

witnesses.: This was accomplished without subpoena. The parties 

had agreed that they would each be responsible for the fees 

charged by the deponent. 

After the hearings in May Mr. Weil and Mr. Parker had not 

been paid by the defendants. The parties were unable to resolve 

the matter and it was submitted to the Magistrate. The Magistrate 

ordered that the parties submit briefs. That Order and resulting 

briefs are attached. The Magistrate has never ruled and these 

expenses were not otherwise before the Magistrate. 

The total claim involved is as follows: 

Frank Parker, 5.5 hrs (1.4 in depo) @ $150 each 
Robert Weil, 9.9 hrs (2.0 in depo) @ $180 each 

  

1 plaintiffs entered into this agreement believing that if 
requested, pursuant to Rule 26 FRCP, the court would likely order 
the deposition; that the agreement allowing a convient deposition 
of the defendant was beneficial to the plaintiffs and out of some 
spirit of cooperation.  



MINUTE ENTRY 
CHASEZ, M. 
JULY 10, 1985 

UNITED STATES DISTRICT COURT LUE ~ 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, ET AL CIVIL ACTION 

VERSUS ; NUMBER: 82-1192 

DAVID C. TREEN, ETC., ET AL SECTION: C(5) 

A dispute has arisen concerning the payment of expert witness fees. The 

parties have requested that the court resolve this matter. 

Accordingly, 

IT IS ORDERED that the parties submit a memorandum directed to this issue 

on or before August 1, 1985. 

   



State of Loutsiana 
DEPARTMENT OF JUSTICE 

WILLIAM J. GUSTE. JR. 7TH FLOOR 

ATTORNEY GENERAL August 1 ; 2-3-4 LOYOLA 3JUILDING 

NEW ORLEANS 70112-2096 

Honorable Alma L. Chasez 
500 Camp Street 
Hale Boggs Building 
Room Bll7 
New Orleans, Louisiana 70130 

Dear Magistrate Chasez: 

This letter is in response to Mr. Menefee's letter 
to you dated July 10, 1985, requesting defendants to compensate 
plaintiffs' expert witnesses for their_time expended responding 
to defendants' discovery. = 

Mr. Menefee cites Rule 26(b) (4) (c) Fed. R. Civ. P. 
as authority for said request. However, 26(b) (4) (c) is inapposite, 
as it applies exclusively to reimbursement for experts, "time 
spent in responding to discovery under subdivisions (b) (4) (a) (ii) 
and (b) (4) (B)". Mr. Menefee's request does not encompass any 
time spent by experts responding to discovery under either (b) (4) 
(a) (ii) or (b) (4) (B). Therefore, his“reliance on 26 (b) (4) (c) 
is misplaced. 

  

  

In the instant case, plaintiffs' egperts were deposed 
pursuant to an agreement between the parties and not by court 
order, upon motions. 
  

Section (b)(4)Y(a) (ii) reads: 

"Upon motion, the court may order further 
discovery by other means, subject to such 
restrictions as to scope and such provisions, 
pursuant. to subdivision (b) (4) (Cc) of this 
rule, concerning fees and expenses as the 
court may deem appropriate." (Emphasis 
added) 

  

  

The agreement was formulated in this way. Mr. Menefee called 
Mrs. Bowers and asked if it would be agreeable for each party 
to pay for the deposition of the other party's expert(s). Mrs. 
Bowers replied that yes that would be fine. There was no other 
discussion of the matter, until the current problem arose.  



August 1, 1985 
Page Two 

Hence, this section, upon which Mr. Menefee relies, which directs 

that "the court shall require" and which Mr. Menefee maintains 

establishes a "presumption of entitlement to compensation" does 

not apply. Likewise, all references throughout Mr. Menefee's 

letter to you with regard to 26(b) (4) (a) (ii) do not apply. 

Additionally, my understanding of the agreement between 
the parties was that defendants would pay for the cost of the 
deposition, i.e., the actual time spent in the deposition and 
not for the costs of preparation and follow-up work. Mr. Menefee 

never brought up paying for these items, and I had no way of 

knowing that that was what he intended. If I had, I never would 

have agreed, because even paying for the depositions themselves 

at the time required a tremendous amount of red tape. I would 

never have agreed to pay for preparation and follow up time, 

because I could not have gotten authorization for such an agreement. 

The defendants deposed Mr. Weil for 2.0 hours and Mr. 

Parker for 1.4 hours. However, Mr. Weil has requested compensation 

for 9.9 hours, and Mr. Parker has requested compensation for 

5.5 hours, 

Mr. Menefee contends that a "substantial portion" of 

the time expended by Mr. Weil was spent responding to the duces 

tecum request. Specifically, he states, "considerable time" 
was spent "developing a bibliography of the numerous published 

articles he has authored in the past twenty years". Mr. Weil 

was examined about the bibliography at his deposition. Mr. Parker 

also spent time preparing a list of cases, "most of which were 

reported decisions”. (Mr. Menefee's letter, p. 4.) 

These are matters which Mr. Weil either should have 

had prepared or which he should have prepared for the Court in 

regard to his live testimony. 

In this regard, Baise v. Alewels, Inc., 99 F.R.D. 95 

(W.D. Mo. 1983) states that since the expert "has already formed 
his opinions" it "should not require any undue effort to compile 

a list of those books upon which he relied". In Baise, the judge 

held that "an order requiring (the defendant) to pay (the expert) 

for time spent in compiling the list would not be appropriate”. 

Baise, supra, at 98. 

  

   



August 1, 1985 
Page Three 

Mr. Menefee also makes reference to Moore's Federal 

Practice, Para. 26.66(5). {See YOl. 4, Dp. 206-423-224.) This 
section comments on section 26 (b) (4) (c) of Rule 26 (b) (4). Section 
26 (b) (4) (c) (i) addresses the situation where discovery is sought 
directly from the expert under subdivisions (b) (4) (a) (ii) and 
(b) (4) (B) and thus is not applicable as, again, (a) (ii) relates 

to the court ordered deposition and (b) (4) (B) relates to the 
expert who will not be called as a witness. (It should be noted 
that it is in this situation where the mandatory "shall require" 
is used). Section 26(b) (4) (c) (ii) provides that "when discovery 
is had from the party under (b) (4) (A) (ii) the court may require 
the party seeking discovery to pay the other party" reasonable 
fees. Defendants were not seeking discovery frcm the party. 
They were seeking it from the expert. Furthermore, section (b) (4) 
(a) (ii) applies to a court ordered deposition and not an agreement 
between the parties, as is the case here, and thus is not applicable. 
Likewise, (b) (4) (B) (the only other section of Rule 26 mentioned 
in Moore's relates to the witness who will not appear at trial 
and is inapplicable. 

  

  

  

  

  

Mr. Menefee has neglected to mention that the tenor 
of the Moore's commentary is that requiring the party seeking 
discovery to pay for the discovery is used to combat any unfairness 
in seeking that discovery. There is no such unfairness here. 
The Court will see in defendants' Post-hearing Memorandum that 
much of the discovery sought has been used to rebut the expert's 
testimony, i.e. a showing that Mr. Weil's statistics are skewed 
through use of publications obtained By discovery. 

This conflict boils down to one thing. Plaintiffs 
want defendants to "front" the money for their fees experts. 
Mr. Menefee himself said in a telephone conversation on July 
30, 1985, that it comes down to whether the State pays now or 

he pays now. This was confirmed by Mr. Menefee's refusal of 
Mrs. Bowers' offer to simply re-open the record to include these 
expenses. 

Because the State has contended that it should pay 
no fees at all, because the plaintiffs' victory was merely pyrrhic 
(and accordingly no expenses such as expert fees), it is inequit- 
able that they should have to front plaintiffs' fee expenses 
and then have to try to get them back later. 

This Court, of course, is well aware of the principle 
at law that words are held to mean what they mean in common usuage. 
Mr. Menefee didn't say "deposition and preparations and follow- 
up.” He said "deposition" and that is all defendants agreed 
to pay.  



August 1, 1985 
Page Pour 

The parties had an agreement to the effect that each 

side would pay for the actual time that it spent deposing the 

opposition's expert. It certainly was not within the contemplation 

of the defendants at the time of the agreement that the defendants 

would pay for time spent in preparing for the deposition or the 

follow-up of the deposition. 

It is for the above stated reasons that the defendants 

respectfully request your honor to refuse Mr. Menefee's request 

for compensation of hours not contemplated in the agreement. 

Sincerely, 

WILLIAM J. GUSTE, JR. 
ATTORNEY GENERAL 

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ban LOR NN 
PATRICIA NALLEY BOWERS< 
ASSISTANT ATTORNEY GENERAL 
LOUISIANA DEPARTMENT OF JUSTICE 

  

PNB/jhv 

RE: Major v. Treen 
Attorneys' fees 

. OF SERVICE 
I certity that 3 ¢g PY of the foregoin i 

- 
8 pleading has Sn upon course for ail parties by Toe Say each, Property addressed ang ® Same 

2 : Postage prepaid [a hy 

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BLACKSHER MENEFEE & STEIN, P.A. 

ATTORNEYS AT LAW 

40% VAM ANTWERP BUILDING 

P.O. BOX 1031 

MOBILE, ALABAMA 36633 

JAMES U. BLACKSHER TELEPHONE 

LARRY T. MENEFEE (2085) 433-2000 

GREGORY B. STEIN August 8. 1889 
WANDA J, COCHRAN . 

Honorable Aima Chasez 

500 Camp Street 

Hale Boggs Building 

Room B117 

New Or leans, Louisiana 70130 

RE : Major v. Treen: Clvil Action No. 82-1192 Section. 2 
  

Dear Magistrate Chasez: 

This is in response to Ms. Bowers' letter of August 1, 1885, 

concerning expenses for expert depositions. 

First, the defendants argue that Rule 26(b)(4)(A)(li) requires a 

motion and subsequent order from the Court whereas the defendants 

contend there was an agreement in this instance. | thought for 

once we had avoided going to the Court for an order. When Ms. 

Bowers’ Informed me she wished to depose the experts, | knew | 

could apply to the Court for a protective order. jt was my firm 

impression that Your Honor would have allowed deposition of the 

experts and this is clear practice. in virtually ail of the 

federal courts that | have |itigated. The only matter to be 

determined Is payment of the attendant expenses. if those have 

been agreed upon, there was no need to have gone to the Court for 

an order. The only written expression of our agreement that | 

have found is contained in a letter of March 28, 1885 to Ms. 

Bowers and reads in its entirety as follows: 

| assume that you will be responsible for paying Mr. 

Wiel’'s fees and | will be responsible for paying Mr. 

lLeonard’'s fees. if my understanding is not correct, 

please let me please !et me Know. 

Ms. Bowers’ response dated April 2, 1985, says at page 2: 

You are also correct in assuming that you will pay 

Mr. Leonard's fees and | will pay Mr. Wiel. 

Ms. Bowers’ memory of the agreement is obviously incorrect since 

the matter was handled by letter rather than telephone call. The 

quoted statements attributed to Mr. Menefee are not properly 

quotations. The facts clearly appear that there was no 

agreement. That Is precisely why the parties are before Your 

Honor at this time on this matter.  



Honorable Aima L. Chasez August 8, 1885 

Page Two 

| do not find this or Ms. Bowers memory particularly dispositive 

of the Issue. | understood that we were agreeing that 

compensation of expert expenses would be handled as provided for 

in the Federal Rules. | believe those rules provide payment of "a 

reasonable fee for time spent in responding to discovery". 

Fed. R.Civ.P. (b)Y(4)(C). "Reshonding fo discoverv" includes the 

time in the deposition, reasonable time in preparing for: the 

deposition, answering a duces tecum request or other time 

expended by the expert in response to the adverse party's 

discovery request. 

  

Second, the defendants mischaracter ized financial burdens. it~is 

not as they characterized a question of who is to "iront" the 

money for the expert witness fees. These experts were required 

to spend additional time on the litigation because of the type 

and kind of discovery conducted by the defendants. Plaintiffs 

attempted to cooperate in their discovery process but only wanted 

assurances that the expenses incurred as a result of the 

defendants’ discovery tactics wou | d¥compensated. That is exactly 

what the rules provide. When the rules are as clear as they are 

requiring "a reasonable fee for time spent responding to 

discovery" is It really necessary to invoke the authority of the 

Court at every turn? 

Very respectfully, 

BLACKSHER, MENEFEE & STEIN, P.A. 

Patricia Bowers, Esquire 

 



IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF LOUISIANA 
  

BARBARA MAJOR, ET AL., 

Plaintiffs, 

Vv. 

DAVID C. TREEN, ETC., 

Defendants. 

PLAINTIFF 

ET AlL., 

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a
 

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CIVIL ACTION NO. 82-1192 
SECTION C 

FS' MEMORANDUM IN SUPPORT OF 
SUPPLEMENTAL MOTION FOR AWARD OF ATTORNEYS' FEES AND EXPENSES 
  

Plaintiffs rely upon the previously filed memoranda 

briefs 

fees and expenses. 

he 
Respectfully submitted this 12° day of April, 1988. 

    

) : 
\ZARRY /TV. MENEFE 

Fifth Ploor Title Buil 
300 North 21st Street 

Birmingham, AL 35203 
(205) 592-6227 

R. JAMES KELLOGG 

130 Jane Street #4-5 
New York, NY 10014 

STEVEN SCHECKMAN 
700 Camp Street 
New Orleans, ILA 
(504) 528-9500 

70130 

ARMAND DERFNER 
Box 608 
Charleston, SC 29402 

ding 
WILLIAM P. QUIGLEY 

631 St. Charles Avenue 

New Orleans, LA 70130 

(504) 524-0016 

STANLEY HALPIN 
2206 W, St. Mary 
Lafayette, LA 70506 
{318) 367-2207 

LANI GUINIER 
Legal Defense Fund 
99 Hudson Street 
l6th Floor 
New York, NY 
(212) 219-1900 

10013 

and 

in support of their pending motion for award of attorneys!’ 

 



CERTIFICATE OF SERVICE 
  

I hereby certify that the foregoing brief has been 

served upon the following by mailing a copy thereof by first class 

United States mail, properly addressed and postage prepaid on this 

the / 5% day of Apel : 198% : 

Kendall Vick, Esq. 
Assistant Attorney General 
State of Louisiana 
Department of Justice 
7th Floor, 234 Loyola Building 
New Orleans, LA 70112-2096 

  

a 
N_Farey 7: Mengfee /