Affidavit of Vanzetta Penn Durant

    SIATE OF ALABAMA )

COUNTY OF MONTGOMERY)

NECEIVE D

'Brt JUN hr nUt l0 r U E

OF

trl+l miia, ! quuop, * o*,

Bef ore *. , ''i't','!' ,ro.i.t iLfi[d' i'Not ary

appeared VANZEITA PENN DURANT, who being

by me first being duly sworn on her oath,

follows:

FILED
JUN 5 SB4

THOMAS C. CAVER, CLEtiK
ev 

-5ar--ull1tERt'{-

Pub 1 i c, personal 1y

known to ffi€, and who

deposes and says as

My name is Vanzetta Penn Durant; my resi-

dence address is 321 North Anton Dri ve,

Montgomery, Alabama 36105; I am in the

solo practice of law with offices at Mont-

gomery, Al ab ama. I h ave been act i ve 1y

engaged in the pract'ice of law in the state

of A'abama since 1975. I am a member of

the Bar in good stand'i ng of the State of

Alabama and the State of New York, and i
h ave been admi t ted to pr act i ce before the

United States District Court for the

Northern District of Alabama, the United

States Distri ct Court for the Midd le

Djstrict of A"abama, the United States Dis-

tri ct Court for the Southern Distri ct of

New York, the Uni ted States Court of

Appeals for the Second Circuit, and the

Un'ited States Court of Appeals for the



Eleventh Circuit. A substanti a1 portjon of

my practice has consjsted of the prepara-

tion for trial and tri al of civil rights

cases and in cases jnvolving the'litigation
of the constitutional ri ghts of

ind'i viduals.

The successful preparation and trial

of cases of th'is nature necessari 1y

involved the'inspection, copying, examina-

tion, analysis and evaluation of a

substanti al number of documents and

transcri pts of prior proceed'ings. The

cus tomary fees ch arged for th i s type of

work in Federal Courts in the State of

A'abama range f rom approx'imate ly $60 per

hour to over $100 per hour.

I am of the oPinion that during mY

experience as a private practit'ioner, I

have developed a degree of ski ll in the re-

presentation of clients in litigation
'involving constitutional law issues, and

th at my sk i 1 I and experi ence f aci l'itated my

representation of the Petitioners in thjs

case and contri buted to the success of

their Petitions.
The Petitioners and I generally agreed

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th at I wou ld be compensated pursu ant to 42

U.S.C. Section 1988. The Petitioners were

indigent at the time their Petitions were

filed and were granted leave by this Court

to file in Forma Pauperis. The Petitjoners

have not paid any fees or costs in this

case. To that extent, the fee arrangement

between the Petitioners and me can be

deemed to have been cont'ingent .

I have not prev'ious Iy represented

either Petitioner nor have I had any

prof ess'ional rel ationshi p wi th them other

than as their attorney'in this case. As a

result of my representation, Petitioner

Bozeman ' s conv i ct i on was vac ated , and the

obv'ious st'igma of a criminal conv'i ction was

thereby removed. Moreover, in asmuch as Pe-

t i t i oner Bozeman was a paro I ee, the

restra'ints upon her dai ly activities, her

associ ations, her trave'l , and the exercise

of other civil rights vrere removed. Peti-

tioner Wi lder's convi ction was not vacated

as a result of my representat'ion, however,

this Court's 0rder and Memorandum 0pinion

are tantamount to a reversal of her convic-

tion, thereby raising a substantial likeli-

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hood th at she too wi I I be free of the

stigma 'imposed by a criminal conviction and

the resulting restraints on her daily

act'ivit'ies, h€r associ ations, her travel,

and her exerci se of other c'i vi I ri ghts.

In securing relief jn these cases, the

f o I'lowi ng servi ces were perf ormed by me:

Date Serv i ces Rendered Time

04/05/83

04/06/83

04/Zsl83

0s/05/83

06/01/83

06/08/03

06/29/83

07 /01/ 83

07 /05/83

07 /07 / 83

07 /20l83

07 /26l83

08/08/83

Telephone conference wi th Ms. Gui ni er

Telephone conf erence w'i th Ms. Guinier

Telephone conf erence w'ith Ms. Guinier

Telephone conference w'i th Ms. Guinier

Telephone conference with Ms. Guinier

Telephone conference with Ms. Guinier

Review of documents and avai lable fi les

Telephone conference with Ms. Guinier

Telephone conference with United States
D'istrict CIerk's 0ffice and with Ms. Brown
re issues; rev'iew of documents; prepara-
tion of Motion to Appear Pro Hac Vice;
telephone conference with Ms. Guinier

Research of issues; organi zation of fi le

Telephone conf erence wi th Ms. Guini er;
te I ephone conf erence wi th Mr . Cope'l and
( Law C lerk ) ; revi ew of documents

Research of issues; review of documents

Tel ephone conference wi th Ms . Gu i n i er ;
telephone conference with Mr. Miller
(Lrw Clerk)

.1

.1

.2

.2

.t

.5

1.1

.1

1.5

2.5

1.0

1.5

.5

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09/02/83

09 / 08/ 83

09/L9/83

09/22/83

09/30/83

l0/03/83

L0/04/83

t0/06/83

11/08/83

L2/01/83

l?/02/83

12/Ls/83

L2/23/83

01/03/84

0L/24/84

0L/27 / 84

0L/30/84

Revi ew of Court 0rder denyi ng Mot i on to
Dismiss

Telephone conference wi th Mr. Knopf
( LDF counse I ) ; letter to Mr. Knopf; re-
vi ew of 0rder ; te I ephone conference wi th
Ms. Brown re transcri pts

felephone conference with Ms. Guinier; let-
ter to Ms. Guinier re 0rder

Telephone conference with Ms. Guinier

Telephone conference wi th Ms. Gu i ni er and
with Mr. Mi I Ier; review of pleadings and
memor and a

.3

.5

.5

.4

1.0

1.0
Preparat'ion of Motions to
phone conference wi th Ms.

Te I ephone conf erence w'i t h

disposition on Motions; te
ence wi th Ms. Brown

Telephone conference wi th

Letter to Ms. Guinier; tel
with Mr. M'i ller re transcr

Telephone conference wi th
transcripts
Te I ephone conference wi t h

Review of file documents;
ference wi th Mr. Mi I I er re
hearing

Letter to Ms. Guinier

Telephone conference wi th

Telephone conference wi th

Te1 ephone conference wi th
with Mr. M'i ller
felephone conference with
Ms. Gu'inier

Produce; te I e-
Gu i n i er

Mr. Miller re
1 ephone confer-

.4

Mr. Miller .1

ephone conferen ce
ipts .5

Mr. Miller re
.1

Mr. Miller .1

telephone con-
date for

.4

.2

Ms. Guinier .4

Ms. Guinier .2

Ms. Guinier and
.5

Ms. Brown and
.3

Tel ephone conference wi th Ms . Gui n i er re02/17 / 84

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Summary Judgment Motion

Telephone conference with Ms. Brown and
wi th Mr. Mi I ler re amendment

Conference with Ms. Guinier; review of
pleadings and memoranda

Hearing on Summary Judgment Motions; con
ferences with Ms. Guinier and with Peti-
tioners

Let ter to Ms . Gu i n'i er

Conference with Ms. Guinier and with
LDF New York offi ce; revi ew of Judg-
ments and 0rders; te 1 ephone conferences
with Mrs. Bozeman and Mrs. Wilder

Letters to clients

Telephone conf erence w'ith Ms. Gu'inier
letter to Mr. SeaY

Telephone conferences wi th Ms. Guinj er

Preparation of Motion for A'lowance of
Attorney's Fees and Costs Petit'ion; te
phone conf erences wi th Ms . Gu'in'ier , Ms

Brown, and with United States Clerk's
of f i ce

.5

02/2U84

03/0L/84

03/02/84

03/05/84

04/L3/84

04/L6/84

04/19/84

04/24/84

04/25/84

L

4.5

.7

.t

3.4

.4

.4

.3

4.8

$7s4.00

6

le-

TOTAL SERVICES
$20.00 per hour

EXPENSES

RENDERED - 37.7 at

fo'l lowi ng expenses
reasonab 1y 'incurred
his case up to and
pri I 1984:

'i ng - 567 copies at
0.25 per copy

The
and
in t
25A

c opy
$

Post

Lon g

TOTA
EXPE

were necessari 1y
in securing rel'ief

including

age

$141.75

44.18

55.09d'i stance telephone calls

SERVICES RENDERED ANDL
N SES S 995.02

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)
t.r

STATE OF ALABAMA )

COUNTY OF I{ONTGOMERY)

I , the unders i gned vAN zETTA PENN DURANT ' hereby

certify that I have read the above and foregoing ltlotion and

Affidavit and know the contents thereof and that the matters

and things set forth therein are true and correct.

Suorn to and

day of Apri l, 1984.

subscribed before me this the,.,''5 th

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