Stipulation of Fact

Public Court Documents
November 1, 1984

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Stipulation of Fact preview

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  • Case Files, Major v. Treen Hardbacks. Stipulation of Fact, 1984. 4b2a12ca-c803-ef11-a1fd-6045bddc4804. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/e914ab2c-4834-4df9-abdc-985131b66048/stipulation-of-fact. Accessed November 05, 2025.

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    IN THE UNITED STATES DISTRICT COURT FOR THE 

FOR THE EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, et al., 

Plaintiffs, 

Civil Action No .32-11902 

Section ( 

DAVID. CC. TREEN, etc., et a}. 

Defendants. 

STIPULATION OF FACT 
  

Plaintiffs and defendants, through their undersigned counsel 

hereby enter into the following stipulation of facts. This 

agreed stipulation of facts is entered into solely for the 

purposes of this litigation to conserve the resources of the 

parties and the Court. The parties hereto stipulate as follows: 

1. Both sides could present credible testimony that a 

non-contingent hourly rate for an attorney with the experience 

and reputation of Mr.Stan Halpin, handling litigation of similar 

complexity and novelty as the present, would range from $100 to 

$175 per hour in New Orleans, Louisiana. 

2. Both sides could present credible testimony that a 

non-contingent hourly rate for an attorney with the experience  



and reputation of Ms.Lani Guinier, handling litigation of similar 

complexity and novelty as the present, would range from $100 to 

$175 per hour in New York City. 

3. Both sides could present credible testimony that a 

non-contingent hourly rate for an attorney with the experience 

and reputation of Mr.James Kellogg, Steven Scheckman, and William 

Quigley, handling litigation of similar complexity and novelty as 

the present, would range from $75 to $150 per hour in New 

Orleans, Louisiana. 

4. Both sides could present credible testimony that 2a 

non-contingent hourly rate for an attorney with the experience 

and reputation of Mr.Armand Derfner, handling litigation of 

similar complexity and novelty as the present, would range from 

$100 to $220 per hour in Washington, D.C. 

5. The parties agree that credible evidence could be 

presented which would show that customary legal fees for 

attorneys handling cases on a contingent basis in New Orleans, 

Louisiana, provide that an attorney for a prevailing plaintiff 

should recover from 33% to 50% of the plaintiffs' judgment. The 

higher percentage traditionally reflects the increased risk and 

complexity of the litigation. 

Respectfully submitted this day of November, 1984,  



BLACKSHER, MENEFEE & STEIN, P.A. 
405 Van Antwerp Bldg. 
P. 0. Box 1051 
Mobile, Alabama 36633 
(205) 433-2000 

Attorney for Plaintiffs 

ASSISTANT ATTORNEY GENERAL 
234 Loyola Avenue 
New Orleans, Louisiana 70112 
(504) 568-5575 

BY: 

PATRICIA BOWERS 
  

Attorney for Defendants

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