Correspondence from Maurice E. Franklin to Steve Ralston

    AVON N. WILLIAMS, JR 
ATTORNEY-AT-LAW

SUITE 1414-PARKWAY TOW ERS 

404 JA M ES ROBERTSON PARKWAY 

NASHVILLE.TENNESSEE 37S18 

TELEPHONE 244-3880

May 26, 1977
MAURICE E. FRANKLIN

Steve Ralston, Esquire 
Suite 2030 
10 Columbus Circle 
New York, New York 10019

In Re: Garner vs. City of Memphis

Dear Steve:

Please find enclosed one copy of the Brief on Appeal 
in the above referenced case which I prepared and mailed for 
filing at 11:58 p.m. on 25 May, 1977. As you will see I did 
not make any citations to the Appendix. After talking with 
you on yesterday I thought it better that instead of running 
a risk of making incorrect citations that I should file the 
Brief as it is and file a Motion For An Extension of Time 
within which to make the citations to the Appendix. If the 
Motion is granted we can then ascertain how the transcript 
which was transmitted to the Sixth Circuit is numbered and 
then coordinate our numbering to theirs.

Because of time constraints I was not able to devote 
aa much time as I wanted to on the Brief and am not completely 
satisfied with its quality I think under the circumstances the 
B^isf adequately addresses the relevant issues in the case. In 
any event, I think that we are in a position to file either an 
Amended Brief or A Reply Brief which will fill in the holes which 
were left in the original Brief.

Also enclosed you will find a bill for expenses incurred 
in connection with the preparation of the Brief specifically 
secretarial help, photocopying, postage, phone charges, and suste­
nance (food). In connection with the secretarial charges, it 
was necessary for me to secure the services of one of our secretarys 
after hours in order to complete the typing and photocopying of the 
Brief and it would have been impossible for me to have it mailed on 
time without her help. In connection with the phone bill charges 
it was necessary that I have dictated over the phone a Brief in the 
possession of Walter Bailey in Memphis in order to provide back­
ground and meat to the Brief. I am sure that you will find the 
charges reasonable and they are as follows:



Page 2
May 26, 1977

Photocopying 
Secretary 
Postage 
Sustenance 
Phone charges

TOTAL

$ 130.50 
62.50 
6.93
6.00

*

$ 205.93

I expect to receive a copy of the Appendix that you 
prepared shortly and then I will contact the Clerk in the Sixth 
Circuit to ascertain whether their paginations are the same as 
ours and I will then complete the preparation of the Brief.

Very t p ^ y  yours

Maurice E. Franklin

MEF/af

P.S. We have not been able to ascertain the phone charges and 
we will submit a bill later for those charges.

MEF



NAAOi" LEGAL DEFEMSS AND EDUCATIONAL .IJNDj INC.
 ̂ .t.

/ 1

REQUEST FOR PAYMENT 

(PLEASE TYPE OR PRINT)
OEIE CASE PER REQUEST ONLY ■;

' PA^E: ■ CASE NAME; STATE: DATE: -
AVON N. VnUilAMS, JR. GARNER VS MEMPHIS POLICE DEP [■. TENNESSEE 5/26/77 '

LDF USE o n l y : 07 V 3 - 0 a a - 7

ACCOUNT NAME; DISBURSEMENT CODE: AMOUNT

Legal Fees 01-7165 ,1
Travel 01 -7166
Court Costs 01 -7167 [• *
Expert Witness 01-7168
Misc. Ebcpenses 01-7169 1 -'-I1 ' '»
Legal Printing 01-7171 TOTAL

RATE PA.ID:
LDF ATTORNEY; AUTHORIZED SIGNATURE AI40UNT: CK.#

TO BE COMPLETED BY AliT. AMT . '
COOPERATING ATTORNIY:

m
DAYS REQUESTED APPROVED

1 . IN OFFICE STATEMENT
(If all or part of this work was performed outsidd your officej 
please indicate and explain the circumstances; show vdiole and 
half days as appropriate throughout).

a. Preparation of Briefs, Memoranda, Pleadings, etc.(Specify)

b. Preparation for Trial, Hearing, Deposition, etc.(Specify)

c. Other (Specify) ________________________

01-7165 ........... TOTAL IN OFFICE FEES."-5.'............$50.1.

; II. OUT OF OFFICE
a. Trial, Hearing, Oral Argument or Appeal, etc. (Specify)

b. Deposition, Investigation, etc. (Specify)

. .$ipo.x
T O U L  l e g a l fees , ; .

01-7165............ TOTAL OUT OF OFFICE FEES

EXPENSES AND COURT COSTS • ; ___ _______________
(Attach original receipts for all travel expense items except small cash meals, taxis, etc.j 

-^attach bills of court reporters, marshals, show date on which expense was ^g^urred)'. '
“ ■ __  ________ - -  -DATE

*01-71 66/ s/2S-?.A/77 Meals, Lodging, Personal auto @ 10?i PM, Car rental, 
^  Air, Train and taxis, etc. other (Specify)

Maurice Franklin (sustenance)

REQUESTED ' APPRO VEI

6.00

01-7167

5/25/77

01 -7171

Notice of appeal, docketing fees,
court and court reporter fee, other (Specify)

Expert Vatness and Conspltant fee
-i\D,i.tfcL.£itageraId. .Se.cre.t̂ rifll Tiran---=-----------

ici^ieraxmcf Telephone *( Other specify)
Postage for shiTxt\ent of package

6?.5n-

130.50

Legal Printing of briefs, etc.
*T£!lepbnne hill_in, approximate .amount of—$&5--0Q to be- siAamitted' later--------
ijpon receipt of bill. 'X ^

____________ TOTAL EXPENSES AND COURT COSTS .•..........?pR <2
LITIGATION CATEGORY (PLEASE CIRCLE ONE)

Teacher Rights, School Desegregation, Student Dismissals. Capital Punishment,Prisons 
Jury Exclusion,Removal, <^dicial Control Of Police Practice^Voting, Housing and Land Use 
Private Employment Discrirahation, Public Employmenl!. DisciImnation,Federal Emp. Discrimination 
Other Employment Discrimination, Municipal Service Equalization, Public Accomodations 
Consumer Protection, Ear Discrimination,Mscellaneous.