Parker v. Lewis Brief for Appellant

    BRIEF FOR APPELLANT

UNITED STATES COURT OF APPEALS 
FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 81-1965

BEVERLY L.B. PARKER, Appellee,
v.

DREW LEWIS, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA

CHARLES F. C. RUFF, 
United States Attorney.

ROYCE C. LAMBERTH,
KENNETH M. RAISLER,
CHERYL M. LONG,
Assistant United States Attorneys.

C .A. No. 79-3443



I N D E X

Page
0 REFERENCES TO PARTIES AND RULINGS....................1

STATEMENT OF THE CASE................................. 1
ARGUMENT............................................... 3

The District Court abused its discre­
tion when it denied discovery and award­
ed $14,200.95 in attorney's fees in a 
conclusory manner with no basis in the 
record.

A. The District Court's
failure to permit 
discovery and a hering 
is an abuse of discre­
tion...................................4

B. The District Court's con­
clusion that all of the 
hours claimed by counsel 
for appellees were rea­
sonably expended is an
abuse of discretion................. 6

C. The District Court 
abused its discretion 
when it awarded counsel 
for appellees compensa­
tion at the hourly rates
that they sought................... 7

CONCLUSION. . ........................................ 12

T



11

TABLE OF CASES
Page

* Copeland v. Marshall, 641 F.2d 880
(D.C. Cir. 1980).....................................  3, Passim
Crowley v. Haig, No. 74-0494 (D.D.
C. 1 9 8 1 ) ................................................9
Detroit v. Grinnel Corp., 495
F . 2d 488 (2d Cir. 1974) ..............................  5
Lindy Brothers Builders, Inc., v.
American Radiator & Standard Corp., 487
F . 2d 161 (3rd Cir. 1973)............................  5
Grumin v. International House
of Pancakes, 513 F. 2d 114 (8th Cir. 1975)............. 5
Johnson v. Georgia Highway Express,
Inc., 488 F . 2d 714 (5th Cir. 1974)......................7
Naismith v. Professional Golf
Association, 85 F.R.D.................................... 4
Stastny v. Southern Bell Telephone
and Telegraph Co., 77 R.D. 662 (W.D.N.C . 1978)........ 4
Wolf v. Frank, 555 F. 2d 1213 (5th Cir. 1977)......... 4

TABLE OF AUTHORITIES
42 U.S.C. §2000e-16..................................... 1
Equal Access to Justice Act,
Public Law 96-481 §201 et seq........................... 10

asterisks.



ISSUES PRESENTED -/

In the opinion of appellant, the following issue is presented 
Whether the District Court abused its discretion, when it 

denied discovery and a hearing, when it awarded $14,200.95 in 
attorneys' fees in a Title VII discrimination case, and when it 
awarded the fees in a conclusory manner with no basis in the 
record.

*/ This case has not previously been before this Court.



UNITED STATES COURT OF APPEALS 
FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 81-1965

BEVERLY L.B. PARKER, Appellee,
v .

DREW LEWIS, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA

BRIEF FOR APPELLANT

REFERENCES TO PARTIES AND RULINGS

Appellant is the Secretary of Transportation. Appellee is 
Beverly L.B. Parker, an employee at the Department of Transportation. 
The subject of this appeal is the Order filed by the Honorable 
Aubrey E. Robinson, Jr. on June 30, 1981, awarding appellee
$17,200.95 in attorneys' fees and $140.79 in costs.

STATEMENT OF THE CASE
Appellee brought this action pursuant to Title VII of the 

Civil Rights Act of 1964, 42 U.S.C. § 2000e-16, against the 
Secretary of Transportation requesting a retroactive promotion,



2

back pay and attorney's fees. Specifically, appellee alleged 
that sex discrimination had caused a denial of a promotion at the 
GS-9 level to the position of attorney-advisor in the Federal 
Highway Administration. The case was settled on February 13, 
1981, resulting in an agreement to provide a retroactive promotion, 
the sum of $4,254.76 in back pay and reasonable attorneys fees 
which would be litigated separately.

On April 15, 1981, appellee filed a motion requesting an award 
of attorneys' fees and costs totaling $24,442.22. The request 
included a lodestar amount $14,200.95 for retained counsel; 
$3,000 for appellee's own pro se representation; and $140.79 in 
costs. Appellant has appealed only the first of the three compo­
nents of the award.

The total "lodestar" fee demanded for appellee's retained 
counsel was outlined as follows:

ATTORNEY CLASS YEAR HOURS HOURLY ]RATE FEES
Valerie V. Ambler Partner 1979 5.6 $102.00 $ 571.201980 0.6 123.00 73.801981 1.0 138.00 138.00
Elizabeth L. Newman Partner 1980 31.85 123.00 3 ,917.551981 18.80 138.00 2 ,594.40
Alan M. Sandals Associate 1981 49.35 60.00 2 ,961.00
Paula Carmody Associate 1980 78.90 50.00 3 ,945.00

TOTAL $14 ,200.95

1/ In addition, appellee sought a contingency adjustment to the 
lodestar of 50% bringing the total amount demanded for retained 
counsel to $21,301.43.



3

Appellant filed an opposition to appellee's motion on May 15, 1981, 
and requested the opportunity to take discovery and have a hearing 
regarding appellee's request.

The District Court issued an Order on June 30, 1981, in which 
it awarded appellee her requested lodestar amount of $14,200 in 
attorneys' fees, $3,000 in pro se fees and $140.79 in costs. No 
separate contingency adjustment was awarded.

ARGUMENT
The District Court abused its discretion when 
it denied discovery and awarded $14,200.95 in 
attorneys' fees in a conclusory manner with no basis in the record.____________

In Copeland v. Marshall, 641 F.2d 880 (D.C. Cir. 1980) (en 
( Copeland III ) , this Court established that the determina­

tion of a fee award is to begin with the fixing of a "lodestar" 
amount by multiplying the number of hours reasonably expended 
times the reasonable hourly rate (or rates). Id. at 891. The 
District Court correctly cited to Copeland III for its analysis 
and determination of the award amount. However, we submit that 
the District Court's analysis and its attorneys' fee award repre­
sents an abuse of discretion in three respects: (1) the Court
denied appellant's request for discovery and a hearing; (2) the 
Court held that all of the hours claimed by counsel for appellees 
were reasonably expended; and (3) the Court established what it 
defined as the reasonable hourly rate in the Washington, D.C. 
area for similar Title VII work without any basis. In each 
respect in which the District Court abused its discretion, it



4

failed to adequately articulate its reasons or based its decision 
on improper factors. See Copeland III, supra at 901 n.39. As a 
result, the District Court's fee award should be reversed and this 
action should be remanded with instructions to grant appellant's 
request for discovery and a hearing and thereafter to recalculate 
the fee award using the appropriate factors.

A. The District Court's failure to
permit discovery and a hearing is 
an abuse of discretion.

This Circuit in Copeland III recognized the appropriateness 
of discovery and a hearing in contested attorneys' fees claims. 
Icl. at 905. We submit that the denial of discovery and a request­
ed hearing in the context of this case was an abuse of discretion.

Discovery is necessary on the issues of the number of hours 
reasonably expended and the hourly rate counsel for appellees are 
entitled to receive. Counsel for appellee failed to submit
any documentation that specifically addressed the rate "prevailing 
in the community for similar work." Copeland III at 975. Instead 
of allowing discovery, or even compelling counsel for appellees

-•£•» Stastny v. Southern Bell Telephone and Telegraph Co., 
^  F.R.D. 662 (W.D.N.C. 1978) (discovery relevant and production 
ordered of original time records of counsel along with documenta­
tion of fees received by same attorneys in other related cases);
Naismith v. Professional Golf Association. 85 F.R.D. 552, 562-565 
(N.D. Ga. 1979) (discovery relevant and production ordered of 
a^ ° rneys ' hours, rates and total fees as well as their knowledge 
of fee awards obtained in community (Atlanta) by same attorneys 

’ —  also Volf v - Frank, 555 F.2d 1213 (5th Cir.19/7) (after a challenge to attorneys fee supporting affidavits 
as inadequate, Court permitted deposition of the attorney seeking the fee and others).



5

to produce more evidence of the hourly rates paid by their paying 
clients or of the hourly rates prevailing in the community for 
similar work, Judge Robinson simply adopted counsel for appellees' 
proposed hourly rates.

For essentially the same reasons, we submit that the District 
Court abused its discretion in denying our request for a hearing. 
This Court in Copeland III recognized the usefulness of con­
ducting a hearing on the issue of the fee when such a hearing is 
requested and when the amount of the fee is contested. Id. at 
905. Courts of Appeals in other Circuits have recognized that a 
hearing is required where the amount of the fee is contested and 
the failure to hold a hearing under such circumstances is an 
abuse of discretion. See Detroit v. Grinnel Corp.. 495 F.2d 448, 
468 (2d Cir. 1974); Lindy Brothers Builders, Inc, v. American Radi- 
ator & Standard Sanitary Corp.. 487 F.2d 161, 169-170 (3rd Cir. 
1973) (Lindy I); Grumin v. International House of Pancakes, 513 
F.2d 114, 127 (8th Cir. 1975). As the Third Circuit Court of 
appeals stated:

[0]pposing interests should be afforded a 
hearing to provide an evidentiary basis for 
resolution of disputed factual matters and to 
allow the parties to supplement possibly 
incomplete statements of opposing parties.

Lindy— I, 487 F.2d at 169. In this case both the hours reasonably
expended and the reasonable hourly rate were contested; the
District Court's refusal to grant discovery and a hearing is
reversible error.



6

B. The District Court's conclusion 
that all of the hours claimed by 
counsel for appellees were reasonably 
expended is an abuse of discretion.

The District Court correctly recognized, citing Copeland III, 
that the first issue in any fee setting inquiry is to determine 
the reasonable number of hours spent by the attorneys requesting 
the fee. However, the District Court then clearly erred in 
awarding compensation to appellees' attorneys for every hour of 
time that they requested.

It is incumbent upon the party seeking fees to present the 
Court with sufficient documentation to allow the kind of searching 
analysis that Copeland III requires. In this case, appellant's 
challenge to the reasonableness of the hours was severely limited 
by the District Court's refusal to allow discovery and a hearing. 
Nonetheless, appellant did identify certain points that required 
a reduction in the hours which the District Court rejected. For 
example, counsel for appellee claimed compensation for hours 
spent by partners and associates talking with each other in their 
law office. Just as Copeland III, supra at 891, provided that 
where three attorneys are at a hearing where one would suffice, 
billing judgment requires that compensation should be denied for 
the excess time, we believe billing judgment requires that compen­
sation for more than one counsel should be denied when counsel 
discuss the case among themselves. It is not uncommon for attorneys 
in private practice to review each others work or to discuss a 
case among themselves. However such time is duplicative and



7

should be reduced in the exercise of "billing judgment." This is 
especially true when partners discuss a case or review each 
others work. To do otherwise results in the government being 
billed at the maximum rate of $276 per hour every time counsel 
choose to discuss this case among themselves. The Distrct Court's 
wholesale acceptance of counsel for appellee's hours while denying 
appellant discovery and a hearing was an abuse of discretion.

C. The District Court abused its
discretion when it awarded counsel 
for appellees compensation at the 
hourly rates that they sought.

After determing the reasonable hours expended, the remaining 
element in fixing the lodestar is determining the reasonable 
hourly rate. We submit that the District Court clearly erred 
when it accepted wholesale counsel for appellee's statement of 
the hourly rate they believed that they were entitled to receive.

It is clear that "plaintiff has the burden of proving his 
entitlement to an award of attorney's fees just as he would bear 
the burden of proving a claim for any other money judgment." 
Johnson v. Georgia Highway Express, Inc., 488 F.2d 714, 720 (5th 
Cir. 1974). accord, Copeland III at 891-892. ^  Counsel for 
appellee simply have not met their burden of proof in providing 
that the hourly rates sought are reasonable.

Remain specifically recognized that the Johnson analysisremain!s] central to any fee award." Copeland III, supra at 889.

)



8

At this juncture, it is helpful to summarize the method by 
which counsel for appellee attempted to establish their reasonable 
hourly rate. Essentially, counsel for appellee's started calcula­
tion of their hourly rate by using a base figure of $75.00 per 
hour which one of the counsel had obtained in a 1977 settlement. 
Next, counsel added $5.00 per hour since 1977 for each succeeding 
year to account for their alleged "increased expertise in employment 
discrimination cases." Then, each year's hourly rate was also 
adjusted, "to compensate for the effects of inflation on that 
base rate, using the consumer price index as a key to the average 
annual inflation factor." (App. 14-16). Counsel for appellee cal­
culation of their hourly rate is totally artificial and gives no 
clue as to what rates were actually paid to counsel for appellee 
or what fees were actually paid to other local Title VII lawyers 
for similar services. Counsel for appellee's method of calcula­
tion of their present hourly rate is even more artificial than the 
"cost plus" hourly rate expressly rejected by the Court in Cope­
land III. Id. at 896-900. In rejecting that artificial approach, 
the Court stated that it would rely upon the "market mechanism" 
or law of supply and demand to determine a reasonable hourly 
rate. The Court in Copeland III envisioned that the pressure of 
the market would keep attorneys' hourly rates at a reasonable 
level. Thus while counsel for appellee may hypothesize that they 
acquired $5.00 per hour more experience per year, the real relevant 
question under Copeland III is whether clients in the marketplace 
paid such fees to counsel or to similarly situated Title VII 
counsel. Moreover, while counsel for appellee may hope that



their hourly rate kept pace with inflation, the relevant question 
again is whether counsel for appellee or similarly situated 
counsel have been successful in passing on the costs of inflation 
to their clients. If the market has not allowed counsel to pass 
on inflation costs to their clients, then counsel in this action 
should not be allowed to pass such costs on in this action simply 
because the government is paying the attorneys' fees.

Counsel for appellee's determination of the hourly rate 
chargable by associates, $50 and $60 per hour, is no more realistic. 
Both associates only graduated from law school in 1980. There 
was absolutely no evidence that either had experience in Title 
VII law or that paying clients paid the firm at the high rates 
sought from the government. Additionally, there was no evidence 
that paying clients paid other recent law school graduates at 
those high rates for similar work.

Review of counsel for appellee's affidavits describing their 
experience does not justify the hourly rate of $138 per hour. 
Both lead partners were only admitted to the Bar in 1973. Neither 
appears to have tried a case at the time compensation was paid.
It appears that the firm of Ambler and Newman was only established 
in 1980. None of these factors would seem to justify what was at 
the thime the highest hourly rate awarded against the government 
by a Court in this Circuit. Counsel for appellee did not

4/ We are only aware of one case, which was decided subsequent 
to the decision at bar with an hourly rate above the $138 rate 
awarded in this case. Crowley v. Haig No 74-0494 (D.D.C. 1981) 
(FOOTNOTE CONTINUED ON NEXT PAGE)

9



10

provide supporting facts about rates actually being paid to 
themselves or to attorneys of similar skill performing similar 
work. There was no such evidence presented to the District Court 
in this action, except for a conclusory claim that there have 
been instances of clients paying $150.00 per hour to counsel for 
appellee (App. 32). Without explanatory detail and discovery, 
even this assertion seems to be an aberation that is clearly 
insufficient to support the Court's award.

The Equal Access to Justice Act, Public Law 96-481 § 201 et 
seq., October 1, 1980, which became effective for actions pending 
or commenced on or after October 1, 1981, authorizes the payment 
of attorney's fees to a prevailing private person in administra­
tive or judicial proceedings against the United States unless it 
is determined that the position of the United States was substan­
tially justified or special circumstances make an award unjust. 
The Act provides that attorneys' fees which are to be based on 
prevailing market rates shall not be awarded in excess of $75 per 
hour unless the Court determines that an increase in the cost of 
living or a special factor, such as limited availability of 
qualified attorneys available for the proceedings involved, 
justifies a higher fee. Although this Act's hourly rate specifi­
cally does not apply to actions brought under Title VII, the $75

(FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
($148.28). That case, which was also decided by Judge Robinson, 
xs pending appeal. No. 81-2213. All other attorneys' fees 
awards against the government in this Circuit by Judges other 
than Judge Robinson are at levels considerably lower than $138 per hour. See Appendix A to our brief.



11

per hour is the amount that Congress has determined generally is 
the outside limit on market rates in 1981 when attorney's fees 
are to be paid by the government. The outside limit of $75 per 
hour by definition includes any adjustments which may be sought 
such as for a delay contingency adjustment, and incentive adjustment. 
Presumably the rates would have lower for work performed prior to 
1981.

As reflected in Appendix A to this brief, the rates awarded 
in this case, at the time of decision, included the highest 
hourly rates ever awarded against the government by any court in 
this District. Thus, the government is seriously concerned that 
these rates may set the new "floor" for rates "prevailing in this 
community," within the meaning of Copeland III. Id. at 892.
Since these rates are so out of line with other recent awards, 
and since the district court committed several errors in setting 
them, we submit that a reversal is required.

Appellee submitted as an exhibit to her motion for fees a 
list of twelve cases that purport to show a wide range of attorney's 
fees awarded since 1972. This submission certainly could not 
form a basis for determining that $138.00 per hour is a reasonable, 
prevailing rate for a case such as this one. Seven of the cases 
cited are labelled as being antitrust or securities-related 
cases. Five others are broadly labelled Title VII, Title VI or 
desegregation cases. There is nothing stated or argued about how 
this second group of cases compare in difficulty or range of 
issues to the instant action. Moreover, any pre-Copeland III



12

case is subject to further scrutiny to determine how, if at all, 
the particular court confronted the same analysis of factors to 
establish an award.

CONCLUSION

WHEREFORE, appellant respectfully submits that the judgment 
of the District Court be reversed and the case be remanded to the 
District Court with directions to permit discovery and a hearing 
and to reconsider the fee award using the appropriate Copeland III 
factors.

CHARLES F. C. RUFF, 
United States Attorney.

ROYCE C. LAMBERTH,
KENNETH M. RAISLER,
CHERYL M. LONG,
Assistant United States Attorneys.



9

A P P E N D I X  A



ATTORNEYS' FEE AWARDS 
DISTRICT OF COLUMBIA

►
CASE TITLE HOURLY RATE CASE TYPE

Vaughn v. Rosen, No. 73-1039 
(D.C. Cir. 1973)

$85 FOIA

Smith v. Kleindiest, 8 FEP 
753 (D.D.C. 1974)

$40-$75 Title VII

Communist Party of the United
States v. Department ot Justice, 
No. 75-1770 (D.D.C. 19/b; “

,$45 FOIA

Parker v. Matthews, 411 F. Supp. 
1059 (1976J~

$30-$60 Title VII

Pealo v. Farmers Home Adm., 412 
F. Supp. 561 (D.D.C. 1976)

$50-60 Housing

Rucker v. Matthews, No. 75-0531 
(TTD.C. 1976) “

$58.05
(average) Title VII

Weahkee v. Perry, 16 FEP 755 
^(D.D.'C. 1976)~
Walden v. Boorstin, 16 FEP 1739 

(D.D.C. 1976)“

$60 Title VII

$50 Title VII

Williams v. Saxbe, 17 FEP 1657 
(D.D.C. 1976)

$30-$65 Title VII

Zeldin v. Hoffman, No. 75-1913 
(D.D.C. 1976)“

$40 FOIA

Anderson v. Treasury, et al., 
— No. "76-1404 (D.D.C. 19/ T)

Not based on hourly 
rate (awarded $2,000)

Privacy Act

Founding Church of Scientology 
of Washington, D.U., Inc. v. 
Marshall, 439 F. Supp. 1267 
(D.D.C. ”1977)

$60 FOIA

Copeland v. Usery, 14 FEP 1677 
(D.D.C. 1977)

$57.17
(average)

Title VII

Pace v. Califano, No. 76-99
t d .d .c . T<nrr

$52-$54 Title VII

R p Amnicillin Antitrust 
Litigation, MDL. No. 3U,
Rise. No~45-70 (D.D.C. 1978)

$40-$200 Antitrust
(non­
government)

.)

13



CASE TITLE HOURLY RATE CASE TYPE
Cayce v. Adams, 18 FEP 465 

(D.D.C." 1978)
Tpeland v. Marshall, No. 77-1351 

t (D.D.C. 19781
Kinsey v. Legg Mason Wood Walker, 

* No. 71-1338 (D.D.C. 1978)

Parker v. Califano, 443 F. Su d d . 
789 (D.D.C. 1978)

Postow v. Oriental Bldg. Ass'n, 
455 F. Supp. 781 (D.D.C. 1978)

American Broadcasting Companies 
Inc., et al. v. Department of 
Labor, et al.. No. 78-1711 
TTT.C.c. 1979)

Crooker v. Department of Justice, 
No. 78-1820 (D.D.C. 1979)

iB»es. v. United States Secret 
^service, et al., No. 78-0891 

"(D.D.C. 1979)
Marimont v. Califano, No. 1992-73 
“ (D.D.C. 19791

Public Citizen Health Research 
Group v. Department of Labor, 
No. 76-88/ (D.D.C. 1979)

Sonnenberg v. Adams, 18 Emp.
Prac. Dec. IT 8875 (D.D.C. 1979)

Ward v. Postal Rate Commission, 
No. 77-0145 (D.D.C. 1979)

Williams v. Boorstin, No. 78-2408 
(D.D.C. 19791

Wolfson v. Dept, of Justice,
No. 75-1714 (D.D.C. 1979)

Jones v. Trailways Corporation, 
No. 78-TT27- (D.D.C. 19S01---

$40-$75

$51.65

$20-$65

$35-$72

$60-$75

$55-$75

$5
(Pro se 
Prisoner)
$10
(Pro se 
Prisoner)
$50-85

$55

$50

$50-75

$75

$60-$75

$75

Title VII

Title VII

Title VII 
(non­
government)
Title VII

Truth-in 
Lending 
(non­
government)
FOIA

FOIA

FOIA

Title VII 

FOIA

Title VII

FOIA
PA
Title VII 

FOIA

Title VII 
(non­
government)



CASE TITLE A HOURLY RATE ^ CASE TYPE

V7illiams v. Civiletti,
No. 74-0186 (D.D.C7 1980)

$30-$85 Title VII

ffchman v. Pertschuk, 
i No. 76-0079TD.D.C. 1981)

$70-$100 Title VII

Blake v. Hoston, 513 F. Supp. 
* 6^3 (D.D.C. 1981)

$40-$75 Title VII

Caton v. Barry, No. 80-1584 
[D. D. C . _T913l)

$50-100 Housing
(non­
government)

Donnell v. United States of 
America, No. 78-0392 (D.D.C. 
1981)

$40-60 Voting
Rights

Fells v. Brooks, No. 80-2981 
T dTD.C. 1981)

$75 Vocational 
Rehabili­

tation 
Act (non­
government)

G a m e s  v. Brown, No. 76-0974 
(D.D.C. 1981)

$60-$100 Title VII

Green v. Department of Commerce, 
^ N o .  77-0363 (D.D.C. 19FT)
Indian Lav; Resource Center v. 

U.S. Department of the 
Interior, No. 79-0540 
(D.D.C. 1981)

$45-95 FOIA

$70
(average)

FOIA

In Re Swine Flu Immunization 
Products Liability Litigation, 
MDL No. 330, Misc. No. /8-Ou40 
(D.D.C. 1981)

$40-$75
and

$100 (lawyer- 
physician)

Swine Flu

Kemp v. Williams, No. 77-2014 
“ID.D.C. 1981)

$45-$60 Title VII

Lawrence v. Franklin Investment 
Co., Inc., et al., No. 78-0919 
TDTD.C. 1981)

$75 Truth-in 
Lending 
(non­
government)

Mangiapane v. Secretary of 
Transportation, No. 75-1239 
(D.D.C. 193IT~

$70 Title VII

1 National Ass'n. of Concerned $85 FOIA
Veterans v. Secretary of 
Defense, No. 79-0212 (D.D .C .TTOTT- 15



CASE TITLE HOURLY RATE CASE TYPE

North Slope Borough v. Andrus,
 ̂ 515 F.Supp. 961 (D.D.C. 1981)
Metropolitan Washington 

* Coalition for Clean Air,
et al. v. District of Columbia, 
NosT- 73-1424, 73-F844 (D.D.C.- 
^981)

Parker v. Lewis, No. 79-3443
(D7D.C. 1981)

Quinto v. Legal Times of 
Washington, Inc., 511 F.
Supp. 579 (D.D.C. 1981)

Smith v. Schweiker, No. 76-2311 
(D.D.C. 1981)

Sneed v. Harris, No. 77-2191 
(D.D.C. 1981)

Veterans Education Project
v. Secretary of the Air Force, 
et al., No. 79-210 (D.D.C. 1981)

Whelchel v. Lewis, No. 78-0514
--(D.D.C. 198T)

Crowley v. Hai£, No. 74-0494 
(D.D.C. 1981)

Breen v. Tucker, No. 78-2222 
(DTD.C. 1981)

$45-$125 ESA/OCSLA

$40-$175 Clean Air

$50-$138 Title VII

$5 - law student 
(Pro se)

Copyright
(non­
government)

$55-$65 Title VII

$80 Title VII

$35-$110 FOIA

$65-$85 Title VII/ 
Equal Pay 
Act

$40-$l48.28 Personnel 
Action - 
Back Pay Ac

$90 Title VII 
(non­
government)

I

16



p