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noting that it is well established that the relevant community is the district in which the court sits
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Civ. 97-7895 (SAS), 98 Civ. 8202 (SAS)
July 29, 2003
Linda M. Cronin, Esq. Joan M. Cresap, Esq., Trager, Cronin Byczek, L.L.P., Lake Success, New York, for Police Officer Plaintiffs
Peter J. Blessinger, Esq. George C. Cerrone, Esq. Cerrone Geoghan, New York, New York, for SBA Plaintiffs
James M. Lemonedes, Esq. Donald Sullivan, Esq., Assistant Corporation Counsel, New York, New York, for Defendants
OPINION AND ORDER
In this consolidated action, the Patrolmen's Benevolent Association ("PBA"), the Sergeant's Benevolent Association ("SBA") and twenty-four members of the New York Police Department brought suit to redress civil rights violations resulting from defendants' race-based decision to transfer the officers into the 70th Precinct in the wake of the Abner Louima incident. The PBA and SBA filed their Complaints on October 23, 1997, and November 18, 1998, respectively. After voluminous discovery, a jury trial was held from May 24, 2000 until June 15, 2000.
The term "officers" is used herein to include both police officers and sergeants.
For a fuller discussion of the facts surrounding this litigation see Patrolmen's Benevolent Ass'n of the City of New York v. City of New York, 74 F. Supp.2d 321 (S.D.N.Y. 1999).
The jury returned a verdict for plaintiffs in the aggregate amount of $1,200,000 ($50,000 for each officer). Post-trial, plaintiffs requested the following equitable relief: (1) that defendants be enjoined from making race based transfers absent exigent circumstances; and (2) that the individual plaintiffs be afforded the opportunity to transfer out of the 70th Precinct. See Patrolmen's Benevolent Ass'n of the City of New York v. City of New York, No. 97 Civ. 7895, 98 Civ. 8202, 2000 WL 1538608, at *3 (S.D.N.Y. Oct. 18, 2000). Plaintiffs' request for equitable relief was denied. See Id. at *4 Defendants then moved for judgment as a matter of law under Federal Rule of Civil Procedure 50(b) and for a new trial under Rules 59 and 60. See Id. at *1-2. Both of these motions were also denied. See Id. at *2. Defendants appealed the judgment to the Second Circuit where it was affirmed. See Patrolmen's Benevolent Ass'n of the City of New York v. City of New York, 310 F.3d 43, 56 (2d Cir. 2002). The Second Circuit taxed $736.10 and $461.14 in costs in favor of the PBA and the sergeant plaintiffs respectively. Defendants sought a rehearing en banc which was denied. Defendants finally petitioned the United States Supreme Court for certiorari but this too was denied. See City of New York v. Patrolmen's Benevolent Ass'n of the City of New York, 71 U.S.L.W. 3721 (U.S. May 19, 2003) (No. 02-1321).
Plaintiffs now seek an award of attorney's fees and costs incurred in this litigation. Cronin and Byczek, LLP, counsel for the PBA plaintiffs, incurred a total of $767,080.13 ($753,711.50 in fees and $13,368.63 in costs) while Cerrone and Geoghan, counsel for the SBA plaintiffs, incurred a total of $285,746.25 ($282,270 in fees and $3,476.25 in costs). In addition, Norman A. Olch, an attorney hired by the SBA to handle the appeal, seeks $49,052.50 in attorney's fees. For the following reasons, defendants are hereby ordered to pay Cronin and Byczek, LLP $635,612.83, Cerrone Geoghan $188,585.25 and Norman Olch $49,052.50.
I. GENERAL PRINCIPLES
In the Civil Rights Attorney's Fees Awards Act of 1976, Congress provided that in federal civil rights actions, "the court, in its discretion, may allow the prevailing party, other than the United States, a reasonable attorney's fee as part of the costs. . . ." 42 U.S.C. § 1988 (b) (emphasis added). "The purpose of § 1988 is to ensure effective access to the judicial process for persons with civil rights grievances." Hensley v. Eckerhart, 461 U.S. 424, 429 (1983) (internal quotation marks and citation omitted). "Accordingly, a prevailing party should ordinarily recover an attorney's fee unless special circumstances would render such an award unjust." Id. (internal quotation marks and citation omitted). Because the amount of a fee award depends on the unique facts of each case, district courts are given broad discretion in assessing what is reasonable under the circumstances. See Luciano v. Olsten Corp., 109 F.3d 111, 115 (2d Cir. 1997) ("[A]bsent an abuse of discretion or an error of law, we will not disturb the district court's calculation of reasonable attorney's fees.").
A. Lodestar Method
"In determining reasonable attorney's fees, the district court must calculate a `lodestar' figure based upon the number of hours reasonably expended by counsel on the litigation multiplied by a reasonable hourly rate." Id. (citing Blanchard v. Bergeron, 489 U.S. 87, 94 (1989)). The party seeking a fee award bears the burden of demonstrating that the claimed rates and number of hours are reasonable. See Blum V. Stenson, 465 U.S. 886, 897 (1984); Hensley, 461 U.S. at 433 ("The party seeking an award of fees should submit evidence supporting the hours worked and rates claimed.").
"The task of determining a fair fee requires a conscientious and detailed inquiry into the validity of the representations that a certain number of hours were usefully and reasonably expended." Lunday v. City of Albany, 42 F.3d 131, 134 (2d Cir. 1994). In determining what is reasonable, "the district court does not play the role of an uninformed arbiter but may look to its own familiarity with the case and its experience generally as well as to the evidentiary submissions and arguments of the parties." Gierlinger v. Gleason, 160 F.3d 858, 876 (2d Cir. 1998).
B. Hourly Rates
Plaintiffs must demonstrate that the hourly rates they seek are "in line with those prevailing in the community for similar services by lawyers of reasonably comparable skill, experience, and reputation." Blum, 465 U.S. at 896 n. 11. It is well-established that the relevant "community" is "the district in which the court sits." Polk v. New York State Dep't of Corr. Servs., 722 F.2d 23, 25 (2d Cir. 1983). Because this action took place in the Southern District of New York, the prevailing hourly rates are those of lawyers in small law firms located in this district.
C. Number of Hours
A court may exclude those hours it finds to be "excessive, redundant, or otherwise unnecessary." Hensley, 461 U.S. at 434. See also Shannon v. Fireman's Fund Ins. Co., 156 F. Supp.2d 279, 301 (S.D.N.Y. 2001) ("Attorneys should not be reimbursed for inefficiencies, duplication or excessive submissions.") (citing Lunday, 42 F.3d at 134). In reducing the number of hours claimed, a court may, in its discretion, apply an across-the-board percentage reduction "`as a practical means of trimming fat from a fee application.'" Kirsch v. Fleet Street, Ltd., 148 F.3d 149, 173 (2d Cir. 1998) (quoting New York Assoc. for Retarded Children v. Carey, 711 F.2d 1136, 1146 (2d Cir. 1983)). See also Luciano, 109 F.3d at 117 ("[A] district court can exclude excessive and unreasonable hours from its fee computation by making an across-the-board reduction in the amount of hours.").
D. Costs
It is well-settled that "attorney's fees awards include those reasonable out-of-pocket expenses incurred by attorneys and ordinarily charged to their clients." LeBlanc-Sternberg v. Fletcher, 143 F.3d 748, 763 (2d Cir. 1998) (internal quotation marks and citation omitted). Compensable costs are not limited to those costs taxable pursuant to 28 U.S.C. § 1920, as implemented by Federal Rule of Civil Procedure 54(d)(1), but include expenses incurred for postage, photocopying, long distance telephone, local travel, process servers, and messengers. See Kuzma v. I.R.S., 821 F.2d 930, 933 (2d Cir. 1987); Sulkowska v. City of New York, 170 F. Supp.2d 359, 370 (S.D.N.Y. 2001).
II. FEES AWARDED
A. Cronin Byczek, LLP
Cronin Byczek, LLP ("CB") seek approximately $767,080.13 in attorney's fees and costs. See Rider 1. This amount can be divided between trial work and appellate work. Requested trial fees amount to $628,962.75 with costs of $11,310.43. Fees and costs requested for CB's appellate work, including the appeal to the Second Circuit and the opposition to defendants' petition for certiorari, amount to $126,806.95 ($124,748.75 in fees and $2,058.20 in costs). These fee amounts were calculated based on the following hourly rates proposed by CB: $350 for partners Linda Cronin and Marshall Trager; $250 for all associates; and $45 for paralegals.
Note that the Rider contains a line for "Discrepancy" which deducts $7,477.75 from Total Trial Fees. This adjustment was needed because the number of hours listed in Exhibit A to Linda M. Cronin's July 21, 2003 Letter to the Court ("Cronin Ltr.") exceeded the hours and fees included in CB's original fee application. The number of hours were reduced by 16.70 and the fees were reduced by $7,477.75 to correlate to the amount requested by CB ($640,273.18).
In a letter dated July 21, 2003 to the Court, plaintiffs concede that Culver and Crusius are junior associates and that the hourly billing rate should be reduced to $125 per hour. See Cronin Ltr. at 5. Plaintiffs also concede that the unnecessary expenses cited by defendants should be discounted from plaintiffs' fee application. See 9/25/00 Letter from Linda M. Cronin. Those expenses, as calculated by the Court, amount to $945. See Attachment to 9/11/00 Letter from Donald C. Sullivan, defendants' counsel ("Sullivan Ltr."). Accordingly, the trial costs, as adjusted, amount to $10,365.43.
Another adjustment is necessary, however, to some of the hourly rates submitted by CB and used to calculate both trial and appellate fees. Defendants argue that the hourly rate for Linda Cronin and Marshall Trager should be $275 per hour and that the rate for associates, other than Culver and Crusius, should be $200 per hour. I agree in part. Here, a blended rate of $200/hr for associates is appropriate as it takes into account their divergent backgrounds and differing levels of experience. See Marisol A. ex rel. Forbes v. Giuliani, 111 F. Supp.2d 381, (S.D.N.Y. 2000) (finding the following rate scale to be reasonable: $230-250/hr for attorneys with seven to nine years of experience; $180-200 for attorneys with four to six years of experiences; and $130-150 for attorneys with one to three years experience).
I disagree, however, with the $275/hr rate suggested by defendants for Cronin and Trager for several reasons. First, rates have gone up dramatically since 2000. This is significant because the rates used in calculating a fee award should be "`current rather than historic hourly rates.'" Gierlinger, 160 F.3d at 882 (quoting Missouri v. Jenkins, 491 U.S. 274, 284 (1989)). Second, this Court has recently endorsed rates of $350-375 for attorneys with substantial experience. See S.W. ex rel. N.W. v. Board of Educ. of the City of New York, 257 F. Supp.2d 600, 604-05 (S.D.N.Y. 2003) (finding $350/hr rate reasonable for an attorney with twenty-three years experience and particular expertise in education law) (citing cases). Several other courts in this district have likewise approved of rates in this range. See M.S. v. New York City Bd. of Educ., Nos. 01 Civ. 4015, 01 Civ. 10871, 01 Civ. 10872, 2002 WL 31556385, at *5 (S.D.N.Y. Nov. 18, 2002) (approving a rate of $350 per hour for attorney with more than twenty years experience); Mr. X v. New York State Educ. Dep't, 20 F. Supp.2d 561, 564 (S.D.N.Y. 1998) (approving a rate of $350 to $375 per hour for a "very experienced litigator" in an IDEA action); Marisol A., 111 F. Supp.2d at 386 (finding, based upon research on recent fee awards in civil rights cases, $350/hr to be a reasonable rate for attorneys with more than fifteen years experience). Linda Cronin has been practicing since 1988 and has approximately thirteen years of experience in representing police officers. See Affidavit in Support of Application for Attorney's Fees dated August 28, 2000 ¶¶ 10, 11. Marshall Trager has been practicing since 1976 and has handled "literally thousands of police-related matters as well as dozens of Federal and State Court trials on behalf of police officers. Id. ¶ 15. For these reasons, the rates for Cronin and Trager will not be adjusted.
However, an adjustment to the total number of trial hours billed by CB is warranted. As stated by Linda Cronin, three attorneys including herself and her partner, Marshall Trager, were assigned to this case at all times. See id. ¶ 14. In addition, I recall that three attorneys, including Cronin and Trager, attended most of the trial. All of this indicates that there was some duplication of effort and some of the functions performed by Cronin and Trager could have been delegated to the firm's associates. See Luciano, 109 F.3d at 117 ("[I]t was within the purview of the court's discretion to determine whether or not the actual time expended by an additional attorney was reasonable."); Beech Cinema, Inc. v. Twentieth Century Fox Film Corp., 480 F. Supp. 1195, 1197 (S.D.N.Y. 1979) ("Many of the functions performed by the partners could have been satisfactorily accomplished by associates, with a considerable saving in fees."), aff'd, 622 F.2d 1106 (2d Cir. 1980). I therefore find that a 10% reduction in CB's total trial hours is warranted. See Carey, 711 F.2d at 1146 (Because "it is unrealistic to expect a trial judge to evaluate and rule on every entry in an application" courts may apply across-the-board percentage cuts "as a practical means of trimming fat from a fee application.")
While this percentage reduction is the same as that requested by defendants, it is for an entirely different reason. Defendants argue that plaintiffs needlessly pursued the claim that the Police Department regularly made race-based transfer decisions. See 9/11/00 Letter from Donald C. Sullivan ("Sullivan Ltr.") at 3. Plaintiffs respond that the only plaintiff that pursued this claim was the PBA which was dismissed from the case in June of 2000. Because plaintiffs have the better argument, trial fees will not be reduced an additional 10% as requested by defendants.
Defendants also seek a 30% reduction in all post-trial fees as plaintiffs arguably "engage[d] in patently redundant billing." 7/8/03 Letter from Donald C. Sullivan at 5. Defendants also argue that because the issues on the petition for certiorari were the same as those presented to the Second Circuit, plaintiffs' hours in opposing the certiorari petition were excessive and redundant. Defendants point to the April 9, 2003 entries listed in the time sheets submitted with plaintiffs' Supplemental Affidavit in Support of Application for Attorneys' Fees as evidence of this point. Plaintiffs' time sheets indicate that five attorneys worked a total of 41.3 hours on "Preparation of Opposition to Writ of Certiorari," including two attorneys who worked 13.5 hours and 9 hours that day. While this number of hours seems high, it is surely not impossible. Law firms often require a number of associates to work on the same project well into the night. Furthermore, it was defendants' decision to petition the Supreme Court for certiorari that caused these additional hours to be expended. Surely, defendants cannot complain of the number of hours plaintiffs were required to spend to respond to defendants' motions. Accordingly, I decline to reduce the total hours incurred by CB for its appellate work.
In sum, applying a 10% reduction in the number of hours, reduced hourly rates for associates, and an adjustment to costs, I find that a total reduction of $123,405.3 from plaintiffs' total requested fees and costs for trial work ($640,273.18) is warranted. Defendants are therefore ordered to pay CB $516,867.88 for its trial work. With regard to CB's appellate work, where only the associate hourly rate was reduced, the revised calculation results in a $8,062.00 reduction. Defendants are therefore ordered to pay CB $118,744.95 for its appellate work. Combining these amounts results in a total $131,467.30 reduction to the requested fees and costs of $767,080.13, which nets out to a payment of $635,612.83 to CB.
B. Cerrone Geoghan
Cerrone Geoghan ("CG") request $285,746.25 in total fees and costs. See Rider 2. See also 6/13/03 Letter from George M. Cerrone and Peter J. Blessinger at 2. This amount again can be divided into total trial work of $228,870 (699.60 hours) and total appellate work of $56,876.25 (146.4 hours). Defendants request two adjustments to CG's total fees: a reduction in the hourly rate and a 30% reduction in the number of hours expended post-trial. For the reasons stated with respect to the CB partners' hourly rates, the hourly rates requested by CG ($325/hr for work performed through 2000 and $375 for work performed thereafter) will not be reduced.
Peter Blessinger became an attorney in 1975 while an active member of the New York Police Department. Since his retirement from the force in 1985, he has had fifteen years of legal experience representing police officers. See Attorney Fee Application dated August 28, 2000 ¶¶ 19, 20. George Cerrone began practicing law in 1976 and has been continuously active as a police labor representative for over twenty-five years. See id. ¶ 29.
With regard to the number of hours, a reduction is warranted for both CG's trial and appellate work, albeit in different percentages. A 30% reduction is applied to CG's trial hours given CG's limited role in the trial and in the litigation in general. CG represented only two individual plaintiffs compared to CB's representation of twenty-two officers. In addition, this Court recalls that the CG firm relied on the work performed by CB for much of the trial proceedings. For these reasons, a 30% reduction to CG's total trial hours is justified. In addition, CG has not provided any supporting documentation for the expenses of $1,500 that it claims. As a result, CG's trial costs are disallowed in their entirety. Applying these adjustments to CG's total trial fees and costs of $228,870 yields a reduction of $69,711.00, reducing the amount of compensable trial work to $159,159.00.
CG's total appellate fees and costs of $56,876.25 are subject to an even greater reduction. CG's time entries appear to be inflated. Defendants cite, as an example, the entries for May 26, 2001. Peter J. Blessinger entered five hours on that day with the description "Met with G. Cerrone for overall review of appeal. Reviewed transcriptes [sic] cases and briefs." The identical entry appears for George M. Cerrone. While CG attempts to explain these entries as necessary to plan a defense against defendants' "oversized brief," it does not explain how Cerrone could have met with himself on May 26, 2001. This is highly suspicious and indicative of shoddy record-keeping. There is, however, another reason why CG's total appellate hours should be substantially reduced.
For his experience and expertise in appellate work, CG retained a new attorney, Norman A. Olch, to handle the appeal. In his supporting affirmation, Olch states that he filed a 51-page brief for appellees Tai and Robertson. See Attorney's Affirmation in Support of Motion ¶ 9(b). Olch also states that: he responded to each issue raised by the appellants, see id. ¶ 9(d); he orally argued the case before the Second Circuit, see id. ¶ 9(e); and that as lead counsel, he "personally did all the research and all the writing of the brief and the opposition to the certiorari petition." Id. ¶ 14. Olch, who had to familiarize himself with the entire 2860-page trial transcript, expended a total of 140.15 hours in the performance of these duties. See id. ¶ 10.
In light of Olch's statements, it is difficult to comprehend how CG billed a total of 146.4 hours, which is more than Olch billed, when it was Olch who took the lead role in the appeal. For this reason, CG's hours on appeal are reduced by 50%, resulting in a total reduction of $27,450.00 to the total requested of $56,876.25 ($54,900.00 in fees and $1,976.25 in costs). In total, CG's requested fees and costs of $285,746.25 have been reduced by $97,161.00, resulting in a net payment to CG of $188,585.25
C. Norman A. Olch
The rate of $350/hr requested by Norman A. Olch is reasonable given his expertise in appellate proceedings. See New York State Nat'l Org. for Women v. Pataki, No. 93 Civ. 7146, 2003 WL 2006608, at *2 (S.D.N.Y. Apr. 30, 2003) (citing numerous cases approving of fees within the $345-400/hr range). Also reasonable is the number of hours requested (140.15). No costs were requested. For these reasons, there is no reduction to total fees requested of $49,052.25.
Olch began practicing law in 1968 and has been lead appellate counsel in over fifty reported federal and state cases. See Attorney's Affirmation in Support of Motion dated June 13, 2003 ¶¶ 5, 7. He has recently been appointed Chairman of the New York State Bar Association's Committee on Courts of Appellate Jurisdiction. See id. ¶ 8.
III. CONCLUSION
For the reasons stated above, defendants are ordered to pay the following amounts forthwith: $635,612.83 to Cronin and Byczek, LLP; $188,585.25 to Cerrone Geoghan; and $49,052.25 to Norman A. Olch. The Clerk of the Court is directed to close all fee applications.
SO ORDERED
PBA/SBA v. CITY OF NEW YORK RIDER 1 97 Civ. 7895, 98 Civ. 8202 Attorney's Fees Worksheet — Cronin Byczek, LLP PLAINTIFFS' APPLICATION FEES AWARDED 0.9 NAME EXPERIENCE HOURS RATE TOTAL HOURS RATE TOTAL TRIAL WORK 10% Reduction; Lower Rates Marshall Trager Partner 315.00 $350.00 $110,250.00 283.50 $350.00 $99,225.00 Linda Cronin Partner 402.8 $350.00 $140,980.00 362.52 $350.00 $126,882.00 Joan Cresap Associate 1025.6 $250.00 $256,400.00 923.04 $200.00 $184,608.00 Sebastian Alia Associate 224 $250.00 $56,000.00 201.60 $200.00 $40,320.00 Joe B. Associate 63.1 $250.00 $15,775.00 56.79 $200.00 $11,358.00 Lattime Associate 60.8 $250.00 $15,200.00 54.72 $200.00 $10,944.00 Rocco Associate 60.7 $250.00 $15,175.00 54.63 $200.00 $10,926.00 McKenna Associate 32.75 $250.00 $8,187.50 29.48 $200.00 $5,895.00 Nack Associate 11.45 $250.00 $2,862.50 10.31 $200.00 $2,576.25 Murray Associate 9.5 $250.00 $2,375.00 8.55 $200.00 $2,137.50 Albom Associate 2.05 $250.00 $512.50 1.85 $200.00 $369.00 Quaranta Associate 3 $250.00 $750.00 2.70 $200.00 $540.00 Funk Associate 1.2 $250.00 $300.00 1.08 $200.00 $216.00 Various Paralegals 259.4 $45.00 $11,673.00 233.46 $45.00 $10,505.70 =========== =========== Total Trial Fees 2,471.35 $636,440.50 $506,502.45 Less: Discrepancy 16.70 $7,477.75 =========== Total Trial Fees — Adjusted 2,454.65 $628,962.75 Total Trial Costs $11,310.43 $10,365.43 =========== =========== Total Trial Work $640,273.18 $516,867.88 Reduction — Trial Work $123,405.30 =========== APPEAL — 2D CIR. 0% Reduction; Lower Rates 1 Linda Cronin Partner 95.25 $350.00 $33,337.50 95.25 $350.00 $33,337.50 Various Associate 79.4 $250.00 $19,850.00 79.40 $200.00 $15,880.00 Culver Jr. Associate 1.3 $125.00 $162.50 1.30 $125.00 $162.50 Crusius Jr. Associate 226.2 $125.00 $28,275.00 226.20 $125.00 $28,275.00 Various Paralegals 77.1 $45.00 $3,469.50 77.10 $45.00 $3,469.50 ========== ========== Total — 2d Cir. Appeal 479.25 $85,094.50 479.25 $81,124.50 CERT. PETITION 0% Reduction; Lower Rates 1 Linda Cronin Partner 24.75 $350.00 $8,662.50 24.75 $350.00 $8,662.50 Mahoney Associate 23 $250.00 $5,750.00 23.00 $200.00 $4,600.00 Avallone Associate 35.5 $250.00 $8,875.00 35.50 $200.00 $7,100.00 Bernstein Associate 23.34 $250.00 $5,835.00 23.34 $200.00 $4,668.00 Culver Associate 66.2 $125.00 $8,275.00 66.20 $125.00 $8,275.00 Various Paralegals 50.15 $45.00 $2,256.75 50.15 $45.00 $2,256.75 ========== ========== Total — Cert. Petition 222.94 $39,654.25 222.94 $35,562.25 Total Appellate Fees $124,748.75 $116,686.75 Total Appellate Costs $2,058.20 $2,058.20 =========== =========== Total Appellate Work $126,806.95 $118,744.95 Reduction — Appellate Work $8,062.00 =========== Total Fees Costs 3,173.54 $767,080.13 2,926.41 $635,612.83 Total Reduction $131,467.30 =========== PBA/SBA v. CITY OF NEW YORK RIDER 2 97 Civ. 7895, 98 Civ. 8202 Attorney's Fees Worksheet — Cerrone Geoghan PLAINTIFFS' APPLICATION FEES AWARDED 0.7 NAME HOURS RATE TOTAL HOURS RATE TOTAL TRIAL WORK 30% Reduction Peter J. Blessinger 609.30 $325.00 $198,022.50 426.51 $325.00 $138,615.75 George M. Cerrone 90.3 $325.00 $29,347.50 63.21 $325.00 $20,543.25 =========== =========== Total Trial Fees 699.60 $227,370.00 489.72 $159,159.00 Total Trial Costs $1,500.00 $0.00 =========== =========== Total Trial Work $228,870.00 $159,159.00 Reduction — Trial Work $69,711.00 =========== APPEAL — 2D CIR. 50% Reduction 0.5 Peter J. Blessinger 85.00 $375.00 $31,875.00 42.5 $375.00 $15,937.50 George M. Cerrone 26.2 $375.00 $9,825.00 13.1 $375.00 $4,912.50 ========== ========== Total — 2d Cir. Appeal 111.20 $41,700.00 55.6 $20,850.00 CERT. PETITION 50% Reduction Peter J. Blessinger 26.1 $375.00 $9,787.50 13.05 $375.00 $4,893.75 George M. Cerrone 9.1 $375.00 $3,412.50 4.55 $375.00 $1,706.25 ========== ========== Total — Cert. Petition 35.2 $13,200.00 17.60 $6,600.00 Total Appellate Fees $54,900.00 $27,450.00 Total Appellate Costs $1,976.25 $1,976.25 ========== ========== Total Appellate Work $56,876.25 $29,426.25 Reduction — Appellate Work $27,450.00 =========== Total Fees Costs 846.00 $285,746.25 562.92 $188,585.25 Total Reduction $97,161.00 ===========