Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

· · Case 3:00-cv-01128-HBF Document 124-6 Filed 10/29/200B,U JP@é0|l’~d{¤2‘¢’/"*" S i
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
RENE M. PALMA , : CIVIL ACTION NO.
Plaintiff, : 3:00CV01 128(HBF)
v. : E
PHARMEDICA COMMUNICATIONS, INC. :
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Defendant. : OCTOBER 28, 2003
'''''''''''''''''''”‘"”'“''''''''''''''''''''''''''''''' “ ””"““‘
AFFIDAVIT OF JOSEPH D. GARRISON
My name is Joseph Garrison. I am over the age of eighteen and understand and believe in
the obligations of an oath. I hereby depose and say:
1. I am a practicing attorney in New Haven, Connecticut and a partner in the law firm I
of Garrison, Levin-Epstein, Chimes & Richardson, P.C. i
2. I graduated from Wesleyan University in 1965 and Comell Law School in 1968. i
3. Until early 1995, I was the Chairman by judicial appointment of the Federal Court
Grievance Committee. I was the founding Chairman of the Cormecticut Employment Lawyers ]
Association, and am a past President and a present member of the Board of Directors of the N
National Employment Lawyers Association which has over 3,200 members nationally. I have [
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in I Case 3:00-cv—O1128—HBF Document 124-6 Filed 10/29/2003 Page 2 of 2 `
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been a speaker at ABA National Institutes, Annual Meetings and seminars, at NELA conventions, r
and am a frequent lecturer and seminar contributor in Connecticut. I was appointed a Charter J
Fellow of the Board of Governors of the College of Labor and Employment Lawyers, and am
Vice-President of the College now. In 2004 I will serve as President ofthe College.
I 4. My practice is concentrated in the area of employment law. Our office represents l
employees more than 95% of the time. Many of our cases involve statutes in which attorney's y
g fees are awarded, so that I remain current with the market for fee award purposes of attorneys in
my office.
5. My billing rate was $225.00 per hour from January 1991 until January, 1994, then
$250.00 per hour until January, 1996, then $275 per hour until January 1998, when it went to
$300 per hour. In January, 1999 I increased it again to $325 per hour, and from January, 2000 to
January, 2002 it was $350 per hour. From January, 2002 to the present it is $400 per hour.
6. Ibill many clients on an hourly fee basis, at the $400 per hour rate. There are
substantially more persons who would like to hire me than I can represent, so this market rate has
been correct for me.
7. Our firm is one of the best- known firms representing employees in the United
States. We are very selective in taking new clients. Our fee structure is higher than those of
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