Free Affidavit - District Court of Delaware - Delaware

Case 1 :04-cv-00834-SLR Document 19 Filed 05/18/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
In re: ) Chapter II
· )
STONE & WEBSTER, INCORPORATED ) Case No. 00-02142 (PI W)
e Q Q., ) Jointly Administered
) Adv. No. Ol-7766 (PJW)
Debtors )

)
SAUDI AMERICAN BANK, )
Plaintiff )
A )
v. )
)
THE SHAW GROUP INC., SWINC )
ACQUISTION THREE, INC., and )
STONE & WEBSTER ENGINEERING )
A CORPORATION, et al., )
Defendants )

AFFIDAVIT OF KEVIN J. MANGAN IN SUPPORT OF
PLAINTIFF’S MOTION FOR ASSESSMENT OF DAMAGES
I, Kevin J. Mangan, do hereby depose and state:
l. I am a senior associate in the law firm of Monzack and Monaco, P. A. ("M&M"),
local counsel for the plaintiff, Saudi American Bank ("SAMBA") in the above captioned action.
This affidavit is made in support of Plaintiff ’s Motion for Assessment of Damages and
Memorandum in support thereof, which are being filed herewith.
2. I am familiar with the facts surrounding this case. M&M has served as local
Delaware counsel in this matter since it was contacted by Kirkpatrick & Lockhart Nicholson
Graham LLP ("K&LNG") in May 2001. I have been responsible for overseeing the selection
and supervision of other attorneys and support personnel working on behalf of SAMBA.
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Case 1:04-cv-00834-SLR Document 19 Filed 05/18/2005 Page 2 of 4
3. I have reviewed and have direct personal knowledge of all of the M&M billing
items referred to below.
4. Each item that is included in the invoices attached hereto is, in my judgment,
which is based on my substantial litigation experience: (1) a reasonable and necessary expense;
(2) does not include any expenses that were unnecessary, redundant, or excessive; (3) was
calculated using hourly rates and fees that are no greater than M&M’s customary fees for cases
of this type; and (4) is the amount that has been or will be charged by M&M to SAMBA in
connection with this litigation.
5. The rates, relevant experience, and roles of the attorneys and paraprofessionals
who assisted in the litigation and supervised or billed time during the course of the litigation are
as follows:
i i . .
ttt lrr
Kevin J. Mangan, Associate $215 - $295 205.97
Experience in the litigation of a wide variety of complex
civil litigation matters. J .D., Villanova University, 1989;
B.S., University of Scranton, 1986
Francis A. Monaco, Jr., Partner $315 — $425 83.26
Heidi E. Sasso, Paralegal $110 — $135 11.95
Joseph J. Bodnar, Associate $305 1.70
Joseph R. Biden, 111, Of Counsel $195 1.70
Edward M. Lilly, Associate $205 0.4
6. Exhibit A attached hereto and incorporated herein are invoices dated June 2000 —
May 2005 which detail the total hours of legal services performed by M&M attorneys and
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Case 1:04-cv-00834-SLR Document 19 Filed 05/18/2005 Page 3 of 4
paraprofessionals and fees expended in connection with this litigation. The fees for professional
services total $86,523.07; costs total $3,227.81.
7. To date, there are unbilled fees in the amount of $1,981 .50. These fees and costs
are detailed in Exhibit B attached hereto. Counsel estimates that additional fees and costs related
to the filing of the Motion for Assessment of Fees, and Memorandum and Affidavits in support
thereof will total $750.00.
8. The sum of SAMBA’s reasonable attorneys’ fees and related costs, performed by
M&M in connection with this litigation, are as follows:
Professional Services (billed): $ 86,523.07
(Exhibit A)
Professional Services (to be billed): $ 1,981.50
(Exhibit B)
.; , Vstibtqati nil- Piaiessiomi isefviggs ` j- i a fs; 88,50§Ii5i7E- 2
Costs (billed): $ 3,227.81
(Exhibit A)
Costs (to be billed):
(Exhibit B)
2 x , Y `° 22- 2F 2 ‘sub¢o¢ai,t¤i·2C;1sms., 1 ii 2 $3,227.8-1 gi ,
iril

wil l .1 2 ‘ i ai* ? ¤¥ £ i i til.? 52 3% §i T?1‘ i»i$i ’i 3€ii it il
Estimate--01`·additi‘0nalrfeesgt0 _beiii1cnrred Ein Z in -_ in 750..00, 1
· 2 2 eermectiou with Mzctibnffor . Q r 2 Z I A ‘ _ 1 - ` `
E2- ¥ ~_ 2Assess¤rncn¤t:ofDatuages_ . E. 2; ` _ _`_i __ 2, _ _
tg ; i l 1
*
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Case 1:04-cv-00834-SLR Document 19 Filed 05/18/2005 Page 4 of 4
Signed under the pains and penalties of perjury this { Yi-ckday of May 2005.
Kevin §angan fj
STATE OF DELAWARE :
: SS
NEW CASTLE COUNTY :
On this M day of May 2005, before me, the undersigned notary public, personally
appeared Kevin J. Mangan, known to me personally to be such, and acknowledged this Affidavit
In Support Of Plaintiff ’s Motion for Assessment of Damages.
Notary Public E
TARA L. KRATZER
NOTARY PU BLiC
STATE OF DELAWARE
My Commission Expires May 18, 2007
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