AFFIDAVIT OF WAYNE T. GILL
STATE OF FLORIDA
COUNTY OF PALM BEACH
I, Wayne T. Gill, being first duly sworn, depose and say:
l. I am attorney licensed to practice law in the state of Florida since l969, and have
personal knowledge of the following:
2. I am a partner with the law firm of Walton Lantaff Schroeder Carson LLP. My
office address is l700 Palm Beach Lakes Blvd., Suite 700, West Palm Beach, Florida 3340l.
3. On April 2l, 2004, the court granted my application to appear in this action as pro
hac vice counsel for defendant, Lumbennens Mutual Casualty Company.
4. I have served as Lumbermens' lead counsel in this action throughout all
proceedings, including the trial that took place on March 8, 2007.
5. I have reviewed plaintiffs' memorandum in support of plaintiffs' motion for
attorneys' fees, and all exhibits attached thereto, including the attorney fee bills rendered by
plaintiffs' New York counsel Rubin, Fiorella and Friedman, and by plaintiffs’ Phoenix local
counsel Mariscal Weeks McIntyre and Friedlander.
6. Attached hereto as Exhibit "A" is the chart that I prepared which identifies all of
the improper billing entries contained in each of said attorney fee bills, and which sets forth a
descriptive list of each type of numbered objection contained therein, including a statement of
the legal grounds for each such objection.
DATED this 27th day of April 2007.
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Wayne . Gill, Esq.
Case 2:04-cv-00662-DGC Document 187-3 Filed O4/27/2007 Page 1 of2
SUBSCRIBED AND SWORN to me before this 27th day of April, 2007.
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Case 2:04-cv-00662-DGC Document 187-3 Filed O4/27/2007 Page 2 of 2
Case 2:04-cv-00662-DGC
Document 187-3
Filed 04/27/2007
Page 1 of 2
Case 2:04-cv-00662-DGC
Document 187-3
Filed 04/27/2007
Page 2 of 2