Free Reply to Response to Motion - District Court of Arizona - Arizona

Declaration of Richard J. Harris
Richard J. Harris, under penalty of perjury testifies as follows:
l. This declaration is supplemental to the declaration already on tile with the court in
connection with Matt Shaffer’s Attorney’s Fees petition.
2. Attached hereto is a summary of the time spent in researching and drafting the reply brief
filed herewith. The records were made in accordance with the practice as described in the
declaration I provided in Plaintiff s initial brief in support ofthe award of attorneys fees and
expenses.
3. In working on the reply brief, the undersigned expended 43 hours.
4. The hours for which compensation is sought, and fees related to those hours, were reasonable
and necessary under the circumstances of this case. At issue is over a quarter of a million
dollars in attomeys fees and the time spent to preserve the right to such a large sum were
reasonable.
5. My current hourly rate for straight contingency fee matters is $400.00.
Executed this May 5, 2006 ;
Richard J. Harris
l
Case 2:03-cv—02344-FJIVI Document 171 -2 Filed 05/05/2006 Page 1 of 2

Richard J. Harris Law Offices, P.C. Invoice
4445 E. Holmes Ave., Ste 106 ees·e ——·—~————-~—~····—~~·~·
Mesa AZ 85206 DATE I INVOICE NO,
5/5/2006
F"_ ;"'“`“ ““
I BILL TO I
I Shaffer, l\/latt I
*5825 E, Rosewood St.
Tucson, AZ 8571 1—1532
TERMS DUE DATE
Due on receipt 5/5/2006
SERvIcED I DESCRIPTION HOURS AIvIouI~IT
4/18/2006 Research status of response brief on attorney's fees, ww W 0,1 29,00
4/24/2006 Receive and review response brief on attorney's fees application; begin researching 2,5 725.00
erroneous citations by Jay Zweig,
4/25/2006 Begin outlining response on attorney's fees request. 6,5 1,885,00
I4/26/2006 Work on attorney's fees reply memorandum 1,2 348,00
I4/27/2006 Work on attorneys fees matters; research liberty interest damage elements per law of the 2.1 609.00
I case; call with client,
14/28/2006 Research and brief the attorney‘s fees reply brief. 6,2 1,798,00
5/1/2006 Work on attorney's fees and costs reply brief; research time for reply to be tiled, 6.2 1,798.00
5/2/2006 Work on attorneys‘ fees reply brief 7.8 2,262,00
5/3/2006 Research cases cited by Zweig; work on reply to motion for attorneys fees; e—mail to l\/latt I 8.6 2,494,00
Shaffer for comment. I
5/5/2006 Finalize brief; draft declaration for fees on reply (with exhibit of time records) I 1,8 522,00
I
I I
Ew.IE_.,EEm_E_m...-
Total $12,470,00
Case 2:03-cv—02344-FJIVI Document 171 -2 Filed 05/05/2006 Page 2 of 2

Case 2:03-cv-02344-FJM

Document 171-2

Filed 05/05/2006

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Case 2:03-cv-02344-FJM

Document 171-2

Filed 05/05/2006

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