District Court, affidavit of Sam Jones

The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. NO. LR-C-82-~. 1 ~ l-'f (:1 ~en n PULASKI COUNTY SPECIAL SCHOOL ':::..~~f ~/~ti, DISTRICT NO. 1, ET AL. r;;;_,~_;. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. AFFIDAVIT OF SAM JONES 1996 PLAINTIFF DEFENDANTS INTERVENORS My name is Sam Jones and I represent the Pulaski county Special School District in this litigation and have done so since its inception. Attached as Exhibit A are the billing records representing time reasonably expended in pursuit of these claims against the State beginning April 28, 1994 and continuing through November 27, 1996. I have supervised the process of removing time entries which did not relate to these claims and have reviewed the resultant narratives for accuracy. It is my professional belief that the narratives submitted as Exhibit A reasonably reflect time actually spent and devoted toward the prosecution of these claims against the State. Exhibit B represents the total hours expended during this timeframe by each timekeeper. The individual totals are derived from adding the time spent each month as reflected at the end of each individual statement. Because of the financial circumstances of the PCSSD, we have represented thea in this matter at reduced hourly rates. My standard rate for clients during 1996 was $175. 00 per hour. However, during 1996, I have represented the PCSSD in this matter for $135.00 per hour. I have been a partner since January 1, 1981. Claire Shows Hancock has been a licensed attorney practicing primarily in New York City where her last standard hourly rate was $245.00 per hour. Her normal hourly rate in Little Rock is now $145.00 an hour. She too has represented the PCSSD in this matter at the reduced hourly rate of $110.00 an hour. Angell Jones is the Manager of our Litigation Support Department. That department evolved because of the instant case and several other complex cases involving the creation of databases - and the management and retrieval of hundreds of thousands of documents and pleadings. Her hourly rate during 1996 has been $75.00 an hour and that is her normal hourly rate. Valerie Bryant is a paralegal in the Litigation Support Department. She is primarily charged with maintaining this litigation database as well as with the management of the hundreds of thousands of documents that this case involves. Her normal hourly rate is $55.00 an hour and that is what she was paid by the PCSSD during 1996. However, prior to that her hourly rate for the PCSSD was $40.00 an hour. Denise Compton was a paralegal in the Litigation Support Department. She was replaced by Valerie Bryant and her duties were similar. Ms. Compton's hourly rate was $55. 00. Similarly, 2 Jennifer Thompson was the precursor to Ms. Compton. Ms. Thompson's hourly rate was $55.00. The remaining timekeepers are document clerks within the Litigation Support Department. Their principal function is to update the database and to chronicle and organize the documents and pleadings as they are received. They have been paid their normal. hourly rates which are: Leta Hudson $25.00; Joanne Sorn $25.00; M.A. Gocke $25.00; and A. Haguewood $25.00. I respectfully submit that a total fee award of hours multiplied by standard 1996 rates would be appropriate in this matter. STATE OF ARKANSAS COUNTY OF PULASKI SUBSCRIBED AND SWORN TO before me, a notary public, this ~l day ofDe<..r..,rtlJ.k-:, 199,. ~ / / <)G-z-~ r11- Ki?::'"'--~ My Commission Expires: ~ ? :i :;:c 00 C:-- 1 Notary Public U 3 Respectfully submitted: WRIGHT, LINDSEY JENNINGS 200 West Capitol Avenue suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 By _ _fL.~~~'.'.::::::::;/::::.!-;._=-----M. Att Spe I (76060) Pulaski County District CERTIFICATE OF SERVICE On December ,)._' 1996, a copy of the foregoing was served by U.S. mail on the following persons of record:. Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg., Ste. 510 201 East Markham street Little Rock, Arkansas 72201 4 Mr. Richard w. Roachell Roachell and street First Federal Plaza 410 w. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 II Dr. Don Stewart WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 June 16, 1994 Pulaski County Special School Distri Invoice I 93261 Post Office Box 8601 Client Number 005406 Little Rock, AR 72216 Matter Number 035919 Re: Little Rock School District v. FOR PROFESSIONAL SERVICES RENDERED THROUGH 02/28/95: Date Timekeeper Hours 04/28/94 04/28/94 ~/28/94 -/28/94 05/09/94 05/10/94 05/11/94 05/24/96 05/24/94 05/24/94 05/25/94 A. Jones A. Jones S. Jones s. Jones s. Jones S. Jones S. Jones s. Jones S. Jones s. Jones s. Jones TIMEKEEPER TIME SUMMARY: Timekeeper MS Jones, III .Jones Confer with Dr. Stewart regarding hearing Confer with Mr. Jones regarding hearing Telephone conference with Chris Heller Monitor hearing in Chancery Court regarding school funding Review correspondence from Robbie Keopple, President of Pulaski Association of Classroom Teachers Review order scheduling July hearings Review Gene Wilhoit deposition Telephone conference with Chris Heller and Elizabeth Boyter Telephone conference with Don Stewart regarding workers' compensation issue Telephone conference with Don Stewart and Chris Heller Telephone conference with Mr. Lester 0.2 0.2 0.2 1.2 0.1 0.1 0.5 0.3 0.2 0.2 0.2 Total For Services TOTAL THIS STATEMENT $352.00 $352.00 Hours 3.0 at .4 at Rate $110 = $55 = Value 330.00 22.00 I EXHIBIT Mr. Don Stewart WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 Pulaski County Special School Distri Post Office Box 8601 Invoice Number Invoice Date Client Number North Little Rock, AR 72216 Matter Number Re: Little Rock School District v. FOR PROFESSIONAL SERVICES RENDERED THROUGH 10/31/94: 1378 12/06/94 005406 014007 Date Timekeeper Hours 07/06/94 07/07/94 07/07/94 07/07/94 07/15/94 - /15/94 07/18/94 07/21/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 07/25/94 e, /25/94 MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant Telephone conference with Steve Jones regarding workers' compensation and MFPA Telephone conference with Mr. Lester Telephone conference with Mr. Heller Telephone conference with Mr. Lester Review joint motion to enforce settlement agreement Telephone conference with Barry in Judge Wright's office. Review Brief in Support of Joint Motion to Enforce Settlement Agreement regarding Joshua/Knight Review correspondence from Mr. Walker Rescheduling settlement agreement meeting to 8/4/94. Telephone conference with Mr. Heller and Dr. Stewart. Prepare Special language for subpoena duces tecum. Telephone conference with Elizabeth Boyter Telephone conference with Don Stewart Telephone conference with Dr. Stewart regarding various issues. Telephone conference with Dr. Stewart Telephone conference with Chris Heller Telephone conference with Mr. Heller and Mr. Humphries Telephone conference with Mr. Heller and Ms. B'oyter Prepare memorandum to Angell Jones regarding review of PCSSD materials Prepare motion and brief regarding 0.3 0.2 0.2 0.2 0.1 0.2 0.1 0.1 0.4 0.4 0.2 0.3 0.3 0.2 0.2 0.2 0.2 0.2 0.1 ./26/94 07/26/94 07/26/94 07/26/94 07/26/94 07/26/94 07/26/94 07/26/94 07/27/94 07/27/94 07/27/94 07/27/94 07/27/94 07/27/94 07/27/94 07/27/94 M/28/94 -/28/94 07/28/94 07/28/94 07/28/94 07/28/94 07/29/94 07/29/94 07/29/94 07/29/94 08/19/94 08/19/94 08/19/94 08/19/94 08/19/94 08/22/94 08/22/94 08/22/94 ./23/94 MS Jones, III MS Jones, III MS Jones, III A Jones A Jones A Jones MS Jones, III V Bryant MS Jones, III MS Jones, III MS Jones, III V Bryant A Jones MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant A Jones A Jones MS Jones, III MS Jones, III MS Jones, III MS Jones, III A Jones MS Jones, III MS Jones, III A Jones A Jones MS Jones, III MS Jones, III MS Jones, III A Jones settlement agreement for attorney review Telephone conference with Dr. Stewart and Mr. Heller to prepare for hearing Prepare response to joint motion Telephone conference with Chris Heller regarding reply to state position Telephone conference with Charlotte at PCSSD Confer with Valerie Bryant regarding hearing preparation Prepare for hearing Review correspondence from ADE with response to the LRSD and Joshua intervenors joint motion to enforce settlement agreement Confer with Angell Jones regarding hearing preparation Telephone conference with Don Stewart and Bobby Lester Telephone conference with Mr. Heller Prepare for hearing Hearing preparation Organize materials for hearing Telephone conference with Don Stewart Telephone conference with Mr. Heller Review Invoice from PST&T for special service on Gene Wilhoit Hearing in federal court Review ADE amended response to the LRSD and the Jushua intervenors' joint motion to enforce settlement agreement Update docket via Pacer Prepare documents for hearing Attend hearing in Federal Court Prepare for hearing Hearing in federal court Confer with Mr. Miller, Mr. Lester and Dr. Stewart Telephone conference with Mr. Lester Telephone conference with Jerry Malone and Dr. Don Stewart Organize materials for Sam Jones for developing brief on loss funding formula Telephone conference with Don Stewart Work on motion for loss funding Confer with Sam Jones regarding Brief Confer with Sam Jones regarding Exhibits to Brief Work on motion and brief regarding loss funding Telephone Telephone Telephone regarding conference with Don Stewart conference with Dr. Stewart conference with Sam Jones depositions 1.0 0.3 0.6 0.2 0.8 0.8 0.1 0.8 0.3 0.2 1.3 2.8 0.3 0.2 0.2 0.1 6.8 0.1 0.5 0.4 1.9 0.5 2.2 1.0 0.4 0.2 1.9 0.2 1.4 0.2 0.2 1.6 0.2 0.3 0.2 08/23/94 - /23/94 08/23/94 08/23/94 08/23/94 08/23/94 08/23/94 08/23/94 08/23/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 - /24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/24/94 08/25/94 08/25/94 08/25/94 - /25/94 A Jones A Jones A Jones A Jones A Jones MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant B Benjamin MS Jones, III MS Jones, III MS Jones, III MS Jones, III A Jones A Jones A Jones A Jones V Bryant V Bryant V Bryant V Bryant Confer with Valerie Bryant regarding service copies of brief Telephone conference with Chris Heller with Sam Jones regarding brief and motions Telephone conference with Dr. Stewart with Sam Jones regarding loss funding Telephone conference with Valerie Bryant regarding brief Review correspondence regarding depositions of ADE Employees Telephone conference with Mr. Heller Telephone conference with Mr. Heller Telephone conference with Mr. Heller and Jay Charles Telephone conference with Mr. Heller Telephone conference with Sam Jones and Mr. Heller regarding preparation for hearing and depositions Telephone conference with Sam Jones and Dr. Stewart regarding preparation for hearing and depositions Confer with Angell Jones regarding preparation for hearing Preparation for deposition of Robert Shaver Attend deposition of of Robert Shaver Preparation for depositions to be continued on August 26 and for September 12 hearing Confer with Angell Jones regarding cancellation of depositions Westlaw Computer Act Telephone conference with Mr. Heller and Valarie Bryant to prepare for hearing Telephone conference with Dr. Stewart and Valarie Bryant regarding exhibits for hearing Prepare for Shaver deposition Deposition of Robert Shaver Confer with Valerie Bryant Confer with Valerie Bryant Assist Valerie Bryant regarding subpoenas for hearing, FOI request, legislation Telephone conference with Berniece Benjamin regarding Act 1034 and Act 668 - twice Work on FOI request to Impac Learning Services Prepare project outline for hearing Prepare for September 12 hearing Telephone conference with Berniece Benjamin regarding Worker's Compensation 0.3 0.3 0.2 0.3 0.2 0.3 0.2 0.2 0.2 0.8 0.3 0.3 0.3 2.5 0.5 0.2 0.2 0.5 0.4 0.8 3.3 0.3 0.4 0.3 0.3 1. 3 1.3 1.8 0.2 -/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/25/94 08/26/94 08/26/94 08/26/94 08/26/94 -/26/94 08/26/94 08/26/94 08/26/94 08/26/94 08/26/94 08/26/94 08/26/94 08/29/94 08/29/94 08/29/94 08/29/94 08/29/94 08/29/94 08/30/94 08/30/94 - /30/94 V Bryant V Bryant V Bryant A Haguewood MS Jones, III MS Jones, III MS Jones, III MS Jones, III A Jones A Jones A Jones A Jones L Hudson B Benjamin B Benjamin V Bryant V Bryant V Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III Legislation Telephone conference with John Walker's office confirming depositions Confer with Angell Jones regarding depositions scheduled for August 26th Prepare for depositions scheduled for August 26th RFP document production Prepare for deposition Deposition of Weiss and Shaver Telephone conference with Mr. Walker regarding COE Telephone conference with Mr. Lester Confer with Valerie Bryant Prepare for depositions Work on FOI Request for Impac Learning Center Confer hearing Prepare labels with Valerie Bryant preparation computer-generated regarding subfile Research Lexis re: Workers' Compensation coverage Research Westlaw re: Workers' Compensation coverage Attend deposition of Richard Weiss Prepare for depositions of Richard Weiss and Robert Shaver Confer with Angell Jones regarding depositions Organize exhibits to Richard Weiss' depositions Telephone conference with Ann Brown Telephone conference with Mr. Lester Telephone conference with Dr. Stewart Telephone conference with Dr. Stewart continue work on Loss Findings motion Telephone conference with Chris Heller Telephone conference with John Walker Telephone conference with Ray Scott Confer with Valerie Bryant Telephone conference with John Walker's office verifying schedule for depositions Confer with Sam Jones regarding issuance of subpoenas for hearing Telephone conference with Sam Jones and Ray Scott of Impac Learning Systems regarding FOI request Telephone conference with Chris Heller and Steve Jones Telephone conference with Mr. Walker settlement conference at John Walker's office 0.2 0.2 1.0 0.3 0.5 3.1 0.2 0.2 0.2 0.3 0.3 0.3 0.6 0.3 0.2 1.8 0.3 0.2 0.2 0.3 0.2 0.2 0.2 2.6 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.3 0.2 3.2 08/30/94 -/30/94 08/30/94 08/31/94 08/31/94 08/31/94 08/31/94 08/31/94 08/31/94 08/31/94 09/01/94 09/01/94 09/01/94 09/01/94 09/01/94 09/02/94 09/05/94 -/05/94 ~/06/94 09/06/94 09/06/94 09/06/94 09/06/94 09/06/94 09/06/94 09/07/94 09/09/94 09/09/94 09/09/94 09/09/94 09/10/94 09/12/94 09/12/94 -/12/94 V Bryant V Bryant JD Thompson V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant MS Jones, III A Jones V Bryant MA Gocke MS Jones, III MS Jones, III MS Jones, III MS Jones, III L Hudson A Jones V Bryant V Bryant V Bryant MS Jones, III V Bryant MS Jones, III MS Jones, III MS Jones, III Prepare fax transmittal to Mr. Bowles regarding settlement conference Work on issuance of subpoenas and witness check for September 12 hearing Assist with preparation of subpoenas Preparation for hearing scheduled for September 12 Telephone conference with Ray Scott Telephone conference with Tim Humphries Telephone conference with John Walker Review records at computer center Work on stipulation for friday hearing Telephone conference with Mr. Walker Prepare documents from APSCN office for attorney review Update docket via Pacer Work on filing of subpoenas with Court Telephone conference with clerk regarding exhibits to July budget hearing Review correspondence and pleadings and transmit copies to the school district Review correspondence and pleadings and prepare for attorney review and for transmittal to district Work on exhibits for September 12 hearings Assist with hearing preparation Prepare witness list and exhibits for submission to parties Prepare Exhibits for Hearing Telephone conference with Mr. Lester regarding hearing Telephone conference with Don Telephone conference with Don Telephone conference with Don Generate document production address label,s Stewart Stewart Stewart labels and Review and organize file materials Telephone conference with Sam Jones regarding notification of hearing date to subpoenaed witnesses Notify subpoenaed witnesses of scheduled hearing date Confer with Susan Franks regarding Robert Shaver's deposition Telephone conference with Chris Heller and Dale Hanson Notify subpoenaed witnesses of scheduled hearing date Telephone conference with Dr. Stewart Telephone conference with Dr. Stewart and Mr. Bryant Confer with Ms. Bryant 0.2 3.5 1.3 0.8 0.2 0.2 0.2 3.4 0.7 0.2 1.8 0.5 0.3 0.2 0.8 0.8 0.5 0.8 3.5 1.2 0.2 0.2 0.2 0.3 0.4 0.3 0.2 0.3 0.2 0.3 0.2 0.2 0.2 0.2 09/12/94 -/12/94 09/12/94 09/12/94 09/12/94 09/12/94 09/12/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 -/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/13/94 09/14/94 09/14/94 09/14/94 09/14/94 09/14/94 09/15/94 09/15/94 09/15/94 /15/94 /15/94 MS Jones, III V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant V Bryant v Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant Confer with Ms. Bryant regarding ASCPN documents Telephone conference with APSCN office regarding additional information to FOI request Telephone conference with Sam Jones regarding follow-up to FOI request to APSCN Telephone conference with Dr. Stewart and Sam Jones regarding witness and exhibit lists for hearing Telephone conference with Walter Smiley's office regarding hearing Prepare exhibits for attorney review Transmit ADE's response to joint motion to Dr. Stewart Preparation for hearing Telephone conference with Stephanie Branton, court reporter regarding depositions of Weiss and Shaver Telephone conference with Ms. Horner from Walter Smiley's office regarding hearing Telephone conference with subpoenaed witnesses regarding hearing Telephone conference with Don Stewart Telephone conference with Mr. Heller and Dr. Stewart Telephone conference with John Walker and Chris Heller Telephone conference with Mr. Walker, Chris Heller, and Ann Brown Confer with Valerie Bryant Telephone conference with Mr. Humphries regarding computer issues Preparations for hearing Telephone conference with Sharon Street Telephone conference with Don Stewart continue preparation for hearing Confer with Mr. Heller, Ms. STreet, and Mr. Walker continue hearing preparations at home Preparation for hearing Attend hearing on Motions to Enforce Settlement Agreement Telephone conference with Sam Jones regarding IMPAC Learning Systems correspondence from John Walker Hearing in Federal Court Hearing in Federal court Prepare for third day of hearings correspondence from John Walker correspondence from John Walker Prepare memorandum to Sam Jones 0.2 0.3 0.2 0.3 0.2 0.2 0.2 3.8 0.2 0.3 0.3 0.3 0.2 0.3 0.3 0.2 0.5 1.3 0.2 0.2 1.6 1.2 2.7 0.8 6.5 0.2 0.1 6.9 7.9 0.8 0.1 0.1 0.3 - /15/94 09/15/94 09/15/94 09/15/94 09/16/94 09/16/94 09/20/94 09/20/94 09/20/94 09/21/94 09/21/94 09/21/94 09/21/94 09/22/94 09/28/94 09/28/94 - /28/94 09/29/94 09/29/94 09/29/94 09/30/94 09/30/94 09/30/94 09/30/94 10/03/94 10/03/94 10/03/94 10/03/94 10/03/94 10/03/94 10/03/94 10/04/94 10/04/94 10/04/94 - /04/94 V Bryant V Bryant V Bryant A Haguewood MS Jones, III MS Jones, III MS Jones, III V Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III V Bryant MS Jones, III MS Jones, III V Bryant V Bryant MS Jones, III V Bryant V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III V Bryant MS Jones, III MS Jones, III MS Jones, III MS Jones, III regarding Impac Learning Systems and Walter Smiley Telephone conference with Walter Smiley's office regarding hearing Telephone conference with Berniece Benjamin regarding computer research on Impac Learning Systems Telephone conference with Secretary of State's office regarding Impac Learning systems Preparation for hearing Prepare for third day of hearings Hearing in Federal Court Review Charts regarding wee for Stewart Preparation for hearing on September 21st Telephone conference with Court regarding time for hearing Final preparation of resumption of hearing hearing in Federal Court Confer with Mr. Allen and Dr. Stewart Preparation for hearing Correspondence from USDC Clerk with Certificates Prepare memo to Ms. Bryant. Confer with Sam Jones regarding witness checks Confer with Sam Jones regarding brief deadlines Confer with Ms. Bryant. Preparation for loss funding and computer brief Prepare letters to Julie Rhodes, Gene Wilhoit and Richard Nagel Work on post hearing brief regarding funding issue. Telephone conference with Don Stewart. Telephone conference with Steve Jones. Review correspondence from Gene Wilhoit. Review correspondence from Sheila Freeman. Telephone conference with Chris Heller. Telephone conference with Mark Burnett. Work on post hearing brief. Telephone conference with Chris Heller. Telephone conference with Chris Heller. Confer with Sam Jones regarding brief Review State and ADE's Post-Hearing Brief. Review LRSD, PCSSD and Joshua Intervenors Joint Post-Hearing Brief. Review final brief. Telephone conference with Mr. Heller. 0.2 0.2 0.3 1.0 1.3 5.3 0.1 0.8 0.2 0.5 6.5 0.5 1. 3 0.1 0.2 0.2 0.2 0.2 0.3 0.4 4.3 0.2 0.3 0.1 0.1 0.3 0.2 0.5 0.2 0.2 0.2 0.2 0.1 0.3 0.3 10/04/94 MS Jones, III ~ /04/94 MS Jones, III /05/94 MS Jones, III /07/94 MS Jones, III 10/07/94 MS Jones, III 10/10/94 MS Jones, III 10/10/94 MS Jones, III 10/11/94 MS Jones, III 10/28/94 MS Jones, III TIMEKEEPER TIME SUMMARY: Timekeeper ------------------------- MS Jones, III B Benjamin V Bryant A Jones Thompson Gocke A Haguewood L Hudson Review ADE brief. Telephone conference with Chris Heller. Telephone conference with Steve Jones. Telephone conference with Mr. Lester. Telephone conference with Don Stewart. Telephone conference with Steve Jones. Review correspondence from John Walker. Telephone conference with Chris Heller. Review post-hearing memorandum of NLR District regarding ADE funding issues. Review correspondence from Rick regarding witness check. Hours Rate -------------------- 96.6 at $110 0.7 at $40 50.2 at $45 11.8 at $55 1.3 at $45 1.2 at $25 1.3 at $25 1.0 at $20 = = = = = = = = TOTAL HOURS Value 10,626.00 28.00 2,259.00 649.00 58.50 30.00 32.50 20.00 Nagel CURRENT FEES $ 0.3 0.4 0.3 0.2 0.2 0.1 0.2 0.1 0.1 ----- 164.1 13,703.00 WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 Dr. Don Stewart Pulaski County Special School Distri Post Office Box 8601 Little Rock, AR 72216 Re: Little Rock School District V. Invoice Number Invoice Date Client Number Matter Number FOR PROFESSIONAL SERVICES RENDERED THROUGH 02/28/95: 4474 03/27/95 005406 014007 Date Timekeeper Hours 01/12/95 01/13/95 01/13/95 01/17/95 ~ /17/95 Wi11a/95 01/19/95 01/19/95 01/25/95 01/25/95 01/25/95 01/25/95 01/25/95 01/25/95 01/25/95 01/26/95 01/27/95 01/27/95 01/30/95 01/31/95 01/31/95 02/13/95 02/15/95 .;. /15/95 . /17/95 MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III JD Thompson Telephone conference with Mr. Palnick Telephone conference with Mr. Heller Telephone conference with Mr. Heller regarding Order Telephone conference with Don Stewart Telephone conference with Mr. Bowles Confer with Mr. Spivey regarding majority to minority issues Telephone conference with Mr. Lester Review Minority to Majority stipulation Telephone conference with Mr. Heller Telephone conference with Chris Heller and Steve Jones Telephone conference with Chris Heller Telephone conference with Chris Heller and Tim Humphries Telephone conference with Don Stewart Telephone conference with Mr. Heller Telephone conference with Mr. Heller and Mr. Walker Telephone conference with Mr. Heller Telephone conference with Mr. Lester Telephone conference with Mr. Heller and Mr. Jones Telephone conference with Chris Heller Telephone conference with Don Stewart Review motion to extend time and notice of filing by LRSD Review ADE notice of appeal Telephone conference with Chris Heller Review USDC notice of appeal Confer with Valerie Bryant regarding 0.2 0.2 0.3 0.3 0.3 0.4 0.2 0.2 0.2 0.6 0.2 0.3 0.2 0.2 0.2 0.2 0.4 0.5 0.2 0.2 0.1 0.1 0.3 0.1 0.2 -/17 /95 JD Thompson 02/17/95 V Bryant 02/17/95 V Bryant 02/17/95 V Bryant 02/17/95 L Hudson 02/17/95 MS Jones, III 02/17/95 MS Jones, III 02/17/95 MS Jones, III 02/20/95 MS Jones, III 02/20/95 MS Jones, III 02/20/95 MS Jones, III 02/21/95 MS Jones, III 02/21/95 MS Jones, III TIMEKEEPER TIME SUMMARY: Timekeeper MS Jones, III V Bryant JD Thompson L Hudson computer search for documents pertaining to state Aid Computer search of documents regarding State Aid to PCSSD Telephone conference with Sam Jones regarding documents needed for preparation of brief Confer with Jennifer Thompson regarding documentation regarding state aid Organize documents in preparation for brief for attorney review Organize pleadings for attorney review Work on response to State's motion for stay Telephone conference with Chris Heller Telephone conference with Valerie Bryant regarding documents needed for preparation of brief Review State of Arkansas' letter regarding appendix for appeal Review and revise response to stay Telephone conference with Mr. Heller Telephone conference with Mark Pryor school funding Telephone conference Hours Rate -------------------- 10.5 at $135 1.2 at $45 3.2 at $55 2.6 at $25 with Mr. Heller TOTAL HOURS = = = = Value 1,417.50 54.00 176.00 65.00 -re CURRENT FEES $ 2 3.0 0.2 0.2 0.8 2.6 2.6 0.5 0.2 0.1 0.4 0.2 0.2 0.2 ----- 17.5 1,712.50 WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 Dr. Don Stewart Pulaski County Special School Distri Post Office Box 8601 Little Rock, AR 72216 Re: Claim for attorney's fees Invoice Number Invoice Date Client Number Matter Number FOR PROFESSIONAL SERVICES RENDERED THROUGH 02/28/95: 4476 03/27/95 005406 035919 Date Timekeeper Hours 01/25/95 01/26/95 . /26/95 01/27/95 01/30/95 01/30/95 02/01/95 02/06/95 02/07/95 02/08/95 02/08/95 02/09/95 02/13/95 02/15/95 MS Jones, III JD Thompson JD Thompson JD Thompson JD Thompson JD Thompson JD Thompson MS Jones, III JD Thompson JD Thompson JD Thompson JD Thompson JD Thompson JD Thompson Confer with Jennifer Thompson re fee petition Confer with Sam Jones regarding fee petition Organize accounting records regarding time spent on loss funding, computers, and workers compensation Work on calculations for fee petition Prepare accounting of all time spent on loss funding, APSCN and workers' comp. Prepare accounting narrative for fee petition Work on narrative Review order regarding extension to file for attorney fees Work on narrative for fee petition Work on narrative for fee petition Prepare memorandum to file regarding status of narrative Review and revise narrative Review and revise narrative Finalize narrative for fee petition 0.2 0.3 4.4 3.9 1.2 1.7 2.4 0.1 2.1 0.8 0.2 0.3 0.9 0.6 5406 35919 /27/95 Pulaski County Special School District Claim for attorney's fees TIMEKEEPER TIME SUMMARY: Timekeeper MS Jones, III JD Thompson Hours 0.3 18.8 CURRENT FEES at at Rate $135 = $55 = Invoice Number Page 2 TOTAL HOURS Value 40.50 1,034.00 $ 4476 19.1 1,074.50 WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 Mr. Don Stewart Invoice Number Invoice Date Client Number Matter Number 5451 04/26/95 005406 014007 Pulaski County Special School Distri Post Office Box 8601 Little Rock, AR 72216 Re: Little Rock School District V. FOR PROFESSIONAL SERVICES RENDERED THROUGH 03/31/95: Date Timekeeper -------- ---------- 03/01/95 MS Jones, III 03/03/95 MS Jones, III 03/06/95 - /10/95 JD Thompson MS Jones, III /10/95 MS Jones, III 03/13/95 MS Jones, III 03/20/95 MS Jones, III 03/22/95 MS Jones, III TIMEKEEPER TIME SUMMARY: Timekeeper MS Jones, III JD Thompson Hours Review reply brief on motion for stay 0.1 Review Court of Appeals docketing 0.1 Docket ADE Appeal 0.4 Telephone conference with Chris Heller 0.6 Review ADE's appeals filings 0.1 Telephone conference with Chris Heller 0.6 Review Joshua's Eighth Circuit filings 0.1 Confer with Mr. Spivey regarding M-to-M 0.2 issues Hours 1.8 4 at at Rate $135 = $55 = TOTAL HOURS Value 243.00 22.00 2.2 CURRENT FEES $ 265.00 WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 Mr. Don Stewart Pulaski County Special School Distri Post Office Box 8601 Little Rock, AR 72216 Re: Little Rock School District v. Invoice Number Invoice Date Client Number Matter Number FOR PROFESSIONAL SERVICES RENDERED THROUGH 05/31/95: 6743 06/14/95 005406 014007 Date Timekeeper Hours 04/03/95 04/05/95 .4/10/95 04/12/95 04/12/95 04/12/95 04/13/95 04/13/95 04/13/95 04/13/95 04/13/95 04/17/95 04/19/95 04/19/95 04/20/95 04/26/95 04/26/95 JIM/26/95 W4/26/95 MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III JD Thompson MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III Review Dr. Stewart's letter regarding payment by ADE pursuant to court order Review State and ADE's motion for stay pending appeal Telephone conference with Clerk, Court of Appeals Telephone conference with Mr. Gauger Confer with Steve Jones Work on response to State stay request to court of appeals Review and revise response to stay motion Telephone conference with Chris Heller Telephone conference with John Walker Review State's request for extension to file brief Legal research regarding 1991 Appeal in preparation for Response to Motion to Stay Pending Appeal Review ADE's calculations pursuant to Court's 1/13/95 ruling Review court's order granting appellant extension to file brief Telephone conference with Steve Jones Prepare correspondence to Mr. Heller Telephone conference with Mr. Lester and Dr. Stewart regarding State calculations Telephone conference with Ms. Boyter Telephone conference with Mr. Lester Telephone conference with Dr. Stewart 0.1 0.1 0.2 0.2 0.3 2.9 0.7 0.2 0.2 0.1 0.9 0.1 0.1 0.2 0.2 0.3 0.2 0.2 0.2 04/26/95 . /28/95 05/08/95 05/08/95 05/08/95 05/09/95 MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III MS Jones, III TIMEKEEPER TIME SUMMARY: Timekeeper MS Jones, III JD Thompson Prepare correspondence to Mr. Gauger Telephone conference with Bobby Lester and Dr. Stewart Preliminary review of state's opening brief Work on response to State's brief Telephone conference with Billy Bowles Telephone conference with Sandi in Judge Wright's office Hours 8.2 .9 at at Rate $135 = $55 = TOTAL HOURS Value 1,107.00 49.50 CURRENT FEES $ 0.2 0.2 0.1 0.8 0.2 0.2 9.1 1,156.50 WRIGHT, LINDSEY, JENNINGS 200 West Capitol Avenue, Suite 2200 Little Rock, Arkans~s 72201-3699 (501) 371-0808 Mr. Don Stewart Pulaski County Special School Distri Post Office Box 8601 Little Rock, AR 72216 Re: Claim for attorney's fees Invoice Number Invoice Date Client Number Matter Number FOR PROFESSIONAL SERVICES RENDERED THROUGH 05/31/95: 6748 06/14