MEDINA v. DC GOVERNMENT, No. 1:1997cv00594 - Document 182 (D.D.C. 2012)

Court Description: MEMORANDUM AND OPINION re 173 . Signed by Magistrate Judge John M. Facciola on 4/23/12. (Attachments: # 1 Exhibit Excel Spreadsheet) (SP, )

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Medina v. DC 97-594 Attachment A 12/1/1994 Total Total Sought Awarded Hours Rate Task Met with Medina for at least 2 hours. He had received a letter or determination in his favor from the Office of Human Rights. 2 495 990 990 He needed representation since he was scheduled to attend a mediation session at DCHR. 0 0 0 0 I reviewed his Letter of Determination 1 495 495 495 Mediation occurred at DCHR on this date 0 0 0 0 Reviewed file from 8:30 to 9:30. 0 0 0 0 Attended Mediation from 9:30 to 11:30 2 495 990 990 Notes Reflect 2 meetings with Medina prior to this date. 2 495 990 990 Draft First Retainer Agreement. 1 495 495 495 Follow up call with Medina. He was concerned about the hourly rate. He wanted Contingency Agreement 0.5 495 247.5 247.5 12/13/1994 12/21/1994 12/21/1994 Drafted a second retainer agreement that called for %25 retainer, offset by whatever amount we receive by Court Order Medina agreed to this. Discussed settlement with Peacock Drafted letter to Medina re discussions with Peacock. Date Oct-94 Oct-94 Oct-94 11/21/1994 11/21/1994 11/21/1994 11/21/1994 12/1/1994 2/15/1995 2/15/1995 2/16/1995 3/15/1995 3/16/1995 4/17/1995 9/19/1995 Had a telephone conversation with client regarding settlement. Agreed to convey demand to settle for $165,000.00; that letter to Peacock. Peacock called later in the day to advise that the demand letter had been improperly captioned; we issued retraction. We issued a retraction by facsimile. MPD did not respond to our settlement demand. I had discussion with the client about what could be done to advance the matter. Did some research and contacted the Office of Human Rights and learned that I could request a Summary Determination. Drafted letter, after reviewing the regulation to DCHR Seeking Summary Determination. Letter from HVM to DCHR re status. 1 1 0.5 0.5 495 495 495 495 247.5 247.5 495 247.5 247.5 1.5 495 742.5 742.5 0.25 0.25 0 495 495 0 123.75 123.75 0 123.75 123.75 0 1 495 495 495 1.5 495 742.5 742.5 1.5 0.5 495 495 742.5 247.5 742.5 247.5 Medina v. DC 97-594 Attachment A 9/21/1995 Received and reviewed Summary Determination from DCHR, called client and conveyed news. 1.5 495 742.5 742.5 1.5 495 742.5 742.5 3 0.5 1 495 495 495 1485 247.5 495 1485 247.5 495 1.5 0.5 0.5 1.5 0.5 1.5 1.5 495 495 495 495 495 495 495 742.5 247.5 247.5 742.5 247.5 742.5 742.5 742.5 247.5 24.75 742.5 247.5 742.5 742.5 Received, reviewed no probable cause finding and discussed with client Research regarding Garzon issue, letter to Rogers. Received, Reviewed letter from Rogers discussed with client. Decided to pursue litigation Received letter, reviewed from Draper. Drafted initial complaint. Reviewed draft, sent to client. Reviewed and filed complaint. 1.5 3 495 495 742.5 1485 742.5 1485 1.5 0.5 3 2 1.5 495 495 495 495 495 742.5 247.5 1485 990 742.5 742.5 247.5 1485 990 742.5 Received and reviewed Green Card regarding service, filed proof of service. Received and reviewed order dated 4/23/97. Called Phillip Lattimore to try to determine who was assigned to the case. He did [sic] know. Drafted, reviewed status. Attended status conference with Judge Sullivan, court suspended discovery and set briefing schedule 0.25 0.25 495 495 123.75 123.75 123.75 123.75 0.25 0.5 495 495 123.75 247.5 123.75 247.5 2.5 495 1237.5 1237.5 10/13/1995 11/28/1995 11/28/1995 Soulsby appealed Summary determination reviewed and discussed with client. Wilmore, on behalf of MPD, appealed the Summary Determination, reviewed and discussed. Researched. I recall that it was late. Call to the DCHR regarding status. Discussion with Medina regarding status of DOJ Complaint 1/18/1996 1/18/1996 2/4/1996 2/29/1996 3/4/1996 5/22/1996 9/11/1996 Reviewed Wilmore's Appeal, researched the regulations and determined that it was untimely, wrote letter to DCHR seeking dismissal of Appeal as untimely. Discussed with client. Discussion with Lake, who said that Mayor's office was handling Letter to Mayor and Letter to City Administrator regarding status. Medina called regarding officers not being allowed to speak Spanish. McKnight to Rogers regarding status of appeal/review of file. McKnight to Rogers, regarding status/review of file. 10/11/1995 1/27/1997 2/11/1997 3/6/1997 3/6/1997 3/10/1997 3/11/1997 3/26/1997 4/7/1997 4/25/1997 4/28/1997 5/1/1997 5/2/1997 2 Medina v. DC 97-594 Attachment A 5/5/1997 6/3/1997 Received and reviewed Defendant's Answer to Complaint. Filed Supplement/reviewed file. Drafted and filed Motion for Extension, unsuccessfully tried to reach defense counsel. Draft and review of Plaintiff's Motions for Partial Summary Judgment. Discussions with Corporation Counsel regarding extension. Review of DC's Motion for Extension 1 1 495 495 495 495 495 495 1 25 0.1 0.1 495 495 495 495 495 12375 49.5 49.5 495 0 49.5 49.5 0.25 0.1 0.1 2 10 3.5 4 0.5 0.5 2 25 3 495 495 495 495 495 495 495 495 495 495 495 495 123.75 49.5 49.5 990 4950 1732.5 1980 247.5 247.5 990 12375 1485 123.75 49.5 49.5 0 0 0 0 0 247.5 990 0 0 2.5 2.5 495 495 1237.5 1237.5 0 1237.5 9/13/1999 10/13/1999 10/14/1999 Received and reviewed New Order from the Court, noted new schedule. Corp. Counsel sought leave to oppose motion late, refused. Received and reviewed a motion for extension. Received and reviewed Defendant's Opposition to Plaintiff's MSJ. Research regarding reply. Drafted reply. Drafted, prepared filed plaintiff's motion to supplement the record. Reviewed court's order/denied plaintiff's MSJ and get new dates. Wrote letter to DOJ regarding MPD investigations. Received response from DOJ/review of resolution agreement. Research, prepared renewed Motion for Summary Judgment. Received and reviewed Defendant's Opposition. Received and reviewed court's order/memo denying plaintiff's motion for summary judgment, communicated with client Attended status conference, case referred to Judge Kay for Mediation Received and reviewed Defendant's discovery requests scheduled meeting to respond. Preparation, meeting attendance of Mediation with Judge Kay Meeting with client review of file to answer discovery requests. 1 5 3 495 495 495 495 2475 1485 495 2475 1485 11/3/1999 11/11/1999 11/19/1999 11/23/1999 12/9/1999 12/10/1999 Received and reviewed favorable probable cause finding discussed with client Transmitted probable cause finding to Corp Counsel. Status conference, New dates set. Drafted and sent proposed order to court. Letter to EEOC, review of file, right to sue letter sought. Met with client completed and transmitted discovery. 1.5 0.1 2.5 0.25 1.5 2 495 495 495 495 495 495 742.5 49.5 1237.5 123.75 742.5 990 742.5 49.5 1237.5 123.75 742.5 990 6/13/1997 6/16-20/1997 7/30/1997 8/4/1997 8/6/1997 10/1/1997 10/3/1997 10/20/1997 10/21-28/1997 10/30/1997 2/19-20/1998 3/23/1998 4/17/1998 5/6/1998 4/20-24/1998 5/22/1998 4/2/1999 8/9/1999 3 Medina v. DC 97-594 Attachment A 12/16/1999 12/7-10/1999 12/15/1999 Letter from Corp Counsel complaining about discovery review file. Drafted, prepared Motion to Amend reviewed file. Prepared, Served discovery upon DC. 1.5 10 3 495 495 495 742.5 4950 1485 742.5 4950 1485 1/13/2000 2/10-11/2000 Received/reviewed right to sue letters reviewed file communicated with client. Received and reviewed defendants response- Mosley Documents. 1.5 2.5 495 495 742.5 1237.5 742.5 1237.5 2/21/2000 2/25/2000 2/28/2000 3/9/2000 3/10/2000 4/3/2000 4/6/2000 5/15/2000 5/15/2000 5/30/2000 6/7/2000 6/16/2000 6/24/2000 8/9/2000 8/14/2000 8/28/2000 9/8/2000 9/19/2000 10/9/2000 1/17/2001 2/1/2001 2/13/2001 2/20/2011 4/2/2001 5/24/2001 6/4/2001 7/5/2001 Received and reviewed Defendant's Opposition to Plaintiff's Motion to Amend. Prepared/draft motion to compel review of file Transmitted draft Motion to Compel to Defendant. Filed Motion to Compel. Attended status conference with Judge Sullivan. Letter to Defendant regarding late discovery, review of file. Review of file, Answer by Defendants. Exchanges with DC regarding discovery and scheduling/review. Review of file, DC's new discovery responses. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. HVM Communications DCHR and client. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Status Conference in Court. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Call and letter regarding scheduling. Preparation and Attendance Settlement Conference with Facciola. 1.5 4.5 0.1 0.5 2.5 0.5 1.5 0.5 1.5 0.1 0.1 0.1 0.1 0.1 1.5 0.1 0.1 0.1 0.1 0.1 2.5 0.1 0.1 0.1 0.1 0.1 3.5 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 742.5 2227.5 49.5 247.5 1237.5 247.5 742.5 247.5 742.5 49.5 49.5 49.5 49.5 49.5 742.5 49.5 49.5 49.5 49.5 49.5 1237.5 49.5 49.5 49.5 49.5 49.5 1732.5 742.5 2227.5 49.5 247.5 1237.5 247.5 742.5 247.5 742.5 49.5 49.5 49.5 49.5 49.5 742.5 49.5 49.5 49.5 49.5 49.5 1237.5 49.5 49.5 49.5 49.5 49.5 1732.5 4 Medina v. DC 97-594 Attachment A 9/28/2001 11/2/2001 11/12-23/2001 12/3-7/2001 1/7/2002 9/23/2002 10/21-25/2002 10/29/2002 11/29/2002 Attendance at status conference before Judge Sullivan. Received, reviewed Defendant's MSJ. Research, Preparation, reply. Draft final opposition to Defendants MSJ. Review of Reply by DC. Status Conference in front of Judge Sullivan Preparation, Draft of Second Amended Complaint. Finalize complaint and file. Review of DC Motion for more time to file responsive pleading. 12/9/2002 1/15/2003 2/7-14/2003 2/14-28/2003 2/29-3/3/2003 Review of file, opposition to DC Motion for more time to file responsive pleading. Review of File, review defendants MSJ. Research, file review for opposition. Drafting, finalization of opposition. Research, draft plaintiff's motion for preliminary injunction. 3/20/2003 6/2-6/2003 7/29/2003 7/8/2003 8/8/2003 10/7/2003 5/6/2004 5/14/2004 7/1/2004 9/29/2004 9/16/2004 7/27/2004 10/6/2004 10/29/2004 Review of DC opposition to Plaintiff's motion for preliminary injunction. Research, draft of reply to DC's opposition to Plaintiff's motion for preliminary injunction. Memo to Court regarding Robinson v. DC Decision. Review of File; communication with client. Call and correspondence with Hennessey. Review of file communication with client. Review of file, Notice to Court. Review of file, Notice to Court. Review of file, demand letter, client discussion. Status conference. Mediation, Meeting with client. Follow up to Counsel. Follow up to Counsel. Preparation, Proposed Order, discussion with Defense Counsel. 1/10-14/2005 1/24/2005 Preparation, review, drafting of Plaintiff's Motion for Partial Summary Judgment. Receipt and review of Defendant's 3rd Motion to Dismiss 5 2.5 4 25 20 5 2.5 7 2 2 495 495 495 495 495 495 495 495 495 1237.5 1980 12375 9900 2475 1237.5 3465 990 990 1237.5 1980 12375 9900 2475 1237.5 3465 990 990 1.5 3 20 25 12.5 495 495 495 495 495 742.5 1485 9900 12375 6187.5 742.5 1485 9900 12375 0 3 495 1485 0 15 4 0.5 0.5 0.5 0.5 0.5 3 2.5 3.5 0.1 0.1 0.5 495 495 495 495 495 495 495 495 495 495 495 495 495 7425 1980 247.5 247.5 247.5 247.5 247.5 1485 1237.5 1732.5 49.5 49.5 247.5 0 1980 247.5 247.5 247.5 247.5 247.5 1485 1237.5 1732.5 49.5 49.5 247.5 17 2 495 495 8415 990 8415 990 Medina v. DC 97-594 Attachment A 1/25-2/2/2005 Preparation, drafting of Opposition to Defendant's Motion to Dismiss. 2/7/2005 2/8/2005 3/14/2005 6/7/2007 6/13-14/2007 7/1/2007 10/18/2007 10/29/2007 10/29/2007 10/29/2007 10/30/2007 10/30/2007 10/31/2007 11/15/2007 12/17/2007 12/20/2007 12/21/2007 1/17/2008 1/18/2008 1/25/2008 1/28/2008 1/29/2008 1/29/2008 1/29/2008 1/30/2008 1/31/2008 1/31/2008 1/31/2008 2/5/2008 2/6/2008 2/6/2008 Review of DC Opposition to Plaintiff's Motion for partial Summary Judgment. Preparation, drafting of Reply Defendants Opposition. Review of Defendant's Reply Memorandum. Review of Memorandum opinion filed by the court. Conversation with Defendant regarding ADR. Review of file, review of Defendant's Answer to Complaint. Review of File, meeting with client, attend mediation. Email to Jackson re status report. Draft Joint Status Report. Review status, e-mail to Medina. Email to defense counsel with Joint Status report. Review of DC changes to status report. Exchange e-mails with David Jackson, draft of praecipe re referral of case to Magistrate Judge. Email to DC re settlement. Review of file/discovery/email to DC re supplemental responses. Research and organization of file in Summation format. Research and organization of file in Summation format. Loading and organizing file. Loading and organizing file. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Document review - Summation. Review documents - Summation. Review documents - Summation. Review documents - Summation. 6 24 495 11880 11880 2 4 1.5 2 0.25 1.5 3.5 0.25 0.5 0.25 0.15 0.15 495 495 495 495 495 495 495 495 495 495 495 495 990 1980 742.5 990 123.75 742.5 1732.5 123.75 247.5 123.75 74.25 74.25 990 1980 742.5 990 123.75 742.5 1732.5 123.75 247.5 123.75 74.25 74.25 0.5 0.25 1 4 2.5 7 6 3.5 3 5 2 2 6 3.75 1.5 1 7 3 1 495 495 495 495 495 495 495 140 140 140 140 140 140 140 140 140 140 140 140 247.5 123.75 495 1980 1237.5 3465 2970 1732.5 1485 2475 990 990 2970 1856.25 742.5 495 3465 1485 495 247.5 123.75 495 1980 1237.5 3465 2970 490 420 700 280 280 840 525 210 140 980 420 140 Medina v. DC 97-594 Attachment A 2/7/2008 2/7/2008 2/7/2008 2/8/2008 Review documents - Summation. Review documents - Summation. Review documents - Summation. Review documents - Summation. 2/11/2008 2/11/2008 2/25/2008 2/26/2008 2/26/2008 Review of file, communication with Jackson re discovery, letter sent on Thursday. Discussion with Jackson re document production, review of documents. Research and review letter to PI to locate witnesses. Research re discrimination. Note to Jackson re late documents. Call to Jackson, put personnel file in mail to me, asks to have until end of week re rest of requested materials. Review of DC Production of records, e-mail to David Jackson Motion to compel. Motion to Compel, emails, etc. Follow up re witness location project. Review of latest document submission, adverse action file, discussion with JB re Summation Spoke to Horsley, witness in case. Document review - Summation. Review of opposition to Motion to Compel, reply drafted. Research and review of issues for trial. Loading Summation and review of files. Document review - Summation. Document review - Summation, call with DJ, received more documents. Document review - Summation, etc. Document review - Summation. Pretrial Statement. E-mail re scheduling, review of documents. Review Summation documents. Review Summation documents. Review Summation documents. Review Summation documents. Review Summation documents. 3/10/2008 3/12/2008 3/12/2008 3/14/2008 3/17/2008 3/19/2008 3/19/2008 3/20/2008 3/25/2008 3/25/2008 3/27/2008 3/28/2008 3/31/2008 3/31/2008 4/3/2008 4/10/2008 4/14/2008 4/14/2008 4/15/2008 4/16/2008 4/16/2008 4/16/2008 2 4.5 1.5 5 7 140 140 140 140 990 2227.5 742.5 2475 280 630 210 700 0.25 0.5 3.5 1 0.25 495 495 495 495 495 123.75 247.5 1732.5 495 123.75 123.75 247.5 1732.5 495 123.75 0.15 2 3.5 1 0.25 495 495 495 495 495 74.25 990 1732.5 495 123.75 74.25 990 1732.5 495 123.75 0.5 0.5 2.5 1.5 0.75 1.7 3 3.5 1.5 6 4 1.5 1.5 1.5 2 1 2 495 495 140 495 495 140 140 140 140 140 495 495 140 140 140 140 140 247.5 247.5 1237.5 742.5 371.25 841.5 1485 1732.5 742.5 2970 1980 742.5 742.5 742.5 990 495 990 247.5 247.5 350 742.5 371.25 238 420 490 210 840 1980 742.5 210 210 280 140 280 Medina v. DC 97-594 Attachment A 4/17/2008 4/21/2008 5/5/2008 5/6/2008 5/7/2008 5/8/2008 Review Summation documents. Review Summation documents. Review Summation documents. Review Summation documents. Review Summation documents. Review Summation documents. 2.5 1 4.5 3.5 3.5 3 140 140 140 140 140 140 1237.5 495 2227.5 1732.5 1732.5 1485 350 140 630 490 490 420 5/19/2008 6/2/2008 6/2/2008 6/3/2008 Status conference at court, to select dates, e-mail to client re new dates. Review draft pretrial, sent same to DJ. Review of file, letters to potential witnesses. Review of draft letters and pretrial and returned call to Jackson. Discussion with JJB re anticipated request of DJ regarding exhibits and need to use for Summation experience. Review file, pretrial, Summation material. Review file, pretrial, Summation material, Trial Director file. Review telephone conference and meeting with David Jackson, research on me too. Review of motion, research, issuance of subpoenas. Research on Motion in limine. Research. Legal Research. Research & Drafting outline of opposition to motion in limine. Writing, research opposition to Motion in Limine. Writing, research opposition to Motion in Limine. Writing, research opposition to Motion in Limine. Pretrial Statement, conference, preparation, etc. Research, pretrial preparation. Research, pretrial preparation. Research, pretrial preparation. Research, pretrial preparation. Planning, trial preparation. Planning, trial preparation, discussion with client and DJ, draft of motion and review. Planning, trial preparation. 3 1.5 2.5 0.1 495 495 495 495 1485 742.5 1237.5 49.5 1485 742.5 1237.5 49.5 0.25 5 5 495 495 495 123.75 2475 2475 123.75 2475 2475 5 3 2 4 1.5 3 5 5 5 5 6 6 8.5 3.5 8.5 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 2475 1485 990 1980 742.5 1485 2475 2475 2475 2475 2970 2970 4207.5 1732.5 4207.5 2475 1485 990 1980 742.5 1485 2475 2475 2475 2475 2970 2970 4207.5 1732.5 4207.5 7 7 495 495 3465 3465 3465 3465 6/4/2008 6/9/2008 6/10/2008 6/12/2008 6/17/2008 6/18/2008 6/18/2008 6/19/2008 6/19/2008 6/23/2008 6/24/2008 6/25/2008 6/26/2008 6/30/2008 7/1/2008 7/8/2008 7/9/2008 7/10/2008 7/11/2008 7/12/2008 8 Medina v. DC 97-594 Attachment A 7/13/2008 7/14/2008 7/15/2008 7/16/2008 7/17/2008 7/18/2008 7/19/2008 7/20/2008 7/21/2008 7/22/2008 7/23/2008 7/24/2008 7/25/2008 7/28/2008 8/4/2008 8/5/2008 7/30/2008 7/31/2008 8/1/2008 8/18/2008 8/21/2008 8/22/2008 8/25/2008 8/26/2008 8/27/2008 9/2/2008 9/4/2008 9/8/2008 9/10/2008 9/16/2008 9/19/2008 3/12/2009 3/30/2009 4/1/2009 Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Planning, trial preparation. Trial. Trial. Trial. Trial. Trial. Trial. File review for fees motion, draft. File review for fees motion, draft. File review for fees motion. Research re fees and costs. Draft motion re fees and costs. Review - research re post-trial motions. Review - research re post-trial motions. Review - research re post-trial motions. Review - research re post-trial motions. Review - research re post-trial motions - draft, etc. Draft/research. Final draft and filing. Email: reply to motion for fees. Email: reply to motion for fees. Email: examination of a witness. Email: DC govt Order for Motion for Extension of time to reply Email: Government reply to opposition to motion. Email re: Angel Medina Email: Research on Westlaw, Medina v. DC Email from Angel Medina, Status. 9 7 7.5 9.5 8 8 8 8 8 12 14 12 12 8 6 5 4.5 5 4 6 4 3.5 4 3 5 5.5 2.5 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 495 3465 3712.5 4702.5 3960 3960 3960 3960 3960 5940 6930 5940 5940 3960 2970 2475 2227.5 2475 1980 2970 1980 1732.5 1980 1485 2475 2722.5 1237.5 123.75 123.75 123.75 123.75 123.75 123.75 123.75 123.75 3465 3712.5 4702.5 3960 3960 3960 3960 3960 5940 6930 5940 5940 3960 2970 2475 2227.5 2475 1980 2970 1980 1732.5 1980 1485 2475 2722.5 1237.5 123.75 123.75 123.75 123.75 123.75 123.75 123.75 123.75 Medina v. DC 97-594 Attachment A 4/28/2009 5/8/2009 Email: Government Order on Motion for new Trial. Email: David Jackson, Government Motion to Vacate. Various tasks performed by McKnight from 9/7/2009 - 9/19/2011 Various tasks performed by Jean-Baptiste from 6/4/2008 - 7/28/2008 10 0.25 0.25 119 140.25 495 495 495 140 123.75 123.75 58905 19635 493746 123.75 123.75 58905 19635 406991

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