Case 3:11-cv MJR-PMF Document 125 Filed 10/17/14 Page 1 of 4 Page ID #1615

Transcription

1 Case 3:11-cv MJR-PMF Document 125 Filed 10/17/14 Page 1 of 4 Page ID #1615 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS BENTON DIVISION MARY E. SHEPARD and the ILLINOIS STATE RIFLE ASSOCIATION, Plaintiffs, v. LISA M. MADIGAN, solely in her official capacity as ATTORNEY GENERAL OF ILLINOIS, GOVERNOR PATRICK J. QUINN, solely in his official capacity as Governor of the State of Illinois, TYLER R. EDMONDS, solely in his official capacity as the State s Attorney of Union County, Illinois, and SHERIFF DAVID LIVESAY, solely in his official capacity as Sheriff of Union County, Defendants. No. 3:11-cv MJR-PMF Honorable Judge Michael J. Reagan Magistrate Judge Philip M. Frazier PLAINTIFFS SUPPLEMENTAL MOTION FOR ATTORNEYS FEES Pursuant to this Court s order of September 29, 2014, Doc. 124 ( Order, Plaintiffs submit this supplemental request for attorneys fees reflecting expenses of securing their fee award that were not included in their initial fee petition. Plaintiffs request a supplemental award in the amount of $116, Where a plaintiff has obtained excellent results, his attorney should recover a fully compensatory fee. Normally this will encompass all hours reasonably expended on the litigation, Hensley v. Eckerhart, 461 U.S. 424, 435 (1983, including the hours reasonably required... for the collection of fees, Order 15 (quoting Johnson v. GDF, Inc., 668 F.3d 927, 933 (7th Cir Plaintiffs obtained excellent results in this case; as this Court recognized, their victory was comprehensive. Id. at 22. They thus are entitled to recover fees reflecting 1

2 Case 3:11-cv MJR-PMF Document 125 Filed 10/17/14 Page 2 of 4 Page ID #1616 Cooper & Kirk and Locke Lord attorneys work on securing their fee award that were not included in the initial fee petition. Id. at 23. Those fees are detailed below. I. Cooper & Kirk Plaintiffs initial fee petition included Cooper & Kirk s fees through November See Thompson Decl. 6, Doc With this supplemental motion, Plaintiffs submit additional Cooper & Kirk fees in the amount of $92, See Thompson Supp. Decl., Exhibit A, at 1. Of that amount, $25, reflects work related to the filing of the fee petition. See id. at 1-3. The remainder $67, primarily reflects work responding to the State s discovery requests, its unpersuasive legal arguments, Order 5, and its niggling objections to Plaintiffs time sheets that sought to punish Plaintiffs by... decontextualizing every description of the work their attorneys performed, id. at 16, 17. See Thompson Supp. Decl., Exhibit A, at 1, 3-6. Plaintiffs attempted to eliminate the necessity of much of this work by extending an offer to settle the fee litigation in March 2014, but the State declined to engage in substantive settlement discussions. See Thompson Supp. Decl. 8 & Exhibit B. II. Locke Lord With this supplemental motion, Plaintiffs request $23, for Locke Lord fees that were not included in their initial fee petition. See Howard Supp. Decl. 4. Of that amount, $16, reflects work related to the filing of the fee petition, see id. Exhibit A, at 3, while the remainder primarily reflects work related to responding to the State s discovery requests and its opposition to the fee petition. In conclusion, Plaintiffs request a supplemental fee award in the amount of $116, as compensation for the amount of additional time their attorneys spent securing their fee award. 2

3 Case 3:11-cv MJR-PMF Document 125 Filed 10/17/14 Page 3 of 4 Page ID #1617 Dated: October 17, 2014 William N. Howard LOCKE LORD LLP 111 S. Wacker Drive Chicago, IL Tel: ( Fax: ( whoward@lockelord.com Respectfully submitted, s/ Charles J. Cooper Charles J. Cooper* David H. Thompson* COOPER & KIRK, PLLC 1523 New Hampshire Avenue, N.W. Washington, D.C Tel: ( Fax: ( ccooper@cooperkirk.com *Admitted pro hac vice Attorneys for Plaintiffs 3

4 Case 3:11-cv MJR-PMF Document 125 Filed 10/17/14 Page 4 of 4 Page ID #1618 CERTIFICATE OF SERVICE The undersigned attorney states that he caused a true and correct copy of PLAINTIFFS SUPPLEMENTAL MOTION FOR ATTORNEYS FEES to be served upon the parties of record, as shown below, via the Court s CM/ECF system on the 17th day of October, By: s/ Charles J. Cooper SERVICE LIST Terence J. Corrigan Illinois Attorney General s Office 500 South Second Street Springfield, IL Tel: ( Fax: ( tcorrigan@atg.state.il.us Jonathan Lee Diesenhaus HOGAN LOVELLS LLP th Street, N.W. Washington, D.C Tel: ( Fax: ( jonathan.diesenhaus@hoganlovells.com Karen L. McNaught Illinois Attorney General's Office - Springfield 500 South Second Street Springfield, IL Tel: ( Fax: ( kmcnaught@atg.state.il.us Joseph A. Bleyer K. Rockne Bleyer BLEYER & BLEYER 601 West Jackson P.O. Box 487 Marion, IL Tel: ( jableyer@bleyerlaw.com Karl Triebel Illinois Attorney General's Office - Chicago West Randolph Street 12th Floor Chicago, IL Tel ( Fax: ( ktriebel@atg.state.il.us 4

5 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 1 of 18 Page ID #1619 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS BENTON DIVISION MARY E. SHEPARD and the ILLINOIS STATE RIFLE ASSOCIATION, Plaintiffs, v. LISA M. MADIGAN, solely in her official capacity as ATTORNEY GENERAL OF ILLINOIS, GOVERNOR PATRICK J. QUINN, solely in his official capacity as Governor of the State of Illinois, TYLER R. EDMONDS, solely in his official capacity as the State s Attorney of Union County, Illinois, and SHERIFF DAVID LIVESAY, solely in his official capacity as Sheriff of Union County, Defendants. No. 3:11-cv MJR-PMF Honorable Judge Michael J. Reagan Magistrate Judge Philip M. Frazier SUPPLEMENTAL DECLARATION OF DAVID H. THOMPSON I, David H. Thompson, hereby declare as follows: 1. I submit this declaration in support of Plaintiffs Supplemental Motion for Attorneys Fees. I am the Managing Partner of Cooper & Kirk, PLLC ( Cooper & Kirk or the Firm, and information regarding my background and experience and my efforts to staff this case in an efficient manner is detailed in the declaration I submitted in support of Plaintiffs initial fee petition. See Declaration of David H. Thompson 1-5, Doc ( Thompson Decl.. 1

6 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 2 of 18 Page ID # Attached as Exhibit A is a true and correct copy of the summary of attorneys fees and expenses for Cooper & Kirk from December 2013 through July These entries are derived from the actual charges billed by the Firm for its work on this case and paid by the National Rifle Association of America, Inc. ( NRA on behalf of the Plaintiffs. The entries were derived from entries in the Firm s Timeslips database which is maintained in the ordinary course of the Firm s business. The database entries are recorded at or about the time of the events recorded. 3. I have reviewed all of the time entries and expenditures for this case and in the exercise of billing judgment have sought to eliminate any hours that I believe were potentially unproductive or that were otherwise not the proper subject of this supplemental fee request. 4. The hourly rates sought by Cooper & Kirk reflect the rates actually paid to the Firm in this case. Thus, the hourly rates sought here reflect the rates actually paid to the Firm in typical arm s-length, market-rate transactions. Indeed, in light of the non-profit status of the NRA (which paid for the rates incurred by Plaintiffs in this case, the hourly rates we charged and that we seek here reflect a discount on rates the Firm has charged to other clients in litigation of similar complexity and magnitude. 5. This Court has already found the Firm s 2013 rates reasonable. Memorandum & Order at 13, Doc The Firm s 2014 rates represent a modest yearly increase from those rates, and they are the same as the hourly rates [that] drew no objection in the wake of NRA v. Chicago. Id.; see Doc From the inception of the Firm s involvement in this case, I have had personal familiarity with the work performed by attorneys assigned to this case. In addition to attorneys who are discussed in my initial declaration, see Thompson Decl. 10, Haley Proctor also worked 2

7 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 3 of 18 Page ID #1621 on this case. Ms. Proctor is a 2012 graduate of Yale Law School, and she joined Cooper & Kirk as an associate in 2013 after clerking for Judge Thomas B. Griffith of the United States Court of Appeals for the District of Columbia Circuit. Ms. Proctor recently left the Firm to clerk for Justice Clarence Thomas of the United States Supreme Court. 7. Additional Cooper & Kirk staff have spent time on this litigation, and their reasonable hours and billing rates are also reflected in Exhibit A. The rates reflected in Exhibit A are the rates Cooper & Kirk charged in this litigation. 8. In March 2014, Plaintiffs sent the State an offer to settle the attorneys fees issue. Attached as Exhibit B is a true and correct copy of the extending the offer. The State did not respond to the or otherwise engage in substantive settlement discussions. 9. In sum, Exhibit A sets forth both the reasonable time spent by Cooper & Kirk attorneys in this case from December 2013 through July 2014 and the amount Cooper & Kirk charged for that time. The total amount of supplemental fees being sought at this time for Cooper & Kirk s work in this case is $92, See Ex. A at 1. 3

8 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 4 of 18 Page ID #1622 I declare under penalty of perjury that the foregoing is true and correct. Executed this day of October, 2014, in. David H. Thompson 4

9 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 5 of 18 Page ID #1623 EXHIBIT A

10 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 6 of 18 Page ID #1624 INDEX TO EXHIBIT A Summary of Fees...1 Detailed Fee Records...2

11 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 7 of 18 Page ID #1625 SUMMARY OF FEES 2013 Attorney/Staff Member Rate Hours Total Katerina S. Kariolis $ $2, Peter A. Patterson $ $19, David H. Thompson $ $3, $25, Attorney/Staff Member Rate Hours Total Katerina S. Kariolis $ $1, Lizzie A. Lipovsky $ $1, Peter A. Patterson $ $24, Haley N. Proctor $ $37, David H. Thompson $ $ $67, TOTAL: $92,

12 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 8 of 18 Page ID # /04/13 PP Draft fee petition /05/13 PP Draft fee petition /06/13 DHT Prepare motion for attorneys' fee /06/13 DHT Conference with P. Patterson re fee petition /06/13 PP Conference with D. Thompson re fee 0.20 petition. 12/06/13 PP Work on preparing supporting materials for 0.70 fee petition. 12/06/13 PP Draft fee petition /07/13 PP Review Shepard bills for fee petition /08/13 DHT Revise motion for fees /16/13 PP Review research re attorney fee awards /16/13 PP Work on drafting Shepard fee petition and 0.30 supporting materials. 12/16/13 PP Conference with K. Gibson re Shepard fee 0.10 petition. 12/17/13 DHT Prepare motion for attorney fees /17/13 KSK Citecheck Shepard fee motion for 2.50 P.Patterson. 12/17/13 PP Work on drafting Shepard fee petition and 2.70 supporting materials. 12/17/13 PP Review Shepard bills for fee petition /18/13 DHT Review affidavit for fee motion /18/13 PP Research re Shepard fee petition /19/13 KSK Citecheck second half of Shepard fee 2.90 motion for P. Patterson. 12/19/13 PP Draft declaration of D. Thompson in 0.20 support of fee petition. 12/19/13 PP Review cite check of fee petition brief /20/13 PP Review and comment on co-counsel's fee 0.80 petition materials. 12/22/13 DHT Analyze billing records in preparation of 0.90 affidavit. 12/23/13 PP Work on drafting Shepard fee petition and 7.70 supporting materials, including declaration. 12/24/13 DHT Prepare affidavit for attorneys' fees /24/13 PP Work on drafting Shepard fee petition and 0.20 supporting materials, including declaration. 12/26/13 DHT Prepare affidavit in support of motion for 1.70 attorneys fee and review accompanying attachments. 12/26/13 KSK Cite check Shepard fee motion for P. Patterson

13 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 9 of 18 Page ID # /26/13 PP Work on drafting Shepard fee petition and 8.70 supporting materials, including timesheet exhibit and declaration of D. Thompson. 12/27/13 DHT Further work on fee application /27/13 KSK Cite check Shepard fee motion, 8.90 declarations, and exhibits; file fee motion and components for P. Patterson. 12/27/13 PP Work on drafting and preparing to file 7.30 Shepard fee petition and supporting materials. 12/27/13 PP Conference with K. Gibson re fee petition /27/13 PP Conference with K. Kariolis re filing fee 0.20 petition. 01/06/14 PP Work on strategy for responding to state 0.10 motion for discovery. 01/07/14 DHT Conference with P. Patterson re Shepard 0.10 attorneys' fees discovery motion. 01/07/14 PP Conference with D. Thomson re Shepard 0.10 attorneys' fees discovery motion. 01/07/14 PP Communicate with B. Howard re state 0.10 discovery motion. 01/07/14 PP Research re state discovery motion /08/14 HNP Telephone conference with P. Patterson re 0.40 opposition to government's discovery motion re attorneys' fees; research discovery for attorneys' fees. 01/08/14 PP Research re opposition to discovery motion /08/14 PP Conference with H. Procter re opposition to 0.30 state discovery motion. 01/09/14 HNP Research discovery for attorneys' fees; draft opposition to government's motion re attorneys' fees. 01/10/14 HNP Research discovery for attorneys' fees; draft opposition to government's motion re attorneys' fees /10/14 LAL Cite check Shepard Opposition to State's 0.80 Discovery Motion. 01/10/14 PP Draft opposition to motion for discovery /13/14 DHT Review and revise brief in opposition to 0.40 state's request for discovery. 01/13/14 KSK Cite check Shepard opposition to discovery 1.80 motion for P. Patterson. 01/13/14 LAL Review Shepard cite check for K. Kariolis /13/14 PP Edit and prepare for filing opposition to discovery motion

14 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 10 of 18 Page ID # /17/14 PP Review order granting discovery motion /27/14 DHT Analyze discovery propounded by state and 0.30 legitimacy of scope of interrogatories. 01/27/14 PP Review fee petition interrogatories /29/14 PP Research re discovery requests /17/14 PP Work on responding to state discovery 2.50 requests. 02/18/14 DHT Call with P. Patterson re discovery issues /18/14 PP Work on responses to state discovery 4.80 requests. 02/18/14 PP Conference with D. Thompson re Shepard 0.40 discovery requests. 02/19/14 PP Draft responses to discovery requests /24/14 PP Work on responses to State discovery 0.80 requests. 02/26/14 PP Work on responses to state discovery 1.10 requests. 02/28/14 LAL Cite check response to rogs for P. Patterson /28/14 PP Work on responses to state discovery 1.30 requests. 03/01/14 PP Work on responses to state discovery 0.20 requests. 03/03/14 PP Work on Shepard discovery replies /10/14 DHT Conference with P. Patterson re Shepard 0.10 discovery. 03/10/14 HNP Prepare for fees discovery conference /10/14 PP Conference with D. Thompson re Shepard 0.10 discovery. 03/10/14 PP Work on arranging meet and confer 0.30 regarding Shepard discovery. 03/11/14 DHT Conference with P. Patterson & H. Proctor 0.20 re attorneys' fees discovery. 03/11/14 HNP Prepare for, attend, and follow up on fees 1.60 discovery conference. 03/11/14 PP Prepare for and participate in call with State 0.40 regarding attorneys' fees discovery. 03/11/14 PP Conference with D. Thompson & H. Proctor 0.20 re attorneys' fees discovery. 03/11/14 PP Work on responding to Illinois discovery 0.60 requests. 03/12/14 DHT Conference with P. Patterson re Shepard 0.10 attorney fees. 03/12/14 PP Conference with D. Thompson re Shepard 0.10 attorney fees. 03/13/14 HNP Follow up on discovery conference

15 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 11 of 18 Page ID # /13/14 PP Work on responding to State discovery 0.40 requests. 03/14/14 PP Review state motion for extension /17/14 PP Draft response to Shepard discovery 1.30 requests. 03/18/14 PP Work on responses to discovery requests /21/14 PP Edit response to state discovery requests /21/14 PP Draft fees settlement offer /25/14 PP Draft letter supplementing discovery 0.30 responses. 04/15/14 PP Review and respond to state request for 0.10 extension. 04/18/14 PP Review fee petition response /21/14 PP Draft message for opposing counsel re 0.20 motion for extension. 04/22/14 PP Respond to state motion for extension /22/14 PP Work on motion for extension of page 0.10 limits and time to file reply. 04/23/14 DHT Review motion for extension of time and 0.20 page limits. 04/23/14 KSK Cite check Shepard motion and file for P Patterson. 04/23/14 PP Draft motion for extension of time and page 3.10 limits. 04/24/14 PP Work on reply in support of fee motion /30/14 PP Work on strategy for reply in support of fee 0.10 petition. 05/14/14 HNP Review State's opposition to fee petition /15/14 HNP Research prevailing party status arguments 8.00 in State's opposition to fee petition. 05/16/14 HNP Draft section of reply brief responding to 5.70 State's prevailing party argument. 05/17/14 HNP Draft section of reply brief responding to 5.30 State's prevailing party argument. 05/18/14 HNP Draft section of reply brief responding to 5.10 State's prevailing party argument. 05/19/14 HNP Research and draft reply brief section concerning reasonable rates and reasonable hours. 05/19/14 HNP Telephone conference with P. Patterson re 0.40 reply brief. 05/19/14 LAL Create and proof Shepard tables of attorney 1.00 fees/hours for H. Proctor. 05/19/14 PP Conference with H. Proctor re Shepard fee reply 0.4 5

16 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 12 of 18 Page ID # /20/14 HNP Research and draft reply brief section 9.00 concerning reasonable hours and expenses. 05/20/14 HNP Respond to line-by-line fees objections in 1.30 Defendants' exhibits. 05/21/14 HNP Respond to line-by-line fees objections in 9.50 Defendants' exhibits. 05/21/14 PP Work on fee petition reply brief /22/14 HNP Respond to line-by-line fees objections in 4.80 Defendants' exhibits. 05/22/14 HNP Revise reply brief /22/14 HNP Telephone conferences with P. Patterson re 0.20 reply brief. 05/22/14 PP Work on fee petition reply brief /22/14 PP Conferences with H. Proctor re fee petition 0.20 reply. 05/23/14 HNP Respond to line-by-line costs and expenses 5.70 objections in Defendants' exhibits. 05/23/14 HNP Revise reply brief /23/14 HNP Revise tables responding to line-by-line 2.30 objections. 05/23/14 PP Review and edit exhibits for fee petition 2.90 reply. 05/24/14 HNP Revise reply brief and tables responding to 3.20 line-by-line objections. 05/24/14 PP Edit reply in support of fee petition /25/14 DHT Review and revise reply brief in support of 0.90 the petition and accompanying chart. 05/25/14 HNP Review edits to brief /25/14 PP Work on reply is support of fee petition /26/14 HNP Revise reply brief and accompanying tables /26/14 LAL Cite check Shepard reply to response to 7.20 motion for att'y's fees for H. Proctor. 05/26/14 PP Work on reply in support of fee petition /27/14 HNP Finalize reply brief and exhibits for filing /27/14 KSK Cite check Shepard fee motion reply brief 6.10 table exhibits. 05/27/14 LAL Proof tables, cite check brief, table, file for 4.20 H. Proctor. 05/27/14 PP Review and finalize for filing reply in 1.70 support of fee petition. 07/14/14 PP Draft notice of Benson fee petition ruling /15/14 KSK Cite check and file motion to cite 2.20 supplemental authority for P. Patterson. 07/15/14 PP Work on finalizing motion to cite supplemental authority

17 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 13 of 18 Page ID # /23/14 PP Review state response to motion to cite supplemental authority

18 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 14 of 18 Page ID #1632 EXHIBIT B

19 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 15 of 18 Page ID #1633 Pete Patterson From: Pete Patterson Sent: Friday, March 21, :52 PM To: McNaught, Karen L. Cc: Corrigan, Terence; Triebel, Karl; David Thompson; Gibson, Keith Subject: RE: Discovery Responses - Shepard v. Madigan, No. 11-cv-405 Karen, I m writing with an offer to settle Plaintiffs motion for attorneys fees, costs, and taxable expenses for $625,000. This is a very generous offer. As an initial matter, for the reasons set forth in our brief we believe our motion has a strong likelihood of success. Furthermore, our motion asks for a total of about $641,000, and the State s potential liability is much higher. Prevailing plaintiffs, of course, are entitled to the fees they incur to secure their fee award. For example, from December 2013 through February 2014, Cooper & Kirk alone billed over $40,000 in additional potentially recoverable fees for work related to Plaintiffs motion. Of course, the State s potential liability will only increase if the State continues to litigate this matter. We look forward to your response, and please let me know if you have any questions regarding this offer. Thank you, Pete ; 1

20 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 16 of 18 Page ID #1634

21 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 17 of 18 Page ID #1635

22 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 18 of 18 Page ID #1636 4

23 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 1 of 22 Page ID #1637 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS BENTON DIVISION MARY E. SHEPARD and the ILLINOIS STATE RIFLE ASSOCIATION vs. Plaintiffs, LISA M. MADIGAN, solely in her official ~ capacity as ATTORNEY GENERAL OF ILLINOIS, GOVERNORPATRICKJ. QUINN, solely in his official capacity as Governor of the State of Illinois, TYLER R. EDMONDS, solely in his official capacity as the State's Attorney of ~ Union County, Illinois, and SHERIFF DAVID LIVESAY, solely in his official capacity as Sheriff of Union County, Defendants. Case No. 3:11-cv MJR Honorable Judge Michael J. Reagan SUPPLEMENTAL DECLARATION OF WILLIAM N. HOWARD My name is William N. Howard. Pursuant to 28 U.S.C. 1746, I make this Declaration on personal knowledge. I am an attorney of record in the above-entitled action. I am over the age of 18 years and competent to testify to the matters set forth herein. 1. The original fee petition filed in this case contained invoices through October 31, Since the submission ofthe original fee petition, I billed 10.7 hours at $450.00, for a total charge to Plaintiffs of$4, See Ex. "A". This work was necessary to adequately represent Plaintiffs' interests. Additionally, attorney Keith L. Gibson and paralegal Vickie Waide assisted me with the additional work on this case. 2. Keith Gibson is an attorney at LL that assisted me in the above-entitled action. Keith Gibson has been actively practicing law for over 16 years. Since the submission of the

24 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 2 of 22 Page ID #1638 original fee petition, Keith Gibson billed 33.1 hours at $425.00, for a total charge to Plaintiffs of $14, See Ex. "A". 3. Vickie Waide is a paralegal at LL that assisted me in the above-entitled action. Vickie Waide has been actively working as a paralegal for 29 years. Since the submission of the original fee petition, Vickie Waide billed 15.5 hours at $290.00, for a total charge to Plaintiffs of $4, See Ex. "A". 4. In total, LL charged the Plaintiffs $23, in fees and costs since the original Petition for Fees was submitted. I declare under penalty of perjury that the foregoing is true and correct. Dated: JO II~ tlf -2-

25 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 3 of 22 Page ID #1639 EXHIBIT A

26 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 4 of 22 Page ID #1640 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA January 16, 2014 Invoice No.: Total amount due for the legal services rendered and expenses incurred in connection with the referenced matter through December 31, 2013 $16, File Number: RE: Illinois Concealed Carry Law / Shepard DATE ATTY DESCRIPTION HOURS. 11/08/13 WNH Tended to issues related to Bill of Costs /08/13 KLG Exchange s with counsel regarding status of filing of mandate and filing of petition for fees and costs. 11/08/13 KLG Review of file materials and legal research regarding filing of mandate and petition for fees and costs. 12/02/13 WNH Tended to issues pertaining to fees and costs recover /05/13 KLG Initial review of invoices for fee petition; prepare to W Howard regarding status of same. 12/06/13 KLG Exchange s with counsel regarding status of fee petition /09/13 WNH Tended to bill of costs issues including affidavits, securing billing records and related matters. 12/09/13 KLG Exchange s regarding production of Freeborn & Peters invoices Atlanta Austin Chicago Dallas Hong Kong Houston London Los Angeles New Orleans New York Sacramento San Francisco Washington DC

27 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 5 of 22 Page ID #1641 National Rifle Association Invoice Date: January 16, 2014 File No.: Invoice No.: Page: 2 DATE ATTY 12/10/13 KLG 12/11/13 WNH 12/11/13 KLG 12/11/13 KLG 12/11/13 VLW 12/11/13 VLW 12/11/13 VLW 12/12/13 KLG 12/12/13 VLW 12/12/13 VLW 12/13/13 VLW 12/13/13 VLW 12/16/13 WNH 12/16/13 KLG DESCRIPTION HOURS Review of draft fee petition; review of invoices in support of fee 2.40 petition. Tended to bill of costs issues including affidavits, securing 0.80 billing records and related matters. Exchange s with counsel regarding status of preparation 0.20 of attorneys fees petition. Review of invoices in preparation of declaration in support of 2.60 petition for attorneys fees. Begin preparation of list of all attorneys who worked on this 3.10 matter, all hours billed, rates at which times were billed and total fees incurred. Office conference with K. Gibson regarding assistance needed 0.20 in preparing Memorandum in Support of Attorney's Fees in this matter. Preparation of Declaration of William N. Howard Work on attorneys fees petition including declaration of B Howard, preparation of exhibits and review of invoices and bill of costs. Preparation of list of attorneys who worked on this matter, all 3.50 hours billed, rates at which times were billed and total fees incurred, and office conference with K. Gibson regarding revisions needed. Preparation of Declaration of William N. Howard and office 1.40 conference with K. Gibson regarding revisions needed. Correspond with Locke Lord billing coordinator to obtain copies 0.20 of various invoices for inclusion in Declaration of William N. Howard. Attention to rechecking list of hours billed, rates at which times 0.90 were billed and total fees incurred for inclusion in Declaration of William N. Howard. Continued work on fees motions and materials; work with K 0.30 Gibson regarding same. Work on draft declaration of William Howard, review invoices 6.60 and prepare supporting exhibits for petition for attorneys fees; prepare draft bill of costs. 12/16/13 VLW Office conference with K. Gibson re: status of Declaration and 5.10 continued preparation of attachments to Declaration and prepare Bill of Costs. 12/20/13 KLG Exchange s with counsel (Patterson regarding status of 0.20

28 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 6 of 22 Page ID #1642 National Rifle Association File No.: Invoice Date: January 16, 2014 Invoice No.: Page: 3 DATE ATTY DESCRIPTION HOURS fee petition. 12/20/13 KLG Continued preparation and edit/revision of draft declaration of 2.50 W. Howard; continued preparation of supporting exhibits to fee petition. 12/23/13 KLG Exchange numerous s with counsel (Patterson regarding 0.80 preparation of fee petition and bill of costs. 12/27/13 KLG Final preparation of declaration, bill of costs, invoices and 5.20 exhibits for petition for attorneys fees. TOTAL FEES TOTAL HOURS 44.3 $16, BILLING PROFESSIONALS TIMEKEEPER CLASS RATE HOURS VALUE W. N. Howard Partner K. L. Gibson Senior Counsel V.L. Waide-Ashmore Paralegal , TIMEKEEPER TOTALS $ 1, , , DATE EXPENSES VALUE Photocopies TOTAL EXPENSES $55.00 TOTAL FEES $ $ 16, TOTAL EXPENSES $55.00 TOTAL FEES AND EXPENSES $ TOTAL BALANCE DUE $ $16, $16, PLEASE REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account:

29 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 7 of 22 Page ID #1643 ATTN: Locke Lord Bissell & Liddell LLP, Box #24259 Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( , can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

30 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 8 of 22 Page ID #1644 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA January 16, 2014 Invoice No.: REMITTANCE ADVICE Total amount due for the legal fees and expenses rendered in connection w through December 31, 2013 File Number: RE: Illinois Concealed Carry Law / She Total Fees.$ $16, Total Expenses $55.00 Total Due this Stateme $16, PL E REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

31 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 9 of 22 Page ID #1645 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA April 18, 2014 Invoice No.: Total amount due for the legal services rendered and expenses incurred in connection with the referenced matter through February 28, 2014 $3, File Number: RE: Illinois Concealed Carry Law / Shepard DATE ATTY DESCRIPTION HOURS 01/07/14 KLG Review of Defendants' Motion for Extension of Time to 1.20 Response to Fee Petition and for Leave to Conduct Discovery; exchange s with P. Patterson and conference with B. Howard regarding same; telephone call to Judge's clerk regarding filing of response to same 01/08/14 KLG Telephone call with court clerk (Fix regarding filing of response 0.30 to defendant's motion for leave to conduct discovery and for extension of time to respond to fee petition 01/08/14 KLG Exchange s with counsel (Patterson regarding response 0.30 to defendant's motion for leave to conduct discovery and for extension of time to respond to fee petition 01/13/14 KLG Review of draft response memorandum in opposition to 1.50 defendants motion for extension and leave to conduct discovery; conference with B. Howard and exchange s with P. Patterson regarding same 02/11/14 KLG Exchange s with P. Patterson regarding status of 0.40 discovery responses; review of defendant's discovery requests to plaintiffs 02/12/14 WNH Review of discovery filed by Defendant with regard to fees /18/14 WNH Tended to securing information required for discovery 0.30 responses.. Atlanta Austin Chicago Dallas Hong Kong Houston London Los Angeles New Orleans New York Sacramento San Francisco Washington DC

32 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 10 of 22 Page ID #1646 National Rifle Association File No.: Invoice Date: April 18, 2014 Invoice No.: Page: 2 DATE ATTY 02/25/14 WNH 02/26/14 WNH 02/26/14 KLG 02/27/14 WNH 02/28/14 WNH DESCRIPTION HOURS Tended to discovery issues and communication with team 0.80 regarding proper responses to same. Tended to discovery issues and communication with team 0.80 regarding proper responses to same. Review of file materials regarding status of discovery 0.40 responses. Tended to discovery issues ad communication with team 0.80 regarding proper responses to same. Tended to discovery issues and communication with team 0.80 regarding proper responses to same. TOTAL HOURS 8.1 TOTAL FEES $3, BILLING PROFESSIONALS TIMEKEEPER CLASS RATE HOURS VALUE W. N. Howard Partner , K. L. Gibson TIMEKEEPER TOTALS Senior Counsel , $3, DATE EXPENSES Photocopies PACER Online Research TOTAL EXPENSES VALUE $8.80 TOTAL FEES $3, TOTAL EXPENSES $8.80 TOTAL FEES AND EXPENSES TOTAL BALANCE DUE $3, $3,551.30

33 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 11 of 22 Page ID #1647 PLEASE REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord Bissell & Liddell LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( , can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

34 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 12 of 22 Page ID #1648 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA April 18, 2014 Invoice No.: REMITTANCE ADVICE Total amount due for the legal fees and expenses rendered in connection w through February 28, 2014 File Number: RE: Illinois Concealed Carry Law / She Total Fees $3, Total Expenses $8.80 Total Due this Stateme $ $3, PL REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

35 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 13 of 22 Page ID #1649 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA June 4, 2014 Invoice No.: Total amount due for the legal services rendered and expenses incurred in connection with the referenced matter through April 30, 2014 $2, File Number: RE: Illinois Concealed Carry Law / Shepard DATE ATTY DESCRIPTION HOURS 03/01/14 WNH 03/03/14 WNH Review of discovery materials from co-counsel and work on 0.50 finalizing same. Tended to discovery issues /10/14 WNH 03/11/14 KLG 03/13/14 WNH 03/13/14 KLG 03/21/14 WNH 03/21/14 KLG 03/25/14 KLG Tended to discovery conference issues Telephone conference with defendants attorneys regarding 0.40 discovery responses related to fee petition. Follow-up on status of discovery responses and information Exchange s with attorney Patterson regarding production 0.40 of documents to defendants. Tended to discovery issues and communication with team 0.30 regarding same; review of communications from team regarding same. Review of from attorney Patterson and production of 0.40 documents to defendants regarding attorneys fees petition. Review of letter from attorney Patterson regarding amended 0.20 response to defendant's interrogatories. Atlanta Austin Chicago Dallas Hong Kong Houston London Los Angeles New Orleans New York Sacramento San Francisco Washington DC

36 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 14 of 22 Page ID #1650 National Rifle Association File No.: Invoice Date: June 4, 2014 Invoice No.: Page: 2 DATE ATTY 03/28/14 KLG 4 04/23/14 WNH 04/25/14 WNH DESCRIPTION HOURS Telephone call with attorney Patterson regarding status of 0.20 production of documents and status of settlement Review of motion for extension of time and for additional pages 0.30 for Reply. Review of fee petition objections TOTAL HOURS 5.1 TOTAL FEES $2, BILLING PROFESSIONALS TIMEKEEPER CLASS RATE HOURS VALUE W. N. Howard Partner $1, K. L. Gibson Senior Counsel TIMEKEEPER TOTALS $ $2, DATE EXPENSES VALUE PACER Online Research 6.10 Binding Supplies TOTAL EXPENSES $34.90 TOTAL FEES $2, TOTAL EXPENSES $34.90 TOTAL FEES AND EXPENSES $2, TOTAL BALANCE DUE $2,289.90

37 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 15 of 22 Page ID #1651 Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( , can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

38 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 16 of 22 Page ID #1652 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA June 4, 2014 Invoice No.: REMITTANCE ADVICE Total amount due for the legal fees and expenses rendered in connection withet through April 30, 2014 File Number: RE: Illinois Concealed Carry Law / She Total Fees $2, Total Expenses $34.90 Total Due this Stateme $2, PL -E REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

39 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 17 of 22 Page ID #1653 Locke Lord"' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA August 21, 2014 Invoice No.: Total amount due for the legal services rendered in connection with the referenced matter through June 30, 2014 $ File Number: RE: Illinois Concealed Carry Law / Shepard DATE ATTY DESCRIPTION HOURS 05/27/14 KLG Review and edit/revision of draft reply brief in support of plaintiffs' motion for attorneys fees. 05/27/14 KLG Telephone call with attorney Patterson regarding edits to reply brief TOTAL HOURS 1.40 TOTAL FEES $ BILLING PROFESSIONALS TIMEKEEPER CLASS RATE HOURS VALUE K. L. Gibson Senior Counsel TIMEKEEPER TOTALS 1.40 $ TOTAL BALANCE DUE $ PLEASE REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord Bissell & Liddell LLP, Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. Atlanta Austin Chicago Dallas Hong Kong Houston London Los Angeles New Orleans New York Sacramento San Francisco Washington DC

40 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 18 of 22 Page ID #1654 Box # Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( , can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

41 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 19 of 22 Page ID #1655 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA August 21, 2014 Invoice No.: REMITTANCE ADVICE Total amount due for the legal fees and expenses rendered in connection w through June 30, 2014 File Number: RE: Illinois Concealed Carry Law / She Total Fees Total Due this Statement $ PL REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

42 Locke Lord' Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 20 of 22 Page ID #1656 Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA September 16, 2014 Invoice No.: Total amount due for the legal services rendered in connection with the referenced matter through August 31, 2014 $ File Number: RE: Illinois Concealed Carry Law / Shepard DATE ATTY DESCRIPTION 07/15/14 KLG Review of draft motion to cite supplemental authority in support of fee petition; exchange s with counsel regarding same. TOTAL HOURS HOURS TOTAL FEES $ BILLING PROFESSIONALS TIMEKEEPER CLASS RATE HOURS VALUE K. L. Gibson Senior Counsel TIMEKEEPER TOTALS 0.40 $ BALANCE DUE FROM PREVIOUS STATEMENT $ TOTAL BALANCE DUE $ PLEASE REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATTN: Locke Lord Bissell & Liddell LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Atlanta Austin Chicago Dallas Hong Kong Houston London Los Angeles New Orleans New York Sacramento San Francisco Washington DC

43 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 21 of 22 Page ID #1657 Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( , can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.

44 Case 3:11-cv MJR-PMF Document Filed 10/17/14 Page 22 of 22 Page ID #1658 Locke Lord' Attorneys & Counselors 111 South Wacker Drive Chicago, IL Telephone: Fax: Tax ID: National Rifle Association Waples Mill Rd. Fairfax, VA September 16, 2014 Invoice No.: REMITTANCE ADVICE Total amount due for the legal fees and expenses rendered in connection w through August 31, 2014 File Number: RE: Illinois Concealed Carry Law / She Total Fees Total Due this Statement Balance Due from Previo Total Balance Due ent $ $ $ PL- REMIT PAYMENT: Via US Mail: Locke Lord LLP Network Place Chicago, IL Via Courier: JPMorgan Chase 131 S. Dearborn, 6th Floor Chicago, IL ATM: Locke Lord LLP, Box #24259 Via Wire: ABA Routing: Swift Code (International: CHASUS33 Account: Bank: JPMorgan Chase Bank, N.A. 712 Main Street, Houston, TX Reference: LL Invoice Number / Matter This statement is due upon receipt. Please call W. N. Howard of this firm if you have questions concerning legal services covered by it or if you dispute the amount of the statement. Tim ( can answer questions concerning payments on your account. (Please note that this statement covers only those services and expenses described above. It does not include the unpaid balance of any prior statement.