Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 06-21265-CIV-SEITZIMCALILEY LEAGUE OF WOMEN VOTERS OF FLORIDA, PEOPLE ACTING FOR COMMUNITY TOGETHER, FLORIDA AFL-CIO, AMERICAN FEDERATION OF STATE AND MUNICIPAL EMPLOYEES, COUNCIL 79 (AFSCME), SEIU FLORIDA HEALTHCARE UNION, as organizations and as representatives of their members, and MARILYN WILLS, v. Plaintiffs, x DECLARATION OF AMY WEINER IN SUPPORT OF PLAINTIFFS' MOTION FOR ATTORNEYS' FEES AND COSTS KURT S. BROWNING, in his official capacity as Secretary of State for the State of Florida; and DONALD PALMER, in his official capacity as Director of the Division of Elections within the Department of State for the State of Florida, Defendants. --------------------------------------- x I, Amy Weiner, declare as follows: 1. I a a member of the bars of the States of New York and New Jersey and am an associate of the law firm of Kramer Levin Naftalis & Frankel LLP, attorneys for plaintiffs in this case; League of Women Voters of Florida ("LWVF"), SEIU Florida Healthcare Union, Florida AFL-CIO, Marilynn Wills, People Acting For Community Together ("PACT") and American Federation of State and Municipal Employees, Counsel 79 ("AFSCME"). I respectfully submit this declaration in support of plaintiffs' motion for attorneys' fees and costs. Amy Weiner's Background
Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 2 of 6 2. I received a B.A., summa cum laude, from Columbia College in 2002 and a J.D. from Harvard Law School in 2007, where I was an Arthur S. Heyman fellow and a member of the Criminal Justice Institute and the Harvard International Law Journal. I have published two 3. articles on Constitutional freedoms. One on First Amendment litigation under the Religious Land Use and Institutionalized Persons Act was published in the National Law Journal in August 2001. Another on making Miranda warnings meaningful for suspects with cognitive limitations was published in the National Association of Children's Counsel Law Manual in 2007. Additionally, before attending law school, I worked as Assistant Legislative Director of the American Jewish Committee, where I produced a report on the significance of the 2002 elections to the American Jewish community and lobbied Members of Congress regarding church-state separation, refugee policy, and abortion rights. 4. Since 2007, I have been an associate at Kramer Levin Naftalis & Frankel LLP (the "firm"), where y practice focuses on white collar defense. Amy Weiner's Attorneys' Fees Request Attached hereto as 5. Exhibit A is a true and correct statement of hours and services that I rendered in this case. I prepared the statement to the best of my personal knowledge, based upon a review of my contemporaneous records and correspondences. It is my practice to keep regular and contemporaneous records of the time I spend on litigation matters. Once this case was completed, I reviewed my contemporaneous time records, and checked them against the time records of co-counsel, and made adjustments as appropriate in the exercise of ordinary billing judgment. 6. I believe that the hours that I am claiming are reasonable and do not 2
Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 3 of 6 duplicate the work of co-counsel. As my time records indicate, I researched plaintiffs' entitlement to attorneys' fees and costs, drafted the instant motion for fees and costs, drafted the several attorneys' declarations, and prepared their accompanying exhibits. 7. The hourly rate that I am seeking ($300.00) is consistent with the rate of attorneys who have comparable qualifications and experience in the Florida market, which is the appropriate lodestar rate given my expertise in this area. 8. After exercising billing judgment, I seek compensation in the amount of $7,470.00 for a significantly reduced 24.9 hours that I worked on this case. 9. I certify that I have fully reviewed my time records and supporting data and my request is well grounded in fact and justified. 3
Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 4 of 6 I declare under penalty of perjury that the foregoing is true and correct. Executed at 14a-',oAL, 1 j' f, on June 90, 2008. Amy Weiner 4
Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 5 of 6 Exhibit A
Case 1:06-cv-21265-PAS Document 86-7 Entered on FLSD Docket 06/20/2008 Page 6 of 6 Amy Weiner Adjusted and Reduced Hours League of Women Voters of Florida v. Browning -,DATA Q RS DESCRIPTION 4/1/2008 7.4 Research case law on motions for attorney fees. 4/2/2008 0.6 Research fee affidavits and mootness 517/2008 0.6 Meet with Craig Siegel and paralegal 5/13/2008 3.6 Revise draft motion for attorneys' fees and research "special circumstances" and relative importance of Johnson factors. 5/14/2008 3.9 _Research attorney fee cases in the Southern District of Florida 5/15/2008 4.4 research section 1988 cases decided by FL district courts 5/19/2008 0.3 Assemble list of documents needed for motion 5/20/2008 1.7 review cases on reimbursable costs and cases forwarded by Craig Siegel. 5/29/2008 2.4 Research L.R. 7.3, interpretive case law, and post-sole case law TOTAL = 24.9 This document does not include any time or costs incurred for plaintiffs' application for an award of attorneys' fees and costs after May 31, 2008. Plaintiffs reserve the right to supplement their application to seek reimbursement for their time and costs incurred after May 31, 2008. 1