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REP13797
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REP13797
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Last modified
8/24/2016 11:43:57 PM
Creation date
11/27/2007 1:18:46 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1981277
IBM Index Class Name
Report
Doc Date
5/11/1983
Doc Name
RESPONSE TO PLAINTIFFS OBJECTION TO BILL FOR COSTS & ATTORNEYS FEES
Media Type
D
Archive
No
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i ~ <br />second category. and responding to them required the expendi- <br />ture of a significant amount of time reviewing the record <br />and compiling the evidence that conclusively refuted those <br />aryuments. An example of this was plaintiffs• assertion <br />that the record lacked evidence of their violation of the <br />law. E.g.. "Plaintiffs' yemorandum Brief in Support of <br />Their Motion for Summary" and "Cefendants' Memorandum Brief <br />in Opposition to Plaintiffs' Motion for Summary Judgment <br />and in Further Support of Defendants' Motion for Summary <br />Judyment." When a party repeatedly and egregiously misstates <br />record facts and asserts issues for which there is no eviden- <br />tiary basis. it is incumbent upon opposing counsel to bring <br />those errors to the court's attention. Any other course of <br />conduct would disserve both one's clients and the court. <br />Had it not been for plaintiffs' many errors. this litigation <br />would nave consumed significantly less time and resources <br />of the Office of the Attorney General. <br />II. <br />THE HOURLY RATE CLAIMED BY DEFENDANTS <br />IS WELL WITHIN THE RANGE OF PREVAILING <br />RATES IN THE COMMUNITY FOR ATTORNEYS <br />OF COMPARABLE EXPERIENCE AND EXPERTISE. <br />Plaintiffs assert that the hourly rates set forth in <br />plaintiffs• bill of costs and accompanying documentation <br />-8- <br />
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