Free Declaration - District Court of Delaware - Delaware

Case 1 :96-cv-00525-JJF Document 214 Filed 11/1 1/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GERALD LEVINE, individually and :
on behalf of all others similarly :
situated, i
Piamurr, E
v5_ CIVIL ACTION
: NO. 95-690 JJF
METAL RECOVERY TECHNOLOGIES, :
INC., formerly known as :
MALVY TECHNOLOGY, INC., :
J. STEPHEN SMITH, ROY PEARCE, :
WILLIAM M. GREENWOOD, and :
MICHAEL LUCAS, :
Defendants.
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GERALD LEVINE, individually and :
on behalf of all others similarly :
situated, :
Piaimirr, Z
vs. CIVIL ACTION
: NO. 96-525 JJF
METAL RECOVERY TECHNOLOGIES, INC., :
et al. :
Defendants.
DECLARATION OF NORMAN M. MONHAIT, ESQUIRE
IN SUPPORT OF JOINT PETITION FOR ATTORNEYS’ FEES
AND REIMBURSEMENT OF EXPENSES
I, NORMAN M. MONHAIT, declare as follows:
1. I am a member ofthe Delaware bar and ofRosenthal Monhait Gross & Goddess, P.A.,
Delaware counsel for the plaintiff in this action. I make this declaration in support ofthe application

Case 1:96-cv-00525-JJF Document 214 Filed 11/11/2005 Page 2 of 4
of plaintiff’ s counsel for an award of attomeys’ fees for services rendered to the Class in this
litigation, and for reimbursement of expenses reasonably incurred in the course of such
representation.
2. My firm’s compensation for the services rendered in this matter is wholly contingent.
Any fees and reimbursement of expenses will be limited to such amount as the Court may award.
3. My services in this matter subsequent to May 2000 have included communications
regarding discovery, motions, and settlement; reviewing and revising drafts of and tiling notices,
motions, memoranda, and status reports; preparation and filing of deposition notices; and
consultation with other plaintiffs’ counsel regarding litigation strategy.
4. During the period from June 2000 to date, my work on this matter encompassed 16.5
hours. The lodestar value of that time is $5,775.00 at my current hourly rate of $350.00. I have
reviewed my time records and believe that this time is appropriate and reasonably incurred in
prosecuting this matter.
5. From June 2000 to the present, my firm paid or incurred unreimbursed expenses in the
total of $542.07. Those expenses were reasonably and necessarily incurred in connection with this
litigation, and are comprised of:
Courier Service $ 16.50
Facsimile 36.70
Photocopying 397.50
Postage 86.67
Telephone 4.70
Total Expenses $542.07
The above listed expenses incurred are reflected on the books and records of my law firm, which are
regularly kept and maintained in the course of our practice and accurately reflect the expenses
incurred.
6. The hourly rate set forth above is my usual and customary hourly rate charged for work
performed for non—contingent fee paying clients.
2

Case 1:96-cv-00525-JJF Document 214 Filed 11/11/2005 Page 3 of 4
7. I make this declaration on November 1 l, 2005 in Wilmington, Delaware, subject to the
penalties for perjury provided by law.
Nonnan M. Monhait (#1040)
3

Case 1:96-cv-00525-JJF Document 214 Filed 11/11/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1 1"‘ day of November, 2005, a copy of Declaration
Of Norman M. Monhait, Esquire In Support Of Joint Petition For Att0rneys’ Fees And
Reimbursement Of Expenses was served electronically upon:
Joanne P. Pinckney, Esquire
Bouchard Margules & Friedlander, P.A.
222 Delaware Avenue, Suite 1400
Wilmington, Delaware 19899
and a copy was served by first class mail, postage prepaid, upon the following:
Barron Chase Securities
7700 West Camino Real
Suite 200
Boca Raton, Florida 33433
Raymond L. Robin, Esquire Mr. Jack Alexander
Olle Macaulay & Zorrilla, P.A. Hog Town Road
Suite 2200 Mulbeny, AZ 72947
One S.E. Third Avenue
Miami, Florida 33131-1716 Brian D. Graifman, Esquire
Gusrae Kaplan & Bmno
120 Wall Street
Mr. William M. Greenwood New York, New York 10005
Pro Se
10620 Bethany Drive David B. Simpson, Esquire
Aurora, Colorado 80014 Stein Simpson & Rosen, P.A.
Suite 109, Two University Plaza
Mr. Gary Salter Hackensack, NJ 07601-6202
c/o Sheldon Skryzlo, Esquire
210 Dundas Street West David S. Mandel, Esquire
Toronto, ON M5G 2E8 Mandel & McAliley
Canada 1200 Alfred I. DuPont Building
169 East Flagler Street
/ Miami, FL 33131
0//my W7%n/
Norman M. Monhait (# 1040)
ROSENTHAL MONHAIT GROSS
& GODDESS, P.A.
919 Market Street, Suite 1401
Citizens Bank center
P.O. Box 1070
Wilmington, Delaware 19899
(302) 656-4433
Email: [email protected]