Free Declaration - District Court of Delaware - Delaware

Case 1 :06-mc—OO203-***-IVIPT Document 37 Filed O3/06/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
KENTUCKY SPEEDWAY, LLC :
Plaintiff,
vs. Misc. No. 06-203 (KAJ)
NATIONAL ASSOCIATION FOR STOCK
CAR AUTO RACING, INC., et al. :
Defendants.
DECLARATION OF JOHN M. SEAMAN
REGARDING ATTORNEYS’ FEES INCURRED IN RESPONDING TO
DOVER MOTORSPORTS 1NC.’S MOTION FOR SANCTIONS
STATE OF DELAWARE )
COUNTY OF NEW CASTLE g SS.
1. I am an associate at the firm of Bouchard Margules & Friedlander, P.A. I
submit this Declaration in Support of Plaintiff Kentucky Speedway, LLC’s (“Kentucky")
application for sanctions incurred in responding to Dover Motorsports Inc.’s ("Dover")
application for attorneys’ fees incurred in responding to Kentucky’s subpoenas. (D.I. 29)
2. Kentucky seeks an award of its attorneys’ fees incurred in responding to
Dover’s application for sanctions against Kentucky for issuing two Delaware subpoenas
and for responding to the motions as ordered and granted by the Court (the "Dover Fee
Application”).
3. I make this declaration setting out for the Court the attomeys’ fees that
Kentucky has incurred in responding to Dover’s Fee Application. The hours spent and
rates set forth are based upon the time records and bills of my Emi Bouchard Margules &
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Case 1:06-mc-OO203—***—lV|PT Document 37 Filed O3/06/2007 Page 2 of 2
Friedlander, P.A. ("BMF"), and my co-counsel’s firm, Susman Godfrey, LLP ("SG"),
which are accurate to the best of my knowledge, information and belief.
4. SG Fees — 8.0 hours of attorney associate time at $400 per hour for Justin
Nelson, and 1.0 hour of attorney associate time at $3 00 per hour for John M. Neukom.
5. BMF Fees — 2.75 hours of attorney associate time at $300 per hour for
John M. Seaman.
g John M. Seagan
S\yvomft·o and Sl.ii`_l cribgyefore me this
6th\da ` of March 200- . _ li JULIE L. FIELDER
-, , · _ _ * y x_ _i_ ST§_g£Tg§EPusLrc
- `T ELAWARE
Nvtar Public My Commission Expires Dec. 9, 2008
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