Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00452-CFD

Document 26-3

Filed 10/14/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DAVID RURAN, Plaintiff, V. BETH EL TEMPLE OF WEST HARTFORD, INC., Defendant : : : : : : : : CIVIL ACTION NO 3:03 CV 452 (CFD)

OCTOBER 14, 2004

SUPPLEMENTAL AFFIDAVIT OF ATTORNEYS' FEES The undersigned, being duly sworn, does depose and say: 1. 2. I am over the age of eighteen and believe in the obligations of an oath. I am admitted to practice law in the State of Connecticut and am currently

a partner with the law firm Madsen, Prestley & Parenteau, LLC. 3. 4. I represent the Plaintiff David Ruran in the above referenced matter. I was admitted to the Maine Bar in 1990 and the Connecticut Bar in 1992.

Since that time my practice has been focused on litigation, including employment discrimination litigation. I have handled several complex cases which have required trials of significant duration and I have handled appeals before the United States Court of Appeals for the Second Circuit. 5. At the present time, and for most of the past twelve years, over ninety

percent (90%) of my practice has been devoted to employment litigation. 6. Attached as Exhibit 1 is a bill, current through October 14, 2004,

identifying all hours expended by me, Law Intern and current law student at UCONN School of Law Todd Steigman, and paralegal Kate Demitrus in connection with researching and writing Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion to Compel.

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Case 3:03-cv-00452-CFD

Document 26-3

Filed 10/14/2004

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7.

At the present time I charge clients $300.00 per hour for my services,

$150.00 per hour for Law Intern Todd Steigman and $100.00 per hour for paralegal time. 8. The foregoing is true and accurate to the best of my knowledge and belief.

_______________________________ William G. Madsen

Subscribed and sworn to before me this 14th day of October, 2004.

___________________________

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