Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-00149-WIG Document 148-3 Filed O4/25/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
FERRON SIIORTER IR., :
Plaintiff. CASE NO. 3:{l3—cv-l49(‘i*z‘IO]
I-LQRTFORD FINANCIAL SERVICES
GROUP, ESC., :
Defendant. APRIL 25, ZUU5
CORRECTED SECOND .·*tI·`F1DAVI'I` OF RACHEL M. Bgglij
Rachel Ivi. Baird, being Erst duly stvorrt. deposes and states as follows:
I. This Aliidavit is sttbntitted in support ofthe motion for fees and costs made by Plait1tilT
Fetron Shorter Jr., by and through his undersigned counsel, inthe above-referenced matter.
2. I aliirrtt that Exhibit l to Plaintil`t`s Briefin Reply to DeI`enda.nt’s l'vIemorandum of Law
in Opposition to PlsintiH"s Motion for Attomey`s Fees and Oosts contain true and conect copies
of letters exchanged between me and representatives of The I-Lartford.
3. In reply to The Ha.rtt`ord`s citation to Baird v. Boies. Schiller & Flexner LLP, 219
F.Supp.2d Sli], {S.D.l*~l.Y. EUU2], I ailiinn that Boies, Schiller 5: Plexner LLP billed me out at
between $285.tlU and $3·Dtl-i}ti per hour while employed there from January oF2DIJt`Zl through
January of 2DDl and while assigned to casa involving the Etnfs clients Napster, Phillip Morris,
and EchoStar, for which I traveled to the Ninth Circuit Court offtppeals in San Francisco,
Richmond, Virginia, and Houston, Texas, respectively.
4. In reply to The Hartford`s assertion that I have a local practice,] assert that I have clienm
in Florida Georgia, and Ohio. l am admitted to the bars of Massachusetts and the District of
Columbia as well as Connecticut. [presently have matters pending against New York as well as

Case 3:03-cv-00149-WIG Document 148-3 Filed O4/25/2005 Page 2 of 2
iviassachusetts corporations including Berkshire Medical Center in Pittsfield, Massachusetts,
Four Winds Hospital in Saratoga Springs, New York, and The L'ieSisto School, in Stockbridge.
Massachusetts.
RAC!-1EL ht. BAIRD, being duly swom, on oath, states that she has read the foregoing Affidavit
and knows the content thereof; that the same is true of her ovm knowledge, except as to the
matter herein stated on information and beiiefaod that as to these matters she believes the same
to be true.
Sigied at Torrington, Connecticut.
Rachel M. Baird
Subscribed and sworn to before me on this 25th day of April,
.2005 .
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