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

Case 3:03-cv-00149-WIG Document 147-4 Filed O4/22/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
FERROBE SI-IORTER IR., :
Plaintiff`, CASE NO. 3:t}3-cv-149(WIO}
FLARTFORD FITQANCIAL SERVICES
GROUP. ThiC.. :
Defendant. APRII. 22, 2tJt}5
QECOND AFI·`IDAVIT QF RACHEL M. BAIRD
Rachel M. Baird, being first duly sworn, deposes and states as follows:
1. "this Affidavit is submitted in support ofthe motion for fees and costs made by Plaintiff
Ferron Shorter Jr., by and through his undersigned counsel, in the above-referenced maner.
2. I aiiirrn that Exhibit 1 to Plaintiffs Briefin Reply to Defendant’s Memorandum of Law
in Opposition to Plaintiff s Motion for Anomcy’s Fees and Costs contain true and correct copies
of letters exchanged between me and representatives of The Hartford.
3. In reply to The Hart:ford`s citation to Baird v. Boim. Schiller & Flcxner LLP, 219
F.Sapp.2d SIU. {S.D.N.Y. 2t]U2]. I affirm that Boies, Schiller dt iilexner LLP billed me out at
between $285.00 and $3Dt].t]·[l per hour while employed there frorrr January of 2t]DlJ through
January of EDU] and while assigned to casa involving the tirm’s clients Napster, Phillip Zvlorris,
and EchoStar, for which I naveled tn the Ninth Circuit Court of Appeals in San Francisco.
Richmond, Virginia, and Houston, Texas. respectively.
-1. in reply to The H,artt"ord`s assertion that I have a local practice, 1 assert that I have clients
in Florida, Georgia, and Ohio. l am admitted to the bars ol` lviassachusens and the District of
Colurnhia as welt as Connecticut. I presently have matters pending against New York as wcl.l as

Case 3:03-cv-00149-WIG Document 147-4 Filed O4/22/2005 Page 2 of 2
Tviassachusetts corporations including Berkshire Medica] Center in Pittslield, Massachusetts,
Four Winds Hospital in Saratoga Springs, New York, and The DeSisto School, in Stockbridge,
Massachttsetts.
RACI-TEL BAIRD, being duly sworn, on oath, statm that she is the Afiiant herein; that she has
read the foregoing Affidavit and knows the content thereof; that the same is true ot` her own
knowledge, except as to the matter herein stated on it1f`ot‘rnaLion and belief and that as to these
matters she beiieves the same to be true.
Dated at Torringttoit, CT
tf h *tili
Rachel M. rd
Subscribed and svnom to before me on this 11d day of February, 2{K}5-
Y .i._ _
J¤ ` an ,F.—---.1
• to `4*’¤" er ofthe Superior Court `
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