Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1 :04-cv-01488-JJF Document 93-2 Filed 08/20/2007 Page 1 of 3
‘ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBERT V. TOWNES, IV, )
Individually and on behalf of )
all persons similarly situated, )
)
Plaintiff, ) Case No. 04-1488-JJF
)
vs. )
) .
TRANS UNION, LLC and ) CLASS ACTION
TRUELINK, INC., )
)
Defendants. )
AFFIDAVIT OF CARMELLA P. KEENER, ESQUIRE
STATE OF DELAWARE )
) .ss.:
NEW CASTLE COUNTY )
CARMELLA P. KEENER, being duly sworn, deposes and says:
1. I arn a member of the Bar of the State of Delaware and the firm of Rosenthal,
Monhait & Goddess, P.A., which has served as Plaintiff s Delaware cotmsel in this
matter since August 10, 2006. I submit this Affidavit in connection with Class Counsel’s
Motion for Award of Attorneys’ Fees and Reimbursement of Reasonable Expenses, filed
contemporaneously herewith.
2. Since my firm’s entry of its appearance as Plaintiff` s counsel, my firm has
expended in excess of 18.9 hours of attorney time and in excess of $260.82 in expenses in
connection with the litigation and resolution of this matter, based on contemporaneous

Case 1:04-cv-01488-JJF Document 93-2 Filed 08/20/2007 Page 2 of 3
records kept by my firm and compiled in anticipation of the Settlement hearingl: In
recognition of my tirm’s role as Delaware counsel (as opposed to Lead Counsel), my
hourly billing rate in this matter is $350.
Time
Carmella P. Keener 18.9 @ $350 = $6,615.00
Expenses
Court Costs (PACER) $14.40
Long Distance Telephone $44.41
Photocopying $161 .40
Courier Service $38.00
Postage ` $2.61 0
I Total Expenses $260.82
C13 E. EQZQ ,1 Z,
¢ ‘ _ p
CARMELLA P. KEENER (D BA No. 2810)
SWORN TO AND SUBSCRIBED before me this 20th day of August 200]: i .
0 , il . xiii Q
CAROL Nl. SNYDER L Q/i~ Mi q//yi I g; _p_- ·-
NOTAHY Fuerte Notary Public ” 0 -79
My Commission Expires: O? ' J 7- 6 Q ii
1The time and expense figures detailed herein do not include time and expenses in
connection with the preparation and Bling of Class Counsel’s submissions in support of
the Motion for Award of Attorneys’ Fees and Reasonable Expenses or the Brief in
Support of Motion for Final Approval of Settlement, or time and expenses in connection
with the settlement hearing.
I 2

Case 1:04-cv-01488-JJF Document 93-2 Filed 08/20/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I, Carmella P. Keener, hereby certify that on this 20th day of August, 2007, I
caused the foregoing Affidavit of Cannella P. Keener, Esquire to be electronically filed
with the Clerk of` the Court using CM/ECF, which will send notification of such tiling to
the following:
William M. Lafferty, Esquire Christopher J. Curtin, Esquire
Morris, Nichols, Arsht & Tunnell, LLP Erisman & Curtin
1201 N. Market Street 629 Mt. Lebanon Road
P.O. Box 1347 Wilmington, DE 19803
Wilmington, DE 19899-1347
/s/ Carme/la P. Keener
Carmella P. Keener (DSBA No. 2810)
ROSENTHAL, MONHAIT & GODDESS, P.A.
919 Market Street, Suite 1401
q Citizens Bank Building
Wilmington, DE 19899-1070
(302) 656-4433
ckeener@,rmgglaw.com
DELA WARE COUNSEL FOR PLAIN TIF F