(1)I believe that the $400.00 per hour rate is reasonable given the results achieved and Tom Wieder’s experience and standing in the legal community;

(2)recall that in the Neal versus Michigan Department of Corrections case, the Washtenaw County Circuit Court awarded the prevailing plaintiffs a rate equivalent to approximately $900.00 per hour ($28 million for 31,000 hours of work) – so Mr. Wieder’s submitted hourly rate herein appear bargain-basement by that comparison;

(3) Mr. Dascola will be the beneficiary of the attorney-fees-on-attorney-fees theory recognized with respect to statutory fee awards that allows recovery for legal fees incurred in actually litigating the very issue of the attorney fee award;

(4)in the event that City Attorney Postema does contest the reasonableness of the hours or the hourly rate being claimed, Judge Zatkoff will likely order an evidentiary hearing in which both sides can present proofs on these issues so that a final liquidated award of attorney fees and costs may be entered against the City of Ann Arbor – as a practical matter very few of these evidentiary hearings occur in the practice of law due to the attorney-fees-on-attorney-fees theory enunciated above, and also the fact plaintiffs want to avoid the risk the judge may give a low cost and fee award;

(5)Mr. Dascola filed his action under the Federal Civil Rights Act of 1871(42 USC 1983), which was a post-Civil War Act of Congress that was primarily intended to give freed slaves a legal mechanism to enforce denials of their constitutional rights via monetary damage and injunctive relief within the United States District Court system.