Township Council Meeting — Agenda

MRS L 000300-20 05/22/2020 Pg 12 of 16 Trans ID: LCV2020932426 Order to Show Cause to induce compliance, not knowing if or when Defendants would produce this record. Had Plaintiff not commenced the instant litigation, it is unknown whether Defendants would provided her with the BWC footage within the time under the statute of limitations. , having founded and authored several OPRA-related articles, so it is unlikely that the instant matter presented novel or complex elements counsel would have been unfamiliar with. See Griffin Cert. ¶¶ 14, 24-27. This was a relatively simple and straightforward OPRA matter that did not raise particularly difficult legal questions or substantive issues. Indeed, prior to filing the OPRA complaint, Plaintiff had already compelled Defendants to produce the dash camera footage, leaving only the matter of the BWC footage to be resolved. Regarding the second factor of RPC 1.5(a)(2), Plaintiff counsel was not precluded from pursuing other matters on behalf of Plaintiff or other clients while preparing for the instant litigation. this case was prioritized because OPRA that there had to be schedule adjustments and that the firm had to accommodate . Id. ¶ 29. As s counsel normally bills $565.00 per hour, but that this rate is routinely discounted to $500.00 per hour for OPRA matters as a courtesy to the government agency. Id. ¶ 32 that this rate is reasonable for what large law firms in northern New Jersey charge for skilled OPRA litigators. Ibid. Plai that OPRA fees ranging from $450.00 to $524.00 per hour were reasonable rates. Id. ¶¶ 33-34. 12 Pa053