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In The United States District Court For The Western District of Wisconsin
In The United States District Court For The Western District of Wisconsin
I submit this declaration in support of the motion filed by the Plaintiffs for an
award of attorney fees and costs for preparing, filing, and litigating the above-captioned case.
2.
district court granted plaintiffs motion for summary judgment and the defendants did not appeal.
5.
costs and fees. In the settlement agreement (a copy of which is attached as Exh. 1), the
defendants agreed to pay $1,500,000 for plaintiffs attorneys fees and costs. Although Exhibit 1
does not bear the signatures of the defendants, it was agreed to by the parties and the defendants
1
fulfilled their obligations under its terms. As a result, plaintiffs submitted an Uncontested
Motion to Discontinue and Close Case informing the court that the parties had resolved and
settled their dispute over plaintiffs attorneys fees and that defendants have fully satisfied their
obligations, and the motion was granted by the court. (Motion and order attached as Exh. 2).
5.
attorneys from the ACLU Lesbian, Gay, Bisexual, and Transgender Project; three attorneys from
the ACLU of Pennsylvania; five attorneys from the law firm Hangley Aronchick Segal Pudlin &
Schiller; and law professor Seth Kreimer.
I declare under the penalty of perjury that the foregoing is true and correct.
DATE:
EXHIBIT 1
EXHIBIT 2