Full opinion text
ORDER JAMES C. FOX, District Judge. This matter is before the Court on plaintiff’s application for an award of reasonable attorney’s fees as the prevailing party under the Civil Rights Attorney’s Fees Awards Act of 1976, 42 U.S.C. § 1988. Plaintiff’s counsel have filed extensive affidavits requesting compensation for a total of 2,087.60 hours of time, worth, in their estimation, $240,350.00. This lodestar figure, they propose, should then be increased by a discretionary multiplier in recognition of what they contend to be the extraordinary risks associated with the contingent nature of this case and the superior performance of counsel as well as the exceptional result. In addition, plaintiff seeks costs totalling $19,741.90. For the reasons that follow, a substantial fee is clearly mandated and, under the circumstances of this litigation, a significant multiplier is warranted. Defendants, in their opposition to plaintiff’s request, challenge 932.8 of counsel’s hours on a variety of broad-based as well as line-item grounds. These objections, well over two hundred (200) in number, can somewhat be categorized into the following arguments: 1. a portion of the fee petition seeks compensation for time and effort spent on unsuccessful claims and motions; 2. plaintiff’s documentation is inadequate or inaccurate; 3. the use of multiple counsel resulted in a substantial and unnecessary duplication of effort; 4. a number of hours claimed were excessive, unwarranted and unreasonable; 5. attorneys were unreasonably used to perform paralegal and clerical tasks; 6. most of the costs requested are not properly recoverable; and 7. a multiplier is not justified. Each argument will be addressed in detail in this opinion. However, at the outset, the Court feels it imperative to set forth the principles which it finds must govern its fee petition analysis. I. BASIC PRINCIPLES OF FEE PETITION ANALYSIS In resolving the issues raised by plaintiff’s application and defendants’ objections thereto, the Court is caught between several competing concerns. The Court must, of course, be supplied with sufficient information from which it can determine a reasonable and equitable fee. Counsel for plaintiff clearly bear the burden of documenting and submitting evidence to support their claim of hours and costs expended in the litigation, as well as hourly rates and enhancement requested. Hensley v. Eckerhart, 461 U.S. 424, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983). Although fee applications come in all shapes and sizes, there is a definite minimum of documentation required to substantiate counsel’s claims before the court can act on the application. It is not the Court’s goal to describe that minimum at this point in the opinion—that comes later—only to establish the existence of the requirement and its purpose, which is to provide the defendants with the opportunity to meaningfully scrutinize the reasonableness of the award requested and to present any legitimate objections. National Association of Concerned Veterans v. Secretary of Defense, 675 F.2d 1319, 1324 (D.C.Cir.1982). By the same token, the party opposing the application must submit specific and detailed objections. Just as the fee applicant cannot submit a conclusory application, an opposing party does not meet its burden by simply asserting broad challenges to the petition. Id. at 1338 (Tamm, J., concurring). Evidence must be submitted in support of any assault on the application and the more extensive the attack, the more evidence required. The problem district courts now face, as in the case sub judice, is how to avoid allowing fee applications to assume massive proportions, thereby dwarfing the underlying litigation on the merits. Laffey v. Northwest Airlines, Inc., 572 F.Supp. 354, 389 (D.D.C.1983), reversed in part, 746 F.2d 4 (D.C.Cir.1984). See also Copeland v. Marshall, 641 F.2d 880, 896 (D.C.Cir. 1980) (en banc). The Supreme Court has admonished the lower courts that “request[s] for attorney’s fees should not result in a second major litigation,” Hensley v. Eckerhart, 103 S.Ct. at 1941, yet this Court finds it almost impossible to “avoid becoming ensnared in the minute details of the professional relationship under scrutiny [while at the same time insisting] upon specific documentation for every component of the fee award.” Laffey, 572 F.Supp. at 389. The Supreme Court’s admonishment is extremely difficult to effectuate given that Court and the Courts of Appeals’ increasing insistence upon detailed supporting documentation by the parties and findings by the district court— “ironically, in conjunction with judgments that are conceded to be uniquely within the capacity of the trial court and that are theoretically committed to its discretion____” Id. See also Laffey, 746 F.2d at 31 and 39 (Wright, J., dissenting). In resolving this conflict between requiring detail and exercising well-informed discretion, this Court, where it is necessary in this opinion, chooses the latter. The Court has been involved continually with this action since its filing in January of 1984, having witnessed or reviewed the conduct of nearly the entire case. Numerous pre and post-trial hearings on motions were held by Magistrate Dixon, with whom the Court has been in constant communication throughout the litigation. In addition, at this Court’s order, the Magistrate conducted extremely extensive and exhaustive pretrial conferences and hearings. The Magistrate’s pre-trial efforts not only assisted in providing the parties an equitable and expeditious trial, but also allowed the Court to gain a tremendous amount of knowledge about the complex evidentiary and factual issues in the case prior to the commencement of trial. Furthermore, the court’s resident law clerk in Fayetteville has maintained, by necessity, almost daily contact with the parties since December of 1984. The Court has taken the time to recite this background to establish the depth of the Court’s involvement in this litigation and its knowledge of counsel who tried the case. With this background in mind, the Court approaches plaintiff’s fee petition and defendants’ objections with the firm intention of not allowing its inquiry to assume “massive proportions” or “result in a second major litigation.” In this regard, the Court has previously determined that an evidentiary hearing was unnecessary to resolve defendants’ objections. Order of May 28, 1985. Given the Court’s intimate knowledge of this case, the depth of the briefing on plaintiff’s fee petition, the detail of plaintiff’s verified motion and affidavits, the extensiveness of the written record, the submission for in camera review of counsel for plaintiff’s contemporaneous and original time logs, this court’s knowledge of the quality of plaintiff’s counsels’ performance throughout this litigation, and the fact that defendants have submitted little or no credible evidence in support of their objections, the Court is confident that the decisions rendered herein are well-founded. The result is an adequate fee award for plaintiff’s counsel and one which does not unfairly or unjustly burden the defendants. In exercising its discretion in certain areas and refusing to rule independently on each and every line-item objection tendered by defendants, the Court is not abdicating its function to fully explore the merits of plaintiff’s fee petition; rather, it is simply performing its task in a manner it feels is economical for the judicial system, which has already devoted extraordinary amounts of time to this litigation, and proeedurally fair to both parties. Before the Court proceeds to address defendants’ objections, a review of this litigation is in order as a preface to the discussions which follow: II. BACKGROUND Plaintiff initiated this action pursuant to 42 U.S.C. § 1983 by complaint filed January 26, 1984. The complaint, as amended, alleged that on November 19, 1983, plaintiff was arrested by defendant McDaniel in Fayetteville, North Carolina, for driving while impaired and possession of a controlled substance. McDaniel transported Spell to the Law Enforcement Center (LEC) for breathalyzer testing and arrest procedures. Upon completion of the breathalyzer examination, Spell alleged that while handcuffed, he was removed to the Fayetteville Police Department (F.P.D.) Assembly Room, whereupon McDaniel, without justification or provocation, assaulted Spell by striking him with his hands and by kneeing him in the testicles with such force that plaintiff suffered permanent loss of his right testicle. Spell contended he was rendered irreversibly sterile as a result of McDaniel’s actions. Plaintiff further alleged that McDaniel’s actions were in furtherance of and under color of the official policy, practice, custom and procedure of the F.P.D. See Monell v. Department of Social Services, 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). Plaintiff set forth a number of allegations against the supervisory defendants, Dalton, Holman, Johnson, Dixon and Smith, and the City to support the above contention, including: 1. Knowledge of defendants, prior to the November 19, 1983, incident, of repeated claims and instances of police abuse and assaultive conduct toward detainees and arrestees; 2. Prior knowledge of similar allegations of abuse against McDaniel; 3. Establishment and enforcement of a quota system for arrests and citations, thereby condoning unlawful and abusive arrests and detentions; 4. Refusal to competently investigate allegations of abuse and assault filed against members of the F.P.D.; 5. Cover-up of acts of misconduct and abuse by police officers; 6. Failure to adequately train police officers in the use of reasonable force; 7. Failure to adequately supervise the actions of police officers; and 8. Rewarding officers who displayed overly aggressive and abusive behavior, while threatening and reprimanding those officers who reported acts of misconduct. Plaintiff claimed these policies, practices, customs and procedures directly and proximately resulted in defendant McDaniel’s brutal assault upon Spell. Plaintiff predicated his action upon a deprivation of his constitutional rights substantively secured by the Fourth, Eighth and Fourteenth Amendments. Specifically, Spell asserted that defendants’ tortious conduct rose to constitutional significance, and was therefore cognizable under § 1983, on four independent substantive grounds, including (1) the right of physical integrity, to be free from unlawful detention and to be properly cared for and treated as secured by the substantive due process provisions of the Fourteenth Amendment and (2) the right to be secure against unreasonable seizures as secured by the Fourth Amendment. Defendants answered, denying all substantive allegations and advanced omnibus motions early in the litigation. In March of 1984, all defendants moved to dismiss, contending (1) lack of jurisdiction over the person; (2) lack of jurisdiction over the subject matter; (3) plaintiff's complaint was conclusory and lacked sufficient factual allegations; (4) plaintiff’s allegations failed to state any cognizable claim for relief under § 1983; (5) plaintiff’s claims amounted to mere tortious conduct for assault and battery; and (6) Parratt v. Taylor, 451 U.S. 527, 101 S.Ct. 1908, 68 L.Ed.2d 420 (1981) barred the action. In addition, defendants raised a host of affirmative defenses including absolute immunity and good faith immunity. Finally, defendants Holman and Johnson moved at this same time for summary judgment and the City moved to strike plaintiff’s claim for punitive damages. Extensive and competent briefing accompanied these motions as well as a motion by plaintiff to compel discovery. With the exception of one minor item requested by plaintiff, defendants refused to voluntarily comply with any of Spell’s request for discovery, thus necessitating plaintiff’s motion. This Court thoroughly reviewed the above delineated motions for four months before issuing a 73-page written memorandum opinion and order on July 11, 1984. All of defendants’ motions were denied, except the motion of defendant City to dismiss plaintiff’s prayer for punitive damages against the City, and plaintiff’s motion to compel discovery was granted with an accompanying protective order. During the next few months, defendants complied with the Court’s order and over 14,000 internal documents were disclosed to the plaintiff. Plaintiff and defendants exchanged discovery with a maximum of effort and a minimum of further motions. The litigation was calendared for pre-trial and trial, while the Court began the process of scheduling final motions and the submission of pre-trial materials. However, as trial drew nearer, disputes between counsel grew and a number of motions concerning discovery and witnesses were filed. The motions generally were briefed, with two of them requiring argument before Magistrate Dixon. Between November 1,1984, and January 1,1985, the Magistrate issued eight (8) orders, attempting to resolve all pending areas of contention. One of the motions filed by plaintiff requested a protective order for plaintiff’s police witnesses due to potential problems of intimidation. Although the Magistrate denied plaintiff’s motion and found no evidence of intimidation, given the background and circumstances of this case, the Magistrate ordered the scheduled depositions of these witnesses to be held at the courthouse (1) so as to remove any perception or appearance of harassment or intimidation, whether real or imagined by the witnesses, and (2) to allow the Magistrate to timely rule on any objections by counsel or the witnesses at the deposition. Defendants appealed this order and the Court affirmed the Magistrate’s ruling. Subsequently, defendants cancelled the scheduled depositions. During this period of time, the Court became aware that this litigation would require an extraordinary pre-trial workup in order to ensure an equitable and expeditious trial. Accordingly, the Court directed the Magistrate to pre-try the case as extensively as the law would allow under F.R.Civ.P. 16. On January 14, 1985, the pre-trial hearing commenced. It lasted three days with the third day consuming nearly eleven hours in court. Defendants filed, pre-hearing, motions to suppress and exclude much of plaintiffs proposed evidence, while plaintiff moved to exclude his prior convictions and a limited number of defendants’ documents. With his staff working around the clock, a 55 page order was issued by the Magistrate on January 21, discussing all of the pending pretrial motions, plus a number of procedural questions raised by this Court. The Magistrate denied an overwhelming majority of defendants’ motions and found frivolous a significant number of late objections interposed by defendants to plaintiff’s proposed exhibits. Defendants appealed the Magistrate’s order and this Court affirmed the same with a few minor modifications. Trial in this action began on January 25, 1985. Counsel for plaintiff were Messrs. Beaver, Thompson and Richardson. Counsel for defendants were Messrs. Barring-ton, Cogswell & Deaver. Plaintiff presented twenty-seven (27) witnesses at trial, all tending to prove either the assault in question or a pattern of misconduct within the F.P.D. Included within the twenty-seven were seven (7) lay citizens of Fayetteville, eight (8) present and former police officers of the F.P.D., an assistant district attorney from Fayetteville, plaintiff’s treating physician, his former attorney, an expert in police civil liability and the former police attorney, all of whom testified in support of plaintiff’s allegations regarding (1) the assault on November 19, 1983, or (2) the existence of a defacto policy, practice and custom within the F.P.D. of brutality, cover-up and misconduct. In addition, plaintiff introduced hundreds of documents contained in two exhibit notebooks, many of the exhibits being internal F.P.D. documents obtained through discovery. These exhibits were properly offered by plaintiff to establish his major allegations of an unconstitutional quota system for arrest, failure to discipline officers, failure to investigate citizens’ complaints, failure to supervise officers, cover-up of police misconduct and repeated acts of excessive force and brutality. Defendants presented fourteen (14) witnesses, including three (3) of the defendants, two (2) present police officers and two (2) experts in the area of police civil liability, all offered to prove that the McDaniel assault never occurred, that plaintiff suffered his injury earlier in the day when he allegedly fell on a rock or log at a nearby riverbank, and that, in fact, no policy, practice, custom or procedure of misconduct existed within the F.P.D. In addition, defendants, like plaintiff, introduced hundreds of documents to support their position, with a particular emphasis on the issue of the adequacy of training within the F.P.D. The trial lasted eighteen (18) days. It was extremely hard-fought and emotional. The tension level in the courtroom was continually high. Local and state press coverage was extensive. Both parties submitted detailed requests for jury instructions, including a number of cautionary instructions during trial. Two issues of liability were submitted to the jury; first, whether defendant McDaniel assaulted the plaintiff by kneeing him in the testicles proximately causing plaintiff’s injury and second, whether the assault by McDaniel proximately resulted from a de facto policy, custom or practice developed or maintained by the supervisory defendants, or of which they reasonably should have been aware, and as a result of which, the supervisory defendants’ actions or omissions amounted to gross negligence or deliberate indifference to the constitutional rights of others. Two issues on damages were also submitted, one for compensatory damages and one for punitive damages. The case went to the jury on Monday, February 18, 1985, and thirteen (13) working hours later, on Wednesday, February 20, 1985, the jury returned its verdict. The jury found defendants McDaniel, Dalton, Holman, Dixon, Johnson, and through these official supervisory defendants, the City of Fayetteville, liable for violating plaintiff’s constitutional rights and assessed compensatory damages at one thousand dollars ($1,000). The jury assessed no punitive damages and also found in favor of defendant Smith—on liability. As a result of the jury’s verdict, the parties filed numerous post-trial motions, including defendants’ motions for judgment notwithstanding the verdict and for a new trial, as well as plaintiff’s motion for a new trial solely on the issue of compensatory damages. All issues were fully briefed and oral argument was heard in Wilmington on March 5, 1985. On March 12, 1985, the Court issued a memorandum opinion denying defendants’ motions and granting plaintiffs motion. The Court held that (1) the jury instructions as given were correct and in accordance with law; (2) evidence in support of the jury’s verdict on liability was substantial; (3) the jury award was grossly inadequate and would shock the conscience of the Court were it allowed to stand; (4) the totality of the circumstances did not clearly and substantially point to a compromise verdict; and (5) a new trial on the issue of compensatory damages was mandated. In this order, the Court made clear the new trial would be “solely and strictly limited to the narrow issue of how much money will fairly and adequately compensate plaintiff for his damages.” Order at 26. The Court informed counsel that the second jury would be “instructed to accept as fact that defendant McDaniel kneed plaintiff in the testicles on November 19, 1983, proximately causing his injuries.. ” Id. Again, the litigation was referred to Magistrate Dixon for a comprehensive pretrial conference and hearing, which was subsequently held in Wilmington on March 21, 1985. Prior to that hearing, the parties submitted pre-trial contentions and a proposed pre-trial order. Defendants contended that neither the Order of March 12, 1985, nor the jury verdict as to liability precluded them from presenting evidence to establish that: (1) any injury suffered by plaintiff to his right testicle occurred prior to his arrest on November 19, or after he was placed in jail; (2) McDaniel’s actions did not proximately cause the rupturing of plaintiff’s testicle or his sterility; (3) plaintiff was not entitled to recover any compensatory damages from the defendants; (4) McDaniel never committed any act that caused any injury to plaintiff; and (5) even if McDaniel assaulted plaintiff, the force used was reasonable. Plaintiff moved in limine to bar evidence at the second trial on the above contentions and for F.R.Civ.P. 11 sanctions for the interposing of frivolous defenses. The Magistrate in his 34 page order of March 26, 1985, granted plaintiff's motion and scheduled a hearing on sanctions for a date after the second trial. The Magistrate further granted plaintiff’s motion to exclude evidence of his prior convictions for the second trial. Defendants appealed Magistrate Dixon’s order and on April 1, 1985, this Court affirmed the Magistrate’s order with the exception of his ruling on plaintiff’s prior convictions. The Court determined that, with proper restrictions placed on defendants’ inquiry into plaintiff’s convictions, said inquiry should be allowed because the probative value of the evidence, as those convictions related to plaintiff’s credibility, was not substantially outweighed by the danger of unfair prejudice. F.R.Evid. 403. The second trial commenced on April 2, 1985, in Wilmington. Trial lasted less than two days with plaintiff presenting three witnesses, including two physicians, and introducing a number of documents, all tending to prove plaintiff’s intense pain and suffering. Defendants presented two witnesses, including defendant McDaniel, attempting to establish the limited nature of plaintiff’s pain, suffering and mental anguish. The jury deliberated less than three hours and on April 4, 1985, returned a $900,000 verdict on the sole issue of compensatory damages. Judgment was entered accordingly by the Clerk of Court. Defendants immediately filed post-trial motions for judgment notwithstanding the verdict and for a new trial. Both sides briefed the issues and upon a review of these submissions, defendants’ motions were denied by order filed April 18, 1985, with the Court finding substantial evidence to support the verdict. Subsequent to the April 4 verdict, Magistrate Dixon conducted a hearing on the issue raised by plaintiff of defendants’ frivolous pre-trial contentions. The Magistrate found that most of defendants’ contentions for the second trial were unjustified and unwarranted under any objective view of the facts and applicable law. Attorney’s fees in the amount of $652.50 were awarded to plaintiff’s counsel for time spent in pursuing their motion to exclude evidence on defendants’ claims. Defendants appealed the Magistrate’s order and this Court affirmed by opinion filed May 29, 1985. Defendants have noted their appeal of the $900,000 Judgment to the Fourth Circuit Court of Appeals and a stay of any proceedings to enforce judgment has been granted pending appeal pursuant to F.R.Civ.P. 62(d). See Order of May 29, 1985. Final fee petition supplements and objections have been filed and plaintiff’s application is now ripe for disposition. The Court will now proceed to consider seriatim defendants’ objections and contentions heretofore summarized. III. THE CIVIL RIGHTS ATTORNEY’S FEES AWARD ACT OF 1976 The Civil Rights Attorney’s Fees Awards Act (the Act) of 1976, 42 U.S.C. § 1988, provides in relevant part that: In any action or proceeding to enforce a provision of [Section 1983], the court, in its discretion, may allow the prevailing party... a reasonable attorney’s fee as part of the costs. The statute thus confers power on the courts to award attorney’s fees as part of “costs” to parties who prevail in civil rights actions. The underlying concept behind the Act is a departure from the traditional American Rule, which requires that each party in a lawsuit ordinarily bear its own costs of litigation. Explicitly reacting to the Supreme Court’s decision in Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240, 95 S.Ct. 1612, 44 L.Ed.2d 141 (1978), wherein the Court limited the private attorney general doctrine to situations in which Congress had expressly authorized an award of attorney’s fees, Congress enacted the Act in 1976 to achieve consistency in the application of civil rights laws. S.Rep. No. 1011, 94th Cong., 2d Sess. 1, reprinted in 1976 U.S.Code Cong. & Ad.News, 5908, 5909. The purpose of § 1988 is to ensure meaningful and effective access to the judicial system for persons with civil rights grievances so that they may act as private attorneys general and vigorously enforce the civil rights laws. Hensley v. Eckerhart, 103 S.Ct. at 1937. Accordingly, a prevailing plaintiff “should ordinarily recover an attorney’s fee unless special circumstances would render such an award unjust.” Id. quoting S.Rep. No. 1011 at 4, U.S.Code Cong. & Ad.News at 5912. The initial question in ruling on any petition for fees, therefore, is whether the fee applicant qualifies for a § 1988 award by meeting the “prevailing party” requirement. A. Plaintiff as the Prevailing Party This issue is governed by the Supreme Court’s decision in Hensley v. Eckerhart, supra, in which the appropriate test is set forth in the following language: A plaintiff must be a “prevailing party” to recover an attorney’s fee under § 1988. The standard for making this threshold determination has been framed in various ways. A typical formulation is that “plaintiffs may be considered ‘prevailing parties’ for attorney’s fees purposes if they succeed on any significant issue in the litigation which achieves some of the benefit the parties sought in bringing suit.” Nadeau v. Helgemoe, 581 F.2d 275, 278-79 (CA 1 1978). This is a generous formulation that brings the plaintiff only across the statutory threshold. It remains for the district court to determine what fee is “reasonable.” 103 S.Ct. at 1939 (footnotes omitted). Thus, a plaintiff is a prevailing party if he or she succeeds on “any significant issue... which achieves some of the benefit the parties sought in bringing suit.” Id. (emphasis added). It is not necessary that a plaintiff succeed on all the significant issues, or that the Court award all of the monetary, declaratory or injunctive relief sought in the complaint. Fast v. School District of City of Ladue, 728 F.2d 1030, 1033 (8th Cir.1984) (en banc). The fact that plaintiff did not prevail on every theory espoused in his complaint against every defendant sued for every dollar requested does not preclude an award of fees in this action. Any argument to the contrary is without merit as plaintiff’s $900,000 verdict against all defendants except Smith easily meets the Hensley standard. In point of fact, plaintiff prevailed on nearly all the significant issues in this litigation. Accordingly, this Court finds that plaintiff is the “prevailing party” under 42 U.S.C. § 1988 and, as such, is entitled to an award of reasonable attorney’s fees absent special circumstances prohibiting the same. B. No Special Circumstances Bar Losing defendants in civil rights cases have urged upon the lower courts a variety of considerations as “special circumstances” warranting the denial or limitation of § 1988 fee awards. In the case sub judice, defendants argue or imply that the fee award should be reduced or limited by the following considerations. First, throughout this litigation, defendants have urged upon the Court various creative applications of the doctrines of qualified and absolute immunity. To the extent that argument remains alive for purposes of a fee award, the Court now puts it to rest permanently. The law is clear that no “special circumstances” justifying the denial or reduction of § 1988 fees inhere in the governmental status of defendants sued in their official capacity. “[F]ee awards against enforcement officials are run-of-the-mill occurrences.” Supreme Court of Virginia v. Consumers Union, 446 U.S. 719, 739, 100 S.Ct. 1967, 1978, 64 L.Ed.2d 641 (1980). See also Hutto v. Finney, 437 U.S. 678, 98 S.Ct. 2565, 57 L.Ed.2d 522 (1978); Venuti v. Riordan, 702 F.2d 6, 7-8 (1st Cir.1983); Cohen v. West Haven Board of Police Commissioners, 638 F.2d 496, 505 (2d Cir.1980). Second, the fact that the award will expend itself on the public treasury and, ultimately, on the taxpayers is not a consideration meriting a reduction in plaintiff’s fee award. Kirchberg v. Feenstra, 708 F.2d 991, 999 n. 7 (5th Cir.1983); Robinson v. Kimbrough, 652 F.2d 458, 467 (5th Cir.1981). Similarly, budgetary problems or limited resources of the public defendant do not warrant the denial or reduction of fees under § 1988. Hall v. Board of School Commissioners, 707 F.2d 464, 465 (11th Cir.1983); Lenard v. Argento, 699 F.2d at 899-900. Therefore, despite defendants’ status, they are fully liable for plaintiff’s reasonable attorney’s fees. Defendants’ next argument, and this contention is directly urged upon the Court, relates to plaintiff’s contingent fee arrangement with his counsel. Defendants argue that counsel for plaintiff’s fee award is limited by the nature of their contract with Spell which calls for compensation by counsel of the greater of (a) 50% of the damages judgment in the action or (b) the fee award set by this Court. Defendants, focusing on option (a), advanced this argument after the $1,000 verdict was rendered in an effort to substantially limit the amount of the fee award, given the minimum amount of damages awarded by the jury- 18] Although this argument, as with the previous discussion on prevailing parties, would appear moot after the second verdict on compensatory damages, defendants have not withdrawn or abandoned the contention. Therefore, to the extent defendants continue to argue that option (a) of the contingent fee contract in this case between plaintiff and his counsel somehow limits counsels’ fee award, or defendants’ payment thereof, the Court holds that the percentage recovery fixed in a contingent fee contract does not establish a ceiling on or otherwise limit the amount of a § 1988 award. Sisco v. J.S. Alberici Construction Co., 733 F.2d 55, 56-57 (8th Cir.1984); Wojtkowski v. Cade, 725 F.2d 127, 131 (1st Cir.1984); Criswell v. Western Airlines, Inc., 709 F.2d 544, 556 (9th Cir.1983), aff’d — U.S. —, 105 S.Ct. 2743, 86 L.Ed.2d 321 (1985); Wheatley v. Ford, 679 F.2d 1037, 1041 (2d Cir.1982). One final matter may also be summarily dispensed with at this point and that concerns defendants’ assertion that a January 24, 1985, offer of settlement, tendered to plaintiff in the amount of $100,000 (including attorney’s fees and expenses), somehow affects and limits counsel’s § 1988 award. First, as with several arguments before the Court, this contention has been rendered moot by the $900,000 verdict. Second, even if the $1,000 verdict were in effect, the offer contained in the January 24 letter was simply an informal negotiating offer, one which was never accepted by the plaintiff. It certainly was not an offer of judgment consistent with the requirements of F.R.Civ.P. 68. See Marek v. Chesny, — U.S. —, 105 S.Ct. 3012, 87 L.Ed.2d 1 (1985). Accordingly, defendants’ offer of January 24, 1985, is of no effect and does not in any manner limit plaintiff’s § 1988 fees award. Based on the aforesaid, the Court fails to find any special circumstances which would negate or limit plaintiff's entitlement to an award of reasonable attorney’s fees under 42 U.S.C. § 1988. C. The Extent of Plaintiff s Success Because § 1988 authorizes an award of fees only to the “prevailing party,” defendants object to an award of fees for the hours plaintiff’s counsel spent preparing and litigating motions decided in defendants’ favor, particularly plaintiff’s November, 1984, motion and protective order. See n. 6 supra. In addition, implicit in defendants’ contention that plaintiff was not the prevailing party, are the arguments that because defendant Smith prevailed on the issue of liability and because the verdict was considerably less than the amount of damages prayed for in the complaint, plaintiff should not be allowed to recover fees attributable to those unsuccessful claims. The Court disagrees. Hensley v. Eckerhart, supra, teaches that even when the Court finds the plaintiff to be a “prevailing party,” thus, one entitled to recover fees under § 1988, the Court is required to determine the extent of plaintiffs success in order to determine the scope of the fee award. Hensley specifically addressed (1) the standards that govern reduction of a fee award to account for issues on which the fee applicant did not prevail and (2) the determination of whether the overall results obtained justify compensation for the related but unsuccessful issues. 103 S.Ct. at 1940; See also Rybicki v. State Board of Elections of Illinois, 584 F.Supp. 849, 856-57 (N.D.Ill. 1984); Laffey v. Northwest Airlines, Inc., 572 F.Supp. at 363. The Court held that when a fee applicant has succeeded on only some of its claims for relief, the scope of the fee award turns upon two questions: First, did the plaintiff fail to prevail on claims that were unrelated to the claims on which he succeeded? Second, did the plaintiff achieve a level of success that makes the hours reasonably expended a satisfactory basis for making a fee award? 103 S.Ct. at 1940. Successful and unsuccessful claims will be considered “related” if they involve a “common core of facts” or “related legal theories.” Id. An unsuccessful claim will be considered “unrelated” to a successful claim when “the relief sought on the unsuccessful claim is intended to remedy a course of conduct entirely distinct and separate from the course of conduct that gave rise to the injury on which the relief granted is premised.” Mary Beth G. v. City of Chicago, 723 F.2d 1263, 1265, 1279 (7th Cir.1983). If the claims for relief are unrelated, no fee is awarded for time spent in pursuit of the unsuccessful claim. Hensley v. Eckerhart, 103 S.Ct. at 1940. However, in cases which contain only a single claim or present related multiple claims for relief, the Court recognized that [m]uch of counsel’s time will be devoted generally to the litigation as a whole, making it difficult to divide the hours expended on a claim by claim basis. Such a lawsuit cannot be viewed as a series of discrete claims [or motions]. Instead the district court should focus on the significance of the overall relief obtained by the plaintiff in relation to the hours reasonably expended in the litigation. Where a plaintiff has obtained excellent results, his attorney should recover a fully compensatory fee. Normally this will encompass all hours reasonably expended on the litigation____ In these circumstances the fee award should not be reduced simply because the plaintiff failed to prevail on every contention raised in the lawsuit. Litigants in good faith may raise alternative legal grounds for a desired outcome, and the court’s rejection of or failure to reach certain grounds is not a sufficient reason for reducing the fee. The result is what matters. Id. (citation omitted) (emphasis added). Applying the Hensley standards to this case, the Court has no difficulty in holding that the matters defendants identify as “unsuccessful” or “lost” issues or motions are not “distinct in all respects from [plaintiff’s] successful claims.” Id. at 1943. In point of fact, the claims against defendant Smith, for additional compensatory and punitive damages, and the motion to protect plaintiff’s police witnesses from perceived feelings of intimidation and harassment, were directly “related” to plaintiff’s successful claims in the lawsuit. Having so found, the Court’s focus, pursuant to the dictates of Hensley, shifts to the extent of plaintiff’s success. Where the plaintiff has achieved only partial success, compensating him for all the hours expended on the litigation would be excessive. Illinois Welfare Rights Organization v. Miller, 723 F.2d 564, 567 (7th Cir.1983). However, where the plaintiff has obtained “excellent results,” counsel should normally recover a full compensatory fee. Hensley v. Eckerhart, 103 S.Ct. at 1940. The Court has no hesitation in finding that plaintiff achieved “excellent results” in this litigation. Faced with the difficult task of proving a Monell police brutality claim, plaintiff prevailed on a vast majority of the issues in this case, overcoming the tenacious defenses and objections advanced by the defendants. The monetary award achieved was significantly large. By any standard of measure, the relief obtained in this action was substantial—both in absolute terms and in comparison to the scope of the litigation and the number of hours expended. See Laffey v. Northwest Airlines, Inc., 572 F.Supp. 363-64. Under these circumstances, the Court declines to reduce plaintiffs compensable hours because they failed to prevail against defendant Smith and on a handful of relatively minor motions and issues. See United Slate, Tile, and Composition v. G & M Roofing, 732 F.2d 495, 503 (6th Cir.1984); Abraham v. Pekarski, 728 F.2d 167, 175 (3d Cir.1984); Rutherford v. Pitchess, 713 F.2d 1416, 1421-22 (9th Cir.1983); Marion v. Barrier, 694 F.2d 229, 232 (11th Cir. 1982); Lyons v. Cunningham, 583 F.Supp. 1147, 1152-53 (S.D.N.Y.1983); Society for Good Will v. Cuomo, 574 F.Supp. 994, 999 (E.D.N.Y.1983), vacated on other grounds, 737 F.2d 1253 (2d Cir.1984). IV. LODESTAR CALCULATION A. General Framework In calculating a “reasonable attorney’s fee” for plaintiff, the Court is bound by the Supreme Court’s framework for determining such awards set forth in Hensley v. Eckerhart, supra and Blum v. Stenson, 465 U.S. 886, 104 S.Ct. 1541, 79 L.Ed.2d 891 (1984). Basically, this marketvalue methodology consists of three steps. The initial step in the computation is to establish the number of hours reasonably expended in the litigation. Hensley, 103 S.Ct. at 1939. This figure is then multiplied by a reasonable hourly rate for counsel, which is generally deemed to be the prevailing market rate for the services rendered. Id., Blum, 104 S.Ct. at 1547 n. 11. The burden is on the fee applicant to produce evidence that the requested rates are in line with those prevailing in the community for similar services, by lawyers of reasonably comparable skill, experience and reputation. Id. The sum of the two numbers is commonly referred to as the “lodestar” figure. Ramos v. Lamm, 713 F.2d 546, 552 (10th Cir.1983); Furtado v. Bishop, 635 F.2d 915, 920 (1st Cir.1980); City of Detroit v. Grinnell Corp., 560 F.2d 1093, 1098 (2d Cir.1977); Lindy Brothers Builders, Inc. of Philadelphia v. American Radiator & Sanitary Corp., 487 F.2d 161 (3d Cir.1973), aff’d. 540 F.2d 102 (3d Cir.1976) (en banc). The final step in the methodology allows the Court to enhance or reduce the lodestar based upon contingency and quality adjustments. National Association of Concerned Veterans v. Secretary of Defense, 675 F.2d at 1328-29; Copeland v. Marshall, 641 F.2d at 892-94. As previously stated by the Court, because many of the calculations mandated by this framework are inherently imprecise and require certain approximations, the Court must, with some frequency, exercise its discretion— well informed by its detailed knowledge of the litigation before it—to arrive at the final fee award. See Laffey v. Northwest Airlines, Inc., 572 F.Supp. at 361. Having reviewed plaintiff’s fee application and defendants’ objections thereto, the Court now begins its analysis to determine the appropriate lodestar figure. B. Number of Hours Reasonably Expended The first component of any court-awarded attorney’s fee is the number of hours reasonably expended on the litigation. National Association of Concerned Veterans, 675 F.2d at 1323. Although counsel are entitled to full compensation for their efforts, “[i]t does not follow that the amount of time actually expended is the amount of time reasonably expended.” Copeland v. Marshall, 641 F.2d at 891. Since the prevailing party is not entitled to those hours claimed that were not “reasonably expended,” this Court’s inquiry requires the resolution of two distinct yet related issues. The first concerns itself with how much time was actually spent on the litigation. The second focuses on the extent to which the commitment of time was reasonable in terms of the amount of time expended on each task. Ramos v. Lamm, 713 F.2d at 553; Grendel’s Den Inc. v. Larkin, 582 F.Supp. 1220, 1225-26 (D.Mass.1984); Wabasha v. Solem, 580 F.Supp. 448, 458 (D.S.D.1984). When reviewing the actual hours reported, the Court must distinguish between “raw” time and “hard” or “billable” time to determine the number of hours reasonably expended. Ramos v. Lamm, 713 F.2d at 553. “Billing judgment” is an important element of fee setting, whether the fee is set in the private sector by counsel or is established by court award; in either case, unnecessary or excessive hours must be excluded from the fee calculations. Id., Laffey v. Northwest Airlines, Inc., 572 F.Supp. at 361. As the Court of Appeals for the District of Columbia Circuit stated in Copeland v. Marshall, supra, Compiling raw totals spent, however, does not complete the inquiry____ In the private sector, ‘billing judgment’ is an important component in fee setting. It is no less important here. Hours that are not properly billed to one’s client also are not properly billed to one’s adversary pursuant to statutory authority. 641 F.2d at 891 (emphasis in original). In ascertaining which hours reported were reasonably expended, and thus billable, the Court must examine the total number of hours reported by each lawyer, the hours counsel allotted to specific tasks, whether those tasks would normally be billed to a paying client, and the potential duplication of services, particularly where multiple lawyers are involved. Ramos v. Lamm, 713 F.2d at 553-54. See New York State Association for Retarded Children v. Carey, 711 F.2d 1136, 1146 (2d Cir.1983); Johnson v. University College of University of Ala. in Birmingham, 706 F.2d 1205, 1207-08 (11th Cir.1983), cert. denied 464 U.S. 994, 104 S.Ct. 489, 78 L.Ed.2d 684 (1983); Copeland v. Marshall, 641 F.2d at 903; Northcross v. Board of Education of Memphis, 611 F.2d 624, 636-7 (6th Cir. 1979), cert. denied, 447 U.S. 911, 100 S.Ct. 3000, 64 L.Ed.2d 862 (1980). These determinations must be made in the context of the specific case at bar; what is reasonable in one case may be excessive and unnecessary in another. The reasonableness of hours expended in a particular case depends upon the complexity of the case, the number of reasonable strategies pursued, and the responses necessitated by the tactics of the opponent. Ramos v. Lamm, 713 F.2d at 554; Wabasha v. Solem, 580 F.Supp. at 458. If these factors demand an extraordinary number of hours to perform a task, then those hours are properly billable. Id. Finally, the Court must “weigh the hours claims against [its] own knowledge, experience, and expertise of the time required to complete similar activities.” Johnson v. Georgia Highway Express, Inc., 488 F.2d 714, 717 (5th Cir.1974). See also Rajender v. University of Minnesota, 546 F.Supp. 158, 165 (D.Minn.1982). In sum, the Court must carefully scrutinize the total number of hours reported by the prevailing party to arrive at the number of hours that can fairly and reasonably be charged to the losing party. In Hensley v. Eckerhart, supra, the Supreme Court noted that the § 1988 fee applicant bears the burden of documenting and supporting the number of hours expended in the litigation. 103 S.Ct. at 1939-41. See also National Association of Concerned Veterans, 675 F.2d at 1323-24. The fee application should be supported by “contemporaneous, complete and standardized time records which accurately reflect the work done by each attorney.” Id. at 1327. Initially, the application may be accompanied by summaries of work performed, but the actual time sheets should be submitted to the Court in the event of a dispute concerning the reasonableness of the hours. See id. Plaintiff has done so in this case. “Although it is not necessary to know ‘the exact number of minutes spent nor the precise activity to which each hour was devoted,’ the fee application must contain sufficient detail to permit both the Court and opposing counsel to conduct an informed appraisal of the merits of the application.” Laffey v. Northwest Airlines, Inc, 572 F.Supp. at 361 quoting National Association for Concerned Veterans, 675 F.2d at 1327. See also United Slate, Tile & Composition v. G & M Roofing, 732 F.2d at 502 n. 2 (supporting documentation “must be of sufficient detail and probative value to enable the court to determine with a high degree of certainty that such hours were actually and reasonably expended”); Wotjtkowski v. Cade, 725 F.2d at 130 (attorneys are “well-advised to maintain detailed, contemporaneous time records that will enable a later determination of the amount of time spent on particular issues”); New York State Association for Retarded Children v. Carey, 711 F.2d at 1148 (counsel must document their fee applications with contemporaneous time records specifying for each attorney “the date, the hours expended, and the nature of the work”); White v. City of Richmond, 713 F.2d 458, 461 (9th Cir.1983). In addition, the fee application should indicate what unproductive time, if any, was excluded from the fee petition in the exercise of “billing judgment.” National Association of Concerned Veterans, 675 F.2d at 1327-28. As for defendants who seek to contest the reasonableness of hours claimed by plaintiff’s counsel, their burden is to submit to the court “evidence” calling into question “the accuracy and reasonableness of the hours charged” or “the facts asserted in the affidavits” submitted by plaintiff. Blum v. Stenson, 104 S.Ct. at 1545 n. 5. Absent exceptional circumstances, arguments and objections contained in a defendant’s brief are not alone sufficient to create a genuine issue of fact warranting an evidentiary hearing on the reasonableness of the hours claimed. Id. Having established the basic guidelines for analysis, the Court now turns to 1. Plaintiffs Fee Application Plaintiff’s counsel submitted the following materials documenting their fee request: (1) a fourteen (14) page verified motion requesting attorney’s fees and costs, setting forth the basic grounds for the same and detailing counsel’s experiences and skills; (2) a copy of the contingent fee contract with their client; (3) eight (8) affidavits setting forth the date, the hours expended in tenths of hours and the nature of the work for all 2,087.6 hours requested; (4) an additional affidavit containing a line-item list of litigation expenses incurred by counsel; (5) a verified line-item bill of costs and supplemental bill of costs pursuant to 28 U.S.C. § 1920; (6) a brief memorandum of law in support of the motion for fees and costs; (7) a thirteen (13) page affidavit and reply to defendants’ objections to plaintiff’s motion; (8) a five (5) page affidavit and reply to defendants’ supplemental objections; (9) four (4) affidavits from local attorneys providing prevailing community rate information; and (10) counsel’s contemporaneous time records (under seal). Although plaintiff’s documentation is flawed in a few minor aspects, see n. 25 infra, it basically comports with the requirements for fee petitions delineated by this Court, supra at 1085-1086 and with the standards established in National Association of Concerned Veterans, 675 F.2d at 1327-29 and Copeland v. Marshall, 641 F.2d at 891. Turning to counsel’s individual requests, the hours claimed, separated by the Court into chronological litigation phases, break down as follows: Pre-Trial #1 (Hrs. through 1-24-85) Trial 1 (1-25-85 through 2-22-85) Post-Trial 1/Pre-Trial 2 (2-21-85 through 4-1-85) Trial 2 (4-2-85 through 4-4-85) Post-Trial 2 (Hrs. since 4-4-85) Fee Petition Beaver 653.5 196.1 81.9 21.6 7.8 17.1 Richardson 511.0 201.8 27.0 10.7 0 2.6 Thompson 101.0 154.7 12.0 17.9 0 0 Holt 54.2 6.0 10.7 _0 _0 0 Totals 1,319.7 558.6 131.6 50.2 7.8 19.7 TOTAL HOURS REQUESTED Beaver 978.0 Richardson 753.1 Thompson 285.6 Holt 70.9 Total 2,087.6 In addition, for purposes of reviewing the tasks performed and the reasonableness of the hours allotted to those tasks in light of defendants’ objections, the Court has collapsed counsel’s hours into seven work categories: (A) meetings with clients and witnesses; (B) meetings and conferences with co-counsel; (C) drafting of pleadings and legal research; (D) court hearings, pre-trial conferences and general preparation for trial; (E) trial time; (F) formal and informal discovery; and (G) miscellaneous—serving subpoenas; meetings with juristic psychologist; preparation of exhibits; conferences with defense counsel and court personnel, etc____ See Wabasha v. Solern, 580 F.Supp. at 459—61; EEOC v. Sage Realty Co., 521 F.Supp. 263, 271-73 (S.D.N.Y.1981). The Court further examined the hours claimed for each of these functions within the six litigation phases established above. This breakdown is as follows: PHASE 1—PRE-TRIAL #1 A B D E F G Beaver 87.0 11.7 231.7 45.9 0 122.2 155.0 Richardson 175.0 5.7 40.8 46.7 0 136.3 106.5 Thompson 32.5 0 12.0 43.0 0 12.0 1.5 Holt 8.0 2.5 14.1 2.5 0 4.2 22.9 Totals 302.5 19.9 298.6 138.1 274.7 285.9 PHASE 2—TRIAL #1 A B D E F G Beaver 7.5 0 5.6 50.0 129.2 3.8 Richardson 4.4 0 0 64.1 131.7 1.6 Thompson 0 0 0 23.0 131.7 0 Holt 0 0 0 0 6.0 0 Totals 11.9 5.6 137.1 398.6 5.4 PHASE 3—POST-TRIAL #1/PRE-TRIAL #2 A B D E F G Beaver 3.0 8.2 31.5 13.6 0 25.6 Richardson 3.3 2.6 4.1 7.5 0 9.5 Thompson 1.0 4.0 0 2.0 0 5.0 Holt 0 5.2 5.5 0 0 0 Totals 7.3 20.0 41.1 23.1 40.1 PHASE 4—TRIAL #2 A B D E G Beaver 0 1.4 2.3 15.9 2.0 Richardson 0 0 0 8.7 2.0 Thompson 0 0 0 15.9 2.0 Holt 0 0 0 0 0 6.0 Totals 1.4 2.3 40.5 PHASE 5—POST-TRIAL #2 A B C D E F G Beaver 0 0 2.6 0.6 0 0 4.6 PHASE 5—POST-TRIAL #2 A B C D E F G Richardson 0 0 0 0 0 0 0 Thompson 0 0 0 0 0 0 0 Holt 0 0 0 0 0 0 0 Totals 0 0 2.6 0.6 0 4.6 PHASE 6—FEE PETITION HOURS A B C D E F G Beaver 0 0 15.5 0 0 1.6 Richardson 0 0 2.6 0 0 0 Thompson Holt 0 0 0 0 0 0 0 0 0 0 0 0 Totals 0 0 18.1 0 0 0 1.6 Prior to proceeding to defendants’ objections, some preliminary thoughts are in order based upon a review of the information contained in plaintiff’s petition and in the above tables. First, any evaluation of the reasonableness of counsel for plaintiff’s hours must and will begin from the Court’s view of the conduct of counsel during the course of this litigation. Without exception, Messrs. Beaver, Thompson, Richardson and Holt have performed their respective tasks in a professional and competent manner, never giving the Court reason to doubt the veracity of their representations. The Court presumes, as it does with all members of the Bar who appear before it unless shown to the contrary, that counsel have litigated all aspects of this action in good faith. The Court’s view of counsel’s conduct and performance is a critical factor when one considers the number of credibility determinations that are inherent in any fee petition analysis. Second, in the Court’s opinion, this complex § 1983 litigation was prepared and tried efficiently and expeditiously. The case went to trial exactly one year from the date the complaint was filed. The trial was conducted under exacting time limitations. For the litigation to have proceeded so swiftly, credit must be placed where it primarily belongs—with counsel. Therefore, absent evidence to support defendants’ objections that plaintiff’s counsel engaged in unproductive, wasted or unnecessary time, such assertions will be viewed with disfavor. Third, given the scope and magnitude of this litigation, the number of issues to be resolved, witnesses to be interviewed, documents to be read, depositions taken, exhibits prepared and research conducted, plaintiff’s total requested hours appear to be well within the range of reasonableness. See Williamsburg Fair Housing Committee v. Ross-Rodney Housing Corp., 599 F.Supp. 509, 516 (S.D.N.Y.1984). No one request or line-item expenditure of time is so out of the ordinary or unusual that it demands a detailed explanation. See e.g., Ramos v. Lamm, 713 F.2d at 554 (more than 100 hours spent drafting the complaint); Laffey v. Northwest Airlines, Inc., 572 F.Supp. at 364 (59.25 hours claimed for a motion to reconsider a previous ruling of the Court). None of the attorneys claimed an excessive number of hours for any one day or week. See Ramos v. Lamm, 713 F.2d at 553 n. 2. Duplication of hours for tasks and functions described with particularity appears minimal. Fourth, from a review of plaintiff’s verified motion, responses to objections, and time logs, the Court is convinced that plaintiff’s counsel exercised considerable billing judgment. For example, absolutely no compensation is requested for the obvious investment of hundreds of hours of secretarial time. In addition, counsel have not sought compensation for either lodging or food during the second trial in Wilmington. (see also conference of March 18, 1985, between co-counsel where hours for Messrs. Thompson and Richardson are specifically not claimed). Finally, the Court finds that plaintiffs counsel honestly and accurately recorded their hours spent and submitted their claims in good faith. Defendants’ assertions that plaintiff’s counsel inaccurately recorded some of their time are meritless. See defendant’s March 11, 1985, Response at 3-4, parag. 6. No credible evidence has been tendered by defendants to support such allegations. Of the three (3) affidavits filed by defendants in this regard, two can be dispensed with summarily. In one instance, the affiant (Hutcheson) was one of a number of witnesses contacted by Mr. Richardson on January 21, 1985, with regard to defendants’ pre-trial witness list, see n. 11 supra at 1078, and the time spent talking with Hutcheson was included within a 3.6 hour line-item request for time expended interviewing all prospective defense witnesses on that same day. Hutcheson confirms in his affidavit that Richardson did indeed talk to him on the 21st. Hutcheson further states he has no idea whom else Richardson interviewed and how long those interviews may have lasted. Thus, Hutcheson’s affidavit fails to provide any support for defendants’ objection and plaintiff’s verified and reasonable explanation is accepted. See plaintiff’s Affidavit and Reply of April 9, 1985, at 5-6. The second affidavit (Dunn) simply reveals a clerical error in plaintiff’s fee application. Two numbers, .9 and 2.3, were apparently transposed by counsel’s secretary and plaintiff’s response has corrected the error. Id. at 4-5. It is important to note that the actual total time reflected in the original affidavit of 3.2 hours for the combined activities was in fact correct. The final affidavit and piece of evidence filed by defendants is from Ernest McCoy, an officer of the F.P.D. Officer McCoy contends that the 3.6 hours claimed by Mr. Richardson for interviews conducted with McCoy and another officer, Peregoy, on April 6, 1984, are excessive. This matter can be resolved on two grounds without the need for hearing. First, counsel’s verified reply indicates that Peregoy was interviewed for a significant period of time prior to and after the McCoy interview so that, in fact, the 3.6 hours is a correct figure for the interviews of both officers. McCoy admits that during his interview with Richardson, they were joined by Peregoy and further concedes that he does not know whether Peregoy returned for an additional interview after McCoy’s ended. Second, testimony by witnesses at trial and exhibits introduced by the plaintiff established in an uncontraverted fashion the close personal relationship between McCoy and defendant Dixon. Given this background, plus the fact that counsel’s contemporaneous time records are consistent with the hours as claimed, the Court finds the McCoy challenge to be without merit and allows the 3.6 hours to stand. This being the sum total of defendants’ evidence to support their claim that plaintiff’s hours are inaccurate, the Court holds the hours claimed by counsel were actually expended and turns to 2. Defendants’ Objections to the Reasonableness of Time Spent As previously stated, defendants have sifted through the affidavits of plaintiff’s counsel and registered specific line-item objections to approximately 45% of the hours claimed for specific tasks performed. Utilizing the same phases system of cataloging the hours as employed supra at 1087-1088, defendants’ objections break down as follows: PreTrial #1 Trial 1 Post-1 1/Pre-2 'rial •Trial Trial 2 Post-Trial 2 Fee Petition Beaver 215.0 1.5 17.7 0 0 0 Richardson 239.2 185.4 2.0 10.7 0 0 Trial 1 Post-Trial 1/Pre-Trial 2 Trial 2 Post-Trial 2 Fee Petition Thompson 89.0 137.5 5.2 17.9 0 0 Holt 11.7 0 0 0 0 0 Totals 554.9 324.4 24.9 28.6 0 0 Total Reduction Request Beaver - 234.2 Richardson - 437.3 Thompson - 249.6 Holt - 11.7 Total 932.8 Utilizing the same function or task system of cataloging the hours as employed supra at 1088-1089, defendants’ objections break down as follows: PHASE 1—PRE-TRIAL #1 A B D F G Beaver 45.8 4.5 23.9 14.3 78.7 47.8 Richardson 126.6 0 20.3 39.3 14.1 38.9 Thompson 31.5 0 4.0 43.0 9.0 1.5 Holt 5.0 2.5 0 0 4.2 0 Totals 208.9 7.0 48.2 96.6 106.0 88.2 PHASE 2—TRIAL #1' A B C D E G Beaver 0 1.5 0 0 Richardson 4.4 60.0 119.4 1.6 Thompson 0 23.0 114.5 0 Holt 0 0 0 0 Totals 4.4 84.5 233.9 1.6 PHASE 3—POST-TRIAL #1/PRE-TRIAL #2 A B D G Beaver 0 2.4 5.8 6.8 2.7 Richardson 0 0 0 0 2.0 Thompson 0 3.2 0 ' 0 2.0 Holt 0 0 0 0 0 Totals 0 5.6 5.8 6.8 6.7 PHASE 4—TRIAL #2 A B C D E F G Beaver 0 0 0 0 8.7 0 2.0 Richardson 0 0 0 0 15.9 0 2.0 Thompson 0 0 0 0 0 0 0 Holt 0 0 0 0 0 0 0 Totals 0 0 0 0 24.6 0 4.0 Defendants’ objections are contained in three documents; a 35 page “Response” to plaintiff’s motion filed March 11, 1985; an 18 page memorandum of law in support of the March 11 Response; and a 3 page supplemental list of objections, filed April 22, 1985. Therein, defendants object to approximately 45% of plaintiff’s hours claims as unreasonably spent. Aside from the McCoy, Dunn and Hutcheson affidavits discussed' earlier in this opinion, and a few documents relating to defendants’ assertion regarding settlement negotiations between the parties, supra at 1082, defendants’ 200 + objections to plaintiff’s hours are void of evidentiary support. Although defendants were provided ample opportunity to object to plaintiff’s fee application and submit evidentiary support for their position, none has been forthcoming. Defendants have patantly failed to comply with the requirements of Blum v. Stenson, 104 S.Ct. at 1545, n. 5 and National Association of Concerned Veterans, 675 F.2d at 1338 (Tamm, J; concurring). The Court assumes defendants’ counsel billed their clients (and received payment) for the erroneous outlays of time made on their behalf; yet by filing such cavalier objections to plaintiff’s request, it seems defendants are determined to preclude plaintiff’s counsel from doing the same. It thus appears that defendants are attempting to invoke a double standard for this fee litigation—one set of rules governing payment of defense counsel and quite another for plaintiff’s counsel. See Laffey v. Northwest Airlines, Inc., 572 F.Supp. at 388. Just as an example, defendants object to nearl