Newsletter 151

Return to Lawsuit Index

PROSKAUER ROSE LLP
Dale A. Schreiber (DS-9211)
Bruce E. Fader (BF-5564)
Allison B. Feld (AF-9464)
1585 Broadway
New York, NY 10036
(212) 969-3000 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK



--------------------------------------x


BLEECKER CHARLES COMPANY,             :       00 Civ. 7827 (GEL)

                         Plaintiff,   :
                                              REPLY DECLARATION
             -against-                :       OF BRUCE E. FADER

350 BLEECKER STREET APARTMENT         :
CORPORATION,
                                      :
                         Defendant,
                                      :
             -against-
                                      :
BLEECKER PARKING CORP.,
                                      :
 Additional Counterclaim Defendant.
                                      :
--------------------------------------x

I, BRUCE E. FADER, hereby declare:

1. I am a member of the Bar of the State of New York and this Court. I am the engagement partner at Proskauer Rose LLP ("Proskauer"), attorneys for Bleecker Charles Company (the "Sponsor"), with respect to this action and have been involved in it from its inception. I submit this declaration to place before the Court certain facts and documents in further support of the Sponsor's motion under Rule 54(d)(2) for an order under 15 U.S. §3611 (d) awarding attorneys's fees and related expenses.

2. A true and correct copy of a New York Law Journal article, dated December 11, 2000, entitled "NYLJ 100: Ranked By Size" is annexed hereto as Exhibit A.

3. A true and correct copy of a New York Law Journal article, dated December 10, 2001, entitled "NYLJ 100: Ranked By Size" is annexed hereto as Exhibit B.

4. A true and correct copy of a National Law Journal article dated December 2001 entitled "A Firm-By-Firm Sampling of Billing Rates Nationwide" is annexed hereto as Exhibit C.

5. A true and correct copy of the biography of Richard E. Siegler, as posted on the web site for Stroock & Stroock & Lavan LLP as of March 11, 2002, is annexed here to as Exhibit D.

6. A true and correct copy of the "First Interim Application of Stroock & Stroock Lavan LLP, Special Corporate Counsel to the Chapter 11 Debtors, For Interim Allowance of Compensation... For Services Rendered ... From October 20, 1999 Through March 31, 2000" is annexed hereto as Exhibit E.

7. In preparation of this reply to the Co-op's Opposition to the Sponsor's Motion for Attorneys' Fees, Proskauer billed $20,982.25 in attorneys' and legal assistants' fees and $1,409.77 in expenses. (Annexed hereto, as Exhibit F, is the pro forma statement reflecting billing for the period February 1 to March 8, 2002).

Pursuant to to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on March 11, 2002

/s/ Bruce E. Fader
Bruce E. Fader

Exhibit A

Exhibit A is a New York Law Journal article, dated December 11, 2000, entitled "NYLJ 100: Ranked By Size". If you wish to see this article, please contact any board member.

Exhibit B

Exhibit B is a New York Law Journal article, dated December 10, 2001, entitled "NYLJ 100: Ranked By Size." If you wish to see this article, please contact any board member.

Exhibit C

Exhibit C is a National Law Journal article, dated December 3, 2001, entitled "A Firm-By-Firm Sampling of Billing Rates Nationwide." If you wish to see this article, please contact any board member.

Exhibit D

Richard Siegler

Partner
212-806-5464
Fax: 212-806-6006
rsiegler@stroock.com

Practice Group

·	Real Estate

Education

·	J.D., Harvard Law School, 1965, cum laude
·	A.B., Amherst College, 1962, magna cum laude; Phi Beta Kappa

Admitted to Practice

·	New York, 1965
·	Florida, 1975
·	Washington, D.C., 1986

Richard Siegler concentrates in cooperative housing and condominium law. He provides legal services to cooperative corporations and condominium associations, ranging from luxury apartment houses to large hotel cooperatives.

Mr. Siegler serves as secretary and general counsel to the boards of some of the most prestigious cooperatives in New York, including: The Sherry-Netherland; 795 Fifth Avenue Corporation, the co-op which owns The Pierre Hotel; Plaza 400 Owners Corp., one of the largest New York City co-ops consisting of 628 apartments (400 East 56th Street); The Ritz Tower Hotel (465 Park Avenue); and 111 East 56th Street, Inc., the owner/operator of The Lombardy, where he is also a board member. He is also General Counsel to The Majestic (115 Central Park West), Imperial House (150 East 69th Street), and 200 Central Park South. Mr. Siegler provides counsel to numerous other cooperatives.

Mr. Siegler has provided legal services to condominium associations.

Selected Activities

·	Monthly Columnist, "Cooperatives and Condominiums," New York Law Journal, 1985--
·	Monthly Columnist, "Co-op/Condo Case Notes," NY Habitat, 1983--
·	Articles Published in Real Estate Review, The National Law Journal, The New York Times
·	Adjunct Professor of Cooperative Housing and Condominium Law, New York Law School, 1986–
·	Vice President, Secretary and Director, Apartment Owners Association, Inc., 1983-
·	Professor, Cooperative and Condominium Management: Legal and Practical Aspects, Real Estate Institute of NYU, 1983-1986
·	Seminar Instructor, National Association of Housing Cooperatives, Los Angeles, Pittsburgh, New Orleans, Washington, D.C.
·	Lecturer, Co-op and Condominium Law, Fordham Law School, 1989-1992
·	Speaker, programs sponsored by Law Journal Seminars-Press, Chemical Bank, Brooklyn Bar Association, Insignia Residential Group, Brown Harris Stevens Residential Management, LLC, Akam Associates, Rose Associates, Wallack Management Co., and Charles H. Greenthal Group

Memberships

·	Member, Committee on Condominiums and Cooperatives, New York State Bar Association, 1983–
·	The Association of the Bar of the City of New York: Member, Committee on Housing and Urban Developments, 1986–1989; Member, Committee on Real Property Law, 1980–1983

Exhibit E

Exhibit E is a copy of the "First Interim Application of Stroock & Stroock Lavan LLP, Special Corporate Counsel to the Chapter 11 Debtors, For Interim Allowance of Compensation And For Reimbursement of Expenses For Services Rendered During the Period From October 20, 1999 Through March 31, 2000." If you wish to see this document, please contact any board member.

Exhibit F

Exhibit F is a pro forma statement reflecting billing to the Sponsor from Proskauer Rose LLP for the period February 1 to March 8, 2002. If you wish to see this document, please contact any board member.

Return to Lawsuit Index