McCallion v. Marra

District Court, N.D. New York·Decided May 1, 2025·No. 9:22-cv-00253·Unknown

Opinion

AO 133 (Rev. 07/24) Bill of Costs UNITED STATES DISTRICT COURT for the Northern District of New York ) Michael McCallion ) Vv. ) Case No.: 9:22-CV-253 ) C.O. Matthew Marra )

BILL OF COSTS Judgment having been entered in the above entitled action on 3/21/2025 against Plaintiff Date the Clerk is requested to tax the following as costs: Fees of the Clerk 2.0... cence tenet teen ee tne tenet $ Fees for service of summons and subpoena 1.0... teen eeee Fees for printed or electronically recorded transcripts necessarily obtained for use in the case...... 2,083.08 Fees and disbursements for printing .. 2.2... □□ eee eee Fees for witnesses (itemize on page WO) oo eee eee eens 164.64 Fees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case... 2... eee □□□ eeee 165.00 Docket fees under 28 U.S.C. § 1923 20. eens Costs as shown on Mandate of Court of Appeals... 2... eee Compensation of court-appointed experts 2... eee eens Compensation of interpreters and costs of special interpretation services under 28 U.S.C. § 1828 .... Other costs (please itemize) 66. eee ee eee eee eens TOTAL § 2,412.72 SPECIAL NOTE: Attach to your bill an itemization and documentation for requested costs in all categories. Declaration I declare under penalty of perjury that the foregoing costs are correct and were necessarily incurred in this action and that the services for which fees have been charged were actually and necessarily performed. A copy of this bill has been served on all parties in the following manner: lV | Electronic service [| First class mail, postage prepaid | Other: s/ Attorney: s/Jorge A. Rodriguez Name of Attorney: Jorge A. Rodriguez For, Defendants Date: 4/4/2025 Name of Claiming Party Taxation of Costs Costs are taxed in the amount of $2,412.72 for the reasons stated a wee th a i and included in the judgment. —) Qa Tl i if EFT iaAnaes

WJINLT I DL DOLZIOLININ I WVUIAN!L Witness Fees (computation, cf. 28 U.S.C. § 1821 for statutory fees) ATTENDANCE SUBSISTENCE TRAVEL Total Cost NAME, CITY AND STATE OF RESIDENCE Total Total |Expenses/ Total Each Witness Days Cost Days Cost Miles Cost Jeff Villeneuve, Gouverneur, NY, testified 300 | 92.39 92.30 on March 20, 2025 : $82. Keri Woods, Gouverneur, NY, testified on March 20, 2025 392 | 82.32 $82.32

$0.00

NOTICE Section 1924, Title 28, U.S. Code (effective September 1, 1948) provides: “Sec. 1924. Verification of bill of costs.” “Before any bill of costs is taxed, the party claiming any item of cost or disbursement shall attach thereto an affidavit, made by himself or by his duly authorized attorney or agent having knowledge of the facts, that such item is correct and has been necessarily incurred in the case and that the services for which fees have been charged were actually and necessarily performed.” See also Section 1920 of Title 28, which reads in part as follows: “A bill of costs shall be filed in the case and, upon allowance, included in the judgment or decree.” The Federal Rules of Civil Procedure contain the following provisions: RULE 54(da)(1) Costs Other than Attorneys’ Fees. Unless a federal statute, these rules, or a court order provides otherwise, costs — other than attorney’s fees — should be allowed to the prevailing party. But costs against the United States, its officers, and its agencies may be imposed only to the extent allowed by law. The clerk may tax costs on 14 days’ notice. On motion served within the next 7 days, the court may review the clerk’s action. RULE 6 (d) Additional Time After Certain Kinds of Service. When a party may or must act within a specified time after being served and service is made under Rule 5(b)(2)(C) (mail), (D) (leaving with the clerk), or (F) (other means consented to), 3 days are added after the period would otherwise expire under Rule 6(a). RULE 58(e) Cost or Fee Awards: Ordinarily, the entry of judgment may not be delayed, nor the time for appeal extended, in order to tax costs or award fees. But if a timely motion for attorney's fees is made under Rule 54(d)(2), the court may act before a notice of appeal has been filed and become effective to order that the motion have the same effect under Federal Rule of Appellate Procedure 4(a)(4) as a timely motion under Rule 59.

| Inn =n "SG

ITEMIZATION AND DOCUMENTATION

Fees for printed or electronically recorded transcripts necessarily obtained for use in the case, 28 U.S.C. §1920(2)

Attached hereto as Exhibit A are the invoices concerning the transcription of the depositions of Plaintiff Michael McCallion, taken on April 4, 2023; Dr. Lloyd Loft, taken on August 31, 2023; Dr. Lloyd Loft, taken on January 20, 2025; and Dr. Timothy Moon, taken on February 28, 2025, totaling $2,083.08. The deposition transcripts were necessary because the individuals deposed were either parties to this action or testified at the trial on March 17-20, 2025. See Yunus v. Jones, No. 9:16-CV-1282, 2020 WL 3026238, at *3 (N.D.N.Y. June 5, 2020); 28 U.S.C § 1920(2); NDNY Guidelines for Bills of Costs at D(1)(c), (d). Fees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case, 28 U.S.C. §1920(4)

The cost is $165.00, for copying 660 pages at $0.25 per page. The 660 pages were necessary in that they consist of Defendants’ Rule 26 mandatory disclosures, supplemental disclosures, and responses to Plaintiff’s discovery demands. See Yunus v. Jones, No. 9:16-CV- 1282, 2020 WL 3026238, at *3 (N.D.N.Y. June 5, 2020); 28 U.S.C § 1920(4); NDNY Guidelines for Bills of Costs at (H)(1)(g). Witness Fees, 28 U.S.C. § 1920(3) Attached hereto as Exhibit B is the google map printout that indicates the milage between Gouverneur Correctional Facility in Gouverneur, New York and the James T. Foley Courthouse, 445 Broadway, Albany, NY, for non-party travel costs of witnesses Keri Woods and Jeff Villeneuve (charged at the rate of 0.21 cents per mile, per 28 U.S.C. § 1821(c)(2)), who testified at trial on March 20, 2025. See NDNY Guidelines for Bills of Costs at (F)(1)(b). Exhibit A Associ ated Phone - 518-465-8029 | □□□□□ Re po rte rs Email - ARI[@courtsteno.com International Incorporated sill To Reporters Int'l., Inc. NYS AG's Office . . Attn: Nicholas Dorando, Esq. River Drive . The Capitol New York Box 16° Albany, NY 12224 NY 13662 ys

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