A portion of the introduction to the fee petition submitted by Victor John Yannacone, jr. following the settlement of the Agent Orange litigation coerced by Jack B. Weinstein, Chief Judge of the United States District Court for the Eastern District of New York through his appointed “settlement masters” Leonard Garment and Kenneth Feinberg.

 

The Claim of Paul Reutershan
6 June 1978 to 9 October 1978
125 days; 17.86 weeks

 

The Senate Hearings; The Alvin Young Reports
10 October 1978 to 14 December 1978
65 days; 9.29 weeks

 

The Amended Reutershan Class Action Complaint
14 December 1978 to 8 January 1979
25 days; 3.57 weeks

 

The Early Veterans Claims; Marcie Smith and the Children
9 January 1979 to 22 February 1979
44 days; 6.29 weeks

 

Associated Counsel Agreements; The CHAOS DBMS
23 February 1979 to 26 April 1979
62 days; 8.86 weeks

 

Claim Consolidation; The MDL Application
21 March 1979 to 26 April 1979
36 days; 5.14 weeks

 

Consolidation of the “Agent Orange” Cases.
27 April 1979 to 28 May 1979
31 days; 4.43 weeks

 

Practice & Procedure; Amended Class Action Complaint
29 May 1979 to 21 June 1979
23 days; 3.29 weeks

 

Defendants First Wave of Motions to Dismiss
22 June 1979 to 18 July 1979
26 days; 3.71 weeks

 

EPA RPAR/FIFRA Proceedings
19 July 1979 to 15 August 1979
27 days; 3.86 weeks

 

Federal Question Jurisdiction; Federal Common Law
16 August 1979 to 3 October 1979
48 days; 6.86 weeks

 

Defendants Second Wave of Motions to Dismiss
4 October 1979 to 22 November 1979
49 days; 7.00 weeks

 

Claims Examination and Case Consolidation
23 November 1979 to 4 January 1980
42 days; 6.00 weeks

 

Defendants Answers/Third Party Complaints

 

Plaintiffs’ Statement of Issues
5 January 1980 to 21 January 1980
16 days; 2.29 weeks

 

Defendants Appeal to the Second Circuit;

 

Preliminary Discovery of United States Documents
22 January 1980 to 1 May 1980
100 days; 14.29 weeks

 

Government Discovery; FTCA Claims
2 May 1980 to 29 December 1980
241 days; 34.43 weeks

 

Discovery Startup; The Australian/New Zealand Claims
30 December 1980 to 30 January 1981
31 days; 4.43 weeks

 

Discovery Motions; Defendants Amend Answers
31 January 1981 to 20 May 1981.
109 days; 15.57 weeks

 

The Government Contractor Immunity Defense
21 May 1981 to 15 September 1981
117 days; 16.71 weeks

 

Document Discovery Matters; Claims Management
16 September 1981 to 16 December 1981
44 days; 6.29 weeks

 

Document Motions; Class Decertification Attempts
17 December 1981 to 24 February 1982
69 days; 9.86 weeks

 

Defendants Non-Jury Request; Definition of “Agent Orange
25 February 1982 to 18 March 1982
21 days; 3.00 weeks

 

Preparation for Depositions
19 March 1982 to 30 April 1982
42 days; 6.00 weeks

 

The Government Contractor Immunity Defense Depositions; in general
1 May 1982 to 23 October 1983
540 days; 77.14 weeks

 

Early Discovery: Government Contractor Immunity Issues
1 May 1982 to 27 December 1982
240 days; 34.29 weeks

 

PSAC Depositions; Initial Settlement Negotiations
28 December 1982 to 22 February 1983
56 days; 8.00 weeks

 

Litton Bionetics; PSAC; Edgewood Arsenal/Camp Detrick
23 February 1983 to 20 April 1983
56 days; 8.00 weeks

 

The Defendants Motions for Summary Judgment
21 April 1983 to 12 May 1983
21 days; 3.00 weeks

 

Discovery of the Defendants; Government Witnesses
13 May 1983 to 23 October 1983
163 days; 23.29 weeks
* * *

 

The Yannacone Leadership Period
6 June 1978 to 23 October 1983
1,965 days; 280.71 weeks

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