Free Notice (Other) - District Court of Connecticut - Connecticut

Case 3:03-cv-00630-DJS

Document 141

Filed 02/22/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARIO RICHARDS V. COMPUTER SCIENCES CORP. : : : : : CIVIL ACTION NO: 3:03-CV-00630-DJS

FEBRUARY 21, 2007

NOTICE OF ATTORNEY'S CHARGING LIEN Notice is hereby given that The Bartinik Law Firm, P.C. claims an attorney's charging lien in the amount of $21,657.80 (see Schedule A attached billing statement) for attorneys' fees and costs incurred in prosecuting this case on behalf of the plaintiffs. From May of 2004 until December of 2004, Attorney Michael J. Melly was employed by the law firm of Bartinik, Giancopolis, Bartinik, Bartinik & Grater, P.C. n/k/a The Bartinik Law Firm, P.C and was simultaneously representing Mario Richards in this case.

BY /s/ Peter J. Bartinik, Jr. Peter J. Bartinik, Jr. # 14208 The Bartinik Law Firm, P.C. 100 Fort Hill Rd. Groton, CT 06340 Ph 860 445 8521 Fax 860 445 5873 Email [email protected]

Case 3:03-cv-00630-DJS

Document 141

Filed 02/22/2007

Page 2 of 5

CERTIFICATION I hereby certify that a copy of the foregoing document was filed electronically, and that notice of this filing will be sent by e-mail through the Court's electronic filing system to all parties who may access this filing through the Court's system. This document was filed electronically on February 21, 2007.

BY /s/ Peter J. Bartinik, Jr. Peter J. Bartinik, Jr. # 14208 The Bartinik Law Firm, P.C. 100 Fort Hill Rd. Groton, CT 06340 Ph 860 445 8521 Fax 860 445 5873 Email [email protected]

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Case 3:03-cv-00630-DJS

Document 141

Filed 02/22/2007

Page 3 of 5

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARIO RICHARDS V. COMPUTER SCIENCES CORP. : : : : : CIVIL ACTION NO: 3:03-CV-00630-DJS

FEBRUARY 21, 2007

MEMORANDUM OF LAW REGARDING ATTORNEY'S CHARGING LIEN

In 2004 The Bartinik Law Firm, P.C. through its then employee, Attorney Michael Melly, expended billable hours in the form of legal research; drafting of pleadings, notices and discovery requests; communications; and meetings in behalf of the plaintiff in this action. A charging lien is a lien that is placed upon funds or recovery due the client at the conclusion of the action. Marsh, Day & Calhoun v. Elisabeth Solomon, 204 Conn. 639, 645 (1987). It is well settled that this common law lien is an equitable measure to allow an attorney or firm to collect for the services and expenses of a particular suit Carbone Financing Services, LLC v. Hawley 560, LLC et al., 31 Conn. L. Rptr. 85 (2001). Charging liens are based upon the principal that attorneys should be favored to collect on an asset they worked to create. Id. The Bartinik Law Firm, P.C. is entitled to an attorney's charging lien in the matter of

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Case 3:03-cv-00630-DJS

Document 141

Filed 02/22/2007

Page 4 of 5

Richard v. Computer Sciences Corporation, Docket No.: 3:03-CV-00630-DJS for the work performed on its behalf in 2004. BY /s/ Peter J. Bartinik, Jr. Peter J. Bartinik, Jr. # 14208 The Bartinik Law Firm, P.C. 100 Fort Hill Rd. Groton, CT 06340 Ph 860 445 8521 Fax 860 445 5873 Email [email protected]

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Case 3:03-cv-00630-DJS

Document 141

Filed 02/22/2007

Page 5 of 5

CERTIFICATION I hereby certify that a copy of the foregoing document was filed electronically, and that notice of this filing will be sent by e-mail through the Court's electronic filing system to all parties who may access this filing through the Court's system. This document was filed electronically on February 21, 2007.

BY /s/ Peter J. Bartinik, Jr. Peter J. Bartinik, Jr. # 14208 The Bartinik Law Firm, P.C. 100 Fort Hill Rd. Groton, CT 06340 Ph 860 445 8521 Fax 860 445 5873 Email [email protected]

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