Free Motion for Attorney Fees - District Court of Connecticut - Connecticut

Case 3:03-cv-00986-JCH Document 162 Filed 01/17/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, CIVIL ACTION NO.
3:03-CV-986 (JCH)
Plaintiff,
V.
SEMPRA ENERGY TRADING
CORPORATION, Jaauaw 17, 2006
Defendant.
DEFENDANT’S MOTION FOR AWARD OF ATTORNEYS’ FEES
Pursuant to Federal Rule of Civil Procedure 54(d)(2), Local Rule ll and 42 U.S.C. §
2000e-5(k), Defendant respectfully moves this Court for entry of an Order awarding Defendant
its reasonable attomeys’ fees incurred after it became obvious that Plaintiff’ s claims were
frivolous, unreasonable and without foundation. This motion is supported by associated
Memorandum of Law and bythe Declaration of Raymond W. Bertrand.
Dated: January 17, 2006 PAUL, HASTINGS, JANoPs1 . Ta/G`
Mary . Dollarhide (ctl225l)
Raymond W. Bertrand (ct22968)
Paul, Hastings, J anofsky & Walker LLP
1055 Washington Blvd.
Stamford, CT 06901
(203) 961-7477
Attorneys for Defendant Sempra Energy Trading Corp.

Case 3:03-cv-00986-JCH Document 162 Filed 01/17/2006 Page 2 of 2
CERTIFICATE OF SERVICE
The undersigned, a member of the bar of this Court, hereby certifies that on this 17th day
A of J anuary, 2006, a true and correct copy of the foregoing Motion for Award of Attomeys’ Fees
was served on the following counsel of record via hand delivery to:
Brendan J. O’Rourke, Esq.
Jeffrey M. McCormick, Esq.
Ann H. Brickley, Esq.
O’Rourke & Associates, LLP
27 Pine Street
New Canaan, CT 06840
L.
Ra ond W. Bertrand
LEGAL_US_W # S3l77648.l