Free Statement - District Court of Colorado - Colorado

Case 1:00-cv-02350-LTB-MJW

Document 50

Filed 01/25/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 00-cv-02350-LTB-MJW PAULETTE GOMEZ, Plaintiff, v. KING SOOPERS, INC., Defendant.

DEFENDANT'S REASONABLE EFFORT STATEMENT REGARDING BILL OF COSTS

Defendant King Soopers, Inc., through its attorneys SHERMAN & HOWARD L.L.C. and pursuant to D.C.COLO.LCivR 54.1, hereby files Defendant's Reasonable Effort Statement Regarding Defendant's Bill of Costs. In support of this statement, Defendant states as follows: 1. 2. This case was dismissed pursuant to the Court's Order dated January 10, 2006. Defendant's counsel submitted its Bill of Costs with supporting documentation to the

Court on January 25, 2006. Defendant's counsel also attempted to serve the Bill of Costs on Plaintiff's counsel that same day. 3. Defendant's counsel attempted to confer with Plaintiff's counsel regarding Defendant's

Bill of Costs in an effort to agree on the amount of the costs, but was unable to locate Plaintiff's counsel. Plaintiff's counsel's telephone number has been disconnected, and there is no current listing with directory assistance. Further, Plaintiff's counsel is no longer at the last known address listed

Case 1:00-cv-02350-LTB-MJW

Document 50

Filed 01/25/2006

Page 2 of 3

on Plaintiff's filings, and the undersigned counsel was unable to obtain a current mailing address for Plaintiff's counsel. In addition, Defendant's counsel's office tried to communicate with Plaintiff's counsel through electronic mail but received no response. Accordingly, the parties were not able to stipulate regarding costs. However, because Plaintiff's counsel cannot be reached and because Defendant's counsel has learned that Plaintiff's counsel's license to practice law has been suspended by the Colorado Supreme Court, counsel for Defendant has served its Bill of Costs and this Statement upon Plaintiff's counsel and Plaintiff at their last known addresses. Respectfully submitted this 25th day of January, 2006. SHERMAN & HOWARD L.L.C.

s/ Edward J. Butler Raymond M. Deeny Edward J. Butler 90 South Cascade Avenue, Suite 1500 Colorado Springs, CO 80903 (719) 475-2440/Telephone (719) 635-4576/Facsimile [email protected]; [email protected] Attorneys for Defendant

2

Case 1:00-cv-02350-LTB-MJW

Document 50

Filed 01/25/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on January 25, 2006, a true and correct copy of the foregoing was electronically filed with the Clerk of Court using the CM/ECF system, and I hereby certify that on January 25, 2006, I have mailed a true and correct copy of the document to the following non CM/ECF participants by depositing the foregoing in the U.S. Mail, postage prepaid, addressed to the following: Cecilia M. Serna, Esq. Law Offices of Cecilia M. Serna, Esq. 600 17th Street, Suite 2800 South Denver, CO 80202-5428 Ms. Paulette Gomez 11108 Eudora Circle Thornton, CO 80233 s/ Peggy J. Barber, Secretary to Edward J. Butler

3