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

Case 1:00-cv-02325-MSK-MEH

Document 315-3

Filed 04/27/2006

Page 1 of 3

D O N H. S H E R W O O D Attorney at Law 10861 West 28th Place Denver, Colorado 80215 Telephone (303) 233-0335 or (303) 916-7726 (Cell) Facsimile (303) 237-4180 eMail: [email protected] Statement Date: March 6, 2006 For fees from May 3 through July 2, 2001 Billing Account No. 224.02 Golden Cycle Gold Corporation 1515 South Tejon Street, Suite 201 Colorado Springs, Colorado 80906 Attention: Mr. R. Herbert Hampton President and Chief Executive Officer Re: Defense of Suit Brought Against the Corporation by the Sierra Club and the Mineral Policy Council in the United States District Court for the District of Colorado (No. 00-MK-2325) For: Representation of the Corporation by Mr. Sherwood in the litigation, with particular attention to such matters as may require pleadings, discovery, evidence, and witnesses separate from those of the owner and operator, but without increasing the cost of the litigation except as may be necessary to prevent liability to the Corporation separate from or jointly with the other defendants as to such liability as may be determined to exist as against the Joint Venture entity owning the property and against the other defendant corporations conducting for the benefit of that entity operations upon that property.
PREVIOUS BALANCE BILLED FEES FOR SERVICES BILLED AT $ 235.00 HOURLY:

$

0.00

3/26/01 Pursuant to a special entry of appearance in behalf of all defendants, AngloGold counsel filed a motion in behalf of all

During this billing period, Mr. Sherwood was generally confined to his home following hospitalization for a serious illness

Case 1:00-cv-02325-MSK-MEH

Document 315-3

Filed 04/27/2006

Page 2 of 3

defendants for an extension of time in which to respond to the Complaint; by Minute Order, the motion was granted 5/3/01 Don H. Sherwood, Craig R. Carver, and Michelle C. Carmody entered their appearances in behalf of Golden Cycle Gold Corporation and simultaneously filed a motion to dismiss in behalf of that defendant adopting and incorporating therein the AngloGold defendants' brief in support of their motion to dismiss; informed Mr. Hampton, President and Chief Executive Officer of Golden Cycle Gold Corporation, that the repre-sentation had been so commenced, and that Mr. Sherwood would be responsible for the defense, with the assistance of Ms. Carmody, and Mr. Carver to act for Mr. Sherwood in his absence or inability to continue; described to Ms. Carmody the work which will be required primarily by her during the early stages of the litigation 5/18/01 Prepared and filed motion for protective order to stay discovery for the reasons given by the AngloGold defendants, and then met with Ms. Carmody to outline the approach to be taken by Golden Cycle 5/18/01 Attention with Ms. Carmody to Rule 26(a) disclosures 5/22/01 Reviewed the Plaintiffs' initial Rule 26(a) disclosures 5/25/01 Reviewed Plaintiffs' responses to the motions to dismiss 5/30/01 Reviewed Plaintiffs' responses in opposition to the motions for protective order to stay discovery 6/ 1/01 Attended and participated in a hearing before the Magistrate Judge concerning the motions regarding discovery; reported results to Ms. Carmody and described necessary research on apparent legal issues 6/13/01 Prepared and filed a reply brief in support of the motion to dismiss; attended and participated in a scheduling conference with Magistrate Judge Schlatter concerning when defendants will be required to state such defenses as they intend to raise; did not participate in so much thereof as related to whether Plaintiffs should be allowed to inspect the interior of the Roosevelt Tunnel

0.00

0.00

0.00

0.00

0.3 0.1 0.2 0.8

70.50 23.50 47.00 188.00

0.3

70.50

0.9

211.50

1.8

423.00

During this billing period, Mr. Sherwood was generally confined to his home following hospitalization for a serious illness

Case 1:00-cv-02325-MSK-MEH

Document 315-3

Filed 04/27/2006

Page 3 of 3

D O N H. S H E R W O O D

PAGE 3.

6/26/01 Considered AngloGold Defendants' substitution of exhibits and the scheduling order signed by Magistrate Judge Schlatter 0.5 117.50 _______ __________ TOTAL FEES FOR THIS PERIOD 4.9 1,151.50 DISBURSEMENTS TOTAL FEES AND DISBURSEMENTS None ____________ $ 1,151.50

THIS STATEMENT IS DUE UPON RECEIPT AND DOES NOT INCLUDE FEES OR DISBURSEMENTS AFTER THE STATEMENT-THROUGH DATE