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

Case 1:04-cv-00665-RPM

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00665-RPM DAVID HELLER, On Behalf of Himself and All Others Similarly Situated, Plaintiff, v. QUOVADX, INC., LORINE R. SWEENEY and GARY T. SCHERPING, Defendants. LEAD PLAINTIFF'S NOTICE OF MOTION AND APPLICATION FOR AWARD OF ATTORNEYS' FEES AND REIMBURSEMENT OF EXPENSES

Case 1:04-cv-00665-RPM

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TO:

ALL PARTIES AND THEIR ATTORNEYS OF RECORD PLEASE TAKE NOTICE that pursuant to this Court's Order of November 20, 2006, on a

date to be determined by the Court at the Bryon White United States Courthouse, 1823 Stout Street, Denver, Colorado, in the courtroom of the Honorable Richard P. Matsch, Lead Plaintiff will and hereby does move for an order awarding Lead Counsel attorneys' fees of 25% of the Settlement Fund and reimbursement of litigation expenses, including the expenses of the Lead Plaintiff. Lead Plaintiff's motion is based upon the Memorandum of Law in Support of Application for Award of Attorneys' Fees and Reimbursement of Expenses, the Declaration of Jeffrey W. Lawrence in Support of Lead Counsel's Application for an Award of Attorneys' Fees and Reimbursement of Expenses, the declarations of Joy Ann Bull, the Second Amended Stipulation of Settlement dated as of November 20, 2006, all other pleadings and matters of record, and such additional evidence and testimony as may be presented at the hearing on the Lead Plaintiff's motion. DATED: February 15, 2007 Respectfully submitted,

s/ Joy Ann Bull JOY ANN BULL JOY ANN BULL LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: 619/231-1058 619/231-7423 (fax) Email: [email protected]

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JEFFREY W. LAWRENCE DENNIS J. HERMAN EX KANO S. SAMS II LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 100 Pine Street, Suite 2600 San Francisco, CA 94111 Telephone: 415/288-4545 415/288-4534 (fax) Email: [email protected] Email: [email protected] Email: [email protected] Lead Counsel for Plaintiffs
S:\Settlement\Quovadx.set\MTN FEE AWARD 00039206.doc

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CERTIFICATE OF SERVICE I hereby certify that on February 16, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the attached Manual Notice List.

s/ Joy Ann Bull JOY ANN BULL LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 655 West Broadway, Suite 1900 San Diego, CA 92101-3301 Telephone: 619/231-1058 619/231-7423 (fax) E-mail:[email protected]

Case 1:04-cv-00665-RPM

Document 132

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Case 1:04-cv-00665-RPM

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Case 1:04-cv-00665-RPM

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