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

Case 1:03-cv-02582-RPM

Document 38

Filed 06/30/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Senior District Judge Richard P. Matsch Civil Action No. 03-

cv - 02582 RPM

NICHOLAS SYTSEMA, a minor, by and through his parents, JACK AND REBECCA SYTSEMA, Plaintiff, v. ACADEMY SCHOOL DISTRICT NO. 20, Defendant.

MOTION FOR ATTORNEYS' FEES

COMES NOW, Michael C. Cook, the attorney for Plaintiff, Nicholas Sytsema, a minor, by and through his parents, Jack and Rebecca Sytsema, to move the Court for an order awarding attorneys' fees to counsel for Plaintiff as the prevailing party in this action. In support thereof and in compliance with D.C. COLO. LCivR 54.3, Plaintiff respectfully submits the attached Affidavit of Attorneys' Fees setting forth a detailed description of the services rendered, the amount of time spent, the hourly rate, the total amount claimed, and a summary of counsel's relevant qualifications and experience. WHEREAS, Plaintiff respectfully requests that the Court order Defendant to reimburse counsel for the Plaintiff the sum of $75,676.50 for attorneys' fees incurred in the above entitled action.

Case 1:03-cv-02582-RPM

Document 38

Filed 06/30/2006

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DATED this 30th day of June, 2006. Respectfully submitted, By: s/ Michael C. Cook Michael C. Cook, #24155 Michael C. Cook, P.C. 509 North Tejon Street Colorado Springs, CO 80903 Telephone: (719) 632-1222 Facsimile: (719) 632-0974 Electronic Mail: [email protected]

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Case 1:03-cv-02582-RPM

Document 38

Filed 06/30/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 30th day of June, 2006, a true and correct copy of the foregoing MOTION FOR ATTORNEYS' FEES was served on the following at the indicated address by:

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hand delivery first class U.S. mail, postage prepaid e-mail

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certified U.S. mail, postage prepaid facsimile transmittal

Robert I. Cohn, Esq. [email protected]

s/ Michael C. Cook Michael C. Cook

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