Free Motion to Amend/Correct/Modify - District Court of Colorado - Colorado

Case 1:03-cv-02474-WYD-PAC

Document 156

Filed 03/07/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-02474-WYD-PAC CHARLOTTE SCHNEIDER and DEAN WYMER, Plaintiffs, v. LANDVEST CORPORATION, a Kansas corporation, And DAVID MASON, individually Defendants.

Plaintiff's Revised Motion for Attorney's Fees

Come now the Plaintiffs, Charlotte Schneider and Dean Wymer, by their counsel and move the Court for an award of attorney's fees, including actual costs incurred in litigation under the federal Fair Labor Standards Act. Plaintiffs seek an award of fees in the amount of $142,614.27, which includes $138,722.50 in attorney's fees and $3,891.77 in actual costs incurred in addition to those included in the Bill of Costs. This motion is supported by the Revised Brief in Support of the Motion for Attorney's Fees, exhibits to the brief, Affidavit of Glen Schlabs, Affidavit of Craig Cornish, Affidavit of Donna Dell'Olio, Affidavit of Ian Kalmanowitz and Affidavit of Cari Frederick. Certificate of Compliance With D. Colo. L. R. 7.1 The undersigned complied with Local Rule 7.1 by conferring with counsel for Landvest. The undersigned attempted to limit the fee litigation by suggesting stipulation

Case 1:03-cv-02474-WYD-PAC

Document 156

Filed 03/07/2006

Page 2 of 2

to the reasonableness of Plaintiffs' counsels' hourly rates. Landvest was unwilling to enter into any stipulations concerning the fee petition. Respectfully submitted this 7th day of March, 2006.

CORNISH & DELL'OLIO

s/ Donna Dell'Olio Donna Dell'Olio, #10887 Ian D. Kalmanowitz, #32379 431 N. Cascade Avenue, Suite 1 Colorado Springs, CO 80903 Phone: (719) 475-1204 Fax: (719) 475-1264 E-mail: [email protected] Attorneys for Plaintiffs

CERTIFICATE OF SERVICE I hereby certify that on this 7th day of March, 2006, I electronically filed the foregoing Plaintiff's Revised Motion for Attorney's Fees with the Clerk of Court using CM/ECF system which will send notification of such filing to the following e-mail addresses: Alan Rupe Stacia G. Boden Heather Davis [email protected] [email protected] [email protected]

s/Esther Kumma Abramson Esther Kumma Abramson

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