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

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

Document 151-6

Filed 02/28/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-cv-2474-WYD-PAC CHARLOTTE SCHNEIDER and DEAN WYMER, Plaintiffs, v. LANDVEST CORPORATION, a Kansas corporation, and DAVID MASON, individually, Defendants. DECLARATION OF GLENN H. SCHLABS I, Glenn H. Schlabs, having been informed that this Declaration is made under penalty of perjury, do hereby declare, based on my own personal knowledge, the following: 1. My name is Glenn H. Schlabs. I am over the age of 18, and I am fully competent

to testify concerning the matters contained in this Affidavit, of which I am aware based on my own personal knowledge. 2. I am an attorney licensed to practice law in Colorado and Nevada, and I am on

inactive status in Texas. I began the practice of law as an Air Force Judge Advocate in 1977 after graduating from the University of Texas School of Law. For all of my twelve years of active duty, I regularly engaged in the practice of employment law, representing the Department of the Air Force in a variety of labor and employment matters. During this time I also earned an LL.M. in labor law from Cornell University.

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

Document 151-6

Filed 02/28/2006

Page 2 of 2

3.

In 1989 I retired from the Air Force and began work as an associate in the firm of

Sherman & Howard L.L.C. For the past 17 years, I have regularly appeared in the federal and state courts in Colorado, Texas and Nevada. I am now an equity member in Sherman & Howard and am responsible for supervising employment litigation in federal and state courts as well as participating in that litigation as lead counsel. My responsibilities require me to appear regularly in the United States District Court for the District of Colorado. 4. I am familiar from experience with rates charged by firms for employment-related

litigation in Colorado, including Denver. In this case, I believe the rates charged by Plaintiff's counsel are customary and reasonable for that "market." In this regard, I understand Mr. Cornish charges a rate of $300/hour, Ms. Dell'Olio charges a rate of $250/hour and Mr. Kalmanowitz charges a rate of $200/hour. I believe these rates are reasonable and customary for partners (Mr. Cornish and Ms. Dell`Olio) and associates (Mr. Kalmanowitz), respectively. 5. Also, based on my experience, it is a customary practice for a firm to bill a client

the costs related to the taking of depositions; the costs of copies of documents made for use in preparing for and participating in trial; and the costs to the firm of using computer-assisted research. In accordance with 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. EXECUTED on this 28th day of February, 2006.

s/ Glenn H. Schlabs

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