Free Notice (Other) - District Court of Colorado - Colorado

Case 1:03-cv-02440-EWN-BNB

Document 83

Filed 08/23/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2440-EWN-BNB MATTHEW ARAGON, Plaintiff, v. LIFE QUOTES, INC. Defendant. ______________________________________________________________________________ NOTICE OF ATTORNEY'S LIEN ______________________________________________________________________________ Pursuant to §12-5-119, C.R.S., the undersigned hereby provides notice of an attorney's lien in the above-cited case in the amount of $36,519.98, and, as grounds therefore, states as follows: 1. Mr. Aragon entered into an agreement with the undersigned on May 3, 2004, to

represent him in on-going litigation. See Exhibit 1 [Engagement Letter, dated May 5, 2004]. Under that agreement, Mr. Aragon promised to pay the costs of litigation and fees for the services of the undersigned on an hourly basis, at a rate of $200 per hour. Id. 2. The undersigned did provide legal services to Mr. Aragon, including but not

limited to responding to defendant's written discovery, defending and taking depositions, and responding to a motion for summary judgment. The brief prepared by the undersigned in response to defendant's motion for summary judgment was successful in defeating the motion with regard to the federal claims made in Mr. Aragon's complaint. 3. The undersigned provided 224 hours of legal services, totaling $44,800. See

Exhibits 2a-2e [Bills for costs and legal services]. The undersigned also incurred at least

Case 1:03-cv-02440-EWN-BNB

Document 83

Filed 08/23/2005

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$3,398.48 in costs in providing these services. Id. 4. The undersigned billed Mr. Aragon for these services and costs, minus adjustments

for services provided at no cost. See Exhibits 2a-2e. Mr. Aragon paid a portion of these bills, but did not pay the remaining $36,519.98. 5. For reasons indicated in the applicable filings, the undersigned was forced to

request permission to withdraw as representative of Mr. Aragon, which request was granted by this Court. WHEREFORE, the undersigned provides notice to the Court and the parties of her lien in the amount of $36,519.98.

DATED this 23rd day of August, 2005.

Respectfully submitted,

s/Patricia S. Bangert Patricia S. Bangert, Esq. Bangert & Associates, LLC 3773 Cherry Creek Drive North, Suite 575 Denver, Colorado 80209 Former Attorney for Plaintiff Matthew Aragon

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Case 1:03-cv-02440-EWN-BNB

Document 83

Filed 08/23/2005

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CERTIFICATE OF SERVICE I hereby certify that on August 23, 2005, a true and correct copy of the foregoing was electronically filed with the Clerk of the Court using the CM/ECF system which sent notification of such filing to the following: Kristen L. Mix, Esq. and Stuart David Mann and deposited in the U.S. mail, first-class postage prepaid, without attachments, addressed to the following:

Matthew Aragon 4198 S. Timbervale Drive Evergreen, CO 80439

s/Patricia S. Bangert
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