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

Case 1:04-cv-01211-MPT

Document 41

Filed 05/01/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE : : Plaintiff, : : v. : : THOMAS P. GORDON, individually: and in his official capacity; : SHERRY FREEBERY, individually : and in her official capacity; : COLONEL JOHN L. CUNNINGHAM, : RETIRED, individually; : COLONEL DAVID F. MCALLISTER, : individually and in his : official capacity; and : NEW CASTLE COUNTY, : a municipal corporation, : : Defendants. : CHIEF HENRY V. TOBIN III,

C.A. No. 04-1211 MPT

PLAINTIFF'S MOTION FOR REASONABLE ATTORNEYS' FEES OF THE LAW OFFICE OF JOHN M. LaROSA, PURSUANT TO 42 U.S.C. § 1988 AND FED.R.CIV.P. 541 1. Pursuant to 42 U.S.C. § 1988 and Fed.R.Civ.P. 54,

plaintiff Moves that the Court make an award of attorneys' fees of the Law Office of John M. LaRosa, for the successful entry of judgment in this case. 2. Memoranda in support of this motion will proceed in

accord with the Jointly Stipulated Scheduling Order for

Since the time records of plaintiff's counsel, The Neuberger Firm, P.A. and the Law Office of John M. LaRosa were kept using different billing systems, a separate motion and memorandum is being filed by The Neuberger Firm, P.A. relating to its attorneys' fees and costs.

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Case 1:04-cv-01211-MPT

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Filed 05/01/2008

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Plaintiff's Fee Petition (D.I. 38) issued by the Court in its Order dated April 17, 2008. Respectfully Submitted, LAW OFFICE OF JOHN M. LaROSA /S/ John M. LaRosa JOHN M. LaROSA, ESQUIRE (#4275) Two East 7th Street, Suite 302 Wilmington, DE 19801-3707 (302) 655-0582 [email protected] Attorney for Plaintiff Dated: May 1, 2008

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Case 1:04-cv-01211-MPT

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Filed 05/01/2008

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CERTIFICATE OF SERVICE I, John M. LaRosa, being a member of the bar of this Court do hereby certify that on May 1, 2008, I electronically filed this PLEADING with the Clerk of the Court using CM/ECF which will send notification of such filing to the following: William W. Bowser, Esq. Margaret M. DiBianca, Esq. Young Conaway Stargatt & Taylor LLP The Brandywine Building 1000 West Street, 17th Floor P.O. Box 391 Wilmington, DE 19899 Charles E. Butler, Esq. 1224 North King Street Wilmington, DE 19801 Kathleen M. Jennings, Esq. Oberly Jennings and Rhodunda, P.A. 1220 North Market Street, Suite 710 P.O. Box 2054 Wilmington, DE 19899 /s/ John M. LaRosa JOHN M. LaROSA, ESQ. (#4275)