Free Affidavit - District Court of Delaware - Delaware

Case 1:O4—cv-00705-JJF Document 41 Filed O3/31/2006 Page 1 of 2
_ UNITED STATES DISTRICT COURT
DISTRICT OP DELAWARE
) Q
IAMES M. KAMARA, )
) C A No. 04—705 ITF
Plaintiff, )
)
MICHAEL FUNDING, LLC, a Limited Liability ) E
Company ofthe State of New York, ) E
) 1
Defendant. )
——————·————— !
I APFIDAVIT OP MICHAEL W. ARRINGTON
STATE Ol? DELAWARE )
) ss
COUNTY Ol: NEW CASTLE ) `
BE IT REMEMBERED, that on this 3lst day of March, A D., 2006, personally appeared
before me, a Notary Public for the state and county aforesaid, MICHAEL W. ARRINGTON,
personally known to me to be such, who deposes and says as follows:
1.. He is a member ofthe Bar ofthe Supreme Court of`Delaware and is the managing
member of the Wilmington office of Parkowski, Guerke & Swayze, P..A. He makes this
application pursuant to the March 24, 2006, Order of the Honorable Joseph J. Faman, Ir on
Defendanfs Motion to Compel. l
2., He-represents Defendant, Michael Funding, LLC, in the above-captioned matter
at the rate of`$325.00 per hour.

Case 1 :O4—cv-00705-JJF Document 41 Filed O3/31/2006 Page 2 of 2 I I
3. On February 28, 2006 and March l, 2006, he spent 1..00 hours in preparation and
filing ofthe Motion to Compel and exhibits. The total expense incurred by the Respondent on
the preparation ofthe Motion to Compel exclusively is $325 .00
4.. Defendant is liable for all amounts owed.
5 .. Other relevant factors under DLRPC 1.5 include:
a. The time was utilized efficiently as he attempted to obtain compliance without
filing of the motion;
b. Plaintiff was aware that failure to comply would require a motion that would
preclude other employment by him during such time;
c The fee is similar to that customarily charged in the jurisdiction;
d The total time spent on good faith efforts and communications with" Plaintiff ` D
was three times the amount of time requested in this affidavit;
e. Defendant has a two-year history with him on this matter.
. 6. He submits this application for attorney’s fees and costs in the total amount of
$325.00..
I aa
MICHAEL W. GTON
SWORN TO AND SUBSCRTBED before me the day and year aforesaid
Notary Public T
... ...~r A. iii ‘‘r ‘
my gcmmmm Expires June 5. 2007 _

Case 1:04-cv-00705-JJF

Document 41

Filed 03/31/2006

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Case 1:04-cv-00705-JJF

Document 41

Filed 03/31/2006

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