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

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RICHARD J. HARRIS LAW OFFICES, P.C .
4445 E. HOLMES AVE., SUITE 106 MESA, AZ 85206 (480) 854-3500 [email protected]

Richard J. Harris ­ #013859 Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Matthew Shaffer, Plaintiff, v. State of Arizona Citizens Clean Election Commission; Colleen Connor and Chad Jacobs; husband and wife; and Jessica Funkhouser and Lindy Funkouser, husband and wife; John Does I-X; Jane Does I-X Defendants. Pursuant to Rule 54(d)(2) of the Federal Rules of Civil Procedure and Local Rule 54.2, Plaintiff Matt Shaffer hereby supplements his motion for an award of attorneys' fees and related non-taxable expenses pursuant to 42 U.S.C. § 1988. The fees and expenses request for the 42 U.S.C. §1983 claim is based upon a judgment of $1,100,000.00 on that claim entered by the court on October 6, 2005 (later remitted to $660,000.00). The fees sought are fairly estimated at $264,865.50 based on 931.2 hours spent by Attorney Richard J. Harris (807.5 hrs), Attorney David C. Larkin (103.2 hrs), Attorney Robert Gregory (2 hrs); paralegal Susan Larkin (18.5). The total expenses sought are fairly estimated to be $10,684.11. This includes expert witness fees; cost of trial transcript; outside copy and delivery charges; and parking charges. This reflects the business judgment to not charge the client for the voluminous copies made in the office; no charges for faxes; no charges for computer aided research; etc. Case 2:03-cv-02344-FJM Document 168 Filed 04/03/2006 Page 1 of 2 CV03 2344 PHX FJM PLAINTIFF'S SUPPLEMENTAL MOTION FOR AWARD OF ATTORNEYS' FEES AND EXPENSES

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DATED this April 3, 2006 R ICHARD J. H ARRIS L AW O FFICES, P.C.

By: s/Richard J. Harris Richard J. Harris 4445 E. Holmes Ave., Suite 106 Mesa, AZ 85206 Copy of the foregoing electronically transmitted via the U.S. District Court's Electronic Case Filing System this April 3, 2006 and to: Jay Zweig Gallagher & Kennedy 2575 E. Camelback Rd. Phoenix, AZ 85016-9225 Attorney for Defendants

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R ICH ARD J. H ARRIS L AW O FFICES , P .C .
Shaffer\pleadings\Motion for Attorneys' Fees and Expenses Supplement

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