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

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JOSEPH C. DOLAN, ESQ. (007376) 1650 North 1st Avenue Phoenix, Arizona 85003 (602) 266-7667 Fax (602) 277-9839 Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT IN AND FOR DISTRICT OF ARIZONA JERRY SIMMS, a single man, Plaintiff, vs STATE FARM FIRE AND CASUALTY COMPANY, an Illinois corporation; ABC CORPORATIONS I-X; JOHN DOES I-X, Defendants. MOTION FOR AWARD OF ATTORNEYS FEES CV-03-1415-PHX-ROS

Pursuant to L. R. Civ. 54.2(b)(1), plaintiff Jerry Simms hereby moves this Court for an award of attorneys fees and related non-taxable expenses in the present matter. The present award for attorneys fees and non-taxable expenses is made pursuant to A.R.S. §12-341.01. Plaintiff Simms will claim approximately $60,308 in attorneys fees and paralegal fees. This amount consists of $51,000 in attorneys fees payable to Joseph C. Dolan pursuant to a contingent fee agreement. This amount also consists of $9,308 incurred with Verdict Systems, LLC for paralegal and documentary/exhibit support at trial. The foregoing will be more fully established in the Memorandum in Support of Fees and Costs supplied by plaintiff pursuant to the Rules. RESPECTFULLY SUBMITTED this day of August, 2006.

By

s/Joseph C. Dolan 007376 JOSEPH C. DOLAN, ESQ. 1650 North 1st Avenue Phoenix, Arizona 85003 Attorney for Plaintiff

Case 2:03-cv-01415-ROS

Document 208

Filed 08/07/2006

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 7, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: William Phillips, Esq. BROENING OBERG WOODS & WILSON 1122 East Jefferson Phoenix, Arizona 85036 Attorneys for State Farm

I HEREBY CERTIFY that on August 7, 2006 I served the attached document by mailing a copy of the following: Hon. Roslyn Silver United States District Court, Suite 624 401 W. Washington Street Phoenix, Arizona 85003-2158

JOSEPH C. DOLAN

1650 North First Avenue Phoenix, Arizona 85003

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s/Joseph C. Dolan, Esq. 007376 Attorney

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