Free Motion for Cost and Fees - District Court of Connecticut - Connecticut

Case 3:03-cv-00149-WIG

Document 174

Filed 01/05/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FERRON SHORTER JR., Plaintiff, v. HARTFORD FINANCIAL SERVICES GROUP, INC., Defendant. : : : : : : : : : :

CASE NO. 3:03-cv-149(WIG)

JANUARY 5, 2006

PLAINTIFF'S SUPPLEMENTAL MOTION FOR ATTORNEY'S FEES AND COSTS Plaintiff Ferron Shorter Jr., by and through his undersigned counsel and pursuant to 42 U.S.C. § 2000e-2(k) and 28 U.S.C. § 1920, hereby moves for attorney's fees and costs for the time period February 23, 2005, through January 5, 2006, inclusive. Following a five-day trial, the jury returned a verdict on January 28, 2005, in favor of the Plaintiff, Ferron Shorter Jr., on his claims of race and gender discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., as well as on his claim of negligent infliction of emotional distress.1 Plaintiff filed post-trial motions on February 22, 2005, (doc. # 127) and February 28, 2005, (doc. # 133) for equitable relief, specifically, attorney's fees, costs, and prejudgment interest. The Court issued an Order on May 31, 2005, granting in part and denying in part Plaintiff's motions for equitable relief. (doc. #150.) Following Plaintiff's submission of pre-judgment interest calculations on June 28, 2005, (doc. # 156) the Court issued orders dated July 15, 2005, (doc. ## 158, 159) and rendered judgment in favor of Plaintiff in the amount of $516,963.97. (doc. # 160.)

The jury rendered verdicts in favor of Defendant on Plaintiff's claim of hostile work environment and intentional infliction of emotional distress.

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Case 3:03-cv-00149-WIG

Document 174

Filed 01/05/2006

Page 2 of 3

The Defendant filed a Motion for Judgment as a Matter of Law on July 28, 2005. (doc. # 161.) Plaintiff opposed Defendant's motion for judgment as a matter of law against Plaintiff's discrimination claims. (doc. # 171.)2 On December 6, 2005, the Court granted in part and denied in part Defendant's Motion for Judgment as a Matter of Law. (doc. # 172.) The Court's December 6, 2005, Order did not change the Judgment against Defendant in the amount of $516,963.97. In accordance with the Court's grant of Plaintiff's motion to file a supplemental motion for attorney's fees and costs within thirty (30) days following an Order on Defendant's Motion for Judgment as a Matter of Law, Plaintiff hereby moves for supplemental attorney's fees and costs in the amount of $8784.00, and such pre-and post-judgment interest as may attach. In support, Plaintiff submits an Affidavit of Rachel M. Baird as Exhibit 1 and an invoice dated January 5, 2005, as Exhibit 2. The instant motion incorporates (1) Plaintiff's Memorandum of Law in Support of Motion for Attorney's Fees, Costs, and Pre-Judgment Interest filed on February 22, 2005, (doc. #127-1); (2) Plaintiff's Reply on that motion (doc. # 147); and (3) the Affidavit of Peter Prestley (doc. # 127-5) in support filed on February 22, 2005.

Plaintiff did not oppose judgment as a matter of law against the negligent infliction of emotional distress common law claim.

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Case 3:03-cv-00149-WIG

Document 174

Filed 01/05/2006

Page 3 of 3

PLAINTIFF FERRON SHORTER JR.

BY:

________________________ Rachel M. Baird (ct12131) Law Office of Rachel M. Baird 379 Prospect St Torrington CT 06790-5239 Tel: (860) 626-9991 Fax: (860) 626-9992 [email protected]

CERTIFICATION I HEREBY CERTIFY that a copy of the foregoing Plaintiff's Supplemental Motion for Attorney's Fees and Costs, and Exhibits 1 and 2, were mailed first-class, postage paid to the following counsel of record on February 22, 2005: Margaret J. Strange, Attorney Jackson Lewis LLP 90 State House Sq Fl 8 Hartford CT 06103

______________________________ Rachel M. Baird

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