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

Case 3:03-cv-00149-WIG

Document 127

Filed 02/22/2005

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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)

FEBRUARY 22, 2005

PLAINTIFF'S MOTION1 FOR ATTORNEY'S FEES, COSTS, AND PREJUDGMENT INTEREST 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, costs, and prejudgment interest. 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.2 The jury awarded Plaintiff $170,000.00 in back pay and benefits and $85,000.00 in general compensatory damages. In support of his motion, Plaintiff submits a memorandum of law and these exhibits: (1) an Affidavit by his undersigned counsel ("Baird Affidavit") (Ex. 1); (2) a Table of Attorney's Fees and Costs with columns for "Total Hours," "Claimed Hours," "Fees," Client Receivables," and "Costs," with twenty-six (26) attached invoices (Ex. 2); (3) a contemporaneous listing of

Local Civil Rule 11 references a "motion" for attorney's fees while, in practice and in case law, such a request is referred to as an "application." The terms are used interchangeably by Plaintiff. 2 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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ORAL ARGUMENT REQUESTED

Case 3:03-cv-00149-WIG

Document 127

Filed 02/22/2005

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costs maintained on the software program "Quicken" (Ex. 3); and (4) an Affidavit by Attorney Peter B. Prestley (Ex. 4). The attached memorandum of law and its exhibits support Plaintiff's motion for attorney's fees in the amount of $110,718.00 with a 2.0 multiplier and costs of $2813.41.

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 Motion for Attorney's Fees, Costs, and Prejudgment Interest was mailed first-class, postage paid to the following counsel of record on February 22, 2005: Margaret J. Strange, Esq. Jackson Lewis LLP 55 Farmington Ave Ste 1200 Hartford CT 06105 David L. Metzger, Esq. Metzger & Associates 25 Capitol Ave Hartford CT 06106

______________________________ Rachel M. Baird

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