Free Motion for Settlement - District Court of Delaware - Delaware


File Size: 85.6 kB
Pages: 1
Date: December 31, 1969
File Format: PDF
State: Delaware
Category: District Court of Delaware
Author: unknown
Word Count: 481 Words, 2,853 Characters
Page Size: 614 x 792 pts
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https://www.findforms.com/pdf_files/ded/8716/29-2.pdf

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C · - - - .
ase 1.04 cv 01364 SLR Document 29-2 Filed 10/24/2005 Page 1 of 1
AGREEMENT FOR LEGAL SERVICES
1*: ( (
This Agreement is made this Qiday of 5 jg 7L 2004 between O V a EGP 0 4. . bra Lew,
and C. Christopher Brown and Brown, Goldstein & Levy, LLP
(hereafter "Attorneys"), as follows:
1. I hereby appoint C. Christopher Brown and Brown, Goldstein & Levy, LLP my
attorneys in law and in fact with full authorization to take such actions, including the tiling of a
lawsuit, as my Attorneys may deem necessary, reasonable, and proper to pursue my claim for
compensation or damages resulting from or related to Fresh Cut Lawn and Landscape Seryices’
nonpayment of overtime wages and other employee benefits. I agree to cooperate with my
Attorneys in pursuit of my claims.
2. My Attorneys agree to undertake my representation to and including settlement,
final judgment or conclusion of any proceedings related to my claims, exclusive of any appeal.
If I fail to cooperate with my Attorneys in pursuit of my claim, they may elect at any time to
discontinue my representation. Also, if in their professional judgment my Attorneys determine
that there is not a substantial likelihood of prevailing in pursuit of my claim, they may
discontinue representation.
3. In consideration for my Attorneys’ services and in the event of a favorable
judgment in this matter, I agree that my Attorneys may receive reasonable compensation for their
services and reimbursement of any expenses and costs incurred, and I assign to them any
amounts so awarded. I also agree that in the event of a settlement, my Attorneys have the right
to receive the greater of (i) reimbursement of their professional compensation, plus incurred
expenses and costs or (ii) thirty-three percent (33%) of the total recovery, minus any statutory
attorneys’ fees awarded or paid to my attorneys. If the complaint and! or claims brought on my
behalf result in no recovery, I will have no obligation to pay attorneys’ fees.
4. I further agree, authorize and direct that any checks issued by the defendants to
me in connection with my claim shall be paid to my Attorneys as trustees on my behalf. After
attorneys’ fees are deducted therefrom, the balance shall be forwarded to me by my Attomeys.
5. I understand that under Section l5(a)(3) of the Fair Labor Standards Act
("FLSA”), I cannot be discharged, disciplined, or otherwise penalized by Fresh Cut Lawn and
Landscape Services because of my having filed a FLSA lawsuit arrd/or claim.
6. No representation has been made to me as to what amount, if any, I may be
entitled to recover in this case.
IN WITNESS WHEREOF, the parties have hereby set their hands and seals.
I I A
’/ P ` I
‘ arntr ` L_ C. Christophe Brown
N"! BROWN, GOLDSTEIN & LEVY, LLP
120 East Baltimore St., Suite 1700
Baltimore, MD 21202
410-962-1030