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

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Rosval A. Patterson, SBN 018872 Patterson & Associates, P.L.L.C. 777 East Thomas Road, Suite 210 Phoenix, Arizona 85014 Tel.: (602) 462-1004 E-mail: [email protected] Attorney for the Plaintiff

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) Case No.: CIV 04-429 PHX MHM ) ) ) ) MOTION REQUESTING ) ATTORNEY'S FEES ) ) ) ) ) ) )

Alexander Jung, Plaintiff, vs. John E. Potter, Postmaster General , Defendant.

Plaintiff, Alexander Jung (hereinafter referred to as "Plaintiff") by and through undersigned counsel submits his request for attorney's fees in accordance with Fed. R. Civ. P. 54(d)(2)(B). On July 1, 2008, this Court entered Judgment against the Defendant, John Potter and in favor of Plaintiff in the amount of $172,142.12 in equitable damages. The jury's verdict for compensatory damages was in the amount of $280,000.00 for Defendants violation of the Rehabilitation Act. The judgment establishes Plaintiff as the prevailing party, entitling him to an award of attorney's fees pursuant to 29 U.S.C. §§ 505 (b), 794a(a)(2) and 794a(b).

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Case 2:04-cv-00429-MHM

Document 219

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Plaintiff seeks to recover his reasonable attorney's fees (attorneys' hourly rates times hours worked) in the amount of $529,167.00 as the prevailing party in this action. Additionally, Plaintiff requests the court award him the lodestar value of the attorney's fees amounting to $1,058,334.00. This figure is based on the lodestar value of Plaintiff's reasonable attorney's fees times a requested multiplier of 2.0 to compensate Plaintiff for the risk of non-payment, the inevitable delay in receiving payment, and to encourage Plaintiff's attorneys and other civil rights attorneys to undertake public interest litigation of similar importance in the future. Respectfully submitted this 15th day of July, 2008 s/Rosval A. Patterson Rosval A. Patterson 777 E. Thomas Rd. #210 Phoenix, AZ 85014 Attorney for the Plaintiff

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CERTIFICATE OF SERVICE I hereby certify that on the 15th of July, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF Systems for filing and transmittal of a Notice of Electronic Filing for the following CM/ECF registrants: Suzanne M Chynoweth at [email protected] A copy of this document was provided by mailed to: The Honorable Judge Mary H. Murguia United States District Court 401 West Washington Courtroom 525 Phoenix, AZ 85003

By:

s/Stephanie Coulter Stephanie Coulter

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