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

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Quarles & Brady Streich Lang LLP
Firm State Bar No. 00443100 Renaissance One Two North Central Avenue Phoenix, Arizona 85004-2391
TELEPHONE 602.229.5200

André H. Merrett (#020889) Kathleen A. Biesterveld (#021676) Attorneys for Plaintiff Best Western International, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Best Western International, Inc., an Arizona non-profit corporation, Plaintiff, vs. Oasis Investments, L.P., a Utah limited partnership; and Richard M. Knapp, Defendants.

NO. CV-04-0123-PHX-ROS BEST WESTERN INTERNATIONAL, INC.'S
MOTION FOR AWARD OF ATTORNEYS' FEES AND RELATED NON-TAXABLE EXPENSES

Pursuant to Rule 54.2, United States District Court Local Rules of Civil Procedure (the "Rule"), Best Western International, Inc,. ("Best Western") hereby moves the Court for an award of attorneys' fees and non-taxable expenses in the above-entitled action. By Order dated November 8, 2005, this Court granted Best Western's Motion for Partial Summary Judgment as to Counts I and II of its Complaint against defendants. Accordingly, on January 20, 2006, Best Western filed its Motion for Entry of Judgment as to Counts I and II, along with a proposed form of judgment. The Court has yet to enter judgment, but it is that judgment upon which Best Western is entitled to the award sought herein. Best Western is also entitled to an award of attorneys' fees and costs pursuant to A.R.S. §§ 12-341, 12-341.01(A) and paragraph 36 of the agreement entered into by Best

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Western and defendants. Best Western hereby seeks an award of attorneys' fees in the amount of $6,049.50 and non-taxable expenses in the amount of $397.15. This motion is supported by the Memorandum of Points and Authorities filed herewith. WHEREFORE, Best Western International, Inc. hereby respectfully requests that the Court award it the amount of $6,446.65, representing the attorneys' fees and nontaxable expenses incurred in this action. RESPECTFULLY SUBMITTED this 24th day of March, 2006. QUARLES & BRADY STREICH LANG LLP Renaissance One Two North Central Avenue Phoenix, Arizona 85004-2391

By s/ André H. Merrett André H. Merrett Kathleen A. Biesterveld Attorneys for Plaintiff Best Western International, Inc.

ORIGINAL of the foregoing Motion electronically filed this 24th day of March, 2006, with the: Clerk of the U.S. District Court District of Arizona 401 West Washington Phoenix, Arizona 85003

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COPY of the foregoing Motion electronically delivered this 24th day of March, 2006, to: The Honorable Roslyn O. Silver United States District Judge 401 West Washington Phoenix, Arizona 85003 Thomas M. Stanley, Esq. KOGLMEIER, DOBBINS & SMITH, P.L.C. 715 North Gilbert Road Suite 5 Mesa, Arizona 85203-6656

s/ Mary Willson

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