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

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RICHARD J. HARRIS LAW OFFICES, P.C .
4445 E. HOLMES AVE., SUITE 106 MESA, AZ 85206 (480) 854-3500 [email protected]

Richard J. Harris ­ #013859 Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Matthew Shaffer, Plaintiff, v. State of Arizona Citizens Clean Election Commission; Colleen Connor and Chad Jacobs; husband and wife; and Jessica Funkhouser and Lindy Funkouser, husband and wife; John Does I-X; Jane Does I-X Defendants. Pursuant to Rule 54(d)(2) of the Federal Rules of Civil Procedure and Local Rule 54.2, Plaintiff Matt Shaffer moves for an award of attorneys' fees and related non-taxable expenses pursuant to 42 U.S.C. § 1988. The fees and expenses request for the 42 U.S.C. §1983 claim is based upon a judgment of $1,100,000.00 on that claim entered by the court on October 6, 2005. The fees sought are fairly estimated at $219,997.50 based on 804.9 hours spent by Attorney Richard J. Harris (677.5 hrs), Attorney David C. Larkin (100.4 hrs), Attorney Robert Gregory (27 hrs). The total expenses sought are fairly estimated to be $2,522.00. This includes CV03 2344 PHX FJM PLAINTIFF'S MOTION FOR AWARD O F ATTORNEYS' FEES AND EXPENSES

$1,450.00 for expert witness fees and expenses and $72.00 in parking charges. This reflects the business judgment to not charge the client for the voluminous copies made in the office; no charges for faxes; no charges for computer aided research; etc. Case 2:03-cv-02344-FJM Document 142 Filed 10/18/2005 Page 1 of 2

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In addition, Plaintiff reserves the right to supplement this petition with the amount of fees and expenses incurred in preparing this motion, the Bill of Costs and the memorandum of points and authorities and supporting documentation, and for any fees and expenses in responding to any response or other post-judgment motions which the Defendants may file. DATED this October 18, 2005 R ICHARD J. H ARRIS L AW O FFICES, P.C.

By: s/Richard J. Harris Richard J. Harris 4445 E. Holmes Ave., Suite 106 Mesa, AZ 85206 Copy of the foregoing electronically transmitted via the U.S. District Court's Electronic Case Filing System this August 26, 2005 and to: Jay Zweig Melissa Berrens Gallagher & Kennedy 2575 E. Camelback Rd. Phoenix, AZ 85016-9225 Attorney for Defendants

s/Richard J. Harris
Shaffer\pleadings\Motion for Attorneys' Fees and Expenses

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R IC H A R D J. H AR RIS L A W O FFICES , P . C .

2 Case 2:03-cv-02344-FJM Document 142 Filed 10/18/2005 Page 2 of 2