Free Joinder - District Court of Arizona - Arizona

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Richard L. Green ­ State Bar #003259 Paul D. Friedman ­ State Bar #012716 O'STEEN & HARRISON Attorneys at Law 300 W. Clarendon Avenue Suite 400 Phoenix, Arizona 85013-3424 (602) 252-8888 Attorneys for Plaintiff-Intervenor IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Equal Employment Opportunity Commission, Plaintiff and, No. CIV 03-1210 PHX PGR PLAINTIFF-INTERVENOR MILES' JOINDER IN EQUAL EMPLOYMENT OPPORTUNITY COMMISSION'S RESPONSE TO DEFENDANTS' MOTION FOR ATTORNEY FEES

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Kelley J. Miles, Plaintiff-Intervenor, v. The Boeing Company, a Delaware corporation, and Boeing Aerospace Operation, Inc., a Delaware corporation, Defendants.

Plaintiff-Intervenor Kelley J. Miles joins in Plaintiff Equal Employment Opportunity Commission's Response to Defendants' Motion for Award of Attorneys' Fees. On October 12, 2005, Defendants The Boeing Company and Boeing

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Aerospace Operations, Inc. (collectively "Boeing") moved this Court for an
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award of (a) attorneys' fees in regard to the retaliation claims of Plaintiff and
Case 2:03-cv-01210-PGR Document 133
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Plaintiff-Intervenor and (b) related non-taxable expenses. Defendant Boeing, however, failed to state the amount of attorneys' fees it was seeking or provide a fair estimate of the amount sought1 nor did it provide any information at all concerning related nontaxable expenses it was seeking. Both Rule 54(d)(2)(B)

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of the Federal Rules of Civil Procedure and Rule 54.2(b)(1)(B) of the Local Rules Civ. require this information be specified in the Motion. Pursuant to LRCiv. 54.2(b)(2), Boeing has stated it will submit its memorandum of points and authorities and the supporting documentation specifically required by 54.2(d) within 60 days of entry of judgment, or as otherwise ordered by the Court.

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After Boeing submits its memorandum and other documentation, Plaintiff13 14 15 16 17 18 19 20 21 22 23 24 25

Intervenor will file its response as provided for in LRCiv. 54.2(b)(3). DATED this 31st day of October, 2005. O'STEEN & HARRISON Attorneys at Law s/Richard L. Green Richard L. Green Paul D. Friedman 300 W. Clarendon Avenue Suite 400 Phoenix, Arizona 85013-3424 Attorneys for Plaintiff-Intervenor

Boeing merely stated its total attorneys' fees were approximately $157,000.00, but did not estimate the amount of the fees attributable to the retaliation claims, the 2:03-cv-01210-PGR atDocument 133 Case only fees which are issue. Filed 10/31/2005 Page 2 of 3
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Original of the foregoing filed electronically with the Clerk of the United States District Court this 31st day of October, 2005. Copy of the foregoing mailed this 31st day of October, 2005 to: Mary Jo O'Neill C. Emanuel Smith Katherine J. Kruse EEOC Phoenix District Office 3300 North Central Avenue, Suite 690 Phoenix, Arizona 85012 Attorneys for Plaintiff Tibor Nagy, Jr. Erica Rocush Snell and Wilmer One South Church Avenue, Suite 1500 Tucson, Arizona 85701 Attorneys for Defendants By s/Beverly Hart

Case 2:03-cv-01210-PGR

Document 133

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