HomeMy WebLinkAbout2018CV220 - Stacy Lynne V. Noah Beals, Senior Planner, And Jeremy Call - 037A - ExhibitFrom: kschutt@wicklaw.com <kschutt@wicklaw.com>
Sent: Thursday, August 01, 2019 3:11 PM
To: 'stacy_lynne@comcast.net' <stacy_lynne@comcast.net>
Subject: Lynne v. Beals - Attorney fee hearing
Good afternoon, Ms. Lynne –
As you know, we have the attorney fee hearing scheduled in this matter for Monday afternoon. With
the submissions we have made to the Court, the defense has carried its initial burden to establish the
amount of the fees and their reasonableness, and those fees are entitled to a presumption of
reasonableness based on the showing made. Nevertheless, to the extent necessary or requested by the
judge, we may call Mr. Daniel C. Muffly as an expert witness to testify to those issues. His biographical
information is being provided as a courtesy below.
Kimberly B. Schutt, Esq.
Wick & Trautwein, LLC
323 S. College Avenue, Suite 3
Fort Collins, CO 80524
P: 970-482-4011 * 866-686-1410
F: 970-482-8929
http://www.wicklaw.com/
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Daniel C. Muffly practices in the areas of employment law, civil rights, business law,
construction excavation law and general litigation. Dan’s practice focuses on advising employer
clients in the prevention of unlawful employment practices and defending employers in
employment-based litigation arising from alleged discrimination, harassment, wrongful
discharge and unfair competition. Dan was previously a Senior Internal Auditor and Terminal
Manager for Consolidated Freightways, a national trucking company. He received a B.S. and a
B.A. degree from Nebraska Wesleyan University in Lincoln, Nebraska. Dan received his Juris
Doctorate, with distinction, from the University of Nebraska. He is a member of the Larimer
County, Colorado and Nebraska Bar Associations. Dan was the President of the Larimer County
Bar Association from 2006-2007 and served on the Colorado Bar Associations Board of
Governors and the Board of Governors’ Executive Board. Dan has also been active in
community service. He has served on the Boards of Crossroads Safehouse, Larimer County
Small Business Development Center and the Fort Collins Soccer Club
Daniel C. Muffly
323 South College Avenue, Suite 1
Fort Collins, Colorado 80524
Office (970) 482-4846
Facsimile (970) 482-3038
E-Mail: dmuffly@gjmlawfirm.com
www.gjmlawfirm.com
EXHIBIT A