HomeMy WebLinkAbout2017CV219 - ERIC SUTHERLAND V. CITY OF FORT COLLINS, ET AL - 007B - EXHIBIT B TO OBJECTIONDISTRICT COURT, LARIMER COUNTY, COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, CO 80521-2761
(970) 498-6100
Plaintiff: ERIC SUTHERLAND,
V.
Defendant: THE CITY OF FORT COLLINS
Indispensable Party: Angela Myer [SIC], Larimer
County Clerk and Recorder
Kimberly B. Schutt, #25947
WICK & TRAUTWEIN, LLC
P.O. Box 2166
Fort Collins, CO 80522
Phone: (970) 482-4011
Email:
John R. Duval, #10185
FORT COLLINS CITY ATTORNEY'S OFFICE
P.O. Box 580
Fort Collins, CO 80522
Phone: (970) 221-6520
Email:
COURT USE ONLY
Case Number: 2017 C 219
Courtroom: 5C
ATTORNEY VERIFICATION OF COSTS AND FEES TO BE INCURRED
THROUGH SUMMARY ADJUDICATIVE HEARING
PURSUANT TO C.R.S. 1-11-203.5
AFFIANT, being duty sworn upon oath, states as follows:
1. I am over the age of 18 years and have personal knowledge of the matters stated
herein.
2. I am an attorney in good standing and have been licensed to practice law in the
State of Colorado since 1995. I have been practicing law with the law firm of Wick &
Trautwein, LLC in Fort Collins, Larimer County, Colorado since 1997.
3. I have been retained as co -defense counsel by the City of Fort Collins to represent
the City in the above -captioned action brought by Plaintiff Eric Sutherland.
4. I have considered the work which I reasonably expect to complete as co -defense
counsel in this case, taking into the account the nature of this type of summary and expedited
proceeding set forth in C.R.S. § 1-11-203.5. I have done so for purposes of providing a good
faith estimate of the costs and fees which the City will likely incur with me and my firm through
the summary adjudicative hearing in this case.
5. Accordingly, I provided a good faith estimate to the City of approximately
nineteen (19) hours of attorney time for preparation of the Answer and motions and briefs to be
filed in this case, as well as preparation for and participation in the summary adjudicative
hearing, and extensive related communications. I believe this estimate to be conservative, based
upon the time already incurred in defense of this case.
6. My hourly rate billed to the City is $175.00 per hour, which is reduced from my
usual hourly rate of $225 per hour billed to non -governmental clients. Based on my experience
practicing law in Northern Colorado for over 20 years, I believe the xate being charged to the
City in this case is very reasonable compared to what most attorneys with 20-plus years of
experience charge in this locality.
7. Based upon the above, I believe that I will be billing at least $3,325 in attorney's
fees to the City for my legal work in defense of this case. It is also quite likely that additional
court costs may be incurred by the City for such things as the service of subpoenas on potential
witnesses, copying and preparation of exhibits for trial, as well as the charges incurred through
ICCES for electronic filing of all court documents. Those court costs may reasonably total
another $175.00 or more.
Further, Affiant sayeth naught.
C
Kimberly 1. Schutt
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STATE OF COLORADO }
} ss:
COUNTY OF WELD }
The foregoing instrument was subscribed and sworn to before me this the day
of August, 2017, by Kimberly B. Schutt.
Witness my hand and official seal.
MICHA oD� CONNORSUBLIC
STATE OF COLORADO Notary Public
NOTARY 10 19964OM75 /0
My cOMMISS*N EXPIRES MOW 6, 2018 My Commission Expires: A�'x 2-0 18
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