HomeMy WebLinkAbout2018CV149 - SUTHERLAND V. CITY OF FORT COLLINS, STEVE MILLER & IRENE JOSEY - 052B - EXHIBIT A TO AFFIDAVITEXHIBIT A
DATE FILED: September 26, 2018 5:37 PM
FILING ID: 2AB89412B555D
CASE NUMBER: 2018CV149
001607.037 THIS INVOICE IS DUE UPON RECEIPT
IN ACCOUNT WITH
633 Seventeenth Street, Suite 3000, Denver, Colorado 80202
Telephone 303.297.2900 Fax: 303.298.0940 www.shermanhoward.com
FEDERAL TAX PAYER ID NO. 84-0420314
City of Fort Collins, Colorado
City Attorney's Office
P.O. Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 731069
JUNE 29, 2018
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 4/30/18 through 6/16/18 in
accordance with the itemized statement
attached:
TIME COST: 2,678.75
LESS 10% DISCOUNT: -267.88
OUR FEE: 2,410.87
DISBURSEMENTS: 0.00
INVOICE TOTAL: 2,410.87
cc:
John Duval
EXHIBIT A
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DATE DESCRIPTION OF SERVICES BILLED
04/30/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Read complaint by Mr. Sutherland.
05/01/18 HOURS: 1.50 RATE: 545 COST: 817.50
John Mill Prepared for and had call with Ms. Daggett, Mr. Duval
regarding Sutherland lawsuit.
05/11/18 HOURS: 0.25 RATE: 360 COST: 90.00
Amanda Milgrom Reviewed Complaint.
05/30/18 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Spoke with Mr. Duvall regarding case status, Timnath's potential
notice and bond issuance date.
06/12/18 HOURS: 2.50 RATE: 545 COST: 1,362.50
John Mill Reviewed Tinmath and Compass's Motion to Dismiss,
counterclaims and Motion to enjoin further pro se filings by Mr.
Sutherland; drafted email to Ms. Daggett and Mr. Duval
regarding issues and recommendations.
FEES: 2,678.75
EXHIBIT A
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EXHIBIT A
001607.037 THIS INVOICE IS DUE UPON RECEIPT
IN ACCOUNT WITH
633 Seventeenth Street, Suite 3000, Denver, Colorado 80202
Telephone 303.297.2900 Fax: 303.298.0940 www.shermanhoward.com
FEDERAL TAX PAYER ID NO. 84-0420314
City of Fort Collins, Colorado
City Attorney's Office
P.O. Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 734168
AUGUST 13, 2018
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 6/25/18 through 7/14/18 in
accordance with the itemized statement
attached:
TIME COST: 17,491.25
LESS 10% DISCOUNT: -1,749.13
OUR FEE: 15,742.12
DISBURSEMENTS: 267.58
INVOICE TOTAL: 16,009.70
cc:
John Duval
EXHIBIT A
- 2 -
DATE DESCRIPTION OF SERVICES BILLED
06/25/18 HOURS: 1.00 RATE: 545 COST: 545.00
John Mill Read two court orders regarding Mr. Sutherland's motions to
intervene in proposed metro district matters; read string of emails
from Mr. Sutherland regarding broadband vote and bonds; read
information on City's plan for broadband service.
06/27/18 HOURS: 2.25 RATE: 545 COST: 1,226.25
John Mill Reviewed relevant documents from City
; reviewed other cases involving Mr.
Eric Sutherland; reviewed Complaint against City; drafted memo
; reviewed Court Order denying Mr.
Sutherland's challenge to ballot title for broadband measure on
November 2017 ballot.
06/28/18 HOURS: 0.75 RATE: 360 COST: 270.00
Amanda Milgrom Strategized with Mr. Mill about potential arguments for Motion
to Dismiss and next steps.
06/28/18 HOURS: 2.00 RATE: 545 COST: 1,090.00
John Mill Revised memo ; reviewed Court orders in
Sutherland cases against Poudre School District; considered
arguments regarding lack of standing; met with Ms. Milgrom
regarding research on standing issue and potential motion to
dismiss; drafted email to Mr. Duval regarding needed documents.
06/29/18 HOURS: 1.75 RATE: 360 COST: 630.00
Amanda Milgrom Researched standing and other legal issues for Motion to
Dismiss.
07/02/18 HOURS: 1.75 RATE: 360 COST: 630.00
Amanda Milgrom Conferred with Mr. Mill on issue of standing; researched issue of
standing and drafted analysis.
07/02/18 HOURS: 2.50 RATE: 545 COST: 1,362.50
John Mill Spoke with Mr. Woodward regarding court hearing on Timnath's
motion to dismiss claims by Mr. Sutherland; drafted email to
clients; spoke with Mr. Duval regarding standing and other
issues; reviewed relevant City Charter provisions; revised memo
regarding key issues; spoke briefly with Ms. Milgrom regarding
research on standing; ; read part of Plaintiff's
response to Timnath.
07/03/18 HOURS: 1.00 RATE: 360 COST: 360.00
Amanda Milgrom Conferred with Mr. Mill about Motion to Dismiss, including
issues of standing ; had e-mail correspondence with
clients about standing issue;
EXHIBIT A
- 3 -
07/03/18 HOURS: 1.50 RATE: 545 COST: 817.50
John Mill Read emails from Mr. Sutherland; drafted response; drafted email
to Mr. Duval.
07/05/18 HOURS: 3.25 RATE: 360 COST: 1,170.00
Amanda Milgrom Researched
arguments for Motion to Dismiss.
07/05/18 HOURS: 0.75 RATE: 545 COST: 408.75
John Mill Reviewed April 3, 2018 minutes of council and electric utility
enterprise; drafted emails regarding additional
needed documents; drafted email to Mr. Duval
.
07/06/18 HOURS: 1.50 RATE: 360 COST: 540.00
Amanda Milgrom Conferred with Mill about ;
reviewed memorandum
07/06/18 HOURS: 3.50 RATE: 545 COST: 1,907.50
John Mill Read Official Statement regarding Sutherland claims; read
; considered issues for
call; had call with Mr. Duval.
07/08/18 HOURS: 1.25 RATE: 360 COST: 450.00
Amanda Milgrom Began drafting Motion to Dismiss.
07/09/18 HOURS: 2.75 RATE: 360 COST: 990.00
Amanda Milgrom Drafted additional parts of Motion to Dismiss.
07/10/18 HOURS: 0.75 RATE: 360 COST: 270.00
Amanda Milgrom Continued drafting Motion to Dismiss.
07/11/18 HOURS: 3.50 RATE: 360 COST: 1,260.00
Amanda Milgrom Continued drafting Motion to Dismiss; had telephone conference
with Mr. Duval about standing argument.
07/12/18 HOURS: 3.75 RATE: 360 COST: 1,350.00
Amanda Milgrom Had email correspondence with Mr. Mill about standing
argument; continued work on Motion to Dismiss.
07/12/18 HOURS: 1.25 RATE: 545 COST: 681.25
John Mill Reviewed draft motion to dismiss and considered issues and
needed revisions.
07/13/18 HOURS: 3.50 RATE: 360 COST: 1,260.00
Amanda Milgrom Had telephone conference with Mr. Mill about revisions to
Motion to Dismiss; revised Motion to Dismiss.
EXHIBIT A
- 4 -
07/13/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Spoke with Ms. Milgrom regarding revisions to motion to
dismiss.
FEES: 17,491.25
DISBURSEMENTS:
Computer Assisted Research 194.08
Filing Fees 73.50
267.58
TOTAL FEES AND DISBURSEMENTS: $ 16,009.70
EXHIBIT A
- 5 -
EXHIBIT A
001607.037 THIS INVOICE IS DUE UPON RECEIPT
IN ACCOUNT WITH
633 Seventeenth Street, Suite 3000, Denver, Colorado 80202
Telephone 303.297.2900 Fax: 303.298.0940 www.shermanhoward.com
FEDERAL TAX PAYER ID NO. 84-0420314
City of Fort Collins, Colorado
City Attorney's Office
P.O. Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 735911
AUGUST 29, 2018
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 7/16/18 through 8/18/18 in
accordance with the itemized statement
attached:
TIME COST: 14,688.75
LESS 10% DISCOUNT: -1,468.88
OUR FEE: 13,219.87
DISBURSEMENTS: 935.92
INVOICE TOTAL: 14,155.79
cc:
John Duval
EXHIBIT A
- 2 -
DATE DESCRIPTION OF SERVICES BILLED
07/16/18 HOURS: 1.00 RATE: 545 COST: 545.00
John Mill Revised motion to dismiss.
07/17/18 HOURS: 7.00 RATE: 360 COST: 2,520.00
Amanda Milgrom Revised Motion to Dismiss; drafted affidavits for Mr. Beckstead
and Ms. Knoll; had telephone conference with Mr. Duvall, Ms.
Daggett, and Mr. Mill about Motion to Dismiss.
07/17/18 HOURS: 3.00 RATE: 545 COST: 1,635.00
John Mill Made further changes to motion to dismiss; conferred with Ms.
Milgrom regarding revisions and affidavit; had call with Ms.
Daggett and Mr. Duval regarding motion; drafted conferral email
to Mr. Sutherland; spoke with Ms. Milgrom regarding affidavits
and revisions; reviewed and revised draft motion and two draft
affidavits; revised motion.
07/18/18 HOURS: 5.50 RATE: 360 COST: 1,980.00
Amanda Milgrom Revised Motion to Dismiss; had telephone conference with Mr.
Duvall and Mr. Beckstead about Mr. Beckstead's affidavit;
revised affidavits.
07/18/18 HOURS: 4.75 RATE: 545 COST: 2,588.75
John Mill Gave direction to Ms. Milgrom; reviewed latest drafts of
affidavits and motion; revised proposed order; reviewed and
revised Beckstead affidavit; spoke with Mr. Duval
.
08/07/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Reviewed various motions and responses
drafted email to clients regarding status and
fees.
08/08/18 HOURS: 1.50 RATE: 545 COST: 817.50
John Mill Read Mr. Sutherland's email regarding dismissing some but not
all of his claims; drafted email to Mr. Duval with
recommendations; spoke with Mr. Duval; spoke with Mr. Burris
(counsel for Timnath) regarding his response to Mr. Sutherland;
drafted response to Mr. Sutherland.
08/10/18 HOURS: 1.50 RATE: 360 COST: 540.00
Amanda Milgrom Reviewed Plaintiff's Response to Motion to Dismiss; conferred
with Mr. Mill about arguments for reply brief.
08/11/18 HOURS: 1.75 RATE: 360 COST: 630.00
Amanda Milgrom Researched validity and scope of recital statutes as related to
issuing municipal bonds.
EXHIBIT A
- 3 -
08/13/18 HOURS: 2.50 RATE: 360 COST: 900.00
Amanda Milgrom Continued researching legal arguments for Reply in support of
Motion to Dismiss; conferred with Mr. Mill about drafting Reply;
began drafting Reply.
08/13/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Read Plaintiff's motion for reconsideration regarding
Timnath/Compass and Court's order; spoke with Ms. Milgrom
regarding reply supporting City's motion to dismiss; drafted email
to clients.
08/14/18 HOURS: 2.50 RATE: 360 COST: 900.00
Amanda Milgrom Continued drafting Reply in support of Motion to Dismiss.
08/14/18 HOURS: 1.00 RATE: 545 COST: 545.00
John Mill Reviewed draft reply; spoke with Ms. Milgrom regarding
revisions.
08/15/18 HOURS: 0.75 RATE: 360 COST: 270.00
Amanda Milgrom Revised Reply in support of Motion to Dismiss per Mr. Duval's
feedback.
08/15/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Reviewed and revised reply brief in support of City's motion to
dismiss.
FEES: 14,688.75
DISBURSEMENTS:
Postage 7.90
Computer Assisted Research 914.52
Filing Fees 13.50
935.92
TOTAL FEES AND DISBURSEMENTS: $ 14,155.79
EXHIBIT A
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EXHIBIT A
001607.037 THIS INVOICE IS DUE UPON RECEIPT
IN ACCOUNT WITH
633 Seventeenth Street, Suite 3000, Denver, Colorado 80202
Telephone 303.297.2900 Fax: 303.298.0940 www.shermanhoward.com
FEDERAL TAX PAYER ID NO. 84-0420314
City of Fort Collins, Colorado
City Attorney's Office
P.O. Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 737567
SEPTEMBER 20, 2018
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 9/5/18 through 9/15/18 in
accordance with the itemized statement
attached:
TIME COST: 2,123.75
LESS 10% DISCOUNT: -212.38
OUR FEE: 1,911.37
DISBURSEMENTS: 266.92
INVOICE TOTAL: 2,178.29
cc:
John Duval
EXHIBIT A
- 2 -
DATE DESCRIPTION OF SERVICES BILLED
09/05/18 HOURS: 0.75 RATE: 360 COST: 270.00
Amanda Milgrom Drafted Bill of Costs.
09/05/18 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Read Court Order dismissing all claims against the City; drafted
email to clients.
09/06/18 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Read email from Mr. Duval; read order regarding fees, costs in
other case; considered costs issues; drafted email to Mr. Duval.
09/11/18 HOURS: 1.00 RATE: 545 COST: 545.00
John Mill Read Order awarding attorney's fees to Timnath and drafted
email to clients; spoke with Ms. Milgrom regarding motion for
fees and costs; read email from Ms. Daggett regarding fees;
drafted email regarding fees and hourly rates.
09/12/18 HOURS: 2.50 RATE: 360 COST: 900.00
Amanda Milgrom Drafted Motion for Attorneys' Fees and Bill of Costs; drafted
Affidavit of Mr. Mill.
FEES: 2,123.75
DISBURSEMENTS:
Computer Assisted Research 253.29
Copies 0.13
Filing Fees 13.50
266.92
TOTAL FEES AND DISBURSEMENTS: $ 2,178.29
EXHIBIT A
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EXHIBIT A