Loading...
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 - 2 - 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 - 3 - 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 - 4 - 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 - 3 - EXHIBIT A