HomeMy WebLinkAbout2018CV149 - SUTHERLAND V. CITY OF FORT COLLINS, STEVE MILLER & IRENE JOSEY - 149A - EXHIBIT A TO MOTIONDISTRICT COURT, LARIMER COUNTY, COLORADO
Court Address: 201 La Porte Avenue
Fort Collins, CO 80521
Phone Number: (970) 494-3500
Plaintiff: ERIC SUTHERLAND, pro se
v.
Defendants: THE CITY OF FORT COLLINS, a home rule
municipality in the State of Colorado; STEVE MILLER, in his
capacity as the Larimer County Assessor and all successors in
this office; IRENE JOSEY, in her capacity as the Larimer
County Treasurer and all successors to this office; and
Indispensable Parties: THE TIMNATH DEVELOPMENT
AUTHORITY, an Urban Renewal Authority; and COMPASS
MORTGAGE CORPORATION, an Alabama company doing
business in Colorado. ♦COURT USE ONLY
Attorneys for Defendant City of Fort Collins:
John W. Mill (#22348)
Rosemary A. Loehr (52559)
Case No,: 2018CV 149
Sherman &Howard L,L.C.
633 17th Street, Suite 3000
Denver, CO 80202
Phone Number; (303) 297-2900
Email: „jmill cz,shermanhoward.com
Courtroom/Division: 3C
rloehr(a~shermanhoward.com
Car-~•ie M. Daggett, #23316
John R. Duval, #10185
Fort Collins City Attorney's Office
300 LaPorte Avenue
Fort Collins, CO 80522-0580
970-221-6520
cddaggett(cr~fc~ov.com,
'duval fc ov.com
SECOND SUPPLEMENTAL AFFIDAVIT OF JOHN W. MILL
I, John W. Mill, hereby state under oath as follows:
I have personal knowledge of the facts stated herein.
Exhibit A
DATE FILED: July 25, 2019 10:54 AM
FILING ID: 1243363B9C700
CASE NUMBER: 2018CV149
2, I am over the age of 18 years and competent to give testimony,
3. I submit this Second Supplemental Affidavit in support of the City of Fort
Collins' Second Motion for Attorneys' Fees and Costs (the "Motion"), and to set forth the costs
and attorneys' fees incurred in the above-captioned litigation by the City of Fort Collins ("the
City") that were not previously requested by the City and in part awarded by the Court in its
Order Granting Fort Collins' Motion for Attorneys' Fees and Bill of Costs (Apr. 2, 2019) (the
"Order Awarding Fees"),
4. I am lead counsel for the City of Fort Collins ("the City") in this case.
5, I am the partner or member of Sherman &Howard, L.L.C. ("S&H") who has
been responsible for (i) supervising the legal services provided by S&H in its representation of
the City in this matter, and (ii) reviewing and approving all invoices for attorneys' fees and costs
charged by S&H to the City for services related to this matter,
Attorneys Providing Leal Services
6, The attorneys who have performed legal services for the City in this matter are:
John W. Mill S&H Member and Lead Counsel
Rosemary A. Loehr
Amanda Milgrom ;
Carrie Mineart Daggett
John R, Duval
S&H
S &H'
City of Fort Collins
City of Fort Collins
Associate
Associate
City Attorney
Deputy City Attorney
7. I have been practicing law in Colorado at S&H for 26 years. My practice has
included a wide range of litigation including:
a. Municipal litigation. I have represented several Colorado municipalities in
various types of litigation. This has included reporting to and working with city attorneys, city
councils and city staff, as well as handling issues relating to city charters, codes, ordinances and
procedures.
b. Election issues, My practice has included four cases under the Fair Campaign
Practices Act, C.R.S. § 1-45-101 et seq. including representing municipalities and municipal
employees, My experience also includes being lead counsel for a state agency in a case of
statewide significance, Mesa Cry. Bd of Cty. Commis v. State of Coloi°ac~o, 209 P.3d 519 (Colo.
' Ms. Milgrom is now a partner at the firm Milgrom & Daskam. Prior to Milgrom & Daskam,
Ms. Milgrom was an associate at S&H until February 2019. For purposes of this Second
Supplemental Affidavit and the Motion, the City only seeks $81.00 for .25 hours of
Ms. Milgrom's time working on this case.
2
Exhibit A
2009) (involving ballot measures by school districts and the Colorado Constitution's Taxpayer's
Bill of Rights ("TABOR")).
c. Complex civil litigation. In addition, I have years of experience in complex civil
litigation including class actions, construction, financial claims, RICO claims, appeals and other
issues.
8. Rosemary Loehr is a first-year associate at S&H, She has experience working on
complex civil litigation involving federal securities law, intellectual property, CERCLA, RCRA,
and government investigations. At S&H, Ms. Loehr conducts electronic legal research on a
variety of legal issues for both state and federal cases. She routinely drafts complaints, answers,
motions to dismiss, affidavits, and other written pleadings. Prior to law school, Ms. Loehr was a
litigation case assistant at Spencer Fane, LLP. In that role, she supervised a team of bar-admitted
attorneys to determine residual CERCLA liability stemming from one of the largest and most
complex CERCLA cases ever litigated. She also conducted legal research, drafted affidavits,
and supervised company personnel under receivership in amulti-million dollar federal consumer
protection case.
9. Amanda Milgrom was afourth-year associate at S&H, Prior to S&H, Ms.
Milgrom was a law clerk for the Tenth Circuit and an associate at Hogan Lovells, She has
experience working on complex government investigations and related civil litigation under the
False Claims Act. At S&H, Ms, Milgrom conducted electronic legal research on a variety of
legal issues ranging from construction law to intellectual property for both state and federal
cases. She routinely drafted complaints, answers, motions to dismiss, affidavits, and other
written pleadings.
10. Carrie Mineart Daggett is the City Attorney for the City and John R. Duval is the
Deputy City Attorney for the City. Mr. Sutherland's claims have required Ms. Daggett and Mr.
Duval to spend considerable time on this matter. While the City could seek attorneys' fees for
their time on this matter, the City is only seeking the fees and costs it incurred for outside
counsel on this case,
Work Required to Seelc Attorneys' Fees and Respond to Mr. Sutherland's Post-
Jud~ment Motions
11. The City was required to incur substantial attorneys' fees and costs to seek
attorneys' fees for Mr. Sutherland's frivolous claims and respond to Mr, Sutherland's frivolous
post judgment motions.
12. At the March 15, 2019 hearing on the City's first motion for attorneys' fees, the
City only requested attorneys' fees and costs incurred through January 12, 2019 as reflected on
S&H's invoices through January 2019.
13. Preparing for and participating in the March 15, 2019 hearing on the City's first
attorneys' fees motion required substantial witness preparation, exhibit preparation, legal
Exhibit A
research and in-court time. Mr. Sutherland also filed five subpoenas less than forty-eight hours
before the hearing that required a response from the City. The fees and costs incurred by the
City to prepare for and participate in the March 15, 2019 hearing are included on S&H's
February 28 and March 25, 2019 invoices. Those invoices were issued too late to be included in
the City's first motion for attorneys' fees or were issued after the March 15, 2019 hearing.
14. Just before the attorneys' fees hearing on March 15, 2019 or after that hearing,
Mr. Sutherland filed five post-dismissal motions. Responding to each motion involved the initial
conferral, an analysis of Mr. Sutherland's motion, drafting the response, and analyzing Mr,
Sutherland's reply as well as the corresponding orders. Each motion required its own legal
research, often over obscure legal topics such as coram non judice.
15. Mr. Sutherland also continued to send counsel lengthy emails that required
attention from counsel, even if we ultimately decided not to respond.
16. The City further incurred additional attorneys' fees and costs due to Mr.
Sutherland's unwillingness to settle, The City made multiple settlement offers wherein the City
offered to refrain from collecting its judgment against Mr, Sutherland if Mr. Sutherland would,
among other things, cease litigating the present case. Mr. Sutherland ultimately refused every
settlement offer.
Attorneys' Fees Incurred by the City
17. I have reviewed S&H's invoices and other records related to S&H's work in
connection with Mr, Sutherland's post-dismissal conduct.
18. In connection with the City's first motion for attorneys' fees, the City requested
fees and costs included on S&H's invoices dated June 2018 through January 2019. In the Order
Awarding Fees, the Court awarded the City a portion of those fees and costs.
19. With this Motion, the City requests an award of the fees and costs incurred by the
City and included on S&H's invoices dated February 2019 through June 2019.
20, Attached as Exhibit A to this Affidavit are true and correct copies of the February
through June 2019 invoices S&H has sent to the City for services in this matter, The City has
paid, and/or is obligated to pay, these attorneys' fees and costs.
21. The attorneys' fees and costs incurred by the City in this matter after January 12,
2019, which the City has not previously requested or been awarded are $45,472,50. This
consists of:
INVOICE DATE INVOICE NO. COSTS FEES TOTAL
February 28, 2019 751828 $43.62 $3,024.00 $3,067.62
March 25, 2019 753439 108.78 26,914.50 27,023,28
April 23, 2019 756158 807.71 4,891,50 5,699.21
L~
Exhibit A
May 24, 2019 758850 80.43 4,978.12 5,058.55
June 19, 2019 760807 292.59 4,331.25 4,623.84
TOTAL: $1,333.13 $44,139.37 $45,472.50
22. The standard rates of the S&H attorneys involved are as follows: (1) $545 per
hour for John Mill, a member; (2) $310 for Rosemary Loehr, afirst-year associate; and (3) $360
per hour for Amanda Milgrom, a third-year associate. S&H provided the City a ten percent
discount on all fees. Thus, the net hourly rates after the ten percent discount were $490,50 for
Mr. Mill, $324 for Ms. Milgrom, and $279 for Ms. Loehr.
23. Based upon my experience, in my opinion the net hourly rates billed by S&H in
this matter are reasonable and consistent with the billing rates of attorneys performing this type
of work in similar-sized firms with similar levels of expertise and experience in Denver,
Colorado.
24. I directed Ms. Loehr to conduct a search of attorneys in Fort Collins who hold
themselves out as municipal litigation attorneys. Ms. Loehr conducted this search through the
Colorado Bar Association's "Find a Colorado Lawyer" search tool. Ms. Loelu• searched for
attorneys of any experience level who hold themselves out as experienced in government
administration. Only one attorney was responsive to this search and no data was provided as to
that attorney's hourly rates or fees. Thus, we could not obtain a locality rate for attorneys in Fort
Collins who hold themselves out as experienced in this type of litigation.
25. Based on my experience, in my opinion the number of hours expended by S&H in
defending this matter is reasonable, Preparing for and conducting the March 15, 2019 fee
hearing required substantial time and effort. In addition, Mr. Sutherland's filing of five post-
judgment motions required substantial time and effort to respond to and it is highly atypical for a
litigant to file so many post judgment motions in addition to an appeal.
26. All of the time entries on the attached invoices are directly related to defending
against Mr. Sutherland's claims in this case, seeking attorneys' fees for Mr, Sutherland's
frivolous conduct and/or responding to Mr. Sutherland's post-dismissal conduct in this action,
The fees were calculated by multiplying the number of hours spent on the tasks noted in each
diary entry by the attorney's normal hourly rate. A ten percent discount was then applied to the
attorneys' fees on each invoice.
27. In addition, as the billing partner on this matter, throughout the matter on all
invoices, I have exercised reasonable and appropriate billing judgment. As a result, in some
instances, I have written off and not charged, or reduced and charged a lower amount, than the
actual number of hours spent on certain tasks. This was done to be fair and ensure that the fees
charged are reasonable.
Exhibit A
Costs Incurred by the City
28. In addition to attorneys' fees, Mr. Sutherland's claims required the City to incur
costs. The costs billed to the City, as shown on the February 2019 through June 2019 invoices as
Exhibit A, total $1,333,13.
29. Attached as Exhibit B to this Affidavit is an itemized summary of the litigation
costs and expenses incurred by the City on the February 2019 through June 2019 invoices,
These costs have not been previously requested by the City or awarded by the Court. Exhibit B
itemizes costs incurred for things like filing fees and electronic legal research and shows total
costs billed for this matter.
30. S&H billed the City for these costs separately from, and in addition to, the
attorneys' fees. In my opinion, the amount of costs incurred were reasonable and were necessary
for the City to respond to Mr. Sutherland's claims, prepare for and conduct the March 15, 2019
hearing and/or respond to Mr, Sutherland's post judgment conduct.
I hereby swear or affirm that the foregoing is true and correct to the best of ~x~y
information and belie£
John W. Mill
STATE OF COLORADO )
ss,
CITY AND COUNTY OF DENVER)
I hereby certify that the foregoing SECOND SUPPLEMENTAL AFFIDAVIT OF JOHN
W. MILL was subscribed and sworn to before me on this 25th day of July, 2019, by John W.
Mill
WITNESS my hand and official seal,
My commission expires:
[SEAL] EILEEN E. LYNCH
NOTARY PUBLIC
STATE OF COLORADO
NOTARY ID 20124043500
MY COMMISSION EXPIRES 07/18)?020
Notary Public
6
Active/50258915.2
Exhibit A
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
SHERMAN~HOWARD ~.~.~,
City of Fort Collins, Colorado
City Attorney's Office
P.O. Boa 580
Fort Collins, CO 80522-0580
INVOICE NO. 751828
FEBRUARY 28, 2019
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 1/17/19 through 2/9/19 in
accordance with the itemized statement
attached.
TIME COST: 3,360,00
~~
LESS 10°/a DISCOtTNT: -336.00
OUR FEE; 3,024.00
DISBURSEMENTS: 43.62
INVOICE TOTAL; 3,067.62
~~:
John Duval
001607.037 THIS INVOICE IS DUE UPON RECEIPT
Affidavit Exhibit A
DATE DESCRIPTION OF SERVICES BILLED
O1/17/I9 HOURS: 0.50 RATE: 0 COST: 0.00
Amanda Milgrom (No charge) Conferred with Mr, Mill about issue of judges
recusal in Larimer County; began tracking down documents
relating to recusals.
01/17/19 HOURS: 0.75 RATE: 545 COST: 408.75
John Mill Revised supplemental affidavit regarding attorneys' fees and
costs; spoke with Ms. Milgrom regarding appeal,
01/22/19 HOURS: 0.25 RATE: 360 COST: 90.00
Amanda Milgrom Analyzed issues of judge recusals and assignments for upcoming
hearing on attorneys' fees.
01/22/19 HOURS: 0.25 RATE: 545 COST; 136.25
John Mill Revised supplemental affidavit regarding attorneys' fees.
01/24/19 HOURS: 1.25 RATE: 545 COST: 681.25
John Mill Finalized supplemental affidavit; drafted email to clients;
reviewed TRO against Mr. Sutherland and Timnath fraudulent
conveyance action; drafted email to redacted
invoices.
OU28/19 HOURS: 0,75 RATE: 545 COST: 408.75
John Mill Spoke with Mr. Burris regarding Sutherland issues; drafted email
to clients regarding potential prejudgment attachment.
01/30/19 HOURS: 0.25 RATE: 545 COST: 136,25
John Mill Responded toregarding response to Mr. Sutherland's
open records request for documents.
01/31/19 HOURS: 0.25 RATE: 0 COST; 0.00
Amanda Milgrom (No charge) Continued researching issue of judge recusal.
02/04/19 HOURS: 2.75 RATE: 545 COST: 1,498.75
John Mill Reviewed documents cited in City's motion to dismiss; reviewed
Mr, Sutherland's CORA request; considered documents to
produce; spoke with and provided recommendations.
FEES: 3,360.00
DISBURSEMENTS:
Filing Fees 43.62
43.62
~►,~
Affidavit Exhibit A
TOTAL FEES AND DISBURSEMENTS: $ 3,067.62
-3-
Affidavit Exhibit A
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
SHERMAN~HOWARD ~.~.~.
City of Fort Collins, Colorado
City Attorney's Office
P,O. Box 580
Fort Collins, CCU 80522-0580
INVOICE NO. 753439
MARCH 25, 2019
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 2/15/19 through 3/16/19 in
accordance with the itemized statement
attached:
TIlVIE COST: 29,905.00
LESS 10% DISCOUNT: -2,990.50
OUR FEE: 26,914.50
DISBURSEMENTS: 108.78
INVOICE TOTAL: 27.023,28
cc:
John Duval
001607.037 THIS INVOICE IS DUE UPON RECEIPT
Affidavit Exhibit A
DATE DESCRIPTION OF SERVICES BILLED
02/19/19 HOURS: 4.50 RATE: 545 COST: 2,452.50
John Mill Reviewed Mr. Sutherland's motions regarding amending notice of
appeal, supplemental record and issue on Timnath; read
Appellant's opening brief; considered issues; drafted email to
regarding Mr. Sutherland's motions; read email form Mr.
Sutherland regarding dismissal of appeal.
02/20/1.9 HOURS: 1.75 RATE: 0 COST: 0.00
John Mill (No charge) Telephone conference with ~ and
prepared joinder and motion for leave,
02/21/19 HOURS: 4.25 RATE: 0 COST: 0.00
John Mill (No charge) Revised joinder; revised motion for leave; gave
direction to staff to determine if State Court Administrator letter
rescinding appointment of senior judge is in appellate record;
drafted email to Mr, Sutherland regarding his suggestion of
dismissing the appeal; drafted email to clients regarding joinder;
reviewed Mr, Sutherland's motion to amend opening brief;
drafted email to clients.
02/24/19 HOURS: 1.50 RATE: 0 COST: 0.00
Rosemary Loehr Continued preparing for the evidentiary hearing to persuade the
court that (1) Mr. Sutherland's litigation was frivolous, (2) Fort
Collins deserves a fee award and (3) the amount of fees assessed
is reasonable.
02/28/19 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Read Court of Appeals order regarding jurisdiction; drafted email
to clients.
03/01/19 HOURS; 0.25 RATE: 545 COST: 136,25
John Mill Reviewed Judge Lammons' practice standards; dra$ed email to
Mr. Sutherland regarding witness and exhibit lists.
03/04/19 HOURS: 2.00 RATE: 0 COST: 0.00
Rosemary Loehr Continued preparing for the evidentiary hearing .
03/04/19 HOURS: 1.50 RATE: 545 COST: 817.50
John Mill Considered issues for hearing on City's Motion for Attorney's
Fees; met with Ms. Loehr and outlined arguments regarding
importance of broadband issue, lack of injury in fact, Mr.
Sutherland's arguments, compliance with charter provisions and
amount and reasonableness of fees.
03/05/19 HOURS: 5.50 RATE: 0 COST: 0.00
Rosemary Loehr Continued preparing for the fees hearing to recoup the City's fees
in defending against Sutherland's suit by (1) researching
-2-
Affidavit Exhibit A
applicable fee recovery law and drafting arguments for the
hearing, (2) determining witnesses and exhibits for the hearing,
(3) creating new arguments to rebut the court's inclination to
reduce fees from Denver attorneys, and (4) drafting the hearing
arguments.
03/06/19 HOURS; 3.50 RATE: 0 COST: 0.00
Rosemary Loehr Worked with Mr. Mill and to continue preparing for
the hearing by: (1) determining witnesses, (2) crafting the City's
position, and (3) confirming the in-court strategy; continued
working separately with Mr. Mill to fine tune the strategy,
develop chart of exhibits and witnesses for the court, and outline
the arguments to present during the hearing.
03/06/19 HOURS: 2,50 RATE: 545 COST: 1,362.50
John Mill Reviewed Court's order dismissing Mr. Sutherland's claims;
reviewed SPSA and Open Meetings Act; read email from Mr,
Sutherland; prepared for and had call with and Ms,
Loehr regarding preparation for March 15 hearing.
03/07/19 HOURS: 2.50 RATE: 0 COST: 0.00
Rosemary Loehr (No charge) Continued working with Mr. Mill to strategize on
which e~ibits to include at the hearing; continued finalizing the
witness and exhibit list,
03/07/19 HOURS: 3.25 RATE: 545 COST: 1,771,25
John Mill Prepared for hearing; considered exhibits; reviewed Mr.
Sutherland's arguments; spoke with Ms. Loehr regarding witness
and exhibit lists.
03/08/19 HOURS: 3.25 RATE: 0 COST: 0.00
Rosemary Loehr Continued finalizing the hearing exhibits; analyzed Mr.
Sutherland's Rule 60 motion to vacate the fees hearing; located
exhibit regarding voter approval for the 2015 ballot measure,
03/08/19 HOURS: 0.00 RATE: 0 COST: 0.00
John Mill Reviewed hearing exhibits; drafted email to~regarding
witnesses for hearing; worked extensively on exhibits for
hearing; had calls with regarding witnesses for
hearing; reviewed and revised summary of fees.
03/11/19 HOURS: 2.50 RATE: 310 COST: 775.00
Rosemary Loelir Began drafting and researching the City's response to Mr.
Sutherland's motion to vacate the proceedings.
03/11/19 HOURS: 4.25 RATE: 545 COST: 2,316.25
John Mill Read and responded to email from Mr. Sutherland regarding his
proposed motion to file a brief before the hearing; read and
considered Mr. Sutherland's witness and exhibit list; drafted
email to clients regarding witnesses for hearing; met with Ms.
Loehr and discussed direct examination regarding amount and
-3-
Affidavit Exhibit A
reasonableness of fees and costs; spoke with regarding
Plaintiffs intent to call City Council members to testify.
03/12/19 HOURS: 3.25 RATE: 310 COST: 1,007.50
Rosemary Loehr Analyzed Mr, Sutherland's set of subpoenas on Ms, Coldiron and
Ms. Knoll (.50); began researching caselaw to quash the
subpoenas (1); worked with Mr. Mill to prepare Mr. Beckstead
for his testimony (1.75); drafted and submitted a notice of
erratum corrected a mis-filed exhibit (.5); reviewed the remaining
exhibits to ensure correct filing (.5); analyzed the Court of
Appeals Order Dismissing Mr. Sutherland's Appeal (.5); worked
with to coordinate on sharing the exhibits (.25);
worked with the City to determine whether additional subpoenas
were served (,25); began drafting a motion to quash the
subpoenas (.25).
03/12/19 HOURS; 4.00 RATE: 545 COST: 2,180.00
John Mill Outlined issues for hearing; had call with ~
regarding preparation for his anticipated testimony at attorneys'
fees hearing; had call with and others regat•ding
preparation for her anticipated testimony at hearing.
03/13/19 HOURS: 1.00 RATE: 310 COST: 310.00
Rosemary Loehr Worked with the City to determine additional grounds for
quashing the subpoenas; continued drafting the motions to quash
the subpoenas.
03/13/19 HOURS: 5.50 RATE: 545 COST: 2,997.50
John Mill Prepared for hearing; drafted emails with Ms. Loehr; outlined to
do list for hearing preparation; worked on outline for hearing;
reviewed emails from Mr. Sutherland; outlined examination of
Mr. Beckstead; reviewed attorneys' fees issues.
03/14/19 HOURS: 9,00 RATE; 310 COST: 2,790.00
Rosemary Loehr Drafted a motion to quash Mr. Sutherland's subpoenas of Ms.
Knoll and Ms. Coldiron; updated the motion after Mr. Sutherland
served two additional subpoenas; filed the motion; analyzed
critical cases for inclusion at the hearing relating to standing and
the open meetings law in preparation to respond to questions
from the Judge or Mr. Sutherland; continued revising my outline
of Mr. Mill's direct examination.
03/14/19 HOURS: 8.75 RATE: 545 COST: 4,768.75
John Mill Continued preparation for hearing; reviewed Complaint and Mr.
Sutherland's response; reviewed subpoenas and drafted Motion to
Quash; spoke with Ms. Loehr.
03/15/19 HOURS: 6.00 RATE: 310 COST: 1,860.00
Rosemary Loehr Reviewed exhibits from Mr. Sutherland (.5); continued preparing
for Mr. Mill's direct examination and refined outline of his
examination and considered possible objections during the cross
-4-
Affidavit Exhibit A
examination (2); attended the hearing and conducted a direct
examination of Mr, Mill (3.5),
03/15/19 HOURS: 5.75 RATE: 545 COST: 3,133.75
John Mill Prepared for hearing; represented City in court hearing on Motion
for Attorneys' Fees,
03/15/19 HOURS: 2.00 RATE: 545 COST: 1,090.00
John Mill Drove to and from Fort Collins for court hearing on City's
Motion for Attorneys' Fees. (Only charged for one-half of travel
time),
FEES: 29,905.00
DISBURSEMENTS:
.Postage 7,91
Computer Assisted Research 0.72
Filing Fees 100.15
108.78
TOTAL FEES AND DISBURSEMENTS: $ 27,023.28
-5-
Affidavit Exhibit A
IN ACCOUNT WITH
633 Seventeenth Street, Suite 3000, Denver, Colorado 80202
Telephone 303.297.2900 Fax: 303298.0940 www.shermanhoward.com
FEDERAL TAX PAYER ID NO. 84-0420314
SH ERMAN HOWARD ~.~.~.
City of Fort Collins, Colorado
City Attorney's; Office
P.O. Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 756158
APRIL 23, 2019
RE: Suthej•land Litigation
FOR PROFESSIONAL SERVICES RENDERED
Frorn 3/18/19 through 4/13/19 in
accordance with the itemized statement
attached:
TIME COST: 5,435.00
LESS 10% DISCOUNT: -543.50
OUR FEE: 4,891.50
DISBURSEMENTS: 807.71
INVOICE TOTAL: 5,699.21
cc:
John Duval
001607.037 THIS INVOICE IS DUE UPON RECEIPT
Affidavit Exhibit A
DATE DESCRIPTION OF SERVICES BILLED
03/18/19 HOURS; 0.75 RATE: 310 COST: 232.50
Rosemary Loehr Worked with Mr, Mill and o determine whether to
drafted
an affidavit for Mr. Beckstead explaining the correction,
03/18/19 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Spoke withregarding I'
spoke with Ms. Loehr regarding ~~'~~~
03/19/19 HOURS: 2.50 RATE: 310 COST; 775.00
Rosemary Loellr Continued drafting
• drafted a notice to file in conjunction with the
finalized the
for filing; briefly reviewed Mr. Sutherland's e-mail
to determine whether his complaints were directed at ~~~~
continued drafting the City's
response to the Motion to Vacate and discussed key arguments in
the response with Mr. Mill.
03/19/19 HOURS: 1.50 RATE: 545 COST: 817.50
John Mill Reviewed and revised draft
reviewed and gave comments to Ms.
Loehr on notice revised
read email to City leaders from Mr. Sutherland; reviewed Mr.
Sutherland's motion to vacate and considered issues and
response; spoke with Ms. Loehr regarding draft response.
03/20/19 HOURS: 3.75 RATE: 310 COST: 1,162.50
Rosemary Loehr Completed drafting and researching the City's response to Mr.
Sutherland's motion to vacate the Court's dismissal order and
submitted the draft to the City for review.
03/20/19 HOURS: 0.75 RATE: 545 COST: 408.75
John Mill Reviewed Ms. Loehr's draft response to Mr. Sutherland's Motion
to Vacate; made minor revisions and discussed issues with Ms.
Loehr.
03/27/19 HOURS: 1.75 RATE: 310 COST: 542.50
Rosemary Loehr Worked with o revise and edit the response to the
motion to vacate; finalized the response for filing,
04/04/19 HOURS: 1.75 RATE: 310 COST; 542.50
Rosemary Loehr Analyzed and evaluated Mr. Sutherland's Reply to the City's
Response to his Motion to Vacate; drafted email to clients
summarizing his Relply; worked with the City and counsel for
Timnath to discuss settlement strategies; separately worked with
the City to discuss its responses to the settlement offer proposed
-2-
Affidavit Exhibit A
by Timnath.
04/04/19 HOURS: 1.00 RATE: 545 COST: 545.00
John Mill Had call with Timnath's counsel and regarding
Sutherland issues; had separate call with
04/09/19 HOURS: 0,25 RATE: 545 COST: 136.25
John Mill Read Court Order granting fees and costs to City.
04/11/19 HOURS: 0.25 RATE: 0 COST: 0.00
John Mill Reviewed letter to Mr. Sutherland regarding settlement; drafted
email to
04/12/19 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Spoke with ~~egarding offer to Mr. Sutherland,
potential collection actions and other issues,
FEES: 5,435.00
DISBURSEMENTS:
Computer Assisted Research 707.05
Out of Town Travel 73.66
Filing Fees 27.00
TOTAL FEES AND DISBURSEMENTS:
807.71
$ 5,699.21
-3-
Affidavit Exhibit A
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
SH ERMAN B~HOWARD ~.~.~,
City of Fort Collins, Colorado
City Attorney's Office
P.O. Box 580
Font Collins, CO 80522-0580
INVOICE NO. 758850
MAY 24, 2019
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 4/18/19 through 5/18/19 in
accordance with the itemized statement
attached;
TIME COST; 5,531.25
LESS 10°/a DISCOUNT: -553.13
OUR FEE: 4,978.12
DISBURSEMENTS: 80.43
INVOICE TOTAL: 5,058.55
cc:
John Duval
001607.037 THIS INVOICE IS DUE UPON RECEIPT
Affidavit Exhibit A
DATE DESCRIPTION OF SERVICES BILLED
04/18/19 HOURS: 0.75 RATE: 545 COST: 408.75
Johu Mill Reviewed email from Mr. Woodward; drafted email to clients;
had call with Mr, Woodward and others regarding potential
settlement with Mr. Sutherland.
04/22/19 HOURS: 1.00 RATE: 310 COST: 310.00
Rosemary Loehr Determined the basis for the City to request a supersedeas bond
of Mr, Sutherland in excess of the presumptive amount to stop
Mr, Sutherland's motions until he can post the bond.
04/22/19 HOURS: 0.75 RATE: 545 COST: 408.75
John Mill Read and responded to email from Mr. Sutherland regarding stay
on appeal; read email regarding Timnath's position on stay; read
and responded to email from clients regarding judgment and stay
enforcement.
04/24/19 HOURS: 1.00 RATE: 310 COST: 310.00
Rosemary Loehr Analyzed the Court's Order on Mr. Sutherland's motion to vacate
the judgement; worked with and Mr. Mill to
determine settlement strategy; determined the City's response
times to respond to Mr. Sutherland's two pending motions.
04/24/19 HOURS: 0.75 RATE: 545 COST; 408,75
John Mill Read emails; had call with egarding settlement.
04/29/19 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Reviewed draft settlement agreement between City and Mr.
Sutherland and drafted permanent injunction; drafted email to
05/01/19 HOURS: 0.25 RATE: 545 COST: 136.25
John Mill Read email from Mr. Sutherland regarding settlement; drafted
email to
05/03/19 HOURS: 0.50 RATE: 545 COST: 272.50
John Mill Reviewed email from Mr, Sutherland; drafted email to clients;
spoke with egarding Sutherland issues.
05/06/19 HOURS: 0.25 RATE: 310 COST; 77.50
Rosemary Loehr Worked with Mr. Mill to analyze Mr. Sutherland's recent filings
and outline the strategy to respond to those motions.
05/07/19 HOURS; 2.00 RATE: 310 COST; 620.00
Rosemary Loehr Drafted and filed the City's response to the Plaintiffs motion to
withdraw his motion for reconsideration.
05/07/19 HOURS: 0.25 RATE: 545 COST; 136.25
-2-
Affidavit Exhibit A
John Mill Reviewed draft response to Mr. Sutherland's motion to
"withdraw" Rule 59 Motion; gave suggestions to Ms. Loehr.
05/08/19 HOURS: 0.25 RATE: 310 COST: 77.50
Rosemary Loehc Reviewed Mr. Sutherland's notice of appeal.
05/11/19 HOURS: 1.25 RATE: 310 COST: 387.50
Rosemary Loelir Continued researching and drafting the City's response to the
motion to stay the execution of its judgment.
05/12/19 HOURS: 3.75 RATE: 310 COST: 1,162.50
Rosemary Loehr Continued drafting the City's response to Mr. Sutherland's motion
to stay the execution of the judgment; began analyzing Mr.
Sutherland's appeal.
05/13/19 HOURS: 0,75 RATE: 310 COST: 232.50
Rosemary Loelir Edited and finalized the City's response to Mr. Sutherland's
motion to stay the execution of the judgment.
05/17/19 HOURS: 1.00 RATE: 310 COST: 310.00
Rosemary Loehr Began researching and drafting the City's response to Mr.
Sutherland's motion to vacate the judgment under Rule 60.
FEES: 5,531.25
DISBURSEMENTS:
Computer Assisted Research 66.93
Filing Fees 13,50
80.43
TOTAL FEES AND DISBURSEMENTS: $ 5,458.55
~c~
Affidavit Exhibit A
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
SH ERMAN B~HOWARD ~.~.~.
City of Fort Collins, Colorado
City Attorney's Office
P.O, Box 580
Fort Collins, CO 80522-0580
INVOICE NO. 760807
JiJNE 19, 2019
RE: Sutherland Litigation
FOR PROFESSIONAL SERVICES RENDERED
From 5/13/19 through 6/8/19 in
accordance with the itemized statement
attached:
TIME COST: 4,812.50
LESS 10%DISCOUNT; -481.25
OUR FEE; 4,331.25
DISBURSEMENTS: 292.59
INVOICE TOTAL: 4.623.84
cc:
John Duval
001607.037 THIS INVOICE IS DUE UPON RECEIPT
Affidavit Exhibit A
DATE DESCRIPTION OF SERVICES BILLED
05/13/19 HOURS: 1.25 RATE: 545 COST: 681.25
John Mill Reviewed draft response to Mr. Sutherland's Motion to Stay
execution of City's judgment; made revisions; reviewed
changes; read Timnath's response; revised response,
05/19/19 HOURS: 0,25 RATE: 545 COST: 136,25
John Mill Conferred with Ms. Loehr regarding arguments for response to
Mr. Sutherland's "coram non judice" motion.
05/20/19 HOURS: 0,75 RATE: 310 COST: 232.50
Rosemary Loehr Continued researching and drafting the City's response to Mr.
Suthlerland's Rule 60 motion to vacate the City's fee award
against him,
05/21/19 HOURS: 2.50 RATE: 310 COST: 775.00
Rosemary Loehr Analyzed Mr. Sutherland's reply in support of his motion to stay
the execution of his judgment (.50); continued researching and
drafting the City's response to Mr. Sutherland's coram non judice
motion to vacate the City's fee award (2.0).
05/22/19 HOURS: 3.25 RATE: 310 COST: 1,007.50
Rosemary Laehr Completed the draft of the response to the coram non judice
motion for the City's review; analyzed the motion with Mr. Mill
and incorporated his edits,
05/22/19 HOURS: 0.50 RATE: 545 COST; 272.50
John Mill Reviewed draft response to Mr. Sutherland's "coram non judice"
motion and gave input to Ms. Loehr,
05/23/19 HOURS; 1,75 RATE: 310 COST; 542.50
Rosemary Loehr Analyzed correspondence from Mr. Sutherland regarding his
proposed motion to strike and his comments on the City's
response to his motion (.25); analyzed Judge Lammons' order on
the motion to stay the execution of the judgment and advised the
City on
incorporated
those edits into the City's response to the coram non judice
motion and finalized the City's response (.75); advised the City
on
05/28/19 HOURS: 0.75 RATE: 310 COST: 232.50
Rosemary Loehr Worked with Mr. Mill to determine next steps for the fees motion
and for the execution of the judgment; analyzed Mr. Sutherland's
reply in support of his coram non judice motion and submitted
analysis of the motion to the City .
05/28/19 HOURS: 0.25 RATE: 545 COST; 136.25
-2-
Affidavit Exhibit A
John Mill Conferred with Ms. Loehr regarding collection actions, attorneys'
fees motion, appeal status and other issues,
05/29/19 HOURS: 0.25 RATE: 310 COST: 77.50
Rosemary Loehr Began preparing the City's second motion for attorneys' fees and
costs against Mr. Sutherland.
06/06/19 HOURS: 0.75 RATE: 545 COST: 408.75
John Mill Read email from egarding effort to settle with Mr.
Sutherland; reviewed revised settlement documents; spoke with
06/07/19 HOURS: 1.00 RATE: 310 COST: 310.00
Rosemary Loehr Analyzed the court's status order regarding Sutherland's notice of
appeal (.25); continued drafting the City's motion for fees (.75).
FEES: 4,812.50
DISBURSEMENTS:
Computer Assisted Research 255.59
Filing Fees 37.00
292,59
TOTAL FEES AND DISBURSEMENTS: $ 4,623.84
-3-
Affidavit Exhibit A
Billed and Unbilled Recap Of Cost Detail - [001607.037 -Sutherland Litigation]
Client:001607 -FORT COLLINS, COLORADO 7/22/2019 10:13:48 AM
Page
-- - _ _
Date INtlals Name /Invoice Number i Code ~ Quantity Rate ~ Amount ~i Description Cost Index
Ot/18I2019 2394 Amanda Milgrom 110 1.00 10.00 10.00 Purchase Type -The Town Of Timnath et al v. Sut 1703418
02/28/2019 Invoice=751828 1.00 10.00 10.00
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
01/25/2019 0331 John Mill 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1703411
02/28/2019 Invoice=751828 1.00 6.00 6.00
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
01!25/2019 0331 John Mill 110 1.00 7,50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1703412
02/28/2019 Invoice=751828 1.00 7.50 7.50
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
01/29/2019 2394 Amanda Miigrom 110 1.00 0.12 0.12 Purchase Type -Sutherland, Eric v. The City Of 1703413
02/28/2019 Invoice=751828 1.00 0.12 0.12
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02!08/2019
01/29!2019 2394 Amanda Milgrom 110 1.00 0.50 0,50 Purchase Type -Sutherland, Eric v. The City Of 1703414
02/28!2019 Invoice=751828 1.00 0.50 0.50
Voucher=291681 Pald Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08!2019
01/29/2019 2394 Amanda Milgrom 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1703415
02/28/2019 Invoice=751828 1.00 6.00 6.00
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
01/29/2019 2394 Amanda Milgrom 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1703416
02/28/2019 Invoice=751828 1.00 6.00 6.00
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
01/29/2019 2394 Amanda Milgrom 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The Cily Of 1703417
02/28!2019 Invoice=751828 1.00 7.50 7.50
Voucher=291681 Paid Vendor=lCCES Balance= .00 Amount= 9195.62
Check #357464 02/08/2019
02/12/2019 0331 John Mill 110 1.00 10.00 10.00 Purchase Type -The Town Of Timnath et al v. Sut 1705234
03/25/2019 Invoice=753439 1.00 10.00 10.00
Voucher=292055 Paid Vendor=lCCES Balance= .00 Amount= 1620.70
Check #357744 03/12/2019
02/21/2019 0331 John Mill 110 1.00 0.28 0,28 Purchase Type - Sutherland, E v Cily of Ft. Coll 1705855
03/25/2019 Invoice=753439 1.00 0.28 0.28
Voucher=292421 Paid Vendor=lCCES Balance= .00 Amount= 4551.39
Check #357744 03/12/2019
02/21/2019 0331 John Mill 110 1.00 6.00 6.00 Purchase Type - Sutherland, E v City of Ft. Coll 1705856
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=292421 Paid Vendor=lCCES Balance= ,00 Amount= 4551.39
Check #357744 03/12/2019
02/21/2019 0331 John Mill 110 1.00 6.00 6.00 Purchase Type - Sutherland, E v Cily of Ft. Coll 1705857
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=292421 Paid Vendor=lCCES Balance= .00 Amount= 4551.39
Check #357744 03/12/2019
02/21/2019 0331 John Mill 110 1.00 6.00 6.00 Purchase Type - Sutherland, E v City of Ft. Coil 1705858
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=292421 Paid Vendor=lCCES Balance= .00 Amount= 4551.39
Check #357744 03/12/2019
02/24/2019 2327 Rosemary Loehr 017 1.00 0.72 0.72 Computer Assisted Research - Lexis 1707247
03/25/2019 Invoice=753439 1.00 0.72 0.72
03/05/2019 2327 Rosemary Loehr 110 1.00 0.08 0.08 Purchase Type -Sutherland, Eric v. The City Of 1707612
Billed and Unbilled Recap Of Cost Detail - [001607.037 -Sutherland Litigation]
Client:001607 -FORT COLLINS, COLORADO 7/22/2019 10:13;48 AM
Page 2
Date I Initlals Name I Invoice Number Code ~ Quantlty Rate ~ Amount Description ( Cost Index
-- _~__ _ I
03/25/2019 Invoice=753439 1.00 0.50 0.50
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/05/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1707616
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/05/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1707617
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/05/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1707621
03/25/2019 Invoice=753439 1.00 7.50 7.50
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/05/2019 2327 Rosemary Loehr 017 1.00 143.50 143.50 Computer Assisted Research - Lexis 1709153
04/23/2019 Invoice=756158 1.00 143.50 143.50
03/06/2019 2327 Rosemary Loehr 017 1.00 0.37 0.37 Computer Assisted Research - Lexis 1709154
04/23!2019 Invoice=756158 1.00 0.37 0.37
03/08/2019 0331 John Mill 015 1.00 7.91 7.91 Postage 1706660
03/25/2019 Invoice=753439 1.00 7.91 7.91
03/08/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1707624
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/08/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1707625
03/25/2019 Invoice=753439 1.00 7.50 7.50
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/11/2019 2327 Rosemary Loehr 017 1.00 76.14 76.14 Computer Assisted Research - Lexis 1709155
04/23!2019 Invo(ce=756158 1.00 76.14 76.14
03/12/2019 2327 Rosemary Loehr 110 1.00 2.64 2.64 Purchase Type -Sutherland, Eric v. The City Of 1707614
03/25/2019 Invoice=753439 1.00 2.64 2.64
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/12/2019 2327 Rosemary Loehr 110 1.00 2.65 2.65 Purchase Type -Sutherland, Eric v. The City Of 1707615
03/25/2019 Invoice=753439 1.00 2.65 2.65
Voucher=293015 Paid Vendor=lCCES Balance= ,00 Amount= 5746.63
Check #357960 04/02/2019
03/12/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1707618
03/25/2019 Invoice=753439 1.00 6.00 6.00
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/12!2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1707619
03!25/2019 Invoice=753439 1.00 6.00 6,00
Voucher=293015 Pa(d Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/12/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v, The City Of 1707622
03/25/2019 Invoice=753439 1.00 7,50 7.50
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02!2019
03/12/2019 2327 Rosemary Loehr 017 1.00 173.14 173.14 Computer Assisted Research - Lexis 1709156
04/23/2019 Invoice=756158 1.00 0.00 0.00
03/13/2019 2327 Rosemary Loehr 017 1.00 393.23 393,23 Computer Assisted Research - Lexis 1709157
04/23/2019 Invoice=756158 1.00 393.23 393.23
Billed and Unbilled Recap Of Cost Detail - [001607.037 -Sutherland Litigation]
Client:001607 -FORT COLLINS, COLORADO 7/22/2019 10:13:48 AM
Page
i
Date Initlals ~ Name /Invoice Number Code ! Quantity ~ Rate ~ Amount Description Cost Index
t
Voucher=293015 Paid Vendor=lCCES Balance- .00 Amount= 5746.63
Check #357960 04/02/2019
03/14/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1707623
03/25/2019 Invoice=753439 1.00 7.50 7.50
Voucher=293015 Paid Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/1412019 2327 Rosemary Loehr 017 1.00 115.93 115.93 Computer Assisted Research - lexis 1709158
04!23!2019 Invoice=756158 1.00 0.00 0.00
03/19/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1708476
04/23/2019 Invoice=756158 1.00 6.00 6.00
Voucher=293407 Paid Vendor=lCCES Balance= .00 Amount= 5036.08
Check #357960 04/02/2019
03/19/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1708478
04/23/2019 Invoice=756158 1.00 7.50 7.50
Voucher=293407 Paid Vendor=lCCES Balance= ,00 Amount= 5036,08
Check #357960 04/02/2019
03/19!2019 2327 Rosemary Loehr 017 1.00 0.37 0.37 Computer Assisted Research - Lexis 1709159
04/23/2019 Invoice=756158 1.00 0.37 0.37
03/20/2019 2327 Rosemary Loehr 017 1.00 77.99 77.99 CompuierAssisted Research - Lexis 1709160
04/23/2019 Invoice=756156 1.00 77.99 77.99
03/ ,7/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1708477
04/23/2019 Invoice=756158 1.00 6.00 6.00
Voucher=293407 Paid Vendor=lCCES Balance= .00 Amount= 5036.08
Check #357960 04!02!2019
03/27/2019 2327 Rosemary Loehr 110 1.00 7,50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1708479
04/23/2019 Invoice=756158 1.00 7.50 7,50
Voucher=293407 Paid Vendor=lCCES Balance= .00 Amount= 5036.08
Check #357960 04!02/2019
03/27!2019 2327 Rosemary Loehr 017 1.00 15,45 15.45 Computer Assisted Research - Lexis 1709161
04/23/2019 Invoice=756158 1.00 15.45 15.45
04/04/2019 2327 Rosemary Loehr 017 1.00 12.97 12.97 Computer Assisted Research - Lexis 1712891
05/24/2019 Invoice=758850 1.00 12.97 12.97
04/05/2019 0331 John Mill 104 1.00 73.66 73.66 Out of Town Travel -Vendor: JOHN W. MILL 1708986
04/23/2019 Invoice=756158 1.00 73,66 73.66 MILEAGE RT-ATTEND HEARING ON ATTORNEY'S FEES
FT COLLINS,CO 03/15/19
Voucher=293549 Paid Vendor=JOHN W. MILL Balance= ,00 Amount= 73,66
Check #20012521 04/11 /2019
04/22/2019 2327 Rosemary Loehr 017 1.00 53.96 53.96 Computer Assisted Research - Lexis 1712892
05/24/2019 Invoice=758850 1.00 53.96 53.96
05/07/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The Cily Of 1712654
05/24/2019 Invoice=758850 1.00 6.00 6.00
Voucher=294730 Paid Vendor=lCCES Balance= .00 Amount= 4305.01
Check #358624 06/06!2019
05/07/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type - Sutherland, Eric v. The Cily Of 1712655
05/24/2019 Invoice=758850 1.00 7.50 7.50
Voucher=294730 Paid Vendor=lCCES Balance= .00 Amount= 4305,01
Check #358624 06/06/2019
05/07/2019 2327 Rosemary Loehr 017 1.00 60.59 60.59 ComputerAssfsted Research - Lexis 1715251
06/19/2019 Invoice=760807 0,00 0.00 0,00
05/11/2019 2327 Rosemary Loehr 017 1.00 85.75 85.75 Computer Assisted Research - Lexis 1715252
06/19/2019 Invoice=760807 1.00 85.75 85.75
05/12/2019 2327 Rosemary Loehr 110 1.00 10.00 10.00 Purchase Type -The Town Of Timnath et aI v. Sut 1714038
06/19/2019 Invoice=760807 1.00 10.00 10,00
Voucher=295358 Pald Vendor=lCCES Balance= .00 Amount= 8195.24
Billed and Unbilled Recap Of Cost Detail - [001607.037 -Sutherland Litigation]
Client:001607 -FORT COLLINS, COLORADO 7/22/2019 10:13:48 AM
Page
Date Initla4s Name /Invoice Number Cade j Quantity I Rate I Amount Descrlptlon Cost Index
06/19/2019 I nvolce=760807 1,00 14.73 14.73
05/12/2019 2327 Rosemary Loehr 017 1.00 95.43 95.43 Computer Assisted Research - ~exis 1715253
06/19/2019 Invoice=760807 1.00 95.43 95.43
05/13/2019 2327 Rosemary Loehr 110 1.00 6,00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1714034
06/19/2019 Invoice=760807 1.00 6.00 6.00
Voucher=295358 Paid Vendor=ICCES Balance= .00 Amount= 8195,24
Check #358624 06/06/2019
05/13/2019 2327 Rosemary Loehr 110 1.00 7.50 7,50 Purchase Type -Sutherland, Eric v. The City O( 1714035
06/19/2019 Invoice=760807 1.00 7,50 7.50
Voucher=295358 Paid Vendor=lCCES Balance= .00 Amount= 8195.24
Check #358624 06/06/2019
05/13(2019 2327 Rosemary Loehr 017 1.00 12.00 12.00 Computer Assisted Research - Lexis 1715254
06/19/2019 I nvoice=760807 1,00 12.00 12.00
05/17/2019 2327 Rosemary Loehr 017 1.00 35.39 35.39 Computer Assisted Research - Westlaw 1714577
0 611 9/2 0 1 9 Invoice=760807 1.00 35.39 35.39
05/17/2019 2327 Rosemary Loehr 017 1.00 12.29 12,29 Computer Assisted Research - Lexis 1715255
06/19/2019 Invoice=760807 1.00 12.29 12.29
05/20/2019 2327 Rosemary Loehr 017 1.00 12.87 12.87 Computer Assisted Research - Lexis 1715256
06/19/2019 Invoice=760807 0,00 0.00 0.00
05/21/2019 2327 Rosemary Loehr 017 1.00 39,78 39.78 Computer Assisted Research - Lexis 1715257
06/19/2019 Invoice=760807 0.00 0.00 0.00
05/23/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The City Of 1714036
06/19/2019 Invoice=760807 1.00 6.00 6.00
Voucher=295358 Paid Vendor=lCCES Balance= .00 Amount= 8195.24
Check#358624 06/06/2019
05/23/2019 2327 Rosemary Loehr 110 1.00 7.50 7.50 Purchase Type -Sutherland, Eric v. The City Of 1714037
06/19/2019 Invoice=760807 1.00 7,50 7,50
Voucher=295358 Paid Vendor=lCCES Balance= .00 Amounl= 8195.24
Check #358624 06/06/2019
BILLED TOTALS: WORK: 1,735.44 61 records
BILLED TOTALS: BILL: 1,333.13
GRAND TOTAL: WORK: 1,735.44 61 records
GRAND TOTAL; BILL: 1,333.13
Affidavit Exhibit B
Check #358624 06/06/2019
05/12/2019 2327 Rosemary Loehr 017 1.00 14.73 14.73 Computer Assisted Research - Westlaw 1714576
Affidavit Exhibit B
03/14/2019 2327 Rosemary Loehr 110 1.00 6.00 6.00 Purchase Type -Sutherland, Eric v. The
City O( 1707620
03/25/2019 Invoice=753439 1.00 6.00 6.00
Affidavit Exhibit B
03/25/2019 Invoice=753439 1.00 0.08 0.08
Voucher=293015 Pald Vendor=lCCES Balance= .00 Amount= 5746.63
Check #357960 04/02/2019
03/05/2019 2327 Rosemary Loehr 110 1.00 0.50 0.50 Purchase Type -Sutherland, Eric v. The City Of 1707613
Affidavit Exhibit B