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HomeMy WebLinkAbout2018CV220 - STACY LYNNE V. NOAH BEALS, SENIOR PLANNER, AND JEREMY CALL - 035 - DEFENDANT BEAL'S NOTICE OF SUBMISSION OF SUPPLEMENTAL ATTORNEY FEE AFFIDAVITDISTRICT COURT, LARIMER COUNTY, COLORADO Larimer County Justice Center 201 Laporte Avenue, Suite 100 Fort Collins, CO 80521-2761 (970) 498-6100 Plaintiff: STACY LYNNE v. Defendants: NOAH BEALS, Senior Planner, City of Fort Collins, in his individual and official capacity, and JEREMY CALL, Senior Associates – Logan Simpson Design, Contractor for the City of Fort Collins, in his individual and official capacity COURT USE ONLY Kimberly B. Schutt, #25947 WICK & TRAUTWEIN, LLC P.O. Box 2166 Fort Collins, CO 80522 Phone: (970) 482-4011 Email: kschutt@wicklaw.com Case Number: 2018 CV 220 Courtroom: 3C DEFENDANT BEAL’S NOTICE OF SUBMISSION OF SUPPLEMENTAL ATTORNEY FEE AFFIDAVIT COMES NOW, the Defendant, Noah Beals, by and through his counsel, Wick & Trautwein, LLC, and hereby submits his attorney’s supplemental affidavit of fees incurred in the defense of this litigation. Said affidavit is submitted for purposes of the upcoming hearing on the award of attorney’s fees to be awarded to the Defendant, which was set pursuant to the Court’s order dated June 12, 2019. Mr. Beals submits that the additional fees reflected in the detailed Supplemental Affidavit attached hereto are in fact reasonable and necessary for the further defense of this ongoing litigation. Therefore, the Court will be acting properly under the standards set forth in the Defendant’s prior attorney fee submission to award these fees, along with any additional fees incurred in the preparation for and at the hearing set for August 5, 2019. DATE FILED: July 31, 2019 9:10 AM FILING ID: 5151239E53C91 CASE NUMBER: 2018CV220 2 WHEREFORE, Defendant Beals respectfully requests the Court to accept the attached Supplemental Affidavit, find that the fees incurred were both reasonable and necessary in defense of this ongoing litigation, and enter a judgment against the Plaintiff and in favor of Defendant Beals, for the fees incurred in his defense, with statutory interest as allowed by law until satisfied in full. Respectfully submitted this 31 st day of July, 2019. WICK & TRAUTWEIN, LLC By: s/Kimberly B. Schutt Kimberly B. Schutt, #25947 Attorneys for Defendant Beals [This document was served electronically pursuant to C.R.C.P. 121 §1-26. The original pleading signed by defense counsel is on file at the offices of Wick & Trautwein, LLC and the Fort Collins City Attorney’s Office] CERTIFICATE OF ELECTRONIC FILING The undersigned hereby certifies that a true and correct copy of the foregoing DEFENDANT BEAL’S NOTICE OF SUBMISSION OF SUPPLEMENTAL ATTORNEY FEE AFFIDAVIT, with attached Affidavit, was filed via the Colorado Courts E-Filing System and served this 31 ST day of July, 2019, on the following: Stacy Lynne 305 W. Magnolia Street #282 Fort Collins, CO 80521 A courtesy copy was also emailed to Ms. Lynne at stacy_lynne@comcast.net s/ Jody L. Minch [The original certificate of electronic filing signed by Jody L. Minch is on file at Wick & Trautwein, LLC)