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Charles Robert Gorton v. Todd

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


May 21, 2012

CHARLES ROBERT GORTON,
PLAINTIFF,
v.
TODD, ET AL. DEFENDANTS.

The opinion of the court was delivered by: The Honorable Lawrence K. Karlton

REQUEST FOR AUTHORITY TO INCUR COSTS (APPOINTED COUNSEL) AND REQUEST FOR PAYMENT

Amended Complaint Filed: February 26, 2009

Trial Date: February 20, 2013

PART I

I, Nicholas Short, attorney for Charles Robert Gorton ("Plaintiff") declare as follows: I was appointed to represent Plaintiff in this action on November 3, 2010 by the Honorable Lawrence K. Karlton, United States District Judge. I believe that the following course of action is necessary to the prosecution of this action: further consultation with nephrologist David Lovett, M.D. in connection with the preparation of his expert report and expert discovery, and preparation for his deposition.

On August 29, 2011, I filed a Request for Authority to Incur Costs (Appointed Counsel) and Request for Payment ("Request") with this Court in the amount of $3,750. At this time, the requested funds have been incurred (see chart below) for the purposes set forth in the August 29, 2 2011 Request. I have made reasonable inquiry and believe that it is necessary to incur additional 3 costs for the purposes stated above, and that the cost of the course of action will not exceed $7500. 4

Should this case proceed to trial, however, it will become necessary to incur additional costs for the 5 expert's trial preparation and attendance, and I will submit another request at that time. 6

I therefore request that this court authorize the expenditure, in an amount not to exceed that 7 stated above, for the completion of this contemplated course of action. 8

The following payments of costs have been heretofore approved in this matter:

Amount Amount Approved Purpose Paid $3,750 Consultation with nephrologist; preparation of report $2750 paid $1000 incurred and billed I declare under the penalty of perjury that the foregoing is true and correct.

Signed this 16th day of May, 2012 in San Francisco, California. WINSTON & STRAWN LLP By: /s/ Nicholas Short Nicholas Short Attorney for Plaintiff

Pursuant to General Order 230 (E.D. Cal. May 17, 1988), the above expenditure is: __x___ Approved. _____ Disapproved.

PART II

To the clerk of the above-entitled court:

I declare under the penalty of perjury that I have completed the action contemplated above, 4 that I have incurred actual cost in the amount of $_______________, and that I have paid that cost. 5

I therefore request reimbursement of this cost. I understand and agree that this cost will be 6 reimbursed out of any recovery or settlement resulting from this action. 7

Signed this ___ day of _____________________, 2012, at San Francisco, California.

WINSTON & STRAWN LLP By: Nicholas Short Attorney for Plaintiff

20120521

© 1992-2012 VersusLaw Inc.



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