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Charles Robert Gorton v. Todd

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


January 31, 2013

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

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

PLAINTIFF'S THIRD 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. to prepare for trial, and for his time to testify at trial (set to begin on February 20, 2013).

On August 29, 2011, I filed a Request for Authority to Incur Costs (Appointed Counsel) and Request for Payment with this Court in the amount of $3,750. On May 16, 2011, I filed a second Request for Authority to Incur Costs (Appointed Counsel) and Request for Payment with this Court in the amount of $7,500. The Court approved both of those request, and at this time, the requested funds have been incurred (see chart below).

In the second request, I indicated my intent to file a third request for the costs of expert preparation and attendance should the case proceed to trial. I have made reasonable inquiry and believe that the cost of this course of action will not exceed $7,000, which includes $3,000 for one 6 day of Dr. Lovett's attendance at trial and 16 hours of consultation for preparation at Dr. Lovett's 7 standard rate of $250 per hour.

I therefore request that this court authorize the expenditure, in an amount not to exceed $7,000, for the completion of this contemplated course of action. 9 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 $3,750 paid $7,500 Further consultation with nephrologist; preparation of expert $7,675 paid report and discovery; preparation for expert depositions

I declare under the penalty of perjury that the foregoing is true and correct. Signed this 25th day of January, 2013 in San Francisco, California.

WINSTON & STRAWN LLP

By: /s/ Nicholas Short

Nicholas Short

Attorney for Plaintiff

The above expenditure is: __X__ Approved. _____ Disapproved.

Or, _____ Good cause appearing therefore, this matter is set for discovery conference, pursuant to Rule _____, on _________________________, 2013, at__________ in Courtroom Number ___.

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.

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

Signed this ___ day of ___________, 2013, at San Francisco, California.

8

WINSTON & STRAWN LLP

9

By:

Nicholas Short Attorney for Plaintiff

20130131

© 1992-2013 VersusLaw Inc.



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