Opinion
No. 2:08-cv-2177
07-27-2012
ROBERT HAYNES Plaintiff(s) v. D.K. SISTO, et al. Defendants.
REQUEST FOR AUTHORITY TO INCUR
COSTS (APPOINTED COUNSEL) AND
REQUEST FOR PAYMENT
REQUEST OF PRO BONO FOR PRE-APPROVAL OF EXPENDITURES
Complete this form and return it to the court (with two copies) for approval prior to incurring the cost for which reimbursement is requested.
ALDEN KNISBACHER , attorney for plaintiff(s), declare as follows:
I, was appointed to represent plaintiff(s) in this action on October 7, 2011, by the Honorable judge Susan P. Graber, United States District Judge/Magistrate. I believe that the following course of action is reasonably necessary to the prosecution of this action:
I need to depose defendants D.K, Sisto, T. Sequira, and V. Singh regarding the lockdown and unlock procedures at California State Prison, Solano. All three defendants have submitted declarations in support of defendants' motion for summary judgment, which allege that Black inmates were locked down because the entire race appeared to be involved in tensions with Southern Hispanic inmates. Plaintiff has plead that tensions between Black and Southern Hispanic inmates did not warrant a lockdown of all Black inmates, and that defendants employed this tactic as a punitive response to the Black inmate representatives'. refusal to meet with Southern Hispanic representatives. In order to oppose defendants' motion for summary judgment, need to question these defendants about how the lockdown was instituted and what steps were taken to release inmates that had no connection to tensions with Southern Hispanic inmates.
(e.g., deposition of _________________, defendant herein).
I have made reasonable inquiry and believe that the cost of this course of action will not exceed the amount of $ 2,180.00.
I therefore request that this court authorize the expenditure in an amount not to exceed that stated above for the completion of this contemplated course of action.
The following payments of costs have been heretofore approved in this matter:
+-----------------------------+ ¦Amount ¦ ¦ ¦ ¦ ¦Purpose¦Amount Paid ¦ ¦Approved¦ ¦ ¦ +--------+-------+------------¦ +--------+-------+------------¦ +--------+-------+------------¦ +--------+-------+------------¦ +--------+-------+------------¦ +--------+-------+------------¦ +-----------------------------+
I declare under penalty of perjury that the foregoing is true and correct.
Signed this 13th day of July, 2012, at Oakland, California.
_________________
Attorney for Plaintiff(s)
The above expenditure is √ Approved ___ Denied Or.
___ Good cause appearing therefore, this matter is set for discovery conference, pursuant to rule ___ , on _________________ at,______, ___M. in Courtroom Number ___.
__________________________________
United States District Judge/Magistrate