Opinion
20-CV-00131-NONE-EPG(PQ)
09-07-2021
Edmond Paul Price Plaintiffs v. Alvarado, et al. Defendants.
Lori Rifkin Attorney for Plaintiff(s).
Lori Rifkin Attorney for Plaintiff(s).
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.
I, Lori Rifkln, attorney for plaintiff(s), declare as follows:
I was appointed to represent plaintiff(s) in this action on 112-4-20, by the Honorable [Erica P. Grosjean, United States District Judge/Magistrate Judge.
I believe that the following course of action is reasonably necessary to the prosecution of this action:
The Court extended Plaintiffs counsel's appointment on 6-2-21 for the parties to conduct non-expert discovery in this case, including depositions of all parties, in preparation for a Feb. 2021 settlement conference. Plaintiffs counsel requests pre-approval for the following deposition expenses. Please note that counsel will seek reimbursement first from The Certified Reporters' Fund (TRF) and request reimbursement from the Court only for expenses not fully covered by the TRF: Defending deposition of Plaintiff: Cost of ordering the transcript.
Taking depositions of the 3 individual Defendants: Costs of court reporter services & transcripts for half-day depositions of each Defendant. The current expense request is for remote depositions. An additional pre-approval will be submitted for travel costs if the COVID situation permits in-person depositions.
Counsel seeking reimbursement must support all claimed expenses by submitting invoices, receipts or similar documentation. Without such documentation, counsel will not be reimbursed.
I have made reasonable inquiry and believe that the cost of this course of action will not exceed the amount of $ 5350
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 Approved
Purpose
Amount paid
250
Transcript of Plaintiffs deposition
1700
Court reporter services & transcript for Defendant Alvarado deposition
1700
court reporter services & transcript for Defendant Martinez deposition
1700
court reporter services & transcript for Defendant Caraveo deposition
I declare under penalty of perjury that the foregoing is true and correct.
The above expenditure is x Approved _______ Denied.
Or, ___________ Good cause appearing therefore, this matter is set for discovery conference, pursuant to rule _____, on _______________, at_____, _____.M. in Courtroom Number _____.