Opinion
Case Number: 2:06-cv-0633-KJN
10-31-2012
Artay Scruggs Plaintiff(s) v, S. Vance, et al. Defendants,
Hyongsoon Kim Attorney's Signature
REQUEST FOR AUTHORITY TO INCUR
COSTS (APPOINTED PRO BONO COUNSEL)
REQUEST OF PRO BONO COUNSEL FOR PRE-APPROVAL OF EXPENDITURES Complete this form and return it to the court for approval prior to incurring the cost for which reimbursement is requested.
All yellow highlighted fields must he completed prior to submission of this form.
I, Hyongsoon Kim , attorney for plaintiff(s), declare as follows: I was appointed to represent plaintiff(s) in this action on May 2, 2011 , by the Honorable Kendall J. Newman , United States District Judge/Magistrate Judge. If no expenditure is being requested in one or more of the following itemized areas, enter 0 in the appropriate field. TRAVEL EXPENSES:
[ ] Miles (Mileage is paid at the prevailing GSA raw which is available at www.gsn.gov).$
Non-mileage travel expenses:...............................................$ DEPOSITION COSTS: (Not covered by the Court Reporters Transcript Fund).......................$ 1500 SERVICE OF PAPERS, WITNESS FEES:.................................................$ INTERPRETER AND EXPERT WITNESS FEES:..................................$ PHOTOCOPIES, PHOTOGRAPHS, & TELEPHONE TOLL CALLS:......$ OTHER: (A description of expenses must be attached) .......................................$
Please provide a more detailed description of your expense request.
Plaintiff has brought claims under 42 USC 1983; his claims arise out of Defendants' actions relating to an assault by a fellow inmate. Plaintiff's key non-party witness is Dr. Gabrielle Paladino, a medical professional who treated Plaintiff while he was housed at Atascadero State Hospital ("ASH"). Dr. Paladino diagnosed Plaintiff with post-traumatic stress disorder arising from the assault. The other medical professionals who diagnosed Plaintiff with PTSD have either refused to testify or are unavailable. This past summer, Dr. Paladino resigned her position at ASH and took a position in Michigan, (continued on next page)
TOTAL AMOUNT REQUESTED:..............................................................$ 1500 I therefore request that this court authorize the expenditure(s) stated above which is/are necessary to continue my pro bono representation of plaintiff. The following requests for authority to incur costs in this case have already been approved. The amount that has been reimbursed by the court for each previously approved expenditure is indicated in the "Amount Reimbursed" column,
+-----------------------------------------+ ¦Amount Approved¦Purpose¦Amount Reimbursed¦ +---------------+-------+-----------------¦ +---------------+-------+-----------------¦ +---------------+-------+-----------------¦ +---------------+-------+-----------------¦ +---------------+-------+-----------------¦ +---------------+-------+-----------------¦ +-----------------------------------------+
I declare under penalty of perjury that the foregoing is true and correct,
Signed this 29 day of October ,2012 > at Los Angeles .California, Hyongsoon Kim
Attorney's Signature
IT IS SO ORDERED
______________________
For questions concerning this form, please contact;
ADR & Pro Bono Program Director
United States District Court, Eastern District of California
501 I Street, Suite 4-200, Sauramcnlo, CA 9584
Email: spark@caed.uscourts.gov
Scruggs v. Vance, et al. - 02:cv:Q6-633-KJN
Continuation of Request for Reimbursement
Dr. Paladino agreed to be deposed in Michigan, which deposition will take place on Tuesday, October 30. To save costs, we will not be flying to Michigan but instead will depose Dr. Paladino by a three-way videoconference. Because this is a preservation deposition. Dr. Paladino's deposition will need to be videotaped. We are seeking reimbursement for the costs of: (1) reservation of videoconference facilities in Lansing, Michigan; (2) costs for a court reporter to transcribe the deposition; and (3) costs for videography for the deposition. We have received a cost estimate from the court reporting service of $1J 84,50 after discount (estimate is attached). The cost to reserve the videoconference facilities for two hours is $300 (email from videoconference coordinator containing cost estimate is attached). We therefore seek approval to incur no more than £1500,00 in reimbursable expenses. Thank you.