Giraldes v. Beard

Filing 28

ORDER signed by Magistrate Judge Carolyn K. Delaney on 7/13/2015 ORDERING plaintiff's attorney's request for authority to incur costs by appointed pro bono counsel Alan J. Reinach is GRANTED. (Crouch, J)

I. .·P!in~ Form;

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

Ilarry Glraldes

Plaintiff(s)

No.

VS.

IJeffrey Beard

Defendants.

!2:14-CV-01780-CKD

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

----------------~/
REQUEST OF PRO BONO FOR PRE-APPROVAL OF EXPENDITURES
Complete this fonn and return it to the court (with two copies) for approval prior to incurring the
cost for which reimbursement is requested.

I,

!Alan J. Reinach

, attorney for plaintiffts), declare as follows:

F=-=...===~=="""",,,.u...:i:.:.n..:t:.:.h~is action on /March 10,2015
, by the
, United States District JUdgelMagistrate Judge.
Honorable Carolyn K. Delaney
I believe that the following course of action is reasonably necessary to the prosecution of this
action:

1. Obtain an expert witness report with respect to Christian religioUS teachings and laws concerning marriage,
and the importance of consummation, as well as physical, emotional and spiritual intimacy nurtured during
private time;
2. One or two visits to Plaintiffto secure his declaration In support of his MSJ.

Counsel seeking reimbursement must support all claimed expenses by submitting invoices, I'eceipts or similar
documentation. Witbout sucb 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 $13,000
I therefore request that this court authorize the expenditure in an amount not to exceed that stated
above for the completion ofthis contemplated course of action.

.,

REQUEST OF PRO BONO FOR PRE-APPROVAL OF EXPENDITURES - PAGE 2
Case Number: 1 :14-cV-0178<>-CKD
2
The following payments of costs have been heretofore approved in this matter:
Amount
Approved

Amount
Paid

Purpose

1$2,000

IExpert Witness Fee I report

1$1000

ITravel budget for two (2) trips to Sacramento from southern California

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I declare under penalty of perjury that the foregoing is true and correct.

Signed this 18th

day of [July

, 20

rs .

at [Thousand Oaks

, California.

Attorney for Plaintiff(s)

The above expenditure is

~pproVed

- - - -Denied

Or,

- - - -Good cause appearing therefore, this matter is set for discovery conference, pursuant
to rule _ _ _" on _ _ _ _ _ _ _ _ _->, at _____, __.M. in Courtroom
Number
.
Dated:

7 Ad LOp IS-

Caftltyn K. De4aney

u.s. Maglstl'ilte Judge

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