AdvanceMe Inc v. RapidPay LLC

Filing 345

PROPOSED BILL OF COSTS filed by Merchant Money Tree, Inc., Reach Financial, LLC. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Text of Proposed Order)(Sutliff, Graham)

AdvanceMe Inc v. RapidPay LLC

Doc. 345

Case 6:05-cv-00424-LED

Document 345

Filed 08/28/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ADVANCEME, INC. Plaintiff VS. RAPIDPAY, LLC, BUSINESS CAPITAL CORPORATION, FIRST FUNDS LLC, MERCHANT MONEY TREE, INC., REACH FINANCIAL, LLC and FAST TRANSACT, INC. d/b/a SIMPLE CASH Defendants § § § § § § § § § § § §

CAUSE NO. 6:05-CV-424 LED

MOTION FOR ENTRY OF AGREED BILL OF COSTS

COME NOW Defendants Merchant Money Tree, Inc. and Reach Financial, LLC (collectively referred to as "Defendants") and file this Motion for Entry of Agreed Bill of Costs as set out in the Court's August 14, 2007 Memorandum Opinion and Order (Dkt. 341) and the Court's June 20, 2007 Standing Order Regarding Bills of Costs. The parties have conferred and agree that the following costs are taxable to the Plaintiff: CATEGORY Court Reporter Fees Witness Fees Exemplification and copy costs Court Appointed Expert Fee TOTAL AGREED COSTS $ 15,342.41 $4,631.59 $7,818.37 $6,250.00 $34,042.37

Attached hereto as Exhibits 1-4 are spreadsheets and invoices documenting these four categories of the taxable costs. Defendants respectfully request that the Court adopt these costs

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Dockets.Justia.com

Case 6:05-cv-00424-LED

Document 345

Filed 08/28/2007

Page 2 of 3

as set out herein and enter an order instructing the Court Clerk to enter the Agreed Bill of Costs, attached hereto as Exhibit 5.

Dated: August 28 , 2007

Respectfully submitted, By: /s/ Graham E. Sutliff William G. Schuurman (TX State Bar No. 17855200) [e-mail] Brian K. Buss (TX Bar No. 00798089) [e-mail] Joseph D. Gray (TX Bar No. 24045970) [e-mail] Hilary L. Preston (Admitted pro hac vice) [e-mail] Graham E. Sutliff (TX Bar No. 24046935) [e-mail] R. Floyd Walker (TX Bar No. 24044751) [e-mail] VINSON & ELKINS L.L.P. 2801 Via Fortuna, Suite 100 Austin, Texas 78746 Phone: [phone] Fax: [phone] -andDouglas R. McSwane, Jr. (TX Bar No. 13861300) J. Matt Rowan (TX Bar No. 24033137) POTTER MINTON, P.C. 110 North College 500 Plaza Tower Tyler, Texas 75702 Phone: [phone] Fax: [phone] Counsel for Defendants Merchant Money Tree, Inc. and Reach Financial, LLC

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Case 6:05-cv-00424-LED

Document 345

Filed 08/28/2007

Page 3 of 3

CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on August 28, 2007. Any other counsel of record will be served by First Class mail on this same date. /s/ Graham E. Sutliff

CERTIFICATE OF CONFERENCE Counsel for the Defendants and counsel for Plaintiff conferred several times between August 24, 2007 and August 28, 2007 on the terms of the Bill of Costs. Counsel for Plaintiff confirmed via electronic mail on August 28, 2007 that Plaintiff does not oppose the relief sought herein. /s/ Graham E. Sutliff

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