ATTACHMENTS TO
`DOCKETING STATEMENT
`
`Electronically Filed
`Apr 11 2025 11:56 AM
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`PART 4
`
`Docket 90001 Document 2025-16400
`
`

`

`EXHIBIT 3
`EXHIBIT 3
`
`EXHIBIT 3
`EXHIBIT 3
`
`

`

`4:36 PM
`
`Burris & Thomas, LLC
`Advanced Costs
`11/10/22
`Accrual Basis
`All Transactions
`
`
`
` Date Source Name Memo Amount
`
`
`
`
`
`Extra Space Storage
`Vasey, Deland Estate of
`Nevada HighwayPatrol
`
`Extra Space Storage
`Vasey, Deland Estate of
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`Vasey, Deland Estate of
`Filefee
`Extra Space Storage
`Doubletree
`SouthwestAirlines
`SouthwestAirlines
`Extra Space Storage
`Extra Space Storage
`
`SouthwestAirlines
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`Vasey, Deland Estate of
`LV Process & Investigations
`Clark County Coroner
`Vasey, Deland Estate of
`SouthwestAirlines
`Extra Space Storage
`
`Vasey, Deland Estate of
`220.00
`Storage
`01/03/2019
`Extra Space Storage
`3,50
`Vasey/fee/EXPP
`01/16/2019
`Filefee
`259.50
`Special Administration
`02/07/2019
`Nye County Clerk
`16.30
`Postage
`02/07/2019
`220.00
`Storage
`Extra Space Storage
`02/11/2019
`6.80
`Postage
`Vasey, Deland Estate of
`02/20/2019
`
`
`02/22/2019 Western Motor Carrier Safety |..._Initial setup fee 750.00
`03/04/2019
`Postage
`6.83
`03/07/2019
`Storage
`220.00
`03/14/2019
`Seminar TS/trucking regulations
`650.00
`03/22/2019
`Police Report
`15.00
`03/22/2019
`Focus Group
`1,684.00
`03/26/2019
`Focus Group
`1,187.50
`03/27/2019
`Focus Group
`1,350.00
`03/28/2019
`Focus Group
`1,300.00
`04/09/2019
`Storage
`220.00
`04/15/2019
`Clear Search
`150.00
`05/03/2019
`Storage
`237.00
`06/04/2019
`Storage
`237.00
`07/07/2019
`Storage
`237.00
`07/29/2019
`Clear Search(2)
`300.00
`08/15/2019
`Vasey/fee/ACSR
`3.50
`09/07/2019
`Storage
`237.00
`09/13/2019
`Atlanta room/Travis
`345.85
`09/13/2019
`Atlanta Airfare / Travis
`379.96
`09/19/2019
`Airfare (9-27)
`133.98
`10/07/2019
`Storage
`237.00
`11/08/2019
`Storage
`237.00
`11/08/2019
`Faxes (wk end 11/08)
`5.00
`12/03/2019
`FL travel 12/15
`647.50
`42/07/2019
`Storage 336
`229.10
`01/06/2020
`Storage
`237.00
`02/06/2020
`Storage
`254.00
`02/07/2020
`Case Conference with Expert Institute
`350.00
`02/12/2020
`Service on CC Coroner
`85.00
`02/20/2020
`Coroner Report
`44.00
`02/27/2020
`4 Case Conferences/Expert Institute
`1,400.00
`03/04/2020
`FL Travis travel
`226.46
`03/06/2020
`Storage fee
`254.00
`03/06/2020
`Copies (wk end 3/6/20)
`114.50
`03/24/2020
`Travis air travel Florida
`497.96
`03/30/2020
`Hertz Car rental FL 3/14
`377.07
`04/06/2020
`254.00
`05/06/2020
`254.00
`05/08/2020
`350.00
`06/06/2020
`254.00
`07/06/2020
`254.00
`07/20/2020
`600.00
`07/29/2020
`30.00
`08/06/2020
`254.00
`09/08/2020
`254.00
`10/06/2020
`254.00
`41/09/2020
`1,967.50
`42/06/2020
`276.00
`02/06/2021
`276.00
`03/06/2021
`276.00
`04/06/2021
`276.00
`05/06/2021
`276.00
`05/10/2021
`3.50
`06/06/2021
`276.00
`08/06/2021
`356.00
`
`SW Air
`Travis Shetler
`Extra Space Storage
`Extra Space Storage
`
`Extra Space Storage
`Extra Space Storage
`Curt E. Harper, Ph.D.
`Bank of The West
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`Extra Space Storage
`Filefee
`Extra Space Storage
`Extra Space Storage
`
`Storage
`PeopleMap research
`Vasey
`Storage
`Expert retainer
`Add'lfee/IAFD
`Storage
`Storage unit
`
`Copies
`
`Storage
`
`Vasey
`Storage
`T. Vasey/fee/ATLN
`
`Storage
`
`Total Vasey, Deland Estate of
`
`TOTAL
`
`22,307.31
`
`22,307.31
`
`Page 1
`
`

`

`EXHIBIT 4
`EXHIBIT 4
`
`EXHIBIT 4
`EXHIBIT 4
`
`

`

`4:35 PM
`
`Burris & Thomas, LLC
`Advanced Costs
`11/10/22
`Accrual Basis
`All Transactions
`
`
`
` Date Source Name Memo Amount
`
`
`
`
`
`Vasey, Tamara
`02/19/2019
`02/25/2019
`02/28/2019
`03/04/2019
`03/21/2019
`04/02/2019
`04/05/2019
`04/17/2019
`06/24/2019
`07/25/2019
`08/19/2019
`08/20/2019
`09/30/2019
`10/11/2019
`10/11/2019
`10/18/2019
`10/30/2019
`11/08/2019
`11/08/2019
`11/15/2019
`12/04/2019
`12/06/2019
`12/06/2019
`12/09/2019
`12/10/2019
`01/09/2020
`01/09/2020
`01/09/2020
`01/10/2020
`01/13/2020
`01/15/2020
`01/17/2020
`01/17/2020
`01/17/2020
`01/17/2020
`01/22/2020
`01/22/2020
`01/22/2020
`01/22/2020
`01/22/2020
`01/23/2020
`01/24/2020
`01/24/2020
`01/27/2020
`01/29/2020
`01/31/2020
`02/03/2020
`02/07/2020
`02/11/2020
`02/14/2020
`02/18/2020
`02/21/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/22/2020
`02/25/2020
`02/26/2020
`02/27/2020
`
`ChartSwap
`MRO
`Bank of The West
`
`MRO
`Scripps Health
`Vasey, Tamara
`Scripps Health
`Filefee
`Superior Court of California
`SouthwestAirlines
`South Point Hotel
`Filefee
`
`Filefee
`
`Filefee
`
`Vasey, Tamara
`Scripps Health
`San Diego Imaging
`San Diego Imaging.
`Southern Nevada Pain Center
`
`Scripps Health
`Douglas Parking Garage
`Doc Request, LLC
`Sharecare Health Data Service...
`
`Records/Desert Radiologists
`Medical Records
`NHP Fees
`Postage
`UMC records
`Billing Records
`Copies
`Medical Records
`T.Vasey/fee/COMP
`Fee
`8/22 Airfair
`Room Deposit
`T.Vasey/fee/ABREA
`Scans (Wk end 10/11)
`Copies (wk end 10/11)
`Faxes (week end 10/18)
`T.Vasey/fee/NECC
`Faxes (wk end 11/08)
`Copies (wk end 11/08)
`Copies (wk end 11/15)
`T.Vasey/fee/JCCR
`Scans (wk end 12/06)
`Copies (Wk end 12/06)
`Legal Wings Runner
`Medical Records
`Billing Records
`Medical Records
`Medical Records
`Faxes (wk end 1/10)
`Medical Records
`court parking
`Records & Bills/Hand Surgery Spec.
`Medical Records/SW Medical Assoc
`Scans (wk of 1/17)
`Copies (wk end 1/17)
`Medical records Palomar Health
`Integrity Document Solutions
`Medical Records
`Tri-City Medical Center
`Orthopedic Specialists of North... Medical Records
`Tri-City Medical Center
`Medical Records
`Carlsbad Physical Therapy
`Medical Records
`Scripps Health
`Medical Records
`Faxes (wk end 1/24)
`Copies (wk end 1/24)
`Records & Bills
`Medical Records CD
`Faxes (wk end 1/31/20)
`Medical Records/Coastal Pain
`Copies (wk end 2/07)
`T.Vasey/fee/NTTD
`T.Vasey/fee/PSER
`T.Vasey/fee/NTTD
`Service on NHP
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/SUBP
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`T.Vasey/fee/NTTD
`Travel/Tamara
`T.Vasey/fee/NTTD
`T.Vasey/fee/NI
`
`Tri-City Medical Center
`Sharp Mesa Vista Hospital
`
`Medical Docs-CA
`
`Filefee
`Filefee
`Filefee
`LV Process & Investigations
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`Filefee
`SW Air
`Filefee
`Filefee
`
`9.20
`10.80
`10.00
`6.83
`1,301.40
`15.00
`18.00
`17.10
`281.60
`18.00
`551.96
`77.97
`3.50
`3.25
`3.25
`5.00
`3,50
`15.00
`40.50
`3.50
`3.50
`22.00
`57.50
`10.00
`15.30
`15.00
`15.00
`5.40
`5.00
`15.00
`10.00
`16.00
`135.35
`26.00
`6.00
`15.00
`30.00
`30.00
`74,25
`30.00
`8.64
`5.00
`4.00
`6.16
`6.00
`20.00
`40.25
`26.25
`3.50
`3.50
`3.50
`85.00
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`3.50
`264.98
`3.50
`3.50
`
`Page 1
`
`

`

`4:35 PM
`
`Burris & Thomas, LLC
`Advanced Costs
`11/10/22
`Accrual Basis
`All Transactions
`
`
`
` Date Source Name Memo Amount
`
`
`
`
`
`South Point Hotel
`South Point Hotel
`Mizpah Hotel
`South Point Hotel
`Filefee
`Vasey, Tamara
`
`Travis Shetler
`Vasey, Tamara
`Vasey, Tamara
`
`SouthwestAirlines
`Red Rock Hotel
`Uber Trip
`Vasey, Tamara
`Filefee
`Wal-Mart
`
`274.43
`Room Tamara
`02/27/2020
`98.97
`3/01 Room
`02/29/2020
`347.35
`Rooms in Tonopah
`03/02/2020
`13.00
`3/2 charge
`03/03/2020
`3.50
`T.Vasey/fee/PSER
`03/06/2020
`4.80
`Postage
`03/06/2020
`5.00
`Faxes (wk end 3/06/20)
`03/06/2020
`117,00
`Scans (wk end 3/6/20)
`03/06/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3,50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/10/2020
`5.00
`Faxes
`Vasey, Tamara
`03/10/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/11/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/11/2020
`3.50
`T.Vasey/fee/NTTD
`Filefee
`03/11/2020
`25.00
`Billing Records/CEP America
`ChartSwap
`03/11/2020
`15.00
`Rafael Acevedo-Casillas License Search
`Records Section
`03/12/2020
`
`
`03/17/2020 VRC Companies LLC dba Vital...|Medical Records / Palomar Health 142.25
`05/06/2020
`Filefee
`T.Vasey/fee/OPPM
`3.50
`05/08/2020
`PeopleMap research
`350.00
`06/10/2020
`Deposit on Apartment
`100.00
`06/25/2020
`Secure Med. Expert(Voc.Rehab)Elite
`2,500.00
`06/26/2020
`Expert Referral / Elite
`2,500.00
`06/30/2020
`Faxes (wk end 6/30)
`15.00
`07/08/2020
`Sharecare Health Data Service... Medical Records / Optum
`4.66
`07/09/2020
`Robert W. Johnson & Associates
`Retainer Fee
`6,000.00
`07/09/2020
`H. Ronald Fisk, MD
`Retainer Fee
`7,000.00
`07/12/2020
`Tri-City Medical Center
`Medical Records
`109.55
`07/17/2020
`Faxes (wk end 7/17)
`20,00
`Marcel Fraix
`07/20/2020
`Expert Retainer
`1,500.00
`
`
`07/21/2020 VRC Companies LLC dba Vital..._Billing Records 15.00
`07/23/2020
`Scripps Health
`Billing Records/Hospital
`15.00
`07/23/2020
`Scripps Clinic
`Billing records/clinic
`15.00
`07/31/2020
`Faxes (wk end 7/31)
`40.00
`07/31/2020
`Copies (wk end 7/31)
`105.25
`08/07/2020
`Ticket 8/14
`118.98
`08/08/2020
`Room 8/11
`467.82
`08/11/2020
`Uber trip
`290.35
`08/11/2020
`Westlaw Searches
`1,856.00
`08/13/2020
`T.Vasey/fee/OPPM
`3.50
`08/13/2020
`PZ Supplies
`31.44
`08/14/2020
`Faxes (wk end 8/14)
`5,00
`08/14/2020
`Scans (wk end 8/14)
`38.50
`08/15/2020
`Lodging
`34.95
`08/16/2020
`Fedex Book
`38.36
`08/17/2020
`T.Vasey/fee/NTTD
`3.50
`08/20/2020
`Tonopah 8/12 8/15, gas, food, lodging
`654.69
`08/25/2020
`Plastic Bubble Cusion
`64,98
`08/28/2020
`Faxes (wk end 8/28)
`5.00
`09/04/2020
`Moving Boxes
`137.80
`09/08/2020
`Media Search/Silver State Lit.
`150.00
`09/09/2020
`Lodging, fuel, food, labor & supplies for move
`984.56
`09/14/2020
`T.Vasey/fee/ANTD
`3.50
`09/18/2020
`Lodging
`159.77
`
`Red Rock Hotel
`Thriftbooks
`Filefee
`Travis Shetler
`Lowe's
`
`U-Haul
`
`Travis Shetler
`Filefee
`South Point Hotel
`
`Total Vasey, Tamara
`
`TOTAL
`
`29,892.40
`
`29,892.40
`
`Page 2
`
`

`

`EXHIBIT 5
`EXHIBIT 5
`
`EXHIBIT 5
`EXHIBIT 5
`
`

`

`:
`
`NOTABLERete
`SETEMES
`
`oeDOESNOT INCLUDE cass $10.BILLIONoa
`EDGE© VERDICTS ce eatooaie baad TO
`J\OCTOBER 2023
`
`VERDICTS &
`
`Dyce
`
`

`

`
`
`Travis Shetler/ Stacey Cutting
`Confidential 8 - Figure
`Settlement
`Las Vegas, NV
`
`
`
`

`

`INTENTIONALLY
`INTENTIONALLY
`LEFT BLANK
`LEFT BLANK
`
`

`

`TRAVIS E. SHETLER, ESQ.
`Nevada Bar No. 4747
`travis@shetlerlawfirm.com
`LAW OFFICES OF TRAVIS E. SHETLER
`3202 W. Charleston Boulevard
`Las Vegas, Nevada 89102
`(702) 931-9700 - Telephone
`(702) 931-9800 - Facsimile
`Attorney for Plaintiff
`
`EIGTH JUDICIAL DISTRICT COURT
`CLARK COUNTY, NEVADA
`
`CASE NO.: A-19-797292-C
`DEPT. NO.: 5
`
`HEARING REQUESTED
`Hearing Date: 9/19/2024
`Hearing Time: 9:30 a.m.
`
`TAMARA VASEY, individually and as
`Special Administrator of the Estate of
`DELAND SIDNEY VASEY, Deceased,
`Plaintiff,
`
` vs.
`
`FEDEX GROUND PACKAGE SYSTEM
`INC.; F E D E X C O R P R O A T I O N ;
`G H G CORPORATION; RAFAEL
`ACEVEDO-CASILLAS and DOE
`EMPLOYEES 1 through X; ROE
`CORPORATIONS I through X; inclusive
`Defendants.
`
`
`
`PLAINTIFF’S OPPOSITION TO
`PRIOR COUNSEL’S MOTION IN SUPPORT OF
`COURT’S AWARD OF ATTORNEY FEES & COSTS
`
`NOTICE is hereby given by the undersigned attorney, Travis E. Shetler, Esq. of the LAW
`OFFICE OF TRAVIS E. SHETLER, P.C., hereby files Plaintiff’s Opposition to Prior Counsel’s
`Motion in Support of Attorney Fees & Costs.
`
`Burris is entitled to $196,012.50 for actual billable hours. This Honorable Court must find that
`Burris, who received $750,000 based on this court’s prior ruling, should not only disgorge
`$553,987.50 as well as pay attorneys fees and costs with interest.
`....
`
`Page 1 of 9
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Las Vegas, Nevada 89102
`
`3202 W. Charleston Boulevard
`TRAVIS E. SHETLER
`
`Law Office Of
`
`Case Number: A-19-797292-C
`
`Electronically Filed
`
`8/22/2024 9:04 PM
`
`Steven D. Grierson
`
`CLERK OF THE COURT
`
`

`

`HOURS THAT ARE ACTUALLY BILLABLE
`FOR BURRIS, ASSOCIATE ATTORNEYS AND STAFF
`
`BURRIS
`
`claimed hours 45.4
`
`Actual hours 39.9
`
` @$750 =
`
`$29,925
`
`ASSOCIATE ATTORNEYS
`TES
`claimed hours 1202.2
`MAK
`claimed hours 176.3
`KB
`claimed hours 12.2
`AG
`claimed hours 4.6
`SAM
`claimed hours .1
`
`LEGAL ASSISTANT/ PARALEGAL
`PZ
`claimed hours 300.1
`CJD
`claimed hours 2.1
`CS
`claimed hours .2
`
`SUPPORT STAFF
`MC
`claimed hours 17.6
`FB
`claimed hours 2.1
`CPD
`claimed hours .4
`DB
`claimed hours .1
`BB
`claimed hours .1
`
`Actual Hours 354.8 @ $350.00
`Actual Hours 27.6 @ $350.00
`Actual Hours 12
`@ $350.00
`Actual Hours 4.
`@ $350.00
`Actual Hours .1
` @ $350.00
`
`$124,180
`$ 9,660
`$ 4,200
`$ 1,610
`$ 35
`
`Actual Hours 202.1 @ $125.00
`Actual Hours .8
`@ $125.00
`Actual Hours .2
`@ $125.00
`
`$ 25,262.50
`$ 100
`$ 25
`
`Actual Hours 17.6 @ $50.00
`Actual Hours 2.1
` @ $50.00
`Actual Hours .4
` @ $50.00
`Actual Hours .1
`@ $50.00
`Actual Hours .1
` @ $50.00
`
`$ 880
`$ 105
`$ 20
`$ 5
`$ 5
`
`$196,012.50 for actual hours claimed is the only amount Burris should be entitled to recover
`
`Attached hereto are Exhibits 1, 2, 3 & 4 setting forth the actual hours listed that Burris can claim.
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Page 2 of 9
`
`

`

`BURRIS’ CLAIMED $750 HOURLY RATE FOR HIMSELF AND
` ASSOCIATE ATTORNEYS IS NOT REASONABLE.
`Nevada Courts have limited fees for senior associate attorneys to $350 per hour.
`The Court of Appeals of the State of Nevada has directed that this Honorable Court conduct
`an analysis of the reasonableness of the claimed lien, specifically the hourly rate Burris claimed for
`himself and also for associates, utilizing the factors set forth in Brunzell v. Golden Gate Nat'l Bank,
`85 Nev. 345, 349, 455 P.2d 31, 33-34 (1969).
`Brunzell requires that Burris justify his fees, rates and costs. The Brunzell factors consist of
`the following inquiries:
`
`(1) the qualities of the advocate: his ability, his training, education, experience,
`professional standing and skill;
`(2) the character of the work to be done: its difficulty, its intricacy, its importance,
`time and skill required, the responsibility imposed and the prominence and
`character of the parties where they affect the importance of the litigation;
`(3) the work actually performed by the lawyer: the skill, time and attention given to
`the work [and];
`(4) the result: whether the attorney was successful and what benefits were derived.
`Brunzell, at 349.
`While the Motion filed spends a great deal of time discussing extraneous matters, the relevant
`Brunzell factors are eventually addressed in the final 2 pages. At that point, Burris spends roughly a
`page of the Motion addressing his qualifications. However, at no point does the Motion address the
`issues referenced by the Court of Appeals and discussed in LVMPD v. Yeghiazarian, 129 Nev. 760,
`770 (2013), the reasonableness of the hourly rate claimed for his associate attorneys.
`Where there is an agreement, Brunzell requires an analysis of the agreement the lien is based
`upon to ensure that the agreement itself is not unreasonable. More specifically, the order of the Court
`of Appeals wants an analysis conducted regarding whether the $750 hourly rate “billed by both
`partners and associates were also “reasonable under the circumstance,”“ referencing the Yeghiazarian
`case.
`
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`The Burris Motion makes no reference whatsoever to a distinction in the hourly rate between
`Burris’ hourly rate and the hourly rate of associates. The Motion fails to provide this Honorable Court
`with any argument in support of his claim that all hours are to be billed at $750. This leaves no choice
`but for the court to seek out its own information, a task that is not this court’s responsibility. In order
`to assist, the undersigned references language set forth by the Supreme Court in Yeghiazarian.
`[A] “reasonable attorney’s fee” cannot have been meant to compensate only work
`performed personally by members of the bar. Rather, the term must refer to a
`reasonable fee for the work product of an attorney. Thus, the fee must take into
`account the work not only of attorneys, but also of secretaries, messengers,
`librarians, janitors, and others whose labor contributes to the work product for
`which an attorney bills her client . . . . We thus take as our starting point the
`“reasonable attorney’s fee” provided for by statute should compensate the work of
`paralegals, as well as that of attorneys.
`Yeghiazarian, citing to the United States Supreme Court decision in Missouri v. Jenkins, 491 U.S. 274
`(1989). The Jenkins court then goes on to discuss that fact that the use of others reduces litigation
`costs, “so long as they are billed at a lower rate.” Jenkins at 288.
`The cited language leaves it to this Honorable Court to make a decision as to the
`reasonableness of the claimed fees for the associate attorneys. It is not reasonable for Burris to seek
`the same rate of compensation for associates, paralegals and all staff, as well as himself. As set forth
`in the article written by Nevada attorney John Naylor, a survey was conducted of Nevada Court
`decisions on the topic of attorney fees versus fees for associates. The article states that Nevada Courts
`have held that while $750 per hour is a reasonable rate for attorneys similarly situated as Burris, $350
`per hour is what has been awarded for Senior Associates. (See John Naylor, ESQ., What are
`“Reasonable Attorney’s Fees” According to the State and Federal Courts in Nevada? December 4,
`2017 (Attached hereto as Exhibit 5)).
`A review of Burris’ claimed lien coupled with his Motion, fails to find support for a decision
`that the rate of $750 per hour is a “Reasonable Attorney Fee” for associates. Based on the survey of
`Nevada Court decisions, the rate Burris should be allowed to bill for associates should be limited to
`
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`$350 per hour.
`
`DISCUSSION REGARDING BURRIS’ CLAIMED FACTS
`
`During the extensive course of litigation required to adjudicate Burris’ claimed lien, he has
`penned several untrue facts regarding the undersigned and my staff both personally and professionally.
`In an attempt to maintain civility and professionalism, I have taken the high road and bit my tongue.
`However, his vindictive, bullying has stooped so low, I must point out the most recent untruths in the
`8/8/2024 pleading.
`On behalf of Mr. Burris, I originally signed the contract with the Keenan Law Firm. The
`contact signed between Burris and the Keenan Law Firm was a 50/50 split on attorney fees. This case
`was never assigned to Bish & Cutting by Mr. Keenan or Mr. Burris, as Burris falsely states in his
`Motion. During the time the Vasey case was with Burris’ office, Keenan’s office participated by
`holding focus groups and training courses. It was only after I left the Burris firm, and Mr. Burris was
`fired by Plaintiff Vasey, that Mindy Bish, Esq. become more intimately involved on a day to day basis.
`A new contract was then executed between the undersigned and Keenan. Approximately two
`years after that, the contract did change from Shetler/Keenen to Shetler/Keenan/Bish & Cutting. I
`associated Stacy Cutting into the case, not Keenan, not Burris.
`Burris’ Motion (page 3 lines 20-22) accuses me of advertising that the case settled for the
`amount of $10,000,000. First, at no time has the undersigned ever published anything regarding a
`settlement amount. The terms of the resolution in the case are protected by a confidentiality
`agreement. As clearly shown in the exhibit, it was the Keenan Law Firm who published that Ms.
`Cutting and the undersigned settled a case for an 8 figure settlement. I was unaware of this
`advertisement until it was brought to my attention by Mr. Burris.
`How Burris came to the conclusion that the case resolved for a specific amount is not
`explained. Burris’ false claim that I advertised the settlement does not set forth a figure. Where did
`Burris obtain this alleged amount from? What makes him believe and write in this public document,
`governed by his obligations of candor under Nevada Rule of Civil Procedure 11, the amount is
`
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`$10,000,000 when this settlement amount is confidential? NRCP 11 requires attorneys to maintain
`candor in their legal pleadings, yet no source of this “claim” is provided.
`Burris carries on and writes that after the undersigned was terminated (although he told to Ms.
`Vasey that I was laid off), that I then persuaded various clients to fire the Burris firm. Let me be very
`clear on this, I never called a client and never told anyone to fire Burris. In fact, it was Burris who
`approached clients who left his firm and attempted to “persuade, threaten and harass” some of those
`same clients to return to his firm. As is his style, plenty of vindictive bullying was employed.
`On page 5 of the Burris Motion, beginning on Line 14, he discusses his “entitlement” to a
`contingency share. Ms. Vasey was given an offer to settle on 2/11/2020 for a confidential amount far
`less than seven figures. If, in fact, this Honorable Court grants the Burris request for “40%" of the
`settlement, it is respectfully requested that these figures be discussed in camera and that the fee be
`granted as to only those monies offered during the 22 months the Vasey claim was with the Burris
`office.
`This result is what would be contemplated by both the retainer contract and the case law of
`Nevada. It is also reflected in the Brunzell analysis. The fourth factor directs this Honorable Court
`to conduct an analysis of the outcome. It requires that a determination analyzing:
`(4) the result: whether the attorney was successful and what benefits were derived.
`An application of this analysis shows that Burris’ contingency would be limited to an interest in the
`monies actually offered while the case was at his firm. To grant Burris a percentage of the increased
`fee realized, only through a great deal of work by several attorneys roughly 30 months after the case
`left his firm, would not be reasonable.
`Burris’ Motion goes on to make yet more untruthful statements, claiming when other cases
`settled where he had a lien, the undersigned “took the money, and failed to inform me until I found
`out through other means.” This is completely false and flagrantly violates the candor requirement set
`forth in NRCP 11 as well as the civility and professionalism required before this Honorable Court.
`If a case settled and litigation was required to obtain a determination of the value of the actual
`lien (as was the case in most instances), Burris was paid immediately, once a Judge made a ruling.
`If any case settled after the lien was ruled on, Mr. Burris was paid at the exact same time all checks
`
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`

`

`were disbursed, which was once the check cleared. In the instant case, Burris was paid his lien as it
`was ordered by this Honorable Court.
`In the Burris pleading, he again states that the undersigned “persuaded Ms. Vasey...” to
`terminate him. This is also completely false. Ms. Vasey’s case had the highest earning potential in
`the Burris firm. Burris instructed me to handle the case and give her anything she wants.
`Burris claims that he was the “uppermost attorney overseeing the case.” When I was “fired”
`Burris sent Ms. Vasey and email telling her that he would like her to stay with his firm “but I will not
`take care of you the way Travis did.” Why anyone would ever make such a comment to their highest
`earning client is beyond immigration. Most tellingly, Burris NEVER spoke a word to Ms. Vasey in
`the nearly 2 years her case was at his firm. Additionally, Burris NEVER laid eyes on Ms. Vasey in
`the nearly 2 years her case was at his firm, despite claiming to be the “uppermost attorney overseeing
`the case.”
`The main relevance to this Honorable Court is that the Burris pleading is permeated with mere
`ramblings and rantings based on anger which is barely concealed within the 157 pages of his alleged
`lien and throughout his vituperous pleadings. Even now, with Burris’ second bite at the apple, one
`finds only the machinations of fantasy, conjecture and dissatisfaction. There is no Brunzell analysis,
`no review to meet his burden of reasonableness and no supporting documents or explanations.
`When one looks behind Burris curtain, it is revealed that the lien is specious, only loosely
`based on fact and no more than at attempt to grab monies that he is not entitled to. The reality is that
`Burris’ interest in the funds of the Vasey case is truly only worth roughly the value he would have
`received at the time of the original offer. To hold otherwise would be an abuse of discretion and with
`would create a manifest injustice. It is respectfully requested that this Honorable Court determine that
`true amount of Burris’ claimed lien is $196,012.50. This is a supportable amount pursuant to the
`reasonableness standard required by Brunzell and that he be ordered to disgorge the overpayment, with
`interest.
`
`CONCLUSION
`Based upon the foregoing, Plaintiff respectfully request that this Honorable Court reduce the
`Burris’ Lien to the extent said lien complies with the reasonableness factors set forth in Brunzell.
`
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`

`

`Specifically, it is requested that this Honorable Court issue an Order granting Burris a lien in the
`amount of $196,012.50 and disgorge the overpayment of $553,987.50. Additionally, it is
`respectfully requested that the Burris bear the attorney’s fees incurred in fighting to resolve the
`distorted and deceitful liens and pleadings filed by the Respondent as well as interest.
`DATED this 22nd day of August, 2024.
`
`
`
`LAW OFFICES OF TRAVIS E. SHETLER
`/s/ Travis Shetler
`By:
` Travis E. Shetler, Esq.
` Nevada Bar No. 4747
` travis@shetlerlawfirm.com
` 3202 W. Charleston Boulevard
` Las Vegas, Nevada 89102
` Attorney for Plaintiff
`
`
`
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`

`CERTIFICATE OF SERVICE
`
`Pursuant to Nevada Rules of Civil Procedure 5(b), the amendment to the Eighth Judicial
`District Court Rule 7.26, and N.E.F.C.R. 9, I hereby certify that service of the foregoing
`PLAINTIFF’S OPPOSITION TO PRIOR COUNSEL’S MOTION IN SUPPORT OF
`COURT’S AWARD OF ATTORNEY FEES & COSTS was made this date by electronic
`service via the Court’s electronic filing and service system, addressed to the following:
`
`Steven M. Burris, Esq.
`STEVEN M. BURRIS, LLC
`2810 W. Charleston Blvd., Suite F58
`Las Vegas, Nevada 89102
`Telephone: (702) 258-6238
`Facsimile: (702) 258-8280
`
`Michael J. Nunez, Esq.
`Murchison & Cumming LLP
`350 South Rampart Boulevard, Suite 320
`Las Vegas, Nevada 89145
`Attorney for Defendants,
`FedEx Ground Systems
`
`M. Bradley Johnson, Esq.
`Kravitz, Schnitzer & Johnson, CHTD.
`8985 S. Eastern Ave., Suite 200
`Las Vegas, Nevada 89123
`Attorneys for Defendant,
`Rafael Acevedo-Casillas
`
`Michael C. Mills, Esq.
`Bauman Loewe Witt & Maxwell
`3650 N. Rancho Dr., Suite114
`Las Vegas, Nevada 89130
`Attorneys for Defendant,
`GHG Corporation
`
`Stacey R. Cutting, Esq.
`Devin A. Cutting, Esq.
`Bish & Cutting, APC
`22505 Market Street, Suite 104
`Newhall, CA 91321-2935
`Previously Appearing Pro Hac Vice
`
`Mindy Susan Bish, Esq.
`Keenan Law Firm
`148 Nassau St. NW
`Atlanta, GA 30303
`Attorney for Plaintiffs Tamara Vasey
`and the Estate of Deland Sidney Vasey
`Previously Appearing Pro Hac Vice
`
`DATED this 22nd day of August, 2024.
`
`
`
`/s/Mary Chopski
`______________________________________
`An Employee of the Law Office of Travis E. Shetler
`
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`

`

`EXHIBIT 1
`EXHIBIT 1
`
`EXHIBIT 1
`EXHIBIT 1
`
`

`

`$16,533 IN CHARGES AFTER BURRIS WAS TERMINATED
`
`As previously ruled, all charges after the termination date of 9/25/2020
`cannot be billed to the client.
`
`The following pages claimed hours on the Burris lien after 9/25/2020.
`
`$16,533 must be subtracted from the Burris lien.
`
`

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