Case 1:05-cv-01121-DDD-CMH Document 403 Filed 05/11/10 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT

ALEXANDRIA, LOUISIANA

CITY OF ALEXANDRIA : CIVIL ACTION NO. No: 05-CV-1121-A

VERSUS : JUDGE DEE DRELL

CLEOCO CORPORATION, ET AL : MAGISTRATE C. MICHAEL HILL

MOTION TO SEGREGATE FUNDS

NOW comes Attorney Bridget Brown counsel, files this Motion to Segregate Funds,

respectfully represent that:

1.

Attorney Bridget Brown (Intervenor) asserts that the City Of Alexandria (Defendant) has

settled litigation with CLECO.

2.

Intervenor further avers that per her contract with the Defendant she is to receive ten

(10%) percent of the total settlement value of settlement amount.

3.

Intervenor further avers that the Defendant is negotiating payment of fees to consultants

and attorneys retained in said litigation.

4.

Intervenor further avers that city is contemplating a cash rebate to rate payers of City-

owned Utility out settlement funds between it and CLECO.

1
 Case 1:05-cv-01121-DDD-CMH Document 403 Filed 05/11/10 Page 2 of 3

5.

Intervenor further avers that her contract with Defendant grants her a special lien and

privileges on any amount recovered by Defendant in CLECO litigation.

6.

Intervenor further avers that Louisiana Revised Statute 37:218 and Rule 1.15 of the

Ethics Code grants her special lien and privileges.

7.

Intervenor further avers that the court issue an Order directing the Defendant to deposit

ten (10%) percent of any monies received by Defendant from the CLECO settlement in the

registry of the court until all matters involving her claim has been settled.

8.

Intervenor further avers that the court issue an Order directing the Defendant to deposit

ten (10%) percent of an future monies it receives from the CLECO settlement, within ten (10 )

days of its receipt, into the registry of the Court until all matters involving her claim has been

settled.

Wherefore, Intervenor prays that her Motion to Segregate Funds be granted.

RESPECTFULLY SUBMITTED BY:

/s/
LARRY ENGLISH
ENGLISH & ASSOCIATES, LLC
Louisiana Bar Roll #: 22772
415 Texas Street #320
Shreveport, Louisiana 71101
Telephone: (318) 222-1900
Facsimile: (318) 226-1660

2
 Case 1:05-cv-01121-DDD-CMH Document 403 Filed 05/11/10 Page 3 of 3

__________________________________
Thomas M. Flanagan, 19569
Harold J. Flanagan, 24091
Stephen M. Pesce, 29380
Sean P. Brady, 30410
FLANAGAN PARTNERS LLP
201 St. Charles Ave., Suite 2405
New Orleans, LA 70170
Telephone: (504) 569-0235
Facsimile: (504) 592-0251
Attorneys for Bridgett Brown, Intervenor

CERTIFICATE OF SERVICE

I hereby certify that copies of the above and foregoing pleading were filed electronically

with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to all

counsel of record by operation of the Court’s electronic filing system on this __11th__ day of

May, 2010.

/s/ Larry English

3
 Case 1:05-cv-01121-DDD-CMH Document 403-1 Filed 05/11/10 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT

ALEXANDRIA, LOUISIANA

CITY OF ALEXANDRIA : CIVIL ACTION NO. No: 05-CV-1121-A

VERSUS : JUDGE DEE DRELL

CLEOCO CORPORATION, ET AL : MAGISTRATE C. MICHAEL HILL

ORDER

Considering the foregoing Plaintiff’s Motion to Segregate Funds ORDERED,

ADJUDGED AND DECREED that this motion be and is hereby granted.

THIS DONE AND SIGNED, in chambers on this ______day of 2010,

at Alexandria, Rapides Parish, Louisiana.

HON.___________________________________
JUDGE