Motion-Secondary: NACE REYNOLDS VS. ROBIN AMELIA SHEEHAN ET AL

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                                1    Jacob Harker (State Bar No. 261262)
                  LAW OFFICES OF JACOB HARKER
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                  268 Bush St. #3732                                                                             ELECTRONICALLY
             3    San Francisco, CA 94104                                                                           F  I  L   E  D
                  Tel: (415) 624-7602                                                                            Superior Court of California,
             4                                                                                                    County of San Francisco
                  Fax: (415) 684-7757
             5    Email: jacob@harkercounsel.com                                                                     01/04/2022
                                                                                                                 Clerk of the Court
                                                                                                                   BY: SANDRA SCHIRO
             6                                                                                                                Deputy Clerk
                  Daniel L. Balsam (State Bar No. 260423)
             7    THE LAW OFFICES OF DANIEL BALSAM
                  2601C Blanding Avenue #271
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                  Alameda, CA 94501
             9    Tel: (415) 869-2873
                  Fax: (415) 869-2873
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                  Email: legal@danbalsam.com
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                  Attorneys for Plaintiff NACE REYNOLDS
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                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
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           15                    COUNTY OF SAN FRANCISCO (UNLIMITED JURISDICTION)
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                  NACE REYNOLDS;                                            ) Case No.:         CGC-21-594238
           17                                                               )                   Consolidated with
                                    Plaintiff,                              )                   CGC-21-594246
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                           v.                                               )
           19                                                               ) DECLARATION OF JACOB HARKER IN
                  ROBIN AMELIA SHEEHAN, et al;                              ) SUPPORT OF PLAINTIFF’S MOTION
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                                                                            ) FOR SANCTIONS AGAINST
           21                       Defendants.                             ) DEFENDANTS AND THEIR ATTORNEY
                                                                            ) ED SASAKI
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                                                                            )
           23     And Related Action                                        ) Date:             February 28, 2022
                                                                            ) Time:             9:30 am
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                                                                            ) Department:       302
           25                                                               ) Action Filed:     August 2, 2021
                                                                            ) Trial Date:       Not Set
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                  I, Jacob Harker, declare:
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                  1.    I am an attorney duly licensed to practice law in all courts of the State of California and an
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                        attorney of record for Plaintiff Nace Reynolds in Reynolds v. Sheehan (CGC-21-
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                        594238/594246) and for Tomi Mendez in Mendez v. Sheehan (CGC-21-594247).                           I make
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                                         HARKER DECL. ISO PLAINTIFF’S MOTION FOR SANCTIONS
             1          this Declaration based upon personal knowledge.             I could and would testify competently as
             2          to the matters contained in this Declaration.
             3    2.    In the fall of 2021, Defendants’ counsel Edwin Sasaki “inadvertently” sent me two emails.                     I
             4          cannot provide documentary evidence of these emails because I deleted them after replying
             5          to Sasaki to advise him of his mistakes.
             6    3.    I graduated from UCLA (BA), and U.C. Hastings (JD).                 I have been a member of the
             7          California State Bar in good standing since 2008.            Most of my practice is plaintiff-side
             8          multi-party consumer litigation.
             9    4.    My billing rate is $600 per hour.        I spent 7.8 hours reviewing Defendants’ Motions for
           10           Sanctions in the Reynolds and Mendez Actions, researching, and preparing Reynolds’ and
           11           Mendez’s Motions for Sanctions.          If Reynolds’ and Mendez’s Motions for Sanctions are
           12           filed, then I expect to spend at least 5.0 more hours reviewing the Oppositions, preparing
           13           Replies, and appearing at the hearings on Reynolds’ and Mendez’s Motions.
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           15     I declare under penalty of perjury under the laws of the State of California that the foregoing is
           16     true and correct.
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           18                                                           LAW OFFICES OF JACOB HARKER
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           20     Date:    December 3, 2021                             BY:
           21                                                                    JACOB HARKER
                                                                                 Attorneys for Plaintiff Nace Reynolds
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                                         HARKER DECL. ISO PLAINTIFF’S MOTION FOR SANCTIONS