Hearing: RAMESH SHRESTHA VS. HOTEL SUNRISE, INC. ET AL

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                                McNAMARA, NEY, BEATTY, SLATTERY, BORGES & AMBACHER LLP
ATTORNEYS AT LAW

3480 BUSKIRK AVENUE, SUITE 250, PLEASANT HILL, CA 94523

TELEPHONE: (925) 939-5330

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LUANNE RUTHERFORD (State Bar No. 153336)
luanne.rutherford@menamaralaw.com
MCNAMARA, NEY, BEATTY, SLATTERY,

BorGEs & AMBACHER LLP ELECTRONICALLY
3480 Buskirk Avenue, Suite 250 FILED
Pleasant Hill, CA 94523 Superior Court of California,
Telephone: (925) 939-5330 County of San Francisco
Facsimile: (925) 939-0203 11/16/2018
Clerk of the Court
Attorneys for Defendants BY: VANESSA WU
HOTEL SUNRISE, INC.; KIRITKUMAR PATEL and Dende errr

SHAKUNTLA PATEL

SUPERIOR COURT OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO
CIVIL - UNLIMITED JURISDICTION

RAMESH SHRESTHA aka RAY Case No. CGC-16-553387 [CONSOLIDATED
SHRESTHA, an individual, W/CGC-18-566014]
Plaintiff, NOTICE OF MOTION FOR ATTORNEY
FEES
vs.
Date: December 18, 2018
HOTEL SUNRISE, INC., et al., Time: 9:30 a.m.
Dept: 501
Defendants.

Trial Date: 2/11/2019

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

NOTICE IS HEREBY GIVEN that on December 18, 2018, at 9:30 a.m., or as soon
thereafter as the matter may be heard in Department 501 of the above-entitled Court, located at
400 McAllister Street, San Francisco, California, Defendants Hotel Sunrise, LLC and Ketan
Patel, will move this Court for an award of attorney fees totaling $152,581.60 against Plaintiff
Ramesh Shrestha.

This motion is made based on: (1) defendants Hotel Sunrise, LLC and Ketan Patel, having
prevailed on all causes of action; (2) the operative pleadings that contain a claim for attorney fees
pursuant to California Civil Code section 1942.5 and (3) the attorney fees defendants incurred in
defending this action are reasonable and fully recoverable.

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NOTICE OF MOTION FOR ATTORNEY FEES<
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TELEPHONE: (925) 939-5330

This Motion is be based upon this Notice, the attached Memorandum of Points and
Authorities, the Declaration of Luanne Rutherford, papers, documents and records filed in support

thereof, and upon any oral and documentary evidence to be produced at the time of the hearing.

Dated: November 15, 2018 MCNAMARA, NEY, BEATTY, SLATTERY,
BORGES & AMBACHER LLP

uafne Rutherford
Attorneys for Defendants
HOTEL SUNRISE, INC.; KIRITKUMAR PATEL and
SHAKUNTLA PATEL

KAFRM\I786 - Shrestha v. Hotel Sunrise\Motions\Motion for Atty Fees\Notice.docx

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NOTICE OF MOTION FOR ATTORNEY FEESMcNAMARA,

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TELEPHONE: (925) 939-5330

3480 BUSKIRK AVENUE, SUITE 250.

CERTIFICATE OF E-SERVICE VIA FILE & SERVEXPRESS

Shrestha v. Hotel Sunrise, Inc.
San Francisco County Superior Court, Case No. CGC-16-553387

I hereby declare that 1 am a citizen of the United States, am over the age of eighteen years,
and not a party to the within action. My electronic notification address is:
Jaura.selling@menamaralaw.com.

On this date, I electronically served the foregoing document NOTICE OF MOTION
FOR ATTORNEY FEES as required by the Court’s Order Authorizing Electronic Service in
this matter, and as performed by File & ServeXpress on the parties in this action, addressed as
follows:

SEE SERVICE LIST PROVIDED BY FILE & SERVEXPRESS

The transmission was reported as complete and without error. A copy of the File &
ServeXpress filing receipt will be maintained with the document in our file.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on November 16, 2018 at

Pleasant Hill, California.

Masa AAA

Laura Selling