On June 30, 2010 a
Motion-Secondary
was filed
involving a dispute between
Arata, Thomas,
Leake, Joseph,
Owyang, Rich,
Pecot, Johna,
Taylor, Oscar,
Tilton, Stephen,
and
Does 1-100,
Does 1 To 100,
Mcdaniels, Shedrick,
San Francisco Deputy Sheriff'S Association,
San Francisco Deputy Sheriff'S Association, A,
San Francisco Deputy Sheriff'S Foundation,
Savage, Brian,
Wong, David,
Zehner, Michael,
for civil
in the District Court of San Francisco County.
Preview
LAW OFFICES OF PAUL L. KRANZ
PAUL L. KRANZ, FSQ., SBN 114999
2 | 499 14® Sireet, Suite 300
Oakland, CA 94612
7 - ELECTRONICALLY
3 | kranzlaw@sbeglobal net
| an FILED
| Telephone: (510) 839-1200 ee Court of Caitfornia,
| Facsimile: ($10) 444-6698 ‘ounty of San Francisco
07/13/2015
| Attomeys for Plaintiffs Johna Pecot, ef al. Cler or ue Court
Deputy Clerk
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOHNA PECOT, ef al. , Individually and on CASE NO, CGC-10-S01168
15 || Behalf of All Others Similarly Situated,
DECLARATION OF PAUL L. KRANZ IN
16 Plaintiffs. SUPPORT OF PLAINTIFFS’ MOTION
FOR ATTORNEY’S FEES
17 ve
18 || SAN FRANCISCO DEPUTY SHERIFF'S
ASSOCIATION, a California Nonprofit
19 || Corporation, et al.
Date: August 4, 2015
Time: 9:30 a.m.
Dept.: 302
20 Defendants.
21
22 1, Paul L. Kranz, declare:
23 1. Tam an attorney at law duly licensed to practice before all the courts of the State of
24 || California, I know the following facts of my own knowledge and could and would testify to
25 || them in a court of law if called upon to do so. Tam attorney of record for the Plaintiffs in this
26 |) matter.
27 2. Tum a graduate of Boalt Hall of the University of C ‘alifornia, Berkeley. While at Boalt
28 |] Hall, L was in a joint degree program with Health and Medical Sciences Program in the Graduate
cle
DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES
C RlsersupsiarsDewsiosde ion dec sity teas 2wpdhool of the University California and have a master’s degree in Health and Medical Sciences.
3. [have been an attorney since 1984 and have been involved in civil litigation for more
| than 25 years.
4. In 1999, I was nominated for a MacArthur Foundation “Genius Grant”.
5. My civil litigation experience is varied and extensive, and includes the following cases
and experience.
6. I was a trial counsel in Patricia Shugart v. OFA, Inc., Solano County Superior Court
| Case No. L-11697, on behalf of a plaintiff who lost an eye while employed by a private
manufacturer producing ejector seat mechanisms for United States Navy aircraft. After a
seven week trial, the jury awarded plaintiff $3.85 million in compensatory damages and $10
million in punitive damages. | understand that was the largest punitive damage award on behalf
| of a single plaintiff in the Solano County Superior Court.
7. Iwasa counsel in Karen Wise v. OFA, Inc., et al., the Solano County Superior Court
No. L-11591, on behalf of a woman employed by a temporary employment agency to work on an
assembly line at an explosives factory, who lost most of the fingers on her dominant hand in an
explosion there. The case settled on the eve of trial for $5.5 million.
8. Iwas counsel in Kristi Blakey v. Gateway Apartments, Alameda County Superior
Court Case No. 775419-5. [represented a woman who was sexually assaulted upon returning
home to the apartment complex where she lived. The perpetrator was never apprehended or
identified. The sexual assault infected the plaintiff with the HIV virus. That case settled on the
eve of trial of $2.5 million.
9. Twas co-counsel in the case Enkbaatar Tsedendorj v. Yeviushenko, et al., San
Francisco Superior Court No. CGC-06-453-286, the Honorable William McBride presiding.
| Plaintiff was an undocumented immigrant who was injured while doing construction work. A
|| jury awarded him $1.8 million dollars.
10. I was counsel in Dove Klein, et al. v. Shelter, Inc_et al., Alameda County Superior
Court Case No. 824497-2. I represented four homeless, mentally disabled young adults, abused
|, and exploited emotionally, physically and financially by a person house manager of a residential
iH ’y.
DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES
if doc tty Fens DergCrUsesuptareiouncadsl
|| facility where they lived. The manager was a twice-convicted pedophile. ‘The settled on the eve
of trial for $2.5 million.
11. Twas counsel in the first private anti-trust action against Microsoft, Inc. Terms of the
settlement preclude me from disclosing any further information about that case.
12. Iwas counsel in Joel Adelson, M.D., Ph.D. v. St. Barnabus Medical Center, Superior
| Court of New Jersey, Law Division-Essex County, Docket No.. L-1197-00, for which I was
|| admitted pro hae vie. I represented the former Chief of Medicine of the Children’s Hospital of
I New Jersey in a wrongful termination and whistle blower action against the St. Barabas Health
| Care System, of which the Children’s Hospital of New Jersey is a component. The St. Barnabas
Health Care System was the largest private employer in the State of New Jersey at that time, The
case settled during jury selection for approximately one million dollars.
13. Lam a member of the Governing Committee of the Alameda County Lawyer Referral
Service. Among the responsibilities of the Governing Committee is to review, evaluate and
|| approve attomey applicants to the panel, and to also review the services and performances by the
}) panel.
14. Based on the Lafferty Matrix, the market rate for an attorney with my years of
experience is $425.00.
15. Based on the foregoing. [ believe that a reasonable hourly market rate for my time is
|) at least $400.
16. As of July 13, 2015, [have personally devoted 32.1 hours of time on Defendants’
| Second Motion to Strike Claims in (First) Amended Complaint. Attached hereto as Exhibit A is a
true and accurate record of my hours devoted to the motion. I compiled Exhibit A by (1) review
| my handwritten time records and taking from those time records the time devoted to this motion.
Ihave also personally checked that Exhibit A is accurate and that time spent on other matters was
excluded. The total amount requested to date for my work in connection with Defendants
Second Motion to Strike Claims in (First) Amended Complaint is $ $12,840.
I declare under penalty of perjury of the laws of the State of California that the foregoing
is true and correct and that this declaration was executed at Oakland, California on July 13,
; 3
DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES
na Gee atty fees 2upe‘| 2015. Puc ( Leo
Paul L. Kranz
4.
DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES
CotSeetuestersbownt ec ay Fees BudEXHIBIT A09/17/14
IVS 4
i/l4
L194
124
1214
1 2214
11/22/14
11 24/14
Pecot vy. Wong Time: Motion to Strike Second Amended Complaint
Task
Review defendants’ aity letter re
Rule 11 and 128.7 motion; research
FRCP 11 and ease and CCP 128.7
Review motion to strike + exhibits
Work on letter to defendants’ atty; review
file re: 1" SLAP motion, motion for
judgment on the pleadings. motion for
new trial, court orders
Continue work for letter to
defendants’ atty; research CCP 1008,
CCP 425.16 60 day notice; review
amended complaint
Draft, edit letter to defendants’ atty
Research for opposition to motion to
strike: research 30 day calendaring.
CCP 425.16 sanctions, CCP 128.5,
CCP 1008 sanctions
Review file for language and quotes
from: 1° SLAPP motion; defendants”
motion for judgment on the pleadings;
motion for new trial, court rulings;
identifying exhibits to use from
previous motions
Research re amending complaint after
SLAPP, California noticed pleading
issue
Begin drafting opposition
Edit, finalize memo and declaration
apehitorre:Onenicads\Pecct Tere on Motion to Sika Sacer Avvendeg ComciantDateTaskTime wed
Time (hours)
Ll
1.0
LlQA
12/18/14
2/18/14
2/20/14
224/14
01/06/15
O7/09F15
OT/I2/15
Task
Review, research re defendants”
Reply memo
Prepare for hearing
Prepare for hearing
Appearance at hearing. including
travel to/from court
Review defendants’ attorney's e-mail
with proposed orders
Draft proposed orders and letter to
defendants’ atty
Draft letter to court re proposed
orders with orders
Research CCP 128.5, CCP 425.6 re
motion for sanctions; begin drafting
memo and declaration for sanctions
motion
Continue drafting. edit motion memo
and declaration for sanctions motion
Finalize, edit motion for sanctions
bo
opetttoms'Doonscers\Pecdt Tine on Motion te Sithe Second Amended CompisinDatsTeskTine wpe
Time (hours)
0.7
Preview
LAW OFFICES OF PAUL L. KRANZ PAUL L. KRANZ, FSQ., SBN 114999 2 | 499 14® Sireet, Suite 300 Oakland, CA 94612 7 - ELECTRONICALLY 3 | kranzlaw@sbeglobal net | an FILED | Telephone: (510) 839-1200 ee Court of Caitfornia, | Facsimile: ($10) 444-6698 ‘ounty of San Francisco 07/13/2015 | Attomeys for Plaintiffs Johna Pecot, ef al. Cler or ue Court Deputy Clerk SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JOHNA PECOT, ef al. , Individually and on CASE NO, CGC-10-S01168 15 || Behalf of All Others Similarly Situated, DECLARATION OF PAUL L. KRANZ IN 16 Plaintiffs. SUPPORT OF PLAINTIFFS’ MOTION FOR ATTORNEY’S FEES 17 ve 18 || SAN FRANCISCO DEPUTY SHERIFF'S ASSOCIATION, a California Nonprofit 19 || Corporation, et al. Date: August 4, 2015 Time: 9:30 a.m. Dept.: 302 20 Defendants. 21 22 1, Paul L. Kranz, declare: 23 1. Tam an attorney at law duly licensed to practice before all the courts of the State of 24 || California, I know the following facts of my own knowledge and could and would testify to 25 || them in a court of law if called upon to do so. Tam attorney of record for the Plaintiffs in this 26 |) matter. 27 2. Tum a graduate of Boalt Hall of the University of C ‘alifornia, Berkeley. While at Boalt 28 |] Hall, L was in a joint degree program with Health and Medical Sciences Program in the Graduate cle DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES C RlsersupsiarsDewsiosde ion dec sity teas 2wpdhool of the University California and have a master’s degree in Health and Medical Sciences. 3. [have been an attorney since 1984 and have been involved in civil litigation for more | than 25 years. 4. In 1999, I was nominated for a MacArthur Foundation “Genius Grant”. 5. My civil litigation experience is varied and extensive, and includes the following cases and experience. 6. I was a trial counsel in Patricia Shugart v. OFA, Inc., Solano County Superior Court | Case No. L-11697, on behalf of a plaintiff who lost an eye while employed by a private manufacturer producing ejector seat mechanisms for United States Navy aircraft. After a seven week trial, the jury awarded plaintiff $3.85 million in compensatory damages and $10 million in punitive damages. | understand that was the largest punitive damage award on behalf | of a single plaintiff in the Solano County Superior Court. 7. Iwasa counsel in Karen Wise v. OFA, Inc., et al., the Solano County Superior Court No. L-11591, on behalf of a woman employed by a temporary employment agency to work on an assembly line at an explosives factory, who lost most of the fingers on her dominant hand in an explosion there. The case settled on the eve of trial for $5.5 million. 8. Iwas counsel in Kristi Blakey v. Gateway Apartments, Alameda County Superior Court Case No. 775419-5. [represented a woman who was sexually assaulted upon returning home to the apartment complex where she lived. The perpetrator was never apprehended or identified. The sexual assault infected the plaintiff with the HIV virus. That case settled on the eve of trial of $2.5 million. 9. Twas co-counsel in the case Enkbaatar Tsedendorj v. Yeviushenko, et al., San Francisco Superior Court No. CGC-06-453-286, the Honorable William McBride presiding. | Plaintiff was an undocumented immigrant who was injured while doing construction work. A || jury awarded him $1.8 million dollars. 10. I was counsel in Dove Klein, et al. v. Shelter, Inc_et al., Alameda County Superior Court Case No. 824497-2. I represented four homeless, mentally disabled young adults, abused |, and exploited emotionally, physically and financially by a person house manager of a residential iH ’y. DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES if doc tty Fens DergCrUsesuptareiouncadsl || facility where they lived. The manager was a twice-convicted pedophile. ‘The settled on the eve of trial for $2.5 million. 11. Twas counsel in the first private anti-trust action against Microsoft, Inc. Terms of the settlement preclude me from disclosing any further information about that case. 12. Iwas counsel in Joel Adelson, M.D., Ph.D. v. St. Barnabus Medical Center, Superior | Court of New Jersey, Law Division-Essex County, Docket No.. L-1197-00, for which I was || admitted pro hae vie. I represented the former Chief of Medicine of the Children’s Hospital of I New Jersey in a wrongful termination and whistle blower action against the St. Barabas Health | Care System, of which the Children’s Hospital of New Jersey is a component. The St. Barnabas Health Care System was the largest private employer in the State of New Jersey at that time, The case settled during jury selection for approximately one million dollars. 13. Lam a member of the Governing Committee of the Alameda County Lawyer Referral Service. Among the responsibilities of the Governing Committee is to review, evaluate and || approve attomey applicants to the panel, and to also review the services and performances by the }) panel. 14. Based on the Lafferty Matrix, the market rate for an attorney with my years of experience is $425.00. 15. Based on the foregoing. [ believe that a reasonable hourly market rate for my time is |) at least $400. 16. As of July 13, 2015, [have personally devoted 32.1 hours of time on Defendants’ | Second Motion to Strike Claims in (First) Amended Complaint. Attached hereto as Exhibit A is a true and accurate record of my hours devoted to the motion. I compiled Exhibit A by (1) review | my handwritten time records and taking from those time records the time devoted to this motion. Ihave also personally checked that Exhibit A is accurate and that time spent on other matters was excluded. The total amount requested to date for my work in connection with Defendants Second Motion to Strike Claims in (First) Amended Complaint is $ $12,840. I declare under penalty of perjury of the laws of the State of California that the foregoing is true and correct and that this declaration was executed at Oakland, California on July 13, ; 3 DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES na Gee atty fees 2upe‘| 2015. Puc ( Leo Paul L. Kranz 4. DECLARATION IN SUPPORT OF MOTION FOR ATTORNEY'S FEES CotSeetuestersbownt ec ay Fees BudEXHIBIT A09/17/14 IVS 4 i/l4 L194 124 1214 1 2214 11/22/14 11 24/14 Pecot vy. Wong Time: Motion to Strike Second Amended Complaint Task Review defendants’ aity letter re Rule 11 and 128.7 motion; research FRCP 11 and ease and CCP 128.7 Review motion to strike + exhibits Work on letter to defendants’ atty; review file re: 1" SLAP motion, motion for judgment on the pleadings. motion for new trial, court orders Continue work for letter to defendants’ atty; research CCP 1008, CCP 425.16 60 day notice; review amended complaint Draft, edit letter to defendants’ atty Research for opposition to motion to strike: research 30 day calendaring. CCP 425.16 sanctions, CCP 128.5, CCP 1008 sanctions Review file for language and quotes from: 1° SLAPP motion; defendants” motion for judgment on the pleadings; motion for new trial, court rulings; identifying exhibits to use from previous motions Research re amending complaint after SLAPP, California noticed pleading issue Begin drafting opposition Edit, finalize memo and declaration apehitorre:Onenicads\Pecct Tere on Motion to Sika Sacer Avvendeg ComciantDateTaskTime wed Time (hours) Ll 1.0 LlQA 12/18/14 2/18/14 2/20/14 224/14 01/06/15 O7/09F15 OT/I2/15 Task Review, research re defendants” Reply memo Prepare for hearing Prepare for hearing Appearance at hearing. including travel to/from court Review defendants’ attorney's e-mail with proposed orders Draft proposed orders and letter to defendants’ atty Draft letter to court re proposed orders with orders Research CCP 128.5, CCP 425.6 re motion for sanctions; begin drafting memo and declaration for sanctions motion Continue drafting. edit motion memo and declaration for sanctions motion Finalize, edit motion for sanctions bo opetttoms'Doonscers\Pecdt Tine on Motion te Sithe Second Amended CompisinDatsTeskTine wpe Time (hours) 0.7