On June 17, 2021 a
Declaration Filed - Decl of atty Lena D. Wade iso Pltf's Appl for An Award of Atty's Fees
was filed
involving a dispute between
City Of Needles,
and
Countrywide Title Corporation,
Cusson, Lorraine L,
Does 1 Through 10,
Schmidt, William,
for Other Complaint (Not Spec) Unlimited
in the District Court of San Bernardino County.
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ORIGINAL v
JOHN O. PINKNEY, Bar No. 162586 EXEMPT FROM FILING FEES PURSUANT
LENA D. WADE, Bar N0. 258356 TO GOVERNMENT CODE SECTION 6103
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP SUPERIo
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g
‘25:
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u
COER’ OFCALR'O
COUNT5 OF.
74785 Highway 111, Suite 105 sAN Al . Rm
Indian Wells, CA 92210 BERNAEDEN‘EEEEWW
Telephone: (760) 322-9240
Ni; ‘
4 .20
'
\OmflfimAuND—t
Facsimile: (760) 565-1 189
Email: wade@sbemp.com
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LEANNE
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K
"x4“ E'Y"
Attorneys for Plaintiff CITY OF NEEDLES L .:.;=_ 1
(
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION
'II:i
LLP
Pinkney
105
CITY OF NEEDLES, a Charter City, Case No.2 CIVSB21 16939
Assigned for A11 Purposes t0: Ud
& Suite
92210
Plaintiff; Hon. Lynn Poncin
1,
Murphy
11 CA
Wells,
v. AH
Highway
Empey
LORRAINE L. CUSSON, a Joint Tenant; DECLARATION OF LENA D. WADE
WILLIAM SCHMIDT, a Joint Tenant;
Indian
Baron
74-785 IN SUPPORT OF PLAINTIFF’S
COUNTRYWIDE TITLE CORPORATION, APPLICATION FOR AN AWARD OF
XVd
Slovak Beneficiary; and DOES through 10, 1
ATTORNEY’S FEES
inclusive,
Warrant Issued June 22, 2021
NNNNNNNNNHHHHHHHHHH
Defendants‘
wQQUIhMNH©©QQQUIhMNHO
Date: December 16, 2021
Time: 9:00 a.m.
Dept: $28
I, LENA D. WADE, declare as follows:
1. I am an attorney licensed to practice law in the State 0f California and am Deputy
City Attorney for the City 0f Needles.
DECLARATION OF LENA D. WADE IN SUPPORT OF PLAINTIFF’S APPLICATION FOR AN AWARD OF
ATTORNEY’S FEES
2. I make this declaration in support 0f the City’s request for attorney’s fees,
paralegal fees, and court costs in this matter.
3. That our office employs associates, law clerks, paralegals and other support staff
who assist in the preparation of litigation documents.
wwflc‘xmkri—l
4. I charge my time, and other attorneys at Slovak Baron Empey Murphy & Pinkney
LLP, charge their time t0 the City of Needles at the rate 0f $226.00 per hour.
This firm has spent the following hours on this case.
m
5.
Name and Position Billable Rate Time to Date
Lena D. Wade 7.8 $226 $ 1,762.80
Zayra Botello 1.8 $140 $ 252.00
LLP
Donna Sanchez 2.1 $140 $ 294.00
Pinkney
105
& Suite 92210
Subtotal $ 2,308.80
Murphy 111,
CA
6. The invoices generated by our office detailing the time spent are attached as
Wells,
Exhibit “1”.
Highway
Empey
Indian
Baron
74-785
7. Additionally, I anticipate spending 2.0 hours ($452.00) attending the hearing on
Slovak
fees and following up with the City regarding a lien on the subject Property and my paralegal,
Zayra Botello, spending and additional 1.5 hours with filings and service of documents
”\l@UthNHO\DM\IO\UI&MNh-d©
NNNNNNNNNHHHHHHHHHH
($210.00). The Total Attorney’s fees are $2,970.80 ($2,308.80 + $452.00 + 210).
8. Costs, in the amount of $357.15, incurred by the firm in connection With this
matter are set forth in the invoices generated by our office which are attached as Exhibit “2”.
9. Based on the foregoing, the reasonable attomey’s fees and costs incurred in this
action are $3,327.95.
I declare under the penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and if called upon as a witness, I could and would competently
testify to the facts set forth herein, which facts are of my own personal knowledge.
2
DECLARATION OF LENA D. WADE TN SUPPORT OF PLAINTIFF’S APPLICATION FOR AN AWARD OF
ATTORNEY’S FEES
Document Filed Date
October 04, 2021
Case Filing Date
June 17, 2021
Category
Other Complaint (Not Spec) Unlimited
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ORIGINAL v JOHN O. PINKNEY, Bar No. 162586 EXEMPT FROM FILING FEES PURSUANT LENA D. WADE, Bar N0. 258356 TO GOVERNMENT CODE SECTION 6103 SLOVAK BARON EMPEY MURPHY & PINKNEY LLP SUPERIo h g ‘25: r u COER’ OFCALR'O COUNT5 OF. 74785 Highway 111, Suite 105 sAN Al . Rm Indian Wells, CA 92210 BERNAEDEN‘EEEEWW Telephone: (760) 322-9240 Ni; ‘ 4 .20 ' \OmflfimAuND—t Facsimile: (760) 565-1 189 Email: wade@sbemp.com mmgh LEANNE i mm; K "x4“ E'Y" Attorneys for Plaintiff CITY OF NEEDLES L .:.;=_ 1 ( SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION 'II:i LLP Pinkney 105 CITY OF NEEDLES, a Charter City, Case No.2 CIVSB21 16939 Assigned for A11 Purposes t0: Ud & Suite 92210 Plaintiff; Hon. Lynn Poncin 1, Murphy 11 CA Wells, v. AH Highway Empey LORRAINE L. CUSSON, a Joint Tenant; DECLARATION OF LENA D. WADE WILLIAM SCHMIDT, a Joint Tenant; Indian Baron 74-785 IN SUPPORT OF PLAINTIFF’S COUNTRYWIDE TITLE CORPORATION, APPLICATION FOR AN AWARD OF XVd Slovak Beneficiary; and DOES through 10, 1 ATTORNEY’S FEES inclusive, Warrant Issued June 22, 2021 NNNNNNNNNHHHHHHHHHH Defendants‘ wQQUIhMNH©©QQQUIhMNHO Date: December 16, 2021 Time: 9:00 a.m. Dept: $28 I, LENA D. WADE, declare as follows: 1. I am an attorney licensed to practice law in the State 0f California and am Deputy City Attorney for the City 0f Needles. DECLARATION OF LENA D. WADE IN SUPPORT OF PLAINTIFF’S APPLICATION FOR AN AWARD OF ATTORNEY’S FEES 2. I make this declaration in support 0f the City’s request for attorney’s fees, paralegal fees, and court costs in this matter. 3. That our office employs associates, law clerks, paralegals and other support staff who assist in the preparation of litigation documents. wwflc‘xmkri—l 4. I charge my time, and other attorneys at Slovak Baron Empey Murphy & Pinkney LLP, charge their time t0 the City of Needles at the rate 0f $226.00 per hour. This firm has spent the following hours on this case. m 5. Name and Position Billable Rate Time to Date Lena D. Wade 7.8 $226 $ 1,762.80 Zayra Botello 1.8 $140 $ 252.00 LLP Donna Sanchez 2.1 $140 $ 294.00 Pinkney 105 & Suite 92210 Subtotal $ 2,308.80 Murphy 111, CA 6. The invoices generated by our office detailing the time spent are attached as Wells, Exhibit “1”. Highway Empey Indian Baron 74-785 7. Additionally, I anticipate spending 2.0 hours ($452.00) attending the hearing on Slovak fees and following up with the City regarding a lien on the subject Property and my paralegal, Zayra Botello, spending and additional 1.5 hours with filings and service of documents ”\l@UthNHO\DM\IO\UI&MNh-d© NNNNNNNNNHHHHHHHHHH ($210.00). The Total Attorney’s fees are $2,970.80 ($2,308.80 + $452.00 + 210). 8. Costs, in the amount of $357.15, incurred by the firm in connection With this matter are set forth in the invoices generated by our office which are attached as Exhibit “2”. 9. Based on the foregoing, the reasonable attomey’s fees and costs incurred in this action are $3,327.95. I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct, and if called upon as a witness, I could and would competently testify to the facts set forth herein, which facts are of my own personal knowledge. 2 DECLARATION OF LENA D. WADE TN SUPPORT OF PLAINTIFF’S APPLICATION FOR AN AWARD OF ATTORNEY’S FEES