On January 01, 1900 a
Motion-Secondary
was filed
involving a dispute between
Bagga, Surjit,
and
City National Bank,
Fresno Management Company, A California Corporation,
Hutchins, Ray,
Kruse, James,
for 26 Unlimited - Other Real Property
in the District Court of Fresno County.
Preview
I G. Andrew Slater, Esq.(SBN 238126)
DO\ilLING AARON INCORPORATED
2 8080 North Palm Avenue, Third Floor E-FILED
P.O. Box 28902 6/11/2018 8:34 AM
a
J Fresno, California 937 29 -8902 FRESNO COUNTY SUPERIOR COURT
Telephone: (559) 432-4500 By: R. Faccinto, Deputy
4 Facsimile: (559) 432-4590
aslater@dowlingaaron. com
5
Attomeys for Defendant
6 CITY NATIONAL BANK
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF FRESNO
9
10
SURJIT BAGGA, Case No. 16CECG03336
11
Plaintiff, DECLARATION OF MARK A. \ilALLER
t2 IN SUPPORT OF MOTION FOR ORDER
V IMPOSING MONETARY SANCTIONS
13 AND ISSUEN EVIDENCE, AND/OR
CITY NATIONAL BANK, FRESNO TERMINATING SANCTIONS AGAINST
14
MANAGEMENT COMPANY, a California PLAINTIFF SURJIT BAGGA AND HER
Corporation; Ray Hutchins, an individual; ATTORNEY OF RECORD
15 an individual; and DOES
Jamès Krause, 1-
100, inclusive, Date: July 19,2018
I6 Time: 3:30 p.m.
Defendants. Dept: 402
t7 Judge: Hon. Jeffrey Hamilton
18
19 I, Mark A. V/aller, declare:
20 l. I am an attorney at law duly admitted to practice before all the courts of
2t the State of California and I currently work for the law firm Dowling Aaron Incorporated, the
22 attorney of record for Defendant City National Bank ("CNB") in the above-described action.
23 This Declaration is submitted in support of CNB's Motion for Sanctions against Plaintiff Surjit
24 Bagga and her attorney of record. I have personal knowledge of the time spent preparing
25 CNB's Motion for Sanctions.
26 2. My law firm maintains comprehensive and accurate timekeeping
27 records. At or near the time of the service, the timekeeper makes a record of each service, the
28
ÞOWLINGIAARON
DECLARATION OF MARK A. WALLER IN SUPPORT OF MOTION FOR ORDER IMPOSING
MONETARY SANCTIONS AND ISSUE, EVID ENCE, AND/OR TERMTNATING SANCTIONS
AGAINST PLAINTIFF SURJIT BAGGA AND HER ATTORNEY OF RECORD
I time spent performing the service, and the amount charged for the service, which is then
2 entered into a central billing program maintained by the law firm and administered by
a
J employees in the firm's accounting department. By my own and firm policy, these entries are
4 typically made within twenty-four Q$ to forty-eight (48) hours after the service is provided,
5 and are routinely checked for accuracy. The entries are further reviewed in pre-bills on a
6 monthly basis for accuracy and reasonableness before they are presented as the monthly bill to
7 the client. The law firm relies on the accuracy of these records in maintaining its own files and
I records.
9 3. Iama first year litigation associate and have an hourly billable rate of
10 $185.00. I believe that this hourly rate is reasonable for associate attorneys of comparable
11 experience in this jurisdiction.
I2 4, I spent a total of 11.5 hours in drafting, reviewing, and revising the
13 Motion for Sanctions, the Declaration of G. Andrew Slater, the Memorandum of Points and
I4 Authorities, and this Declaration, resulting in a sum of $21127.50 incurred by CNB for the
15 Motion packet' s preparation.
T6 5. I declare under penalty of perjury in Fresno County, State of California
T7 that the foregoing is true and correct to the best of my knowledge.
18
I9
20 Dated: June7,2018
2T
22 By:
Mark A. Waller
23
24 014939-000004-0242975 |
6. doc-
25
26
27
28
2
"e;*.,::iî*hîie- DECLARATION OF MARK A. WALLER IN SUPPORT OF MOTION FOR ORDER IMPOSING
MONETARY SANCTIONS AND ISSUE, EVIDENCE, AND/OR TERMINATING SANCTIONS
AGAINST PLAINTIFF SURJIT BAGGA AND HER ATTORNEY OF RECORD
Document Filed Date
June 11, 2018
Case Filing Date
January 01, 1900
Category
26 Unlimited - Other Real Property
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
I G. Andrew Slater, Esq.(SBN 238126) DO\ilLING AARON INCORPORATED 2 8080 North Palm Avenue, Third Floor E-FILED P.O. Box 28902 6/11/2018 8:34 AM a J Fresno, California 937 29 -8902 FRESNO COUNTY SUPERIOR COURT Telephone: (559) 432-4500 By: R. Faccinto, Deputy 4 Facsimile: (559) 432-4590 aslater@dowlingaaron. com 5 Attomeys for Defendant 6 CITY NATIONAL BANK 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF FRESNO 9 10 SURJIT BAGGA, Case No. 16CECG03336 11 Plaintiff, DECLARATION OF MARK A. \ilALLER t2 IN SUPPORT OF MOTION FOR ORDER V IMPOSING MONETARY SANCTIONS 13 AND ISSUEN EVIDENCE, AND/OR CITY NATIONAL BANK, FRESNO TERMINATING SANCTIONS AGAINST 14 MANAGEMENT COMPANY, a California PLAINTIFF SURJIT BAGGA AND HER Corporation; Ray Hutchins, an individual; ATTORNEY OF RECORD 15 an individual; and DOES Jamès Krause, 1- 100, inclusive, Date: July 19,2018 I6 Time: 3:30 p.m. Defendants. Dept: 402 t7 Judge: Hon. Jeffrey Hamilton 18 19 I, Mark A. V/aller, declare: 20 l. I am an attorney at law duly admitted to practice before all the courts of 2t the State of California and I currently work for the law firm Dowling Aaron Incorporated, the 22 attorney of record for Defendant City National Bank ("CNB") in the above-described action. 23 This Declaration is submitted in support of CNB's Motion for Sanctions against Plaintiff Surjit 24 Bagga and her attorney of record. I have personal knowledge of the time spent preparing 25 CNB's Motion for Sanctions. 26 2. My law firm maintains comprehensive and accurate timekeeping 27 records. At or near the time of the service, the timekeeper makes a record of each service, the 28 ÞOWLINGIAARON DECLARATION OF MARK A. WALLER IN SUPPORT OF MOTION FOR ORDER IMPOSING MONETARY SANCTIONS AND ISSUE, EVID ENCE, AND/OR TERMTNATING SANCTIONS AGAINST PLAINTIFF SURJIT BAGGA AND HER ATTORNEY OF RECORD I time spent performing the service, and the amount charged for the service, which is then 2 entered into a central billing program maintained by the law firm and administered by a J employees in the firm's accounting department. By my own and firm policy, these entries are 4 typically made within twenty-four Q$ to forty-eight (48) hours after the service is provided, 5 and are routinely checked for accuracy. The entries are further reviewed in pre-bills on a 6 monthly basis for accuracy and reasonableness before they are presented as the monthly bill to 7 the client. The law firm relies on the accuracy of these records in maintaining its own files and I records. 9 3. Iama first year litigation associate and have an hourly billable rate of 10 $185.00. I believe that this hourly rate is reasonable for associate attorneys of comparable 11 experience in this jurisdiction. I2 4, I spent a total of 11.5 hours in drafting, reviewing, and revising the 13 Motion for Sanctions, the Declaration of G. Andrew Slater, the Memorandum of Points and I4 Authorities, and this Declaration, resulting in a sum of $21127.50 incurred by CNB for the 15 Motion packet' s preparation. T6 5. I declare under penalty of perjury in Fresno County, State of California T7 that the foregoing is true and correct to the best of my knowledge. 18 I9 20 Dated: June7,2018 2T 22 By: Mark A. Waller 23 24 014939-000004-0242975 | 6. doc- 25 26 27 28 2 "e;*.,::iî*hîie- DECLARATION OF MARK A. WALLER IN SUPPORT OF MOTION FOR ORDER IMPOSING MONETARY SANCTIONS AND ISSUE, EVIDENCE, AND/OR TERMINATING SANCTIONS AGAINST PLAINTIFF SURJIT BAGGA AND HER ATTORNEY OF RECORD