On April 22, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Baird, Candy W,
Baird, Jason R,
and
Does 1 Through 10,
Hyundai Motor America,
Rusnak Corporation,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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ELECTRONICALLY FILED
O'CONNOR LAW GROUP, P.C. SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Mark O'Connor, Esq. (SBN 157680) SAN BERNARDINO DISTRICT
Shawna M. Melton, Esq. (SBN 276989)
384 Forest AV6., Suite 17 10/27/2023 7:12 PM
Laguna Beach, CA 92651 By: Leslie Zepeda, DEPUTY
Tel: (949) 494-9090 Fax: (949) 494-9913
|
KOOONQUILUJNr—t
Email: hello@teamolg.com
Attorneys for Plaintiffs: JASON R. BAIRD and
CANDY W. BAIRD
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER
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JASON R. BAIRD and CANDY W. Case N0. CIVSB2208297
BAIRD, Unlimited Jurisdiction
Plaintiffs, DECLARATION 0F LARRY s.
CASTRUITA 1N SUPPORT 0F
VS. PLAINTIFFS' MOTION FOR
ATTORNEY FEES PURSUANT T0
HYUNDAI MOTOR AMERICA, a CIVIL CODE §1794(d)
California Corporation; RUSNAK
CORPORATION, a California [Filed concurrently with: Notice ofMotion
Corporation, d/b/a HYUNDAI INLAND and Motion; Memorandum ofPoim‘s and
EMPIRE; and DOES 1 through 10, Authorities; Declarations ofM O’Connor, S.
NNNNNNNNNh—r—Hr—Hh—kr—Ah—r—AH
inclusive, Melton, D. Castruita, M Goethals, D.
Womack, K. Arndt; Compendium ofExhibits
Defendants. 1—20;and [Proposed] Order and Judgment]
OONONMJ>WNHOKOOONONMJ>WNHO
Hearing Date: December 6, 2023
Hearing Time: 8:30 a.m.
Assigned t0 the Hon. Wilfred J. Schneider, Jr.,
Dept. S32
Date Filed: April 22, 2022
Trial Date: None
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Baird v. Hyundai - DECLARATION OF LARRY S. CASTRUITA IN SUPPORT OF
PLAINTIFFS' MOTION FOR ATTORNEY FEES
DECLARATION OF LARRY S. CASTRUITA
I, LARRY S. CASTRUITA, declare as follows:
1. I am an attorney at law duly licensed t0 practice before the courts 0f the State 0f
California. Iwas a senior associate at O'Connor Law Group, P.C. ("OLG"), counsel 0f record for
KOOONQUILUJNr—t
Plaintiffs JASON R. BAIRD and CANDY W. BAIRD ("Plaintiffs") in the instant action.
2. I am familiar with the files, papers, records, and documents maintained by my
office in the regular course of business in connection With this matter. I submit this declaration in
support of Plaintiffs' Motion for Attorney Fees, Costs, and Expenses. I have personal knowledge
0f the following facts and, if sworn as a Witness, I could and would testify to them competently.
3. I was employed by OLG from August 2019 to September 2023. I have been a
member of the California bar and actively practicing law since June 201 1. I graduated With honors
from Southwestern Law School. I have conducted trials in almost all counties and districts across
California in State and Federal Court. I hold one of the top three jury verdicts in California from
2019 for consumer protection cases. I currently specialize as a trial attorney in consumer law,
business law, copyright law, and contract law.
4. OLG's regular practice is t0 complete all time billing entries contemporaneously
With each dated entry, and to accurately set forth the actual time expended for the matters indicated.
NNNNNNNNNh—r—Hr—Hh—kr—Ah—r—AH
Furthermore, it is the firm's and my regular practice to bill in 1/10 hour increments together with
the date and description of the work performed. I follow this regular billing practice. I personally
OONONMJ>WNHOKOOONONMJ>WNHO
reviewed my billing entries in this lawsuit t0 ensure that they accurately reflect the time expended.
5. My rate at the time of my billing entries for this case was $550/hour, which has
been approved by multiple state and federal Courts in the State 0f California, as more fully set
forth in the Declaration of Mark O'Connor.
6. This rate is reasonable for an attorney of my experience in this particular area of
law and is consistent With hourly rates that I am familiar with in this area of law.
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Baird v. Hyundai - DECLARATION OF LARRY S. CASTRUITA IN SUPPORT OF
PLAINTIFFS' MOTION FOR ATTORNEY FEES
Document Filed Date
October 27, 2023
Case Filing Date
April 22, 2022
Category
Breach of Contract/Warranty Unlimited
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ELECTRONICALLY FILED O'CONNOR LAW GROUP, P.C. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO Mark O'Connor, Esq. (SBN 157680) SAN BERNARDINO DISTRICT Shawna M. Melton, Esq. (SBN 276989) 384 Forest AV6., Suite 17 10/27/2023 7:12 PM Laguna Beach, CA 92651 By: Leslie Zepeda, DEPUTY Tel: (949) 494-9090 Fax: (949) 494-9913 | KOOONQUILUJNr—t Email: hello@teamolg.com Attorneys for Plaintiffs: JASON R. BAIRD and CANDY W. BAIRD SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER - JASON R. BAIRD and CANDY W. Case N0. CIVSB2208297 BAIRD, Unlimited Jurisdiction Plaintiffs, DECLARATION 0F LARRY s. CASTRUITA 1N SUPPORT 0F VS. PLAINTIFFS' MOTION FOR ATTORNEY FEES PURSUANT T0 HYUNDAI MOTOR AMERICA, a CIVIL CODE §1794(d) California Corporation; RUSNAK CORPORATION, a California [Filed concurrently with: Notice ofMotion Corporation, d/b/a HYUNDAI INLAND and Motion; Memorandum ofPoim‘s and EMPIRE; and DOES 1 through 10, Authorities; Declarations ofM O’Connor, S. NNNNNNNNNh—r—Hr—Hh—kr—Ah—r—AH inclusive, Melton, D. Castruita, M Goethals, D. Womack, K. Arndt; Compendium ofExhibits Defendants. 1—20;and [Proposed] Order and Judgment] OONONMJ>WNHOKOOONONMJ>WNHO Hearing Date: December 6, 2023 Hearing Time: 8:30 a.m. Assigned t0 the Hon. Wilfred J. Schneider, Jr., Dept. S32 Date Filed: April 22, 2022 Trial Date: None /// /// /// /// -0- Baird v. Hyundai - DECLARATION OF LARRY S. CASTRUITA IN SUPPORT OF PLAINTIFFS' MOTION FOR ATTORNEY FEES DECLARATION OF LARRY S. CASTRUITA I, LARRY S. CASTRUITA, declare as follows: 1. I am an attorney at law duly licensed t0 practice before the courts 0f the State 0f California. Iwas a senior associate at O'Connor Law Group, P.C. ("OLG"), counsel 0f record for KOOONQUILUJNr—t Plaintiffs JASON R. BAIRD and CANDY W. BAIRD ("Plaintiffs") in the instant action. 2. I am familiar with the files, papers, records, and documents maintained by my office in the regular course of business in connection With this matter. I submit this declaration in support of Plaintiffs' Motion for Attorney Fees, Costs, and Expenses. I have personal knowledge 0f the following facts and, if sworn as a Witness, I could and would testify to them competently. 3. I was employed by OLG from August 2019 to September 2023. I have been a member of the California bar and actively practicing law since June 201 1. I graduated With honors from Southwestern Law School. I have conducted trials in almost all counties and districts across California in State and Federal Court. I hold one of the top three jury verdicts in California from 2019 for consumer protection cases. I currently specialize as a trial attorney in consumer law, business law, copyright law, and contract law. 4. OLG's regular practice is t0 complete all time billing entries contemporaneously With each dated entry, and to accurately set forth the actual time expended for the matters indicated. NNNNNNNNNh—r—Hr—Hh—kr—Ah—r—AH Furthermore, it is the firm's and my regular practice to bill in 1/10 hour increments together with the date and description of the work performed. I follow this regular billing practice. I personally OONONMJ>WNHOKOOONONMJ>WNHO reviewed my billing entries in this lawsuit t0 ensure that they accurately reflect the time expended. 5. My rate at the time of my billing entries for this case was $550/hour, which has been approved by multiple state and federal Courts in the State 0f California, as more fully set forth in the Declaration of Mark O'Connor. 6. This rate is reasonable for an attorney of my experience in this particular area of law and is consistent With hourly rates that I am familiar with in this area of law. /// /// /// -1- Baird v. Hyundai - DECLARATION OF LARRY S. CASTRUITA IN SUPPORT OF PLAINTIFFS' MOTION FOR ATTORNEY FEES