On March 04, 2015 a
Motion-Secondary
was filed
involving a dispute between
Diana P. Blum,
and
Palo Alto Foundation Medical Group, Inc.,
Palo Alto Medical Foundation,
Sutter Health,
for Wrongful Termination Unlimited(36)
in the District Court of Santa Clara County.
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MARCIE ISOM FITZSIMMONS (SBN: 226906)
HIEU T. WILLIAMS (SBN: 280585)
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: (415) 986-5900
Facsimile: (415) 986-8054
Misom@grsm.com.
HWilliams@grsm.com
Attol for Defendant
PALO ALTO FOUNDATION MEDICAL GROUP, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
DIANA P. BLUM, M.D., CASE NO. 115CV277582
Plaintiff, DECLARATION OF
HIEUT. WILLIAMS
sas INSUPPORT OF REPLY TO
DEFENDANT'S MOTION FOR
SUTTER HEALTH, a Califomia corporation; ATTORNEYS’ FEES AND COSTS
PALO ALTO FOUNDATION MEDICAL POST CCP § 998- OFFER TO
GROUP, INC., a Califomia corporation; COMPROMISE
PALO ALTO MEDICAL FOUNDATION, a
Califomia corporation; and DOES 1 through Acepmpar ving Doomrents:
Declaration of Marcie I. Fitzsimmons;
Defendants. Declaration of Meg Nai:
Declaration of Mai i- Kanivas
Hearing Date: April 24, 2018
ing Time: 1:30pm.
216
Honorable Judge Drew C. Takaichi
Trial Date: January 8, 2018
I Hiew T. Williams, declare:
Taman attomey at law licensed to practice before all courts
of the State of
Califomia and am a Senior Counsel in the law firm of Gordon Rees Scully Mansukhani, LLP,
attomeys for the defendant PALO ALTO FOUNDATION MEDICAL GROUP, INC. (“the
Physician Group”). I have personal knowledge of the matters contained in this declaration and if
called to testify to them could and would do so competently.
“1
DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF REPLY TO DEFENDANT’S
MOTION FOR ATTORNEYS’ FEES AND COSTS POST CCP § 998 - OFFER TO COMPROMISE
2. Attached hereto as ExhibitA is a true and correct copy of the “Services Recap”
page from my firm's billing invoice in the above entitled matter, dated October 7, 2016,
reflecting that my billing rate for this case was $235 per hour when I held the position of
“Associate.” This billing invoice reflects my maiden name “Minh Tran.”
3, Attached
hereto as Exhibit B is a true and correct copy of the “Services Recap”
page from my firm's billing invoice in the above entitled matter, dated November 7, 2016,
reflecting that my billing rate for this case changed from $235 to $275 per hour when I was
promoted to “Senior Counsel” in October 2016. The billing invoice reflects my married name
“Hieu Williams.”
10 4. In December 2016, I filed a declaration
in support of a motion
to compel in the
11 above entitled matter, wherein I erroneously declared that my billing rate for this case was $225
12 per houras
an “Associate.” This was a result of a typographical error and was incorrect. The
13 declaration should have stated that my billing rate was $275 per hour as “Senior Counsel.” At
14 the time I submitted that declaration
to the Court, the correct billing rate for my time for this case
15 was $275 per hour as “Senior Counsel.”
16 5, While litigating this case, I billed for traveling for court appearances and trial, to
17 meet with witnesses (physicians and clinical staff) at various PAMF locations throughout the
18 Bay Area to prepare for testimony in deposition and/or trial.
19 6. During
the trial in the above entitled matter, I accurately reported my time
20 worked, which included reporting the time I actually spent
at trial (i.e., from the time I arrived or
21 departed
the Courthouse). The time I billed fluctuated depending on the tasks I needed to
perform before or after trial for that day. Ms. Fitzsimmons and I did not always arrive and
depart from the Courthouse
at the same time.
24 I declare, under penalty of perjury under
the laws of the State of Califomia, the foregoing
25 is true and correct.
26 Executed on this 17th day of April 2018 at San Francisco, Califomia.
27
Drumaallianng
Hieu T. Williams
-2
DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF REPLY TO DEFENDANT’S
MOTION FOR ATTORNEYS’ FEES AND COSTS POST CCP § 998 - OFFER TO COMPROMISE
EXHIBIT A
Gataber 7, 2016
Invoice No.: 20384863
Services Recap
Init Name Title Rate Hours Amount
ASS Alexander Simonenko Technical Services and 115.00 1.00 115.00
Support
IRS Trene Rizzi Associate 235.00 1.10 258.50
MADI1 Melissa Diaz Paralegal ul 10.20 1,173.00
MHT4
MSI In om Pesinmens ssociate
Partner
235.00
275.00
52.60
54.50
10,687.00
13,605.00
Expenses
EXHIBIT B
Invoice No.: 20392434
Init Name Title Rate Hours Amount
MAD1 Melis i 115,00. 17.50 2,012.50
MHT4 ieu Williams 0 80.70 22,192.50
MSI Marcie Isom Fitzsimmons 275.00 33.30 9,157.50
TQ Tiara Quintana Law Clerk 115.00 12.90 1,483.50
Expenses
Document Filed Date
April 17, 2018
Case Filing Date
March 04, 2015
Category
Wrongful Termination Unlimited(36)
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MARCIE ISOM FITZSIMMONS (SBN: 226906) HIEU T. WILLIAMS (SBN: 280585) GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 San Francisco, CA 94111 Telephone: (415) 986-5900 Facsimile: (415) 986-8054 Misom@grsm.com. HWilliams@grsm.com Attol for Defendant PALO ALTO FOUNDATION MEDICAL GROUP, INC. SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA DIANA P. BLUM, M.D., CASE NO. 115CV277582 Plaintiff, DECLARATION OF HIEUT. WILLIAMS sas INSUPPORT OF REPLY TO DEFENDANT'S MOTION FOR SUTTER HEALTH, a Califomia corporation; ATTORNEYS’ FEES AND COSTS PALO ALTO FOUNDATION MEDICAL POST CCP § 998- OFFER TO GROUP, INC., a Califomia corporation; COMPROMISE PALO ALTO MEDICAL FOUNDATION, a Califomia corporation; and DOES 1 through Acepmpar ving Doomrents: Declaration of Marcie I. Fitzsimmons; Defendants. Declaration of Meg Nai: Declaration of Mai i- Kanivas Hearing Date: April 24, 2018 ing Time: 1:30pm. 216 Honorable Judge Drew C. Takaichi Trial Date: January 8, 2018 I Hiew T. Williams, declare: Taman attomey at law licensed to practice before all courts of the State of Califomia and am a Senior Counsel in the law firm of Gordon Rees Scully Mansukhani, LLP, attomeys for the defendant PALO ALTO FOUNDATION MEDICAL GROUP, INC. (“the Physician Group”). I have personal knowledge of the matters contained in this declaration and if called to testify to them could and would do so competently. “1 DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF REPLY TO DEFENDANT’S MOTION FOR ATTORNEYS’ FEES AND COSTS POST CCP § 998 - OFFER TO COMPROMISE 2. Attached hereto as ExhibitA is a true and correct copy of the “Services Recap” page from my firm's billing invoice in the above entitled matter, dated October 7, 2016, reflecting that my billing rate for this case was $235 per hour when I held the position of “Associate.” This billing invoice reflects my maiden name “Minh Tran.” 3, Attached hereto as Exhibit B is a true and correct copy of the “Services Recap” page from my firm's billing invoice in the above entitled matter, dated November 7, 2016, reflecting that my billing rate for this case changed from $235 to $275 per hour when I was promoted to “Senior Counsel” in October 2016. The billing invoice reflects my married name “Hieu Williams.” 10 4. In December 2016, I filed a declaration in support of a motion to compel in the 11 above entitled matter, wherein I erroneously declared that my billing rate for this case was $225 12 per houras an “Associate.” This was a result of a typographical error and was incorrect. The 13 declaration should have stated that my billing rate was $275 per hour as “Senior Counsel.” At 14 the time I submitted that declaration to the Court, the correct billing rate for my time for this case 15 was $275 per hour as “Senior Counsel.” 16 5, While litigating this case, I billed for traveling for court appearances and trial, to 17 meet with witnesses (physicians and clinical staff) at various PAMF locations throughout the 18 Bay Area to prepare for testimony in deposition and/or trial. 19 6. During the trial in the above entitled matter, I accurately reported my time 20 worked, which included reporting the time I actually spent at trial (i.e., from the time I arrived or 21 departed the Courthouse). The time I billed fluctuated depending on the tasks I needed to perform before or after trial for that day. Ms. Fitzsimmons and I did not always arrive and depart from the Courthouse at the same time. 24 I declare, under penalty of perjury under the laws of the State of Califomia, the foregoing 25 is true and correct. 26 Executed on this 17th day of April 2018 at San Francisco, Califomia. 27 Drumaallianng Hieu T. Williams -2 DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF REPLY TO DEFENDANT’S MOTION FOR ATTORNEYS’ FEES AND COSTS POST CCP § 998 - OFFER TO COMPROMISE EXHIBIT A Gataber 7, 2016 Invoice No.: 20384863 Services Recap Init Name Title Rate Hours Amount ASS Alexander Simonenko Technical Services and 115.00 1.00 115.00 Support IRS Trene Rizzi Associate 235.00 1.10 258.50 MADI1 Melissa Diaz Paralegal ul 10.20 1,173.00 MHT4 MSI In om Pesinmens ssociate Partner 235.00 275.00 52.60 54.50 10,687.00 13,605.00 Expenses EXHIBIT B Invoice No.: 20392434 Init Name Title Rate Hours Amount MAD1 Melis i 115,00. 17.50 2,012.50 MHT4 ieu Williams 0 80.70 22,192.50 MSI Marcie Isom Fitzsimmons 275.00 33.30 9,157.50 TQ Tiara Quintana Law Clerk 115.00 12.90 1,483.50 Expenses