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DOWNEY BRAND LLP
Christian L. Marsh (SBN 209442)
Arielle O. Harris (SBN 257792)
Natalie C. Kirkish (SBN 300101) ELECTRONICALLY
455 Market Street, Suite 1500 F I L E D
San Francisco, California 94105 Superior Court of California,
County of San Francisco
Telephone: (415) 848.4830
Facsimile: (415) 848.4801 08/01/2019
Email: cmarsh downevbrand.corn Clerk of the Court
BY: CAROL BALISTRERI
Deputy Clerk
Attorneys for Real Party in Interest
HANSON MARINE OPERATIONS, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
10 SAN FRANCISCO BAYKEEPER, INC., CASE NO. CPF-12-512620
Petitioner, DECLARATION OF CHRISTIAN L.
MARSH IN SUPPORT OF REAL PARTY
12 IN INTEREST'S OPPOSITION TO
BAYKEEPER'S MOTION TO STRIKE
13 CALIFORNIA STATE LANDS OR IN THE ALTERNATIVE TO TAX
COMMISSION, MEMORANDUM OF COSTS
14
Respondent, (Code of Civ. Proc., $ 1021.5)
15
HANSON MARINE OPERATIONS, Date: Wednesday, August 14, 2019
16 INC., Time: 10:00 a.m.
Dept.: 613
17 Real Party in Interest. Judge: Hon. Teri L. Jackson
18 Date Filed: November 16, 2012
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j566448.1 I
DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION
TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS
I, CHRISTIAN L. MARSH, declare as follows:
l. I am an attorney at law licensed to practice before the Courts of the State of
California, and a partner with Downey Brand LLP, and counsel of record for Real Party in
Interest Hanson Marine Operations, Inc. ("Hanson") in the above-captioned lawsuit.
2. I have personal knowledge of the matters set forth herein based on my work for
Hanson in this matter and, if called upon to testify thereto, could and would competently do so.
3. On January 31, 2017, the trial court emailed the parties to request a joint
compilation containing hard copies of the pages of the record that are cited in the parties'riefs
separated by: (1) documents cited in the return/moving papers and objection to return/opposition
10 to motion to discharge; and (2) pages cited in Baykeeper's reply that were not previously cited in
prior briefs. True and correct copies of those emails are attached hereto as Exhibit A.
12 4. My office offered to prepare the joint excerpts because I know Rom experience
13 that allowing one party to retain control would help reduce costs by reducing the number of
14 binders and reducing the potential for disparate or overlapping pages. Baykeeper's attorney
15 agreed to my offer and thanked us. True and correct copies of those emails are attached hereto
16 as Exhibit A.
17 5. Baykeeper never offered to prepare the required excerpts.
18 6. Baykeeper's attorney then offered to assist us in compiling the joint administrative
record citations by providing a list of the pages that Baykeeper cited to. I responded, informing
20 Baykeeper's attorney that we already had the pages cited from all briefs. Thus, Baykeeper's offer
21 to provide the record citations would not have saved any costs. The record citations were pulled
22 from the briefs by a secretary in my office, and those costs are not claimed in the memorandum
23 of costs.
24 7. On May 5, 2019, the Parties entered into a Stipulation to Extend Deadline to File
25 Motion for Attorneys'ees and Memorandum of Costs thus agreeing "that the deadline for any
26 Party to file a memorandum of costs or a motion for attorneys'ees is hereby extended to June 14,
27 2019"—The stipulation extended the deadline for Respondent or Real Parties'fforts to seek trial
28 court costs. A true and correct copy of that stipulation was filed with the court and is attached
n 66448
I 2
DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION
TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS
hereto as Exhibit B.
8. Under Rule of Court, Rule 3.300 there is mandatory duty to file and serve notice
of a related case "[w]henever a party in a civil action knows or learns that the action or
proceeding is related to another action or proceeding." This duty arose when Baykeeper filed a
meritless related case in San Francisco Superior Court Case No CPF-16-515281. This parallel
action filed by Baykeeper challenged the SLC's re-approval of the leases. My office complied
with this mandatory duty and filed a notice of related case and paid the first appearance fee in the
action. Baykeeper acknowledged this case was meritless when it stayed the proceedings and
subsequently dismissed the case without prejudice on its own accord. The notice of related case
10 required a first appearance fee of $ 450. That fee is stated on the register of actions for Case No
CPF-16-515281. A true and correct copy of the register of actions in the related case is attached
12 hereto as Exhibit C.
13 9. Hanson incurred and paid $ 469.90 in filing fees and vendor costs for filing the
14 notice of related case. This included a $ 450 first appearance fee in San Francisco Superior Court
15 Case No CPF-16-515281 and a $ 9.95 e-filing service fee. A true and correct copy of the invoice
16 is attached hereto as Exhibit D
17 10. Hanson incurred and paid $ 109.90 in filing fees and vendor filing and service costs
18 for filing the notice of lodging of the supplemental administrative record, the notice of lodging of
19 the joint excerpts of the administrative record, the reply memorandum in support of motion to
20 discharge peremptory writ of mandate, and the proposed order granting motion to discharge
21 preemptory writ of mandate. The invoices indicate that these costs were incurred on February 3,
22 7, and 17, of 2017. True and correct copies of the three invoices are attached hereto as Exhibit E.
23 11. Hanson incurred and paid $404.15 for the court reporter appearance fee and
24 $ 360.00 for the transcript for the February 15, 2017 hearing on the motion to discharge the writ of
25 mandate and the transcript of the hearing. These costs total $ 764.15. True and correct copies of
26 these invoices are attached hereto as Exhibit F.
27 12. It was necessary for my firm to retain a court reporter because one was not
28 provided by the court. On February 13, 2017, Erica Maharg, Baykeeper's managing attorney,
1M644i,l 3
DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION
TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS
email ed in my office to ask if anyone had retained a court reporter for the hearing, noting that the
department did not have one and that she would likely schedule one if no one had retained one
yet. Arielle Harris, an attorney at my firm, informed Ms. Maharg that we had already retained a
court reporter. Thus, there was a meeting of the minds amongst the parties that a court reporter
was necessary. A true and correct copy of this email exchange is attached hereto as Exhibit G.
13. Hanson incurred and paid $ 3,640.29 in preparing the joint compilation of the
pages of the record that were cited in the parties'rief. The first invoice dated February 6, 2018
is for $ 1,839.23 and shows that the vendor charged for 2,628 pages at 15 cents per page, 1,377
color copies at 85 cents per page, 81 index tabs at 35 cents per tab, 75 custom tabs at 75 cents per
10 tab, and 12 velo bindings at 3.50 per binding. The second invoice dated February 8, 2018 is for
$ 1,801.06 and shows that the vendor charged for 1,878 color copies at 85 cents per page, 96 index
12 tabs at 35 cents per tab, 21 custom tabs at 75 cents per tab, and 3 velo binds at 3.50 per binding
13 totaling $ 1,801.06. Combined these invoices add up to $ 3,640.29. True and correct copies of the
14 invoices are attached hereto as Exhibit H.
15 14. The two separate vendor invoices represent two bound excerpts requested by the
16 trial court, and were used by the trial court in the hearing on February 10, 2017.
17 15. Hanson incurred and paid $ 18,528.73 in vendor costs and staff costs to prepare the
18 supplemental administrative record and the excerpts of the record. True and correct copies of the
19 vendor invoices are attached hereto as Exhibit I.
20 16. It was necessary for my firm to utilize the assistance of paralegals and one attorney
21 highly knowledgeable in the case to prepare the administrative record. The attorney at my firm
22 who prepared the record had an intimate understanding of the SLC's approvals at issue, and
23 worked diligently to ensure that the record was complete, properly organized, adequately indexed,
24 and presented in a way that complied with the Rules of Court and allowed the proceedings to be
25 followed by the reviewing court.
26 17. The record in this case required significant hours to identify and review
27 documents for relevance and inclusion, transfer records to the appropriate format and database,
28 review and analyze search terms, de-duplicate extra'neous records, prepare the index, review the
u664481 4
DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION
TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS
record and index for completeness, identify and compile relevant record excerpts, undertake
quality control review, and create and ensure hyperlinking in compliance with the Rules of Court.
18. The memorandum of costs only seeks to recover costs for a portion of the time
expended on preparation of the record, and not time to conduct legal research or other non-
chargeable activities. My office made every effort to ensure that paralegals or non-billing staff
conducted the work where appropriate.
19. The possible record was not limited to the thousands of pages ultimately
included, but necessitated culling through multiple records from an intensive, four-year
permitting and regulatory process from October 2012 (the SLC's original approval) and June
10 2016 (re-approval), All of this time was necessary to ensure an accurate, complete, and properly
organized record for the parties and the Court.
12 20. The attorney and paralegals preparing the supplemental administrative records and
13 excerpts of record kept contemporaneous time records and the dates that these tasks were
14 performed are included in a revised table attached hereto as Exhibit J.
15 21. All of the costs that Hanson has claimed were actually incurred and necessary to
16 the defense of this action. A chart containing the dates that the costs were incurred is attached
17 hereto as Exhibit J.
18 I declare under penalty of perjury pursuant to the laws of the State of California that the
19 foregoing is nue and correct.
20 Executed August 1, 2019, at S
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CHRISTIAN L. MARSH
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a6644s.l 5
DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION
TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS
Exhibit A
Kirkish, Natalle
From: Erica Maharg &erica@baykeeper.org &
Sent: Tuesday, January 31, 2017 3:47 PM
To: Marsh, Christian
Cc: JoeiJacobs
Subject: Re: San Francisco Baykeeper v. Cai. SLC (CPF-12-512620) - hearing on return/motion
to discharge writ
Christian,
I think it makes sense to put together a joint excerpts of the record and a complete set of courtesy copies.
Thanks for offering to put that together. I can provide a list of the pages that Baykeeper cited to and that should
be in the excerpts.
Thanks, Erica
Erica Maharg
Managing Attorney
San Francisco Baykeeper
1736 Franklin St., Suite 800
Oakland, CA 94612
Office: 510-735-9700, x106
Fax: 510-735-9160
Protecting San Francisco Bay from pollution since f989
www.bavkeeper.ore
@sfbaykeeper
On Tue, Jan 31, 2017 at 3:34 PM, Marsh, Christian &cmarsh@downevbrand.corn& wrote:
Erica, we'l make February 15 work. Also, I need to note for the staff attorney that we have the electronic copy
of the original record (cited in the briefs) that we are the midst of re-lodging.
May I also suggest to the staff attorney, as we'e done before for Judge Jackson, that by February 7 we prepare
and lodge: (I) a complete set of "joint" excerpts to the record (original and supplemental); and (2) complete set
of courtesy copies of filed papers. Due to the overlap, I find this avoids duplication. Plus, Jackson very much
appreciated the joint excerpts last time.
My office is happy to put this all together, but would need a couple extra days.
Christian
DQWNEYBRANI3
Downey Brand LLP
455 Market Street, Suite 1500
San Francisco, CA 94105
415.848.4800 Main
415.848.4830 Direct
415.848.4831 Fax
cmarsh@downevbrand. corn
For an update on recent CEQA developments, please visit our blogr CEOA Chronicles
From: Erica Maharg [mailto:ericaCabavkeeoer.ore)
Sent: Tuesday, January 31, 2017 3:22 PM
To: Joel Jacobs
Cc: Marsh, Christian
Subject: Re: San Francisco Baykeeper v. Cal. SLC (CPF-12-512620) —
hearing on return/motion to discharge
writ
I just realized I actually do have a conflict on March 8.
Christian, would February 15 work for you?
—
Erica
Erica Maharg
Managing Attorney
San Francisco Baykeeper
1736 Franklin St., Suite 800
Oakland, CA 94612
Office: 510-735-9700. x106
Fax: 510-735-9160
Protecting San Francisco Bay from pollution since 1989
www.bavkeener.ora
8 s fbaykeeper
On Tue, Jan 31, 2017 at 2:55 PM, Erica Maharg &ericaCabavkeeoer.ore& wrote:
I am available on aII of the dates she suggested and, for me, the sooner the better.
Thanks, Erica
Erica Maharg
Managing Attorney
San Francisco Baykeeper
1736 Franklin St., Suite 800
Oakland, CA 94612
Office: 510-735-9700. x106
Fax: 510-735-9160
Protecting San Francisco Bay from pollution since 1989
www.bavkeeoer.ore
Is fbaykeeper
On Tue, Jan 31, 2017 at 2:50 PM, Joel Jacobs &Joel Jacobs Ndoi.ca.aov& wrote:
I have a conflict on 3/1, but the other dates are fine for me.
From: Elizabeth Kelber [mailto:EKelber@sftc.oral
Sent: Tuesday, January 31, 2017 2:49 PM
To: Joel Jacobs; 'cmarsh@downevbrand.corn',
'ericaObavkeeoer.ora'ubject:
San Francisco Baykeeper v, Cal. SLC (CPF-12-512620) - hearing on return/motion to discharge writ
Counsel,
The hearing on the return and motion to discharge the writ is currently scheduled for February 10, 2017. Hon.
Teri L. Jackson will be hearing this matter and her duties and calendars allow her limited availability, This is a
courtesy notice that the hearing will be continued.
Judge Jackson is available for a hearing on Wednesday, February 15, 2017 at 1:30p.m. Other available hearing
dates are February 22 and March 1, 8, 15 and 29, all at I:30p.m. Please confer amongst yourselves and when
you'e reached'n agreement let me know to which date the hearing should be moved. Any continuance does
not affect the briefing schedule.
Additionally, we are in possession of a disc containing the supplemental administrative record. The Court
requires the parties to submit a joint compilation containing hard copies of the pages of the record that are cited
in the parties'riefs as follows:
~ Compilation of pages cited in the return/moving papers and objection to return/opposition to motion to
discharge (if any were filed) are to be lodged in Department 503 no later than February 3, 2017 at 4:00p.m.
~ Compilation of pages cited in a reply (if any is filed) that were not previously cited in prior briefs, if any, are
to be lodged in Department 503 no later than February 7, 2017 at 2:00p.m.
Finally, we are in possession of courtesy copies of the Return and the Joint Motion to Discharge Peremptory
Writ. Those are the only papers we have received. If any other papers have been filed in relation to this hearing,
please make sure courtesy copies are promptly delivered to Department 503. (San Francisco Uniform Local
Rules of Court, Rule 2.7(B).)
Thank you,
Elizabeth Kelber
Staff Attorney
Asbestos /k CEQA Dept.
San Francisco Superior Court
ekelber@sftc.ore
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you.
Exhibit B
Erica A. Maharg (State Bar No. 279396)
M. Benjamin Eichenberg (State Bar No. 270893)
Nicole C. Sasaki (State Bar No. 298736)
SAN FRANCISCO BAYKEEPER, INC.
1736 Franklin Street, Suite 800
Oakland, California 94612
Telephone: (510) 735-9700
Facsimile: (510) 735-9160
Email: ericaibaykeeper.org
Email: ben@baykeeper.org
Email: nicole baykeeper.org
Attorneys for Petitioner
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SAN FRANCISCO
12 SAN FRANCISCO BAYKEEPER, INC., Case No. CPF-12-512620
Date Filed: November 16, 2012
13
Petitioner,
14 STIPULATION TO EXTEND
vs. DEADLINE TO FILE MOTION FOR
15 ATTORNEYS'EES AND
CALIFORNIA STATE LANDS MEMORANDUM OF COSTS
16 COMMISSION,
17
Respondents,
HANSON MARINE OPERATIONS, INC4
HANSON AGGREGATES, LLC; JERICO
PRODUCTS, INC., MORRIS TUG dc
20 BARGE, INC4 and SUISUN ASSOCIATES,
21
Real Parties in Interest.
22
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26
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CASE NO. CPF-12-512620
STIPULATION
The Parties to this action, by and through their respective counsel and as authorized by
California Rules of Court 3.1702(c) and 8.278, hereby stipulate that the deadline for any Party to
file a memorandum of costs or a motion for attorneys'ees is hereby extended to June 14, 2019.
Respectfully Submitted,
DATED: May l~, 2019
i SAN FRANCISCO BAYKEEPER
Erica A. Mahar
Attorney for Petitioner
10
11 DATED: May t, 2019 XAVIER BECERRA
12 Attorney General of California
DAVID ALDERSON
13 Supervising Deputy Attorney General
CALIFORNIA ATTORNEY GENERAL
14
15
16
JOEL JACOBS
17 Attorneys for Respondent
STATE LANDS COMMISSION
18
20
DATED: May7, 2019 DOWNlP BRAND LLP
21
22 ! r'!! g. ''! i xL=
23
CHRISTIAN MARSH
24 Attorneys for Real Party in Interest
HANSON MARINE OPERATIONS, INC.
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STIPULATION CASE NO. CPF-12-512620
PROOF OF SERVICE
2 I ain a resident of the State of California, over the age of eighteen years, and not a party to
the action. My business address is 1736 Franklin Street, Suite 800, Oakland, CA 94612.
3
On May 10, 2019, I served the following document(s), STIPULATION TO EXTEND
4 DEADLINE TO FILE MOTION FOR ATTORNEYS'EES AND MEMORANDUM OF
COSTS, on the following parties or attorney for parties, as shown below:
5
Joel Jacobs
Deputy Attorney General
Office of the Attorney General
1515 Clay Street, 20th Floor
Oakland, CA 94612-0550
Joel.JacobsSdoi.ca.gov
Christian L. Marsh
Arielle Harris
Downey Brand LLP
455 Market Street, Suite 1500
12 San Francisco, CA 94105
cmarsh(a downevbrand. corn
13
aharrisfa downevbrand. corn
14
X BY EMAIL: Per agreement between the parties, I caused each document to be sent by
15 email to the following persons or their representative listed above.
16 0 BY FACSIMILE: I caused each such document to be sent by facsimile to the
17
following persons or their representative listed above.
18 0 BY FIRST CLASS MAIL: I am readily familiar with this business's practice of
collecting and processing correspondence for mailing with the U.S. Postal Service. On the date
19 written above, following ordinary business practices, Idelivered to the U.S. Postal Service the
attached document in a sealed envelope, with postage fully prepaid, addressed as shown above.
20
21 I declare under the penalty of perjury that the foregoing is true and correct and that this
declaration was executed at Oakland, California on May 10, 2019
22
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g&E+
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STIPULATION, PROOF OF SERVICE CASE NO. CPF-12-512620
1114141.2
Exhibit C
7/31/201 9 Case Info
Conla ct Ua
THE SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Case Number: CPF1651 5281
Title: SAN FRANCISCO BAYKEEPER, INC. VS. CALIFORNIA STATE LANDS COMMISSION ETAL
Cause of Action: WRITS OF MANDATE OR PRON., CERT)., ETC./AD MIN. AGE N
Generated: 20194)7-31 11:28 em
Register of Actions Parties Attorneys Calendar Payments Documents
Please Note: The "View" document links on this web page sre valid untu 11:38i32 sm
After that, please refresh your web browser. (by pressing Command +R for Mac, preening F6 for Windows or cucking the refresh button on your web
browser)
Register of Actions
Show ~25 v entnes Search:
Date Proceedings Document
2019-01-15 ¹ 100041020) FILED BY
NOTICE OF ENTRY OF DISMISSAL AND PROOF OF SERVICE (TRANSACTION ID View
PETITIONER SAN FRANCISCO BAYKEEPER, INC.
201 9-1 2-1 9 CAUSES OF ACTION WITHOUT PREJUDICE
DISMSSAL OF ENTIRE ACTION OF ALL PARTIES ANIJ
ALL uew
¹ 100040299)
(TRANSACTION ID
201 7-08-1 5 ¹ 17226014) FILED BY PE7ITIONER SAN FRANCISCO SAYKEEPER, INC.
JOINT STATUS REPORT (TRANSACTION ID View
2017 08 15 ¹ 17226013) FILED BYPETITIONER SAN FRANCISCO BAYKEEPER,INC.
JOINT STATUS REPORT (TRANS/CTION ID View
2016-12-29 NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED TO STAY PROCEEDINGS
(STIPULATED) ((RAN SACTIQNI¹ew
ID¹10000831 6) FILED BY REAL PARTY IN INTEREST HAN SON M/IR INE OPERATIONS, INC.
2016-12-28 ORDER JINDSTIPULATIONTOSTAYPROCEEDINGS I¹ew
2015-12-21 FEE P/9 D ON; STIPULATION AND (PROPOSED] ORDER 70 STAY PROCEEDINGS ¹ 100007915)
(TRANSACTION ID $ EXEMPT
FILED BY RESPONDENT CALIFORNIA STATE LAND 3 COMMISSION
2016-1245 ¹ I 00007062) FILED BY REAL PARTY IN INTEREST HAN SON MARINE
NOTICE OF RELATED CASE (TRANSACTION ID I/iew $ 450.00
OPERATIONS, INC.
201 6-11-07 REQUEST TO PREPAFtE ADMINISTRATIVE RECORD (TRANSACTION ID ¹ 16311062) FILED BY PETITIONER SAN
View
FRANCISCO BAYKEEPER, INC.
2016-10-27 NollCE AND ACKNOWLEDGMENT OF RECEIPT, SIGNED OCT-25.2016, SERVED SEP-28-201 8 (TRANSACTION ID ¹
'clew
16300020) FILED BY PETITIONER SAN FRANCISCO BAYKEEPER, INC. AS TO RESPONDENT CALIFORNIA STATE
LANDS COM¹ISSION
2016-10-27 NOTICE AND ACKNOWLEDGMENT OCTM5-201 6 (TRANSACTION ID 9
OF RECEIPT, SIGNED OCT-1 2-2016, SERVED Iaew
I 6299051) FILED BY PETITIONER SAN FRANCISCO BAYKEEPER, INC. AS TQ REAL PARTY IN INTEREST HAN SON
MARINE OPERATIONS, INC
2016-09-28 CERTIFICATION FILED BY PETITIONER SAN FRANCISCO
PETITION FOR WRIT OF MANDATE/ PROHIBITION/ uew $ 450.00
BAYKEEPER, INC. AS TO RESPONDENT CALIFORNIA STATE LANDS COMMISSION DOES 1 TO 25 JUDICIAL
coU ROILCli)IL CASE COvER SHEET FILED
Showing enlriea
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Exhibit D
~NE LEGAL'04
Invoice
kwlktag 04S Sgg egg
Redwood Blvd. Date 12/8/2016
Suite 223
Novato CA 94947
415-4914606
TIN; 26-0259046 Invoice ¹ 10777389
t tr Due Date 1/22/2017
Downey Brand LLP
Accounting
621 Capitol Mall
18th Floor
Sacramento CA 95814-4686
Sales Order: 10715412
Firm Contact: Christian Marsh
Filer Name: Emilie Alcantara
Billing Code: 32606.00093
Case Number CPF-16-515281
Plaintiff: SAN FRANCISCO BAYKEEPER, INC. VS. CALIFORNIA STATE LANDS
Defendant:
Documents: Notice of Related Case
Court Branch: Superior Court of California, San Francisco County
Target:
Served:
Serve Info:
Item Amount
Court Filing Fee 450.00
e-Filing Service Fee 9.95
Convenience Fee 11.70
Convenience Fee Waived (11.70)
Total 5459.95
Statutory court fees and witness fees disbursed on your behalf sre
assessed e 2.6% convenience lee for processing end coliecling
these distwrsemenls. Tha convenience fee is waived If you elect Ihs Balance Due $ 459.95
ACH payment servrcs.
Exhibit E
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DOWNEY BRAND LLP Christian L. Marsh (SBN 209442) Arielle O. Harris (SBN 257792) Natalie C. Kirkish (SBN 300101) ELECTRONICALLY 455 Market Street, Suite 1500 F I L E D San Francisco, California 94105 Superior Court of California, County of San Francisco Telephone: (415) 848.4830 Facsimile: (415) 848.4801 08/01/2019 Email: cmarsh downevbrand.corn Clerk of the Court BY: CAROL BALISTRERI Deputy Clerk Attorneys for Real Party in Interest HANSON MARINE OPERATIONS, INC. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO 10 SAN FRANCISCO BAYKEEPER, INC., CASE NO. CPF-12-512620 Petitioner, DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY 12 IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE 13 CALIFORNIA STATE LANDS OR IN THE ALTERNATIVE TO TAX COMMISSION, MEMORANDUM OF COSTS 14 Respondent, (Code of Civ. Proc., $ 1021.5) 15 HANSON MARINE OPERATIONS, Date: Wednesday, August 14, 2019 16 INC., Time: 10:00 a.m. Dept.: 613 17 Real Party in Interest. Judge: Hon. Teri L. Jackson 18 Date Filed: November 16, 2012 19 20 21 22 23 24 25 26 27 28 j566448.1 I DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS I, CHRISTIAN L. MARSH, declare as follows: l. I am an attorney at law licensed to practice before the Courts of the State of California, and a partner with Downey Brand LLP, and counsel of record for Real Party in Interest Hanson Marine Operations, Inc. ("Hanson") in the above-captioned lawsuit. 2. I have personal knowledge of the matters set forth herein based on my work for Hanson in this matter and, if called upon to testify thereto, could and would competently do so. 3. On January 31, 2017, the trial court emailed the parties to request a joint compilation containing hard copies of the pages of the record that are cited in the parties'riefs separated by: (1) documents cited in the return/moving papers and objection to return/opposition 10 to motion to discharge; and (2) pages cited in Baykeeper's reply that were not previously cited in prior briefs. True and correct copies of those emails are attached hereto as Exhibit A. 12 4. My office offered to prepare the joint excerpts because I know Rom experience 13 that allowing one party to retain control would help reduce costs by reducing the number of 14 binders and reducing the potential for disparate or overlapping pages. Baykeeper's attorney 15 agreed to my offer and thanked us. True and correct copies of those emails are attached hereto 16 as Exhibit A. 17 5. Baykeeper never offered to prepare the required excerpts. 18 6. Baykeeper's attorney then offered to assist us in compiling the joint administrative record citations by providing a list of the pages that Baykeeper cited to. I responded, informing 20 Baykeeper's attorney that we already had the pages cited from all briefs. Thus, Baykeeper's offer 21 to provide the record citations would not have saved any costs. The record citations were pulled 22 from the briefs by a secretary in my office, and those costs are not claimed in the memorandum 23 of costs. 24 7. On May 5, 2019, the Parties entered into a Stipulation to Extend Deadline to File 25 Motion for Attorneys'ees and Memorandum of Costs thus agreeing "that the deadline for any 26 Party to file a memorandum of costs or a motion for attorneys'ees is hereby extended to June 14, 27 2019"—The stipulation extended the deadline for Respondent or Real Parties'fforts to seek trial 28 court costs. A true and correct copy of that stipulation was filed with the court and is attached n 66448 I 2 DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS hereto as Exhibit B. 8. Under Rule of Court, Rule 3.300 there is mandatory duty to file and serve notice of a related case "[w]henever a party in a civil action knows or learns that the action or proceeding is related to another action or proceeding." This duty arose when Baykeeper filed a meritless related case in San Francisco Superior Court Case No CPF-16-515281. This parallel action filed by Baykeeper challenged the SLC's re-approval of the leases. My office complied with this mandatory duty and filed a notice of related case and paid the first appearance fee in the action. Baykeeper acknowledged this case was meritless when it stayed the proceedings and subsequently dismissed the case without prejudice on its own accord. The notice of related case 10 required a first appearance fee of $ 450. That fee is stated on the register of actions for Case No CPF-16-515281. A true and correct copy of the register of actions in the related case is attached 12 hereto as Exhibit C. 13 9. Hanson incurred and paid $ 469.90 in filing fees and vendor costs for filing the 14 notice of related case. This included a $ 450 first appearance fee in San Francisco Superior Court 15 Case No CPF-16-515281 and a $ 9.95 e-filing service fee. A true and correct copy of the invoice 16 is attached hereto as Exhibit D 17 10. Hanson incurred and paid $ 109.90 in filing fees and vendor filing and service costs 18 for filing the notice of lodging of the supplemental administrative record, the notice of lodging of 19 the joint excerpts of the administrative record, the reply memorandum in support of motion to 20 discharge peremptory writ of mandate, and the proposed order granting motion to discharge 21 preemptory writ of mandate. The invoices indicate that these costs were incurred on February 3, 22 7, and 17, of 2017. True and correct copies of the three invoices are attached hereto as Exhibit E. 23 11. Hanson incurred and paid $404.15 for the court reporter appearance fee and 24 $ 360.00 for the transcript for the February 15, 2017 hearing on the motion to discharge the writ of 25 mandate and the transcript of the hearing. These costs total $ 764.15. True and correct copies of 26 these invoices are attached hereto as Exhibit F. 27 12. It was necessary for my firm to retain a court reporter because one was not 28 provided by the court. On February 13, 2017, Erica Maharg, Baykeeper's managing attorney, 1M644i,l 3 DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS email ed in my office to ask if anyone had retained a court reporter for the hearing, noting that the department did not have one and that she would likely schedule one if no one had retained one yet. Arielle Harris, an attorney at my firm, informed Ms. Maharg that we had already retained a court reporter. Thus, there was a meeting of the minds amongst the parties that a court reporter was necessary. A true and correct copy of this email exchange is attached hereto as Exhibit G. 13. Hanson incurred and paid $ 3,640.29 in preparing the joint compilation of the pages of the record that were cited in the parties'rief. The first invoice dated February 6, 2018 is for $ 1,839.23 and shows that the vendor charged for 2,628 pages at 15 cents per page, 1,377 color copies at 85 cents per page, 81 index tabs at 35 cents per tab, 75 custom tabs at 75 cents per 10 tab, and 12 velo bindings at 3.50 per binding. The second invoice dated February 8, 2018 is for $ 1,801.06 and shows that the vendor charged for 1,878 color copies at 85 cents per page, 96 index 12 tabs at 35 cents per tab, 21 custom tabs at 75 cents per tab, and 3 velo binds at 3.50 per binding 13 totaling $ 1,801.06. Combined these invoices add up to $ 3,640.29. True and correct copies of the 14 invoices are attached hereto as Exhibit H. 15 14. The two separate vendor invoices represent two bound excerpts requested by the 16 trial court, and were used by the trial court in the hearing on February 10, 2017. 17 15. Hanson incurred and paid $ 18,528.73 in vendor costs and staff costs to prepare the 18 supplemental administrative record and the excerpts of the record. True and correct copies of the 19 vendor invoices are attached hereto as Exhibit I. 20 16. It was necessary for my firm to utilize the assistance of paralegals and one attorney 21 highly knowledgeable in the case to prepare the administrative record. The attorney at my firm 22 who prepared the record had an intimate understanding of the SLC's approvals at issue, and 23 worked diligently to ensure that the record was complete, properly organized, adequately indexed, 24 and presented in a way that complied with the Rules of Court and allowed the proceedings to be 25 followed by the reviewing court. 26 17. The record in this case required significant hours to identify and review 27 documents for relevance and inclusion, transfer records to the appropriate format and database, 28 review and analyze search terms, de-duplicate extra'neous records, prepare the index, review the u664481 4 DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS record and index for completeness, identify and compile relevant record excerpts, undertake quality control review, and create and ensure hyperlinking in compliance with the Rules of Court. 18. The memorandum of costs only seeks to recover costs for a portion of the time expended on preparation of the record, and not time to conduct legal research or other non- chargeable activities. My office made every effort to ensure that paralegals or non-billing staff conducted the work where appropriate. 19. The possible record was not limited to the thousands of pages ultimately included, but necessitated culling through multiple records from an intensive, four-year permitting and regulatory process from October 2012 (the SLC's original approval) and June 10 2016 (re-approval), All of this time was necessary to ensure an accurate, complete, and properly organized record for the parties and the Court. 12 20. The attorney and paralegals preparing the supplemental administrative records and 13 excerpts of record kept contemporaneous time records and the dates that these tasks were 14 performed are included in a revised table attached hereto as Exhibit J. 15 21. All of the costs that Hanson has claimed were actually incurred and necessary to 16 the defense of this action. A chart containing the dates that the costs were incurred is attached 17 hereto as Exhibit J. 18 I declare under penalty of perjury pursuant to the laws of the State of California that the 19 foregoing is nue and correct. 20 Executed August 1, 2019, at S 21 22 CHRISTIAN L. MARSH 23 24 25 26 27 28 a6644s.l 5 DECLARATION OF CHRISTIAN L. MARSH IN SUPPORT OF REAL PARTY IN INTEREST'S OPPOSITION TO BAYKEEPER'S MOTION TO STRIKE OR IN THE ALTERNATIVE TO TAX MEMORANDUM OF COSTS Exhibit A Kirkish, Natalle From: Erica Maharg &erica@baykeeper.org & Sent: Tuesday, January 31, 2017 3:47 PM To: Marsh, Christian Cc: JoeiJacobs Subject: Re: San Francisco Baykeeper v. Cai. SLC (CPF-12-512620) - hearing on return/motion to discharge writ Christian, I think it makes sense to put together a joint excerpts of the record and a complete set of courtesy copies. Thanks for offering to put that together. I can provide a list of the pages that Baykeeper cited to and that should be in the excerpts. Thanks, Erica Erica Maharg Managing Attorney San Francisco Baykeeper 1736 Franklin St., Suite 800 Oakland, CA 94612 Office: 510-735-9700, x106 Fax: 510-735-9160 Protecting San Francisco Bay from pollution since f989 www.bavkeeper.ore @sfbaykeeper On Tue, Jan 31, 2017 at 3:34 PM, Marsh, Christian &cmarsh@downevbrand.corn& wrote: Erica, we'l make February 15 work. Also, I need to note for the staff attorney that we have the electronic copy of the original record (cited in the briefs) that we are the midst of re-lodging. May I also suggest to the staff attorney, as we'e done before for Judge Jackson, that by February 7 we prepare and lodge: (I) a complete set of "joint" excerpts to the record (original and supplemental); and (2) complete set of courtesy copies of filed papers. Due to the overlap, I find this avoids duplication. Plus, Jackson very much appreciated the joint excerpts last time. My office is happy to put this all together, but would need a couple extra days. Christian DQWNEYBRANI3 Downey Brand LLP 455 Market Street, Suite 1500 San Francisco, CA 94105 415.848.4800 Main 415.848.4830 Direct 415.848.4831 Fax cmarsh@downevbrand. corn For an update on recent CEQA developments, please visit our blogr CEOA Chronicles From: Erica Maharg [mailto:ericaCabavkeeoer.ore) Sent: Tuesday, January 31, 2017 3:22 PM To: Joel Jacobs Cc: Marsh, Christian Subject: Re: San Francisco Baykeeper v. Cal. SLC (CPF-12-512620) — hearing on return/motion to discharge writ I just realized I actually do have a conflict on March 8. Christian, would February 15 work for you? — Erica Erica Maharg Managing Attorney San Francisco Baykeeper 1736 Franklin St., Suite 800 Oakland, CA 94612 Office: 510-735-9700. x106 Fax: 510-735-9160 Protecting San Francisco Bay from pollution since 1989 www.bavkeener.ora 8 s fbaykeeper On Tue, Jan 31, 2017 at 2:55 PM, Erica Maharg &ericaCabavkeeoer.ore& wrote: I am available on aII of the dates she suggested and, for me, the sooner the better. Thanks, Erica Erica Maharg Managing Attorney San Francisco Baykeeper 1736 Franklin St., Suite 800 Oakland, CA 94612 Office: 510-735-9700. x106 Fax: 510-735-9160 Protecting San Francisco Bay from pollution since 1989 www.bavkeeoer.ore Is fbaykeeper On Tue, Jan 31, 2017 at 2:50 PM, Joel Jacobs &Joel Jacobs Ndoi.ca.aov& wrote: I have a conflict on 3/1, but the other dates are fine for me. From: Elizabeth Kelber [mailto:EKelber@sftc.oral Sent: Tuesday, January 31, 2017 2:49 PM To: Joel Jacobs; 'cmarsh@downevbrand.corn', 'ericaObavkeeoer.ora'ubject: San Francisco Baykeeper v, Cal. SLC (CPF-12-512620) - hearing on return/motion to discharge writ Counsel, The hearing on the return and motion to discharge the writ is currently scheduled for February 10, 2017. Hon. Teri L. Jackson will be hearing this matter and her duties and calendars allow her limited availability, This is a courtesy notice that the hearing will be continued. Judge Jackson is available for a hearing on Wednesday, February 15, 2017 at 1:30p.m. Other available hearing dates are February 22 and March 1, 8, 15 and 29, all at I:30p.m. Please confer amongst yourselves and when you'e reached'n agreement let me know to which date the hearing should be moved. Any continuance does not affect the briefing schedule. Additionally, we are in possession of a disc containing the supplemental administrative record. The Court requires the parties to submit a joint compilation containing hard copies of the pages of the record that are cited in the parties'riefs as follows: ~ Compilation of pages cited in the return/moving papers and objection to return/opposition to motion to discharge (if any were filed) are to be lodged in Department 503 no later than February 3, 2017 at 4:00p.m. ~ Compilation of pages cited in a reply (if any is filed) that were not previously cited in prior briefs, if any, are to be lodged in Department 503 no later than February 7, 2017 at 2:00p.m. Finally, we are in possession of courtesy copies of the Return and the Joint Motion to Discharge Peremptory Writ. Those are the only papers we have received. If any other papers have been filed in relation to this hearing, please make sure courtesy copies are promptly delivered to Department 503. (San Francisco Uniform Local Rules of Court, Rule 2.7(B).) Thank you, Elizabeth Kelber Staff Attorney Asbestos /k CEQA Dept. San Francisco Superior Court ekelber@sftc.ore CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. CONFIDENTIALITY NOTICE: This communication and any accompanying document(s) are confidential and privileged. They are intended for the sole use of the addressee. If you receive this transmission in error, you are advised that any disclosure, copying, distribution, or the taking of any action in reliance upon the communication is strictly prohibited.Moreover, any such inadvertent disclosure shall not compromise or waive the attorney-client privilege as to this communication or otherwise. If you have received this communication in error, please contact our IS Department at its Internet email address ( is(Rdownevbrand.corn), or by telephone at (9161444-1000 xS325. Thank you. Exhibit B Erica A. Maharg (State Bar No. 279396) M. Benjamin Eichenberg (State Bar No. 270893) Nicole C. Sasaki (State Bar No. 298736) SAN FRANCISCO BAYKEEPER, INC. 1736 Franklin Street, Suite 800 Oakland, California 94612 Telephone: (510) 735-9700 Facsimile: (510) 735-9160 Email: ericaibaykeeper.org Email: ben@baykeeper.org Email: nicole baykeeper.org Attorneys for Petitioner SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN FRANCISCO 12 SAN FRANCISCO BAYKEEPER, INC., Case No. CPF-12-512620 Date Filed: November 16, 2012 13 Petitioner, 14 STIPULATION TO EXTEND vs. DEADLINE TO FILE MOTION FOR 15 ATTORNEYS'EES AND CALIFORNIA STATE LANDS MEMORANDUM OF COSTS 16 COMMISSION, 17 Respondents, HANSON MARINE OPERATIONS, INC4 HANSON AGGREGATES, LLC; JERICO PRODUCTS, INC., MORRIS TUG dc 20 BARGE, INC4 and SUISUN ASSOCIATES, 21 Real Parties in Interest. 22 23 24 25 26 27 CASE NO. CPF-12-512620 STIPULATION The Parties to this action, by and through their respective counsel and as authorized by California Rules of Court 3.1702(c) and 8.278, hereby stipulate that the deadline for any Party to file a memorandum of costs or a motion for attorneys'ees is hereby extended to June 14, 2019. Respectfully Submitted, DATED: May l~, 2019 i SAN FRANCISCO BAYKEEPER Erica A. Mahar Attorney for Petitioner 10 11 DATED: May t, 2019 XAVIER BECERRA 12 Attorney General of California DAVID ALDERSON 13 Supervising Deputy Attorney General CALIFORNIA ATTORNEY GENERAL 14 15 16 JOEL JACOBS 17 Attorneys for Respondent STATE LANDS COMMISSION 18 20 DATED: May7, 2019 DOWNlP BRAND LLP 21 22 ! r'!! g. ''! i xL= 23 CHRISTIAN MARSH 24 Attorneys for Real Party in Interest HANSON MARINE OPERATIONS, INC. 25 26 27 28 STIPULATION CASE NO. CPF-12-512620 PROOF OF SERVICE 2 I ain a resident of the State of California, over the age of eighteen years, and not a party to the action. My business address is 1736 Franklin Street, Suite 800, Oakland, CA 94612. 3 On May 10, 2019, I served the following document(s), STIPULATION TO EXTEND 4 DEADLINE TO FILE MOTION FOR ATTORNEYS'EES AND MEMORANDUM OF COSTS, on the following parties or attorney for parties, as shown below: 5 Joel Jacobs Deputy Attorney General Office of the Attorney General 1515 Clay Street, 20th Floor Oakland, CA 94612-0550 Joel.JacobsSdoi.ca.gov Christian L. Marsh Arielle Harris Downey Brand LLP 455 Market Street, Suite 1500 12 San Francisco, CA 94105 cmarsh(a downevbrand. corn 13 aharrisfa downevbrand. corn 14 X BY EMAIL: Per agreement between the parties, I caused each document to be sent by 15 email to the following persons or their representative listed above. 16 0 BY FACSIMILE: I caused each such document to be sent by facsimile to the 17 following persons or their representative listed above. 18 0 BY FIRST CLASS MAIL: I am readily familiar with this business's practice of collecting and processing correspondence for mailing with the U.S. Postal Service. On the date 19 written above, following ordinary business practices, Idelivered to the U.S. Postal Service the attached document in a sealed envelope, with postage fully prepaid, addressed as shown above. 20 21 I declare under the penalty of perjury that the foregoing is true and correct and that this declaration was executed at Oakland, California on May 10, 2019 22 23 24 g&E+ 25 26 27 28 STIPULATION, PROOF OF SERVICE CASE NO. CPF-12-512620 1114141.2 Exhibit C 7/31/201 9 Case Info Conla ct Ua THE SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Case Number: CPF1651 5281 Title: SAN FRANCISCO BAYKEEPER, INC. VS. CALIFORNIA STATE LANDS COMMISSION ETAL Cause of Action: WRITS OF MANDATE OR PRON., CERT)., ETC./AD MIN. AGE N Generated: 20194)7-31 11:28 em Register of Actions Parties Attorneys Calendar Payments Documents Please Note: The "View" document links on this web page sre valid untu 11:38i32 sm After that, please refresh your web browser. (by pressing Command +R for Mac, preening F6 for Windows or cucking the refresh button on your web browser) Register of Actions Show ~25 v entnes Search: Date Proceedings Document 2019-01-15 ¹ 100041020) FILED BY NOTICE OF ENTRY OF DISMISSAL AND PROOF OF SERVICE (TRANSACTION ID View PETITIONER SAN FRANCISCO BAYKEEPER, INC. 201 9-1 2-1 9 CAUSES OF ACTION WITHOUT PREJUDICE DISMSSAL OF ENTIRE ACTION OF ALL PARTIES ANIJ ALL uew ¹ 100040299) (TRANSACTION ID 201 7-08-1 5 ¹ 17226014) FILED BY PE7ITIONER SAN FRANCISCO SAYKEEPER, INC. JOINT STATUS REPORT (TRANSACTION ID View 2017 08 15 ¹ 17226013) FILED BYPETITIONER SAN FRANCISCO BAYKEEPER,INC. JOINT STATUS REPORT (TRANS/CTION ID View 2016-12-29 NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED TO STAY PROCEEDINGS (STIPULATED) ((RAN SACTIQNI¹ew ID¹10000831 6) FILED BY REAL PARTY IN INTEREST HAN SON M/IR INE OPERATIONS, INC. 2016-12-28 ORDER JINDSTIPULATIONTOSTAYPROCEEDINGS I¹ew 2015-12-21 FEE P/9 D ON; STIPULATION AND (PROPOSED] ORDER 70 STAY PROCEEDINGS ¹ 100007915) (TRANSACTION ID $ EXEMPT FILED BY RESPONDENT CALIFORNIA STATE LAND 3 COMMISSION 2016-1245 ¹ I 00007062) FILED BY REAL PARTY IN INTEREST HAN SON MARINE NOTICE OF RELATED CASE (TRANSACTION ID I/iew $ 450.00 OPERATIONS, INC. 201 6-11-07 REQUEST TO PREPAFtE ADMINISTRATIVE RECORD (TRANSACTION ID ¹ 16311062) FILED BY PETITIONER SAN View FRANCISCO BAYKEEPER, INC. 2016-10-27 NollCE AND ACKNOWLEDGMENT OF RECEIPT, SIGNED OCT-25.2016, SERVED SEP-28-201 8 (TRANSACTION ID ¹ 'clew 16300020) FILED BY PETITIONER SAN FRANCISCO BAYKEEPER, INC. AS TO RESPONDENT CALIFORNIA STATE LANDS COM¹ISSION 2016-10-27 NOTICE AND ACKNOWLEDGMENT OCTM5-201 6 (TRANSACTION ID 9 OF RECEIPT, SIGNED OCT-1 2-2016, SERVED Iaew I 6299051) FILED BY PETITIONER SAN FRANCISCO BAYKEEPER, INC. AS TQ REAL PARTY IN INTEREST HAN SON MARINE OPERATIONS, INC 2016-09-28 CERTIFICATION FILED BY PETITIONER SAN FRANCISCO PETITION FOR WRIT OF MANDATE/ PROHIBITION/ uew $ 450.00 BAYKEEPER, INC. AS TO RESPONDENT CALIFORNIA STATE LANDS COMMISSION DOES 1 TO 25 JUDICIAL coU ROILCli)IL CASE COvER SHEET FILED Showing enlriea I to 12 of 12 Preuoue I Nen httPs://sebaPPs.sftc.or 9/ci/Caselnfo.dl(7C aseNurn= 6 PF 1651 5281 &Session)D =CD E7EF 821 BED796CTABA92BE( EESECSCC 78697A5 Exhibit D ~NE LEGAL'04 Invoice kwlktag 04S Sgg egg Redwood Blvd. Date 12/8/2016 Suite 223 Novato CA 94947 415-4914606 TIN; 26-0259046 Invoice ¹ 10777389 t tr Due Date 1/22/2017 Downey Brand LLP Accounting 621 Capitol Mall 18th Floor Sacramento CA 95814-4686 Sales Order: 10715412 Firm Contact: Christian Marsh Filer Name: Emilie Alcantara Billing Code: 32606.00093 Case Number CPF-16-515281 Plaintiff: SAN FRANCISCO BAYKEEPER, INC. VS. CALIFORNIA STATE LANDS Defendant: Documents: Notice of Related Case Court Branch: Superior Court of California, San Francisco County Target: Served: Serve Info: Item Amount Court Filing Fee 450.00 e-Filing Service Fee 9.95 Convenience Fee 11.70 Convenience Fee Waived (11.70) Total 5459.95 Statutory court fees and witness fees disbursed on your behalf sre assessed e 2.6% convenience lee for processing end coliecling these distwrsemenls. Tha convenience fee is waived If you elect Ihs Balance Due $ 459.95 ACH payment servrcs. 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