On October 04, 2017 a
Party Discovery
was filed
involving a dispute between
Taghavi, Ali,
and
Alticor, Inc., A Michigan Corporation,
Does 1-10, Inclusive,
The Leland Stanford Junior University, A California Nonprofit Corporation,
for (36) Unlimited Wrongful Termination
in the District Court of San Mateo County.
Preview
wr Fredrick A. Hagen, California Bar No. 196220
Kyle Z. Pineo, California Bar No. 317320
BERDING & WEIL LLP
FILED
2175 N. California Blvd, Suite 500 SAN MATEO COUNTY
Walnut Creek, California 94596
Telephone: 925-838-2090
, - OCTAT 2018
Facsimile: 925-820-5592 or Gourt exe
fhagen@berdingweil.com
kpineo@berdingweil.com
LM
Attorneys for Plaintiff
ALI TAGHAVI
1.
“7-clv—04670
Hs
Destaraton in Support SUPERIOR COURT OF THE STATE OF CALIFORNIA
l|
1432448
| vn
a ll IN AND FOR THE COUNTY OF SAN MATEO
11 ALI TAGHAVI, an individual, No. 17CIV04570
12 Plaintiff, DECLARATION OF KYLE Z. PINEO IN
SUPPORT OF PLAINTIFF’S MOTION
13 vs. TO COMPEL STANFORD’S FURTHER
RESPONSE TO REQUEST FOR
14 THE LELAND STANFORD JUNIOR DOCUMENTS, SETS ONE AND TWO
UNIVERSITY, a California nonprofit
15 corporation, doing business as STANFORD Date: November J, 2018
UNIVERSITY; ALTICOR, INC., a Michigan Time: 9:00 a.m.
16 corporation; and DOES 1-10, inclusive, Dept.: Law and Motion=
17 Defendants.
Complaint Filed: October 4, 3017
18 Trial Date: December 17. 2018
19
20 I, Kyle Z. Pineo, declare as follows:
21 1 Iam an attorney at law duly licensed to practice law-in the State of California and
22 am an associate with the law firm of Berding & Weil LLP, attorneys of record for Plaintiff Ali
23 Taghavi (“Plaintiff”). I make this declaration in support of Plaintiffs motion for an order
24 compelling Defendant Trustees of the Leland Stanford Junior University (“Stanford”) to provide
25 further responses to plaintiff's requests for production of documents, sets one and two.
26 2. I have worked nearly 21 hours on the instant motion which includes researching
27 the statutes and caselaw on motions to compel further responses and drafting the motion
28 documents. Assuming an additional two hours to attend the hearing on this matter, I anticipate
-1-
BERDING
RISC & WEIL LLP DECLARATION OF KYLE Z. PINEO IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL STANFORD’S
wi c miSe
FURTHER RESPONSE TO REQUEST FOR DOCUMENTS, SETS ONE AND TWO
= N
a
working a total of 23 hours on the motion. At my rate of $275 per hour, a standard rate for
associates in my field, the total attorneys’ fees for this motion would be $6,325.
I declare under penalty of perjury under the laws of the state of California that the
foregoing is true and correct, and that this declaration was executed in Walnut Creek, California
on October 11, 2018. y
Kyle Z. Pineo
9
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BERDINC ‘WEILte LLP DECLARATION OF KYLE Z. PINEO IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL STANFORD’S
dnaNara
eek clfonin 0
98396
FURTHER RESPONSE TO REQUEST FOR DOCUMENTS, SETS ONE AND TWO
Document Filed Date
October 11, 2018
Case Filing Date
October 04, 2017
Category
(36) Unlimited Wrongful Termination
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wr Fredrick A. Hagen, California Bar No. 196220 Kyle Z. Pineo, California Bar No. 317320 BERDING & WEIL LLP FILED 2175 N. California Blvd, Suite 500 SAN MATEO COUNTY Walnut Creek, California 94596 Telephone: 925-838-2090 , - OCTAT 2018 Facsimile: 925-820-5592 or Gourt exe fhagen@berdingweil.com kpineo@berdingweil.com LM Attorneys for Plaintiff ALI TAGHAVI 1. “7-clv—04670 Hs Destaraton in Support SUPERIOR COURT OF THE STATE OF CALIFORNIA l| 1432448 | vn a ll IN AND FOR THE COUNTY OF SAN MATEO 11 ALI TAGHAVI, an individual, No. 17CIV04570 12 Plaintiff, DECLARATION OF KYLE Z. PINEO IN SUPPORT OF PLAINTIFF’S MOTION 13 vs. TO COMPEL STANFORD’S FURTHER RESPONSE TO REQUEST FOR 14 THE LELAND STANFORD JUNIOR DOCUMENTS, SETS ONE AND TWO UNIVERSITY, a California nonprofit 15 corporation, doing business as STANFORD Date: November J, 2018 UNIVERSITY; ALTICOR, INC., a Michigan Time: 9:00 a.m. 16 corporation; and DOES 1-10, inclusive, Dept.: Law and Motion= 17 Defendants. Complaint Filed: October 4, 3017 18 Trial Date: December 17. 2018 19 20 I, Kyle Z. Pineo, declare as follows: 21 1 Iam an attorney at law duly licensed to practice law-in the State of California and 22 am an associate with the law firm of Berding & Weil LLP, attorneys of record for Plaintiff Ali 23 Taghavi (“Plaintiff”). I make this declaration in support of Plaintiffs motion for an order 24 compelling Defendant Trustees of the Leland Stanford Junior University (“Stanford”) to provide 25 further responses to plaintiff's requests for production of documents, sets one and two. 26 2. I have worked nearly 21 hours on the instant motion which includes researching 27 the statutes and caselaw on motions to compel further responses and drafting the motion 28 documents. Assuming an additional two hours to attend the hearing on this matter, I anticipate -1- BERDING RISC & WEIL LLP DECLARATION OF KYLE Z. PINEO IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL STANFORD’S wi c miSe FURTHER RESPONSE TO REQUEST FOR DOCUMENTS, SETS ONE AND TWO = N a working a total of 23 hours on the motion. At my rate of $275 per hour, a standard rate for associates in my field, the total attorneys’ fees for this motion would be $6,325. I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct, and that this declaration was executed in Walnut Creek, California on October 11, 2018. y Kyle Z. Pineo 9 10 11 X:\wdoes\8236\9 1\PLD\00961674.DOCX. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- BERDINC ‘WEILte LLP DECLARATION OF KYLE Z. PINEO IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL STANFORD’S dnaNara eek clfonin 0 98396 FURTHER RESPONSE TO REQUEST FOR DOCUMENTS, SETS ONE AND TWO