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1 RAFFI KHATCHADOURIAN, ESQ. (SBN 193165)
HEMAR, ROUSSO & HEALD, LLP
2 15910 Ventura Blvd., 12th Floor
Encino, California 91436
3 Telephone: (818) 501-3800
Facsimile: (818) 501-2985
E-FILED
11/30/2018 4:06 PM
5 Attorneys for Plaintiff,
BMO HARRIS BANK N.A. FRESNO COUNTY SUPERIOR COURT
6 By: I. Herrera, Deputy
7
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF FRESNO - B.F. SISK COURTHOUSE
10
11 BMO HARRIS BANK N.A., ) CASE NO: 18CECG02708
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12 Plaintiff, )
) DECLARATION OF RAFFI
13 vs. ) K.IJATCHADOURIAN RE
) CALCULATION OF ATTORNEYS
14 RASHPAL VIRK, an individual; and DOES 1-) FEES AND INTEREST
100, inclusive, )
15 )
Defendants. )
16 _____________ )
17 I, RAFFI KHATCHADOURIAN, declare:
18 1. That I am an attorney duly admitted and licensed to practice before all the Courts of
19 the State of California and an associate of the HEMAR, ROUSSO & HEALD, LLP attorneys for
20 Plaintiff herein.
21 2. Pursuant to the written Loan and Security Agreements, Plaintiff is entitled to recover
22 attorney's fees in the above-referenced matter. Plaintiff is requesting attorney's fees in the amounts
23 below, pursuant to the Fresno Superior Court Local Rule Appendix A-1, as follows:
24 Principal Amount of Agreements: $156,425.74
25 20% of the first $5,000.00 in principal,
26 or $400.00, whichever is greater: $1,000.00
27 15% of the next $10,000.00 in principal: $1,500.00
28 10% of the next $10,000.00 in principal: $1,000.00
DECLARATION OF RAFFI KHATCHADOURIAN RE CALCULATION OF ATTORNEYS FEES AND INTEREST
1 5% of the next $25,000.00 in principal: $1,250.00
2 2% of the next $50,000.00 in principal: $1,000.00
3 1% of the principal amount over $100,000.00: $ 564.25
4 Total amount of attorney's fees: $6,314.25
5 3. With respect to Agreement 1, interest is accruing at the rate of eighteen percent
6 (18%) per annum at the daily rate of $25.7178, for the total sum of accrued interest from June 26,
7 2018 through November 5, 2018, in the amount of $3,394.75. Attached hereto as Exhibit "1" is the
8 interest calculation.
9 4. With respect to Agreement 2, interest is accruing at the rate of eighteen percent
10 (18%) per annum at the daily rate of $10.6984, for the total sum of accrued interest from July 14,
11 2018 through November 5, 2018, in the amount of $1,219.62. Attached hereto as Exhibit "2" is the
12 interest calculation.
1 'J
lJ J. \Vith respect to A1:,ieement 3, interest is accruing at the rate of eighteen percent
14 (18%) per annum at the daily rate of $40.7252, for the total sum of accrued interest from July 12,
15 2018 through November 5, 2018, in the amount of $4,274.13. Attached hereto as Exhibit "3" is the
16 interest calculation.
17 I declare under penalty of perjury under the laws of the State of California that the
18 foregoing is true and correct.
19 Executed on November 30, 20 ta.
r
20 �,.
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2
DECLARATION OF RAFFI KHATCHADOURIAN RE CALCULATION OF ATTORNEYS FEES AND INTEREST
........ �......
' ..,;·•··.;.·•... .
' ...: ...
....
.
•...;.
Exhibit 1
Sheet1
CA CULATING SIMPLE INTEREST
Principal Amount Annual Interest Daily Int. Rate
$52,149.99 $9,387.00 $25.7178033
Beginning Date Today's Date Resulting Days
132
Page 1
M‘w‘
Exhibit 2
Sheet1
I
CA CULATING SIMPLE INTEREST
Principal Amount Annual lntenest Daily Int. Rate
$21,694.02 $3,904.92 $10.6984208
Beginning Date Today's Datte Resulting Days
114
Page 1
...,....
.....
'
...;,-
Exhibit 3
Sheet1
CULATING SIMPLE INTEREST
Principal Amount Annual Interest Daily Int. Rate
$82,581.73 $14,864.71 $40.7252367
Beginning Date Today's Date Resulting Days
116
Page 1
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1 RAFFI KHATCHADOURIAN, ESQ. (SBN 193165) HEMAR, ROUSSO & HEALD, LLP 2 15910 Ventura Blvd., 12th Floor Encino, California 91436 3 Telephone: (818) 501-3800 Facsimile: (818) 501-2985 E-FILED 11/30/2018 4:06 PM 5 Attorneys for Plaintiff, BMO HARRIS BANK N.A. FRESNO COUNTY SUPERIOR COURT 6 By: I. Herrera, Deputy 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF FRESNO - B.F. SISK COURTHOUSE 10 11 BMO HARRIS BANK N.A., ) CASE NO: 18CECG02708 \ r A ,..,..�nnarl tn Unnnnn,;1lrl Al,;1�1,,-1 J LL>...:,.:,.15.1.1vu LV .1..1.v.1..1. • ..i..,v.1..1....,.1.,y ......, ... ...,,.,_,....J 12 Plaintiff, ) ) DECLARATION OF RAFFI 13 vs. ) K.IJATCHADOURIAN RE ) CALCULATION OF ATTORNEYS 14 RASHPAL VIRK, an individual; and DOES 1-) FEES AND INTEREST 100, inclusive, ) 15 ) Defendants. ) 16 _____________ ) 17 I, RAFFI KHATCHADOURIAN, declare: 18 1. That I am an attorney duly admitted and licensed to practice before all the Courts of 19 the State of California and an associate of the HEMAR, ROUSSO & HEALD, LLP attorneys for 20 Plaintiff herein. 21 2. Pursuant to the written Loan and Security Agreements, Plaintiff is entitled to recover 22 attorney's fees in the above-referenced matter. Plaintiff is requesting attorney's fees in the amounts 23 below, pursuant to the Fresno Superior Court Local Rule Appendix A-1, as follows: 24 Principal Amount of Agreements: $156,425.74 25 20% of the first $5,000.00 in principal, 26 or $400.00, whichever is greater: $1,000.00 27 15% of the next $10,000.00 in principal: $1,500.00 28 10% of the next $10,000.00 in principal: $1,000.00 DECLARATION OF RAFFI KHATCHADOURIAN RE CALCULATION OF ATTORNEYS FEES AND INTEREST 1 5% of the next $25,000.00 in principal: $1,250.00 2 2% of the next $50,000.00 in principal: $1,000.00 3 1% of the principal amount over $100,000.00: $ 564.25 4 Total amount of attorney's fees: $6,314.25 5 3. With respect to Agreement 1, interest is accruing at the rate of eighteen percent 6 (18%) per annum at the daily rate of $25.7178, for the total sum of accrued interest from June 26, 7 2018 through November 5, 2018, in the amount of $3,394.75. Attached hereto as Exhibit "1" is the 8 interest calculation. 9 4. With respect to Agreement 2, interest is accruing at the rate of eighteen percent 10 (18%) per annum at the daily rate of $10.6984, for the total sum of accrued interest from July 14, 11 2018 through November 5, 2018, in the amount of $1,219.62. Attached hereto as Exhibit "2" is the 12 interest calculation. 1 'J lJ J. \Vith respect to A1:,ieement 3, interest is accruing at the rate of eighteen percent 14 (18%) per annum at the daily rate of $40.7252, for the total sum of accrued interest from July 12, 15 2018 through November 5, 2018, in the amount of $4,274.13. Attached hereto as Exhibit "3" is the 16 interest calculation. 17 I declare under penalty of perjury under the laws of the State of California that the 18 foregoing is true and correct. 19 Executed on November 30, 20 ta. r 20 �,. 21 22 23 24 25 26 27 28 2 DECLARATION OF RAFFI KHATCHADOURIAN RE CALCULATION OF ATTORNEYS FEES AND INTEREST ........ �...... ' ..,;·•··.;.·•... . ' ...: ... .... . •...;. Exhibit 1 Sheet1 CA CULATING SIMPLE INTEREST Principal Amount Annual Interest Daily Int. Rate $52,149.99 $9,387.00 $25.7178033 Beginning Date Today's Date Resulting Days 132 Page 1 M‘w‘ Exhibit 2 Sheet1 I CA CULATING SIMPLE INTEREST Principal Amount Annual lntenest Daily Int. Rate $21,694.02 $3,904.92 $10.6984208 Beginning Date Today's Datte Resulting Days 114 Page 1 ...,.... ..... ' ...;,- Exhibit 3 Sheet1 CULATING SIMPLE INTEREST Principal Amount Annual Interest Daily Int. Rate $82,581.73 $14,864.71 $40.7252367 Beginning Date Today's Date Resulting Days 116 Page 1