On April 05, 2019 a
Motion-Secondary
was filed
involving a dispute between
Cpi Chico Beneficiary Llc,
Ta Chico Llc,
Hk Deluxe Llc,
and
Hk Deluxe Llc,
for civil
in the District Court of Butte County.
Preview
is}
Oo ON DH FR WwW
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dennis M. Wilson (State Bar No. 43877) F
dwilson @wilsonlawfirmea.com
Justin A. Berg (State Bar No. 335451) I
jberg@wilsonlawfirmea.com L
Wilson Law Firm, A Professional Corporation E E
D
By
50 Iron Point Circle, Suite 115 D
tte...
Folsom, California 95630
Facsimile: (916) 608-8892 Electronically FILED
Superior Court of California F
County of Butte I
Telephone: (916) 608-8891
Attorneys for HK Deluxe, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF BUTTE
CPI CHICO BENEFICIARY LLC et al., No. 19CV01079
Plaintiffs, Declaration of Dennis M. Wilson in
Support of Reply to Opposition to
vs. Motion for Order Attorney’s Fees
HK DELUXE, LLC, and Costs
Defendant.
Dept: 1
Date: February 2, 2022
. Time: 9:00 a.m.
And Related Cross-Action. Judge: Hon. Tamara Mosbarger
I, Dennis M. Wilson, declare:
1, Tam an attorney at law licensed to practice in California, and I am an attorney
of record for HK Deluxe, LLC in the above-entitled action in Butte County Superior
Court Case #19CV01079. HK Deluxe, LLC, is the defendant and cross-complainant in
this action. I have personal knowledge of the matters contained in this declaration and,
if called as a witness to testify, I could and would competently testify to them.
2, During the course of this litigation, 1 carefully delegated tasks to Justin Berg in
his capacity as my paralegal before he passed the bar. Indeed, | still supervise him.
Despite what the billing records show, I closely supervised Justin Berg on every single
project that I delegated to him. I did not bill for every time J supervised his work,
1
Declaration of Dennis M. Wilson Supporting Reply to Opposition Motion for Attorney's Fees and Costste
Pm ODN DH FF Ww
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
because that would be duplicative and unfair to our client. I specifically delegated this
work to reduce the costs to our client, which will result in a reduction of costs for
plaintiffs. If] had performed all of that work, defendant's attorney fee motion would be
seeking double the amount it is seeking herein.
J declare under penalty of perjury under the laws of the state of California that
the foregoing is true and correct.
Z£
spasen Mle Clete
Dennis M. Wilson,
Attorney for HK Deluxe, LLC
Date: January 26, 2022
2
Declaration of Dennis M. Wilson Supporting Reply to Opposition Motion for Attorney’s Fees and Costs
Document Filed Date
January 26, 2022
Case Filing Date
April 05, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
is} Oo ON DH FR WwW 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dennis M. Wilson (State Bar No. 43877) F dwilson @wilsonlawfirmea.com Justin A. Berg (State Bar No. 335451) I jberg@wilsonlawfirmea.com L Wilson Law Firm, A Professional Corporation E E D By 50 Iron Point Circle, Suite 115 D tte... Folsom, California 95630 Facsimile: (916) 608-8892 Electronically FILED Superior Court of California F County of Butte I Telephone: (916) 608-8891 Attorneys for HK Deluxe, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF BUTTE CPI CHICO BENEFICIARY LLC et al., No. 19CV01079 Plaintiffs, Declaration of Dennis M. Wilson in Support of Reply to Opposition to vs. Motion for Order Attorney’s Fees HK DELUXE, LLC, and Costs Defendant. Dept: 1 Date: February 2, 2022 . Time: 9:00 a.m. And Related Cross-Action. Judge: Hon. Tamara Mosbarger I, Dennis M. Wilson, declare: 1, Tam an attorney at law licensed to practice in California, and I am an attorney of record for HK Deluxe, LLC in the above-entitled action in Butte County Superior Court Case #19CV01079. HK Deluxe, LLC, is the defendant and cross-complainant in this action. I have personal knowledge of the matters contained in this declaration and, if called as a witness to testify, I could and would competently testify to them. 2, During the course of this litigation, 1 carefully delegated tasks to Justin Berg in his capacity as my paralegal before he passed the bar. Indeed, | still supervise him. Despite what the billing records show, I closely supervised Justin Berg on every single project that I delegated to him. I did not bill for every time J supervised his work, 1 Declaration of Dennis M. Wilson Supporting Reply to Opposition Motion for Attorney's Fees and Costste Pm ODN DH FF Ww 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 because that would be duplicative and unfair to our client. I specifically delegated this work to reduce the costs to our client, which will result in a reduction of costs for plaintiffs. If] had performed all of that work, defendant's attorney fee motion would be seeking double the amount it is seeking herein. J declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Z£ spasen Mle Clete Dennis M. Wilson, Attorney for HK Deluxe, LLC Date: January 26, 2022 2 Declaration of Dennis M. Wilson Supporting Reply to Opposition Motion for Attorney’s Fees and Costs