Party Discovery: LOUIS PAYCHECK vs. PUNIT K. SARNA, et al

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                                1/30/2020
                    1   MATTHEW A. HAULK               (SBN:    272457)
                        RAGGHIANTI FREITAS LLP
                    2   1101 Fifth Avenue,        Suite 100
                        San Rafael,      California 94901
                    3   Telephone:       (415) 453-9433
                        Facsimile:       (415) 453- 8269
                    4
                        Attorney for Defendants
                    5   PUNIT K. SARNA and
                        PUJA SARNA

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                   8                           SUPERIOR COURT OF THE STATE OF CALIFORNIA

                   9                                             COUNTY OF SAN MATEO

                  10    LOUIS PAYCHECK,                                               CASE NO.:        19CIV02595
                  11
                                                   Plaintiff,                        SUPPLEMENTAL DECLARATION OF
                  12                                                                 MATTHEW A.          HAULK IN SUPPORT OF
                                          vs.                                        MOTION TO COMPEL FURTHER
                  13                                                                 RESPONSES TO SPECIAL
                        PUNIT K. SARNA,          et aL,                              INTERROGATORIES AND REQUESTS
                  14                                                                 FOR PRODUCTION
                                                   Defendants.
                  15
                                                                                     DATE:           February 6, 2020
                  16                                                                 TIME:           9:00 a.m.
                                                                                     DEPT.:          1, Courtroom 4C
                  17                                                                 JUDGE:          Honorable Leland Davis,          Ill

                  18                                                                 Complaint Filed:         May 10,     2019
                        AND RELATED CROSS-ACTION.                                    Trial Date:              Not set.
                  19

                  20             I, Matthew A. Haulk,        declare as follows:

                 21              1.       I am a partner at the law firm Ragghianti Freitas,               LLP and am counsel of
                  22    record in the above-captioned action for Punit K. Sarna and Puja Sarna (collectively,                           the

                 23     "Owner").     I have personal knowledge of the facts stated herein and,                    if called as a

                 24    witness,    I could and would competently testify thereto.

                 25             2.        I have spent in excess of 8-hours reviewing the Contractor's Opposition and

                 26    preparing a Reply to the Opposition. My billable rate for these types of matters is

                 27    generally $395/hour.        However,      my hourly rate for this matter is $350/hour. As such,                the

                 28    reasonable attorney's fees related            to the preparation of the Reply are $2, 800. The Owner


                          SUPPLEMENTAL DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF MOTION TO COMPEL FURTHER
                                                                            RESPONSES
                         therefore    requests    an  award    of reasonable      attorney's fees     in the   amount of $6,650.

                    2             I declare   under penalty of perjury,        under the     laws of the    State   of California,   that the

                    3    foregoing    is true  and   correct.    Executed     on  January 30,      2020,   in San   Rafael,   California.



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                                                                                        Matthew A.      Haulk

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                           SUPPLEMENTAL DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF MOTION TO COMPEL FURTHER
                                                                             RESPONSES