Party Statement: Diana Blum, MD vs Sutter Health et al

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                                MARCIE ISOM FITZSIMMONS                    (SBN: 226906)
                           HIEU T. WILLIAMS            (SBN: 280585)
                           GORDON REES SCULLY MANSUKHANI, LLP
                           275 Battery Street, Suite 2000
                           San Francisco, CA 94111
                           Telephone:     (415) 986-5900
                           Facsimile:    (415) 986-8054
                           MIsom@grsm.com
                           HWilliams@grsm.com

                           Attorneys for Defendant
                           PALO ALTO FOUNDATION MEDICAL GROUP, INC.


                                                             SUPERIOR COURT OF CALIFORNIA

                                                                  COUNTY OF SANTA CLARA



                           DIANA P. BLUM, M.D.,                                          CASE NO.       115CV277582
         275 Battery Street, Suite 2000




                                                               Plaintiff,                DECLARATION OF
           San Francisco, CA 94111




                                                                                         HIEU T. WILLIAMS
              Gordon & Rees LLP




                                                                                         IN SUPPORT OF OPPOSITION TO
                                                                                         PLAINTIFF’S MOTION TO STRIKE
                           SUTTER HEALTH, a California corporation;                      AND TAX DEFENDANT’S
                           PALO ALTO FOUNDATION MEDICAL                                  MEMORANDUM OF COSTS
                           GROUP, INC., a California corporation;
                           PALO ALTO MEDICAL FOUNDATION, a                               Accompanying Documents:
                           California corporation; and DOES 1 through                         Opposition Brief;
                                                                                              Declaration of Marcie I. Fitzsimmons;
                                                                                              Declaration of Mary Lipian
                                                               Defendants.
                                                                                         Hearing Date:      May 18, 2018
                                                                                         Hearing Time:      9:30 p.m.
                                                                                         Dept.: 16
                                                                                         Honorable Judge Drew C. Takaichi

                                                                                         Trial Date: January 8, 2018

                                    I Hieu T. Williams, declare:

                                             I am an attorney at law licensed to practice before all courts of the State of

                           California and am a Senior Counsel in the law firm of Gordon Rees Scully Mansukhani, LLP,

                           attorneys for the defendant PALO ALTO FOUNDATION MEDICAL GROUP, INC. (“the

                           Physician Group”).       I have personal knowledge of the matters contained in this declaration and if

                           called to testify to them could and would do so competently.


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                              DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF OPPOSITION TO PLAINTIFF’S MOTION TO
                                                   STRIKE AND TAX DEFENDANT’S MEMORANDUM OF COSTS
                                    2.       I live in San Francisco, near Golden Gate Park.           The commute from my home to

                           Santa Clara Superior Court takes anywhere from 1.5 hours to more than 2 hours depending on

                           traffic.  The Fairmont Hotel in San Jose was within walking distance of the Court and the office

                           of PAMF’s counsel, where I along with my colleague, Marcie Fitzsimmons, had daily meetings

                           regarding trial strategy with co-defense counsel and with witnesses.               I would meet with witnesses

                           and prepare for trial separately from Ms. Fitzsimmons.             Commuting would have severely

                           impacted my ability to adequately prepare for each day of trial.             In the evenings during trial, I

                           prepared for the following day of trial, including but not limited to meeting with witnesses in San

                           Jose or Palo Alto, preparing examinations slated to testify, and the motion for nonsuit.                 I

                    10     regularly worked well past midnight during trial.           The evening before the Physician Group’s

                    11     motion for nonsuit was filed, I stayed up until 4 a.m. preparing the motion.               I only stayed in San

                    12     Jose on days necessary for trial preparation (i.e., Sunday evening through Friday morning).

                    13     Staying overnight in San Jose and incurring hotel costs during trial was reasonably necessary to

                    14     the conduct of the litigation, and not merely convenient or beneficial to preparation.

                    15              I declare, under penalty of perjury under the laws of the State of California, the foregoing

                    16     is true and correct.

                    17              Executed on this 7th day of May 2018 at San Francisco, California.

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                                                                                          Hieu T. Williams
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                                                                                    -2-
                              DECLARATION OF HIEU T. WILLIAMS IN SUPPORT OF OPPOSITION TO PLAINTIFF’S MOTION TO
                                                   STRIKE AND TAX DEFENDANT’S MEMORANDUM OF COSTS