On August 19, 2020 a
Party Statement
was filed
involving a dispute between
Finishmaster, Inc,
and
Aeropro, Llc A California Limited Liability Company,
Does 1-10, Inclusive,
Ermalovich, Joseph,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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Alan L. Brodkin State Bar No. 85991
Law Offices
ALAN L. BRODKIN & ASSOCIATES SfiEgiigRgf n
-.
Cgkwgggh7I§ANlBgfiénl 3
A Professional Corporation
Rm“) “fmw— =
15500 B Rockfield Blvd.
Irvine, CA 92618 DEC 0 3 2L
(949)457-8686 Fax(949)457-8688
71:2,-..»
*
.
{2:3, swan L
Attorney for Plaintiff
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, CENTRAL JUDICIAL DISTRICT
10
11 FINISHMASTER, INC., CASE NO. CIVDS 2017064
12
DECLARATION OF ALAN L.
13 Plaintiff, BRODKIN IN SUPPORT OF
ATTORNEY
VVVVVVVVVV\/\/\/
FEES PURSUANT
14 vs. TO COURT SCHEDULE
15 AEROPRO, LLC, ET AL., UNLIMITED CIVIL
16 DEPT: S31
Defendant. JUDGE: JOHN M. PACHECO
17
18
19 I, ALAN L. BRODKIN, hereby declare as follows:
20
I am an attorney at law duly admitted to practice before
21 1.
Courts of the State of California and the attorney of record
22 all
23 herein for plaintiff.
2. If called to testify I could and. would competently
24
as to the matters contained within this declaration.
25 testify
26
27
28
Declaration Re: Attorney Fees, Page 1
'
\—v \_/
3. That the above entitled action is for breach of contract,
open book account, account stated, and reasonable value, wherein
the debt was incurred after January 1, 1987.
4. Defendant(s) have not filed and served a response to the
Complaint herein. Therefore, plaintiff is the prevailing party by
reason of said default.
5. Plaintiff request attorney's fees pursuant to court
schedule in an amount of 25% of first $1,000 with a minimum fee of
$75.00, 10% of next $14,000, 3% of next $35,000, 2% of next
10 $50,000, 1% of the amount over $100,000. The principal amount in
11 the instant matter is $37,723.01, therefore, plaintiff respectfully
12 requests attorney fees in the amount of $2,331.69, as specified in
13 the Request for Entry of Default and proposed Judgment herein.
14
15 I declare under the penalty of perjury under the laws of the
16 State of California that the foregoing is true and correct and that
17 this declaration was executed on November 30, 2021, Irvine,
18 California.
19
20 /;}?
L. BRODKIN
K1?f
21
22
23
24
25
26
27
28
Declaration Re: Attorney Fees, Page 2
Document Filed Date
December 03, 2021
Case Filing Date
August 19, 2020
Category
Breach of Contract/Warranty Unlimited
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Alan L. Brodkin State Bar No. 85991 Law Offices ALAN L. BRODKIN & ASSOCIATES SfiEgiigRgf n -. Cgkwgggh7I§ANlBgfiénl 3 A Professional Corporation Rm“) “fmw— = 15500 B Rockfield Blvd. Irvine, CA 92618 DEC 0 3 2L (949)457-8686 Fax(949)457-8688 71:2,-..» * . {2:3, swan L Attorney for Plaintiff SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, CENTRAL JUDICIAL DISTRICT 10 11 FINISHMASTER, INC., CASE NO. CIVDS 2017064 12 DECLARATION OF ALAN L. 13 Plaintiff, BRODKIN IN SUPPORT OF ATTORNEY VVVVVVVVVV\/\/\/ FEES PURSUANT 14 vs. TO COURT SCHEDULE 15 AEROPRO, LLC, ET AL., UNLIMITED CIVIL 16 DEPT: S31 Defendant. JUDGE: JOHN M. PACHECO 17 18 19 I, ALAN L. BRODKIN, hereby declare as follows: 20 I am an attorney at law duly admitted to practice before 21 1. Courts of the State of California and the attorney of record 22 all 23 herein for plaintiff. 2. If called to testify I could and. would competently 24 as to the matters contained within this declaration. 25 testify 26 27 28 Declaration Re: Attorney Fees, Page 1 ' \—v \_/ 3. That the above entitled action is for breach of contract, open book account, account stated, and reasonable value, wherein the debt was incurred after January 1, 1987. 4. Defendant(s) have not filed and served a response to the Complaint herein. Therefore, plaintiff is the prevailing party by reason of said default. 5. Plaintiff request attorney's fees pursuant to court schedule in an amount of 25% of first $1,000 with a minimum fee of $75.00, 10% of next $14,000, 3% of next $35,000, 2% of next 10 $50,000, 1% of the amount over $100,000. The principal amount in 11 the instant matter is $37,723.01, therefore, plaintiff respectfully 12 requests attorney fees in the amount of $2,331.69, as specified in 13 the Request for Entry of Default and proposed Judgment herein. 14 15 I declare under the penalty of perjury under the laws of the 16 State of California that the foregoing is true and correct and that 17 this declaration was executed on November 30, 2021, Irvine, 18 California. 19 20 /;}? L. BRODKIN K1?f 21 22 23 24 25 26 27 28 Declaration Re: Attorney Fees, Page 2