In Re Quantcast Advertising Cookie Litigation

Filing 76

NOTICE OF MOTION AND MOTION for Attorney Fees and Final Approval of Class Action Settlement filed by plaintiffs Alan Bonebrake, Alejandro Godoy, Byron Griffith, Mary Huebner, Jose Marquez, Austin Muhs, Brittany Sanchez, Edward Valdez, Gerardo Valdez, Kayla Valdez. Motion set for hearing on 6/13/2011 at 09:30 AM before Judge George H Wu. (Attachments: #1 Declaration of David A. Stampley, #2 Declaration of Majed Nachawati, #3 Declaration of Jeremy Wilson, #4 Declaration of David Parisi)(Stampley, David)

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DAVID C. PARISI (SBN 162248)
[e-mail]
PARISI & HAVENS LLP
15233 Valleyheart Drive
Sherman Oaks, California 91403
Telephone: [phone]
Facsimile: [phone]

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Plaintiffs’ Counsel

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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In Re QUANTCAST ADVERTISING
COOKIE LITIGATION, and

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In Re CLEARSPRING FLASH COOKIE
LITIGATION

No. 2:10-cv-05484-GW-JCG
No. 2:10-cv-05948-GW-JCG
[Assigned to the Hon. George H. Wu]
DECLARATION OF DAVID C.
PARISI IN SUPPORT OF AN
AWARD OF FEES AND COSTS
Date:
June 13, 2011
Location: Courtroom 10
312 N. Spring Street
Los Angeles, CA 90012
Time:
9:30 a.m.

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PARISI DECL IN SUPPORT OF AN AWARD OF ATTORNEYS’ FEES AND COSTS

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I, David C. Parisi, declare as follows pursuant to 28 U.S.C. § 1746:
1.

I am a partner of the law firm of Parisi & Havens LLP, and pursuant to the

Court’s Order, I submit this declaration. I am a member of the Bar of the State of
California and licensed to practice before this Court. I make this declaration based upon
my own personal knowledge. If called to testify, I could and would testify to the facts
contained herein. I am competent to testify that the following facts are true and correct to
the best of my knowledge.

2.

I am submitting this Declaration setting forth the time expended by the

professionals in my firm and the expenses that we incurred in support of the application
for an award of attorneys’ fees and reimbursement of expenses incurred in connection
with services rendered in the actions entitled In Re Quantcast Advertising Cookie
Litigation (“Quantcast action”) and In Re Clearspring Flash Cookie Litigation
(“Clearspring action”) (the “Actions”).

3.

In connection with the prosecution of the claims set forth in the Actions, at

the direction and request of the Interim Lead Counsel, my firm performed numerous tasks
including, but not limited to performing legal research for and revising the draft
complaints, strategizing legal theories with counsel, analyzing insurance policies of
defendants for purposes of assessing defendants’ assets available for any resolution,
attending the mediation session and discussing in depth the legal theories with the
mediator and various defendants’ counsel, drafting and revising the settlement agreement
and supporting documents, including the motion for preliminary approval, and preparing
for and attending several of the hearings in the Actions.

4.

The Actions were pursued on a fully contingent basis. The total number of

hours expended by the attorneys and professional support staff of my firm through April
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MASTER FILE NO. C-07-2852 SBA

PARISI DECL IN SUPPORT OF MOTION FOR AN AWARD OF ATTORNEYS FEES AND COSTS
DECL. GRETCHEN M. NELSON IN SUPPORT OF MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTELMENT

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18, 2011 in the Quantcast action is 146.2 hours and in the Clearspring action is 66.3

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hours. This number is derived from the time records regularly maintained by my firm. A

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listing of the professionals who worked on these actions, the number of hours spent by

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each such professional and their hourly rate, is attached as Exhibit A. The lodestar value

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of the services performed by my firm in the Quantcast action is $59,238.00 and in the

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Clearspring action is $26,589.00. This loadstar is based upon our current hourly rates of

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$510.00 for myself (I have been practicing law for over 18 years), $490.00 for Suzanne

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Havens Beckman (Ms. Havens Beckman has over 16 years experience practicing law) and

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$250.00 for Azita Moradmand (Ms. Moradmand has been practicing law for 3 years).

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The foregoing does not include any time spent by my firm in preparing the fee and

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expense application in this matter.

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5.

As detailed in Exhibit B, my firm has incurred a total of $955.22 in

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unreimbursed expenses in connection with the prosecution of the Quantcast action and

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$25.87 in connection with the Clearspring action.

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6.

The expenses incurred pertaining to these cases are reflected in the books

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and records of this firm. These books and records are prepared from expense vouchers

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and check records and are an accurate record of the expenses incurred.

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I declare under penalty of perjury under the laws of the United States of America,

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that the foregoing declaration is true and correct. Executed this 19th day of April 2011, at

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Sherman Oaks, California.

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__s/David C. Parisi___
David C. Parisi

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EXHIBIT A

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LODESTAR REPORT

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CASE:
In Re QUANTCAST ADVERTISING COOKIE LITIGATION
PERIOD: July 21, 2010 through April 18, 2011

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Professional
David C. Parisi
Suzanne Havens
Beckman

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Status*
P
P

$490.00

5.7

$2,793.00

Azita Moradmand

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HOURLY
RATE
$510.00

A

$250.00

58.5

$14,625.00

146.2

$59,238.00

TOTAL

TOTAL
HOURS
82

Current Lodestar
$41,820.00

____

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CASE:
In Re CLEARSPRING FLASH COOKIE LITIGATION
PERIOD: August 19, 2010 through April 18, 2011

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Professional
David C. Parisi
Suzanne Havens
Beckman

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Status*
P
P

$490.00

2.4

$1,176.00

Azita Moradmand

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HOURLY
RATE
$510.00

A

$250.00

27.6

$6,900.00

66.3

$26,589.00

TOTAL
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* Partner (P)
Associate (A)

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TOTAL
HOURS
36.3

Current Lodestar
$18,513.00

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EXHIBIT B

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EXPENSE REPORT

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CASE:

In Re QUANTCAST ADVERTISING COOKIE LITIGATION

SUMMARY OF COST

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Messenger/Filing Fees
Overnight Delivery
Legal Research
Travel Related

$904.72
$17.56
$12.94
$20.00

TOTAL COSTS

$955.22

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CASE:

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SUMMARY OF COSTS

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In Re CLEARSPRING FLASH COOKIE LITIGATION

Overnight Delivery
Travel Related

$5.87
$20.00

TOTAL COSTS

$25.87

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