Rupa Marya v. Warner Chappell Music Inc

Filing 364

MEMORANDUM in Support of NOTICE OF MOTION AND MOTION for Attorney Fees Plaintiffs' Notice of Motion and Motion for Award of Attorneys' Fees and Expenses and for Incentive Compensation Awards; Memorandum of Points and Authorities in Support Thereof 323 Response to Defendants' Statement Regarding Class Counsel's Billing Records [354-1] filed by Plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Declaration of Dina Perez, # 2 Declaration of Marc L. Godino)(Manifold, Betsy)

1 FRANCIS M. GREGOREK (144785)
[e-mail]
2 BETSY C. MANIFOLD (182450)
[e-mail]
3 RACHELE R. RICKERT (190634)
[e-mail]
4 MARISA C. LIVESAY (223247)
[e-mail]
5 BRITTANY N. DEJONG (258766)
[e-mail]
6 WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
7 750 B Street, Suite 2770
San Diego, CA 92101
8 Telephone: [phone]
9 Facsimile: 619/234-4599
10 Interim Lead Counsel for Plaintiffs and the [Proposed] Class
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA -

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WESTERN DIVISION

14 GOOD MORNING TO YOU
PRODUCTIONS CORP., et al.,
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Plaintiffs,
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v.

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19 WARNER/CHAPPELL MUSIC,
INC., et al.
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Defendants.
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Lead Case No. CV 13-04460-GHK (MRWx)
DECLARATION OF MARC L.
GODINO IN FURTHER SUPPORT
OF REQUEST FOR ATTORNEYS’
FEES AND EXPENSES
Room:
Judge:

650
Hon. George H. King, Chief
Judge

1

The undersigned, Marc L. Godino, under penalty of perjury, hereby declares

2 and states as follows:
3

1.

I am an attorney duly licensed to practice law in the State of California

4 and I am admitted to practice in this Court. I am a Partner of the law firm Glancy
5 Prongay & Murray LLP (“GPM”), one of Plaintiffs’ Counsel in this litigation. I have
6 personal knowledge of the matters set forth herein concerning all matters pertaining
7 to this Action and, if called upon, I could and would competently testify thereto.
8

2.

I submit this Declaration in further support of Plaintiffs’ motion for an

9 award of attorneys’ fees and reimbursement of expenses.

This motion and

10 supporting memoranda of law are filed concurrently herewith.
11

3.

GPM primarily litigates consumer and securities class actions.

12

4.

During my more than 10 years at GPM, it has been the firm’s customary

13 practice to include litigation-related travel time as part of the total lodestar submitted
14 to a Court in a request for reimbursement of fees.
15

5.

Litigation related travel time is billed at 100% percent of the rate of the

16 attorney billing for such time.
17

6.

Litigation related travel time includes such necessary and reasonable

18 time as attending meetings, court appearances, depositions, and travel between
19 activities related to the case.
20

7.

To my knowledge, GPM’s requests for litigation related travel time has

21 never been challenged or denied.
22

8.

Prior to joining GPM, I was an associate at the class action firm Stull

23 Stull & Brody (“SSB”) for approximately seven years. During my time at SSB, it
24 was the firm’s customary practice to include litigation-related travel time, billed at
25 100% percent of the rate of the attorney billing for such time, as part of the total
26 lodestar submitted to a Court in a request for reimbursement of fees.
27

9.

To my knowledge, SSB’s requests for litigation-related travel time was

28 never challenged or denied during my employment at SSB.
1
GODINO DECL.
CASE NO. CV 13-04460-GHK (MRWX)