Mou v. City of San Jose et al

Filing 3008

Mou v. City of San Jose et al

Doc. 3008

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PATRICK E. TAYLOR, JR., Bar No. 113248 MATTHEW D. MARCA, Bar No. 180686 DANIEL P. DEAN, Bar No. 161028 TAYLOR & GUTIERREZ, LLP 332 Pine Street, Suite 600 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff STEPHAN SMITH COLLINS

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA STEPHAN SMITH COLLINS (formerly Stephan Jones), Plaintiff, v. BONNEVILLE INTERNATIONAL CORPORATION, VALERIE HOWARD, and DOES 1-30, inclusive, Defendant. I, Daniel P. Dean, declare as follows: 1. I am an associate with Taylor & Gutierrez, LLP, attorneys of record for plaintiff ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CV 05-01545 WHA

Declaration of Daniel P. Dean in Support of Plaintiff's Motion for Remand
Date: June 23, 2005 Time: 8:00 a.m. Place: Courtroom 9, 19th Floor

Stephan Smith Collins in this case. I am authorized to practice law before this Court. I am one of the attorneys responsible for working on this case. As such, the following facts are within my personal knowledge. If I am called to testify as to these facts, I can and will do so competently. 2. Attached hereto as Exhibit A is a true and correct copy of plaintiff's First

Amended Complaint filed on March 16, 2005 in San Francisco County Superior Court. 3. 4. The value of my legal services in this case is $275 per hour. I spent 1 hour reviewing and analyzing defendants' removal paperwork; 7.1 hours

conducting legal researching for this motion; 4.5 hours preparing this motion; half an hour reviewing the Honorable William H. Alsup's standing order and case management order and I
Declaration of Daniel P. Dean in Support of Plaintiff's Motion for Remand
X:\715\001C\mot-remand-dec-dpd.wpd

Page 1 of 2 Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

anticipate spending 1 hour attending the hearing on this motion. Thus, the value of my legal services for incurred in making his motion amounts to $3,877.50. I declare under penalty of perjury under the laws of the State of California and the laws of the United States that the foregoing is true and correct. Executed this 9th day of May, 2005 in San Francisco, California.

/s/ DANIEL P. DEAN Daniel P. Dean

Declaration of Daniel P. Dean in Support of Plaintiff's Motion for Remand
X:\715\001C\mot-remand-dec-dpd.wpd

Page 2 of 2