Hovsepian v. Apple, Inc.

Filing 1464

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Hovsepian v. Apple, Inc. Doc. 1464 Att. 1 EXHIBIT 2 DECLARATION OF ROBERT G. RYAN IN SUPPORT OF MOTION FOR EAJA FEES C - 0 4 - 4 6 4 3 CW 1 Dockets.Justia.com DECLARATION OF ROBERT G. RYAN I, the undersigned, declare: 1. I am an Associate Attorney in th Law Offices of Eugene This declaration is C. Wong in San Francisco, California. submitted in support of a Motion for Attorneys' Fees in Yick Hung Sim v. USCIS, et al, No. C-04-4643 CW. 2. I am a graduate of the University of California at Santa Cruz, having received a B.A. degree in U.S. History in 1971. 3. I worked from 1973-77, and in 1979, as a legislative staff member in the California State Senate in Sacramento. 4. I received my law degree from Golden Gate University Law School in 1983. 5. From 1983 to 1991, I worked primarily as a legal researcher and writer with various law forms in the San Francisco Bay Area, including the Law Offices of Valencia & Wong (now Law Offices of Eugene C. Wong) in a contact basis from September 1989 until January 31, 1992. 6. On November 26, 1991, I was admitted to the Pennsylvania Bar. 7. On December 13, 1991, I was admitted to practice before the United States District Court for the Northern District of California. 8. On February 1, 1992, I became an Associate Attorney with the Law Offices of Valencia & Wong (now Law Offices of Eugene C. DECLARATION OF ROBERT G. RYAN IN SUPPORT OF MOTION FOR EAJA FEES C - 0 4 - 4 6 4 3 CW 2 W9ng) where I have worked until the present time. 9. On November 29, 2001, I was admitted to the bar of Washington State. 10. During the past three years I have been the lead attorney for more than 100 petitions for review filed with the United States Court of Appeals for the Ninth Circuit. I was lead attorney in Sael v. Ashcroft, 386 F.3d 922 (9th Cir. 2004), an asylum case, which held that Indonesia's ethnic Chinese are members of a disfavored group. As a result, ethnic Chinese Indonesians now have a "comparatively lower" burden of proof to establish eligibility for asylum. 11. Although I am paid on a salary basis as an Associate Attorney, I am aware that the law firm charges $250.00 per hour for immigration matters requiring litigation. 12. Pursuant to Rule 54-6 of the Civil Local Rules of this Court, this morning Assistant U.S. Attorney Edward A. Olsen and I conducted a telephonic meet and confer session after I sent to Counsel Olson him by facsimile transmission of a draft of petitioner's motion for EAJA fees and memorandum of points and authorities in support of the motion, and my billing statement. We discussed the legal issues in the case and my billing statement. After considering the government's arguments, petitioner has decided to proceed with the EAJA motion. 13. Attached to the Declaration is an itemization of all DECLARATION OF ROBERT G. RYAN IN SUPPORT OF MOTION FOR EAJA FEES C - 0 4 - 4 6 4 3 CW 3 fees incurred by me in connection with this litigation. I swear under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. Executed on this 4th day of August, 2005 at San Francisco, California. /s/ ROBERT G. RYAN ROBERT G. RYAN Declarant DECLARATION OF ROBERT G. RYAN IN SUPPORT OF MOTION FOR EAJA FEES C - 0 4 - 4 6 4 3 CW 4

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