The opinion of the court was delivered by: Hon. James F. Holderman
THIS DOCUMENT RELATES TO ALL CLASS ACTIONS DECLARATION OF DAVID C. PARISI REGARDING ATTORNEYS' FEES AND EXPENSES
I, David C. Parisi, the undersigned, being competent to testify, swear under penalty of perjury as provided by 28 U.S.C. § 1746 that the following facts and statements are true and correct, except as to such matters stated to be made on information and belief, and as to such matters, I certify that I believe the same to true:
1. I am an attorney at law and a partner in the law firm Parisi & Havens LLP. I am the attorney primarily responsible for the handling of this litigation on behalf of Parisi & Havens LLP. This declaration is made in support of Plaintiffs' Motion for Final Approval of Class Action Settlement, Attorneys' Fees, and Incentive Awards in this matter.
2. I have been practicing law since passing the California State bar in 1992. The principals of Parisi & Havens LLP are Suzanne Havens Beckman and myself. Together, over the last ten years, we have successfully litigated numerous complex class actions and insurance coverage cases on behalf of plaintiffs. We have been lead counsel for plaintiffs in lawsuits which, combined, have settled for in excess of $200,000,000.00 payments to our clients. I have been practicing law for approximately 19 years, Ms. Havens Beckman for approximately 15 years, and Ms. Moradmand for approximately 3 years. A true and accurate copy of my firm resume is attached hereto as Exhibit 1.
3. I am familiar with (i) the claims, evidence, and legal arguments involved in this settlement, (ii) the terms of the settlement, and (iii) the relevant defenses, evidence, and legal arguments to date.
4. Throughout my firm's involvement in this action, we did our part to ensure that the tasks necessary to prosecute the case were allocated among counsel in our firm and outside of our firm appropriately and were conducted efficiently, without undue duplication of effort, and at minimal expense. We worked very efficiently with our co-counsel and complemented each other's work and skill-set. Not being paid by the hour, we had an incentive to conduct our efforts efficiently. So too, being responsible for advancing all expenses, we had an incentive not to expend funds unnecessarily.
5. The attorneys at Parisi & Havens LLP record their time contemporaneously with the work performed. As reflected in the chart below (segregating time by attorney) as of November 4, 2011, the total number of attorney hours spent on this matter by my firm is 29.5 and our total loadstar is $13,261.00. The lodestar figure is based on the ordinary professional billing rate that my law office charges clients, including those that pay for legal services by the hour. Expenses are accounted for and billed separately and are not duplicated in our professional billing rate. None of this time was spent preparing this fee declaration or addressing the attorney fee application. This time breaks down as follows:
Attorney Hours Rate Total
David C. Parisi 18.3 $510.00 $9,333.00 Suzanne Havens Beckman 4.7 $490.00 $2,303.00 Azita Moradmand 6.5 $250.00 $1,625.00 Totals 29.5 $13,261.00
6. As of November 4, 2011, my firm advanced a total of $1,002.49 in unreimbursed actual third-party expenses in connection with the prosecution of these cases. The actual expenses incurred in the prosecution of these cases are reflected on the computerized accounting records of my firm. Those accounting records are prepared by bookkeeping staff based on receipts and check records and accurately reflect all actual expenses incurred.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 4th day of November 2011.
LAW FIRM RESUME Parisi & ...