Free Declaration in Support - District Court of California - California

Case 3:07-cv-04936-CRB

Document 54

Filed 03/07/2008

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BRIAN C. BUNGER, ESQ. (SB#142001) District Counsel ALEXANDER G. CROCKETT, ESQ. (SB#193910) Assistant Counsel BAY AREA AIR QUALITY MANAGEMENT DISTRICT 939 Ellis Street San Francisco, CA 94109 Telephone: (415) 749-4920 Facsimile: (415) 749-5103 Email: [email protected] Counsel for DEFENDANT THE BAY AREA AIR QUALITY MANAGEMENT DISTRICT UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SAN FRANCISCO CHAPTER OF THE A. PHILIP RANDOLPH INSTITUTE, et al., Plaintiffs, ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. C-07-4936 CRB SECOND DECLARATION OF ALEXANDER G. CROCKETT, ESQ., IN SUPPORT OF MOTION FOR SANCTIONS Date: Time: Place: Judge: April 11, 2008 10:00 a.m. Courtroom 8, 19th Floor Hon. Charles R. Breyer

14 vs. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, et al., Defendants.

I, Alexander G. Crockett, Esq., hereby submit this Second Declaration in support of the Motion for Sanctions being submitted concurrently herewith in the above-captioned action. 1. Since the execution of my first Declaration in support of the Motion for Sanctions on

February 15, 2008, I have spent an additional 26.5 hours working on the above-captioned matter. I have kept a record of the additional time I have spent working on this matter since execution of my first Declaration, as set forth in the spreadsheet attached as Exhibit 1 hereto (which includes some time spent on February 15, 2008, after execution of the first Declaration, which was not reflected in the first Declaration). I certify that the hours shown in Exhibit 1 were actually expended performing work on the topics indicated. I also certify that the hours I spent on the topics indicated were reasonable and necessary to fulfill my professional, legal, and ethical duties to my client the Air District. 1
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Case No. C-07-4936 CRB SECOND CROCKETT DECL. IN SUPPORT OF MOTION FOR RULE 11 SANCTIONS

Case 3:07-cv-04936-CRB

Document 54

Filed 03/07/2008

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2.

With the 72 hours I spent working on responding to the First Amended Complaint that I

documented in my first Declaration, plus the 26.5 hours I have spent since that first Declaration documented in Exhibit 1 hereto, I have worked a total of 98.5 hours responding to the First Amended Complaint. 3. I anticipate spending additional time working on the above-captioned matter after the

execution of this Section Declaration. I anticipate that I will spend time replying to Plaintiffs' oppositions to the Motion To Strike and Motion to Dismiss that I have filed in response to Plaintiffs' First Amended Complaint and the Rule 11 Motion for Sanctions I am filing concurrently herewith. I also anticipate spending time preparing for and attending the hearing on these motions. I intend to continue to document the time I spend working on this matter, and intend to supplement this Declaration at a later date to provide evidence of my further work on this matter.

I certify under penalty of perjury of the laws of California and of the United States of America that the foregoing is true and correct. Executed at San Francisco, California, on March 7, 2008.

__________/s/_______________________________ Alexander G. Crockett, Esq.

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Case No. C-07-4936 CRB SECOND CROCKETT DECL. IN SUPPORT OF MOTION FOR RULE 11 SANCTIONS