I, Anna von Herrmann, declare:

1. I am an attorney licensed to practice before all the courts of the State of California. I am a solo practitioner and the sole attorney of the Law Office of Anna von Hernnann. Along with Abenicio Cisneros, a solo practitioner with the Law Offices of Abenicio Cisneros, I am the attorney of record for Petitioners and Plaintiffs … (“Petitioners”) in this matter. If called as a witness, I would and could competently testify as follows:

2. On January 23, 2019, Petitioners propounded upon Respondent Form Interrogatories, Special Interrogatories, Requests for Production of Documents and Things, and Requests for Admission. A true and accurate copy of this discovery is attached hereto as Exhibit A.

3. On February 20, 2019, having received no response from Respondent to any of the discovery, I mailed a meet and confer letter to Respondent on behalf of Petitioners. In the letter, I reminded Respondent of the February 22, 2019, deadline to respond to the propounded discovery. I expressed my hope that Respondent would properly respond to the propounded discovery so that the issue could be resolved informally without the use of judicial resources. However, I also made clear that Petitioners intended to file a Motion to Compel if Respondent failed to provide responses to the discovery as required by law.

4. Respondent has provided Petitioners with no response whatsoever to any of the propounded discovery. Respondent did not request any extension of its deadline to respond to discovery. Indeed, Petitioners have not received any communication whatsoever from Respondent related to the propounded discovery.

5. When I attempted to reserve a date on which to have this motion heard, I was informed that the earliest date available was in July of 2019. The Hearing on Petition for Writ of Mandate in this matter, which is essentially a trial date, is currently scheduled for July 24, 2019. Petitioners’ opening brief on the Petition for Writ of Mandate is due 60 days prior to the hearing. As such, it was necessary for me to apply ex parte to have the time within which to have a hearing on the instant motion to compel shortened.

6. Attorney’s fees have been incurred in connection with this Motion in the amount of $3,160.00. I bill $345 per hour for my time, pursuant to the Laffey Matrix, which has been applied to determine “reasonable market rates” in California courts in cases such as Syers Properties III, Inc. v. Rankin (2014) 226 Cal. App. 4th 691, 701. I personally spent 4.25 hours preparing this motion.

7. Because my practice is based in northern California, and because of scheduling conflicts, I anticipate employing the services of Joseph Wangler, Esq., located in Upland, CA, to specially appear for me at both the hearing on the ex parte application and the hearing on the instant motion to compel. Mr. Wangler bills at rates similar to mine, and never any less than $345 per hour. I anticipate Mr. Wangler will spend approximately 1 hour to attend the hearing via Courtcall for the ex parte application to shorten time to hear this motion. I then anticipate Mr. Wangler will spend 3 hours to travel to and attend the hearing on the merits for the instant motion. It cost $106.75 to file this motion electronically, and $106.75 to file the ex parte application to shorten time for this motion to be heard electronically. I also incurred a fee of $100 to deliver a courtesy copy of the ex parte application to ensure it would be before the court on the day of the hearing. In sum, these fees and costs total $3,160.00

I declare the foregoing is true and correct under the penalty of perjury of the laws of California.

Dated: April 29, 2019