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Cox, Castle & Nicholson LLP <br />C O X C A $ T l I=' N I C H O L S O N 505 Montgomery Street, 20* Floor <br /> San Francisco, California 94111-2585 <br /> P.415.296.9966 F 415.397.1095 <br /> <br /> Robert P. Doty <br /> 415.263.7183 <br /> rdo .ty~coxca~tle.com <br /> <br /> File No. 35874 <br /> <br /> January 28, 2002 <br /> <br /> VIA FACSIMILE AND U.S. MAIL <br /> ATTORNEY-CLIENT PRIVILEGE <br /> <br /> Stan T. Yamamoto <br /> City Attorney <br /> City of Redwood City <br /> P.O. Box 391 <br /> Redwood City, CA 94064 <br /> <br /> Re: Report To Council Re Proposal For Legal Services <br /> <br /> Dear Mr. Yamamoto: <br /> <br /> This letter responds to your memorandum of January 23rdl My firm's hourly <br /> rates for 2002 for the attorneys and legal assistants most likely to be involved in this matter are <br /> as follows. Partners (myself and perhaps Stuart Block or Ron Aronovsky if the level of litigation <br /> activity should warrant a second partner-level attorney) will be billed at $315 per hour, which <br /> represents an approximitely 15% discount from my standard rate. For work that can be <br /> efficiently handled by a mid-level associate, the individual would most likely be Kristina <br /> Kelchner at $230 per hour. For work that can be efficiently handled by a junior associate, the <br /> individual would most likely be either Heather Stem or Alicia Vaz, both of whom bill at $185 <br /> per hour. For paralegal assistance, the attorneys will use Kelly Simpson, and her rate is $180 per <br /> hour. Our partners stay involved in matters day-to-day so that the work of the junior attorneys is <br /> focused and productive. <br /> <br /> The approximate time line of litigation-related events, as best I can predict, would <br /> be as follows: (1) complete and file the complaint that has been partially drafted (during <br /> February), (2) conduct document discovery focusing on operations at Roy's Cleaners (during the <br /> spring produce the City's documents, serve production requests and review the documents <br /> produced), (3) serve and respond to interrogatories (likely summer to fall depending on the pace <br /> of document production and review), (4) undertake and defend depositions of the most <br /> knowledgeable individuals and consultants (likely fall), and then (5) participate in court- <br /> sanctioned mediation (fall/winter). While I think it is reasonable to achieve the foregoing within <br /> a 12-month period, it is a fairly aggressive schedule. Should mediation not resolve the case, I <br /> would expect a trial date some time next year. <br /> <br /> Throughqut the process, I would anticipate two tracks of work related to but <br /> distinct from the litigation. First, we will continue to work with the Regional Board and the <br /> <br /> ~vw.coxcastlc.com Los Angeles I Orange County [ San Francisco <br /> <br /> <br />