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I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 for Partial Swmnary Judgment, and purported Points and Authorities, there was approximately one inch of loose papers which appear to be photocopied pages from unidentified depositions, and photocopied pages which appear to be answers to Interrogatories which contain no referents to the questions. My initial reaction upon quickly reviewing these papers was that they constituted a highly improper and ineffectual attAmpt'by plaintiffs, counsel to combine a Motion for Partial Summary Judgment with his Opposition to a Motion for Sem kuy Judgment previously filed by defendant Santos, and I felt that perhaps the papers could be ignored. However, after consultation with counsel for other defendants, and upon reviewing the documents in more detail, and in light of the complexity of this litigation, I decided that out of an abundance of caution to protect the interest of my clients, it was rnele&Sary to Conduct legal research, read depositions, Interrogatories and their answers, Request for Admissions aryl I their Responses, and prepare an appropriate response to the papers served by plaintiff. A minimum of 20 hours of my time has been spent in responding to Plaintiffs, sham and meritless purported Motion for Partial Summary Judgment and Adjudication of Issues, and my hourly fee is $75.0, for a total of $1,500.00 in attorney's fees alone. In addition, = will be required to travel to Stockton and appear in court to oppose a soaritless motion. 14 In addition to the attorneys fees and expenses in-reins:d in li travelling to court, approximately 10 hours time has been expencr,3 by my 26 office staff to prepare a: -,J copy the documents filed in oppc=_:tion to 27 plaintiffs' motion. It is n7 best estimate that the total attorney fees, ,8 nth• and expenses to be ince-'-red by my clients as the result of -2-