I, JENNIFER J. GRAY, do hereby declare:It is amazing how she can waste money and lie to the court about it.
1. I was the attorney of record for PETITIONER Ms. [name] AngryDad. If called upon to testify as to the facts contained herein, I could do so competently.
2. On May 10th, 2005, I executed the "DECLARATION OF JENNIFER J. GRAY IN SUPPORT OF PETITIONER'S REQUEST FOR ATTORNEY'S FEES", for the May 13, 2005 hearing.
3. Nature and Complexity of the Litigation: This is a complex family law case involving contested issues of the following: physical and legal custody of the two minor children, and division of assets. Mr. AngryDad has challenged every decision and procedure in this case, resulting in excessively time consuming mediation attempts and litigation efforts.
4. Examples of the nature and the complexity of the litigation include the following: an August 30, 2004 financial hearing on support issues; a May 13, 2005 hearing on custody issues, involving the examination and cross examination of Mr. AngryDad, Ms. AngryDad, Dr. Bret Johnson, and four witnesses (additional declarations were prepared for other witnesses); deposition of Mr. AngryDad; research pertaining to experts retained by Mr. AngryDad; motion to compel the production of documents; motion for an expedited hearing; and a motion to continue a hearing date.
5. Amount Involved: The amount of the attorney's fees Ms. AngryDad still owes our law firm is $25,073.89, out of a total of $54,892.54 billed. This amount was for over 247 hours of legal work done by my assistants and myself.
6. The Skill Required and Empployed in Handling the Litigation involved the following activities:
a. Drafting: Declarations for my client in support of OSC; OSC Notices; Income and Expense Declaration; Status Conference Statements (at least two times); Declaration in Support of Motion to Seal Court Records; Points and Authorities re: Motion to Seal; Reply Declaration; Reply Brief, Level II Investigation packet; Findings and Order After Hearing (at least nine times); Form interrogatories; Meet and confer letter; Notice to exchange expert witness list; Ex parte application; Motion to compel responses to discovery; Motion to compel responses to form interrogatories; Motion to compel responses to request for production of documents; Declarations in support of motion to compel; Motion to continue trial and supporting declaration; Ex parte motion to continue and request for order shortening time; Drafting witness examination questions for Deposition of Mr. AngryDad; Schedule of Assets and Debts; Drafting witness examination questions for expert Dr. Johnson; Drafting Client's declaration for status hearing; Drafting declaration regarding attorney's fees; Memorandum of points and authorities regarding fees issue; Response and status report regarding safety and parenting issues.
b. Court Appearances Regarding: Status Conference (several); Custody and Support hearing; Child and Spousal Support Hearing; Support issues; Mediation/Dr. Berrenge and Dr. Johnson; Review Hearing on Support and Custody Issues; Review Hearing; Custody Evaluation; Ex. parte hearing for order to shorten time; Motion to continue and motion to compel; Motion to compel and setting of continued evidentiary hearing; Custody hearing Evidentiary hearing regarding custody and visitation issues; Review hearing on custody, visitation, support and attorney's fees; Review hearing regarding the psychological evaluations report for both my client and Mr. AngryDad.
c. Discovery: Deposition of Mr. AngryDad; Examination of supporting witnesses; Cross-examination of Mr. AngryDad's witnesses;
7. Attention Given to Case: I worked on this case with Ms. AngryDad for over two years. As outlined in the attached billing statements, I did not bill for seventeen hours worth of work, equivalent to $3,825.00. Further, I worked, at a minimum, an additional twenty hours on this case, at no cost to Ms. AngryDad.
8. Success of My Efforts: Every court action concluded in Ms. AngryDad's favor.
9. Attorney's Professional Standing and Reputation: I have been in the practice of law, specifically litigation, for over twelve years. I have been in the practice of family law for almost five years at Bosso Williams, one of the larger law firms in Santa Cruz County.
10. I billed Ms. AngryDad at a rate of $225.00 per hour for the work done in 2004, and at a rate of $250.00 per hour for work done in 2005. My assistant's work was billed at a rate of $95 per hour for work done in 2004, and $110 per hour for work done in 2005.
11. Intricacies and Importance of the Litigation: This case involved important contested child custody and visitation issues. The nature of the parties and the contested issues required time beyond the average custody and support matter. Mr. AngryDad chose to contest every issue presented to the court, regardless of whether or not his position was supported by law.
12. Labor and Necessi1y for Skilled Legal Training and Ability In Trying the Case: This case involved a lot of attention to detail and in depth familiarity with the Rules of Civil Procedure. All issues in this case were contested, and involved many court appearances.
13. Litigation Costs Already Incurred and Exvected to be Incurred Tbrough Conclusion of the Case: The litigation costs incurred at the time that Ms. AngryDad substituted herself in as her own attorney were $54,892.54. That was in October of 2005. It is now April of 2006, and this case is scheduled for yet another hearing on financial matters. It is estimated that attorney's fees would have grown to at least another $30,000 owing had I remained on the case.
14. Time Consumed: This case consumed a majority of time over a two year period. In addition to Mr. AngryDad's decision to represent himself, his demands required an unusual amount of time on seemingly routine issues.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: Apr 2, 2006 By JENNIFER J. GRAY
DECLARATION OF JENNIFER J. GRAY IN SUPPORT OF MOTION FOR ATTORNEY'S FEES
Friday, April 07, 2006
Justifying $55k in legal fees
My ex-wife submitted this affidavit: