On January 13, 2016 a
Motion-Secondary
was filed
involving a dispute between
Williams, Edwin,
Wilson, Desabian Keith,
and
Button, Donjonique,
Cooper, Ashley,
County Of San Bernardino,
County Of San Bernardino, A Public Entity,
Deputy Brown, Individually And In His Official Capacity,
Deputy Chambers, Individually And In His Official Capacity,
Deputy Frias, Individually And In His Offical Capacity As,
Deputy K. Rodriguezindividually And In His Official Capacity,
Deputy Lim, Indivually And In His Official Capacity As,
Deputy Silva, Individually And In His Official Capacity,
San Bernardino County Sheriff'S Department,
San Bernardino County Sheriff'S Department A Public Entity,
Sergeant Thornburg,Individually And In His Official Capacity,
West Valley Detention Center,
West Valley Detention Center, A San Bernardino County Jail,
Frias, Juan,
Rodriguez, Kenneth,
Silva Jr., Joseph,
for Miscellaneous Petition
in the District Court of San Bernardino County.
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Yana G. Henriks, Esq. (SBN: 25063 8)
Email: vhenriks@laW-mh.com ELECTRONICALLY FILED
Randy H. McMurray, Esq. (SBN 126888) SUPERIOR COURT OF CALIFORNIA
Email: rmcmurrav(a31aw-mh.com COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Cameron R. Chapman-Pinto, Esq. (SBN: 349339)
Email: cpint0@1aW-mh.com 12/7/2023 1:49 PM
McMURRAY HENRIKS, LLP DEPUTY
By: Paola Iniguez Solorio,
811 Wilshire B1Vd., Suite 1640
Los Angeles, California 90017
Telephone: (323) 931-6200
Facsimile: (323) 93 1 -9521
Attorneysfor PlaintififDESABIAN KEITH WILSON, as successor-in-interest to deceased
KOOOQQ
Plaintiff EDWIN WILLIAMS
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, CENTRAL DIVISION
11
1640
12
LLP
SUITE
90017
13
DESABIAN KEITH WILSON, as successor CASE NO. CIVDS 1 600447
HENRIKs,
in interest t0 deceased Plaintiff EDWIN
CA [AssignedforAll Purposes t0 the Hon.
WILLIAMS, an individual;
BOULEVARD,
ANGELES,
14
John M Pacheco in Dept. S31]
15 Plaintiff,
MCMURRAY
DECLARATION OF RANDY H.
WILSHIRE
Los
16
V.
MCMURRAY IN SUPPORT OF
PLAINTIFF’S MOTIONS FOR ATTORNEYS
811 17
COUNTY OF SAN BERNARDINO, et al.,
FEES, COSTS, AND CIVIL PENALTIES
18
[Filed concurrently with Plaintifi’iv Motionfor
19 Defendants.
’
Attorneys Fees &
Costs; Plaintifi’iv Motionfor
Cost ofProofSanctions; Plaintifi’k Motionfor
20 Civil Penalties; the Supporting Declarations 0f
Yana G. Henriks, Lauren I. Freidenberg,
21 Cameron R. Chapman-Pinto, and Dale K. Galipo]
22 Hearing Date: February 8, 2024
Hearing Time: 8:30 am.
23 Location: Dept. S31
24 ***
25
Filed: January 13,2016
26 Trial Date: August 7, 2023
Verdict Date: August 22, 2023
27 Entry 0f Judgment: September 14, 2023
Notice 0f Entry 0f Judgment: November 6, 2023
28
1
DECLARATION OF RANDY H. MCMURRAY
DECLARATION OF RANDY H. MCMURRAY:
I, RANDY H. MCMURRAY, declare as follows:
1. I am an attorney licensed to practice in the State of California. I represent Plaintiff
Desabian Keith Wilson, as successor in interest to deceased Plaintiff Edwin Williams, in this case.
Ihave personal knowledge of the facts stated herein, and, if called as a Witness, I could and would
testify competently thereto. I give this Declaration in support of Plaintiff” s concurrently filed Motion
for Attorneys’ Fees and Costs Under 42 U.S.C. § 1988, the ADA, and Rehab Act; Motion for Cost
0f Proof Sanctions Under C.C.P. § 2033.420; and Motion for Civil Penalties Under the ADA and
Rehab Act.
10 2. Ihave approximately 37 years 0f experience in the practice of law, the vast maj ority
11 0f Which has been in civil rights litigation. Following my undergraduate education at California
1640
12 Polytechnic State University, Pomona, I received my law degree from Southwestern University
LLP
SUITE
90017
13 School 0f Law and was admitted to the California Bar in December of 1986. In my nearly four
HENRIKs,
CA
BOULEVARD, 14 decades 0f practice in the areas 0f catastrophic personal injury litigation, complex medical
ANGELES,
15 malpractice, products liability, governmental entity liability, police abuse, road design, and business
MCMURRAY
WILSHIRE
Los
16 fraud, I have successfully tried several cases resulting in multi-million-dollar verdicts and have
811 17 obtained over $100,000,000 in favorable judgements or settlements for my clients.
18 3. Due t0 my success as a trial attorney, I have been consistently recognized by
19 Thomson Reuters as a “Super Lawyer” every year since 2006, a distinction only conferred on the
20 top 2% of attorneys in a given practice area, i.e., civil rights. Likewise, Ihave received an AV rating
21 from Martindale-Hubbell for the past 18 years. Further, in 2019, I was named by Law Dragon as
22 among the “500 Leading Plaintiff Consumer Lawyers,” after Which I was again distinguished by
23 Thompson Reuters as one 0f the “Most Honored Lawyers” in 2021 and 2022, among other
24 accolades. Additionally, I am a former president 0f the Consumer Attorneys Association 0f Los
25 Angeles (“CAALA”) and have served 0n the Board 0f Governors for over two decades.
26 4. Being that this matter was within the personal caseload 0f my partner, Ms. Yana
27 Henriks, my participation consisted mostly 0f reviewing and revising filings by our office, as well
28 as some assistance With trial preparations. These contributions are accurately reflected in the time
2
DECLARATION OF RANDY H. MCMURRAY
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Yana G. Henriks, Esq. (SBN: 25063 8) Email: vhenriks@laW-mh.com ELECTRONICALLY FILED Randy H. McMurray, Esq. (SBN 126888) SUPERIOR COURT OF CALIFORNIA Email: rmcmurrav(a31aw-mh.com COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Cameron R. Chapman-Pinto, Esq. (SBN: 349339) Email: cpint0@1aW-mh.com 12/7/2023 1:49 PM McMURRAY HENRIKS, LLP DEPUTY By: Paola Iniguez Solorio, 811 Wilshire B1Vd., Suite 1640 Los Angeles, California 90017 Telephone: (323) 931-6200 Facsimile: (323) 93 1 -9521 Attorneysfor PlaintififDESABIAN KEITH WILSON, as successor-in-interest to deceased KOOOQQ Plaintiff EDWIN WILLIAMS 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, CENTRAL DIVISION 11 1640 12 LLP SUITE 90017 13 DESABIAN KEITH WILSON, as successor CASE NO. CIVDS 1 600447 HENRIKs, in interest t0 deceased Plaintiff EDWIN CA [AssignedforAll Purposes t0 the Hon. WILLIAMS, an individual; BOULEVARD, ANGELES, 14 John M Pacheco in Dept. S31] 15 Plaintiff, MCMURRAY DECLARATION OF RANDY H. WILSHIRE Los 16 V. MCMURRAY IN SUPPORT OF PLAINTIFF’S MOTIONS FOR ATTORNEYS 811 17 COUNTY OF SAN BERNARDINO, et al., FEES, COSTS, AND CIVIL PENALTIES 18 [Filed concurrently with Plaintifi’iv Motionfor 19 Defendants. ’ Attorneys Fees & Costs; Plaintifi’iv Motionfor Cost ofProofSanctions; Plaintifi’k Motionfor 20 Civil Penalties; the Supporting Declarations 0f Yana G. Henriks, Lauren I. Freidenberg, 21 Cameron R. Chapman-Pinto, and Dale K. Galipo] 22 Hearing Date: February 8, 2024 Hearing Time: 8:30 am. 23 Location: Dept. S31 24 *** 25 Filed: January 13,2016 26 Trial Date: August 7, 2023 Verdict Date: August 22, 2023 27 Entry 0f Judgment: September 14, 2023 Notice 0f Entry 0f Judgment: November 6, 2023 28 1 DECLARATION OF RANDY H. MCMURRAY DECLARATION OF RANDY H. MCMURRAY: I, RANDY H. MCMURRAY, declare as follows: 1. I am an attorney licensed to practice in the State of California. I represent Plaintiff Desabian Keith Wilson, as successor in interest to deceased Plaintiff Edwin Williams, in this case. Ihave personal knowledge of the facts stated herein, and, if called as a Witness, I could and would testify competently thereto. I give this Declaration in support of Plaintiff” s concurrently filed Motion for Attorneys’ Fees and Costs Under 42 U.S.C. § 1988, the ADA, and Rehab Act; Motion for Cost 0f Proof Sanctions Under C.C.P. § 2033.420; and Motion for Civil Penalties Under the ADA and Rehab Act. 10 2. Ihave approximately 37 years 0f experience in the practice of law, the vast maj ority 11 0f Which has been in civil rights litigation. Following my undergraduate education at California 1640 12 Polytechnic State University, Pomona, I received my law degree from Southwestern University LLP SUITE 90017 13 School 0f Law and was admitted to the California Bar in December of 1986. In my nearly four HENRIKs, CA BOULEVARD, 14 decades 0f practice in the areas 0f catastrophic personal injury litigation, complex medical ANGELES, 15 malpractice, products liability, governmental entity liability, police abuse, road design, and business MCMURRAY WILSHIRE Los 16 fraud, I have successfully tried several cases resulting in multi-million-dollar verdicts and have 811 17 obtained over $100,000,000 in favorable judgements or settlements for my clients. 18 3. Due t0 my success as a trial attorney, I have been consistently recognized by 19 Thomson Reuters as a “Super Lawyer” every year since 2006, a distinction only conferred on the 20 top 2% of attorneys in a given practice area, i.e., civil rights. Likewise, Ihave received an AV rating 21 from Martindale-Hubbell for the past 18 years. Further, in 2019, I was named by Law Dragon as 22 among the “500 Leading Plaintiff Consumer Lawyers,” after Which I was again distinguished by 23 Thompson Reuters as one 0f the “Most Honored Lawyers” in 2021 and 2022, among other 24 accolades. Additionally, I am a former president 0f the Consumer Attorneys Association 0f Los 25 Angeles (“CAALA”) and have served 0n the Board 0f Governors for over two decades. 26 4. Being that this matter was within the personal caseload 0f my partner, Ms. Yana 27 Henriks, my participation consisted mostly 0f reviewing and revising filings by our office, as well 28 as some assistance With trial preparations. These contributions are accurately reflected in the time 2 DECLARATION OF RANDY H. MCMURRAY