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.
Preview
Yana G. Henriks, Esq. (SBN: 25063 8)
ELECTRONICALLY FILED (Auto
Email: Vhenriksflawmhwm SUPERIOR COURT 0F CALIFOF RNIA
Randy H- McMurray, ESq- (SBN 126888) COUNTY 0F SAN BERNARDINC D
Emall: rmcmurrav(a31aw-mh.com 2/5/2024 4:58 PM
Cameron R. Chapman-Pinto, Esq. (SBN: 349339)
Email: cpint0@1aW-mh.com
McMURRAY HENRIKS, LLP
811 Wilshire B1Vd., Suite 1640
Los Angeles, California 90017
Telephone: (323) 931-6200
Facsimile: (323) 931-9521
Attorneysfor Plaintifif
KOOOQQ
DESABIAN KEITH WILSON, as successor-in-interest to deceased Plaintiff EDWIN WILLIAMS
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
FOR THE COUNTY OF SAN BERNARDINO, CENTRAL DIVISION
1640
12
LLP
SUITE
90017
13
DESABIAN KEITH WILSON, as successor CASE NO. CIVDSl600447
in interest t0 deceased Plaintiff EDWIN
M Pacheco
HENRIKs,
CA
BOULEVARD, 14 WILLIAMS, an individual; [Assigned t0 Hon. John in Dept. S31]
ANGELES,
15 Plaintiff, DECLARATION 0F YANA G. HENRIKS IN
MCMURRAY
WILSHIRE
SUPPORT OF PLAINTIFF’S REPLY TO
Los
16
V. DEFENDANTS’ OPPOSITION TO
ATTORNEYS’ FEES & COSTS
811 17
COUNTY OF SAN BERNARDINO, et al.,
18
Hearing Date: February 8, 2024
19
Hearing Time: 8:30 a.m.
Defendants.
Location: Dept. S31
20
***
21
Filed: January 13,2016
22 Trial Date: August 7, 2023
Verdict Date: August 22, 2023
23
Entry 0f Judgment: September 14, 2023
Notice 0f Entry 0f Judgment: November 6, 2023
24
25
26
27
28
1
DECLARATION OF YANA G. HENRIKS
DECLARATION OF YANA G. HENRIKS
I, YANA G. HENRIKS, declare as follows:
1. I am an attorney licensed to practice in the State of California. I have been a
practicing trial attorney in the United States for approximately 16 years and in multiple foreign
jurisdictions for at least two decades before that. 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.
KOOOQQ
I give this Declaration in support of Plaintiff s Reply to Defendants” Opposition t0 Plaintiff’s
Motion for Attorneys’ Fees and Costs Under 42 U.S.C. § 1988, the ADA, and Rehab Act.
10 2. Attached hereto as “Exhibit 1” are true and correct copies of the following
11 documents, 0n record in the matter styled Demajay Williams v. Kohl ’s Department Stores, Ina, Case
1640
12 No. 5: 19-cv-00397—JGB-SHKX, in U.S. District Court for the Central District of California:
LLP
SUITE
submitted 0n March 16, 2020 (Dkt.
90017
13 a. Pages 1—3 and 32-34 0f the Motion t0 Strike
HENRIKs,
CA
BOULEVARD, 14 No. 148, therein), in which I, along with the plaintiffs' other attorneys, requested
ANGELES,
15 $76,450.00 in attorneys' fees as monetary sanctions against the defendants;
MCMURRAY
Pages 1—2 and 8—9 0f the Declaration gave on March 2020 (Dkt. N0. 148-1,
WILSHIRE
Los
16 b. I 16,
811 17 therein), in support 0f the referenced Motion, WhereinI set forth my then-existing
18 hourly rate of $650 as it pertained t0 my portion 0f the requested sanctions; and
19 c. Pages 1 and 41 0fthe Order issued by the Court 0n June 16, 2020 (Dkt. N0. 265,
20 therein), awarding the plaintiffs' attorneys' fees as sanctions in the full amounts
21 requested, including my portion at the approved hourly rate 0f $650.
22 3. Attached hereto as “Exhibit 2” is a true an correct copy 0f Defendants’ counter-offer
23 to settle this case for $3 following the death of Edwin Williams.
24 I declare under penalty ofperjury, under the laws of the State 0f California, that the foregoing
25 is true and correct based 0n my personal knowledge. Executed this day 2nd day of February 2024, at
26 Los Angeles, California.
27 (a
28 Yana G. Hénriks, Esq.
Declarant
2
DECLARATION OF YANA G. HENRIKS
Preview
Yana G. Henriks, Esq. (SBN: 25063 8) ELECTRONICALLY FILED (Auto Email: Vhenriksflawmhwm SUPERIOR COURT 0F CALIFOF RNIA Randy H- McMurray, ESq- (SBN 126888) COUNTY 0F SAN BERNARDINC D Emall: rmcmurrav(a31aw-mh.com 2/5/2024 4:58 PM Cameron R. Chapman-Pinto, Esq. (SBN: 349339) Email: cpint0@1aW-mh.com McMURRAY HENRIKS, LLP 811 Wilshire B1Vd., Suite 1640 Los Angeles, California 90017 Telephone: (323) 931-6200 Facsimile: (323) 931-9521 Attorneysfor Plaintifif KOOOQQ DESABIAN KEITH WILSON, as successor-in-interest to deceased Plaintiff EDWIN WILLIAMS 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SAN BERNARDINO, CENTRAL DIVISION 1640 12 LLP SUITE 90017 13 DESABIAN KEITH WILSON, as successor CASE NO. CIVDSl600447 in interest t0 deceased Plaintiff EDWIN M Pacheco HENRIKs, CA BOULEVARD, 14 WILLIAMS, an individual; [Assigned t0 Hon. John in Dept. S31] ANGELES, 15 Plaintiff, DECLARATION 0F YANA G. HENRIKS IN MCMURRAY WILSHIRE SUPPORT OF PLAINTIFF’S REPLY TO Los 16 V. DEFENDANTS’ OPPOSITION TO ATTORNEYS’ FEES & COSTS 811 17 COUNTY OF SAN BERNARDINO, et al., 18 Hearing Date: February 8, 2024 19 Hearing Time: 8:30 a.m. Defendants. Location: Dept. S31 20 *** 21 Filed: January 13,2016 22 Trial Date: August 7, 2023 Verdict Date: August 22, 2023 23 Entry 0f Judgment: September 14, 2023 Notice 0f Entry 0f Judgment: November 6, 2023 24 25 26 27 28 1 DECLARATION OF YANA G. HENRIKS DECLARATION OF YANA G. HENRIKS I, YANA G. HENRIKS, declare as follows: 1. I am an attorney licensed to practice in the State of California. I have been a practicing trial attorney in the United States for approximately 16 years and in multiple foreign jurisdictions for at least two decades before that. 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. KOOOQQ I give this Declaration in support of Plaintiff s Reply to Defendants” Opposition t0 Plaintiff’s Motion for Attorneys’ Fees and Costs Under 42 U.S.C. § 1988, the ADA, and Rehab Act. 10 2. Attached hereto as “Exhibit 1” are true and correct copies of the following 11 documents, 0n record in the matter styled Demajay Williams v. Kohl ’s Department Stores, Ina, Case 1640 12 No. 5: 19-cv-00397—JGB-SHKX, in U.S. District Court for the Central District of California: LLP SUITE submitted 0n March 16, 2020 (Dkt. 90017 13 a. Pages 1—3 and 32-34 0f the Motion t0 Strike HENRIKs, CA BOULEVARD, 14 No. 148, therein), in which I, along with the plaintiffs' other attorneys, requested ANGELES, 15 $76,450.00 in attorneys' fees as monetary sanctions against the defendants; MCMURRAY Pages 1—2 and 8—9 0f the Declaration gave on March 2020 (Dkt. N0. 148-1, WILSHIRE Los 16 b. I 16, 811 17 therein), in support 0f the referenced Motion, WhereinI set forth my then-existing 18 hourly rate of $650 as it pertained t0 my portion 0f the requested sanctions; and 19 c. Pages 1 and 41 0fthe Order issued by the Court 0n June 16, 2020 (Dkt. N0. 265, 20 therein), awarding the plaintiffs' attorneys' fees as sanctions in the full amounts 21 requested, including my portion at the approved hourly rate 0f $650. 22 3. Attached hereto as “Exhibit 2” is a true an correct copy 0f Defendants’ counter-offer 23 to settle this case for $3 following the death of Edwin Williams. 24 I declare under penalty ofperjury, under the laws of the State 0f California, that the foregoing 25 is true and correct based 0n my personal knowledge. Executed this day 2nd day of February 2024, at 26 Los Angeles, California. 27 (a 28 Yana G. Hénriks, Esq. Declarant 2 DECLARATION OF YANA G. HENRIKS