107 1 Exhibit McLaughlin declaration .pdf

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Case 2:11-cv-08305-ODW-PLA Document 107-1 Filed 02/22/13 Page 1 of 3 Page ID #:688

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Craig McLaughlin, Esq. (SBN 182876)
LAW OFFICE OF CRAIG MCLAUGHLIN
650 Town Center Drive, Suite 1300
Costa Mesa, California 92626
(714) 545-8500 ♦ (888) 545-7131 fax
cmc@smartpropertylaw.com
Attorney for Defendants
Kelly C. Sugano and Taka-O

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IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION

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SLEP-TONE ENTERTAINMENT
CORPORATION,

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Plaintiff,
vs.
BACKSTAGE BAR AND GRILL, et
al.,
Defendants.

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Case No.: CV11-08305 ODW (PLAx)
DECLARATION OF CRAIG
MCLAUGHLIN, ESQ. IN SUPPORT
OF OPPOSITION BY
DEFENDANTS KELLY C.
SUGANO AND TAKA-O TO SLEPTONE’S MOTION FOR
RECONSIDERATION
Hearing Date: March 18, 2013
Time: 1:30 p.m.
Courtroom: 11
Complaint Filed : Oct. 6, 2011

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DECLARATION OF CRAIG MCLAUGHLIN, ESQ. IN SUPPORT OF OPPOSITION BY DEFENDANTS
KELLY C. SUGANO AND TAKA-O TO SLEP-TONE’S MOTION FOR RECONSIDERATION

Case 2:11-cv-08305-ODW-PLA Document 107-1 Filed 02/22/13 Page 2 of 3 Page ID #:689

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DECLARATION OF CRAIG MCLAUGHLIN, ESQ.

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I, Craig McLaughlin, Esq. hereby declare that:
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I am currently attorney of record for Defendants Kelly C. Sugano and

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Taka-O in connection with the above entitled case and am a member in good

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standing of the State Bar of California and have personal knowledge of the facts

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set forth below and if called upon to testify to them could and would competently

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do so.
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I have over 16 years of experience practicing intellectual property law

in California, including litigation matters and trials. My hourly rate charged in the

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above entitled case has been $350 per hour. This rate is in line if not below other

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attorneys’ rates with similar experience in the locale.
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During the afternoon of February 12, 2013, I received a telephone call

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from a person identifying himself to be an associate of Fox Rothschild, counsel for

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Slep-tone. He was not an attorney of record, but did say that Alan Chen asked him

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to call and that Mr. Chen is a partner at Fox Rothschild. He indicated that Slep-

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tone intended to file a motion for reconsideration. I asked him on what grounds

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the motion would be based. He explained that it would be based on authority

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supporting the proposition that payment of a settlement amount shows that a party

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cannot be a prevailing party. I asked him whether such authority was new or was

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in connection with the Lanham Act and he did not indicate. I told him that Slep-

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tone failed to oppose the underlying fee motion and that therefore a motion for

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reconsideration would be untimely and likely frivolous, and that Defendants would

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vigorously oppose it if filed. Less than four hours later, I received electronic

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notice of the filing of the motion.
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I drafted the instant opposition which required 6.5 hours of my work

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at $350 per hour. An additional 0.5 hours is anticipated to review Slep-tone’s

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DECLARATION OF CRAIG MCLAUGHLIN, ESQ. IN SUPPORT OF OPPOSITION BY DEFENDANTS
KELLY C. SUGANO AND TAKA-O TO SLEP-TONE’S MOTION FOR RECONSIDERATION

Case 2:11-cv-08305-ODW-PLA Document 107-1 Filed 02/22/13 Page 3 of 3 Page ID #:690

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expected reply and another 2.0 hours to prepare for and appear at the hearing.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on February 21, 2013, in Orange County, California.

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/s/ Craig McLaughlin, Esq.

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Craig McLaughlin, Esq.

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DECLARATION OF CRAIG MCLAUGHLIN, ESQ. IN SUPPORT OF OPPOSITION BY DEFENDANTS
KELLY C. SUGANO AND TAKA-O TO SLEP-TONE’S MOTION FOR RECONSIDERATION


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