HomeMy WebLinkAbout2013 CON Seltzer Caplan McMahon Vitek - Investigative Services750 8 STREET, SUITE 2100
SAN DIEGO, CALIFORNIA 92101
S ELTZER
NORMAN T. SELTZER
(19LB-20L1)
ROBERT CAPLAN
GERALD L. MCMAHON
REGINALD 4. VITEK
DAVID J. OORNE
JAMES R. DAWE
BRIAN T. SELTZER
JOYCE A. MCCOY
DENNIS J. WICKHAM
JOHN H. ALSPAUGH
JAMES P. LJELPHEY
ELINOR T. MERIDETH
MICHAEL G. NARDI
THOMAS F. STEINKE
NEAL F. PAN15H
SEAN T. HARGADEN
DAVID J. ZUBKUFF
MICHAEL A. LEONE
J. SCOTT SCHEPER
DANIEL E. EATON
GREGORY A. VEGA
HOWARD J. BARNHORST, 11
AMANDA L. HARRIS
DAVID M. GREELEY
CHARLES B. WITHAM
RHONDA CRANDALL
SCOTT ALAN MILLER
ROBERT (ROBIN) M. TRAYLOR
JOSEPH P, MARTINEZ
G. SCOTT WILLIAMS
)EEFREY B. HARR15
MATTHEW M. M4HPNEY
ERIK L. SCHRANER
TRACY A. WARREN
DANIEL W. ABBOTT
JAMES H. SIEGEL
CHRISTINE M. LA PINTA
TODD E. MYATT
ANDREW O. BROOKS
ANGELA A. WOOLARO
JASON M. SANTANA
MICHAEL B. LEES
MATTHEW D. SELTZER
KATHRYN B. QUARLES
JAMES R. THOMPSON
OAVID H. LICHTENSTEIN
ANDREA N. MYERS
MARISSA A. MCARTHUR
TREVOR B. POTTER
BRIAN M. RAGEN
BRIAN M. KATUSIAN
REBECCA L. VAN LOON
JASON R. FAAS
PARISA F. WEISS
C APLAN
OP COUNSEL
LAWRENCE S. BRANTON
DAVID P. RUTH
LAURA M, LAMB
McMAHON
Claudia Silva, City Attorney
City of National City
1243 National City Blvd.
National City, CA 91950-4301
V ITEK
A LAW CORPORATION
May 2, 2013
w w w. sc mv. com
619.685.3003
619.685.3100 IAx
DANIEL E. EATON
Eaton (g)sc mv.com
(619) 685-3052
(619) 702-6880 F A x
ELECTRONIC MAIL AND MAIL
Re: City of National City/Citizen Complaint
Our File No. 09077.70639
Dear Ms. Silva:
1. Engagement
This letter sets forth the basis upon which our firm is engaged to represent the City
of National City with respect to the above -referenced matter. The matter involves
an investigation of a complaint by citizens Ann Marie Villegas and Leticia
Guadarrama.
As you know, from time to time our firm represents applicants with land -use
matters presented for the City's review and approval. Our firm's undertaking of the
investigation outlined in this letter, of course, will not preclude our representation
of such applicants.
2. Attorneys' Services, Fees and Costs
It is difficult to predict with any reasonable degree of accuracy the nature and
extent of legal services to be performed. We therefore have not made any
commitment as to a maximum amount for fees or costs or as to the outcome of the
matter.
City of National City agrees to pay the usual fees charged from time to time by
Mr. Daniel E. Eaton and additional attorneys in our firm who work on this matter
under his supervision. Mr. Eaton's current hourly rate is $410. Other hourly rates,
which vary according generally to levels of experience, are as follows: Senior
members of the firm, $350 to $675; Associate and Of Counsel Attorneys, $200 to
SELTZER CAPLANIMcMAHONIVITEK
Claudia Silva, City Attorney
City of National City
May 2, 2013
Page 2
$475; Paralegals, $125 to $165; Law Clerks, $150; Word Processing, $40 to $55;
and, Document Control Clerks, $25 to $40. Our hourly charges shall include time
spent on the telephone, performing legal research, conferring with persons who
may have relevant information, negotiating for settlement, in court or in related
proceedings, and performing all other services on your behalf. If our firm adopts
new usual hourly rates from time to time during the course of our representation,
later charges will be billed and payable at such rates. No new rates will be adopted
before January 1, 2014.
Independent of and in addition to the fees for legal services to be rendered on your
behalf, it may be necessary for our firm to incur costs and advance sums for items
such as filing fees, process service fees, deposition transcripts, photocopying at
200/pg. if done in-house, expert witness' fees, investigator's fees, long-distance
telephone charges, facsimile transmission charges at $1/pg. plus any long-distance
telephone charges, travel expenses and other charges. We may request that you
advance such costs; however, to the extent that our firm advances such costs on
your behalf, it is agreed that you will reimburse us monthly and hold us harmless
from liability for these costs. Certain vendors may be billing you directly for
services performed at our request. We of course will identify all such vendors to
you.
3. Billing Statements and Correspondence
We will send our detailed monthly statements addressed to you indicating the
current status of National City's account, both for services rendered and for costs
advanced. The statements will show the date of each service performed, who
performed it, the time expended and rate involved. The statements will be due and
payable in full monthly upon billing. You agree to review our firm's monthly
statements promptly upon receipt and to immediately raise, in email or writing, any
questions or concerns about the propriety of the charges. Payment of any statement
will constitute your agreement that the charges therein were reasonable and
appropriate. A late charge of ten percent (10%) per annum will be assessed on any
portion of your account owing for both services performed and costs advanced
remaining unpaid for more than 35 days after the date of any statement.
To the extent you are or become indebted to this firm for fees and/or costs incurred,
you hereby assign to the firm a lien, on all monies and property awarded to you,
obtained by negotiation or otherwise recovered, for the amounts which may
become due to the firm under this Agreement. You may seek the advice of an
independent lawyer of your choice before making this assignment.
Our practice is to furnish our clients with copies of pleadings and/or
correspondence and to give verbal or written status reports from time to time
SELTZER CAPLAN McMAHDN
Claudia Silva, City Attorney
City of National City
May 2, 2013
Page 3
VITEK
concerning progress of a case. We will send all such copies and make all such
reports to you unless we are requested in writing to do otherwise.
We have not required that you deposit with us an initial retainer amount. We
reserve the right to review this decision from time to time to determine whether or
not a retainer amount for this matter is appropriate.
4. Arbitration Provision
Concurrently with this Agreement, you agree to and enter into the Arbitration
Agreement attached as Exhibit "A," by which you and this firm agree that any
controversy, claim or dispute which arises from or relates to this agreement or
services rendered or to be rendered by this firm (including its attorneys and
employees) shall be determined exclusively by submission to mandatory, binding
arbitration, instead of by a lawsuit or resort to court action
5. Other Provisions
It is important that you do not erase, destroy or alter any documents in paper or
electronic format that are potentially relevant to the subject matter of this case.
In this regard, please suspend any normal business practices, such as writing over
electronic records, that would result in such erasure, destruction or alteration.
Naturally, once our file has been closed, we will not perform any services on your
behalf concerning this matter. Thereafter, unless otherwise requested and agreed in
writing, we will not notify you of changes in the law which may affect you or your
interests with respect to this matter.
We wish to advise you that it is the policy of our firm to destroy papers in files any
time after 10 years from the conclusion of a matter. If for any reason you wish to
preserve any of the records or files from this matter, please request them from our
office well before this time period elapses.
No change, waiver or modification of any of the provisions of this agreement shall
be effective unless in writing and signed by our firm. This letter contains our entire
agreement concerning the services we will be performing and our compensation for
such services and costs. We have made no representations or promises other than
those expressly set forth in this agreement.
Should you ask us to render additional legal services of the same general kind as
requested by you in this matter, and should we agree to undertake them, and if no
new written fee agreement is entered into, the terms and conditions of this
agreement shall control our engagement for any such additional services.
SELTZER CAPLAN McMAHON
Claudia Silva, City Attorney
City of National City
May 2, 2013
Page 4
VITEK
To confirm our agreement under the terms and conditions set forth above, please
sign and return a copy of this letter to us on or before May 9, 2013.
We look forward to working with you again.
SELTZER CAPLAN McMAHON VITEK
A Law Corporation
By:
janiel E. Eaton
APPROVED AND ACCEPTED: CITY
Dated: May 15 , 2013
By:
Name: C V 'ia S va
Title: City Atto y
NATIONAL CITY
EXHIBIT "A"
ARBITRATION AGREEMENT
THE UNDERSIGNED AGREE THAT ANY AND ALL CONTROVERSIES, CLAIMS OR DISPUTES
(COLLECTIVELY "DISPUTES") WHICH ARISE FROM OR RELATE TO THE ENGAGEMENT OF
OR SERVICES RENDERED OR TO BE RENDERED BY SELTZER CAPLAN McMAHON VITEK
(INCLUDING ITS ATTORNEYS AND EMPLOYEES) (COLLECTIVELY "THE LAW FIRM")
SHALL BE DETERMINED EXCLUSIVELY BY SUBMISSION TO MANDATORY, BINDING
ARBITRATION, INSTEAD OF BY A LAWSUIT OR RESORT TO COURT ACTION. SUCH
DISPUTES SHALL INCLUDE, WITHOUT LIMITATION, DISPUTES AS TO FEES, COSTS OR
PROFESSIONAL MALPRACTICE (THAT IS, AS TO WHETHER ANY LEGAL SERVICES
RENDERED WERE UNNECESSARY OR UNAUTHORIZED OR WERE IMPROPERLY,
NEGLIGENTLY OR INCOMPETENTLY RENDERED).
THE PARTIES TO THIS AGREEMENT, BY ENTERING INTO IT, ARE GIVING UP THEIR
CONSTITUTIONAL RIGHTS TO HAVE ANY SUCH DISPUTES DECIDED IN A COURT OF LAW
BEFORE A JURY, AND INSTEAD ARE ACCEPTING THE USE OF ARBITRATION.
ACCORDINGLY, CITY. OF NATIONAL CITY ("CLIENT") IS ADVISED TO OBTAIN THE
ADVICE OF INDEPENDENT COUNSEL BEFORE ENTERING INTO THIS AGREEMENT.
ANY ARBITRATION PROCEEDING UNDER THIS AGREEMENT SHALL BE
CONDUCTED IN SAN DIEGO, CALIFORNIA, AND BE ADMINISTERED BY THE
AMERICAN ARBITRATION ASSOCIATION ("AAA") IN ACCORDANCE WITH THE
AAA'S COMMERCIAL ARBITRATION RULES AND, IF APPLICABLE, THE AAA'S
SUPPLEMENTARY PROCEDURES FOR CONSUMER -RELATED DISPUTES
("CONSUMER RULES") AND CONSUMER DUE PROCESS PROTOCOL ("PROTOCOL").
THE CLIENT AND THE LAW FIRM SHALL CAUSE A SINGLE ARBITRATOR TO BE
SELECTED UNDER THE AAA'S RULES AND SHALL SHARE EQUALLY THE
ARBITRATOR'S FEES AND THE AAA'S ADMINISTRATIVE FEES, EXCEPT, WHERE
THE CONSUMER RULES AND THE PROTOCOL APPLY, THEY SHALL BE FOLLOWED.
THE ARBITRATOR'S DECISION SHALL BE CONCLUSIVE, FINAL AND BINDING
UPON THE PARTIES.
THE LAWS OF THE STATE OF CALIFORNIA PERTAINING TO BINDING
ARBITRATION ALSO SHALL APPLY, AND JUDGMENT ON THE ARBITRATOR'S
DECISION MAY BE ENTERED IN ANY COURT OF COMPETENT JURISDICTION.
NEITHER PARTY MAY SEEK AN APPEAL OR REVIEW OF THE ARBITRATOR'S
DECISION EXCEPT UPON THE GROUNDS SPECIFIED IN CALIFORNIA CODE OF
CIVIL PROCEDURE SECTIONS 1285 AND FOLLOWING.
SELTZER CAPLAN McMAHON VITEK
By:
4.
Daniel E. Eaton, Vice President
APPROVED AND ACCEPTED: CITY TIONAL ITY
Dated: May\ , 2013 By:
va, City Attorney
Mayor
Ron Morrison
Council Members
Louis Natividad
Alejandra Sotelo-Solis
Mona Rios
Jerry Cano
INcoapUnATED
Office of the City Attorney
TO: City Clerk
FROM: Ginny Miller, Executive Assists
SUBJECT: Letter of Engagement for Legal rvices
City Attorney
Claudia Gacitua Silva
Deputy City Attorney
Jennifer Knight
DATE: May 16, 2013
Attached please find an original, full -executed Agreement between the City and the law firm of
Seltzer Caplan McMahon Vitek (Seltzer Caplan}for processing. A fully -executed original is
being mailed to attorney Dan Eaton at Seltzer Caplan.
Attachment
1243 National City Boulevard; National City, California 91950-4301
Tel.: (619) 336.4220 Fax: (619) 336.4327
Mayor
Ron Morrison
Council Members
Louis Natividad
Alejandra Sotelo-Solis
Mona Rios
Jerry Cano
May 16, 2013
Daniel Eaton, Esq.
Seltzer Caplan McMahon Vitek
750 B Street, Suite 2100
San Diego, CA 92101-8177
rift Rip
Office of the City Attorney
RE: Agreement for Legal Services
Dear Dan:
City Attorney
Claudia Gacitua Silva
Deputy City Attorney
Jennifer Knight
Enclosed please find a fully -executed original Agreement dated May 2, 2013, between the City
of National City and Seltzer Caplan McMahon Vitek for your files.
Very truly yours,
(4
Ginny Miller
Executive Assistant to the City Attorney
Enclosure
cc: City Clerk
1243 National City Boulevard; National City, California 91950-4301
Tel.: (619) 336.4220 Fax: (619) 336.4327