AFFIDAVIT IN SUPPORT OF FEE SCHEDULE

Eun Jung Lim

 

Irvine, California [92623]

invokemyright@protonmail.com

Plaintiff in Pro Per

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE

EUN JUNG LIM,

              Plaintiff,

              v.

HOAG MEMORIAL HOSPITAL PRESBYTERIAN; and HERBERT CONRAD, in his official and individual capacity,

             Defendants.

 Case No.: 30-2022-01242187

AFFIDAVIT IN SUPPORT OF FEE SCHEDULE

 

AFFIDAVIT IN SUPPORT OF FEE SCHEDULE

 

I, EUN JUNG LIM, hereby state as follows:

  1. I am the Plaintiff in the above captioned case. 
  2. I am over the age of 18 years and am a party to this action.
  3. I have personal knowledge of the facts stated in this declaration, and if called as a witness, could and would testify competently to the truth of the facts as stated herein.
  4. I filed an action against the Defendants on or about January 25, 2022.
  5. On or about March 8, 2022, Defendant Hoag Memorial Hospital Presbyterian’s attorney filed an Answer to my Complaint.
  6. I filed a Motion for Summary Judgment on or about March 16, 2022. In addition to the grounds in the said Motion, I also allege that I am entitled to Summary Judgment because the Defendant replied to my Complaint past the 30 days’ time limit. Notably, I served the Summons on the Defendant on February 2, 2022. The Defendant had 30 days to respond according to the law. However, Defendant filed an answer on or about March 8, 2022. Further, Defendant filed an incorrect proof of service by email. Specifically, my email is incorrect in the said proof of service.
  7. I do hereby set forth fees to be instated from the date of Injury January 25, 2020 against the Defendants.
  8. The fees are subject to change at any time without prior notice. Eun Jung Lim is the only authorized soul to alter, void, and/or enforce said fees and may do so at any time.
  9. WHEREAS I TESTIFY THAT THIS CONTRACT IS LEGALLY AND LAWFULLY BINDING AND IS NON-NEGOTIABLE.
  10. WHEREAS this is a formal notice of a fee schedule for all lawful and unlawful matters relating to Case No.: 30-2022-01242187. 
  11. The fee will accrue as follows starting January 25, 2020:
  • $ 1,440,000 per day staring January 25, 2020 (every minute attracting $1000)
  • The $ 1,440,000.00 is arrived at by multiplying the number of minutes in a day (1 day = [24 hours/day] × [60 minutes/hour] = 1440 by the fee per minute ($1000). 
  • For each filing to court services:                                      $ 25,000.00 
  • For each vehicle transportation to courthouse or attorney: $25,000.00 
  • For each Deposition hearing:                                           $100,000 .00
  • For each letter that I have to write to DEFENDANTS
    and/or AGENTS:     $7,000.00
                                               
  • For each letter I receive and read from DEFENDENTS AND/OR AGENTS RESPONDENTS/AGENTS/demands:             $7,000.00
  • For each demand I need to reply:                                     $ 7,000.00
  • For each phone call I have to make to relevant bodies: $7000; Plus $500 per hour
  • Every Appearance in court:      $500,000
  • Time in Court:                                                                 $75,000/hour with 1 hour min.
  • Any documents produced by me:                                     $90,000.00
  • Produce any personal information for any kind :
  • Financial Information:               $500,000
  • Driver’s License:               $1,000,000.00
  • Social Security Number             $ 1,000,000.00
  • Any documents produced by me             $10,000.00 per document

Legal Arguments

Exemplary fees and/or punitive damages may be granted, by way of punishing the defendant, in an action for the breach of an obligation not arising from contract, where it is proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud, or malice. See Cal. Civ. § 3294(a). 

The decision to award punitive damages is exclusively the function of the trier of fact. So too is the amount of any punitive damage award. The relevant considerations are the nature of the defendant’s conduct, the defendant’s wealth, and the plaintiff’s actual damages. Gagnon v. Continental Casualty Co., 1989 211 Cal.App.3d 1598, 1602 [260 Cal.Rptr. 305].

By placing the defendant’s conduct on one occasion into the context of a business practice or policy, an individual plaintiff can demonstrate that the conduct toward him or her was more blameworthy and warrants a stronger penalty to deter continued or repeated conduct of the same nature. Izell v. Union Carbide Corp. (2014) 231 Cal.App.4th 962, 986, fn. 10[180 Cal.Rptr.3d 382].

The Plaintiff asserts that the conduct of the Defendants was so capricious and arbitrary that the Plaintiff is entitled to punitive damages. Further, the actions and/or inactions of the Defendants have caused the Plaintiff notable harm and/or damage, thus warranting the punitive damages to punish the Defendants. 

Conclusion

Given the facts provided within this Affidavit, and pursuant to 28 USC § 1746(1), I move the fee schedule to be admitted and the defendants be sanctioned for bringing a irrelevant and erroneous response before this Court, and my summary judgment be ordered.

I therefore declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. 

Executed on this the 21st day, of the 3rd month, in the year of our Lord and Savior, two thousand twenty two.

 

CERTIFICATE OF SERVICE

I hereby certify that on [ENTER DATE], copies of the foregoing document have been sent to the Defendant in the following address:

 

CARROLL, KELLY, TROTTER & FRANZEN 

MICHAEL J. TROTTER (SBN 139034) 

JO LYNN VALOFF (SBN 177081) 

111 West Ocean Boulevard, 14th Floor 

Post Office Box 22636 

Long Beach, California 90801-5636 

Telephone No. (562) 432-5855 / Facsimile No. (562) 432-8785 

mjtrotter@cktflaw.com / jlvaloff@cktflaw.com 

Attorneys for Defendant, Hoag Memorial Hospital Presbyterian

 

DATED: ______________     

   

 

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