HomeMy WebLinkAboutMINUTES - 09101996 - C99 THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on SPptPmhP-r 10, 199(; by the following vote :
AYES: Supervisors Rogers, Bishop, DeSaulnier, Torlakson, Smith
NOES: None
ABSENT: None
ABSTAIN: None
SUBJECT: Approving Second Contingency Fee Agreement and Addendum
No . 1 to Contingency Fee Agreement in Tobacco Litigation
WHEREAS, the County of Contra Costa joined in litigation
initiated by the City and County of San Francisco against the t
tobacco industry to enjoin certain practices, including the
marketing of cigarettes targeted at minors; and
WHEREAS, the Board of Supervisors previously authorized the
County Counsel to retain the law firm of Lieff, Cabraser, Heimann
& Bernstein to co-counsel said litigation on a contingency fee
basis, whereby the law firm will advance all expenses in the
litigation, with the sole contingency upon which the County will
pay compensation for their services and reimburse expenses being
recovery and collection of moneys in the litigation by way of
settlement or judgment, with the County Counsel retaining the
right to add additional law firms under the retainer agreement;
and
WHEREAS, the County Counsel, San Francisco City Attorney, and
Lieff, Cabraser, Heimann & Bernstein have decided to clarify that
the law firm will not be entitled to any share of any award of
civil penalties by entering into a second, similar contingent fee
agreement covering the specific claims that the County is
asserting which may result in the collection of civil penalties,
as well as by executing an addendum to the existing fee agreement
to the same effect;
Now, therefore, it is by the Board ORDERED that :
The Second Engagement and Contingency Agreement and Addendum
No. 1 to Engagement and Contingency Agreement are APPROVED and
the County Counsel is AUTHORIZED to sign both documents .
I hereby certify that this is a true
and correct copy of an action taken
and entered on the minutes of the
Board of Supervisors on the date
shown.
Attested: (�� %O /99,4
PHIL BAfCHELOR, Clerk of the
Board of Supervisors and
County Administrator
By:
Deputy(91
VLD: ld
Orig. Dept: County Counsel (Vickie Dawes)
cc: Health Services Department
County Administrator
TL:a:\tobaco2.ord
OW
ADDENDUM NO. I TO
ENGAGEMENT AND CONTINGENCY AGREEMENT
The Engagement and Contingency Agreement between the County of Contra Costa and
Special Attorneys, dated July 22, 1996 ("the Agreement"), is hereby amended as follows:
1. Section I.. A. of the Agreement shall be amended to read as follows:
A. The Special Attorneys are retained to provide legal services to the County
Counsel for the purpose of seeking injunctive relief, monetary relief and other relief against
tobacco industry companies and related entities ("defendants") in litigation arising from the
advertising, marketing, promotion, sale and/or distribution of cigarettes ("the Litigation").
2. Section II. C. of the Agreement shall be amended to read as follows:
C. Compensation on the foregoing contingency shall be the Special Attorneys'
reasonable disbursements in the Litigation, plus 20% of any recovery collected by the Special
Attorneys in this litigation up to $25 million, and 15% of any recovery in excess of the first $25
million, provided that if any additional entities become plaintiffs in this litigation represented by
Special Attorneys,and/or if any recovery is collected by the Special Attorneys on behalf of the
County and/or co-plaintiffs on Business & Professions Code claims pursuant to the Second
Engagement and Contingency Fee Agreement dated August_, 1996, such percentages shall
apply to the aggregate recoveries on behalf of all such plaintiffs on all claims, exclusive of any
civil penalties; provided further, however, that any entities that make voluntary contributions to
finance the Litigation shall, in the discretion of the City Attorney, after consultation with the
County Counsel as well as the county counsel and city attorneys of any other counties and cities
which join as plaintiffs and retain Special Attorneys in this action, be reimbursed first in amounts
equal to their respective contributions. As used in this paragraph, the term "recovery" shall not
include amounts awarded or ordered to be paid as attorneys' fees and costs. If the Special
Attorneys recover moneys in the Litigation, but in an amount that does not exceed the
disbursements in the Litigation, such moneys shall be used to reimburse disbursements. In no
event shall Special Attorneys share in any award of civil penalties.
3. Section II. F. of the Agreement shall be amended to read as follows:
F. The claims that the County intends to assert in the Litigation provide for the
payment of attorneys' fees and costs to the County. The County intends to seek an order for
payment of its attorneys' fees and costs should it prevail, in whole or in part, in the Litigation. If
the Court in the Litigation awards attorneys' fees, such fees shall be paid to the Special Attorneys
to the extent that the award is based on services furnished by the Special Attorneys, provided that
to the extent that such fees come from the recovery, e.g., under a common fund theory, Special
Attorneys shall not receive any greater payment than they are entitled to under Sections II.C. and
II.D., above. However, any attorneys' fees that are awarded by the Court for Special Attorneys'
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services and collected in the Litigation shall be deducted from any fees payable to the Special
Attorneys by the County pursuant to this Section II, paragraphs B, C and D, above. If the Court
awards expenses and costs in the Litigation, such amount shall be applied as directed in this
Agreement. The County Counsel and the Special Attorneys are aware that the tobacco industry
has previously challenged and sought to invalidate contingency fee arrangements between certain
states and outside counsel engaged in litigation to recover their tobacco-related medical
expenditures. The County Counsel and the Special Attorneys believe that such challenges lack
merit and that this contingent fee arrangement is valid. However, in the event that this
contingent fee arrangement is found to be invalid, the Special Attorneys agree to continue to
represent the County and advance expenses with the understanding that Special Attorneys will be
paid only such attorneys' fees and expenses as are awarded for their services by the Court or
recovered as reasonable fees and expenses for their services.
4. Except as expressly amended by this Addendum No. 1 to the Agreement, the
Agreement and its attachments shall remain in full force and effect in accordance with their
terms.
Dated: Auguste 1996 CONTRA COSTA COUNTY
VICTOR J. WE AN
County Counsel
SPECIAL ASSISTANT CITY ATTORNEYS:
`j Dated: , 1996
Richard M. Heimann, Esq.
Individually and on behalf of
Lieff, Cabraser, Heimann& Bernstein, LLP
a-Q� J- CaLnc�—, Dated: �� , 1996
Elizabeth J. Cabraser, Esq.
Lieff, Cabraser,.Heimann& Bernstein, LLP
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CiCJ � sc� � �� Dated: /o , 1996
William B. Hirsch, Esq.
Lieff, Cabraser, Heimann& Bernstein, LLP
Dated: 6410 , 1996
Robert J. Nelson, Esq.
Lieff, Cabraser, Heimann &Bernstein, LLP
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JOINT PROSECUTION AND CONFIDENTIALITY AGREEMENT
1. Purpose of the Joint Prosecution and ConfidentialityAgreement
(a) Governmental entities, governmental agencies, non-profit organizations and/or
individuals have initiated and/or are considering initiating litigation against companies, individuals
and trade organizations affiliated with the tobacco industry and/or the sale of tobacco products. The
purpose of this Joint Prosecution and Confidentiality Agreement ("Agreement") is to enable the
counsel and their respective clients who are parties to this Agreement to share and exchange
information in connection with that litigation or any administrative or legislative proceedings that
arise from or relate to the same subject matter, while maintaining the confidential nature of such
information and any attorney-client privileges and/or work product protection afforded such
information. The parties to this Agreement have determined that they share common interests,
purposes and claims in connection with this litigation and any related proceedings and consider this
Agreement essential to the full investigation and effective prosecution of their claims.
2. Joint Prosecution Information
(a) All information which is exchanged between parties to this Agreement and which is.
otherwise protected under the attorney-client privilege or work product doctrine shall be referred to .
as Joint Prosecution Information. Joint Prosecution Information includes all written and oral
communications, as well as documents, writings and recordings, as those terms are broadly defined
in California Evidence Code section 250 and Rule 1001 of the Federal Rules of Evidence.
(b) The parties to this Agreement intend that Joint Prosecution Information may be
exchanged among them without any waiver or compromise of any attorney-client privilege or work-
product doctrine. The parties to this Agreement agree that Joint Prosecution Information shall be
treated and maintained as protected, privileged, confidential information.
3. Disclosure of Joint Prosecution Information
(a) Any party to this Agreement may disclose Joint Prosecution Information to any other
party to this Agreement, regardless of whether the disclosure is between counsel (including those
individuals assisting counsel), between counsel (including those individuals assisting counsel) and
client or between clients.
354.ros
Joint Prosecution and Confidentiality Agreement
(b) The parties to this Agreement further acknowledge that there shall be no disclosure of
Joint Prosecution Information, other than as described in paragraphs 3(a) and.3(e), without the
consent of the party who originally provided the information, or as required by law(and subject to
the notice provision described in paragraph 3(c)).
(c) Any party to this Agreement who receives a subpoena,discovery request or Public
Record Act request under state laws or any similar local ordinances from any person or entity
(including any party to this Agreement) seeking discovery or production of any Joint Prosecution
Information shall immediately notify all parties to this Agreement and shall not surrender any Joint
Prosecution Information(except such information originated by the subpoenaed or subpoenaing
party) without permitting all other parties to this Agreement an opportunity to protect their interests
by motion in an appropriate court.
(d) Notwithstanding the common interests, purposes and claims among the parties to this
Agreement, nothing in this Agreement shall be construed to require any party to this Agreement to
disclose privileged or work-product information which that party determines not to disclose.
Likewise, any privileged or work product information which a party to this Agreement came into
possession of independent of any other party to this Agreement may be disclosed to any third party
without application of the terms of this Agreement.
(e) If any party to this Agreement enters into a settlement with the defendant, such party
shall not disclose Joint Prosecution Information obtained under this Agreement without the express
written permission of all parties to this Agreement. If any party to this Agreement enters into a
settlement agreement with the defendant, nothing in this Agreement shall create a conflict of interest
to require the disqualification of any Counsel from the representative of their respective clients.
4. Violation of this Agreement
(a) The parties to this Agreement acknowledge that disclosure of any Joint Prosecution
Information in violation of this Agreement will cause the parties to this Agreement to suffer
irreparable harm for which there is no adequate legal remedy. The parties to this Agreement further
acknowledge that immediate injunctive relief is an appropriate and necessary remedy for the
disclosure of any Joint Prosecution Information in violation of this Agreement or the threatened
354.TOB - 2 -
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disclosure of any Joint Prosecution Information in violation of this agreement.
5. Withdrawal from this Agreement
(a) Any party to this Agreement may withdraw from it upon giving express written
notification to every other party to this Agreement. Once a party to this Agreement has given
express written notification of withdrawal from the Agreement, the Agreement shall no longer
operate as to the withdrawing party, but shall continue to protect all Joint Prosecution Information
covered by this Agreement and previously disclosed to the withdrawing party.
(b) A withdrawing party shall, to the extent permitted by law, immediately return all
Joint Prosecution Information including originals and duplicates, and any other documents or
1
records which contain or reveal Joint Prosecution Information, to the party who provided the
information.
(c) The withdrawal of a party from this Agreement shall have no effect upon the
applicability.or enforceability of this Agreement as between all other parties to the Agreement.
(d) , Each party to this Agreement acknowledges that the party is obligated to withdraw,
and agrees to withdraw, from the Agreement immediately when, in good faith, the party reasonably
believes a commonality of interest no longer exists between that party and any-of the other parties to
the Agreement.
6. Destruction or Return of All Joint Prosecution Information
(a) Within sixty (60) days after formal termination of all proceedings relating to the
litigation described in paragraph 1(a), each party to this Agreement shall, to the extent permitted by
law, destroy or return all Joint Prosecution Information including originals and duplicates, and any
other documents which contain or reveal Joint Prosecution Information, to the party who provided
the information.
7. Miscellaneous Provisions
(a) This Agreement memorializes earlier oral agreements and incorporates any.prior
written agreements between or among any of the parties to this Agreement, according to which Joint
Prosecution Information may have been exchanged. This Agreement shall apply to any such Joint
Prosecution Information which may have been previously shared among parties to this Agreement
354.TOB - 3 -
Joint
3 -
Joint Prosecution and Confidentiality Agreement
prior to their execution of this Agreement.
(b) This Agreement may be executed in counterparts, each of which shall constitute an
original and all of which taken together shall constitute one and the same agreement.
(c) This Agreement shall be governed by the laws of the State of California.
IN WITNESS THEREOF, Counsel have executed this Agreement as of the dates set
forth below.
DATED: , 1996 •
ounsel for
DATED: , 1996
Counsel for
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Joint Prosecution and Confidentiality Agreement
T
SECOND ENGAGEMENT AND CONTINGENCY AGREEMENT
This AGREEMENT is made this ,0 day of August, 1996 in the
County of Contra Costa, State. of California, by and between the
County of Contra Costa ("the County" ) acting through Victor J.
Westman, its County Counsel ( "the County Counsel" ) and the law
firm of Lieff, Cabraser, Heimann & Bernstein, LLP, San Francisco,
California, retained as Special Assistant County Counsels
( "Special Attorneys" ) .
Whereas, unfair, unlawful and deceptive acts and practices
by the tobacco industry harm the California public, including but
not limited to minors;
Whereas, _the County Counsel plans to -bring a claim in the
name of the people of the State of California against cigarette
companies and related entities, pursuant to his authority to
protect the public under the California Business and Professions
Code;
Whereas, any litigation involving tobacco-related industries
is likely to entail numerous complex factual and legal issues;
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Whereas, any such litigation will require the expenditure of
substantial resources by any private attorneys retained to assist
the County;
Whereas, the County Counsel seeks to limit the expenditure
of the County' s resources in any such litigation; now therefore
County Counsel and Special Attorneys AGREE AS FOLLOWS :
I . SCOPE OF SERVICES/CASE HANDLING
A. . The Special Attorneys are retained to provide
legal services to the County Counsel for the purpose of seeking
injunctive and other relief, including disgorgement of profits
but excluding civil penalties, against tobacco industry companies
and related entities ( "defendants") in litigation pursuant to
Business and Professions Code Sections 17200, et sect. , and 17500,
ELL sea. , arising from the advertising, marketing, promotion, sale
and/or distribution of cigarettes ("the Litigation") . The
parties intend this agreement to govern the County' s claims under
Business and Professions Code Section 17500, et s_aq. ,
rather than the Engagement and Contingency Agreement
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dated July 22,1996, insofar as they differ.
B. The County Counsel, as the chief legal officer of
the County, together with the San Francisco City Attorney and the
County Counsel and City Attorneys of any other counties and
cities which join as plaintiffs and retain Special Attorneys in
this action, retains final authority over all aspects of the
Litigation.
C. As provided herein, the Special Attorneys are
authorized to take appropriate l-egal steps to prosecute the
Litigation as it pertains to liability, injunctive relief and
restitution/disgorgement of profits and participate in any
settlement negotiations . The County Counsel shall designate a
member or members of his staff to monitor, review and participate
as counsel in the prosecution of all aspects of the Litigation
and to prosecute the Litigation as it pertains to civil
penalties . The Special Attorneys shall consult in advance with,
and obtain the prior approval of, the San Francisco City
Attorney, who in turn shall consult with the County Counsel as
well as the county counsel and city attorneys of any other
r
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J 1F
counties and cities which join as plaintiffs and retain Special
Attorneys in this action, concerning all substantive matters
related to the Litigation, including, but not limited to, the
complaint and dispositive motions, selection of consultants and
experts, and whether the Special Attorneys may represent
additional co-plaintiffs in the Litigation. Special Attorneys
shall inform the County Counsel or his designee in advance of all
significant meetings with third parties that concern or
potentially affect the Litigation. Regular status meetings shall
be held as requested by either the County Counsel or the Special
Attorneys .
D. The Special Attorneys shall provide the County
Counsel with copies of all correspondence, pleadings, and
discovery requests and responses related to the Litigation.
E. The Special Attorneys shall communicate with the
County' s departments through the County Counsel unless
alternative arrangements are made in advance among the Special
Attorneys, the County Counsel and the department (s) . Where
written communications from the Special Attorneys to state
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agencies are authorized, the County Counsel shall be provided
with copies of those communications .
F. The Special Attorneys shall provide sufficient
resources, including attorney time and capital for payment of
expenses, to prosecute the Litigation faithfully and with due
diligence . Legal services under this Agreement shall be
performed only by competent personnel under the supervision and
in the employment of Special Attorneys or retained by Special
Attorneys as consultants with the approval of the San Francisco
City Attorney,, after consultatioL,with the County Counsel as well
as the county counsel and city attorneys of any other counties
and cities which join as plaintiffs and retain Special Attorneys
in this action. Prior to executing this Agreement, the Special
Attorneys shall provide to the County Counsel or his designee a
specific written description of the actual attorney and paralegal
resources that the firm will devote to the Litigation. Any
change in this commitment shall be made only with the prior
written agreement of the San Francisco City Attorney, after
consultation with the County Counsel as well as the county
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counsel and city attorneys of any other counties and cities which
join as plaintiffs and retain Special Attorneys in this action.
G. The San Francisco City Attorney, after
consultation with the County Counsel as well as the county
counsel and city attorneys of any other counties and cities which
Join as plaintiffs and retain Special Attorneys in this action,
retains the right to add not more than five firms as additional
Special Attorneys in this Litigation, who shall share in such
compensation, if any, as is provided to Special Assistants
pursuant to Section II of this Agreement . In the event that the
Special Attorneys are unable to agree on the terms under which .
the new firms shall share in the compensation, the San Francisco
City Attorney, after consultation with the County Counsel as well
as the county counsel and city attorneys of any other counties
and cities which join as plaintiffs and retain Special Attorneys
in this action, shall decide and such decision shall be final and
binding on all the Special Attorneys . In addition, the San
Francisco City Attorney, after consultation with the County
Counsel as well as the county counsel and city attorneys of any
other counties and cities which join as plaintiffs and retain
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Special Attorneys in this action, retains the right to add as
many attorneys and firms as she chooses who agree to participate
on a pro bono publico basis, without sharing in the percentages
of any recovery provided in Section II .C. , below, or seeking
court-awarded fees payable from the recovery of damages or
penalties, e.g. , under a common fund theory. However, such pXQ
bono counsel shall be eligible on the same basis as the Special
Attorneys to recover their reasonable disbursements as provided
under Section II .B . and Section II . C. , below, and may seek court-
awarded fees payable by defendants in addition to any recovery.
H. The Special Attorneys agree that in the event that
additional attorneys or law firms are retained to participate in
the Litigation as Special Attorneys, the San Francisco City
Attorney, after consultation with the County Counsel as well as
the county counsel and city attorneys of any other counties and
cities which join as plaintiffs and retain Special Attorneys in
this action, may determine in her discretion to appoint an
Executive Committee to oversee the day-to-day conduct of the
Litigation. The Executive Committee shall include : a designee of
the County Counsel; Richard M. Heimann, Esq. (or designee) ; and
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any additional members that the San Francisco City Attorney
designates, after consultation with the County Counsel as well as
the county counsel and city attorneys of any other counties and
cities which join as plaintiffs and retain Special Attorneys in
this action. The San Francisco City Attorney, after consultation
with the County Counsel as well as the county counsel and city
attorneys of any other counties and cities which join as
plaintiffs and retain Special Attorneys in this action, retains
the right to determine the number and membership of the Executive
Committee .
I . The San Francisco City Attorney, after
consultation with the County Counsel as well as the county .
counsel and city attorneys of any other counties and cities which
join as plaintiffs and .retain Special Attorneys in this action,
retains the right to designate lead counsel and lead trial
counsel in the Litigation on the claims for injunctive relief and
restitution/disgorgement of profits. The County Counsel,
together with city and county counsel for any co-plaintiff cities
and counties, shall prosecute this Litigation as it pertains to
civil penalties . In her sole discretion, after consultation with
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the County Counsel as well as the county counsel and city
attorneys of any other counties and cities which join as
plaintiffs and retain Special Attorneys in this action, the San
Francisco City Attorney may require that during the time period
that any firm is designated as a lead counsel, it shall devote at
least the equivalent of two full-time attorneys to the Litigation
on an ongoing basis and such additional, attorney and paralegal
resources as she deems appropriate from time to time to meet the
needs of the Litigation.
J. . The Special Attorneys agree to maintain
contemporaneous time and expense records . The Special Attorneys
shall submit quarterly statements to the County Counsel setting
forth for that period the hours and services devoted to the
Litigation, and all disbursements . Where disbursements are made
by Special Attorneys which also benefit other clients of Special
Attorneys in other, similar litigation, only the portion of such
disbursements fairly and properly allocable to plaintiffs in this
action shall be claimed as reasonable expenses of prosecuting
this action.
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K. Audit and Inspection: The Special Attorneys agree
to maintain and make available to the County Counsel accurate
books and accounting records relative to its activities under
this Agreement . The Special Attorneys will permit the County
Counsel to audit, examine and make excerpts and transcripts from
such time and expense records, payrolls, records of personnel and
other documents and data related to in whole or in part matters
covered by this Agreement . The Special Attorneys shall maintain
such data and records in an accessible location and condition for
a period of no less than one (1) year after final payment under
this Agreement .
II. CONTINGENT FEE AGREEMENT
A. The Special Attorneys shall advance all expenses
in the Litigation, including payment of reasonable travel
expenses for travel by the County Counsel' s designated staff on
the Litigation following advance consultation with Special
Attorneys . The County is not liable to pay any of the expenses
of the Litigation, whether such expenses are attorneys' fees,
costs or other amounts, except as provided in the remaining
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paragraphs of this Section II (B, C, D, E, F and G) . The
repayment of costs and other expenses is contingent upon a
recovery being obtained. If no recovery is obtained, the County
owes nothing for costs and other expenses.
B. The sole contingency upon which the County shall
pay compensation to the Special Attorneys is the recovery and
collection by the Special Attorneys on behalf of the County of
moneys in the Litigation, whether by settlement or judgment .
C. Compensation on the foregoing contingency shall be
the Special Attorneys, reasonable disbursements in the
Litigation, plus 200 of any recovery collected by the Special
Attorneys in this litigation up to $25 million, and 150 of any
recovery in excess of the first $25 million, excluding civil
penalties, provided that if any additional entities become
plaintiffs in this litigation represented by Special Attorneys
and/or if any recovery is collected by the Special Attorneys on
behalf of the County and/or co-plaintiffs in litigation pursuant
to the Engagement and Contingency Fee Agreement, dated July 22 ,
1996, such percentages shall apply to the aggregate recoveries,
exclusive of civil penalties, on behalf of all such plaintiffs;
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provided further, however, that any entities that make voluntary
contributions to finance the Litigation shall, in the discretion
of the City Attorney, be reimbursed first in amounts equal to
their respective contributions . As used in this paragraph, the
term "recovery." shall not include amounts awarded or ordered to
be paid as attorneys' fees and costs . If the Special Attorneys
recover moneys in the Litigation, but in an amount that does not
exceed the disbursements in the Litigation, such moneys shall be
used to reimburse disbursements . In no event shall Special
Attorneys share in any recovery of civil penalties pursuant to
Business and Professions Code Sections 17206 and/.or 17536 .
D. Notwithstanding paragraph II .A. above, the County
shall pay no higher percentage for compensation of the Special
Attorneys than is paid by any other co-plaintiff that the Special
Attorneys represent in the Litigation or any other county and/or
city that the Special Attorneys represent on a contingent fee
basis .
E. As used in this Agreement, the term
"disbursements" shall include reasonable travel expenses,
telephone charges, copying charges, fax charges, deposition
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costs, investigator costs, messenger service costs, mediation
expenses, computer research fees, medical or nursing consultation
fees, expert fees, other consultation fees and all other
reasonable out-of-pocket costs incurred in the Litigation.
Reasonable costs do not include mark-ups above actual costs,
meals not connected with travel or costs of transportation
between Special Attorneys' residences and offices or
disbursements for travel expenses and accommodations that exceed
the usual and customary business rate charged in the locality
where such expenses are incurred.
F. Plaintiffs intend to seek an order for payment of
their attorneys' fees and costs should they prevail, in whole or
in part, in the Litigation. If the Cburt in the Litigation
awards attorneys' fees, such fees shall be paid to the Special
Attorneys to the extent that the award is based on services
furnished by the Special Attorneys; provided that, to the extent
that such fees come from the recovery, e.g. , under a common fund
theory, Special Attorneys shall not receive any greater payment
than they are entitled to under Sections II .C. and II .D. , above.
However, any attorneys' fees that are awarded by the Court for
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Special Attorneys' services and collected in the Litigation shall
be deducted from any fees payable to the Special Attorneys
pursuant to this Section II, paragraphs B, C and D, above. If
the Court awards expenses and costs in the Litigation, such
amount shall be applied as directed in this Agreement . The
County Counsel and the Special Attorneys are aware that the
tobacco industry has previously challenged and sought to
invalidate contingency fee arrangements between certain states
and outside counsel engaged in litigation to recover their
tobacco-related medical expenditures . The County Counsel and the
Special Attorneys believe that suQh challenges lack merit and
that this contingent fee arrangement is valid. However, in the
event that this contingent fee arrangement is found to be
invalid, the Special Attorneys agree to •continue to represent the
County and advance expenses with the understanding that Special
Attorneys will be paid- only such attorneys, fees and expenses as
are awarded for their services by the Court or recovered as
reasonable fees and expenses for their services .
G. In the event that the Litigation is resolved by
settlement under terms involving the provision of goods, services
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or any other "in-kind" payment, the County Counsel agrees to
seek, as part of any such settlement, a mutually agreeable
monetary settlement of attorneys fees and expenses . The County
Counsel agrees to consult with the Special Attorneys prior to
making a recommendation to the Board of Supervisors regarding
settlement or dismissal of legal proceedings .
III. GENERAL REQUIREMENTS
A. The Special Attorneys shall attach to this
Agreement a copy- of the resumes of Elizabeth J. Cabraser, Richard
M. Heimann, William B. Hirsch, Robert J. Nelson, and all other
key personnel assigned by the Special Attorneys to handle the
Litigation. The Special Attorneys shall replace or remove key
personnel only upon.'. the prior written approval of the San
Francisco City Attorney, after consultation with the County
Counsel as well as the county counsel and city attorneys of any
other counties and cities which join as plaintiffs and retain
Special Attorneys in this action.
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1 A J
B. The County acknowledges that by this Agreement
Special Attorneys are retained as attorneys and that neither
Special Attorneys nor their members or employees thereby become
officers or employees of the County. Special Attorneys shall be
deemed at all times to be independent contractors and shall be
wholly responsible for the manner in which they perform the
services required of them by the terms of this Agreement .
Special Attorneys shall be liable for any act or acts of their
own, or their agents or employees, and nothing contained herein
shall be construed as creating the relationship of employer and
employee between- the County and ',Special Attorneys or their agents
and employees .
C. Assignment : This Agreement may not be assigned by
the Special Attorneys . The Special Attorneys are' expressly
employed because of their unique skills, ability and experience
and therefore it is understood that no substitution or assignment
may be made unless the San Francisco City Attorney, after
consultation with the County Counsel as well as the county
counsel and city attorneys of any other counties and cities which
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join as plaintiffs and retain Special Attorneys , in this action,
expressly approves such substitution or assignment .
D. The Special Attorneys are prohibited from
subcontracting this Agreement or services unless such
subcontracting is agreed to in writing by ,the San Francisco City
Attorney, after consultation with the County Counsel as well as
the county counsel and city attorneys of any other counties and
cities which join as plaintiffs and retain Special Attorneys in
this action. No party on the basis of this Agreement shall in
any way contzact• on behalf .of or—in the name of the other party
of this Agreement . Any violation of this provision shall confer
no right on any party and shall be void.
E. Insurance: Special Attorneys will maintain in
force, during the full term of this Agreement, insurance in the
following amounts and coverage :
1 . Workers' Compensation, with Employers' Liability limits
not less than one million dollars ($1, 000, 000) each
accident .
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2 . Commercial General Liability Insurance with limits not
less than one million dollars ($1, 000, 000) each
occurrence . Combined Single Limit for Bodily Injury and
Property Damage, including Contractual Liability,
Personal Injury, Products and Completed Operations .
3 . Business Automobile Liability Insurance with limits not
less than one million dollars ($1, 000 , 000) each
occurrence combined Single Limit for Bodily Injury and
Property Damage, including Owned and Non-owned and hired
auto coverage, as applicable .
4 . Professional Liability Ifisurance with limits not less
than one million dollars ($1, 000, 000) each claim with
respect to negligent acts, errors or omissions, and any
deductible not to exceed two hundred fifty thousand
dollars ($250 , 000) each claim.- The Special Attorneys
certify that the services that the Special Attorneys will
be performing in connection with the Litigation are
covered by their firm' s Professional Liability Insurance .
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F. Commercial General Liability and Business
Automobile Liability Insurance policies shall be endorsed to
provide the following:
1 . Name as Additional Insured the County, its Officers,
Agents, and Employees .
2 . That such policies are primary insurance to any other
insurance available to the Additional Insureds, with
respect to any claims arising out of this contract, and
that insurance applies separately to each insured against
whom claim is made or sui_t, is brought .
G. ALL POLICIES SHALL BE ENDORSED TO PROVIDE:
Thirty (30) days advance written notice to the County
of cancellation, non-renewal or reduction in coverage .
H. Certificates of insurance, satisfactory to the
County, evidencing all coverages above shall be furnished to the
County before commencing any operations under this Agreement,
with complete copies of policies upon the County' s request .
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I . Approval of the insurance by the County shall not
relieve or decrease the liability. of the Special Attorneys .
J. Indemnity: The Special Attorneys shall take full
responsibility for their work and shall bear all losses and
damages directly resulting from it if the result of professional
malpractice . The Special Attorneys shall assume the defense of,
indemnify and hold harmless the County and its officers,
representatives, agents and employees from all claims, loss,
damage, injury, and liability of every kind, nature and
description gaused by the willful ,and intentional misconduct or
negligence of the Special Attorneys . Such negligence shall
include, but not be limited to, any negligence of the Special
Attorneys in connection with acts, errors or omissions by the
Special Attorneys' agents, employees or subcontractors arising
out of performance under, or any action taken in furtherance of,
this Agreement . Nothing in this paragraph shall limit any right
or remedy otherwise available to the County under law. It is
understood and agreed that the indemnification provided above
shall not apply to the extent of any negligence of the County and
its officers, representatives, agents and employees .
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K. Liability of The County: The County' s obligations
under this contract shall be limited to the payment of the
compensation provided for in this Agreement . Notwithstanding any
other provision of this Agreement, in no event shall the County
be liable, regardless of whether any claim is based on contract
or tort, for any special, consequential, indirect or incidental
damages, including, but not limited to, lost profits, arising out
of or in connection with this Agreement or the services performed
in connection with this Agreement.,
L. During the term of this Agreement, the Special
Attorneys shall promptly provide a statement describing any
criminal investigation relating to, or material litigation
asserted against, the Special Attorneys' firm or members of the
firm.
M. Each California Special Attorney firm .shall
certify in writing, under penalty of perjury, that the firm has
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fully complied with the laws of the California and the County, if
applicable, relating to payment of taxes .
N. The Special Attorneys shall list and describe any
litigation or representation ever undertaken by their firm or its
members on behalf of any member of the tobacco industry.
O. Conflicts of Interest: The Special Attorneys shall
avoid conflicts of interest and shall comply with all applicable
professional conduct standards . The Special Attorneys shall not
represent a party involved in a Claim, dispute or transaction of
any kind which would create a conflict of interest for counsel or
the County Counsel unless and until the Special Attorneys have
informed the• County Counsel of the proposed representation and
received his .written approval to proceed. Special Attorneys
state that they are familiar with provisions of Section 87100 et
seq. of the Government Code of the State of California, and
certify that they do not know of any facts which constitute a
violation of those sections .
P. Termination:
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1 . Without Cause: The County Counsel may
terminate this Agreement as to any Special
Attorneys, without cause and without penalty, by
providing the Special Attorneys with written
notice of termination delivered to it at least
fourteen (14) calendar days before the effective
date of termination.
2 . For Cause : If any Special Attorneys breach
any material term or condition of this Agreement ,
or fails to perform or fulfill any material
obligation required by this Agreement, then the
County Counsel may give notice to the Special
Attorneys of his intent to terminate or suspend
those Special Attorneys by providing at least
seven (7) calendar days written notice of an
intent to terminate or suspend. If the Special
Attorneys do not substantially cure or correct
such breach or failure to perform or fulfill any
material obligation within seven (7) calendar days
after receipt of such written notice from the
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County Counsel, or within such longer period as
the County Counsel might prescribe in writing,
then the County Counsel may thereafter terminate
the Special Attorneys or suspend the Special
Attorneys . In any event, the County Counsel
reserves the right to terminate immediately any
Special Attorneys who are (a) disbarred or
suspended in any jurisdiction, (b) indicted by a
grand jury, or (c) convicted of a felony.
3 . Consequences—of Termination: If any Special
Attorneys are terminated for cause, such Special
Attorneys shall not be entitled to compensation or
reimbursement of any kind under this Agreement .
If any Special Attorneys are terminated for
reasons other than "cause" , such Special Attorneys
shall be entitled (1) to be reimbursed reasonable
out-of-pocket costs that they incurred, but only
if and to the extent and at the time such amounts
would otherwise be payable pursuant to Section II,
above, and (2) to be paid such compensation as
2 4
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t
might be payable to them in accordance with this
Agreement and any fee sharing arrangement among
them and any additional Special Attorneys, but
only if, and to the extent and at the time,
compensation is payable to the Special Attorneys
from any recovery in the Litigation pursuant to
Section II of this Agreement .
Q. Confidentiality: The Special Attorneys understand
and agree that, in the performance of this Agreement, the Special
Attorneys may have access to private or- confidential information,
including confidential patient medical information, which may be
owned or controlled by the County and that such information may
contain proprietary or confidential details, whose disclosure to
third parties may be damaging to the County•or prohibited by law.
The Special Attorneys agree that such information shall be held
in confidence and used only in performance of the Agreement and
shall not to be furnished to others by Special Attorneys except
as authorized by the County Counsel or as required by law.
R. Notice to the Parties : All notices and copies of
documents to be given by the parties hereto shall be in writing
2 5 n:\lit\elaporte\tobacco\contfeeb\contraco.bip
and served by depositing same in the United States Post Office,
postage prepaid and registered as follows :
TO THE COUNTY COUNSEL: Office of the County Counsel
651 Pine Street, 9th Floor
Martinez, CA 94553
Attention: Vickie Dawes
2 6 n:\lit\elaporte\tobacco\contfeeb\contraco.b&p
TO SPECIAL ATTORNEYS : Lieff, Cabraser, Heimann
& Bernstein, LLP
Embarcadero Center West
275 Battery Street, 30th Floor
San Francisco, California 94111
S . Forum and Choice of Law: Any actions arising out
of this Agreement shall be governed by the laws of California,
and shall be brought and maintained in San Francisco Superior
Court, which shall have exclusive jurisdiction thereof, except
that any action concerning issues that solely affect the County
and do not affect other counties or cities that have joined in
the Litigation shall be brought and maintained in Contra Costa
Superior Court, which shall have exclusive jurisdiction thereof .
T. . If any provision of the Agreement is found to be
illegal, unenforceable, or void, then the parties shall be
relieved of all obligations under that provision, provided,
however, that the remainder of the Agreement shall be enforcedto
the fullest extent permitted by law. The headings used herein
are for reference and convenience only and shall not be a factor
in the interpretation of this Litigation.
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U. This Agreement may not be modified, nor may
compliance with its terms be waived, except by written instrument
executed and approved by the County Counsel or his designee and
by authorized representatives of all parties to be bound or
affected thereby.
V. Entire Agreement : This contract sets forth the
entire Agreement between the parties, and supersedes all other
oral or written provisions .
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J
IN WITNESS WHEREOF, the County Counsel and the Special
Attorneys have executed this Agreement on the day and year first
written above .
COUNTY OF CONTRA COSTA:
ICTOR J. jzS&P
County Counsel
SPECIAL ASSISTANT CITY ATTORNEYS :
Richard M. Heimann, Esq.
Individually and on behalf of
Lieff, Cabraser, Heimann & Bernstein, LLP
El'i.zabeth J. Cabraser, Esq.
Lieff, Cabraser, Heimann & Bernstein, LLP
William B. Hirsch, Esq.
Lieff, Cabraser, Heimann & Bernstein, LLP
Robert J. Nelson, Esq.
Lieff, Cabraser, Heimann & Bernstein, LLP
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ti
RESUMES OF SPECIAL ATTORNEYS
ELIZABETH J. CABRASER, born Oakland, California, June 23, 1952, admitted to bar,
1978, California and U.S. District Court,Northern District of California, 1979; California
Supreme Court, 1978. Also admitted to: Northern, Eastern, Central and Southern Districts of
California; Second, Third, Fifth, Sixth,Ninth, Tenth and Eleventh Circuit Courts of Appeals;
United States Tax Court, 1979; District of Hawaii, 1986; District of Arizona, 1990. Education:
University of California at Berkeley (A.B., 1975); Boalt Hall School of Law, University of
California (J.D., 1978). Author: "Mandatory Certification of Settlement Classes," 10 Class
Action Reports 151 (1987); "The Applicability of the Fraud-On-The-Market Theory to
'Undeveloped' Markets: When Fraud Creates the Market," 12 Class Action Reports 402 (1989);
"How To Streamline Complex Litigation: Tailor a Case Management Order to Your
Controversy," 21 The Brief 12 (ABA/TIPS Summer 1992); "Mass Tort Class Action
Settlements," 24 CTLA Forum I I (Jan./Feb. 1994); "Do You Know the Way from San Jose?
The Evolution of Environmental and Toxic Nuisance Class Actions," Class Actions &Derivative
Suits, ABA Section of Litigation (Spring 1994). Member: American Law Institute; American
Bar Association: ABA Tort and Insurance Practice Section (TIPS), ABA Section of Litigation
Committee on Class Actions & Derivative Skills; Chair, Subcommittee on Mass Torts;
California Constitution Revision Commission; National Center for State Courts Mass Tort
Conference Planning Committee; Association of Trial Lawyers of America, Women Trial
Lawyers Caucus; Consumer Attorneys of Califoriiia; Bar Association of the Fifth Federal
Circuit; California Women Lawyers; Association of Business Trial Lawyers; Bar Association of
San Francisco, Vice President, Securities Litigation Section. National Association of Securities
& Commercial Attorneys (NASCAT); Bay Area Lawyers for Individual Freedom;"Lawyer-
Delegate, Ninth Circuit Judicial Conference 1992-1995;Northern District of California.Civil
Justice Reform Act(CJRA)Advisory Committee, and Advisory Committee on Professional
Conduct.
RICHARD M HEIMAAW, born Miami, Florida, August 23, 1948; admitted to bar,
1972; Pennsylvania, 1974, District of Columbia; 1975, California, U.S. District Court,Northern
District of California and U.S. Court of Appeals,Ninth Circuit; 1980, U.S. Court of Appeals,
Second Circuit; 1986, U.S. District Court, District of Hawaii. Education: University of Florida
(B.S.B.A., with honors, 1969); Georgetown University (J.D., 1972). Member, Georgetown Law
Journal, 1971-1972. Member: Pennsylvania Bar Association; State Bar of California.
Mr. Heimann served as Deputy District Attorney and Acting Assistant District Attorney for
Tulare County, California, in which capacity he tried 25-35 jury cases. As a Public Defender in
Philadelphia, Pennsylvania(1972-74)he tried 10-20 jury cases and over 50 non jury criminal
cases. As a private attorney,.Mr. Heimann has tried over 30 civil jury cases, including complex
cases such as the successful FPI/A reg tech securities class action trial.
J
LCH\SPECIAL.LCH - I -
WILLIAM B. HIRSCH, born Los Angeles, California,May 19, 195 1; admitted to bar,
1983, California; U.S. District Court,Northern District of California; U.S. District Court, District
of Hawaii (1991). Education: University of California at Santa Cruz(B.A., with highest honors,
1973); Princeton University (M.A., 1975); Harvard University (J.D., 1983). Member: Bar
Association of San Francisco; State Bar of California; Barristers Club of San Francisco;
California Trial Lawyers Association;National Association of Securities and Commercial Law
Attorneys (Executive Committee, 1991-1994); ACLU of Northern California Lawyers' Counsel
(Steering Committee, 1993-94). Honors: 1995 Trial Lawyer.of the Year Award, awarded by
Trial Lawyers for Public Justice. Frequent lecturer on product liability and mass tort class
actions.
ROBERT J. NELSON, born New York,New York, October 20, 1960; admitted to bar,
1987, California; 1987, U.S. District Court, Central District of California; 1988,U.S. District
Court,Northern District of California; 1988, U.S. Court of Appeals, Ninth Circuit; 1995, U.S.
Court of Appeals, Sixth Circuit. Education: Cornell University (A.B., cum laude 1982);
London School of Economics (General Course, 1980-81);N.Y.U. School of Law(J.D., 1987).
Member, Phi Beta Kappa, Cornell. Member, College Scholar Honors Program, Cornell. Root-
Tilden Scholarship Program,N.Y.U. School of Law. Order of the Coif, N.Y.U. School of Law.
Articles Editor,New York University Law Review. Author: "To Infer or Not to Infer a
Discriminatory Purpose: Rethinking Equal Protection Doctrine," 61 New York University Law
Review 334, 1986. Judicial Clerk, Judge Stephen Reinhardt, Ninth Circuit Court of Appeals,
1987-1988. Assistant Federal Public Defender,Northern District of California, 1988-1993.
Legal Research and Writing Instructor, University of California-Hastings College of the Law,
1989-1991. Faculty Member, Stanford Advocacy Skills Workshop, 1994 to present. Member:
State Bar of California; Association of Trial Lawyers of America.
LW\SPECIAL.LCH - 2 -