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Case No. 19STCP01402
DECLARATION OF GREGORY A. FUOCO, ESQ. IN SUPPORT OF QUINN EMANUEL URQUHART &
1 DECLARATION OF GREGORY A. FUOCO
2 I, Gregory A. Fuoco, declare as follows:
3 1. I am a member of the bar of the State of California and an associate at Quinn Emanuel
4 Urquhart & Sullivan, LLP, attorneys for petitioner Quinn Emanuel Urquhart
6 unless noted otherwise, and if called and sworn as a witness, I could and would testify competently
7 hereto.
8 2. The Court in the above-captioned matter entered a judgment against William H. Cosby,
9 Exhibit 1 is a true
10 and correct copy of the Judgment.
12 4. To date, Quinn Emanuel has not received any payment towards the Judgment from
13 Mr. Cosby. The principle amount of the Judgment remains unpaid in its entirety.
14 5. Pursuant to the Judgment, Quinn Emanuel was also awarded post-judgment interest in
15 the amount of 10% per annum. The daily amount of post-judgment interest is calculated as follows:
2 to the preparing and issuing of the abstract of judgment in connection with the Judgment on Quinn
4 8. On November 19, 2019, First Legal also remitted payment in the amount of $25.00
5 related to the issuing of the writ of execution in Los Angeles County in connection with the Judgment
7 9. On September 10, 2020, First Legal also remitted payment in the amount of $40.00
8 related to the issuing of the writ of execution in Orange County in connection with the Judgment on
10 10. Therefore, pursuant to the Judgment, the amount owed by Mr. Cosby to Quinn
11 Emanuel through and including September 9, 2020 is: $2,758,610.16 + $267,546.12+ $25.00 +
13 I declare under penalty of perjury under the laws of the State of California that the foregoing is
14 true and correct.
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Gregory A. Fuoco
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Amount subject to change based upon accrual of post-judgment interest at the daily rate of
28 $755.78 from September 10, 2020, onward, as calculated above.
-1- Case No. 19STCP01402
DECLARATION OF GREGORY A. FUOCO, ESQ. IN SUPPORT OF QUINN EMANUEL URQUHART &
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1 Quinn Emanuel Urquhart & Sullivan, LLP
Duane R. Lyons (Bar. No. 125091)
2 duanelyons@quinnemanuel.com
Claire Hausman (Bar No. 282091)
3 clairehausman@quinnemanuel.com
865 South Figueroa Street, 10th Floor
4 Los Angeles, California 90017-2543
Telephone: (213) 443-3000
5 Facsimile: (213) 443-3100
10 CENTRAL DISTRICT
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3 cross-petitioner Quinn Emanuel Urquhart & Sullivan, LLP (“Quinn Emanuel”) and against petitioner
4 and cross-respondent William H. Cosby Jr. (“Mr. Cosby”) in the amount of $2,581,183.02 (the “Final
5 Award”). The Final Award is composed of a principal amount of $2,390,870, plus $190,313.02 in
6 arbitration fees and costs. On January 16, 2019, the Final Award was served on the parties.
7 On April 19, 2019, Mr. Cosby filed a petition to vacate the Final Award (“Petition to Vacate”).
8 On May 2, 2019, Quinn Emanuel filed a response to the Petition to Vacate and a petition to
10 On April 22, 2019, Mr. Cosby filed a motion to vacate the Final Award (“Motion to Vacate”).
11 On July 8, 2019, Quinn Emanuel filed a motion to confirm the Final Award (“Motion to
12 Confirm”).
13 In the Petition to Vacate and Motion to Vacate, Mr. Cosby requested that the Court vacate the
14 Final Award entered in the arbitration and remand the case back to arbitration for rehearing before a
15 new arbitrator.
16 In the Petition to Confirm and Motion to Confirm, Quinn Emanuel requested that the Final
17 Award be confirmed by the Court, and that judgment be entered against Mr. Cosby in the amount of
18 $2,581,183.02 (principal amount of $2,390,870, plus $190,313.02 in arbitration fees and costs) plus
19 prejudgment interest in the amount of ten (10) percent per annum starting on January 14, 2019 until
20 the entry of judgment by the Court, plus post-judgment interest in the amount of ten (10) percent per
22 On September 20, 2019, the Motion to Confirm and Motion to Vacate came before the Court
23 for hearing and, with both parties having been provided the opportunity to submit written and oral
24 arguments, the Court GRANTED the Motion to Confirm and DENIED the Motion to Vacate.
25 On September 20, 2019, the Court ordered Quinn Emanuel to submit a Memorandum of Costs
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2 reviewed the Memorandum of Costs, the Court finds Quinn Emanuel’s costs of $1,340.96 are
4 NOW, having considered the Petition to Vacate, the Petition to Confirm, the Motion to Vacate
5 and associated papers, the Motion to Confirm and associated papers, the oral arguments of counsel in
6 the above-captioned action, all parties having been given notice and an opportunity to be heard, and
7 for GOOD CAUSE appearing therefore, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED
8 that Judgment is entered against petitioner and cross-respondent William H. Cosby, Jr., in favor of
9 respondent and cross-petitioner Quinn Emanuel Urquhart & Sullivan, LLP. Mr. Cosby shall pay
10 Quinn Emanuel the total amount of $2,758,610.16, which is composed of the following:
11 $2,390,870
Principal Amount of Final Award
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$190,313.02
13 Arbitration Fees and Costs in Final Award
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Prejudgment Interest (from January 14, $163,103.19
15 2019, to September 20, 2019) on Principal
Amount of Final Award
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Prejudgment Interest (from January 14, $12,982.99
17 2019, to September 20, 2019) on Arbitration
Fee and Costs in Final Award (not
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previously calculated by the Court in
19 September 20, 2019 Order)
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22 The date of this Judgment is September 20, 2019, and post-judgment interest shall accrue at
23 the rate of 10 percent per annum on the entire amount of the Judgment ($2,758,610.16), which
24 includes pre-judgment interest and costs, from September 21, 2019, until the date this Judgment is
25 paid in full.
26 IT IS SO ORDERED.
27 Dated: September 20, 2019 ______________________________
November 5, 2019 The Honorable Elaine Lu
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Judge of the Superior Court
-3- Case No. 19STCP01402
[PROPOSED] JUDGMENT