Brinkman

BACKGROUND

The General Setting In March 2019, represented by Erin Brinkman, Doe filed in the United States District Court a class action lawsuit naming a bank as defendant (the federal action). The federal action alleged that the bank, which came to be identified as Bank One,1 unlawfully discriminated against Doe and the putative class by denying them the ability to open an account because of their United States citizenship status. The complaint stated causes of action under the Unruh Act (Civ. Code, § 51 et seq.) and the Civil Rights Act of 1866 (42 U.S.C. § 1981), and sought statutory damages under the Unruh Act of $4,000 for Doe and the members of the putative California class, an award of attorney fees, and punitive damages. In February 2020, Doe retained additional counsel to represent her along with Ms. Brinkman: the firm of Lieff Cabraser Heimann & Bernstein LLP (Lieff Cabraser). When referred to collectively, Ms. Brinkman and Lieff Cabraser will, for consistency with the briefing, will be called Attorneys. When Lieff Cabraser became involved, Anne Shaver, an attorney at that firm, prepared a fee agreement and sent it to Ms. Brinkman for execution by Doe. On February 14,…