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MC-350
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
| Mark Hooshmand, Esq. (SBN 194878); Tyson Redenbarger, Esq. (SBN 294424)
22 Battery Street, Suite 610
San Francisco, CA 94111
ELECTRONICALLY
TELEPHONENO: (415) 318-5709 FAXNO. (Optonay: (415) 376-5897 FILED
E-MAL ADDRESS (Optonel: Mark@lawmmh.com Superior Court of California,
ATTORNEY FOR Wome: Plaintiffs Angelique, et al. County of San Francisco
San Franck 03/21/2018
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco Clerk of the Court
street aopress: 400 McAllister Street BY: ANNIE PASCUAL
maiLincappress: 400 McAllister Street Deputy Clerk
cITy AND zip cope: San Francisco 94102
BRANCH NANE: Civic Center
CASE NAME: ‘CASE NUMBER:
Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
P : HEARING DATE
ETITION TO APPROVE: COMPROMISE OF DISPUTED CLAIM April 3, 2018
[7] COMPROMISE OF PENDING ACTION
(—_] DISPOSITION OF PROCEEDS OF JUDGMENT
Minor Person With a Disability
NOTICE TO PETITIONERS:
Except as noted below, you must use this form to request court approval of (1) the compromise of a disputed claim of a minor,
(2) the compromise of a pending action or proceeding in which a minor or a person with a disability (including a conservatee) is a
party, or (3) the disposition of the proceeds of a judgment for a minor or person with a disability. (See Code Civ. Proc., § 372; Prob.
DEPT: 514, THE: 9-00) am
Code, § 3600 et seq.) You and the minor or disabled person must attend the hearing on this petition unless the court for good cause
dispenses with a personal appearance. The court may require the presence and testimony of witnesses, including the attending or
examining physician, and other evidence relating to the merits of the claim and the nature and extent of the injury, care, treatment,
and hospitalization. The court may consider on an expedited basis without a hearing requests for approval of the compromises of
certain claims and actions or the disposition of the proceeds of certain judgments. if your claim, action, or judgment qualifies for
expedited consideration and you want to request it, you must use form MC-350EX for your request. See Cal. Rules of Court, rule
7.950.5.
1, Petitioner (name): Angelique Rochelle
2. Claimant (name): Ella Rochelle- Lawton
a. Address: 808A Lyon Street, San Francisco, CA
b. Date of birth: April 9, 2000 c. Age:17 d. Sex: Female ¢ [7] minor [1] Person with a disability
3. Relationship Petitioner's relationship to the claimant (check all applicable boxes):
a Parent 9. Other relationship (specify:)
b. Guardian ad litem
c. Guardian
d. Conservator
e. Disabled adult claimant is a petitioner. (See instructions for items 3e and 3f below.)
f. Disabled adult claimant's express consent to the relief requested in this petition is provided on Attachment 3f.
(if you checked item 3e or 3f, state facts on Attachment 3e or 3f showing that the claimant has capacity under Probate
Code section 812 to petition or consent to a petition. Only an adult claimant who has sufficient capacity and who does not
have a conservator of the estate may petition or consent to a petition. See Probate Code section 3613.)
4. Nature of claim The claim of the minor or adult person with a disability:
[_] Has not been filed in an action or proceeding. (Complete items 5-23.)
: [1 |s the subject of a pending action or proceeding that will be compromised without a trial on the merits of the claim.
Name of court: San Francisco Superior Court
Case no,:CGC-16-555761 Trial date: Nov. 13, 2017 (Complete items 5-23.)
Page tot 10
Form adopter PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM “de clcv precede § 372 tea;
sei Ganclot cons OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF cal Ros ofr nos 358%
Beinn ones el JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY 7401-7550, 7.951
(Miscellaneous)MC-350
CASE NAME: ‘CASE NUMBER:
[Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
4, Nature of claim The claim of the minor or adult person with a disability:
c Js the subject of a pending action or proceeding that has been or will be reduced to a judgment for the claimant against
the defendants named below in the total amount (exclusive of interest and costs) of (specify below):
$
Defendants (names)
Additional defendants listed on Attachment 4. [__] The judgment was filed on (date):
(Attach a copy of the (proposed) judgment as Attachment 4c and complete items 13-23.)
Incident or accident — The incident or accident occurred as follows:
a. Date and time: June 2014
b. Place: 778 25th Avenue, San Francisco, CA
c. Persons involved (names): Plaintiffs Angelique Rochelle, Baz Rochelle, Ella Lawton, Leona Paslay and
Defendants Trevor Deng, May Deng, and Yu Yao Tan
Continued on Attachment 5.
6. LY] Nature of incident or accident
The facts, events, and circumstances of the incident or accident are (describe):
Plaintiffs allege that Defendants served them with a false relative move-in eviction, causing interference with their quiet use
and enjoyment, violation of the San Francisco Rent Ordinance Sections 37.9 and 37.10, and negeligent and intentional
misrepresentation.
Continued on Attachment 6.
7. L¥_J Injuries
The following injuries were sustained by the claimant as a result of the incident or accident (describe):
Emotional distress and loss of rent-controlled unit.
[1 Continued on Attachment 7.
8. Treatment
The claimant received the following care and treatment for the injuries described in item 7 (describe):
[—] Continued on Attachment 8.
‘Me-950 Rev. January $, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 2. 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
CASE NAME: ‘CASE NUMBER:
|-Angelique Rochelle, et al. v. Trevor Deng, et al. |CGC-16-555761
9. Extent of injuries and recovery (An original or a photocopy of all doctors’ reports containing a diagnosis of and prognosis
for the claimant's injuries, and a report of the claimant's present condition, must be attached to this petition as Attachment 9.
Anew report is not necessary so long as a previous report accurately describes the claimant's current condition.)
a. (] The claimant has recovered completely from the effects of the injuries described in item 7, and there are no
permanent injuries.
b. (J The claimant has not recovered completely from the effects of the injuries described in item 7, and the following injuries
from which the claimant has not recovered are temporary (describe the remaining injuries):
Continued on Attachment 9b.
c. [1 The claimant has not recovered completely from the effects of the injuries described in item 7, and the following injuries
from which the claimant has not recovered are permanent (describe the permanent injuries):
[_] Continued on Attachment 9c.
10. [-] Petitioner has made a careful and diligent inquiry and investigation to ascertain the facts relating to the incident or
accident in which the claimant was injured; the responsibility for the incident or accident; and the nature, extent,
and seriousness of the claimant's injuries. Petitioner fully understands that if the compromise proposed in this
petition is approved by the court and is consummated, the claimant will be forever barred from seeking any further
recovery of compensation from the settling defendants named below even though the claimant's injuries may in
the future appear to be more serious than they are now thought to be.
11.7] Amount and terms of settlement
By way of settlement, the defendants named below have offered to pay the following sums to the claimant:
a. The total amount offered by all defendants named below is (specify): $| 10,000.00
b. The defendants and amounts offered by each are as follows (specify):
Defendants (names) Amounts
Trevor Deng $ 10,000.00
$
$
$
$
. Defendants and amounts offered continued on Attachment 11.
¢. The terms of settlement are as follows (if the settlement is to be paid in installments, both the total amount and the
present value of the settlement must be included):
Continued on Attachment 11.
‘MC-850 (Rov. January 1, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Pago 3 of 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)CASE NAME: CASE NUMBER:
[Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
12. [7] Settlement payments to others
a. [_] No defendant named in item 11b has offered to pay money to any person or persons other than the claimant to
settle claims arising out of the same incident or accident that resulted in the claimant's injury.
b. L¥] By way of settlement, one or more defendants named in item 11b have also offered to pay money to a person or
Persons other than claimant to settle claims arising out of the same incident or accident that resulted in the
claimant's injury.
(1) The total amount offered by all defendants to others (specify): $ 20,000.00
(2) Petitioner is not ] is a claimant against the recovery of the claimant (other than for
reimbursement for expenses paid by petitioner and listed under item 15).
(if you answered “is,” explain in Attachment 12 the circumstances and the effect your claim has on the
proposed compromise of the claim described in this petition.)
(3) Petitioner isnot [Vis a plaintiff in the sane action with the claimant.
(if you answered "is," explain'in Attachment 12 the circumstances and the effect your claim and its disposition
has on the proposed compromise of the claim or action described in this petition.)
(4) Petitioner would receive money under the proposed settlement.
(5) The settlement payments are to be apportioned and distributed as follows:
Other plaintiffs or claimants (names) Amounts
Leona Paslay g 10,000.00
Baz Rochelle g¢ 10,000.00
$
$
[—] Additional plaintiffs or claimants and amounts are listed on Attachment 12.
(6) Reasons for the apportionment of the settlement payments between the claimant and each other
plaintiff or claimant named above are specified on Attachment 12.
13. The claimant's medical expenses, including medical expenses paid by petitioner and insurers, to be reimbursed from
proceeds of settlement or judgment
a. Totals
(1) Total medical expenses: $ 0
(2) Total outstanding medical expenses to be paid from the proceeds: $
(3) Total out-of-pocket, co-payments, or deductible payments to be reimbursed from proceeds: $
b. Medical expenses were paid and are to be reimbursed from proceeds as follows:
(1) Paid by petitioner in the amount of: $
(2) Paid by private health insurance or a self-funded plan under:
(a) [7 An Employee Retirement Income Security Act (ERISA) insured plan.
(b) An ERISA self-funded pian.
(c) ANon-ERISA insured plan.
(a) [1] ANon-ERISA self-funded plan.
(e) Amount paid by plan: $
(f) Amount of reimbursement to the plan from proceeds of settlement or judgment:
@ No reimbursement is requested by the plan.
(ii) [—] Reimbursement is to be made to the plan and:
(A) (J There is a contractual reduction of $ ( )
(B) There is a negotiated reduction of $ ( )
(C) No reduction has been agreed to,
for a total reimbursement to the plan in the amount of: $
‘MC-350 (Rev. January 1, 2041] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 4 of 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
CASE NAME:
(CASE NUMBER:
[Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
13. The claimant's medical expenses, including medical expenses paid by petitioner and insurers, to be reimbursed from
proceeds of settlement or judgment
b. Medical expenses were paid and are to be reimbursed from proceeds as follows:
(3)
Paid by Medicare in the amount of: $
less the statutory reduction in the amount of: $ ( )
for a total reimbursement to Medicare in the amount of: $
{Attach a copy of the final Medicare demand letter or letter agreement as Attachment 13b(3).)
(4) Paid by Medi-Cal in the amount of $
(a) Notice of this claim or action has been given to the State Director of Health Care Services under Welfare
and Institutions Code section 14124.73. A copy of the notice and proof of its delivery is attached.
was filed in this matter on (date):
(b) Notice of this claim or action has not been given to the State Director of Health Care Services.
(Explain why notice has not been given in Attachment 13b(4).)
(c) L__J In full satisfaction of its lien rights, Medi-Cal has agreed to accept reimbursement
in the amount of: $
(Attach a copy of the final Medi-Cal demand letter or letter agreement as Attachment 13b(4).)
(d) Petitioner is entitled to a reduction of the Medi-Cal lien under Welfare and institutions Code
section 14124.76 and:
() [1 Is filing a motion seeking a reduction of the lien concurrently with this petition.
(i) Requests that the court reserve jurisdiction over this issue.
The amount of the lien in dispute is: $
(5) (a) There are one or more statutory or contractual liens of medical service providers for payment of medical
expenses, The total amount claimed under these liens is: $ «_ In full satisfaction
of their lien claims, the lienholders have agreed to accept the total sum of: $
(Provide requested information on each lienholder and certain other medical service providers below.)
(b) The name of each medical service provider that furnished care and treatment to claimant and (1) has a lien for all
or any part of the charges or (2) was paid (or will be paid from the proceeds) by petitioner for which petitioner
requests reimbursement; the amounts charged and paid; the amount of negotiated reduction of charges, if any;
and the amount to be paid from the proceeds of the settlement or judgment to each provider are as follows:
(i) (A) Provider (name):
(B) Address:
(C) Amount charged: $
(D) Amount paid (whether or not by insurance): $( )
(E) Negotiated reduction, if any:
(F) Amount to be paid from proceeds of settlement or judgment: $
(ii) (A). Provider (name):
(B) Address:
{C) Amount charged: $
{D) Amount paid (whether or not by insurance): $( )
(E) Negotiated reduction, if any: $( )
{F) Amount to be paid from proceeds of settlement or judgment: $
Continued on Attachment 13b(5). (Provide information about additional providers in the above format,
including providers paid or to be paid by petitioner for which reimbursement is requested in item 13b(1)
above. You may use form MC-350(A-13b(5)) for this purpose.)
MC-260 [Rew. Jorwary 4.2061) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Sf 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
‘CASE NAME: CASE NUMBER:
t-Angelique Rochelle, et al. v. Trevor Deng, et al. ICGC-16-555761
14. The claimant's attorney's fees and all other expenses (except medical expenses), including expenses advanced by
claimant's attorney or paid or incurred by petitioner to be reimbursed from proceeds of settlement or judgment
a. Total amount of attomey’s fees for which court approval is requested: $|2,000.00
(if fees are requested, attach as Attachment 14a, a declaration from the attorney explaining the basis for the request, including
a discussion of applicable factors listed in rule 7.955(b) of the Cal. Rules of Court. Respond to item 18a(2) on page 7 and
attach a copy of any written attorney fee agreement as Attachment 18a.)
b. The following additional items of expense (other than medical expenses) have been incurred or paid, are reasonable, resulted
from the incident or accident, and should be paid out of claimant's share of the proceeds of the settlement or judgment:
items Payees (names) Amounts
$
$
$
$
$
$
$
$
$
$
Petitioner is requesting 19.4% of the total costs $ 10,315.90
Continued on Attachment 14b. Total: $
15. Reimbursement of expenses paid by petitioner
a. [) Petitioner has paid none of the claimant's expenses listed in items 13 and 14 for which reimbursement is requested.
b. [4%] Petitioner has paid (or become obligated to pay) the following total amounts of the claimant's expenses for which
reimbursement is requested.
(1) (] Medical expenses listed in item 13: go
(2) [<] Attorney's fees included in the total fee amount shown in item 14a: $ 2,000.00
(3) [¥-] Other expenses included in the total shown in item 14b: $ 2,000.00
Total: — $ [4,000.00
(Attach proofs of the expenses incurred and payments made or obligations to pay incurred, e.g., bills or invoices,
canceled checks, credit card statements, explanations of benefits from insurers, etc.)
16. Net balance of proceeds for the claimant
The balance of the proceeds of the proposed settlement or judgment remaining for the claimant
after payment of all requested fees and expenses is: [6,000.00
17. Summary
a. Gross amount of proceeds of settlement or judgment for claimant: g 10,000.00
b. Medical expenses to be paid from proceeds of settlement
or judgment: $0
c. Attomey's fees to be paid from proceeds of settlement or
judgment: $ 2,000.00
d. Expenses (other than medical) to be paid from proceeds
of settlement or judgment: 2,000.00
e. Total of fees and expenses to be paid from proceeds of settlement or judgment
(add (b), (c), and (a)): $(4,000.00 SS)
f. Balance of proceeds of settlement or judgment available for claimant after payment of all
fees and expenses (subtract (e) from (a): $
MC-S60 (Rev. January 2069) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Sof10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MG-350
CASE NAME: ‘CASE NUMBER:
Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
18. Information about attorney representing or assisting petitioner
a. (1) Petitioner has not been represented or assisted by an attorney i in preparing this petition or in any other way with
respect to the claim asserted. (Go to item 19.)
(2) (¥] [4] Petitioner has been represented or assisted by an attorney in preparing this petition or with respect to the claim
asserted. Petitioner and the attorney donot [¥_] do have an agreement for services provided in
connection with the claim giving rise to this petition. (If you answered “do,” attach a copy of the agreement as
Attachment 18a, and complete items 18b—18f.)
b. The attomey who has represented or assisted petitioner is (name): Mark Hooshmand, Esq.
(1) State Bar number; 194878
(2) Law firm: Hoohsmand Law Group
(2) Address: 22 Battery Street, Suite 610, San Francisco, CA 94111
(4) Telephone number:
c. The attorney has not [__] has received attomey’s fees or other compensation in addition to that requested in this
petition for services provided in connection with the claim giving rise to this petition. (if you answered "has," identify the person
who paid the fees or other compensation, the amounts paid, and the dates of payment):
From whom (names) Amounts Dates
PHAaH
[21 Continued on Attachment 18c.
d. Theattomey [7] didnot [ did become concemed with this matter, directly or indirectly, at the instance of a party
against whom the claim is asserted or a party's insurance carrier. (If you answered "did," explain the circumstances in
Attachment 18d.)
e. The attorney isnot [7] is representing or employed by any other party or any insurance carrier involved in the
matter. (if you answered ‘is,” identify the party or carrier and explain the relationship in Attachment 18e.)
f. Theattomey [_] doesnot [7] does expect to receive attorney's fees or other compensation in addition to that
requested in this petition for services provided in connection with the claim giving rise to this petition. (if you answered "does,"
identify the person who will pay the fees or other compensation, the amounts to be paid, and the expected dates of payment):
Erom whom (names)
Amounts Expected dates
Ella Rochelle-Lawton ¢ 2,000.00 Upon approval
Baz Rochelle 2,000.00 Upon release execution
$
$
$
(1 Continued on Attachment 18F.
MC-360 (Rew. January 1, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 7 of 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
CASE NAME:
‘CASE NUMBER:
| Angelique Rochelle, et al. v. Trevor Deng, et al. ‘CGC-16-555761
19. Disposition of balance of proceeds of settlement or judgment
Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows:
a. There is a guardianship of the estate of the minor or a conservatorship of the estate of the adult person with a
disability filed in (name of court):
Case no.:
(1) $ of the proceeds in money or other property will be paid or delivered to
the guardian of the estate of the minor or the conservator of the estate of the conservatee. The money
or other property is specified in Attachment 19a(1).
(2) [{] Petitioner is the guardian or conservator of the estate of the minor or the adult person with a disability.
(3)
MC-350 [Rev. January 1, 2011]
Petitioner requests authority to deposit or invest $ of the money or other
property to be paid or delivered under 19a(1) with one or more financial institutions in this state or with a trust
company, subject to withdrawal only as authorized by the court. The money or other property and the name,
branch, and address of each financial institution or trust company are specified in Attachment 19a(2).
Petitioner proposes that all or a portion of the proceeds not become part of the guardianship or
conservatorship estate. Petitioner requests authority to deposit or transfer these proceeds as follows
(check all that apply):
@ Cs will be deposited in insured accounts in one or more financial
institutions in this state from which no withdrawals can be made without a court order.
The name, branch, and address of each depository are specified in Attachment 19a(3).
(b) $ will be invested in a single-premium deferred annuity subject to
withdrawal only on order of the court. The terms and conditions of the annuity are specified in
Attachment 19a(3).
@¢ C$ will be transferred to a custodian for the benefit of the minor under the
California Uniform Transfers to Minors Act. The name and address of the proposed custodian
and the property to be transferred are specified in Attachment 19a(3).
@ C$ will be transferred to the trustee of a trust that is either created by or
approved of in the order approving the settlement or the judgment given or to be given for the
minor. This trust is revocable when the minor attains the age of 18 years and contains all other
terms and conditions determined to be necessary by the court to protect the minor's interests. The
terms of the proposed trust and the property to be transferred are specified in Attachment 19a(3).
A copy of the (proposed) judgment is attached as Attachment 4c.
(e) $ will be transferred to the trustee of a special needs trust under
Probate Code sections 3602(d) and 3604 for the benefit of the minor or the adult person with a
disability. The terms of the proposed special needs trust and the property to be transferred are
specified in Attachment 19a(3).
PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Gof 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
(CASE NAME:
t-Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
‘CASE NUMBER:
19. Disposition of balance of proceeds of settlement or judgment (cont.)
Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows:
b. [_] There is no guardianship of the estate of the minor or conservatorship of the estate of the adult person with a disability.
Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows
(check ail that apply):
(1)
(2)
(3)
A guardian of the estate of the minor or a conservator of the estate of the adult person with a disability
will be appointed. $ of money and other property will be paid or delivered
to the person so appointed. The money or other property are specified in Attachment 19b(1).
$ of money will be deposited in insured accounts in one or more financial
institutions in this state, subject to withdrawal only upon the authorization of the court. The name,
branch, and address of each depository are specified in Attachment 19b(2).
of money will be invested in a single-premium deferred annuity, subject to
withdrawal only upon the authorization of the court. The terms and conditions of the annuity are specified
in Attachment 19b(3).
4) (7 $ will be paid or transferred to the trustee of a special needs trust under
(8)
(6)
7”
(8)
(9)
(10)
(11)
Probate Code sections 3604 and 3611(c) for the benefit of the minor or the adult person with a disability.
The terms of the proposed special needs trust and the money or other property to be paid or transferred are
specified in Attachment 19b(4).
$ will be paid or delivered to a parent of the minor, upon the terms and under the
conditions specified in Probate Code sections 3401-3402, without bond. The name and address of the
parent and the money or other property to be delivered are specified in Attachment 19b(5). (Value of minor's
entire estate, including the money or property to be delivered, must not exceed $5,000.)
$ will be transferred to a custodian for the benefit of the minor under the California
Uniform Transfers to Minors Act. The name and address of the proposed custodian and the money or other
property to be transferred are specified in Attachment 19b(6).
$ will be transferred to the trustee of a trust that is either created by or
approved of in the order approving the settlement or the judgment given or to be given for the minor. This
trust is revocable when the minor attains the age of 18 years and contains all other terms and conditions
determined to be necessary by the court to protect the minor's interests. The terms of the proposed trust and
the money or other property to be transferred are specified in Attachment 19b(7).
() Acopy of the (proposed) judgment is attached as Attachment 4c.
$ of money will be held on such conditions as the court in its discretion determines
is in the best interest of the minor or the adult person with a disability. The proposed conditions are specified
‘on Attachment 19b(8). (Value must not exceed $20,000.)
$ of property other than money will be held on such conditions as the court in its
discretion determines is in the best interest of the minor or the adult person with a disability. The proposed
conditions and the property are specified in Attachment 19b(9).
$ will be deposited with the county treasurer of the County of (name):
The deposit is authorized under and subject to the conditions specified in Probate Code section 361 1(h).
$ will be paid or transferred to the adult person with a disability. The money or other
property is specified in Attachment 19b(11).
Continued on Attachment 19.
MC-350 [Rev. January 1, 2011]
PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 8 of 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)MC-350
CASE NAME: : ‘CASE NUMBER:
j Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761
20. [] Statutory liens for special needs trust
Petitioner requests a court order for payment of funds to a special needs trust (explain how statutory lens under Probate
Cade section 3604, if any, will be satisfied):
Continued on Attachment 20.
21. (_] Additional orders
Petitioner requests the following additional orders (specify and explain):
Continued on Attachment 21.
22. Petitioner recommends the compromise settlement or the proposed disposition of the proceeds of the judgment for the claimant to
the court as being fair, reasonable, and in the best interest of the claimant and requests that the court approve this compromise
settlement or proposed disposition and make such other and further orders as may be just and reasonable.
23. Number of pages attached: i
Date: March 5, 2018
Tyson Redenbarger, Esq. » Wwe
{TYPE OR PRINT NAME OF ATTORNEY) (SIGNATURE OF ATTORNEY)
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and corre
Date: March 5, 2018
Angelique Rochelle >
{IVPE OR PRINT NAME OF PETITIONER) (BIGNAT ER)
MC-250 (Rev. January 1, 2011) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 10 of 10
OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF
JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY
(Miscellaneous)Total for
Client Cost
Court
Reporter
Date
10/24/20
17
08/09/20
17
08/09/20
17
08/09/20
17
08/09/20
17
09/11/20
17
09/11/20
17
09/11/20
17
09/11/20
17
11/01/20
17
11/01/20
17
Name Memo/Description
Amount
Cogent
Legal, Retainer - Rochelle v Deng Nov. 13,
LLC 2017 trial
DeAlba
Reporting Invoice 9245 - Rochelle - Depo of Yu
Service Tao Tan 7/17/17
DeAlba
Reporting Invoice 9243 - Rochelle - Depo of May
Service Deng 7/13/17
DeAlba
Reporting Invoice 9237 - Rochelle - Depo of Trevor
Service Deng 7/12/17
DeAlba
Reporting Invoice 9206 - Shkipin - Depo of Chris
Service Lee 6/19/17
US Legal
Support
(CA Invoice 410092535 - Rochelle - Records
Reporting) of Douglas Wong
US Legal
Support
(CA Invoice 410092533 - Rochelle - Records
Reporting) of Laurel Properties
US Legal
Support
(CA Invoice 410092530 - Rochelle - Records
Reporting) of Raymond Alives
US Legal
Support
(CA
Reporting) Invoice 410084782 - Rochelle
DeAlba
Reporting Invoice 9417 - Rochelle - Depo of
Service William Wong 10/4/2017
DeAlba
Reporting Invoice 9419 - Rochelle - Depo of Doug
Service Wong 10/15/2017
10,000.00
$ 10,000.00
400.80
1,143.90
1,380.20
671.70
125.00
95.00
95.00
247,52
286.25
406.6011/01/20
17
11/01/20
17
11/01/20
17
11/14/20
17
11/14/20
17
11/14/20
17
11/14/20
17
11/14/20
17
11/14/20
17
11/14/20
17
DeAlba Invoice 9423 - Rochelle - Dept. 301
Reporting Motion to Compel Discovery and Defs'
Service Protective Order Hearing 9/14/2017
DeAlba
Reporting Invoice 9385 - Rochelle - Depo of Trevor
Service Deng, Vol. I] 9/21/2017
DeAlba
Reporting Invoice 9389 - Rochelle - Depo of Calvin
Service Chan 9/27/2017
US Legal
Support
(CA Invoice 110089151 - Rochelle - Certified
Reporting) Transcript of John Lawton
US Legal
Support
(CA Invoice 110076634 - Rochelle - Certified
Reporting) Transcript of Baz Rochelle
US Legal
Support Invoice 110091079 - Rochelle - Certified
(CA Transcript and Arbitrator's Copy of
Reporting) Transcript
US Legal
Support
(CA Invoice 110096149 - Rochelle - Certified
Reporting) Transcript of Paul Elizondo, D.O.
US Legal
Support
(CA Invoice 110090328 - Rochelle - Certified
Reporting) Transcript of Paul Elizondo, D.O.
US Legal
Support
(CA Invoice 110091102 - Rochelle - Certified
Reporting) Transcript of Hearing
US Legal
Support
(CA Invoice 110083513 - Rochelle - Certified
Reporting) Transcript of Angelique Rochelle, Vol. I
889.15
699.65
402.40
309.45
435.91
364.54
327.30
343.35
299.10
942.30Total for
Court
Reporter
Deposition
Fee
Total for
Deposition
Fee
Discovery
Total for
Discovery
Expert
Witness
11/14/20
17
11/14/20
17
11/14/20
17
01/17/20
18
09/27/20
17
01/01/20
17
06/01/20
17
06/28/20
17
10/20/20
17
US Legal
Support
(CA Invoice 110093253 - Rochelle - Certified
Reporting) Transcript Raymond Tom Palsay III 240.45
US Legal
Support
(CA Invoice 110091524 - Rochelle - Certified
Reporting) Transcript of Richard Devine 373.05
US Legal
Support
(CA Invoice 110076635 - Rochelle - Certified
Reporting) Transcript of Ella Lawton 332.75
DeAlba
Reporting Invoice 9447 - Rochelle - Depo of Eric
Service Drabkin 10/23/2017 454.95
$ 11,266.32
Calvin Rochelle - Witness Fee and travel,
Tran deposition of Calvin Tran 55.00
$ 55.00
Joffe
Investigati
ons Rochelle - Surveillance, 12/5/16 323.00
TLOx
Transunio Rochelle - TLOx address reports, persons
n and license plate research 100.00
Kaiser
Permanent
e Rochelle - Medical Records Request 0.00
$ 423.00
Eric
Drabkin Rochelle v Deng deposition 10/23 915.00Total for
Expert
Witness
Filing Fee
10/23/20
17
10/30/20
17
12/15/20
17
12/15/20
17
12/08/20
16
01/13/20
17
02/22/20
17
04/11/20
17
05/12/20
17
06/23/20
17
09/19/20
17
10/05/20
17
11/02/20
17
Eric Rochelle v Deng deposition 10/23 -
Drabkin second check
Invoice 2442 - Rochelle - Expert Witness
RJD, LLC Rendered - 9/28/17 - 10/23/17, 8.5 hrs
Invoice 2452 - Rochelle - Expert Witness
RJD, LLC Rendered - 11/20/17 - 11/27/17
Judy H.
Rothschild Rochelle - Trial Consultant Fees
San
Francisco
Superior
Court Rochelle - New Complaint Filing Fee
File &
ServeXpre Rochelle - File & ServeXpress Filing
ss, LLC Fees
File &
ServeXpre Rochelle - File & ServeXpress Filing
ss, LLC Fees
File & Rochelle - Plts' Notice of Jury Fees; POS
ServeXpre of Summons. Affidavit of Reasonable
ss, LLC Diligence and POS by Mail
File &
ServeXpre Rochelle - Plaintiffs' Case Management
ss, LLC Statement
San
Francisco
Superior Rochelle - Transcript, CCH-12-574089,
Court 12/12/12
File &
ServeXpre Rochelle - Motion to Compel Discovery;
ss, LLC Opp to Defs' Motion for Protective Order
File & Rochelle - Reply ISO Motion to Compel
ServeXpre Discovery; NOE for Protective Order;
ss, LLC Opp to MSJ
File & Rochelle - Opp to Defs' Motion for
ServeXpre Sanctions. Notice of Entry of Order
ss, LLC Denying Defs' MSJ
203.33
3,400.00
1,900.00
1,350.00
7,168.33
450.00
47.00
14,00
178.00
15.00
57.00
90.00
60.00
45.00Total for
Filing Fee
Medical
Records
Total for
Medical
Records
Messenger
Service
08/02/20
17
01/20/20
17
02/17/20
17
03/17/20
17
04/28/20
17
05/26/20
17
06/09/20
17
John Muir
Medical
Center —_ Rochelle - Leona Paslay Medical Records
Western
Messenger
Service,
Inc. Rochelle - Courtesy Copy Drop-Off
Western
Messenger
Service,
Inc. Rochelle Filed Summons in SF Court
Western
Messenger Rochelle - Drop Summons and
Service, Complaint to SF Sheriff's Office for
Inc. Sheriff to serve Def. Deng
Western
Messenger
Service, Rochelle - Drop Off Courtesy Copies to
Inc. Dept. 610 and Dept. 206
Western
Messenger
Service, Rochelle - Pick Up Docs from Court to
Inc. Western Messenger's Office
Western
Messenger
Service, Rochelle - Copy Job from Court to WM
Inc. Office
$ 956.00
15.00
$ 15.00
14.06
43.00
41.00
30.81
92.50
92.3906/09/20
17
06/16/20
17
07/21/20
17
08/25/20
17
09/01/20
17
09/08/20
17
09/15/20
17
09/29/20
17
10/06/20
17
Western
Messenger
Service, Rochelle - Research and Printing Docs
Inc. from Court to SF Office
Western
Messenger
Service, Rochelle - Send Docs to Court. Returned
Inc. Endorsed Copy from Court to SF Office
Western
Messenger
Service, Rochelle - Personally Serve Docs to
Inc. Calvin Chan
Wester
Messenger Rochelle - Personally Serve Docs to
Service, Seema Ullal, Aneese Hasnail, Etc. -
Inc. 8/18/17 - 8/22/17
Western
Messenger
Service, Rochelle - Personally Serve Docs to
Inc. Seema Ullal
Western
Messenger
Service, Rochelle - Drop Off Courtesy Copy from
Ine, WM Office to Court
Western
Messenger Rochelle - Additional Trip to Court for
Service, CC of Reply ISO MTC Discovery and
Inc. Request for Sanctions
Western
Messenger Rochelle - Personally Serve Depo
Service, Subpoena to Third Party Witness Calvin
Inc. Tran
Western
Messenger
Service, Rochelle - Drop Off Courtesy Copies to
Inc. Court
49.50
44.75
156.03
43.54
70.61
5.20
96.00
26.58Western
Messenger
10/13/20 Service, Rochelle - Personally Served Docs to Dr.
17 Inc. Paul Elizondo 29.46
Total for
Messenger
Service $ 931.43
Process
Service
San
Francisco
Sheriff's
03/15/20 Departme
17 nt Rochelle - Process Service Fee 40.00
Specialize
d Legal
04/18/20 Services,
7 Inc. P147726 - Trevor Deng 120.00
Specialize
d Legal
04/18/20 Services,
7 Inc. P147729 - Yu Tao Tan 60.00
Specialize
d Legal
04/18/20 Services,
17 Inc. P147728 - May Deng 120.00
Specialize
d Legal
09/08/20 Services, Rochelle - P152341 - Service of Doug
17 Inc. Wong 60.00
Total
for Process
Service $ 400.00
Subpoena
US Legal
10/11/20 Support Rochelle - Invoice No. 410092535 -
17 Ine. Records 143.75
US Legal
10/11/20 Support Rochelle - Invoice No. 410092533 -
17 Inc. Records 109.25
US Legal
10/11/20 Support Rochelle - Invoice No. 410084782 -
17 Inc. Records 283.46Total for
Subpoena
Transcripts
Total for
Transcripts
Video
10/11/20
17
10/27/20
17
08/02/20
17
08/02/20
17
08/04/20
17
10/02/20
17
07/31/20
17
10/04/20
17
10/04/20
\7
11/14/20
17
US Legal
Support
Inc.
US Legal
Support
Inc.
Second
Sight
Source To
Target
Translatio
ns
Wheeler
&
Hallford,
Inc.
Source To
Target
Translatio
ns
Eureka
Street
Legal
Video
Eureka
Street
Legal
Video
Eureka
Street
Legal
Video
Eureka
Street
Legal
Video
Rochelle - Invoice No. 410092530 -
Records
Rochelle - Invoice No..110087420 -
Records
Rochelle - depo of Angelique Rochelle,
6/16/17
Invoice 860602 - Rochelle -
interpretation at depo of Y. Tan, 7/14/17
Invoice 134223 - transcript for depo of
Angelique Rochelle
Invoice 830903 - Rochelle -
Interpretation at Depo of C. Chan,
9/28/17
INV #ES-1563 - Rochelle - depo of T.
Deng (7/12/17), 11 hrs, M. Deng
(7/13/17), 10.25 hrs, ¥. Tan (7/14/17),
6.5 hrs
INV #ES-1783 - Rochelle - Depo of
Trever Deng - 9/21/17, 4.5 hrs
INV #ES-1783 - Rochelle - Depo of
Calvin Chan - 9/21/17,3 hrs
INV #ES-1887 - Rochelle - Eric Drabkin
depo (10/23), 3.25 hrs; Mock Trial
(10/25), 2 hrs
109,25
299.00
944.71
337.50
1,230.00
831.25
660.00
3,058.75
1,982.50
473.00
293.00
592.50Total
for Video
Total for
Client Cost
with sub-
accounts
Contract
labor
01/29/20
18
01/29/20
18
01/29/20
18
11/13/20
17
11/13/20
\7
11/13/20
17
11/13/20
17
11/13/20
17
11/13/20
17
11/13/20
17
11/13/20
17
Eureka
Street
Legal INV #ES-1815 - Rochelle - William
Video "Doug" Wong Depo (10/4/17), 3.75 hrs
Eureka
Street
Legal INV #ES-1813 - Rochelle - Site
Video Inspection (10/4/17), 3 hrs
Eureka
Street
Legal INV #ES-1913 - Rochelle - Calvin Tran
Video Depo (9/27/17) - Sync Fee
Robert Rochelle - Invoice - #49554767 - Mock
Half Legal Trial Jury, Daniela Piccetti
Robert Rochelle - Invoice - #49600036 - Mock
Half Legal Trial Jury, Alan Pham
Robert Rochelle - Invoice - #49592071 - Mock
Half Legal Trial Jury, Andrew Lei
Robert Rochelle - Invoice - #49592077 - Mock
Half Legal Trial Jury, Jayme Smiley
Robert Rochelle - Invoice #49592075 - Mock
Half Legal Trial Jury, Eric Dunn
Robert Rochelle - Invoice - #49592076 - Mock
Half Legal Trial Jury, Haley Wong
Robert Rochelle - Invoice - #49592073 - Mock
Half Legal Trial Jury, Elizabeth Freestone
Robert _ Rochelle - Invoice - #49592093 - Mock
Half Legal Trial Jury, Mayra Morales
412.50
285.00
85.00
$ 4,123.50
$ 51,742.93
135.00
135.00
135.00
135.00
135.00
135.00
135.00
135.00Total for
Contract
labor
Meals
and
Entertainme
nt
Total for
Meals and
Entertainme
nt
Total for
Expenses
‘Thursday, Feb 15,
2018 04:47:42 PM
GMT-8 - Accrual
Basis
11/13/20
17
11/03/20
7
Robert Rochelle - Invoice - #49592092 - Mock
Half Legal Trial Jury, Ugur Ozturk
Rochelle - Snacks and Coffee for Mock
Specialty's Trial Jurors
Total costs divided by 4 plaintiffs
135.00
$ = 1,215.00
106.55
$ 106.55
$ 41,263.59
$ 10,315.90Rochelle v Deng
CGC-16-555761
Attachment 18e
Plaintiffs’ Attorney is also representing petitioners Angelique Rochelle (mother), Baz Rochelle (sibling),
and Leona Lawton (sibling)
Preview
MC-350 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY | Mark Hooshmand, Esq. (SBN 194878); Tyson Redenbarger, Esq. (SBN 294424) 22 Battery Street, Suite 610 San Francisco, CA 94111 ELECTRONICALLY TELEPHONENO: (415) 318-5709 FAXNO. (Optonay: (415) 376-5897 FILED E-MAL ADDRESS (Optonel: Mark@lawmmh.com Superior Court of California, ATTORNEY FOR Wome: Plaintiffs Angelique, et al. County of San Francisco San Franck 03/21/2018 ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco Clerk of the Court street aopress: 400 McAllister Street BY: ANNIE PASCUAL maiLincappress: 400 McAllister Street Deputy Clerk cITy AND zip cope: San Francisco 94102 BRANCH NANE: Civic Center CASE NAME: ‘CASE NUMBER: Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 P : HEARING DATE ETITION TO APPROVE: COMPROMISE OF DISPUTED CLAIM April 3, 2018 [7] COMPROMISE OF PENDING ACTION (—_] DISPOSITION OF PROCEEDS OF JUDGMENT Minor Person With a Disability NOTICE TO PETITIONERS: Except as noted below, you must use this form to request court approval of (1) the compromise of a disputed claim of a minor, (2) the compromise of a pending action or proceeding in which a minor or a person with a disability (including a conservatee) is a party, or (3) the disposition of the proceeds of a judgment for a minor or person with a disability. (See Code Civ. Proc., § 372; Prob. DEPT: 514, THE: 9-00) am Code, § 3600 et seq.) You and the minor or disabled person must attend the hearing on this petition unless the court for good cause dispenses with a personal appearance. The court may require the presence and testimony of witnesses, including the attending or examining physician, and other evidence relating to the merits of the claim and the nature and extent of the injury, care, treatment, and hospitalization. The court may consider on an expedited basis without a hearing requests for approval of the compromises of certain claims and actions or the disposition of the proceeds of certain judgments. if your claim, action, or judgment qualifies for expedited consideration and you want to request it, you must use form MC-350EX for your request. See Cal. Rules of Court, rule 7.950.5. 1, Petitioner (name): Angelique Rochelle 2. Claimant (name): Ella Rochelle- Lawton a. Address: 808A Lyon Street, San Francisco, CA b. Date of birth: April 9, 2000 c. Age:17 d. Sex: Female ¢ [7] minor [1] Person with a disability 3. Relationship Petitioner's relationship to the claimant (check all applicable boxes): a Parent 9. Other relationship (specify:) b. Guardian ad litem c. Guardian d. Conservator e. Disabled adult claimant is a petitioner. (See instructions for items 3e and 3f below.) f. Disabled adult claimant's express consent to the relief requested in this petition is provided on Attachment 3f. (if you checked item 3e or 3f, state facts on Attachment 3e or 3f showing that the claimant has capacity under Probate Code section 812 to petition or consent to a petition. Only an adult claimant who has sufficient capacity and who does not have a conservator of the estate may petition or consent to a petition. See Probate Code section 3613.) 4. Nature of claim The claim of the minor or adult person with a disability: [_] Has not been filed in an action or proceeding. (Complete items 5-23.) : [1 |s the subject of a pending action or proceeding that will be compromised without a trial on the merits of the claim. Name of court: San Francisco Superior Court Case no,:CGC-16-555761 Trial date: Nov. 13, 2017 (Complete items 5-23.) Page tot 10 Form adopter PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM “de clcv precede § 372 tea; sei Ganclot cons OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF cal Ros ofr nos 358% Beinn ones el JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY 7401-7550, 7.951 (Miscellaneous)MC-350 CASE NAME: ‘CASE NUMBER: [Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 4, Nature of claim The claim of the minor or adult person with a disability: c Js the subject of a pending action or proceeding that has been or will be reduced to a judgment for the claimant against the defendants named below in the total amount (exclusive of interest and costs) of (specify below): $ Defendants (names) Additional defendants listed on Attachment 4. [__] The judgment was filed on (date): (Attach a copy of the (proposed) judgment as Attachment 4c and complete items 13-23.) Incident or accident — The incident or accident occurred as follows: a. Date and time: June 2014 b. Place: 778 25th Avenue, San Francisco, CA c. Persons involved (names): Plaintiffs Angelique Rochelle, Baz Rochelle, Ella Lawton, Leona Paslay and Defendants Trevor Deng, May Deng, and Yu Yao Tan Continued on Attachment 5. 6. LY] Nature of incident or accident The facts, events, and circumstances of the incident or accident are (describe): Plaintiffs allege that Defendants served them with a false relative move-in eviction, causing interference with their quiet use and enjoyment, violation of the San Francisco Rent Ordinance Sections 37.9 and 37.10, and negeligent and intentional misrepresentation. Continued on Attachment 6. 7. L¥_J Injuries The following injuries were sustained by the claimant as a result of the incident or accident (describe): Emotional distress and loss of rent-controlled unit. [1 Continued on Attachment 7. 8. Treatment The claimant received the following care and treatment for the injuries described in item 7 (describe): [—] Continued on Attachment 8. ‘Me-950 Rev. January $, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 2. 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 CASE NAME: ‘CASE NUMBER: |-Angelique Rochelle, et al. v. Trevor Deng, et al. |CGC-16-555761 9. Extent of injuries and recovery (An original or a photocopy of all doctors’ reports containing a diagnosis of and prognosis for the claimant's injuries, and a report of the claimant's present condition, must be attached to this petition as Attachment 9. Anew report is not necessary so long as a previous report accurately describes the claimant's current condition.) a. (] The claimant has recovered completely from the effects of the injuries described in item 7, and there are no permanent injuries. b. (J The claimant has not recovered completely from the effects of the injuries described in item 7, and the following injuries from which the claimant has not recovered are temporary (describe the remaining injuries): Continued on Attachment 9b. c. [1 The claimant has not recovered completely from the effects of the injuries described in item 7, and the following injuries from which the claimant has not recovered are permanent (describe the permanent injuries): [_] Continued on Attachment 9c. 10. [-] Petitioner has made a careful and diligent inquiry and investigation to ascertain the facts relating to the incident or accident in which the claimant was injured; the responsibility for the incident or accident; and the nature, extent, and seriousness of the claimant's injuries. Petitioner fully understands that if the compromise proposed in this petition is approved by the court and is consummated, the claimant will be forever barred from seeking any further recovery of compensation from the settling defendants named below even though the claimant's injuries may in the future appear to be more serious than they are now thought to be. 11.7] Amount and terms of settlement By way of settlement, the defendants named below have offered to pay the following sums to the claimant: a. The total amount offered by all defendants named below is (specify): $| 10,000.00 b. The defendants and amounts offered by each are as follows (specify): Defendants (names) Amounts Trevor Deng $ 10,000.00 $ $ $ $ . Defendants and amounts offered continued on Attachment 11. ¢. The terms of settlement are as follows (if the settlement is to be paid in installments, both the total amount and the present value of the settlement must be included): Continued on Attachment 11. ‘MC-850 (Rov. January 1, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Pago 3 of 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)CASE NAME: CASE NUMBER: [Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 12. [7] Settlement payments to others a. [_] No defendant named in item 11b has offered to pay money to any person or persons other than the claimant to settle claims arising out of the same incident or accident that resulted in the claimant's injury. b. L¥] By way of settlement, one or more defendants named in item 11b have also offered to pay money to a person or Persons other than claimant to settle claims arising out of the same incident or accident that resulted in the claimant's injury. (1) The total amount offered by all defendants to others (specify): $ 20,000.00 (2) Petitioner is not ] is a claimant against the recovery of the claimant (other than for reimbursement for expenses paid by petitioner and listed under item 15). (if you answered “is,” explain in Attachment 12 the circumstances and the effect your claim has on the proposed compromise of the claim described in this petition.) (3) Petitioner isnot [Vis a plaintiff in the sane action with the claimant. (if you answered "is," explain'in Attachment 12 the circumstances and the effect your claim and its disposition has on the proposed compromise of the claim or action described in this petition.) (4) Petitioner would receive money under the proposed settlement. (5) The settlement payments are to be apportioned and distributed as follows: Other plaintiffs or claimants (names) Amounts Leona Paslay g 10,000.00 Baz Rochelle g¢ 10,000.00 $ $ [—] Additional plaintiffs or claimants and amounts are listed on Attachment 12. (6) Reasons for the apportionment of the settlement payments between the claimant and each other plaintiff or claimant named above are specified on Attachment 12. 13. The claimant's medical expenses, including medical expenses paid by petitioner and insurers, to be reimbursed from proceeds of settlement or judgment a. Totals (1) Total medical expenses: $ 0 (2) Total outstanding medical expenses to be paid from the proceeds: $ (3) Total out-of-pocket, co-payments, or deductible payments to be reimbursed from proceeds: $ b. Medical expenses were paid and are to be reimbursed from proceeds as follows: (1) Paid by petitioner in the amount of: $ (2) Paid by private health insurance or a self-funded plan under: (a) [7 An Employee Retirement Income Security Act (ERISA) insured plan. (b) An ERISA self-funded pian. (c) ANon-ERISA insured plan. (a) [1] ANon-ERISA self-funded plan. (e) Amount paid by plan: $ (f) Amount of reimbursement to the plan from proceeds of settlement or judgment: @ No reimbursement is requested by the plan. (ii) [—] Reimbursement is to be made to the plan and: (A) (J There is a contractual reduction of $ ( ) (B) There is a negotiated reduction of $ ( ) (C) No reduction has been agreed to, for a total reimbursement to the plan in the amount of: $ ‘MC-350 (Rev. January 1, 2041] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 4 of 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 CASE NAME: (CASE NUMBER: [Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 13. The claimant's medical expenses, including medical expenses paid by petitioner and insurers, to be reimbursed from proceeds of settlement or judgment b. Medical expenses were paid and are to be reimbursed from proceeds as follows: (3) Paid by Medicare in the amount of: $ less the statutory reduction in the amount of: $ ( ) for a total reimbursement to Medicare in the amount of: $ {Attach a copy of the final Medicare demand letter or letter agreement as Attachment 13b(3).) (4) Paid by Medi-Cal in the amount of $ (a) Notice of this claim or action has been given to the State Director of Health Care Services under Welfare and Institutions Code section 14124.73. A copy of the notice and proof of its delivery is attached. was filed in this matter on (date): (b) Notice of this claim or action has not been given to the State Director of Health Care Services. (Explain why notice has not been given in Attachment 13b(4).) (c) L__J In full satisfaction of its lien rights, Medi-Cal has agreed to accept reimbursement in the amount of: $ (Attach a copy of the final Medi-Cal demand letter or letter agreement as Attachment 13b(4).) (d) Petitioner is entitled to a reduction of the Medi-Cal lien under Welfare and institutions Code section 14124.76 and: () [1 Is filing a motion seeking a reduction of the lien concurrently with this petition. (i) Requests that the court reserve jurisdiction over this issue. The amount of the lien in dispute is: $ (5) (a) There are one or more statutory or contractual liens of medical service providers for payment of medical expenses, The total amount claimed under these liens is: $ «_ In full satisfaction of their lien claims, the lienholders have agreed to accept the total sum of: $ (Provide requested information on each lienholder and certain other medical service providers below.) (b) The name of each medical service provider that furnished care and treatment to claimant and (1) has a lien for all or any part of the charges or (2) was paid (or will be paid from the proceeds) by petitioner for which petitioner requests reimbursement; the amounts charged and paid; the amount of negotiated reduction of charges, if any; and the amount to be paid from the proceeds of the settlement or judgment to each provider are as follows: (i) (A) Provider (name): (B) Address: (C) Amount charged: $ (D) Amount paid (whether or not by insurance): $( ) (E) Negotiated reduction, if any: (F) Amount to be paid from proceeds of settlement or judgment: $ (ii) (A). Provider (name): (B) Address: {C) Amount charged: $ {D) Amount paid (whether or not by insurance): $( ) (E) Negotiated reduction, if any: $( ) {F) Amount to be paid from proceeds of settlement or judgment: $ Continued on Attachment 13b(5). (Provide information about additional providers in the above format, including providers paid or to be paid by petitioner for which reimbursement is requested in item 13b(1) above. You may use form MC-350(A-13b(5)) for this purpose.) MC-260 [Rew. Jorwary 4.2061) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Sf 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 ‘CASE NAME: CASE NUMBER: t-Angelique Rochelle, et al. v. Trevor Deng, et al. ICGC-16-555761 14. The claimant's attorney's fees and all other expenses (except medical expenses), including expenses advanced by claimant's attorney or paid or incurred by petitioner to be reimbursed from proceeds of settlement or judgment a. Total amount of attomey’s fees for which court approval is requested: $|2,000.00 (if fees are requested, attach as Attachment 14a, a declaration from the attorney explaining the basis for the request, including a discussion of applicable factors listed in rule 7.955(b) of the Cal. Rules of Court. Respond to item 18a(2) on page 7 and attach a copy of any written attorney fee agreement as Attachment 18a.) b. The following additional items of expense (other than medical expenses) have been incurred or paid, are reasonable, resulted from the incident or accident, and should be paid out of claimant's share of the proceeds of the settlement or judgment: items Payees (names) Amounts $ $ $ $ $ $ $ $ $ $ Petitioner is requesting 19.4% of the total costs $ 10,315.90 Continued on Attachment 14b. Total: $ 15. Reimbursement of expenses paid by petitioner a. [) Petitioner has paid none of the claimant's expenses listed in items 13 and 14 for which reimbursement is requested. b. [4%] Petitioner has paid (or become obligated to pay) the following total amounts of the claimant's expenses for which reimbursement is requested. (1) (] Medical expenses listed in item 13: go (2) [<] Attorney's fees included in the total fee amount shown in item 14a: $ 2,000.00 (3) [¥-] Other expenses included in the total shown in item 14b: $ 2,000.00 Total: — $ [4,000.00 (Attach proofs of the expenses incurred and payments made or obligations to pay incurred, e.g., bills or invoices, canceled checks, credit card statements, explanations of benefits from insurers, etc.) 16. Net balance of proceeds for the claimant The balance of the proceeds of the proposed settlement or judgment remaining for the claimant after payment of all requested fees and expenses is: [6,000.00 17. Summary a. Gross amount of proceeds of settlement or judgment for claimant: g 10,000.00 b. Medical expenses to be paid from proceeds of settlement or judgment: $0 c. Attomey's fees to be paid from proceeds of settlement or judgment: $ 2,000.00 d. Expenses (other than medical) to be paid from proceeds of settlement or judgment: 2,000.00 e. Total of fees and expenses to be paid from proceeds of settlement or judgment (add (b), (c), and (a)): $(4,000.00 SS) f. Balance of proceeds of settlement or judgment available for claimant after payment of all fees and expenses (subtract (e) from (a): $ MC-S60 (Rev. January 2069) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Sof10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MG-350 CASE NAME: ‘CASE NUMBER: Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 18. Information about attorney representing or assisting petitioner a. (1) Petitioner has not been represented or assisted by an attorney i in preparing this petition or in any other way with respect to the claim asserted. (Go to item 19.) (2) (¥] [4] Petitioner has been represented or assisted by an attorney in preparing this petition or with respect to the claim asserted. Petitioner and the attorney donot [¥_] do have an agreement for services provided in connection with the claim giving rise to this petition. (If you answered “do,” attach a copy of the agreement as Attachment 18a, and complete items 18b—18f.) b. The attomey who has represented or assisted petitioner is (name): Mark Hooshmand, Esq. (1) State Bar number; 194878 (2) Law firm: Hoohsmand Law Group (2) Address: 22 Battery Street, Suite 610, San Francisco, CA 94111 (4) Telephone number: c. The attorney has not [__] has received attomey’s fees or other compensation in addition to that requested in this petition for services provided in connection with the claim giving rise to this petition. (if you answered "has," identify the person who paid the fees or other compensation, the amounts paid, and the dates of payment): From whom (names) Amounts Dates PHAaH [21 Continued on Attachment 18c. d. Theattomey [7] didnot [ did become concemed with this matter, directly or indirectly, at the instance of a party against whom the claim is asserted or a party's insurance carrier. (If you answered "did," explain the circumstances in Attachment 18d.) e. The attorney isnot [7] is representing or employed by any other party or any insurance carrier involved in the matter. (if you answered ‘is,” identify the party or carrier and explain the relationship in Attachment 18e.) f. Theattomey [_] doesnot [7] does expect to receive attorney's fees or other compensation in addition to that requested in this petition for services provided in connection with the claim giving rise to this petition. (if you answered "does," identify the person who will pay the fees or other compensation, the amounts to be paid, and the expected dates of payment): Erom whom (names) Amounts Expected dates Ella Rochelle-Lawton ¢ 2,000.00 Upon approval Baz Rochelle 2,000.00 Upon release execution $ $ $ (1 Continued on Attachment 18F. MC-360 (Rew. January 1, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 7 of 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 CASE NAME: ‘CASE NUMBER: | Angelique Rochelle, et al. v. Trevor Deng, et al. ‘CGC-16-555761 19. Disposition of balance of proceeds of settlement or judgment Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows: a. There is a guardianship of the estate of the minor or a conservatorship of the estate of the adult person with a disability filed in (name of court): Case no.: (1) $ of the proceeds in money or other property will be paid or delivered to the guardian of the estate of the minor or the conservator of the estate of the conservatee. The money or other property is specified in Attachment 19a(1). (2) [{] Petitioner is the guardian or conservator of the estate of the minor or the adult person with a disability. (3) MC-350 [Rev. January 1, 2011] Petitioner requests authority to deposit or invest $ of the money or other property to be paid or delivered under 19a(1) with one or more financial institutions in this state or with a trust company, subject to withdrawal only as authorized by the court. The money or other property and the name, branch, and address of each financial institution or trust company are specified in Attachment 19a(2). Petitioner proposes that all or a portion of the proceeds not become part of the guardianship or conservatorship estate. Petitioner requests authority to deposit or transfer these proceeds as follows (check all that apply): @ Cs will be deposited in insured accounts in one or more financial institutions in this state from which no withdrawals can be made without a court order. The name, branch, and address of each depository are specified in Attachment 19a(3). (b) $ will be invested in a single-premium deferred annuity subject to withdrawal only on order of the court. The terms and conditions of the annuity are specified in Attachment 19a(3). @¢ C$ will be transferred to a custodian for the benefit of the minor under the California Uniform Transfers to Minors Act. The name and address of the proposed custodian and the property to be transferred are specified in Attachment 19a(3). @ C$ will be transferred to the trustee of a trust that is either created by or approved of in the order approving the settlement or the judgment given or to be given for the minor. This trust is revocable when the minor attains the age of 18 years and contains all other terms and conditions determined to be necessary by the court to protect the minor's interests. The terms of the proposed trust and the property to be transferred are specified in Attachment 19a(3). A copy of the (proposed) judgment is attached as Attachment 4c. (e) $ will be transferred to the trustee of a special needs trust under Probate Code sections 3602(d) and 3604 for the benefit of the minor or the adult person with a disability. The terms of the proposed special needs trust and the property to be transferred are specified in Attachment 19a(3). PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page Gof 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 (CASE NAME: t-Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 ‘CASE NUMBER: 19. Disposition of balance of proceeds of settlement or judgment (cont.) Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows: b. [_] There is no guardianship of the estate of the minor or conservatorship of the estate of the adult person with a disability. Petitioner requests that the balance of the proceeds of the settlement or judgment be disbursed as follows (check ail that apply): (1) (2) (3) A guardian of the estate of the minor or a conservator of the estate of the adult person with a disability will be appointed. $ of money and other property will be paid or delivered to the person so appointed. The money or other property are specified in Attachment 19b(1). $ of money will be deposited in insured accounts in one or more financial institutions in this state, subject to withdrawal only upon the authorization of the court. The name, branch, and address of each depository are specified in Attachment 19b(2). of money will be invested in a single-premium deferred annuity, subject to withdrawal only upon the authorization of the court. The terms and conditions of the annuity are specified in Attachment 19b(3). 4) (7 $ will be paid or transferred to the trustee of a special needs trust under (8) (6) 7” (8) (9) (10) (11) Probate Code sections 3604 and 3611(c) for the benefit of the minor or the adult person with a disability. The terms of the proposed special needs trust and the money or other property to be paid or transferred are specified in Attachment 19b(4). $ will be paid or delivered to a parent of the minor, upon the terms and under the conditions specified in Probate Code sections 3401-3402, without bond. The name and address of the parent and the money or other property to be delivered are specified in Attachment 19b(5). (Value of minor's entire estate, including the money or property to be delivered, must not exceed $5,000.) $ will be transferred to a custodian for the benefit of the minor under the California Uniform Transfers to Minors Act. The name and address of the proposed custodian and the money or other property to be transferred are specified in Attachment 19b(6). $ will be transferred to the trustee of a trust that is either created by or approved of in the order approving the settlement or the judgment given or to be given for the minor. This trust is revocable when the minor attains the age of 18 years and contains all other terms and conditions determined to be necessary by the court to protect the minor's interests. The terms of the proposed trust and the money or other property to be transferred are specified in Attachment 19b(7). () Acopy of the (proposed) judgment is attached as Attachment 4c. $ of money will be held on such conditions as the court in its discretion determines is in the best interest of the minor or the adult person with a disability. The proposed conditions are specified ‘on Attachment 19b(8). (Value must not exceed $20,000.) $ of property other than money will be held on such conditions as the court in its discretion determines is in the best interest of the minor or the adult person with a disability. The proposed conditions and the property are specified in Attachment 19b(9). $ will be deposited with the county treasurer of the County of (name): The deposit is authorized under and subject to the conditions specified in Probate Code section 361 1(h). $ will be paid or transferred to the adult person with a disability. The money or other property is specified in Attachment 19b(11). Continued on Attachment 19. MC-350 [Rev. January 1, 2011] PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 8 of 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)MC-350 CASE NAME: : ‘CASE NUMBER: j Angelique Rochelle, et al. v. Trevor Deng, et al. CGC-16-555761 20. [] Statutory liens for special needs trust Petitioner requests a court order for payment of funds to a special needs trust (explain how statutory lens under Probate Cade section 3604, if any, will be satisfied): Continued on Attachment 20. 21. (_] Additional orders Petitioner requests the following additional orders (specify and explain): Continued on Attachment 21. 22. Petitioner recommends the compromise settlement or the proposed disposition of the proceeds of the judgment for the claimant to the court as being fair, reasonable, and in the best interest of the claimant and requests that the court approve this compromise settlement or proposed disposition and make such other and further orders as may be just and reasonable. 23. Number of pages attached: i Date: March 5, 2018 Tyson Redenbarger, Esq. » Wwe {TYPE OR PRINT NAME OF ATTORNEY) (SIGNATURE OF ATTORNEY) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and corre Date: March 5, 2018 Angelique Rochelle > {IVPE OR PRINT NAME OF PETITIONER) (BIGNAT ER) MC-250 (Rev. January 1, 2011) PETITION TO APPROVE COMPROMISE OF DISPUTED CLAIM Page 10 of 10 OR PENDING ACTION OR DISPOSITION OF PROCEEDS OF JUDGMENT FOR MINOR OR PERSON WITH A DISABILITY (Miscellaneous)Total for Client Cost Court Reporter Date 10/24/20 17 08/09/20 17 08/09/20 17 08/09/20 17 08/09/20 17 09/11/20 17 09/11/20 17 09/11/20 17 09/11/20 17 11/01/20 17 11/01/20 17 Name Memo/Description Amount Cogent Legal, Retainer - Rochelle v Deng Nov. 13, LLC 2017 trial DeAlba Reporting Invoice 9245 - Rochelle - Depo of Yu Service Tao Tan 7/17/17 DeAlba Reporting Invoice 9243 - Rochelle - Depo of May Service Deng 7/13/17 DeAlba Reporting Invoice 9237 - Rochelle - Depo of Trevor Service Deng 7/12/17 DeAlba Reporting Invoice 9206 - Shkipin - Depo of Chris Service Lee 6/19/17 US Legal Support (CA Invoice 410092535 - Rochelle - Records Reporting) of Douglas Wong US Legal Support (CA Invoice 410092533 - Rochelle - Records Reporting) of Laurel Properties US Legal Support (CA Invoice 410092530 - Rochelle - Records Reporting) of Raymond Alives US Legal Support (CA Reporting) Invoice 410084782 - Rochelle DeAlba Reporting Invoice 9417 - Rochelle - Depo of Service William Wong 10/4/2017 DeAlba Reporting Invoice 9419 - Rochelle - Depo of Doug Service Wong 10/15/2017 10,000.00 $ 10,000.00 400.80 1,143.90 1,380.20 671.70 125.00 95.00 95.00 247,52 286.25 406.6011/01/20 17 11/01/20 17 11/01/20 17 11/14/20 17 11/14/20 17 11/14/20 17 11/14/20 17 11/14/20 17 11/14/20 17 11/14/20 17 DeAlba Invoice 9423 - Rochelle - Dept. 301 Reporting Motion to Compel Discovery and Defs' Service Protective Order Hearing 9/14/2017 DeAlba Reporting Invoice 9385 - Rochelle - Depo of Trevor Service Deng, Vol. I] 9/21/2017 DeAlba Reporting Invoice 9389 - Rochelle - Depo of Calvin Service Chan 9/27/2017 US Legal Support (CA Invoice 110089151 - Rochelle - Certified Reporting) Transcript of John Lawton US Legal Support (CA Invoice 110076634 - Rochelle - Certified Reporting) Transcript of Baz Rochelle US Legal Support Invoice 110091079 - Rochelle - Certified (CA Transcript and Arbitrator's Copy of Reporting) Transcript US Legal Support (CA Invoice 110096149 - Rochelle - Certified Reporting) Transcript of Paul Elizondo, D.O. US Legal Support (CA Invoice 110090328 - Rochelle - Certified Reporting) Transcript of Paul Elizondo, D.O. US Legal Support (CA Invoice 110091102 - Rochelle - Certified Reporting) Transcript of Hearing US Legal Support (CA Invoice 110083513 - Rochelle - Certified Reporting) Transcript of Angelique Rochelle, Vol. I 889.15 699.65 402.40 309.45 435.91 364.54 327.30 343.35 299.10 942.30Total for Court Reporter Deposition Fee Total for Deposition Fee Discovery Total for Discovery Expert Witness 11/14/20 17 11/14/20 17 11/14/20 17 01/17/20 18 09/27/20 17 01/01/20 17 06/01/20 17 06/28/20 17 10/20/20 17 US Legal Support (CA Invoice 110093253 - Rochelle - Certified Reporting) Transcript Raymond Tom Palsay III 240.45 US Legal Support (CA Invoice 110091524 - Rochelle - Certified Reporting) Transcript of Richard Devine 373.05 US Legal Support (CA Invoice 110076635 - Rochelle - Certified Reporting) Transcript of Ella Lawton 332.75 DeAlba Reporting Invoice 9447 - Rochelle - Depo of Eric Service Drabkin 10/23/2017 454.95 $ 11,266.32 Calvin Rochelle - Witness Fee and travel, Tran deposition of Calvin Tran 55.00 $ 55.00 Joffe Investigati ons Rochelle - Surveillance, 12/5/16 323.00 TLOx Transunio Rochelle - TLOx address reports, persons n and license plate research 100.00 Kaiser Permanent e Rochelle - Medical Records Request 0.00 $ 423.00 Eric Drabkin Rochelle v Deng deposition 10/23 915.00Total for Expert Witness Filing Fee 10/23/20 17 10/30/20 17 12/15/20 17 12/15/20 17 12/08/20 16 01/13/20 17 02/22/20 17 04/11/20 17 05/12/20 17 06/23/20 17 09/19/20 17 10/05/20 17 11/02/20 17 Eric Rochelle v Deng deposition 10/23 - Drabkin second check Invoice 2442 - Rochelle - Expert Witness RJD, LLC Rendered - 9/28/17 - 10/23/17, 8.5 hrs Invoice 2452 - Rochelle - Expert Witness RJD, LLC Rendered - 11/20/17 - 11/27/17 Judy H. Rothschild Rochelle - Trial Consultant Fees San Francisco Superior Court Rochelle - New Complaint Filing Fee File & ServeXpre Rochelle - File & ServeXpress Filing ss, LLC Fees File & ServeXpre Rochelle - File & ServeXpress Filing ss, LLC Fees File & Rochelle - Plts' Notice of Jury Fees; POS ServeXpre of Summons. Affidavit of Reasonable ss, LLC Diligence and POS by Mail File & ServeXpre Rochelle - Plaintiffs' Case Management ss, LLC Statement San Francisco Superior Rochelle - Transcript, CCH-12-574089, Court 12/12/12 File & ServeXpre Rochelle - Motion to Compel Discovery; ss, LLC Opp to Defs' Motion for Protective Order File & Rochelle - Reply ISO Motion to Compel ServeXpre Discovery; NOE for Protective Order; ss, LLC Opp to MSJ File & Rochelle - Opp to Defs' Motion for ServeXpre Sanctions. Notice of Entry of Order ss, LLC Denying Defs' MSJ 203.33 3,400.00 1,900.00 1,350.00 7,168.33 450.00 47.00 14,00 178.00 15.00 57.00 90.00 60.00 45.00Total for Filing Fee Medical Records Total for Medical Records Messenger Service 08/02/20 17 01/20/20 17 02/17/20 17 03/17/20 17 04/28/20 17 05/26/20 17 06/09/20 17 John Muir Medical Center —_ Rochelle - Leona Paslay Medical Records Western Messenger Service, Inc. Rochelle - Courtesy Copy Drop-Off Western Messenger Service, Inc. Rochelle Filed Summons in SF Court Western Messenger Rochelle - Drop Summons and Service, Complaint to SF Sheriff's Office for Inc. Sheriff to serve Def. Deng Western Messenger Service, Rochelle - Drop Off Courtesy Copies to Inc. Dept. 610 and Dept. 206 Western Messenger Service, Rochelle - Pick Up Docs from Court to Inc. Western Messenger's Office Western Messenger Service, Rochelle - Copy Job from Court to WM Inc. Office $ 956.00 15.00 $ 15.00 14.06 43.00 41.00 30.81 92.50 92.3906/09/20 17 06/16/20 17 07/21/20 17 08/25/20 17 09/01/20 17 09/08/20 17 09/15/20 17 09/29/20 17 10/06/20 17 Western Messenger Service, Rochelle - Research and Printing Docs Inc. from Court to SF Office Western Messenger Service, Rochelle - Send Docs to Court. Returned Inc. Endorsed Copy from Court to SF Office Western Messenger Service, Rochelle - Personally Serve Docs to Inc. Calvin Chan Wester Messenger Rochelle - Personally Serve Docs to Service, Seema Ullal, Aneese Hasnail, Etc. - Inc. 8/18/17 - 8/22/17 Western Messenger Service, Rochelle - Personally Serve Docs to Inc. Seema Ullal Western Messenger Service, Rochelle - Drop Off Courtesy Copy from Ine, WM Office to Court Western Messenger Rochelle - Additional Trip to Court for Service, CC of Reply ISO MTC Discovery and Inc. Request for Sanctions Western Messenger Rochelle - Personally Serve Depo Service, Subpoena to Third Party Witness Calvin Inc. Tran Western Messenger Service, Rochelle - Drop Off Courtesy Copies to Inc. Court 49.50 44.75 156.03 43.54 70.61 5.20 96.00 26.58Western Messenger 10/13/20 Service, Rochelle - Personally Served Docs to Dr. 17 Inc. Paul Elizondo 29.46 Total for Messenger Service $ 931.43 Process Service San Francisco Sheriff's 03/15/20 Departme 17 nt Rochelle - Process Service Fee 40.00 Specialize d Legal 04/18/20 Services, 7 Inc. P147726 - Trevor Deng 120.00 Specialize d Legal 04/18/20 Services, 7 Inc. P147729 - Yu Tao Tan 60.00 Specialize d Legal 04/18/20 Services, 17 Inc. P147728 - May Deng 120.00 Specialize d Legal 09/08/20 Services, Rochelle - P152341 - Service of Doug 17 Inc. Wong 60.00 Total for Process Service $ 400.00 Subpoena US Legal 10/11/20 Support Rochelle - Invoice No. 410092535 - 17 Ine. Records 143.75 US Legal 10/11/20 Support Rochelle - Invoice No. 410092533 - 17 Inc. Records 109.25 US Legal 10/11/20 Support Rochelle - Invoice No. 410084782 - 17 Inc. Records 283.46Total for Subpoena Transcripts Total for Transcripts Video 10/11/20 17 10/27/20 17 08/02/20 17 08/02/20 17 08/04/20 17 10/02/20 17 07/31/20 17 10/04/20 17 10/04/20 \7 11/14/20 17 US Legal Support Inc. US Legal Support Inc. Second Sight Source To Target Translatio ns Wheeler & Hallford, Inc. Source To Target Translatio ns Eureka Street Legal Video Eureka Street Legal Video Eureka Street Legal Video Eureka Street Legal Video Rochelle - Invoice No. 410092530 - Records Rochelle - Invoice No..110087420 - Records Rochelle - depo of Angelique Rochelle, 6/16/17 Invoice 860602 - Rochelle - interpretation at depo of Y. Tan, 7/14/17 Invoice 134223 - transcript for depo of Angelique Rochelle Invoice 830903 - Rochelle - Interpretation at Depo of C. Chan, 9/28/17 INV #ES-1563 - Rochelle - depo of T. Deng (7/12/17), 11 hrs, M. Deng (7/13/17), 10.25 hrs, ¥. Tan (7/14/17), 6.5 hrs INV #ES-1783 - Rochelle - Depo of Trever Deng - 9/21/17, 4.5 hrs INV #ES-1783 - Rochelle - Depo of Calvin Chan - 9/21/17,3 hrs INV #ES-1887 - Rochelle - Eric Drabkin depo (10/23), 3.25 hrs; Mock Trial (10/25), 2 hrs 109,25 299.00 944.71 337.50 1,230.00 831.25 660.00 3,058.75 1,982.50 473.00 293.00 592.50Total for Video Total for Client Cost with sub- accounts Contract labor 01/29/20 18 01/29/20 18 01/29/20 18 11/13/20 17 11/13/20 \7 11/13/20 17 11/13/20 17 11/13/20 17 11/13/20 17 11/13/20 17 11/13/20 17 Eureka Street Legal INV #ES-1815 - Rochelle - William Video "Doug" Wong Depo (10/4/17), 3.75 hrs Eureka Street Legal INV #ES-1813 - Rochelle - Site Video Inspection (10/4/17), 3 hrs Eureka Street Legal INV #ES-1913 - Rochelle - Calvin Tran Video Depo (9/27/17) - Sync Fee Robert Rochelle - Invoice - #49554767 - Mock Half Legal Trial Jury, Daniela Piccetti Robert Rochelle - Invoice - #49600036 - Mock Half Legal Trial Jury, Alan Pham Robert Rochelle - Invoice - #49592071 - Mock Half Legal Trial Jury, Andrew Lei Robert Rochelle - Invoice - #49592077 - Mock Half Legal Trial Jury, Jayme Smiley Robert Rochelle - Invoice #49592075 - Mock Half Legal Trial Jury, Eric Dunn Robert Rochelle - Invoice - #49592076 - Mock Half Legal Trial Jury, Haley Wong Robert Rochelle - Invoice - #49592073 - Mock Half Legal Trial Jury, Elizabeth Freestone Robert _ Rochelle - Invoice - #49592093 - Mock Half Legal Trial Jury, Mayra Morales 412.50 285.00 85.00 $ 4,123.50 $ 51,742.93 135.00 135.00 135.00 135.00 135.00 135.00 135.00 135.00Total for Contract labor Meals and Entertainme nt Total for Meals and Entertainme nt Total for Expenses ‘Thursday, Feb 15, 2018 04:47:42 PM GMT-8 - Accrual Basis 11/13/20 17 11/03/20 7 Robert Rochelle - Invoice - #49592092 - Mock Half Legal Trial Jury, Ugur Ozturk Rochelle - Snacks and Coffee for Mock Specialty's Trial Jurors Total costs divided by 4 plaintiffs 135.00 $ = 1,215.00 106.55 $ 106.55 $ 41,263.59 $ 10,315.90Rochelle v Deng CGC-16-555761 Attachment 18e Plaintiffs’ Attorney is also representing petitioners Angelique Rochelle (mother), Baz Rochelle (sibling), and Leona Lawton (sibling)