Preview
Mark Hooshmand, Esq. (SBN 194878)
Tyson Redenbarger, Esq. (SBN 294424)
Hooshmand Law Group
22 Battery Street. Suite 610
San Francisco, CA 94111
Tel: (415) 318-5709
Fax: (415) 376-5897
Attorneys for Plaintiff Angelique Rochelle
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
12/12/2017
Clerk of the Court
BY: EDNALEEN ALEGRE
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA.
COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION
ANGELIQUE ROCHELLE, individually
and as Guardian ad litem of ELLA
LAWTON and LEONA PASLAY and
BAZ ROCHELLE individually
Plaintiffs,
vs.
TREVOR DENG, MAY DENG, YU TAO
TAN and DOES | TO 10,
Defendants.
CASE: CGC-16-555761
DECLARATION OF TYSON
REDENBARGER IN SUPPORT OF
PLAINTIFF'S EX PARTE APPLICATION TO
EXTEND TIME TO ENTER JUDGMENT
AND FILE NEW TRIAL MOTION
Date: December 12, 2017
Time: 2:30 pm
Dept.: 504
DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE
APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL
MOTION
DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND
TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 127
28
I, TYSON REDENBARGER, declare the following:
1.
nN
Jam an attorney for Plaintiffs in this present matter.
The facts stated within this declaration are based upon my personal knowledge, except for
those which are based on information and belief, and I am competent to testify as to these
facts.
Trial in this case concluded on December 4, 2017.
It is understood that Defendant submitted a proposed Judgment After Special Verdict to
the court, but that no Judgment has yet been entered by the Court.
Plaintiff requested the trial transcripts in this matter, and the court reporter indicated that
Plaintiff can anticipate receiving them on or around Friday, December 15, 2017, on an
expedited basis. More time is needed after the transcripts are received to review the
transcripts. According to the court reporter there are nine transcripts. See Exhibit A
attached, a true and correct copy of an email chain with the court reporting company from
this trial.
Plaintiff is also in the process of reaching out to several jurors, to obtain declarations in
support of a motion for new trial. However, with the holidays approaching, Plaintiff does
not anticipate receiving signed juror declarations until at least late December or early
January.
The issues in this case are complicated and additional time is needed to address each
properly.
My office gave opposing counsel notice of this ex parte on Friday Dec. 8, 2017 by email.
Opposing counsel responded on December 11, 2017 at 8:55 am. I also gave telephonic
notice of this hearing on December 11, 2017 at 11:00am. See Exhibit B attached, a true
and correct copy of an email chain with Opposing counsel regarding notice for this
hearing.
DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND
TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 227
28
Date: December 11, 2017 HOOSHMAND LAW GROUP
f)
\Aw < ——__.
Tyson Redenbarger, Esq.
Attorney for Plaintiffs Angelique Rochelle, et al.
DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND
TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 3Exhibit ATyson Redenbarger
From: Lauren Pierce
Sent: Friday, December 8, 2017 9:49 AM
To: Eloisa Sigua
Cc: Mark Hooshmand; Jenny Jin; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Eloisa,
Yes, we are confirmed for the 9 transcripts from trial.
Thanks!
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
‘This email and any attachments thereto may contain private, confidential, and privileged material for the sole u:
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
s
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Friday, December 8, 2017 9:45 AM
To: Lauren Pierce
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
We will be sending you total of 9 transcripts next week (Friday).
Can you please confirm orders for a “yes” total of 9 above?
Thanks, Lauren!
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigui slegalsupport.com
www.uslegalsupport.comLEGAL
PPORT
The Power of Commitment™
U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Lauren Pierce [mailto:lauren@lawmmbh.com]
Sent: Friday, December 08, 2017 9:40 AM
To: Eloisa Sigua
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Eloisa,
That’s great; thank you for working with Lori to accommodate our request. Please let me know if you need anything
further from me.
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged matetial for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
sttictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Friday, December 8, 2017 9:25 AM
To: Lauren Pierce
Subject: RE: Rochelle v. Deng, et al
Good morning Lauren,
| hope all is well. | spoke with the court reporter over the phone yesterday and she is aware with your concerns. Per
court reporter; possible she can get them all done by next week Friday (expedite).
Also, | just realize; there are 9 trial depos to be exact. Attached is the modified updated list for all the trial dep
transcript. Total of 9.Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@uslegalsupport.com
www.uslegalsuppert.com
SLECAL
PPORT /
The Power of Commitment™ 4
U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the franscript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Lauren Pierce [mailto:lauren@lawmmh.com]
Sent: Friday, December 08, 2017 8:46 AM
To: Eloisa Sigua
Ce: Jenny Jin ; Mark Hooshmand ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Eloisa,
As a follow up to our phone call yesterday, I’m confirming that we’d like the trial transcripts as soon as possible. We will
need them for a Motion for a New Trial in the next few weeks, so the regular 8-10 business day turnaround on
transcripts likely won’t work. We are willing to pay the fee to expedite them. As soon as you’re able to get an ETA on the
transcripts, please let me know.
Thanks for your help.
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Lauren Pierce
Sent: Thursday, December 7, 2017 4:32 PMTo: ‘Eloisa Sigua’
Subject: RE: Rochelle v. Deng, et al
Eloisa,
Ok, thank you. Do you have a time estimate for an expedited order?
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tek: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Thursday, December 7, 2017 3:19 PM
To: Lauren Pierce
Subject: RE: Rochelle v. Deng, et al
Would it be possible to have this order expedited? — In this instance, you will pay the expedite fee on the original in
addition to your copy.
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@usiegalsupport.com
www.uslegalsupport.com
LEGAL
PPORT
The Power of Gommitment™
U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.From: Eloisa Sigua
Sent: Thursday, December 07, 2017 2:56 PM
To: ‘Lauren Pierce’
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Sorry. Our IP Phones are DOWN for West Region. Our IT is pushing this hard to get it fix.
Per your request; Ill contact the reporter first and find out what is the quickest time for her to get it done.
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@uslegalsupport.com
www.uslegalsupport.com
LEGAL
PPORT
The Power of Commitme
U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Lauren Pierce [mailto:|auren@lawmmh.com]
Sent: Thursday, December 07, 2017 2:28 PM
To: Eloisa Sigua
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Eloisa,
Would it be possible to have this order expedited? If so, how much more would that cost and when would you be able
to have the transcripts to us?
Also, just FYI, it appears that your phones aren’t working—| wasn’t able to connect to your direct line or to the main line.
Thanks,
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or disttibution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Thursday, December 7, 2017 10:05 AM
To: Lauren Pierce
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Lauren,
Per court reporter; this production will take longer than 8-10 business days plus 2-3 days shipping.
Is that okay?
Eloisa Sigua
US Legal Support ~ San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@uslegalsupport.com
www.uslegalsupport.com
LEGAL
PPORT
The Power of Commitment™
U.S, Legal Support is proud to announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Lauren Pierce [mailto:lauren@lawmmh.com]
Sent: Thursday, December 07, 2017 9:47 AM
To: Eloisa Sigua
Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Eloisa,That’s great—thanks. Yes, please prepare a certified copy of all trial transcripts for us. Can we expect to have them by
the end of next week?
Thanks for your help,
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
‘Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Thursday, December 7, 2017 9:40 AM
To: Lauren Pierce
Subject: RE: Rochelle v. Deng, et al
Lauren,
Hartsuyker confirmed for a copy a order. Would you also like to confirm for a copy? =)
(certified transcript) only.
Thanks!
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@uslegalsupport
LEGAL
PPORT
The Power of Gommitment™
U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.From: Lauren Pierce [mailto:lauren@lawmmh.com]
Sent: Tuesday, December 05, 2017 5:18 PM
To: Eloisa Sigua
Ce: Jenny Jin ; Mark Hooshmand ; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Eloisa,
Sounds good; thank you.
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Tuesday, December 5, 2017 3:45 PM
To: Lauren Pierce
Subject: RE: Rochelle v. Deng, et al
Lauren,
Per our conversation over the phone; I’Il contact the 0 & 1 side if they also would like to obtain a copy order. If they
decide not to order, then your firm will be billed for orgl plus certified which | need confirmation from you if you want us
to proceed or not.
V'll keep you posted.
Eloisa Sigua
US Legal Support ~ San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@uslegalsupport.com
www.uslegalsupport.comSLECAL
PPORT
The Power of Commitment™
U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Eloisa Sigua
Sent: Tuesday, December 05, 2017 3:14 PM
To: ‘Lauren Pierce!
Subject: RE: Rochelle v. Deng, et al
Hi Lauren,
It appears that none of the transcripts are transcribe or nobody requested for a copy. Let me get more info and | will get
back to you.
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@usiegalsupport.com
www.uslegalsupport.com
SLucaL e
PPORT nee
The Power of Commitment”
U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the transcript or a CD of your files, please
contact your local U.S. Legal Support office.
From: Lauren Pierce [mailto:lauren@lawmmh.com
Sent: Tuesday, December 05, 2017 2:36 PM
To: Eloisa Sigua
Cc: Mark Hooshmand ; Jenny Jin ; Marielena Lopez
; Tyson Redenbarger
Subject: RE: Rochelle v. Deng, et al
Hi Eloisa,Thank you for getting these estimates to me. Could we please order certified copies of the following transcripts:
Job # 636527
Job # 636529
Job # 636531
Job # 636532
Job # 638512
Please let me know if there’s anything more that we need to do to get the transcripts.
Thanks,
Lauren Pierce
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Eloisa Sigua [mailto:esigua@uslegalsupport.com]
Sent: Tuesday, December 5, 2017 1:07 PM
To: Lauren Pierce
Subject: Rochelle v. Deng, et al
Hi Lauren,
It was a pleasure speaking with you today. Per your request; below is an estimate to obtain a depo transcript in the
matter of case above.
Job # 625144, 10/5/2017
Witness: John Lawton
$309.95
Job #636527, 11/14/2017
Trial
$513.50
Job # 636529, 11/16/2017
Trial
$223.70
Job # 636531, 11/20/2017
Trial
$196.10
Job # 636532, 11/21/2017
10Trial
$775.70
Job #638512, 11/27/2017
Trial
$817.10
Please let me know if you need anything else.
Best,
Eloisa Sigua
US Legal Support — San Francisco
44 Montgomery Street, Suite 550
San Francisco, California 94104
Direct 415.692.4953
Main 415.362.4346 | Fax 415.362.4495
esigua@usiegalsupport.com
www.uslegalsupport.com
SLEGAL
PPORT i
The Power of Commitment™ a :
U.S. Legal Support is proud fo announce we are green! Our Lifigation Support Package will include all
digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our
secure online portal. Should you require a hard copy of the franscripf or a CD of your files, please
contact your local U.S. Legal Support office.
11Exhibit BTyson Redenbarger
From: Edward Rodzewich
Sent: Monday, December 11, 2017 8:55 AM
To: Jenny Jin
Cc: Mark Hooshmand; Tyson Redenbarger; Sam Leff
Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment
We do not agree to the 10 day extension.
Edward J. Rodzewich, Esq.
HARTSUYKER, STRATMAN &
WILLIAMS-ABREGO
Not a Partnership
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
Office: (510) 457-3460
Cell: (415) 509-4425
From: Jenny Jin [mailto:jenny@lawmmh.com]
Sent: Friday, December 08, 2017 3:09 PM
To: Edward Rodzewich
Cc: Mark Hooshmand ; Tyson Redenbarger ; Sam Leff
Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment
Ed,
Dept. 504 set our ex patte hearing for December 12 at 2:30pm. We will file and serve out moving papers next
Monday afternoon.
With this ex parte pending, let us know if you will stipulate to the court waiting 10 days before entering judgment,
and an additional 10 days for us to file our memorandum and declarations in support of a motion for new trial, per
CCP 659a,
Jenny Jin
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
‘This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
From: Edward Rodzewich [mailto:edward.rodzewich@farmersinsurance.com]
Sent: Thursday, December 7, 2017 7:13 AMTo: Jenny Jin ; Department504 @sfte.org
Cc: Mark Hooshmand ; Tyson Redenbarger ; Sam Leff
Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment
The defense requests that the following judgment be signed.
This form was circulated to plaintiff's counsel on Monday afternoon.
| placed a copy in the court’s in box yesterday.
Thank you.
Edward J. Rodzewich, Esq.
HARTSUYKER, STRATMAN &
WILLIAMS-ABREGO
Not a Partnership
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
Office: (510) 457-3460
Cell: (415) 509-4425
From: Jenny Jin [mailto:jenny@lawmmb.com]
Sent: Wednesday, December 06, 2017 4:39 PM
To: Department504 @sftc.org
Cc: Mark Hooshmand ; Tyson Redenbarger ; Edward Rodzewich
; Sam Leff
Subject: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment
Ms. Fong,
Plaintiff would like to request an ex parte hearing to delay entry of judgment in this matter by 10 days, to ensure
that we are able to obtain the trial transcripts for post-trial motions in time. Please let me know the earliest date and
time available to set this hearing.
‘Thank you,
Jenny Jin
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of
the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is
strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently
delete the original and any copies of this email and any attachments thereto.
*#4*** PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may
2contain privileged and/or confidential information and is intended solely for the addressee(s) named above. If you are
not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying, distribution, or
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you. Please reply to the sender advising of the error in transmission and immediately delete/destroy the message and
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***** PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may
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Preview
Mark Hooshmand, Esq. (SBN 194878) Tyson Redenbarger, Esq. (SBN 294424) Hooshmand Law Group 22 Battery Street. Suite 610 San Francisco, CA 94111 Tel: (415) 318-5709 Fax: (415) 376-5897 Attorneys for Plaintiff Angelique Rochelle ELECTRONICALLY FILED Superior Court of California, County of San Francisco 12/12/2017 Clerk of the Court BY: EDNALEEN ALEGRE Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA. COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION ANGELIQUE ROCHELLE, individually and as Guardian ad litem of ELLA LAWTON and LEONA PASLAY and BAZ ROCHELLE individually Plaintiffs, vs. TREVOR DENG, MAY DENG, YU TAO TAN and DOES | TO 10, Defendants. CASE: CGC-16-555761 DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION Date: December 12, 2017 Time: 2:30 pm Dept.: 504 DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 127 28 I, TYSON REDENBARGER, declare the following: 1. nN Jam an attorney for Plaintiffs in this present matter. The facts stated within this declaration are based upon my personal knowledge, except for those which are based on information and belief, and I am competent to testify as to these facts. Trial in this case concluded on December 4, 2017. It is understood that Defendant submitted a proposed Judgment After Special Verdict to the court, but that no Judgment has yet been entered by the Court. Plaintiff requested the trial transcripts in this matter, and the court reporter indicated that Plaintiff can anticipate receiving them on or around Friday, December 15, 2017, on an expedited basis. More time is needed after the transcripts are received to review the transcripts. According to the court reporter there are nine transcripts. See Exhibit A attached, a true and correct copy of an email chain with the court reporting company from this trial. Plaintiff is also in the process of reaching out to several jurors, to obtain declarations in support of a motion for new trial. However, with the holidays approaching, Plaintiff does not anticipate receiving signed juror declarations until at least late December or early January. The issues in this case are complicated and additional time is needed to address each properly. My office gave opposing counsel notice of this ex parte on Friday Dec. 8, 2017 by email. Opposing counsel responded on December 11, 2017 at 8:55 am. I also gave telephonic notice of this hearing on December 11, 2017 at 11:00am. See Exhibit B attached, a true and correct copy of an email chain with Opposing counsel regarding notice for this hearing. DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 227 28 Date: December 11, 2017 HOOSHMAND LAW GROUP f) \Aw < ——__. Tyson Redenbarger, Esq. Attorney for Plaintiffs Angelique Rochelle, et al. DECLARATION OF TYSON REDENBARGER IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION TO EXTEND TIME TO ENTER JUDGMENT AND FILE NEW TRIAL MOTION 3Exhibit ATyson Redenbarger From: Lauren Pierce Sent: Friday, December 8, 2017 9:49 AM To: Eloisa Sigua Cc: Mark Hooshmand; Jenny Jin; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Eloisa, Yes, we are confirmed for the 9 transcripts from trial. Thanks! Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 ‘This email and any attachments thereto may contain private, confidential, and privileged material for the sole u: the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. s From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Friday, December 8, 2017 9:45 AM To: Lauren Pierce Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al We will be sending you total of 9 transcripts next week (Friday). Can you please confirm orders for a “yes” total of 9 above? Thanks, Lauren! Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigui slegalsupport.com www.uslegalsupport.comLEGAL PPORT The Power of Commitment™ U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office. From: Lauren Pierce [mailto:lauren@lawmmbh.com] Sent: Friday, December 08, 2017 9:40 AM To: Eloisa Sigua Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Eloisa, That’s great; thank you for working with Lori to accommodate our request. Please let me know if you need anything further from me. Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged matetial for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is sttictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Friday, December 8, 2017 9:25 AM To: Lauren Pierce Subject: RE: Rochelle v. Deng, et al Good morning Lauren, | hope all is well. | spoke with the court reporter over the phone yesterday and she is aware with your concerns. Per court reporter; possible she can get them all done by next week Friday (expedite). Also, | just realize; there are 9 trial depos to be exact. Attached is the modified updated list for all the trial dep transcript. Total of 9.Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@uslegalsupport.com www.uslegalsuppert.com SLECAL PPORT / The Power of Commitment™ 4 U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the franscript or a CD of your files, please contact your local U.S. Legal Support office. From: Lauren Pierce [mailto:lauren@lawmmh.com] Sent: Friday, December 08, 2017 8:46 AM To: Eloisa Sigua Ce: Jenny Jin ; Mark Hooshmand ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Eloisa, As a follow up to our phone call yesterday, I’m confirming that we’d like the trial transcripts as soon as possible. We will need them for a Motion for a New Trial in the next few weeks, so the regular 8-10 business day turnaround on transcripts likely won’t work. We are willing to pay the fee to expedite them. As soon as you’re able to get an ETA on the transcripts, please let me know. Thanks for your help. Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Lauren Pierce Sent: Thursday, December 7, 2017 4:32 PMTo: ‘Eloisa Sigua’ Subject: RE: Rochelle v. Deng, et al Eloisa, Ok, thank you. Do you have a time estimate for an expedited order? Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tek: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Thursday, December 7, 2017 3:19 PM To: Lauren Pierce Subject: RE: Rochelle v. Deng, et al Would it be possible to have this order expedited? — In this instance, you will pay the expedite fee on the original in addition to your copy. Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@usiegalsupport.com www.uslegalsupport.com LEGAL PPORT The Power of Gommitment™ U.S. Legal Support is proud to announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office.From: Eloisa Sigua Sent: Thursday, December 07, 2017 2:56 PM To: ‘Lauren Pierce’ Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Sorry. Our IP Phones are DOWN for West Region. Our IT is pushing this hard to get it fix. Per your request; Ill contact the reporter first and find out what is the quickest time for her to get it done. Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@uslegalsupport.com www.uslegalsupport.com LEGAL PPORT The Power of Commitme U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office. From: Lauren Pierce [mailto:|auren@lawmmh.com] Sent: Thursday, December 07, 2017 2:28 PM To: Eloisa Sigua Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Eloisa, Would it be possible to have this order expedited? If so, how much more would that cost and when would you be able to have the transcripts to us? Also, just FYI, it appears that your phones aren’t working—| wasn’t able to connect to your direct line or to the main line. Thanks, Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or disttibution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Thursday, December 7, 2017 10:05 AM To: Lauren Pierce Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Lauren, Per court reporter; this production will take longer than 8-10 business days plus 2-3 days shipping. Is that okay? Eloisa Sigua US Legal Support ~ San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@uslegalsupport.com www.uslegalsupport.com LEGAL PPORT The Power of Commitment™ U.S, Legal Support is proud to announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office. From: Lauren Pierce [mailto:lauren@lawmmh.com] Sent: Thursday, December 07, 2017 9:47 AM To: Eloisa Sigua Cc: Mark Hooshmand ; Jenny Jin ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Eloisa,That’s great—thanks. Yes, please prepare a certified copy of all trial transcripts for us. Can we expect to have them by the end of next week? Thanks for your help, Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 ‘Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Thursday, December 7, 2017 9:40 AM To: Lauren Pierce Subject: RE: Rochelle v. Deng, et al Lauren, Hartsuyker confirmed for a copy a order. Would you also like to confirm for a copy? =) (certified transcript) only. Thanks! Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@uslegalsupport LEGAL PPORT The Power of Gommitment™ U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office.From: Lauren Pierce [mailto:lauren@lawmmh.com] Sent: Tuesday, December 05, 2017 5:18 PM To: Eloisa Sigua Ce: Jenny Jin ; Mark Hooshmand ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Eloisa, Sounds good; thank you. Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Tuesday, December 5, 2017 3:45 PM To: Lauren Pierce Subject: RE: Rochelle v. Deng, et al Lauren, Per our conversation over the phone; I’Il contact the 0 & 1 side if they also would like to obtain a copy order. If they decide not to order, then your firm will be billed for orgl plus certified which | need confirmation from you if you want us to proceed or not. V'll keep you posted. Eloisa Sigua US Legal Support ~ San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@uslegalsupport.com www.uslegalsupport.comSLECAL PPORT The Power of Commitment™ U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office. From: Eloisa Sigua Sent: Tuesday, December 05, 2017 3:14 PM To: ‘Lauren Pierce! Subject: RE: Rochelle v. Deng, et al Hi Lauren, It appears that none of the transcripts are transcribe or nobody requested for a copy. Let me get more info and | will get back to you. Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@usiegalsupport.com www.uslegalsupport.com SLucaL e PPORT nee The Power of Commitment” U.S. Legal Support is proud fo announce we are green! Our Litigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the transcript or a CD of your files, please contact your local U.S. Legal Support office. From: Lauren Pierce [mailto:lauren@lawmmh.com Sent: Tuesday, December 05, 2017 2:36 PM To: Eloisa Sigua Cc: Mark Hooshmand ; Jenny Jin ; Marielena Lopez ; Tyson Redenbarger Subject: RE: Rochelle v. Deng, et al Hi Eloisa,Thank you for getting these estimates to me. Could we please order certified copies of the following transcripts: Job # 636527 Job # 636529 Job # 636531 Job # 636532 Job # 638512 Please let me know if there’s anything more that we need to do to get the transcripts. Thanks, Lauren Pierce Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Eloisa Sigua [mailto:esigua@uslegalsupport.com] Sent: Tuesday, December 5, 2017 1:07 PM To: Lauren Pierce Subject: Rochelle v. Deng, et al Hi Lauren, It was a pleasure speaking with you today. Per your request; below is an estimate to obtain a depo transcript in the matter of case above. Job # 625144, 10/5/2017 Witness: John Lawton $309.95 Job #636527, 11/14/2017 Trial $513.50 Job # 636529, 11/16/2017 Trial $223.70 Job # 636531, 11/20/2017 Trial $196.10 Job # 636532, 11/21/2017 10Trial $775.70 Job #638512, 11/27/2017 Trial $817.10 Please let me know if you need anything else. Best, Eloisa Sigua US Legal Support — San Francisco 44 Montgomery Street, Suite 550 San Francisco, California 94104 Direct 415.692.4953 Main 415.362.4346 | Fax 415.362.4495 esigua@usiegalsupport.com www.uslegalsupport.com SLEGAL PPORT i The Power of Commitment™ a : U.S. Legal Support is proud fo announce we are green! Our Lifigation Support Package will include all digital file formats of your transcripts and exhibits. Your files are also readily available 24/7 via our secure online portal. Should you require a hard copy of the franscripf or a CD of your files, please contact your local U.S. Legal Support office. 11Exhibit BTyson Redenbarger From: Edward Rodzewich Sent: Monday, December 11, 2017 8:55 AM To: Jenny Jin Cc: Mark Hooshmand; Tyson Redenbarger; Sam Leff Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment We do not agree to the 10 day extension. Edward J. Rodzewich, Esq. HARTSUYKER, STRATMAN & WILLIAMS-ABREGO Not a Partnership Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies Office: (510) 457-3460 Cell: (415) 509-4425 From: Jenny Jin [mailto:jenny@lawmmh.com] Sent: Friday, December 08, 2017 3:09 PM To: Edward Rodzewich Cc: Mark Hooshmand ; Tyson Redenbarger ; Sam Leff Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment Ed, Dept. 504 set our ex patte hearing for December 12 at 2:30pm. We will file and serve out moving papers next Monday afternoon. With this ex parte pending, let us know if you will stipulate to the court waiting 10 days before entering judgment, and an additional 10 days for us to file our memorandum and declarations in support of a motion for new trial, per CCP 659a, Jenny Jin Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 ‘This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. From: Edward Rodzewich [mailto:edward.rodzewich@farmersinsurance.com] Sent: Thursday, December 7, 2017 7:13 AMTo: Jenny Jin ; Department504 @sfte.org Cc: Mark Hooshmand ; Tyson Redenbarger ; Sam Leff Subject: RE: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment The defense requests that the following judgment be signed. This form was circulated to plaintiff's counsel on Monday afternoon. | placed a copy in the court’s in box yesterday. Thank you. Edward J. Rodzewich, Esq. HARTSUYKER, STRATMAN & WILLIAMS-ABREGO Not a Partnership Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies Office: (510) 457-3460 Cell: (415) 509-4425 From: Jenny Jin [mailto:jenny@lawmmb.com] Sent: Wednesday, December 06, 2017 4:39 PM To: Department504 @sftc.org Cc: Mark Hooshmand ; Tyson Redenbarger ; Edward Rodzewich ; Sam Leff Subject: Rochelle v. Deng - Ex Parte Hearing to Delay Entry of Judgment Ms. Fong, Plaintiff would like to request an ex parte hearing to delay entry of judgment in this matter by 10 days, to ensure that we are able to obtain the trial transcripts for post-trial motions in time. Please let me know the earliest date and time available to set this hearing. ‘Thank you, Jenny Jin Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited. 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