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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 Plaintiffs Angelique Rochelle, individually
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
08/18/2017
Clerk of the Court
BY: SANDRA SCHIRO
Deputy Clerk
and as Guardian ad litem of Ella Lawton and Leona Paslay and
Baz Rochelle individually
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN FRANCISCO COUNTY — UNLIMITED CIVIL 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 1 TO 10,
Defendants.
CASE: CGC-16-555761
DECLARATION OF MARK HOOSHMAND
IN SUPPORT OF PLAINTIFF'S MOTION
TO COMPEL DISCOVERY AND REQUEST
FOR MONETARY SANCTIONS AGAINST
DEFENDANT AND DEFENDANT'S
COUNSEL
Date: September 14, 2017
Time: 9:00 a.m.
Dept: 302
DISCOVERY
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO
COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST
DEFENDANT AND DEFENDANT'S COUNSEL
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND.
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 1MEET AND CONFER DECLARATION OF MARK HOOSHMAND
I, MARK HOOSHMAND, declare the following:
1. Tam an attorney for Plaintiffs in this present matter.
2. 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.
3. Starting on May 19, 2017, I have met and conferred extensively with Defense Counsel on
Plaintiffs’ need to inspect the Subject Property. I explained that our expert needs to see the rental
unit himself in order to render his opinions, and that we would take steps to minimize any
disruption to the current occupants, or help coordinate with the occupants themselves. Attached as
Exhibit A is a true and correct copy of my meet and confer emails with Defense Counsel.
4. Beginning on August 3, 2017, I sent emails to Seema Ullal, an occupant occupant of the
Subject Property, asking her for a convenient date and time for Plaintiffs to perform a site
inspection of the Subject Property. Ms. Ullal did not agree to the inspection. Attached as Exhibit
B are true and correct copies of my emails with Ms. Ullal.
5. Attached as Exhibit C is a true and correct copy of meet and confer emails I sent to
Defense Counsel on August 14, 2017, regarding the subject third party depositions.
6. We have done everything we can to try to reach a middle ground with defense counsel. For
example we explained at a minimum we would be able to see the common areas of the property
and the garage but Defense counsel refused.
7. Defense counsel's actions are very prejudicial. Defense counsel did not meet and confer in
good faith but rather moved to block all discovery from moving forward. Defense counsel knows
we have a burden to carry and also that we have a high burden as we are attempting to prove fraud
which means that most if not all of the key information is in the hands of the Defendants and those
they spoke with. Therefor, Defense counsel knows that his efforts are directly interfering with our
ability to prove our case. The fact that Defense counsel is blocking all discovery from moving
forward, while at the same time he continues to take depositions and seek information from the
Plaintiffs, is very telling because it is not as if Defense counsel sought to limit one area of
discovery or it is not as if he met and conferred to narrow the scope. He is completely blocking the
discovery and is attempting to make us disclose to him our legal theories concerning each witness
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND.
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 2which basically signals to the witnesses the areas of inquiry. This is highly prejudicial especially
where our trial date is so close.
8. My hourly rate is $500.00 an hour.
9. I have spent 3 hours reviewing and researching this motion and supporting papers, for a
total of $1,500.00 in attorney's fees.
10. I graduated from UCLA School of Law in 1997, and have been practicing law for over 18
years. I ama partner at Hooshmand Group.
11. The Hooshmand Law Group specializes in landlord-tenant matters in the San Francisco
bay area.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Date: August 18, 2017 Ma. yw~)
Mark Hooshmand, Esq.
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 3»
a
~
EXHIBIT A
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 48/17/2017 Workspace Webmail :: Print
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Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
From: "Mark Hooshmand”
Date: Fri, May 26, 2017 9:27 am
To: “Edward Rodzewich" , “Jenny Jin"
Ce: , , "Mark Hooshmand"
Ed,
Civil Code 1954 provides for entry pursuant to court order, If you stipulate to a court order we'll go in the
unit for 30 minutes. We can even coordinate with the tenants. Have you spoken to them because | can
reach out to them too to let them know the circumstances unless you would prefer to coordinate. Let us
know so we can avoid the motion to compel since you are not even open to a middle ground. Our experts
will still need to go by the property in any event. Is the upstairs the same size and layout in which case our
experts can possibly take measurements there but we'll need to see our clients’ unit especially since you
have not agreed not to argue that the experts haven’t been in the unit. We also asked for you to extend the
time for a motion to compel — which if you sent it out 30 days or so from the deadline then we could take
the depositions in the meantime. We're trying to find solutions so let us know as otherwise we have to file.
Thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
For immediate assistance please call (415) 318-5709. 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
Sent: Friday, May 26, 2017 9:13 AM
To: Jenny Jin
Cc: Mark Hooshmand ; tyson@lawmmbh.com ; lauren@lawmmh.com
Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
I do not wish to start list of open items. The unit is occupied by third parties. | see no basis for a motion to compel.
You can simply serve a new notice to inspect at later date if the situation changes.
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
httne-/lamail4? andaddyv.com/view print multi.oho?uidArrav247402|INBOX&aEmiPart=0.
41108/17/2017 Workspace Webmail ;; Print
Office: (510) 457-3460
Cell: (415) 509-4425
From: Jenny Jin [mailto:jenny@lawmmh.com]
Sent: Thursday, May 25, 2017 4:47 PM
To: Edward Rodzewich
Cc: Mark Hooshmand ; tyson@lawmmh.com; lauren@lawmmh.com
Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
Ed,
Under CCP 2031.310, we are obligated to file a motion to compel within 45 days from the response date, or
in this case, the date of your objection to our site inspection notice. Please confirm that this deadline can be
extended to August 1, 2017 while we meet and confer on the issue. Otherwise, we'll need to file a motion to
compel in the next two weeks.
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.
soncecee Original Message --------
Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and
Confer
From: tyson@lawmmh.com
Date: Tue, May 23, 2017 10:46 am
To: "Mark Hooshmand” , "Edward Rodzewich"
Cc: lauren@lawmmh.com, "Jenny Jin"
Ed,
Let us know if you will extend the time for us to file a motion to compel until August 1st while
we meet and confer on the site inspection issue. Without an extension we will have to file the
motion. If you want to complete depositions first, then the extension is the best option so
please let us know. Thanks,
Tyson
Hooshmand Law Group
22 Battery St., Ste. 610
San Francisco, CA 94111
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
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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.
- Original Message ---------
Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
From: "Mark Hooshmand”
Date: 5/19/17 10:20 am
To: "Edward Rodzewich"
Cc: lauren@lawmmh.com, "Tyson" , "Jenny Jin"
, "Mark Hooshmand"
Ed, | believe there is a deadline from the time of your objection. Likely its in CCP 2031. If
you agree to extend any deadline to July 31, 2017 in the meantime that may help. Even if
our client videotaped it wouldn’t be the same. But let us know re the extension. Thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 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
Sent: Friday, May 19, 2017 10:18 AM
To: Mark Hooshmand
Ce: Jauren@lawmmh.com ; Tyson ; Jenny Jin
Subject: RE: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
Why is there a deadline?
Why can’t you wait on this minor, minor issue until depositions are completed, and we see if this
step is even needed. You client may have videotaped the premises for security deposit reasons just
before moving out.
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
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Sent: Friday, May 19, 2017 10:08 AM
To: Edward Rodzewich
Ce: Jauren@lawmmh.com; Tyson ; Jenny Jin ; Mark
Hooshmand
Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
Ed, thank you for following up and we are mindful of the third party privacy rights. That is
why we would agree to limit the time in the unit to 30 minutes, only 2 of our experts would
go plus one attorney and our videographer. But our experts and the jury needs to be able to
see the unit and descriptions alone do not suffice. Also since in most cases the defense
argues that our experts have never been there that’s a major point as well. If you would like
we could write a letter to the current occupants or we could stipulate to the court issuing an
order if that provides you with more comfort regarding a discussion with the occupant to
allow an entry since CC 1954 provides for entry with a court order. We just want to avoid
the motion practice and also your experts could see the unit too, thank you and as we have
a deadline to make the motion let us know, thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA94111
Oakland Office 505 14th St., Ste. 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
Sent: Friday, May 19, 2017 10:06 AM
To: Mark Hooshmand
Cc: lauren@lawmmh.com ; Tyson ; Jenny Jin
Subject: RE: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
| Your experts can place a fair market rental value on the apartment by simply interviewing your own
client and doing neighborhaod research.
My client will also describe the apartment, its size, and its amenities when he is deposed. We have
also provided the amounts that we are renting it for now through discovery.
The third party tenants have privacy rights. My clients have no right to insist on an inspection for
this reason.
If you have a good faith reason why you discovery need outweighs third party privacy rights, based
upon these facts, we will consider your request.
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But there certainly no hurry on this issue.
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
ark Hooshmand [mailto:mark@lawmmh.com
Sent: Friday, May 19, 2017 9:39 AM
To: Edward Rodzewich
Cc: lauren@lawmmh.com; Tyson ; Mark Hooshmand
; Jenny Jin
Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer
Ed, thank you for confirming. Our experts need to see the apartment our client lived in to
make their opinions. We have tried to offer a middle ground but your responses was
basically “no”. Let us know if you have a proposal as otherwise it appears we have no choice
but a motion to compel.
Also please provide dates for your clients’ depositions as we will be sending out notices
today, thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 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
Sent: Friday, May 19, 2017 9:34 AM
To: Jenny Jin ; Mark Hooshmand
Ce: lauren@lawmmh.com ; Tyson
Subject: RE: Rochelle v. Deng: Open Items
June 9 does not work.
We will re-notice her deposition for June 16
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DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 58/17/2017 Workspace Webmail :: Print
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Subject: Re: re Request to See Apartment 778 25th
From: "Mark Hooshmand”
Date: Mon, Aug 14, 2017 10:12 pm
To:
. “Tyson Redenbarger” , “Lauren Pierce" , "Jenny Jin"
* , "Mark Hooshmand”
Seema, thank you for following up. We want to avoid the additional time so let us know if we can make it up
to you — gift certificate or other consideration for allowing a 30-45 minute inspection. The reason is that our
client is a single mother who was wrongfully evicted and the inspection is needed to simply show the unit she
lived in. If the roles were reversed and you had been evicted the same situation would apply. If we have to file
the motion, which we'll be filing this week, it will take far more time and expense and the judge will have to
tule on the request. We want to avoid all this but in the meantime we have no choice. If you have questions
about the inspection let us know as we want to work this out. Let us know if you are agreeable to accepting
the motion by email since otherwise we can have it physically delivered to you. We need to hear back by
Wednesday as we have to file the motion this week. Thank you,
Mark
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
For immediate assistance please contact (415) 318-5709. 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: seemaullal@gmail.com
Sent: Monday, August 14, 2017 8:09 PM
To: Mark Hooshmand
Cc: Tyson Redenbarger ; Lauren Pierce ; Jenny Jin
Subject: Re: re Request to See Apartment 778 25th
Hello,
Under no circumstances do we permit you to enter the apartment at 778 25th Avenue, San Francisco, CA 94121 on September 13 or
any other date. You do not have permission to enter.
Seema Ullal
On Aug 14, 2017, at 2:42 PM, Mark Hooshmand wrote:
Seema, please let us know if you have any questions so we can arrive on a date that works for
everyone. If we can agree that would save a lot of time and expense. Please let us know by this
hitos:/lemail12.qcodaddv.com/view print multi.ohp?uidArrav=51495|INBOX&aEmiPart=08/17/2017 Workspace Webmail :; Print
Wednesday. Thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
For immediate assistance please call (415) 318-5709. 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: Jenny Jin
Sent: Wednesday, August 9, 2017 4:08 PM
To: seemaullal@gmail.com
Cc: Tyson Redenbarger ; Mark Hooshmand ; Lauren Pierce
Subject: RE: re Request to See Apartment 778 25th
Hi Seema,
Please see the attached letter and Notice of Site Inspection concerning 778 25th Avenue. A copy
will also be sent to you and your roommates by mail. If the noticed date of Sept. 13th does not work
for you, please let us know 2-3 dates/times that do for a brief site inspection of the unit.
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. .
seceeeee Original Message --------
Subject: re Request to See Apartment 778 25th
From: "Mark Hooshmand"
Date: Thu, August 03, 2017 4:28 pm
To:
Cc: "Mark Hooshmand"” , "Tyson Redenbarger"
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Workspace Webmail :: Print
, "Jenny Jin"
Hi Seema,
We are attorneys in San Francisco and we represent Angelique Rochelle who used to live in
your apartment. You may have seen the news articles about her. We are reaching out
since as part of our lawsuit we need to see the apartment to show the Court where she
used to live. Could you talk with your roommates and provide 2 or 3 days and times that
work for a 30 minute walk through. We would minimize the time needed and we would
really appreciate your cooperation. As a note we obtained your names from the landlord
and | was able to locate your email through your website (coal website). Please let us
know and we can plan a good date and time, thank you,
Mark
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
For immediate assistance please call (415) 318-5709. 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.
Copyright © 2003-2017. All rights reserved.
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3/3EXHIBIT C
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND
REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 68/17/2017 Workspace Webmail :: Print
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Subject: Re: Rochelle v. Deng - William Wong Deposition / Depositions this Week
From: "Mark Hooshmand”
Date: Mon, Aug 14, 2017 12:24 pm
To: “Edward Rodzewich" , "Daniel Piccinini"
. "Tyson Redenbarger” , , "Lauren Pierce"
_ , "Jenny Jin" , "Mark Hooshmand"
Ed, it is unclear from your letter if you received the letter we sent you on Friday which explained why the
discovery and depositions are relevant. There is no basis to a protective order and you can object to
questions at the time of the deposition if you believe the question is objectionable. The letter you just sent
does not even address the actual discovery at issue but just recites discovery taken in this case. There is no
valid basis to a protective order motion and it would be highly improper as it is being used to prevent our
ability to obtain relevant information. The allegations are that your clients undertook a fraudulent scheme
and we are entitled to obtain evidence to carry our burden of proof. Thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 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
From: Edward Rodzewich
Sent: Monday, August 14, 2017 12:17 PM
To: Mark Hooshmand ; Daniel Piccinini
Ce: Tyson Redenbarger ; marielena@lawmmbh.com ; Lauren Pierce ; Jenny Jin
Subject: RE: Rochelle v. Deng - William Wong Deposition / Depositions this Week
Please find another “meet and confer” letter attached.
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: Mark Hooshmand [mailto:Mark@Lawmmh.com]
Sent: Monday, August 14, 2017 9:09 AM
To: Edward Rodzewich ; Daniel Piccinini
Cc: Tyson Redenbarger ; marielena@lawmmh.com; Lauren Pierce ;
Mark Hooshmand ; Jenny Jin
nttos://email12.qodaddy.comiview print multi.php?uidArray=51428|INBOX&aEmIPart=0
immediately and permanently delete the original and any copies of this email and any attachments thereto.
4/48/17/2017 Workspace Webmail :: Print
Subject: Re: Rochelle v. Deng - William Wong Deposition / Depositions this Week
Importance: High
Ed, please allow the depositions to go forward this week since if you truly have objections they can be made
at the deposition rather than blocking the deposition altogether. In addition, since these are third parties
who we had to coordinate and serve, if you block these depositions it will create significant difficulty and
expense. As we noted in our letter, the defendants placed many items at issue by choosing the path they
chose to evict. In addition, you have not met and conferred in a sufficient fashion to resolve these items.
Given the allegations at issue, including your defenses, we are entitled to take this discovery and since you
do not know what the witnesses know it is improper to argue that it is irrelevant. Thank you,
Mark Hooshmand, Esq.
Hooshmand Law Group
San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111
Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
For immediate assistance please call (415) 318-5709. 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: Jenny Jin
Sent: Friday, August 11, 2017 5:19 PM
To: Edward Rodzewich ; Daniel Piccinini
Cc: Mark Hooshmand ; Tyson Redenbarger ; marielena@lawmmh.com ; Lauren Pierce
Subject: RE: Rochelle v. Deng - William Wong Deposition
Ed,
Please see Plaintiffs' attached meet and confer letter in response to yours.
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.
secceen Original Message --------
Subject: RE: Rochelle v. Deng - William Wong Deposition
i From: Edward Rodzewich
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2/48/17/2017 Workspace Webmail :: Print
Date: Fri, August 11, 2017.11:04 am
i Jenny Jin ‘, Daniel Piccinini
I piccini
ce: Mark Hooshmand SMark@Lawmmb, com>, Tyson Redenbarger
, "marielena@lawmmh.com" ,
Lauren Pierce
We will object to any attempt to take the deposition of Mr. William Wong. We are also objecting to the
depositions of Calvin Chan and Doug Wong, the proposed inspection of property, and your second set of
document requests.
None of these requests are designed to lead to admissible discovery. All of these requests are designed to
harass the defendants and designed to further invade my client’s privacy rights, and the privacy rights of
third parties.
Please find a “meet and confer” letter attached. | mailed this letter yesterday. | plan to file a motion to
protective order on Tuesday of next week if your office does not stop this endless, frivolous discovery.
The motion will now include the deposition of William Wong.
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 lenny Jin [mailto:jen. ny@lawmmh. com}
Sent: Friday, August 11, 2017 10:55 AM
To: Edward Rodzewich ; Daniel Piccinini
Ce: Mark Hooshmand ; Tyson Redenbarger n@Lawmmh.com>;
marielena@lawmmh.com; Lauren Pierce
Subject: Rochelle v. Deng - William Wong Deposition
Ed and Daniel,
We'll be setting third party William Wong's deposition for 11:00am on Sept. 1.
Please confirm you are both available then, if you intend to attend.
Thank you,
Jenny Jin
Hooshmand Law Group
505 14th Street, Suite 320
Oakland, CA 94612
Tel: (415) 318-5709
Fax: (415) 376-5897
httos://email12.qodaddy.com/view _print_multi.ohp?uidArray=51428/INBOX&aEmI|Part=0
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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 Plaintiffs Angelique Rochelle, individually ELECTRONICALLY FILED Superior Court of California, County of San Francisco 08/18/2017 Clerk of the Court BY: SANDRA SCHIRO Deputy Clerk and as Guardian ad litem of Ella Lawton and Leona Paslay and Baz Rochelle individually SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN FRANCISCO COUNTY — UNLIMITED CIVIL 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 1 TO 10, Defendants. CASE: CGC-16-555761 DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL Date: September 14, 2017 Time: 9:00 a.m. Dept: 302 DISCOVERY DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND. REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 1MEET AND CONFER DECLARATION OF MARK HOOSHMAND I, MARK HOOSHMAND, declare the following: 1. Tam an attorney for Plaintiffs in this present matter. 2. 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. 3. Starting on May 19, 2017, I have met and conferred extensively with Defense Counsel on Plaintiffs’ need to inspect the Subject Property. I explained that our expert needs to see the rental unit himself in order to render his opinions, and that we would take steps to minimize any disruption to the current occupants, or help coordinate with the occupants themselves. Attached as Exhibit A is a true and correct copy of my meet and confer emails with Defense Counsel. 4. Beginning on August 3, 2017, I sent emails to Seema Ullal, an occupant occupant of the Subject Property, asking her for a convenient date and time for Plaintiffs to perform a site inspection of the Subject Property. Ms. Ullal did not agree to the inspection. Attached as Exhibit B are true and correct copies of my emails with Ms. Ullal. 5. Attached as Exhibit C is a true and correct copy of meet and confer emails I sent to Defense Counsel on August 14, 2017, regarding the subject third party depositions. 6. We have done everything we can to try to reach a middle ground with defense counsel. For example we explained at a minimum we would be able to see the common areas of the property and the garage but Defense counsel refused. 7. Defense counsel's actions are very prejudicial. Defense counsel did not meet and confer in good faith but rather moved to block all discovery from moving forward. Defense counsel knows we have a burden to carry and also that we have a high burden as we are attempting to prove fraud which means that most if not all of the key information is in the hands of the Defendants and those they spoke with. Therefor, Defense counsel knows that his efforts are directly interfering with our ability to prove our case. The fact that Defense counsel is blocking all discovery from moving forward, while at the same time he continues to take depositions and seek information from the Plaintiffs, is very telling because it is not as if Defense counsel sought to limit one area of discovery or it is not as if he met and conferred to narrow the scope. He is completely blocking the discovery and is attempting to make us disclose to him our legal theories concerning each witness DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND. REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 2which basically signals to the witnesses the areas of inquiry. This is highly prejudicial especially where our trial date is so close. 8. My hourly rate is $500.00 an hour. 9. I have spent 3 hours reviewing and researching this motion and supporting papers, for a total of $1,500.00 in attorney's fees. 10. I graduated from UCLA School of Law in 1997, and have been practicing law for over 18 years. I ama partner at Hooshmand Group. 11. The Hooshmand Law Group specializes in landlord-tenant matters in the San Francisco bay area. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: August 18, 2017 Ma. yw~) Mark Hooshmand, Esq. DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 3» a ~ EXHIBIT A DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 48/17/2017 Workspace Webmail :: Print Print | Close Window Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer From: "Mark Hooshmand” Date: Fri, May 26, 2017 9:27 am To: “Edward Rodzewich" , “Jenny Jin" Ce: , , "Mark Hooshmand" Ed, Civil Code 1954 provides for entry pursuant to court order, If you stipulate to a court order we'll go in the unit for 30 minutes. We can even coordinate with the tenants. Have you spoken to them because | can reach out to them too to let them know the circumstances unless you would prefer to coordinate. Let us know so we can avoid the motion to compel since you are not even open to a middle ground. Our experts will still need to go by the property in any event. Is the upstairs the same size and layout in which case our experts can possibly take measurements there but we'll need to see our clients’ unit especially since you have not agreed not to argue that the experts haven’t been in the unit. We also asked for you to extend the time for a motion to compel — which if you sent it out 30 days or so from the deadline then we could take the depositions in the meantime. We're trying to find solutions so let us know as otherwise we have to file. Thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 For immediate assistance please call (415) 318-5709. 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 Sent: Friday, May 26, 2017 9:13 AM To: Jenny Jin Cc: Mark Hooshmand ; tyson@lawmmbh.com ; lauren@lawmmh.com Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer I do not wish to start list of open items. The unit is occupied by third parties. | see no basis for a motion to compel. You can simply serve a new notice to inspect at later date if the situation changes. 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 httne-/lamail4? andaddyv.com/view print multi.oho?uidArrav247402|INBOX&aEmiPart=0. 41108/17/2017 Workspace Webmail ;; Print Office: (510) 457-3460 Cell: (415) 509-4425 From: Jenny Jin [mailto:jenny@lawmmh.com] Sent: Thursday, May 25, 2017 4:47 PM To: Edward Rodzewich Cc: Mark Hooshmand ; tyson@lawmmh.com; lauren@lawmmh.com Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer Ed, Under CCP 2031.310, we are obligated to file a motion to compel within 45 days from the response date, or in this case, the date of your objection to our site inspection notice. Please confirm that this deadline can be extended to August 1, 2017 while we meet and confer on the issue. Otherwise, we'll need to file a motion to compel in the next two weeks. 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. soncecee Original Message -------- Subject: RE: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer From: tyson@lawmmh.com Date: Tue, May 23, 2017 10:46 am To: "Mark Hooshmand” , "Edward Rodzewich" Cc: lauren@lawmmh.com, "Jenny Jin" Ed, Let us know if you will extend the time for us to file a motion to compel until August 1st while we meet and confer on the site inspection issue. Without an extension we will have to file the motion. If you want to complete depositions first, then the extension is the best option so please let us know. Thanks, Tyson Hooshmand Law Group 22 Battery St., Ste. 610 San Francisco, CA 94111 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 httos://email12.qodaddy.com/view_print_multi.php?uidArray=47402|INBOX&aEm|Part=0 208/17/2017 Workspace Webmail :: Print 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. - Original Message --------- Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer From: "Mark Hooshmand” Date: 5/19/17 10:20 am To: "Edward Rodzewich" Cc: lauren@lawmmh.com, "Tyson" , "Jenny Jin" , "Mark Hooshmand" Ed, | believe there is a deadline from the time of your objection. Likely its in CCP 2031. If you agree to extend any deadline to July 31, 2017 in the meantime that may help. Even if our client videotaped it wouldn’t be the same. But let us know re the extension. Thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 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 Sent: Friday, May 19, 2017 10:18 AM To: Mark Hooshmand Ce: Jauren@lawmmh.com ; Tyson ; Jenny Jin Subject: RE: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer Why is there a deadline? Why can’t you wait on this minor, minor issue until depositions are completed, and we see if this step is even needed. You client may have videotaped the premises for security deposit reasons just before moving out. 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 httns://email12.aodaddv.com/view print multi.oho?uidArray=47402|/INBOX&aEm!|Part=0 308/17/2017 Workspace Webmail :: Print Sent: Friday, May 19, 2017 10:08 AM To: Edward Rodzewich Ce: Jauren@lawmmh.com; Tyson ; Jenny Jin ; Mark Hooshmand Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer Ed, thank you for following up and we are mindful of the third party privacy rights. That is why we would agree to limit the time in the unit to 30 minutes, only 2 of our experts would go plus one attorney and our videographer. But our experts and the jury needs to be able to see the unit and descriptions alone do not suffice. Also since in most cases the defense argues that our experts have never been there that’s a major point as well. If you would like we could write a letter to the current occupants or we could stipulate to the court issuing an order if that provides you with more comfort regarding a discussion with the occupant to allow an entry since CC 1954 provides for entry with a court order. We just want to avoid the motion practice and also your experts could see the unit too, thank you and as we have a deadline to make the motion let us know, thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA94111 Oakland Office 505 14th St., Ste. 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 Sent: Friday, May 19, 2017 10:06 AM To: Mark Hooshmand Cc: lauren@lawmmh.com ; Tyson ; Jenny Jin Subject: RE: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer | Your experts can place a fair market rental value on the apartment by simply interviewing your own client and doing neighborhaod research. My client will also describe the apartment, its size, and its amenities when he is deposed. We have also provided the amounts that we are renting it for now through discovery. The third party tenants have privacy rights. My clients have no right to insist on an inspection for this reason. If you have a good faith reason why you discovery need outweighs third party privacy rights, based upon these facts, we will consider your request. httos://email12.godaddy.com/view_print_multi.php ?uidArray=47402|INBOX&aEmiPart=0 4NO8/17/2017 Workspace Webmail :: Print But there certainly no hurry on this issue. 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 ark Hooshmand [mailto:mark@lawmmh.com Sent: Friday, May 19, 2017 9:39 AM To: Edward Rodzewich Cc: lauren@lawmmh.com; Tyson ; Mark Hooshmand ; Jenny Jin Subject: Re: Rochelle v. Deng: Open Items / Site Inspection Meet and Confer Ed, thank you for confirming. Our experts need to see the apartment our client lived in to make their opinions. We have tried to offer a middle ground but your responses was basically “no”. Let us know if you have a proposal as otherwise it appears we have no choice but a motion to compel. Also please provide dates for your clients’ depositions as we will be sending out notices today, thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 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 Sent: Friday, May 19, 2017 9:34 AM To: Jenny Jin ; Mark Hooshmand Ce: lauren@lawmmh.com ; Tyson Subject: RE: Rochelle v. Deng: Open Items June 9 does not work. We will re-notice her deposition for June 16 httos://email12.godaddy.com/view print muilti.oho?uidArray=47402/INBOX&aEmIiPart=0 5/10EXHIBIT B DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 58/17/2017 Workspace Webmail :: Print Print | Close Window Subject: Re: re Request to See Apartment 778 25th From: "Mark Hooshmand” Date: Mon, Aug 14, 2017 10:12 pm To: . “Tyson Redenbarger” , “Lauren Pierce" , "Jenny Jin" * , "Mark Hooshmand” Seema, thank you for following up. We want to avoid the additional time so let us know if we can make it up to you — gift certificate or other consideration for allowing a 30-45 minute inspection. The reason is that our client is a single mother who was wrongfully evicted and the inspection is needed to simply show the unit she lived in. If the roles were reversed and you had been evicted the same situation would apply. If we have to file the motion, which we'll be filing this week, it will take far more time and expense and the judge will have to tule on the request. We want to avoid all this but in the meantime we have no choice. If you have questions about the inspection let us know as we want to work this out. Let us know if you are agreeable to accepting the motion by email since otherwise we can have it physically delivered to you. We need to hear back by Wednesday as we have to file the motion this week. Thank you, Mark Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 For immediate assistance please contact (415) 318-5709. 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: seemaullal@gmail.com Sent: Monday, August 14, 2017 8:09 PM To: Mark Hooshmand Cc: Tyson Redenbarger ; Lauren Pierce ; Jenny Jin Subject: Re: re Request to See Apartment 778 25th Hello, Under no circumstances do we permit you to enter the apartment at 778 25th Avenue, San Francisco, CA 94121 on September 13 or any other date. You do not have permission to enter. Seema Ullal On Aug 14, 2017, at 2:42 PM, Mark Hooshmand wrote: Seema, please let us know if you have any questions so we can arrive on a date that works for everyone. If we can agree that would save a lot of time and expense. Please let us know by this hitos:/lemail12.qcodaddv.com/view print multi.ohp?uidArrav=51495|INBOX&aEmiPart=08/17/2017 Workspace Webmail :; Print Wednesday. Thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 For immediate assistance please call (415) 318-5709. 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: Jenny Jin Sent: Wednesday, August 9, 2017 4:08 PM To: seemaullal@gmail.com Cc: Tyson Redenbarger ; Mark Hooshmand ; Lauren Pierce Subject: RE: re Request to See Apartment 778 25th Hi Seema, Please see the attached letter and Notice of Site Inspection concerning 778 25th Avenue. A copy will also be sent to you and your roommates by mail. If the noticed date of Sept. 13th does not work for you, please let us know 2-3 dates/times that do for a brief site inspection of the unit. 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. . seceeeee Original Message -------- Subject: re Request to See Apartment 778 25th From: "Mark Hooshmand" Date: Thu, August 03, 2017 4:28 pm To: Cc: "Mark Hooshmand"” , "Tyson Redenbarger" httos://email12.aodaddv.com/view print multi.oho?uidArray=51495}INBOX&aEmIPart=08/17/2017 Workspace Webmail :: Print , "Jenny Jin" Hi Seema, We are attorneys in San Francisco and we represent Angelique Rochelle who used to live in your apartment. You may have seen the news articles about her. We are reaching out since as part of our lawsuit we need to see the apartment to show the Court where she used to live. Could you talk with your roommates and provide 2 or 3 days and times that work for a 30 minute walk through. We would minimize the time needed and we would really appreciate your cooperation. As a note we obtained your names from the landlord and | was able to locate your email through your website (coal website). Please let us know and we can plan a good date and time, thank you, Mark Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 For immediate assistance please call (415) 318-5709. 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. Copyright © 2003-2017. All rights reserved. htine-Jlamail1? andaddv camiview onnt multi. oho?uidArrav251495 INBOX&aEm|Part=0 3/3EXHIBIT C DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT AND DEFENDANT'S COUNSEL 68/17/2017 Workspace Webmail :: Print Print | Close Window Subject: Re: Rochelle v. Deng - William Wong Deposition / Depositions this Week From: "Mark Hooshmand” Date: Mon, Aug 14, 2017 12:24 pm To: “Edward Rodzewich" , "Daniel Piccinini" . "Tyson Redenbarger” , , "Lauren Pierce" _ , "Jenny Jin" , "Mark Hooshmand" Ed, it is unclear from your letter if you received the letter we sent you on Friday which explained why the discovery and depositions are relevant. There is no basis to a protective order and you can object to questions at the time of the deposition if you believe the question is objectionable. The letter you just sent does not even address the actual discovery at issue but just recites discovery taken in this case. There is no valid basis to a protective order motion and it would be highly improper as it is being used to prevent our ability to obtain relevant information. The allegations are that your clients undertook a fraudulent scheme and we are entitled to obtain evidence to carry our burden of proof. Thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 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 From: Edward Rodzewich Sent: Monday, August 14, 2017 12:17 PM To: Mark Hooshmand ; Daniel Piccinini Ce: Tyson Redenbarger ; marielena@lawmmbh.com ; Lauren Pierce ; Jenny Jin Subject: RE: Rochelle v. Deng - William Wong Deposition / Depositions this Week Please find another “meet and confer” letter attached. 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: Mark Hooshmand [mailto:Mark@Lawmmh.com] Sent: Monday, August 14, 2017 9:09 AM To: Edward Rodzewich ; Daniel Piccinini Cc: Tyson Redenbarger ; marielena@lawmmh.com; Lauren Pierce ; Mark Hooshmand ; Jenny Jin nttos://email12.qodaddy.comiview print multi.php?uidArray=51428|INBOX&aEmIPart=0 immediately and permanently delete the original and any copies of this email and any attachments thereto. 4/48/17/2017 Workspace Webmail :: Print Subject: Re: Rochelle v. Deng - William Wong Deposition / Depositions this Week Importance: High Ed, please allow the depositions to go forward this week since if you truly have objections they can be made at the deposition rather than blocking the deposition altogether. In addition, since these are third parties who we had to coordinate and serve, if you block these depositions it will create significant difficulty and expense. As we noted in our letter, the defendants placed many items at issue by choosing the path they chose to evict. In addition, you have not met and conferred in a sufficient fashion to resolve these items. Given the allegations at issue, including your defenses, we are entitled to take this discovery and since you do not know what the witnesses know it is improper to argue that it is irrelevant. Thank you, Mark Hooshmand, Esq. Hooshmand Law Group San Francisco Office 22 Battery St., Ste. 610 San Francisco, CA 94111 Oakland Office 505 14th St., Ste. 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 For immediate assistance please call (415) 318-5709. 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: Jenny Jin Sent: Friday, August 11, 2017 5:19 PM To: Edward Rodzewich ; Daniel Piccinini Cc: Mark Hooshmand ; Tyson Redenbarger ; marielena@lawmmh.com ; Lauren Pierce Subject: RE: Rochelle v. Deng - William Wong Deposition Ed, Please see Plaintiffs' attached meet and confer letter in response to yours. 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. secceen Original Message -------- Subject: RE: Rochelle v. Deng - William Wong Deposition i From: Edward Rodzewich httos://email12.godaddy.com/view_ print_multi.php?uidArray=51428/INBOX&aEmiPart=0 2/48/17/2017 Workspace Webmail :: Print Date: Fri, August 11, 2017.11:04 am i Jenny Jin ‘, Daniel Piccinini I piccini ce: Mark Hooshmand SMark@Lawmmb, com>, Tyson Redenbarger , "marielena@lawmmh.com" , Lauren Pierce We will object to any attempt to take the deposition of Mr. William Wong. We are also objecting to the depositions of Calvin Chan and Doug Wong, the proposed inspection of property, and your second set of document requests. None of these requests are designed to lead to admissible discovery. All of these requests are designed to harass the defendants and designed to further invade my client’s privacy rights, and the privacy rights of third parties. Please find a “meet and confer” letter attached. | mailed this letter yesterday. | plan to file a motion to protective order on Tuesday of next week if your office does not stop this endless, frivolous discovery. The motion will now include the deposition of William Wong. 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 lenny Jin [mailto:jen. ny@lawmmh. com} Sent: Friday, August 11, 2017 10:55 AM To: Edward Rodzewich ; Daniel Piccinini Ce: Mark Hooshmand ; Tyson Redenbarger n@Lawmmh.com>; marielena@lawmmh.com; Lauren Pierce Subject: Rochelle v. Deng - William Wong Deposition Ed and Daniel, We'll be setting third party William Wong's deposition for 11:00am on Sept. 1. Please confirm you are both available then, if you intend to attend. Thank you, Jenny Jin Hooshmand Law Group 505 14th Street, Suite 320 Oakland, CA 94612 Tel: (415) 318-5709 Fax: (415) 376-5897 httos://email12.qodaddy.com/view _print_multi.ohp?uidArray=51428/INBOX&aEmI|Part=0 3/4