Motion-Secondary: ANGELIQUE ROCHELLE ET AL VS. TREVOR DENG ET AL

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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,

ELECTRONICALLY

FILED

Superior Court of California,
County of San Francisco

08/18/2017
Clerk of the Court
BY: SANDRA SCHIRO-
Deputy Clerk

individually 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 RICHARD DEVINE IN
SUPPORT OF PLAINTIFF'S MOTION TO
COMPEL SITE INSPECTION

Date: September 14, 2017
Time: 9:00 a.m.
Dept: 302

DISCOVERY

DECLARATION OF RICHARD DEVINE IN SUPPORT OF PLAINTIFF'S MOTION TO
COMPEL SITE INSPECTION

DECLARATION OF RICHARD DEVINE IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL SITE INSPECTION 1DECLARATION OF RICHARD DEVINE
I, RiCHARD DEVINE, declare the following:

1. lam a retained economics expert for Plaintiff's counsel, Hooshmand Law Group.

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, My topics of opinion include but are not limited to the increase of rents in the San
Fraccisco Bay Area, the expected value of a tenant's continued tenancy within a rental unit, the
fair snarket value of a given rental unit, and the value of the loss of a tenant's rent-controlled unit.
4, I have been retained by the Hooshmand Law Group to render the foregoing opinions in this
case, In order to accurately opine on the above topics in this case, I need to inspect the actual
apartment that the Plaintiff lived in at 776 and 778 25" Avenue, San Francisco, CA 94121 in
order to determine the value of the loss of this rental space. A large part of determining the fair
market value for this apartment would include measuring the apartment's interior, reviewing the
quality and finishings of the unit, as well as seeing the age of the appliances as to compare it to
other comparable units in San Francisco. I also need to see the views the apartment has as well as
noise levels, whether it has sufficient heat, and any other amenities.

5. I need approximately 45 minutes to complete my inspection and I would take steps to avoid
disruptions to any current tenants of the apartment.

6. I would not be able to provide proper opinions based on photographs alone, since I need to
be able to test the appliances, walk through the apartment, and use my all of my senses to evaluate
the value of the unit.

7. I have participated in hundreds of site inspections and I base these statements on my
experience as an expert testifying in San Francisco Superior Court. Part of my goal is to make the
process easier for the Court and jurors in understanding the value of the apartment. J would be

limited in my opinions if I were not allowed to see and inspect the apartment.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Date: August 3, 2017

hak wd Bea

DECLARATION OF RICHARD DEVINE IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL SITE INSPECTION 2