On May 12, 2010 a
Hearing
was filed
involving a dispute between
Kwok, Jennifer Shuk-Han,
Kwong, Jeanne,
Ouyang, Feng,
Wong, Gary,
and
Kwok, Jennifer Shuk-Han,
Kwong, Jeanne,
Ouyang, Feng,
Stan Kwong Irrevocable Trust Ii,
Wong, Gary,
for OTHER PROBATE (petition by beneficiary to recover benefits of insurance proceeds from trustee on claims of breach of fiduciary duty, negligence and fraud)
in the District Court of San Francisco County.
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FREELAND COOPER & FOREMAN LLP
150 Spear Street, Suite 1800
San Francisco, California 94105
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Daniel T. Bernhard (CSB #104229)
FREELAND COOPER & FOREMAN LLP
150 Spear Street, Suite 1800 “FILED
San Francisco, California 94105
Telephone: (415) 541-0200
Facsimile: (415) 495-4332
Email: bernhard@freelandlaw.com
Superior Court of Catifornia,
County of San Francisco
06/11/2018
Clerk of the Court
o sas BY:ROBERT WOODS
Attorneys for Petitioner Deputy Clerk
Jennifer Shuk-Han Kwok
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
PROBATE DIVISION
JENNIFER SHUK-HAN KWOK, CASE NO.: PES-10-293505
Petitioner, PETITIONER'S NOTICE OF MOTION AND
MOTION TO TAX COSTS
v.
Hearing Date: July 18, 2018
(Approved by Rosie)
JEANNE KWONG, individually and as a former | Time: 2:00 p.m.
trustee of the Stan Kwong Irrevocable Trust II, Dept. 204, Judge Stewart
Respondent.
AND RELATED CROSS-PETITIONS.
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE that on July 18, 2018 at 2:00 p.m., or as soon thereafter as the
matter can be heard in Department 204 of the Superior Court of California for the City and County
of San Francisco, located at 400 McAllister Street, San Francisco, California, Petitioner Jennifer
Shuk-Han Kwok (“Kwok”) will and hereby does move for an order reducing or taxing the costs
claimed in Respondent Jeanne Kwong's ("Kwong") Memorandum of Costs that were not claimed or
that are improper, unsupported, unreasonable, and/or not reasonably necessary, in accordance with
CCP sections 1032 and 1033.5.
In addition to the specific line items to which an objection is made, Kwok objects to the entire
{00288061} 1
PETITIONER'S NOTICE OF MOTION AND MOTION TO TAX COSTSFREELAND COOPER & FOREMAN LLP
150 Spear Street, Suite 1800
nN
we
Francisco, California 94105
San
oO we 2
y
3
Cost Memorandum on the ground that it is not properly apportioned. Any recoverable costs should be
apportioned to exclude any costs attributable to litigating jointly against other parties: here,
Respondent filed cross-actions against two other parties, which were actively litigated
This motion is based on this Notice of Motion, the memorandum of points and authorities
submitted and filed herewith, the Declaration of Daniel T, Bernhard filed and submitted herewith, the
papers and pleadings on file in this action, and such other evidence as may be presented to and
considered by the Court at the hearing of this matter.
FREELAND COOPER & FOREMAN LLP
By ( (
Daniel’. Bernhard
Dated: June \ \ 22018
Attorneys for Petitioner Jennifer Shuk-~-Han Kwok
{00288061} 2
PETITIONER'S NOTICE OF MOTION AND MOTION TO TAX COSTS
Document Filed Date
June 11, 2018
Case Filing Date
May 12, 2010
Category
OTHER PROBATE (petition by beneficiary to recover benefits of insurance proceeds from trustee on claims of breach of fiduciary duty, negligence and fraud)
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FREELAND COOPER & FOREMAN LLP 150 Spear Street, Suite 1800 San Francisco, California 94105 oo ND nA Bs NN NN N NY NR YN NY eo NN DA A KF HwNH F SS Daniel T. Bernhard (CSB #104229) FREELAND COOPER & FOREMAN LLP 150 Spear Street, Suite 1800 “FILED San Francisco, California 94105 Telephone: (415) 541-0200 Facsimile: (415) 495-4332 Email: bernhard@freelandlaw.com Superior Court of Catifornia, County of San Francisco 06/11/2018 Clerk of the Court o sas BY:ROBERT WOODS Attorneys for Petitioner Deputy Clerk Jennifer Shuk-Han Kwok SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO PROBATE DIVISION JENNIFER SHUK-HAN KWOK, CASE NO.: PES-10-293505 Petitioner, PETITIONER'S NOTICE OF MOTION AND MOTION TO TAX COSTS v. Hearing Date: July 18, 2018 (Approved by Rosie) JEANNE KWONG, individually and as a former | Time: 2:00 p.m. trustee of the Stan Kwong Irrevocable Trust II, Dept. 204, Judge Stewart Respondent. AND RELATED CROSS-PETITIONS. TO ALL PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that on July 18, 2018 at 2:00 p.m., or as soon thereafter as the matter can be heard in Department 204 of the Superior Court of California for the City and County of San Francisco, located at 400 McAllister Street, San Francisco, California, Petitioner Jennifer Shuk-Han Kwok (“Kwok”) will and hereby does move for an order reducing or taxing the costs claimed in Respondent Jeanne Kwong's ("Kwong") Memorandum of Costs that were not claimed or that are improper, unsupported, unreasonable, and/or not reasonably necessary, in accordance with CCP sections 1032 and 1033.5. In addition to the specific line items to which an objection is made, Kwok objects to the entire {00288061} 1 PETITIONER'S NOTICE OF MOTION AND MOTION TO TAX COSTSFREELAND COOPER & FOREMAN LLP 150 Spear Street, Suite 1800 nN we Francisco, California 94105 San oO we 2 y 3 Cost Memorandum on the ground that it is not properly apportioned. Any recoverable costs should be apportioned to exclude any costs attributable to litigating jointly against other parties: here, Respondent filed cross-actions against two other parties, which were actively litigated This motion is based on this Notice of Motion, the memorandum of points and authorities submitted and filed herewith, the Declaration of Daniel T, Bernhard filed and submitted herewith, the papers and pleadings on file in this action, and such other evidence as may be presented to and considered by the Court at the hearing of this matter. FREELAND COOPER & FOREMAN LLP By ( ( Daniel’. Bernhard Dated: June \ \ 22018 Attorneys for Petitioner Jennifer Shuk-~-Han Kwok {00288061} 2 PETITIONER'S NOTICE OF MOTION AND MOTION TO TAX COSTS