Preview
1 Stacy M. Tucker (SBN 218942)
stucker@kantorlaw.net
2 Jaclyn D. Conover (SBN 266749)
jconover@kantorlaw.net
3
KANTOR & KANTOR LLP
4 19839 Nordhoff Street
Northridge, California 91324
5 Telephone: (818) 886-2525
Facsimile: (818) 350-6272
6
Attorneys for Plaintiff,
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GARY KOOP
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF SONOMA
10
11 GARY KOOP, CASE NO. SCV-266944
12 [Assigned To Hon. Oscar A. Pardo]
Plaintiff,
13 DECLARATION OF STACY MONAHAN
Northridge, California 91324
vs.
KANTOR & KANTOR LLP
19839 Nordhoff Street
TUCKER DOCUMENTING MEET AND
14
(818) 886 2525
CONFER EFFORT AND SANCTION
FIRE INSURANCE EXCHANGE, dba
15 INFORMATION
FARMERS INSURANCE GROUP, BRIAN
HUNSAKER,
16 [Filed concurrently with the Motion to
Compel, Separate Statement, Request for
17 Defendants.
Judicial Notice, and [Proposed] Order]
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21 Action Filed: August 24, 2020
22 Trial Date: November 17, 2023
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1
DECLARATION OF STACY MONAHAN TUCKER
1 I, Stacy Monahan Tucker, declare as follows:
2 1. I am an attorney at law duly licensed to practice before all courts in the State of
3 California and am a partner at the law firm of Kantor & Kantor LLP, attorneys for Gary Koop. I
4 make this Declaration on behalf of Plaintiff in relation to his Motion to Compel Further Document
5 Production and Responses to their Second Set of Requests for Production. I have personal
6 knowledge of the facts stated herein and, if called upon to testify, could and would competently
7 testify thereto.
8 2. On May 15, 2023, I contacted counsel for Defendant Fire Insurance Exchange
9 (“Farmers”), Steven Inouye, and asked to set up a time to meet and confer telephonically about
10 Plaintiff’s pending motion to compel. I had previously contacted his colleagues Margaret Drugan
11 and David Jones with the same request on April 19, 2023, and again on April 27, 2023, without
12 receiving a response. Mr. Inouye agreed to meet and we spoke telephonically on May 17, 2023.
13 The parties were unable to resolve the dispute.
Northridge, California 91324
KANTOR & KANTOR LLP
19839 Nordhoff Street
14 3. As a partner at Kantor & Kantor, my billing rate is $700 per hour. I graduated from
(818) 886 2525
15 the University of Chicago in 1994, and then spent four years as a management consultant advising
16 and restructuring insurance companies. I graduated from the University of Chicago Law School in
17 2001. I have been practicing law without interruption since September 2001. I began practicing at
18 Jones Day in San Francisco, California, where I handled insurance litigation. When I left Jones
19 Day in 2006, the firm billed $450 per hour for my time. I joined Quinn Emanual Urquhart &
20 Sullivan in 2006, where I continued to represent insurance companies. When I left at the end of
21 2008, Quinn Emanuel billed $600 per hour for my time. I joined Ropers Majeski Kohn & Bentley
22 at the start of 2009. My regular billing rate at Ropers Majeski remained $600 throughout my decade
23 at that firm, though if I worked on matters for clients who had specialized rate agreements with the
24 entire firm based on the amount of work they agreed to send to the firm, that firm-wide negotiated
25 rate would apply to my work as well. When I joined Kantor & Kantor in 2020, the firm set my
26 billable rate at $700 per hour and my rate has remained there for the last three years. I am admitted
27 to practice in California, Oregon, Washington, Nevada, Arizona, the Ninth Circuit and the U.S.
28 Supreme Court.
2
DECLARATION OF STACY MONAHAN TUCKER
1 4. I have spent 25.9 hours to date on this discovery dispute, including meet and confer
2 efforts, preparing the motion to compel and supporting documents, reviewing Farmers’ opposition,
3 and preparing the reply. A true and correct copy of my time spent on this matter is attached as
4 Exhibit 1.
5 I declare under penalty of perjury that the foregoing is true and correct and that this
6 Declaration was executed on May 24, 2023 at Woodinville, Washington.
7
8 /s/Stacy M. Tucker
Stacy M. Tucker
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Northridge, California 91324
KANTOR & KANTOR LLP
19839 Nordhoff Street
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(818) 886 2525
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DECLARATION OF STACY MONAHAN TUCKER
EXHIBIT 1
EXHIBIT 1
Case Name: Koop. v. Fire Ins. Exchange et al.
Case No.: SCV-266944
KANTOR & KANTOR ATTORNEY TIME SHEET - Motion to Compel
TOTAL TIME (hours) 25.90
BILLABLE RATE $700.00
TOTAL FEE $18,130.00
DATE DESCRIPTION ATTY HOURS
1/30/2023 Research and prepare first meet and confer letter SMT 1.80
2/7/2023 Email to M. Drugan following up on letter SMT 0.10
2/14/2023 Receive and analyze meet and confer letter from Farmers SMT 0.40
2/16/2023 Prepare email response to meet and confer letter from Farmers SMT 0.30
2/22/2023 Email to M. Drugan following up on meet and confer process SMT 0.10
2/22/2023 Receive and respond to M. Drugan's suggestion to extend time to confer SMT 0.10
3/13/2023 Email to M. Drugan following up on meet and confer process SMT 0.10
3/14/2023 Receive and analyze M. Drugan's email providing position. SMT 0.30
3/15/2023 Respond to M. Drugan's email providing her position SMT 0.60
3/17/2023 Begin preparation of motion to compel, preparing outline and conducting legal SMT 3.40
research
3/21/2023 Continue preparation of motion to compel, drafting and finalizing motion. SMT 7.20
3/21/2023 Prepare separate statement SMT 2.10
3/22/2023 Prepare declaration in support of motion to compel and identify exhibits SMT 1.30
4/19/2023 Email to M. Drugan seeking to schedule meet and confer call SMT 0.10
4/27/2023 Email to M. Drugan following up on request to schedule meet and confer call SMT 0.10
5/15/2023 Email to S. Inouye following up on request to schedule meet and confer call SMT 0.10
5/17/2023 Meet and confer call with S. Inouye SMT 0.20
5/19/2023 Receive and analyze Farmers' opposition to motion to compel, separate statement, SMT 0.70
and declaration
5/20/2023 Research responses to arguments in oppositon brief SMT 1.60
5/21/2023 Begin preparation of reply in support of motion to compel SMT 2.40
5/22/2023 Complete and finalize reply in support of motion to compel SMT 2.20
5/23/2023 Prepare meet and confer declaration required by court SMT 0.40
5/23/2023 Prepare timesheet summary in support of sanctions SMT 0.30
Page 1 of 1
1 PROOF OF SERVICE
2
I, Carolyn Spencer, declare as follows:
3
I am employed in the County of Los Angeles, State of California. I am over the age of 18
4 and not a party to the within action; my business address is 19839 Nordhoff Street, Northridge,
CA 91324.
5
On May 24, 2023, I served the foregoing document described as DECLARATION OF
6 STACY MONAHAN TUCKER IN SUPPORT OF MOTION TO COMPEL AND EXHIBIT
ONE (1) in this action by serving a true copy thereof addressed as follows:
7
Christopher R. Wagner, Esq. cwagner@grsm.com
8
David Jones, Esq. djones@grsm.com
9 Steven Inouye, Esq. sinouye@grsm.com
GORDON REES SCULLY MANSUKHANI, LLP ilopez@grsm.com (assistant)
10 633 West Fifth Street, 52nd floor jodell@grsm.com (assistant)
Los Angeles, CA 90071
11
Attorneys for Defendant Fire Insurance
12
Exchange, dba Farmers Insurance
13 Group
Northridge, California 91324
KANTOR & KANTOR LLP
19839 Nordhoff Street
14 Albert M. T. Finch, III, Esq. tfinch@fgppr.com
(818) 886 2525
Jason Deng, Esq. jdeng@fgppr.com
15 FORAN GLENNON kokasaki@fgppr.com (assistant)
16 1741 Technology Drive, Suite 250
San Jose, CA 95110
17
Attorneys for Defendant Brian Hunsaker
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19 [X] BY E-MAIL SERVICE: I caused a copy of the document(s) to be sent from e-mail address
cspencer@kantorlaw.net to the persons at the e-mail addresses listed above. I did not receive,
20 within a reasonable time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
21
22
[x] STATE: I declare under penalty of perjury under the Laws of the State of California that the
23 foregoing is true and correct.
24 I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed on May 24, 2023, Rohnert Park, California.
25
26 /s/Carolyn Spencer
Carolyn Spencer
27
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4
DECLARATION OF STACY MONAHAN TUCKER
Preview
1 Stacy M. Tucker (SBN 218942) stucker@kantorlaw.net 2 Jaclyn D. Conover (SBN 266749) jconover@kantorlaw.net 3 KANTOR & KANTOR LLP 4 19839 Nordhoff Street Northridge, California 91324 5 Telephone: (818) 886-2525 Facsimile: (818) 350-6272 6 Attorneys for Plaintiff, 7 GARY KOOP 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SONOMA 10 11 GARY KOOP, CASE NO. SCV-266944 12 [Assigned To Hon. Oscar A. Pardo] Plaintiff, 13 DECLARATION OF STACY MONAHAN Northridge, California 91324 vs. KANTOR & KANTOR LLP 19839 Nordhoff Street TUCKER DOCUMENTING MEET AND 14 (818) 886 2525 CONFER EFFORT AND SANCTION FIRE INSURANCE EXCHANGE, dba 15 INFORMATION FARMERS INSURANCE GROUP, BRIAN HUNSAKER, 16 [Filed concurrently with the Motion to Compel, Separate Statement, Request for 17 Defendants. Judicial Notice, and [Proposed] Order] 18 19 20 21 Action Filed: August 24, 2020 22 Trial Date: November 17, 2023 23 24 25 26 27 28 1 DECLARATION OF STACY MONAHAN TUCKER 1 I, Stacy Monahan Tucker, declare as follows: 2 1. I am an attorney at law duly licensed to practice before all courts in the State of 3 California and am a partner at the law firm of Kantor & Kantor LLP, attorneys for Gary Koop. I 4 make this Declaration on behalf of Plaintiff in relation to his Motion to Compel Further Document 5 Production and Responses to their Second Set of Requests for Production. I have personal 6 knowledge of the facts stated herein and, if called upon to testify, could and would competently 7 testify thereto. 8 2. On May 15, 2023, I contacted counsel for Defendant Fire Insurance Exchange 9 (“Farmers”), Steven Inouye, and asked to set up a time to meet and confer telephonically about 10 Plaintiff’s pending motion to compel. I had previously contacted his colleagues Margaret Drugan 11 and David Jones with the same request on April 19, 2023, and again on April 27, 2023, without 12 receiving a response. Mr. Inouye agreed to meet and we spoke telephonically on May 17, 2023. 13 The parties were unable to resolve the dispute. Northridge, California 91324 KANTOR & KANTOR LLP 19839 Nordhoff Street 14 3. As a partner at Kantor & Kantor, my billing rate is $700 per hour. I graduated from (818) 886 2525 15 the University of Chicago in 1994, and then spent four years as a management consultant advising 16 and restructuring insurance companies. I graduated from the University of Chicago Law School in 17 2001. I have been practicing law without interruption since September 2001. I began practicing at 18 Jones Day in San Francisco, California, where I handled insurance litigation. When I left Jones 19 Day in 2006, the firm billed $450 per hour for my time. I joined Quinn Emanual Urquhart & 20 Sullivan in 2006, where I continued to represent insurance companies. When I left at the end of 21 2008, Quinn Emanuel billed $600 per hour for my time. I joined Ropers Majeski Kohn & Bentley 22 at the start of 2009. My regular billing rate at Ropers Majeski remained $600 throughout my decade 23 at that firm, though if I worked on matters for clients who had specialized rate agreements with the 24 entire firm based on the amount of work they agreed to send to the firm, that firm-wide negotiated 25 rate would apply to my work as well. When I joined Kantor & Kantor in 2020, the firm set my 26 billable rate at $700 per hour and my rate has remained there for the last three years. I am admitted 27 to practice in California, Oregon, Washington, Nevada, Arizona, the Ninth Circuit and the U.S. 28 Supreme Court. 2 DECLARATION OF STACY MONAHAN TUCKER 1 4. I have spent 25.9 hours to date on this discovery dispute, including meet and confer 2 efforts, preparing the motion to compel and supporting documents, reviewing Farmers’ opposition, 3 and preparing the reply. A true and correct copy of my time spent on this matter is attached as 4 Exhibit 1. 5 I declare under penalty of perjury that the foregoing is true and correct and that this 6 Declaration was executed on May 24, 2023 at Woodinville, Washington. 7 8 /s/Stacy M. Tucker Stacy M. Tucker 9 10 11 12 13 Northridge, California 91324 KANTOR & KANTOR LLP 19839 Nordhoff Street 14 (818) 886 2525 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 DECLARATION OF STACY MONAHAN TUCKER EXHIBIT 1 EXHIBIT 1 Case Name: Koop. v. Fire Ins. Exchange et al. Case No.: SCV-266944 KANTOR & KANTOR ATTORNEY TIME SHEET - Motion to Compel TOTAL TIME (hours) 25.90 BILLABLE RATE $700.00 TOTAL FEE $18,130.00 DATE DESCRIPTION ATTY HOURS 1/30/2023 Research and prepare first meet and confer letter SMT 1.80 2/7/2023 Email to M. Drugan following up on letter SMT 0.10 2/14/2023 Receive and analyze meet and confer letter from Farmers SMT 0.40 2/16/2023 Prepare email response to meet and confer letter from Farmers SMT 0.30 2/22/2023 Email to M. Drugan following up on meet and confer process SMT 0.10 2/22/2023 Receive and respond to M. Drugan's suggestion to extend time to confer SMT 0.10 3/13/2023 Email to M. Drugan following up on meet and confer process SMT 0.10 3/14/2023 Receive and analyze M. Drugan's email providing position. SMT 0.30 3/15/2023 Respond to M. Drugan's email providing her position SMT 0.60 3/17/2023 Begin preparation of motion to compel, preparing outline and conducting legal SMT 3.40 research 3/21/2023 Continue preparation of motion to compel, drafting and finalizing motion. SMT 7.20 3/21/2023 Prepare separate statement SMT 2.10 3/22/2023 Prepare declaration in support of motion to compel and identify exhibits SMT 1.30 4/19/2023 Email to M. Drugan seeking to schedule meet and confer call SMT 0.10 4/27/2023 Email to M. Drugan following up on request to schedule meet and confer call SMT 0.10 5/15/2023 Email to S. Inouye following up on request to schedule meet and confer call SMT 0.10 5/17/2023 Meet and confer call with S. Inouye SMT 0.20 5/19/2023 Receive and analyze Farmers' opposition to motion to compel, separate statement, SMT 0.70 and declaration 5/20/2023 Research responses to arguments in oppositon brief SMT 1.60 5/21/2023 Begin preparation of reply in support of motion to compel SMT 2.40 5/22/2023 Complete and finalize reply in support of motion to compel SMT 2.20 5/23/2023 Prepare meet and confer declaration required by court SMT 0.40 5/23/2023 Prepare timesheet summary in support of sanctions SMT 0.30 Page 1 of 1 1 PROOF OF SERVICE 2 I, Carolyn Spencer, declare as follows: 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 4 and not a party to the within action; my business address is 19839 Nordhoff Street, Northridge, CA 91324. 5 On May 24, 2023, I served the foregoing document described as DECLARATION OF 6 STACY MONAHAN TUCKER IN SUPPORT OF MOTION TO COMPEL AND EXHIBIT ONE (1) in this action by serving a true copy thereof addressed as follows: 7 Christopher R. Wagner, Esq. cwagner@grsm.com 8 David Jones, Esq. djones@grsm.com 9 Steven Inouye, Esq. sinouye@grsm.com GORDON REES SCULLY MANSUKHANI, LLP ilopez@grsm.com (assistant) 10 633 West Fifth Street, 52nd floor jodell@grsm.com (assistant) Los Angeles, CA 90071 11 Attorneys for Defendant Fire Insurance 12 Exchange, dba Farmers Insurance 13 Group Northridge, California 91324 KANTOR & KANTOR LLP 19839 Nordhoff Street 14 Albert M. T. Finch, III, Esq. tfinch@fgppr.com (818) 886 2525 Jason Deng, Esq. jdeng@fgppr.com 15 FORAN GLENNON kokasaki@fgppr.com (assistant) 16 1741 Technology Drive, Suite 250 San Jose, CA 95110 17 Attorneys for Defendant Brian Hunsaker 18 19 [X] BY E-MAIL SERVICE: I caused a copy of the document(s) to be sent from e-mail address cspencer@kantorlaw.net to the persons at the e-mail addresses listed above. I did not receive, 20 within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 21 22 [x] STATE: I declare under penalty of perjury under the Laws of the State of California that the 23 foregoing is true and correct. 24 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on May 24, 2023, Rohnert Park, California. 25 26 /s/Carolyn Spencer Carolyn Spencer 27 28 4 DECLARATION OF STACY MONAHAN TUCKER