On July 31, 2020 a
Party Discovery
was filed
involving a dispute between
Flores, Sergio Lee Andrew,
and
Jasper Auto Group, Inc.,
Kessenger, Ashley,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
Ffl XED V
DanielP. Schrader (SBN 145670)
dschraderga/mgmlaw.com
N Dane W. Schrader (SBN 317004)
dwschradcr azm law.com
#0)
MANNING GROSS + MASSENBURG LLP F LE
201 Spear Street, 18m Floor SUPERIOR co
San Francisco, CA 94105 CSOAUQgggF gm ?géjrfiggousgm
NARU'NO Dismcr
Tel: 415.5 12.4381
Fax: 415.512.6791 JUN 3 0 202]
Attorneys for Defendants -
BY
ASHLEY KESSENGER and JASPER AUTO GROUP, INC. 4&1“
WA VALLEJO
D
‘
.
dba VICTORVILLE HYUNDAI MAZDA
'
\QOOQOUI
GAR A, DEPU’TY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
LLP
SERGIO LEE ANDREW FLORES, Case No. CIVDSZOISS 1 5
[Assigned t0 Hon. Donald Alvarez, Dept. 523]
Plaintiff,
Massenburg
DECLARATION OF DANE W.
V. SCHRADER IN SUPPORT OF
OPPOSITION TO PLAINTIFF SERGIO
+ ASHLEY KESSENGER; JASPER AUTO LEE ANDREW FLORES MOTION FOR
GROUP, INC; and DOES to 100, inclusive,
1 FURTHER RESPONSES T0 REQUEST
Gross
FOR PRODUCTION 0F DOCUMENTS
Defendants. (SET ONE) AND REQUEST FOR
MONETARY SANCTIONS
Manning
[Filed concurrently with Opposition t0 Motion
t0 Compel Further Responses t0 Requestfor
Production ofDocuments (Set One); Response
t0 Separate Statement in Support 0f
Opposition t0 Motion t0 Compel Further
Responses]
DATE: July 14, 2021
TIME: 9:00 a.m.
DEPT.: 823
Date Filed: July 31, 2020
Trial Date: October 17, 2022
1
DECLARATION 0F DANE w. SCHRADER 1N SUPPORT 0F OPPOSITION To MOTION To COMPEL FURTHER RESPONSES To REQUEST
FOR PRODUCTION 0F DOCUMENTS (SET ONE)
DECLARATION OF DANE W. SCHRADER
I, Dane W. Schrader declare as follows:
1. I am an associate of the law firm of Manning Gross + Massenburg LLP in Los Angeles,
California, attorneys of record for Defendants Ashley Kessenger (“Kessenger”) and Jasper Auto Group
dba Victorville Hyundai Mazda (“Jasper”). Imake this declaration in suppon of Kessenger’s Opposition
to Plaintiff Sergio Lee Andrew Flores’ (“Plaintiff”) Motion to Compel Further Responses t0 Request for
Production of Documents (Set One) and Request for Monetary Sanctions. This declaration is based on
my own personal knowledge, except where stated on information and belief. If called to testify on these
matter, I could and would do so competently.
10 2. On April 23, 2021, Kessenger timely responded to Plaintiff s first set 0f discovery which
11 included requests for admissions, form and special interrogatories, and requests for production of
12 documents. After exchanging multiple e-mails with Plaintiff’s counsel Sayeh Dayen regarding further
13 responses to Plaintiff’s first set of discovery, Kessenger agreed t0 supplement multiple responses t0
14 Plaintiff’s requests, including a privilege log, but requested additional authority supporting further
15 responses to the remainder 0f Plaintiff’s requests. (See Dayen Decl. at Exs. E, G). However. Plaintiff
16 filed four motions to compel further responses to the entire first set of discovery and ceased meet and
17 confer discussions.
18 3. I also explained to counsel that Kessenger produced all of her documents in her
19 possession that were responsive to Plaintiff’s specific and particularized requests and requested that
20 Plaintiff amend his request so it specifically stated the documents he wanted from Kessenger. (See Dayen
21 Decl. at Exs. E, G).
22 4. It took me a total of six hours to review Plaintiff’s Motion to Compel Further Responses
23 to Request for Production of Documents (Set One), prepare the Opposition, this Declaration, Separate
24 Statement in support of the Opposition, gather supporting evidence and t0 meet and confer with
25 Plaintiff’s counsel. I anticipate that I will expend an additional two hours reviewing Plaintiff’s reply
26 memorandum and preparing for and attending the hearing for this Motion. This brings the total hours for
27 this Opposition to eight hours. My reasonable hourly rate is $220.00 which amounts to $1,760.00 in
28
2
DECLARATION OF DANE W. SCHRADER INSUPPORT OF OPPOSITION TO MOTION T0 COMPEL FURTHER RESPONSES TO REQUEST
FOR PRODUCTION OF DOCUMENTS (SET ONE)
Document Filed Date
June 30, 2021
Case Filing Date
July 31, 2020
Category
Personal Injury Motor Vehicle Unlimited
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Ffl XED V DanielP. Schrader (SBN 145670) dschraderga/mgmlaw.com N Dane W. Schrader (SBN 317004) dwschradcr azm law.com #0) MANNING GROSS + MASSENBURG LLP F LE 201 Spear Street, 18m Floor SUPERIOR co San Francisco, CA 94105 CSOAUQgggF gm ?géjrfiggousgm NARU'NO Dismcr Tel: 415.5 12.4381 Fax: 415.512.6791 JUN 3 0 202] Attorneys for Defendants - BY ASHLEY KESSENGER and JASPER AUTO GROUP, INC. 4&1“ WA VALLEJO D ‘ . dba VICTORVILLE HYUNDAI MAZDA ' \QOOQOUI GAR A, DEPU’TY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO LLP SERGIO LEE ANDREW FLORES, Case No. CIVDSZOISS 1 5 [Assigned t0 Hon. Donald Alvarez, Dept. 523] Plaintiff, Massenburg DECLARATION OF DANE W. V. SCHRADER IN SUPPORT OF OPPOSITION TO PLAINTIFF SERGIO + ASHLEY KESSENGER; JASPER AUTO LEE ANDREW FLORES MOTION FOR GROUP, INC; and DOES to 100, inclusive, 1 FURTHER RESPONSES T0 REQUEST Gross FOR PRODUCTION 0F DOCUMENTS Defendants. (SET ONE) AND REQUEST FOR MONETARY SANCTIONS Manning [Filed concurrently with Opposition t0 Motion t0 Compel Further Responses t0 Requestfor Production ofDocuments (Set One); Response t0 Separate Statement in Support 0f Opposition t0 Motion t0 Compel Further Responses] DATE: July 14, 2021 TIME: 9:00 a.m. DEPT.: 823 Date Filed: July 31, 2020 Trial Date: October 17, 2022 1 DECLARATION 0F DANE w. SCHRADER 1N SUPPORT 0F OPPOSITION To MOTION To COMPEL FURTHER RESPONSES To REQUEST FOR PRODUCTION 0F DOCUMENTS (SET ONE) DECLARATION OF DANE W. SCHRADER I, Dane W. Schrader declare as follows: 1. I am an associate of the law firm of Manning Gross + Massenburg LLP in Los Angeles, California, attorneys of record for Defendants Ashley Kessenger (“Kessenger”) and Jasper Auto Group dba Victorville Hyundai Mazda (“Jasper”). Imake this declaration in suppon of Kessenger’s Opposition to Plaintiff Sergio Lee Andrew Flores’ (“Plaintiff”) Motion to Compel Further Responses t0 Request for Production of Documents (Set One) and Request for Monetary Sanctions. This declaration is based on my own personal knowledge, except where stated on information and belief. If called to testify on these matter, I could and would do so competently. 10 2. On April 23, 2021, Kessenger timely responded to Plaintiff s first set 0f discovery which 11 included requests for admissions, form and special interrogatories, and requests for production of 12 documents. After exchanging multiple e-mails with Plaintiff’s counsel Sayeh Dayen regarding further 13 responses to Plaintiff’s first set of discovery, Kessenger agreed t0 supplement multiple responses t0 14 Plaintiff’s requests, including a privilege log, but requested additional authority supporting further 15 responses to the remainder 0f Plaintiff’s requests. (See Dayen Decl. at Exs. E, G). However. Plaintiff 16 filed four motions to compel further responses to the entire first set of discovery and ceased meet and 17 confer discussions. 18 3. I also explained to counsel that Kessenger produced all of her documents in her 19 possession that were responsive to Plaintiff’s specific and particularized requests and requested that 20 Plaintiff amend his request so it specifically stated the documents he wanted from Kessenger. (See Dayen 21 Decl. at Exs. E, G). 22 4. It took me a total of six hours to review Plaintiff’s Motion to Compel Further Responses 23 to Request for Production of Documents (Set One), prepare the Opposition, this Declaration, Separate 24 Statement in support of the Opposition, gather supporting evidence and t0 meet and confer with 25 Plaintiff’s counsel. I anticipate that I will expend an additional two hours reviewing Plaintiff’s reply 26 memorandum and preparing for and attending the hearing for this Motion. This brings the total hours for 27 this Opposition to eight hours. My reasonable hourly rate is $220.00 which amounts to $1,760.00 in 28 2 DECLARATION OF DANE W. SCHRADER INSUPPORT OF OPPOSITION TO MOTION T0 COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)