On August 24, 2021 a
Raymond.Memo of Costs
was filed
involving a dispute between
Raymond, James,
and
Songer, Jacob John,
for Other non-PI/PD/WD Tort Unlimited (35)
in the District Court of Napa County.
Preview
[PLEASE SEE THE ATTACHED POS BY EMAIL SERVICE]
Raymond v. Songer
Superior Court of California, County of Napa Case No. 21CV001225
Memorandum of Costs – Attachment
Attachment 1g
Filing Fees
Date Paper Filed Fee
1. 9/17/21 Filing Defendant’s Answer to Plaintiff’s Complaint $452.25
2. 1/18/22 Filing Case Management Statement $17.14
3. 1/19/22 Obtain copy of Case Management Statement with Napa $79.00
County Superior Court
4. 2/11/22 Filing Post Jury Fees and Demand for Jury Trial $234.26
5. 7/1/22 Filing Case Management Statement $17.64
6. 7/1/22 Obtain copy of Case Management Statement with Napa $81.50
County Superior Court
7. 9/22/22 Filing of Case Management Statement with Napa County $17.64
Superior Court
8. 9/22/22 Filing of Case Management Statement with Napa County $111.50
Superior Court
9. 12/6/22 Filing Notice of Change of Handling Attorney $110.00
10. 1/20/23 Filing Notice with Napa County Superior Court $18.09
11. 5/12/23 Obtain Motion for Summary Judgment, Memorandum of $92.50
Points and Authorities, Separate Statement and
Declaration with Napa County Superior Court
12. 5/15/23 Filing Declaration with Napa County Superior Court $18.09
13. 5/15/23 Filing Motion for Summary Judgment or Summary $518.20
Adjudication, Memorandum of Points and Authorities
and Declaration with Napa County Superior Court
14. 5/15/23 Obtain Notice of Motion with Napa County Superior $248.46
Court
15. 5/19/23 Filing Amended Declaration with Napa County Superior $261.78
Court
16. 6/22/23 Filing Request with Napa County Superior Court $12.95
17. 6/27/23 Filing Request with Napa County Superior Court $18.09
18. 7/28/23 Filing Notice of Motion and Motion to Compel with $106.89
Napa County Superior Court
19. 7/28/23 Filing Ex Parte Application with Napa County Superior $131.89
Court
20. 7/28/23 Filing Proof of Service with Napa County Superior Court $45.09
21. 7/28/23 Filing Notice of Change of Handling Attorney $45.09
22. 7/28/23 One Legal – Filing Response or Reply at Superior Court $18.09
of California, Napa County
23. 8/3/23 Filing Proposed Order at Napa County Superior Court $18.09
24. 8/4/23 Nationwide Legal - Obtain Minute Order with Napa $296.50
County Superior Court
25. 8/8/23 Filing Notice at Napa County Superior Court $18.09
26. 8/14/23 Filing Motion in Limine (x4) at Napa County Superior $18.09
Court
27. 8/18/23 Filing Motion in Limine with Napa County Superior $212.20
Court
28. 8/22/23 Filing Opposition with Napa County Superior Court $18.09
29. 8/24/23 Filing Brief: Trial, Witness List at Napa County Superior $18.09
Court
30. 8/25/23 Filing Opposition to Motion in Limine with Napa County $250.66
Superior Court
31. 8/28/23 Filing Jury Instruction with Napa County Superior Court $18.09
32. 8/28/23 Filing Statement with Napa County Superior Court $18.09
33. 8/28/23 Filing Brief with Napa County Superior Court $18.09
TOTAL $3,560.22
Attachment 4e Deposition Costs
(Deposition Testimony)
Name of Taking Transcribing Travel Video- Total
Deponent Taping
1. Jacob John $119.50 $119.50
Songer (8/31/22)
2. James Raymond $1,199.73 $1,199.73
(8/26/22)
4. Further $2,771.75 $2,771.75
Deposition
Invoicing from
Sims & Sims
Court Reporting
TOTAL $4,090.98
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Attachment 4e.Deposition costs (Cont'd)
(Deposition Subpoenas)
(Costs of "processing, serving deposition subpoenas" and "record production of treating
physician's medical records" in lieu of a personal appearance by the custodian of records,
pursuant to Code of Civil Procedure sections 2020.020 and 2020.410)
Deponent Costs
a. Deponent: Santa Rosa Fire Department (4/28/22) $165.00
b. Deponent: Santa Rosa Police Department (4/28/22) $172.50
c. Deponent: Sonoma County Sheriff’s Office (5/21/22) $172.50
d. Deponent: Napa County Sheriff’s Office (5/21/22) $162.50
e. Deponent: Napa County Counsel c/o Clerk of the Board $130.25
(5/21/22)
f. Deponent: Joe Branum Tree Care Inc. (5/21/22) $215.35
g. Deponent: Farmers Insurance Company Inc. (5/23/22) $199.07
h. Deponent: Cal Fire Sonoma-Lake-Napa (7/25/22) $102.75
i. Deponent: Gib Toby Stump Removal (7.25.22) $172.50
j. Deponent: Pacific Gas and Electric Company c/o Brian $184.00
M. Wong (8/29/22)
TOTAL $1,676.42
Attachment 5d – Service of Process - Attorney Service Expense
Date Paper Fee
a. 12/16/22 Service of Deposition Subpoena for Personal Appearance $202.00
on Ric Armijo
TOTAL $202.00
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Attachment 8b(5) – Expert Fees (per Code of Civil Procedure section 998)
Date Item Total
a. 8/2/23 Plaintiff’s Expert Steve Bickford Deposition and $2,520.79
Deposition Fees (8/2/23)
b. 9/23/21 9/23/21 – Invoice from Defense Expert Pramuk $700.00
Trees and Associates LLC
c. 4/12/22 4/12/22 – Invoice from Defense Expert Pramuk $1,000.00
Trees and Associates LLC
d. 8/1/23 8/1/23 – Invoice from Defense Expert Pramuk $1,100.00
Trees and Associates LLC
9/8/23 9/8/23 – Invoice from Defense Expert Pramuk $1,566.25
Trees and Associates LLC
TOTAL $6,887.04
Attachment 16 (other):1
Item Category Authority Amount
a 5/12/23 - Serving of Documents to Michael W. Rupprecht Reasonably CCP § $290.55
Esq. on Service Date 5/11/23 necessary to 1033.5(a)(16)
conduct
litigation
b 7/21/23 - Serving of Documents to Michael W. Rupprecht Reasonably CCP § $244.00
Esq. on Service Date 7/18/23 necessary to 1033.5(a)(16)
conduct
litigation
c 8/30/23 – Knox Attorney Service Inc. – Billing Services 0 Reasonably CCP § $1,798.22
Outside Printing on Service Date 8/30/23 necessary to 1033.5(a)(16)
conduct
litigation
d 9/20/21 – Online Research Reasonably CCP § $52.34
necessary to 1033.5(a)(16)
conduct
litigation
e 10/1/21 – ATT Teleconference Services, Fee for Reasonably CCP § $6.31
Conference Call on 9/10/21 necessary to 1033.5(a)(16)
1
CCP Section 1033.5 4(c) (2-4) Allowable costs shall be reasonably necessary to the conduct of the
litigation rather than merely convenient or beneficial to its preparation. (3) Allowable costs shall be
reasonable in amount. (4) Items not mentioned in this section and items assessed upon application may
be allowed or denied in the court's discretion.
Item Category Authority Amount
conduct
litigation
f 10/31/21 – Online Research Reasonably CCP § $ 164.76
necessary to 1033.5(a)(16)
conduct
litigation
g 11/30/21 – Online Research Attorney CCP § $149.23
Service 1033.5(a)(16)
Expense
h 12/31/21 – Online Research Reasonably CCP § $71.45
necessary to 1033.5(a)(16)
conduct
litigation
i 1/31/22 – Online Research Reasonably CCP § $117.07
necessary to 1033.5(a)(16)
conduct
litigation
j 2/28/22 – Online Research Reasonably CCP § $209.96
necessary to 1033.5(a)(16)
conduct
litigation
k 3/1/22 – Online Research Reasonably CCP § $3.14
necessary to 1033.5(a)(16)
conduct
litigation
l 9/21/22 – Michael James Ney – Mediator – Review Briefs Reasonably CCP § $1, 250.00
and Conduct Mediation on Service Date 9/19/22 necessary to 1033.5(a)(16)
conduct
litigation
m 8/8/23 - Federal Express – Delivery Services/Messenger to Reasonably CCP § $36.43
Steve Bickford in Pope Valley necessary to 1033.5(a)(16)
conduct
litigation
n 9/5/23 – Copies of Documents for Use At Trial Reasonably CCP § $262.29
necessary to 1033.5(a)(16)
conduct
litigation
TOTAL: $3,405.75
1 PROOF OF SERVICE
James Raymond v. Jacob John Songer
2 Case No. 21CV001225
3 STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO
4 At the time of service, I was over 18 years of age and not a party to this action. I
am employed in the County of San Francisco, State of California. My business address is
5 505 Sansome Street, Suite 1701, San Francisco, CA 94111.
6 On September 19, 2023, I served true copies of the following document(s)
described as:
7
MEMORANDUM OF COSTS (SUMMARY)
8
on the interested parties in this action as follows:
9
Michael W. Rupprecht, Esq. T: 707-252-9000 / F: 707-252-0729
10 GVM LAW, LLP MRupprecht@gvmlaw.com
1000 Main Street, Suite 300 Cathy@gvmlaw.com
11 Napa, CA 94559
Attorneys for Plaintiff, JAMES
12 RAYMOND
13 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent from e-mail address pjohnson@hbblaw.com to the persons at the
14 e-mail addresses listed in the Service List. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was
15 unsuccessful.
16 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
17
Executed on September 19, 2023, at San Francisco, California.
18
19
20 Paula M. Johnson
21
22
23
24
25
26
27
28
NW08-0000074
14701834.1
Document Filed Date
September 20, 2023
Case Filing Date
August 24, 2021
Category
Other non-PI/PD/WD Tort Unlimited (35)
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[PLEASE SEE THE ATTACHED POS BY EMAIL SERVICE] Raymond v. Songer Superior Court of California, County of Napa Case No. 21CV001225 Memorandum of Costs – Attachment Attachment 1g Filing Fees Date Paper Filed Fee 1. 9/17/21 Filing Defendant’s Answer to Plaintiff’s Complaint $452.25 2. 1/18/22 Filing Case Management Statement $17.14 3. 1/19/22 Obtain copy of Case Management Statement with Napa $79.00 County Superior Court 4. 2/11/22 Filing Post Jury Fees and Demand for Jury Trial $234.26 5. 7/1/22 Filing Case Management Statement $17.64 6. 7/1/22 Obtain copy of Case Management Statement with Napa $81.50 County Superior Court 7. 9/22/22 Filing of Case Management Statement with Napa County $17.64 Superior Court 8. 9/22/22 Filing of Case Management Statement with Napa County $111.50 Superior Court 9. 12/6/22 Filing Notice of Change of Handling Attorney $110.00 10. 1/20/23 Filing Notice with Napa County Superior Court $18.09 11. 5/12/23 Obtain Motion for Summary Judgment, Memorandum of $92.50 Points and Authorities, Separate Statement and Declaration with Napa County Superior Court 12. 5/15/23 Filing Declaration with Napa County Superior Court $18.09 13. 5/15/23 Filing Motion for Summary Judgment or Summary $518.20 Adjudication, Memorandum of Points and Authorities and Declaration with Napa County Superior Court 14. 5/15/23 Obtain Notice of Motion with Napa County Superior $248.46 Court 15. 5/19/23 Filing Amended Declaration with Napa County Superior $261.78 Court 16. 6/22/23 Filing Request with Napa County Superior Court $12.95 17. 6/27/23 Filing Request with Napa County Superior Court $18.09 18. 7/28/23 Filing Notice of Motion and Motion to Compel with $106.89 Napa County Superior Court 19. 7/28/23 Filing Ex Parte Application with Napa County Superior $131.89 Court 20. 7/28/23 Filing Proof of Service with Napa County Superior Court $45.09 21. 7/28/23 Filing Notice of Change of Handling Attorney $45.09 22. 7/28/23 One Legal – Filing Response or Reply at Superior Court $18.09 of California, Napa County 23. 8/3/23 Filing Proposed Order at Napa County Superior Court $18.09 24. 8/4/23 Nationwide Legal - Obtain Minute Order with Napa $296.50 County Superior Court 25. 8/8/23 Filing Notice at Napa County Superior Court $18.09 26. 8/14/23 Filing Motion in Limine (x4) at Napa County Superior $18.09 Court 27. 8/18/23 Filing Motion in Limine with Napa County Superior $212.20 Court 28. 8/22/23 Filing Opposition with Napa County Superior Court $18.09 29. 8/24/23 Filing Brief: Trial, Witness List at Napa County Superior $18.09 Court 30. 8/25/23 Filing Opposition to Motion in Limine with Napa County $250.66 Superior Court 31. 8/28/23 Filing Jury Instruction with Napa County Superior Court $18.09 32. 8/28/23 Filing Statement with Napa County Superior Court $18.09 33. 8/28/23 Filing Brief with Napa County Superior Court $18.09 TOTAL $3,560.22 Attachment 4e Deposition Costs (Deposition Testimony) Name of Taking Transcribing Travel Video- Total Deponent Taping 1. Jacob John $119.50 $119.50 Songer (8/31/22) 2. James Raymond $1,199.73 $1,199.73 (8/26/22) 4. Further $2,771.75 $2,771.75 Deposition Invoicing from Sims & Sims Court Reporting TOTAL $4,090.98 \\\ \\\ \\\ \\\ \\\ Attachment 4e.Deposition costs (Cont'd) (Deposition Subpoenas) (Costs of "processing, serving deposition subpoenas" and "record production of treating physician's medical records" in lieu of a personal appearance by the custodian of records, pursuant to Code of Civil Procedure sections 2020.020 and 2020.410) Deponent Costs a. Deponent: Santa Rosa Fire Department (4/28/22) $165.00 b. Deponent: Santa Rosa Police Department (4/28/22) $172.50 c. Deponent: Sonoma County Sheriff’s Office (5/21/22) $172.50 d. Deponent: Napa County Sheriff’s Office (5/21/22) $162.50 e. Deponent: Napa County Counsel c/o Clerk of the Board $130.25 (5/21/22) f. Deponent: Joe Branum Tree Care Inc. (5/21/22) $215.35 g. Deponent: Farmers Insurance Company Inc. (5/23/22) $199.07 h. Deponent: Cal Fire Sonoma-Lake-Napa (7/25/22) $102.75 i. Deponent: Gib Toby Stump Removal (7.25.22) $172.50 j. Deponent: Pacific Gas and Electric Company c/o Brian $184.00 M. Wong (8/29/22) TOTAL $1,676.42 Attachment 5d – Service of Process - Attorney Service Expense Date Paper Fee a. 12/16/22 Service of Deposition Subpoena for Personal Appearance $202.00 on Ric Armijo TOTAL $202.00 \\\ \\\ Attachment 8b(5) – Expert Fees (per Code of Civil Procedure section 998) Date Item Total a. 8/2/23 Plaintiff’s Expert Steve Bickford Deposition and $2,520.79 Deposition Fees (8/2/23) b. 9/23/21 9/23/21 – Invoice from Defense Expert Pramuk $700.00 Trees and Associates LLC c. 4/12/22 4/12/22 – Invoice from Defense Expert Pramuk $1,000.00 Trees and Associates LLC d. 8/1/23 8/1/23 – Invoice from Defense Expert Pramuk $1,100.00 Trees and Associates LLC 9/8/23 9/8/23 – Invoice from Defense Expert Pramuk $1,566.25 Trees and Associates LLC TOTAL $6,887.04 Attachment 16 (other):1 Item Category Authority Amount a 5/12/23 - Serving of Documents to Michael W. Rupprecht Reasonably CCP § $290.55 Esq. on Service Date 5/11/23 necessary to 1033.5(a)(16) conduct litigation b 7/21/23 - Serving of Documents to Michael W. Rupprecht Reasonably CCP § $244.00 Esq. on Service Date 7/18/23 necessary to 1033.5(a)(16) conduct litigation c 8/30/23 – Knox Attorney Service Inc. – Billing Services 0 Reasonably CCP § $1,798.22 Outside Printing on Service Date 8/30/23 necessary to 1033.5(a)(16) conduct litigation d 9/20/21 – Online Research Reasonably CCP § $52.34 necessary to 1033.5(a)(16) conduct litigation e 10/1/21 – ATT Teleconference Services, Fee for Reasonably CCP § $6.31 Conference Call on 9/10/21 necessary to 1033.5(a)(16) 1 CCP Section 1033.5 4(c) (2-4) Allowable costs shall be reasonably necessary to the conduct of the litigation rather than merely convenient or beneficial to its preparation. (3) Allowable costs shall be reasonable in amount. (4) Items not mentioned in this section and items assessed upon application may be allowed or denied in the court's discretion. Item Category Authority Amount conduct litigation f 10/31/21 – Online Research Reasonably CCP § $ 164.76 necessary to 1033.5(a)(16) conduct litigation g 11/30/21 – Online Research Attorney CCP § $149.23 Service 1033.5(a)(16) Expense h 12/31/21 – Online Research Reasonably CCP § $71.45 necessary to 1033.5(a)(16) conduct litigation i 1/31/22 – Online Research Reasonably CCP § $117.07 necessary to 1033.5(a)(16) conduct litigation j 2/28/22 – Online Research Reasonably CCP § $209.96 necessary to 1033.5(a)(16) conduct litigation k 3/1/22 – Online Research Reasonably CCP § $3.14 necessary to 1033.5(a)(16) conduct litigation l 9/21/22 – Michael James Ney – Mediator – Review Briefs Reasonably CCP § $1, 250.00 and Conduct Mediation on Service Date 9/19/22 necessary to 1033.5(a)(16) conduct litigation m 8/8/23 - Federal Express – Delivery Services/Messenger to Reasonably CCP § $36.43 Steve Bickford in Pope Valley necessary to 1033.5(a)(16) conduct litigation n 9/5/23 – Copies of Documents for Use At Trial Reasonably CCP § $262.29 necessary to 1033.5(a)(16) conduct litigation TOTAL: $3,405.75 1 PROOF OF SERVICE James Raymond v. Jacob John Songer 2 Case No. 21CV001225 3 STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO 4 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of San Francisco, State of California. My business address is 5 505 Sansome Street, Suite 1701, San Francisco, CA 94111. 6 On September 19, 2023, I served true copies of the following document(s) described as: 7 MEMORANDUM OF COSTS (SUMMARY) 8 on the interested parties in this action as follows: 9 Michael W. Rupprecht, Esq. T: 707-252-9000 / F: 707-252-0729 10 GVM LAW, LLP MRupprecht@gvmlaw.com 1000 Main Street, Suite 300 Cathy@gvmlaw.com 11 Napa, CA 94559 Attorneys for Plaintiff, JAMES 12 RAYMOND 13 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address pjohnson@hbblaw.com to the persons at the 14 e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was 15 unsuccessful. 16 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 17 Executed on September 19, 2023, at San Francisco, California. 18 19 20 Paula M. Johnson 21 22 23 24 25 26 27 28 NW08-0000074 14701834.1