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BNRERRPERBRRSSCRSVTABDEBHRAS
Mark Hooshmand, Esq. (SBN 194878)
Tyson Redenbarger, Esq. (SBN 294424)
Jenny Jin, Esq. (SBN 296184)
Hooshmand Law Group
22 Battery Street, Ste. 610
San Francisco, CA 94111
Tel: (415) 318-5709
Fax: (415) 376-5897
Attorneys for Plaintiff Angelique Rochelle
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
02/15/2018
Clerk of the Court
BY: YOLANDA TABO-RAMII
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO - UNLIMITED CIVIL JURISDICTION
ANGELIQUE ROCHELLE,
Plaintiff,
vs.
TREVOR DENG, and DOES 1-10,
Defendants.
eS SS SS ee ee
CASE NO.: CGC-16-555761
DECLARATION OF JENNY JIN IN
SUPPORT OF PLAINTIFF ANGELIQUE
ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT’S MEMORANDUM OF
COSTS
Date: March 21, 2018
Time: 2:00 p.m.
Dept: 504
Judge: Hon. Suzanne Bolanos
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S
MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT’S MEMORANDUM OF COSTS 1om YN DA HM BBW NY
PN YP YN RN Dee ew ew ee ee —
&® Xa RRSK HS Se ARDBARBHR AS
DECLARATION OF JENNY JIN
I, JENNY JIN, declare the following:
1.
2.
I am an attorney for Plaintiff Angelique Rochelle in this matter.
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.
Judgment was entered on December 12, 2017, following the jury’s special verdict in this
matter.
Plaintiff Angelique Rochelle’s three children, Baz Rochelle, Ella Lawton, and Leona
Paslay, were also Plaintiffs in this case, but had resolved their claims against Defendant
after accepting Defendant’s Code of Civil Procedure section 998 offers, prior to the
commencement of trial.
A true and correct copy of Defendant’s Memorandum of Costs, filed on December 27,
2017, is attached hereto as Exhibit A.
Defendant’s only retained expert, Eric Drabkin, gave improper opinions as to measuring
Plaintiff’s loss for a rent-controlled unit through an out-of-pocket method. Mr. Drabkin
further testified at trial that his calculation was “fairly straightforward” as he simply
compared Plaintiff’s prior rent to her new rent amount. A true and correct copy of the
relevant portions of Mr. Drabkin’s trial testimony transcript is attached hereto as Exhibit B.
A true and correct copy of the January 10, 2018 stipulation extending the deadline for
Plaintiff to file the present Motion to Strike/Tax is attached hereto as Exhibit C.
This Court entered an Order denying Plaintiff’s Motion for New Trial on February 14,
2018. My office is preparing a Notice of Appeal as to this order and the underlying
judgment and will be filing it no later than February 22, 2018.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT'S MEMORANDUM OF COSTS 2Co Oe IN DAH BF WN
wR NYRR NK KN ee ee ee et
eon A aA FF oNH |= SOCOM ADA FF WN | SD
Dated: February 15, 2018 SN
ary << 7
Jenny Jin, Esq.
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT'S MEMORANDUM OF COSTS 3Co Oo IN DH BF WN
NN YN YN NNN Be Be Be Be Be Se ee ee
ont AA BF OoONH FS SOD OA DA BF YW NHN | DS
Exhibit A
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT’S MEMORANDUM OF COSTS 4MC-010
[ATTORNEY OR PARTY Wil IOLT ATTORNEY
Name: Edward Rodzewich
riemvaveHartsuyker, Stratman & Williams-Abrego
[streer anpress: P.O, Box 258829
cry: Oklahoma City state OK = zipcove:73 125
TELEPHONE NO: 707-521-4272 FAX NO: 707-544-938 1
EMAL aDpRass, jessica nudelman@farmersinsurance.com
JArroRNeY For (came: Trevor Deng
STATEBAR NUMBER:1 59466
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
stReEeT aobress: 400 McAllister Street
Manne Aopress: 400 McAllister Street
cry aNa zip cove: San Francisco, 94102
BRANCH NAME: Civic Center Courthouse
PLAINTIFF:Angelique Rochelle
DEFENDANT: Trevor Deng
FOR COURT USE ONLY
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
12/27/2017
Clerk of the Court
BY: DAVID YUEN
Deputy Clork
MEMORANDUM OF COSTS (SUMMARY)
‘CASE NUMBER:
CGC-16-555761
The following costs are requested: TOTALS
4. Filing and motion fees $ 935.00
2. Jury feces $ 1,006.25
3, Jury food and lodging § 0.00
4, Deposition costs $ 10,0 34.58
5. Service of process $ 0.00
6, Attachment expenses $ 0.00
7. Surety bond premiums $ 0.00
8. Witness fees $ 7381.63
9, Court-ordered transcripts $ 0.00
10, Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court $
determination; otherwise a noticed motion is required)
11. Court reporter fees as established by statute $ 0.00
12, Models, enlargements, and photocopies of exhibits $ 137.66
13. Interpreter feos $ 0.00
14, Fess for elactionic filing or service $ 0.00
15, Fees for hosting electronic documents $ 0.00
46. Other $ 0.00
fora costs $ vaya x 2
| am the attorney, agent, or party who claims these costs, To the best of my knowledge and belief this memorandum of costs Is correct
and these costs Were necessarily incurred in this case,
Date: wie] 2
Edward Rodzewich
LEP a?
(TYPE OR PRINT NAME) (SIGNATURE OF SECLARANT)
(Proof of service on reverse} Paaiees
Foam hoped i Optonal log MEMORANDUM OF COSTS (SUMMARY) coin cate,
‘Ray, Soptembar 1, 2017]
‘WistteDoc Fo BldMC-010
SHORT TITLE Rochelle v. Deng CASE NUMBER:
CGC-16-555761
PROOF OF [__] MAILING [_] PERSONAL DELIVERY
4, Atthe time of maiting or personal delivery, | was at least 18 years of age and not a party to this iegal action.
2. My residence or business address Is (specify):
Doe
See Axtmalasll (oa oF Samice
3. _f mailed or personally delivered a copy of the Memorandum of Cosfs (Summary) as follows {complete either a or b):
a, [] Mall. 1 ema resident of or emptoyed in the county where the mailing occurred,
(1) | enclosed a copy in an envelope AND
(a) [__] deposited the seaied envelope with the United States Postal Service with the postage fully prepaid.
(b) [__] placed the envelope for collection and maiing on the date and at the place shown in items below following
our ordinary business practices. | am readily familiar with this business' practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and mailing, itis
deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with
postage fully prepaid,
(2) The envelope was addressed and mailed as follows:
(a) Name of person served:
{b) Address on envelope:
(c) Date of mailing:
(a) Place of mailing (city and state):
b. [7] Personat delivery. | personally delivered a copy as follows:
(1) Name of person served:
(2) Address where delivered:
(3) Date delivered:
(4) Time delivered:
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date;
»
(IYPE OR PRINT NAME) = (SIGNATURE OF DECLARANT)
Page 20f2
MEDIO [Rew Soplember 1, 2047 MEMORANDUM OF COSTS (SUMMARY)Mc-014
SHORT TITLE Rochelle vy, Deng CASE NUMBER:
CGC-16-555761
MEMORANDUM OF COSTS (WORKSHEET)
1. Filing and motion fees
Paper filed Filing fee
a. Answer to Complaint $ 435
b. Motion for Summary Judgment $ 500
© 8
a 8
e $
t 8
g. Information about additional filing and motion fees is contained in Attachment 4g.
TOTAL 1. b 935.00
2. dury fees
Date Feo & mileage
a LV/IG/I7 “12/4/17 s 1006.25
>, 8
© s
a $
©. [C5] Information about additional jury fees Is contained in Attachment 2e.
TOTAL2. [& 1006.25
3, Juror food: $ and lodging: $ TOTAL3, Bd
4, Deposition costs
Name of deponent Taking Transcribing Travel Videotapi Subtotals
a. John Lawion 8 $ 326.19 $ $ $ 326.19
b. Angelique Rochelle $ $ 2091.28 $ S$ 1650.88 = $_—_—_—3,742.16
©. Richard Devine 8 Soo 3 420.07 $ $ S$ A207
Paul Elizondo $ 227 8 374.67 $ $ 8 Galo?
@. [-X] Information about additional deposition costs is contained in Attachment 4e.
TOTAL 4. [STS 034.58
(Continued on reverse) Page_1 of 4.
Tiel Bore domia MeO MEMORANDUM OF COSTS (WORKSHEET) Gave Gi Pree
[Rev. September 1, 2047] ‘Westay Doc Form Buder=MC-011
SHORT TITLE Rochelle v, Deng
CASE NUMBER:
CGC-16-555761
6. Service of process
Registered
Name of person served, Public officer process Publication. Other (specify)
a, $ $ $ $
b. $ $ 8 $
Oo _§ $ $ $ a
d. [_] Information about adcitional costs for service of process is contained in Attachment 5d.
roraLs. (5
6. Attachment expenses (specify): 8. [8
7. Surety bond premiums (femize bonds and amounts): 7. F_____]
8. a Ordinary witness fees
Name of witness: Dally fee Mileage Total
(1) days at $iday iniles at gimile: $
(2) days at $iday miles at gimile: ._
(3) days at $iday miles at éimile: czcr---—)]
{4) days at $iday miles at ¢imile: gE_ 7
(5) days at Siday miles at ¢imile: g
(8) [_] Information about additional ordinary witness fees is contained in Attachment €a(6).
SUBTOTAL 8a. $ oe
{Continued on next page)
MC-O11 [Rev. Soplember 1, 2017] MEMORANDUM OF COSTS (WORKSHEET) Page 2 of 4MC-011
SHORT TITLE Rochelle y, Deng CASE NUMBER:
CGC-16-555761
8. b, Expert fees (per Code of Civil Procedure section 998)
Name of witness Fee
(1) Eric Drabkin 17.25 __ hours at $ 390/nr
(2) Bric Drabkin - Trial Tesimony 1 hours at $ 610/hr 8 ~_ 610.00
(3) Bric Drabkin- Travel Costs 1 hours at $ 44.13%hr 5 44.1
(4) hours at $ fhe Ss 4
(5) [__] Information about additional expert fees is contained in Attachment 85(5).
SUBTOTAL 8b[3 7,381.63
c, Court-ordered expert fees
Name of witness Fee
(1) hours at $ thr sO
(2) hours at $ fer §
(3) ["_] Information about additional court-ordered expert fees is contained in Attachment 8¢(3).
SUBTOTAL 8e[5
TOTAL (8a, 8b, & 8c) 8/$ 7,381.63
‘—
9. Court-ordered transcripts (specify):
10. Attorney fees (enter here if contractual or statutory fees are fixed without necassity of a court 10. [8
determination; otherwise a noticed motion is required): Attorneys fees to be determined by motion
41. Models, enlargements, and photocopies of exhibits (specify): 11. [8 137.66
Three enlargements of document used at trial
12. Court reporter fees (as established by statute)
a. (Name of reporter): Fees: $
b. (Name of reporter}: Fees: $ TOTAL 12. ge
c Information about additional court-reporter fees is contained in Attachment 12c,
43. Interpreter fees
a. Fees of a certified or registered interpreter for the deposition of a party or witness
(Name of interpreter): Fees: $
(Name of interpreter): Fees: $
b. Fees for a qualified court interpreter authorized by the court for an indigent
person represented by a qualified legal services project or a pro bono attorney
(Name of interpreter): Fees: $
(Name of interpreter): Fees: $ ToTAL 13. [FB ~Sd
c. [__] Information about additional court-reporter fees is contained in Attachment 13c.
14, Fees for electronic filing or service of documents through an electronic filing service provider peer
(enter here if required or ordered by the court): 14. [5 0.00
15, Fees for hosting electronic documents through an electronic filing service provider {enter here
if required or ordered by the court): 15,
16. Other (specify): _ 6B ‘|
TOTAL costs BG Aye
(Additional information may ba supplied on the reverse)
MC-O11 Rev. September 1, 2017] MEMORANDUM OF COSTS (WORKSHEET) Page_3 of 4_Mc-011
SHORT TITLE Rochelle v. Deng
CASE NUMBER:
CGC-16-555761
Additional Information
MC-O11 Rex. September 4, 20171
MEMORANDUM OF COSTS (WORKSHEET)
Page 4 of 4MC-025
SHORT TITLE: Roctelle v. Deny eee
|S oe CGC-16-555761
ATTACHMENT (Number): de
(This Attachment may be used with any Judicial Council form.)
Name of Deponent Taking Transcribing Travel Videotaping Subtotals
f Ella Lawton $ 8 198.30 $ $ 8 198.30
g. Baz Rochelle $ $ 429.24 § 8 8 429.24
bh. Brie Drabkin 3 $ 256.75 § 3 3 256.75
i. Trevor Deng $ $ 1014.20 $ $ 480 $ 1,494.20
j. May Deng $ $ 651.65 $ $ 400.00 $ 1,051.65
k. Yu Yuo Tan $ 8 212.80 $ 3 240 $ 452.80
L William Wong $ 8 152.95 $ $ $ 152,95
m. Doug Wong 8 8 225,20 $ $ 8 225,20
a, Calvin Chan 3 $ 183.40 $ 3 3 183.40
(if the item that this Attachment concems is made under penaity of perjury, al! statements in this Page _ of
Attachment are made under penalty of perjury.) (ndd pages as required)
Fora Appiaod ior Opin se ATTACHMENT renutaca gar
“isi Cuneo Calfomia a 7
‘MC-025 fRev. July 4, 2006] to Judicial Council FormRe: Rochelle v. Deng, et al.
Case Number: CGC-16-555761
PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
I am a resident of the State of California and over the age of eighteen years, and not a party to the
within action, My business address is 505 14th Street, Suite 400, Oakland, CA 94612-1913. On
December “¢ > 2017, I served the following document(s);
MEMORANDUM OF COSTS
By placing the document(s) listed above in a sealed envelope, addressed as set forth
LS below, and placing the envelope for collection and mailing in the place designated for
such in our offices, following ordinary business practices.
By transmitting via facsimile the document(s) listed above to the fax number(s} set
forth below on this date before 5:00 p.m.
By causing a true copy thereof to be personally delivered to the person(s) at the
address(es) set forth below.
By electronically serving the document(s) described above via a Court approved File
4 & Serve vendor on those recipients designated on the Transaction Receipt located on
the vendor’s Website.
By electronically serving the document(s) to the electronic mail address set forth
below on this date before 5:00 p.m. pursuant to the signed stipulation of the parties
and consistent with Code of Civil Procedure section 1010.6(a)(2).
SEE ATTACHED SERVICE LIST
I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I
am aware that on motion of the party served, service is presumed invalid if postal cancellation date or
postage meter date is more than one day after date of deposit for mailing in affidavit.
I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
Executed on December zZ Zz 2017, at Oakland, California.
Suc] Ce
C7 FESBIE A. ENGELMEIER
/Re: Rochelle v. Deng. et al.
Case Number: CGC-16-555761
SERVICE LIST
Mark Hooshmand, Esq.
Hooshmand Law Group - San Francisco
22 Battery Street, Suite 610
San Francisco, CA 94111
Attomey for Plaintiffs, ANGELIQUE ROCHELLE, individually and as Guardian ad litem of ELLA
LAWTON and LEONA PASLAY and BAZ ROCHELLE, individually
Phone: (415) 318-5709
Fax: (415) 376-5897
mark@lawmmh.com
Daniel Piccinini, Esq.
Law Office of Daniel Piccinini
714 Van Ness Avenue
San Francisco, CA 94102
Attorney for Defendant, YU TAO TAN
Phone: (415) 345-8610
Fax: (415) 345-8612oO em ND KH WN |
RPM YN YN NN ND ee ee ee eB Be ee
oa anan fF © S | FS CM HN DAH BB wWN = OO
Exhibit B
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT’S MEMORANDUM OF COSTS 5Transcript of Proceedings Volume VI
November 28, 2017
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
BEFORE THE HONORABLE SUZANNE R. BOLANOS, JUDGE
DEPARTMENT 504
ANGELIQUE ROCHELLE,
individually and as Guardian ad
Litem of ELLA LAWTON and LEONA
PASLAY and BAZ ROCHELLE, No. CGC-16-555761
individually,
Plaintiffs,
vs.
TREVOR DENG; MAY DENG; YU TAO
TAN, and DOES 1 to 10,
Defendants.
REPORTER'S TRANSCRIPT OF PROCEEDINGS
Civic Center Courthouse
Tuesday, November 28, 2017
VOLUME VI
Reported by:
Lori L. Nicora, CSR No. 6074
U.S. Legal Support | www.uslegalsupport.comTranscript of Proceedings Volume VI
November 28, 2017
INDEX OF WITNESSES
PLAINTIFF:
EXAMINATION
Direct Cross Redirect Recross
TREVOR DENG 570 601 654 637
687 684
WILLIAM WONG 626 634 636
CALVIN CHAN (By Video) 690
--000-—
DEFENDANT:
EXAMINATION
Direct Cross Redirect Recross
YU TAO TAN 696 701
ANGELIQUE ROCHELLE
(Video Testimony) 712
ERIC DRABKIN 713 724 736 737
--000-~-
U.S. Legal Support | www.uslegalsupport.com
568Transcript of Proceedings Volume VI
November 28, 2017
A. Yes.
Q. What were you hired to do?
A. I was hired to calculate the economic damages
of the financial damage on Ms. Rochelle from being
evicted from her apartment in San Francisco.
Q. Did you do this calculation?
A. I did.
Q. How did you do this calculation?
A. Fairly straightforward. How much was her rent
in her San Francisco apartment, how much would that rent
have changed over time, so that's the amount she would
have been paying had she not been evicted, and I've
compared that with her expenses, in particular the rent
that she's had to pay given that she's been evicted.
So I'm comparing what would have been in terms
of her rent that's rent expenses with what her expenses
are because she's been evicted, the difference between
the damages or the financial impact from the eviction.
Q. So to do this, do you have her current rent?
A. Yes. So, again, I started in July, 2014, when
the eviction took place. So I knew the monthly rent at
the 25th Avenue apartment in San Francisco. I knew the
monthly rent in her new apartment in Oakland. So I know
the difference, and I'm able to project forward how the
rents would change over time.
Q. Did you make a calculation based on looking at
her rent previously at 25th Avenue versus her rent now
in Oakland?
U.S. Legal Support | www.uslegalsupport.com
715Transcript of Proceedings Volume VI
November 28, 2017
A. Correct.
Q. And what is this calculation?
A. When Ms. Rochelle was evicted, her monthly went
was $1,787.20 a month. So that was the San Francisco
rent.
She found a three-bedroom unit, I believe, in
Oakland, and her monthly went was and still is 1,450 per
month. So it went from 1787 to 1450.
Q. So to reach your calculation, you simply just
looked at her rent previously versus her rent now. Did
you take any other factors into account?
A. That's essentially the calculation I performed.
Q. Did you calculate this out based on the amount
of years that she has been living in her new unit?
A. I started the calculation on the date she moved
out of the San Francisco unit. I believe it was
July 9th, 2014.
I actually did it on somewhat a year-by-year
basis. So I took it from that date up until the current
date, and I projected it forward, as well for an
additional, I believe, ten years.
Q. Okay. So let's go through this a step ata
time. To the current date, what did you calculate
Ms. Rochelle's economic damages?
A. Well, because she's paying less now than she
would have been paying had she remained in the San
Francisco unit through -- it's actually through
November 13th, which is the date I was told the trial
U.S. Legal Support | www.uslegalsupport.com
716Transcript of Proceedings Volume VI
November 28, 2017
CERTIFICATE OF REPORTER
I, LORI L. NICORA, a Certified Shorthand
Reporter, hereby certify that the foregoing proceedings
were taken in shorthand by me to the best of my ability
at the time and place therein stated, and that the said
proceedings were thereafter reduced to typewriting, by
computer, under my direction and supervision.
I further certify that I am not of counsel or
attorney for either or any of the parties to the said
cause, nor in any way interested in the event of this
cause, and that I am not related to any of the parties
thereto.
DATED: December 14, 2017
Bo. . Aerie
LORI L. NICORA, CSR NO. 6074
State of California
U.S. Legal Support | www.uslegalsupport.com
744Oo mY DW FF WN &
NY NY NY WYNN DN ND wwe me ea
ot AA KB OK EF SCM I DH BF WY = OS
Exhibit C
DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX
DEFENDANT’S MEMORANDUM OF COSTS 6Mark Hooshmand, Esq. (SBN 194878)
Jenny Jin, Esq. (SBN 296184)
Hooshmand Law Group
22 Battery Street, Suite 610
San Francisco, CA 94111
Tel: (415) 318-5709
Fax: (415) 376-5897
Attorneys for Plaintiff Angelique Rochelle
ELECTRONICALLY
FILED
Superior Court of Catifornia,
Counry of San Francisco
01/10/2018
Clerk of the Court
BY:CRAIG BLACKSTONE
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION
ANGELIQUE ROCHELLE,
Plaintiff,
vs.
TREVOR DENG, and DOES 1 TO 10,
Defendants.
CASE: CGC-16-555761
)
)
)
)
) STIPULATION BETWEEN THE PARTIES AS
) TO EXTENDING THE TIME FOR
) PLAINTIFF TO FILE MOTION TO STRIKE
) OR TAX COSTS TO FEBRUARY 15, 2018
)
)
)
)
)
STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF
TO FILE MOTION TO STRIKE OR TAX COSTS TO FEBRUARY 15, 2018
STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF TO FILE MOTION TO STRIKE
OR TAX COSTS TO FEBRUARY 15, 2018 1In the matter of Rochelle v. Deng (CGC-16-555761), Plaintiff Angelique Rochelle and
Defendant Trevor Deng, by and through their counsels of record, hereby stipulate to the
following:
1. Defendant filed a Memorandum of Costs on December 27, 2017;
2. Plaintiff’s Motion to Strike or Tax Defendant’s Costs is currently due to be served and
filed on January 16, 2018;
3. Whereas, Plaintiff’s Motion for New Trial and Motion for Judgment Notwithstanding the
Verdict are currently set to be heard on February 7, 2018;
4. Pursuant to California Rules of Court 3.1700(b)(3), the parties hereby stipulate that the
deadline for Plaintiff to serve and file a Motion to Strike or Tax Defendant’s Costs is
extended to February 15, 2018.
5. This stipulation may be executed in counterparts. Facsimile and scanned copies of the
signature page will be deemed as originals.
Date: January 10 , 2018 HOOSHMAND LAW GROUP
Mark Hooshmand, Esq./Jendy Jin, Esq.
Attomeys for Plaintiff Angelique Rochelle
Date: January 10, 2018 HARTSUYKER, STRATMAN & WILLIAMS-
ABREGO i
ce Rodzewich, Esq,
Attomey for Defendant Trevor Deng
STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF TO FILE MOTION TO STRIKE
OR TAX COSTS TO FEBRUARY 15, 2018 2
Preview
Cm nN DH RF WN a Te aed BNRERRPERBRRSSCRSVTABDEBHRAS Mark Hooshmand, Esq. (SBN 194878) Tyson Redenbarger, Esq. (SBN 294424) Jenny Jin, Esq. (SBN 296184) Hooshmand Law Group 22 Battery Street, Ste. 610 San Francisco, CA 94111 Tel: (415) 318-5709 Fax: (415) 376-5897 Attorneys for Plaintiff Angelique Rochelle ELECTRONICALLY FILED Superior Court of California, County of San Francisco 02/15/2018 Clerk of the Court BY: YOLANDA TABO-RAMII Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO - UNLIMITED CIVIL JURISDICTION ANGELIQUE ROCHELLE, Plaintiff, vs. TREVOR DENG, and DOES 1-10, Defendants. eS SS SS ee ee CASE NO.: CGC-16-555761 DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS Date: March 21, 2018 Time: 2:00 p.m. Dept: 504 Judge: Hon. Suzanne Bolanos DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS 1om YN DA HM BBW NY PN YP YN RN Dee ew ew ee ee — &® Xa RRSK HS Se ARDBARBHR AS DECLARATION OF JENNY JIN I, JENNY JIN, declare the following: 1. 2. I am an attorney for Plaintiff Angelique Rochelle in this matter. 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. Judgment was entered on December 12, 2017, following the jury’s special verdict in this matter. Plaintiff Angelique Rochelle’s three children, Baz Rochelle, Ella Lawton, and Leona Paslay, were also Plaintiffs in this case, but had resolved their claims against Defendant after accepting Defendant’s Code of Civil Procedure section 998 offers, prior to the commencement of trial. A true and correct copy of Defendant’s Memorandum of Costs, filed on December 27, 2017, is attached hereto as Exhibit A. Defendant’s only retained expert, Eric Drabkin, gave improper opinions as to measuring Plaintiff’s loss for a rent-controlled unit through an out-of-pocket method. Mr. Drabkin further testified at trial that his calculation was “fairly straightforward” as he simply compared Plaintiff’s prior rent to her new rent amount. A true and correct copy of the relevant portions of Mr. Drabkin’s trial testimony transcript is attached hereto as Exhibit B. A true and correct copy of the January 10, 2018 stipulation extending the deadline for Plaintiff to file the present Motion to Strike/Tax is attached hereto as Exhibit C. This Court entered an Order denying Plaintiff’s Motion for New Trial on February 14, 2018. My office is preparing a Notice of Appeal as to this order and the underlying judgment and will be filing it no later than February 22, 2018. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT'S MEMORANDUM OF COSTS 2Co Oe IN DAH BF WN wR NYRR NK KN ee ee ee et eon A aA FF oNH |= SOCOM ADA FF WN | SD Dated: February 15, 2018 SN ary << 7 Jenny Jin, Esq. DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT'S MEMORANDUM OF COSTS 3Co Oo IN DH BF WN NN YN YN NNN Be Be Be Be Be Se ee ee ont AA BF OoONH FS SOD OA DA BF YW NHN | DS Exhibit A DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS 4MC-010 [ATTORNEY OR PARTY Wil IOLT ATTORNEY Name: Edward Rodzewich riemvaveHartsuyker, Stratman & Williams-Abrego [streer anpress: P.O, Box 258829 cry: Oklahoma City state OK = zipcove:73 125 TELEPHONE NO: 707-521-4272 FAX NO: 707-544-938 1 EMAL aDpRass, jessica nudelman@farmersinsurance.com JArroRNeY For (came: Trevor Deng STATEBAR NUMBER:1 59466 SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco stReEeT aobress: 400 McAllister Street Manne Aopress: 400 McAllister Street cry aNa zip cove: San Francisco, 94102 BRANCH NAME: Civic Center Courthouse PLAINTIFF:Angelique Rochelle DEFENDANT: Trevor Deng FOR COURT USE ONLY ELECTRONICALLY FILED Superior Court of California, County of San Francisco 12/27/2017 Clerk of the Court BY: DAVID YUEN Deputy Clork MEMORANDUM OF COSTS (SUMMARY) ‘CASE NUMBER: CGC-16-555761 The following costs are requested: TOTALS 4. Filing and motion fees $ 935.00 2. Jury feces $ 1,006.25 3, Jury food and lodging § 0.00 4, Deposition costs $ 10,0 34.58 5. Service of process $ 0.00 6, Attachment expenses $ 0.00 7. Surety bond premiums $ 0.00 8. Witness fees $ 7381.63 9, Court-ordered transcripts $ 0.00 10, Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court $ determination; otherwise a noticed motion is required) 11. Court reporter fees as established by statute $ 0.00 12, Models, enlargements, and photocopies of exhibits $ 137.66 13. Interpreter feos $ 0.00 14, Fess for elactionic filing or service $ 0.00 15, Fees for hosting electronic documents $ 0.00 46. Other $ 0.00 fora costs $ vaya x 2 | am the attorney, agent, or party who claims these costs, To the best of my knowledge and belief this memorandum of costs Is correct and these costs Were necessarily incurred in this case, Date: wie] 2 Edward Rodzewich LEP a? (TYPE OR PRINT NAME) (SIGNATURE OF SECLARANT) (Proof of service on reverse} Paaiees Foam hoped i Optonal log MEMORANDUM OF COSTS (SUMMARY) coin cate, ‘Ray, Soptembar 1, 2017] ‘WistteDoc Fo BldMC-010 SHORT TITLE Rochelle v. Deng CASE NUMBER: CGC-16-555761 PROOF OF [__] MAILING [_] PERSONAL DELIVERY 4, Atthe time of maiting or personal delivery, | was at least 18 years of age and not a party to this iegal action. 2. My residence or business address Is (specify): Doe See Axtmalasll (oa oF Samice 3. _f mailed or personally delivered a copy of the Memorandum of Cosfs (Summary) as follows {complete either a or b): a, [] Mall. 1 ema resident of or emptoyed in the county where the mailing occurred, (1) | enclosed a copy in an envelope AND (a) [__] deposited the seaied envelope with the United States Postal Service with the postage fully prepaid. (b) [__] placed the envelope for collection and maiing on the date and at the place shown in items below following our ordinary business practices. | am readily familiar with this business' practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, itis deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid, (2) The envelope was addressed and mailed as follows: (a) Name of person served: {b) Address on envelope: (c) Date of mailing: (a) Place of mailing (city and state): b. [7] Personat delivery. | personally delivered a copy as follows: (1) Name of person served: (2) Address where delivered: (3) Date delivered: (4) Time delivered: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date; » (IYPE OR PRINT NAME) = (SIGNATURE OF DECLARANT) Page 20f2 MEDIO [Rew Soplember 1, 2047 MEMORANDUM OF COSTS (SUMMARY)Mc-014 SHORT TITLE Rochelle vy, Deng CASE NUMBER: CGC-16-555761 MEMORANDUM OF COSTS (WORKSHEET) 1. Filing and motion fees Paper filed Filing fee a. Answer to Complaint $ 435 b. Motion for Summary Judgment $ 500 © 8 a 8 e $ t 8 g. Information about additional filing and motion fees is contained in Attachment 4g. TOTAL 1. b 935.00 2. dury fees Date Feo & mileage a LV/IG/I7 “12/4/17 s 1006.25 >, 8 © s a $ ©. [C5] Information about additional jury fees Is contained in Attachment 2e. TOTAL2. [& 1006.25 3, Juror food: $ and lodging: $ TOTAL3, Bd 4, Deposition costs Name of deponent Taking Transcribing Travel Videotapi Subtotals a. John Lawion 8 $ 326.19 $ $ $ 326.19 b. Angelique Rochelle $ $ 2091.28 $ S$ 1650.88 = $_—_—_—3,742.16 ©. Richard Devine 8 Soo 3 420.07 $ $ S$ A207 Paul Elizondo $ 227 8 374.67 $ $ 8 Galo? @. [-X] Information about additional deposition costs is contained in Attachment 4e. TOTAL 4. [STS 034.58 (Continued on reverse) Page_1 of 4. Tiel Bore domia MeO MEMORANDUM OF COSTS (WORKSHEET) Gave Gi Pree [Rev. September 1, 2047] ‘Westay Doc Form Buder=MC-011 SHORT TITLE Rochelle v, Deng CASE NUMBER: CGC-16-555761 6. Service of process Registered Name of person served, Public officer process Publication. Other (specify) a, $ $ $ $ b. $ $ 8 $ Oo _§ $ $ $ a d. [_] Information about adcitional costs for service of process is contained in Attachment 5d. roraLs. (5 6. Attachment expenses (specify): 8. [8 7. Surety bond premiums (femize bonds and amounts): 7. F_____] 8. a Ordinary witness fees Name of witness: Dally fee Mileage Total (1) days at $iday iniles at gimile: $ (2) days at $iday miles at gimile: ._ (3) days at $iday miles at éimile: czcr---—)] {4) days at $iday miles at ¢imile: gE_ 7 (5) days at Siday miles at ¢imile: g (8) [_] Information about additional ordinary witness fees is contained in Attachment €a(6). SUBTOTAL 8a. $ oe {Continued on next page) MC-O11 [Rev. Soplember 1, 2017] MEMORANDUM OF COSTS (WORKSHEET) Page 2 of 4MC-011 SHORT TITLE Rochelle y, Deng CASE NUMBER: CGC-16-555761 8. b, Expert fees (per Code of Civil Procedure section 998) Name of witness Fee (1) Eric Drabkin 17.25 __ hours at $ 390/nr (2) Bric Drabkin - Trial Tesimony 1 hours at $ 610/hr 8 ~_ 610.00 (3) Bric Drabkin- Travel Costs 1 hours at $ 44.13%hr 5 44.1 (4) hours at $ fhe Ss 4 (5) [__] Information about additional expert fees is contained in Attachment 85(5). SUBTOTAL 8b[3 7,381.63 c, Court-ordered expert fees Name of witness Fee (1) hours at $ thr sO (2) hours at $ fer § (3) ["_] Information about additional court-ordered expert fees is contained in Attachment 8¢(3). SUBTOTAL 8e[5 TOTAL (8a, 8b, & 8c) 8/$ 7,381.63 ‘— 9. Court-ordered transcripts (specify): 10. Attorney fees (enter here if contractual or statutory fees are fixed without necassity of a court 10. [8 determination; otherwise a noticed motion is required): Attorneys fees to be determined by motion 41. Models, enlargements, and photocopies of exhibits (specify): 11. [8 137.66 Three enlargements of document used at trial 12. Court reporter fees (as established by statute) a. (Name of reporter): Fees: $ b. (Name of reporter}: Fees: $ TOTAL 12. ge c Information about additional court-reporter fees is contained in Attachment 12c, 43. Interpreter fees a. Fees of a certified or registered interpreter for the deposition of a party or witness (Name of interpreter): Fees: $ (Name of interpreter): Fees: $ b. Fees for a qualified court interpreter authorized by the court for an indigent person represented by a qualified legal services project or a pro bono attorney (Name of interpreter): Fees: $ (Name of interpreter): Fees: $ ToTAL 13. [FB ~Sd c. [__] Information about additional court-reporter fees is contained in Attachment 13c. 14, Fees for electronic filing or service of documents through an electronic filing service provider peer (enter here if required or ordered by the court): 14. [5 0.00 15, Fees for hosting electronic documents through an electronic filing service provider {enter here if required or ordered by the court): 15, 16. Other (specify): _ 6B ‘| TOTAL costs BG Aye (Additional information may ba supplied on the reverse) MC-O11 Rev. September 1, 2017] MEMORANDUM OF COSTS (WORKSHEET) Page_3 of 4_Mc-011 SHORT TITLE Rochelle v. Deng CASE NUMBER: CGC-16-555761 Additional Information MC-O11 Rex. September 4, 20171 MEMORANDUM OF COSTS (WORKSHEET) Page 4 of 4MC-025 SHORT TITLE: Roctelle v. Deny eee |S oe CGC-16-555761 ATTACHMENT (Number): de (This Attachment may be used with any Judicial Council form.) Name of Deponent Taking Transcribing Travel Videotaping Subtotals f Ella Lawton $ 8 198.30 $ $ 8 198.30 g. Baz Rochelle $ $ 429.24 § 8 8 429.24 bh. Brie Drabkin 3 $ 256.75 § 3 3 256.75 i. Trevor Deng $ $ 1014.20 $ $ 480 $ 1,494.20 j. May Deng $ $ 651.65 $ $ 400.00 $ 1,051.65 k. Yu Yuo Tan $ 8 212.80 $ 3 240 $ 452.80 L William Wong $ 8 152.95 $ $ $ 152,95 m. Doug Wong 8 8 225,20 $ $ 8 225,20 a, Calvin Chan 3 $ 183.40 $ 3 3 183.40 (if the item that this Attachment concems is made under penaity of perjury, al! statements in this Page _ of Attachment are made under penalty of perjury.) (ndd pages as required) Fora Appiaod ior Opin se ATTACHMENT renutaca gar “isi Cuneo Calfomia a 7 ‘MC-025 fRev. July 4, 2006] to Judicial Council FormRe: Rochelle v. Deng, et al. Case Number: CGC-16-555761 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 I am a resident of the State of California and over the age of eighteen years, and not a party to the within action, My business address is 505 14th Street, Suite 400, Oakland, CA 94612-1913. On December “¢ > 2017, I served the following document(s); MEMORANDUM OF COSTS By placing the document(s) listed above in a sealed envelope, addressed as set forth LS below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. By transmitting via facsimile the document(s) listed above to the fax number(s} set forth below on this date before 5:00 p.m. By causing a true copy thereof to be personally delivered to the person(s) at the address(es) set forth below. By electronically serving the document(s) described above via a Court approved File 4 & Serve vendor on those recipients designated on the Transaction Receipt located on the vendor’s Website. By electronically serving the document(s) to the electronic mail address set forth below on this date before 5:00 p.m. pursuant to the signed stipulation of the parties and consistent with Code of Civil Procedure section 1010.6(a)(2). SEE ATTACHED SERVICE LIST I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on December zZ Zz 2017, at Oakland, California. Suc] Ce C7 FESBIE A. ENGELMEIER /Re: Rochelle v. Deng. et al. Case Number: CGC-16-555761 SERVICE LIST Mark Hooshmand, Esq. Hooshmand Law Group - San Francisco 22 Battery Street, Suite 610 San Francisco, CA 94111 Attomey for Plaintiffs, ANGELIQUE ROCHELLE, individually and as Guardian ad litem of ELLA LAWTON and LEONA PASLAY and BAZ ROCHELLE, individually Phone: (415) 318-5709 Fax: (415) 376-5897 mark@lawmmh.com Daniel Piccinini, Esq. Law Office of Daniel Piccinini 714 Van Ness Avenue San Francisco, CA 94102 Attorney for Defendant, YU TAO TAN Phone: (415) 345-8610 Fax: (415) 345-8612oO em ND KH WN | RPM YN YN NN ND ee ee ee eB Be ee oa anan fF © S | FS CM HN DAH BB wWN = OO Exhibit B DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS 5Transcript of Proceedings Volume VI November 28, 2017 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO BEFORE THE HONORABLE SUZANNE R. BOLANOS, JUDGE DEPARTMENT 504 ANGELIQUE ROCHELLE, individually and as Guardian ad Litem of ELLA LAWTON and LEONA PASLAY and BAZ ROCHELLE, No. CGC-16-555761 individually, Plaintiffs, vs. TREVOR DENG; MAY DENG; YU TAO TAN, and DOES 1 to 10, Defendants. REPORTER'S TRANSCRIPT OF PROCEEDINGS Civic Center Courthouse Tuesday, November 28, 2017 VOLUME VI Reported by: Lori L. Nicora, CSR No. 6074 U.S. Legal Support | www.uslegalsupport.comTranscript of Proceedings Volume VI November 28, 2017 INDEX OF WITNESSES PLAINTIFF: EXAMINATION Direct Cross Redirect Recross TREVOR DENG 570 601 654 637 687 684 WILLIAM WONG 626 634 636 CALVIN CHAN (By Video) 690 --000-— DEFENDANT: EXAMINATION Direct Cross Redirect Recross YU TAO TAN 696 701 ANGELIQUE ROCHELLE (Video Testimony) 712 ERIC DRABKIN 713 724 736 737 --000-~- U.S. Legal Support | www.uslegalsupport.com 568Transcript of Proceedings Volume VI November 28, 2017 A. Yes. Q. What were you hired to do? A. I was hired to calculate the economic damages of the financial damage on Ms. Rochelle from being evicted from her apartment in San Francisco. Q. Did you do this calculation? A. I did. Q. How did you do this calculation? A. Fairly straightforward. How much was her rent in her San Francisco apartment, how much would that rent have changed over time, so that's the amount she would have been paying had she not been evicted, and I've compared that with her expenses, in particular the rent that she's had to pay given that she's been evicted. So I'm comparing what would have been in terms of her rent that's rent expenses with what her expenses are because she's been evicted, the difference between the damages or the financial impact from the eviction. Q. So to do this, do you have her current rent? A. Yes. So, again, I started in July, 2014, when the eviction took place. So I knew the monthly rent at the 25th Avenue apartment in San Francisco. I knew the monthly rent in her new apartment in Oakland. So I know the difference, and I'm able to project forward how the rents would change over time. Q. Did you make a calculation based on looking at her rent previously at 25th Avenue versus her rent now in Oakland? U.S. Legal Support | www.uslegalsupport.com 715Transcript of Proceedings Volume VI November 28, 2017 A. Correct. Q. And what is this calculation? A. When Ms. Rochelle was evicted, her monthly went was $1,787.20 a month. So that was the San Francisco rent. She found a three-bedroom unit, I believe, in Oakland, and her monthly went was and still is 1,450 per month. So it went from 1787 to 1450. Q. So to reach your calculation, you simply just looked at her rent previously versus her rent now. Did you take any other factors into account? A. That's essentially the calculation I performed. Q. Did you calculate this out based on the amount of years that she has been living in her new unit? A. I started the calculation on the date she moved out of the San Francisco unit. I believe it was July 9th, 2014. I actually did it on somewhat a year-by-year basis. So I took it from that date up until the current date, and I projected it forward, as well for an additional, I believe, ten years. Q. Okay. So let's go through this a step ata time. To the current date, what did you calculate Ms. Rochelle's economic damages? A. Well, because she's paying less now than she would have been paying had she remained in the San Francisco unit through -- it's actually through November 13th, which is the date I was told the trial U.S. Legal Support | www.uslegalsupport.com 716Transcript of Proceedings Volume VI November 28, 2017 CERTIFICATE OF REPORTER I, LORI L. NICORA, a Certified Shorthand Reporter, hereby certify that the foregoing proceedings were taken in shorthand by me to the best of my ability at the time and place therein stated, and that the said proceedings were thereafter reduced to typewriting, by computer, under my direction and supervision. I further certify that I am not of counsel or attorney for either or any of the parties to the said cause, nor in any way interested in the event of this cause, and that I am not related to any of the parties thereto. DATED: December 14, 2017 Bo. . Aerie LORI L. NICORA, CSR NO. 6074 State of California U.S. Legal Support | www.uslegalsupport.com 744Oo mY DW FF WN & NY NY NY WYNN DN ND wwe me ea ot AA KB OK EF SCM I DH BF WY = OS Exhibit C DECLARATION OF JENNY JIN IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION TO STRIKE/TAX DEFENDANT’S MEMORANDUM OF COSTS 6Mark Hooshmand, Esq. (SBN 194878) Jenny Jin, Esq. (SBN 296184) Hooshmand Law Group 22 Battery Street, Suite 610 San Francisco, CA 94111 Tel: (415) 318-5709 Fax: (415) 376-5897 Attorneys for Plaintiff Angelique Rochelle ELECTRONICALLY FILED Superior Court of Catifornia, Counry of San Francisco 01/10/2018 Clerk of the Court BY:CRAIG BLACKSTONE Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION ANGELIQUE ROCHELLE, Plaintiff, vs. TREVOR DENG, and DOES 1 TO 10, Defendants. CASE: CGC-16-555761 ) ) ) ) ) STIPULATION BETWEEN THE PARTIES AS ) TO EXTENDING THE TIME FOR ) PLAINTIFF TO FILE MOTION TO STRIKE ) OR TAX COSTS TO FEBRUARY 15, 2018 ) ) ) ) ) STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF TO FILE MOTION TO STRIKE OR TAX COSTS TO FEBRUARY 15, 2018 STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF TO FILE MOTION TO STRIKE OR TAX COSTS TO FEBRUARY 15, 2018 1In the matter of Rochelle v. Deng (CGC-16-555761), Plaintiff Angelique Rochelle and Defendant Trevor Deng, by and through their counsels of record, hereby stipulate to the following: 1. Defendant filed a Memorandum of Costs on December 27, 2017; 2. Plaintiff’s Motion to Strike or Tax Defendant’s Costs is currently due to be served and filed on January 16, 2018; 3. Whereas, Plaintiff’s Motion for New Trial and Motion for Judgment Notwithstanding the Verdict are currently set to be heard on February 7, 2018; 4. Pursuant to California Rules of Court 3.1700(b)(3), the parties hereby stipulate that the deadline for Plaintiff to serve and file a Motion to Strike or Tax Defendant’s Costs is extended to February 15, 2018. 5. This stipulation may be executed in counterparts. Facsimile and scanned copies of the signature page will be deemed as originals. Date: January 10 , 2018 HOOSHMAND LAW GROUP Mark Hooshmand, Esq./Jendy Jin, Esq. Attomeys for Plaintiff Angelique Rochelle Date: January 10, 2018 HARTSUYKER, STRATMAN & WILLIAMS- ABREGO i ce Rodzewich, Esq, Attomey for Defendant Trevor Deng STIPULATION BETWEEN THE PARTIES AS TO EXTENDING THE TIME FOR PLAINTIFF TO FILE MOTION TO STRIKE OR TAX COSTS TO FEBRUARY 15, 2018 2