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\ yn KELLY LITIGATION GROUP, INC.
Richard M. Kelly, Esq. SBN 154504
ILED
SAN MaTEO COUNTY
Michael Mengarelli, Esq. SBN 215000
3 Lagoon Drive, Suite 225 JAN 2 4 2019
Redwood City, CA 94065
Clerk of iperios rt
Telephone: (650) 591-2282
Facsimile: (650) 591-2292 8y Ftv CA Re
CHAUVEL & GLATT, LLP
April S. Glatt, Esq. SBN 185708
Thomas J. Walsh, Esq. SBN 311862 “ta ClV-00846
66 Bovet Road, Suite 280
Det in Support
San Mateo, CA 94402
Telephone: (650) 573-9500
Facsimile: (650) 573-9689
Attorneys for Plaintiffs and Cross-Defendants,
| ‘itu IMT
10 MATTHEW SQUIRES and NICOLE SQUIRES
u IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
Ba
ys IN AND FOR THE COUNTY OF SAN MATEO
at 12
2h (UNLIMITED CIVIL JURISDICTION)
go
13 MATTHEW SQUIRES; NICOLE SQUIRES. Case No.: 18CTV00846
Be 14 Plaintiffs.
wan
DECLARATION OF APRIL S. GLATT IN
>3
Aa
15 VS. SUPPORT OF CROSS-DEFENDANTS’
MOTION FOR TERMINATING
R.C. WEHMEYER CONSTRUCTION, INC., dba
16 SANCTIONS AGAINST CROSS-
O2 WEHMEYER CUSTOM HOMES; ROBERT C.
WEHMEYER, an individual; AMERCIAN COMPLAINANT ROBERT C.
17
CONTRACTORS INDEMNITY COMPANY: WEHMEYER (OR ISSUE SANCTIONS
18 and DOES 1 through 20, inclusive. IN THE ALTERNATIVE) AND
MONETARY SANCTIONS
19 Defendants.
R.C. WEHMEYER CONSTRUCTION, INC., dba Action Filed: February 20, 2018
20
WEHMEYER CUSTOM HOMES; ROBERT C.
21 WEHMEYER, JEFFREY BORDIN AND Date:
GREGORIO MARTINEZ, Time 9:00 a.m.
22 Cross-Complainants Dept. Law and Motion
23 VS.
24 MATTHEW SQUIRES; NICOLE SQUIRES, and
ROES 1 through 10.
25
Cross-Defendants
26
27
1
28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING
SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE
ALTERNATIVE) AND MONETARY SANCTIONS
J, April S. Glatt, hereby declares and certifies as follows:
1 Iam an attorney duly licensed to practice law in the State of California, am a Partner at
the Law Offices of Chauvel & Glatt, LLP ("C&G") and one of the attorneys of record for Plaintiffs
Matthew and Nicole Squires ("Squires"). I received my Juris Doctor from the University of San Diego
School of Law in 1996. My practice focuses on civil litigation with an emphasis in employment
representing employer side only.
2. I have personal knowledge of the facts set forth in this Declaration and could testify
competently to them if called upon to do so.
3. Squires’ counsel has been seeking discovery responses from Cross-Complainant Robert
10 C. Wehmeyer (“Cross-Complainant”) since April 10, 2018. Due to Cross-Complainant’s failure to
i respond to certain discovery and their improper and inadequate responses to other discovery requests,
Ra
aEok 12 Squires filed three simultaneous motions to compel discovery in this matter on May 31, 2018.
13 4 To date, Cross-Complainant Robert C. Wehmeyer has not supplemented, amended or
14 provided any further response to Cross-Defendant Nicole Squires’ April 10, 2018 Special
15 Interrogatories, Set One, as required by the Joint Stipulation and Order executed by this court on July
16 24, 2018.
17 5 The hours claimed by Chauvel & Glatt are as evidenced by all the detailed billing
18 submitted with this motion, declarations. The billings do not reflect the time for preparing for, or
19 attending, the upcoming hearing.
20 6. Attached hereto as “Exhibit 1” is the billing associated with undersigned's attempts as
21 described above. The attached itemized bills are the time me and Mr. Walsh have spent on researching;
22 strategizing; communications with opposing counsel; meeting and conferring with Mr. Newcomb and
23 Mr. Finch and Mr. Wilson, an associate of Mr. Finch’s, in attempts to informally resolve these discovery
24 disputes; drafting the instant motion and the costs for filing, serving of same, to represent Squires.’
25 These billings cover January 1, 2019 through the date of the filing of this motion up and through the
26 filing of this motion.
27
2
28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING
SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE
ALTERNATIVE) AND MONETARY SANCTIONS
7 Thave handled numerous litigation matters throughout my career. My hourly rate is $365
which is commensurate, or lower, than attorneys with like experience and location in the Bay Area.
8 I also work with Mr. Thomas (“TJ”) Walsh, my associate attorney, duly licensed in
California as well as Florida. Mr. Walsh has been an attommey with C&G for almost two years and has
been a licensed attorney for 6 years receiving his Juris Doctor from Shepard Broad Law Center at Nova
Southeastern University in 2012. Mr. Walsh's hourly rate is $325/hour and is commensurate or lower
than other practicing attomeys with like experience and location in the Bay Area.
9 Chauvel & Glatt, LLP uses the recognized legal billing system Cosmolex to record time,
fees and costs expended in this matter. Contemporaneous with work throughout this case, I entered the
10 time I spent with a detailed description of what was accomplished; properly recording all work billed as
HW did the other attommeys who worked on this matter, including Mr. Walsh. At the end of each month, both
12 Jand Mr. Walsh reviewed our billings on this matter to ensure accuracy.
13 10. Since January 1, 2019, myself and Mr. Walsh have conducted reasonable and necessary
14 work in this matter to obtain legitimate discoverable information and to adequately defend our client
15 while defense counsel either refuses to provide discovery or is not providing code-compliant or court
16 ordered responses.
17 ll. Ihave conducted a total of 5.6 hours of billable hours of work on this matter and my time
18 is billed at a rate of $365.00 per hour for TWO THOUSAND FORTY-FOUR and 00/100 dollars
19 ($2,044.00) as of the date of this reply declaration. (See Exhibit 1.)
20 12. Mr. Walsh has conducted a total of 9.8 hours of billable hours of work on this matter and
21 his time is billed at a rate of $325.00 per hour for THREE THOUSAND ONE HUNDRED EIGHTY-
22 FIVE and 00/100 dollars ($3,185.00) as of the date of this declaration. (See Exhibit 1.)
13. J anticipate four hours to account for the preparation and attendance of this hearing. As
24 such, I request an additional $1,460.00 in reasonable attorneys’ fees.
25 14, The total amount requested from this court, which does not include the hearing scheduled
26 Sor this Motion for Terminating Sanctions and associated costs and associated costs or attorneys/fees
27 and costs of co-counsel, currently totals $6,689.00 (representing 19.4 hours)
3
28
DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING
SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE
ALTERNATIVE) AND MONETARY SANCTIONS
Under penalty of perjury under the laws of the State of California, the undersigned declares that
the foregoing is true and correct.
Dated: January 23, 2019 CHAUVEL & GLATT, LLP
By:
April S. Glatt, Esq.
Attomeys for Plaintiffs and Cross-Defendants,
MATTHEW SQUIRES and NICOLE SQUIRES
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28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING
SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE
ALTERNATIVE) AND MONETARY SANCTIONS
CHAUVEL & GLATT, LLP
66 Bovet Road, Suite 280
San Mateo, CA 94402
Phone: 650-573-9500
ELLN 30-0581317
INVOICE
Date:01/31/2019
Bill To:
Matthew & Nicole Squires
Professional Services
Date Details Hours Rate Amount
01/04/2019 ASG Call from Matt on strategy, concerns. Call with Mike 0.70 $365.00 $255.50
on same.
01/07/2019 ASG Email from Newcomb and email with MM on whether 0.20 $365.00 $73.00
to continue deposition of Rob; multiple email
exchange with MM on continuing deposition and
rescheduling same and position, pros, cons.
01/11/2019 ASG Email from MM on updated notice of continuation of 0.10 $365.00 $36.50
Rob's depo. Brief review and advise on service of
same.
01/15/2019 ASG Conf. with TJ to narrow issues for terminating 0.60 $365.00 $219.00
sanctions motion; go through special rogs and
RPODs and strategic discussion on inclusion vs.
exclusion and attribute to each COA.
01/15/2019 TJW Discussion with ASG on scope of motion for 0.80 $325.00 $260.00
terminating sanctions; review of outstanding Special
interrogatories from Robert C. Wehmeyer to include in
motion.
01/16/2019 ASG Additional disc. with TJ and MM on structure of 0.30 $365.00 $109.50
terminating sanctions motions. Profcon arguments.
Evaluation of COA and substantial justification.
01/16/2019 TUW Draft and edit Memorandum of Points and Authorities 3.50 $325.00 $1,137.50
in Support of Motion for Terminating Sanctions against
Robert C. Wehmeyer.
o1t6r201 9 TIW Additional discussion with ASG and Mike Mengarelli 0.30 $325.00 $97.50
regarding terminating sanctions motion and evaluation
of substantial justification defense to same.
*
tae e -
01/17/2019 ASG Brief disc. with TJ on terminating sanctions motion 0.10 $365.00 $36.50
and next steps for completion.
0117/2019 ASG Review and revise MPA ISO Terminating sanctions 2.30 $365.00 $839.50
motion and draft comments to TJ. Draft new
declaration ISO motion; reference emails to include as
exhibits to declaration and use language for
~ declaration.
0172019 TW Brief discussion with ASG on terminating sanctions 0.10 $325.00 $32.50
01/18/2019 ASG Strategic disc. on concerns with RPOD request within 0.50 $365.00 $182.50
terminating sanctions motion with TJ. Discuss
“willfulness" and defenses due to ESI efforts by Finch.
Conf. call with MM on same,; additional disc. on
Bordin depo, approaching pre-depo, arguments on
privilege. Disc. subpoena to Maxine Rowe and timing
due to Notice to Consumer requirements.
01/18/2019 ASG Additional conf. with TJ on terminating sanctions 0.20 $365.00 $0.00
motion and narrowing same. (No Charge)
o1ie2019 TIW Draft and edit Notice of Motion for Terminating 0.80 $325.00 $260.00
Sanctions against Robert C. Wehmeyer.
01/18/2019 TIW Draft and edit [proposed] Order for Motion for 1.30 $325.00 $422.50
Terminating Sanctions against Robert C. Wehmeyer.
01/18/2019 TUw Draft and edit Separate Statement in Support of 1.50 $325.00 $487.50
Motion for Terminating Sanctions against Robert C.
Wehmeyer.
01/18/2019 TuW Review billing for monetary sanctions request in 0.90 $325.00 $292.50
Motion for Terminating Sanctions against Robert C.
Wehmeyer; edits to Declaration of April S. Glatt
regarding same.
01/18/2019 TIW Second discussion with ASG on terminating 0.20 $325.00 $65.00
sanctions motion and narrowing issues.
01/18/2019 TW Discussion with ASG regarding "willful" requirement 0.40 $325.00 $130.00
for Motion for Terminating Sanctions.
01/18/2019 ASG Discovery discussions and recap with TJ on outline 0.30 $365.00 $109.50
and items due. Disc. extensions for RCWC but
Newcomb. Email MM on same. Email exchanges re:
not meeting and conferring as not required and
another motion to compel.
01/18/2019 ASG Multiple disc on terminating sanctions motion and 0.30 $365.00 $109.50
discovery trail with TJ to minimize risk at hearing.
EXHIBIT 1
Preview
\ yn KELLY LITIGATION GROUP, INC. Richard M. Kelly, Esq. SBN 154504 ILED SAN MaTEO COUNTY Michael Mengarelli, Esq. SBN 215000 3 Lagoon Drive, Suite 225 JAN 2 4 2019 Redwood City, CA 94065 Clerk of iperios rt Telephone: (650) 591-2282 Facsimile: (650) 591-2292 8y Ftv CA Re CHAUVEL & GLATT, LLP April S. Glatt, Esq. SBN 185708 Thomas J. Walsh, Esq. SBN 311862 “ta ClV-00846 66 Bovet Road, Suite 280 Det in Support San Mateo, CA 94402 Telephone: (650) 573-9500 Facsimile: (650) 573-9689 Attorneys for Plaintiffs and Cross-Defendants, | ‘itu IMT 10 MATTHEW SQUIRES and NICOLE SQUIRES u IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA Ba ys IN AND FOR THE COUNTY OF SAN MATEO at 12 2h (UNLIMITED CIVIL JURISDICTION) go 13 MATTHEW SQUIRES; NICOLE SQUIRES. Case No.: 18CTV00846 Be 14 Plaintiffs. wan DECLARATION OF APRIL S. GLATT IN >3 Aa 15 VS. SUPPORT OF CROSS-DEFENDANTS’ MOTION FOR TERMINATING R.C. WEHMEYER CONSTRUCTION, INC., dba 16 SANCTIONS AGAINST CROSS- O2 WEHMEYER CUSTOM HOMES; ROBERT C. WEHMEYER, an individual; AMERCIAN COMPLAINANT ROBERT C. 17 CONTRACTORS INDEMNITY COMPANY: WEHMEYER (OR ISSUE SANCTIONS 18 and DOES 1 through 20, inclusive. IN THE ALTERNATIVE) AND MONETARY SANCTIONS 19 Defendants. R.C. WEHMEYER CONSTRUCTION, INC., dba Action Filed: February 20, 2018 20 WEHMEYER CUSTOM HOMES; ROBERT C. 21 WEHMEYER, JEFFREY BORDIN AND Date: GREGORIO MARTINEZ, Time 9:00 a.m. 22 Cross-Complainants Dept. Law and Motion 23 VS. 24 MATTHEW SQUIRES; NICOLE SQUIRES, and ROES 1 through 10. 25 Cross-Defendants 26 27 1 28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE ALTERNATIVE) AND MONETARY SANCTIONS J, April S. Glatt, hereby declares and certifies as follows: 1 Iam an attorney duly licensed to practice law in the State of California, am a Partner at the Law Offices of Chauvel & Glatt, LLP ("C&G") and one of the attorneys of record for Plaintiffs Matthew and Nicole Squires ("Squires"). I received my Juris Doctor from the University of San Diego School of Law in 1996. My practice focuses on civil litigation with an emphasis in employment representing employer side only. 2. I have personal knowledge of the facts set forth in this Declaration and could testify competently to them if called upon to do so. 3. Squires’ counsel has been seeking discovery responses from Cross-Complainant Robert 10 C. Wehmeyer (“Cross-Complainant”) since April 10, 2018. Due to Cross-Complainant’s failure to i respond to certain discovery and their improper and inadequate responses to other discovery requests, Ra aEok 12 Squires filed three simultaneous motions to compel discovery in this matter on May 31, 2018. 13 4 To date, Cross-Complainant Robert C. Wehmeyer has not supplemented, amended or 14 provided any further response to Cross-Defendant Nicole Squires’ April 10, 2018 Special 15 Interrogatories, Set One, as required by the Joint Stipulation and Order executed by this court on July 16 24, 2018. 17 5 The hours claimed by Chauvel & Glatt are as evidenced by all the detailed billing 18 submitted with this motion, declarations. The billings do not reflect the time for preparing for, or 19 attending, the upcoming hearing. 20 6. Attached hereto as “Exhibit 1” is the billing associated with undersigned's attempts as 21 described above. The attached itemized bills are the time me and Mr. Walsh have spent on researching; 22 strategizing; communications with opposing counsel; meeting and conferring with Mr. Newcomb and 23 Mr. Finch and Mr. Wilson, an associate of Mr. Finch’s, in attempts to informally resolve these discovery 24 disputes; drafting the instant motion and the costs for filing, serving of same, to represent Squires.’ 25 These billings cover January 1, 2019 through the date of the filing of this motion up and through the 26 filing of this motion. 27 2 28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE ALTERNATIVE) AND MONETARY SANCTIONS 7 Thave handled numerous litigation matters throughout my career. My hourly rate is $365 which is commensurate, or lower, than attorneys with like experience and location in the Bay Area. 8 I also work with Mr. Thomas (“TJ”) Walsh, my associate attorney, duly licensed in California as well as Florida. Mr. Walsh has been an attommey with C&G for almost two years and has been a licensed attorney for 6 years receiving his Juris Doctor from Shepard Broad Law Center at Nova Southeastern University in 2012. Mr. Walsh's hourly rate is $325/hour and is commensurate or lower than other practicing attomeys with like experience and location in the Bay Area. 9 Chauvel & Glatt, LLP uses the recognized legal billing system Cosmolex to record time, fees and costs expended in this matter. Contemporaneous with work throughout this case, I entered the 10 time I spent with a detailed description of what was accomplished; properly recording all work billed as HW did the other attommeys who worked on this matter, including Mr. Walsh. At the end of each month, both 12 Jand Mr. Walsh reviewed our billings on this matter to ensure accuracy. 13 10. Since January 1, 2019, myself and Mr. Walsh have conducted reasonable and necessary 14 work in this matter to obtain legitimate discoverable information and to adequately defend our client 15 while defense counsel either refuses to provide discovery or is not providing code-compliant or court 16 ordered responses. 17 ll. Ihave conducted a total of 5.6 hours of billable hours of work on this matter and my time 18 is billed at a rate of $365.00 per hour for TWO THOUSAND FORTY-FOUR and 00/100 dollars 19 ($2,044.00) as of the date of this reply declaration. (See Exhibit 1.) 20 12. Mr. Walsh has conducted a total of 9.8 hours of billable hours of work on this matter and 21 his time is billed at a rate of $325.00 per hour for THREE THOUSAND ONE HUNDRED EIGHTY- 22 FIVE and 00/100 dollars ($3,185.00) as of the date of this declaration. (See Exhibit 1.) 13. J anticipate four hours to account for the preparation and attendance of this hearing. As 24 such, I request an additional $1,460.00 in reasonable attorneys’ fees. 25 14, The total amount requested from this court, which does not include the hearing scheduled 26 Sor this Motion for Terminating Sanctions and associated costs and associated costs or attorneys/fees 27 and costs of co-counsel, currently totals $6,689.00 (representing 19.4 hours) 3 28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE ALTERNATIVE) AND MONETARY SANCTIONS Under penalty of perjury under the laws of the State of California, the undersigned declares that the foregoing is true and correct. Dated: January 23, 2019 CHAUVEL & GLATT, LLP By: April S. Glatt, Esq. Attomeys for Plaintiffs and Cross-Defendants, MATTHEW SQUIRES and NICOLE SQUIRES 9 10 11 Ra As 12 13 ig 14 wa 15 16 O% 17 18 19 20 21 22 23 24 25 26 27 4 28 DECLARATION OF APRIL S. GLATT IN SUPPORT OF CROSS-DEFENDANT’S MOTION FOR TERMINATING SANCTIONS AGAINST CROSS-COMPLAINANT ROBERT C. WEHMEYER (OR ISSUE SANCTIONS IN THE ALTERNATIVE) AND MONETARY SANCTIONS CHAUVEL & GLATT, LLP 66 Bovet Road, Suite 280 San Mateo, CA 94402 Phone: 650-573-9500 ELLN 30-0581317 INVOICE Date:01/31/2019 Bill To: Matthew & Nicole Squires Professional Services Date Details Hours Rate Amount 01/04/2019 ASG Call from Matt on strategy, concerns. Call with Mike 0.70 $365.00 $255.50 on same. 01/07/2019 ASG Email from Newcomb and email with MM on whether 0.20 $365.00 $73.00 to continue deposition of Rob; multiple email exchange with MM on continuing deposition and rescheduling same and position, pros, cons. 01/11/2019 ASG Email from MM on updated notice of continuation of 0.10 $365.00 $36.50 Rob's depo. Brief review and advise on service of same. 01/15/2019 ASG Conf. with TJ to narrow issues for terminating 0.60 $365.00 $219.00 sanctions motion; go through special rogs and RPODs and strategic discussion on inclusion vs. exclusion and attribute to each COA. 01/15/2019 TJW Discussion with ASG on scope of motion for 0.80 $325.00 $260.00 terminating sanctions; review of outstanding Special interrogatories from Robert C. Wehmeyer to include in motion. 01/16/2019 ASG Additional disc. with TJ and MM on structure of 0.30 $365.00 $109.50 terminating sanctions motions. Profcon arguments. Evaluation of COA and substantial justification. 01/16/2019 TUW Draft and edit Memorandum of Points and Authorities 3.50 $325.00 $1,137.50 in Support of Motion for Terminating Sanctions against Robert C. Wehmeyer. o1t6r201 9 TIW Additional discussion with ASG and Mike Mengarelli 0.30 $325.00 $97.50 regarding terminating sanctions motion and evaluation of substantial justification defense to same. * tae e - 01/17/2019 ASG Brief disc. with TJ on terminating sanctions motion 0.10 $365.00 $36.50 and next steps for completion. 0117/2019 ASG Review and revise MPA ISO Terminating sanctions 2.30 $365.00 $839.50 motion and draft comments to TJ. Draft new declaration ISO motion; reference emails to include as exhibits to declaration and use language for ~ declaration. 0172019 TW Brief discussion with ASG on terminating sanctions 0.10 $325.00 $32.50 01/18/2019 ASG Strategic disc. on concerns with RPOD request within 0.50 $365.00 $182.50 terminating sanctions motion with TJ. Discuss “willfulness" and defenses due to ESI efforts by Finch. Conf. call with MM on same,; additional disc. on Bordin depo, approaching pre-depo, arguments on privilege. Disc. subpoena to Maxine Rowe and timing due to Notice to Consumer requirements. 01/18/2019 ASG Additional conf. with TJ on terminating sanctions 0.20 $365.00 $0.00 motion and narrowing same. (No Charge) o1ie2019 TIW Draft and edit Notice of Motion for Terminating 0.80 $325.00 $260.00 Sanctions against Robert C. Wehmeyer. 01/18/2019 TIW Draft and edit [proposed] Order for Motion for 1.30 $325.00 $422.50 Terminating Sanctions against Robert C. Wehmeyer. 01/18/2019 TUw Draft and edit Separate Statement in Support of 1.50 $325.00 $487.50 Motion for Terminating Sanctions against Robert C. Wehmeyer. 01/18/2019 TuW Review billing for monetary sanctions request in 0.90 $325.00 $292.50 Motion for Terminating Sanctions against Robert C. Wehmeyer; edits to Declaration of April S. Glatt regarding same. 01/18/2019 TIW Second discussion with ASG on terminating 0.20 $325.00 $65.00 sanctions motion and narrowing issues. 01/18/2019 TW Discussion with ASG regarding "willful" requirement 0.40 $325.00 $130.00 for Motion for Terminating Sanctions. 01/18/2019 ASG Discovery discussions and recap with TJ on outline 0.30 $365.00 $109.50 and items due. Disc. extensions for RCWC but Newcomb. Email MM on same. Email exchanges re: not meeting and conferring as not required and another motion to compel. 01/18/2019 ASG Multiple disc on terminating sanctions motion and 0.30 $365.00 $109.50 discovery trail with TJ to minimize risk at hearing. EXHIBIT 1