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THE LAW OFFICE OF JESSICA R. BARSOTTI
Jessica R. Barsotti Esq. / SBN 209557
5032 Woodminster Lane ELECTRONICALLY
Oakland, CA 94602 FILED
510.530.4078
Supertor Court of Calffornia,
510.530.4725 / FAX County of San Frencisce
01/27/2016
Attomey for Defendant/Cross-Complainant, ere menue
Dean Gregory Asimos, dba Drake Realty Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA.
FOR THE COUNTY OF SAN FRANCISCO
JASON EVERETT THOMPSON and WIRED REAL Case No.: CGC-11-514980
ESTATE GROUP, INC.
DEFENDANT DEAN GREGORY
ASIMOS’S OPPOSTION TO MOTION
FOR ATTORNEY’S FEES
Plaintifts,
vs.
Date: February 4, 2016
Time: 1:30pm
Dept.: 503
DEAN GREGORY ASIMOS, DBA DRAKE REALTY
Defendant.
DEAN GREGORY ASIMOS, DBA DRAKE REALTY
Cross-Complainant,
vs.
JASON EVERETT THOMPSON and WIRED REAL
ESTATE GROUP, INC.
and DOES 1 through 50.
Eee
Cross-Defendants.
L INTRODUCTION
This fee motion is made for a single act of contempt and the Plaintiff is asking or over
$64,000 in fees despite the fact that this is a duplicative motion that was made by Plaintiff
previously and likely required little additional effort.
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
1v
This case is currently under Appeal, has been fully briefed, and the parties await oral
argument. Defendant believed that the mandatory injunction ordering him to release the
settlement funds he earned as a real estate broker, which were being held by a third party, was
stayed pending this appeal. Indeed that is what was advised by counsel. However, despite Mr.
Asimos’s willingness to sign the release document and lodge it with the court as described in
CCP 917. 3!, the court found him in contempt, ordered him to pay $1000 fine and ordered him to
sign and deliver the release document. Mr. Asimos paid the fine and signed the document. The
court then ordered Carr McClellan to release Mr. Asimos’ settlement funds to Plaintiff. Now,
despite the pending Court of Appeal decision regarding the disposition of these funds under a
breach of contract claim, these funds (approximately $100,000) have given to Plaintiff. Plaintiff
has now made a motion to dismiss the appeal based on this contempt charge, has file an
adversary proceeding in his bankruptcy proceeding to attempt to have it discharged and filed this
motion for more than $64,000 in attorney’s fees. This is all punishment for a single act: failing to
register his dba with the department of insurance for a period of 9 months. The injustice that has
come from this case is unending, including this latest unreasonable request for attorney’s fees.
This court should exercise its discretion and reduce the fees claimed in the interest of justice and
the tenants of law.
I. THE FEES REQUESTED ARE EXCESSIVE
“It is well established that the determination of what constitutes reasonable attorney fees
is committed to the discretion of the trial court.... [Citations.] The value of legal services
performed in a case is a matter in which the trial court has its own expertise. [Citation.] The trial
court may make its own determination of the value of the services contrary to, or without the
' The perfecting of an appeal shall not stay enforcement of the judgment or order in the trial court if the
judgment or order appealed from directs the execution of one or more instruments unless the instrument or
instruments are executed and deposited in the office of the clerk of the court where he original judgment or order is
entered to abide the order of the reviewing court. Code Civ. Proc., § 917.3
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
2necessity for, expert testimony. [Citations.] The trial court makes its determination after
consideration of a number of factors, including the nature of the litigation, its difficulty, ***207
the amount involved, the skill required in its handling, the skill employed, the attention given,
the success or failure, and other circumstances in the case.” (Melnyk v. Robledo (1976) 64
Cal.App.3d 618, 623-624, 134 Cal.Rptr. 602.) Although the terms of the contract may be
considered, they “do not compel any particular award.”
PLCM Group v. Drexler (2000) 22 Cal.4th 1084, 1096 , 95 Cal.Rptr.2d 198, 206-07, as
modified (June 2, 2000)
The fees requested by Plaintiff in this case for the contempt motion are unreasonable and
excessive, and should be reduced by this court.
The time billed includes purported attorney time incurred in attempting to execute a
judgment, rather than pursue a contempt finding, and the amounts of fees are not supported by
competent evidence, requiring a reduction in the amount of fees requested to a reasonable
amount as required by the law.
A. Hourly Rate of Attorneys and Paralegals is Excessive and Not Based on Competent
Evidence nor the Prevailing Rate in the Community
As noted by Plaintiff in his motion, attorney’s fees allowable under Code of Civil
Procedure section 1218, may be fixed by the court in a reasonable amount. To determine
reasonable attorney fees, trial court is required to determine the number of hours reasonably
expended on the case and a reasonable hourly rate for the work. Douglas E. Barnhart, Inc. v.
CMC Fabricators, Inc. (App. 4 Dist. 2012) 211 Cal.App.4th 230. Under California law, the
“reasonable hourly rate” for purposes of calculating lodestar for award of attorney's fees is that
rate prevailing in the community for similar work. Competent evidence as to the nature and valud
of the attorney’s services must be presented. Mardirossian & Associates, Inc. v. Ersoff (2007)
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
3153 Cal.App.4th 257, 269. A party's request for fees and costs should be supported by
appropriate declarations and other competent evidence (see Church of Scientology v Wollersheim!|
(1996) 42 Cal.App,4th 628, 658-659, such as time records describing the services provided (see
Maughan v Google Technol., Inc., supra, 143 Cal.App.4th at 1251, 1253 (time records that
contained vague descriptions of how time was spent were insufficient to support substantial fee
request).
Here, the Plaintiff has failed to present any competent evidence of the prevailing hourly
rate in the community for attorney and paralegal work, but rather simply reciting the terms of the
agreement with Plaintiff's counsel and quoting Laffey with no further explanation or competent
evidence to show that the claimed rates are reasonable. The reasonable hourly rate in the
community is not based on the amount that a Plaintiff has agreed to pay, and that is not the
standard to be used by the court to fix a reasonable fee. Although the terms of the contract may
be considered, they “do not compel any particular award.” Vella v. Hudgins, 151 Cal.App.3d at
p. 520; All—-West Design, Inc. v. Boozer (1986) 183 Cal.App.3d 1212, 1227.The Plaintiff has the
burden to produce competent evidence of the prevailing rate in the community. Mardirossian,
supra.
Here the Court must consider the prevailing rates in the community charged for similar
services, but no evidence has been presented by Plaintiff.
In addition, no competent evidence has been presented to substantiate the hours claimed
by Mr. Weintraub or Mr. Corpuz, as they failed to provide declarations regarding their
experience and rates and hours worked. As such the amounts claimed for Weintraub and Corpuz
should be denied in their entirety under Church of Scientology, supra..
B. The Number of Hours Claimed are Also Excessive and Must be Reduced
If the Court intends to entertain the claims of Weintraub and Corpuz despite the lack of
competent evidence of their experience and rates and hours worked, the Court still has a duty to
determine if the hours claimed are excessive. The Court has a duty to fix a reasonable fee for the
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
4work done to pursue a contempt judgment upon a motion for attorney’s fees under CCP 1218.
This requires the court to not only consider the reasonable rate in the community for similar
work, but also to fix a reasonable number of hours for the work done. Douglas E. Barnhart,
supra. Here, Plaintiffs have apparently billed their client excessive fees for the work done in this
matter, with the billing notations indicating vague block-billed conduct by the attorney.
Kyle Law has billed 65.8 hours (43.4 by Weintraub and 22.4 by Kyle) for “analyzing”
and “preparing” a seven page motion for Order to Show Cause re Contempt, and a 4 page
declaration. The motion cites a total of two cases and three statutes. The Declaration submitted
with the motion is nearly identical to the Declaration submitted by Plaintiff attorney Todd Norris
in 2013, with the addition of some documents from 2015. It is clear that over a sixty hours of
legal analysis in order to cite two cases and three statutes is excessive. Nearly ten hours per
page?
Kyle also bills another 49.8 hours for “preparing for the hearing” on the motion to show
cause and contempt (45 by Weintraub and 4.8 by Kyle). Kyle bills an additional 20.8 hours
responding to the four page Opposition to the motion (15.5 by Weintraub and 5.3 by Kyle). See
Motion for Attorney’s Fees. Thus, Kyle claims a total of 136.4 hours for making this motion, at a
cost of $31,616. This is the sum total of fees actually claimed for the contempt proceeding, and
should represent the absolute upper limit of fees available on this motion. However, even this
amount is excessive for the analysis and preparation of this motion, which was not significant,
and had already been done by this litigant for the previous motion. As such, and given the minor
infractions by Defendant and his belief that this matter was stayed by the appeal, should be
reduced by at least % for a total award of $7904, in the interest of justice.
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
3wo
Kyle also improperly included in this motion fees for collecting on the judgment from
Carr McClellan, these hours add up to 5.2 by Weintraub and 3.5 by Kyle, for a total of $2239.00.
The time expended attempting to collect the judgment after the contempt proceedings are not
recoverable in this motion as those have nothing to do with the contempt proceedings. Also
included herein is 2.1 hours for providing courtesy copies, at a cost of $409.50; and researching
efiling in San Francisco, clearly not required by the contempt proceedings a total of 2.6 hours at
a cost of $507. Also included are 10.8 hours related to helping the court with issuing a bench
warrant which was unnecessary and without merit. Mr. Asimos was never ordered to appear and
never failed to appear willingly. The “failure to appear” was at a compliance hearing for which
he was never noticed any non-compliance. This amounts to an additional $2106.00. The
remaining fees claimed are related to the making of this motion.
Under California law, once trial court has calculated a “lodestar” attorney fee award, it
must consider whether the total award so calculated under all the circumstances of case is more
than a reasonable amount and, if so, must reduce award to reasonable figure. Jn re Gorina,
Bkrtcy.C.D.Cal.2002, 296 B.R. 23. A court can determine a reasonable lodestar attorney fee
award based on the apparent reasonable amount of hours and a reasonable hourly rate and then
proceed to adjust it downward by way of equitable principles. EnPalm, LCC v. Teitler Family
Trust (App. 2 Dist. 2008) 162 Cal.App.4th 770. Here the court should exercise this discretion
and reduce the amount of fees requested to a reasonable amount. In a proper case, the amount of
reasonable fees to be awarded may be “zero.” Otherwise, fear of financial ruin from an adverse
award could discourage indigent persons from seeking justice. Garcia v. Santana (2009) 174
Cal.App.4th 464, 476-477.
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
6Here, the judgment in this matter pushed Defendant into Chapter 7 bankruptcy which he
has just recently come out of and thus an award of zero in this case may be appropriate given the
circumstances and based on equitable principles. Here. Mr. Asimos vigorously opposed this
motion and requested sanctions against Mr, Kyle because it seemed abundantly clear that the
mandatory injunction was stayed on appeal. The sanctions were requested because Mr. Kyle
intentionally intended to mislead this court when he failed to even mention the pending appeal
when he filed his motion for Order to Show Cause. Apparently all of the 65 hours of research
didn’t indicate that this little fact should be mentioned to the court. Indeed a writ should have
been filed to overturn this finding of contempt given the appeal and Asimo’s Notice of lodging
of document under CCP 917.4, however Asimos, being indigent, was unable to afford such a
review.
il. CONCLUSION
The court must exercise its discretion to determine a reasonable and just award of
attorney’s fees in this matter. In doing so, the court must reduce the hours claimed to a
reasonable and non-excessive amount to reflect unnecessary and duplicative work, as well as
require proof of the fees claimed by competent evidence. Finally, the court should consider the
equity and reasonableness of the fee award based on equitable considerations. Based on these
considerations Defendant asks that the court deny the motion for fees or in the alternative, based
on equitable considerations determine that the reasonable amount of fees is $0. In the event that
the court is inclined to award fees despite the procedural and equitable considerations, the fees
should be reduced to a total of $7904,
DATED: January 20, 2016 THE LAW OFFICE OF JESSICA R. BARSOTTI
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
7(\_
y
JESSICA IR. BARSOTTI
‘Attorneys for De ndant and Cross-Complainant
DEAN GREGORY ASIMOS
ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES
CGC-11514980
8
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27 28 THE LAW OFFICE OF JESSICA R. BARSOTTI Jessica R. Barsotti Esq. / SBN 209557 5032 Woodminster Lane ELECTRONICALLY Oakland, CA 94602 FILED 510.530.4078 Supertor Court of Calffornia, 510.530.4725 / FAX County of San Frencisce 01/27/2016 Attomey for Defendant/Cross-Complainant, ere menue Dean Gregory Asimos, dba Drake Realty Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA. FOR THE COUNTY OF SAN FRANCISCO JASON EVERETT THOMPSON and WIRED REAL Case No.: CGC-11-514980 ESTATE GROUP, INC. DEFENDANT DEAN GREGORY ASIMOS’S OPPOSTION TO MOTION FOR ATTORNEY’S FEES Plaintifts, vs. Date: February 4, 2016 Time: 1:30pm Dept.: 503 DEAN GREGORY ASIMOS, DBA DRAKE REALTY Defendant. DEAN GREGORY ASIMOS, DBA DRAKE REALTY Cross-Complainant, vs. JASON EVERETT THOMPSON and WIRED REAL ESTATE GROUP, INC. and DOES 1 through 50. Eee Cross-Defendants. L INTRODUCTION This fee motion is made for a single act of contempt and the Plaintiff is asking or over $64,000 in fees despite the fact that this is a duplicative motion that was made by Plaintiff previously and likely required little additional effort. ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 1v This case is currently under Appeal, has been fully briefed, and the parties await oral argument. Defendant believed that the mandatory injunction ordering him to release the settlement funds he earned as a real estate broker, which were being held by a third party, was stayed pending this appeal. Indeed that is what was advised by counsel. However, despite Mr. Asimos’s willingness to sign the release document and lodge it with the court as described in CCP 917. 3!, the court found him in contempt, ordered him to pay $1000 fine and ordered him to sign and deliver the release document. Mr. Asimos paid the fine and signed the document. The court then ordered Carr McClellan to release Mr. Asimos’ settlement funds to Plaintiff. Now, despite the pending Court of Appeal decision regarding the disposition of these funds under a breach of contract claim, these funds (approximately $100,000) have given to Plaintiff. Plaintiff has now made a motion to dismiss the appeal based on this contempt charge, has file an adversary proceeding in his bankruptcy proceeding to attempt to have it discharged and filed this motion for more than $64,000 in attorney’s fees. This is all punishment for a single act: failing to register his dba with the department of insurance for a period of 9 months. The injustice that has come from this case is unending, including this latest unreasonable request for attorney’s fees. This court should exercise its discretion and reduce the fees claimed in the interest of justice and the tenants of law. I. THE FEES REQUESTED ARE EXCESSIVE “It is well established that the determination of what constitutes reasonable attorney fees is committed to the discretion of the trial court.... [Citations.] The value of legal services performed in a case is a matter in which the trial court has its own expertise. [Citation.] The trial court may make its own determination of the value of the services contrary to, or without the ' The perfecting of an appeal shall not stay enforcement of the judgment or order in the trial court if the judgment or order appealed from directs the execution of one or more instruments unless the instrument or instruments are executed and deposited in the office of the clerk of the court where he original judgment or order is entered to abide the order of the reviewing court. Code Civ. Proc., § 917.3 ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 2necessity for, expert testimony. [Citations.] The trial court makes its determination after consideration of a number of factors, including the nature of the litigation, its difficulty, ***207 the amount involved, the skill required in its handling, the skill employed, the attention given, the success or failure, and other circumstances in the case.” (Melnyk v. Robledo (1976) 64 Cal.App.3d 618, 623-624, 134 Cal.Rptr. 602.) Although the terms of the contract may be considered, they “do not compel any particular award.” PLCM Group v. Drexler (2000) 22 Cal.4th 1084, 1096 , 95 Cal.Rptr.2d 198, 206-07, as modified (June 2, 2000) The fees requested by Plaintiff in this case for the contempt motion are unreasonable and excessive, and should be reduced by this court. The time billed includes purported attorney time incurred in attempting to execute a judgment, rather than pursue a contempt finding, and the amounts of fees are not supported by competent evidence, requiring a reduction in the amount of fees requested to a reasonable amount as required by the law. A. Hourly Rate of Attorneys and Paralegals is Excessive and Not Based on Competent Evidence nor the Prevailing Rate in the Community As noted by Plaintiff in his motion, attorney’s fees allowable under Code of Civil Procedure section 1218, may be fixed by the court in a reasonable amount. To determine reasonable attorney fees, trial court is required to determine the number of hours reasonably expended on the case and a reasonable hourly rate for the work. Douglas E. Barnhart, Inc. v. CMC Fabricators, Inc. (App. 4 Dist. 2012) 211 Cal.App.4th 230. Under California law, the “reasonable hourly rate” for purposes of calculating lodestar for award of attorney's fees is that rate prevailing in the community for similar work. Competent evidence as to the nature and valud of the attorney’s services must be presented. Mardirossian & Associates, Inc. v. Ersoff (2007) ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 3153 Cal.App.4th 257, 269. A party's request for fees and costs should be supported by appropriate declarations and other competent evidence (see Church of Scientology v Wollersheim!| (1996) 42 Cal.App,4th 628, 658-659, such as time records describing the services provided (see Maughan v Google Technol., Inc., supra, 143 Cal.App.4th at 1251, 1253 (time records that contained vague descriptions of how time was spent were insufficient to support substantial fee request). Here, the Plaintiff has failed to present any competent evidence of the prevailing hourly rate in the community for attorney and paralegal work, but rather simply reciting the terms of the agreement with Plaintiff's counsel and quoting Laffey with no further explanation or competent evidence to show that the claimed rates are reasonable. The reasonable hourly rate in the community is not based on the amount that a Plaintiff has agreed to pay, and that is not the standard to be used by the court to fix a reasonable fee. Although the terms of the contract may be considered, they “do not compel any particular award.” Vella v. Hudgins, 151 Cal.App.3d at p. 520; All—-West Design, Inc. v. Boozer (1986) 183 Cal.App.3d 1212, 1227.The Plaintiff has the burden to produce competent evidence of the prevailing rate in the community. Mardirossian, supra. Here the Court must consider the prevailing rates in the community charged for similar services, but no evidence has been presented by Plaintiff. In addition, no competent evidence has been presented to substantiate the hours claimed by Mr. Weintraub or Mr. Corpuz, as they failed to provide declarations regarding their experience and rates and hours worked. As such the amounts claimed for Weintraub and Corpuz should be denied in their entirety under Church of Scientology, supra.. B. The Number of Hours Claimed are Also Excessive and Must be Reduced If the Court intends to entertain the claims of Weintraub and Corpuz despite the lack of competent evidence of their experience and rates and hours worked, the Court still has a duty to determine if the hours claimed are excessive. The Court has a duty to fix a reasonable fee for the ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 4work done to pursue a contempt judgment upon a motion for attorney’s fees under CCP 1218. This requires the court to not only consider the reasonable rate in the community for similar work, but also to fix a reasonable number of hours for the work done. Douglas E. Barnhart, supra. Here, Plaintiffs have apparently billed their client excessive fees for the work done in this matter, with the billing notations indicating vague block-billed conduct by the attorney. Kyle Law has billed 65.8 hours (43.4 by Weintraub and 22.4 by Kyle) for “analyzing” and “preparing” a seven page motion for Order to Show Cause re Contempt, and a 4 page declaration. The motion cites a total of two cases and three statutes. The Declaration submitted with the motion is nearly identical to the Declaration submitted by Plaintiff attorney Todd Norris in 2013, with the addition of some documents from 2015. It is clear that over a sixty hours of legal analysis in order to cite two cases and three statutes is excessive. Nearly ten hours per page? Kyle also bills another 49.8 hours for “preparing for the hearing” on the motion to show cause and contempt (45 by Weintraub and 4.8 by Kyle). Kyle bills an additional 20.8 hours responding to the four page Opposition to the motion (15.5 by Weintraub and 5.3 by Kyle). See Motion for Attorney’s Fees. Thus, Kyle claims a total of 136.4 hours for making this motion, at a cost of $31,616. This is the sum total of fees actually claimed for the contempt proceeding, and should represent the absolute upper limit of fees available on this motion. However, even this amount is excessive for the analysis and preparation of this motion, which was not significant, and had already been done by this litigant for the previous motion. As such, and given the minor infractions by Defendant and his belief that this matter was stayed by the appeal, should be reduced by at least % for a total award of $7904, in the interest of justice. ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 3wo Kyle also improperly included in this motion fees for collecting on the judgment from Carr McClellan, these hours add up to 5.2 by Weintraub and 3.5 by Kyle, for a total of $2239.00. The time expended attempting to collect the judgment after the contempt proceedings are not recoverable in this motion as those have nothing to do with the contempt proceedings. Also included herein is 2.1 hours for providing courtesy copies, at a cost of $409.50; and researching efiling in San Francisco, clearly not required by the contempt proceedings a total of 2.6 hours at a cost of $507. Also included are 10.8 hours related to helping the court with issuing a bench warrant which was unnecessary and without merit. Mr. Asimos was never ordered to appear and never failed to appear willingly. The “failure to appear” was at a compliance hearing for which he was never noticed any non-compliance. This amounts to an additional $2106.00. The remaining fees claimed are related to the making of this motion. Under California law, once trial court has calculated a “lodestar” attorney fee award, it must consider whether the total award so calculated under all the circumstances of case is more than a reasonable amount and, if so, must reduce award to reasonable figure. Jn re Gorina, Bkrtcy.C.D.Cal.2002, 296 B.R. 23. A court can determine a reasonable lodestar attorney fee award based on the apparent reasonable amount of hours and a reasonable hourly rate and then proceed to adjust it downward by way of equitable principles. EnPalm, LCC v. Teitler Family Trust (App. 2 Dist. 2008) 162 Cal.App.4th 770. Here the court should exercise this discretion and reduce the amount of fees requested to a reasonable amount. In a proper case, the amount of reasonable fees to be awarded may be “zero.” Otherwise, fear of financial ruin from an adverse award could discourage indigent persons from seeking justice. Garcia v. Santana (2009) 174 Cal.App.4th 464, 476-477. ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 6Here, the judgment in this matter pushed Defendant into Chapter 7 bankruptcy which he has just recently come out of and thus an award of zero in this case may be appropriate given the circumstances and based on equitable principles. Here. Mr. Asimos vigorously opposed this motion and requested sanctions against Mr, Kyle because it seemed abundantly clear that the mandatory injunction was stayed on appeal. The sanctions were requested because Mr. Kyle intentionally intended to mislead this court when he failed to even mention the pending appeal when he filed his motion for Order to Show Cause. Apparently all of the 65 hours of research didn’t indicate that this little fact should be mentioned to the court. Indeed a writ should have been filed to overturn this finding of contempt given the appeal and Asimo’s Notice of lodging of document under CCP 917.4, however Asimos, being indigent, was unable to afford such a review. il. CONCLUSION The court must exercise its discretion to determine a reasonable and just award of attorney’s fees in this matter. In doing so, the court must reduce the hours claimed to a reasonable and non-excessive amount to reflect unnecessary and duplicative work, as well as require proof of the fees claimed by competent evidence. Finally, the court should consider the equity and reasonableness of the fee award based on equitable considerations. Based on these considerations Defendant asks that the court deny the motion for fees or in the alternative, based on equitable considerations determine that the reasonable amount of fees is $0. In the event that the court is inclined to award fees despite the procedural and equitable considerations, the fees should be reduced to a total of $7904, DATED: January 20, 2016 THE LAW OFFICE OF JESSICA R. BARSOTTI ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 7(\_ y JESSICA IR. BARSOTTI ‘Attorneys for De ndant and Cross-Complainant DEAN GREGORY ASIMOS ASIMOS OPPOSITION TO MOTION FOR ATTORNEY FEES CGC-11514980 8