Motion-Secondary: Diana Blum, MD vs Sutter Health et al

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                                Theresa J. Barta, SBN 150995
BARTA LAW

4041 Macarthur Blvd., Ste. 280
Newport Beach, CA 92660-2537
Telephone: (949) 833-3383
Facsimile: (949) 209-2530
Email: theresa@barta-law.com.

Charles M. Louderback, SBN 88788
Stacey L, Pratt, SBN 124892
LOUDERBACK LAW GROUP

44 Montgomery Street, Suite 2970
San Francisco, CA 94104
Telephone: (415) 615-0200
Facsimile: (415) 795-4775

E-Mail: — clouderback@louderbackgroup.com
spratt@louderbackgroup.com
Attorneys for Plaintiff

DIANA P. BLUM, M.D.

IN AND FOR THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA - UNLIMITED JURISDICTION

DIANA P. BLUM, M.D., Civil Case No. 2015-1-CV-277582

Plaintiff,
DECLARATION OF ERICKA
v. CLARKE IN SUPPORT OF
PLAINTIFF’S OPPOSITION TO
SUTTER HEALTH, a California corporation; | DEFENDANT PALO ALTO

PALO ALTO FOUNDATION MEDICAL
GROUP, INC., a California corporation; PALO

FOUNDATION MEDICAL GROUP,
INC.’S MOTION TO STRIKE / TAX
MEMORANDUM OF COSTS BASED

ALTO MEDICAL FOUNDATION, a

to : ON 998 OFFER
California corporation; and DOES 1 through 20,
Date: August 20, 2018
Defendants. Time: 1 30 pan,
"| Dept: 16
Judge: Hon, Drew C. Takaichi

Complaint filed: March 4, 2015
Trial Date: January 8, 2018

00023482 v3

DECLARATION OF ERICKA CLARKE IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT.
PALO ALTO FOUNDATION MEDICAL GROUP, INC.’S MOTION TO STRIKE / TAX MEMORANDUM OF
COSTS BASED ON 998 OFFER; Case No, 2015-1-CV-277582oD me I DOA

I, Ericka Clarke, declare:

1. lam a senior paralegal with the Louderback Law Group. The Louderback Law
Group is counsel for Plaintiff Diana P. Blum, M.D. (“Plaintiff’) along with co-counsel Theresa J.
Barta from Barta Law, in this action. I make this declaration in support of Plaintiff's Opposition
to Defendant Palo Alto Foundation Medical Group Inc.’s (““PAFMG”) Motion to Strike/ Tax
Memorandum of Costs Based on 998 Offer. The matters stated herein are of my own personal
knowledge and if called to testify to these matters, I could and would competently testify thereto.

2. assisted with preparing Plaintiffs Memorandum of Costs, including generating
the worksheets from expense information provided by trial counsel Theresa J. Barta. The
deposition travel costs included on Plaintiff's Memorandum of Costs were prepared from
accounting records generated by the Barta Law firm consisting of airfare and hotel charges related
to appearances in this action.

3. Attached hereto as Exhibit A is a true and correct copy of a table setting forth in
detail the costs incurred relating to recorded travel to depositions in this action. On many
occasions, multiple depositions were taken on the same date or consecutive dates. For these
depositions, I divided the deposition costs by the number of deponents and apportioned them
equally, as sct forth in the Memorandum of Costs under Item 4--Deposition Costs. I have grouped
these costs together in the attached table for ease of reference. The charges listed in Item 4--

Deposition Costs are not duplicative.

Executed this 7" day of August 2018 in San Francisco, California.
I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

¢/ Bricka Clarke
00023482 v3 -1-

DECLARATION OF ERICKA CLARKE IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT
PALO ALTO FOUNDATION MEDICAL GROUP, INC.’S MOTION TO STRIKE / TAX MEMORANDUM OF
COSTS BASED ON 998 OFFER; Case No. 2015-1-CV-27758210/7/15

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