Sulphur Mountain Land and Livestock Co., LLC (Plaintiff) v. John A. Redmond, Maureen C. Redmond, Geraldine Redmond (Defendants) Superior Court No. CIV 214702 County of Ventura The Honorable Judge Hintz
Sulphur Mountain Land and Livestock Co., LLC (Plaintiff) v. John A. Redmond, Maureen C. Redmond, Geraldine Redmond (Defendants) Superior Court No. CIV 214702 County of Ventura The Honorable Judge Hintz
Sulphur Mountain Land and Livestock Co., LLC (Plaintiff) v. John A. Redmond, Maureen C. Redmond, Geraldine Redmond (Defendants) Superior Court No. CIV 214702 County of Ventura The Honorable Judge Hintz
Date _|Attorney|Description Hours| Rate _| Total Charge
[IC WITH SGT. LINDER RE
REDMOND; T/C WITH SGT. BILL
12/7/2004]DBC_|MARTIN RE REDMOND 0.50] $300.00] _ $150.00
Trial preparation; Conferences with
David Chatfield, Ryan Vos, and co-
12/712004|PJV__|counsel regarding same. 5.50| $300.00] _$1,650.00
Multiple T/Cs with Colleen Connors
re: trial preparation; Multiple T/Cs
lwith Clerk in Dept. 32 re: same;
[Multiple T/Cs with Pam Voich re: trial
lexhibits; Prepare trial exhibits for
[Pete Bezek; Travel to Bankruptcy
12/7/2004REV __|Court; Review and obtain case fle | 8.50|_$185.00| __ $1,572.50
12/8/2004|CC _|Prepare database 1.75] $125.00] $218.75.
Teleconference with Judge Hintz's
12/8/2004|CC__|courtroom regarding trial 0.20] $125.00] __$25.00
[continue preparing document
1218/2004\cC__|database 1.75] $125.00] $218.75
eleconference with Judge Long's
Jcourtroom regarding trial;
{teleconference with Mr. Chatfield
12/8/2004|/CC regarding the same 0.25] $125.00} $31.25
12/8/2004|CC [Draft email to attorneys regarding triall__0.25| $125.00] $31.25
[Continue preparing trial document
12/8/2004|CC |database 2.25] $125.00) $281.25
]REVIEW AND COMMENT ON MIL
12/8/2004|DBC IFOR REDMOND TRIAL 1.00] $300.00} $300.00
IREVIEW AND COMMENT ON MIL
|12/6/2004|DBC_ IFOR REDMOND TRIAL 1.00} $300.00] $300.00
12/6/2004/PJB_ Review documents, emails 1.20] $350.00] $420.00
12/€/2004|PJB [Review trial brief 0.80] __ $350.00] $280.00
Trial preparation: Conferences with
David Chatfield and Ryan Vos
12/6/2004|PJv__|regarding same. 4.75] $300.00] _$1,425.00Date _|Attorney|Description Hours| Rate | Total Charge
HT/c with Personal Attomey Service;
|Meet with David Chatfield re: trial
|preparation; Review multiple emails
from David Chatfield; Prepare on call
lagreements for Marsha Adamson,
[Sgt. Linder and Sgt. Martin; Multiple
12/8/2004|REV_ IT/Cs with Colleen re: trial exhibits 2.50] $185.00} $462.50
TIC WITH SUPERVISOR RE SANTA
IBARBARA BANKRUPTCY.
IDOCUMENTS - EXHIBITS FOR
IREDMOND TRIAL; REVIEW NEW
JAND COMMENT ON NEW DRAFTS.
|OF MOTIONS IN LIMINE; T/C WITH
IVOICH RE POCKET BRIEFS; TIC
WITH VALERIE GILBERT'S OFFICE
IRE JORDEN DOCUMENTS; TIC
WITH INVESTIGATOR RE
REDMOND; REVIEW JORDEN
DOCUMENTS, REVIEW
|GERALDINE REDMOND'S THREE
DEPOSITION TRANSCRIPTS FOR
CITATIONS; CONFERENCE WITH
BEZEK RE TRIAL BRIEF,
ICONFERENCE WITH BEZEK AND.
|VOICH RE JOINT STATEMENT OF
|THE CASE, CONFERENCE WITH
IBEZEK RE WITNESS LIS; REVIEW
REDMOND DEPOSITIONS FOR
USEFUL TESTIMONY; MEMO TO
BEZEK RE ADDITIONAL MOTIONS
IN LIMINE; TIC TO VOICH RE
12/9/2004|DBC_|ADDITIONAL MOTIONS IN LIMINE. | _ 9.50] $300.00] __ $2,850.00Date
[Description
Total Charge
12/8/2004]
DBC.
T/C WITH SUPERVISOR RE SANTA|
BARBARA BANKRUPTCY
IDOCUMENTS - EXHIBITS FOR
IREDMOND TRIAL; REVIEW NEW.
|AND COMMENT ON NEW DRAFTS
|OF MOTIONS IN LIMINE; T/C WITH
IVOICH RE POCKET BRIEFS; T/C
WITH VALERIE GILBERT'S OFFICE
IRE JORDEN DOCUMENTS; T/C.
WITH INVESTIGATOR RE
IREDMOND; REVIEW JORDEN
IDOCUMENTS, REVIEW
|GERALDINE REDMOND'S THREE
DEPOSITION TRANSCRIPTS FOR
CITATIONS; CONFERENCE WITH
IBEZEK RE TRIAL BRIEF,
|CONFERENCE WITH BEZEK AND
|VOICH RE JOINT STATEMENT OF.
ITHE CASE, CONFERENCE WITH
BEZEK RE WITNESS LIS; REVIEW
|REDMOND DEPOSITIONS FOR
USEFUL TESTIMONY; MEMO TO
IBEZEK RE ADDITIONAL MOTIONS
IN LIMINE; T/C TO VOICH RE
[ADDITIONAL MOTIONS IN LIMINE.
9.50]
$300.00}
$2,850.00
42/5/2004)
PIB
[Emails regarding trial strategy
0.40]
$350.00]
$140.00
42/9/2004
PIB
|Emails regarding jury and trial
0.40)
$350.00]
$140.00,
12/9/2004]
PJV
j aeosiaton
Trial preparation: Conferences with
[David Chatfield, Ryan Vos, and co-
counsel regarding same: Research
jadditional issues for trial brief.
7.75
$300.00]
$2,325.00Date _|Attorney|Description Hours| Rate _| Total Charge
[Prepare subpoena Tor Laurie Canty,
Multiple T/Cs with Colleen Connors
re: trial prep; Prepare final trial
lexhibits; Prepare on call letter to
Laurie Canty; Meet with David
Chatfield re: trial prep; Multiple T/Cs
lwith Personal Attorney Service;
[Travel to and meet with client re: trial
12/912004|REV__|documents 475| $185.00] _ $878.75
TIC FROM BEZEK RE FURTHER
REVISIONS TO TRIAL BRIEF,
PREPARE FURTHER REVISIONS.
TO TRIAL BRIEF; REVIEW AND
|ANALYSIS OF DOCUMENTS
PRODUCED BY JACKSON
FEDERAL AND CAL FED FOR USE
IN REDMOND TRIAL; MEETING
WITH VOICH RE CONTRACT
ISSUES ANALYSIS; REVIEW
JABLON'S PROPOSED
[STATEMENT OF THE CASE;
WORK WITH VOICH ON
REVISIONS TO PLAINTIFF'S
PROPOSED STATEMENT OF THE
CASE .5;REVIEW FINAL VERSIONS
|OF MOTIONS IN LIMINE;
ICONTINUED TRIAL PREP, WORK
JON TRIAL BRIEF, REVIEW
12/102004]DBC__ [DOCUMENTS 15.25] $300.00] __ $4,575.00Date __| Attorney|Description Hours| Rate _| Total Charge
TiC FROM BEZEK RE FURTHER |
REVISIONS TO TRIAL BRIEF,
PREPARE FURTHER REVISIONS
[TO TRIAL BRIEF; REVIEW AND
ANALYSIS OF DOCUMENTS
PRODUCED BY JACKSON
FEDERAL AND CAL FED FOR USE
IN REDMOND TRIAL; MEETING
WITH VOIGH RE CONTRACT
ISSUES ANALYSIS; REVIEW
JABLON'S PROPOSED
STATEMENT OF THE CASE;
WORK WITH VOICH ON
REVISIONS TO PLAINTIFF'S
PROPOSED STATEMENT OF THE
ICASE .5;REVIEW FINAL VERSIONS|
OF MOTIONS IN LIMINE;
CONTINUED TRIAL PREP, WORK
ION TRIAL BRIEF, REVIEW
42M0/2004DBC__|DOCUMENTS: 15.25| $300.00] _ $4,575.00
42/10/2004|PJB [Teleconference with cent 10.40] $350.00[ $140.00
Trial preparation; Conferences with
[David Chatfield and Ryan Vos
regarding same: Research additional
issues for trial brief: Conference with
ldefense counsel regarding trial
12/10/2004|PJV_|documents and exhibits. 10.25| $300.00|__$3,075.00
Meet with Chris Chatfield, Prepare
trial exhibits; Meet with Pam Voich
land David Chatfield re: trial
lpreparation; Prepare revised witness
list; Review and revise plaintiffs
|statement of the case; Prepare
lproposed orders for the motions in
imine; Review motions in limine;
[Draft motion in imine to exclude
12/10/2004]REV___ evidence of Giginin Trust 11.75] $185.00] _ $2,173.75eee
Date
Attorney
Description
Total Charge
12/11/2004]
DBC.
T/C WITH LAURIE CANTY, TIC
WITH INVESTIGATOR RE
WITNESSES
$300.00|
$1,050.00
12/11/2004)
DBC
REVIEW TRIAL DOCUMENTS;
IRESEARCH ON EDWARD SCHILLO
0.25
$300.00)
$75.00
12/11/2004]
DBC.
TC WITH LAURIE CANTY, T/C
WITH INVESTIGATOR RE
WITNESSES REVIEW TRIAL
DOCUMENTS; RESEARCH ON
IEDWARD SCHILLO
3.50]
$300.00}
$1,050.00
12/11/2004)
PUB
[Review depositions
6.00]
$350.00]
$2,100.00
12/11/2004
Pav
Trial preparation; Conferences with
David Chatfield regarding same.
4.50)
$300.00]
$1,350.00
12/11/2004
REV
Review multiple emails from David
|Chatfield; Revise Joint Witness List;
Review voicemail from A. Jablon re:
Isame: T/C with David Chatfield
0.75]
$185.00)
$138.75
12/12/2004]
DBC
[TRAVEL TO AND MEETING WITH
IMARAVELAS. ; REVIEW AND
JANALYSIS OF CLIENT'S
|COMMENTS AND REVISIONS TO
TRIAL BRIEF; REVISING THE
TRIAL EXHIBIT BLOW UPS
REVIEWING THE MOTIONS IN
6.00}
$300.00)
$1,800.00
12/12/2004)
lDBC
LIMINE
AND MEETING WITH
MARAVELAS. ; REVIEW AND
|ANALYSIS OF CLIENT'S
ICOMMENTS AND REVISIONS TO
TRIAL BRIEF; REVISING THE
TRIAL EXHIBIT BLOW UPS;
REVIEWING THE MOTIONS IN
LIMINE
6.00
$300.00)
$1,800.00
12/12/2004
PIB
[Review depositions
7.00
$350.00]
($2,450.00
12/12/2004]
REV
[Multiple T/Cs with David Chatfield re:
trial preparation
0.25)
$185.00]
$46.25Date _|Attorney
[Description
Rate
Total Charge
12/13/2004|CC
Trial prep; pick up case files from
|Attorney Vos
$125.00]
$62.50
12/13/2004|DBC
REVISIONS TO TRIAL BRIEF,
MOTIONS IN LIMINE, AND OTHER
RIAL DOCUMENTS; TRAVEL TO
|AND APPEAR FOR TRIAL CALL IN
IDEPT 32, TIC WITH CLIENT, TIC
|WITH BEZEK; REVIEW
IMARAVELAS DEPOSITION AND
EXHIBITS; PREPARE WITNESS.
FOLDERS FOR REDMOND TRIAL;
|OUTLINE MARK MARAVELAS
TESTIMONY WITH EXHIBITS,
MEMO TO BEZEK, MEMO TO.
CLIENT,
14.00}
$300.00]
$4,200.00
[12/1372004|DBc
REVISIONS TO TRIAL BRIEF,
IMOTIONS IN LIMINE, AND OTHER
TRIAL DOCUMENTS; TRAVEL TO
|AND APPEAR FOR TRIAL CALL IN
DEPT 32, T/C WITH CLIENT, T/C
WITH BEZEK; REVIEW
IMARAVELAS DEPOSITION AND
EXHIBITS; PREPARE WITNESS
FOLDERS FOR REDMOND TRIAL;
[OUTLINE MARK MARAVELAS
[TESTIMONY WITH EXHIBITS,
IMEMO TO BEZEK, MEMO TO.
CLIENT
14.00}
$300.00}
$4,200.00
42/13/2004)PJB.
‘eview trial documents,
teleconference with client;
teleconference with Attorney
IChattfield; review motions In limine;
redraft motions in limine; prepare for
trial
7.09]
$350.00)
$2,450.00Date
[Attorney |Description
Total Charge
12/13/2004]
Trial preparation: Conferences with
[David Chatfield. Ryan Vos, and co-
Icounsel regarding same; Appearance|
at trial; Conference with defense
[counsel regarding trial documents.
7.25]
$300.00)
$2,175.00
12/13/2004|REV
Revise and finalize witness lists;
Meet with David Chatfield and Pam
|Voich; Review voicemail from Pete
Bezek re: MIL; Prepare documents
Hor trial; Prepare case fife for Pete
Bezek; Meet with Colleen Connors
Ire: same; Prepare motion in lt
Icharacter evidence; Finalize all
imotions in limine
5.75]
$185.00]
$1,063.75
12/14/2004)
s2ar2o04|cc
[Trial prep; prepare index of files
received from Mr. Chattiela's office
Prepare witness binders for
witnesses; Geraldine Redmond,
[Marsha Adamson and Stephen M
IGaggero
1.00]
5.50)
$125.00]
$125.00
$125.00]
$687.50
42/14/2004]
Meeting with attomey Karczag
0.50)
$125.00]
$62.50
regarding document reviewDate
Description
Total Charge
12/14/2004]
lDBC
T/C WITH CLIENT RE REDMOND;
T/C WITH BEZEK RE REDMOND,
MEMO TO BEZEK RE REDMOND
IDAMAGE EXHIBITS; MEMO TO
IBEZEK RE REDMOND REPAIR
|AND MAINTENANCE DAMAGE.
JEXHIBITS; T/C WITH COURT RE
IREDMOND; T/C WITH CONNORS;
TIC WITH CLIENT, REVIEW
IDOCUMENTS RE REDMOND
DAMAGES; TIC WITH MARK
IMARAVELAS RE REDMOND; T/C
WITH BEZEK, 2 MEMOS FROM
IBEZEK, 2 MEMOS TO BEZEK RE
IREDMOND DAMAGES AND
[DOCUMENTS
3.25]
$300.00]
$975.00
12/14/2004
DBC.
TIC WITH CLIENT RE REDMOND;
TIC WITH BEZEK RE REDMOND;
IMEMO TO BEZEK RE REDMOND
IDAMAGE EXHIBITS; MEMO TO
BEZEK RE REDMOND REPAIR
JAND MAINTENANCE DAMAGE.
EXHIBITS; T/C WITH COURT RE
REDMOND; T/C WITH CONNORS;
T/C WITH CLIENT, REVIEW
IDOCUMENTS RE REDMOND
IDAMAGES; T/C WITH MARK
IMARAVELAS RE REDMOND; T/C
WITH BEZEK, 2 MEMOS FROM
IBEZEK, 2 MEMOS TO BEZEK RE
IREDMOND DAMAGES AND
DOCUMENTS
3.25]
$300.00]
$975.00
12/14/2004]
[Trial preparation. Conferences with
David Chatfield. Ryan Vos. and co-
Puy
lcounsel regarding same.
6.50
$300.00]
$1,950.00Date
Description
Total Charge
12/14/2004]
REV
Meet with David Chatfield; Prepare
ldocuments for David Chatfield;
Prepare and organize case file
2.25]
$185.00)
$416.25
42/15/2004]
Pu
Trial preparation; Conferences with
[David Chatfield and Ryan Vos
regarding same.
375
$300.00]
$1,125.00
12/16/2004
PJV
Trial preparation: Conferences with
David Chatfield and Ryan Vos.
regarding same.
2.00]
$300.00]
$600.00,
12/47/2004]
PUB
Review Redmond deposition;
repare for trial
1.50)
$350.00]
$525.00
12/17/2004)
tial preparation; Conferences with
David Chatfield and Ryan Vos
Psv___ regarding same.
1.50]
$300.00]
$450.00
12/17/2004
REV
IT/C with trial witnesses re: new trial
ldate; Meet with David Chatfield
4.25]
$185.00)
$231.25,
12/18/2004]
PIB
[Continued trial preparation; finish
review of Redmond deposition
2.00]
$350.00)
$700.00
12/20/2004)
[Trial preparation; Conferences with
David Chatfield and Ryan Vos
PJV___|regarding same.
2.50]
$300.00]
$750.00,
12/22/2004
ICC
Draft Notice of Nonavailability of
Icounsel
0.40
$125.00]
$50.00
12/22/2004]
cc.
Prepare witness binder for John
Redmond
0.30)
$125.00)
$37.50
[ 1222/2004]
Pav
~ Trial preparation, Conferences with
David Chatfield and Ryan Vos
regarding same.
1.50|
$300.00]
$450.00
12/22/2004)
REV
TIC with Colleen Connors re: witness
list; Revise per Pete's request;
Review emails from David Chatfield
land Colleen Connors re: same
0.50)
$185.00]
$92.50
12/24/2004
PIV
[Trial preparation,
2.50]
'$300.00)
$750.00
12/28/2004]
PIB.
[Prepare for trial
1.50]
$350.00]
$525.00Date
[Attorney |Description
Total Charge
12/27/2004]
DBC
REVIEW PRIOR REDMOND BK
PRETRIAL CONFERENCE
ISTATEMENTS, DRAFT NEW
IREDMOND BK JOINT PRETRIAL
|CONFERENCE STATEMENT.
1.00]
$300.00]
$300.00,
12/27/2004
Pav
Trial preparation; Conferences with
David Chatfield and Ryan. Vos
1.50]
$300.00)
$450.00,
12/27/2004|REV.
{regarding same
Review email from David Chatfield;
Meet with David Chatfield re: same;
[Voicemail to Jim Walters re: trial
testimony; T/C with Jim Walters re:
|scheduling and trial testimony; T/C
lwith David Chatfield re: same
1.25)
$185.00}
$231.25
12/29/2004!
DBC.
FIC TO JIM WALTERS RE
IREDMOND;MEMO TO VOS RE
IREDMOND AMENDMENT IN
IBANKRUPTCY CASE.
0.50)
$300.00]
$150.00
12/29/2004
Pav
{Trial preparation; Conferences with
David Chatfield regarding same.
5.50]
$300.00]
$1,650.00
12/30/2004|DBC.
IT/C WITH WALTERS RE
IREDMOND_
0.25]
$300.00]
$75.00
12/30/2004]
Pv
[Trial preparation; Conferences with
[David Chatfield and Ryan Vos
regarding same.
3.50)
$300.00]
$1,050.00
12/30/2004]REV.
Review email from David Chatfield re:
ladversary proceeding; Legal
research re: the same
2.25]
$185.00]
$416.25Date
[Description
Total Charge
12/31/2004)
DBC
IPREPARE QUARTERLY REPORT
LETTER TO COURT OF APPEAL IN
IREDMOND; LETTER TO STEVEN
STANLEY; PREPARE PRE-TRAIL
ICONFERENCE ORDER;
IRESEARCH ON AMENDMENT TO
ICOMPLAINT IN REDMOND
BANKRUPTCY
3.75]
$300.00]
$1,125.00
41212005]
Pav
~ [Trial preparation, Conferences with
David Chatfield and Ryan Vos
regarding same.
3.09]
$300.00]
$900.00
1/3/2005]
loc
Teleconference with attomey Bezek
regarding trial; teleconference with
fattorney Vos regarding same (x2);
draft email to Ms. Hudgens and Mr.
[Soriano regarding same
0.25]
$125.00]
$31.25
DBC.
ITC WITH BEZEK RE REDMOND
TRIAL; T/C WITH COURT CLERK
IRE REDMOND TRIAL;T/C WITH
IBEZEK RE EXHIBITS AND TRIAL
ISTRATEGY; TIC WITH STEVEN
ISTANLEY RE REDMOND RE PRE-
TRIAL CONFERENCE
ISTATEMENT; WORK ON
PREPARING EXHIBITS FOR
IREDMOND TRIAL
2.50)
$300.00]
$750.00,
PIB
[Trial preparation (7.5 = no charge)
9.50]
$350.00]
$875.00,
4113/2005]
Pav
[Trial preparation; Conferences with
David Chatfield and Ryan Vos
regarding same.
675]
$300.00]
$2,025.00Date
jAttorney
Description
Total Charge
4/3/2005)
REV
Multiple T/Cs with Bankruptcy Court
re: amended complaint and pretrial
Iconference order, Research re:
lsame; TIC with Pete Bezek re: trial;
|T/C with Colleen Connors re: same;
|Voicemail to Steven Stanley re
lpretrial conference order; Meet with
David Chatfield re: same; Prepare
lexhibits for trial
4.25]
$185.00|
$786.25
114/205]
DBC
MULTIPLE T/C’S WITH PETE
IBEZEK AND CLIENT RE REDMOND)
TRIAL STRATEGY, REVIEW
INOTICE OF UNAVAILABILITY OF
|COUNSEL AND CALENDARING
ISSUES; TRAVEL TO AND ATTEND
ITRIAL CONFERENCE IN
IREDMOND; REVISIONS TO
MOTION TO AMEND COMPLAINT
IN REDMOND BANKRUPTCY,
IREVIEW LETTER AND DRAFT
|FROM STEVE STANLEY RE
ISTATUS CONFERENCE ORDER
5.50]
$300.00]
$1,650.00
4114/2005]
PIB
[Trial preparation (no charge 2.0 Hrs.)
8.00}
$350.00]
$2,100.00
1/4'2005|PsV
Trial preparation; Conferences with
David Chatfield. Ryan Vos, and co-
|counsel regarding same; Appearance|
lat trial; Conference with defense
lcounsel regarding trial and
settlement: Conferences with David
(Chatfield and Ryan Vos regarding
Imotion to amend and bankruptcy trial
lpreparation; Correspondence with
[client regarding trial issues,
6.00)
$300.00]
$1,800.00Date _|Attorney|Description
Total Charge
4/4/2005|REV.
4/5/2005|DBC
[Multiple TICS with Bankruptcy Court
|Clerk; Begin drafting Motion to
[Amend Complaint: Research re:
lpleading fraud in bankruptcy matter,
Meet with David Chatfield; Meet with
Pam Voich re: trial preparation;
Review pre-trial conference order;
[Prepare the same for filing
5.25)
$185.00)
$971.25
FURTHER REVISIONS TO MOTION
ITO AMEND REDMOND
|COMPLAINT IN BK,
MEMORANDUM OF POINTS AND
|AUTHORITIES, RESEARCH
4.00|
$300.00]
$1,200.00
1/5/2005|PJV
Trial preparation: Conferences with
David Chatfield regarding same;
Review and revise motion to amend
bankruptcy complaint; Conferences
lwith David Chatfield and Ryan Vos
same.
3.75]
$300.00)
$1,125.00
1/5/2005|REV
[Meet with David Chatheld: Prepare
[Request for Hearing. Order for
[Setting Hearing. Motion to Amend
|Adversary Proceedings and Order
|Granting Leave to Amend; Prepare
ldocuments for filing; Travel to
[Bankruptcy Court and review court
file
7.50]
$185.00)
$1,387.50
1/6/2005] DBC_
IREWRITE PROPOSED LETTER RE
IREDMOND, MEMO TO CLIENT
0)
$300.00]
$150.00
116/2005|PJV
[Trial preparation; Conferences with
[David Chatfield and Ryan Vos
regarding same.
1.50]
$300.00]
$450.00
116/2005]REV
T/C with Tom Stevens re: exhibits,
IT/C with Bob Haber re: same; Review)
land organize case file
175
$185.00]
$323.75,Date _| Attorney,
Description
Total Charge
4/7/2005|DBC_
[TIC WITH BEZEK'S OFFICE RE
IREDMOND; MEMO AND T/C WITH
IRYAN VOS RE REDMOND.
075
$300.00}
$225.00
4/7/2005|P SV
‘Trial preparation; Conferences with
David Chatfield and Ryan Vos
regarding same.
3.00]
$300.00]
$900.00,
4/712005|REV
ITIC with David Chatfield re: trial
preparation; TIC with Carli
Youngsmouth at Foley & Bezek re:
lsame; Prepare notice of name
[change for Westlake Law Group
4.25]
$185.00]
$231.25
4/10/2005|DBC.
ITC WITH SANTA BARBARA
IBANKRUPTCY COURT RE
ITOMORROW'S HEARING; REVIEW
IDOCUMENTS FROM SANTA
IBARBARA BANKRUPTCY COURT
IRE MOTION FOR LEAVE TO
|AMEND; REVIEW AND ANALYSIS
IOF PACER RECORDS ON LINE RE
|GERALDINE REDMOND:
IBANKRUPTCY AND ADVERSARY
PROCEEDING.
2.50)
$300.00]
$750.00
1/10/2005] PJV.
[Trial preparation: Conferences with
David Chatfield and Ryan Vos
regarding same
$300.00]
$0.00
1/10/2005|REV.
[Multiple T/Cs re: pre-trial conference;
IT/C with Bankruptoy ct clerk re same
0.75]
$185.00]
$138.75,Date
Description
Total Charge
1111/2005]
DBC
TRAVEL TO AND ATTEND THE
IPRE-TRIAL STATUS
ICONFERENCE IN REDMOND; T/C
WITH COURT CLERK RE
|REDMOND; T/C TO JABLON RE
REDMOND; T/C WITH JABLON RE
IREDMOND .25; REVISION TO
LETTER RE REDMOND ; T/C WITH
JUDGE LONG'S SECRETARY, T/C
|WITH JUDGE HINTZ’ SECRETARY;
IMEMO TO BEZEK RE REDMOND
6.50] $300.00]
$1,950.00
4/41/2005}
REV
[Meet with David Chatfield re: trial
lpreparation: Locate and prepare
ldocuments for David Chatfield;
Review emails from C. Conners re:
lsame
41.50] _ $185.00}
$27.50,
4/42/2005}
Pav
[Conferences and correspondence
lwith Dayid Chatfield and Ryan Vos
regarding trial issues.
0.25| $300.00}
$75.00
4142/2005}
REV
Review emails from David Chatfield
land Pam Voich re: trial; Locate and
lreview documents re: same.
0.73| $185.00]
$135.05,
4113/2005}
DBC
REVISIONS TO STIPULATION FOR
REMOVAL FROM TRAILING LIST IN}
IREDMOND PER THE COURT'S
IREQUEST, MEMO TO BEZEK WITH
STIPULATION
0.50} _ $300.00]
$150.00,
4113/2005]
REV
Prepare stipulation and order to
[continue trial; meet with David
IChatield re: same; Prepare
ldocuments for service and filing
1.75| $185.00)
$323.75,
1114/2005]
DBC.
T/C FROM ANDREW JABLON RE
STIPULATION IN REDMOND,
REVISIONS TO STIPULATION,
0.50] $300.00]
$150.00,
1/14/2005]
REV
Prepare documents for service; Meet
lwith David Chatfield re: same
4.25] $185.00}
$231.25395
ember 3, 2003 CCP & 998 Offer Attorneys’ Fee
Date __|Attorney|Description Hours| Rate _| Total Charge
[T/C WITH CLIENT, T/C FROM
JABLON RE REDMOND STIP, T/C
1/19/2005]DBC__|TO VOS RE STIPULATION 0.25| $300.00] _$75.00
IRevise stipulation; Meet with David
|Chatfield; Review Jablon’s comments
1/19/2005|REV___|re: changes to Stipulaiton 1,00|_$185.00|__$185.00
[TIC with Bill Martin re: trial status;
Review voicemail from David
4/25/2005|REV___|Chatfield re: same 0.25] $185.00} $46.25
[TIC with Personal Aflorney Service
re: status of the stipulation to
continue trial: Meet with Pam Voich
1/26/2005|REV__|re: same 0.50] $185.00] __ $92.50
TIC with Personal Attorney Service
re: status of Stipulation; T/C with
Icourt clerk re: same; Meet with Calvin
4/27/2005|REV___|Rose re: status of case 0.75| $185.00] __ $138.75
[Teleconference with court in
Jconnection with determining whether
Motion to Amend Complaint was filed
in response to a notification
2118/2005|CSR__|contradicting same. 0.25| $225.00] __ $56.25
2/18/2005|CSR___|Review and organize case fie. 0.50] $225.00] $112.50
Review, analyze, and organize case
2121/2005|PJV__|file and discovery documents. 1.50] $300.00] __ $450.00
Review of case file in connection with
Jdetermining whether opposing
Jcounse! was served with first motion
3/21/2005|CSR__|for leave to amend complaint. 0.50] $225.00] __$112.50
Review opposition to motion for leave
3/22/2005|CSR__|to tile amended complaint. 0.75| $225.00] __$168.75
Review and analysis of Redmond
lOpposition to Motion to Amend
|Adversary Proceeding, conference
3/22/2005|DBC___|with Calvin Rose 2.00] $300.00] _ $600.00Date
[Attorney |Description
Total Charge
3/22/2005}
Puy
Review and analyze opposition to
Imotion to amend in bankruptcy
Imatter; Conferences with David
[Chatfield and Calvin Rose regarding
lsame.
4.00]
$300.00)
$300.00
CSR
Review of opposition to motion to
lamend complaint: Conduct review of
[Redmond deposition transcript to
liocate misrepresentations; Prepare
reply to opposition to motion to
lamend complaint.
0)
$225.00)
$1,462.50
3/25/2005]
DBC
TRAVEL TO AND ATTEND
IBANKRUPTCY HEARING ON PLAN
ICONFIRMATION IN REDMOND.
4.00}
$300.00]
$1,200.00
3/28/2005]
cs
[Review and modification of Reply to
lOpposition to Motion to Amend
|Complaint
150|
$225.00]
$337.50
3/26/2005]
[DBC
Review and Revise Reply Bref
2.00]
'$300.00)
‘$600.00
3/28/2005]
Pav
[Conferences with David Chatfield
land Calvin Rose regarding factual
issues for bankruptcy motion to
lamend reply brief
0.75|
$300.00)
$225.00
3/29/2005}
IcsR
[Continue modification of Reply brie
Prepare Judicial Notice for filing with
Reply to Opposition to Motion to
Amend.
4.75| $225.00
$393.75,
3/29/2005|
Pav
~_ |Conferences with David Chatfield
land Calvin Rose regarding
evidentiary issues for bankruptcy
Imotion to amend reply brief
0.50)
$300.00]
$150.00
4/4/2005)
DBC
'T/e with client, memo from client,
draft letter to Michael Baum
0.50)
$300.00]
$150.00
4/5/2005]
csR
Review and highlight pertinent
Jexcerpts of certified copy of
|deposition transcript of Geraldine
Redmond for incorporation into Reply
|to Opposition to Motion to Amend
|Compiaint
0.25}
$225.00]
$56.25Date__| Attorney]
Description
Total Charge
4/5/2005|DBC
Prepare letter to court of appeal
‘$150.00
4/11/2005|CSR
Review, modify and assemble
documents for incorporation into
Reply to opposition to motion to
lamend complaint and Request for
|Judicial Notice.
3.50]
$225.00]
$787.50
4/11/2005] DBC
Review and revise Opposition to
Motion to Amend, research; review
land revise request for judicial notice
$300.00]
$1,200.00
4/1 1/2005]DBC
Finalize review and changes to Reply
Brief
4.00]
$300.00)
$300.00
4/1 112005)PsV.
Trial preparation; Conferences with
[David Chatfield regarding same
| 225]
$300.00]
$675.00
4/15/2005]2727
Conferences and correspondence
lwith David Chatfield and co-counse!
regarding trial preparation,
0.25]
$0.00
4/18/2005|CSR
|Assemble all moving and opposing
papers in preparation for hearing on
Imotion to amend complaint.
0.50)
$225.00)
$112.50
4/19/2005]CSR
Review file to determine operative
federal statute relied on to advance
ladversary proceeding in preparation
Hor hearing on motion to amend
lcomplaint; Conduct research
regarding 11 U.S.C. 727 in
preparation for hearing on motion to
lamend complaint; Conduct on-line
research in federal database to
|determine court's docket regarding
ladversary proceeding
2.00]
$225.00]
$450.00
[Research Sth circuit issues, review
loriginal complaint, Motion,
Opposition, Reply Briefs, prepare
4/19/2005] DBC
Joutline for tomorrow's hearing _
475]
$300.00]
$1,425.00Date
|Description
Total Charge
4/20/2005}
lcsR
|Conduct research regarding the
loperative date of when complaint was|
tiled in connection with determining
bar date; Conference with Chatfield
regarding case strategy in
preparation for hearing on motion for
leave to amend complaint: Telephone|
Jcall to court clerk in connection with
|determining date of 341(a) meeting of
lcreditors and date complaint was
tiled; Research rules applicable to
Voluntary dismissals of adversary
complaints.
2.00| $225.00}
$450.00
4/20/2005]
DBC
Travel to and attend hearing on
[Motion to Amend, meet with counsel
lfor Redmond, tic to trustee
4.75)
$300.00)
$1,425.00
4/20/2005|
Pav
[Conferences with David Chatfield
land Calvin Rose regarding
|bankruptcy hearing and trial issues,
land regarding trial preparation issues
lin state court action.
0.50)
$300.00]
| __ $10.00
4/21/2005]
IcsR
[Teleconference with Chapter 7
Trustee regarding the seeking of a
|dismissal of adversary action against
Jdebtor; Conduct research regarding
Imotions to voluntarily dismiss
ladversary actions in bankruptcy
_|court.
2.75
$225.00)
$618.75
4/21/2005]
jpBc
'T/c with client regarding dismissal of
ladversary proceeding, tc with
[Colleen Conners regarding trial
preparation, memo to Conners
regarding trial documents
0.50)
$300.00]
$150.00Date _| Attorney
Description
Total Charge
4/21/2005|PJV
Trial preparation; Conferences and
lcorrespondence with David Chatfield
land co-counsel regarding same.
2.00)
$300.00]
$600.00
4/22/2005|CSR
Prepare notice of motion and motion
Hfor order dismissing complaint
Jpursuant to Bankruptcy Rule 7041
7.00)
$225.00|
$1,575.00
4/25/2005|CSR
Teleconference with court clerk
regarding procedural requirement for
noticing hearing on motion to
dismiss; Review of self-calendaring
system pdf tile from U.S. Bankruptcy
ICourt; Research regarding judicial
leconomy as a factor for voluntarily
Idismissing adversary complaints:
Prepare declarations for motion to
ldismiss adversary complaint;
[Teleconference with opposing
lcounsel regarding dismissal of
ladversary complaint; Continue
Ipreparation of Notice of Motion and
[Motion to Dismiss Adversary
Complaint; Prepare and assemble
INotice of Motion and Motion to
Dismiss Adversary Complaint for
lservice on 27 interested parties
land/or creditors.
8.00]
$225.00)
$1,800.00
4/26/2005]CSR
~ [Prepare notices to appear at tral for
John Redmond, Geraldine Redmond
land Maureen Redmond
4.00]
$225.00]
$225.00Date
|Attorney |Description
Hours
Total Charge
4/27/2005]
IcsR.
relephone callto court clerk in
response to notice of additional
Jdocuments and confirming whether
hearing on motion to dismiss is on
|calendar; Telephone call from court
|clerk confirming that motion to
ldismiss is on calendar and was
Iproperly self calendared: Review of
lcase file
0.75
$225.00|
$168.75,
4/27/2005]
DBC.
[Meet with Rose regarding trial
lwitness subpoenas, review am;
revise notices to appear at trial for
John Redmond, Geraldine Redmond
land Maureen Redmond
1.00]
$300.00] _
$300.00
5/3/2005]
IcsR
[Review case tile in connection with
revising trial subpoena and on-call
letters
1.50)
$225.00)
$337.50
5/4/2005|
csr
Review case file in connection with
preparing revised subpoenas to
1.50]
$225.00)
$337.50
5/5/2005]
csr
—feppest at tial
Research regarding whether tral
lattendance subpoenas must be
reissued following a continued trial
ldate: Prepare trial subpoena for
Georgia Jorden.
1.75]
$225.00]
$393.75
5/6/2005]
IcsR
[Review case file in connection with
reparing trial subpoenas.
0.50)
$225.00|
$112.50
5/6/2005}
Pav
[Trial preparation; Conferences and
|correspondence with David Chatfield
land Calvin Rose regarding same.
2.00]
$300.00)
‘$600.00
5/10/2005}
DBC
[Quarterly status letter to court of
lappeal
0.50}
$300.00)
$150.00
5/40/2005}
Pav
Trial preparation; Conferences and
lcorrespondence with David Chatfield.
client, and co-counsel regarding
same.
3.50]
$300.00]
$1,050.00Date
Description
Total Charge
5/1 1/2005}
Pav
Trial preparation; Conferences with
David Chatfield regarding same.
3.50)
$300.00]
$1,050.00
5/2/2005)
Ics
[Assemble and review documents in
reparation for trial
3.00)
$225.00)
$675.00
5/12/2005)
Pav
Trial preparation: Conferences with
[David Chatfield and Calvin Rose
regarding same.
2.00]
$300.00]
$600.00
5/43/2005]
IcsR
[Prepare subpoena to Jeff Ohaco,
Prepare on-call letters to tr
witnesses; Prepare correspondence
to trial witnesses regarding new tral
date.
4.75]
$225.00]
$393.75,
5/13/2005)
Pav
rial preparation, Conferences with
[David Chatfield and Calvin Rose
regarding same.
3.09]
$300.00]
$900.00
5/17/2005}
IcsR
Telephone call from L.A.P.D.
|subpoena division regarding Officer
Martin; Telephone calll to L.A.P.D.
Isubpoena division regarding witness
Hees concerning Officer Martin;
Review of case file to determine
lwhether witness fees were tendered
involving Officer Martin.
0.50)
$225.00]
$112.50
5/17/2005}
Pav
[Trial preparation: Conferences with
David Chatfield and Calvin Rose
regarding same.
2.50
$300.00]
$750.00
5/21/2005|
csr
Prepare proposed order and creditor
Imatrix for service of process.
1.00|
$225.00)
$225.00
5/22/2005)
DBC.
[Memo to Voich regarding notices to
trial NA witnesses
0.25]
$300.00]
$75.00
§/22/2005|
Pav
|Trial preparation; Correspondence
lwith David Chatfield regarding same
2.50)
$300.00]
$750.00
5/22/2005)
Pav
[Trial preparation: Conferences and
|correspondence with David Chatfield
regarding same.
5.50]
$300.00]
$1,650.00Date
[Attorney |Description
Hours| Rate
Total Charge
5/24/2005]
Prepare trial subpoena and on-call
letter to Nereyda Seymour.
0.70] _ $225.00}
$157.50
5/24/2005)
Pu
|Trial preparation: Conferences and
|correspondence with David Chatfield
land Calvin Rose regarding same.
2.50| $300.00]
$750.00,
5/25/2005)
DBC.
[Travel to and attend court hearing,
Imeet with opposing counsel
4.00} _ $300.00]
$1,200.00
5/25/2005]
Pav
Trial preparation; Research issues
for bankruptcy hearing Conferences
lwith David Chatfield regarding trial
land bankruptcy issues.
2.00| $300.00]
=I
$600.00
5/26/2005]
csr
elephone call to LAPD. Subpoena
Division regarding Officer Martin's
testimony at tril: Telephone call to
‘is. Canc. in connection with trial
preparation; Telephone call to court
clerk regarding June 6, 2005 trial
ldate
0.50). $225.00}
$112.50
5/26/2005}
DBC
[Review order of the cour, review
Inotice of ruling from Stanley, review
Imemos from Bezek
0.50] $300.00]
$150.00
5/26/2005)
Pav
Trial preparation; Conferences and
lcorrespondence with David Chatfield
land co-counsel regarding same.
2.50} _ $300.00}
$750.00
5/27/2005]
lec
oH
[Trial preparation; teleconference with
JAttorney Bezek and Mr. Chatfield
regarding trial dates; compare and
review trial exhibits to trial exhibit list
land database; drafting emails to Mr.
[Chatfield regarding trial prep
2.67] $125.00]
$333.75Date
Description
Total Charge
5/27/2005]
DBC.
Review trial documents in
Ipreparation for conference call with
Pete Bezek, conference call with
Pete Bezek, Pam Voich, Colleen
Connors regarding trial documents
status and strategy, Lc with Andrew
\Jablon regarding 998 offer, vc with
IBezek regarding 998 offer, t’c with
client regarding 998 offer, tc with
|Jabion regarding 998 offer, t/c with
[Bezek regarding 998 strategy,
prepare new 998 offer, prepare cover
letter for 998 offer, tic with Andrew
JJablon,
3.50]
$300.00]
$1,050.00
5/27/2005]
PIB
[Teleconference with Ms. Connors
land Attorney Chatfield;
teleconference with Attorney
[Chatfield (x2)
0.80)
$350.00]
$280.00
5/27/2005]
Pav
Trial preparation: Conferences and
|correspondence with David Chatfield
land co-counsel regarding same, and
[settlement negotiations; Conferences
lwith defense counsel regarding trial
issues and settlement negotiations;
Prepare statuton offer to compromise
land revise letter to defense counsel
regarding same.
4.50)
$300.00]
$1,350.00
15/30/2005)
Pav
[Trial preparation.
2.50 $300.00}
‘$750.00
5/31/2005]
DBC.
[T/c’s with Jablon regarding 996, Uc's
lwith client, ic with Bezek, prepare
letter to Jablon
1.75]
$300.00)
$525.00
5/31/2005]
Trial preparation, Conferences and
Icorrespondence with David Chatfield
regarding same, and settlement
Pav
negotiations.
4.50]
$300.00]
$450.00Date _|Attorney|Description Hours| Rate | Total Charge
lvc's with Jabion regarding 998. tic to
client, tc to Bezek, memo to client
land Bezek, review correspondence
6/1/2005]DBC__]and notice of acceptance 0.50] $300.00] __$150.00
[Conferences and correspondence
lwith David Chatfield regarding
settlement acceptance; Research
issues relating to recovery of fees
6/1/2005|P.JV___|and costs 1.00 $300.00] __ $300.00
[Conference with Voich regarding
Ipreparation of proposed judgment,
research, outline items necessary for
6/2/2005|DBC__|cost bil and motion for attomeys fees| 2.00] _$300.00| _$600.00
Trepare proposed judgment;
[Research factual and legal issues for
lattorney fee motion; Conferences
lwith David Chatfield regarding
judgment, fee recovery, and trial
6/2/2005|PJV__lappearance issues 2.50| $300.00] __$750.00
[Telephone call to trial witness
|Georgia Jorden regarding resolution
6/3/2005|CSR_|of lawsuit 0.50] $225.00] __$112.50
Research factual and legal issues for
lattorney fee motion; Conferences
lwith David Chatfield and Calvin Rose
regarding fee recovery, and trial
6/3/2005|PJV___ appearance issues 2.00] $300.00] _ $600.00
Research factual and legal issues for
6/4/2005|PJV__|attorney fee motion. 2.00] $300.00] _ $600.00
[Research and draft attomey fee
Imotion: Review and revise proposed
judgment: Preparation for court
6/5/2005|PJV___ appearance. 4.00] $300.00] _ $1,200.00
Prepare, organize and index
Jun-04JREV___|documents 2.00] $185.00] _ $370.00Date
[Attorney |Description
Rate | Total Charge
Total: $317,092.55Exhibit MDate
Attorney
Description
Total Charge
10/27/2000]
pac
IPREPARATION OF SUBPOENAS IN SMLLC V.
REDMOND
$300.00,
10/28/2002
pac
[T/C WITH PERSONAL ATTORNEY SERVICE RE
BUSINESS RECORDS SUBPOENAS IN SOMERSET:
PREPARATION OF BUSINESS RECORDS SUBPOENA,
[TO AES FINANCIAL MANAGEMENT
4.00
$300.00
$300.00
1114/2002|
pec.
LETTER TO COUNSEL FOR REDMOND: T/C WITH,
JEFFREY COWAN RE: SOMERSET
075
$300.00
$225.00
s1/t2r2002|
pec.
IREVIEW ANSWER FILED BY SOMERSET, JOHN
REDMOND, MAUREEN REDMOND AND GERALDINE
REDMOND.
0.25
$300.00
$75.00
11/13/2002]
loge
|PREPARE PROOF OF SERVICE ON AES; TIC WITH
|COURT, CLERK ON SMMLC V. SOMERSET; TRAVEL.
ITO VENTURA, SUPERIOR COURT DISCUSS TRIAL
|SETTING AND PROOFS OF SERVICE WITH CLERK
ANSWER HAS NOT BEEN FILED YET ACCORDING TO_
COURT); DRAFT REPLACEMENT SUBPOENA FOR AES|
IBASED ON NON-SERVICE
1.25
$300.00
$375.00
11/16/2002
lpsc
IREVIEW CORRESPONDENCE FROM COWAN RE
IREDMOND DISCOVERY
0.25
$300.00
$75.00
11/18/2002]
pac
IREVIEW REQUEST FOR PRODUCTION OF
DOCUMENTS, AND FORM INTERROGATORIES FROM
|SOMERSET; PREPARE SUBPOENA TO CAL FED FOR
|SOMERSET; SERVE SUBPOENA ON CAL FED FOR
SOMMERSET
4.50
$300.00
$450.00,
14/19/2003]
DBC.
IC WITH COWAN RE REDMOND DISCOVERY
025
$300.00
$75.00
41/22/2002|
bec
[TIC FROM JEFFREY COWAN RE REDMOND; LETTER
[TO JEFFREY", _COWAN RE MOTIONS.
0.50
$300.00
$150.00
41124/2002|
pec.
JREVIEW LETTER FROM COWAN AND OBJECTIONS
IDEPOSITIONS, RESEARCH AND PREPARE
[RESPONSE
4.09,
$300.00
$300.00
11/25/2002
psc.
JREVIEW AND CALENDAR THIRD PARTY DISCOVERY
DUE DATES IN REDMOND FINALIZE MEET AND
CONFER LETTER TO COWAN.
4.00
$300.00
$300.00
1126/2002)
lose
7 TO REBECCA CALDERWOOD RE REDMOND
DECLARATION ; TIC TO MARSHA RE AES
DOCUMENTS; T/C WITH MARSHA ADAMSON RE HER
DOCUMENTS AND RESPONDING TO SUBPOENAS,
IMEMO TO GAGGERO
4.00,
$300.00
$300.00
12/2/2002|
lose
[TC WITH REBECCA CALDERWOOD RE INMAN V.
REDMOND
025
$300.00
$75.00.
12/3/2002
lbec
ITIC WITH COWAN RE REDMOND DOCUMENTS AND
DEPOSITIONS
025
$300.00
$75.00.
42/4/2003]
[bec
LETTER TO COWAN RE REDMOND.
0.50
$300.00
$150.00
72/16/2002]
[DBC
MOTION FOR PROTECTIVE ORDER IN SOMERSET,
1.00)
$300.00
$300.00Plaintiff's Properly Allocated Attorneys! Foes
Incurred Prior To January 13, 2002 CCP §998 Offer =
Date
Attorney |
Description
Hours
Total Charge
12/17/2002)
pec.
[OBJECTIONS TO SOMERSETS REQUEST FOR
|PRODUCTION OF DOCUMENTS; OBJECTIONS TO
|SOMERSET'S FORM INTERROGATORIES
12/18/2000
lpac
3.00
$300.00
$900.00
IPREPARE PROOF OF SERVICE, REVISIONS TO
|RESPONSE TO REQUEST FOR PRODUCTION,
IPREPARE PROOF OF SERVICE; REVISIONS TO
IMOTION FOR PROTECTIVE ORDER, PREPARE
IDECLARATION IN SUPPORT OF MOTION FOR
PROTECTIVE ORDER, PREPARE PROOF OF SERVICE
|OF MOTION FOR PROTECTIVE ORDER
2.00
$300.00
‘$600.00
12/20/2002)
psc.
REVIEW LETTER FROM JEFFREY COWAN RE
REDMOND DEPOSITIONS AND DOCUMENT
PRODUCTION, DRAFT AND FAX RESPONSIVE LETTER|
ITO COWAN; TIC WITH COWAN RE DISCOVERY
|DISPUTES, POSSIBLE SETTLEMENT PRESENTATION,
|PERSONAL RECORDS OF CLIENTS, ETC.
4.00
$300.00
$300.00
s2/22/200%
lose
ILETTER TO COWAN RE SOMERSET MOTION TO
ICOMPEL
0.50
$300.00
$150.00
12/29/2002)
lpac
IREVIEW RECENT CORRESPONDENCE AND
|PLEADINGS, INDEX AND FILE DOCUMENTS
SOMERSET
1.50
$300.00
$450.00
41712003)
psc
IMEETING WITH CLIENT TO DISCUSS SOMERSET
ISSUE
0.50
$300.00
$150.00
41972003]
psc.
LETTER TO COWAN RE SOMERSET; PREPARE
ICHRONOLOGY OF SOMERSET LEASE NEGOTIATION
0.50
$300.00
$150.00
10/2003]
lpac
IREVIEW LETTER FROM COWAN RE SOMERSET
|DEPOS; MEETING WITH ATTORNEY SERVICE RE
|SOMERSET, FILE ORDER RE DEPOSITIONS WITH
court
075,
$300.00
$225.00
171200:
loge
IMEETING WITH CLIENT TO DISCUSS SOMERSET
issue
050,
$300.00
$150.00
19/2003)
lpec
|LETTER TO COWAN RE SOMERSET; PREPARE
CHRONOLOGY OF SOMERSET LEASE NEGOTIATION
0.50
$300.00
$150.00
111072003]
REVIEW LETTER FROM COWAN RE SOMERSET
IDEPOS; MEETING WITH ATTORNEY SERVICE RE
SOMERSET, FILE ORDER RE DEPOSITIONS WITH
psc.
lcourt
0.75
$300.00
$225.00
Total:
$6,975.00Exhibit N1 || Michael C. Baum (SBN 65158)
Andrew V. Jablon (SBN 199083)
RESCH POLSTER ALPERT & BERGER LLP
10390 Santa Monica Boulevard, Fourth Floor
3 || Los Angeles, California 90025-6917
Telephone: (310) 277-8300
4 ||Facsimile: (310) 552-3209
5 |] Attomeys for Defendants John A. Redmond,
Maureen Redmond, Geraldine Redmond, and
6 || Somerset Farms, LLC
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF VENTURA
10
11 || SULPHUR MOUNTAIN LAND AND Case No. CIV 214702
LIVESTOCK CO., LLC,
12 Honorable Steven E. Hintz/Department 42
Plaintiff,
13 Complaint filed: October 4, 2002
14 ee j
JOHN REDMOND; MAUREEN REDMOND; | NOTICE OF TAKING DEPOSITION OF DAVID
15 || GERALDINE REDMOND; SOMERSET | BLAKE CHATFIELD AND DEMAND FOR
FARMS LLC, etc., et al | PRODUCTION OF DOCUMENTS AT
16 | DEPOSITION
Defendants. |
17 Date: August 4, 2005
* |Time: 10:00 am.
Place: 10390 Santa Monica Boulevard, Fourth Floor
re Los Angeles, California 90025
20 ||TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
21 PLEASE TAKE NOTICE that on August 4, 2005, at 10:00 a.m. at the law offices of Resch
22 ||Polster Alpert & Berger LLP, 10390 Santa Monica Boulevard, Fourth Floor, Los Angeles, California
23 || 90025, Defendant John Redmond (“Defendant”) will take the deposition of David Blake Chatfield as
24 || to the following matters:
25, 1. Any and all facts supporting plaintiff Sulphur Mountain Land & Livestock LLC’s
26 || Motion for Attorneys Fees dated June 30, 2005, in the above-entitled action;
27 2. The documents requested in Exhibit “A” to this Deposition Notice.
ea 1
Notice of Taking Deposition of David Blake Chaifeld
‘and Demand for Production of Documents ThereatThe deposition shall be taken before a certified shorthand reporter authorized to administer
oaths in the State of California, Pursuant to the provisions of Code of Civil Procedure
§ 2025.220(a\(5), Defendant may record said deposition testimony by audiotape or videotape in
‘addition to recording the testimony by stenographic method through the instant visual display of the
testimony with the certified stenographic reporter and may be recorded through instant visual display
of testimony.
The deposition shall continue from day to day, excluding Saturdays, Sundays, and legal
holidays, until completed.
Defendant reserves the right to use a transcript of said deposition at trial or in any other
judicial proceeding in this action,
PLEASE TAKE FURTHER NOTICE that, pursuant to Code of Civil Procedure
§ 2025.220(a)(4), the deponent is. directed to produce at the deposition the documents requested in
Exhibit “A.”
Dated: July 20, 2005 RESCH POLSTER ALPERT & BERGER LLP
a ~
aa %
ANDREW V-AABLON
Attomeys for Defendants
John A. Redmond/Maureen Redmond, Geraldine
Redmond Gnd Somerset Farms, LLC
‘Notice of Taking Deposition of David Blake Chaajteld
‘and Demand for Production of Documents Thereatwar nuan
EXHIBIT “A”
DEFINITIONS
A. Defined Terms.
1. As used herein, the words “DOCUMENT” or “DOCUMENTS” includes any
“writing” as defined in California Evidence Code § 250, which provides as follows:
“Writing” means handwriting, typewriting, printing, photostatting,
photographing, photocopying, transmitting by electronic mail or facsimile,
and every other means of recording upon any tangible thing any form of
communication or representation, including letters, words, pictures, sounds,
or symbols, or combinations thereof, and any record thereby created,
regardless of the manner in which the record has been stored.
‘As such, DOCUMENTS includes, without limitation, any kind of written, typewritten, printed, or
recorded material whatsoever, data, tapes, cassettes, discs, magnetic cards, printouts, telegrams,
teletypes, facsimiles, notes, memoranda, correspondence, diaries, calendars, appointment books,
logs, audio and/or video recordings and transcriptions of recordings, microfilm, microfiche,
jelectronic records or representations of any kind, including information stored on computer or on
any type of computer readable storage media and capable of being reproduced by printed
representation in any form, whether or not ever printed out or displayed, photographs, pictures,
diagrams, or any other writing, however produced or reproduced, and further includes, without
limitation, originals, copies with different marks or notations, and drafts prepared in connection with
any such documents, whether or not used. Every DOCUMENT containing notations, marks, or
stamps not part of the original DOCUMENT shall be considered a separate writing subject to
production, As used herein, DOCUMENTS does not include privileged attorney-client
communications or attorney work product, and propounding party does not hereby demand
|production of such privileged attorney-client communications or attorney work product. Any
DOCUMENTS produced by responding party in connection with this demand may be redacted to
exclude privileged attorney-client communications or attorney work product, however, responding
party shall provide a Privilege Log pursuant to Code of Civil Procedure §2031.240(b)(2).
1
‘Notice of Taking Deposition of David Blake Chaifield
‘and Demand for Production of Documents ThereatCmdr annaun
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2. As used herein, “PERSON” includes any natural person, firm, association.
partnership, joint venture, corporation, government agency or any other legally cognizable entity.
3. As used herein, “YOU" or “YOUR” refers to Responding Party, and includes all
Persons or entities acting at the direction of or on behalf of Responding Party, and each of them.
4, As used herein “WESTLAKE” refers to the Westlake Law Group, and all persons or
entities acting at the direction of or on behalf of the Westlake Law Group, including but not limited
to David Blake Chatfield, Miles Carlsen, James Gustafson, Pamela J. Voich., Ryan Vos, and Calvin
S. Rose.
5. As used herein, the “ACTION” shall mean collectively all proceedings, judicial or
extra-judicial, in Sulphur Mountain Land and Livestock Co. LLC v. John Redmond; Maureen
Redmond; Geraldine Redmond; Somerset Farms LLC, etc., et al., Ventura County Superior Court
Case No. CIV 214702.
6. As used herein, the “TRO” shall mean, collectively or individually, the complaint
filed, and subsequent temporary restraining order secured, in the action captioned Geraldine
Redmond v. Steve Gaggero, Ventura County Superior Court Case No. D292677.
7. As used herein, the “BANKRUPTCY” shall mean all Bankruptcy proceedings of
Geraldine Redmond, including but not limited to the Chapter 7 Proceedings of Geraldine Redmond
in the United States Bankruptcy Court for the Central District of California, Northern Division,
bearing Case No. NDO3-12487RR and Adversary Proceeding No. 04-01005.
‘Notice of Taking Deposition of David Blake Chaifield
‘and Demand for Production of Documents ThereatSoe daau aw
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Dor
1. All DOCUMENTS, including but not limited to billing statements, fee invoices.
'S TO BE PRODUCED AT DEPOSIT:
attorney time sheets, cancelled checks and correspondence, referring to or constituting payments to
YOU for legal services rendered in connection with the ACTION.
2. All DOCUMENTS, including -but not limited to billing statements, fee invoices,
attorney time sheets, cancelled checks and correspondence, referring to or constituting payments to
YOU for legal services rendered in connection with the TRO.
3. All DOCUMENTS, including but not limited to billing statements, fee invoices,
attorney time sheets, cancelled checks and correspondence, referring to or constituting payments to
YOU for legal services rendered in connection with the BANKRUPTCY.
4. All DOCUMENTS, including but not limited to billing statements, fee invoices,
attorney time sheets, cancelled checks and correspondence, referring to or constituting attomeys fees
actually paid to WESTLAKE for legal services rendered in connection with the ACTION.
5. All DOCUMENTS, including but not limited to billing statements, fee invoices,
attorney time sheets, cancelled checks and correspondence, referring to or constituting attorneys fees
actually paid to WESTLAKE for legal services rendered in connection with the TRO.
6. All DOCUMENTS, including but not limited to billing statements, fee invoices,
attorney time sheets, cancelled checks and correspondence, referring to or constituting attorneys fees
actually paid to WESTLAKE for legal services rendered in connection with the BANKRUPTCY.
7. All DOCUMENTS upon which YOU relied in making the statements set forth in
YOUR Declaration filed in support of Plaintiff's Motion for Attorneys Fees dated June 30, 2005, in
the ACTION.
Notice of Taking Deposition of David Blake Chaajield
and Demand for Production of Documents Thereat4
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PROOF OF SERVICE
STATE OF CALIFORNIA )
dss.
COUNTY OF LOS ANGELES)
Sulphur Mountain Land and Livestock Co., LLC v. John Redmond, ete., etal.
Ventura County Superior Court Case No. CIV 214702
1 am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action: my business address is 10390 Santa Monica Boulevard. Fourth
Floor, Los Angeles, California 90025-6917.
On July 21, 2005, I served the foregoing document described as NOTICE OF TAKING
DEPOSITION OF DAVID BLAKE CHATFIELD AND DEMAND FOR PRODUCTION OF
DOCUMENTS THEREAT on te interested partes in this action via overnight delivery adaressed
as follows:
David Blake Chatfield Attorneys for Plaintiff
WESTLAKE LAW GROUP Sulphur Mountain Land and Livestock Co.
2625 Townsgate Road, Suite 330
Westlake Village, California 91361
Peter J. Bezek
FOLEY & BEZEK
15 West Carillo Street
Santa Barbara, California 93101
BY OVERNIGHT COURIER: I caused the above-referenced document to be delivered to
Federal Express for delivery to the above address.
I declare under penalty of perjury under the laws of the State of California that the above is
true and correct.
Executed on July 21, 2005, at Los Angeles, California,
(ttyExhibit OSent By:
sae 9
Soewr.4anu
805267121115 ‘Aug-29-05 8:07PM; Page 1
Peter J. Bezek, State Bar No. 102310
FOLEY & BEZEK |
15 West Carrillo Street |
Santa Barbara, California 93101
Telephone: 805-962-9495 |
Facsimile: 805-962-0722
David Blake Chatfield, State Bar No, 88991 |
WESTLAKE LAW GROUP. |
2625 Townseate Road, Suite 330 i
Westlake Village, California 91361
‘Telephone: 805-267-1220
Facsimile: 805-267-1211
Attorneys for Plaintiff
SULPHUR MOUNTAIN LAND & LIVESTOCK CO. LLC
|
SUPERIOR COURT OF THE STATE OF CALIFORNIA |
FOR THE COUNTY OF VENTURA \
SULPHUR MOUNTAIN LAND & | CASENO.: CIV214702
LIVESTOCK CO. LLC. Filed: October 4, 2002 |
Plaintiff, Assigned For All P To: |
Hon, Steven E. Hintz, |
v. Dept. 32 |
JOHN REDMOND; MAUREEN REDMOND; | PLAINTIFF'S OBJECTIONS _ 7:
GERALDINE REDMOND; SOMERSET | NOTICE OF DEPOSITION — DIRECTE!
LLC, AKA SOMERSET FARMS LLC; and | TO DAVID BLAKE CHATFIELD
DOES | through 25, inclusive,
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|
Defendants. |
|
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|
Date: August 4, 2005
Time: 10:00 a.m. 1
Place: 10390 Santa Monica Blvd., 4" Floor
Los Angeles, CA, 90025
i
Trial: June 6, 2005 |
PLAINTIFF'S OBJECTIONS TO NOTICE OF DEPOSITION |Sent By:
80526712111; ‘Aug-20-05 4:08PM; Page 2
TO ALL PARTIES AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: |
Plaintiff Sulphur Mountain Land & Livestock Co. LLC hereby makes the following
objections to the Notice of Deposition and Demand for Production of Documents ~ Directed to
David Blake Chatfield, and served by defendant John Redmond on the following grounds:
GENERAL OBJECTIONS |
1. Plaintiff objects to the Notice of Deposition in its entirety on the grounds that it Is
untimely. All statutory and court ordered discovery deadlines in this action expired in Decembtr
2003, Defendant John Redmond has never made a motion to reopen discovery, or obtained court
permission to conduct any additional discovery. Therefore, defendant is not permitted to notice
this deposition at this late stage.
2. Plaintiff objects to the Notice of Deposition in its entirely on the grounds that it is
improper and ineffective to compel the deponent’s attendance at the deposition. The deponent is ne
1 party (o this action. Defendant has not served the deponent with the requisite deposition subpoena,
pursuant to Code of Civil Procedure §1985, witich is necessary to compel the attendance of a nor
party at a deposition. |
a. Plaintiff objects to the Notice of Deposition in its entirety on the grounds that it ,
improper and ineffective to compel the deponent’s production of documents at the deposition.
[Notice of Deposition seeks the personal records of various consumers, namely several differei
clients of the deponent who is licensed California attorney; among those clients are plaintiff and
its agents. However, the defendant has failed to serve a copy of the Notice of Deposition, with
Notice of Privacy Rights and Deposition Subpoena, on all of the deponent’s clients wh«
personal records are sought by the Notice of Deposition as required by C.C.P. §§1985.3(b) and (e)
land §2025.240. The deponent asserts these Objections on behalf of his many clients whos
‘constitutional rights of privacy are affected by this Notice.
4. Plaintiff objects to the time and place for the deposition on the grounds that it is
unduly burdensome and oppressive. On or about June 29, 2005, plaintiff filed a Notice of}
‘Unavailability, advising the court and all parties that its counsel David Blake Chatfield would “be out
of the country and unavailable for proceedings in this matter from August 1, 2005, tough and|
2,
PLAINTIFF'S OBJECTIONS TO NOTICE OF DEPOSITION