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] _$1,425.00Date _|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] __ $2,850.00Date [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] $2,325.00Date _|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] __ $4,575.00Date __| 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] _ $2,173.75eee 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] $46.25Date _|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) $2,450.00Date [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 reviewDate 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] $1,950.00Date 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] $525.00Date [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] $416.25Date [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] $2,025.00Date 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] $1,800.00Date _|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} $231.25395 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] _ $600.00Date [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] $56.25Date__| 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] $1,425.00Date |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] $150.00Date _| 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] $225.00Date |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] $1,050.00Date 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] $1,650.00Date [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] $333.75Date 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] $450.00Date _|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] _ $370.00Date [Attorney |Description Rate | Total Charge Total: $317,092.55Exhibit MDate 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 $300.00Plaintiff'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: $6,975.00Exhibit N1 || 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 ThereatThe 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 Thereatwar 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 ThereatCmdr annaun 10 nt 12 13 14 15 16 17 18 19 20 21 22 23 24 26 27 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 ThereatSoe daau aw uM 12 13 14 15 16 7 18 19 20 22 23 24 25 26 27 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 Thereat4 5 6 Ei 8 9 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, (ttyExhibit OSent 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, | | Defendants. | | | | 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