Motion To Tax Costs

Motion

Cal. Super. - 2nd Dist.July 15, 2015

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The Law Office of Cliff Dean Schneider Cliff Schneider, SBN 290819 8939 S. Sepulveda Blvd., Suite 102 Los Angeles, CA 90045 (888) 332-2999 Attorney for Plaintiff Marina Kostanian SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, UNLIMITED JURISDICTION Marina Kostanian Case No.: BC587999 Plaintiff, PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER VS. John Anthony; Charles Dunn Company, Inc.; Ticor Title Company of Date: February 1, 2019 Time: 8:31 a.m. California; and Does 1 to 10, Dept: 49 Defendants CRS: 851750321360 -_ - - - - - - - - - - - - - - - - TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT on February 1, 2019, at 8:31 a.m., or as soon thereafter as the matter may be heard, in Department 49 of the above-titled Court, located at 111 North Hill Street, Los Angeles, California, 90012, Plaintiff Marina Kostanian will and hereby does move this Court, pursuant to Rule 3.1700 of the California Rules of Court, for an order taxing certain costs claimed in Defendant Ticor Title Company of California’s (hereinafter “Ticor”) Memorandum of Costs. Plaintiff requests that the following claimed costs be taxed on the following grounds: A. Item 1 Costs (Filing and Motion Fees) Should be Taxed. Ticor seeks to recover $2,873.80 in filing and motion fees. The court should tax PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 these costs because the amount sought is unreasonable and not necessary to conduct litigation. (Code Civ. Proc., § 1033.5(c) (2) and (3)) Item 4 Costs (Deposition Costs) Should be Taxed. Ticor seeks to recover $15,237.45 in deposition costs. The Court should tax the deposition costs because that amount sought is unreasonable and the amount was not actually incurred. (Code Civ. Proc., § 1033.5(c) (1) and (3)) Item 5 Costs (Service of Process) Should be Taxed. Ticor requests $11,167.60 in service of process costs. The court should tax these costs because the amount sought is unreasonable and the amount was not actually incurred. (Code Civ. Proc., § 1033.5(c) (1) and (3)) Item 8 Costs (Witness Fees) Should Be Taxed. Ticor seeks to recover $4,200 in expert witness costs. The Court should tax the costs sought by Ticor because the amount requested is inconsistent with what was actually incurred and is unreasonable because the expert never testified in the trial. (Code Civ. Proc., § 1033.5(c) (1) and (3)) Item 9 Costs (Court-ordered Transcripts) Should be Stricken. Ticor seeks to recover $7,022.87 in costs for court-ordered transcripts. The Court should strike these costs because the Court never ordered any transcripts. (Code Civ. Proc., § 1033.5(b) (5)) Item 13 Costs (Interpreter Fees) Should be Stricken. Ticor seeks to recover $555.10 in interpreter fees for witness Elizaveta Krilliova. The Court should strike this cost because they were not reasonably necessary to conduct the litigation. Ms. Krilliova speaks English and testified before this Court without an interpreter. (Code Civ. Proc., § 1033.5(c) (2)) PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 This Motion is based on this Notice of Motion, the accompanying Memorandum of Points and Authorities, the pleadings and file of this matter, the declaration of Cliff Dean Schneider, and upon such other argument and evidence as may be properly presented at the hearing on this motion. Dated this 31th of December, 2018 Go Cliff Dean Schneider, Esq. Attorney for Plaintiff Marina Kostanian MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION On December 10, 2018, Ticor filed and served by mail a Memorandum of Costs (“MOC”) as the prevailing party. This MOC seeks to recover costs that are duplicative, unnecessary, and unreasonable, and Ticor has not provided sufficient support for their claimed costs. Plaintiff Kostanian requests that the Court carefully scrutinize Ticor’s Memorandum of Costs and tax certain costs or strike costs in their entirety. The Court Should Tax Ticor’s Costs Insofar as They are Unreasonable or Have Not Been Actually Incurred by Ticor. As a general rule “the parties to civil litigation are required to finance their own participation in the litigation.” Ripley v. Pappadopoulos, (1994) 23 Cal.App.4th 1616, 1622. This general rule is subject to the exceptions contained in the cost statutes. Id. California Code of Civil Procedure (“CCP”) § 1032 provides that a prevailing party in an action is entitled to recover costs. CCP § 1033.5 lists the costs recoverable by a PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 prevailing party. However, any costs claimed must be actually incurred, “reasonably necessary to the conduct of the litigation rather than merely ”convenient or beneficial to its preparation,” and “reasonable in amount.” CCP § 1033.5(c) (1)-(3). If a party seeks what appear to be allowable costs, the party seeking to tax those costs must show that they are either unreasonable or unnecessary. Ladas v. Ca. State Auto Ass’n (1993) 19 Cal.App.4th 761, 774. Once the costs are contested, they are put in issue and the burden of proof shifts to the party claiming those costs to prove their legitimacy through documentation showing their reasonableness in amount and necessity in the conduct of litigation. Nelson v. Anderson (1999) 72 Cal.App.4th 111, 131 [“We agree the mere filing of a motion to tax costs may be a proper objection to an item, the necessity of which appears to be doubtful, or which does not appear to be proper on its face.”]; see also Oak Grove Sch. Dist. V. City Title Ins. Co. (1963) 217 Cal.App.2d 678, 698-699 [where the claim is for items “the necessity for which is doubtful,” or “if the correctness of the memorandum is challenged . . . by affidavit or other evidence of the contesting party,” the burden is on the party seeking costs to establish the items’ necessity.] Throughout the MOC, Ticor claims amounts for costs that greatly exceed the amount actually incurred. In addition, much of the costs actually incurred were unreasonable and/or unnecessary to the pursuit of the litigation. As a result, the Court should tax Ticor’s costs insofar as they are unreasonable or have not been actually incurred by Ticor. Ticor’s Claimed Costs for Filing Fees Should be Taxed to the Extent That Those Costs are Unreasonable and/or Were Not Incurred. In its MOC, Ticor lists $2,873.80 as its costs for “Filing and motion fees.” This is wholly unsupported in the included worksheet and appears to PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 bear no relation to actual filing costs in this matter. A thorough review of the case history reveals that Ticor paid a first appearance fee of $435.00 when it filed its Demurrer, another $500 when it filed its Motion for Summary Judgment and several $60 filing fees for motions. It is beyond comprehension how this could have totaled to nearly $3,000 of filing fees. Ticor bears the burden of proving these filing fees, and in the absence of proof, the Court should tax any claimed costs. Ticor’s Claimed Deposition Costs Should be Taxed to the Extent That Those Costs are Unreasonable and/or Were Not Incurred. In its MOC, Ticor lists $15,237.45 as its deposition costs. This figure is unsupported by the attached worksheet which lists 10 depositions totaling $6,675.06. Even this lesser figure is inappropriate, however, because there were only three depositions taken in this matter. After receiving the MOC, Plaintiff’s counsel, Cliff Schneider, contacted Robin Ratner, counsel for Ticor, seeking some documentation to support these charges. Ticor provided two invoices related to the deposition of Elizaveta Kirillova and no invoices for the depositions of Michael Mahoney or Plaintiff Marina Kostanian. (Exhibit 1) Ticor bears the burden of proving its deposition costs, and in the absence of proof, the Court should tax any claimed costs. Ticor’s Claimed Costs for Service of Process Should be Taxed to the Extent That Those Costs are Unreasonable and/or Were Not Incurred. In its MOC, Ticor lists $11,167.60 as its costs for service of process. This figure is unsupported by the attached worksheet which lists process on two individuals totaling $6,310.29. Even this figure is inappropriate, however, because Ticor chose an unreasonably expensive method by which to effectuate service. Whereas service of a subpoena typically costs between $50 and $100, including multiple service attempts, Ticor chose to retain a PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 5 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 private investigation firm in Orange County to serve two individuals living in Woodland Hills. In total, Ticor was billed for 1,488 miles of driving at $95/hr plus $.59/mile. (Exhibit 2) Indeed, each service attempt included hours of driving time for which Ticor now seeks to have Plaintiff pay. This is unreasonable under the circumstances, and the Court should tax these costs to the extent that they exceed a reasonable amount to effectuate service. Ticor’s Claimed Witness Fees Should be Stricken, or in the Alternative, be Taxed to the That Those Costs are Unreasonable and/or Were Not Incurred. In its MOC, Ticor lists $4,200 in Witness fees. In its worksheet, Ticor lists an expert named PJ Garcia as having performed 9.3 hours of work at $400.00 per hour. Inexplicably, Ticor totals this to $4,200.00 instead of $3,720.00. Even this amount is unreasonable, however, because no such witness ever testified at trial. Ticor bears the burden of proving its Witness fees, and in the absence of proof, the Court should tax any claimed costs. Ticor’s Claimed Costs for Court-Ordered Transcripts Should be Stricken in Their Entirety Because the Court Never Ordered any Transcripts be Prepared. In its MOC, Ticor lists $7,022.87 in costs for preparation of Court- Ordered Transcripts. This cost is wholly inappropriate because the Court never ordered that any transcripts be prepared throughout the trial in this matter. Instead, Ticor seeks to have Plaintiff pay for rush and daily transcripts ordered by Ticor for Ticor’s use throughout the trial. These costs are expressly unrecoverable under §1033.5(b) (5). PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Ticor’s Claimed Interpreter Fees Should be Stricken Because No Interpreter was Necessary or Used for any Witness. In its MOC, Ticor lists $555.10 in interpreter fees. In response to Plaintiff’s Counsel’s request, Ticor provided an invoice for this cost showing that it was related to the deposition of Elizaveta Kirillova. (Exhibit 3) This cost is unnecessary because no interpreter was used at Ms. Kirillova’s deposition. Pursuant to C.C.P. 1033.5(3) (B) an interpreter for a deposition is only a cost as it relates to “the deposition of a party or witness who does not proficiently speak or understand the English language. Ms. Kirillova testified at trial in perfect English without the use of an interpreter. It would be wholly inappropriate for Plaintiff to be responsible for Ticor’s costs for interpreter fees. Conclusion For the reasons stated above, Plaintiff respectfully requests the Court tax costs claimed in Items 1, 4, 5, and 8 of Defendant Ticor Title Company of California’s Memorandum of Costs. Plaintiff further requests the Court to strike the costs claimed in Items 9 and 13 of Defendant Ticor Title Company of California’s Memorandum of Costs. Dated this 31th of December, 2018 G Cliff Dean Schneider, Esq. Attorney for Marina Kostanian PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, DECLARATION OF CLIFF DEAN SCHNEIDER Cliff Dean Schneider, declare as follows: 1. I am a duly licensed attorney in the State of California and I represent Plaintiff Marina Kostanian in the above-captioned matter. I received Defendant Ticor Title Company of California’s Memorandum of Costs (“MOC”) on December 12, 2018. On December 12, 2018, I emailed Ticor’s counsel Robin Ratner explaining that the MOC has some inconsistencies and asking for receipts that reflect the costs in the MOC. On December 13, 2018, Ms. Ratner responded with invoices and a spreadsheet. Upon review of these invoices, I was able to find two invoices related to the deposition of Elizaveta Kirillova. Attached as Exhibit 1 to this motion is a true and accurate copy of these invoices. Among the documents disclosed to me, I was unable to locate any invoices related to any other depositions. Included in the documents provided by Ms. Ratner, I found invoices related to service of process of both Elizaveta Kirillova and Natalia Movshovich. Attached as Exhibit 2 to this motion is a true and accurate copy of these invoices. In my experience as a litigator, I typically pay $50 to $100 for personal service. Which generally includes up to three attempts. I have never paid more than a total of $350 to have someone served, including with the use of skip-trace services. Included in the documents provided by Ms. Ratner, I found an invoice related to interpreter services. Attached as Exhibit 3 to this motion is a true and accurate copy of that invoice. PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. December 31, 2018 G- Dated Cliff Dean Schneider Attorney for Marina Kostanian PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE State of California County: Los Angeles Case number: BC587999 I am over the age of 18, a resident of Los Angeles County, California, and not a party to the action referenced above. My business address is 8939 S. Sepulveda Blvd., Suite 102, Los Angeles, CA 90045. On December 31, 2018, I served PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER, by placing a true copy thereof into an envelope with first-class postage affixed and addressed to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 90017 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on the above date in Los Angeles, California G Declarant PLAINTIFF MARINA KOSTANIAN’S NOTICE OF MOTION AND MOTION TO STRIKE OR TAX COSTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CLIFF DEAN SCHNEIDER - 10 EXHIBIT 1 Veritext Corporate Services, Inc. 290 West Mt. Pleasant Ave, Suite 2260 Livingston NJ 07039 Tel. 973-410-4098 Fax. 973-410-1313 Fed. Tax ID: 20-3457913 VERITEXT aLEGAL SOLUTIONS Bill To: Invoice #: CS3379001 Fidelity National Law Group : .915 Wilshire Blvd. Invoice Date: 6/14/2018 Suite 2100 Balance Due: $0.00 Los Angeles, CA, 90017 Case: Kostanian v. Ticor, Et Al. Claim #: 520846 Job #: 2904046 | Job Date: 5/23/2018 | Delivery: Normal File No: L076045 Billing Atty: Location: FNLG/California (LA) 915 Wilshire Blvd | Suite 2100 Los Angeles, CA 90017-3450 Sched Atty: Robin Ratner | FNLG/California (LA) Witness Description Units Quantity Price Amount Original with 1 Certified Transcript Page 194.00 $3.95 $766.30 Attendance Fee - Per Session 1 1.00 $25.00 $25.00 Exhibits Per Page 33.00 $0.35 $11.55 Elizaveta Kirillova Rough Draft Page 194.00 $1.55 $300.70 Litigation Package (all Electronic Files) 1 1.00 $34.00 $34.00 Parking Expense Per hour 1.00 $22.00 $22.00 Shipping & Handling Package 1.00 $49.99 $49.99 Notes: Invoice Total: $1,209.54 Payment: ($1,209.54) Credit: $0.00 Interest: $0.00 Balance Due: $0.00 please consult http://www.veritext.com/services/all-services/services-information TERMS: Payable upon receipt. Accounts 30 days past due will bear a finance charge of 1.5% per month. Accounts unpaid after 90 days agreeto pay all collection costs,including reasonable attorney's fees. Contact us to correct payment errors. No adjustments will be made after 90 days. For more information on chargesrelated to our services To pay online, go to Please remit payment to: . Veritext www.veritext.com P.O. Box 71303 74428 Veritext accepts all major credit cards Chicago IL 60694-1303 (American Express, Mastercard, Visa, Discover) Invoice #: Job #: Invoice Date: Balance: CS3379001 2904046 6/14/2018 $0.00 Veritext Corporate Services, Inc. 290 West Mt. Pleasant Ave, Suite 2260 Livingston NJ 07039 Tel. 973-410-4098 Fax. 973-410-1313 Fed. Tax ID: 20-3457913 VERITEXT Taer SOLUTIONS Bill To: Invoice #: CS3382333 Fidelity National Law Group ; : 915 Wilshire Blvd. Invoice Date: 6/26/2018 Suite 2100 Balance Due: $0.00 Los Angeles, CA, 90017 Case: Kostanian v. Ticor, Et Al. Claim #: 520846 J : : i :ob # 2904046 | Job Date: 5/23/2018 | Delivery: Normal File No: L076045 Billing Atty: Location: FNLG/California (LA) 915 Wilshire Blvd | Suite 2100 Los Angeles, CA 90017-3450 Sched Atty: Robin Ratner | FNLG/California (LA) Witness Description Units Quantity Price Amount Video - Initial Fee 1 1.00 $250.00 $250.00 Video - Additional Hours Hour 4.00 $95.00 $380.00 Video - Media and Cloud Services Per disk 2.00 $22.00 $44.00 Elizaveta Kirillova - co ’ Video - Digitizing & Transcript Synchronization Hour 4.00 $110.00 $440.00 Parking Expense Per hour 1.00 $22.00 $22.00 Shipping & Handling - Video Media Package 1.00 $36.23 $36.23 Notes: Invoice Total: $1,172.23 Payment: ($1,172.23) Credit: $0.00 Interest: $0.00 Balance Due: $0.00 TERMS: Payable upon receipt. Accounts 30 days past due will bear a finance charge of 1.5% per month. Accounts unpaid after 90 days agree to pay all collection costs, including reasonable attorney's fees. Contact us to correct payment errors. No adjustments will be made after 90 days. For more information on chargesrelated to our services please consult http://www.veritext.com/services/all-services/services-information To pay online, go to www.veritext.com 74428 Veritext accepts all major credit cards (American Express, Mastercard, Visa, Discover) . Invoice #: Please remit payment to: Veritext Job #: P.O. Box 71303 Invoice Date: Chicago IL 60694-1303 Balance: CS3382333 2904046 6/26/2018 $0.00 EXHIBIT 2 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 80017 May 07, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #35983 Professional Services 4/30/2018 DRV Search for Elizaveta Krillova Search for Photo, Cell Phone Number, and Home Address 5/1/2018 DRV Search for Natalia Moushovich 5/3/2018 DRV Attempt Service on Ms. Kirillova Attempt Service on Ms. Moshovich 5/4/2018 DRV Prepare Proof of Service on Kirillova Search for Witness Attempt Service on Witness in Woodland Hills For professional services rendered Case Costs : 4/30/2018 DRV Database Search 5/1/2018 DRV Database Search DRV Utility Search Re: Elizaveta Kirillova 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal ID. 33-065-2508 Hrs/Rate 0.90 95.00/hr 1.30 95.00/hr 5.75 95.00/hr 4.40 95.00/hr 12.356 Qty/Price 1 $72.00 1 $78.00 1 $200.00 Amount 85.50 123.50 546.25 418.00 $1,173.25 72.00 78.00 200.00 Knowles & Vacca, Inc. Page 2 KOSTANIAN, CLAIM NO. 520846 Qty/Price Amount 5/2/2018 DRV Utility Search Re: Natalia Movshovich 1 200.00 $200.00 5/3/2018 DRV Mileage: 179 179 105.61 $0.59 5/4/2018 DRV Database Search 1 38.00 $38.00 DRV Mileage: 120 120 70.80 $0.59 Total Case Costs $764.41 Total Amount of This Invoice $1,937.66 Balance due $1,937.66 Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal ID. 33-065-2508 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 80017 June 11, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #36243 Professional Services Hrs/Rate Amount 57/2018 MB Service of Deposition Subpoena on Natalia Movshovich in Woodland Hills 3.60 342.00 95.00/hr For professional services rendered 3.60 $342.00 Case Costs : Qty/Price 5/7/2018 MB Mileage: 130 130 76.70 $0.59 Total Case Costs $76.70 Total Amount of This Invoice $418.70 Previous balance $1,937.66 Balance due $2,356.36 Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I 19011 - Federal ID. 33-065-2508 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 80017 August 20, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #36711 8/7/2018 8/13/2018 8/14/2018 8/16/2018 8/17/2018 8/19/2018 8/7/2018 Professional Services DRV ZRV ZRV ZRV ZRV ZRV Attempt Service on Natalia Moshovich Conference with Young Man at Residence Attempt Service of Deposition Subpoena on Natalia Movshovich at Home Attempt Service of Deposition Subpoena on Natalia Movshovich at Home Attempt Service of Deposition Subpoena on Natalia Movshovich at Home Attempt Service of Deposition Subpoena on Natalia Movshovich at Home Travel from Trabuco Canyon Attempt Service of Deposition Subpoena on Natalia Movshovich Via Stake Out on Home For professional services rendered Case Costs : DRV Mileage: 133 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal ID. 33-065-2508 Hrs/Rate 3.75 95.00/hr 3.50 95.00/hr 3.30 95.00/hr 3.50 95.00/hr 3.20 95.00/hr 7.80 95.00/hr 25.056 Qty/Price 133 $0.59 __Amount 356.25 332.50 313.50 332.50 304.00 741.00 $2,379.75 78.47 Knowles & Vacca, Inc. KOSTANIAN, CLAIM NO. 520846 8/13/2018 ZRV 8/14/2018 ZRV 8/16/2018 ZRV 8/17/2018 ZRV 8/19/2018 ZRV Mileage: 114 Mileage: 114 Mileage: 114 Mileage: 114 Mileage: 164 Total Case Costs Total Amount of This Invoice Previous balance Accounts receivable transactions 6/21/2018 Payment Received - Thank youl. E-Check No. 3800936 8/9/2018 Payment Received - Thank you!. E-Check No. 3934313 Total payments and adjustments Balance due Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal 1.D. 33-065-2508 Page 2 Qty/Price Amount 114 67.26 $0.59 114 67.26 $0.59 114 67.26 $0.59 114 67.26 $0.59 164 96.76 $0.59 $444.27 $2,824.02 $2,356.36 ($1,937.66) ($418.70) ($2,356.36) $2,824.02 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 90017 September 30, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #36950 Professional Services Hrs/Rate Amount 8/29/2018 ZRV Attempt Service of Deposition Subpoena on Natalia Movshovich Via 3.80 361.00 Stakeout on Home in Woodland Hills 95.00/hr 9/7/2018 ZRV Attempt Service of Deposition Subpoena on Natalia Movshovich at Home 1.80 171.00 in Woodland Hills 95.00/hr For professional services rendered 5.60 $532.00 Case Costs : Qty/Price 8/29/2018 ZRV Mileage: 122 122 71.98 $0.59 9/7/2018 ZRV Mileage: 62 62 36.58 $0.59 Total Case Costs $108.56 Total Amount of This Invoice $640.56 Previous balance $2,824.02 Balance due $3,464.58 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal I.D. 33-065-2508 Knowles & Vacca, Inc. KOSTANIAN, CLAIM NO. 520846 Page 2 Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal ID. 33-065-2508 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 80017 November 05, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #37184 Professional Services Hrs/Rate Amount 10/31/2018 ZRV Attempt Service of Trial Subpoena on Natalia Movshovich at Home in 4.40 418.00 Woodland Hills 95.00/hr For professional services rendered 4.40 $418.00 Case Costs : Qty/Price 10/31/2018 ZRV Mileage: 122 122 71.98 $0.59 Total Case Costs $71.98 Total Amount of This Invoice $489.98 Previous balance $3,464.58 Accounts receivable transactions 10/9/2018 Payment Received - Thank you!. E-Check No. 4036606 ($2,824.02) 10/16/2018 Payment Received - Thank you!. E-Check No. 4053631 ($640.56) Total payments and adjustments ($3,464.58) Balance due $489.98 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal I.D. 33-065-2508 Knowles & Vacca, Inc. Investigators. Invoice submitted to: Robin Ratner, Esq. Fidelity National Law Group 915 Wilshire Blvd., Suite 2100 Los Angeles, CA 90017 November 28, 2018 In Reference To: KOSTANIAN, CLAIM NO. 520846 Invoice #37293 Professional Services Hrs/Rate Amount 11/5/2018 DRV Prepare Due Diligence Declaration 1.00 95.00 95.00/hr For professional services rendered 1.00 $95.00 Previous balance $489.98 Balance due $584.98 Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal I.D. 33-065-2508 Knowles & Vacca, Inc. P 2 KOSTANIAN, CLAIM NO. 520846 age Thank you for your business! 525 Cabrillo Park Drive, Suite 250, Santa Ana, CA 92701 Telephone (714) 560-9400 / Fax (714) 560-9411 License Number P.I. 19011 - Federal ILD. 33-065-2508 EXHIBIT 3 74428 Veritext Corporate Services, Inc. 290 West Mt. Pleasant Ave, Suite 2260 Livingston NJ 07039 Tel. 973-410-4098 Fax. 973-410-1313 Fed. Tax ID: 20-3457913 VERITEXT -SOLUTIONS Bill To: Invoice #: CS3364425 Fidelity National Law Group i i915 Wilshire BIvd. Invoice Date: 6/13/2018 Suite 2100 Balance Due: $0.00 Los Angeles, CA, 90017 Case: Kostanian v. Ticor, Et Al. Claim #: 520846 Job #: 2904046 | Job Date: 5/23/2018 | Delivery: Normal File No: LO76045 Billing Atty: Location: FNLG/California (LA) 915 Wilshire Blvd | Suite 2100 Los Angeles, CA 90017-3450 Sched Atty: Robin Ratner | FNLG/California (LA) Witness d Description Units Quantity Price Amount Elizaveta Kirillova Interpreting 1 1.00 $555.10 $555.10 Notes: Invoice Total: $555.10 Payment: ($555.10) Credit: $0.00 Interest: $0.00 Balance Due: $0.00 TERMS: Payable upon receipt. Accounts 30 days past due will beara finance charge of 1.5% per month. Accounts unpaid after 90 days agreeto pay all collection costs,including reasonable attorney's fees. Contact us to correct paymenterrors. No adjustments will be made after 90 days. For more information on charges related to our servicesplease consult http://www.veritext.com/services/all-services/services-information To pay online, go to www.veritext.com Veritext accepts all major credit cards (American Express, Mastercard, Visa, Discover) Please remit payment to: Veritext P.O. Box 71303 Chicago IL 60694-1303 Invoice #: Job #: Invoice Date: Balance: CS3364425 2904046 6/13/2018 $0.00 Make a Reservation | Journal Technologies Court Portal Journal Technologies Court Portal Page 1 of 2 Make a Reservation MARINA KOSTANIAN VS JOHN ANTHONY ET AL Case Number: BC587999 Case Type: Civil Unlimited Category: Contractual Fraud Date Filed: 2015-07-15 Location: Stanley Mosk Courthouse - Department 49 Reservation Case Name: MARINA KOSTANIAN VS JOHN ANTHONY ET Case Number: AL Type: Motion to Tax Costs Party: Marina Kostanian (Plaintiff) Date/Time: 02/01/2019 8:31 AM Reservation ID: 851750321360 Fees Description Motion to Tax Costs Credit Card Percentage Fee (2.75%) TOTAL Payment Amount: $61.65 Account Number: XXXX4656 = Print Receipt == Reserve Another Hearin BC587999 Status: RESERVED Location: Stanley Mosk Courthouse - Department 49 Number of Motions: 1 Confirmation Code: CR-3JTL7SH6FYJZEGVGU Fee Qty 60.00 1 1.65 1 Type: Visa Authorization: 155755 https://portal-lasc.journaltech.com/public-portal/?q=calendar/reserve Amount 60.00 1.65 $61.65 12/30/2018 Make a Reservation | Journal Technologies Court Portal Page 2 of 2 Copyright © Journal Technologies, USA. All rights reserved. https://portal-lasc.journaltech.com/public-portal/?q=calendar/reserve 12/30/2018