Reply_memorandum_in_support_of_motion_to_tax_costs

Reply

Cal. Super. - 2nd Dist.July 29, 2015

Electronically FILED by L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Buperior Court of California, County of Los Angeles on 03/01/2019 09:59 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk ASHTON R. WATKINS SBN: 235310 LAW OFFICES OF ASHTON R. WATKINS Figueroa Tower Building 660 S. Figueroa Street, Suite 1960 Los Angeles, California 90017 Telephone: (310) 855-3904 Facsimile: (310) 943-3896 ashton@watkinslawgroup.com Attorney for Defendant and Cross-Complainant Sharon Ransom SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES-STANLEY MOSK COURTHOUSE DARRYL LUCIEN Case No.: BC 589 554 Plaintiff, REPLY MEMORANDUM IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS Court Reservation ID: 268 776 487 042 SHARON RANSOM, an individual; and DOES 1 (hrough 100, nelusive, HEARING and all persons unknown claiming | oc yon 8 2019 any interest in the property named as Time: 8:30 a.m. DOES 51 through 100, inclusive, pept.: 47 Defendants. Before the Honorable Randolph Hammock Filed 7.29.15 ALL RELATED CROSS-ACTIONS Defendant and Cross-Complainant Sharon Ransom (“Defendant or “Ms. Ransom”) submit the following Reply Memorandum in support of the Motion to Tax Costs as follows: REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES L PRELIMINARY STATEMENT Ms. Ransom filed a motion to strike and/or tax (“Motion”) Plaintiff and Cross-Defendant’s memorandum of costs. Plaintiff filed an opposition to the Motion. However, the opposition fails to establish that Plaintiff is entitled to all costs requested in this case. Plaintiff did not carry his burden to show that the contested costs were reasonable and necessary. The law provides that only certain costs are allowed. Many of the costs claimed in this action are not expressly allowed under the statute whereas others are expressly disallowed. For example, Plaintiff did not provide any cancelled checks for the amount requested even though such records are readily available online from most banks. Similarly, Plaintiff did not provide any meaningful analysis on why the offer to settle (“998 offer”) was more favorable to Ms. Ransom than the money judgment in this case, particularly where the 998 offer required Ms. Ransom to dismiss her cross-complaint, give Plaintiff half of the current equity, and pay Plaintiff’s unspecified attorney’s fees and noneconomic damages. Accordingly, Ms. Ransom urges this Court to strike and/or tax the contested charges. II. COSTS ARE ALLOWED ONLY IF NECESSARY AND REASONABLE. The right to recover costs is purely statutory and, in the absence of an authorizing statute, no costs can be recovered by the party. Davis v. KGO T.V., Inc. (1998) 17 Cal.4th 436, 439; California Code of Civil Procedure § 1032. Code of Civil Procedure section 1033.5 lists the categories of costs that are recoverable. Code Civ. Proc. § 1033.5(a)(1)-(13) (listing “allowable costs.). Moreover, the same statute explicitly provides that “allowable” costs are only recoverable if they are “reasonably necessary to the conduct of the litigation rather than merely convenient or beneficial to its preparation,” and are “reasonable in amount.” Code Civ. Proc. § 1033.5(¢c)(2)-(3). 1 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The court has power to disallow even costs “allowable as a matter of right” if they were not “reasonably necessary” or to reduce the amount of any cost item to that which is “reasonable.” California Practice Guide: Civil Trials and Evidence (Rutter Group 2015) (“Practice Guide”) at 17:112.1, citing Perko’s Enterprises, Inc. v. RRNS Enterprises (1992) 4 Cal. App.4th 238, 245 (“intent and effect of Section 1033.5 subdivision (c¢)(d) is to authorize as trial court to disallow recovery of costs, including filing fees, when it determines the costs were incurred unnecessary”). As discussed in the moving papers, the contested charges were not “reasonably necessary to the conduct of the litigation” or “reasonable in amount.” For example, Plaintiff’s anti-SLAPP motion filed against the cross-complaint was not reasonably necessary to the conduct of the litigation where, as here, it was filed too late (the court denied it because it was not timely filed) and this court later determined that Ms. Ransom’s cross- complaint had merit (“As to the Cross-Complaint, this Court finds that Ransom has met her burden of proof as to some of her claims, to wit, certain monies owed to her by [Lucien] as either personal loans, or breaches of the oral contract to equally share in the living and household expenses.”). Similarly, Plaintiff filed several motions to compel and yet the court never ordered Ms. Ransom to provide responses, further responses, or appear for a second session of her deposition. In other words, these motions were pointless. III. THE COURT SHOULD TAX ALL CONTESTED COSTS If an item of cost is expressly allowed by statute and appears to be a proper charge, the verified memorandum of costs is prima facie evidence that the item is necessarily incurred. The burden of proving otherwise is on the objecting party to show it is unnecessary or unreasonable. Whatley-Miller v. Cooper (2013) 212 Cal. App. 4th 1103, 1113. However, if the item of cost does not on its face appear proper, the burden of showing that it is reasonable and necessary shifts to the party claiming the cost. Ladas v. California State Auto Assn. (1993) 19 Cal. App.4th 761, 774-776 (Once items are properly objected to and put in issue by 2 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the moving party, the burden is on the party claiming them as costs). Thus, in awarding an item of costs, the court must first determine whether the statute expressly allows the particular item and whether it appears proper on its face. Whatley-Miller v. Cooper (2013) 212 Cal. App. 4th 1103, 1113. Plaintiff’s costs here are not expressly allowed by statute and do not appear to be proper charges. Ms. Ransom’s Motion also objects to these items and put them in issue. As a result, Plaintiff has the burden of showing that the costs are reasonably necessary. Plaintiff did not meet that burden. a. The Claimed Motion and Filing Fees Are Not Allowed By Law. Ms. Ransom challenged the filing and motion fees on the grounds that (1) Plaintiff’s motions [motions to compel; Anti-SLAPP motion; ex parte applications] were unsuccessful; (2) Plaintiff’s ex parte application to set aside a court order allowing one of his attorneys to withdraw from the case had nothing to do with Ms. Ransom. Plaintiff did not address any of these grounds in his opposition. First, he did not explain why the motion and ex parte application fees were reasonably necessary, particularly where he was unsuccessful in each of the motions and ex parte applications. The court denied the anti-SLAPP motion as untimely, took the motion to compel discovery off- calendar, and Plaintiff withdrew his motion to compel a second session of deposition. See Exhibit A. Second, he did not explain why Ms. Ransom should be responsible for the ex parte application fee to set aside a court order allowing one of his attorneys (Oak Tree Law) to withdraw from the case. Ms. Ransom had nothing to do with Plaintiff’s relationship with his attorneys and she was not involved in his attorney’s motion to withdraw. In fact, Plaintiff failed to give notice of his ex parte application to challenge the order allowing Oak Tree Law to withdraw. 3 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Accordingly, the court should use its power to disallow these costs that were not reasonably necessary to this litigation. b. The Jury Fees Are Disallowed. Ms. Ransom challenged the jury fees on the ground that Plaintiff waived jury. First, Plaintiff failed to pay the nonrefundable jury fee on or before the date scheduled for the initial case management conference in the action. Code of Civil Procedure §631 (c)(“The fee...shall be due on or before the date scheduled for the initial case management conference in the action...”). The initial case management conference took place on November 2, 2015 and Plaintiff did not pay the fee at that point. See Exhibit B. Second, Plaintiff waived the jury prior to trial and Plaintiff concedes as much in his opposition (“Plaintiff Darryl Lucien ultimately decided to waive jury trial...at the Final Status Conference.”). Accordingly, the fees should be disallowed. c. The Deposition Costs Should be Reduced Ms. Ransom challenged the deposition costs on the grounds that (1) Plaintiff overstated the cost of the deposition; (2) the videotaping was not necessary; and (3) Plaintiff failed to present cancelled checks for these items. Plaintiff did not adequately address these objections. First, Plaintiff admitted that he overstated the cost of the deposition. Plaintiff asked for $2,287.32, whereas the court reporter charged Plaintiff $2,006.40. The other charges relate to Plaintiff’s refusal to pay his bills on time, which is exactly why Ms. Ransom was unwilling to put Plaintiff’s name on title to the property. See Court’s 11/21/18 Decision (Ms. Ransom would have be 4 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 willing “to refinance the property at a ‘future date’ when and if Lucien’s credit rating improved.”). Plaintiff is financially irresponsible and he could not be trusted to pay his share of the expenses. Second, the video recording of the deposition was never used at any time in the litigation or trial. Plaintiff failed to use the video deposition even though the court requested that Plaintiff present it in connection with its motion to compel a second session of Ms. Ransom’s deposition. Third, Plaintiff failed to submit proof of payment for any of these charges. He did not submit copies of any cancelled checks for any of these items. Accordingly, Ms. Ransom urges this court to reduce the deposition costs from $3,311.07 to $1,040.00. d. The Service of Process Costs Should Be Disallowed. Ms. Ransom challenged the service of process costs on the grounds that (1) Plaintiff did not incur service of process costs by a public officer or registered process server; and (2) plaintiff did not call any of the witnesses purportedly served with legal process to trial. Plaintiff’s opposition does not prove that he is entitled to these costs. First, Plaintiff submitted no evidence that the messenger, Attorney Related Services, Inc., is a registered process server. This messenger certainly is not a public officer and, as noted in the moving papers, the cost of messengers is not expressly allowed. Second, Plaintiff failed to explain why he incurred $40.00 to hire the Los Angeles County Sheriff on or about May 4, 2016 when Ms. Ransom appeared in case in March 2016. e. The Expert Witness Fees Are Not Allowed By Law. Ms. Ransom challenged the expert witness fees on the grounds that (1) the expert witness was not ordered by the court; (2) fees from expert witnesses not ordered by the court are specifically disallowed. 5 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff did not dispute these grounds. He concedes that the expert witness was not ordered by the court and fees from expert witnesses not ordered by the court are specifically disallowed. Plaintiff instead argues that the expert witness fees are allowed because “Plaintiff Darryl Lucien beat his 998 offer by obtaining a monetary judgment of $118,700 plus recoverable costs against Defendant Sharon Ransom.” This argument is not supported by the facts. Plaintiff did not beat his “998 offer” in this case for a number of reasons. First, contrary to Plaintiff’s argument, the “998 offer” contemplates that the court would enter a judgment against Ms. Ransom and in favor of Plaintiff. It provides, in part, that “Plaintiff offers to have a judgment entered pursuant to California Code of Civil Procedure §998 in his favor by Defendant...” Second, the “998 offer” offers substantially more favorable terms to Plaintiff than does the current judgment including, but limited to the following, terms: A. The “998 offer” requires Ms. Ransom to execute a quitclaim deed to Plaintiff, whereas the judgment declares Ms. Ransom as the sole legal title holder of the subject property located at 18314 Citronia Street, Northridge, California 91325; B. The “998 offer” requires Ms. Ransom to sale the property, whereas the judgment makes no such order; C. The “998 offer” requires Ms. Ransom to split the equity from the property equally between Plaintiff and Ms. Ransom, whereas the judgment makes no such order. This difference alone destroys Plaintiff’s argument that he ‘beat his 998 offer.” Plaintiff presented evidence at trial that the house increased in value from $750,000.00 in 2015 to $870,000.00 in 2018 and he argued that he was entitled to $261,090.03 in damages based on the equity in house. See Plaintiff’s Closing Argument (3:18-24; 4:25-26) filed on October 16, 2018. If Ms. Ransom had accepted the 998 offer and sold the house in 2018, then 6 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff would have received $261,090.03 in equity instead of the $118,700.00 plus costs under the judgment. D. The “998 offer” requires Ms. Ransom to pay Plaintiff's non-economic damages, whereas the judgment makes no such order; E. The “998 offer” requires Ms. Ransom to pay Plaintiffs attorney fees, whereas the judgment makes no such order; F. The “998 offer” requires Ms. Ransom to dismiss her cross-complaint, whereas the judgment gives Ms. Ransom $15,000 in damages on her cross-complaint; G. The “998 offer” requires Ms. Ransom to pay Plaintiff’s attorney’s fees for filing the anti- SLAPP motion, whereas the judgment gives not such order and the court previously denied the anti-SLAPP motion in its entirety. Third, Plaintiff failed to submit copies of the invoice or cancelled checks from the expert. He simply provided the front of the checks, making it unclear whether Plaintiff actually paid the expert as opposed to simply creating two checks to support this request. For these reasons, Ms. Ransom urges this court to strike and/or tax the costs relating to the expert witness fees. f. The Court Reporter Fees Are Not Allowed By Law. Ms. Ransom challenged the costs of the court reporters on the ground that Plaintiff did not show that the fees charged were set by statute. Plaintiff did not address this objection in the opposition. For that reason, the court reporter fees should be taxed and reduced to zero. 7 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IV. PLAINTIFF DID NOT ADDRESS LAST OBJECTION. Plaintiff did not address Ms. Ransom’s final argument- that is, that the court should exercise its discretion to deny his costs in their entirety. She argued that they should be denied because most of Plaintift’s claims and causes of action “pled or sought by Lucien in the operative First Amended Complaint are denied or rejected by this Court, as they either are barred by the applicable statute of limitations (see, e.g., Ransom’s Initial Closing Argument, pp. 6-9), or more importantly, even if not barred by the statute of limitations, Lucien failed to meet his burden of proof as to all required elements for each of these causes of action.” V. CONCLUSION For the reasons set forth above, Defendant and Cross-Complainant Sharon Ransom respectfully requests that this Court tax and reduce the specific items in the memorandum of costs. Alternatively, Defendant and Cross-Complainant Sharon Ransom requests that the court exercise its discretion to deny Plaintiff and Cross-Defendant Darryl Lucien’s costs in its entirety. DATED: March 1, 2019 Respectfully submitted, LAW OFFICES OF ASHTON WATKINS By: Ashton Watkins Attorney for Sharon Ransom 8 REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Ashton Watkins, declare as follows: 1. make this declaration in support of Sharon Ransom’s motion to tax costs. I have personal knowledge of the facts set forth in this declaration and I would testify to the same in court, as necessary. 2 3. DECLARATION OF ASHTON WATKINS I am an attorney of record for Defendant and Cross-Complainant Sharon Ransom. I I reviewed Plaintiff’s opposition to the motion to tax. It is not persuasive. Plaintiff did not explain why the motion and ex parte application fees were reasonably necessary, particularly where he was unsuccessful in each of the motions and ex parte applications. The court denied the anti-SLAPP motion as untimely, took the motion to compel discovery off-calendar, and Plaintiff withdrew his motion to compel a second session of deposition. Attached hereto as Exhibit A are true and correct copies of the court’s rulings on the anti- SLAPP motion, motion to compel responses to further discovery, and motion to compel the second session of Ms. Ransom’s deposition. Plaintiff did not explain why Ms. Ransom should be responsible for the ex parte application fee to set aside a court order allowing one of his attorneys (Oak Tree Law) to withdraw from the case. Ms. Ransom had nothing to do with Plaintiffs relationship with his attorneys and she was not involved in his attorney’s motion to withdraw. In fact, Plaintiff failed to give me notice of his ex parte application to challenge the order allowing Oak Tree Law to withdraw. Plaintiff failed to pay the nonrefundable jury fee on or before the date scheduled for the initial case management conference in the action, in violation of Code of Civil Procedure §631 (c). The initial case management conference took place on November 2, 2015 and Plaintiff did not pay the fee at that point. -9- REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10. 11. 12. 13. 14 Attached hereto as Exhibit B is a true and correct copy of the relevant portions of the case docket. Plaintiff waived the jury prior to trial and Plaintiff concedes as much in his opposition (“Plaintiff Darryl Lucien ultimately decided to waive jury trial...at the Final Status Conference.”). Plaintiff admitted that he overstated the cost of the deposition. Plaintiff asked for $2,287.32, whereas the court reporter charged Plaintiff $2,006.40. The other charges relate to Plaintiffs refusal to pay his bills on time, which is exactly why Ms. Ransom was unwilling to put Plaintiff’s name on title to the property. See Court’s 11/21/18 Decision (Ms. Ransom would have be willing “to refinance the property at a ‘future date’ when and if Lucien’s credit rating improved.”). Plaintiff is financially irresponsible and he could not be trusted to pay his share of the expenses. The video recording of the deposition was never used at any time in the litigation or trial. Plaintiff failed to use the video deposition even though the court requested that Plaintiff present it in connection with its motion to compel a second session of Ms. Ransom’s deposition. Plaintiff failed to submit proof of payment for any of these charges. He did not submit copies of any cancelled checks for any of these items. Plaintiff submitted no evidence that the messenger, Attorney Related Services, Inc., is a registered process server. This messenger certainly is not a public officer and, as noted in the moving papers, the cost of messengers is not expressly allowed. Plaintiff failed to explain why he incurred $40.00 to hire the Los Angeles County Sheriff on or about May 4, 2016 when Ms. Ransom appeared in case in March 2016. . Plaintiff did not beat his “998 offer” in this case for a number of reasons. -10- REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15. 16. Contrary to Plaintiff’s argument, the “998 offer” contemplates that the court would enter a judgment against Ms. Ransom and in favor of Plaintiff. It provides, in part, that “Plaintiff offers to have a judgment entered pursuant to California Code of Civil Procedure §998 in his favor by Defendant...” The “998 offer” offers substantially more favorable terms to Plaintiff than does the current judgment including, but limited to the following, terms: A. The “998 offer” requires Ms. Ransom to execute a quitclaim deed to Plaintiff, whereas the judgment declares Ms. Ransom as the sole legal title holder of the subject property located at 18314 Citronia Street, Northridge, California 91325; B. The “998 offer” requires Ms. Ransom to sale the property, whereas the judgment makes no such order; C. The “998 offer” requires Ms. Ransom to split the equity from the property equally between Plaintiff and Ms. Ransom, whereas the judgment makes no such order. This difference alone destroys Plaintiff’s argument that he ‘beat his 998 offer.” Plaintiff presented evidence at trial that the house increased in value from $750,000.00 in 2015 to $870,000.00 in 2018 and he argued that he was entitled to $261,090.03 in damages based on the equity in house. See Plaintiff’s Closing Argument (3:18-24; 4:25-26) filed on October 16, 2018. If Ms. Ransom had accepted the 998 offer and sold the house in 2018, then Plaintiff would have received $261,090.03 in equity instead of the $118,700.00 plus costs under the judgment. D. The “998 offer” requires Ms. Ransom to pay Plaintiff’s non-economic damages, whereas the judgment makes no such order; E. The “998 offer” requires Ms. Ransom to pay Plaintiffs attorney fees, whereas the judgment makes no such order; -11- REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS L A W O F F I C E S O F A S H T O N R. W A T K I N S P O B O X 24 16 1 L O S A N G E L E S , C A L I F O R N I A 90 02 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 F. The “998 offer” requires Ms. Ransom to dismiss her cross-complaint, whereas the judgment gives Ms. Ransom $15,000 in damages on her cross-complaint; G. The “998 offer” requires Ms. Ransom to pay Plaintiffs attorney’s fees for filing the anti- SLAPP motion, whereas the judgment gives not such order and the court previously denied the anti-SLAPP motion in its entirety. 17. Plaintiff failed to submit copies of the invoice or cancelled checks from the expert. He simply provided the front of the checks, making it unclear whether Plaintiff actually paid the expert as opposed to simply creating two checks to support this request. 18. Ms. Ransom, through this motion, urges this court to strike and/or tax Plaintiff’s requested costs as set forth in the moving papers. I declare under penalty of perjury that the forgoing is true and correct. Executed in Los Angeles, California on March 1, 2019. X Ashton Watkins -12- REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS Exhibit A REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS -13- aN [==] - - oN o n 3 7 3 oa Az L d i s s s RTE ET ARR PRR The matter is called for a hearing. Ss department. Opposition is to be filed and served no later than April 2, 2018. Parties stipulate to service by email of all documents related to this motion. A courtesy copy of all documents to be submitted directly in this department. ‘ On the Court's own motion, the Final Status Conference scheduled for April 4, 2018, and the Jury Trial scheduled for April 10, 2018, are advanced and vacated. A Trial Setting Conference is set for April 10, 2018, at 8:30 a.m. in this department. ‘ MINUTES ENTERED Page 1 of 2 DEPT. 47 02/28/18 COUNTY CLERK SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES pate: 04/10/18 DEPT. 47 HONORABLE Randolph M. Hammock JUDGE F. Rojas DEPUTY CLERK hg ABLE JUDGE PRO TEM ELECTRONIC RECORDING MONITOR ; G. Hironaka, C.A. Deputy Sheriff] None Reporter 8:30 am|BC589554 Plaintiff Counsel Todd Fuson(X) DARRYL LUCIEN VS Ashton Watkins (X) SHARON RAMSOM Defendant Counsel NATURE OF PROCEEDINGS: S ; (EX PARTE APPLICATION FILED 2/28/18) TRIAL SETTING CONFERENCE; The case is called for a hearing. SEnBHE TEESE eons Poet she mosien co A Trial Setting Conference is conducted. Final Status Conference is set for July 13, 2018, at 8:30 a.m. in this department. Jury Trial is set for July 23, 2018, at 9:30 a.m. in this department. ’ A Mandatory Settlement Conference is set for June 29, 2018, at 8:30 a.m. in this department. Notice is waived. 10 oe feo my MINUTES ENTERED = ‘ Page 1 of 1 DEPT. 47 04/10/18 f= COUNTY CLERK "3 Exhibit B REPLY MEMO IN SUPPORT OF DEFENDANT’S MOTION TO TAX COSTS -14- aN [==] - - oN o n