Motion_for_attorney_fees

Motion

Cal. Super. - 2nd Dist.June 8, 2017

Electronically FILED by Superior Court of California, County of Los Angeles on 06/22/2020 12:00 AM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk SH W N N e N N O N Wn LAW OFFICES OF JOSEPH R. BROWN State Bar No. 143594 13808 VENTURA BLVD. SHERMAN OAKS, CALIFORNIA 91423 (818) 907-0880 Attorney for Plaintiffs/Cross-Defendants, SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES KIVORK DAKARMENIJIAN AND ELIZABETTE DAKARMENIJIAN, INDIVIDUALLY AND AS TRUSTEES OF THE KIVORK DAKARMENIJIAN AND ELIZABETTE DAKARMENIJIAN LIVING TRUST DATED SEPTEMBER 8, 2006, Plaintiffs, Vv. SARA RENYER DAKARMEN, AN INDIVIDUAL; SARA RENYER DAKARMEN AS PERSONAL REPRESENTATIVE OF THE ESTATE OF TROUD STROUD DAKARMENIJIAN; CLAUDIA MOLINA, AN INDIVIDUAL; AVEDIS (SHAWN) DAKARMENIIAN, AN INDIVIDUAL; COLLATERALIZED INVESTMENTS ACQUISITIONS, LLC; ALL PERSONS UNKNOWN CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN OR INTEREST IN THE PROPERTIES DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF'S TITLE OR ANY CLOUD ON PLAINTIFF'S TITLE THERETO NAMED AS DOES 1 - 10, INCLUSIVE; and DOES 11 - 20, INCLUSIVE. Defendants. RELATED CROSS-COMPLAINT Na tt ’ N t ” “ a t ” “ u t ” “v an t “ t t tt ’ “ t t “ e t t “ a p t “ v a t “ a p t ! “ ge t “ w t ! “ e t t “s et ? “ s t “ s a t “ t t “ t t “ w a t “ o u s t “ e t t “ w a s t “e ws t “ e t t “ s t “ a p t “ p t t “ w t “s wt ! “ s w t “ w t “ w t ! “w as t CASE NO. BC664277 NOTICE OF MOTION AND MOTION FOR ATTORNEY'S FEES AND COSTS IN THE AMOUNT OF $165,132.45 AGAINST SARA RENYER DAKARMEN AS PERSONAL REPRESENTATIVE OF THE ESTATE OF TROUD STROUD DAKARMENIJIAN PURSUANT TO CODE OF CIVIL PROCEDURE §1032 AND WELFARE & INSTITUTIONS CODE §15657.5; POINTS & AUTHORITIES AND DECLARATIONS OF JOSEPH R. BROWN AND ANI KEMKEMIAN IN SUPPORT THEREOF. [Before the Hon. Elizabeth R. Feffer] Hearing Date: TBD Time: TBD. Dept. 39 RESERVATION ID: TBD MOTION FOR ATTORNEY'S FEES TO THE COURT. ALL PARTIES AND THEIR ATTORNEYS OF RECORD, PLEASE TAKE NOTICE: ON A DATE AND TIME TO BE ASSIGNED, IN DEPARTMENT 39 OF THE ABOVE CAPTIONED COURT located at 111 North Hill Street, Los Angeles, CA 90012, Plaintiffs ANI KEMKEMIAN and SEVAN WEIR, as successor co-trustees of the Kivork Dakarmenjian and Elizabette Dakarmenjian Living Trust dated September 8. 2006 and as successor co-trustees of the Kivork Dakarmenjian Family Trust Dated January 12. 2018 (“real parties in interest”) will, and hereby do. move the Court for an award of attorneys fees in the amount of $152,672.50, plus costs in the amount of $12.459.95 (pursuant to cost bill filed May 6, 2020) against DEFENDANT SARA RENYER DAKARMEN, IN HER CAPACITY AS PERSONAL REPRESENTATIVE OF THE ESTATE OF TROUD STROUD DAKARMENIJIAN. The grounds for the Motion are that Plaintiffs are the prevailing parties in this action. They are therefore entitled to recover their attorneys fees and costs pursuant to Code of Civil Procedure §1032 and Welfare and Institutions Code §15657.5(a). The motion is based on this notice. the attached Memorandum. the Declarations of Joseph R. Brown and Sevan Weir, all pleadings. records. files. proceedings in this action, the oral argument of counsel and such other matters as may be presented to the Court at the time of the hearing. Date: June 19, 2020 LAW OFFICE OF JOSEPH R. BROWN BY 7 R. Brown. Attorney for Plaintiffs MOTION FOR ATTORNEY'S FEES 1 Sa wo to NO 0 N N Wn I INTRODUCTION The Court is familiar with the facts of this case. This was, at bottom, a family dispute. All of the current and former parties, living and deceased, are known to each other. Troud Dakarmenjian ("Troud') was the youngest of Kivork Dakarmenjian’s (“Kivork”) and Elizabette Dakarmenjian’s (“Elizabette”) four children. On or about May 18, 2017, Troud and his wife, Sara, were arrested during a police raid at their home located at 15635 Vandorf Place in Encino, CA. The reason for the police raid was that Troud and Sara were in possession of a large number of illegal weapons, including military assault rifles, tracer ammunition for automatic weapons, silencers, etc. While Troud was in police custody following his arrest, he attempted suicide. Troud died of his injuries on May 25, 2017. Shortly after Troud's death, Kivork and Elizabette discovered that two of their properties had been transferred into Troud's name through a series of forged deeds ("the Forged Deeds"). Kivork and Elizabette also discovered that a deed of trust had been recorded against one of their other commercial properties in an amount which was far in excess of what was actually borrowed against that property ("Forged Deed of Trust"). The Forged Deed of Trust was in favor of former defendant Collateralized Investments Acquisitions, LLC ("CIA"). Atthe time the Forged Deed of Trust was recorded, CIA was controlled by Troud. When Kivork and Elizabette discovered what Troud had done, this lawsuit resulted. The original complaint in this matter was filed on June 8, 2017. During the pendency of this litigation, both Kivork and Elizabette died. By stipulation of the parties, Ani Kemkemian (“Ani”) and Sevan Weir (“Sevan”), in their capacities as successor co-trustees of the Kivork Dakarmenjian and Elizabette Dakarmenjian Living Trust dated September 8, 2006 (“2006 Trust”) and as successor co-trustees of the Kivork Dakarmenjian Family Trust Dated January 12, 2018 (“2018 Trust”) became the real parties in interest in this Action. 1" MOTION FOR ATTORNEY'S FEES 2 o o ~ aN wn Ee w No Oo The matter went to trial on November 7, 2019, after nearly two and a half years of extremely contentious litigation. The issues which were litigated at trial were: (1) Plaintiffs’ First and Second Causes of Action for cancellation of forged deeds and quiet title to real property; (2) Plaintiffs’ Fourth and Sixth Causes of Action for damages resulting from fraud and elder abuse; and a Cross-Complaint filed by Defendant Sara Dakarmen for Breach of Contract (claiming damages for rescission and restitution). A bench trial was held over six (6) non-consecutive days. On April 22, 2020, this Court issued a fourteen (14) page statement of decision and entered Judgment in favor of Plaintiffs and against Defendant Sara Renyer Dakarmen, individually and in her Capacity as Personal Representative for the Estate of Troud Stroud Dakarmenjian on all adjudicated causes of action in the Second Amended Complaint and the Cross-Complaint. Relevant to this Motion was the Court’s ruling in favor of Plaintiffs and against Sara Renyer Dakarmen, individually and in her Capacity as Personal Representative for the Estate of Troud Stroud Dakarmenjian on Plaintiffs’ Fourth Cause of Action for Fraud and Plaintiffs’ Sixth Cause of Action for Elder Abuse. As the Judgment applies to this Motion, the Court’s specific findings On Plaintiffs’ Sixth Cause of Action for Elder Abuse were as follows: “The Court finds in favor of Plaintiffs and against Defendant Sara Renyer Dakarmen, in her Capacity as Personal Representative for the Estate of Troud Stroud Dakarmenjian. Both Kivork and Elizabette were “elders” as defined by Welf. & Inst. C. §15610.27. The Court finds that Troud fraudulently appropriated and obtained the Glenoaks Property and the Salt Lake Property from Kivork and Elizabette through forgery and for a wrongful purpose within the meaning of Welf. & Inst. C. §15610.30(a)(1) & (2). The Court further finds that Kivork and Elizabette were harmed as a result of said forgery and that Troud’s wrongful conduct was a substantial factor in causing this harm. However, the Court declines to award monetary damages in addition to the equitable remedies already provided by this judgment.” MOTION FOR ATTORNEY'S FEES 3 O 0 0 N N N n n be W N — oS 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 28 I1 POINTS & AUTHORITIES A. Where, as Here, the Court Has Made a Specific Finding of Elder Abuse, an Award of Attorneys’ Fees and Costs to Plaintiffs is Mandatory Regardless of Whether the Plaintiff Was Awarded Monetary Damages. Welfare and Institutions Code Section 15657.5(a) provides in pertinent part: “Where it is proven by a preponderance of the evidence that a defendant is liable for financial abuse, as defined in Section 15610.30, in addition to compensatory damages and all other remedies otherwise provided by law, the court shall award to the plaintiffreasonable attorney’s fees and costs.” (emphasis added) Under the plain language of the statute, an award of attorney fees is mandatory regardless of whether the plaintiff is awarded any other form of relief. This absolute rule making attorney’s fees mandatory in elder abuse cases, without regard to whether the Court otherwise awards monetary damages, was recently confirmed in the case of Arace v. Medico Investments, LLC, (2020) Cal.App.5th (filed March 24, 2020, Certified for Publication May 11, 2020, Fourth District, Div. Two, Appellate Case No. E071194). B. Plaintiffs’ Request for $152,672.50 in Attorney’s Fees is Reasonable. The total amount of attorney’s fees for litigating this matter for two and a half years and taking it through a six day bench trial - including written closing briefs, was $152,672.50. This amount reflects the substantial work necessary for Plaintiffs to file and prosecute their claims in this action and to defend against Defendant/Cross Plaintiff’s cross- complaint, which this Court ultimately found to be both factually and legally “frivolous”. Judgment at Page 4, Lines 20-21. When this action was initially filed in June of 2017, Plaintiffs were represented by the Jeffrey Alpert/The Alpert Law Group. Attorney Joseph R. Brown was substituted into the case in November of 2017. An accounting of the time which Mr. Brown devoted to this case is attached as Exhibit A. Mr. Alpert’s time sheets are attached as Exhibit B. The amended MOTION FOR ATTORNEY'S FEES 4 to 0 N N N nh ae WwW cost-bill, which was filed with the Court on May 6, 2020, is attached as Exhibit C. The total in attorney’s fees and costs is $165,132.45. All of the requested fees and costs were incurred in connection with Plaintiffs’ prosecution/defense of this action and were necessary, justified and reasonable. In addition, and as more fully discussed below, the hourly rates for all attorney work billed by Plaintiffs’ counsel on these matters is at or below the average market rate for attorneys with similar skill and experience. Statutory attorney fees are ordinarily determined by the court pursuant to the “lodestar” method. Under the lodestar, a “reasonable” hourly rate is the prevailing rate charged by an attorney of similar skill and experience in the relevant community. See, PLCM Group, Inc. v. Drexler (2000) 22 Cal.4th 1084, 1095. However, the trial court may adjust the lodestar amount based on various factors specific to the case in order to fix the attorney fees at fair market value for the services provided. Id. at 1095-1096. The factors include: “(1) the novelty and difficulty of the questions involved, (2) the skill displayed in presenting them, (3) the extent to which the nature of the litigation precluded other employment by the attorneys, (4) the contingent nature of the fee award.” Ketchum v. Moses, (2001) 24 Cal.4th 1122, 1132. In considering the lodestar factors, a trial court must “focus on providing an award of attorney fees reasonably designed to fully compensate [the prevailing party's] attorneys for the services provided.” Horsford v. Board of Trustees, (2005) 132 Cal.App.4th 359, 395. With respect to the novelty and difficulty of the questions involved, the central issues in this case required an in-depth knowledge of real property law, probate & trust law, contract law, and the legal issues surrounding elder abuse. In addition to the normal and general costs of bringing a case to trial, this Court instructed counsel to prepare written closing briefs, which necessitated the review of six days of trial transcripts, followed by the painstaking task of carefully targeting more than seventy (70) trial exhibits to the testimony of eleven (11) witnesses. That evidence was presented to the Court in the written closing briefs, and closing rebuttal. MOTION FOR ATTORNEY’S FEES 5 wn + W o to ~N ON Mr. Brown is a solo practitioner. Trial preparation, trial, and the drafting of closing arguments substantially precluded him other employment during the trial and the drafting of post-trial closing arguments. Mr. Brown was not retained on a contingency basis. Plaintiffs’ attorney, Joseph R. Brown, carefully reviewed all relevant client bills, invoices and billing entries as part of his due-diligence in researching and preparing this Motion. The total billable time expended on this case by Mr. Brown is approximately 480.25 hours. A line-item accounting of Mr. Brown's fees, and the costs which he advanced on behalf of Plaintiffs is attached as Exhibit A. The hourly rate billed by Mr. Brown was $300.00 per hour, billed in quarter-hour increments. This hourly rate is well-below market for rates attorneys with similar skills and experience. Mr. Brown has over 30 years of litigation and appellate experience in the practice of real property law, contract law, and probate & trust law. Mr. Brown's normal hourly rate is $350/hr., which is still below rates typically charged by attorneys of similar skill and experience in Los Angeles. However, due to the equities involved in this matter, Mr. Brown agreed to litigate the case at the reduced rate of $300/hr. See, Svers Properties Ill, Inc. v. Rankin, (2014) 226 Cal.App.4th 691, 702 (trial court's rate calculation was supported by the record, including counsel's more than 20 years experience in litigation of this kind; trial judge considered services rendered as “sophisticated” legal work and stated the hourly rate requested was “not even close to the highest hourly rate that | have seen in this area”). At the reduced rate of $300 per hour, Plaintiffs are entitled to be reimbursed for Mr. Brown’s services in the amount of $144,075.00 (480.25 hrs. x $300/hr.). Considering the amount of time which was necessarily devoted to this matter and the success of Mr. Brown's efforts, Plaintiffs’ request for attorney fees in the amount of $144,075.00 as reimbursement for Mr. Brown’s fees is justified and reasonable. In addition to the fees incurred by Mr. Brown, Plaintiffs incurred attorneys fees for services rendered by attorney, Jeffrey Alpert of the Alpert Law Group. Mr. Alpert represented Plaintiffs between June of 2017 and November of 2017. Mr. Alpert initiated this MOTION FOR ATTORNEY'S FEES 6 ro I wn ~ N O S action for Plaintiffs in June of 2017. Mr. Alpert also represented Plaintiffs in several related matters involving Troud’s estate and guardianship issues pertaining to Troud’s children. A full set of billing statements from Mr. Alpert’s firm is attached as Exhibit B. However. Plaintiffs’ request for fees charged by the Alpert Law Group are restricted to those fees which were incurred in this litigation. The five (5) page spreadsheet at the beginning of Exhibit B represents the break-down of fees which were strictly attributable to this litigation. The total reimbursement request for fees incurred by the Alpert Law Group for this litigation is $8,597.50. C. Plaintiffs are Entitled to Reimbursement for their Costs in the Amount of $12,459.95 Pursuant to Welfare and Institutions Code Section 15657.5(a). As with recovery of attorneys fees in Elder Abuse Cases. the recovery of costs is mandatory. See, Welfare and Institutions Code Section 15657.5(a). Plaintiffs’ Amended Memorandum of Costs. which was filed with the Court on May 6. 2020, is attached hereto as Exhibit C. In addition to the recovery of attorney's fees, Plaintiffs also seek an order awarding them the sum of $12,459.95 as reimbursement for their allowable costs which they expended in as a result of Defendants” elder abuse. VI CONCLUSION For all the foregoing reasons, Plaintiffs respectfully requests that they be awarded attorney fees and costs for the prosecution/defense of this action in the sum of $165,132.45. RESPECTFULLY SUBMITTED, Joseph R. Brown, Attorney for Plaintiffs Dated: June 19, 2020 By: MOTION FOR ATTORNEY'S FEES 7 No wv WwW o e NN DECLARATION OF JOSEPH R. BROWN IN SUPPORT OF MOTION FOR ATTORNEY'S FEES I, Joseph R. Brown, declare as follows: 1. I am an attorney licensed to practice before all courts in the State of California and attorney of record for Plaintiffs ANI KEMKEMIAN and SEVAN WEIR, in their capacities as successor co-trustees of the Kivork Dakarmenjian and Elizabette Dakarmenjian Living Trust dated September 8, 2006 and as successor co-trustees of the Kivork Dakarmenjian Family Trust Dated January 12, 2018 (“real parties in interest”). If called as a witness, | could and would testify to the following facts from personal knowledge, except for those matters stated on information and belief and as to those matters, I believe them to be true. 2. The total amount of attorney's fees generated by my office in this action is $144,075.00. This amount reflects the substantial work necessary to recover the property which Defendant wrongfully took from Plaintiffs as a result of elder abuse. A line-item accounting of my fees amounting to 480.25 hours of attorney time, is attached as Exhibit A. A cost-bill, detailing Plaintiffs’ allowable costs other than attorney's fees, totaling $12,459.95 is attached as Exhibit C. 3. All of the requested fees and costs were incurred in connection with Plaintiffs recovery of the properties which Defendant wrongfully took from Plaintiffs as a result of elder abuse and/or in bringing this Motion and were justified and reasonable under the circumstances. 4. At the conclusion of a six-day bench trial, this Court instructed counsel to prepare written closing briefs and to draft responses to opposing counsel’s briefs. This necessitated the review of six days of trial transcripts and the careful targeting of more than seventy (70) trial exhibits to the testimony of eleven (11) witnesses. I am a solo practitioner. Trial preparation, trial, and the drafting of closing arguments substantially precluded other employment during the trial and during the time it took to draft post-trial closing arguments. I was not retained on a contingency basis. MOTION FOR ATTORNEY'S FEES 8 ro wn 6 16 19 += 5. I have carefully reviewed all relevant client bills, invoices and billing entries as part of my due-diligence in researching and preparing this Motion. The total time I have expended on this case is approximately 480.25 hours of billable time. A line-item accounting of my fees and the costs advanced on behalf of Plaintiffs is attached as Exhibit A. 6. As the Court will note. billable time does not include the many hours I spend meeting with the client. either in-person or by telephone. In order to encourage an open- channel of communication with my clients, it is my policy not to charge for time spent meeting with them in-person, or discussing their case with them over the telephone. Although many hours were spent communicating with my clients in this matter. including multiple visits to see Kivork and Elizabette Dakarmenjian at their home, the clients were not charged for that service and that time is not included in this fee request. 7 I have over 30 years of trial and appellate experience in the practice of real property law, probate & trust law, and contract law. My normal hourly rate is $350/hr., which is below rates typically charged by attorneys of similar skill and experience in Los Angeles. However, due to the equities involved in this matter, | agreed to litigate the case at the reduced rate of $300/hr., billed in quarter-hour increments. 8. Based upon the reduced rate of $300/hr., Plaintiffs are entitled to be reimbursed for my services in the amount of $144,075.00 (480.25 hrs. x $300/hr.). Considering the amount of time which was necessarily devoted to this matter and the success of my efforts, I believe that these fees are justified and reasonable. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 19" day of June 2020 at Los Angeles, California. Jgsepht R. Brown MOTION FOR ATTORNEY'S FEES 9 OO 0 0 N O N L h a W N N o N O N ND P m t p h pe ed pu m p m mm pe T R E E R E B R I V R E R B T C 3 a d = 8 0 = 3 NN oo DECLARATION OF ANI KEMKEMIAN IN SUPPORT OF MOTION FOR ATTORNEY'S FEES I, Ani Kemkemian, declare as follows: 1. I am over the age of eighteen and a party to this action. If called as a witness, I could and would testify to the following facts from personal knowledge, except for those matters stated on information and belief and as to those matters, I believe them to be true. 2. On or about June of 2017, I retained Jeffrey Alpert and the Alpert Law Group to represent my parents, Kivork and Elizabette Dakarmenjian, with respect to, among other matters, a fraud/forgery which we later discovered was perpetrated by my late-brother, Troud Dakarmenjian. 3. My parents and I also retained Mr. Alpert to represent our family with respect to claims involving Troud’s probate estate and with respect to matters involving the guardianship of Troud’s children. 4, In approximately October of 2017, my parents became dissatisfied with Mr. Alpert’s representation. In November of 2017, we retained attorney Joseph Brown and terminated Mr. Alpert’s representation. 5. Attached hereto as Exhibit B are Mr. Alpert’s billing records for the months of June through October of 2017, which Mr. Alpert sent to me and my parents at the time the services were rendered. The first five pages of Exhibit B contain a spreadsheet which I created from Mr. Alperts original billing statements. The spreadsheet identifies those charges which are specific to the elder abuse claims for which this Court has rendered judgment in our favor in this litigation, and for which we request reimbursement under the Elder Abuse Statutes. Based upon my calculations, the total fees charged by Mr. Alpert which are attributable to our elder abuse claims is $8,597.50. 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 19 day of June 2020 at Los Angeles, California, Aims EXHIBIT A LAW OFFICE OF JOSEPH R. Bill To: Invoice Date: Through 6-13-2020 Dakarmenjian v. Dakarmen et al Date Description Attorney Time Hourly Rate CHARGES 11/9/2017 | Interview Sean JRB 1 hr. $300.00 11/9/2037 | Draft Sean Declaration JRb 2 hrs. $300.00 0.00 11/10/2017 | Prepare Substitutions for Filing JRB 1hr. $300.00 $300.00 11/11/2017 | Legal Research re: Conversion & Elder Abuse JR8 S hrs. $300.00 r i eisai 11/13/2017 | Revise Declaration and prepare Exhibits IRB .S hrs. $300.00 : $150.00 11/16/2016 | Draft/File/Serve Supplemental CMS IRB 1hr. $300.00 Wl sioioo 11/20/2017 | Hearing on Probate JRL 75 hrs. $300.00 OC sasseD 12/11/2017 |Meet w/clients at their home .5 hrs. Not Charged i : ; Hn i 12/12/2017 (Begin Second Amended Complaint 1.5 hrs. $300.00 a { 12/12/2017 | Draft Answer to Cross-Complaint 5 hrs. $300.00 12/14/2017 | Research and Draft Second Amended Complaint JRB 6 hrs. $300 12/15/2017 | Complete First Draft of Amended Complaint JRB 4 hrs. $300 12/16/2017 | Review new facts and update Amended Complain JRB 2 hrs. $300 12/17/2017 | Begin Draft of Motion to Amend JRB 2.5 hrs. $300 12/24/2017 | Finalize Motion to Amend Complaint JRB 1hr. $300 1/5/2018 cc IRB 1hr, $300 1/9/2018 Prepare Notices and Acknowledgments JR8 .S hrs. $300 2/1/2018 Answer Written Discovery JRB 5.25 hrs. $300 2/8/2018 Gather and Review Document Production JRB 1hr. $300 2/10/2018 |} email re elder abuse IRB ihr. $300 3/2/2018 Meet & Confer w/Ghareman JRB Shrs. $300 3/12/2018 | Hearing - CMC IRB .5 hrs. $300 3/13/2018 | Notice of Status Conf IRB Shrs. $300 3/13/2018 | Resolve Default issues JRB 1h. $300 3/19/2018 | File Amendment to Complaint {name correction) Not Charged 3/19/2018 | Courier - Name correction Not Charged 3/24/2018 | Draft Opp to Demurrer IRB 6 hrs. $300 3/25/2018 | Drafft Opp to Motion to Strike IRB 4 hrs. $300 3/26/2018 | Creditor's Claim - Probate (Including e-Filing) IRB 75 hrs $300 3/26/2018 | Subpoena to Sheriff JRB Shrs $300 3/27/2018 | Edit and Complete Opp to Dem & Mot to Strike JRB 2 hrs. Not Charged 4/10/2018 | Request far Entry of Default - CIA IRB Shrs. $300 4/11/2018 | Attend Hearing on Status Conf & Motions JRB 1.5 hrs. $300 4/24/2018 | Draft General Denial & Affirmative Defenses CIA JRB 5 hrs $300 5/12/2018 | Sean Letter JRB 1.5 hrs. $300 6/13/2018 | Attend Hearing & confer w/Sevan & Chris JRB 2.25 hrs. $300 6/15/2018 | Notice of Hearing JRB .5 hrs. $300 6/22/2018 | Elizabette Deposition IRB 6 hrs $300 7/23/2018 | Review deeds JRB 1hr. $300 7/31/2018 | Prepare Affidavits and Deeds IRB 2 hrs. $300 10/11/2018 | Supoena to LAPD JRB .Shrs. $300 11/2/2018 | Discussion w/Kurt Kuhn & email to Ani/Sevan JRB .S hrs. $300 11/8/2018 | Review Deeds, organize/Scan/write checks JRB .5 hrs. $300 11/15/2018 | Review Forensic Docs and Oraft Settlement Prop JRB 4 hrs. $300 11/16/2018 | Edit and Revise Settlement Proposal IRB 2 hrs. $300 11/16/2018 | Demand Letter to Defendant's Counsel IRB 2.5 hrs, $300 1/8/2019 Assessor Letter JRB 1.5 hrs. $300 1/9/2019 | Second demand to Defendants & fax to assessor IRB .75 hrs. $300 2/11/2019 | Draft Settlement Agreement w/CIA IRB 3 hrs. $300 3/19/2019 | Misc. re John Kerr JRB 2 hrs. $300 4/3/2019 Final Revisions to Settlement with CIA IRB Shrs. $300 4/12/2019 | Deposition Notice (and Doc Demand) - Dakarmin JRB 2.5 hrs. $300 4/29/2019 | Depo Prep JR 4.5 hrs. $300 5/1/2019 Prepare Section 377.32 Declaration JRB 1hr. $300 5/8/2019 593e form Not Charged 5/8/2019 | Post Mediation Status Conf IRB 1hr. $300 5/9/2019 Revise/add doc demands to Depo Ntc¢ JRB .5 hrs. $300 5/9/2019 Prepare and File Ntc of Hearing {crt order) JRB 1hr. $300 5/22/2019 | Mediation Brief JRB 3.5 hrs. $300 5/30/2019 | Mediation RB 4 hrs. $300 $/31/2019 | Sara Dakarmen Deposition JRB 4 hrs. $300 6/1/2019 Research - Statute of Frauds IRB 75 hrs. $300 6/2/2019 Trial Prep. - Organization & Legal Research IRB 3.5 hrs. $300 6/5/2019 Research re Motion in Limine{rejected) JRB 1.5 hrs. $300 6/8/2019 Draft Trial Brief JRB 8 hrs. $300 6/9/2019 General Trial Prep - Review Exhibits - prep Ex. Lst JRB 4.5 hrs. $300 6/12/2019 | Prepare & File Amended 377.32 Declaration JRB 5 hrs. Not Charged 6/12/2018 | Prepare & Serve McNamee Deposition IRB 5 hrs. $300 6/13/2019 | Jaint Witness List/Exhibit List {drafts) JRB 3.5 hrs. $300 6/14/2019 | Complete Witness list/research/trial brief JRB 9 hrs. $300 6/15/2019 | Misc re: Settlement & Beneficiary letter JRB 2.5 hrs. $300 6/15/2019 | Trial Brief JRB 3 hrs. $300 6/16/2019 | Trial Brief JRB 3 hrs. $300 6/12/2019 | Prepare for Jackie Depo - questions & Exhibits JRB 6 hrs. $300 6/18/2019 | Jackie McNamee Deposition JRB 3.5 hrs. $300 6/18/2019 | Trial Prep. - Exhibit List & Legal Research JRB 3hrs. $300 6/20/2019 | Trial Brief (7 a.m -12 p.m.) JRB S hrs. $300 6/20/2019 | Exhibits for Trial w/Sevan (3 p.m. -7 p.m.) JRB 4 hrs. $300 6/22/2019 | Edit Trial Brief JRB 3 hrs. $300 6/23/2019 | Edit Trial Brief JrR8 4 hrs. $300 6/24/2019 | Edit Trial Brief JR8 2 hrs. Not Charged 6/25/2019 | Notice of Continued Depo of Jackie McNamee IRB Shrs. Not Charged 6/28/2019 | Attend Final Status Conf. - trial cont 11/8/2019 IRB 1.5 hrs. $300 7/3/2019 Mail Beneficiary Letter JRB Shrs. Not Charged 7/3/2019 Send Amended Notice of Jackie Depo JRB .25 hrs. Not Charged 10/8/2019 | Prepare Default Request for Shawn Not Charged 10/14/2019 | Trial Prep - Review Molina Transcript JRB 1.75 hrs. $300 10/22/2019 | Draft Subpoenas/On-Call Agreements JRB 1.75 hrs. $300 10/29/2019 | Organize Exhibits, etc w/Sevan JRB 3 hrs. $300 10/30/2019 | Meet w/Sean IRB .75 hrs. $300 10/30/2019 | Discussion w/Kurt Kuhn (witness prep) Not Charged 11/1/2019 | Prepare Kurt Khun testimony JRB 3.5 Hrs. $300 11/2/2019 | Prepare Shean Testimony IRB Shrs. $300 11/3/2019 | Review - Notate Molina Transcript JRB 1.5 hrs. $300 11/4/2019 | General Trial Prep - Shawn - Motion IRB 9 hrs. $300 $2,700 11/5/2019 | Credit Back - Motion for Judgment on the Pleadings ahs. e100) 11/6/2019 | Trial JRB 3.5 Hrs. $300 81 11/6/2019 | Trial Prep - research re: standing issue JRB 2S hrs. $300 11/2/2019 | Trial Prep - Standing Research JRB 2 hrs. $300 11/7/2019 | Trial IRB 4.5 hrs. $300 11/8/2019 | Trial Prep - Ex Parte JR8 6 hrs. $300 11/9/2019 |{ Telal Prep JRB 8 hrs. $300 11/10/2019 | Trial Prep {a.m.) JR8 4.5 hrs. $300 11/10/2019 | Trial Prep {p.m.} JRB Shrs. $300 11/11/2019 | Trial Prep JRB 10 hrs. $300 11/12/2019 | Trial {Travel and wait time not charged) IRB 3 hrs. $300 11/12/2019 | Trial Prep IRB 2 hrs. $300 11/13/2019 | Trial Prep a.m. JRB 3 hrs. $300 11/13/2019 | Trial {Travel and wait time not charged) JRB 3.5 hrs. $300 11/13/2019 | Trial Prep p.m. JRB 4 hrs. $300 11/142019 | Trial Prep a.m. JRB 2 hrs. $300 11/14/2019 | Trial Prep p.m. JRB 45 hrs. $300 11/15/2019 | Trial Prep - refince Peter Boyadjian Quest. JR8 2.5 hrs. $300 11/15/2019 | Triall {a.m.} JRB 2 hrs. $300 11/15/2018 | Trial {p.m.) JRB 2.5 hrs. $300 12/3/2019 | Review Sara Deposition Transcript JRB 1.5 hrs. Not Charged 1/4/2020 Teial Prep IRB 2 hrs. $300 1/5/2020 | Trial Prep JRB S hrs. $300 1/7/2020 | Trial JRB 4.5 hrs. $300 1/13/2020 | Closing Brief IRB 2 hrs. $300 1/16/2020 | Closing Brief IRB 3 hrs. $300 1/20/2020 | Closing Brief JRB 6 hrs. $300 1/21/2020 | Closing Brief IRB 3 hrs. $300 1/22/2020 | Closing Brief JRB 6 hrs. $300 1/23/2020 | Closing Brief JRB 6 hrs. $300 1/24/2020 | Closing Brief IRB 8 hrs. $300 1/25/2020 | Closing Brief JRB 3 hrs. $300 1/26/2020 | Closing Brief JRB 6 hrs. $300 1/27/2020 | Closing Brief IRB 2 hrs. Not Charged 1/28/2020 | Review Legal Research IRB 1hr. Not Charged 2/2/2020 Closing Brief IRB Shrs. $300 2/3/2020 Closing Brief IRB 8 hrs. $300 2/4/2020 Closing Brief JRB 11 hrs. $300 2/5/2020 Closing Brief JRB 14 hrs $300 2/6/2020 Closing Brief {6-11) JRB S hrs. $300 2/6/2020 Closing Brief {5-12} IRB 7 hrs. $300 2/7/2020 Closing Brief IRB Shrs. $300 2/12/2020 | Draft Reply Brief JRB 2.5 hrs. $300 2/13/2020 | Notice of Correction to Trial Brief JRB 1.5 hrs. Not Charged 2/14/2019 | Draft Reply Brief JRB 6.5 hrs. $300 2/15/2019 | Draft Reply Brief JRB 8 hrs. $300 2/16/2020 | Draft Reply Brief JRB 10 hrs. $300 2/17/2020 | Draft Reply Brief JRB 8 hrs. $300 2/19/2020 | Oraft Reply Brief JRB 6 hrs. $300 2/20/2020 | Draft Reply Brief JRB 6.5 hrs. $300 2/21/2020 | Draft Reply Brief JRB 9 hrs. $300 2/22/2020 | Draft Reply Brief JRB 1.5 hrs. $300 2/22/2020 | Oraft Proposed Statement of Decision IRB 1hr. $300 2/23/2020 | Draft Proposed Statement of Decision JRB 1.5 hrs. $300 2/24/2020 | Draft Proposed Statement of Decision JRB 4 hrs. $300 $1,200 2/25/2020 | Statement of Decision & Reply Closing Brief IRB 8 hrs. $300 i 2/26/2020 | Statement of Decision & Reply Closing Brief IRB 6 hrs. $300 2/27/2026 | Finalize Statement of Decision & Reply Cl. Brief IRB 10 hrs. $300 4/6/2020 Review Statemnt of Dec/Draft Proposed Judgmer JRB 4 hrs. $300 4/15/2020 | Prepare & File Memorandum of Costs JRB 1.5 hrs. $300 5/6/2020 Prepare 30 Day Notice to Quit JRB .75 hrs. $300 6/6/2020 Prepare and File Amended Memorandum of Costs Not Charged 6/14/2020 | Draft Motion for Attorney's Fees JRB 4.5 hrs, $300 6/19/2020 | Complete Motion for Attorney's Fees JRB 3 hrs. $300 Make all checks payable to LAW OFFICE OF JOSEPH R. BROWN. U.S. Tax I.D. No. 95-4354789 EXHIBIT B STATEMENT Date Other Dean Jeff Matter Description of Services Hours Amount Hourly Filing Fees Total Total 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD T7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 7-1-17 DvsD 06/07/2017 06/08/2017 06/08/2017 06/08/2017 06/14/2017 06/19/2017 06/20/2017 06/21/2017 06/22/2017 06/22/2017 06/22/2017 Filing Fees/ ALG ALG ALG DA JA JA JA JA JA JA JA Troud ct Troud et Dakarmenjian, Kivork and Prepare draft of verified complaint for Elizabette v. Dakarmenjian, filing Troud et Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et Filing fee for Verified Complaint: $435.00 Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et Research title documents for legal * descriptions Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Prepare draft complaint Troud et Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et Exchange emails with S. Dakarian re: Notary status and strategy Dakarmenjian, Kivork and Receive, read and analyze email from Elizabette v. Dakarmenjian, S. Dakarian re: status and strategy Troud et Dakarmenjian, Kivork and Receive. read and analyze email from Elizabette v. Dakarmenjian, S. Dakarian re: Sara photo and car information Dakarmenjian, Kivork and Service of Documents for Sara Elizabette v. Dakarmenjian, Dakarian travel to 18901 Salt Lake Place Northridge, CA 91326 Dakarmenjian, Klyork an d ‘Conference with Client re: status and Elizabette v. Dakarmenjian, Troud et Strategy Dakarmenjian, Kivork and Prepare for filing Proof of Service of Elizabette v. Dakarmenjian, Summons for C. Molina and Sara Troud ct Dakarian Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et Finalize complaint and draft/finalize notice of lis pendens $2.60 $650.00 $0.20 $100.00 $1.20 $600.00 $0.10 $50.00 $0.10 $50.00 $0.10 $0.00 $0.80 $400.00 $0.40 $0.00 $0.20 $2.40 $1,200.00 $435.00 $200.00 $435.00 $3,250.00 17-8-1 DvsD 17-8-1 DvsD 06/30/2017 07/06/2017 JA JA Troud ct al. Dakarmenjian, Kivork and Receive, read, and analyze Notice of Elizabette v. Dakarmenjian, OSC Hearing and Notice of Case Management Conference. Dakarmenjian, Kivork and Phone conference with Client re: status Elizabette v. Dakarmenjian, and strategy Troud et al. $0.20 $0.60 $100.00: $300.00 3400.00] $400.00 17-9-1 DvsD 17-9-1 DvsD 17-9-]1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 07/252017 08/04/2017 08/04/2017 08/05/2017 08/05/2017 08/07/2017 08/07/2017 08/07/2017 08/07/2017 08/07/2017 JA JA JA JA JA JA JA JA JA JA Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud ct al. Phone conference with Opposing * Counsel re: notary book Dakarmenjian, Kivork and Elizabette v. Dakarmenjian,: Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Exchange emails with H. Price re: meet and confer Receive, read, and analyze email from * Client re: status Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Exchange emails with client Troud et al. Dakarmenjian, Kivork and . . Exchange cmails with Client re: status Elizabette v. Dakarmenjian, ge ei’ wit of C. Molina's Counsel Troud et al. Dakarmenjian, Kivork and . 5 xchange emails with Client re: Elizabette v. Dakarmenjian, Exchange ema wi h Client re: status of C. Molina's Notary book. Dakarmenjian, Kivork and Receive, read, and analyze Verified Elizabette v. Dakarmenjian, Answer of Complaint from OPC. B. Troud et al. Agopoglu Dakarmenjian, Kivork and Receive. read, and analyze email from Elizabettc v. Dakarmenjian, Opposing Counsel C. Gharhreman re: Troud ct al. Extension of time for reply. . . Receive, read and analyze email from Dakarmenjian, Kivork and ay Elizabette v. Dakarmenjian, . extension of time to file Answer to Troud ct al. Complaint Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Receive, read and analyze email from B. Agopoglu re: Verified Answer C. Ghahreman re: status of C. Molina's $0.20 $0.20 $0.10 $0.20 $0.20 $0.20 $0.20 $0.20 $0.20 $0.20 $100.00 $100.00 $50.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 17-9-1 DvsD 08/08/2017 17-9-1 DvsD 08/09/2017 17-9-1 DvsD 08/09/2017 17-9-1 DvsD 08/09/2017 17-9-1 DvsD 08/09/2017 17-9-1 DvsD 08/09/2017 17-9-1 DvsD 08/10/2017 17-9-1 DvsD 08/10/2017 17-9-1 DvsD 08/10/2017 | 17-9-1 DvsD 08/10/2017 17-9-1 DvsD 08/10/2017 17-9-1 DvsD 08/11/2017 | VG VG DA DA DA DA JA JA JA JA JA JA Pakarmexjian, Kino an , : Prepare and send email to H. Price re: Elizabette v. Dakarmenjian,; meet and confer Troud et al. | Troud et al. Troud et al. Troud et al. Troud ct al. Troud et al. ‘ Dakarmenjian, Kivork and . Elizabette v. Dakarmenjian, ‘Troud ct al. : Dakarmenjian, Kivork and i Elizabette v. Dakarmenjian ‘Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, ‘and strategy Dakarmenjian, Kivork and | Receive, read, and analyze Verified Elizabette v. Dakarmenjian, Answer of Complaint from OPC. B. - Ago sent through the U.S Mail Dakarmerjian, Kivorlound | Phone conference with C. Elizabette v. Dakarmenjian, Dikarmenjian re; strategy Troud ct al. ’ Dakarmenjian, Kivork and Prepare and send email to C. Elizabette v. Dakarmenjian, Ghahreman re: status of C. Molina's Answer to Complaint Dakarmenjian, Kivork and Elizabetie v. Dakarmenjian Troud ct al. ‘Prepare and send eemail to Client A. * Kemkemian re: C. Molina's Answer to Complaint Dakarmenjian, Kivork and : .. Receive, read, and analyze email from Elizabetie v. Dakarmenjian y * Client re: signatures Dakarmenjian, Kivork and Phone conference with Sevan re: Sara Elizabette v. Dakarmenjian, response by Howard Price and Sevan issue with Troud/Sevan car issue. Automatic Extension _and strategy ‘Receive, read, and analyze emails from > Client re: client documents Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Exchange emails with Sevan and Ani re calendar updates. Phone conference with Sevan re: status . Phone conference with Client re: status $0.20 $0.20 $0.20 $0.20 $0.20 $0.10 $0.20 $0.20 'Dakarmenjian, Kivork and Receive, read, and analyze Declaration : Elizabette v. Dakarmenjian, of Demurring Party in Support of .Troud et al. $0.20 $0.20 $0.20 $0.20 $100.00 $50.00 $100.00 | $50.00 $100.00 $7.50 $50.00 $50.00 . $100.00 $100.00 $100.00 $15.00 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 17-9-1 DvsD 08/11/2017 08/11/2017 08/11/2017 08/11/2017 08/11/2017 08/14/2017 08/15/2017 AL JA JA JA JA JA JA Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Reccive, read and analyze email from * H. Price re: second meet and confer Receive, read and analyze email from * H. Price re: discovery request Receive, read, and analyze email from * Client re: status and strategy Daily Journal Corporation Probate ' Petition publication fee: $210.00 Receive, read, and analyze email from Client re:conversation with E + Receive, read, and analyze email from S. Dakarian re: Forensic Specialist that will review the hand writing on the property documents. Receive, read, and analyze email . Forensic Specialist M. Songer re: status and strategy $0.20 $0.20 $0.20 $0.20 $0.20 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $210.00 3210.00 $2,372.50] $2.582.50 17-10-1 DvsD 17-10-1 DvsD 17-10-11 DvsD 17-10-1 DvsD 17-10-1 DvsD 08/28/2017 08/30/2017 08/30/2017 08/30/2017 08/31/2017 VG DA DA JA JA Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian Troud et al. Receive, read and analyze email from Substitution of Attorney from Howard Price to John Kerr Phone conference with Client re: status and strategy Phone conference with Client re: status and strategy * Prepare draft of notice of taking Depo * of C. Molina Service Notice of Deposition to C. * Molina $0.20 $0.60 $0.60 $1.20 $0.20 $100.00 $300.00 $150.00 $300.00 $15.00 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 17-10-1 DvsD 08/31/2017 08/31/2017 09/01/2017 09/01/2017 09/02/2017 09/08/2017 09/11/2017 09/12/2017 09/20/2017 09/20/2017 VG DA DA DA DAnc DAnc DAnc JA JAn JAn Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabeute v. Dakarmenjian, Troud ct al. Dakarmenjian, Kivork and Elizabettc v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud ct al. Phone Conference with client re: Deeds Receive, read and analyze email from client re: status on recorded documents signatures Conference with Client re: status and strategy, file review for deeds. email same to client Receive, read and analyze emails from clients re: licenses and deed of trust Exchange email with client re: filed complaint Prepare draft of the Opposition 10 Demurrer Exchange email with Client re: trial status and strategy Prepare and send email to Bere Agopogluc, Chris Gharcramen re: Deposition of C. Molina Receive. read and analyze email from S. Dakarian re: Ani receiving Molina investigation notice form the State Receive, read and analyze email from S. Dakarian re: link to bonding company's website $0.20 $0.20 $0.60 $0.20 $0.20 $1.40 $0.20 $0.20 $0.10 $0.10 $50.00 $100.00 $150.00 $0.00 $0.00 $700.00 $0.00 $15.00 $0.00 $0.00 $1880.00 17-10-1 DvsD 09/13/2017 DA Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud Dakarmenjain Exchange emails with L. Lebowsky re: continuing matter $0.20 $50.00 $50.00 ALPERT LAW GROUP A Professional Corporation 16133 VENTURA BOULEVARD, SUITE 1180 ENCINO CALIFORNIA 91436 TELEPHONE (818) 285-5370 E-MAIL jeff@alpertlawgroup.com Federal Tax ID No. 47-3236654 Submitted to: Ani Kemkemian 18901 Salt Lake PI. Northridge, CA 91326 Date: 07/01/2017 Due Upon Receipt Regarding: Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et Total Balance Now Due: -$4,165.00 Date Atty Description of Services Hours Amount 6/7/2017 DA Prepare draft of verified complaint for filing 26 $650.00 6/8/2017 ~~ ALG Filing fee for Verified Complaint: $435.00 $435.00 6/8/2017 JA Research title documents for legal descriptions 2 $100.00 6/8/2017 JA Prepare draft complaint 1.2 $600.00 6/14/2017 JA Exchange emails with S. Dakarian re: Notary status and strategy A $50.00 6/19/2017 JA Receive, read and analyze email from S. Dakarian re: status and i $50.00 strategy 6/20/2017 ALG Receive, read and analyze email from S. Dakarian re: Sara photo and B $0.00 car information 6/21/2017 JA Service of Documents for Sara Dakarian travel to 18901 Salt Lake 8 $400.00 Place Northridge, CA 91326 6/22/2017 JA Conference with Client re: status and strategy 4 $200.00 6/22/2017 ALG Prepare for filing Proof of Service of Summons for C. Molina and Sara 2 $0.00 Dakarian 6/22/2017 JA Finalize complaint and draft/finalize notice of lis pendens 24 $1,200.00 Attomeys/Hourly Billing Rate: Billing For This Invoice Period $3,685.00 JA - Jeffrey Alpert $500 Previous Balance -$7,850.00 - Dean Ash 250 o . Ashley Wesacric $ Credit Amount Paid (Thank You) ALG- No Charge Total Balance Now Due -$4,165.00 ALPERT LAW GROUP A Professional Corporation 16133 VENTURA BOULEVARD, SUITE 1180 ENCINO CALIFORNIA 91436 TELEPHONE (818) 285-5370 E-MAIL jeff@alpertlawgroup.com Federal Tax ID No. 47-3236654 Submitted to: Ani Kemkemian 18901 Salt Lake PI. Northridge, CA 91326 Regarding: Dakarmenjian, Kivork and Elizabette - Estate Date: 07/01/2017 Due Upon Receipt Total Balance Now Due: -$7,850.00 Date 6/5/2017 6/6/2017 6/6/2017 6/6/2017 6/6/2017 6/7/2017 6/7/2017 6/7/2017 6/7/2017 6/7/2017 6/8/2017 6/9/2017 6/9/2017 6/9/2017 6/10/2017 6/13/2017 6/13/2017 6/14/2017 6/15/2017 Atty Description of Services JA DA JA JA JA JA JA JA JA JA JA JA JA JA JA JA JA JA JA Exchange emails with S. Dakarmenjian re: status and strategy Prepare draft of trust restatement. Dakarmenjian. Receive, read and analyze emails from S. Dakarmenjian re: status Exchange emails with S. Dakarmenjian re: status and strategy Conference with Client re: status and strategy Receive, read and analyze emails from A. Kemkemian re: Limited Durable Power of Attorney (Dakarmenjian) Exchange multiple emails with S. Dakarian re: status and strategy Receive, read and analyze emails from S. Dakarian re: status Exchange emails with A. Kemkemian re: limited durable power of attorney Exchange multiple emails with S. Dakarian re: limited durable power of attorney Exchange emails with S. Dakarian re: status and strategy Receive, read and analyze email from A. Kemkemian re: notarized and recorded documents Prepare and send email to A. Kemkemian re: restated living trust Receive, read and analyze email from A. Kemkemian re: limited durable power of attorney Phone conference with Client re: status and strategy Phone conference with Client re: status and strategy Exchange emails with A. Kemkemian re: Limited Durable Power of Attorney Phone conference with S. Dakarian re: status and strategy Exchange emails with S. Dakarian re: status and strategy Hours 2 2.8 Amount $100.00 $700.00 $100.00 $50.00 $400.00 $50.00 $100.00 $50.00 $50.00 $200.00 $100.00 $50.00 $50.00 $50.00 $100.00 $100.00 $100.00 $100.00 $100.00 6/20/2017 6/21/2017 6/21/2017 6/22/2017 6/22/2017 6/23/2017 6/23/2017 6/23/2017 6/24/2017 JA - DA - AM - ALG- Atty Description of Services Hours Amount DA Exchange multiple emails with S. Dakarian re: status and strategy 2 $50.00 DA Phone conference with S. Dakarian re: status and strategy 2 $50.00 DA Receive, read and analyze email from S. Dakarian re: status and 2 $50.00 strategy JA Phone conference with S. Dakarian re: status and strategy 2 $100.00 JA Receive, read and analyze emails from S. Dakarian re: status and Ad $50.00 strategy DA Exchange emails with Clients S. Dakarian and A. Kemkemian re: 2 $50.00 status and strategy (independent fiduciary) JA Phone conference with S. Dakarian re: status and strategy 2 $100.00 JA Receive, read and analyze email from S. Dakarian re: status and 1 $50.00 strategy JA Receive, read and analyze emails from efileCA re: status of filing on 2 $100.00 initial documents Atte Hourly Billing Rate: Billing For This Invoice Period $3,150.00 Jeffrey Alpert $500 Previous Balance ~~ -$11,000.00 Dean Ash $250 ; ; Ashley Montgomery Credit Amount Paid (Thank You) No Charge Total Balance Now Due -$7,850.00 ALPERT LAW GROUP A Professional Corporation 16133 VENTURA BOULEVARD, SUITE 1180 ENCINO CALIFORNIA 91436 TELEPHONE (818) 285-5370 E-MAIL jeff@alpertlawgroup.com Federal Tax ID No. 47-3236654 Submitted to: Ani Kemkemian 18901 Salt Lake PI. Northridge, CA 91326 Date: 08/02/2017 Due Upon Receipt Please note that starting September 1, 2017 we will be billing for "paralegal/assistant” time - All time entries are by Veronica Garcia and noted as "VG" Regarding: Multiple Matters Total Balance Now Due $5,929.40 Date 6/29/17 6/30/17 7/4/17 7/5117 7/6/17 7/6/17 7117 T1117 M2117 7/12/17 JA JA JA JA DA JA DA DA DA DA Atty Matter Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Dakarmenjian, Kivork and Elizabette - Dependency Description of Services Phone conference with Client re: status and strategy; review report received from dependency court Prepare and send email to Mr. Iseri re: children guardianship Receive, read and analyze email from Client re: status and strategy Receive, read and analyze email from Client re: status Receive, read and analyze email exchange between A. Kemkemian and J. Alpert re: conference call and status Receive, read and analyze email from Client S. Dakarian re: status Prepare draft of guardianship papers, email to client Prepare, file guardianship paperwork with the court. Meet with Ani regarding same process. Filing fees: $976.45 Prepare to file and serve notice of hearing date and review filed documents re guardianship from the court Further draft of amended petition for guardianship Page 1 6 32 38 1.2 5.6 Hours Amount $300.00 $200.00 $100.00 $50.00 $25.00 $50.00 $800.00 $1,926.45 $300.00 $0.00 Date Atty Matter Descriptionof Services .....ooeeeeeremsesenens... LUE Amount 7/13/17 JA Dakarmenjian, Kivork Receive, read, and analyze letter from S. Dakarmenjianre: 2 $100.00 and Elizabette - status and strategy Dependency Subtotal of Hourly Fees $2,875.00 Subtotal of Costs and/or Flat Fees $976.45 Combined Subtotal (Fees& Costs) $3,851.45 6/26/17 JA Dakarmenjian, Kivork Receive, read and analyze email from A. Kemkemian re: 2 $100.00 and Elizabette - Estate Temporary Detention Order for Minors 6/28/17 JA Dakarmenjian, Kivork Phone conferences with S. Dakarian re: status and strategy .2 $100.00 and Elizabette - Estate 6/28/17 JA Dakarmenjian, Kivork Receive, read and analyze multiple emails from A. 2 $100.00 and Elizabette - Estate Kemkemian re: Minors Attorney 6/28/17 JA Dakarmenjian, Kivork Exchange emails with S. Dakarian re: Minors Attorney and .2 $100.00 and Elizabette - Estate status 6/28/17 AL Dakarmenjian, Kivork Exchange emails with A. Kemkemian re: status and 1 $0.00 and Elizabette - Estate strategy 6/29/17 JA Dakarmenjian, Kivork Exchange emails with A. Kemkemian re: status and 1 $50.00 and Elizabette - Estate strategy 6/29/17 JA Dakarmenjian, Kivork Receive, read and analyze emails from S. Dakarian re: 2 $100.00 and Elizabette - Estate status and strategy 6/30/17 JA Dakarmenjian, Kivork Receive, read and analyze multiple emails from S. 4 $200.00 and Elizabette - Estate Dakarian re: status and strategy 7/3/17 JA Dakarmenjian, Kivork Receive, read and analyze email from S. Dakarian re: D. 2 $100.00 and Elizabette - Estate Gloubiger status and strategy 7/3/17 JA Dakarmenjian, Kivork Receive, read and analyze emails from A. Kemkemianre: 2 $100.00 and Elizabette - Estate Minor Custody Release and social worker communication 7/4/17 JA Dakarmenjian, Kivork Exchange emails with A. Kemkemian re: Sean's property ~~ .2 $100.00 and Elizabette - Estate 7/4/17 JA Dakarmenjian, Kivork Receive, read and analyze email from A. Kemkemianre: .2 $100.00 and Elizabette - Estate social worker communication 7/517 DA Dakarmenjian, Kivork Exchange emails with A. Keren re: Publication- Notice of 2 $50.00 and Elizabette - Estate Petition to Administer estate 7/5/17 DA Dakarmenjian, Kivork Exchange emails with S. Dakarian re: conference call and .1 $25.00 and Elizabette - Estate status 7/10/17 JA Dakarmenjian, Kivork Exchange emails with S. Dakarmenjian re: credit card 1 $50.00 and Elizabette - Estate authorization form 711/17 JA Dakarmenjian, Kivork Prepare and send email to S. Dakarmenjian re: credit card .1 $50.00 and Elizabette - Estate authorization form 713/17 JA Dakarmenjian, Kivork Phone conference with A. Kemkemian re: status and 2 $100.00 and Elizabette - Estate strategy 7/13/17 JA Dakarmenjian, Kivork Receive, read and analyze email from A. Kemkemian re: .2 $100.00 and Elizabette - Estate status and strategy Page 2 Date Atty Matter Description of Services ns _ Hours Amount 7/19/17 JA Dakarmenjian, Kivork Receive, read and analyze email from Opposing Counsel ~~ .2 $100.00 and Elizabette - Estate B. Agopoglu re: request to extend responsive pleadings 71917 JA Dakarmenjian, Kivork Prepare and send email to A. Kemkemian and S. Dakarian .2 $100.00 and Elizabette - Estate re: Opposing Counsel B. Agopoglu's request to extend responsive pleadings Subtotal of Hourly Fees $1,725.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $1,725.00 6/30/17 JA Dakarmenjian, Kivork Receive, read, and analyze Notice of OSC Hearing and 2 $100.00 and Elizabette v. Notice of Case Management Conference. Dakarmenjtan, Troud etal. 7/6/17 JA Dakarmenjian, Kivork Phone conference with Client re: status and strategy 6 $300.00 and Elizabette v. Dakarmenjian, Troud etal. Subtotal of Hourly Fees $400.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $400.00 6/26/17 DA Dakarmenjian, Troud Prepare draft of Guardianship documents and compile all ~~ 3.2 $800.00 Probate information 6/28/17 DA Dakarmenjian, Troud Prepare and send notice letter to all interested parties re: 3.2 $800.00 Probate probate petition. Investigate with child services re children moving to new home. 6/30/17 DA Dakarmenjian, Troud Prepare, file and serve notices of petition to administer 1.8 $450.00 Probate estate. 6/30/17 AL Dakarmenjian, Troud e-filing fee: $3.60 $3.60 Probate 7/3/17 AL Dakarmenjian, Troud One Legal filing fees: $11.55 $11.55 Probate 7/5/17 DA Dakarmenjian, Troud Phone conference with newspaper re publication of notice 4 $100.00 Probate of probate 7/10/17 DA Dakarmenjian, Troud Exchange emails with Client A. Kemkemian re: 2 $50.00 Probate guardianship paperwork 7111/17 DA Dakarmenjian, Troud Receive, read, and analyze Notice of Publication in Ad $25.00 Probate newspaper 7/11/17 JA Dakarmenjian, Troud Receive, read, and analyze email from Client re: status and .2 $100.00 Probate strategy 71/17 JA Dakarmenjian, Troud Receive, read, and analyze email from Client S. Dakarian ~~ .2 $100.00 Probate re: status and strategy 7/12/17 DA Dakarmenjian, Troud Exchange emails with Client A. Kemkemian re: 2 $50.00 Probate guardianship paperwork 7/12/17 AL Dakarmenjian, Troud One Legal filing fees- Notice of Hearing: $7.95 $7.95 Probate Page 3 Date Atty Matte Description of Services Hours Amount 713117 TN3NT 7/14/17 M717 mini 7N7 7/18/17 7/18/17 7/18/17 7119/17 7/20/17 7121/17 721/17 721/17 7121/47 7121/17 7/23/17 7/24/17 AL JA AL DA JA AL DA DA JA DA DA DA DA DA DA DA DA DA Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate Dakarmenjian, Troud Probate One Legal filing fees: $468.75 Receive, read, and analyze email from Client S. Dakarian re: status and strategy One Legal filing fees-Amended Petition: $266.45 Prepare draft of supplement to probate petition to clear probate notes Exchange emails with Opposing Counsel H. Price re: extension of time to respond to the Verified Complaint Exchange multiple emails with Clients S. Dakarian and A. Kemkemian re: status and strategy Phone conference with Jason Rubin re: Neutral special administrator duties. Further draft of supplement to probate petition to clear probate notes. Conference with Ani regarding same. Exchange emails with S. Dakarian re: conference call and status Further draft of final supplement to clear probate notes. Meet with client to sign same. Prepare, file and serve probate supplement to clear notes. Conversation with client and with third party administrator regarding same. OneLegal filing fee: $11.55 Prepare and send email to attorney of special administrator regarding consent to act form. Call to same attorney's office. Phone conference with newly appointed Opposing Counsel, L. Lebowsky re: Probate Hearing Prepare for court hearing re: supplement to probate notes filing Prepare and send email to Opposing Counsel, L. Lebowsky . re: filed Supplements File Supplements OneLegal filing fees: $11.55,$11.55 Total: $23.10 Prepare for court hearing re: probate initial hearing Travel to and from and appear in Court re: initial probate hearing Page 4 1.2 22 $468.75 $100.00 $266.45 $300.00 $100.00 $0.00 $100.00 $300.00 $50.00 $150.00 $311.55 $50.00 $50.00 $300.00 $50.00 $73.10 $200.00 $550.00 Date Atty Matter Description of Services Hours Amount Subtotal of Hourly Fees $5,125.00 Subtotal of Costs and/or Flat Fees $792.95 Combined Subtotal (Fees& Costs) $5,917.95 Attorneys/Hourly Billing Rate: Total Amount Due This Invoice for All Matters $11,894.40 JA - Jeffrey Alpert $500 Previous Balance -$2,965.00 oa ® Dean Asher $250 Credit Amount Paid - Thank You $3,000.00 = cronica Larcia JAnc - Jeffrey Alpert no charge Total Balance Now Due $5,929.40 DAnc- Dean Asher no charge ALG - Courtesy no charge Page 5 ALPERT LAW GROUP A Professional Corporation 16133 VENTURA BOULEVARD, SUITE 1180 ENCINO CALIFORNIA 91436 TELEPHONE (818) 285-5370 E-MAIL jeff@alpertlawgroup.com Federal Tax ID No 47-3236654 Submitted to: Ani Kemkemian Date: 08/31/2017 18901 Salt Lake PI. Due Upon Receipt Northridge, CA 91326 Please note that starting September 1, 2017 we will be billing for "paralegal/assistant” time - All time entries are by Veronica Garcia and noted as "VG" Regarding: Multiple Matters Total Balance Now Due $9,161.50 Date Atty Matter Description of Services Hours Amount 8/9/17 DA Dakarmenjian, Kivork Phone and email follow-up with children's attorney Iseri RB $25.00 and Elizabette - Dependency 8/10/17 DA Dakarmenjian, Kivork Follow up phone with childrens Counsel re dependency A $25.00 and Elizabette - Dependency 8/17/17 DA Dakarmenjian, Kivork Receive, read, and analyze Objections to Petition for 2 $50.00 and Elizabette - Letters of Special Administration Dependency 8/23/17 JA Dakarmenjian, Kivork Receive, read, and analyze email from Client re: 2 $100.00 and Elizabette - Dependency hearing-Case Review. from Court. Dependency Subtotal of Hourly Fees $200.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $200.00 7/25/17 JA Dakarmenjian, Kivork Exchange emails with Client re: status and strategy 2 $100.00 and Elizabette - Estate 7/25/17 JA Dakarmenjian, Kivork Exchange emails with S. Dakarmenjian re: status and 2 $100.00 and Elizabette - Estate strategy 7/31/17 DA Dakarmenjian, Kivork Receive, read and analyze email from S. Dakarian re: ol $25.00 and Elizabette - Estate Guardianship and Escrow Representative Subtotal of Hourly Fees $225.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $225.00 7/25/17 JA Dakarmenjian, Kivork Phone conference with Opposing Counsel re: notary book 2 $100.00 and Elizabette v. Dakarmenjian, Troud etal. Page | Date 8/4/17 8/4/17 8/5/17 8/5/17 8/717 8/1117 8/117 8/7117 8/1117 8/8/17 8/9/17 8/9/17 8/9/17 Atty JA JA JA JA JA JA JA JA JA JA DA DA Matter Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Description of Services Exchange emails with H. Price re: meet and confer Receive, read, and analyze email from Client re: status Exchange emails with client Exchange emails with Client re: status of C. Molina's Counsel Exchange emails with Client re: status of C. Molina's Notary book. Receive, read, and analyze Verified Answer of Complaint from OPC. B. Agopoglu Receive, read, and analyze email from Opposing Counsel C. Gharhreman re: Extension of time for reply. Receive, read and analyze email from C. Ghahreman re: status of C. Molina's extension of time to file Answer to Complaint Receive, read and analyze email from B. Agopoglu re: Verified Answer Prepare and send email to H. Price re: meet and confer Phone conference with Sevan re: status and strategy Receive, read, and analyze Verified Answer of Complaint from OPC. B. Agopoglu sent through the U.S Mail Phone conference with C. Dakarmenjian re: strategy Page 2 Hours Amount 2 . — $100.00 $50.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $50.00 $100.00 $50.00 Date Atty Matter Description of Services Hours Amount 8/9/17 8/9/17 8/10/17 8/10/17 8/10/17 8/10/17 8/10/17 8/11/17 8/11/17 8/11/17 8/11/17 8/11/17 8/11/17 JA VG DA DA JA JA JA VG JA JA JA AL JA Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Prepare and send email to C. Ghahreman re: status of C. Molina's Answer to Complaint Prepare and send email to Client A. Kemkemian re: C. Molina's Answer to Complaint Receive, read, and analyze email from Client re: signatures Phone conference with Sevan re: Sara response by Howard Price and Sevan issue with Troud/Sevan car issue. Receive, read, and analyze Declaration of Demurring Party in Support of Automatic Extension Phone conference with Client re: status and strategy Receive, read, and analyze emails from Client re: client documents Exchange emails with Sevan and Ani re calendar updates. Receive, read and analyze email from H. Price re: second meet and confer Receive, read and analyze email from H. Price re: discovery request Receive, read, and analyze email from Client re: status and strategy Daily Journal Corporation Probate Petition publication fee: $210.00 Receive, read, and analyze email from Client re: conversation with E. Schneider Page 3 2 $100.00 $7.50 $50.00 $50.00 $100.00 $100.00 $100.00 $15.00 $100.00 $100.00 $100.00 $210.00 $100.00 Date Atty Matter Description of Services Hours Amount 8/14/17 JA Dakarmenjian, Kivork Receive, read, and analyze email from S. Dakarian re: 2 $100.00 and Elizabette v. Forensic Specialist that will review the hand writing on the Dakarmenjian, Troud property documents. etal. 8/15/17 JA Dakarmenjian, Kivork Receive, read, and analyze email Forensic Specialist M. 2 $100.00 and Elizabette v. Songer re: status and strategy Dakarmenjian, Troud etal. Subtotal of Hourly Fees $2,372.50 Subtotal of Costs and/or Flat Fees $210.00 Combined Subtotal (Fees& Costs) $2,582.50 7/25/17 DA Dakarmenjian, Troud Prepare and send e mail to Opposing Counsel re: A $25.00 Probate supplements per request of OPC L. Lebowsky 8/21/17 JA Dakarmenjian, Troud Receive, read, and analyze email from A. Kemkemian re: 2 $100.00 Probate probate investigation 8/22/17 JA Dakarmenjian, Troud Receive, read, and analyze email from A. Kemkemianre: 2 $100.00 Probate probate investigation Subtotal of Hourly Fees $225.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $225.00 Attorneys/Hourly Billing Rate: Total Amount Due This Invoice for All Matters $3,232.50 JA - Jeffrey Alpert $500 Previous Balance $5,929.00 ve : Vero iG i 1s Credit Amount Paid - Thank You -; eronica uarcia JAnc- Jeffrey Alpert no charge Total Balance Now Due $9,161.50 DAnc- Dean Asher no charge ALG - Courtesy no charge Page 4 ALPERT LAW GROUP A Professional Corporation 16133 VENTURA BOULEVARD, SUITE 1180 ENCINO CALIFORNIA 91436 TELEPHONE (818) 285-5370 E-MAIL jeff@alpertlawgroup.com Federal Tax ID No. 47-3236654 Submitted to: Date: 10/02/2017 Due Upon Receipt Regarding: Multiple Matters Total Balance Now Due $3,612.50 Date Atty Matter Description of Services Hours Amount 8/30/17 JA Dakarmenjian, Kivork Receive, read, and analyze email from Client A. 2 $100.00 and Elizabette Kemkemian re: Dependency court outcome Gaurdianship 8/31/17 DA Dakarmenjian, Kivork Exchange emails with Client re: deed signatures 2 $50.00 and Elizabette Gaurdianship 9/4/17 JA Dakarmenjian, Kivork Receive, read, and analyze email from Client S. Dakarian ~~ .2 $100.00 and Elizabette re: filing complaint and status Gaurdianship 9/21/17 JA Dakarmenjian, Kivork Receive, read, and analyze email from Client A. 2 $100.00 and Elizabette Kemkemian re: status and strategy Gaurdianship Subtotal of Hourly Fees $350.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $350.00 9/20/17 DA Dakarmenjian, Kivork Travel to and from and appear in Court re: guardianship 32 $800.00 and Elizabette continuance Guardianship 9/20/17 DA Dakarmenjian, Kivork Parking: $17.50 $17.50 and Elizabette Guardianship Subtotal of Hourly Fees $800.00 Subtotal of Costs and/or Flat Fees $17.50 Combined Subtotal (Fees& Costs) $817.50 8/28/17 JA Dakarmenjian, Kivork Receive, read, and analyze Substitution of Attorney from 2 $100.00 and Elizabette v. Howard Price to John Kerr Dakarmenjian, Troud etal. Page | Date 8/30/17 8/30/17 8/30/17 8/31/17 Text 8/31/17 8/31/17 9/1/17 9117 9/2/17 9/8/17 9/11/17 9/12/17 9/20/17 Atty Matter JA DA DA VG DA JA DA JAnc JAnc JA Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. DAnc Dakarmenjian, Kivork VG and Elizabette v. Dakarmenjian, Troud etal. Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. DAnc Dakarmenjian, Kivork and Elizabette v. Dakarmenjian, Troud et al. Description of Services Phone conference with Client re: status and strategy Phone conference with Client re: status and strategy Prepare draft of notice of taking Depo of C. Molina Serve Notice of Deposition to C. Molina Phone conference with Client re: deeds Receive, read, and analyze email from client re: status on recorded document signatures Conference with Client re: status and strategy, file review for deeds. Email same to client. Receive, read, and analyze emails from client re: licenses and Deed of Trust Exchange emails with client re: filed Complaint Prepare draft of Opposition to Demurrer Exchange emails with client re: trial status and strategy Prepare and send email to Berc Agopoglue, Chris Ghareramen re: Deposition of C. Molina Receive. read, and analyze email from S. Dakarian re: Ani receiving Molina investigation notice from the State Page 2 Hours Amount 6 6 12 14 $300.00 $150.00 $300.00 $15.00 $50.00 $100.00 $150.00 $0.00 $0.00 $700.00 $0.00 $15.00 $0.00 ate Atty Matter Cm ——— [ATTY TYRILE 2] SOPEARCEOOEPBEEEOOSTARAROINERTRS seas Description of Services Hours Amount 9/20/17 DAnc Dakarmenjian, Kivork Receive, read, and analyze email from Sevan Dakarian re: .1 $0.00 and Elizabette v. link to bonding company's website Dakarmenjian, Troud etal. Subtotal of Hourly Fees $1,880.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $1,880.00 9/13/17 DA Dakarmenjian, Kivork Exchange emails with L. Lebowsky re: continuing matter ~~ .2 $50.00 and Elizabette v. Dakarmenjian, TrouDakarmeniian. Subtotal of Hourly Fees $50.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $50.00 8/30/17 JAnc Dakarmenjian, Troud Prepare and send email to S. Dakarian and A. Kemkemian 2 $0.00 Probate re: conference call times 9/6/17 JA Dakarmenjian, Troud Receive, read, and analyze emails from client re: Notice of .2 $100.00 Probate Petition to Administer Estate 9/6/17 DA Dakarmenjian, Troud Receive, read, and analyze email from C. Molina re: 2 $50.00 Probate Petition for Probate 9/11/17 VG Dakarmenjian, Troud Prepare and send Email to B. Agopoglu and John Kerr re: 2 $15.00 Probate Reschedule Deposition of Claudia Molina and Request for available dates. 9/12/17 DA Dakarmenjian, Troud Phone conference with counsel for hernandez trust re: 6 $150.00 Probate probate 9/13/17 DA Dakarmenjian, Troud Conference with Opposing Counsel re: continuance of 2 $50.00 Probate probate hearing 9/18/17 JA Dakarmenjian. Troud Receive, read, and analyze Notice of Hearing- Decedent's ~~ 2 $100.00 Probate Estate or Trust 9/20/17 DA Dakarmenjian, Troud Phone conference with Sevan re: notary complaint and Jd $25.00 Probate Troud's will 9/20/17 DA Dakarmenjian, Troud Exchange emails with S. Dakarian re: concerns about Jl $25.00 Probate probate filing page 2 and Gerald Renyer Subtotal of Hourly Fees $515.00 Subtotal of Costs and/or Flat Fees Combined Subtotal (Fees& Costs) $515.00 Attomeys/Hourly Billing Rate: Total Amount Due This Invoice for All Matters $3,612.50 JA - leffrey Alpert $500 Previous Balance $9,161.50 DA - Dean Asher $250 Credit Amount Paid - Thank You $9,161.50 VG - Veronica Garcia $75 JAnc- Jeffrey Alpert no charge Total Balance Now Due $3,612.50 DAnc- Dean Asher no charge ALG - Courtesy no charge Page 3 EXHIBIT C Electronically FILED by Superior Court of California, County of Los Angeles on 05/66/2020 05:54 PM Sheri R. Carter, Executive Officer/Clerk of Court, by E. Gregg.Beputy Clerk MC-010 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER 143554 FOR COURT USE ONLY NAME Joseph R. Brown Fru NAME Law Office of Joseph R. Brown STREET ADCRESS: 13808 Ventura Blvd. cry Sherman Oaks sTATE. CA zPcoce 91423 TELEPHONE NO: 818-807-0880 Faxno: 818-907-1918 E-MAIL ADDRESS. joebrownlaw@gmail.com ATTORNEY FOR (nama) Ani Kemkenian and Sevan Weir, successor trustee SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STREET ADDRESS 111 North Hill Street sMaLNG ACSRESS 111 North Hill Street city avo ap cove Los Angeles, CA 80012 sraxcrnaue Stanley Mosk Courthouse PLAINTIFF: Ani Kemkenian and Sevan Weir, successor trustees DEFENDANT: Sara Dakarment CASE NUMBER: AMENDED MEMORANDUM OF COSTS (SUMMARY) BC664277 The following costs are requested: TOTALS 1. Filing and motion fees 1,505.00 Jury fees Jury food and lodging 2,819.40 528.00 Deposition costs Service of process Attachment expenses Surety bond premiums Witness fees Court-ordered transcripts 165.00 © © N O 0 a ww N ¥Y Hh $hh OO on © »v vv NN ©» - o . Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court determination; otherwise a noliced motion is required) 11. Court reporter fees as established by statute 6,120.00 12. Models, enlargements, and photocopies of exhibits 637.55 13. Interpreter fees 14. Fees for electronic filing or service 245.00 15. Fees for hosting electronic documents 18. Other ww ON nm vw © ow 440.00 TOTAL COSTS S 12,459.95 | am the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is comect and these costs were necessarily incurred in this case. Date: May 8, 2020 Joseph R. Brown b (TYPE CR PRINT NAME) (SIGNATURE CF CECLARANT) (Proof of service on raversa) Page tal? om Agro tr Opraiute MEMORANDUM OF COSTS (SUMMARY) ae i [Rov September 1. 2017) MC-010 SHORT TITLE CASE NUMBER: Dakammenjian v. Dakarmen BCBB4277 PROOF OF [x] MAILING [_] PERSONAL DELIVERY 1. Atthe time of mailing or personal delivery, | was at least 18 years of age and not a party to this legal action. 2. My residence or business address is (specify): 13808 Ventura Blvd, Sherman Oaks, CA 91423 Amended 3. Imailed or personally delivered a copy of the Memorandum of Costs (Summary) as follows (complete either a or b). a. [OX] Mail. | am a resident of or employed in the county where the mailing accurred. (1) enclosed a copy in an envelope AND (a) [x] deposited the sealed envelope with the United States Postal Service with the postage fully prepaid. (b) [_] placed the envelope for collecticn and mailing on the date ard at the place shown in items balow following our ordinary business practices. | am readily familiar with this business’ practice for collecting and processing correspondance for mailing. On the same day that correspondence is placed for collection and mailing, itis deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. (2) The envelope was addressed and mailed as follows: (a) Name of person served: JOHN DALE KERR, ESQ. (b) Address on envelope: Law Offices of John Dale Kerr, 5550 Topanga Canyon Blvd, Ste 200, Woodland Hills, CA 91367-7445 {c) Date of mailing: May 6, 2020 (d) Place of mailing (city and state): Sherman Oaks, CA 91423 b. [] Personal delivery. | personally delivered a copy as follows: (1) Name of person served: (2) Address where delivered: (3) Date delivered: (4) Time delivered: | declare under penalty of perjury under the laws of the State of Califomnia that the foregoing is true and correct. Date: May 6, 2020 Joseph R. Brown (TYPE OR PRINT NAME) (SQ — —_— Psgo2atl HCO10 Rev Sapmmber 1. 2017) MEMORANDUM OF COSTS (SUMMARY) MC-011 SHORT TITLE Dakamenjian v. Dakarmen CASE NUMBER: BC664277 AMENDED MEMORANDUM OF COSTS (WORKSHEET) 1. Filing and motion fees Pape filed Eiling fea a. Filing fee - Verified Complaint $ 435.00 b. Filing fee - Answer to Cross-Complaint (Elizabette) $ 435.00 c. Filing fee - Answer to Cross-Complaint (Kivork) $ 435.00 d. Motion for Leave to File Second Amended Complaint $ 60.00 e. Filing Fee - Ex Parte Application/Order $ 60.00 f. Filing Fee - Stip & Order $ 20.00 g. [x7] Information about additional filing and motion fees is contained in Attachment 1g. 2. Jury fees a. b. c. d. e. {] Information about additional jury fees is contained in Attachment 2e. 3. Jurorfood: $ 4. Deposition costs $ $ and lodging: $ TOTAL 4. ToTAL2 FT] TOTAL FT a. Claudia Molina $ 788.40 $ $ $ $ 788.40 b. Sara Dakarmen $ 1.10825 $ $ $ $ 1.108.265 ¢. Jackie McNamee $ 92275 $ $ $ $ 922.75 $ $ $ $ $ e. [7] Information about additional deposition costs is contained in Attachment 4e. TOTAL 4. (Continued on reverse) Page 1of 4 No am 14 MEMORANDUM OF COSTS (WORKSHEET) E [Rav. Scptambder 1, 2017] MC-011 SHORT TITLE Dakamenjian v. Dakarmen CASE NUMBER: BCE664277 5. Service of process i Registared Name of persan served Public officer process Publication Other (specify) a. Los Angeles Sheriffs Dept $ $ 55.00 $ S$ b. Los Angeles Police Dept $ $ 55.00 $ $ c. Laura Stone $ $ 55.00 § $ d. [x7] Information about additional costs for service of process is contained in Attachment Sd. TOTAL 5. F__ &t»Bu| 6. Attachment expenses (specify): 7. Surety bond pramiums (itemize bonds and amounts): 8. a. Ordinary witness fees Name of witness Daily fee Mileage Total (1) Los Angeles Sheriffs Dept days at $/day miles at ¢/mile: F500 (2) Los Angeles Police Dept. days at $/day miles at ¢/mile: E_—_—_—5mm (3) Robert Bagdashyan days at $/day miles at ¢/mile: 30m (4) Peter Boyadjian days at Siday miles at ¢/mile: Bam (5) Sue Kim days at $/day miles at ¢/mile: Baum (6) [_] Information about additional erdinary witness fees is contained in Attachment 8a(6). ee — {Continued on next page) NOG (Re, Sopmenery. 20m) MEMORANDUM OF COSTS (WORKSHEET) Page _2of 4 MC-011 SHORT TITLE CASE NUMBER: Dakarmenjian v. Dakarmen BC664277 8. b. Expert fees (per Code of Civil Procedure section 998) Name of witness Fee hours at me FE @ hows ats me F_—— fom as hr FF “ bom 83. we FE (5) [J Information about additional expert fees is contained in Attachment 8b(5). SUBTOTAL 80S] ¢. Court-ordered expert fees Name of witness Fee 0) hours a me — @ hours 18 te FE (3) [_] Information about additional court-ordered expert fees is contained in Attachment 8¢(3). SuBTOTALECS | TOTAL (8a. 8b, 880) 8f_ 9. Court-ordered transcripts (specify): 9. ET 10. Attorney fees (enter here if contractual or statutory fees are fixed without necessily of a court 10. CE determination; otherwise a noticed motion is required): TBD per noticed motion 11. Models, enlargements, and photocopies of exhibits (specify): 11. Photocopies of Exhibits (Exhibit Books). 12. Court reporter fees (as established by statute) a. (Name of reporter): Noga Boothby Crt Reporters Fees: $ 6.120.00 b. (Name of reporter): Fees: $ TOTAL 12. — ®i0m c. [1 Information about additional court-reporter fees is contained in Attachment 12c. 13. Interpreter feos a. Fees of a certified or registered interpreter for the deposition of a party or witness (Name of interpreter). Fees: $ (Name of interpreter). Fees: $ p. Fees for a qualified court interpreter authorized by the court for an indigent person represented by a qualified legal services project or a pro bono attomey (Name of interpreter). Fees: $ (Name of interpreter): Fees: $ TOTAL 43. E11 ¢. [] Information about additional court-reporier fees is contained in Attachment 13¢. 14. Foes for olactronic filing or service of documents through an electronic filing service provider (enter here if required or ordered by the court): 14. 15. Faas for hosting electronic decuments through an electronic filing service provider (enter here if required or ordered by the court): 5. E11] 16. Other (specify): Courier - Courtesy Copies to Court per Court Instructions (CCP 1033.5(c)4)) 16. Fm foaL costs Fam {Additional information may be supplied on the reverse) MCN Rev. SERmERLY 2077) MEMORANDUM OF COSTS (WORKSHEET) Page 3of 4 MC-011 SHORT TITLE Dakammenijian v. Dakarmen CASE NUMBER: 8C664277 1 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 ATTACHMENT 1g Filing Fee - Motion for Attomey's Fees (anticipated) - $60.00 ATTACHMENT 5d {Service of Process: Robert Bagdashyan - Registered Process Server - $55.00 [sue Kim - Registered Process Server - $55.00 Peter Boyadjian - Registered Process Server - $55.00 + $198.00 pvt. invest. to locate per CCP1033.5(a)(4)(B) MC-011 [Rov September 1.2017) MEMORANDUM OF COSTS (WORKSHEET) 4of 4 2 w o wn (PROOF OF SERVICE BY MAIL - 1013, 2015.5 C.C.P.) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES [ am a resident of the county aforesaid: I am over the age of eighteen years and not a party to the within action: my business address is 13808 Ventura Blvd., Sherman Oaks, California 91423. On June 20. 2020. I served NOTICE OF MOTION AND MOTION FOR ATTORNEY'S FEES AND COSTS IN THE AMOUNT OF $165,132.45 AGAINST SARA RENYER DAKARMEN AS PERSONAL REPRESENTATIVE OF THE ESTATE OF TROUD STROUD DAKARMENIIAN PURSUANT TO CODE OF CIVIL PROCEDURE §1032 AND WELFARE & INSTITUTIONS CODE §15657.5: POINTS & AUTHORITIES AND DECLARATIONS OF JOSEPH R. BROWN AND ANI KEMKEMIAN IN SUPPORT THEREOF on the parties in said action. by email, e-service, and by enclosing said document in a sealed envelope with first class postage fully paid to be placed in the United States mail at Sherman Oaks. CA. addressed as indicated below: JOHN DALE KERR, ESQ. [Law Offices of John Dale Kerr 5550 Topanga Canyon Blvd. Ste 200 Woodland Hills. CA 91367-7445 I certify. (or declare), under penalty of perjury, that the foregoing is true and correct. Executed on June 20, 2020 at Los Angeles. California. Joseph R. Brown MOTION FOR ATTORNEY'S FEES 11