Free Motion for Attorney Fees - District Court of Colorado - Colorado

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 1 of 33
Exhibit 22c, Page 124

TONETTE SOUTHERN BILLING RECORDS (Reduced) Client Date Tkr Rate Hours Total REF# Descrition
2180.01 2180.01 11/14/2000 11/16/2000 38 38 50 50 1.6 1.2 80.00 60.00 Update filing; tickler date to resolve charge per 79 extension granted; calendar same Fax transmittal of request for right to sue letter to the 81 CCRD; transmittal of same to client and the EEOC Telephone conference with SBlack (CCRD) regarding request for right to sue letter; preparation of same; 80 revise form to include fax number Review and distribute Notice of Right to Sue; tickler and 87 calendar deadline Review Notice of Right to Sue received from the EEOC; research Notice received from CCRD; calculate filing 90 date of EMP claim using CCRD date; distribute same

Rate Reduced
0.75 0.75

Reason

Bartlett/Richards/D 60.00 illon Bartlett/Richards/D 45.00 illon Bartlett/Richards/D 45.00 illon Bartlett/Richards/D 27.00 illon

2180.01 2180.01

11/16/2000 12/15/2000

38 38

50 50

1.2 0.8

60.00 36.00

0.75 0.75

2180.01

1/18/2001

38

50

0.8

36.00

0.75

Bartlett/Richards/D 27.00 illon

2180.01

3/6/2001

38

50

1.8

90.00

Consider merge set up for new files; office conference with LMNeff regarding same; telephone conference with SBlack (CCRD) to request copy of JBartlett's Charge of Discrimination; preparation of Entry of Appearance; review files for deadlines; calendar and tickler same; telephone conference with Stacie (CCRD) regarding Gary Moreford (no Charge on file) and another potential Plaintiff (Dorington); office conference with MClawson and LMNeff regarding same; organize notes and documents for future retrieval; coordinate filing of Entry 106 of Appearance (JBartlett) Revise Complaint per JKKillian and LMNeff; telephone conference with FedEx representative regarding dropoff locations; preparation of correspondence to clerk regarding filing of Complaint; request filing and jury fees; preparation of FedEx package; coordinate filing of 108 Complaint and delivery to FedEx (airport drop-off) 156 Organize file Preparation of correspondence to MSHA to request file of MClawson; preparation of Release package for 251 TRichards; update filing

0.75

Morford, Dorington, Bartlett, 67.50 no charge

2180.01 2180.01

3/7/2001 38 6/20/2001 38

50 50

3.4 6

170.00 300.00

0.15 0.15

25.50 15% Reduction 45.00 15% Reduction

2180.01

9/19/2001

38

50

0.5

25.00

0.5

12.50 T. Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 2 of 33
Exhibit 22c, Page 125

2180.01

9/19/2001

38

50

0.4

20.00

Update filing; telephone conference with MClawson regarding revisions to Amended Complaint; telephone conference with JBartlett regarding same; office 252 conference with JCJensen regarding revisions

0.5

2180.01

1/15/2002

38

50

4.9

245.00

Initial preparation of confidential settlement statement; 300 review tasks and organize same Initial preparation of disclosures (4.5 hours); office conference with JCJensen regarding client's worker's 306 compensation claims (.1) Office conference with JKKillian and JCJensen to initially review the Confidential Settlement Statement; calendar additional meetings for review of proposed Scheduling ORder, initial disclosures, and the Confidential Settlement Statement; re-calendar and tickler deadline to exchange disclosures as agreed to by counsel; office conference with JKKillian regarding dropping of ADA claims; office conference with JCJensen regarding same; continued preparation of initial disclosures; preparation of retention letters (four) 307 to PRiley Preparation of retention letters (four each) to RBrennan and PRenfro; preparation of retention letters to SHeil, EPrice (two), and RFox; office conference with JCJensen to review same and to review the Confidential Settlement Statement and proposed Scheduling Order; transmittal of all correspondence with 308 copies to clients; calendar followup

0.75

2180.01

1/22/2002

38

50

4.6

230.00

0.75

10.00 J. Bartlett Bartlett/Richards/D illon/ 15% Reduction Block 183.75 Billing Bartlett/Richards/D illon/ 15% Reduction Block 172.50 Billing

2180.01

1/23/2002

38

50

2.6

130.00

0.75

Bartlett/Richards/D illon/ 15% Reduction Block 97.50 Billing

2180.01

1/24/2002

38

50

4

200.00

0.75

Bartlett/Richards/D illon/ 15% Reduction Block 150.00 Billing

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 3 of 33
Exhibit 22c, Page 126

2180.01

1/31/2002

38

50

6

300.00

Continued revisions to scheduling Order and Confidential Settlement Statement per JCJensen and JKKillian; numerous office conferences with JKKillian and JCJensen regarding same; telephone conferences with clients, JKKillian and JCJensen regarding same; finalize documents and exhibits for filing; coordinate hand delivery of Scheduling Order to Magistrate Rice with copies to opposing counsel and clients; hand delivery of same to the Post Office; continued preparation of initial disclosures; office conference with 332 JKKillian and JCJensen regarding same Update filing; continued revisions to the Confidential Settlement Statement pre JKKillian and JCJensen; finalize same; coordinate filing and service of same with exhibits; continued preparation of initial disclosures; numerous office conferences with JCJensen regarding 329 same Office conference with JCJensen regarding her review of the Confidential Settlement Statement; review W2 received from TRichards; update filing; telephone conference with SBartlett regarding numerous issues; 326 office conference with JCJensen regarding JBart Review Confidential Settlement Statement per JKKillian; research second surgery on TRichards; office conference with LRichards regarding same and to confirm other facts; office conference with JCJensen regarding Confidential Settlement Statement and Scheduling Order; additional revisions to Scheduling Order; continued preparation of initial disclosures; review correspondence received from opposing counsel regarding revisions to Scheduling Order; preparation of response to same; office conference with JCJensen 330 regarding same

0.75

Bartlett/Richards/D illon/ 15% Reduction Block 225.00 Billing

2180.01

2/1/2002

38

50

8.72

436.00

0.75

Bartlett/Richards/ 15% Reduction 327.00 Block billing

2180.01

1/29/2002

38

50

3.1

155.00

0.75

Bartlett/Richards/ 15% Reduction 116.25 Block billing

2180.01

1/30/2002

38

50

5.4

270.00

0.4

T. Richards/15% Reduction Block 108.00 Billing Bartlett/Richards/D illon/ 15% Reduction Block 259.50 Billing

2180.01

2/4/2002

38

50

6.92

346.00

Office conference with JCJensen to review initial 335 disclosures; continued preparation of same

0.75

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 4 of 33
Exhibit 22c, Page 127

2180.01

2/4/2002

38

50

2

100.00

2180.01

2/6/2002

38

50

0.1

5.00

2180.01

2/11/2002

38

50

0.33

16.50

Finalize initial disclosures; fax transmittal of same to opposing counsel; review disclosures received from opposing counsel; coordinate service of both to clients; transmittal of initial disclosures to opposing counsel via 336 mail; hand delivery of all to the Post Office Telephone conference with MClawson regarding his worker's compensation claim (handled without an attorney); telephone conference with Dr. Wong's office regarding disability form of JBartlett (to locate and fax 357 over) Telephone conference with MClawson regarding discovery responses (will forward answers and releases); telephone conference with LRichards regarding discovery responses and supplemental 366 disclosures; note to file regarding same Office conference with JCJensen regarding disclosure of MClawson's girlfriend, and regarding package of documents sent by SBartlett; preparation of Motion to Reschedule Scheduling Conference; review file for timeline; review documents sent by SBartlett; request tax returns for JBartlett; conference room set up for meeting with JKKillian, JCJensen, and Richards; update 389 filing Preparation of medical records requests (thirty), including certifications, correspondence, and notarizing 394 of releases; transmittal of all with copies to client Telephone conference with Jill (EPrice's office) regarding medical records of TRichards; confirm receipt of all; followup conference with Jill regarding completing of Certification of Records; review records received 400 from DHuene on JBartlett, MClawson, and JDillon Preparation of Second Supplemental Disclosures; initial copying and labeling of disclosed documents; office conference with JCJensen and JKKillian regarding numbering of medical records; continued preparation of 459 documents to be disclosed

0.15

15.00 15% Reduction

0.5

2.50 J. Bartlett

0.5

8.25 T. Richards

2180.01

2/21/2002

38

50

1.8

90.00

0.75

67.50 J. Bartlett

2180.01

2/22/2002

38

50

3.2

160.00

0.75

Bartlett/Richards/D 120.00 illon

2180.01

2/26/2002

38

50

0.2

10.00

0.75

Bartlett/Richards/D 7.50 illon Bartlett/Richards/D illon/ 15% Reduction Block 152.55 Billing

2180.01

3/5/2002

38

50

4.5

203.40

0.75

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 5 of 33
Exhibit 22c, Page 128

2180.01

3/6/2002

38

50

5.4

243.00

461 Continued preparation of disclosures to be produced Review medical records received from Delta Hospital on all four clients; review package of documents received from TRichards; office conference with JCJensen 462 regarding privilege on calendars; update filing

0.75

Bartlett/Richards/D illon/ 15% Reduction Block 182.25 Billing

2180.01

3/6/2002

38

50

0.5

25.00

0.5

2180.01

3/6/2002

38

50

2.6

130.00

Continued preparation of disclosure package to 464 opposing counsel

0.75

2180.01 2180.01

3/10/2002 3/7/2002

38 38

50 50

8.52 1.75

426.00 87.50

465 Continued preparation of disclosure notebooks Preparation of discovery responses for JDillon and 469 MClawson Preparation of discovery responses of JBartlett; revise 474 responses of MClawson Office conference with JCJensen regarding discovery responses; revise same per JCJensen, including detailing of work histories and incomes; finalize disclosure documents; coordinate delivery via FedEx to opposing counsel of disclosed documents; travel to 477 FedEx to facilitate same Finalize discovery responses per JCJensen; print same 480 for review by JKKillian Preparation of Motion to Amend Complaint per JCJensen; finalize discovery responses; coordinate service of same to opposing counsel; preparation of cover letter to opposing counsel and to clients; 482 transmittal of all

0.75 0.5

12.50 T. Richards Bartlett/Richards/D illon/ 15% Reduction Block 97.50 Billing Bartlett/Richards/D illon/ 15% Reduction Block 319.50 Billing 43.75 Dillon

2180.01

3/11/2002

38

50

0.8

40.00

0.5

20.00 J. Bartlett

2180.01 2180.01

3/11/2002 3/12/2002

38 38

50 50

4.1 1.4

205.00 70.00

0.75 0.75

Bartlett/Richards/D 153.75 illon Bartlett/Richards/D 52.50 illon

2180.01

3/12/2002

38

50

2

90.00

0.75

Bartlett/Richards/D 67.50 illon

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 6 of 33
Exhibit 22c, Page 129

2180.01

3/13/2002

38

50

2.6

117.00

Office conference with JCJensen regarding issues involving amending the Complaint; fax transmittal to opposing counsel regarding same; organize tasks following meeting with JCJensen; preparation of Scheduling Order deadlines; distribute same; update 485 filing Submit to accounting invoice received from DenverOrtho for medical records of JBartlett; organize same; preparation of correspondence to opposing counsel supplementing disclosures; label records and update filing; transmittal of correspondence, medical records, and updated index of disclosures to opposing 495 counsel Office conference with JKKillian and telephone conference with MClawson to reschedule deposition preparation meeting; followup conference with JKKillian regarding remaining meetings; reschedule JKKillian's 503 meeting with JDillon Continued preparation of index to Def's disclosed 519 documents Convert Complaint to MS Word format and e-mail same to opposing counsel per his request; continued 523 preparation of index to Def's disclosed documents Continued preparation of indexing of Def's disclosed 536 documents

0.15

17.55 15% Reduction

2180.01

3/18/2002

38

50

1.1

50.40

0.5

25.20 J. Bartlett

2180.01 2180.01

3/19/2002 3/25/2002

38 38

50 50

0.8 7.92

40.00 396.00

0.5 0.15

20.00 Dillon 59.40 15% Reduction

2180.01 2180.01

3/26/2002 3/28/2002

38 38

50 50

4.9 5.8

245.00 290.00

0.15 0.15

36.75 15% Reduction 43.50 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 7 of 33
Exhibit 22c, Page 130

2180.01

4/1/2002

38

50

3.1

140.40

Review tax returns received from MClawson; update discovery responses regarding same; update disclosures and index to same; review and organize medical records received from DFunk for MClawson and JBartlett; submit to accounting invoices (two) regarding same; fax transmittal of correspondence to opposing counsel regarding missing documents disclosed by Def; Bates number medical records of DFunk; update disclosures and index to same; preparation of correspondence to opposing counsel enclosing medical records and tax information; 562 transmittal of all; update filing Notarize releases and request workers' compensation 569 files on MClawson, JDillon, and TRichards Initial preparation of discovery requests; telephone conference with Lori (RBrennan's office) to schedule vocational assessments for MClawson, JDillon, and TRichards; review employment form books for 581 additional interrogatories that may apply in this litigation Continued preparation of interrogatories; office conference with MHorn regarding same; research ADA 585 requirements and various prongs of proof Revise Interrogatories per JCJensen; preparation of Requests for Admission; review research materials to 610 locate pertinent Requests for Production of Documents Continued preparation of Requests for Admission and Requests for Production of Documents; numerous office conferences with JCJensen regarding same; 611 revise Interrogatories per JCJensen Continued revisions to discovery requests; numerous office conferences with JCJensen regarding same; 612 coordinate service of same with copy to clients

0.5

70.20 J. Bartlett T. Richards/J. 9.50 Dillon

2180.01

4/2/2002

38

50

0.33

14.40

0.66

2180.01

4/4/2002

38

50

4.4

198.00

0.66

130.68 T. Richards/Dillon

2180.01

4/5/2002

38

50

8.1

405.00

0.15

60.75 15% Reduction

2180.01

4/17/2002

38

50

7.1

355.00

0.15

53.25 15% Reduction

2180.01

4/18/2002

38

50

3.5

175.00

0.15

26.25 15% Reduction

2180.01

4/18/2002

38

50

4.4

220.00

0.15

33.00 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 8 of 33
Exhibit 22c, Page 131

2180.01

4/19/2002

38

50

2.33

116.50

Submit to accounting for payment invoice received from Hampton General Hospital for medical records of JBartlett; submit to accounting for payment invoices (two) received from EPrice for medical records of JBartlett and MClawson; submit to accounting for payment invoices (three) received from the Division of Labor for worker's compensation files of MClawson, JDillon, and TRichards; organize all medical records and work comp files received to date; Bates label same; update index of disclosures; preparation of correspondence to opposing counsel enclosing all 637 records and an updated index; transmittal of same Review and distribute fax transmittal received from opposing counsel regarding amending pleadings and deadline for same; office conference with JCJensen regarding same; office conference with JKKillian and JCJensen to respond to opposing counsel; preparation of request for worker's compensation records of 643 JBartlett; transmittal of same Office conference with MClawson to supplement discovery responses; office conference with JKKillian and JCJensen regarding same; copy additional records 657 for disclosure to opposing counsel Office conference with JKKillian and JCJensen regarding scheduled depositions of Pls; left message with TRichards regarding same and the possibility of 658 him attending the deposition of MClawson Preparation of supplemental disclosure responses for MClawson and TRichards; copy additional records from both; Bates label those records pertaining to TRichards; 659 update index and disclosure pleading regarding same

0.75

Bartlett/Richards/D 87.38 illon

2180.01

4/24/2002

38

50

0.6

30.00

0.25

7.50 J.Bartlett

2180.01

4/26/2002

38

50

2.75

137.50

0.5

68.75 Bartlett/Richards

2180.01

4/26/2002

38

50

0.2

10.00

0.5

5.00 T. Richards

2180.01

4/28/2002

38

50

6

300.00

0.5

150.00 T. Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 9 of 33
Exhibit 22c, Page 132

2180.01

4/29/2002

38

50

5.2

260.00

2180.01

4/29/2002

38

50

0.75

37.50

Bates label additional documents to be disclosed to opposing counsel; set up conference room for meeting with clients to discuss discovery responses; revise proposed Scheduling Order per JKKillian and 660 JCJensen; review Complaint for claims of relief Refresh conference room; review calendars and handwritten log of MClawson for privilege; office conference with JCJensen regarding same; copy same 661 to her with tabbed sections Attend to deposition preparation tasks per JKKillian and JCJensen; attend deposition of MClawson; preparation of deposition exhibit notebook; locate and copy additional exhibits to be admitted into evidence; numerous conferences with JKKillian, JCJensen, 667 MClawson, and TRichards Revise Scheduling Order per JCJensen, including insertion of undisputed facts; preparation of correspondence to opposing counsel regarding same; numerous office conferences with JCJensen regarding 709 all; numerous e-mail transmittals to opposing counsel Left message with Lori (RBrennan's office) regarding 720 appointments with JBartlett and MClawson in June Initial review of Answer; initial preparation of general 723 deposition questions Telephone conference with Lori (RBrennan's office) regarding expert's appointment with JBartlett; preparation of correspondence to opposing counsel regarding Rule 37 letter; office conference with JKKillian 724 to review correspondence to opposing counsel reg Continued review of Amended Complaint and Answer to 725 prepare general deposition questions Telephone conference with Beavers Construction regarding employment records of MClawson and TRichards; telephone conference regarding San Juan 755 Construction regarding same

0.75

Bartlett/Richards/D 195.00 illon

0.15

5.63 15% Reduction

2180.01

4/30/2002

38

50

11.5

575.00

0.15

86.25 15% Reduction

2180.01

5/8/2002

38

50

4.6

230.00

0.15

34.50 15% Reduction

2180.01 2180.01

5/10/2002 5/13/2002

38 38

50 50

0.1 5.33

5.40 266.50

0.5 0.5

2.70 J. Bartlett 133.25 Bartlett/Richards

2180.01 2180.01

5/14/2002 5/14/2002

38 38

50 50

3.1 4.6

140.40 230.00

0.5 0.5

70.20 J. Bartlett 115.00 Bartlett/Richards

2180.01

5/21/2002

38

50

0.2

10.00

0.5

5.00 T. Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 10 of 33
Exhibit 22c, Page 133

2180.01

5/15/2002

38

50

9.5

475.00

Continued research into Bates numbers for documents referenced in Complaint for use at upcoming depositions; create witness folders; fax transmittal of correspondence, subpoenas, notices, and waivers to opposing counsel due to time sensitivity; initial preparation of discovery responses to second set of requests for all Pls; locate responsive Bates numbers for potential deposition exhibits and copy same to witness folders; compare Fourth and Fifth Amended Complaint paragraphs to the Pls' undisputed facts attached to the Scheduling Order; print same for use during upcoming depositions; office conference with JKKillian regarding deposition exhibits, proposed lines of questioning, and outstanding discovery responses; pull additional resources for deposition per JKKillian; revise correspondence to opposing counsel regarding 729 supplemental discovery Preparation of employment records requests (fifteen total); preparation of Releases for all and certification forms; transmittal of all; update filing; preparation of Amended Notices of Deposition (two) to correct start times of depositions; continued preparation of Jury 732 Instructions

0.15

71.25 15% Reduction

2180.01

5/17/2002

38

50

7.1

355.00

0.75

Bartlett/Richards/D 266.25 illon

2180.01

5/22/2002

38

50

9.75

487.50

Continued deposition preparation, including copying of potential exhibits, setting up of conference room, and office conferences with JKKillian and JCJensen; attend deposition of ELangrand; preparation of exhibits to motion regarding discovery dispute; preparation of fax cover sheet to the Court; office conferences with JRAngel regarding research of case law necessary for same; continued office conferences with JKKillian and JCJensen; brief overview of discovery responses received from opposing counsel; clean conference 757 room following deposition

0.15

73.13 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 11 of 33
Exhibit 22c, Page 134

2180.01

5/23/2002

38

50

9.9

495.00

Continued preparation for deposition of GDiClaudio; set up conference room; attend deposition to assist JKKillian with document production and potential deposition exhibits; clean conference room following deposition; numerous office conferences with JKKillian 758 and JCJensen regarding testimony of GDiClaudio

0.15

74.25 15% Reduction

2180.01

5/28/2002

38

50

1.1

55.00

Review Order returned from JBartlett; telephone conference with SBartlett to confirm client's zip code; resend Order to client; review returned employment records request from RMMiners; research new location; re-send request regarding JDillon; submit to accounting for payment invoice received from Steadman Clinic for medical records of TRichards; organize records for production to opposing counsel; left message with Arlene (Steadman Clinic) regarding records contained 764 in certification not pertaining to TRichards Review, organize, and Bates label employment records of JBartlett and MClawson received to date; copy same for production to opposing counsel; update disclosures 782 and index to same Telephone conference with TDillon to remind of husband's appointment with RBrennan; telephone conference with RBrennan regarding same and regarding MClawson's need to reschedule; calendar 784 followup Continued preparation of Rule 37 letter, including 803 portion pertaining to Def's answers to interrogatories

0.75

Bartlett/Richards/D 41.25 illon

2180.01

6/3/2002

38

50

1.8

90.00

0.5

45.00 J. Bartlett

2180.01

6/4/2002

38

50

0.33

16.50

0.5

8.25 Dillon

2180.01

6/7/2002

38

50

4.6

230.00

0.15

34.50 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 12 of 33
Exhibit 22c, Page 135

2180.01

6/12/2002

38

50

1.33

66.50

Office conference with DJenkins regarding her meeting with JKKillian tomorrow; locate original Protective Order; note to DJenkins regarding same; print draft Rule 37 letter; note to DJenkins regarding same; copy Magistrate Robb's settlement conference sheet; note to DJenkins regarding same; note to DJenkins regarding deadline to amend pleadings; revise discovery responses to include additional objection; telephone conference with LRichards regarding same; additional revisions to discovery responses of TRichards; note to 823 DJenkins regarding all Research Court's prior Order regarding settlement conference; office conference with JCJensen regarding same and regarding need for Offers of Settlement to be exchanged; preparation of Confidential Settlement Statement; review of various pleadings and exhibits for 834 accuracy of settlement statement Revise discovery responses to include additional information provided by MClawson; research disclosures of Def (two volumes) to refer to training of MClawson in discovery responses; same tasks for JDillon and TRichards; office conferences with JKKillian and JCJensen regarding key documents referring to "regarded as disabled" for MClawson, TRichards, and JBartlett; continued research for evidence MtnCoal "regarded" Dillon as disabled; office conference with JCJensen regarding holding deposition of DScanlon at MtnCoal; office conference with JKKillian regarding status of discovery responses and Confidential 856 Settlement Statement

0.25

16.63 T. Richards

2180.01

6/18/2002

38

50

8.6

430.00

0.75

Bartlett/Richards/D 322.50 illon

2180.01

6/21/2002

38

50

4.6

230.00

0.75

Bartlett/Richards/D 172.50 illon

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 13 of 33
Exhibit 22c, Page 136

2180.01

6/26/2002

38

50

4.6

230.00

Office conference with JCJensen regarding additional questions to ask BOlsen and regarding additional potential exhibits, including those for DScanlon; revise draft questions to include location of prior deposition exhibits to refer to in deposition of BOlsen; followup office conference with JCJensen regarding deposition exhibits regarding "respective locations" and questions regarding same; preparation of additional questions and research regarding same; numerous telephone conferences with TRichards and LRichards regarding 885 additional facts Continued preparation of deposition questions for BOlsen per JCJensen; numerous office conferences with JCJensen regarding same; office conference with 886 JKKillian regarding all

0.25

57.50 T. Richards

2180.01

6/26/2002

38

50

2.6

130.00

0.15

19.50 15% Reduction

2180.01

6/27/2002

38

50

9.1

455.00

Set up conference room for deposition of BOlsen and continuation of deposition of ELangrand; numerous office conference with JKKillian and JCJensen; attend deposition of BOlsen; preparation of correspondence to opposing counsel enclosing Offer of Settlement; preparation of Offer of Settlement per JKKillian; revise all to extend four separate Offers; revise correspondence to opposing counsel to reflect same; followup office conference with JKKillian regarding all; fax transmittal of all to opposing counsel with copies to clients; coordinate hand delivery of same to Magistrate Robb; office conference with JCJensen regarding amending Complaint to add party defendant; clean up conference room following depositions; organize files 887 following same

0.33

150.15 Bartlett/Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 14 of 33
Exhibit 22c, Page 137

2180.01

6/28/2002

38

50

1.9

95.00

Office conference with TRichards regarding two volumes of employment records received from opposing counsel; office conference with MClawson regarding "regarded as" disabled language and exhibits regarding same; print Jury Instructions to be used by JKKillian at settlement conference; locate additional documents, including Order and Confidential Settlement Statement regarding same; office conference with JCJensen regarding amending Complaint; initial preparation of Motion regarding same; research time line and applicable pleadings; copy Complaint for use by JCJensen to delete certain facts; followup office 889 conference with JCJensen regarding same Research authorized agents for additional defendants; initial revisions to Amended Complaint; continued preparation of Motion to Amend Complaint; research 908 various timelines 912 Update voluminous filing Internet search for information on Arch Western Resources, LLC, including agent for service of process 916 (none found in Colorado) 928 Update voluminous filing Review and organize employment records received from Smith Forest Products, Asplundh, and North Fork Ambulance regarding MClawson, JDillon, and TRichards, respectively; Bates label all; revise Index to 930 Disclosures; preparation of Fifth Amended Disclosures Preparation of second request to Beavers Construction for employment records of MClawson and TRichards; notarize releases and print certification forms; forward 935 same to Beavers; update filing

0.25

23.75 T. Richards

2180.01 2180.01

7/2/2002 7/5/2002

38 38

50 50

5.33 0.8

266.50 36.00

0.15 0.5

39.98 15% Reduction Bartlett/Richards/D 18.00 illon

2180.01 2180.01

7/7/2002 7/9/2002

38 38

50 50

4.75 0.8

237.50 40.00

0.15 0.5

35.63 15% Reduction Bartlett/Richards/D 20.00 illon

2180.01

7/10/2002

38

50

1.75

87.50

0.66

T. Richards/J. 57.75 Dillon

2180.01

7/11/2002

38

50

0.5

25.00

0.5

12.50 T. Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 15 of 33
Exhibit 22c, Page 138

2180.01

8/8/2002

38

50

4.9

245.00

2180.01 2180.01

8/15/2002 8/16/2002

38 38

50 50

5.2 0.8

260.00 40.00

Brief review of Def's amended discovery responses; review and index documents produced by opposing counsel; numerous office conferences with JCJensen regarding same and documents located that are beneficial to our claim; numerous office conferences with JRAngel regarding documents produced to date 990 relating MtnCoal to Arch Coal p p conferences with JRAngel regarding intended exhibits; office conference with JRAngel regarding additional allegations to add to Complaint; office conference with JCJensen regarding same; pull and confirm exhibits to 1011 Motion; gather all exhibits; update filing; office Revise supplemental discovery responses of MClawson 1016 and TRichards per JKKillian Review and distribute fax transmittals (two) received from opposing counsel; office conference with JCJensen regarding same; office conference with JKKillian regarding discovery responses and conferral on Amended Complaint; revise all sets of discovery responses per JKKillian; preparation of second requests 1044 (two) for education records of JBartlett

0.15

36.75 15% Reduction

0.15 0.5

39.00 15% Reduction 20.00 T. Richards

2180.01

8/20/2002

38

50

2.4

120.00

0.25

30.00 J.Bartlett

2180.01

9/10/2002

38

50

1.6

72.00

Office conference with JKKillian and JCJensen to review subpoenas and to discuss additional discovery to be propounded; preparation of correspondence to opposing counsel confirming voice mail left with MTuttle; re-docket and calendar deadline to appeal Magistrate's Order; office conferences with JKKillian, JCJensen, and JRAngel regarding same; office conference with JKKillian to review letter to opposing counsel; fax transmittal of same with copies to clients; telephone conference with LRichards regarding 1103 compliance with subpoena to Tri-R Pawn Submit to accounting for payment invoice received from PRenfro for legal research services rendered on behalf of MClawson and JDillon; office conference with 1105 JCJensen regarding same

0.1

7.20 T. Richards

2180.01

9/11/2002

38

50

0.2

10.00

0.5

5.00 Dillon

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 16 of 33
Exhibit 22c, Page 139

2180.01 2180.01 2180.01

9/17/2002 9/24/2002 9/26/2002

38 38 38

50 50 50

0.5 3.2 5.4

25.00 160.00 270.00

Preparation of FedEx packages to clients enclosing 1130 Affidavits (four total) Initial indexing of voluminous documents received from 1164 opposing counsel Continued indexing of recent UNUM documents 1178 disclosed by the def Review disclosed documents and index to same; preparation of correspondence to opposing counsel to 1179 request missing documents 1183 Continued preparation of index to UNUM documents Review correspondence received from opposing counsel regarding missing UNUm documents; confirm receipt of all; update index to include same; update 1193 filing Preparation of task list; left message with JBartlett regarding labor report codes; office conference with JCJensen regarding same; preparation of chart regarding labor codes (partial) of JBartlett; office conference with JKKillian and JCJensen regarding various tasks; calendar followup and next meeting regarding all; update filing; create working file for 1221 JKKillian; organize files following depositions Locate letter of accommodation by JBartlett disclosed by Pls and by Def; preparation of correspondence to opposing counsel attaching both copies; office conference with JKKillian to review all; fax transmittal of correspondence to opposing counsel; office conference with JKKillian to review correspondence to opposing counsel regarding labor report codes; fax transmittal of 1222 same Update filing, including legal research, correspondence, notes, deposition transcripts, pleadings, discovery, and deposition exhibits; update index to deposition exhibit notebooks to include exhibits offered during the 1256 depositions of MRichards, LRichards, and SBartlett

0.75 0.15 0.75

Bartlett/Richards/D 18.75 illon 24.00 15% Reduced Bartlett/Richards/D 202.50 illon Bartlett/Richards/D 28.13 illon Bartlett/Richards/D 18.75 illon

2180.01 2180.01

9/26/2002 9/26/2002

38 38

50 50

0.75 0.5

37.50 25.00

0.75 0.75

2180.01

9/30/2002

38

50

0.8

40.00

0.75

Bartlett/Richards/D 30.00 illon

2180.01

10/2/2002

38

50

4.4

220.00

0.25

55.00 J.Bartlett

2180.01

10/2/2002

38

50

0.4

20.00

0.5

10.00 J.Bartlett

2180.01

10/9/2002

38

50

1.9

95.00

0.5

47.50 Bartlett/Richards

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 17 of 33
Exhibit 22c, Page 140

2180.01

10/15/2002

38

50

2.5

125.00

Fax transmittal of signature page to Motion to Amend Scheduling Order to opposing counsel and to request conformed copy; office conference with JKKillian and RBrennan regarding transmittal of draft reports to clients for their review and comment; preparation of cover correspondence to clients regarding same; followup office conference with JKKillian regarding same (RBrennan to revise reports); review work orders received from opposing counsel; office conference with JBartlett regarding same and regarding current work status; followup office conference with JKKillian and RBrennan regarding same; telephone conference with JBartlett regarding timecards and daily summary sheets; notes to file regarding same; office conference with JKKillian to reschedule meeting with JPrice 1280 (JBartlett missed appointment due to having the flu) Numerous office conferences with DDavis regarding upcoming depositions and documents and charts needed for same; office conference with JKKillian and DDavis regarding potential deposition exhibits; gather same; create witness folders; initial draft of chart 1284 regarding clients' restrictions at various times Office conference with JKKillian regarding intended exhibits for deposition of BShanks; fax transmittal of same to BShanks (73 pages); attend deposition; telephone conference with MDoring to confirm remaining depositions; continued indexing of chart of 1287 clients' restrictions

0.33

41.25 J.Bartlett

2180.01

10/16/2002

38

50

4.8

240.00

0.15

36.00 15% Reduction

2180.01

10/17/2002

38

50

4.8

240.00

0.15

36.00 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 18 of 33
Exhibit 22c, Page 141

2180.01

10/18/2002

38

50

11.8

590.00

Prepare for and attend depositions of DScanlon and SHopper; freshen up conference room for additional depositions; preparation of correspondence to clients regarding re-applying for positions at the mine; preparation of correspondence to opposing counsel to request analysis completed by SHopper; prepare for and attend depositions of MStahl and LTurpin; clean up conference room; organize filing following depositions; office conference with JKKillian regarding results of depositions and to review correspondence to client and opposing counsel; minor revisions to same; transmittal of same to clients via mail and to opposing counsel via facsimile; telephone conference with MClawson regarding results of depositions, witness SJones having moved out of state; and regarding corrections to 1293 supplemental disclosures; notes to file regarding same

0.15

88.50 15% Reduction

2180.01

10/24/2002

38

50

4.4

220.00

Preparation of correspondence to RBrennan enclosing various documents; copy all as enclosures; preparation of supplemental disclosures (tax returns of JDillon; pay stub of MClawson; Tidewater Tech information on JBartlett; and employment records of TRichards); Bates label all; update index to disclosures; office conference with JCJensen regarding all; preparation of correspondence to JBartlett enclosing fax transmittal received from opposing counsel regarding missed appointment of client with defense expert; review 1349 deposition transcript of SBartlett

0.75

Bartlett/Richards/D 165.00 illon

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 19 of 33
Exhibit 22c, Page 142

2180.01

10/29/2002

38

50

2.5

125.00

Numerous office conferences with JKKillian regarding tasks; attempt to contact JBartlett at work (no answer on boss' cell phone); left message with JPrice regarding faxing of documents; locate and copy position descriptions for warehouse position; transmittal of email to opposing counsel requesting position description for surface miner and demand analyses for surface miner and warehouse technician positions; review response received from opposing counsel; print same for review by JKKillian; preparation of correspondence to JPrice regarding all; locate in deposition testimony of MClawson position description for surface operator; revise correspondence to JPrice to include same; followup office conference with JKKillian regarding all; fax transmittal of correspondence and attachments to 1365 JPrice Office conference with JKKillian to review current deadlines; telephone conference with Lori (RBrennan's office) to schedule appointment with JKKillian to review 1378 reports; left message with JPrice same retrieve fax and copy for JKK; office conference with atty regarding: Jane Whalen Price; retrieve documents; telephone call to opposing counsel; e-mail opposing counsel; draft and finalize letter to Ron Brennan; fax letter and documents to Ron Brennan; atty note; revise correspondence from opposing counsel; distribute; distribute motion for costs; distribute minute order; blue slip deadlines; revise motion for costs; office conference 1429 with atty regarding: motion for costs and deadlines copy documents for atty; telephone call from client; office conference with atty regarding: letter from 1431 opposing counsel and motion to compel

0.5

62.50 J.Bartlett

2180.01

10/31/2002

38

50

0.2

10.00

0.5

J. Price (J. 5.00 Bartlett)

2180.01

11/5/2002

38

50

2.1

105.00

0.25

J. Price (J. 26.25 Bartlett)

2180.01

11/8/2002

38

50

0.5

25.00

0.5

12.50 Secretarial tasks

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 20 of 33
Exhibit 22c, Page 143

2180.01

11/7/2002

38

50

2.1

105.00

REview various fax transmittals and documents received from opposing counsel and RBrennan; confirm and calendar blue slips generated by DJenkins; review and distribute draft report of JPrice; numerous telephone conferences with Lori (RBrennan's office) regarding facts and information needed for expert report; office conference with JKKillian regarding same; followup telephone conferences with Lori regarding all; print draft report of EPrice sent by e-mail; various fax transmittals to EPrice of job descriptions and physical demand analyses; review disclosures for additional information and forward same to RBrennan and EPrice via fax; followup office conferences with JKKillian 1456 regarding all Distribute expert reports of Def to clients; preparation of correspondence to RBrennan and JPrice enclosing Def's expert reports and asking for rebuttal reports; copy reports for enclosures; office conference with 1472 JCJensen and JKKillian regarding same; update filing Office conference with JKKillian regarding expert reports submitted by Def and regarding proposing times for depositions; transmittal of correspondence and its 1473 enclosures to RBrennan and JPrice Review recent correspondence to and from opposing counsel; office conference with DDavis regarding status of Motion to Compel; office conference with JRAngel regarding status of Motion for Sanctions and regarding costs motion received from opposing counsel and correspondence related thereto; finalize expert witness 1459 disclosures and gather exhibits to same

0.75

J. Price (J. Bartlett)/Richards/ 78.75 Dillon

2180.01

11/14/2002

38

50

0.9

45.00

0.75

J. Price (J. Bartlett)/Richards/ 33.75 Dillon

2180.01

11/14/2002

38

50

0.6

30.00

0.75

J. Price (J. Bartlett)/Richards/ 22.50 Dillon

2180.01

11/11/2002

38

50

0.8

40.00

0.5

20.00 J.Bartlett

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 21 of 33
Exhibit 22c, Page 144

2180.01

12/11/2002

38

50

1.33

66.50

Telephone conference with TRichards regarding status of claim; office conference with JKKillian and JCJensen regarding same and regarding need for group meeting with clients; additional revisions to draft Motion to Compel per JKKillian; fax transmittal of same to opposing counsel with copy of all to clients; office conference with DDavis regarding same and regarding additional revisions needed, including cite to page 1601 number and line in deposition testimony Office conference with DDavis regarding names of possible supervisors or others in management; research names of those provided on medical records; review deposition of LTurpin regarding same; followup office conference with DDavis regarding all; review employment records of JBartlett and MClawson for additional names of supervisors; telephone conference with MClawson regarding same and regarding potential 1651 employment at Bowie Mine Preparation of correspondence to RBrennan and JPrice scheduling meeting with JKKillian to review rebuttal 1677 reports Revise deadlines sheet; left message with Lori (RBrennan's office) regarding scheduled deposition; preparation of correspondence to RBrennan and 1695 JPRice regarding scheduled depositions

0.25

16.63 T. Richards

2180.01

12/31/2002

38

50

2.5

125.00

0.25

31.25 J.Bartlett J. Price (J. 4.50 Bartlett)

2180.01

1/3/2003

38

50

0.2

9.00

0.5

2180.01

1/10/2003

38

50

0.5

25.00

0.5

J. Price (J. 12.50 Bartlett)

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 22 of 33
Exhibit 22c, Page 145

2180.01

1/14/2003

38

50

3.2

160.00

Review and distribute correspondence received from opposing counsel (two); preparation of correspondence to opposing counsel regarding documents subpoenaed from JDarnell; organize amended discovery responses received from opposing counsel; brief overview of same and attached disclosure of documents; preparation of correspondence to opposing counsel requesting Notices of Deposition for RBrennan and JPrice; numerous office conferences with JKKillian regarding upcoming depositions and regarding rebuttal reports needed from experts; brief review of Response to Motion to Strike received from opposing counsel; office conference with JRAngel regarding same; review discovery received from opposing counsel; office conference with DDavis regarding same; distribute 1748 same Prepare for and attend conference with Magistrate Robb; organize tasks following same; office conference with DDavis regarding assigned tasks; gather necessary documents regarding same; telephone conference with MClawson regarding employment options; telephone conference with clients regarding scheduled settlement conference; preparation of correspondence to clients regarding same; left message with JPrice regarding her scheduled deposition; office conference with NBingaman regarding same; telephone conference with JPrice regarding her unavailability on deposition date; preparation of correspondence to opposing counsel regarding same; calendar and tickler deadlines for response to motion to depose RBrennan, motion to compel, update to confidential settlement statement, and settlement conference; office conferences with attorneys regarding all; office conference with DDavis to confirm meetings scheduled with JKKillian regarding all; review file of JDarnell received from opposing counsel; organize same; telephone conference with opposing counsel regarding his desire to speak with

0.15

24.00 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 23 of 33
Exhibit 22c, Page 146

2180.01

1/17/2003

38

50

7.2

360.00

JKKillian; note to JKKillian regarding same; fax transmittal of correspondence to opposing counsel regarding non-retained doctors and regarding unavailability of JPrice for her scheduled deposition; transmittal of correspondence to clients regarding the parties' scheduled settlement conference; review notes to confirm all deadlines on calendar; office conference with DDavis regarding same; review fax transmittal received from opposing counsel regarding proposing 1762 deposition dates for JPrice; distribute same Telephone conference with MClawson regarding employment options; telephone conferences (two) with JPrice regarding status of her rebuttal report and regarding re-scheduling of her deposition; revise correspondence to JPrice per JKKillian; fax transmittal of same; review position descriptions recently disclosed by opposing counsel; review rebuttal expert witness 1785 disclosures for language used regarding JPrice Review and distribute Fourth Amended Answers to Interrogatories received from opposing counsel; office conference with DDavis regarding same; calendar followup on receipt of JDonner medical records on 1849 JBartlett Numerous office conferences with JKKillian to finalize rebuttal expert witness disclosures; telephone conferences with Lori (RBrennan's office) regarding same; attempt to contact JPrice regarding her report; finalize disclosures; office conference with JKKillian regarding same; coordinate service of disclosures with 1846 numerous exhibits to same

0.4

144.00

J. Price (J. Bartlett)/15% Reduction for Block Billing

2180.01

1/23/2003

38

45

1.1

49.50

0.5

J. Price (J. 24.75 Bartlett)

2180.01

1/28/2003

38

50

0.5

25.00

0.5

12.50 J. Bartlett

2180.01

1/27/2003

38

50

2.4

120.00

0.15

18.00 15% Reduction

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 24 of 33
Exhibit 22c, Page 147

2180.01

1/31/2003

38

50

1.4

70.00

2180.01

2/6/2003

38

50

0.5

25.00

Telephone conference with Lori (RBrennan's office) regarding Def's rebuttal disclosures and working file of JDarnell; preparation of correspondence to RBrennan and JPrice enclosing Def's rebuttal disclosures; distribute same to clients; office conference with JCJensen regarding same; transmittal of all; update filing, including discovery binder and expert witness 1882 binders Preparation of correspondence to RBrennan and JPrice enclosing copy of deposition of JDarnell; copy same with enclosure to clients; transmittal of all following 1914 office conference with JCJensen Preparation of correspondence to experts enclosing working file of JDarnell; preparation of dividers; copy enclosures to letters; transmittal of all; review and revise amended expert witness disclosures; office conference with JCJensen and DDavis regarding same; office conference with JKKillian to review various deadlines and dates for upcoming depositions; office conference with JKKillian regarding the deadline for the parties' proposed Pretrial Order and assignment of same; review medical records of JBartlett contained in worker's compensation file; research correct telephone number for MJanssen; telephone conference with records custodian to request medical records of 1922 JBartlett Continued review and revisions to expert witness disclosures; review medical records of MClawson; 1923 partial review of medical records of JDillon Continued revisions to amended expert witness disclosures; continued review of medical records of JDillon; review of medical records of TRichards; telephone conference with MClawson regarding 1927 employment issues

0.25

J. Price (J. 17.50 Bartlett)

0.5

J. Price (J. 12.50 Bartlett)

2180.01

2/10/2003

38

50

4.5

225.00

0.4

J.Bartlett/15% Reduction Block 90.00 Billing

2180.01

2/10/2003

38

50

2.8

140.00

0.33

46.20 Dillon T. Richards/ Dillon/ 15% Reduction Block 191.25 Billing

2180.01

2/11/2003

38

50

5.1

255.00

0.75

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 25 of 33
Exhibit 22c, Page 148

2180.01

2/11/2003

38

50

0.2

9.00

Office conference with JKKillian and JCJensen regarding firm policy for accepting service for retained experts; office conference with JKKillian regarding same and regarding subpoenas received from RBrennan and JPrice; office conference with JCJensen regarding 1928 potential assignment of proposed Pretrial Order Brief review of fax transmittal received from opposing counsel and attached subpoenas for RBrennan and 1930 JPrice Review e-mail transmittals between JKKillian and opposing counsel regarding postponing of settlement conference and RBrennan's deposition; office conference with JCJensen regarding same; office conference with DDavis regarding same and regarding appointment with JKKillian to review expert witness disclosures; telephone conference with Lori (RBrennan's office ) regarding status of depositions; review and distribute e-mail received from opposing counsel attaching draft Motion to Continue Settlement Conference; brief review of same; followup office conference with DDavis regarding subpoenaed items 1934 from RBrennan and JPrice

0.5

J. Price (J. 4.50 Bartlett) J. Price (J. 7.20 Bartlett)

2180.01

2/11/2003

38

50

0.33

14.40

0.5

2180.01

2/12/2003

38

50

1.1

55.00

0.1

J. Price (J. 5.50 Bartlett)

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 26 of 33
Exhibit 22c, Page 149

Office conference with JKKillian and JCJensen regarding a potential Motion to Quash, postponing of the parties' settlement conference, and language of nonretained expert disclosures; sit in on JKKillian's telephone conference with opposing counsel regarding continuing the settlement conference; preparation of correspondence to opposing counsel regarding the subpoenas of RBrennan and JPrice and Pls' objections to same; numerous office conferences with JCJensen regarding same; office conference with JKKillian regarding same; followup office conference with JCJensen regarding approval of correspondence by JKKillian; office conference with DDavis regarding postponed meeting with JKKillian to review expert witness disclosures; telephone conference with JBartlett regarding an employee of MtnCoal transferred recently to Arch in Utah; office conference with JCJensen regarding same; note to JCJensen to return call of JBartlett regarding ADA qualifications; finalize expert witness disclosures per JKKillian and JCJensen; coordinate distribution of same; copy correspondence to opposing counsel and related subpoenas to RBrennan and JPrice; office conference with DDavis regarding status of tasks; update deadlines sheet; copy same to 1935 JKKillian, JCJensen, DDavis, and file Update filing; telephone conference with RBrennan and left message with JPrice regarding subpoenaed items; telephone conference with MClawson regarding 1939 employment issues

2180.01

2/12/2003

38

50

6.6

330.00

0.33

108.90 J.Bartlett

2180.01

2/13/2003

38

50

0.9

45.00

0.5

22.50 J.Bartlett

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 27 of 33
Exhibit 22c, Page 150

2180.01

2/18/2003

38

50

1.33

66.50

Office conference with JCJensen regarding recent correspondence to and conversation with opposing counsel and regarding response needed to opposing counsel regarding expert witness disclosures; preparation of correspondence to opposing counsel regarding same and extension requested per JCJensen; review additional fax transmittals (two) received from opposing counsel; office conference with JCJensen regarding same; copy same to JKKillian; telephone conference with JPrice regarding her deposition subpoena; office conference with JCJensen regarding same and regarding working file of JDarnell; office conference with JRAngel regarding documents given to RBrennan but not noted in the witness folder; 1942 locate some and copy same to witness folder Review and revise Confidential Settlement Statement per JCJensen; office conference with JCJensen regarding summary of damages; review claims for relief against working Complaint; office conference with JKKillian to schedule meeting to review Confidential Settlement Statement and amended disclosures; office conference with JCJensen regarding same and her 1943 availability for meetings with JKKillian requesting extension on expert witness disclosures; telephone conference with JBartlett regarding potential witness in EMP case and regarding medical status for 1944 WC case; review correspondence received from

0.25

J. Price (J. 16.63 Bartlett)

2180.01

2/18/2003

38

50

1.6

80.00

0.5

40.00 Bartlett/Richards

2180.01

2/18/2003

38

50

1.1

55.00

0.5

27.50 J.Bartlett

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 28 of 33
Exhibit 22c, Page 151

2180.01

2/18/2003

38

50

1

50.00

Review hard copies of various correspondence to confirm their reception via fax; review and distribute Motion to Continue Settlement Conference; note to file regarding same; telephone conference with RBrennan regarding status of production of his working file; office conference with JCJensen regarding same; transmittal of correspondence to MClawson regarding missing work for settlement conference; office conference with JCJensen and JKKillian regarding MClawson's acceptance of recent employment offer; telephone conference with LRichards regarding status of 1945 settlement conference Attend conference all with Magistrate Robb, opposing counsel, JKKillian, and JCJensen; calendar and tickler deadlines from same; telephone conference with opposing counsel regarding receipt of working file of JPrice; telephone conference with JPrice regarding same and regarding additional documents to be picked up by courier for delivery to opposing counsel; followup telephone conference with opposing counsel regarding 1965 same

0.25

12.50 T. Richards

2180.01

2/24/2003

38

50

1.1

55.00

0.5

J. Price (J. 27.50 Bartlett)

2180.01

2/24/2003

38

50

1.4

70.00

Finalize Pls' reply brief per JKKillian; office conference with DDavis regarding same; preparation of correspondence to opposing counsel per JCJensen regarding Pls' rebuttal expert witness disclosures; fax transmittal of same to opposing counsel with copies to clients; coordinate filing and service of reply brief; hand delivery of same to Magistrate Robb; revise Certificate of Compliance per JCJensen; office conference with JKKillian regarding same; coordinate filing and service of same, including hand delivery of courtesy copy to Magistrate Robb; telephone conferences with LRichards and JDillon and left message with MClawson and JBartlett regarding scheduling of the parties' settlement 1969 conference

0.75

Bartlett/Richards/D 52.50 illon

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 29 of 33
Exhibit 22c, Page 152

2180.01

2/24/2003

38

50

0.5

25.00

Review and distribute Order received from the Court regarding scheduling of the Settlement Conference; preparation of correspondence to client regarding same; office conference with JCJensen regarding same; transmittal of same to clients; followup telephone conference with JDillon regarding employment issues; note to file regarding same; telephone conference with JCJensen regarding same; telephone conference with MClawson regarding letter needed to employer to miss work to attend conference; preparation of same; office conference with JCJensen regarding same; transmittal 1970 of same to MClawson with a copy to his employer Office conference with JKKillian regarding tasks following deposition of RBrennan; update working notebook of JKKillian with rebuttal reports of all witnesses; copy case law given to RBrennan into his witness folder; fax transmittal of same to JPrice; update 2026 filing Update deposition exhibit notebooks and index to same following deposition of PAnctil; copy 2002 tax returns of JBartlett and return originals to client with cover 2078 correspondence Office conferences with clients prior to settlement conference; distribute Motion for Additional Time to Conclude Deposition of RBrennan; office conference with JCJensen regarding same; office conference with JBartlett regarding surveillance video; gather 2081 documents needed for settlement conference Left message with JPrice and RBrennan to request any corrections to their depositions; left messages with court reporters in Grand Junction and Denver regarding 2169 same

0.5

12.50 Dillon

2180.01

2/26/2003

38

50

1

50.00

0.1

J. Price (J. 5.00 Bartlett)

2180.01

3/11/2003

38

50

0.8

36.00

0.5

18.00 J. Bartlett

2180.01

3/12/2003

38

50

0.8

36.00

0.5

18.00 J. Bartlett

2180.01

4/9/2003

38

50

0.4

20.00

0.5

J. Price (J. 10.00 Bartlett)

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 30 of 33
Exhibit 22c, Page 153

2180.01

4/16/2003

38

50

3.75

187.50

Research local rules for deadline to respond to motions for summary judgment; e-mail BThreatt regarding same and regarding extension to be requested; office conference with JCJensen regarding same; review and distribute Motions for Summary Judgment (five) and voluminous attachments; telephone conference with BThreatt regarding basics of Pls' claims; travel to post 2186 office Copy JKKillian's calendar for attachment to letter to opposing counsel; fax transmittal of same with copies to clients; revise correspondence to opposing counsel regarding transfer issue per JCJensen; telephone 2196 conference with JBartlett regarding status Office conference with JKKillian regarding drafting a response to opposing counsel regarding available dates 2332 for depositions of PAnctil and JPrice Preparation of supplemental expert witness disclosures (amended reports of RBrennan); preparation of correspondence to opposing counsel regarding availability in June for depositions of PAnctil and JPrice; office conference with JKKillian regarding both; fax transmittal of correspondence to opposing counsel; coordinate copying of supplemental disclosures; office conference with JKKillian regarding exhibits to same 2333 (waiting for receipt of same from RBrennan) Office conference with JKKillian regarding depositions of JPrice and PAnctil, and regarding motion for 2416 extension on response briefs

0.15

28.13 15% Reduction

2180.01

4/21/2003

38

50

2.75

122.40

0.25

30.60 J. Bartlett

2180.01

5/23/2003

38

50

0.1

5.00

0.5

J. Price (J. 2.50 Bartlett)

2180.01

5/23/2003

38

50

0.6

30.00

0.5

J. Price (J. 15.00 Bartlett) J. Price (J. 10.00 Bartlett)

2180.01

6/3/2003

38

50

0.4

20.00

0.5

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 31 of 33
Exhibit 22c, Page 154

2180.01

6/5/2003

38

50

1.9

95.00

Telephone conference with BThreatt regarding recent emails; office conference with DDavis regarding same; email transmittal (second attempt) to BThreatt of the index to deposition exhibits; fax transmittal of documents to BThreatt per her request; review and distribute correspondence (two) received from opposing counsel; review and distribute Response to Objection to Magistrate's Order; calendar and tickler deadline for reply to same; preparation of e-mail transmittal to opposing counsel requesting amended Notice of Deposition to correct deposition date of JPrice; preparation of correspondence to JPrice enclosing copy of Notice of Deposition and Subpoena; transmittal of same with copies to clients; office conference with DDavis regarding status of response briefs to motions 2427 for summary judgment Revise exhibit list and facts section of response brief of MClawson per instructions from BThreatt; review and respond to numerous e-mail transmittals received from BThreatt; numerous office conferences with DDavis regarding briefs and exhibits to same; finalize exhibit list to brief of MClawson; gather and copy all exhibits to same; telephone conferences with LRichards and 2630 TDillon regarding affidavits needed Attend to numerous e-mail transmittals received from BThreatt regarding response briefs of MClawson, 2632 JDillon, and TRichards Continued preparation of Affidavit of MClawson, response briefs of MClawson, TRichards, and JDillon, and exhibits to all; numerous office conferences with DDavis regarding same; numerous e-mail transmittals and fax transmittals to BThreatt regarding exhibits to 2633 response briefs

0.25

J. Price (J. 23.75 Bartlett)

2180.01

6/12/2003

38

50

5.75

287.50

0.25

71.88 T. Richards/Dillon

2180.01

6/13/2003

38

50

0.6

30.00

0.66

19.80 T. Richards/Dillon

2180.01

6/13/2003

38

50

5.8

290.00

0.75

T. Richards/ Dillon/ 15% Reduction Block 217.50 Billing

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 32 of 33
Exhibit 22c, Page 155

2180.01

6/15/2003

38

50

11.5

575.00

Preparation of exhibit list, affidavit, and response to motion for summary judgment regarding JDillon; telephone conference with JDillon regarding content of his affidavit; numerous e-mail transmittals to and from BThreatt regarding exhibits; numerous telephone conferences with BThreatt regarding language of affidavits; numerous fax transmittals to BThreatt of potential exhibits; office conference with JKKillian regarding all; finalize exhibits and responses for 2635 MClawson and TRichards Finalize briefs, responses, affidavits, and exhibits for MClawson, TRichards, and JDillon; coordinate filing and 2636 service of all Office conference with JKKillian regarding continued depositions of RBrennan, JPrice, and PAnctil; preparation of correspondence to opposing counsel regarding same; followup office conference with JKKillian regarding same; fax transmittal of correspondence to opposing counsel declining 2638 additional testimony from PAnctil Office conference with JCJensen regarding Motion to Compel filed by opposing counsel; cleanup Bartlett brief 2656 and print same for review by JKKillian Office conference with DDavis regarding status of briefs; office conference with JKKillian regarding same; preparation of Affidavit of JPrice; note to JKKillian regarding same; revise Objection to Magistrate's Order 2657 (regarding JDonner) prepared by JRAngel Finalize response brief and response to motion (integrated enterprise); coordinate filing and service of same; finalize response brief and response to motion (Bartlett); locate and copy all exhibits to same; update index of exhibits; coordinate filing and service of all; 2669 respond to numerous e-mail transmittals of BThreatt

0.75

2180.01

6/16/2003

38

50

6.6

330.00

0.75

T. Richards/ Dillon/ 15% Reduction Block 431.25 Billing T. Richards/ Dillon/ 15% Reduction Block 247.50 Billing

2180.01

6/23/2003

38

50

0.6

30.00

0.33

J. Price (J. 9.90 Bartlett)

2180.01

7/1/2003

38

50

1.33

59.40

0.5

29.70 J. Bartlett

2180.01

7/1/2003

38

50

5.5

248.40

0.4

J. Price (J. Bartlett)/15% Reduction for 99.36 Block Billing

2180.01

7/3/2003

38

50

7.5

375.00

0.4

J. Bartlett/15% Reduction Block 150.00 Billing

Case 1:01-cv-02199-MSK-MEH

Document 464-25
Killian Guthro Jensen, PC Clawson Fees

Filed 04/10/2007

Page 33 of 33
Exhibit 22c, Page 156

2180.01 2180.01

4/20/2004 4/21/2004

38 38

50 50

3.4 2.6 201.2

170.00 130.00

Preparation of Index to Appendix; left messages with JBartlett, MClawson, and TRichards regarding belt issue; telephone conference with BThreatt regarding same; attend to numerous e-mail transmittals to and 3169 from BThreatt; continued consolidation of response Locate and copy voluminous exhibits to response brief; 3170 revise index to same Total Reductions to Billing

0.15 0.15

25.50 15% Reduction 19.50 15% Reduction $ 10,060.72

Total Hours Reduced