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

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 1 of 35
Exhibit 22b, Page 90

TONETTE SOUTHERN BILLING RECORDS (Deleted) Client Date Tkr Rate Hours Total
2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 10/17/2000 10/18/2000 11/10/2000 12/6/2000 12/20/2000 2/16/2001 38 38 38 38 38 38 50 50 50 45 45 50 0.4 2 2 1.2 0.4 0.33 20.00 100.00 100.00 54.00 18.00 16.50

REF#

Description

2180.01 2180.01

3/7/2001 3/13/2001

38 38

50 50

0.2 0.33

10.00 16.50

2180.01 2180.01 2180.01 2180.01

3/14/2001 3/19/2001 3/19/2001 3/27/2001

38 38 38 38

50 45 45 50

0.5 0.2 0.4 0.2

25.00 9.00 18.00 10.00

74 Review task form and locate addresses for Messrs. Dillon and Morford Preparation of correspondence to Messrs. Dillon and Morford regarding potential 75 claims; cleanup file directory and file Research for right to sue request form; preparation of form letter; preparation of 78 correspondence to CCRD and EEOC requesting right to sue Update filing; telephone conference with Stacie Bartlett to have her husband return the 86 call (need name of warehouse worker) Telephone conference with John Barlett to obtain name of witness (can't remember 88 and will call back) 102 Locate client information on JDillon and TRichards for accounting department Telephone conference with Stacie (CCRD) regarding obtaining Charge of Discrimination filed by JBartlett and opposing counsel's position statement, and 107 regarding filing of Entry of Appearance on JDillon Preparation of Entry of Appearance (JDillon) per LMNeff; telephone conference with 112 Stacie (CCRD) regarding same Review Motion for Extension received from the CCRD regarding JDillon; office conference with LMNeff to execute same; calendar and tickler new deadline; fax 114 transmittal of Motion to the CCRD Calendar and tickler reply date (TRichards); office conference with JCJensen 117 regarding same Preparation of fee agreement relative to TRichards; office conference with JCJensen 116 to meet client and execute fee agreement Telephone conference with Stacey (CCRD) regarding right-to-sue letters for TRichards 118 and JDillon; calendar request date Review documents received from JBartlett; distribute same; update file with client's 119 new address; note to LMNeff regarding attachments to position statement of Arch Coal 121 Preparation of right-to-sue letters for JDillon and TRichards Telephone conference with Stacie (CCRD) regarding right-to-sue letter on JDillon; fax 122 transmittal of same to the CCRD Revise Status Report per LMNeff; research Rules on filing of service of process; incorporate CCRD deadlines into the Status Report; calculate date to request right-to124 sue letter on JBartlett; calendar and tickler same; office conference with LMNeff regard 136 Preparation of Affidavit of TRichards per JCJensen Revise Affidavit of TRichards per JCJensen; research notes to incorporate additional 141 facts

2180.01 2180.01 2180.01

4/8/2001 4/11/2001 4/12/2001

38 38 38

45 50 50

0.33 0.2 0.2

14.85 10.00 10.00

2180.01 2180.01 2180.01

4/13/2001 5/8/2001 5/9/2001

38 38 38

45 45 45

1.4 0.5 0.9

63.00 22.50 40.50

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 2 of 35
Exhibit 22b, Page 91

2180.01 2180.01

5/14/2001 5/14/2001

38 38

50 45

1.5 0.2

75.00 9.00

Review and distribute surveillance report on TRichards; office conference with JCJensen regarding right-to-sue letters for JDillon and TRichards; Telephone conference with the CCRD regarding same; calendar client meeting and case status meeting; left message with the EEOC regarding right-to-sue letters for JDillon and TRichards; preparation of correspondence to the EEOC regarding issuing of right-tosue letter on JBartlett prior to 180-day expiration date; review files for additional 142 deadlines Office conference with TRichards to review Affidavit; minor revisions to same; office 143 conference with JKKillian regarding review of same Telephone conference with Stacie (CCRD) regarding her request for copy of letter to 148 EEOC for right-to-sue letter on JBartlett; fax transmittal of same to the CCRD Telephone conference with Stacie (CCRD) regarding right-to-sue letter for John Bartlett; preparation of same; pull file for Charge number and fax transmittal of same 147 to the CCRD Review and distribute Notice of Case Status; preparation of Status Report to the Court; update filing; preparation of correspondence to JBartlett regarding right-to-sue 158 letter from the EEOC (not received to date); calculate, tickler and calendar deadlines 161 Telephone conference with Odessa (EEOC) regarding TRichards (use 05/25/01 date) 171 Update filing Review and distribute right-to-sue letter received from the CCRD regarding JDillon; calendar statute of limitations date; office conference with JCJensen regarding same; left message with Odessa (EEOC) regarding right-to-sue letters for JDillon and 173 JBartlett Telephone conference with Odessa regarding EEOC right-to-sue letters for JBartlett 174 (will fax) and JDillon (not issued to date) 184 Update filing 199 Copy to JKKillian correspondence to JDillon regarding filing of Complaint; update filing 200 Update filing 201 Update filing Office conference with JBartlett and LMNeff; copy client's tax returns; preparation of 213 Release package 218 Update filing Office conference with JCJensen regarding medical records of clients and regarding 225 JBartlett Amended Complaint; calendar followup with LMNeff regarding same

2180.01

5/17/2001

38

45

0.33

14.85

2180.01

5/17/2001

38

45

0.33

14.85

2180.01 2180.01 2180.01

6/21/2001 6/21/2001 6/28/2001

38 38 38

50 45 50

1.8 0.1 0.2

90.00 4.50 10.00

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

6/29/2001 6/29/2001 7/2/2001 7/11/2001 7/11/2001 7/16/2001 7/26/2001 7/28/2001

38 38 38 38 38 38 38 38

50 50 45 50 45 45 45 45

0.33 0.1 0.33 0.2 0.1 0.1 0.5 0.9

16.50 5.00 14.85 10.00 4.50 4.50 22.50 40.50

2180.01

8/10/2001

38

45

0.33

14.85

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 3 of 35
Exhibit 22b, Page 92

2180.01

8/13/2001

38

45

0.4

18.00

Telephone conference with JBartlett regarding next appointment, right-to-sue letters received, and client's current address; note to file regarding same; note to JCJensen regarding next client meeting; office conference with JKKillian and JCJensen to 226 schedule client meeting and meeting to discuss JBartlett Amended Complaint Office conference with LMNeff regarding JBartlett Complaint; revise and print same for review by JKKillian and JCJensen; review Complaint; calendar appointment to review same; calendar next client meeting; preparation of correspondence to clients regarding same; left message with JBartlett regarding next client meeting and his 227 attendance by telephone; transmittal of correspondence to clients and update filing Telephone conference with TRichards regarding upcoming client meeting (to call in); office conference with JCJensen regarding same; return call to TRichards regarding 229 holding telephone conference as opposed to in-house client meeting Telephone conference with JBartlett's father-in-law to obtain client's current address; revise Amended Complaint to include same; update files and accounting; Internet search for zip code information on Hampton, Virginia; update labels, including file cover; preparation of correspondence to the Clerk's office and coordinate filing of 233 Amended Complaint with copies to clients; update filing Telephone conference with JBartlett regarding correct address (misgiven by father-in234 law); correct same in system; copy and re-send Amended Complaint to client 240 Update filing Office conference with JCJensen regarding new telephone number for JBartlett; 244 update file and accounting with new information 253 Update filing Telephone conference with JBartlett to discuss revisions to Amended Complaint and to obtain current address; office conference with JCJensen regarding same; revise 255 Amended Complaint 257 Update filing 262 Update filing Telephone conference with JBartlett regarding upcoming functional capacity 269 evaluation Left message with JBartlett regarding functional capacity evaluation; office conference 270 with JCJensen regarding same; note to file regarding same; update filing 271 Update filing

2180.01

8/14/2001

38

45

1.2

54.00

2180.01

8/15/2001

38

45

0.33

14.85

2180.01

8/28/2001

38

45

0.9

40.50

2180.01 2180.01 2180.01 2180.01

8/29/2001 8/30/2001 9/7/2001 9/24/2001

38 38 38 38

45 45 45 45

0.6 0.1 0.2 0.1

27.00 4.50 9.00 4.50

2180.01 2180.01 2180.01 2180.01

9/25/2001 10/12/2001 11/6/2001 11/26/2001

38 38 38 38

45 45 45 45

0.33 0.2 0.8 0.2

14.85 9.00 36.00 9.00

2180.01 2180.01

11/27/2001 11/27/2001

38 38

45 45

0.2 0.1

9.00 4.50

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 4 of 35
Exhibit 22b, Page 93

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

12/31/2001 1/10/2002 1/15/2002 2/5/2002 2/11/2002 2/19/2002 2/20/2002

38 38 38 38 38 38 38

45 45 45 45 45 50 45

0.1 0.1 0.1 0.5 0.1 0.2 0.8

4.50 4.50 4.50 22.50 4.50 10.00 36.00

279 298 301 351 364 384 385

2180.01

2/21/2002

38

50

1.4

70.00

390

Telephone conference with LRichards regarding status of claim and upcoming Scheduling Conference Update filing Update filing Update filing Office conference with JCJensen regarding disability form on JBartlett from Dr. Wong (not received) Brief review of medical records of JDillon received from RFox; submit invoice for same to accounting for payment Telephone conference with SBartlett to review discovery propounded by opposing counsel Office conference with JKKillian, JCJensen, and the Richards regarding deposition preparation; copy Motion for Summary Judgment in Visconti case for review by clients prior to depositions; brief review of same; preparation of correspondence to client enclosing same with explanation Revise Motion to Reschedule Scheduling Conference per JCJensen; minor revision to correspondence to clients enclosing Motion for Summary Judgment in Visconti case; copy W2s received from JDillon and return originals to him; coordinate filing and service of Motion and transmittal of correspondence to clients Copy medical records of Pls for review by PRenfro, together with the Pls' personnel files, tax returns, and other documents; revise index to same to include medical providers Telephone conference with TDillon to discuss discovery responses; pull file to review same with her Telephone conference with Adair (North Fork Medical Clinic) regarding requested medical records of JDillon (to send from 1999 forward) Initial preparation of discovery responses pertaining to TRichards; office conference with JKKillian regarding recent Order rescheduling Scheduling Conference; numerous office conferences with JKKillian and JCJensen and telephone conferences with opposing

2180.01

2/21/2002

38

50

0.8

40.00

392

2180.01 2180.01 2180.01

2/25/2002 2/25/2002 2/27/2002

38 38 38

50 50 50

3.8 0.4 0.1

190.00 20.00 5.00

397 398 404

2180.01 2180.01

2/27/2002 3/1/2002

38 38

45 50

3.6 0.1

162.00 5.00

405

414 Submit to accounting invoice received from St. Mary's for medical records of JDillon Office conference with JKKillian regarding his conversation with SBartlett; review notes 416 regarding same; followup conversation with JKKillian regarding same Continued preparation of discovery responses of TRichards; office conference with 417 JCJensen regarding same

2180.01 2180.01

2/28/2002 2/28/2002

38 38

45 45

0.5 1.75

22.50 78.75

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 5 of 35
Exhibit 22b, Page 94

2180.01

3/5/2002

38

50

1.1

55.00

Organize medical records for production to opposing counsel; initial preparation of 458 disclosed documents Revise discovery responses of TRichards per JCJensen; pull worker's compensation 463 file for amounts paid from ESIS/CIGNA; office conference with CFeltz regarding same Review and organize documents received from JBartlett; supplement disclosures 470 regarding same; continued preparation of disclosures and discovery responses Preparation of FedEx package to JBartlett to return documents, including original tax 473 returns; left message with TRichards to obtain street address Update filing; review notice received from the Internal Revenue Service regarding back returns of JBartlett; forward same to accounting; office conference with NBingaman 475 regarding same Review medical records of JBartlett received from BMixter; update disclosures and discovery responses regarding same; submit invoice to accounting for payment of copy charges; office conference with JCJensen regarding production of disclosures and regarding discovery responses; print same (four sets) for review by JCJensen; 476 copy voluminous disclosures to opposing counsel; preparation of List of Disclosures Transmittal of supplemental disclosure pleading to clients; office conference with JKKillian regarding his continued review of discovery responses; office conference with JCJensen regarding discovery responses; left message with MClawson to return call; telephone conference with JDillon regarding work history and various sources of income; continued revisions to discovery responses; review and distribute Order received from the Court setting the Scheduling Conference; distribute correspondence received from opposing counsel reserving deposition dates; calendar and tickler Scheduling Conference Telephone conference with LRichards regarding client's work history and sources of income; revise discovery responses regarding same Revise discovery responses of JBartlett per JKKillian; office conference with JCJensen regarding same Office conference with JCJensen regarding time following the settlement conference to be used for deposition preparation (BARTLETT) Update filing

2180.01

3/6/2002

38

45

0.6

27.00

2180.01 2180.01

3/7/2002 3/11/2002

38 38

45 45

7.1 0.33

319.50 14.85

2180.01

3/11/2002

38

45

0.33

14.85

2180.01

3/11/2002

38

45

4.33

194.85

2180.01 2180.01 2180.01 2180.01 2180.01

3/12/2002 3/12/2002 3/12/2002 3/13/2002 3/14/2002

38 38 38 38 38

50 45 45 45 45

3.4 0.5 1.9 0.33 0.6

170.00 22.50 85.50 14.85 27.00

478 479 481 489 490

2180.01

3/14/2002

38

50

0.5

23.40

Telephone conference with LRichards regarding two mistakes in discovery responses; correct same; preparation of supplemental disclosure to correct telephone number for JDillon; telephone conference with opposing counsel regarding all; preparation of e492 mail to opposing counsel regarding conversation; update filing

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 6 of 35
Exhibit 22b, Page 95

2180.01 2180.01

3/15/2002 3/20/2002

38 38

45 45

0.5 0.2

22.50 9.00

2180.01

3/20/2002

38

45

2.9

130.50

493 Initial review of medical records from RMOrtho on JBartlett 505 Update filing Telephone conference with LRichards regarding upcoming meeting date; initial preparation of index of Def's disclosed documents; forward recent e-mail to opposing 506 counsel to TRichards Submit to accounting invoices (two) received from DeltaPT for medicals records of JBartlett and JDillon; update disclosure index and print same for opposing counsel; organize medical records and Bates same; revise supplemental disclosures; preparation of correspondence to opposing counsel regarding same and enclosing call; update filing, including notebooks of disclosed documents; transmittal of 508 correspondence with enclosures to opposing counsel Submit to accounting invoice received from TWorks for medical records of TRichards; organize same; preparation of correspondence to opposing counsel to enclose same; label records; update supplemental disclosures and index of disclosed documents; copy all to opposing counsel; transmittal of same; update filing Note to JCJensen regarding letters to JBartlett's school and employer regarding time to be missed transcribe letter to opposing counsel regarding: deposition dates Preparation of correspondence to JBartlett regarding deposition schedule and time to be missed from work and school Revise correspondence to JBartlett per JCJensen regarding missed time from school and work for his deposition; transmittal of same Update filing Preparation of correspondence to JBartlett regarding missed time from work and school to attend Scheduling Conference; office conference with JCJensen regarding same; office conference with JKKillian to review subpoena for DKazlauskas; copy same to proces

2180.01

3/20/2002

38

50

1.9

86.40

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

3/22/2002 3/22/2002 3/8/2002 3/27/2002 3/27/2002 4/2/2002

38 38 38 38 38 38

45 45 50 45 45 45

1.33 0.1 0.24 0.33 0.1 0.33

59.85 4.50 12.00 14.85 4.50 14.85

510 513 521 533 535 572

2180.01

4/3/2002

38

50

0.4

20.00

575

2180.01

4/3/2002

38

50

0.4

20.00

2180.01 2180.01

4/3/2002 4/3/2002

38 38

45 45

0.5 0.33

23.40 14.85

Telephone conference with Peninsula Emergency Physicians regarding Emergency Room visit of JBartlett; telephone conference with Sentera Hampton General Hospital regarding same; preparation of correspondence to Sentera to request medical 576 records; preparation of Certification forms; notarize release; transmittal of all Review flight arrangements made for JBartlett; review Scheduling Order deadlines and schedule for appointments with experts; left message with Lori (RBrennan's office) regarding availability for a vocational assessment of JBartlett following the settlement 577 conference; consider alternate dates 578 Update filing

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 7 of 35
Exhibit 22b, Page 96

2180.01 2180.01 2180.01

4/3/2002 4/3/2002 4/9/2002

38 38 38

45 45 45

0.1 0.2 0.2

4.50 9.00 9.00

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

4/16/2002 4/16/2002 4/19/2002 4/24/2002 4/25/2002 4/26/2002

38 38 38 38 38 38

45 45 45 45 45 45

0.4 0.33 0.1 0.4 0.5 2.1

18.00 14.85 4.50 18.00 22.50 94.50

2180.01 2180.01 2180.01

4/29/2002 5/1/2002 5/2/2002

38 38 38

45 45 50

0.8 0.4 1.33

36.00 18.00 66.50

Transmittal of correspondence to JBartlett regarding time to be missed to attend 579 Scheduling Conference; update filing Office conference with JCJensen regarding scheduling JBartlett with experts in Grand 580 Junction and time frame for doing so 589 Update filing Telephone conference with Janet (RMOrtho) regarding unpaid office visit of JBartlett; research same (WC issue); office conference with JCJensen regarding same; office conference with JFinley regarding same and assignment of tasks from JCJensen; followup conference with JFinley to answer her questions regarding same and 595 regarding status of tasks Telephone conference with SBartlett regarding upcoming settlement conference and 598 depositions, and regarding documents needed from JBartlett 638 Update filing 644 Update filing Telephone conference with Leslie Sparks regarding SBartlett s request for travel 650 itinerary; obtain same from NBingaman; telephone conference with SBartlett regarding Office conference with TRichards to review discovery responses; review Motion for 656 Leave per JCJensen Update disclosure notebooks; Bates label tax returns received from the Internal Revenue Service on JBartlett; revise disclosure pleading and index regarding same; 664 continued update to disclosure notebooks 688 Copy documents obtained from JBartlett; organize same; return original to him via mail 693 Tab section dividers in disclosure notebooks Review medical records received from Hampton General Hospital on JBartlett; organize same; review worker's compensation records of JBartlett received from the Division of Labor; submit to accounting for payment invoice regarding same; telephone conference with SBartlett regarding possible changing of deposition dates; office conferences with JKKillian and JCJensen regarding same; followup telephone conference with SBartlett regarding same and regarding additional issues; note to JCJensen regarding same; office conference with JCJensen regarding proposed Scheduling Order; print same for her review; copy exhibits to same Update disclosures and index to same; supplement same with numerous new documents, including medical records, employment records, worker's compensation records, and payroll statements of JBartlett received from various sources; numerous office conferences Office conference with JCJensen regarding questions of SBartlett; office conference with JKKillian regarding same Update filing

2180.01

5/7/2002

38

45

1.75

78.75

694

2180.01 2180.01 2180.01

5/7/2002 5/9/2002 5/13/2002

38 38 38

45 45 45

2.8 0.2 0.1

126.00 9.00 4.50

695 713 722

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 8 of 35
Exhibit 22b, Page 97

2180.01

5/16/2002

38

50

4.75

237.50

730

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

5/16/2002 5/20/2002 5/20/2002 5/20/2002 5/20/2002 5/28/2002 5/28/2002

38 38 38 38 38 38 38

50 45 45 45 50 45 45

0.6 0.1 0.2 0.2 0.2 0.2 0.2

30.00 4.50 9.00 9.00 10.00 9.00 9.00

731 750 752 753 754 760 762

2180.01

5/30/2002

38

50

0.5

25.00

770

2180.01

5/30/2002

38

45

0.33

14.85

771

2180.01

5/30/2002

38

45

0.33

14.85

773

Preparation of records subpoenas (two) for TRichards' medical records from DRitter and Steadman Hawkins; preparation of releases (two) regarding same; preparation of witness/records fees requests (two); office conference with JKKillian regarding all; telephone conference with Delta Hospital to locate DRitter; telephone conference with DHuene's office regarding same; telephone conference with DRitter's office in Pueblo to obtain fax number to request medical records; preparation of correspondence, release, and certifications regarding same; left message with Steadman regarding subpoena for records; preparation of correspondence, release, and certification forms to Steadman Clinic; fax transmittal of records requests to DRitter and Steadman; review fax transmittal received from opposing counsel regarding waivers on deposition subpoenas; distribute same; update voluminous filing; review Order received from the Court regarding the parties' scheduled Settlement Conference; review dates contained in same; left message with Gloria (Magistrate Robb's secretary) regarding attachments to Order not being attached; note to JKKillian, JCJensen, and clients regarding same; d Telephone conference with process server to schedule run to Vail to serve Steadman Hawkins Clinic per agreement of counsel; finalize subpoena and attachments; coordinate service of same to opposing counsel and clients Update filing Telephone conference with DenverOrtho regarding disability report of Dr. Wang (to locate and fax over) (BARTLETT) Return call to Molly (RMOrtho) to schedule deposition of Rhall (BARTLETT) Telephone conference with Smith Forest Products regarding employment records requested Telephone conference with TRichards regarding results of depositions Telephone conference with Arlene (Steadman Clinic) regarding records of TRichards (mailed last Thursday) Review fax transmittal received from opposing counsel regarding discovery responses of JDillon; review settlement conference preparation form received from the Court; preparation of correspondence to clients regarding same; copy form as enclosure; consider issues raised in form and need for attorney meeting with clients prior to settlement conference Telephone conference with Delta Sand regarding application for employment of TRichards (company does not save those records; will complete the Certification of No Records and return it to this office) Office conference with JCJensen regarding JBartlett's availability by telephone for the settlement conference; revise correspondence to client to reflect same; transmittal of correspondence to clients

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

Document 464-24
Killian Guthro Jensen, P.C. Clawson Fees

Filed 04/10/2007

Page 9 of 35
Exhibit 22b, Page 98

2180.01 2180.01 2180.01

5/31/2002 5/31/2002 6/3/2002

38 38 38

50 50 50

0.1 1.1 0.9

5.00 55.00 45.00

2180.01 2180.01 2180.01

6/3/2002 6/3/2002 6/3/2002

38 38 38

45 45 45

0.8 0.4 1.1

36.00 18.00 49.50

2180.01 2180.01 2180.01 2180.01

6/4/2002 6/6/2002 6/7/2002 6/7/2002

38 38 38 38

50 45 45 50

3.2 0.4 0.2 0.2

160.00 18.00 9.00 10.00

2180.01

6/7/2002

38

45

0.9

40.50

2180.01 2180.01

6/10/2002 6/10/2002

38 38

50 45

0.9 0.2

45.00 9.00

Telephone conference with RMMiners regarding employment records of JDillon (on 774 their way) 776 Update voluminous filing 777 Clean up notes and documents following depositions Office conference with TRichards to confirm his appointment with RBrennan; telephone conference with Bonnie (PRiley's office) regarding schedule appointments with Pls; office conference with JCJensen regarding same; preparation of 778 correspondence to PRiley 780 Review and organize medical records received from DRitter on TRichards Bates label medical records received from the Steadman Clinic and DRitter on 781 TRichards; update disclosures and index regarding same Review, organize, and Bates label employment records of JDillon and TRichards received to date; update disclosures and index same; review additional documents to 783 be disclosed; note to JCJensen regarding same 798 Update filing 807 Update filing 808 Expand correspondence binder; update filing Review, organize, and Bates label employment records received on JBartlett from Materials Handling; preparation of supplemental disclosures and index to same; office conference with JCJensen regarding same; transmittal of all to opposing counsel; 809 update filing Review and revise discovery responses to second set of requests; review correspondence received from Asplundh regarding JDillon; consider same and various 811 options provided by Asplundh 812 Update filing Left message with JBartlett and TRichards regarding second set of discovery; telephone conference with JDillon regarding same; finalize answers and responses of JDillon; revise answers and responses of remaining Pls and finalize same; office 815 conference with JCJensen regarding same (JKKillian to handle); update filing Review correspondence receive from Asplundh; telephone conference to automated 816 system to receive information on JDillon; note to file regarding same Telephone conference with SBartlett regarding educational background of JBartlett, obtaining a vocational assessment with RBrennan, and regarding upcoming deposition 817 of JBartlett and his need to review Complaint and discovery responses

2180.01

6/11/2002

38

50

1.8

90.00

2180.01

6/11/2002

38

50

0.4

20.00

2180.01

6/11/2002

38

45

0.6

27.00

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

Document 464-24

Filed 04/10/2007

Page 10 of 35
Exhibit 22b, Page 99

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

6/12/2002

38

45

0.5

22.50

Office conference with DJenkins to transfer tasks; telephone conference with LRichards regarding educational background of TRichards; revise discovery 824 responses to include MSHA training Telephone conference with SBartlett regarding JBartlett's upcoming deposition preparation meeting with JKKillian; note to JKKillian regarding same; office conference 825 with NBingaman regarding location of JKKillian's hotel in Denver 826 Update filing Preparation of witness folders for JDillon and JBartlett; office conference with JKKillian regarding discovery needed by him during deposition of JBartlett; locate documents and organize same; office conference with JKKillian regarding hotel reservations; 830 office conference with JKKillian regarding discovery responses of Pls Finalize discovery responses of JBartlett per JKKillian; forward same to JCJensen for 831 review and approval Office conference with JCJensen regarding revisions to discovery responses of JBartlett; add additional sentence per JCJensen; followup office conference with JCJensen; distribute discovery responses of JBartlett and e-mail copy of same to 832 opposing counsel

2180.01 2180.01

6/17/2002 6/17/2002

38 38

45 45

0.4 0.1

18.00 4.50

2180.01 2180.01

6/17/2002 6/17/2002

38 38

50 45

0.6 0.6

30.00 27.00

2180.01

6/17/2002

38

45

0.33

14.85

2180.01 2180.01

6/18/2002 6/19/2002

38 38

45 45

1.1 0.4

49.50 18.00

Telephone conference with JKKillian regarding impairment rating of SHeil for JBartlett (Depo. Ex. No. 104) and regarding Functional Capacity Evaluation performed in Virginia; Internet sear for physical therapists in Virginia; research worker's 833 compensatio 837 Update filing

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

Document 464-24

Filed 04/10/2007

Page 11 of 35
Exhibit 22b, Page 100

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01

6/20/2002 6/20/2002

38 38

50 45

4.75 0.2

237.50 9.00

Review tasks for priority; preparation of correspondence to JBartlett regarding discovery responses; revise discovery responses of JBartlett per JKKillian; research disclosed documents for Bates labeling; preparation of Notice of Continued Deposition of ELangrand; preparation of correspondence to JDillon regarding scheduled meeting with JKKillian to prepare for upcoming deposition; telephone conference with JDillon regarding same; update deposition exhibit notebook with voluminous exhibits following deposition of JBartlett; index same; preparation of correspondence to opposing counsel enclosing executed Protective Order and requesting immediate production of documents; preparation of Motion to File Revise Fifth Amended Complaint per 843 JKKillian 848 Update filing Revise Confidential Settlement Statement per JCJensen; research medical records of 857 JBartlett for time line and regarding placements at maximum medical improvement Copy depositions of ELangrand and GDiClaudio and forward to MClawson per his 858 request 859 Update filing Office conference with JKKillian regarding discovery responses of JBartlett; revise 863 same per JKKillian Office conference with JKKillian to prepare for meeting with JDillon; locate necessary documents regarding same; followup office conference with JKKillian and clients; office conference with JCJensen regarding same and deposition preparation meeting 880 of JDillon and JKKillian Office conference with JDillon regarding location of today's deposition; office conference with JKKillian regarding document review prior to deposition; office conference with JCJensen regarding her attendance at deposition; additional document review; telephone conference with Dufford, Waldeck regarding start time of 883 deposition; update filing Research prior disclosures of JDillon regarding tax returns (W-2s only); preparation of Release forms for 1996-2001 (two forms); preparation of correspondence to JDillon 903 enclosing same; transmittal of all Preparation of correspondence to JDillon to request copies of benefits packages he 904 had with prior and current employers; transmittal of same 910 Copy exhibits to appeal brief per DJenkins 915 Update additional filing, including witness folders 927 Preparation of check request for tax returns of JDillon 932 Update filing 934 Update filing

2180.01 2180.01 2180.01 2180.01

6/22/2002 6/22/2002 6/22/2002 6/24/2002

38 38 38 38

45 50 45 45

1.4 0.5 0.2 2.8

63.00 25.00 9.00 126.00

2180.01

6/25/2002

38

50

0.8

40.00

2180.01

6/26/2002

38

50

1.4

70.00

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

7/1/2002 7/1/2002 7/3/2002 7/5/2002 7/9/2002 7/10/2002 7/11/2002

38 38 38 38 38 38 38

50 50 50 50 50 45 45

0.6 0.2 0.2 0.4 0.1 0.1 0.1

30.00 10.00 10.00 20.00 5.00 4.50 4.50

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

Document 464-24

Filed 04/10/2007

Page 12 of 35
Exhibit 22b, Page 101

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01 2180.01 2180.01 2180.01

7/17/2002 7/18/2002 7/23/2002 7/24/2002 7/24/2002

38 38 38 38 38

50 45 50 50 50

1.2 0.1 0.2 0.1 0.5

60.00 4.50 10.00 5.00 25.00

Preparation of "depo view" letter to JDillon; office conference with JCJensen regarding her review of deposition transcript; calendar and tickler deadline for same; transmittal 941 of correspondence to client with copies of transcripts (Vols. I and II); update filing 942 Update filing g g g p y p 952 on JDillon 954 Research telephone number for from UNUM regardingfile regarding same office Review fax transmittal received Oxbow Mine; note to cost of copying files; 955 conference with JCJensen regarding same; preparation of correspondence to Office conference with JKKillian regarding various tasks, including Sixth Amended Complaint, JDillon's performance at Oxbow Mine, Rule 37 letter, and discovery 956 responses; organize all 957 Update filing Review correspondence from UNUM to opposing counsel regarding no information found on JDillon; copy same for Bates labeling and production to opposing counsel 959 with e co espo de ce ece ed o oppos g cou se ega d g o a d g o copy e next set of disclosures of subpoenaed UNUM documents once received from UNUM; review correspondence 960 received from the Internal Revenue Service regarding tax returns of JDillon Note to NBingaman regarding notice received from court reporter regarding deposition 962 of JBartlett Office conferences (two) with JKKillian to reschedule meeting to discuss Sixth 964 Amended Complaint, Rule 37 letter, discovery responses, and deposition dates Office conference with JKKillian to discuss Sixth Amended Complaint; organize tasks 966 following same

2180.01 2180.01

7/24/2002 7/25/2002

38 38

50 45

1.8 0.1

90.00 4.50

2180.01 2180.01 2180.01

7/26/2002 7/31/2002 7/31/2002

38 38 38

50 50 50

0.2 0.1 0.1

10.00 5.00 5.00

2180.01 2180.01

7/31/2002 7/31/2002

38 38

50 50

0.1 0.75

5.00 37.50

2180.01 2180.01

8/1/2002 8/1/2002

38 38

50 50

0.6 0.2

30.00 10.00

Office conference with JKKillian regarding Sixth Amended Complaints; office 971 conference with JKKillian and JRAngel regarding tasks assigned to JRAngel Additional revisions to Sixth Amended Complaint per JKKillian; compare document to 972 Revised Fifth Amended Complaint and create redlined version

2180.01 2180.01

8/2/2002 8/7/2002

38 38

45 45

0.8 0.4

36.00 18.00

Office conference with CFeltz regarding her conversation with RBrennan and his request for medical records of TRichards; copy medical records of Steadman Clinic; preparation of correspondence to RBrennan enclosing same and a couple worker's 973 compensation documents per CFeltz; transmittal of all 986 Update filing

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

Document 464-24

Filed 04/10/2007

Page 13 of 35
Exhibit 22b, Page 102

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01 2180.01

8/13/2002 8/13/2002 8/19/2002

38 38 38

50 45 45

0.9 0.2 0.4

45.00 9.00 18.00

1002 1003 1042

2180.01

8/21/2002

38

50

0.8

40.00

1047

2180.01 2180.01 2180.01

8/21/2002 8/21/2002 8/22/2002

38 38 38

50 50 45

3.1 0.33 0.1

155.00 16.50 4.50

1048 1049 1056

Telephone conference with JBartlett and LRichards regarding upcoming depositions; office conference with JKKillian regarding same and to schedule deposition date; office conference with JCJensen regarding date selected and deposition preparation meeting with JKKillian and clients; preparation of correspondence to clients regarding all; initial preparation of Sixth Supplemental Disclosures to disclose witness Larry Rose (prior employee of MtnCoal) Update filing Review fax transmittal received from JBartlett; forward copy of same (resume) to RBrennan with cover letter Brief overview of UNUM records received from opposing counsel; preparation of correspondence to opposing counsel regarding missing documents in Def's disclosures and regarding an overlap in numbering; initial indexing of UNUM documents Preparation of supplemental discovery responses for JBartlett and JDillon; research various documents responsive to requests; preparation of medical records request to MJenssen for records of JBartlett; office conference with JKKillian and JCJensen regarding all Fax transmittal of records request to opposing counsel for missing pages of disclosures; calendar followup Review employment records received from Beavers on TRichards (missing those of MClawson)

2180.01

8/23/2002

38

45

0.5

22.50

Review and organize employment records received from Beavers for TRichards; 1057 supplement disclosures to include same; update index; preparation of Bates labels Office conference with JCJensen regarding her conversation with SBartlett and regarding tasks; office conference with JKKillian regarding JBartlett's treating physician in Fort Collins, Colorado; Internet research regarding same; followup office conference with JCJensen; telephone conference with SBartlett's mother regarding job postings for AV Techs in Denver, Salt Lake City, and Grand Junction; notes to file regarding all; followup office conference with JKKillian to schedule client meeting with 1071 JBartlett Preparation of correspondence to JBartlett to schedule meeting with JKKillian; research impairment rating assigned to JBartlett; office conference with JCJensen 1072 regarding same; transmittal of correspondence to JBartlett Telephone conference with PRiley's office regarding scheduling a functional capacity evaluation for JBartlett (appointments on Wednesday afternoons only); note to file regarding same; telephone conference with JDonner's office regarding impairment 1073 ratings

2180.01

8/27/2002

38

45

1.33

59.85

2180.01

8/28/2002

38

45

0.4

18.00

2180.01

8/28/2002

38

45

0.4

18.00

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

Document 464-24

Filed 04/10/2007

Page 14 of 35
Exhibit 22b, Page 103

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

8/28/2002

38

45

0.2

9.00

2180.01 2180.01 2180.01

8/28/2002 8/29/2002 3/30/2002

38 38 38

45 45 50

0.1 0.33 1.1

4.50 14.85 55.00

Office conference with JCJensen regarding information on JDonner and PRiley's 1074 upcoming schedule Office conference with JKKillian regarding qualifications of JDonner and potential functional capacity evaluation of JBartlett with PRiley (hold until results received from 1075 list serve posted by JCJensen) Preparation of correspondence to JBartlett regarding employment opportunities; 1078 transmittal of same Update voluminous filing; telephone conference with MClawson regarding status of 1079 claim Review and distribute subpoena received from opposing counsel for records of Tri-R Pawn, LLC; review and distribute response brief received from opposing counsel regarding Sixth Amended Complaint; calendar and tickler reply date; review and distribute deposition subpoenas received from opposing counsel for depositions of LRichards and SBartlett; note to JKKillian and JCJensen regarding same and 1083 regarding acceptance of service 1091 Telephone conference with RBrennan's office regarding current address for JBartlett Telephone conference with Tidewater Tech regarding education records to be sent on 1092 JBartlett Review and distribute Order denying filing of Sixth Amended Complaint; office conference with JRAngel regarding same; office conference with JKKillian regarding same; tickler and calendar appeal date; office conference with JCJensen regarding same; office conference with JRAngel regarding assignment of task; tickler and calendar deadline to file re-revised Fifth Amended Complaint; tickler deadline for Tri-R Pawn to comply with subpoena per JCJensen; office conference with JKKillian regarding all and to schedule meeting to review subpoenas; followup office conference 1094 with JCJensen regarding scheduled meeting Submit to accounting for payment invoice received from PRenfro for legal research rendered on behalf of JBartlett and TRichards; left message with PRenfro to correct 1113 client's name Review and distribute correspondence and subpoenas received from opposing 1114 counsel; note to JCJensen and JKKillian regarding deposition time for SBartlett

2180.01 2180.01 2180.01

9/3/2002 9/6/2002 9/6/2002

38 38 38

50 45 45

1.1 0.1 0.33

49.50 4.50 14.85

2180.01

9/9/2002

38

50

1.2

54.00

2180.01

9/13/2002

38

45

0.2

9.00

2180.01

9/13/2002

38

45

0.4

18.00

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

Document 464-24

Filed 04/10/2007

Page 15 of 35
Exhibit 22b, Page 104

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

9/13/2002

38

45

3.5

157.50

Office conference with JKKillian and JCJensen to discuss medical treatment of JBartlett; telephone conference with JBartlett regarding same and regarding need to obtain functional capacity evaluation; sit in on telephone conference between JKKillian and MTuttle; organize tasks following same; preparation of confirmatory letter to opposing counsel; preparation of correspondence to SBartlett regarding missing work for scheduled deposition; preparation of correspondence to SBartlett to re-schedule deposition preparation time; preparation of correspondence to LRichards regarding same; preparation of correspondence to JBartlett enclosing copy of deposition transcript; copy same; office conference with JKKillian regarding all; finalize all and 1116 coordinate mailing of same with copies to clients Review task received from JKKillian; telephone conference with JBartlett regarding scheduled appointments with JPrice and JDonner, and regarding locating of MRI films; 1125 office conference with JKKillian regarding appeal brief and Affidavit of JDillon Clean up of Affidavit of JDillon; note to JKKillian and JCJensen regarding same; telephone conference with JDillon's wife regarding signing of Affidavit (JDillon hunting 1126 until Friday or Saturday); note to JKKillian and JCJensen regarding same Office conference with JKKillian regarding Affidavit of JDillon; telephone conference with JBartlett regarding contents of Affidavit; preparation of same; followup office conference with JKKillian; left message with TRichards regarding affidavit Telephone conference with TRichards regarding contents of Affidavit Revise Affidavit of JBartlett per JKKillian; preparation of Affidavit of TRichards Review and organize records received from Tri-R Pawn pursuant to subpoena generated by opposing counsel Telephone conference with JBartlett regarding deposition of SBartlett, Affidavit, and xrays

2180.01

9/16/2002

38

45

0.4

18.00

2180.01

9/16/2002

38

50

1.75

87.50

2180.01 2180.01 2180.01 2180.01 2180.01

9/16/2002 9/16/2002 9/17/2002 9/17/2002 9/17/2002

38 38 38 38 38

45 45 45 45 45

0.6 0.33 0.33 0.2 0.2

27.00 14.85 14.85 9.00 9.00

1127 1128 1129 1131 1132

2180.01 2180.01

9/19/2002 9/19/2002

38 38

45 45

0.75 0.33

33.75 14.85

Telephone conference with JBartlett regarding deposition dates proposed for the deposition of SBartlett; telephone conference with MRichards regarding the scheduling of her deposition; telephone conference with LRichards regarding the scheduling of her deposition; office conference with JCJensen regarding JKKillian's telephone conference with opposing counsel; preparation of correspondence to opposing 1142 counsel confirming earlier telephone conference with JKKillian Telephone conference with SBartlett regarding scheduling of her deposition; note to 1144 JKKillian regarding same; organize voluminous documents for filing

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

Document 464-24

Filed 04/10/2007

Page 16 of 35
Exhibit 22b, Page 105

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

9/20/2002

38

45

0.2

9.00

Preparation of correspondence to SBartlett regarding her scheduled deposition; revise confirmation letter to opposing counsel to include receipt of Protective Order re-filed 1146 with the Court and information regarding deposition of SBartlett Update voluminous filing, including pleadings, discovery, and various documents specific to certain clients; tickler and calendar depositions of SBartlett and others; 1147 telephone conference with MDoring regarding current deposition schedule 1148 Review and notarize Affidavit of JBartlett; copy same to appeal brief; update filing Transmittal of correspondence to SBartlett regarding missing work to attend deposition in Denver; fax transmittal of correspondence to opposing counsel confirming prior 1152 conversation with JKKillian 1153 Update filing Telephone conference with LRichards regarding deposition preparation meeting 1156 (LRichards to call in) Telephone conference with JBartlett regarding functional capacity evaluation (JPrice 1157 has not returned messages in order to make appointment) Office conference with JCJensen regarding upcoming deposition schedule and regarding JBartlett's inability to schedule appointment for functional capacity 1158 evaluation with JPrice 1160 Update filing Left messages (two) with JPrice regarding setting appointment for JBartlett for a functional capacity evaluation; telephone conference with NatJewish regarding same; preparation of correspondence to JPrice; office conference with JCJensen regarding 1161 same; 1163 Fax transmittal of correspondence to opposing counsel regarding GENEX records Review and distribute correspondence received from opposing counsel regarding deposition schedule; telephone conference with Jackie (JPrice's office) regarding scheduling of functional capacity evaluation for JBartlett (have to wait to hear from 1177 JPrice) Telephone conference with JPrice regarding functional capacity evaluation for JBartlett in Denver; calendar same; preparation of correspondence to JPrice enclosing medical records, position descriptions, and essential job functions; locate and copy all; 1180 transmittal of all Office conference with JKKillian regarding scheduling of telephone conference with JPrice to review functional capacity evaluation on JBartlett; preparation of 1181 correspondence to JPrice regarding same

2180.01 2180.01

9/20/2002 9/20/2002

38 38

45 45

1.75 0.2

78.75 9.00

2180.01 2180.01 2180.01 2180.01

9/20/2002 9/20/2002 9/23/2002 9/23/2002

38 38 38 38

45 45 45 45

0.33 0.33 0.1 0.1

14.85 14.85 4.50 4.50

2180.01 2180.01

9/23/2002 9/23/2002

38 38

45 45

0.1 0.1

4.50 4.50

2180.01 2180.01

9/23/2002 9/23/2002

38 38

45 50

0.4 0.1

18.00 5.00

2180.01

9/25/2002

38

45

0.2

9.00

2180.01

9/26/2002

38

45

0.6

27.00

2180.01

9/26/2002

38

45

0.33

14.85

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

Document 464-24

Filed 04/10/2007

Page 17 of 35
Exhibit 22b, Page 106

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

9/26/2002

38

45

0.2

9.00

Office conference with JKKillian regarding fax transmittal received from opposing counsel and to schedule meeting regarding same; office conference with JKKillian to review correspondence to JPrice regarding scheduling of meeting to review functional 1184 capacity evaluation of JBartlett; transmittal of correspondence to JPrice

2180.01 2180.01 2180.01

9/27/2002 9/27/2002 9/27/2002

38 38 38

50 45 45

0.1 0.33 0.2

5.00 14.85 9.00

2180.01

9/30/2002

38

50

0.33

16.50

Fax transmittal of correspondence to opposing counsel regarding missing UNUM 1185 documents Telephone conference with SBartlett and LRichards regarding re-scheduling of 1186 deposition preparation meeting per JKKillian Review correspondence received from opposing counsel regarding upcoming 1187 depositions; forward mileage check to SBartlett Review tasks; office conference with JCJensen regarding deposition preparation of clients' wives (none to date); preparation of correspondence to opposing counsel regarding deposition of BShanks and regarding denial of request for defense 1196 vocational expert to interview JBartlett Office conference with JKKillian regarding Motion to Compel and regarding deposition preparation of MRichards, LRichards, and SBartlett; telephone conference with LRichards regarding same; left message with SBartlett regarding same Revise correspondence to opposing counsel regarding vocational assessment of JBartlett by def's expert witness Transmittal of various documents to clients Telephone conference with JBartlett regarding various worker's compensation names and addresses needed by JDonner Office conference with JKKillian regarding documents needed for deposition preparation of Pls' wives; gather same; initiate conference call; telephone conference with JBartlett regarding conference call procedures Review fax transmittal received from opposing counsel regarding vocational assessment of JBartlett; office conference with JCJensen regarding same

2180.01 2180.01 2180.01 2180.01

9/30/2002 10/1/2002 10/1/2002 10/1/2002

38 38 38 38

45 45 50 45

0.8 0.1 0.2 0.2

36.00 4.50 10.00 9.00

1197 1208 1211 1213

2180.01 2180.01

10/1/2002 10/1/2002

38 38

45 45

0.6 0.2

27.00 9.00

1215 1216

2180.01

10/2/2002

38

45

1.6

72.00

2180.01

10/2/2002

38

45

0.5

22.50

Update voluminous filing; office conference with JKKillian regarding files needed for depositions; gather same; create witness folders for SBartlett, LRichards, and MRichards; copy portions of Labor Report of TRichards; note to JKKillian regarding same; copy current Complaint and last Answer filed for use by JKKillian at depositions; 1218 office conference with JKKillian regarding questions for TRichards Telephone conference with LRichards regarding work order and equipment codes and regarding upcoming settlement conference; confirm date of same and followup with 1219 LRichards

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

Document 464-24

Filed 04/10/2007

Page 18 of 35
Exhibit 22b, Page 107

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01

10/3/2002 10/3/2002

38 38

45 45

5.1 0.1

229.50 4.50

Preparation of correspondence to opposing counsel regarding time cards kept by Pls; preparation of correspondence to MRichards regarding calendar of when TRichards worked at Tri-R Pawn; telephone conference with Pam (JDonner's office) regarding 1223 scheduling 1227 Transmittal of correspondence to MRichards regarding work schedule calendar Copy labor reports to distribute to clients; transmittal of additional correspondence regarding LTD benefits; telephone conference with Lori (RBrennan's office) regarding date to use for future economic losses (settlement conference date given); telephone conference with SBartlett regarding missed appointment with JKKillian; telephone conference with JKKillian regarding same (meeting re-scheduled); left message with SBartlett regarding same; telephone conference with JKKillian regarding SBartlett's reading of JBartlett's deposition; telephone conference with SBartlett regarding various issues; note to file regarding same; telephone conference with JKKillian regarding same; office conference with JCJensen regarding same; office conference with DDavis regarding tasks and regarding status of Motion to Compel; revise subpoenas per JKKillian; print all for review by JCJensen; followup telephone conference with Lori regarding employment status of JBartlett (looking for work); preparation of correspondence to JDillon to request copies of 2002 pay stubs per RBrennan; 1228 transmittal of same with copy to RBrennan 1232 Continued indexing of UNUM records pertaining to TRichards Office conference with JKKillian to reschedule meeting to discuss vocational assessment of JBartlett requested by opposing counsel; office conference with 1233 JCJensen regarding same

2180.01 2180.01

10/4/2002 10/7/2002

38 38

50 45

3.4 2.1

170.00 94.50

2180.01

10/7/2002

38

45

0.1

4.50

2180.01

10/7/2002

38

45

2.2

99.00

2180.01

10/7/2002

38

45

0.5

22.50

Office conference with JKKillian and JCJensen regarding vocational assessment of JBartlett requested by opposing counsel; copy deadlines to JKKillian; preparation of supplemental disclosures; preparation of supplemental discovery responses; revise 1234 index t Left message with JBartlett regarding potential dates for vocational assessment appointment with def's expert witness; office conference with JKKillian to review correspondence to opposing counsel regarding various outstanding issues; revise 1235 same per JKKi

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

Document 464-24

Filed 04/10/2007

Page 19 of 35
Exhibit 22b, Page 108

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

10/8/2002

38

45

2.1

94.50

Review deposition transcripts of MRichards and LRichards; preparation of deposition view letters to each witness; copy deposition transcripts and transmittal of same to MRichards and LRichards with cover correspondence; telephone conference with JKKillian regarding deposition testimony of SBartlett and regarding Def's confidential 1241 documents; telephone conference with PKnapp (MTuttle's office) regarding same Telephone conference with LRichards regarding questions asked by JKKillian regarding answers to same; note to JKKillian regarding same; telephone conference with SHeil's office to obtain last date of treatment for TRichards Review 2002 calendar received from MRichards; preparation of supplemental discovery responses and supplemental disclosures; Bates label calendar and update index to disclosures; office conference with JCJensen regarding all; office conference with JKKilli Office conference with JKKillian regarding JBartlett's appointment with PAnctil (no objection); preparation of response e-mail to MTuttle regarding same; left message with JBartlett to confirm availability; calendar followup Continued indexing of UNUM documents pertaining to TRichards Telephone conference with SBartlett regarding husband's current work status; telephone conference with Lori (RBrennan's office) regarding same; note to file regarding same

2180.01

10/8/2002

38

45

0.33

14.85

1242

2180.01

10/9/2002

38

45

1.8

81.00

1257

2180.01 2180.01

10/15/2002 10/16/2002

38 38

45 45

0.4 1.33

18.00 59.85

1279 1282

2180.01 2180.01 2180.01 2180.01

10/16/2002 10/18/2002 10/17/2002 10/21/2002

38 38 38 38

45 50 45 45

0.5 0.8 0.2 0.6

22.50 40.00 9.00 27.00

1285

1292 Set up conference room in anticipation of depositions; final review of potential exhibits Telephone conference with LRichards regarding outcome of deposition of BShanks 1288 and regarding TRichards to attend remaining depositions Review and organize academic and financial aid files of JBartlett received from 1294 Tidewater Tech Office conference with JKKillian regarding tasks; locate and copy various documents requested by JPrice; preparation of correspondence to JPrice enclosing same; 1295 followup office conference with JKKillian to schedule meeting to review all Office conference with JKKillian to review correspondence to JPrice enclosing various 1296 documents; fax transmittal of all to expert witness (fifty-six pages) Telephone conference with opposing counsel regarding conference room set up for 1342 JBartlett's meeting with defense expert; left message with JBartlett regarding same 1344 Update voluminous filing Office conference with JCJensen regarding missed appointment of JBartlett with 1345 defense expert; attempts made to locate client at home and at work

2180.01 2180.01

10/21/2002 10/21/2002

38 38

45 45

0.75 0.4

33.75 18.00

2180.01 2180.01 2180.01

10/22/2002 10/23/2002 10/23/2002

38 38 38

45 45 45

0.2 1.9 0.4

9.00 85.50 18.00

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

Document 464-24

Filed 04/10/2007

Page 20 of 35
Exhibit 22b, Page 109

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01

10/24/2002 10/24/2002

38 38

45 45

0.5 0.2

22.50 9.00

Numerous office conferences with JCJensen regarding JBartlett's missed 1347 appointment; research correspondence regarding same Review and distribute correspondence received from opposing counsel regarding 1348 JBartlett's missed appointment; update filing Preparation of correspondence to opposing counsel regarding missed appointment of 1350 JBartlett with PAnctil; office conference with JCJensen regarding same Preparation of correspondence to SBartlett regarding review of her deposition transcript for any corrections; continued review of same; telephone conference with John (court reporter's office) regarding incorrect date on transcript; office conference 1351 with Fax transmittal of correspondence to opposing counsel regarding missed appointment 1353 of JBartlett; copy same to client Office conference with JKKillian regarding scheduled appointment with JPrice; attempt to locate home number for expert witness; review and distribute draft of functional 1356 capacity evaluation of JBartlett Preparation of correspondence to LRichards regarding list of jobs prepared by 1359 TRichards; calendar followup; transmittal of same Review and distribute correspondence received from opposing counsel regarding missed appointment of JBartlett; office conference with JCJensen regarding same; 1362 preparation of correspondence to JBartlett regarding same; transmittal of all Office conference with JKKillian, JCJensen, and DDavis to discuss Motion to Compel, scheduling of appointment between JBartlett and PAnctil, and regarding potential for costs to be assessed against JBartlett and/or firm for missing appointment; sit in on telephone conference between JKKillian and Lori (RBrennan's office) regarding scheduling of conference to review expert witness reports; organize tasks following 1363 same Preparation of correspondence to JBartlett confirming appointment with PAnctil; preparation of correspondence to opposing counsel responding to fax transmittal 1364 regarding same; office conference with JCJensen regarding both

2180.01

10/24/2002

38

45

0.4

18.00

2180.01 2180.01

10/25/2002 10/25/2002

38 38

45 45

0.8 0.33

36.00 14.85

2180.01 2180.01

10/28/2002 10/28/2002

38 38

45 45

0.75 0.2

33.75 9.00

2180.01

10/28/2002

38

45

0.33

14.85

2180.01

10/28/2002

38

45

1.33

59.85

2180.01

10/29/2002

38

45

0.9

40.50

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

Document 464-24

Filed 04/10/2007

Page 21 of 35
Exhibit 22b, Page 110

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01

10/29/2002 10/30/2002

38 38

45 45

2.6 1.6

117.00 72.00

Numerous telephone messages left with JPrice to return her call; office conference with JKKillian regarding correspondence to opposing counsel (two) and JBartlett; revise all per JKKillian; review surveillance tape received from MJM Investigations on JBartlett; telephone conference with JPrice regarding content of same; office conference with PWillis regarding obtaining copy of tape; coordinate same; finalize 1367 correspondence to opposing counsel and clients; transmittal of all Initial preparation of expert witness disclosures; left message with Julie (JDonner's 1368 office) to request medical records of JBartlett be faxed Numerous office conferences with JKKillian and RBrennan to locate and copy various 1369 documents; left message with Julie (JDonner's office) to re-request medical records Office conference with JRAngel regarding strategy of the Motion to Strike; office conference with JCJensen and JRAngel regarding same; numerous office conferences with JKKillian regarding expert witness disclosures; telephone conferences with opposing counsel regarding same; obtain Stipulation for extension from opposing counsel; office conference with JKKillian regarding same; fax transmittal of signature page to opposing counsel; telephone conference with JPrice regarding status of her report and regarding stipulation for extension of time; preparation of FedEx package to JPrice enclosing surveillance tape of JBartlett; fax transmittals (two) to JPrice attaching various documents needed by her in order to complete her report; attend to numerous additional tasks, including obtaining JDonner's records and providing them to Pls' expert witnesses; telephone conference with MDoring regarding preparation of deposition transcripts (will be ready early next 1370 week) 1372 Update filing Left message with JBartlett to return his call; review and distribute correspondence received from opposing counsel regarding Motion to Strike; office conferences with 1373 JCJensen and JRAngel regarding same; update filing Review and distribute draft report (partial) of JPrice; left message with JPrice 1374 regarding current deadline for expert disclosures; update filing

2180.01

10/30/2002

38

45

1.4

63.00

2180.01 2180.01

10/30/2002 10/31/2002

38 38

45 45

2.8 0.8

126.00 36.00

2180.01 2180.01

10/31/2002 10/31/2002

38 38

45 45

0.4 0.33

18.00 14.85

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

Document 464-24

Filed 04/10/2007

Page 22 of 35
Exhibit 22b, Page 111

Killian Guthro Jensen, P.C. Clawson Fees

2180.01

10/31/2002

38

50

0.1

5.00

2180.01 2180.01 2180.01 2180.01

10/31/2002 10/31/2002 11/1/2002 11/1/2002

38 38 38 38

45 45 45 45

0.2 0.1 0.1 0.2

9.00 4.50 4.50 9.00

2180.01

11/1/2002

38

45

0.6

27.00

1376 Telephone conference with JDillon regarding rejection of current settlement offer Telephone conference with JBartlett regarding rejection of current settlement offer and regarding location of appointment with PAnctil; office conference with JKKillian 1377 regarding JBartlett attending settlement conference by telephone 1379 Update filing 1449 Update filing Preparation of correspondence to opposing counsel in response to request for job list 1450 prepared by TRichards Office conference with JCJensen regarding list of jobs prepared by TRichards and correspondence to opposing counsel regarding same; revise correspondence per JCJensen; fax transmittal of same with copies to clients; notarize signature pages and 1451 revisions 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 1429 Brennan; at 1427 helped Diane Office conference with JKKillian regarding filing of expert disclosures; telephone conference with JPrice regarding her report (to send this afternoon by e-mail); note to 1461 JKKillian regarding same Numerous office conferences with DDavis regarding facts surrounding JBartlett's 1462 missed appointment; office conference with JCJensen and DDavis regarding same Office conference with JKKillian regarding status of expert disclosures, review and forward e-mail received from JPrice; followup office conference with JKKillian 1463 regarding all Preparation of correspondence to opposing counsel attaching signature page of 1469 JBartlett to discovery responses; fax transmittal of same; update filing Update filing, including expert reports; preparation of notebook and index for same for 1471 working filing of JKKillian 1476 Update filing; calendar date requested from experts to provide rebuttal reports Research date for receipt of deposition transcript changes by SBartlett; left message with SBartlett regarding same; calendar followup; review additional tasks; office 1478 conference with JCJensen regarding upcoming deadlines and assignments

2180.01 2180.01

11/5/2002 11/6/2002

38 38

45 45

2.1 0.25

94.50 11.25

2180.01

11/11/2002

38

45

0.33

14.85

2180.01

11/11/2002

38

45

0.4

18.00

2180.01 2180.01 2180.01 2180.01

11/11/2002 11/14/2002 11/14/2002 11/15/2002

38 38 38 38

45 45 50 50

0.75 0.33 1.9 0.33

33.75 14.85 95.00 16.50

2180.01

11/18/2002

38

45

0.5

22.50

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

Document 464-24

Filed 04/10/2007

Page 23 of 35
Exhibit 22b, Page 112

Killian Guthro Jensen, P.C. Clawson Fees

2180.01 2180.01 2180.01 2180.01 2180.01 2180.01

11/18/2002 11/20/2002 11/21/2002 11/21/2002 11/22/2002 11/22/2002

38 38 38 38 38 38

45 45 45 45 45 45

0.2 0.4 0.1 0.2 0.1 0.4

9.00 18.00 4.50 9.00 4.50 18.00

Telephone conference with JBartlett regarding status of claim; note to JKKillian 1479 regarding same 1500 Update filing 1505 Preparation of note to JKKillian regarding recent telephone conference with JBartlett Office conference with DDavis regarding facts surrounding JBartlett's missed 1508 appointment and DDavis' inability to contact client Office conference with DDavis regarding status of Response to Motion for Costs 1509 (meeting scheduled with JKKillian on Monday) Office conference with JRAngel regarding exhibits to proposed Motion for Sanctions; 1510 copy same for his review; review status of other deadlines Telephone conference with SBartlett regarding various outstanding issues and 1512 regarding her need to talk with DDavis regarding facts surrounding Motion for Costs Office conferences with JRAngel regarding legal research cited by opposing counsel 1513 in its proposed Motion for Sanctions 1514 Revise and finalize Response to Motion for Costs per JKKillian and DDavis 1515 Coordinate filing and service of Response brief Review and revise correspondence to opposing counsel prepared by JRAngel in 1521 response to proposed Motion for Sanctions Office conference with DDavis regarding response to cost motion; office conference 1575 with JRAngel regarding current working Complaint 1579 Update filing 1586 Update filing, including expert reports Telephone conference with JBartlett regarding additional witness; note to file regarding 1590 same; office conference with JCJensen regarding same Telephone conference with SBartlett regarding status of claim and regarding husband 1602 being laid off; telephone conference with Lori (RBrennan's office) regarding same 1615 Transmittal of correspond