Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 1 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Description Entry Hours 0.3 0.6 Hours Claimed 0.3 0.6 0.9 Hourly Rate $600.00 $625.00 Total Objections

10/4/2006 Sparks Conference 1/29/2007 Sparks Review motion Sparks Total

$180.00 Description is too vague to determine if related to the Motions (§ II.A). $375.00 $555.00

3/8/2007 3/9/2007 3/10/2007 Stone Total

Stone Stone Stone

Motion to Compel Motion to Compel Brief Motion to Compel brief

3.0 1.5 0.5

3.0 1.5 0.5 5.0

$600.00 $600.00 $600.00

$1,800.00 Description is too vague to determine if hours are reasonable (§ II.B). $900.00 Description is too vague to determine if hours are reasonable (§ II.B). $300.00 Description is too vague to determine if hours are reasonable (§ II.B). $3,000.00

8/23/2006 8/28/2006

Hurd Hurd

Document review; prepare for teleconference with opposing counsel; teleconference re discovery and related issues Emails re discovery issues

7.5 0.1

2.0 0.1

$475.00 $475.00

Document Review is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); arbitrary allocation of time and description $950.00 is too vague to determine if allocation is reasonable (§ II.C). $47.50 Description is too vague to determine if related to the Motions (§ II.A). Descriptions are too vague to determine if related to the Motions (§ II.A); "Document review" would have been performed regardless of dispute (§ III.A); "Opinion" and ALH Production are unrelated to the Motions (§ III.A); unlikely correspondence related to the Motions because correspondence from Plaintiffs dated 10/6/06 was unrelated $2,090.00 to issues raised in the Motions (§ III.A). Descriptions are too vague to determine if related to the Motions (§ II.A); "Document review" would have been performed regardless of the discovery dispute (§ III.A); unlikely correspondence related to the Motions because correspondence from Plaintiffs dated 10/6/06 was $475.00 unrelated to issues raised in the Motions (§ III.A). "Document review" would have been performed regardless of dispute (§ III.A); unlikely letter related to the Motions because correspondence from Plaintiffs dated 10/6/06 was unrelated to issues raised in the Motions (§ III.A); "confer..."--description is too vague to determine if $1,140.00 related to Motions (§ II.A). Descriptions are too vague to determine if related to Motions (§ II.A); "Document review" would have been performed regardless of dispute (§ III.A); unlikely letter or conference related to the Motions because correspondence from Plaintiffs dated 10/6/06 was unrelated to issues $1,662.50 raised in the Motions (§ III.A).

10/2/2006

Hurd

Document review; review opinion; review and revise draft correspondence to opposing counsel; conference re ALH document production

4.4

4.4

$475.00

10/4/2006

Hurd

Document review; revising correspondence re discovery issues

1.0

1.0

$475.00

10/5/2006

Hurd

Document review; review and revise discovery letter; inter-office conference re discovery issues

2.4

2.4

$475.00

10/6/2006

Hurd

Document review; drafting and revising letter re discovery issues; conference with S Hirzel re same

3.5

3.5

$475.00

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Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 2 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections Descriptions are too vague to determine which, if any, tasks related to the Motions (§ II.A); "Document Review" would have been performed regardless of dispute (§ III.A); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ $950.00 II.C).

10/11/2006

Hurd

11/10/2006

Hurd

Document review; chronology; outline re open discovery issues Review privilege logs; review and revise correspondence; emails re scheduling and other issues

7.0

2.0

$475.00

7.8

4.0

$475.00

11/19/2006

Hurd

1/17/2007 1/22/2007 1/28/2007 2/12/2007 3/9/2007 Hurd Total

Hurd Hurd Hurd Hurd Hurd

Document review; revise letter; emails re discovery issues Document review for expert; conferences with AGS; review record; draft and revise motion to compel Emails re discovery issues Review and revise motion to compel; transcript review teleconferences re discovery issues Expert witness issues; review and revise draft reply on motion to compel

2.0

2.0

$475.00

Arbitrary allocation of time and description is too vague to determine if $1,900.00 allocation is reasonable (§ II.C). "Document review" is work that would have been performed regardless of the discovery dispute (§ III.A); "revise..." and "emails" is too vague to determine if related to the Motions (§ II.A) and unlikely related to the Motions because Defendants received no correspondence at that time regarding the discovery issues raised in $950.00 the Motions (§ III.A). Arbitrary allocation of time and description is too vague to determine if $1,000.00 allocation is reasonable (§ II.C). $100.00 Description is too vague to determine if related to the Motions (§ II.A). $500.00 Arbitrary allocation of time (§ II.C). Description is too vague to determine if related to the Motions (§ II.A); $500.00 arbitrary allocation of time (§ II.C). Arbitrary allocation of time and description is too vague to determine if $1,000.00 allocation is reasonable (§ II.C). $13,265.00

6.5 0.2 1.5 3.8 3.5

2.0 0.2 1.0 1.0 2.0 27.6

$500.00 $500.00 $500.00 $500.00 $500.00

8/2/2006

Hirzel

8/15/2006 8/24/2006 9/8/2006 9/9/2006

Hirzel Hirzel Hirzel Hirzel

Work on trans. memo, revise production for hot documents, organize B's hot documents, confer with JPD re: meeting Privilege documents issues; call with Wood; confer with Mark Hurd, John DiTomo and Mary Muffley re: discovery motions. Meet and confer re: follow up letter and prepare for meeting with REDACTED Letter to Thomas Wood. Revise letter. Follow up production discovery

6.7

0.6

$260.00

$156.00 "Privilege documents issues"--description is too vague to determine if hours are reasonable (§ II.B); "call ..."--description is too vague to $468.00 determine if related to the Motions (§ II.A). Description is too vague to determine if related to the Motions (§ II.A); $182.00 Arbitrary allocation of time (§ II.C). $156.00 Description is too vague to determine if related to the Motions (§ II.A). $130.00 Description is too vague to determine if related to the Motions (§ II.A). Description is too vague to determine if related to the Motions (§ II.A); unlikely related to the Motions because correspondence from Plaintiffs dated 10/6/06 was unrelated to discovery issues raised in the Motions $78.00 (§III.A).

1.8 1.4 0.6 0.5

1.8 0.7 0.6 0.5

$260.00 $260.00 $260.00 $260.00

10/2/2006
264931

Hirzel

Draft letter re: production.

0.3

0.3 2 of 6

$260.00

Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 3 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections Description is too vague to determine if related to the Motions (§ II.A); unlikely letter related to the Motions because letter from Plaintiffs dated 10/6/06 was unrelated to discovery issues raised in the Motions (§III.A). Description is too vague to determine if related to Motions (§ II.A); unlikely letter related to the Motions because correspondence from Plaintiffs dated 10/6/06 was unrelated to issues raised in the Motions (§ III.A). Description is too vague to determine which, if any, tasks related to the Motions (§ II.A); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ II.C). Descriptions are too vague to determine if related to the Motions (§II.A); "Review..." would have been performed regardless of discovery dispute (III.A); unlikely letter related to the Motions because letters from Plaintiffs dated 10/16, 10/17 and 10/18/06 were unrelated to the discovery issues raised in the Motions (§ III.A); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ II.C). Descriptions are too vague to determine if related to the Motions (§ II.A); unlikely letter is related to the Motions because letters from Plaintiffs dated 10/16, 10/17 and 10/18/06 were unrelated to the Motions (§ III.A); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ II.C). Description is too vague to determine if related to Motions (§ II.A); letter from Mr. Wood dated 10/23/06 is unrelated to the Motions (§ III.A).

10/4/2006

Hirzel

Discovery letter

1.4

1.4

$260.00

$364.00

10/6/2006

Hirzel

Revise letter and confer with Smith re: docs. Review GB documents for Hot Docs. Revise Privilege Log. Confer with SMT. L. production.

2.5

2.5

$260.00

$650.00

10/11/2006

Hirzel

6.5

2.0

$475.00

$950.00

10/12/2006

Hirzel

Review new L production. Revise privilege log. Send letter to Wood.

6.2

2.0

$260.00

$520.00

10/13/2006

Hirzel

Production issues. Review new ALH Hot Docs. 1st draft of privilege letter.

1.8

1.0

$260.00

$260.00

10/23/2006 11/10/2006 11/18/2006 11/21/2006

Hirzel Hirzel Hirzel Hirzel

11/29/2006

Hirzel

11/30/2006 12/13/2006
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Hirzel Hirzel

Read Wood letters. Motion to Compel. Research re: waiver of privilege. Send discovery letter. Review logs. Review ALH production. Draft Motion to Compel. Draft Lamm outline. Review new Swiss Re documents. Incorporate Swiss Re documents into chron/Lamm outline. Continue drafting Motion to Compel. Begin Frankel outline. Finish reading Arenson deposition. Incorporate Arenson deposition into Motion to Compel/Lamm outline. Frankel deposition outline. Color code new privilege logs for Motion to Compel. Incorporate new log into Motion to Compel. Review new Lamm documents. Revise Motion to Compel with new "L" docs.

0.2 1.6 1.5 6.5

0.2 1.6 1.0 4.0

$260.00 $260.00 $260.00 $260.00

$52.00

$416.00 $260.00 Arbitrary allocation of time (§ II.C). $1,040.00 Arbitrary allocation of time (§ II.C).

9.0

2.0

$260.00

$520.00 Arbitrary allocation of time (§ II.C).

7.5 10.1

5.0 10.1 3 of 6

$260.00 $260.00

"Finish reading Arenson deposition" is work that would have been performed regardless of the discovery dispute (§ III.A); arbitrary allocation of time and description is too vague to determine if $1,300.00 allocation is reasonable (§ II.C). "Review..." is work that would have been performed regardless of $2,626.00 discovery dispute (III.A); hours claimed are excessive (III.B);

Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 4 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Entry Description Hours Revise Motion to Compel with new "L" documents and log. Edit Lamm outline with new documents. Dictate chron of new "L" documents. 8.0 Finish dictation of new "L" Hot Docs. Revise Motion to Compel. 6.5 Revise and edit Motion to Compel. 2.0 Revise and edit Motion to Compel and compile exhibits. 3.5 Finalize draft of Motion to Compel. Dictate additional production. Incorporate "L" production into Lamm outline. Review SMH edits to logs. 4.0 Privilege log issues. Review and dictate new documents. 1.8 Lamm deposition. Review motion to compel. Compile and edit motion to compel. Review Motion to Compel. Additional research. Motion to Compel. Jesselson outline. Begin reading Lamm II. Incorporate comments to Motion to Compel. Read Robbins. Jesselson deposition preparation. Finalize edits to Motion to Compel. Take Jesselson's deposition. Finalize Motion to Compel, Order, Compendium and Appendix. Lanius outline. Begin reply brief. Interrogatory responses. Re-review JMP documents. Draft and research reply brief. Stein Hot Docs for preparation. Finalize and file interrogatory response. Edit reply brief. Edit reply brief. Read transcript. Read Konig deposition. Edit reply brief. Incorporate Konig deposition. Review reply brief Finalize reply brief, finalize Neuberger outline, prepare for Neuberger deposition, read SMH questions for Lanius 5.3 3.0 1.2 5.8 5.7 6.0 Hours Claimed Hourly Rate Total Objections

12/14/2006 12/15/2006 12/16/2006 12/18/2006

Hirzel Hirzel Hirzel Hirzel

4.0 4.0 2.0 3.5

$260.00 $260.00 $260.00 $260.00

Arbitrary allocation of time and description is too vague to determine if $1,040.00 allocation is reasonable (§ II.C). $1,040.00 Arbitrary allocation of time (§ II.C). $520.00 $910.00

12/19/2006 12/21/2006 1/19/2007 1/20/2007 1/23/2007 1/24/2007 1/29/2007 1/30/2007

Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel

2.0 1.0 3.0 3.0 1.2 3.0 2.0 1.0

$260.00 $260.00 $280.00 $280.00 $280.00 $280.00 $280.00 $280.00

Arbitrary allocation of time and description is too vague to determine if $520.00 allocation is reasonable (§ II.C). Arbitrary allocation of time and description is too vague to determine if $260.00 allocation is reasonable (§ II.C). Arbitrary allocation of time (§ II.C); allocation is excessive for "Review" $840.00 (§ III.B). $840.00 $336.00 Arbitrary allocation of time and description is too vague to determine if $840.00 allocation is reasonable (§ II.C). $560.00 Arbitrary allocation of time (§ II.C). $280.00 Arbitrary allocation of time (§ II.C).

1/31/2007 3/2/2007

Hirzel Hirzel

10.0 10.5

4.0 4.0

$280.00 $280.00

$1,120.00 Arbitrary allocation of time (§ II.C). Arbitrary allocation of time and description is too vague to determine if $1,120.00 allocation is reasonable (§ II.C). Arbitrary allocation of time and description is too vague to determine if $1,400.00 allocation is reasonable (§ II.C). $280.00 Arbitrary allocation of time (§ II.C). "Read transcript. Read Konig Deposition" are work that would have $1,764.00 performed regardless of discovery dispute (§ III.A). $532.00 $56.00 Arbitrary allocation of time and description is too vague to determine if $560.00 allocation is reasonable (§ II.C).

3/5/2007 3/7/2007 3/8/2007 3/9/2007 3/10/2007

Hirzel Hirzel Hirzel Hirzel Hirzel

9.9 2.0 6.3 1.9 0.2

5.0 1.0 6.3 1.9 0.2

$280.00 $280.00 $280.00 $280.00 $280.00

3/12/2007
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Hirzel

5.8

2.0 4 of 6

$280.00

Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 5 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Hirzel Total Description Entry Hours Hours Claimed Hourly Rate 91.4 Total $24,946.00 Objections

11/15/2006 Powell Powell Total

Conf. with MM re privilege log project; Instructions prepared and conf. with Brenda Grier

0.4

0.4 0.4 0.6

$175.00

Descriptions are too vague to determine if related to the Motions (§ $70.00 II.A). $70.00 $147.00

8/2/2006 DiTomo Discuss Motion to Compel with STH Legal research re motion to compel in district court; review standards for attorney client 8/5/2006 DiTomo privilege; work product and scope of discovery

0.6

$245.00

2.0

2.0

$245.00

Reviewed file including complaint; discovery; 8/7/2006 DiTomo and memorandum concerning discovery issues.

1.5

1.5

$245.00

8/8/2006 DiTomo Review file; discuss discovery issues with STH

2.5

2.5

$245.00

8/9/2006 DiTomo Review privilege log and possible objections. Reviewed privilege log and identified objections 8/14/2006 DiTomo thereto. Review documents pertaining to opposing 8/15/2006 DiTomo party's privilege log.

0.5 0.5 2.6

0.5 0.5 2.6

$245.00 $245.00 $245.00

Document review; draft outline for production 8/16/2006 DiTomo deficiencies.

4.0

2.0

$245.00

"review standards..." is work that would have been performed $490.00 regardless of discovery dispute (§ III.A). "Reviewed file" is work that would have been performed regardless of discovery dispute (§ III.A); "discovery" -description is too vague to determine if related to the Motions and if hours are reasonable (§§ II.A-B); "memorandum..." -description is too vague to determine if $367.50 related to the Motions and if hours are reasonable (§§ II.A-B). "Reviewed file" is work that would have been performed regardless of discovery dispute (§ III.A); "discovery issues..."--description is too $612.50 vague to determine if related to the Motions (§ II.A), "Review privilege log" is work that would have been performed regardless of discovery dispute (§ III.A) and description "possible objections" is to vague to determine if objections related to discovery $122.50 issues raised in the Motions. "Review privilege log..." is work that would have been performed $122.50 regardless of discovery dispute (§ III.A). "Review documents..." is work that would have been performed $637.00 regardless of the discovery dispute (§ III.A). "Document Review" is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); "draft outline..." is too vague to determine if related to the Motions (§ II.A) and could be for work that is unrelated to discovery issues raised in the Motions (§ III.A); arbitrary allocation of time and description is too vague to determine if allocation is $490.00 reasonable (§ II.C). "Document Review" is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); "legal research" description is too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); arbitrary allocation of time and description is too vague to $490.00 determine if allocation is reasonable (§ II.C).

Document review; legal research concerning 8/17/2006 DiTomo discovery.
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4.0

2.0 5 of 6

$245.00

Case 1:04-cv-01339-SLR

Document 172-8
EXHIBIT G

Filed 05/20/2008

Page 6 of 6

Section III.B - Excessive Hours Spent on Plaintiffs' Motion to Compel and Reply Entries from August 2, 2006 through March 12, 2007
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections

Document review; legal research concerning 8/18/2006 DiTomo discovery.

3.0

2.0

$245.00

Production review; draft outline concerning 8/22/2006 DiTomo privilege log deficiencies.

8.0

4.0

$245.00

Production review; Finalize drafting memorandum re legal standards to assess 8/23/2006 DiTomo sufficiency of privilege log. DiTomo Total

3.7

2.0 22.2

$245.00

"Document Review" is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); "legal research" description is too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); arbitrary allocation of time and description is too vague to $490.00 determine if allocation is reasonable (§ II.C). "Production Review" is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); "draft outline..." is too vague to determine if related to the Motions (§ II.A) and could be for work that is unrelated to discovery issues raised in the Motions (§ III.A); arbitrary allocation of time and description is too vague to determine if $980.00 allocation is reasonable (§ II.C). "Production Review" is too vague to determine if related to the Motions (§ II.A) or is work that would have been performed regardless of the discovery dispute (§ III.A); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ $490.00 II.C). $5,439.00

Timekeeper A. Gilchrist Sparks III Alan J. Stone S. Mark Hurd Samuel T. Hirzel II Carol N. Powell John P. DiTomo Total

Hours Claimed 0.9 5.0 27.6 91.4 0.4 22.2 147.5

Total 555.00 $3,000.00 $13,265.00 $24,946.00 $ 70.00 $ 5,439.00 $47,275.00 $

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