Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

Document 172-7

Filed 05/20/2008

Page 1 of 4

EXHIBIT F Section III.A - Time Entries Hours for Work That Would Have Been Performed Regardless of Discovery Dispute
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections 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 is too vague to determine if allocation is reasonable (§ II.C). 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 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 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 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 raised in the Motions (§ III.A).

8/23/2006

Hurd

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

7.5

2.0

$475.00

$950.00

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

$2,090.00

10/4/2006

Hurd

Document review; revising correspondence re discovery issues

1.0

1.0

$475.00

$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

$1,140.00

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

$1,662.50

10/11/2006

Hurd

Document review; chronology; outline re open discovery issues

7.0

2.0

$475.00

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 $950.00 description is too vague to determine if 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 $950.00 regarding the discovery issues raised in the Motions (§ III.A). Descriptions are too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); "document review" 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 $500.00 allocation is reasonable (§ II.C).

11/19/2006

Hurd

Document review; revise letter; emails re discovery issues

2.0

2.0

$475.00

5/16/2007

Hurd

Teleconferences; emails re scheduling issues; document review

2.5

1.0

$500.00

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Case 1:04-cv-01339-SLR

Document 172-7

Filed 05/20/2008

Page 2 of 4

EXHIBIT F Section III.A - Time Entries Hours for Work That Would Have Been Performed Regardless of Discovery Dispute
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections Descriptions are too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); "document review" is work that would have been performed regardless of the discovery dispute (§ III.A). Description is too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); work that would have been performed regardless of the discovery dispute (§ III.A). "Motion for sanctions"--Description is too vague to determine if hours are reasonable (§ II.B); "document review" would have been performed regardless of dispute (§ III.A)". "Document.." would have been performed regardless of dispute (§ III.A); Arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ II.A-C).

5/17/2007

Hurd

Emails; teleconferences; document review

1.8

1.8

$500.00

$900.00

5/19/2007

Hurd

Document review

3.3

3.3

$500.00

$1,650.00

5/22/2007

Hurd

motion for sanctions; document review Document review; teleconference re scheduling; email to court re same

5.8

5.8

$500.00

$2,900.00

5/23/2007 Hurd Total

Hurd

1.3

1.0 30.2

$500.00

$500.00 $14,667.50

10/12/2006

Hirzel

11/30/2006 12/13/2006 3/8/2007 5/21/2007 Hirzel Total

Hirzel Hirzel Hirzel Hirzel

Review new L production. Revise privilege log. Send letter to Wood. 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. Edit reply brief. Read transcript. Read Konig deposition. Review new privilege documents and compare to privilege logs, edit reply brief

6.2

2.0

$260.00

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 $520.00 reasonable (§ II.C).

7.5 10.1 6.3 6.2

5.0 10.1 6.3 6.2 29.6

$260.00 $260.00 $280.00 $280.00

$1,300.00 $2,626.00 $1,764.00 $1,736.00 $7,946.00

"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 allocation is reasonable (§ II.C). "Review..." is work that would have been performed regardless of discovery dispute (III.A); hours claimed are excessive (III.B); "Read transcript. Read Konig Deposition" are work that would have performed regardless of discovery dispute (§ III.A). "Review..." is work that would have been performed regardless of discovery dispute (§III.A); hours claimed are excessive (§III.B);

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

2.0

2.0

$245.00

"review standards..." is work that would have been performed $490.00 regardless of discovery dispute (§ III.A).

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Case 1:04-cv-01339-SLR

Document 172-7

Filed 05/20/2008

Page 3 of 4

EXHIBIT F Section III.A - Time Entries Hours for Work That Would Have Been Performed Regardless of Discovery Dispute
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections "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.AB); "memorandum..." -description is too vague to determine if related $367.50 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 or is work unrelated to the Motions (§ III.A) and description "possible objections" is to vague to determine if objections related to discovery issues raised in the Motions. "Review privilege log..." is work that would have been performed regardless of discovery dispute (§ III.A). "Review documents..." is work that would have been performed 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 reasonable (§ II.C).

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

$122.50 $122.50 $637.00

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

4.0

2.0

$245.00

$490.00

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

4.0

2.0

$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). "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 8/18/2006 DiTomo discovery.

3.0

2.0

$245.00

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Case 1:04-cv-01339-SLR

Document 172-7

Filed 05/20/2008

Page 4 of 4

EXHIBIT F Section III.A - Time Entries Hours for Work That Would Have Been Performed Regardless of Discovery Dispute
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections "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 allocation is $980.00 reasonable (§ II.C).

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 21.6

$245.00

"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 $490.00 description is too vague to determine if allocation is reasonable (§ II.C). $5,292.00

Timekeeper S. Mark Hurd Samuel T. Hirzel II John P. DiTomo Total

Hours Claimed Total 30.2 $14,667.50 29.6 $7,946.00 21.6 $5,292.00 81.4 $27,905.50

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