Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

EXHIBIT E Section III.A - Time Entries for Work Unrelated to Discovery Dispute in the Motions
Entry Hours Hours Claimed Hourly Rate Total

Document 172-6

Filed 05/20/2008

Page 1 of 2

Date

Attorney

Description

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

10/2/2006

Hirzel

Draft letter re: production.

0.3

0.3

$260.00

$78.00

10/4/2006

Hurd

Document review; revising correspondence re discovery issues

1.0

1.0

$475.00

$475.00

10/4/2006

Hirzel

Discovery letter

1.4

1.4

$260.00

$364.00

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

10/6/2006

Hirzel

Revise letter and confer with Smith re: docs.

2.5

2.5

$260.00

$650.00

10/12/2006

Hirzel

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

6.2

2.0

$260.00

$520.00

Objections 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). 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 (§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). 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). "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). 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). 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).

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Case 1:04-cv-01339-SLR

EXHIBIT E Section III.A - Time Entries for Work Unrelated to Discovery Dispute in the Motions
Entry Hours Hours Claimed Hourly Rate Total

Document 172-6

Filed 05/20/2008

Page 2 of 2

Date

Attorney

Description

10/13/2006

Hirzel

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

1.8

1.0

$260.00

10/23/2006

Hirzel

Read Wood letters.

0.2

0.2

$260.00

Objections 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 $260.00 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 (§ $52.00 III.A). "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 the Motions (§ III.A). Description is too vague to determine if related to the Motions (§ II.A); unlikely "Emails" related to discovery issues raised in the Motions (§ III.A). "Document.." would have been performed regardless of dispute (§ III.A); work is unrelated to discovery issues raised in the Motions because final brief was filed on 5/22/07 (§ III.A); Arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ II.A-C). Description is too vague to determine if related to Motions and if hours are reasonable (§ II.A, B); work is unrelated to discovery issues raised in the Motions (§ III.A).

11/19/2006

Hurd

Document review; revise letter; emails re discovery issues

2.0

2.0

$475.00

$950.00

1/22/2007

Hurd

Emails re discovery issues

0.2

0.2

$500.00

$100.00

5/23/2007

Hurd

Document review; teleconference re scheduling; email to court re same

1.3

1.0

$500.00

$500.00

4/14/2008

Hirzel

Trial

13.0

4.0

$355.00

$1,420.00

Timekeeper S. Mark Hurd Samuel T. Hirzel II Total

Hours Claimed Total 14.5 $6,917.50 13.4 $4,294.00 27.9 $11,211.50

264923

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