Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

Document 172-3
EXHIBIT B

Filed 05/20/2008

Page 1 of 5

Sections II.A and II.B - Time Entries Are Vague and Lack Sufficient Specificity
Date Attorney Description Entry Hours 0.3 Hours Claimed 0.3 Hourly Rate $600.00 Total Objections

10/4/2006 Sparks Conference

4/25/2007 Sparks Motion to compel; trial prep 5/16/2007 Sparks Telecalls; review memo

3.0 0.7

1.5 0.7

$625.00 $625.00

5/15/2007 Sparks Telecall 5/19/2007 Sparks Emails re privileged docs Sparks Total

0.5 0.2 3.2

0.5 0.2

$625.00 $625.00

$180.00 Description is too vague to determine if related to the Motions (§ II.A). Description is too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ $937.50 II.C). Descriptions are too vague to determine if related to the Motions and if $437.50 hours are reasonable (§ II.A, B); Description is too vague to determine if related to Motions (§ II.A); arbitrary allocation of time and description is too vague to determine if $312.50 allocation is reasonable (§ II.C). $125.00 Description is too vague to determine if related to the Motions (§ II.A); $1,992.50

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 is $950.00 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).

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

264921

1 of 5

Case 1:04-cv-01339-SLR

Document 172-3
EXHIBIT B

Filed 05/20/2008

Page 2 of 5

Sections II.A and II.B - Time Entries Are Vague and Lack Sufficient Specificity
Date Attorney Description Entry Hours Hours Claimed Hourly Rate Objections "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). 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). Total "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). $100.00 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); $500.00 arbitrary allocation of time (§ II.C). Descriptions are 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 determine if allocation is reasonable (§ $500.00 II.C). Descriptions are too vague to determine if related to the Motions and if $900.00 hours are reasonable (§ II.A, B); 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 $1,650.00 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 $2,900.00 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 $500.00 determine if allocation is reasonable (§ II.A-C). $15,315.00

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

10/11/2006

Hurd

Document review; chronology; outline re open discovery issues

7.0

2.0

$475.00

11/19/2006 1/22/2007 2/12/2007

Hurd Hurd Hurd

Document review; revise letter; emails re discovery issues Emails re discovery issues teleconferences re discovery issues

2.0 0.2 3.8

2.0 0.2 1.0

$475.00 $500.00 $500.00

5/16/2007 5/17/2007

Hurd Hurd

Teleconferences; emails re scheduling issues; document review Emails; teleconferences; document review

2.5 1.8

1.0 1.8

$500.00 $500.00

5/19/2007

Hurd

Document review

3.3

3.3

$500.00

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

5/23/2007 Hurd Total

Hurd

1.3

1.0 31.5

$500.00

264921

2 of 5

Case 1:04-cv-01339-SLR

Document 172-3
EXHIBIT B

Filed 05/20/2008

Page 3 of 5

Sections II.A and II.B - Time Entries Are Vague and Lack Sufficient Specificity
Date Attorney Description 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 Entry Hours Hours Claimed Hourly Rate Total Objections "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).

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

Hirzel Hirzel Hirzel Hirzel

1.8 1.4 0.6 0.5

1.8 0.7 0.6 0.5

$260.00 $260.00 $260.00 $260.00

$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). 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 $364.00 (§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 $650.00 (§ 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 $950.00 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 $520.00 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 $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). 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 $1,420.00 in the Motions (§ III.A).

10/2/2006

Hirzel

Draft letter re: production.

0.3

0.3

$260.00

10/4/2006

Hirzel

Discovery letter

1.4

1.4

$260.00

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

10/11/2006

Hirzel

6.5

2.0

$475.00

10/12/2006

Hirzel

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

6.2

2.0

$260.00

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

4/14/2008

Hirzel

Trial

13.0

4.0

$355.00

264921

3 of 5

Case 1:04-cv-01339-SLR

Document 172-3
EXHIBIT B

Filed 05/20/2008

Page 4 of 5

Sections II.A and II.B - Time Entries Are Vague and Lack Sufficient Specificity
Date Attorney Hirzel Total Description Entry Hours Hours Claimed 17.0 Hourly Rate Total $5,230.00 Objections

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

1.5

1.5

$245.00

$367.50

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

2.5

2.5

$245.00

$612.50

8/9/2006 DiTomo Review privilege log and possible objections.

0.5

0.5

$245.00

$122.50

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

4.0

2.0

$245.00

$490.00

"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 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 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 issues raised in the Motions. "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).

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). "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).

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

264921

4 of 5

Case 1:04-cv-01339-SLR

Document 172-3
EXHIBIT B

Filed 05/20/2008

Page 5 of 5

Sections II.A and II.B - Time Entries Are Vague and Lack Sufficient Specificity
Date Attorney Description Entry Hours Hours Claimed Hourly Rate 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); arbitrary allocation of time and description is too vague to determine if allocation is reasonable (§ $490.00 II.C). $4,042.50 Total

Production review; Finalize drafting memorandum re legal standards to assess 8/23/2006 DiTomo sufficiency of privilege log. DiTomo Total Conf. with MM re privilege log project; Instructions prepared and conf. with Brenda Grier

3.7

2.0 16.5

$245.00

11/15/2006 Powell Powell Total

0.4

0.4 0.4

$175.00

Descriptions are too vague to determine if related to the Motions (§ $70.00 II.A). $70.00 Description is too vague to determine if related to the Motions and if $1,376.00 hours are reasonable (§ II.A, B). Description is too vague to determine if related to the Motions and if $608.00 hours are reasonable (§ II.A, B). Description is too vague to determine if related to the Motions and if $336.00 hours are reasonable (§ II.A, B). Description is too vague to determine if related to the Motions and if $48.00 hours are reasonable (§ II.A, B). Description is too vague to determine if related to the Motions and if $144.00 hours are reasonable (§ II.A, B). $2,512.00

4/25/2007 Randall Legal research 4/26/2007 Randall Memorandum writing 4/26/2007 Randall Writing memorandum 4/26/2007 Randall writing memorandum 4/27/2007 Randall Writing memorandum Randall Total

8.6 3.8 2.1 0.3 0.9

8.6 3.8 2.1 0.3 0.9 15.7

$160.00 $160.00 $160.00 $160.00 $160.00

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

Hours Claimed 3.2 5.0 31.5 17.0 16.5 0.4 15.7 89.3

Total $1,992.50 $3,000.00 $15,315.00 $5,230.00 $4,042.50 $70.00 $2,512.00 $32,162.00

264921

5 of 5