Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 1 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Description Date Attorney 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 Entry Hours 0.6 Hours Claimed Hourly Rate 0.6 $245.00 Total $147.00 Objections

2.0

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. "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

$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. 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 172-2
EXHIBIT A

Filed 05/20/2008

Page 2 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections 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. 4/27/2007 Heaney e-mail Hirzel re attorneys fees Work on trans. memo, revise production for hot documents, organize B's hot documents, confer 8/2/2006 Hirzel with JPD re: meeting Privilege documents issues; call with Wood; confer with Mark Hurd, John DiTomo and Mary 8/15/2006 Hirzel Muffley re: discovery motions. Meet and confer re: follow up letter and prepare 8/24/2006 Hirzel for meeting with REDACTED 9/8/2006 9/9/2006 Hirzel Hirzel Letter to Thomas Wood. Revise letter. Follow up production discovery

3.7 0.2

2.0 0.2

$245.00 $475.00

"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). $95.00

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). 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).

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

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

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Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 3 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections 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). 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).

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

Hirzel Hirzel Hirzel Hirzel

11/29/2006

Hirzel

11/30/2006 12/13/2006

Hirzel Hirzel

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

Hirzel Hirzel Hirzel Hirzel

12/19/2006

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. Revise Motion to Compel with new "L" documents and log. Edit Lamm outline with new documents. Dictate chron of new "L" documents. Finish dictation of new "L" Hot Docs. Revise Motion to Compel. Revise and edit Motion to Compel. Revise and edit Motion to Compel and compile exhibits. Finalize draft of Motion to Compel. Dictate additional production. Incorporate "L" production into Lamm outline. Review SMH edits to logs.

0.2 1.6 1.5 6.5

0.2 1.6 1.0 4.0

$260.00 $260.00 $260.00 $260.00

$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

$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 allocation $1,300.00 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);

8.0 6.5 2.0 3.5

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

4.0

2.0

$260.00

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

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Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 4 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date 12/21/2006 1/19/2007 1/20/2007 1/23/2007 1/24/2007 1/29/2007 1/30/2007 Attorney Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Description Privilege log issues. Review and dictate new documents. 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 Letter to Court with Neuberger; draft motion to supplement; confer with Gil Sparks and Rodger D. Smith; read Lanias [sic] Telephone call with Arbor counsel; revise new documents from Wood; file Motion to Supplement; revise Baker documents Revise PTO, confirm facts in PTO, conference calls re PTO, review privileges re MTC Order, draft letter, revise PTO Finalize PTO, finish letter to Court re privilege log, review new Weil documents, respond to Boyle e-mail re letters to Court, Entry Hours 1.8 5.3 3.0 1.2 5.8 5.7 6.0 Hours Claimed 1.0 3.0 3.0 1.2 3.0 2.0 1.0 Hourly Rate $260.00 $280.00 $280.00 $280.00 $280.00 $280.00 $280.00 Total Objections 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). Arbitrary allocation of time and description is too vague to determine if $840.00 allocation is reasonable (§ II.C). Arbitrary allocation of time and description is too vague to determine if $190.00 allocation is reasonable (§ II.C). Arbitrary allocation of time and description is too vague to determine if $840.00 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

Hirzel

5.8

2.0

$280.00

3/19/2007

Hirzel

4.2

3.0

$280.00

3/22/2007

Hirzel

1.2

0.5

$380.00

4/18/2007

Hirzel

11.1

3.0

$280.00

4/19/2007

Hirzel

8.2

2.0

$280.00

$560.00 Arbitrary allocation of time (§ II.C).

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Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 5 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date Attorney Description Research "Affiliate" issues, Motion to Compel follow-up, revise Arbor Outline, draft Capobianco Outline, draft Zyblerberg [sic] Outline, research re: Shield/Sword Draft motion for further relief, trial preparation issues Draft reply on motion for further relief, trial preparation Read opinion, read answering brief Draft reply on motion for further relief Edit reply brief Review new privilege documents and compare to privilege logs, edit reply brief Revise and edit brief Trial, Lamm deposition Entry Hours Hours Claimed Hourly Rate Total Objections

4/25/2007 5/4/2007 5/7/2007 5/15/2007 5/17/2007 5/18/2007 5/21/2007 5/22/2007 4/8/2008

Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel Hirzel

4.2 9.0 4.0 0.6 5.0 1.3 6.2 3.0 14.4

2.0 5.0 2.0 0.6 5.0 1.3 6.2 3.0 4.0

$280.00 $280.00 $280.00 $280.00 $280.00 $280.00 $280.00 $280.00 $355.00

Arbitrary allocation of time and description is too vague to determine if $560.00 allocation is reasonable (§ II.C). $1,400.00 Arbitrary allocation of time (§ II.C). $560.00 Arbitrary allocation of time (§ II.C). $168.00 $1,400.00 $364.00 "Review..." is work that would have been performed regardless of $1,736.00 discovery dispute (§III.A); hours claimed are excessive (§III.B); $840.00 Arbitrary allocation of time (§ II.C); hours claimed are excessive and $1,420.00 redundant because Mr. Sparks also charged for time (§III.B). 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). 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). "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).

4/14/2008

Hirzel

Trial

13.0

4.0

$355.00

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

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

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Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 6 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date Attorney Description Entry Hours Hours Claimed Hourly Rate Objections 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). Total 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). 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 $950.00 regarding the discovery issues raised in 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). Arbitrary allocation of time and description is too vague to determine if $1,000.00 allocation is reasonable (§ II.C). Arbitrary allocation of time and description is too vague to determine if $2,500.00 allocation is reasonable (§ II.C). $200.00 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 $500.00 description is too vague to determine if allocation is reasonable (§ II.C). Descriptions are too vague to determine if related to the Motions and if $900.00 hours are reasonable (§ II.A, B);

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

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 3/23/2007

Hurd 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 Review and revise motion to supplement record; expert report; deposition review Pretrial preparation; response to motion for clarification or order granting motion to compel etc Review order; teleconference with client; emails re motion

2.0

2.0

$475.00

6.5 0.2 1.5 3.8 3.5 5.5

2.0 0.2 1.0 1.0 2.0 2.0

$500.00 $500.00 $500.00 $500.00 $500.00 $500.00

4/25/2007 5/15/2007

Hurd Hurd

9.4 0.8

5.0 0.4

$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

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Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 7 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date Attorney Description Entry Hours Hours Claimed Hourly Rate Total Objections 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). Two hours to prepare for deposition the day before the same witnesses testified at trial is excessive (§III.B). Hours are excessive because same attorney charged 3.5 hours on same day; further this entry demonstrates arbitrary allocation of time (§ II.C)

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 Deposition preparation; deposition of A Arenson

5.8

5.8

$500.00

$2,900.00

5/23/2007 4/13/2008

Hurd Hurd

1.3 3.5

1.0 3.5

$500.00 $525.00

$500.00 $1,837.50

4/13/2008

Hurd

11/15/2006

Powell

Trial preparation; Arenson deposition Conf. with MM re privilege log project; Instructions prepared and conf. with Brenda Grier

14.0

4.0

$525.00

$2,100.00

0.4 8.6 3.8 2.1 0.3 0.9 0.3 0.6 7.0

0.4 8.6 3.8 2.1 0.3 0.9 0.3 0.6 1.0

$175.00 $160.00 $160.00 $160.00 $160.00 $160.00 $600.00 $625.00 $621.00

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 10/4/2006 Sparks Conference 1/29/2007 Sparks Review motion 4/18/2007 Sparks PTO; order to compel; preparation

Descriptions are too vague to determine if related to the Motions (§ $70.00 II.A). 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). $180.00 Description is too vague to determine if related to the Motions (§ II.A). $375.00 Arbitrary allocation of time and description is too vague to determine if $621.00 allocation is reasonable (§ II.C). 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 (§ II.C). 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). Descriptions are too vague to determine if related to the Motions and if hours are reasonable (§ II.A, B);

4/25/2007 Sparks Motion to compel; trial prep 5/7/2007 Sparks Motions and trial prep 5/15/2007 Sparks Telecall 5/16/2007 Sparks Telecalls; review memo 5/19/2007 Sparks Emails re privileged docs 4/8/2008 Sparks Trial; Lamm deposition and preparation
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3.0 2.8 0.5 0.7 0.2 12.8

1.5 1.0 0.5 0.7 0.2 4.0 7 of 8

$625.00 $625.00 $625.00 $625.00 $625.00 $675.00

$937.50 $625.00 $312.50 $437.50

$125.00 Description is too vague to determine if related to the Motions (§ II.A); Two hours to prepare for a two hour deposition when trial is in $2,700.00 progress is excessive (§III.B); arbitrary allocation of time (§ II.C).

Case 1:04-cv-01339-SLR

Document 172-2
EXHIBIT A

Filed 05/20/2008

Page 8 of 8

All Time Entries from the Application in Chronological Order with Defendants' Objections Date 3/8/2007 3/9/2007 Attorney Stone Stone Description Motion to Compel Motion to Compel Brief Entry Hours 3.0 1.5 0.5 Hours Claimed 3.0 1.5 0.5 241.7 Hourly Rate $600.00 $600.00 $600.00 Total Objections

$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). $82,026.00

3/10/2007 Stone Motion to Compel brief Total Hours and Fees

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