Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01339-SLR

Document 172-11
EXHIBIT J

Filed 05/20/2008

Page 1 of 2

Section III.B - Excessive Hours Spent on Plaintiffs' Motion for Further Relief and for Sanctions and Response in Support Entries from April 25, 2007 to May 22, 2007
Entry Hours Hours Claimed

Date

Attorney

Description

Hourly Rate

Total

4/25/2007 5/7/2007 5/15/2007 5/16/2007

Sparks Motion to compel; trial prep Sparks Motions and trial prep Sparks Telecall Sparks Telecalls; review memo

3.0 2.8 0.5 0.7 0.2

1.5 1.0 0.5 0.7 0.2 3.9

$625.00 $625.00 $625.00 $625.00 $625.00

$937.50 $625.00 $312.50 $437.50

Objections 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);

5/19/2007 Sparks Emails re privileged docs Sparks Total Pretrial preparation; response to motion for clarification or order granting motion to compel etc Review order; teleconference with client; emails re motion

$125.00 Description is too vague to determine if related to the Motions (§ II.A); $2,437.50

4/25/2007 5/15/2007

Hurd Hurd

9.4 0.8

5.0 0.4

$500.00 $500.00

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); "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). 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 (§ $900.00 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 $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)". $8,650.00 $95.00 $95.00

5/16/2007

Hurd

Teleconferences; emails re scheduling issues; document review

2.5

1.0

$500.00

5/17/2007

Hurd

Emails; teleconferences; document review

1.8

1.8

$500.00

5/19/2007

Hurd

Document review

3.3

3.3

$500.00

5/22/2007 Hurd Total

Hurd

motion for sanctions; document review

5.8

5.8 17.3 0.2 0.2

$500.00

4/27/2007 Heaney e-mail Hirzel re attorneys fees Heaney Total 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

0.2

$475.00

4/25/2007 5/4/2007 5/7/2007

Hirzel Hirzel Hirzel

4.2 9.0 4.0

2.0 5.0 2.0

$280.00 $280.00 $280.00

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).

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Case 1:04-cv-01339-SLR

Document 172-11
EXHIBIT J

Filed 05/20/2008

Page 2 of 2

Section III.B - Excessive Hours Spent on Plaintiffs' Motion for Further Relief and for Sanctions and Response in Support Entries from April 25, 2007 to May 22, 2007
Entry Hours 0.6 5.0 1.3 6.2 3.0 Hours Claimed Hourly Rate 0.6 $280.00 5.0 $280.00 1.3 $280.00 6.2 3.0 25.1 $280.00 $280.00

Date Attorney Description 5/15/2007 Hirzel Read opinion, read answering brief 5/17/2007 Hirzel Draft reply on motion for further relief 5/18/2007 Hirzel Edit reply brief Review new privilege documents and compare 5/21/2007 Hirzel to privilege logs, edit reply brief 5/22/2007 Hirzel Revise and edit brief Hirzel Total

Total $168.00 $1,400.00 $364.00

Objections

"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 $7,028.00 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 S. Mark Hurd Julia Heaney Samuel T. Hirzel II Karl Randall Total

Hours Claimed 3.9 17.3 0.2 25.1 15.7 62.2

Total $ 2,437.50 $ 8,650.00 $ 95.00 $ 7,028.00 $ 2,512.00 $20,722.50

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