Free Response in Opposition to Motion - District Court of Arizona - Arizona

EXHIBIT D
Case 2:02-cv-02639-SRB Document 161-5 Filed 11/16/2005 Page1 of 3

EXHIBIT D
Non-Specific Legal Research Summary from
BILLING STATEMENT FOR LEGAL SERVICES RENDERED BY SABINUS A.
MEGWA FOR NICHOLAS ALOZIE AGAINST THE MILLS CORP., ET AL.
DATE PROFESSIONAL ssavicas TIME _
04/19/02 Legal research Re: legal theory of Alozie's claim if any W Hrs
02/] I/03 Legal Research Re: Opposition to Def s Motion to Dismiss g_0g Hrs
02/26/03 Legal Research Re: Opposition to Defs Motion to Dismiss g_O0 I.II·S
7/15/05 Legal research and Drafting of Plaiiitiffs First Motion in Limine 7.00 hrs
Re: To Exclude Expert Opinion Report and Anticipated Testimony of
Defendanfs Expert, Brent C. Habakangas.
7/15/05 Legal research and Drafting of Plaintiffs First Motion in Limine 3.00 hrs
Re: To Exclude Expert Opinion Report and Anticipated Testimony of
Defendant's Expert, Brent C. Habakangas
7/16/05 Legal Research and Drafting of Plaintiffs Second Motion in Limine 2.50 Hrs
Re: Exclusion of All Evidence, Regarding a Shooting Incident at
Plaintiff s Store at Spectrum Mall
7/16/05 Legal Research and Drafting of Plaintiff" s Third Motion in Limine 1.50 Hrs
Re: To Exclude Evidence of Late Filing of Plaintiffs Income Tax
Returns
7/17/05 Legal Research and Drafting of Plaintiff’ s F o u r t h in 1.50 hrs
Limine
Re: To Exclude Evidence of Other Lawsuits
7/ 17/05 Legal Research and Drafting of Plaintiffs Fifth Motion in Limine 1.50 hrs
Re: To Exclude or Limit Expert Opinion Report and
Anticipated Testimony of Defendants' Expert, Paul R. Bjorklund
7/19/05 Reviewed Motion and conducted legal research Re; Defendants’ 2.00 hrs
Motion in Limine For Exclusions of Unsupported
Compensatory Damages By Plaintiffs Expert Witness
7/19/055 Reviewed Motion and conducted legal research Re: Defendants' 2.50 hrs
Motion in Limine For Exclusion of Damages Opinion by Retail
Leasing Rebuttal Expert Witness
7/19/05 Reviewed Motion and conducted legal research Re: Defendants’ 2.00 hrs
Motion in Limine for Exclusion of Expert Testimony by Plaintiff
Dr. Alozie As Fact Witness
7/20/05 Reviewed Motion and conducted legal research Re: Defendants' 5.00 hrs
Motion in Limine for Exclusion of Testimony by PlaintiffDr. Alozie
and Others Based on Lack of Personal Knowledge or Hearsay
Case 2:02-cv—02639-SBB Document 161 -5 Filed 11/16/2005 Page 2 of 3

7/21/05 Reviewed Motion and conducted legal research Re: Defendants 8.00 hrs
Motion in Limine for Exclusion of Any Testimony or Evidence
Regarding Punitive Damages
7/22/05 File review and legal research and drafting Plaintiffs version hr
of the Joint Proposed Pretrial Order
7/24/05 File review, legal research and drafting of Plaintiffs version of the 7.00 hrs
Jury Instructions and Pretrial order
7/26/05 Reviewed Motion and conducted legal research Re: Defendants 6.00 hrs
Motion in Limine for Exclusion of Any Testimony or Evidence
Regarding Punitive Damages
7/26/05 Reviewed Motion and conducted legal research Re: Defendants' 2.00 hrs
Motion in Limine for Exclusion of Testimony By Plaintiff
Dr. Alozie and the Introduction of Any Other Evidence Regarding
Certain Alleged Categories of Compensatory Damages
7/26/05 Reviewed Motion and conducted legal research. Re: Defendants' 1.50 hrs
Motion in Limine lor Exclusion of Expert Testimony by Fact Witness
7/26/05 Reviewed Motion and conducted legal research Re: Defendants’ hr
Motion in Limine for Exclusions of Any Testimony Regarding
Damage to Stored Inventory
8/25/05 Research Re: Post-trial motions; Re: New Trial, Costs & Atty Fees 1.00 hr
10/ l 2/05 Legal Research: Re: Preparation for Reply Defendants' Response 2.00 hrs
To Plaintiffs Motion for New Trial
10/13/05 Legal Research: Re: Preparation for Reply to Defendants' Response hr
To Plaintiff’ s Motion for New Trial
10/ 14/05 Legal Research Re: Preparation for Reply to Defendants' Response 3.00 hr
to Plaintiff s Motion for New Trial
10/15/05 Legal Research: Re: Preparation for Reply to Defendants' Response 1.50 hr
to Plaintiff s Motion for New Trial
10/17/05 Legal Research and Drafting of Reply to Defendants' Response 5.00 hrs
to Plaintiffs Motion for New Trial
975 _
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Case 2:02-cv-02639-SRB

Document 161-5

Filed 11/16/2005

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Case 2:02-cv-02639-SRB

Document 161-5

Filed 11/16/2005

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Case 2:02-cv-02639-SRB

Document 161-5

Filed 11/16/2005

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