Free Statement - District Court of Arizona - Arizona

ROSENTHAL LAW OFFICES .
David S. Rosenthal
Gregory A. Rosenthal
4545 East Shea Blvd., Suite 206
Phoenix, AZ 85028
(602) 494-0664
May 31, 2004
Sarah Costilow
MID—CONTINENT GROUP
P.O. Box 18836
Oklahoma City OK 73154-0836
In Reference To: YOUR INSURED: Mike O'Conner
YOUR CLAIM NO.: 1526329
CLAIMANT: True Center Gate Leasing, lnc.
DATE OF LOSS: 5/1 /02
y I-Iours Amount
5/3/2004 GAR Review voluminous notes from deposition of Fleming to 6.20 S 744.00
prepare for last day of deposition (.9); Travel to deposition
(.3); Attend and conduct deposition of Fleming (4.5);
Return travel from deposition -- rush hour (.5).
5/4/2004 GAR Travel to deposition of Kammerzell -- rush hour (.6); 6.20 744.00
Attend and participate in deposition of Kammerzell--lst
day (5.0); Return travel from deposition (.5); Receipt and
review of letter from Rowe re: inspection of documents (.1).
5/5/2004 GAR Receipt and review of fax from adverse attorney re: photo 0.30 I 36.00
and Supplemental Request for Production (.2); E-mail to
adverse attorney re: settlement proposal (.1).
5/6/2004 GAR Travel to deposition of Kammerzell -- day 2 (.4); Attend 5.60 672.00
and participate in deposition and meeting with counsel re: ‘
depositions and strategy (4.8); Return travel from _
deposition (.4).
5/7/2004 GAR Travel to deposition of Kammerzell —— day 3 (.4); Attend 6.50 780.00
and participate in deposition and meeting with co-counsel
re: depositions and strategy (4.9); Return travel from
deposition (.4); Call to Mike O'Conner re: status (. 1);
Review protective order re: deposition preparation (.3);
Call to client re: depositions and status (.3); Receipt and
review of Sonoran's Response to Request to Produce (.1).
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Sarah Costilow Page 2
Hours Amount
5/10/2004 GAR Call from Mike O‘cormer re: in town, meeting and 9.50 1,140.00
depositions (.3); Travel to deposition of Kammerzell —— day
4 —— and meeting with Mike O'Conner (.5); Attend and
participate in deposition of Kamm erzell and numerous
strategy meetings (8.2); Return travel from deposition (.5).
5/11/2004 GAR Travel to deposition of Kammerzell -— day 5 —— rush hour 6.90 828.00
(.6); Attend and participate in deposition of Kammerzell
(5.8); Meet with counsel after deposition to discuss
schedule and strategy (.2); Return travel from deposition
(.3).
5/12/2004 GAR Travel to meeting with all defense parties in preparation of 6.30 756.00
deposition of O'Conner (.5); Attend meeting with parties
and client and prepare for deposition of Mike _O'Conner and
review of his voluminous files re: gate design and 1
correspondence re: same (4.5); Return travel from meeting
—— rush hour (.6); Review prior response to Request to
Produce and Disclosure Statement re: whether gate
sketches were disclosed (.2); Further review of United
Puett website re: logos (.2); Draft Supplemental Disclosure
Statement re: sketches and Puett logos (.3).
5/13/2004 GAR Travel to early morning meeting with client in preparation 10.30 1,236.00
for his deposition —- rush hour (.6); Attend meeting with
client in final preparation for his deposition (.7); Travel
from meeting to deposition site (.2); Meet with adverse
attorney and other counsel re: production of new
documents (.3); Attend and defend deposition of Mike
O'Conner (not including lunch) (7.5); Meet after deposition
and discuss case, deposition and strategy with client and
Kammerzell (.4); Return travel from deposition —— rush
hour (.6).
5/14/2004 GAR Receipt and review of Plaintiffs Fifth Supplemental 1 .30 156.00
Disclosure Statement re: additional patents and prior art
(.2); Receipt and review of Plaintiffs Sixth Supplemental
Disclosure Statement re: additional patents and prior art
(.2); Receipt and review of letter from adverse attorney re:
discovery and confidentiality issues (.1); Revise and edit
Supplemental Response to Request to Produce (.3); Receipt
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Sarah Costilow Page 3
Hours Amount
and review of K—Zell's Response to Plaintiffs Second
Nonuniform lnterrogatories (.1); Receipt and review of
K—Zell's lengthy Response to Plaintiffs Third Request to
Produce (.4). .
5/17/2004 GAR Prepare for deposition of R. Puett. 0.50 60.00
5/18/2004 GAR Travel to deposition of R. Puett (.3); Attend and participate 4.40 528.00
in deposition of R. Puett -— day 1 (3.1); Meet with counsel
after deposition to discuss deposition and strategy (.5);
Return travel from deposition —— rush hour (.5).
5/19/2004 GAR Travel to deposition of R. Puett —- rush hour (.5); Attend 2.70 324.00
and participate in deposition of R. Puett —— day 2 (1.8);
Return travel from deposition (.4).
5/21/2004 GAR Receipt and review of letter from Sullivan re: stipulation 0.20 l 24.00
for expert disclosure (.1); Letter to all parties re: same (.1).
5/24/2004 GAR Status report to S. Costilow re: depositions, expenses and 0.50 60.00
Motion for Summary Judgment.
5/28/2004 GAR Receipt and review of e—mail from adverse attorney re: 0.50 60.00
deposition signatures and review (.1); Receipt and review
of e—mail from Sullivan re: same (.1); Review scheduling
order and draft e—mail to all parties re: deposition and
Motion for Summary Judgment deadline (.2); Receipt and
review of e-mail from S. Costilow re: sharing expenses and
A fees (.1).
Total Time Charges Due 67.90 $8,148.00
Costs lncurred:
5/18/2003 Kwik Kopy. 15.13
5/31/2004 May Photocopy Charges (617 @ .10). 61.70
May Fax Charges (4 pages). ‘ 4.00
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