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
September 30, 2002
Eldon L. Huckabay
Senior Claims Representative -
MID-CONTINENT GROUP
P.O. Box 18836
Oklahoma City OK 73154-0836
In Reference To: YOUR INSURED: Mike O'Cormer
YOUR CLAIM NO.: 1526329
CLAIMANT: True Center Gate Leasing, Inc.
DATE OF LOSS: 5/1/02
_ Hours Amount
9/5/02 GAR Receipt and review of Sonoran's Response to Request to 0.20 24.00
Produce.
9/18/02 GAR Receipt and review of letter from adverse attorney re: 1.30 156.00
answers to Request to Produce (.1); Review Request to
Produce and rules to determine whether response are due
(.6); Review file documents re: response to Request to
Produce (.4); Prepare and finalize response to Request to
Produce (.2).
9/19/02 GAR Receipt and review of letter from adverse attorney re: 0.90 108.00
whether Cavanagh firm represented Plaintiff previously
(.1); Receipt and review of letter from adverse attomey re:
potential stipulation to dismiss portions of case —— analyze
points of offer to dismiss and potential dismissal (.5); 1
Receipt and review of K-Zell's Notice of Service of
Response to Request to Produce (.1); Receipt and review of
K—Zel1's Response to Request to Produce (.2). »
9/23/02 GAR Receipt and review of client's draft answers and responses 2.00 240.00
to Request to Produce —- review voluminous documents
provided by Mike O'Conner.
9/24/02 GAR Draft initial draft of answers to Nonuniform Interrogatories 1.00 120.00
and Request to Produce. i
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Eldon L. Huckabay Page 2
Hours Amount
9/24/02 SG Review, organize and Bates stamp documents received 1.60 1 12.00
from client in response to discovery requests.
9/25/02 GAR Very lengthy telephone conference with client re: case facts 5.50 660.00
and allegations and discovery responses (1.2); Analyze
proposal for dismissal of Counts 1, 2, 3 and 8, and compare
with allegations in Complaint (1.0); Draft answers to
Request to Produce (.8); Draft answers to Nonuniform
Interrogatories (.7); Call to adverse attorney re: discovery
requests (.2); Research re: Uniform Trade Secrets Act to
determine whether O'Conner's gate design violated trade
secrets (1.6).
9/26/02 GAR Call from attorney Shook re: discovery requests and review 1.10 132.00
allegations against K—Zell and O'Comier (.4); Review
K-Zell website re: gate information (.2); Research on—line
re: True Center website and horse gate design (.5).
9/30/02 GAR Letter to adverse attorney re: discovery response date (.2); 0.80 96.00
Letter to E. Huckabay re: discovery and case status (.6).
Total Time Charges Due 14.40 $1,648.00
Hourly Rate and Time Summary
Name Hours Rate
Goodwin, Sherri 1.60 70.00
Rosenthal, Gregory 12.80 120.00
Federal Tax1.D. # 86-0375032
Invoice #:14099 _
Case 2:02-cv-01109-DGC Document 220-4 Filed O1/17/2006 Page 2 of 2

Case 2:02-cv-01109-DGC

Document 220-4

Filed 01/17/2006

Page 1 of 2

Case 2:02-cv-01109-DGC

Document 220-4

Filed 01/17/2006

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