for the eastern district of louisiana...

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF LOUISIANA

LUTHER SCOTT, JR., and LOUISIANA

STATE CONFERENCE OF THE

NAACP,

Plaintiffs,

v.

TOM SCHEDLER, in his official capacity as

the Louisiana Secretary of State, SUZY

SONNIER, in her official capacity as

Secretary of the Louisiana Department of

Children & Family Services, and BRUCE D.

GREENSTEIN, in his official capacity as


Health & Hospitals,

Defendants.

Civil Action No. 2:11-cv-00926-JTM-

JCW

Section “H”

PLAINTIFFS’ MOTION TO SET ATTORNEYS’ FEES AND COSTS

Plaintiffs Luther Scott, Jr. and the Louisiana State Conference of the NAACP

respectfully move the Court to fix attorneys’ fees and costs pursuant to the Findings of Fact and

Conclusions of Law (Doc. No. 436), concluding that the Defendants violated the National Voter

Registration Act, 42 U.S.C. § 1973gg, et. seq.

Accordingly, as set forth in the accompanying memorandum of law, Plaintiffs

seek attorneys’ fees in the amount of $2,894,514.80 and costs and expenses in the amount of

$141,907.35 from the Defendants. These amounts represent the lodestar amounts for hours spent

on prosecuting this action (adjusted by taking a discount of 10% of the entire amount), a

discounted payment for travel time (50 percent of the lodestar rate), and costs and expenses

incurred related to this action.

Case 2:11-cv-00926-JTM-JCW Document 446 Filed 02/26/13 of 4

The accompanying memorandum of law summarizes the totals for each category

of fees claimed and describes in detail how the amount for each category was calculated. The

requested out-of-district hourly rates are reflective of the specialized skills and experience of

counsel in this case and the unavailability of local counsel willing and able to take on this matter.

Further, the accompanying declarations from Plaintiffs’ counsel detail all requested fees, costs

and expenses incurred in litigating this action, reduced by removing duplicative or excessive

entries or charges and otherwise by the exercise of billing discretion.

The results achieved by Plaintiffs constituted an unequivocal victory, and the

requested fees are conservatively calculated, fully documented, and in all respects reasonable.

As requested by your Honor in the Findings of Fact and Conclusions of Law (Doc. No. 436),

Plaintiffs respectfully submit this motion to set attorneys’ fees and costs and pray that the Court

award Plaintiffs’ the reasonable requested amounts in successfully litigating their claims.

Dated: February 26, 2013

Respectfully submitted,

/s/ Dale E.Ho____________________

Dale E. Ho ([email protected])*

Natasha M. Korgaonkar

([email protected])*

Debo P. Adegbile

Elise C. Boddie

Ryan P. Haygood ([email protected])*

NAACP Legal Defense & Educational Fund, Inc.

(New York)

99 Hudson Street, Suite 1600

New York, NY 10013

212-965-2200

*MOTION FOR ADMISSION PRO HAC VICE

GRANTED

Ronald Lawrence Wilson

([email protected])


Ronald L. Wilson, Attorney at Law

701 Poydras Street, Suite 4100

New Orleans, LA 70139

504-525-4361

Michael B. de Leeuw


Israel David ([email protected])*

Erica Sollie*

Jesse Ryan Loffler*

David Yellin*

Fried, Frank, Harris, Shriver & Jacobson LLP

One New York Plaza

New York, NY 10004

212-859-8000


GRANTED

Sarah Brannon ([email protected])*

Niyati Shah ([email protected])*

Michelle Rupp ([email protected])*

Project Vote

1350 Eye Street NW, Suite 1250

Washington, DC 20005

202-546-4173


GRANTED

Attorneys for Plaintiffs


CERTIFICATE OF SERVICE

I hereby certify that on the 26th of February, 2013, I electronically filed the

foregoing Notice of Submission with the Clerk of the Court using the CM/ECF system,

which will send a notice of electronic filing to persons electronically noticed. I further

certify that I mailed the foregoing document and the notice of electronic filing by first

class mail to any non-CM/ECF participant.

/s/ Dale E. Ho____________

8863014






NAACP,

Plaintiffs,

v.








Health & Hospitals,

Defendants.


JCW

Section “H”

NOTICE OF SUBMISSION

PLEASE TAKE NOTICE that Plaintiffs Luther Scott, Jr. and the Louisiana State

Conference of the NAACP will bring the attached Motion to Set Attorneys’ Fees and Costs

before the Honorable Judge Jane Triche Milazzo on the 26th day of February, 2013 at 10:00 a.m.



/s/ Dale E.Ho____________________




Debo P. Adegbile

Elise C. Boddie


Case 2:11-cv-00926-JTM-JCW Document 446-1 Filed 02/26/13 Page 1 of 3


(New York)


New York, NY 10013

212-965-2200


GRANTED


([email protected])




504-525-4361

Michael B. de Leeuw



Erica Sollie*

Jesse Ryan Loffler*

David Yellin*


One New York Plaza

New York, NY 10004

212-859-8000


GRANTED




Project Vote



202-546-4173


GRANTED









/s/ Dale E. Ho____________

8863006






NAACP,

Plaintiffs,

v.








Health & Hospitals,

Defendants.


JCW

Section “H”

ORDER

On Plaintiffs’ Motion to Set Attorneys’ Fees and Costs, and having reviewed the

submissions of Plaintiffs counsel and applied the lodestar methodology, I find that both the

hourly rates charged by Plaintiffs’ counsel, and the hours attributable to the relevant tasks are

eminently reasonable, as are the requested expenses, and IT IS HEREBY ORDERED that

attorneys’ fees and costs in favor of Plaintiffs pursuant to the Findings of Fact and Conclusions

of Law (Doc. No. 436) are set as follows:

1. Plaintiffs are awarded attorneys fees in the amount of $2,894,514.80.

2. Plaintiffs are awarded costs and expenses in the amount of $141,907.35.


This ___ day of February, 2013.

____________________________________

HONORABLE JANE TRICHE MILAZZO

UNITED STATES DISTRICT JUDGE






NAACP,

Plaintiffs,

v.








Health & Hospitals,

Defendants.


JCW

Section ―H‖

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS’ MOTION TO SET

ATTORNEYS’ FEES AND COSTS

On January 23, 2013, the Court issued Findings of Fact and Conclusions of Law (Doc.

No. 436) holding that each of the Defendants had violated the National Voter Registration Act,

42 U.S.C. §§ 1973gg et seq., and that Plaintiffs were entitled to reasonable attorneys‘ fees,

litigation expenses, and costs. As prevailing parties, Plaintiffs respectfully submit this

Memorandum of Law in support of Plaintiffs‘ motion to set attorneys‘ fees and costs and pray

that the Court award Plaintiffs‘ the reasonable requested amounts in successfully litigating their

claims.

This is the first case in the nation to be litigated to trial under the NVRA. As explained

below, this case already has had, and will continue to have, a significant impact on the ability of


2

Louisiana‘s most vulnerable citizens to register to vote, and thus, to exercise the most

fundamental right in our democracy. The significance of this Court‘s ruling interpreting the

NVRA will likely be felt beyond Louisiana. Moreover, this case was highly technical and

extremely complex. Despite considerable experience in civil rights litigation, Plaintiffs‘ local

counsel Ronald Wilson could not have litigated this case without the resources and support of a

large team of attorneys from outside of this district, who also brought unique expertise in voting

rights litigation and, specifically, experience with litigation under this particular statute.

Notably, the length of this litigation was due in part to the intransigence of Defendants, who

repeatedly rebuffed Plaintiffs‘ attempts to negotiate settlement, despite a number of undisputed

violations of the statute.

Plaintiffs seek attorneys‘ fees in the amount of $2,894,514.80and expenses in the amount

of $141,907.35. These amounts represent the lodestar amounts for hours spent on this litigation

(based on reduced, reasonable out-of-district hourly rates, as well as a careful exercise of billing

judgment, including (but not limited to), several exclusions for particular categories of attorney

time, and a further ten-percent (10%) across-the-board reduction by the three organizations and

firms representing Plaintiffs.

Plaintiffs achieved total success in this litigation. Accordingly, no reduction in

the requested fees – beyond the voluntary reductions already taken by Plaintiffs – is necessary or

appropriate.

STATEMENT OF FACTS

I. The Underlying Litigation

Plaintiffs Luther Scott Jr. and the Louisiana State Conference of the NAACP

(―Plaintiffs‖) brought this action on April 19, 2011, against Tom Schedler, in his official capacity


3

as the Louisiana Secretary of State (―SOS‖), Ruth Johnson,1 in her official capacity as Secretary

of the Louisiana Department of Children & Family Services (―DCFS‖), and Bruce D. Greenstein,

in his official capacity as Secretary of the Louisiana Department of Health & Hospitals (―DHH‖)

(collectively, ―Defendants‖), alleging that the Defendants had violated the NVRA, 42 U.S.C. §

1973gg et seq.2 Defendant SOS was responsible for coordinating the responsibilities of

Louisiana under the NVRA, and Defendants DCFS and DHH were considered mandatory voter

registration agencies under Louisiana law and administered a number of public assistance

programs including Supplemental Nutrition Assistance Program (―SNAP‖), the Family

Independence Temporary Assistance (―FITAP‖), Medicaid, the Woman, Infants and Children

Program (―WIC‖), and the Louisiana Children‘s Health Insurance Program (―LaCHIP‖).

Plaintiff Luther Scott Jr. is a recipient of benefits under the SNAP program.

During three separate transactions in 2009 and 2010, DCFS did not provide Mr. Scott the

information required under the NVRA. (Doc. No. 436, at 8-11). Plaintiff Louisiana State

Conference of the NAACP ―expended its limited resources, time, and money, to canvass and

conduct registrations outside of Louisiana DCFS and DHH offices‖ and, because of the failures

of those agencies — which failures were also traceable to Defendant SOS because of its failure

to coordinate their obligations under the NVRA — was ―forced to expend resources registering

Louisiana voters who would have already been registered if the Defendants had complied with

the NVRA.‖ (Doc. No. 436, at 18).

Prior to the filing of this action, Defendants DCFS and DHH systemically

violated the NVRA by, among others, failing to: i) set policies, practices, and procedures which

1 Secretary Johnson was replaced in her official capacity as Secretary of DCFS by Suzy Sonnier effective

July 31, 2012. 2 An additional plaintiff, Roy Ferrand, withdrew from the case prior to trial (Doc. No. 126), and Suzy

Sonnier, in her official capacity, was substituted for Ruth Johnson as Secretary of the Louisiana Department of

Children and Family Services as a defendant (Doc No. 363).


4

complied with the NVRA; ii) provide voter registration services with remote transactions; iii)

provide voter registration services with address changes or renewals of benefits; iv) provide

voter registration services unless the client checked the ―yes‖ box to a voter registration question

in a covered transaction; v) include a voter registration question in a number of forms; vi)

include disclaimers that registering to vote will not affect the ―amount‖ of assistance received;

and vii) provide the same level of assistance for voter registration as provided for benefits. (Doc.

No. 436, at 19-27). Defendant SOS failed to provide accurate and consistent training to the

agencies, if such trainings were conducted at all, and failed to ―engage in any other measures to

ensure that individual public assistance offices are complying with their responsibilities under

the NVRA.‖ (Doc. No. 436, at 28).

As litigation proceeded, Plaintiffs repeatedly attempted to settle this matter, only to see

those efforts rebuffed each time. First, before discovery had begun in earnest—and before the

parties had expended much time or resources on this matter—Plaintiffs repeatedly attempted to

engage in settlement negotiations, only for Defendants to cut off settlement conversations in

September 2011, refusing to even entertain the possibility of a settlement featuring continuing

jurisdiction by this Court—a form of relief that was ultimately awarded. See Ho Decl. ¶ 8,

Brannon Decl. ¶ 6. Next, after oral argument on partial summary judgment was conducted in

April 2012, this Court ordered further settlement discussions, and Plaintiffs once again expressed

their willingness to settle this matter. Defendants, however, once again refused to engage in

meaningful settlement conversations, and reiterated their refusal to even consider any settlement

involving continuing jurisdiction by this Court. See Ho Decl. ¶ 10, Brannon Decl. ¶ 6. Notably,

Defendants‘ repeatedly refused to engage in meaningful settlement conversations despite

numerous uncontested violations of the statute, set forth in the parties‘ Amended Pre-Trial Order,


5

see Doc. 373, at 12-21, and ultimately adopted by this Court‘s Findings of Fact and Conclusions

of Law, see Doc. 436, at 20, 25-26, 28.

Thus, this complex litigation lasted over 18 months, including: over one year of

discovery, with extensive document and electronic discovery (including several rounds of written

discovery requests served by both sides); several months of depositions; substantial discovery-

related litigation (including a successful motion to compel production of responsive documents

and to obtain a privilege log); cross-motions for partial summary judgment, granted in part for

Plaintiffs; and trial. The ECF docket in this case contains over 400 entries.

After a three day trial held in October 2012, this Court issued a permanent

injunction and its findings of fact and conclusions of law on January 23, 2013 and found that

Defendants DCFS and DHH came into substantial compliance only after this suit was filed, and

this, in addition to this Court‘s findings of fact and conclusions of law on Plaintiffs‘ allegations,

demonstrate that the Plaintiffs‘ suit was entirely successful — both by inducing DCFS and DHH

to come into compliance after filing of the suit, and in this Court‘s holdings after trial. (Doc. No.

436, at 32 (―It is undisputed that DHH and DCFS violated the NVRA prior to the filing of this

lawsuit. . . . It is evident that the SOS has failed to enforce the NVRA in Louisiana. Other than

publishing a manual on NVRA compliance and conducting sporadic and faulty training sessions,

the SOS has done nothing to ensure that the State comply with its NVRA obligations.‖)).

With the consent of all Defendants in this action, Plaintiffs filed an Ex Parte

Consent Motion for Extension of Time to File Motion to Set Attorneys‘ Fees and Costs (Doc.

No. 438) (the ―Extension Motion‖) and an Ex Parte Consent Motion to Expedite Submission

Date of the Extension Motion (Doc. No. 439) on Friday, February 8, 2013, requesting an


6

additional two weeks – until February 26, 2013 – to file a motion to set attorneys‘ fees and costs.

Your Honor granted those motions. (Doc. Nos. 440, 441).

This case has already had a substantial impact on the ability of Louisiana‘s most

vulnerable citizens to register to vote, and thus exercise the most precious right in our

democracy. Even before the decision on the merits, after this Complaint was filed in April 2011,

the number of voter registrations through public assistance offices increased seven-fold (when

comparing the third quarter of 2011 to the third quarter during the previous two years). See Pls.‘

Trial Exs. 54-55; Pls.‘ PFOF at 9, 29 (Doc. No. 372). Notably, this figure does not even include

voter registration forms submitted by public assistance clients through remote transactions (mail,

telephone, or internet). Prior to this case, Defendants refused to provide voter registration

services through such means, even though the vast majority of public assistance benefits

transactions are conducted remotely; this unlawful omission translated into hundreds of

thousands of Louisiana citizens being denied an opportunity to register to vote. Amended Pre-

Trial Order, Uncontested Facts 10-29 (Doc. No. 373). Furthermore, Defendants have also been

ordered to cure numerous other violations of the statute, which will further ensure that Louisiana

citizens are offered an opportunity to register to vote in accordance with federal law. (Doc. No.

436). Finally, the impact of this case will likely not be limited to Louisiana, as this Court‘s

rulings interpreting the scope of the NVRA and the requirements it places on state agencies will

also likely be influential in other district courts throughout the country.

The SOS filed a notice of appeal on February 19, 2013 and then also filed a

motion to a stay on February 22, 2013, stating that the Department of Health and Hospitals and

the Department of Children and Family Services have indicated that they do not intend to appeal


7

but rather, plan to certify compliance with the injunction to the court within the time permitted

by the court's order.

II. Plaintiffs‘ Counsel‘s Involvement in this Litigation

a. Plaintiffs’ Counsel

Counsel representing Plaintiffs throughout the litigation were comprised of

attorneys from four organizations and firms — the NAACP Legal Defense and Educational

Fund, Inc. (―LDF‖); Project Vote; Fried, Frank, Harris, Shriver & Jacobson LLP (―Fried Frank‖);

and Ronald Wilson — which together brought considerable experience in election

administration, voting rights, and complex federal litigation, as well as and local Louisiana

Practice. Plaintiffs‘ counsel also included an appropriate mix of attorney experience levels. The

Declarations of Michael de Leeuw, Sarah Brannon, Dale Ho, and Ronald Wilson describe the

qualifications and educational background of each attorney for whom Plaintiffs are seeking fees.

Litigating this complex matter required a large team of attorneys with substantial experience in

voting rights litigation, necessitating the participation of three organizations and firms from

outside of this district. As explained below, under these circumstances, awarding attorneys fees

in conformity with each attorney‘s home district is appropriate.

b. Hours Worked

Plaintiffs‘ counsel maintained detailed time records regarding their work in this

litigation. These records are attached as exhibits to the declarations of Plaintiffs‘ counsel, and

summarized in aggregate below. In total, Plaintiffs‘ counsel seek fees for a total of 7,312.6 hours

litigating this action to its successful conclusion, subject to certain exclusions described below.


8

c. Hourly Rates for Plaintiffs’ Counsel

For the reasons explained below in Plaintiffs‘ Argument, the hourly rates

requested by Plaintiffs‘ counsel are based on prevailing market rates in the Plaintiffs‘ counsel‘s

―home‖ districts, subject to reasonable reductions as described in the accompanying declarations

of counsel. The requested rates are as follows:

Counsel (by Organization/Firm) Year of Graduation Hourly Rate


(Home District: Southern District of New York)

Israel David 1996 $650

Michael de Leeuw 1996 $650

Erica Sollie 2008 $400

David Yellin 2011 $280

Jesse Ryan Loffler 2011 $280

Joseph Chan (Litigation Support) N/A $280

Michael Deguzman (Paralegal) N/A $200

NAACP Legal Defense and Educational Fund, Inc.

(Home District: Southern District of New York)

Ryan Haygood 2001 $600

Dale Ho 2005 $475

Natasha Korgaonkar 2007 $350

La Tanya Harry (Paralegal) 2007 $175

Dhiren Patel (Paralegal) N/A $175

Joseph Puma (Paralegal) N/A $175

Project Vote (Home District: District of the District

of Columbia)

Sarah Brannon 1999 $600

Nicole Kovite Zeitler 2006 $600

Niyati Shah 2005 $275

Michelle Rupp 2011 $280

Kelly Gerlach (Data Analyst) N/A $175

Law Offices of Ronald Wilson

(Home District: Eastern District of Louisiana)

Ronald Wilson 1975 $400


9

For time spent in travel, counsel are requesting rates discounted by fifty percent

(50%). Further, as set forth in the accompanying declarations, a number of attorneys, paralegals,

and other support staff assisted in review and management of the litigation and with filings, but

Plaintiffs‘ counsel voluntarily eliminated the hours billed by these individuals, as described more

fully in the accompanying declarations. See Declaration of Michael de Leeuw (―de Leeuw

Decl.‖); Declaration of Sarah Brannon (―Brannon Decl.‖); Declaration of Dale Ho (―Ho Decl.‖).

d. Expenses and Costs

As this Court‘s order permits recovery of litigation expenses and costs related to

this action (Doc. No. 436), this application also seeks reasonable expenses and costs, subject to a

number of voluntary exclusions set forth below. Itemizations of these expenses are also attached

as exhibits to the declarations of Plaintiffs‘ counsel.

ARGUMENT

As explained in detail below, Plaintiffs‘ requested amounts for fees and expenses are

eminently reasonable. The highly technical and complex nature of this case required the

participation of a large team of attorneys from outside of this district, who have expertise in

voting rights matters and trial practice, thus justifying the use counsel‘s home district rates in the

calculation of this fee award. Moreover, the number of hours for which Plaintiffs seek

compensation is eminently reasonable, particularly given the various exclusions and write-downs

that Plaintiffs have voluntarily adopted as an exercise of billing judgment.

I. Plaintiffs Are Entitled to the Requested Amount of Fees Under the Lodestar

Method

The Fifth Circuit uses the ―lodestar‖ method to calculate attorneys‘ fees, ―which

is applied by multiplying the number of hours reasonably expended by an appropriate hourly

rate.‖ Smith & Fuller, P.A. v. Cooper Tire & Rubber Co., 685 F.3d 486, 490 (5th Cir. 2012).


10

The ―linchpin of the reasonable fee is the lodestar calculation, a product of the hours reasonably

expended by the law firms and the reasonable hourly rate for their services.‖ McClain v. Lufkin

Indus., Inc., 649 F.3d 374, 381 (5th Cir. 2011), cert. denied, 132 S. Ct. 589 (2011). There is a

strong presumption that an award based on the lodestar method is a reasonable fee. See Smith &

Fuller, P.A., 685 F.3d at 490; see also Creecy v. Metro. Prop. & Cas. Ins. Co., 548 F. Supp. 2d

279, 283-84 (E.D. La. 2008). ―After the calculation of the lodestar, the burden then shifts to the

party opposing the fee to contest the reasonableness of the hourly rate requested or the

reasonableness of the hours expended ‗by affidavit or brief with sufficient specificity to give fee

applicants notice‘ of the objections.‖ Creecy, 548 F. Supp. 2d at 284 (citation omitted). As part

of the lodestar calculation, any charges for ―excessive, duplicative, or inadequately documented

work must be excluded.‖ McClain, 649 F.3d at 381.

a. Plaintiffs’ Counsel’s Hourly Rates are Reasonable

As an initial matter, Ronald Wilson‘s rates are reasonable and in accordance with

the rates that he normally charges and collects in this district. See Wilson Decl. ¶ 8.

With respect to out-of-district counsel, the Fifth Circuit has joined the majority of

its sister circuits in taking ―the position that out-of-district counsel may be entitled to the rates

they charge in their home districts‖ under certain circumstances, which are present here.

McClain, 649 F.3d at 381-82 (citing Hadix v. Johnson, 65 F.3d 532, 535 (6th Cir. 1995); Zolfo,

Cooper & Co. v. Sunbeam–Oster Co., 50 F.3d 253, 259–60 (3d Cir. 1995); Casey v. City of

Cabool, Mo., 12 F.3d 799, 805 (8th Cir.1993); Nat’l Wildlife Fed’n v. Hanson, 859 F.2d 313,

317 (4th Cir. 1988); Maceira v. Pagan, 698 F.2d 38, 40 (1st Cir. 1983); Donnell v. United States,

682 F.2d 240, 252 (D.C. Cir. 1982); Chrapliwy v. Uniroyal, Inc., 670 F.2d 760, 768–69 (7th Cir.

1982)).


11

In McClain, the Fifth Circuit cites positively the Sixth Circuit‘s two-prong test to

determine the appropriateness of out-of-district rates. Applying this two-prong test, ―courts must

determine (1) whether hiring the out-of-town specialist was reasonable in the first instance, and

(2) whether the rates sought by the out-of-town specialist are reasonable for an attorney of his or

her degree of skill, experience, and reputation.‖ McClain, 649 F.3d at 382 (quoting Hadix, 65

F.3d at 535).

(i) Reliance on Out-of-Town Counsel

First, Plaintiffs‘ use of out-of-town counsel was reasonable, thus justifying the use

of out-of-town rates in this fee award. In considering whether to award out-of-town rates, courts

inquire whether ―there is reason to believe that competent counsel was readily available locally

at a lower charge or rate.‖ Hadix, 65 F.3d at 535. In McClain, the Fifth Circuit held that out-of-

town counsel‘s rates should serve as the starting point of its lodestar calculation, because, inter

alia, the successful plaintiffs in that case offered sufficient proof of the need for out-of-town

counsel, in form of declarations fro local lawyers ―who swore that no [local] attorneys were

willing and able to assist in such a large case that might drag on for years without any guarantee

of financial remuneration.‖ 649 F.3d at 383. Such rates are particularly appropriate in civil

rights matters such as this case, given the nature of the interests at stake. Where, as here, ―out-

of-district counsel are proven to be necessary to secure adequate representation for a civil rights

plaintiff, the rates charged by that firm are the starting point for the lodestar calculation.‖ Id.

Accordingly, the Fifth Circuit remanded for the district court to reconsider its reduction of out-

of-town counsel‘s rate from $650 per hour to $400 per hour. See id. at 382-84.

Thus, courts in this district and elsewhere have routinely awarded out-of-town

rates. See, e.g., Greater New Orleans Fair Hous. Action Ctr. v. St. Bernard Parish, Civ. A. No.


12

06-7185, Doc. No. 381, at 35-37 (E.D. La. Sept. 1, 2010) (report and recommendation in civil

rights case, approving the use of hourly rates based on Washington, D.C. rates of up to $625 per

hour for out-of-district counsel, because out-of-town counsel served as lead counsel and had

specialized knowledge of the subject matter of the litigation); 2012 WL 4959636, at *7 (E.D. La.

Aug. 24, 2012), report and recommendation adopted, 2012 WL 4959633 (E.D. La. Oct. 17,

2012); Feinberg v. Hibernia Corp., 966 F. Supp. 442, 446 (E.D. La. 1997) (in complex securities

fraud class action, finding local rates to be ―unduly restrictive to out of state counsel‖ and that

―New York counsel pays New York rates in maintaining their law practices . . . [and] to restrict

New York counsel to the prevailing hourly charges in the less expensive New Orleans market

would be unduly unfair‖); Jeffers v. Clinton, 776 F. Supp. 465, 469 (E.D. Ark. 1991), vacated

and remanded on other grounds, judgment reinstated without change, 796 F. Supp 1202 (E.D.

Ark. 1992) (noting that the ―mammoth [Voting Rights Act] case could not have been undertaken

without the [NAACP] Legal Defense Fund‘s lawyers and resources,‖ that the ―expertise, energy,

and resources‖ of the LDF was instrumental in successfully prosecuting the case, and counsel‘s

―unique expertise‖ warranted the compensation of out-of-town attorneys at non-local rates).

This reasonableness standard for the use of out-of-town counsel is satisfied here.

As explained below, this complex voting rights case required a large team of practitioners with:

(i) substantial experience in this particular area of law; and (ii) the ability to commit significant

resources at the outset of the case. Here, as in McClain, local counsel were simply unavailable to

litigate this case. As explained in his declaration, William P. Quigley, who has practiced as a

public interest lawyer in southern Louisiana since 1977 and has been repeatedly recognized for

his work, Quigley Decl. at ¶¶ 2-5, states that ―there is a dearth of practitioners here who

specialize in voting rights and election law specifically, as LDF and its co-counsel do.‖ Quigley


13

Decl. at ¶ 8. Moreover, Mr. Quigley is aware of ―no attorneys in the Eastern District of

Louisiana who possess: (i) expertise in litigation under the NVRA, and (ii) sufficient time and

resources to serve as lead counsel in such a large case without any guarantee of financial

remuneration.‖ Quigley Decl. at ¶ 10. Mr. Quigley thus believes that it was ―reasonable that this

case was litigated by out-of-state attorneys, as local practitioners generally do not have both the

requisite specialization in the relevant area of law, along with the resources to undertake such a

lawsuit.‖ Quigley Decl. at ¶ 10.

Additionally, Ronald Wilson – local counsel in this matter since its inception –

has worked primarily on civil rights and other public interest cases in his nearly four decades of

practice in Louisiana, has participated in over thirteen voting rights cases in Louisiana, many

with LDF, and is well-recognized as a leader in the Louisiana legal community. Wilson Decl. at

¶¶ 10-13. Mr. Wilson concurs with Mr. Quigley that a voting rights claim such as the NVRA

claim at bar ―requires a significant investment of resources . . . invested upfront, and with

potentially no fees awarded at the end.‖ Wilson Decl. at ¶ 15. Although there are civil rights

attorneys in Louisiana, ―there is a paucity of in-state practitioners here who could have served as

lead counsel in this case.‖ Wilson Decl. at ¶ 16. In fact, even though Mr. Wilson has

considerable experience in civil rights cases, he affirms that he ―could not have litigated this case

without support‖ and ―[t]his is simply not an investment that a private practitioner in this District

could make independently.‖ Wilson Decl. at ¶ 16. Simply put, Mr. Wilson explains that he, like

local practitioners, ―do[es] not have the time or resources to serve as lead counsel for indigent

clients in a case, such as this one, without any guarantee of remuneration‖ and, in fact, he is

―doubtful that even two private practitioners in the New Orleans area could have undertaken this

litigation together.‖ Wilson Decl. at ¶ 16.


14

Thus, it was reasonable that this case was litigated primarily by out-of-state

counsel. Wilson Decl. at ¶ 17. Plaintiffs‘ out-of-town counsel expended the bulk of the hours in

this case. LDF, Project Vote, and Fried Frank were able to commit significant resources to this

complex civil rights matter, and brought significant expertise and experience with respect to

voting rights litigation and/or trial practice. See, e.g., Ho Decl. ¶¶ 14, 30-35 (explaining LDF‘s

voting rights work and the experience of its attorneys); Rosenberg Decl ¶¶ 11 (describing

experience and qualifications of LDF attorneys who worked on this matter); Brannon Decl. ¶¶

10-18; de Leeuw Decl. ¶¶ 2-6. Under these circumstances, out-of-town rates are appropriate.

See McClain, 649 F.3d at 383 (awarding out-of-town rates for civil rights practitioners where

local counsel was unavailable); Greater New Orleans Fair Hous. Action Ctr., Civ. A. No. 06-

7185, Doc. No. 381, at 35-37 (awarding out-of-town rates where counsel brought special

expertise to case at bar); Jeffers, 776 F.Supp. at 469 (awarding out-of-town expenses to LDF

based on LDF‘s ―unique‖ ―expertise, energy, and resources‖).

First, Plaintiffs‘ use of out-of-town counsel was reasonable. Where, as here, there

is strong, uncontradicted evidence that plaintiffs were required to turn to out-of-district counsel

to litigate their claims – such necessity rendering plaintiffs engagement of counsel in this matter

reasonable, see Declaration of William P. Quigley, at ¶¶ 8-10 (―Quigley Decl.‖); Declaration of

Ronald Wilson, at ¶¶ 15-17 (―Wilson Decl.‖) — counsel‘s ―‗home‘ rates should be considered as

a starting point for calculating the lodestar amount.‖ McClain, 649 F.3d at 382. In McClain, for

example, the 5th Circuit remanded after the district court had reduced out-of-town counsel‘s rate

from $650 per hour to $400 per hour; the Fifth Circuit held that the district court erred by failing

to use out-of-town counsel‘s rates as the starting point of its lodestar calculation. See id. at 382-

84; see also Greater New Orleans Fair Hous. Action Ctr. v. St. Bernard Parish, Civ. A. No. 06-


15

7185, 2012 WL 4959636, at *7 (E.D. La. Aug. 24, 2012), report and recommendation adopted,

2012 WL 4959633 (E.D. La. Oct. 17, 2012) (in Fair Housing Act civil rights case, approving the

use of hourly rates based on Washington D.C. rates up to $625 per hour for out-of-district

counsel); Greater New Orleans Fair Hous. Action Ctr. v. St. Bernard Parish, Civ. A. No. 06-

7185 (E.D. La. Sept. 1, 2010) (Doc. No. 381, at 14, 35-37; Doc. No. 381-1, Ex. A at 1), report

and recommendation adopted, (E.D. La. Oct. 17, 2012) (Doc. No. 394) (in earlier related

proceeding in Fair Housing Act case, approving use of Washington D.C. rates – up to $625 per

hour for the lead partner – for firm with specialized skills where local counsel could not be

located); Feinberg v. Hibernia Corp., 966 F. Supp. 442, 446 (E.D. La. 1997) (in complex

securities fraud class action, the court found local rates to be ―unduly restrictive to out of state

counsel‖ and ―New York counsel pays New York rates in maintaining their law practices . . .

[and] to restrict New York counsel to the prevailing hourly charges in the less expensive New

Orleans market would be unduly unfair‖); Jeffers v. Clinton, 776 F. Supp. 465, 469 (E.D. Ark.

1991), vacated and remanded on other grounds, judgment reinstated without change, 796 F. Supp

1202 (E.D. Ark. 1992) (noting that the ―mammoth [Voting Rights Act] case could not have been

undertaken without the [NAACP] Legal Defense Fund‘s lawyers and resources,‖ that the

―expertise, energy, and resources‖ of the LDF was instrumental in successfully prosecuting the

case, and counsel‘s ―unique expertise‖ warranted the compensation of out-of-town attorneys at

non-local rates).

In considering whether to award out-of-town rates, courts first determine

―whether hiring the out-of-town specialist was reasonable in the first instance.‖ McClain, 649

F.3d at 382 (quoting Hadix, 65 F.3d at 535)). Thus courts inquire whether ―there is reason to

believe that competent counsel was readily available locally at a lower charge or rate.‖ Hadix,


16

65 F.3d at 535; see also McClain, 649 F.3d at 383 (successful plaintiffs offered sufficient proofs

in form of local lawyers ―who swore that no Texas attorneys were willing and able to assist in

such a large case that might drag on for years without any guarantee of financial remuneration‖).

The Declarations of William P. Quigley and Ronald Wilson demonstrate that this

standard was met in this case. For example, William P. Quigley, who has practiced as a public

interest lawyer in southern Louisiana since 1977 and has been repeatedly recognized for his

work, Quigley Decl. at ¶¶ 2-5, explains that although there are Louisiana attorneys with general

civil rights experience, ―there is a dearth of practitioners here who specialize in voting rights and

election law specifically, as LDF and its co-counsel do.‖ Quigley Decl. at ¶ 8. Moreover, Mr.

Quigley was aware of ―no attorneys in the Eastern District of Louisiana who possess: (i)

expertise in litigation under the NVRA, and (ii) sufficient time and resources to serve as lead

counsel in such a large case without any guarantee of financial remuneration.‖ Quigley Decl. at

¶ 10. Mr. Quigley thus believed that it was ―reasonable that this case was litigated by out-of-

state attorneys, as local practitioners generally do not have both the requisite specialization in the

relevant area of law, along with the resources to undertake such a lawsuit.‖ Quigley Decl. at

¶ 10.

Additionally, Ronald Wilson – local counsel in this matter since its inception –

has worked primarily on civil rights and other public interest cases in his nearly four decades of

practice in Louisiana, has participated in over thirteen voting rights cases in Louisiana, many

with LDF, and is well-recognized as a leader in the Louisiana legal community. Wilson Decl. at

¶¶ 10-13. Mr. Wilson concurs with Mr. Quigley that a voting rights claim such as the NVRA

claim at bar ―requires a significant investment of resources . . . invested upfront, and with

potentially no fees awarded at the end.‖ Wilson Decl. at ¶ 15. Although there are civil rights


17

attorneys in Louisiana, ―there is a paucity of in-state practitioners here who could have served as

lead counsel in this case.‖ Wilson Decl. at ¶ 16. In fact, even though Mr. Wilson has

considerable experience in civil rights cases, he affirms that he ―could not have litigated this case

without support‖ and ―[t]his is simply not an investment that a private practitioner in this District

could make independently.‖ Wilson Decl. at ¶ 16. Simply put, Mr. Wilson explains that he, ―as

most private practitioners, do not have the time or resources to serve as lead counsel for indigent

clients in a case, such as this one, without any guarantee of remuneration‖ and, in fact, he is

―doubtful that even two private practitioners in the New Orleans area could have undertaken this

litigation together.‖ Wilson Decl. at ¶ 16. Therefore, it was reasonable that this case was

litigated by plaintiffs‘ out-of-state counsel. Wilson Decl. at ¶ 17.

(ii) The Reasonableness of Counsel‘s Rates

The second inquiry is ―whether the rates sought by the out-of-town specialist are

reasonable for an attorney of his or her degree of skill, experience, and reputation.‖ McClain,

649 F.3d at 382 (quoting Hadix, 65 F.3d at 535)). This Court has considerable discretion in

fashioning a fair and reasonable award of attorneys‘ fees and costs for prosecuting this complex,

time-consuming, and ultimately entirely successful litigation. See id. (―[A]ppellate courts should

be particularly reluctant to find an abuse of discretion. . . . [T]he district court retains discretion

to adjust the lodestar and achieve an overall reasonable fee award.‖); see also Nat’l Wildlife

Fed’n, 859 F.2d at 317 (―The computation of attorneys fees is primarily the task of the district

court, and we are not entitled to disturb a district court‘s exercise of discretion even though we

might have exercised that discretion quite differently.‖).3

3 Although Plaintiffs‘ counsel believes out-of-market rates are warranted in this case, even if the Court were

to be inclined to look at New Orleans rates, the requested rates – already discounted voluntarily by counsel – are not

unreasonable by comparison. See Wagner v. Boh Bros. Const. Co., LLC., Civ. A. No. 11-2030, 2012 WL 3637392,

at *14 (E.D. La. Aug. 22, 2012) (Wilkinson, J.) (collecting cases in New Orleans area finding reasonable rates for


18

Here, the rates sought by Plaintiffs‘ counsel are generally below market for

attorneys experienced in complex litigation generally and voting rights litigation in particular,

and thus well within reason. First, for purposes of this litigation, Fried Frank has dramatically

lowered its rates below what the firm normally charges and collects for its attorneys‘ time. See

de Leeuw Decl. ¶¶ 3-4, 9, 11.

Similarly, LDF‘s rates are well-below market for experienced practitioners of

complex civil litigation in New York. See, e.g., Declaration of Ezra D. Rosenberg at ¶¶ 13-14

(―Rosenberg Decl.‖); Declaration of Adam Klein at ¶¶ 10-11 (―Klein Decl.‖); Declaration of

Cyrus Mehri at ¶¶ 6-8 (―Mehri Decl.‖); Ho Decl. at ¶¶ 25-28. Indeed, LDF attorneys Dale Ho

and Ryan Haygood are former associates at Fried Frank, and their requested rates in this matter

are well below what Fried Frank would currently charge for their work. See de Leeuw Decl. ¶¶

3-5, 9-10. Moreover, the rates sought by LDF of $350 to $600 per hour are within the range of

rates awarded in civil rights litigation by New York courts. See, e.g., Vilkhu v. The City of New

York, 2009 U.S. Dist. LEXIS 73696 at *13 (E.D.N.Y. June 26, 2009) (describing the range of

rates paid to experienced civil rights attorneys as ―$250 to $600 . . . with average awards

increasing over time.‖); Rozell v. Ross-Holst, 576 F. Supp.2d 527, 546 (S.D.N.Y. 2008)

(awarding an experienced civil rights litigator fees at $600 per hour).

And, Project Vote‘s rates are similarly below what comparable firms would

charge in the Washington, D.C. market. See Brannon Decl. ¶¶ 21-25; Mehri Decl. ¶¶ 5-8.

Furthermore, the rates sought by Project Vote of $280 to $600 per hour are within the range for

D.C.-based attorneys as set forth under the Updated Laffey Matrix, on which the U.S. District

Court for the District for the District of Columbia frequently relies when awarding attorneys‘

attorneys up to $450 per hour for partner-level attorneys, and up to $112 per hour for paralegal work). Moreover,

even under the Johnson factors, discussed infra, ―[b]ecause the lodestar is presumptively reasonable, it should be

modified only in exceptional cases.‖ Wagner, 2012 WL 3637392, at *13.


19

fees. See Adjusted Laffey Matrix, available at http://laffeymatrix.com/see.html (setting rates for

attorneys of comparable experience levels at $312 to $625 per hour); Ricks v. Barnes, No. 05-

1756 HHK/DAR, 2007 U.S. Dist. LEXIS 22410, at *16 (D.D.C. Mar. 28, 2007) (finding

Updated Laffey Matrix rates reasonable); Smith v. District of Columbia, 466 F. Supp. 2d 151,

156 (D.D.C. 2006) (concluding that use of the Updated Laffey Matrix is reasonable‖).

Accordingly, all of the rates sought by Plaintiff‘s counsel are eminently

reasonable for the markets in which these attorneys practice.

b. Plaintiffs’ Counsel Worked Reasonable Hours, and This Time Should be

Fully Compensated

As a general proposition, all time that is excessive, duplicative or inadequately

documented should be excluded. See Wagner v. Boh Bros. Const. Co., LLC., Civ. A. No. 11-

2030, 2012 WL 3637392, at *15 (E.D. La. Aug. 22, 2012). Further, attorneys should ―exercise

‗billing judgment‘ by ‗writing off unproductive, excessive, or redundant hours‘ when seeking fee

awards.‖ Id. (quoting Green v. Administrators of the Tulane Educ. Fund, 284 F.3d 642, 662 (5th

Cir. 2002)).

As described in the accompanying declarations of Plaintiffs‘ counsel, Plaintiffs

have conservatively calculated the number of hours claimed in this fee application. See de

Leeuw Decl. at ¶¶ 9, 11; Brannon Decl. at ¶¶ 9; Ho Decl. at ¶¶ 20; Wilson Decl. at ¶¶ 6-8.

Counsel have reviewed their time records and exercised billing judgment to eliminate or reduce

time entries that could arguably be considered unproductive, duplicative, or excessive.

Additionally, counsel have voluntarily reduced their hours worked in the following respects: (i)

with respect to LDF and Project Vote, eliminating any time billed in investigating the claims

underlying this case, for purposes of drafting and filing the complaint, prior to the filing of the

Complaint on April 19, 2011; (ii) with respect to LDF and Project Vote, omitting time spent by


20

senior staff at reviewing and editing the briefing at the various stages of litigation; (iii) with

respect to LDF and Project Vote, writing off any additional attorney time whenever more than

two attorneys from either of their respective organizations attended a deposition; (iv) with

respect to Fried Frank, omitting time spent by paralegals helping on the matter, as needed from

time to time, and certain individuals from Fried Frank‘s Managing Attorneys Office, which

helped coordinate and file the numerous documents and briefing submitted in this case; (v) with

respect to all three organizations, billing travel time to and from Louisiana at one-half the

respective rates sought for attorneys in this litigation; (vi) with respect to all three organizations,

writing off all time in connection with the preparation and filing the instant fee application,

including the time expended gathering and reviewing counsel‘s records concerning work hours

and litigation expenses; (vii) with respect to all three organizations, writing off an additional ten

percent (10%) of the fees request as an exercise of billing judgment and to account for any

potential duplication. With these voluntary reductions, no further reductions are required.

c. Fees & Expenses Calculations

The ―lodestar‖ method ―is applied by multiplying the number of hours reasonably

expended by an appropriate hourly rate.‖ Smith & Fuller, P.A., 685 F.3d at 486. As discussed

above, Plaintiffs‘ counsel seeks an appropriate hourly rate for this case and the hours expended

and fees incurred in this action were eminently reasonable.4 The Court also ordered in the

Findings of Fact and Conclusions of Law (Doc. No. 436) that Plaintiffs be awarded costs and

4 Plaintiffs‘ counsel LDF and Project Vote have not included any time or expenses associated with the re-

depositions taken as a result of the grant of their motion for sanctions. (Doc. No. 423).


21

expenses in prosecuting this action. Thus, the attorneys‘ fees and expenses are calculated, by

counsel affiliation and cumulatively, as follows:5


Name Hours Rate Total

Israel David 58.3 $650 $30,095

Michael de Leeuw 459.7 $650 $288,730

Erica Sollie 308.2 $400 $118,140

David Yellin 389.6 $280 $107,268

Jesse Ryan Loffler 282.8 $280 $77,140

Michael Deguzman 18.7 $200 $3,740

Joseph Chan 12.4 $180 $2,232

Total 1555.4 $627,345

Total (less 10% voluntary reduction) $564,610.50



Ryan Haygood 185 $600 $110,000.00

Dale Ho 1414.3 $475 $671,792.50

Natasha Korgaonkar 922.3 $350 $322,805.00

Dhiren Patel 31.5 $175 $5,512.50

La Tanya Harry 62.1 $175 $10,867.50

Joseph Puma 260 $175 $45,500.00

Total 2875.2 $1,166,477.50

Total (less 10% voluntary reduction) $1,049,829.80

Project Vote


Sarah Brannon 702.1 $600 $394,310

Nicole Zeitler 638.8 $600 $369,630

Niyati Shah 781.9 $475 $354,540

Michelle Rupp 560.0 $280 $151,515

Kelly Gerlach 22.0 $175 $3,850

5 Note that the totals take into account a voluntary fifty percent (50%) reduction in the lodestar rate for any

travel time, and therefore, the total column may be less than a straight multiplication of the hours and rates, as set

forth in the exhibits to the accompanying declarations of plaintiffs‘ counsel.


22

Total 2,704.8 $1,273,845

Total (less 10% voluntary reduction) $1,146,460

Law Offices of Ron Wilson


Ron Wilson 177.2 $400 $70,880.00

Total 177.2 $70,880.00

Expenses

Counsel Total Expenses

Fried, Frank, Harris, Shriver & Jacobson LLP $49,838.96

NAACP Legal Defense and Education Fund, Inc. $60,939.44

Project Vote $31,128.95

Law Offices of Ron Wilson N/A

Total Expenses $141,907.35

Thus, the total fees, costs, and expenses incurred are $564,610.50 by Fried, Frank,

Harris, Shriver & Jacobson LLP, $1,049,829.80 by NAACP Legal Defense and Educational

Fund, Inc., $1,146,460.00 by Project Vote, and $70,880.00 by the Law Offices of Ron Wilson,

for a cumulative total of $2,894,514.80. In addition to the already reasonable reductions made,

Plaintiffs‘ counsel from LDF, Project Vote, and Fried Frank will voluntarily reduce the requested

amount by a ten percent (10%) across-the-board cut to the fee request, as reflected in the tables

above, as an exercise in billing judgment and to eliminate any duplicative or excessive hours

billed. Thus, the total fees, expenses and costs requested by Plaintiffs are $141,907.35, of which

each Defendant is responsible for one-third. Plaintiffs respectfully request that the Court award


23

Plaintiffs‘ these reasonable requested fees and expenses incurred in successfully litigating their

claims.6

II. The Lodestar Calculation Need Not be Adjusted

After the lodestar is calculated, ―which [lodestar calculation] is presumptively

reasonable,‖ the amount can be ―adjusted upward or downward by the district court based on the

district court‘s considerations of the [Fifth Circuit‘s] Johnson factors.‖ Wagner v. Boh Bros.

Const. Co., LLC., Civ. A. No. 11-2030, 2012 WL 3637392, at *12 (E.D. La. Aug. 22, 2012)

(citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714, 717-19 (5th Cir. 1974)). The

twelve Johnson factors are:

(1) the time and labor required for the litigation; (2) the novelty and difficulty of

the questions presented; (3) the skill required to perform the legal services

properly; (4) the preclusion of other employment by the attorney by acceptance of

the case; (5) the customary fee; (6) whether the fee is fixed or contingent; (7) time

limitations imposed by the client or circumstances; (8) the amount involved and

the result obtained; (9) the experience, reputation and ability of the attorneys; (10)

the ―undesirability‖ of the case; (11) the nature and length of the professional

relationship with the client; and (12) awards in similar cases.

Id.; see also Crosby v. Blue Cross Blue Shield of Louisiana, Civ. A. No. 08-0693, 2013 WL

139805, at *1 n.1 (E.D. La. Jan. 10, 2013).7 However, ―[b]ecause the lodestar is presumptively

reasonable, it should be modified only in exceptional cases.‖ Wagner, 2012 WL 3637392, at *13

(emphasis added). Moreover, after the party seeking attorneys‘ fees has submitted adequate

documentation of the hours reasonably expended and the qualifications of the attorneys, ―the

party seeking reduction of the lodestar bears the burden of showing that a reduction is

warranted.‖ Id.

6 Additionally details concerning these fees, costs and expenses are set forth in the accompanying

declarations of Plaintiffs‘ counsel. Further details, if necessary, can be provided based on contemporaneous records

maintained by Plaintiffs‘ counsel. 7 After Johnson was decided, the Supreme Court ―barred any use of the sixth factor, whether the fee is fixed

or contingent.‖ Wagner, 2012 WL 3637392, at *13 (citing Walker v. U.S. Dep’t of Housing & Urban Dev., 99 F.3d

761, 772 (5th Cir. 1996) (internal citation omitted).


24

The Fifth Circuit has instructed that, of the Johnson factors, the Court should give

special heed to: i) the time and labor involved; ii) the customary fee; iii) the amount involved and

the result obtained; and iv) the experience, reputation, and ability of counsel. Id. (citing Migis v.

Pearle Vision, Inc., 135 F.3d 1041, 1047 (5th Cir. 1998). It is without question that the result

obtained in the litigation was entirely on the side of the Plaintiffs. Counsel for Plaintiffs — with

significant experience handling voting and civil rights, and complex federal litigations —

diligently prosecuted this action, engaged in extensive fact discovery, and put on an ultimately

successful trial – all less than two years after filing the complaint, which itself required extensive

investigation prior to filing. Moreover, the result in this case is of both local and national

significance – it not only vindicates the rights of multitudes of Louisiana voters under the

NVRA, but also serves as a roadmap to compliance with the NVRA nationally, and as the only

Section 7 case to go to and complete trial, is of particular import for potential litigants seeking to

enforce their NVRA-related rights.

The same justifications weigh in favor of factors 3, 7, and 11; Plaintiffs‘ counsel

worked diligently on behalf of Plaintiffs to analyze numerous policies, practices, and forms — in

addition to successfully securing NVRA-related rights for public assistance beneficiaries

connecting with the agencies remotely, often using technology that did not exist when the NVRA

was passed — with no assurance they would be compensated for the time dedicated to the

litigation or reimbursement for the substantial litigation expenses of prosecuting this action

outside of their ―home‖ districts, and completed an extensive amount of discovery and legal

briefing under relatively short time limitations. Moreover, as this was the first time a case

proceeded to trial under Section 7 of the NVRA, plaintiffs‘ counsel had even less assurance of

compensation.


25

It is also well-established that cases vindicating civil rights are often

―undesirable‖ for attorneys because their ―decision to help eradicate discrimination is not

pleasantly received.‖ Johnson, 488 F.2d at 719. Despite their total vindication and success in

this matter, Plaintiffs‘ attempt to secure and enhance voting rights for the most vulnerable

Louisianans was not received well, as indicated by the Declarations of William Quigley and

Ronald Wilson, describing the unavailability of local counsel — as well as the fact that

Defendants often fought tooth and nail over even innocuous matters such as an amendment of

the case caption to accurately reflect the parties to the matter. Indeed, as noted, Plaintiffs

repeatedly attempted to settle this litigation before discovery began in earnest and the parties

expended much time or resources on this matter, see Ho Decl. ¶ 8, Brannon Decl. ¶ 6, and

attempted to do so again after partial summary judgment briefing, see Ho Decl. ¶ 10, Brannon

Decl. ¶ 6, only to be rebuffed on both occasions. Defendants repeatedly refused to even consider

any settlement featuring continuing jurisdiction by this Court—a form of relief that, as noted,

was ultimately ordered—despite the fact that Defendants‘ did not dispute numerous facts

indicating violations of the statute.

Further, ―[t]hree of the Johnson factors, complexity of the issues, results obtained

and preclusion of other employment, are presumably fully reflected and subsumed in the lodestar

amount.‖ Id. (citing Heidtman v. County of El Paso, 171 F.3d 1038, 1043 (5th Cir. 1999)).

Finally, awards in similar and analogous cases demonstrate that Plaintiffs‘

requested amounts in this case are eminently reasonable. See Valdez v. Herrera, No. 09-cv-668

JCH/DJS (D.N.M. Mar. 13, 2012) (Doc. No. 171) (awarding plaintiffs fees and costs in a case

involving Section 7 of the NVRA – which was resolved on summary judgment and settlement);

see also Inclusive Communities Project, Inc. v. Texas Dep’t of Housing & Community Affairs,


26

No. 3:08-cv-00546 (N.D. Tex. Feb. 15, 2013) (Doc. No. 214) (awarding attorneys‘ fees of

$1,869,577 and costs of $24,392 for success on the merits after a bench trial challenging race

discrimination in allocation of Low Income Housing Tax Credits); Graves v. Barnes, 700 F.2d

220, 221 (5th Cir. 1983) (affirming, after reducing by $2,300, an award of approximately

$948,700 in voting rights case); Lochren v. County of Suffolk, 344 F. App‘x 706, 707 (2d Cir.

2009) (the district court awarded $578,704.14 in attorneys‘ fees and costs in civil rights suit

regarding female advancement in police department; vacating and remanding for recalculation to

add amounts by applying 2008 rather than 2006 rates, and to add fees for a reply paper in the fee

application); Butler v. MBNA Tech. Inc., 140 F. App‘x 542, 543 (5th Cir. 2005) (in Title VII

claim, awarded fees of $265,205.07 for requested amounts only from the end of discovery

through completion of trial); Lalla v. City of New Orleans, 161 F. Supp. 2d 686, 713 (E.D. La.

2001) (in civil rights claims of racial discrimination against city, awarding plaintiffs attorneys‘

fees in the total amount of $250,922.34 and costs in the amount of $9,147.37 where claims were

decided on summary judgment and settled prior to trial).

Even if the Court were to consider the Johnson factors — which it should not

because ―the lodestar is presumptively reasonable‖ and under Johnson, ―it should be modified

only in exceptional cases,‖ Wagner, 2012 WL 3637392, at *13 — these factors weigh in favor of

awarding Plaintiffs the lodestar amount calculated with a reasonable rate based on counsel‘s

rates set forth above, and the reasonable hours expended in this litigation.

CONCLUSION

For the foregoing reasons, Plaintiffs respectfully request an award of reasonable

attorneys‘ fees in the amount of $2,894,514.80 and expenses in the amount of $141,907.35

incurred in connection with this litigation.


27



__/s/ Dale E. Ho _________________




Debo P. Adegbile

Elise C. Boddie



(New York)


New York, NY 10013

212-965-2200


GRANTED


([email protected])




504-525-4361

Michael B. de Leeuw



Erica Sollie*

Jesse Ryan Loffler*

David Yellin*


One New York Plaza

New York, NY 10004

212-859-8000


GRANTED




Project Vote




28

202-546-4173


GRANTED



29







__/s/ Dale E. Ho_______________

8863590


1

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

LUTHER SCOTT, JR. and the LOUISIANA STATE CONFERENCE OF THE NAACP, Plaintiffs,

v. TOM SCHEDLER in his official capacity as the Louisiana Secretary of State, SUZY SONNIER, in her official capacity as Secretary of the Louisiana Department of Children & Family Services, and BRUCE D. GREENSTEIN, in his official capacity as Secretary of the Louisiana Department of Health & Hospitals, Defendants.

Civil Action No. 2:11-cv-00926-JTM-JCW

DECLARATION OF EZRA D. ROSENBERG

I, Ezra D. Rosenberg, hereby declare the following: 1. I have been asked by attorneys for the NAACP Legal Defense and

Educational Fund, Inc. (“LDF”) to provide information, based on my personal knowledge

and belief, and my opinions regarding the reasonableness of the hourly rates that they

seek to have recognized in the petition for attorneys’ fees in this case.

2. I am a partner at Dechert LLP (“Dechert”), a leading international law

firm with 26 offices around the world and throughout the United States, including:

Austin; Boston; Charlotte; Chicago; Hartford; Los Angeles; New York; Orange County;

Philadelphia; Princeton; San Francisco; Silicon Valley; and Washington, D.C. Founded

in 1875, the firm has more than 900 lawyers. Dechert is consistently ranked among the


2

leading law firms in each of its core practice areas of corporate and securities, financial

services and investment management, intellectual property, litigation and government

enforcement, real estate and structured finance. Dechert has earned honors from industry

publications including Chambers, The American Lawyer, Best Lawyers, Bloomberg,

Thomson Reuters, The Legal 500, Benchmark Litigation and Law360.

3. Dechert also has a longstanding tradition of providing pro bono legal

services to individuals and organizations who cannot otherwise afford legal counsel.

Firm recognition for our pro bono efforts has included: the Pro Bono Project’s

Distinguished Service Award (New Orleans); the American Civil Liberties Union – New

Jersey’s Legal Leadership Award; The American Lawyer’s Pro Bono Rankings, Ranked

#7 out of 200 U.S. firms for Pro Bono (2012); the Citizens Bank Pro Bono Award

(Philadelphia); the City Bar Justice Center’s Jeremy G. Epstein Award for Pro Bono

Service; the District of Columbia Circuit Judicial Conference Standing; the Committee

on Pro Bono Legal Services, Forty at Fifty recognition; the First Judicial District’s Pro

Bono Roll of Honor; recognition by the Hebrew Immigrant Aid Society and Council

Service of Philadelphia for representation of abused spouses under the Violence Against

Women Act; the Lawyers Clearinghouse Pro Bono Award; recognition by the Lawyers’

Committee for Civil Rights Under Law for contributions to the 2008 Election Protection

program; the Legal Intelligencer and Volunteers for the Indigent Program’s Unsung Hero

Award; the National Law Center on Homelessness & Poverty's Pro Bono Counsel

Award; the National Legal Aid & Defender Association's 2011 Beacon of Justice Award;

the New York City Family Court Volunteer Attorney program’s Pro Bono Service

Award; the New York City Pro Bono Center’s Outstanding Volunteer of the Month; the


3

New York Legal Aid Society’s Pro Bono Publico Award; the Philadelphia Volunteers for

the Indigent Program’s Chancellor Award and Volunteer of the Month; the Political

Asylum/Immigration Representation Project’s Pro Bono Attorney of the Year; the State

Bar of California’s Wiley W. Manuel Certificate for Pro Bono Legal Services Award;

and the Washington Lawyers’ Committee’s Outstanding Achievement Award.

4. I began working at Dechert in 1995. I have handled a variety of complex

commercial litigation matters, both trial and appellate, throughout the United States. I

have served several terms on the firm’s Policy Committee, and as a Deputy Chair of the

firm. I am also a former co-chair of the Mass Torts and Product Liability Group. During

that time, Dechert’s Product Liability and Mass Torts practice was honored for three

consecutive years with the Award for Excellence in Product Liability by Chambers USA,

a referral guide to leading lawyers in the United States.

5. I have been repeatedly recognized for my practice at Dechert. From 2007

to 2012, I was selected among the top product liability litigators both in New Jersey and

nationwide by Chambers. I have also been selected among “The Best Lawyers in

America” for commercial litigation, mass tort litigation, and product liability litigation by

U.S. News and Best Lawyers. From 2007 to 2012, I was also highlighted in The Legal

500 (U.S.) in the fields of Consumer Products and Pharmaceutical Products Liability

Litigation Defense. I was named a “litigation star” for six consecutive years beginning in

2008 by Benchmark Litigation, and was recently named a “Life Science Star” in the

inaugural edition of LMG Life Sciences 2012. In 2011, I received the American Jewish

Committee Judge Learned Hand Award, which is given annually to an outstanding leader


4

in the legal profession who exemplifies the “high principles and noble tradition

associated” with Judge Hand.

6. I have also been very active in pro bono representations and civil rights

matters. I am currently representing a group of defendant-intervenors in Texas v. Holder,

--- F. Supp. 2d ---, No. 12-128, 2012 WL 3743676 (D.D.C. Aug. 30, 2012), in which a

three-judge federal district court blocked Texas’s recent attempt to implement a

government-issued photo identification measure. This case was recently appealed to the

United States Supreme Court. I note that LDF attorneys are participating in that litigation

as well, representing a different set of intervenors. Based on my experience in Texas v.

Holder, I know that voting rights litigation can be particularly challenging and very

complex.

7. I have worked on a number of other pro bono matters in recent years.

Together with two other public interest law groups, I am also representing a group of

African-American parents in a school desegregation case pending in the Eastern District

of North Carolina. I recently completed litigation against the Passaic County Jail,

resulting in a comprehensive settlement to improve jail conditions.

8. Prior to joining Dechert, I served as Assistant Deputy Public Defender and

Counsel to the Public Advocate of New Jersey from 1975 to 1978; as a senior trial

attorney at the U.S. Department of Justice (DOJ) from 1979 to 1982, where I litigated

matters a diverse range of matters, including one-House veto cases and Fifth Amendment

takings cases arising out of the Bikini Atoll nuclear testing, and earned the DOJ Award

for Meritorious Service; and (from 1982 to 1995) as an associate and then partner at a

small Trenton, NJ, firm, Katzenbach, Gildea & Rudner, which then merged into a


5

medium sized Philadelphia firm, Fox Rothschild O’Brien & Frankel, where I was a

partner.

9. I am a past president of the Mercer County Bar Foundation and Mercer

County Bar Association, and a former member of the New Jersey Supreme Court

Committee on Civil Jury Charges, the New Jersey Supreme Court Bench Bar Media

Committee, and the New Jersey State Bar Association’s Special Task Force on

Disciplinary Reforms. I am also a former trustee of the Association of the Federal Bar of

the State of New Jersey.

10. I received my J.D., cum laude, in 1974 from New York University School

of Law in 1974, where I received Founders Day Award, Order of the Coif, and the

American Jurisprudence Award in Constitutional Law. I received my B.A. in 1971, cum

laude from the University of Pennsylvania.

11. I am familiar with LDF and its well-established history of advancing racial

justice. I have high regard for LDF attorneys’ professionalism, skills, and abilities.

Through the Texas v. Holder litigation, I have worked directly with the three LDF

attorneys who worked on this case – Mr. Haygood, Mr. Ho, and Ms. Korgaonkar. They

each bring an impressive degree of competence, knowledge, skill, and expertise to their

practice.

12. Having served as one of the Deputy Chairs of the firm from 2008 through

2011, and as co-chair of its Mass Torts/Product Liability Practice Group from 2006

through 2011, and through the course of my practice, I am familiar with market

information, publicly available, as to billing rates charged by law firms around the

country. I have continued to follow national billing rates, including those charged by


6

firms in New York City, since then through national legal periodicals and other publicly

available information.

13. I understand that the following table reflects the current hourly rates being

sought by LDF attorneys who participated in the above-captioned matter, Scott v.

Schedler:

Name Position Year of Graduation

Rate

Ryan Haygood Director, Political Participation Group

2001 $600

Dale Ho Assistant Counsel 2005 $475

Natasha Korgaonkar Assistant Counsel 2007 $350

LaTanya Harry Paralegal 2007 $175

Joseph Puma Paralegal N/A $175

Dhiren Patel Paralegal N/A $175

14. Based upon my knowledge and experience, the hourly rates for LDF time

keepers (both lawyers and paralegals) are well within the range of reasonable rates

charged by lawyers and paraprofessionals dealing with complex civil matters around the

country. Considering the particular and extensive experience of the timekeepers in the

area of civil rights, and that their primary location is in New York City, their hourly rates

may be considered well below those that would be charged by similarly experienced

timekeepers in national firms situated in New York City.


7

I hereby declare under penalty of perjury that the foregoing is true and correct to

the best of my knowledge.

Executed on: February 22, 2013 /s/ Ezra D. Rosenberg


1



LUTHER SCOTT, JR. and the

LOUISIANA STATE CONFERENCE OF

THE NAACP,

Plaintiffs,

v.

TOM SCHEDLER in his official capacity

as the Louisiana Secretary of State, SUZY



Children & Family Services, and BRUCE

D. GREENSTEIN, in his official capacity

as Secretary of the Louisiana Department of

Health & Hospitals,

Defendants.


JCW

ATTORNEY DECLARATION OF DALE E. HO IN SUPPORT OF

PLAINTIFFS’ MOTION FOR ATTORNEYS’ FEES AND COSTS

Dale E. Ho, an attorney admitted to practice pro hac vice before this Court,

declares under penalty of perjury:

1. I am Assistant Counsel in the Political Participation Group of the NAACP

Legal Defense and Educational Fund, Inc. (“LDF”). LDF represents the plaintiffs in the

above-captioned action, along with Project Vote; Fried, Frank, Harris, Shriver &

Jacobson LLP (“Fried Frank”); and attorney Ronald Wilson.

2. I respectfully submit this declaration in support of Plaintiffs’ application

for an award of their attorneys’ fees and costs (the “Fee Application”), pursuant to this

Court’s Order awarding fees, dated January 22, 2013. Doc. No. 436.


2

3. This declaration is based on my personal knowledge, my consultation with

colleagues at LDF, Project Vote, Fried Frank, and Ronald Wilson, and a review of

documents related to this action.

FACTS RELEVANT TO THE FEE APPLICATION

4. Plaintiffs filed this civil rights action against Defendants on April 19,

2011, against a backdrop of many years of non-compliance with the National Voter

Registration Act (“NVRA”), 42 U.S.C. § 1973gg, et seq. Plaintiffs sought declaratory

and injunctive relief, including a permanent injunction requiring Defendants, their agents

and successors in office, and all persons working in concert with them, to implement

practices and procedures in compliance with Section 7 of the NVRA, 42 U.S.C. §

1973gg-5.

5. Counsel for the Plaintiffs—LDF, Project Vote, Ronald Wilson, and Fried

Frank—have longstanding expertise in civil rights litigation, including, inter alia, in the

areas of voting rights and election law, as well as a long history of working with and on

behalf of low-income and working class individuals and families and communities of

color.

6. Before even filing the case, Plaintiffs’ counsel conducted extensive factual

and legal research, including in-person investigations into Defendants’ non-compliance

with the NVRA, and attending meetings of local branches of the Louisiana State

Conference of the NAACP to discuss Defendants’ practices. Plaintiffs’ counsel also had

discussions with counsel in similar litigation efforts and strategized to develop the facts

and legal theories.


3

7. Before filing, Plaintiffs also attempted to resolve the issues without

litigation by serving all Defendants with a notice letter in January 2011, advising

Defendants of their non-compliance with federal law, and requesting a meeting with

Defendants. These efforts were unsuccessful, as Defendants failed to provide any

meaningful response to Plaintiffs’ request for a meeting at that time, thus leading to this

protracted litigation.

8. The Complaint was filed on April 19, 2011. After the Complaint was

filed, Defendants eventually provided a more detailed response to Plaintiffs’ notice letter,

but again did not respond to Plaintiffs’ initial request for a meeting. Plaintiffs repeatedly

attempted to engage in settlement conversations with the Defendants, particularly during

the early stages of litigation. Indeed, Plaintiffs sought to settle this case during the

summer of 2011, before discovery began in earnest. Although Defendants initially

participated in those discussions, Defendants ultimately rebuffed efforts at settlement,

cutting off settlement conversations in September 2011, indicating that they would not

agree to any settlement in which this Court retained jurisdiction over this matter (such

relief was ultimately ordered). At this point, Plaintiffs would have settled this matter for

little or even no attorneys’ fees. Plaintiffs’ counsel had not yet expended significant

resources in the prosecution of this matter. I personally had expended fewer than 200

hours on this case, and very few other hours had been expended by LDF attorneys. As

explained below, I would ultimately spend over 1,400 hours working on this matter; other

LDF attorneys would collectively spend over 1,000 hours on this case, and LDF

paralegals would spend over 300 hours on this case.


4

9. As required with a case of this magnitude, Plaintiffs counsel devoted

substantial resources to this case at the pre-trial stage. The discovery period lasted over

one year, and included extensive document and electronic discovery (including several

rounds of written discovery requests served by both sides), and several months of

depositions. Moreover, Plaintiffs’ counsel also engaged in discovery litigation, including

a successful motion to compel production of responsive documents and to obtain a

privilege log. Plaintiffs’ counsel also performed extensive legal research and analysis;

successfully opposed all three Defendants’ motions for partial summary; and successfully

cross-moved for partial summary judgment on a question of first impression in the

Eastern District of Louisiana. The ECF docket in this case contains over 400 entries.

10. After oral argument on partial summary judgment was conducted, this

Court ordered further settlement discussions, and Plaintiffs once again expressed their

willingness to settle this matter. Defendants, however, refused to engage in meaningful

settlement conversations, and once again reiterated their refusal to even consider any

settlement involving continuing jurisdiction by this Court—a form of relief, which, as

noted, was ultimately awarded.

11. Trial took place over three days, from October 15-17, 2012, and involved

the testimony of 16 witnesses and the introduction of over 90 exhibits. On January 22,

2013 this Court rendered its Findings of Fact and Conclusions of Law, finding that all

three defendants had violated the voter registration obligations under Section 7 of the

NVRA in numerous different respects. See Doc. 436 at 20 (DHH); 25-26 (DCFS); and

28 (SOS). This Court entered judgment for Plaintiffs and awarded Plaintiffs reasonable

attorneys fees, litigation expenses, and costs.


5

12. This case has already had a substantial impact on the ability of Louisiana’s

most vulnerable citizens to register to vote, and thus exercise the most precious right in

our democracy. After this Complaint was filed in April 2011, the number of voter

registrations through public assistance offices increased seven-fold (when comparing the

third quarter of 2011 to the third quarter during the previous two years). See Pls.’ Trial

Exs. 54-55; Pls.’ PFOF at 9, ¶ 29. Notably, this figure does not even include voter

registration forms submitted by public assistance clients through remote transactions

(mail, telephone, or internet). Prior to this case, Defendants refused to provide voter

registration services through such means, even though the vast majority of public

assistance benefits transactions are conducted remotely; this unlawful omission translated

into hundreds of thousands of Louisiana citizens’ being denied an opportunity to register

to vote. See Amended Pre-Trial Order, Uncontested Facts 10-29. Furthermore,

Defendants have also been ordered to cure numerous other violations of the statute,

which will further ensure that Louisiana citizens are offered an opportunity to register to

vote in accordance with federal law. Finally, the impact of this case will be felt

nationwide, as this Court’s rulings interpreting the scope of the NVRA and the

requirements it places on state agencies will likely be influential in other district courts

throughout the country.

PLAINTIFFS’ ATTORNEYS’ FEES AND COSTS

A. Background on LDF

13. LDF is America’s premier legal organization fighting for racial justice,

and has, for more than seven decades, assisted African Americans and other people of

color in securing their civil and constitutional rights. Through litigation, advocacy, and


6

public education, LDF seeks structural changes to expand democracy, eliminate

disparities, and achieve racial justice in a society that fulfills the promise of equality for

all Americans.

14. For this reason, LDF has served as counsel in voting rights cases before

courts around the country, including, among others, two recent cases in the U.S. Supreme

Court: Shelby County v. Holder, No. 12-96 (currently pending before the United States

Supreme Court); and Northwest Austin Mun. Utility Dist. No. 1 v. Holder, 557 U.S. 193

(2009). In addition to this case, LDF also litigated a number of other voting rights cases

in U.S. District Courts during the same period that it was litigating this case, including

Texas v. Holder, --- F. Supp. 2d ---, No. 12-128, 2012 WL 3743676 (D.D.C. Aug. 30,

2012); Florida v. United States, --- F. Supp. 2d ---, No. 11-1428, 2012 WL 3538298

(D.D.C. Aug. 16, 2012); South Carolina v. United States, --- F. Supp. 2d ---, No. 12-

203, 2012 WL 4814094 (D.D.C. Oct. 10, 2012). LDF has also participated as amicus in

a number of voting rights and election law cases before the U.S. Supreme Court,

including, among others, Arizona v. Inter-Tribal Council of Arizona, Inc., No. 12-71

(currently pending); Bartlett v. Strickland, 556 U.S. 1, 10 (2009); League of United Latin

Am. Citizens v. Perry, 548 U.S. 399 (2006); Shaw v. Hunt, 517 U.S. 899 (1996); Miller

v. Johnson, 515 U.S. 900 (1995); and Thornburg v. Gingles, 478 U.S. 30 (1986).

15. Despite this busy docket, LDF committed time and resources to this case

because of the important issue it raises—namely, ensuring that Louisiana’s most

vulnerable citizens are provided an opportunity to exercise the most fundamental right in

our democracy, in accordance with federal law.


7

16. Because of the large and complex nature of this case and the need for

significant resources, LDF, Project Vote, Ronald Wilson, and, for purposes of trial, Fried

Frank, partnered together to prosecute the case. The three firms and Mr. Wilson are co-

counsel for Plaintiffs.

17. LDF has been involved in all aspects of the litigation. The legal work

performed by LDF includes: substantial pre-complaint investigation; communicating with

the named Plaintiffs; drafting the Complaint; substantial document and deposition

discovery; discovery-related litigation; taking and defending depositions; attempts to

negotiate settlement; successfully opposing Defendants’ motions for partial summary

judgment; moving for and conducting oral argument on Plaintiffs’ cross-motion for

summary judgment; and conducting trial.

18. At all times, LDF attorneys have conducted their representation of

Plaintiffs as efficiently and economically as possible within the bounds of our duty to

pursue our clients’ claims zealously.

B. Summary of Fees and Costs

19. Plaintiffs seek a total award of $1,049,829.80 for LDF’s attorneys’ fees

and $60,939.44 for LDF’s costs. Detailed, contemporaneous records are attached as

Exhibit A.

20. With assistance from other LDF attorneys, I have reviewed the time

descriptions for each LDF attorney and staff in this litigation. We have also coordinated

with our co-counsel to divide work and avoid duplication. We have exercised billing

judgment in a number of ways to ensure that the fees requested are reasonable:


8

a. First, although LDF began investigating Defendants’ unlawful actions in

2008, Plaintiffs do not seek any an award for fees for the extensive time

that LDF attorneys spent in the pre-suit investigations. Plaintiffs are only

seeking fees for work beginning in 2011, which includes some activities

prior to the filing of the Complaint, such as drafting litigation documents

and legal research, but excludes all time spent on investigating Plaintiffs’

claims.

b. Second, Plaintiffs do not seek an award for any fees for four LDF

supervising attorneys who worked on this case—Melissa Bruijneel

(Managing Attorney), Kristen Clarke (former Co-Director of LDF’s

Political Participation Group), Elise Boddie (Acting Director of

Litigation), Debo Adegbile (Director of Litigation, and Acting President

and Director-Counsel of LDF). Ms. Clarke, Ms. Boddie, and Mr.

Adegbile collectively performed dozens of hours of work in connection

with this matter, supervising other LDF attorneys and editing court filings.

In particular, Ms. Bruijneel, LDF’s Managing Attorney, performed several

hundred hours of work, including: performing substantive revisions and

cite-checking of Plaintiffs’ filings; ensuring conformity of those filings

with all applicable rules; and supervising LDF’s support staff and

paralegals who worked on this case.

c. Third, Plaintiffs do not seek an award for fees for time spent by LDF or

our co-counsel in connection with this fee petition.


9

d. Fourth, for all travel time from New York to Louisiana, LDF is billing

only half its rate sought in this matter.

e. Fifth, with respect to depositions or court appearances (other than trial,

where all attorneys present played an active role in proceedings), when

more than two LDF attorneys were present, Plaintiffs do not seek an

award for fees for the work of any additional LDF attorneys who

participated in such proceedings, notwithstanding the active role any such

attorneys may have played. Any such time has been excluded from the

attached billing records.

f. Sixth, Plaintiffs do not seek an award for fees for time spent by LDF or

our co-counsel in connection with the defense of any re-depositions of

witnesses arising from Defendant Schedler’s motion to compel re-

depositions.

g. Seventh, as an exercise of billing judgment and to account for a

duplicative or repetitive work performed in conjunction with this case,

Plaintiffs have reduced the total fees they seek for work performed by

LDF (and other co-counsel) by 10 percent, as indicated in the table below.

C. Attorney Rates

21. Plaintiffs have provided contemporaneous time records for six individuals,

including three attorneys (Dale Ho, Natasha Korgaonkar, and Ryan Haygood) and three

paralegals (LaTanya Harry, Joseph Puma, Dhiren Patel), which are attached as Exhibit A

to this Declaration. Each entry consists of a description of the type of work done and the

amount of time spent by each attorney or staff member on the task.


10

22. I have reviewed LDF’s time descriptions submitted in conjunction with this

fee petition and based on my experience and expertise litigating civil rights class actions and

other complex civil litigation, I believe that the time for which LDF seeks compensation was

necessary and essential to properly litigate this case and obtain favorable results for Plaintiffs.

23. The summary chart below sets forth the following for each LDF employee

for whom Plaintiffs seek compensation on this motion: the attorney’s or paralegal’s

position at LDF; his or her year of law school graduation (if applicable); the number of

hours for which compensation is sought; and the hourly rate requested.

Name Position Year of

Graduation

Hours Rate Total

Ryan

Haygood

Director,

Political

Participation

Group

2001 185

$600 $110,000.00

Dale Ho Assistant

Counsel

2005 1,414.3 $475 $671,792.50

Natasha

Korgaonkar

Assistant

Counsel

2007 922.3 $350 $322,805.00

LaTanya

Harry

Paralegal 2007 62.1 $175 $10,867.50

Joseph Puma Paralegal N/A 260 $175 $45,500.00

Dhiren Patel Paralegal N/A 31.5 $175 $5,512.50

Subtotal $1,166,477.50

Minus 10% - $116,647.75

TOTAL $1,049,829.80

24. LDF is a non-profit civil rights law firm that does not typically bill its

clients. But, for the purposes of civil rights litigation, its relevant hourly rates for


11

comparison purposes are those of a law firm with a national litigation practice and

substantial expertise in civil rights law, as well as significant skill and experience in

appellate advocacy. The billing rates that Plaintiffs seek for LDF attorneys and staff, like

the rates of most other law firms and legal organizations, vary with the experience,

position, and responsibilities of the individual involved.

25. LDF has reviewed these hourly rates to ensure that they are within the

range of reasonableness for attorneys with comparable backgrounds, expertise,

experience, reputation, and positions of national prominence litigating civil rights class

actions and other complex litigation in Washington, DC and New York City, where

LDF’s offices are located, as well as nationwide.

26. I am generally familiar with the range of current hourly rates charged by

attorneys nationwide in large firms that have litigation practices that matters of

significant complexity at the trial, appellate, and Supreme Court level. I am aware of

those rates because they are published in court opinions, the legal press, and surveys.

27. All of the attorneys and staff who contributed to this case work out of

LDF’s New York City office. In my opinion and to the best of my knowledge, LDF’s

hourly rates are within the range of reasonableness and current market rates in New York

City for hourly paid litigation by attorneys of comparable ability, skills, and reputation in

civil rights and other complex litigation in federal trial courts.

28. This assessment is independently confirmed by the accompanying

declarations from other practitioners. Furthermore, as set forth in the declaration of my

co-counsel Michael de Leeuw, I understand that, had Mr. Haygood and I remained


12

attorneys at Fried Frank, the firm would currently bill over $700 per hour for my work,

and over $800 per hour for Mr. Haygood’s.

29. Below, I summarize the experience, qualifications, and work performed by

each.

30. I have been Assistant Counsel in LDF’s Political Participation Group since

2009. In that capacity, I have represented individual citizens and organizations in New

York, Louisiana, Florida, Alabama, and Texas in state or federal proceedings, including

trials and oral arguments on dispositive motions. Recently, I successfully represented

intervenors in two voting rights cases; Florida v. United States, --- F. Supp. 2d ---, No.

11-1428, 2012 WL 3538298 (D.D.C. Aug. 16, 2012), in which a three-judge federal

court rejected Florida’s attempt to drastically reduce the early voting period; and Little v.

LATFOR (NY Supreme Court), in which the New York Supreme Court, Albany County

Court sustained changes to the method of counting incarcerated individuals during New

York State’s legislative redistricting process. I am currently a member of LDF’s

litigation team representing respondent-intervenors in Shelby County v. Holder, No. 12-

96, a case pending before the United States Supreme Court, concerning the

constitutionality of Section 5 of the federal Voting Rights Act of 1965. I have practiced

extensively before the Supreme Court, authoring or contributing to amicus briefs in

McDonald v. Chicago, 130 S. Ct. 3020 (2010) (cited in majority op., 130 S. Ct. at 3030

n.6); Bartlett v. Strickland, supra (cited in dissenting op. of Breyer, J., 556 U.S. at 45);

Graham v. Florida, 130 S.Ct. 2011 (2010); and District of Columbia v. Heller, 554 U.S.

570 (2008). I also currently serve as an Adjunct Professor of Law at Brooklyn Law

School, where I teach a course on Election Law. From 2007 to 2009, I was an associate


13

and the NAACP Legal Defense Fund Fellow in the New York office of Fried Frank,

where I litigated complex commercial and civil rights matters. From 2005 to 2007, I was

a law clerk, first to Judge Barbara S. Jones of the United States District Court for the

Southern District of New York, and then to Judge Robert S. Smith of the New York

Court of Appeals (the State of New York’s highest court). I received a J.D. from Yale

Law School in 2005, where I was an editor of the Yale International Law Journal and a

director of the Immigration Legal Services Clinic. I received an A.B. from Princeton

University in 1999. Plaintiffs seek $475 per hour for my work on this litigation.

31. As lead attorney for LDF in this action, I have been actively involved in

developing and litigating the case from pre-suit investigations beginning in 2010, over

one year before the Complaint was filed in April 2011. Among other things, I drafted our

written discovery requests; compiled our written discovery responses; collected

documents from our clients and coordinated their production during discovery; conducted

LDF’s review of discovery documents produced by Defendants; conducted settlement

negotiations with Defendants; drafted our dispositive motions and numerous other filings;

took several depositions; conducted oral argument on cross-motions for partial summary

judgment; and served as lead counsel at trial.

32. Ryan Haygood is the Director of the of LDF’s Political Participation

Group. In that capacity, he represents African Americans and other people of color in a

variety of actions involving voting discrimination, including challenges to voting

measures under Sections 2 and 5 of the Voting Rights Act, the United States Constitution,

and state laws. Mr. Haygood has practiced before the United States Supreme Court, as a

member of LDF’s litigation team in Northwest Austin Municipal Utility District No. One


14

v. Holder, 557 U.S. 193 (2009); and is currently a member of LDF’s litigation team in

Shelby County v. Holder, No. 12-96. Last year, Mr. Haygood successfully represented

voters in three cases in federal district court: Florida v. United States, --- F. Supp. 2d ---

, No. 11-1428, 2012 WL 3538298 (D.D.C. Aug. 16, 2012); Texas v. Holder, --- F.

Supp. 2d ---, No. 12-128, 2012 WL 3743676 (D.D.C. Aug. 30, 2012), in which a three-

judge federal court blocked Texas’s recent attempt to implement a government-issued

photo identification measure; and South Carolina v. United States, --- F. Supp. 2d ---,

No. 12-203, 2012 WL 4814094 (D.D.C. Oct. 10, 2012), in which a three-judge federal

court rejected South Carolina’s request to implement its photo identification law for the

2012 Presidential election. Mr. Haygood’s other voting rights cases include or have

included: Farrakhan v. Gregoire, 623 F. 3d 990 (9th Cir. 2010), a challenge to

Washington State’s felon disfranchisement law; Williams v. McKeithen, (E.D. La.), a

challenge to Jefferson Parish’s at-large method of electing judges to the state court of

appeals; and Ga. State Conference of the NAACP v. Fayette County Bd. of

Commissioners, (N.D. Ga.), a pending challenge to the County’s at-large method of

electing members to its Board of Commissioners and Board of Education. Prior to

joining LDF in 2003, Mr. Haygood was an associate and the NAACP Legal Defense

Fund Fellow at Fried Frank from 2001 to 2003, where he represented clients in a variety

of complex commercial and civil rights matters before federal courts. Mr. Haygood

received his J.D. from the University of Colorado School of Law in 2001, and a B.A. in

American History and Political Science cum laude from Colorado College, in 1997.

Plaintiffs seek $600 per hour for Mr. Haygood’s work on this litigation.


15

33. Mr. Haygood has worked on this case since its inception, including

supervising numerous depositions; reviewing and revising all filings in the case; and

directing litigation strategy.

34. Natasha M. Korgaonkar has been Assistant Counsel in LDF’s Political

Participation Group since 2011. She is, inter alia, a member of LDF’s litigation team in

Shelby County v. Holder, No. 12-96 (U.S. Supreme Court) and in Texas v. Holder, --- F.

Supp. 2d ---, No. 12-128, 2012 WL 3743676 (D.D.C. Aug. 30, 2012). From 2008 to

2011, she worked for the law firm of Covington & Burling LLP where she was a

litigation associate working on a number of complex commercial cases and white collar

investigations. From 2007 to 2008, she worked at the Corporation for Civil Action and

Education, a non-profit organization in San Juan, Puerto Rico that provides direct legal

services to prisoners. See Morales Feliciano v. Garcia Padilla, 3:79-cv-0004-pjb (D.

P.R.). Ms. Korgaonkar received her undergraduate degree in 2002 from Brown

University, and her Masters Degree in African American history in 2004 from Columbia

University. She earned her law degree in 2007 from Columbia University, where she was

a Harlan Fiske Stone Scholar and Chapter Editor of the Jailhouse Lawyers Manual (a

publication of the Columbia Human Rights Law Review). Plaintiffs seek $350 per hour

for Ms. Korgaonkar’s work on this litigation.

35. Ms. Korgaonkar began working on the case in May 2011. Ms.

Korgaonkar participated in our review of discovery documents; deposed at least five

witnesses; defended depositions of our clients; drafted and revised filings, including our

motion for summary judgment; drafted motions in limine and responses to motions in

limine; engaged in significant trial preparation; and questioned several witnesses at trial.


16

36. LaTanya Harry is a paralegal at LDF. She graduated from Dartmouth

College in 2001. In 2007, she received a J.D. from Rutgers-Newark School of Law, and

a Masters Degree in City and Regional Planning (Urban Planning) from the Edward J.

Bloustein School of Planning and Public Policy at Rutgers University. Ms. Harry has

worked as a paralegal at LDF since August 2011. Joseph Puma was a paralegal at LDF

until 2012. Mr. Puma graduated from Yale University in 2003, and was a paralegal at

LDF from 2011 to 2012, when he left to enroll as a divinity student at Union Theological

Seminary in New York. Dhiren Patel replaced Mr. Puma as a paralegal at LDF in August

2012. Mr. Patel graduated from Seton Hall University in 2010, and has been working as

a paralegal for over two years. Ms. Harry, Mr. Puma, and Mr. Patel performed a number

of tasks in connection with this litigation, including: processing, organizing, and filing

discovery documents received from Defendants; proceeding Plaintiffs’ documents for

production in discovery; preparing exhibits for depositions; cite-checking, blue-booking,

and formatting briefs and other filings; and other case management functions. Plaintiffs

seek $175 per hour for Ms. Harry’s, Mr. Puma’s, and Mr. Patel’s work on this litigation.

C. Costs and Expenses

37. Plaintiffs seek compensation for costs expended by LDF in connection

with this litigation. These costs and expenses are set forth in a spreadsheet, with a brief

description of each item, attached as Exhibit B. Plaintiffs do not seek compensation for

costs associated with: (i) pre-suit investigations from 2008 through 2010; (ii) expenses

associated with meals while traveling for depositions or other court appearances; (iii)

ordinary Westlaw research; (iv) office supplies and all in-house printing related to this

case; and (v) certain travel expenses such as parking and tolls..


17

CONCLUSION

38. For the reasons set forth above and in Plaintiffs’ supporting memorandum

of law, Plaintiffs respectfully request that the Court award them attorneys’ fees in the

amount of $1,049,829.80 for LDF’s work in connection with this matter, and $60,939.44

for LDF’s costs and expenses, in addition to the amounts sought by co-counsel.

Executed: New York, NY

February 25, 2013

/s/

Dale Ho


DALE HO TIME RECORDSTOTAL: 1414.3

2011 2012January: 7 January: 114.6February 7.5 February 72.1March: 12.8 March: 56.7April: 35.2 April: 72.4May: 24.5 May: 47.1June: 90.9 June: 25.5July: 60.7 July: 27August 11.1 August 159.1September 20.3 September 155.1October 41.4 October 176.5November 112.3 November 31.6December 52.9 December 0

TOTAL: 476.6 TOTAL: 937.7

Exhibit A(LDF Time Records)

Page 1


RYAN HAYGOOD TIME RECORDSTOTAL: 167.5

2011 2012January: 1.5 January: 2.6February 1.7 February 0.3March: 2.7 March: 3April: 6.9 April: 6.7May: 4 May: 3.4June: 5.4 June: 17.5July: 6.1 July: 0August 1.9 August 0September 2 September 6.4October 4 October 34.9November 27.6 November 1.7December 27.2 December 0

TOTAL: 91 TOTAL: 76.5


Page 2


Jan-11 Running Total: 1.5

Date Total Summary

7-Jan 1.5 review and revise notice letter


Page 3


Feb-11 Running Total: 1.7

Date Total Summary2/9/2013 0.5 strategy meeting with team

22-Feb 1.2 reviewed SOS response letter


Page 4


Mar-11 Running Total: 2.7

Date Total Summary

28-Mar 2.7 reviewed and edited complaint


Page 5


Apr-11 Running Total: 6.9

Date Total Summary

9-Apr 2.9 reviewed and edited complaint

19-Apr 2.9revised complaint (.9); reviewed and revised draftdiscovery requests (2)

25-Apr 0.4 meeting to discuss discovery strategy26-Apr 0.7 meeting to discuss discovery strategy


Page 6


May-11 Running Total: 4

Date Total Summary

5-May 0.8 meeting to discuss discovery strategy6-May 1.1 reviewed and revised discovery requests

17-May 2.1 reviewed and revised draft opposition brief


Page 7


Jun-11 Running Total: 5.4

Date Total Summary

2-Jun 0.8 review 26(f) submission24-Jun 3.2 review and revise opp to motion to dismiss

30-Jun 1.4review draft settlement offer (.8); reviewdefendants' continuance motion (.6)


Page 8


Jul-11 Running Total: 6.1

Date Total Summary

2-Jul 1.2 review and revise opposition to motion to dismiss

3-Jul 1.5review draft responses to defendants' objections todiscovery requests (1.5)

6-Jul 2.3preparation for moot argument (1.2); mootarguments for motion to dismiss (1)

21-Jul 1.1 review settlement proposal


Page 9


Aug-11 Running Total: 1.9

Date Total Summary

26-Aug 0.1 post settlement call strategy discussion30-Aug 1.8 review defendants' documents


Page 10


Sep-11 Running Total: 2

Date Total Summary

14-Sep 0.8 review and revise discovery requests28-Sep 1.2 review and revise discovery requests


Page 11


Oct-11 Running Total: 4

Date Total Summary

14-Oct 2.8 review draft depo outlines18-Oct 1.2 review and revise responses to interrogatories


Page 12


Nov-11 Running Total: 27.6

Date Total Summary

6-Nov 2.4 review and revise deposition outlines9-Nov 2.2 review and revise deposition outlines

14-Nov 6.0 travel (8 hrs @ half-time); review depo outlines (2)

15-Nov 7.0 depositions16-Nov 0.0 depositions ((7 hours of time written off to avoid duplication)17-Nov 6.0 depositions18-Nov 4.0 travel (8 hrs @ half-time)


Page 13


Dec-11 Running Total: 27.2

Date Total Summary

15-Dec 3.2review and revise deposition outlines (2.3); discussionwith team regarding depositions (0.9)

18-Dec 4.0 travel to Baton Rouge (8 hrs @half)19-Dec 8.0 depositions and deposition preparation20-Dec 8.0 depositions and deposition preparation21-Dec 4.0 travel from Baton Rouge (8 hrs @half)


Page 14


Jan-12 Running Total: 2.6

Date Total Summary1/24/2013 0.8 preparation for deposition

30-Jan 1.8 read and revise motion to compel


Page 15


Feb-12 Running Total: 0.3

Date Total Summary7-Feb 0.3 review defendants' opposition to motion to compel


Page 16


Mar-12 Running Total: 3

Date Total Summary

2-Mar 0.4 review opposition to motion to strike7-Mar 0.5 meeting to discuss PSJ Reply

10-Mar 2.1 review and revise PSJ Reply


Page 17


Apr-12 Running Total: 6.7

Date Total Summary

3-Apr 0.9 review and revise opposition to motion to strike

10-Apr 3.5PSJ oral argument moot (2); review of PSJ papers inpreparation for moot (1.5)

17-Apr 2.1PSJ moot argument (1); review PSJ papers inpreparation for moot (1.1)

20-Apr 0.2 call with team regarding oral argument


Page 18


May-12 Running Total: 3.4

Date Total Summary

1-May 0.1 review settlement proposal from DHH2-May 0.1 review settlement proposal from SOS

3-May 0.7review district court opinion (0.2); revise press release(0.5)

8-May 0.5 Prepare for settlement conference15-May 1 strategy call w/ co-counsel18-May 1 strategy call w/ co-counsel


Page 19


Jun-12 Jun-12 17.5

Date Total Summary

1-Jun 0.7 call with co-counsel regarding depositions

2-Jun 1.6Call with co-counsel regarding depositions and motions (0.5);preparation for defending depositions (1.1)

4-Jun 0.9call with co-counsel (0.5); discussion regarding depositiondefense (.4)

5-Jun 1.2 call with co-counsel regarding depositions10-Jun 1.1 review and revision of scheduling motion (1.1)14-Jun 0.4 review and revision of motion to expedite

20-Jun 1.5review and revision of Ps' responses to rogs (.7); review andrevision of Ps' responses to RFAs (.7)

26-Jun 3.8review and revisions to MSJ (2.6); meeting with co-counselregarding MSJ (1.2)

27-Jun 2.9 review and revision of MSJ and ancillary documents28-Jun 1.9 review and revision of MSJ and ancillary documents30-Jun 1.5 review and revision of MSJ and ancillary documents

TOTAL 17.5


Page 20


Jul-12 Running Total: 24.5

Date Total Summary

2-Jul 1.9 review and revise Statement of Facts3-Jul 4.1 revise, finalize and file MSJ

5-Jul 1.9revising and finalizing opposition to SOSmotion for extension.

9-Jul 1.8review and revise opposition to motion tocompel

10-Jul 1.1 review and revise motion to expedite

12-Jul 2.4

meeting with co-counsel (1.5); review andrevise reply in support of motion to quash(.9)

15-Jul 0.9discussion with co-counsel regardingNAACP documents

16-Jul 1.2Read motion for sanctions (0.3); reviewdraft extension of time (.9)

17-Jul 4.4

review and revise opposition tocompel/sanctions (2.9); call with counsel(1.5)

18-Jul 1.9

strategy call w/ co-counsel (.7); review andrevision of opposition to discoveryextension motion (1.2)

23-Jul 2.2

review opposition to motion for sanctions(.8); review and revise oppostion to motionto compel (.9); communication with co-counsel regarding production of documents(.5)

26-Jul 0.7 review draft MSJ reply (.7)

TOTAL 24.5


Page 21


Aug-12

Date Total Summary

1-Aug 0.5 call with co-counsel3-Aug 0.2 review deadlines for pre-trial order

10-Aug 3.9 review and revise SJ reply brief (3.2); review motion to strike (.7)14-Aug 1.0 review defendants' SJ briefs15-Aug 1.2 review and revise MTS16-Aug 2.2 review Defendants' oppositions to MSJ22-Aug 1.3 Review, finalization and filing of motion to strike23-Aug 1.1 review draft pretrial order24-Aug 0.9 edits to SJ reply27-Aug 1.7 Moot oral argument (1); meeting regarding oral argument (0.7);29-Aug 3.0 preparation for moot oral argument (1); moot oral argument (2)

30-Aug 4.1 preparation for moot oral argument (1.1); moot oral argument (3)

TOTAL 21.1


Page 22


Sep-12 Running Total: 6.4

Date Total Summary

3-Sep 2.9 prepare for moot oral argument (.9); moot oral argument21-Sep 3.5 review of pretrial order (2.1); review conclusions of law


Page 23


Oct-12 Running Total: 34.9

Date Total Summary

13-Oct 2.9 reviewed witness outlines14-Oct 3.0 travel to New Orleans (6 hrs @ half-time)15-Oct 13.0 trial (9); trial prep (4)16-Oct 13.0 trial (9); trial prep (4)17-Oct 3.0 return travel from New Orleans (6 hrs @ half-time)


Page 24


Nov-12 Running Total: 1.7

Date Total Summary

12-Nov 1.7 review of post-trial brief


Page 25


Natasha Korgaonkar (Time Records) Running Total: 922.3

2011 2012

January: 0 January: 57.5February 0 February 5.8March: 0 March: 1.5April: 0 April: 30.9May: 12.7 May: 41.7June: 0 June: 93.1July: 1.5 July: 94August 0 August 142.3September 0 September 126.5October 0 October 187.6November 73.8 November 7.6December 45.8 December 0

TOTAL 2011: 133.8 TOTAL 2012: 788.5


Page 26


May-11

Date Total Summary

2-May 1.6 Assist with responses to discovery requests

5-May 0.8meeting with supervisors to discuss discoverystrategy

6-May9-May 0.6 conference call with opposing counsel (0.6)

10-May

11-May 5.3Draft RFAs and RFPs for one defendant forDEH (5.3)

12-May13-May15-May16-May 1.3 offer edits to discovery requests (1.3)17-May 1.5 Draft deposition notices (1.5)

23-May 1.6revise discovery requests (1.2); call w/ co-counsel re: discovery scheule (0.4)

TOTAL 12.7


Page 27


Jul-11

Date Total Summary

1-Jul

5-Jul6-Jul 1 moot arguments for motion to dismiss (1)7-Jul8-Jul

11-Jul12-Jul

13-Jul 0.5 meeting with DEH regarding motion to dismiss (0.5)14-Jul15-Jul19-Jul20-Jul25-Jul

TOTAL 1.5


Page 28


Nov-11

Date Total Summary

1-Nov 5.5Meet with DEH regarding upcoming depositions (0.5); draft, revisedepo outlines (5)

2-Nov 6.1 Review document for depo outlines3-Nov 2.0 draft, revise depo outlines (2)4-Nov6-Nov7-Nov 3.1 Work on deposition outlines (3.1)8-Nov 8.0 depositions; draft, revise depo outlines (2)9-Nov

10-Nov 5.0Review documents for revised depo outlines, and revision of outlines(5)

11-Nov 6.0 review DHH docs, draft, revise depo outlines

12-Nov 5.0Review documents for revised depo outlines, and revision of outlines(5)

13-Nov 6.0Review documents for revised depo outlines, preparingexhibits/documents for travel, and revision of outlines (6)

14-Nov 10.0 travel (8 hrs @ half-time); draft, revise depo outlines (6)

15-Nov 2.0 revise depo outlines (2); depositions (7 hours of time written off)16-Nov 7.0 depositions (7)

17-Nov 6.1depositions (6); correspondence with counsel regarding documents(0.1)

19-Nov 1.0 travel (8 hrs @ half-time)21-Nov 0.022-Nov 0.023-Nov 0.028-Nov 1.0 call w/ co-counsel (1)

TOTAL 73.8


Page 29


Dec-11

Date Total Summary

5-Dec6-Dec 3.4 call w/ co-counsel (1.1); review SOS production (2.3)

10-Dec12-Dec13-Dec

14-Dec 0.8discuss proposed stipulations for Crawford (SOS)deposition (0.8)

15-Dec 9.8Draft deposition outlines (4.2); discuss depositions withDEH and RPH (0.9)

16-Dec 7.7Review documents for depositions (2.1); revise depositionoutlines (5.6)

18-Dec 4.0 Travel to Baton Rouge (8 hrs @half)19-Dec 8.1 Depositions and deposition preparation (8.1)20-Dec 8.0 Depositions and deposition preparation (8)21-Dec 4.0 Travel from Baton Rouge (8 hrs @half)22-Dec23-Dec24-Dec26-Dec

TOTAL 45.8


Page 30


Jan-12

Date Total Summary

9-Jan10-Jan11-Jan13-Jan17-Jan18-Jan19-Jan 4.1 Reseach for PSJ opposition (4.1)20-Jan

21-Jan 9.9Preparation for depositions (5.3); legal research formotion to compel (4.6)

23-Jan 6.7 Preparation for deposition (2.1); legal research for compel motion (4.6)24-Jan 4.3 Drafting motion to compel (4.3)

25-Jan 3.2 Incorporating edits from DEH in motion to appeals (3.2)

26-Jan27-Jan Preparing documents for upcoming trip to BR for depositions (2.3)28-Jan29-Jan 6 Travel (8 hrs @ half-time); prepare for depositions (2)

30-Jan 9.8depositions (7); prepare client for deposition (1.5);revise deposition transcript (1.3)

31-Jan 13.5depositions (5.4); revise and file motion to compel (4.1);return travel from Baton Rouge (8 hrs @ half-time)

TOTAL 57.5


Page 31


Feb-12

Date Total Summary1-Feb2-Feb3-Feb

4-Feb 2.9research for PSJ Reply Brief (1.1); legal research for motionto compel reply (1.8)

7-Feb 2.6Correspondence regarding questions from DEH on motionto compel (2.6)

8-Feb 0.3 Conversation with DEH regarding motion to compel (0.3)9-Feb

10-Feb13-Feb14-Feb15-Feb16-Feb19-Feb20-Feb21-Feb22-Feb23-Feb24-Feb25-Feb27-Feb28-Feb29-Feb

TOTAL 5.8


Page 32


Mar-12

Date Total Summary

1-Mar 02-Mar 03-Mar 04-Mar 05-Mar6-Mar 1.5 edits to draft PSJ reply motion (1.5)7-Mar 08-Mar9-Mar

10-Mar 011-Mar 012-Mar 013-Mar 014-Mar15-Mar 016-Mar 017-Mar 018-Mar 019-Mar 020-Mar 021-Mar22-Mar23-Mar 024-Mar 025-Mar 026-Mar27-Mar28-Mar29-Mar30-Mar31-Mar 0

TOTAL 1.5


Page 33


Apr-12

Date Total Summary

1-Apr

2-Apr 3

Revise opp to mot to strike (1); reviseopp to discovery motion (1); revisesurreply (1)

3-Apr4-Apr5-Apr6-Apr7-Apr 08-Apr 09-Apr

10-Apr 2 PSJ oral argument moot (2)11-Apr 012-Apr 013-Apr 014-Apr 015-Apr 016-Apr 0

17-Apr 3.5moot argument (1.0); review of PSJpapers in anticipation of argument (2.5)

18-Apr 1.2Research questions in preparations fororal argument (1.2)

19-Apr 8 Travel to New Orleans (5)

20-Apr 2.2Court appearance (2); correspondencewith RPH regarding oral argument (0.2)

21-Apr 5 travel from New Orleans22-Apr 023-Apr 0.8 Conference call with co-counsel (0.8)25-Apr 0

26-Apr 3.4

Discuss client deposition (0.4); beginreview of documents for clientdeposition (2.5); call with client toprepare for deposition (0.5)

27-Apr 1.3

revise draft settlement agreement (0.4);review of past settlement documents(0.7); call w/ co-counsel re: settlement(0.2); discuss deposition with client (0.2)

30-Apr 0.5 client call (0.5)28-Apr 029-Apr 030-Apr

TOTAL 30.9


Page 34


May-12

Date Total Summary

1-May 2.2review settlement proposal from DHH (0.1); depositionprep calls w clients (2.1)

2-May 1review settlement proposal from SOS (0.2); call with co-counsel to discuss meet-and-confer (0.8)

3-May 2.9

Prepare for meet and confer (0.5); meet and confer w/Defs (0.6); meeting with co-counsel to discuss (0.5); callwith client to discuss deposition (1.3)

4-May 4.6Review materials for deposition prep (3); prep client fordeposition (1.6)

8-May 2Prepare for settlement conference (0.5); prepare client fordeposition (1.5)

9-May 7

travel to New Orleans (6 hrs @ half-time); prepare forsettlement conference (1.0); settlement conference (1.0);prepare for deposition (2.0)

10-May 4.9 defend deposition (4.0); meet with client (0.9)12-May 6 return travel from New Orleans (6 hrs @ half-time)15-May 1 strategy call w/ co-counsel (1.0)18-May 1 strategy call w/ co-counsel (1.0)21-May 222-May 0.6 deposition preparation call (0.6)

23-May 0.4review correspondence with court and opposing counsel(0.4)

24-May 2.5edits to draft brief in opposition to certification for appeal(2.0); conference with court (0.5)

27-May 2.1 Review draft motion in opposition to certification

29-May 1Call with client regarding upcoming deposition preparation(1)

31-May 0.5 instructions on next steps for co-counsel

TOTAL 41.7


Page 35


Jun-12

Date Total Summary

1-Jun 2.7

Call with co-counsel regardingdepositions/strategy (0.7); calls to clientsregarding depositions (2)

2-Jun 4.8

Call with co-counsel regardingdepositions/strategy, and upcomingmotions (0.5); drafting motion re: schedule(1.2); deposition defense preparation (3.1)

3-Jun

4-Jun 6.2

Call with co-counsel regarding schedulingmotion (0.5); work on scheduling motion(1.5); preparation of cross examinations fordepo defense (4.2)

5-Jun 11.8

Deposition prep with clients (3.6); work onscheduling motion (1); travel to NewOrleans (6 at half); consult with co-counselregarding depositions and strategy (1.2)

6-Jun 7.3Deposition prep with clients (1.3);defending depositions (6)

7-Jun 8.3

Defending depositions (3.7); depositionprep with clients (1.1); finalizing witness listfor filing (2); work on scheduling motion(1.5)

8-Jun9-Jun 2.4 Draft scheduling motion (2.4)

10-Jun 1.3 revise scheduling motion (1.3)

11-Jun 2.5draft correspondence to Defendants (0.5);revise scheduling motion (2)

12-Jun

13-Jun 2.2 Finalizing and filing scheduling motion (2.2)14-Jun 0.6 Revision of motion to expedite (0.6)15-Jun16-Jun17-Jun18-Jun

19-Jun 4.2Legal research on issues related to MSJ(4.2)

20-Jun 4.9

Drafting correspondence to counsel (0.5);drafting Ps' responses to DHH 2d Rogs(1.3); work on Ps' responses to DCFS 2dRFAs (3.1)

21-Jun 1.2 Preparation for conference with Court (1.2)

22-Jun 1.5Preparation for conference with Court (1);conference with Court (0.5)


Page 36


23-Jun

24-Jun 3.8Work on drafting/editing MSJ (1.3); reviewof deposition transcripts (2.5)

25-Jun 5.1

Revisions to MSJ draft and draftingancillary documents (3); review ofdeposition transcripts (2.1)

26-Jun 4.7

Revisions to MSJ (3); meeting with co-counsel regarding MSJ andcorresponsence with opposing counsel(1.2); drafting ancillary documents,statement of facts, etc. for MSJ (2.3); callto client regarding treasurer deposition(0.2).

27-Jun 3.8

Editing MSJ and ancillary documents (3.1);correspondence with co-counsel regardingdepositions (0.7)

28-Jun 6.6

Editing MSJ and ancillary documents (6.1);meeting with colleague regarding standing(0.5)

29-Jun 4.9 Revisions to MSJ (4.9)

30-Jun 2.3 Editing MSJ and ancillary documents (2.3)

TOTAL 93.1


Page 37


Jul-12 Running Total: 188

Date Total Summary

1-Jul 02-Jul 3.5 revise SOF3-Jul 9.2 Finalizing and filing MSJ

4-Jul 4.1Drafting opposition to SOS motion forextension

5-Jul 5.4Editing and finalizing for filing opposition toSOS motion for extension.

6-Jul 07-Jul 0

8-Jul 5.1Researching and drafting motion to quashsubpoena (5.1)

9-Jul 7.2Draft opposition to motion to compel (3.2);draft motion for reconsideration (4)

10-Jul 4.1Drafting and finalizing for filing motion toexpedite (4.1)

11-Jul 0

12-Jul 6.8

Drafting/revising reply in support of motionto quash (3.6); meeting with co-counsel(1.5); editing reply in support of motion toquash (1.7)

13-Jul 5.1Reading SOS motion to compel (0.5);research and drafting opposition (4.6)

14-Jul 0

15-Jul 4.1

Review of NAA documents (0.9);discussion with co-counsel regarding same(0.9); legal research related to issue forreply brief (2.3)

16-Jul 7.9

Reading motion for sanctions (0.4);research and drafting opposition andancillary documents (6.3); review draftextension of time (1.2)

17-Jul 7.2

Final review of opposition tocompel/sanctions (1); strategy call w/ co-counsel (1.5); drafting and finalizingopposition to motion to compel (4.7)

18-Jul 3.1

strategy call w/ co-counsel (.7); editingopposition to discovery extension motion(2.1)

19-Jul 6.6Review state conference documents (1.5);review all client deposition transcripts (5.1)

20-Jul 2.8Review and edit draft of opp to secondmotion to compel (2.8)

21-Jul 022-Jul 0


Page 38


23-Jul 6.1

Review opp to motion for sanctions (1.3);read discovery order (0.4); review and editopp to motion to compel (1.8);communication with clients regardingdepositions (0.5); communication with co-counsel regarding production of documents(0.5); work on production of documents(1.2)

24-Jul 1.2

Review draft correspondence withopposing counsel regarding untimelydocument requests (0.9); communicationwith clients regarding depositions (0.3)

25-Jul26-Jul 2 Review draft MSJ reply (2)27-Jul 2.5 Review deposition transcripts (2.5)

TOTAL 94


Page 39


Aug-12

Date Total Summary

1-Aug 1.0 Call with co-counsel (0.5); draft motion for sanctions (0.5)

2-Aug 5.1draft summary judgment Reply (1.0); revise motion for sanctions(0.5)

3-Aug 6.7

strategy call with co-counsel (0.9); draft letter to defendantsregarding newly-produced documents (0.6); reviewing deadlinesfor pre-trial order (0.2); review deposition transcripts for summaryjudgment reply (2); draft motion to strike newly produceddocuments (2.5); review newly produced documents fromdefendants (0.5)

6-Aug 5.1 Work on witness charts, review of deposition transcripts (5.1)7-Aug 4.0 Work on witness charts and exhibit lists for pre-trial order (4)

8-Aug 7.0draft MSJ Reply (5.5); co-counsel call re: pre-trial order and casestrategy (1.0); revise co-counsel agreement (0.5)

9-Aug 6.1 Draft motion to strike (6.1)10-Aug 4.0 Review draft SJ Reply brief (3); review motion to strike (1)

14-Aug 5.5Research and revise motion to strike (3.3); work on witness listsand trial exhibits (3.2)

15-Aug 10.5review Defendants' SJ briefs (1.5); edits to MTS (3.1);preparations for and drafting outline for MSJ argument (3.6)

16-Aug 9.4

review Defs' oppositions to MSJ (2.9); conference call with co-counsel to discuss Defs' MSJ Opposition briefs (1); research formotion to strike (2.9); work on portion of MSJ reply (2.6)

18-Aug 7.3client call (1); calls re: client issues (2); research for portion ofMSJ reply (2.3); draft portion of MSJ reply (2)

20-Aug 12.0meeting re: client issues (2.5); client call (0.5); clientcorrespondence (0.5); research for MSJ Reply (8.5)

21-Aug 8.4revise PTO (7); discuss client issues (0.5); revise MSJ Reply (1.3);review MTS (0.3); revise MTS (0.3)

22-Aug 5.3 Finalization and filing of motion to strike (5.3)23-Aug 5.2 review draft pretrial order (5.2)

24-Aug 6.9oral arg outline (3.5); correspondence w/ co-counsel (0.4); edits toSJ Reply (3)

25-Aug 3.6revise SOS oral arg outline (1.5); revise responses to SOS, DHHSOFs (2.8); revise Johnson Dec (0.3)

26-Aug 3.2 Research and revise draft oral arg outline (4)

27-Aug 6.4

Moot oral argument (1); meeting regarding oral argument withRPH (0.7); review of cases pertaining to oral argument (3.7);revision of outline (1)

28-Aug 5.7Revise oral arg outline and other argument preparations (2.1);revisions to draft Reply Brief portions (3.6)

29-Aug 4.9Research for and revisions to draft Reply Brief (3.4); moot oralargument (2); revise oral argument outline (0.5)

30-Aug 3.0 Moot oral argument (3)

31-Aug 6.0Revise outline and notes for oral argument (3); review briefs fororal argument (1); review cases for oral argument (2)

TOTAL 142.3


Page 40


Sep-12 Running Total:

Date Total Summary

2-Sep 5.3Incorporate edits to opp to motion to strike (2.8); prepare for oralargument (2.5)

3-Sep 5.8moot oral argument (2); edits to reply in support of motion to strike(2.8); revise oral argument outline (1)

4-Sep 7.0travel to New Orleans (6 hrs @ half-time); review briefs for oralargument (2); revise outline (2)

5-Sep 10.5revise outline (1.5); court hearing (3); travel back to NY (6 hrs @ half-time)

6-Sep7-Sep

10-Sep11-Sep12-Sep 4.7 Revision of SOS exhibits list (4.7)13-Sep 4.0 Revise exhibit list, locate exhibits (4)14-Sep15-Sep 3.0 Edits to PTO (1.2)16-Sep 4.5 Review draft PTO (3); review defs' proposed trial exhibits (1.5)17-Sep 5.2 Review and edit draft pre-trial order (5.2)

18-Sep 8.4

Review of defs proposed trial exhibits (5.3); draft objections tocertain defense exhibits (1.4); review proposed correspondence toopposing counsel (0.2); edits to draft opposition to proposed statusconference (1.5)

19-Sep 8.3

call with co-counsel regarding trial strategies (0.4); witnessdocument review and outline drafting (2.4); work on exhibitobjections list in anticipation of meet and confer (3); review of defs'pretrial inserts and preliminary objections (0.9); draft responses todefs' preliminary objections in anticipation of meet and confer (1.6)

20-Sep 7.0 Meet and confer (5); co-counsel meeting re: steps forward (2)

21-Sep 3.5 Drafting proposed new PTO sections regarding contested facts (3.5)22-Sep 2.5 revise PTO (2.5)23-Sep 5.2 Revisions to and edits for PTO (5.2)

24-Sep 5.2Assistance to FF with PTO preparation (4.5); edits to letter to Ct onoutstanding issues (0.7)

25-Sep 9.3Work on PCOL (4.6); begin research on relevance motions in limine(4.2); work on witness lists (0.5)

26-Sep 11.1conference call to discuss topics for witnesses (1.3); prep for pretrialconference (2.5); work on witness outlines (3); edits to PFOF (4.3)

27-Sep 7.0

travel to New Orleans for pretrial conference (6 hrs @ half-time);prepare for conference (2); attend conference (1); post-conferencestrategy session (1)

28-Sep 9.0edits to proposed injunction (2); draft witness outlines (1); returntravel from pretrial conference (6 hrs @ half-time)

29-Sep 0.030-Sep 0.0

TOTAL 126.5


Page 41


Oct-12

Date Total Summary

1-Oct 6.5

organize files (0.5); witness prep call (1); revise MILs (1.5);witness outlines (0.5); meeting re: PTO (1); call withopposing counsel re: PTO (0.5); revise PFOF/COL (2)

2-Oct 9.0Preparation for trial, including work on witness outlines andwitness documents; review revised PTO

3-Oct 10.2Work on witness outlines (5.7); review and revisePFOF/PCOL (4.5)

4-Oct 13.5 Witness outlines (3.8); revising/editing PFOF/PCOL (9.7)

5-Oct 7.1

Edits to and finalization/filing of PFOF/PCOL (5.4); co-counsel call (.5); call with opposing counsel (0.2); finaledits to PTO (1.0)

6-Oct 4.0 witness outline preparation (4)

7-Oct 7.3witness outline preparation (3); revisions to motions inlimine (4.3)

8-Oct 10.3Trial preparations, including witness outlines anddocuments, and revisions to motions in limine (10.3)

9-Oct 11.0Trial preparations, including witness outlines anddocuments, and review of defs' motions in limine (9.5)

10-Oct 8.0 Trial preparations, including witness outlines

11-Oct 10.8Trial moot session with co-counsel (5); strategy meetingwith co-counsel (1); revisions to witness outlines (4.8)

12-Oct 10.0 Trial preparations (10)

13-Oct 15.0Trial preparations (12); Travel to New Orleans (6 hrs @half-time)

14-Oct 12.0Trial preparations, including client preparations for trial(12)

15-Oct 14.0 trial (9); trial prep (5)16-Oct 14.0 trial (9); trial prep (5)17-Oct 7.0 trial (7)19-Oct 6.0 Return travel from New Orleans (6 hrs @ half-time)20-Oct21-Oct 4.7 Begin research for post-trial brief (4.7)

23-Oct 2.5Edits to/revisions of motion in support of admitting defs'factual statements

24-Oct 4.7Research for post-trial brief; drafting of portions of post-trial brief

TOTAL 187.6


Page 42


Nov-12

Date Total Summary

1-Nov2-Nov 1.1 Research portion of post-trial brief3-Nov 2.0 Edits on portion of post-trial brief4-Nov5-Nov6-Nov7-Nov 0.08-Nov 0.09-Nov 3.5 Work on portion of post-trial brief

10-Nov 0.011-Nov 1.0 Edits to motion to amend caption12-Nov13-Nov 0.014-Nov 0.015-Nov16-Nov17-Nov

TOTAL 7.6


Page 43


Dhiren Patel (Time Records)

8/23/2012 Scott v. Schedler 0819-013 Preparing binder forcited cases in briefs

2.5

10/1/2012 Scott V Schedler 0819-013 Cite check, blue book 3

10/2/2012 Scott v Schedler 0819-013 Review brief and makecorrections

6

10/4/2012 Scott v Schedler 0819-013 Review brief and makeEdits; TOC & TOA

7

10/5/2012 Scott v Schedler 0819-013 Review brief, Citecheck and make edits;TOC & TOA

11

Total 31.5 hours

28/24/2012 Scott v. Schedler 0819-013 ELMO research(contacted Court)


Page 44


Joseph Puma (Time Records)Date Description Number of hours10/11/2011 Met with attorneys to discuss assignment 0.510/12/2011 Reviewed and organized documents physical and

electronic documents; read attorney memodescribing assigment; corresponded with attorneys reassignement

2

10/13/2011 Searched for, reviewed, and scanned documents,corresponded with attorneys and staff re project

3

10/14/2011 Organized physical and electronic documents forassignment, located physical files held in storage,met with attorney re assignment, prepareddocuments to send to vendor, communicatedspecifications and met vendor for pickup

3

10/17/2011 Printed documents per attorney request, met withattorney to review documents, coordinated withvendor re document production

2.25

10/18/2011 Met with attorney for document review, organizeddocuments to send to vendor, communicatedspecificiations to vendor

2.75

10/19/2011 Met with attorney, organized documents receivedfrom vendor, saved documents to netowrk, andmade redactions to documents per attorneyinstructions

3

10/20/2011 Saved electronic documents to network,corresponded with attorney, delivered documents toattorney, printed documents

2

10/21/2011 Prepared production documents for shipment 1.2510/24/2011 Prepared production documents for shipment,

flagged issues and coordinated with vendor re errorin production.

4

10/25/2011 Scanned, Bates stamped, saved, and organizedproduction documents, prepared documents to sendto vendor, printed documents for attorney review

6.5

10/26/2011 Bates stamped documents, produced CDs andprepared e-documents for shipment via CD to co-counsel.

4

10/28/2011 Organized documents 1.511/2/2011 Prepared binder for attorney, Bates stamped

documents, prepared and organized depositionexhibits, printed pleadings per attorney request,updated electronic docket, checked for arrival of CDcontaining case documents

4.5

11/3/2011 Organized documents and coordinated with vendorto process documents, shipped CD with electroniccopies of documents to co-counsel

2.25

11/4/2011 Prepared deposition exhibits, met with attorneys redocuments, supervised shipment of exhibits

2.5


Page 45


11/7/2011 Organized documents and coordinated with vendorto process documents, communicated with projectattorneys and managing attorneys re status and nextsteps

5.5

11/10/2011 Prepared deposition exhibits, corresponded withattorney re project status, met with, printed andorganized materials for outside vendor

8.5

11/11/2011 Met with attorneys regarding deposition exhibitpreparation, prepared deposition exhibits, readiedmaterials for shipment, traveled to and from courierservice to ship materials

6.5

11/15/2011 Updated document and CD index, sent documents toco-counsel and corresponded with co-counsel tosend documents and announce shipment

0.5

11/18/2011 Saved electronic copies of deposition transcripts tonetwork, organized electronic copies of depositionexhibits

3

11/21//2011 Saved electronic copies of deposition transcripts andexhibits to network

1

11/22/2011 Saved electronic copies of deposition transcripts tonetwork, organized electronic copies of depositionexhibits

2.5

11/28/2011 Saved electronic copies of deposition transcripts tonetwork, organized electronic copies of depositionexhibits, met with attorney re case status, preparedstorage system for deposition transcripts per attnyinstructions

1

12/12/2011 Saved and organized depostition transcripts andexhibits on internal drive

1.5

12/13/2011 0.3312/14/2011 Organized deposisiton exhibits, printed depositon

outlines, called attorney hotel and UPS to coordinatelogistics

2.75

12/15/2011 Printed and organized deposition exhibits,coordinated with vendor, met with attorney

0.75

12/16/2011 Printed, organized, and prepared deposition exhibitsfor shipment. Gathered supplies to include inshipment. Met with attorney to review documents

8

12/19/2011 coordinated with vendor, prepared documents forvendor processing, met with attorney re assignment

1

12/20/2011 Corresponded with attorney regarding assignment,reviewed documents for LDF production, met with ITdepartment re production

2

12/21/2011 reviewed deposition exhibits, organizied depositiontranscripts, met with case attorney and managingattorney re assignment, updated electronic copies ofpleadings

3

12/22/2011 gathered documents per attorney request,electronically organized deposition exhibits

3


Page 46


12/23/2011 prepared documents for production for vendorprocessing

2

12/27/2011 Produced CDs for opposing counsel and internalrecords, saved and organized documentselectronically on internal drive, sent depoisitiontranscript per attorney request, drafted memo tosupervisor with instructions for document production

5

1/9/2012 Reviewed and edited brief, downloaded andorganized electronic copies of deposition transcripts,met with supervisor re document organizationproject, sent electronic copies of depositions toattorney

6

1/10/2012 reviewed and edited brief; gathered and organizedexhibts for filing

6.25

1/11/2012 Drafted and reviewed PSJ Declaration; qualitychecked all exhibits

7

1/12/2012 updated pleadings; transposed edits to master copyof brief; organized exhibits electronically

X thru 3:30

1/13/2012 Met with attorney, sent documents to vendor forprocessing, organized electronic copies ofdepositions

3.5

1/18/2012 Revised declaration; printed emails from andcorresponded with attorneys

1

1/24/2012 compiled and organized exhibits for summaryjudgment; revised declaration for summaryjudgement filing; corresponded with attorneys andsupervisor re project

6.5

1/26/2012 printed and organized exhibits for filing; Batesstamped, organized, and circulated documents

6.75

1/27/2012 cite checked brief; prepared documents fordeposition and organized them for shipment

8.5

1/29/2012 Drafted TOA and TOC for partial summary judgmentbrief; cite checked brief; organized electronic copiesof exhibits

5

1/31/2012 prepared exhibits and declaration for partial summaryjudgment filing; cite checked and edited brief forfiling, prepared TOC and TOA

11.5

2/1/2012 Prepared documents for shipment; drafted coverletter for court enclosing courtesy copies, updatedpleadings folder

6.5

2/3/2012 organized and prepared documents for processing byvendor; updated pleadings folder; organizeddiscovery documents on internal drive

3

2/8/2012 worked on oral argument prep binder,correspondence with attorney

0.5

2/9/2012 organized and prepared documents for processing byvendor

2.5

2/21/2012 Gathered documents for oral argument prep binders;electronically organized deposition prep documents;bates stamped documents

2


Page 47


2/22/2012 updated pleadings folder; burned CDs, correspondedwith attorneys re CDs and shipped CDs

2

2/23/2012 Updated pleadings folder; pulled exhibits andorganized documents; coordinated binder production

3

2/24/2012 updated pleadings folder; prepared binders for oralargument prep, and shipped and circulated them

0.75

3/5/2012 gathered exhibits, drafted supplemental declaration,saved deposition transcripts to electronic folder,updated pleadings folder, organized exhibits on PPGdrive, organized hard copies of deposition transcripts

5

3/7/2012 Prepared TOC and TOA for brief 23/8/2012 Revised TOC and TOA for brief, updated pleadings,

cite and quote checked brief, reviewed exhibits andfiled brief with attorney

5

3/21/2012 Prepared document productions 33/26/2012 Bates stamped documents, burned on CDs and sent

to attorneys and co-counsel3

3/28/2012 Quality check of confidential document production,Bates stamped documents, burned documents toCDs, sent documents to co-counsel, and organizedfiles electronically

5

3/30/2012 cited checked and prepared brief for filing; updatedpleadings

2.5

4/16/2012 cited checked and prepared brief for filing; updatedpleadings

4

4/17/2012 Proofread and filed brief; burned CD; prepared andmailed shipment for oral argument prep

2.5

5/2/2012 printed materials for books for court, drafted TOC forbooks, corresponded with attorney

0.75

5/3/2012 gathered materials for books for court, revised TOC,created cover, coordinated with copy staff, did qualitycheck, and corresponded with attorney

1

5/14/2012 Reserached and added citations to draft brief,inventoried CDs containing production documentsand revised inventory document, and correspondedwith attorney

2

5/16/2012 Saved deposition transcript to internal drive andcorresponded with attorneys

0.25

5/29/2012 Prepared brief for filing (TOC and TOA finalization);compiled list of deposition exhibits forwitness/deposition list for trial; corresponded withattorneys re status of project

5

5/30/2012 restored production documents on system after dataloss, compiled discovery materials and correspondedwith co-counsel, per attorney request, finalized draftexhibit list

5


Page 48


5/31/2012 added production documents to system; preparedCD of production documents; corresponded withattorney re shipment of CD and draft witness andexhibit lists

2.5

6/6/2012 Obtained company check, copied and mailed it tocourt reporter, and corresponded with court reporter.

0.25

6/14/2012 Saved recently filed pleadings to internal documentdatabase; updated electronic pleadings folder

0.4

6/20/2012 Organized electronic copies of deposition transcriptsand deposition exhibits on internal drive

1.1

6/25/2012 Pulled exhibits for SJ liability brief 2.756/26/2012 Pulled exhibits for SJ liability brief; prepared

materials for oral argument prep binders, met withsupervisor

6.6

6/27/2012 pulled exhibits for SJ liability brief, proofread 8.17/2/2012 Organized exhibits for SJ liability brief, including

coordination with vendor and attorney0.7

7/6/2012 Prepared oral argument prep binders; correspondedwith interns

3

7/11/2012 updated pleadings and sent to attorney; updatedtable of contents

0.5

7/13/2012 Prepare job for vendor; reviewed brief for filing 27/23/2012 Circulated deposition transcripts to attorneys; printed

out deposition transcripts per attorney request;updated pleadings folder; organized electronic files ofdeposition exhibits

1

TOTAL 259.98


Page 49


{00032548.DOC}

La Tanya Harry (Time Keeping Records for Scott v. Schedler)

DATE DESCRIPTION HOURS01/09/2012 Edited brief citations 4.501/10/2012 Edited brief citations 1.001/12/2012

Updated pleadings folder;transposed edits to mastercopy of brief; organizedexhibits electronically

3.5

01/13/2012 Met with attorney to discussbrief; assisted Joseph withsending documents toInventus for processing;organized electronic copiesof depositions

01/25/2012 Cite checked brief 2.01/26/2012 Organized exhibits and cite

checked brief6.75

01/27/2012 Cite checked brief; prepareddocuments for deposition,and organized them forshipment

8.5

01/30/2012 Prepared documents forfiling

2.0

01/31/2012 Assisted Joseph withPreparing exhibits anddeclaration for partialsummary judgment filing;cite checked and editedbrief for filing, preparedTOC and TOA

11.5

03/08/2012 Revised TOC and TOA forbrief; updated pleadingsfolder; cite and quotechecked brief; reviewedexhibits and filed brief

5

03/09/2012 Completed filing process 2.00


Page 50


{00032548.DOC}

05/29/2012 Prepared brief for filing(TOC and TOAfinalization); compiled listof deposition exhibits forwitness/deposition list fortrial; corresponded withattorneys re status of project

2.75

06/27/2012 Pulled and reviewedexhibits; cite checked andedited MSJ brief

5

06/28/2012 Pulled exhibits forSummary Judgment liabilitybrief; prepared materials fororal argument prep binders;met with Melissa to discussnext steps in oral argumentprep process

6.6

06/29/2012 Continued editing andpulling exhibits for MSJbrief

5.0

08/16/2012 Assembled documents fortrial prep

2.0

10/05/2012 Assisted with filing prep 3.0

Total 71.1


Page 51


Summary of LDF Expenses

Process Servers & Filing Fees 2,438.79$Depositions & Transcripts 17,936.10$Research 473.64$Mail 2,033.26$Telephone 82.60$Photocopying, Document Review & Production 8,488.39$Air Travel 12,942.45$Car Service, Taxi 1,360.83$Car Rental 4,006.43$Hotel 11,176.95$

TOTAL: 60,939.44$

CATEGORIES

Process Servers, Court Filings

Process Server - 10/24/2011 $ 334.32Process Server - 10/25/2011 $ 305.04Process Server - 12/16/2011 $ 320.89Process Server - 1/3/2012 $ 250.00Process Server - 10/12/12 $ 378.54Pro hac vice motions $ 850.00

SUBTOTAL: 2,438.79$

Depositions & Transcripts

Deposition 11/8/11 Samuel Guillory $ 1,086.80Deposition 11/10/11 Rose Greene $ 928.10Deposition 11/10/11 Johnnie Tyson $ 279.10Deposition 11/15/11 Diane Batts $ 1,077.40Deposition 11/9/11 Dwayne Joubert $ 631.10Deposition 11/16/11 Darlene Hughes $ 490.90Deposition 11/17/11 Kim Ricks $ 394.10Deposition 11/17/11 Brad Coney $ 431.30Deposition 11/8/11 Chandra Kandula $ 318.30Deposition 11/15/11 John Mancuso $ 450.00Deposition 11/17/11 Pamela Denise Harris $ 570.80Deposition 11/9/11 Wendell Young $ 772.20Deposition 11/16/11 Monica McDaniels $ 386.90Deposition 11/10/11 Catherine Michiels $ 377.70Deposition 11/16/11 Christopher Chase $ 605.30

Exhibit B

LDF Expenses (in Total and by Category)

Page 1 of 6


Exhibit B


Deposition 12/19/11 Donna Durand $ 965.20Deposition 12/19/11 Joanne Reed $ 783.40Deposition 12/20/11 William Crawford $ 786.00Deposition 12/20/11 Catherine McRichie $ 388.50Deposition 1/30/12 Angie Rogers $ 1,379.80Deposition 1/31/12 Christine Weatherford $ 540.10Deposition 1/31/12 Elsie Cangelosi $ 511.50Transcript oral argument 4/20/12 before the Honorable Jane TricheMilazzo $ 293.25Deposition 5/10/12 Luther Scott $ 246.85

Deposition 6/7/12 Alice Harris Lewis, Alvin Lewis, Jerome Boykin $ 310.85Deposition 11/9/11 Susan Eversull $ 211.70Deposition 11/9/11 Terri Eckles $ 265.00Deposition 11/9/11 Stephanie Brooks $ 261.80Deposition 6/6/2012 Ernest Johnson $ 349.30Deposition 6/6/2012 Rev. Taylor $ 428.85Deposition 7/12/12 Charles Heckard $ 186.80Deposition 9/13/12 Shawn Banks $ 693.20Deposition 9/13/12 Yolanda Johnson Ash $ 534.00

SUBTOTAL: 17,936.10$

Research

Research: Document retreival in ED La (Case: ACORN v. Fowler),4/6/2011 $ 399.00On-Line Research (Gogo inflight internet) $ 12.95On-Line Research (Gogo inflight internet) (3) $ 24.85On-Line Research (Gogo inflight internet) (2) $ 16.94On-Line Research (Gogo inflight internet) (2) $ 19.90

SUBTOTAL: 473.64$

Mail

Description Amount

Mail to Co-Counsel (Discovery Documents) 11/3/11 $ 16.19Mailings (2) to Defendant (Discovery Documents to DCFS);11/9/2011, 11/11/11 $ 47.463 mailings 11/15/11, 11/16/11, 11/18/11 $ 92.133 overnight mailings, 12/16/11 (deposition materials) $ 290.13Mailing 12/9/11 $ 13.273 mailings, paid 1/9/12 $ 99.76mailing 1/9/12 $ 28.13

Page 2 of 6


Exhibit B


8 overnight mailing, 1/27/12 and 2/1/12 (partial summary judgment) $ 325.52mailing to co-counsel, 2/22/12 $ 5.907 overnight mailings, 2/3/12 through 2/7/12 (partial summaryjudgment) $ 107.562 mailings, 2/9/12 and 2/14/12 $ 43.71mailing 3/6/12 $ 54.493 mailings, 4/18/12 $ 25.96mailing, 5/9/12 $ 20.93mailing, 3/31/12 $ 13.953 mailings, paid 5/10/12 $ 33.094 overnight mailings, 4/11/12 - 4/17/12 $ 150.836 overnight mailings, 5/4/12 (settlement offers) $ 187.77mailing, paid 6/6/12 $ 5.96mailing, paid 6/30/12 $ 11.92overnight mailings, 7/5/12 (summary judgment) $ 107.14overnight mailings 8/31, 9/1/2012 (summary judgment replies) $ 176.98mailing, paid 10/8/12 $ 44.602 overnight mailings, 10/12/12 (trial materials) $ 129.88

SUBTOTAL: $ 2,033.26

Telephone

Conference Call, 2/13/12 $ 15.12Conference Call, 2/16/12 $ 8.14Conference Call, 2/23/12 $ 3.68Conference Call, 5/3/12 $ 3.63Conference Call, 5/15/12 $ 4.99Conference Call, 8/3/12 $ 6.56Conference Call, 8/16/12 $ 11.37Conference Call, 8/20/12 $ 7.09Conference Calls, 9/3/12; 9/24/12; 9/26/12 $ 22.02

SUBTOTAL: 82.60$

Photocopying, Document Review & Production

Description Date Paid Amountdoc scans responses to discovery requests 9/23/2011 $ 532.30doc scans document production 11/23/2011 $ 85.23doc scans document production 11/23/2011 $ 108.52doc scans document production 11/23/2011 $ 320.30doc scans document production 11/23/2011 $ 325.68Photocopying (Kinko's) 12/8/2011 $ 89.57

Page 3 of 6


Exhibit B


File conversions of electronic documents produced by defendants;printing 12/29/2011 $ 88.24File conversions of electronic documents produced by defendants;printing defendants documents 12/29/2011 $ 3,345.61B&W copies, bindings 12/29/2011 $ 177.38Blowbacks, file conversion 4/24/2012 $ 133.60B&W copies 4/24/2012 $ 341.12Blowbacks, EDD 4/24/2012 $ 249.75Blowbacks, scans, EDD -OCR, tabs, bindings 4/24/2012 $ 331.26Scanned pages, EED OCR 5/22/2012 $ 93.48Blowbacks, tabs, bindings 5/22/2012 $ 394.85B&W copies, blowbacks, tabs, bindings 5/22/2012 $ 212.97Scanned pages, EDD file conversion 5/22/2012 $ 252.20Blowbacks, tabs, bindings 5/22/2012 $ 258.53Blowbacks, tabs, bindings 5/22/2012 $ 64.66Copying Expense 6/13/2012 $ 4.42Scanned EED OCR 10/8/2012 $ 57.24Assemble blowbacks 12/7/2012 $ 243.25Assemble blowbacks 12/7/2012 $ 131.82Assemble blowbacks 12/7/2012 $ 400.13B&W copies, tabs, binding; paid 12/7/12 12/7/2012 $ 112.94B&W Copies; paid 12/7/12 12/7/2012 $ 117.00B&W Copies; paid 12/7/12 12/7/2012 $ 16.34

SUBTOTAL: 8,488.39$

Air Travel

Description AmountDH, 7/14/11, to New Orleans for settlement conference and statusconference 487.40$NK, 11/14/11 to Baton Rouge for depositions $ 495.80DH, 11/7/11 and 11/14/11 to Baton Rouge for depositions $ 806.60RH, 11/14/11 to Baton Rouge for depositions $ 778.79NK, 12/18/11 to Baton Rouge for depositions $ 752.80NK, 1/29/12 to Baton Rouge for depositions $ 757.20DH, 1/29/12 to Baton Rouge for depositions 340.37$DH, 4/19/12 to New Orleans for Partial SJ argument $ 560.40

DH, 5/8/12 to New Orleans for settlement conference and deposition $ 373.20

NK, 5/8/12 to New Orleans for settlement conference and deposition $ 545.20NK, 6/5/12 to New Orleans for depositions $ 429.00NK&DH, 9/5/12 to New Orleans for Summary Judgment $ 1,413.20NK, 9/27/12 to New Orleans for Pre-Trial Conference; DH, 9/27/12for Pre-Trial Conference $ 1,541.69

Page 4 of 6


Exhibit B


NK, 10/13/12 to New Orleans for trial; DH 10/8/12 to New Orleansfor trial prep; 10/13/12 to New Orleans for trial $ 3,660.80


Car Service / Taxi

Description Amount

DH, airport roundtrip 7/14/11, 7/18 $ 78.00DH, 2 roundtrips to airport, 11/11 $ 125.84NK, 2 round-trips to airport, 12/11 $ 108.15DH to airport, 1/29/12 $ 50.04NK to airport, 1/29/12 $ 36.62NK from airport, 1/31/12 $ 35.88DH from airport, 2/1/12 $ 35.10NK to and from airport 4/12 $ 115.00DH to and from airport, 4/21/12 and 4/23/12 $ 118.00NK to and from airport $ 87.62DH to airport, 5/9/12 $ 41.00NK to airport, 6/8/12 $ 48.10NK, to airport, 7/8/12 $ 33.66NK 9/3/12 (2); 9/4/12 (2); 9/6/12; 9/19/12; 9/25/12 $ 141.80DH, 9/28/12 $ 59.00NK, 9 car service receipts: 9/29/12; 10/3/12; 10/5/12; 10/8/12;10/10/12 (2); 10/11/12 (2);10/12; 10/13; 10/20/12 $ 247.02

SUBTOTAL: 1,360.83$

Car Rental

Description Amount

DH, New Orleans, 7/15/11 $ 301.64DH, Baton Rouge, 11/7/11 $ 289.83RH, Baton Rouge, 11/18/11 $ 836.85RH, Baton Rouge, 12/18/11 $ 328.15DH, Baton Rouge, 2/1/12 $ 345.28DH, New Orleans, 4/19/12 $ 265.59DH, New Orleans 5/9/12 $ 238.99NK, New Orleans, 6/5/12 $ 329.65DH, New Orleans 10/9/12 through10/19/12 (trial) $ 1,070.45

SUBTOTAL: 4,006.43$

Page 5 of 6


Exhibit B


Hotel

Description Amount

DH, New Orleans 7/14/11 (1 night) $ 275.34

DH, Baton Rouge, 11/7/11 - 11/9/11, 11/14/11 -11/17/11 (6 nights) $ 672.35RH, Baton Rouge, 11/14/11 - 11/18/11 (4 nights) $ 492.68NK, Baton Rouge 11/14/11 - 11/18/11 (4 nights) $ 492.68RH, Baton Rouge, 12/18/11 - 12/20/11 (3 nights) $ 301.71NK, Baton Rouge, 12/18/11 - 12/20/11 (3 nights) $ 301.71NK, Baton Rouge, 1/29/12 - 1/31/12 (2 nights) $ 257.64

DH, Baton Rouge and New Orleans, 1/29/12 - 1/31/12 (3 nights) $ 559.35DH, New Orleans 4/19/12 - 4/20/12 (2 nights) $ 604.25NK, New Orleans 4/19/12 - 4/20/12 (2 nights) $ 604.25NK, New Orleans, 5/9/12 - 5/11/12 (3 nights) $ 649.95DH, New Orleans, 5/9/12 - 5/11/12 (3 nights) $ 649.95NK 6/5/12 - 6/7/12 (3 nights) $ 476.85DH, New Orleans, 10/13/12 - 10/19/12 (6 nights) $2,419.12NK, New Orleans, 10/13/12 - 10/19/12 (6 nights) $2,419.12


Page 6 of 6


1

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

LUTHER SCOTT, JR. and the LOUISIANA STATE CONFERENCE OF THE NAACP, Plaintiffs,

v. TOM SCHEDLER in his official capacity as the Louisiana Secretary of State, SUZY SONNIER, in her official capacity as Secretary of the Louisiana Department of Children & Family Services, and BRUCE D. GREENSTEIN, in his official capacity as Secretary of the Louisiana Department of Health & Hospitals, Defendants.

Civil Action No. 2:11-cv-00926-JTM-JCW

DECLARATION OF RONALD L. WILSON

I, Ronald L. Wilson, hereby declare the following:

1. I am counsel in the above-captioned case, and have worked with the

NAACP Legal Defense and Educational Find (“LDF”), Project Vote, and Fried, Frank,

Harris, Shriver & Jacobson LLP (“Fried Frank”) for in this litigation.

2. I have served as local counsel on this case since its inception, as is

required for visiting attorneys who seek pro hac vice admission to the Eastern District

under Local Rule 83.2.5.


2

3. I respectfully submit this declaration in support of Plaintiffs’ application

for an award of their attorneys’ fees and costs (the “Fee Application”), pursuant to this

Court’s Order awarding fees, dated January 22, 2013. Doc. 436.

4. The Complaint in this case was filed in April 19, 2011, but my work on

the case began before that date. Before filing, Plaintiffs’ counsel conducted background

factual and legal research into the claims raised. We tried to resolve the issues raised in

our Complaint without litigation, as is contemplated by the National Voter Registration

Act (“NVRA”), by sending Defendants a notice letter in January 2011. Our letter advised

the Defendants of non-compliance with the statute, and requested a meeting to discuss to

work towards a resolution of the non-compliance. Defendants provided no meaningful

response to this request within the 90-day statutory notice period. Consequently, after the

notice period delineated in the statute had lapsed, Plaintiffs filed the Complaint. At the

time of our January 2011 notice letter, the number of hours that I had spent on this case

was relatively low.

5. Ultimately, however, as this Court is aware, despite several good faith

attempts by Plaintiffs to settle this case (both before and during litigation), our efforts

were refused.

FEES AND COSTS

6. Plaintiffs seek a total award of $70,880 for my fees. Detailed records, as

well as a summary of my professional fees for which reimbursement is sought are

attached as Exhibit A. During the course of this matter, I recorded my time

contemporaneously, along with a description of the affiliated tasks.


3

7. Plaintiffs do not seek fees for time spent in connection with our work on

this fee petition, or for meals in connection with our work on this case. Plaintiffs also do

not seek other expenses I incurred in connection with this case.

8. I seek an hourly rate of $400 per hour in this case. This lodestar is a

reasonable market rate for an attorney in New Orleans, and the surrounding parts of the

Eastern District, with my level of experience. As reflected in Exhibit A, I spent 177.2

hours on this case.

9. I received my J.D. from Tulane University in 1975, and my B.A. from

Louisiana State University at New Orleans in 1972. In addition to Louisiana, I have been

admitted to the bar in New York, the District of Columbia, Colorado, and Oregon.

10. For the nearly four decades of my practice in Louisiana, I have worked

primarily on civil rights and other public interest cases. The areas in which I have

practiced include employment discrimination, housing discrimination, school

desegregation, voting rights, police misconduct, prison conditions, freedom of speech,

and freedom of association.

11. Moreover, I have litigated over thirteen voting rights cases in Louisiana,

many with the NAACP Legal Defense and Educational Fund, Inc. (“LDF”). Among the

voting cases that I have co-litigated with LDF is Chisom v. Roemer, 501 U.S. 380 (1991),

in which the Supreme Court overturned a Fifth Circuit ruling that the Voting Rights Act

did not apply to elections of judges of the Louisiana State Supreme Court.

12. I also co-litigated Edwards v. Aguillard, 482 U.S. 578 (1987), in which the

Supreme Court held that Louisiana’s Creationism Act violated the Establishment Clause.


4

13. I currently serve as the president of the Louisiana Legal Aid Bureau. I

previously served as president of the ACLU of Louisiana.

14. My work has been recognized by a number of professional, civic, and

educational groups for my work. In 1986, I was named the American Civil Liberties

Union of Louisiana’s Cooperating Attorney of the Year award. In 1987, I received the

Louisiana State Bar Association’s Pro Bono Publico Award for Outstanding

Achievements in the Area of Pro Bono Legal Service. In 1997, I received the University

of New Orleans Ernest “Dutch” Morial Chapter Alumni of the Year award. In 1999, I

was awarded the American Civil Liberties Union of Louisiana’s Ben Smith award for the

advancement of civil liberties in Louisiana. In 2008, I received the Southern Christian

Leadership Conference’s Community Service Award. This year, I am a recipient of the

Emmitt J. Douglas Memorial Award.

RETAINER OF OUT OF STATE COUNSEL

15. Voting rights litigation is well known to be complex, costly, and fact-

intensive. Prosecuting a voting rights claim such as the NVRA claim successfully

brought by Plaintiffs requires a significant investment of resources. Furthermore, electing

to represent indigent plaintiffs, such as those who would be natural plaintiffs in an NVRA

Section 7 claim, requires that those resources be invested upfront, and with potentially no

fees awarded at the end.

16. Although there are of course numerous Louisiana attorneys like myself

with experience in general civil rights issues, there is a paucity of in-state practitioners

here who could have served as lead counsel in this case. As the Court knows, Scott v.

Schedler, et al. was a complex litigation, lasting over 18 months from the filing of the


5

Complaint alone. Even though I am very familiar with voting rights litigation, as a

private practitioner, I could not have litigated this case without support. My

understanding is that LDF and our other co-counsel expended several thousand hours of

attorney time, as well as tens of thousands of dollars in litigation expenses. This is simply

not an investment that a private practitioner in this District could make independently.

Even with significant voting rights experience, I, as most private practitioners, do not

have the time or resources to serve as lead counsel for indigent clients in a case, such as

this one, without any guarantee of remuneration. For these same resource-related reasons,

I am doubtful that even two private practitioners in the New Orleans area could have

undertaken this litigation together.

17. Accordingly, it was reasonable that this case was litigated by out-of-state

attorneys with voting rights expertise.

CONCLUSION

18. For the reasons set forth above and in Plaintiffs’ supporting memorandum

of law, Plaintiffs respectfully request that the Court award them attorneys’ fees in the

amount of $70,880 for my work in connection with this matter in addition to the amounts

sought by co-counsel.



Executed on February 25, 2013 /s Ronald L. Wilson


26



Attorneys' Fees

Pro Bono/Louisiana State Conference of the NAACP

Attorney Position Work Date Description Hourly Rate Hours Amount

de Leeuw, M Partner 8/1/2012 Conference call with Dale Ho (NAACP.LDF); review

materials for same.

650.00 3.60 2,340.00

Yellin, D Associate 8/2/2012 Review motion for SJ and background materials; p/c

w/ M. de Leeuw.

280.00 1.30 364.00

Yellin, D Associate 8/3/2012 NVRA - Review background materials; e-mails w/ M.

de Leeuw.

280.00 4.00 1,120.00

David, I Partner 8/5/2012 Review litigation file and pleadings. 650.00 2.00 1,300.00

de Leeuw, M Partner 8/6/2012 Review materials; multiple calls and emails re:

staffing and case; research.

650.00 3.00 1,950.00

de Leeuw, M Partner 8/7/2012 Conference call; prepare for same. 650.00 3.00 1,950.00

de Leeuw, M Partner 8/8/2012 Review cases and case file; multiple calls and emails

Loffler; conference call with other counsel.

650.00 3.00 1,950.00

de Leeuw, M Partner 8/10/2012 Calls Loffler and Ho; research. 650.00 1.30 845.00

Loffler, J Associate 8/10/2012 Coordinating with MAO on pro hac vice admissions;

gathering materials necessary for pro hac admission.

280.00 0.40 112.00

David, I Partner 8/12/2012 Continued review of litigation file and key

documents.

650.00 3.00 1,950.00

de Leeuw, M Partner 8/13/2012 Multiple calls and emails re: pre-trial order; review

materials re: same.

650.00 3.00 1,950.00

Loffler, J Associate 8/13/2012 Drafting and gathering materials for pro hac forms for

M. de Leeuw and I. David.

280.00 1.40 392.00

Sollie, E Associate 8/13/2012 Meeting with MDL, J. Loffler and D. Yellin regarding

case. Call with co-counsel. Begin work on pre-trial

order.

400.00 3.40 1,360.00

Yellin, D Associate 8/13/2012 Conf. w/ M. de Leeuw, J. Loffler, E. Sollie; attention 280.00 0.80 224.00

Exhibit A

to e-mails.

Deguzman, M Paralegal 8/13/2012 Download deposition transcripts and exhibits from

website and update Livenote and S: Drive per E.

Sollie request; Update electronic litigation binders.

200.00 4.60 920.00

de Leeuw, M Partner 8/14/2012 Multiple calls, meetings and emails re: pretrial order;

review same; research.

650.00 3.00 1,950.00

Loffler, J Associate 8/14/2012 Meeting with E. Sollie and D. Yellin; reading briefs;

editing pro hac forms

280.00 1.70 476.00

Sollie, E Associate 8/14/2012 Work on pre trial order. 400.00 8.60 3,440.00

Yellin, D Associate 8/14/2012 Conf. call w/ M. de Leeuw, E. Sollie, LDF, Project

Vote; Conf. w/ E. Sollie & J. Loffler; draft fact section

of Pre-Trial Order.

280.00 6.40 1,792.00

Deguzman, M Paralegal 8/14/2012 Assist in pulling requested deposition transcripts and

exhibits from website per request.

200.00 3.10 620.00

de Leeuw, M Partner 8/15/2012 Multiple calls and emails re: briefing; pretrial order;

review briefs; calls re: same; review and revise

pretrial order draft.

650.00 5.00 3,250.00

Loffler, J Associate 8/15/2012 Drafting and editing joint pre-trial order 280.00 12.60 3,528.00

Sollie, E Associate 8/15/2012 Work on pre trial order. Meet with D. Yellin and J.

Loffler regarding order. Send draft to MDL and I.

David for review.

400.00 12.30 4,920.00

Yellin, D Associate 8/15/2012 Work on PTO; conf. w/ E. Sollie & J. Loffler re:

same; prepare binders for M. de Leeuw.

280.00 8.70 2,436.00

Deguzman, M Paralegal 8/15/2012 Download exhibits and deposition transcripts and

update S: Drive and Livenote per E. Sollie request.

200.00 2.60 520.00

David, I Partner 8/16/2012 Review PTO; attention to SJ issues; meet and confer

issues.

650.00 2.00 1,300.00

de Leeuw, M Partner 8/16/2012 Review briefs and drafts. 650.00 3.00 1,950.00

Loffler, J Associate 8/16/2012 Meeting with E. Sollie and D. Yellin; review briefs

and statements of fact; review deposition transcripts.

280.00 1.60 448.00

Sollie, E Associate 8/16/2012 Reading depositions. 400.00 1.50 600.00

Page 1 of 12



Attorneys' Fees



Exhibit A

Yellin, D Associate 8/16/2012 Conf. call w/ co-counsel; prepare binders; review

depositions.

280.00 5.70 1,596.00

Deguzman, M Paralegal 8/16/2012 Update livenote exhibits per E. Sollie request. 200.00 1.30 260.00

David, I Partner 8/17/2012 Correspondence. 650.00 0.70 455.00

de Leeuw, M Partner 8/17/2012 Review briefs and drafts; calls Dale Ho, team. 650.00 2.40 1,560.00

Loffler, J Associate 8/17/2012 Reviewing deposition transcripts in advance of trial

and pre-trial order submission.

280.00 1.30 364.00

Sollie, E Associate 8/17/2012 Reading depositions. Send out pre trial order. 400.00 1.70 680.00

Yellin, D Associate 8/17/2012 Read depositions, conf. w/ E. Sollie & J. Loffler 280.00 4.10 1,148.00

de Leeuw, M Partner 8/18/2012 Review materials; call Dale Ho. 650.00 2.10 1,365.00

Loffler, J Associate 8/19/2012 Research on sanctions questions regarding

statements in summary judgment opposition briefs.

280.00 2.70 756.00

Yellin, D Associate 8/19/2012 E-mails w/ E. Sollie & J. Loffler; read depositions. 280.00 2.00 560.00

de Leeuw, M Partner 8/20/2012 Multiple conference calls and emails re: current

status, briefing, etc.

650.00 3.00 1,950.00

Loffler, J Associate 8/20/2012 Research and drafting motion to strike; conference

call over open issues; team meeting on deliverables

and discussion of new exhibits.

280.00 4.80 1,344.00

Sollie, E Associate 8/20/2012 Call with NAACP and Project Vote. Work on Motion

to Strike.

400.00 5.00 2,000.00

Yellin, D Associate 8/20/2012 P/c w/ Team re: M to Strike; conf w/ E. Sollie & J.

Loffler; draft argument section of motion to strike.

280.00 5.00 1,400.00

de Leeuw, M Partner 8/21/2012 Multiple calls and emails re: brief; review and revise

same; conference call.

650.00 4.30 2,795.00

Loffler, J Associate 8/21/2012 Drafting and editing motion to strike; drafting 280.00 9.00 2,520.00

declaration; reviewing materials subject to motion to

strike; conference call with all plaintiffs attorneys; call

with M. de Leeuw

Sollie, E Associate 8/21/2012 Work on drafting motion to strike. Call with NAACP

and PV regarding motion to strike and other

outstanding issues. Meetings with J. Loffler and D.

Yellin regarding motion to strike, pre trial order, and

other outstanding issues.

400.00 6.50 2,600.00

Yellin, D Associate 8/21/2012 Revise argument portion of motion to strike; review

and revise motion to strike.

280.00 6.50 1,820.00

Loffler, J Associate 8/22/2012 Drafting/editing/finalizing the motions to strike,

expedite, affidavit, exhibits, and all supporting

papers.

280.00 8.70 2,436.00

Sollie, E Associate 8/22/2012 Draft Motion to Strike, file Motion to Strike and

Motion to Expedite.

400.00 7.60 3,040.00

Yellin, D Associate 8/22/2012 E-mails w/ J. Loffer & E. Sollie; work on preparing

and filing motion to strike and related motion to

expedite.

280.00 6.60 1,848.00

de Leeuw, M Partner 8/23/2012 Mulitple calls and emails re: scheduling, motions,

and documents; review depositions.

650.00 2.30 1,495.00

Sollie, E Associate 8/23/2012 Review depositions. 400.00 2.10 840.00

Yellin, D Associate 8/23/2012 Review draft reply brief for SJ motion. 280.00 3.50 980.00

de Leeuw, M Partner 8/24/2012 Review and revise summary judgment papers;

multiple calls and emails with team re: status.

650.00 3.00 1,950.00

Sollie, E Associate 8/24/2012 Edits to motion for summary judgement. 400.00 2.00 800.00

Yellin, D Associate 8/24/2012 Research duty to supplement disclosures; review

and revies draft SJ reply.

280.00 3.40 952.00

de Leeuw, M Partner 8/25/2012 Review and revise brief. 650.00 2.00 1,300.00

Yellin, D Associate 8/25/2012 Review and revise draft SJ reply. 280.00 2.50 700.00

de Leeuw, M Partner 8/27/2012 Calls and emails re: briefs and scheduling; review

and revise same.

650.00 1.50 975.00

Page 2 of 12



Attorneys' Fees



Exhibit A

Loffler, J Associate 8/27/2012 Reviewing and proofing reply brief; e-mail

correspondence with team regarding motion to strike

reply.

280.00 1.60 448.00

Sollie, E Associate 8/27/2012 Review depositions. 400.00 3.00 1,200.00

Yellin, D Associate 8/27/2012 Review depositions; review and mark-up SJ reply. 280.00 4.40 1,232.00

de Leeuw, M Partner 8/28/2012 Conference call; calls re: SJ briefs and related

issues.

650.00 2.00 1,300.00

Loffler, J Associate 8/28/2012 Reviewing and editing reply brief for summary

judgment; correspondence with team; conference

call; reviewing summary judgment papers in

preparation for Thursday moot.

280.00 4.70 1,316.00

Sollie, E Associate 8/28/2012 Edit reply to motion for summary judgment. 400.00 2.20 880.00

Yellin, D Associate 8/28/2012 Conf. call w/ M. de Leeuw, E. Sollie, J. Loffler and co-

counsel; attention to e-mails.

280.00 1.30 364.00

Deguzman, M Paralegal 8/28/2012 Cite check brief per E. Sollie request. 200.00 3.50 700.00

de Leeuw, M Partner 8/29/2012 Prepare for moot; review documents; review and

revise brief.

650.00 2.50 1,625.00

Loffler, J Associate 8/29/2012 Reading summary judgment brief and opposition and

motion to strike materials to prep for Thursday moot.

280.00 1.10 308.00

Sollie, E Associate 8/29/2012 Reading depositons 400.00 2.00 800.00

Yellin, D Associate 8/29/2012 Review briefs for moot. 280.00 0.70 196.00

Deguzman, M Paralegal 8/29/2012 Assist in checking citations to briefs per E. Sollie

request.

200.00 3.60 720.00

David, I Partner 8/30/2012 Moot court for summary judgment. 650.00 3.00 1,950.00

de Leeuw, M Partner 8/30/2012 Prepare for and attened moot court. 650.00 4.50 2,925.00

Loffler, J Associate 8/30/2012 Participated in Moot for motion to strike and

summary judgment oral arguments.

280.00 3.00 840.00

Sollie, E Associate 8/30/2012 Moot with LDF and Project Vote. Prepare for moot. 400.00 4.40 1,760.00

Yellin, D Associate 8/30/2012 Moot for SJ Argument; prepare for same; review

depositions.

280.00 4.70 1,316.00

David, I Partner 8/31/2012 Attention to motion to strike issues; correspondence. 650.00 2.20 1,430.00

de Leeuw, M Partner 8/31/2012 Multiple calls and emails re: briefing and arguments,

travel, and related issues.

650.00 1.30 845.00

Loffler, J Associate 8/31/2012 Reviewing briefs filed by defendants for Motion to

Strike; drafting first draft of reply brief for Motion to

Strike; conference call with team; correspondence

with team

280.00 4.10 1,148.00

Sollie, E Associate 8/31/2012 Call with LDF and PV. Draft reply to motions to

strike.

400.00 5.30 2,120.00

Yellin, D Associate 8/31/2012 Work on reply for M to Strike. 280.00 6.70 1,876.00

de Leeuw, M Partner 9/1/2012 Review and revise reply brief; research. 650.00 1.90 1,235.00

Yellin, D Associate 9/1/2012 Review Johnson opposition re: Motion to Strike; e-

mail to J. Loffler & E. Sollie.

280.00 1.50 420.00

de Leeuw, M Partner 9/2/2012 Review and revise brief; emails and call re: same. 650.00 2.20 1,430.00

de Leeuw, M Partner 9/3/2012 Review brief; conference call; research. 650.00 1.30 845.00

Loffler, J Associate 9/3/2012 Conference call/moot for Wednesday oral argument;

turning changes to reply memo of law for motion to

strike.

280.00 2.80 784.00

Yellin, D Associate 9/3/2012 Conf. call w/ co-counsel re: moot for Sept. 5; Review

and revise reply and opposition papers re: motions to

strike; finalize and prepare same for filing.

280.00 6.40 1,792.00

David, I Partner 9/4/2012 Prepare for court hearing. 650.00 1.70 1,105.00

David, I Partner 9/4/2012 Travel from NYC to New Orleans [6 hours travel time

@ 50% lodestar rate].

325.00 6.00 1,950.00

Page 3 of 12



Attorneys' Fees



Exhibit A

de Leeuw, M Partner 9/4/2012 Multiple calls and emails re: court hearing; review all

filings.

650.00 6.00 3,900.00

de Leeuw, M Partner 9/4/2012 Travel to Louisiana for court hearing [6 hours travel

time @ 50% lodestar rate].

325.00 6.00 1,950.00

Loffler, J Associate 9/4/2012 Coordinating filing of papers; e-mail correspondence

with team and MAO; reviewing surreply; reviewing

fees draft from motion to compel.

280.00 2.30 644.00

Sollie, E Associate 9/4/2012 Reviewing depositions 400.00 4.80 1,920.00

Yellin, D Associate 9/4/2012 Work on filings; review case materials; e-mails re:

binders for M. de Leeuw.

280.00 1.60 448.00

David, I Partner 9/5/2012 Attend oral argument and court conference. 650.00 4.50 2,925.00

David, I Partner 9/5/2012 Travel from New Orleans to NYC [6 hours travel time


325.00 6.00 1,950.00

de Leeuw, M Partner 9/5/2012 Attend Court hearing; post-hearing meeting, emails

and call.

650.00 10.00 6,500.00

de Leeuw, M Partner 9/5/2012 Return travel to NYC [6 hours travel time @ 50%

lodestar rate].

325.00 6.00 1,950.00


Yellin, D Associate 9/5/2012 Review sur-replies; conf. w/ E. Sollie & J. Loffler; p/c

w/ M. Rupp & E. Sollie re: oral argument.

280.00 1.90 532.00

de Leeuw, M Partner 9/6/2012 Conference call; team meeting; research; calls and

emails re: ongoing projects; call with Tom Jones;

emails and calls re: same.

650.00 7.50 4,875.00

Loffler, J Associate 9/6/2012 Conference call and team meetings 280.00 1.70 476.00

Sollie, E Associate 9/6/2012 Reorganize statement of uncontested facts for Pre 400.00 7.00 2,800.00

Trial Order.

Yellin, D Associate 9/6/2012 P/c w/ M. de Leeuw, I. David, E. Sollie, J. Loffler, and

co-counsel re: trial prep; revise pre-trial order.

280.00 6.60 1,848.00

de Leeuw, M Partner 9/7/2012 Calls and emails re: proposed injunction language;

emails and calls re: documents; review documents;

conference call.

650.00 5.00 3,250.00

Loffler, J Associate 9/7/2012 Reviewing pre-trial order; discussing matter with E.

Sollie and D. Yellin

280.00 0.60 168.00

Sollie, E Associate 9/7/2012 Work on pre trial order. Work on statement of

uncontested facts. Calls with team.

400.00 5.00 2,000.00

Yellin, D Associate 9/7/2012 Revise facts for PTO. 280.00 4.50 1,260.00

Chan, J Lit.Sup. 9/7/2012 Copying native files from thumb drive to server using

Robocopy. Importing natives into LAW and running

batch processing.

180.00 3.50 630.00

de Leeuw, M Partner 9/8/2012 Review draft injunction and consent decrees from

other jurisdictions.

650.00 2.10 1,365.00

Yellin, D Associate 9/8/2012 Read DHH deposition transcripts; review draft

injunction and e-mails from S. Brannon.

280.00 3.80 1,064.00

Chan, J Lit.Sup. 9/8/2012 Manually tiffing out documents that failed automated

processing.

180.00 3.00 540.00

de Leeuw, M Partner 9/9/2012 Review documents, briefs, drafts, and

correspondence.

650.00 1.40 910.00

Yellin, D Associate 9/9/2012 Review deposition transcripts. 280.00 1.00 280.00

Chan, J Lit.Sup. 9/9/2012 Exporting as single page tiff images and loading to

new concordance database.

180.00 0.90 162.00

de Leeuw, M Partner 9/10/2012 Multiple calls and emails re: scheduling and

negotiations; review documents; review deposition

transcripts.

650.00 4.00 2,600.00

Loffler, J Associate 9/10/2012 Editing and coordinating filing of pro hac for E. Sollie;

editing/researching facts section for order of proof

and pre-trial order.

280.00 3.30 924.00

Sollie, E Associate 9/10/2012 Prepare for depositions. Work on pre trial order. 400.00 6.00 2,400.00

Page 4 of 12



Attorneys' Fees



Exhibit A

Yellin, D Associate 9/10/2012 Conf. call w/ co-counsel; review citations in draft

PTO; review documents on concordance; conf. w/ J.

Loffler & E. Sollie.

280.00 3.50 980.00

Chan, J Lit.Sup. 9/10/2012 Exporting fies as single page tiff images with

Concordance load files. Loading into Concordance

for review.

180.00 1.50 270.00

de Leeuw, M Partner 9/11/2012 Mulitple calls and emails re: status, scheduling, trial

strategy, pre-trial order.

650.00 5.40 3,510.00

Loffler, J Associate 9/11/2012 Editing/updating the order of proof and pre-trial

order; e-mail correspondence with team regarding

the PTO; review of statements of undisputed

material facts.

280.00 5.20 1,456.00

Sollie, E Associate 9/11/2012 Prepare for depositions. Work on pre trial order. 400.00 7.40 2,960.00

Yellin, D Associate 9/11/2012 Conf. w/ J. Loffler & E. Sollie; revise facts for PTO;

read deposition transcripts.

280.00 6.30 1,764.00

de Leeuw, M Partner 9/12/2012 Multiple calls and emails re: list of ongoing

violations/past violations; pre-trial order; emails with

counsel for SoS.

650.00 5.60 3,640.00

Loffler, J Associate 9/12/2012 Fact section for pre-trial order; hard copies of

exhibits and index for production to opposing

counsel.

280.00 2.70 756.00

Sollie, E Associate 9/12/2012 Prepare for deposition. 400.00 2.70 1,080.00

Sollie, E Associate 9/12/2012 Travel to New Orleans [6 hours travel time @ 50%

lodestar rate].

200.00 6.00 1,200.00

Yellin, D Associate 9/12/2012 Work on PTO, conf. w/ J. Loffler; work on

documents; review depositions

280.00 2.80 784.00

de Leeuw, M Partner 9/13/2012 Review depositions and exhibits for pretrial order.

Multiple calls and emails re: same.

650.00 4.30 2,795.00

Loffler, J Associate 9/13/2012 Pulling together and cross-checking final exhibit list

and printed exhibits for completeness and accuracy

for production to opposing counsel.

280.00 3.50 980.00

Sollie, E Associate 9/13/2012 Take depositions of Y. Ash and S. Banks. 400.00 8.00 3,200.00

Sollie, E Associate 9/13/2012 Travel back to NYC [6 hours travel time]. 200.00 6.00 1,200.00

Yellin, D Associate 9/13/2012 Review and prepare exhibits to ship to defendants. 280.00 7.10 1,988.00

de Leeuw, M Partner 9/14/2012 Multiple calls and emails re: status; review

depositions for pretrial conference.

650.00 4.50 2,925.00

Loffler, J Associate 9/14/2012 E-mail correspondence; meeting with team;

conference call; finalizing and shipping exhibit books

to opposing counsel.

280.00 1.40 392.00

Sollie, E Associate 9/14/2012 Work on pre trial order. Work on getting copies of

exhibits to all defendants. Call with co-counsel.

400.00 4.40 1,760.00

Yellin, D Associate 9/14/2012 Work on trial exhibits. 280.00 5.00 1,400.00

de Leeuw, M Partner 9/16/2012 Review documents; multiple emails and calls re:

same.

650.00 4.00 2,600.00

Yellin, D Associate 9/16/2012 Review SOS exhibits and draft objections. 280.00 3.50 980.00

de Leeuw, M Partner 9/17/2012 Review defendants' exhibits' emails and calls re:

same.

650.00 7.50 4,875.00

Loffler, J Associate 9/17/2012 Drafting and editing pretrial order; proofing and

sending pretrial order to opposing counsel;

coordinating with lit support on concordance and ftp

exhibits; reviewing exhibits and pre-trial order inserts

from defendants.

280.00 9.70 2,716.00

Yellin, D Associate 9/17/2012 Review and compile changes to draft PTO; e-mails

w/ team; review exhibits and revisions to PTO.

280.00 3.80 1,064.00

Chan, J Lit.Sup. 9/17/2012 Importing natives into LAW for batch processing.

Exporting as single page tiff images and loading to

Concordance for review.

180.00 1.50 270.00

Page 5 of 12



Attorneys' Fees



Exhibit A

de Leeuw, M Partner 9/18/2012 Attention to meet and confer and pretrial order;

multiple calls and emails re: same; review

depositions.

650.00 7.00 4,550.00

Loffler, J Associate 9/18/2012 Status call with E. Sollie 280.00 0.20 56.00

Sollie, E Associate 9/18/2012 Prepare for meet and confer. 400.00 3.90 1,560.00

Yellin, D Associate 9/18/2012 Draft opposition to Motion for Status; conf. call w/

team; conf. w/ E. Sollie; review SOS exhibits.

280.00 10.80 3,024.00

de Leeuw, M Partner 9/19/2012 Multiple calls and emails re: pretrial order; prepare

for call; meeting.

650.00 7.50 4,875.00

Loffler, J Associate 9/19/2012 Pre-trial order edits/review; objections to list of

exhibits of defendants; supplemental exhibits for

plaintiffs; coordinating with lit support to share with

other counsel.

280.00 5.60 1,568.00

Sollie, E Associate 9/19/2012 Prepare for meet and confer. Calls with co-counsel. 400.00 4.30 1,720.00

Yellin, D Associate 9/19/2012 Conf. call w/ team; p/c w/ J. Loffler, N. Korgaonkar, &

R. Wilson; Review objections and PTO inserts.

280.00 4.20 1,176.00

de Leeuw, M Partner 9/20/2012 Prepare for meet and confer; meet and confer; team

meetings and calls; review revisions.

650.00 10.00 6,500.00

Loffler, J Associate 9/20/2012 Meet and confer with defendants regarding pre-trial

order; making edits and changes to pre-trial order

and exhibit lists.

280.00 11.40 3,192.00

Yellin, D Associate 9/20/2012 Pre-trial meet-and-confer, conf. w' co-counsel re:

same; revise fact sections of pre-trial order.

280.00 11.10 3,108.00

de Leeuw, M Partner 9/21/2012 Review revisions to pretrial order; attention to pretrial

order and communcations re: same.

650.00 4.00 2,600.00

Loffler, J Associate 9/21/2012 Turning all parties edits to pre-trial order; finalizing

updated PTO and exhibit list with objections.

280.00 7.50 2,100.00


Yellin, D Associate 9/21/2012 Revise and circulate PTO; conf. call w/ co-counsel. 280.00 5.40 1,512.00

de Leeuw, M Partner 9/22/2012 Attention to pretrial order and related matters and

communications.

650.00 4.30 2,795.00

Yellin, D Associate 9/22/2012 Review comments on PTO; e-mails w/ co-counsel. 280.00 1.50 420.00

de Leeuw, M Partner 9/23/2012 Attention to pretrial order and related matters and

communications.

650.00 4.70 3,055.00

Yellin, D Associate 9/23/2012 Revisions to PTO; e-mails w/ co-counsel. 280.00 5.20 1,456.00

de Leeuw, M Partner 9/24/2012 Review and revise pretrial order; multiple calls and

emails re: same; multiple conference calls re: same.

650.00 7.60 4,940.00

Loffler, J Associate 9/24/2012 Editing pre-trial order; finalizing and proofing the pre-

trial order; e-mail and phone correspondence with co-

counsel and team; drafting and editing letter to

judge; coordinating filing with MAO.

280.00 7.80 2,184.00

Sollie, E Associate 9/24/2012 Filing pre-trial order. Editing pre trial order. Calls with

opposing counsel regarding pre trial order. Call with

co counsel regarding pre trial order.

400.00 7.20 2,880.00

Yellin, D Associate 9/24/2012 Review, revise, and finalize Pre-Trial Order; conf. call

w/ team.

280.00 5.40 1,512.00

de Leeuw, M Partner 9/25/2012 Calls and emails re: DCFS motion for a continuance;

multiple calls and emails re: scheduling and strategy;

review final version of pretrial order; call re: same.

650.00 7.00 4,550.00

Loffler, J Associate 9/25/2012 Reviewing proposed findings of fact; coordinate with

paralegal on exhibit list and closing binder/flash drive

for judge; correspondence with team regarding order

of proof; witnesses; and pre-trial order.

280.00 2.60 728.00

Page 6 of 12



Attorneys' Fees



Exhibit A

Sollie, E Associate 9/25/2012 Call with co counsel regarding pre trial order and

next steps. Work on motions in limine.

400.00 4.30 1,720.00

Yellin, D Associate 9/25/2012 Conf. call w/ team; research on sanctions and

contested facts in PTO.

280.00 3.90 1,092.00

de Leeuw, M Partner 9/26/2012 Prepare for Louisiana trip; multiple calls and emails;

review draft documents.

650.00 6.00 3,900.00

Loffler, J Associate 9/26/2012 Conference call with team on witnesses, order of

proof, and deliverables; editing witness chart; e-mail

correspondence with co-counsel.

280.00 2.50 700.00

Yellin, D Associate 9/26/2012 E-mails w/ team; research re: admissibility of

statements of facts at trial.

280.00 1.50 420.00

de Leeuw, M Partner 9/27/2012 Team meeting; court hearing; meeting; review

documents and depositions.

650.00 9.50 6,175.00

de Leeuw, M Partner 9/27/2012 Travel to New Orleans [6 hours travel time @ 50%

lodestar rate].

325.00 6.00 1,950.00

Loffler, J Associate 9/27/2012 Editing proposed conclusions of law; meeting with D.

Yellin and E. Sollie; call with E. Sollie to discuss

matter; reviewing proposed injunction and findings of

fact outlines.

280.00 3.10 868.00

Sollie, E Associate 9/27/2012 Calls with co counsel. Drafting motions in limine.

reviewing various documents.

400.00 6.10 2,440.00

Yellin, D Associate 9/27/2012 Draft motions in limine; p/c w/ E. Sollie; Conf. w/ E.

Sollie & J. Loffler; prepare for trial.

280.00 6.60 1,848.00

de Leeuw, M Partner 9/28/2012 Mulitple calls and emails; review proposed

conclusions of law; review depositions.

650.00 4.10 2,665.00

Yellin, D Associate 9/28/2012 Draft Motions in Limine; conf. w/ team. 280.00 5.20 1,456.00

de Leeuw, M Partner 9/29/2012 Review and revise conclusions of law; review and

revise motions in limine.

650.00 4.00 2,600.00

Yellin, D Associate 9/29/2012 Review and revise Motions in Limine; review Draft

Injunction; attention to e-mails from team.

280.00 3.80 1,064.00

de Leeuw, M Partner 9/30/2012 Review depositions; review and revise motions in

limine; emails re: scheduling.

650.00 1.70 1,105.00

Loffler, J Associate 9/30/2012 Gathering replacement exhibits for inclusion on flash

drive for counsel and judge.

280.00 0.50 140.00

de Leeuw, M Partner 10/1/2012 Prepare for meet and confer; meet and confer;

multiple calls and emails re: same.

650.00 8.60 5,590.00

Loffler, J Associate 10/1/2012 Reviewing and editing proposed findings of fact;

meet-and-confer conference call and team meeting;

booking travel for team members for trial.

280.00 6.20 1,736.00

Yellin, D Associate 10/1/2012 Draft MIL; meet and confer w/ opposing counsel;

conf. w/ team.

280.00 6.20 1,736.00

de Leeuw, M Partner 10/2/2012 Attention to pre-trial order; review transcripts and

scripts; multiple calls and emails.

650.00 6.00 3,900.00

Loffler, J Associate 10/2/2012 Conference call with co-counsel; drafting and editing

motions in limine and oppositions; reviewing

depositions for cross-examination scripts; drafting

cross-examination scripts.

280.00 6.60 1,848.00

Sollie, E Associate 10/2/2012 Preparations for trial. 400.00 3.00 1,200.00

Yellin, D Associate 10/2/2012 Conf. w/ team re: trial prep; review and revise fact

sections of pre-trial order.

280.00 6.40 1,792.00

de Leeuw, M Partner 10/3/2012 Trial prep and attention to PTO. 650.00 8.00 5,200.00

Loffler, J Associate 10/3/2012 E-mail correspondence with co-counsel; drafting and

editing motions in limine and oppositions; editing pre-

trial order; creating trial exhibit list for flash drives.

280.00 10.60 2,968.00

Sollie, E Associate 10/3/2012 Work on revised pre trial order. Work on cross

examination scripts. Work on motions in limine.

400.00 6.90 2,760.00

Yellin, D Associate 10/3/2012 Revise PTO; e-mails w/ team re: same. 280.00 4.80 1,344.00

Page 7 of 12



Attorneys' Fees



Exhibit A

de Leeuw, M Partner 10/4/2012 Trial preparation and attention to PTO. 650.00 6.00 3,900.00

Loffler, J Associate 10/4/2012 Cross-checking exhibits and ensuring flash drives

are accurate and complete; mailing flash drives of

exhibits to judge and all parties; e-mail

correspondence with co-counsel re: pre-trial order.

280.00 4.10 1,148.00

Sollie, E Associate 10/4/2012 Work on Amended Pre-Trial Order. Reading

depositions. Work on sending out all exhibits to

Judge Milazzo via fed ex.

400.00 4.50 1,800.00

Yellin, D Associate 10/4/2012 Revise pre-trial order; review Rogers deposition. 280.00 5.20 1,456.00

Chan, J Lit.Sup. 10/4/2012 Burning flash drives and DVDs of required

documentation.

180.00 2.00 360.00

de Leeuw, M Partner 10/5/2012 Trial prep; call with team. 650.00 7.00 4,550.00

Loffler, J Associate 10/5/2012 Conference call with team; e-mail correspondence in

connection with filing PTO and findings of fact; e-

mail correspondence and phone call with trial tech

provider.

280.00 0.90 252.00

Sollie, E Associate 10/5/2012 Work on direct/cross scripts. Work on motions in

limine. Work on filing the Amended Pre Trial Order.

400.00 7.30 2,920.00

Yellin, D Associate 10/5/2012 Review and revise pre-trial order; work on motions in

limine; conf. w/ team; review Rogers deposition.

280.00 4.80 1,344.00

de Leeuw, M Partner 10/6/2012 Calls and emails re: evidentiary issues and Motions

in Limine.

650.00 3.50 2,275.00

Yellin, D Associate 10/6/2012 Read Rogers deposition; draft examination

questions.

280.00 7.90 2,212.00

de Leeuw, M Partner 10/7/2012 Calls and emails re: evidentiary issues and Motions

in Limine; trial prep.

650.00 4.80 3,120.00

Loffler, J Associate 10/7/2012 Drafting cross examination scripts; reviewing

depositions.

280.00 1.50 420.00

Sollie, E Associate 10/7/2012 Work on cross and direct scripts. Editing motions in

limine.

400.00 5.40 2,160.00

Yellin, D Associate 10/7/2012 Review and revise Rogers direct and cross

questions; e-mails w/ team; read Banks deposition.

280.00 6.20 1,736.00

de Leeuw, M Partner 10/8/2012 Trial Prep. 650.00 9.00 5,850.00

Loffler, J Associate 10/8/2012 Drafting cross-examination scripts; conference call

and e-mail correspondence with team and co-

counsel; drafting pro hac admission motions for D.

Yellin and J. Loffler; drafting, editing, finalizing, and

filing motions in limine, memos of law, notices, and

proposed orders.

280.00 14.70 4,116.00

Sollie, E Associate 10/8/2012 Preparing and filing Motions in Limine. Work on

direct and cross scripts. Calls with co-counsel.

400.00 10.40 4,160.00

Yellin, D Associate 10/8/2012 Review S. Banks deposition; draft Banks cross;

Conf. call w/ team.

280.00 6.20 1,736.00

de Leeuw, M Partner 10/9/2012 Trial prep. 650.00 8.50 5,525.00

Loffler, J Associate 10/9/2012 Drafting cross examination scripts; finalizing pro hac

forms for filing.

280.00 2.40 672.00

Sollie, E Associate 10/9/2012 Work on cross examination script. Edit response to

Defendant's motion in limine. Call with co-counsel.

Meeting with M. De Leeuw regarding case. Meetings

with J. Loffler and D. Yellin regarding assignments.

400.00 8.00 3,200.00

Yellin, D Associate 10/9/2012 Conf. w/ team; draft opposition for motions in limine;

p/c w/ N. Korgaonkar.

280.00 9.20 2,576.00


Loffler, J Associate 10/10/2012 Cross-examination scripts; discussion with M. de

Leeuw; call with trial tech person; drafting/editing and

filing supplemental filings to witness list.

280.00 7.00 1,960.00

Page 8 of 12



Attorneys' Fees



Exhibit A

Sollie, E Associate 10/10/2012 Work on cross/direct scripts. Call with co-counsel

regarding proposed SOS stipulation and other

issues. Work on filing witness list and depositions.

Editing responses to motions in limine.

400.00 6.30 2,520.00

Yellin, D Associate 10/10/2012 Draft opposition to judicial notice motion; conf. call w/

team; p/c w. N. Korgaonkar re: Exhibits; review

exhibits for binders; revise opposition papers.

280.00 6.10 1,708.00

de Leeuw, M Partner 10/11/2012 Trial prep; meeting ;review and revise scripts. 650.00 10.00 6,500.00

Loffler, J Associate 10/11/2012 Drafting/editing cross examination scripts; mooting

cross examination scripts with trial team; creating

demonstratives.

280.00 9.80 2,744.00

Sollie, E Associate 10/11/2012 Trial prep 400.00 11.70 4,680.00

Yellin, D Associate 10/11/2012 Witness prep for trial; revise oppositions to Schedler

motions in limine; revise witness scripts; e-mails and

p/cs w/ team; prepare W. Young subpoena; arrange

exhibit binders.

280.00 13.80 3,864.00

de Leeuw, M Partner 10/12/2012 Trial Prep. 650.00 8.00 5,200.00

Loffler, J Associate 10/12/2012 Creating demonstratives; cross examination scripts;

binders for trial; shipping everything to Louisiana.

280.00 9.90 2,772.00

Sollie, E Associate 10/12/2012 Trial prep. Draft scripts. Get exhibit binders. Send

exhibit binders. Call with co counsel .

400.00 7.10 2,840.00

Yellin, D Associate 10/12/2012 Arrange binders of trial exhibits; revise Rogers and

Banks scripts; p/c w/ team; arrange exhibits and

other trial materials; trial prep.

280.00 9.20 2,576.00


Loffler, J Associate 10/13/2012 Meeting with trial team in preparation for arguments. 280.00 1.50 420.00

Loffler, J Associate 10/13/2012 Trial preparation including motion arguments and

exhibits.

280.00 2.60 728.00

Loffler, J Associate 10/13/2012 Travel to New Orleans for trial [6 hours travel time @

50% lodestar rate].

140.00 6.00 840.00

Sollie, E Associate 10/13/2012 Trial prep. 400.00 4.60 1,840.00

Sollie, E Associate 10/13/2012 Travel to New Orleans [6 hours travel time @ 50%

lodestar rate].

200.00 6.00 1,200.00

Yellin, D Associate 10/13/2012 Meet w/ team re: motions in limine and trial

preparations.

280.00 4.60 1,288.00

Yellin, D Associate 10/13/2012 Fly to New Orleans for trial [6 hours travel time @

50% lodestar rate].

140.00 6.00 840.00

de Leeuw, M Partner 10/14/2012 Prepare for trial. 650.00 11.00 7,150.00

de Leeuw, M Partner 10/14/2012 Travel to New Orleans [6 hours travel time @ 50%

lodestar rate].

325.00 6.00 1,950.00

Loffler, J Associate 10/14/2012 Trial preparation; meetings with team; argument

mooting

280.00 10.50 2,940.00

Sollie, E Associate 10/14/2012 Trial prep. 400.00 11.50 4,600.00

Yellin, D Associate 10/14/2012 Prepare for trial; review and rehearse oral argument. 280.00 9.70 2,716.00

de Leeuw, M Partner 10/15/2012 Trial, prepare for day two. 650.00 16.00 10,400.00

Loffler, J Associate 10/15/2012 At trial and preparation for next day after recess 280.00 16.00 4,480.00

Sollie, E Associate 10/15/2012 Trial 400.00 16.00 6,400.00

Yellin, D Associate 10/15/2012 Trial and work re: same. 280.00 15.80 4,424.00

de Leeuw, M Partner 10/16/2012 Trial; prepare for Day 3. 650.00 14.50 9,425.00

Loffler, J Associate 10/16/2012 At trial and preparation for next day; closing

demonstratives

280.00 13.80 3,864.00

Loffler, J Associate 10/16/2012 Trial prep strategy discussion for next day of trial,

and mooting.

280.00 1.00 280.00


Yellin, D Associate 10/16/2012 Trial and work re: same. 280.00 14.30 4,004.00

Page 9 of 12



Attorneys' Fees



Exhibit A

David, I Partner 10/17/2012 Attend trial; review trial materials. 650.00 6.50 4,225.00

David, I Partner 10/17/2012 Travel from NYC to New Orleans [6 hours travel time


325.00 6.00 1,950.00

de Leeuw, M Partner 10/17/2012 Trial; post trial meetings. 650.00 9.00 5,850.00

Loffler, J Associate 10/17/2012 At trial and concluding work after adjournment 280.00 7.30 2,044.00


Yellin, D Associate 10/17/2012 Trial. 280.00 7.30 2,044.00

David, I Partner 10/18/2012 Review trial materials. 650.00 2.80 1,820.00

David, I Partner 10/18/2012 Travel from New Orleans to NYC [6 hours travel time


325.00 6.00 1,950.00

de Leeuw, M Partner 10/18/2012 Post-trial meetings; mutliple calls and emails. 650.00 5.00 3,250.00

Loffler, J Associate 10/18/2012 Breaking down war room and sending all materials

back to firm; shredding attorney work product no

longer needed

280.00 2.00 560.00

Sollie, E Associate 10/18/2012 Break down co cousel's office. Ship things back to

FF.

400.00 3.20 1,280.00

Yellin, D Associate 10/18/2012 Disassemble trial materials and ship to NY; clean

trial war room.

280.00 2.50 700.00

David, I Partner 10/19/2012 Review trial materials. 650.00 3.90 2,535.00

de Leeuw, M Partner 10/19/2012 Research; multiple calls and emails. 650.00 2.50 1,625.00

de Leeuw, M Partner 10/19/2012 Return travel to NYC [7 hours travel time @ 50%

lodestar rate].

325.00 7.00 2,275.00

Loffler, J Associate 10/19/2012 Returning from trial - hotel to home [8.6 hours travel

time @ 50% lodestar rate].

140.00 8.60 1,204.00

Sollie, E Associate 10/19/2012 Travel [7.7 hours travel time @ 50% lodestar rate]. 200.00 7.70 1,540.00

Yellin, D Associate 10/19/2012 Flight to NY from New Orleans. [7 hours travel time] 140.00 7.00 980.00

de Leeuw, M Partner 10/22/2012 Review and revise motion; filing; multiple calls and

emails re: trial-related matters.

650.00 5.50 3,575.00

Loffler, J Associate 10/22/2012 Meeting with D. Yellin and E. Sollie; e-mail

correspondence to/from co-counsel.

280.00 0.40 112.00

Yellin, D Associate 10/22/2012 Review and revise motion to admit facts; research on

standing; draft e-mail to opp. counsel re: caption;

review and organize case materials.

280.00 5.70 1,596.00

de Leeuw, M Partner 10/23/2012 Review updated draft; calls and emails re: post-trial

briefing; research.

650.00 3.30 2,145.00

Sollie, E Associate 10/23/2012 Editing and drafting standing section of post trial

brief.

400.00 2.10 840.00

Yellin, D Associate 10/23/2012 Draft portion of post-trial brief; review brief on

admissibility of fact statements; e-mails w/ team;

research on standing.

280.00 6.30 1,764.00

Loffler, J Associate 10/24/2012 Reviewing standing section of post-trial brief 280.00 0.40 112.00

Yellin, D Associate 10/24/2012 Review and revise standing portion of post-trial brief;

e-mails w/ team re: motion to admit pleadings.

280.00 3.20 896.00

David, I Partner 10/25/2012 Review portion of transcripts. 650.00 2.00 1,300.00

de Leeuw, M Partner 10/25/2012 Attention to post-trial filings. 650.00 1.80 1,170.00

Loffler, J Associate 10/25/2012 Review of standing section in post-trial brief; email

correspondence regarding the same; discussion with

M. de Leeuw, and e-mail correspondence, regarding

invoicing amongst co-counsel.

280.00 0.50 140.00

Yellin, D Associate 10/25/2012 Review and revise motion to admit Defendants'

SMFs.

280.00 1.10 308.00

de Leeuw, M Partner 10/26/2012 Attention to post-trial filings. 650.00 2.20 1,430.00

Loffler, J Associate 10/26/2012 E-mail correspondence with team and court reporter. 280.00 0.20 56.00

Yellin, D Associate 10/26/2012 Revise and file memorandum re: motion to admit

Defendants SMF.

280.00 1.80 504.00

Page 10 of 12



Attorneys' Fees



Exhibit A

Yellin, D Associate 10/29/2012 E-mails w/ team; research and e-mail re: motion to

change caption.

280.00 1.60 448.00

de Leeuw, M Partner 10/30/2012 Attention to post-trial briefing. 650.00 1.50 975.00

de Leeuw, M Partner 10/31/2012 Attention to post-trial briefing. 650.00 2.00 1,300.00

de Leeuw, M Partner 11/4/2012 Multiple emails and calls re: exchange of information;

review same.

650.00 1.30 845.00

de Leeuw, M Partner 11/5/2012 Calls and emails re: post trial briefing and disclosure

of information to defendants.

650.00 4.00 2,600.00

Sollie, E Associate 11/5/2012 Editing post trial brief. 400.00 1.50 600.00

Yellin, D Associate 11/5/2012 Draft motion to amend caption; e-mails w/ team;

review post-trial brief draft.

280.00 1.70 476.00

de Leeuw, M Partner 11/6/2012 Review and revise brief; review cases on standing;

multiple calls and emails.

650.00 3.50 2,275.00

Yellin, D Associate 11/6/2012 Review and revise post-trial brief; revise motion to

amend caption.

280.00 2.40 672.00

de Leeuw, M Partner 11/7/2012 Research; calls and emails re: post-trial briefing and

related issues; review transcripts.

650.00 3.40 2,210.00

Yellin, D Associate 11/7/2012 Circulate motion to amend caption; e-mails w/ team. 280.00 0.20 56.00

de Leeuw, M Partner 11/8/2012 Conference call; follow up; review research;

comments on briefs; calls and emails Dale Ho.

650.00 3.50 2,275.00

Loffler, J Associate 11/8/2012 Conference call with co-counsel; review of research

on points raised in call; e-mail correspondence with

co-counsel after the call.

280.00 2.20 616.00

Yellin, D Associate 11/8/2012 Conf. call w/ team; e-mails w/ opposing counsel re:

motion to amend caption.

280.00 2.20 616.00

de Leeuw, M Partner 11/9/2012 Emails and calls re: filing status; research;. 650.00 3.40 2,210.00

Loffler, J Associate 11/9/2012 E-mail correspondence with Court Reporter re: errata

sheets and trial transcripts; e-mail correspondence

with J. Boros regarding invoice for trial tech services.

280.00 0.40 112.00

Yellin, D Associate 11/9/2012 E-mails w/ opp. counsel and team re: motion to

amend caption.

280.00 0.90 252.00

de Leeuw, M Partner 11/12/2012 Emails and calls re: post-trial matters. 650.00 1.10 715.00

Yellin, D Associate 11/13/2012 Review and revise post-trial brief; finalize motion to

amend caption and motion to expedite same and

send to MAO for filing.

280.00 2.40 672.00

de Leeuw, M Partner 11/14/2012 Calls and emails re: post-trial issues. 650.00 2.00 1,300.00

Yellin, D Associate 11/14/2012 E-mails w/ team re: motion to amend caption and

post-trial brief.

280.00 0.10 28.00

de Leeuw, M Partner 11/15/2012 Conference call; review issues; research; review post-

trial briefing.

650.00 3.00 1,950.00

Yellin, D Associate 11/15/2012 Conf. call w/ team. 280.00 0.60 168.00

11/16/2012 E-mails re: Boros invoice. 280.00 0.10 28.00

de Leeuw, M Partner 11/19/2012 Review post-trial memoranda; calls and emails re:

same; filing issues.

650.00 4.50 2,925.00

Yellin, D Associate 11/19/2012 E-mails re: post-trial briefs. 280.00 0.10 28.00

de Leeuw, M Partner 11/20/2012 Calls and emails re: post-trial briefs; review same. 650.00 2.00 1,300.00

Yellin, D Associate 11/20/2012 Review SOS Opp. to Motion to Amend Captions; e-

mails w/ team.

280.00 0.30 84.00

de Leeuw, M Partner 11/26/2012 calls and emails re: responsive post-trial filing;

research; call Borek; review transcripts.

650.00 2.80 1,820.00

Loffler, J Associate 11/27/2012 Following up with assistant and accounting re:

invoice for court reporter; reviewing e-mail from co-

counsel.

280.00 0.40 112.00

Yellin, D Associate 11/27/2012 Review D's motion to exclude; e-mails re: same. 280.00 0.20 56.00

Loffler, J Associate 11/28/2012 Conference call with co-counsel 280.00 0.90 252.00

Yellin, D Associate 11/28/2012 Call re: D's motion to exclude. 280.00 1.00 280.00

Page 11 of 12

Yellin, D Associate



Attorneys' Fees



Exhibit A

de Leeuw, M Partner 11/30/2012 Conference call. 650.00 0.80 520.00

Yellin, D Associate 11/30/2012 Review opp. to D's objections; e-mails re: same. 280.00 0.40 112.00

de Leeuw, M Partner 12/3/2012 Review order; calls and emails; review response re:

additional evidence.

650.00 2.20 1,430.00

de Leeuw, M Partner 12/4/2012 Review case file; attention to trial expenses;

attention to personal file for appeal purposes; calls

and emails.

650.00 2.40 1,560.00

de Leeuw, M Partner 1/23/2013 Read decision; multiple calls and emails re: same;

conference call; draft and revise press release and

firm announcement language.

650.00 5.00 3,250.00

Loffler, J Associate 1/23/2013 Reading decision; conference call with co-counsel;

reviewing press release on litigation victory

280.00 1.30 364.00

Yellin, D Associate 1/23/2013 Review FOF, COL, and Injunction; conf. call w/ team. 280.00 1.60 448.00

de Leeuw, M Partner 1/24/2013 Multiple calls and emails re: decision; review and

revise press release; draft internal memos;

conference call.

650.00 4.20 2,730.00

Yellin, D Associate 1/24/2013 Review e-mails re: press release. 280.00 0.20 56.00

de Leeuw, M Partner 1/25/2013 Review billing record; review time; calls re: same. 650.00 2.00 1,300.00

Yellin, D Associate 1/25/2013 Review press release. 280.00 0.10 28.00

Total 1,555.40 627,345.00$

Page 12 of 12



Costs & Expenses (by Category, by Date)


TELEPHONE/TELECONFERENCING/INTERNET

Date Name Amount Description

8/1/2012 Michael B. de Leeuw 4.37$ Teleconferencing Expense - 4:56pm MyConference Audio - Toll Free




8/21/2012 David Yellin 13.32$ Teleconferencing Expense - 3:39pm MyConference Audio - Toll Free

8/28/2012 Erica Sollie 11.61$ Teleconferencing Expense - 3:29pm MyConference Audio - Toll Free


9/3/2012 David Yellin 53.66$ Teleconferencing Expense - 10:57am MyConference Audio - Toll Free

9/4/2012 Michael B. de Leeuw 12.95$ Telephone Phone/ Internet Expense - Internet Access at Hotel stay in New

Orleans for court hearing.

9/5/2012 Michael B. de Leeuw 9.95$ Telephone Phone/ Internet Expense - In-flight internet service - Travel to New

Orleans, LA to attend Court hearing.

9/7/2012 Michael B. de Leeuw 2.91$ Teleconferencing Expense - 10:45am MyConference Audio - Toll Free

9/7/2012 Michael B. de Leeuw 4.31$ Teleconferencing Expense - 11:19am MyConference Audio - Toll Free





9/20/2012 Erica Sollie 69.76$ Teleconferencing Expense - 11:55am MyConference Audio - Toll Free


9/27/2012 Michael B. de Leeuw 12.95$ Telephone Phone/ Internet Expense - Internet Access at Hotel stay in New

Orleans for court hearing.






10/13/2012 David Yellin 14.95$ Telephone Phone/ Internet Expense - Telecommunications charge in hotel.

10/13/2012 Erica Sollie 14.95$ Telephone Phone/ Internet Expense - Travel to New Orleans for Trial.


10/14/2012 Michael B. de Leeuw 14.95$ Telephone Phone/ Internet Expense - Travel to New Orleans, LA for trial - Hotel

stay at the JW Marriott.

10/14/2012 Michael B. de Leeuw 9.95$ Telephone Phone/ Internet Expense - Travel to New Orleans, LA for trial - In-

flight Internet Access.


10/15/2012 Michael B. de Leeuw 14.95$ Telephone Phone/ Internet Expense - Travel to New Orleans, LA for trial - Hotel

stay at the JW Marriott - Internet.


Exhibit B

Page 1 of 10


Exhibit B

10/16/2012 Michael B. de Leeuw 14.95$ Telephone Phone/ Internet Expense - Telecommunications charge in hotel.


10/17/2012 Michael B. de Leeuw 14.95$ Telephone Phone/ Internet Expense - Telecommunications charge in hotel.



Subtotal $ 517.54

DUPLICATING


8/27/2012 David Yellin 7.44$ Duplicating / Standard Copies (From: 20120823 To: 20120823)

8/27/2012 Elizabeth Holmok 68.04$ Duplicating / Standard Copies (From: 20120820 To: 20120820)

9/23/2012 Erica Sollie 189.00$ Duplicating / Spiral (From: 20120921 To: 20120921)

9/23/2012 Elizabeth Holmok 81.00$ Duplicating / Spiral (From: 20120917 To: 20120917)

9/23/2012 Erica Sollie 216.90$ Duplicating / Tabs (From: 20120921 To: 20120921)

9/23/2012 Elizabeth Holmok 67.20$ Duplicating / Tabs (From: 20120917 To: 20120917)

9/23/2012 Erica Sollie 5,809.56$ Duplicating / Standard Copies (From: 20120917 To: 20120920)


9/23/2012 Michael B. de Leeuw 75.36$ Duplicating / Standard Copies (From: 20120904 To: 20120904)

9/23/2012 Erica Sollie 63.00$ Duplicating / Standard Copies (From: 20120911 To: 20120911)

9/23/2012 Israel David 2.40$ Duplicating / Standard Copies (From: 20120916 To: 20120916)


9/23/2012 Elizabeth Holmok 2,302.20$ Duplicating / Standard Copies (From: 20120911 To: 20120914)

9/30/2012 Filipina Balahadia 25.00$ Duplicating / CD Copy (From: 20120927 To: 20120927)

9/30/2012 Filipina Balahadia 324.24$ Duplicating / Standard Copies (From: 20120927 To: 20120927)


10/26/2012 Erica Sollie 0.36$ Duplicating / Standard Copies (From: 20121005 To: 20121005)

10/26/2012 Patrick Foote 9.12$ Duplicating / Standard Copies (From: 20121003 To: 20121003)


10/26/2012 Erica Sollie 42.00$ Duplicating / 3 inch Binder (From: 20121012 To: 20121012)


10/26/2012 Erica Sollie 60.00$ Duplicating / Regular Binders (From: 20121012 To: 20121012)

10/26/2012 Amanda Russo 12.48$ Duplicating / Standard Copies (From: 20121012 To: 20121012)

10/26/2012 Erica Sollie 1,455.24$ Duplicating / Standard Copies (From: 20121011 To: 20121012)


10/26/2012 Jessica Gonsowski 1.68$ Duplicating / Standard Copies (From: 20121012 To: 20121012)



10/26/2012 Erica Sollie 175.00$ Duplicating / CD Copy (From: 20121016 To: 20121016)

10/26/2012 David Yellin 200.00$ Duplicating / CD Copy (From: 20121016 To: 20121016)


10/26/2012 David Yellin 35.40$ Duplicating / Tabs (From: 20121016 To: 20121016)

10/26/2012 Filipina Balahadia 7.50$ Duplicating / Tabs (From: 20121016 To: 20121016)

10/26/2012 David Yellin 0.25$ Duplicating / spstock (From: 20121016 To: 20121016)

10/26/2012 Erica Sollie 63.00$ Duplicating / Regular Binders (From: 20121016 To: 20121016)

10/26/2012 David Yellin 144.00$ Duplicating / Regular Binders (From: 20121016 To: 20121016)

10/26/2012 Filipina Balahadia 15.00$ Duplicating / Regular Binders (From: 20121016 To: 20121016)

Page 2 of 10


Exhibit B


12/31/2012 Amanda Russo 0.36$ Duplicating / Standard Copies (From: 20121203 To: 20121203)

12/31/2012 Joyce Epstein 0.12$ Duplicating / Standard Copies (From: 20121128 To: 20121128)

Subtotal 13,831.44$

MEALS


8/30/2012 Michael B. de Leeuw 51.15$ Chargeable Meals - Dining Room - Internal Meeting - Video Conference

8/30/2012 Michael B. de Leeuw 65.32$ Chargeable Meals - Dining Room - Internal Meeting - Video Conference

9/4/2012 Michael B. de Leeuw 332.77$ Meals out of town - Attend Court hearing in New Orleans, LA - Dinner with

members of the NAACP-LDF.

9/5/2012 Michael B. de Leeuw 184.75$ Meals out of town - Lunch for team while attending hearing in New Orleans, LA.

9/5/2012 Michael B. de Leeuw 48.36$ Meals out of town Meals - In-Room Dining - Hotel stay while in New Orleans, LA

for court hearing.

9/12/2012 Erica Sollie 30.10$ Meals out of town - Breakfast before deposition.

9/13/2012 Erica Sollie 44.71$ Meals out of town - Lunch on deposition trip; Luke.

9/20/2012 New York Office 103.43$ Chargeable Meals - Dining Room - Meet and Confer

9/20/2012 New York Office 244.96$ Chargeable Meals - Dining Room - Meet and Confer

9/27/2012 Michael B. de Leeuw 295.32$ Meals out of town - Dinner with team with various NAACP reps while attending

hearing in New Orleans, LA.

10/11/2012 New York Office 108.87$ Chargeable Meals - Dining Room - Sollie, Erica

10/13/2012 Erica Sollie 15.80$ Meals out of town - Travel to New Orleans for Trial

10/13/2012 Erica Sollie 72.80$ Meals out of town - Trip to New Orleans for Trial.

10/13/2012 Jesse Loffler 87.80$ Meals out of town - Dinner re trial prep & trial.

10/13/2012 Jesse Loffler 31.72$ Meals - Local - Meal at airport re trial prep & trial.

10/13/2012 David Yellin 87.80$ Meals out of town - Dinner during trial in New Orleans.

10/14/2012 David Yellin 91.64$ Meals out of town - Dinner on trip to New Orleans for case.

10/14/2012 Jesse Loffler 58.45$ Meals out of town - Breakfast re trial prep & trial

10/15/2012 David Yellin 13.82$ Meals out of town - Lunch during trial in New Orleans

10/15/2012 Erica Sollie 14.00$ Meals out of town - Trip to New Orleans for Trial

10/15/2012 Jesse Loffler 31.47$ Meals out of town - Breakfast re trial prep & trial

10/15/2012 Michael B. de Leeuw 19.12$ Meals out of town - Travel to New Orleans, LA for trial - Hotel stay at the JW

Marriott - Room Service Breakfast.

10/15/2012 Michael B. de Leeuw 23.16$ Meals - Local - Travel to New Orleans, LA for trial - Dinner; LaGuardia Airport

Café.

10/15/2012 Michael B. de Leeuw 866.55$ Meals out of town - Travel to New Orleans, LA for trial - Dinner with Team


10/16/2012 Erica Sollie 11.92$ Meals out of town - Trip to New Orleans for Trial.

10/16/2012 Jesse Loffler 13.34$ Meals out of town - Lunch re trial prep & trial.

10/16/2012 Michael B. de Leeuw 15.83$ Meals out of town - Room Service Breakfast; JW Marriott

10/16/2012 Michael B. de Leeuw 480.00$ Meals out of town - Dinner with team.

10/17/2012 Erica Sollie 11.97$ Meals out of town - Lunch during trial in New Orleans


10/17/2012 Michael B. de Leeuw 5.61$ Meals out of town - Room Service Breakfast; JW Marriott

10/17/2012 Michael B. de Leeuw 350.00$ Meals out of town - Dinner with counsel team

10/17/2012 Michael B. de Leeuw 80.10$ Meals out of town - Drinks with counsel team

10/18/2012 Michael B. de Leeuw 413.21$ Meals out of town - Breakfast with counsel team

10/18/2012 Michael B. de Leeuw 500.00$ Meals out of town - Dinner with counsel team

Page 3 of 10


Exhibit B

10/18/2012 Michael B. de Leeuw 5.61$ Meals out of town - Room Service Breakfast - JW Marriott

10/19/2012 David Yellin 15.64$ Meals out of town - Breakfast on trip to New Orleans for trial.

10/19/2012 Erica Sollie 17.02$ Meals out of town - Breakfast on trip to New Orleans for trial.

10/19/2012 Jesse Loffler 19.48$ Meals out of town - Breakfast on trip to New Orleans for trial.

Subtotal 4,901.06$

LOCAL TRANSPORTATION (TAXIS)


8/28/2012 Erica Sollie 32.19$ Local Transportation (Taxis) Taxis/Subway - 08/14/12 - 1-NEW YORK P-

MANHATTAN 25-W 13 ST-MANHATTAN 11:35PM Sollie, Erica

9/4/2012 David Yellin 34.30$ Local Transportation (Taxis) Taxis/Subway - 08/20/12 10:15PM Yellin, David 1-

NEW YORK P-MANHATTAN 240-EAST 35TH -MANHATTAN

9/4/2012 Jesse Loffler 106.90$ Local Transportation (Taxis) Taxis/Subway - 08/15/12 11:22PM Loffler, Jesse 1-

NEW YORK P-MANHATTAN -WAYNE

9/4/2012 Michael B. de Leeuw 99.66$ Local Transportation (Taxis) Taxis/Subway - 08/16/12 02:00AM de Leeuw,

Michael 1-NEW YORK P-MANHATTAN - GLEN RIDGE



9/4/2012 Israel David 39.00$ Local Transportation - Parking at LaGuardia Airport for trip to New Orleans

9/4/2012 Israel David 25.00$ Local Transportation - Parking at building garage; In-Town



9/12/2012 Erica Sollie 68.76$ Local Transportation - Taxi from apartment to JFK.

9/12/2012 Erica Sollie 40.56$ Local Transportation - Taxi from JFK to apartment.

9/13/2012 Jesse Loffler 23.00$ Local Transportation - worked late - dispatch car never showed up.

9/20/2012 David Yellin 20.00$ Local Transportation - Work after normal business hours.

9/26/2012 Michael Deguzman 66.16$ Local Transportation (Taxis) Taxis/Subway - 08/28/12 09:30PM 1-NEW YORK P-

MANHATTAN - JERSEY CITY





10/3/2012 Michael B. de Leeuw 90.09$ Local Transportation (Taxis) Taxis/Subway - 09/04/12 11:02AM de Leeuw,

Michael 1-NEW YORK P-NEW YORK - FLUSHING


NEW YORK P-MANHATTAN 240-E 35 ST-MANHATTAN

10/3/2012 Erica Sollie 32.19$ Local Transportation (Taxis) Taxis/Subway - 08/22/12 11:51PM Sollie, Erica 1-

NEW YORK P-MANHATTAN 25-W 13 ST-MANHATTAN


NEW YORK P-MANHATTAN 240-E 35 ST-MANHATTAN

10/10/2012 Jesse Loffler 66.16$ Local Transportation (Taxis) Taxis/Subway - 09/20/12 11:48PM Loffler, Jesse 1-

NEW YORK P-MANHATTAN - JERSEY CITY



10/10/2012 Michael B. de Leeuw 23.40$ Local Transportation (Taxis) Taxis/Subway - Transportation for work on NAACP

matter.

10/13/2012 Erica Sollie 53.16$ Local Transportation (Taxis) Taxis/Subway - Taxi Airport to Apt.

10/16/2012 Michael B. de Leeuw 166.96$ Local Transportation (Taxis) Taxis/Subway - 09/05/12 11:02PM de Leeuw,

Michael FLUSHING - GLEN RIDGE

Page 4 of 10


Exhibit B

10/16/2012 Michael B. de Leeuw 93.80$ Local Transportation (Taxis) Taxis/Subway - 10/04/12 11:11PM de Leeuw,

Michael 1-NEW YORK P-MANHATTAN - GLEN RIDGE

10/13/2012 David Yellin 42.25$ Local Transportation (Taxis) Taxis - Cab to Airport for a case located in New

Orleans, LA (With Erica Sollie).

10/13/2012 Jesse Loffler 74.00$ Local Transportation - Taxi to airport re trial prep & trial.

10/18/2012 Israel David 66.00$ Local Transportation (Taxis) Taxis/Subway - Garage parking at LaGuardia Airport

re trip to Louisiana.

10/19/2012 Jesse Loffler 121.25$ Local Transportation (Taxis) Taxis/Subway - cab from airport re trial

10/23/2012 Jesse Loffler 65.65$ Local Transportation (Taxis) Taxis/Subway -10/03/12 09:25PM Loffler, Jes 1-

NEW YORK P-MANHATTAN - -JERSEY CITY

10/23/2012 David Yellin 34.30$ Local Transportation (Taxis) Taxis/Subway - 10/02/12 11:05PM Yellin, Dav 1-


10/23/2012 Michael B. de Leeuw 158.72$ Local Transportation (Taxis) Taxis/Subway - 09/27/12 05:37AM DE LEEUW, MI,

- -GLEN RIDGE - -FLUSHING

10/30/2012 Erica Sollie 32.19$ Local Transportation (Taxis) Taxis/Subway - 10/09/12 12:20AM Sollie, Eri 1-

NEW YORK P-MANHATTAN 25-WEST 13TH -MANHATTAN

10/30/2012 Erica Sollie 32.19$ Local Transportation (Taxis) Taxis/Subway - 10/11/12 11:56PM Sollie, Eri 1-

NEW YORK P-MANHATTAN 25-WEST 13TH -MANHATTAN

10/30/2012 Jesse Loffler 65.65$ Local Transportation (Taxis) Taxis/Subway - 10/09/12 12:21AM Loffler, Jes 1-

NEW YORK P-MANHATTAN - -JERSEY CITY

10/30/2012 David Yellin 34.30$ Local Transportation (Taxis) Taxis/Subway - 10/09/12 10:30PM Yellin, Dav 1-


10/30/2012 David Yellin 34.30$ Local Transportation (Taxis) Taxis/Subway - 10/12/12 12:34AM Yellin, Dav 1-


12/18/2012 Michael B. de Leeuw 187.79$ Local Transportation (Taxis) Taxis/Subway - 10/19/12 11:44AM DE LEEUW, MI,

- -FLUSHING - -GLEN RIDGE

Subtotal 2,269.98$

OUT OF TOWN LOCAL TRANSPORTATION


9/4/2012 Israel David 42.00$ Out of Town Local Transportation - Taxi service from airport to hotel

9/5/2012 Israel David 10.00$ Out of Town Local Transportation - Taxi service from hotel to court.

9/5/2012 Israel David 43.00$ Out of Town Local Transportation - Taxi service from court to airport.

9/12/2012 Erica Sollie 38.00$ Out of Town Local Transportation - Taxi Airport to Hotel.

9/13/2012 Erica Sollie 40.00$ Out of Town Local Transportation - Taxi Hotel to Airport.

9/27/2012 Michael B. de Leeuw 14.00$ Out of Town Local Transportation - Ground transportation while in New Orleans,

LA for court hearing.





10/13/2012 Erica Sollie 15.25$ Out of Town Local Transportation - Taxi Hotel to Airport.

10/13/2012 Erica Sollie 8.00$ Out of Town Local Transportation - Trip to New Orleans for Trial.

10/13/2012 Jesse Loffler 10.50$ Out of Town Local Transportation - Taxi re trial prep & trial.

10/13/2012 David Yellin 49.00$ Out of Town Local Transportation - Cab from airport in New Orleans, LA to hotel

(With J. Loffler and E. Sollie).

10/13/2012 Erica Sollie 37.03$ Out of Town Local Transportation - Trip to New Orleans for Trial; 10/13/12.

10/16/2012 Jesse Loffler 17.00$ Out of Town Local Transportation; cab re trial prep & trial; 10/16/12

Page 5 of 10


Exhibit B

10/17/2012 Israel David 7.50$ Out of Town Local Transportation (Taxis) Taxis/Subway - Taxi to court re

Louisiana hearing

10/17/2012 Israel David 8.25$ Out of Town Local Transportation (Taxis) Taxis/Subway - Taxi from court to

office re Louisiana hearing.

10/17/2012 Israel David 42.00$ Out of Town Local Transportation (Taxis/Subway) - Taxi from airport to court re

Louisiana

10/18/2012 Israel David 39.60$ Out of Town Local Transportation - Taxi to airport for return trip to NY

10/19/2012 Jesse Loffler 47.00$ Out of Town Local Transportation - taxi to airport re trial prep & trial

Subtotal 544.13$

OUT OF TOWN LODGING


9/5/2012 Michael B. de Leeuw 226.87$ Out of Town Lodging Accommodation - Hotel stay while in New Orleans, LA for

court hearing. 09/04/2012 - 09/05/2012

9/5/2012 Israel David 283.06$ Out of Town Lodging Accommodation - Hotel stay re: New Orleans re Louisiana

State Conference 09/04/2012 - 09/05/2012

9/12/2012 Erica Sollie 180.67$ Out of Town Lodging Accommodation - Hotel in New Orleans; 09/12/2012 -

9/13/2012

9/28/2012 Michael B. de Leeuw 283.37$ Out of Town Lodging Accommodation - Hotel stay while in New Orleans, LA for

court hearing. 09/27/2012 - 09/28/2012

10/13/2012 Erica Sollie 2,412.12$ Out of Town Lodging Accommodation - Travel to New Orleans for Trial

10/13/2012 - 10/19/2012.

10/17/2012 David Yellin 1,995.15$ Out of Town Lodging Accommodation - Lodging in New Orleans during trial

(10/13-10/18/2012)

10/18/2012 Israel David 509.37$ Out of Town Lodging Accommodation - Out of Town - Hotel stay re trip to New

Orleans, Louisiana (10/17/2012-10/18/2012)

10/19/2012 Jesse Loffler 2,563.16$ Out of Town Lodging Accommodation - JWMarriott Hotel in New Orleans for

trial (10/13-10/19/2012)

10/19/2012 Michael B. de Leeuw 2,010.10$ Out of Town Lodging Accommodation - Travel to New Orleans, LA for trial - Hotel

stay at the JW Marriott (10/14-10/19/2012)

10/20/2012 David Yellin 416.97$ Out of Town Lodging Accommodation - Hotel at JW Marriott (10/19/2012)

Subtotal 10,880.84$

AIRFARES


8/31/2012 Michael B. de Leeuw 754.92$ Airfares Airfares/ Trains Expense - Ticket #: 7119481705, Origin: LGA, Travel

date: 9/4/2012, Mode: DELTA AIRLINES Destination: MSY - LGA

8/31/2012 Michael B. de Leeuw 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7119481705, Origin: LGA, LGA,

Travel date: 9/4/2012, Mode: AMERICAN EXPRESS Destination: MSY - LGA

9/4/2012 Israel David 547.80$ Airfares Airfares/ Trains Expense - Flight to New Orleans re Louisiana State

Conference Delta # 2332

9/5/2012 Michael B. de Leeuw 29.00$ Airfares Airfares/ Trains Expense - Ticket Upgrade Fee - Attend Court hearing in

New Orleans, LA.

9/5/2012 Israel David 547.80$ Airfares/ Trains Expense - Flight to New Orleans re Louisiana State Conference

Delta #1470; 09/04/2012 - 09/04/2012

Page 6 of 10


Exhibit B

9/6/2012 Michael B. de Leeuw 29.00$ Airfares Airfares/ Trains Expense - Ticket Upgrade Fee - Attend Court hearing in

New Orleans, LA.

9/10/2012 Erica Sollie 681.31$ Airfares Airfares/ Trains Expense - Ticket #: 7131016513, Origin: JFK,Destination:

MSY - LGA, Travel date: 9/12/2012, Mode: DELTA AIRLINES

9/10/2012 Erica Sollie 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016513, Origin: JFK, Destination:

MSY - LGA, Travel date: 9/12/2012 ,Mode: AMERICAN EXPRESS

9/12/2012 Erica Sollie 39.00$ Airfares Airfares/ Trains Expense - Economy Comfort Upgrade.

9/12/2012 Erica Sollie 39.00$ Airfares Airfares/ Trains Expense - Economy Comfort Upgrade.

9/25/2012 Michael B. de Leeuw 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016603, Origin: EWR,

Destination: MSY Travel date: 9/27/2012, Mode: AMERICAN EXPRESS

9/25/2012 Michael B. de Leeuw 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016604, Origin: MSY,

Destination: EWR Travel date: 9/27/2012, Mode: AMERICAN EXPRESS

9/25/2012 Michael B. de Leeuw 410.80$ Airfares Airfares/ Trains Expense - Ticket #: 2469973570, Origin: STL, Destination:

EWR Travel date:, Mode: SOUTHWEST AIRLINE

10/1/2012 Michael B. de Leeuw 593.32$ Airfares Airfares/ Trains Expense - Ticket #: 7131016632, Origin: LGA,

Destination: MSY - LGA Travel date: 10/14/2012, Mode: DELTA AIRLINES

10/1/2012 Michael B. de Leeuw 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016632,Origin: LGA, Destination:

MSY - LGA Travel date: 10/14/2012, Mode: AMERICAN EXPRESS

10/2/2012 Jesse Loffler 1,288.81$ Airfares Airfares/ Trains Expense - Ticket #: 7131016635, Origin: LGA,


10/2/2012 Erica Sollie 1,288.81$ Airfares Airfares/ Trains Expense - Ticket #: 7131016637, Origin: LGA,


10/2/2012 David Yellin 1,288.81$ Airfares Airfares/ Trains Expense - Ticket #: 7131016636, Origin: LGA,


10/2/2012 Israel David 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016641, Origin: LGA,

Destination: MSY - LGA Travel date: 10/14/2012, Mode: AMERICAN EXPRESS

10/2/2012 Jesse Loffler 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016635, Origin: LGA,

Destination: MSY - LGA Traveldate:10/13/2012,Mode:AMERICAN EXPRESS

10/2/2012 Erica Sollie 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016637, Origin: LGA,

Destination: MSY - LGA Travel date: 10/13/2012, Mode: AMERICAN EXPRESS

10/2/2012 David Yellin 10.00$ Airfares Airfares/ Trains Expense - Ticket #: 7131016636,Origin: LGA, Destination:

MSY - LGA Travel date: 10/13/2012, Mode: AMERICAN EXPRESS

10/13/2012 David Yellin 25.00$ Airfares Airfares/ Trains Expense - Checked baggage fee on Delta airlines Delta

1715; 10/14/2012 - 10/20/2012

10/13/2012 Jesse Loffler 25.00$ Airfares Airfares/ Trains Expense - Flight to New Orleans re trial.

10/13/2012 Erica Sollie 25.00$ Airfares Airfares/ Trains Expense - Travel to New Orleans for Trial.

10/13/2012 Erica Sollie 25.00$ Airfares Airfares/ Trains Expense - Travel to New Orleans for Trial.

10/15/2012 Michael B. de Leeuw 25.00$ Airfares Airfares/ Trains Expense - Travel to New Orleans for trial - Tkt Fee.

10/17/2012 Israel David 516.80$ Airfares Airfares/ Trains Expense - Airfare to New Orleans LA; Delta #1533

10/18/2012 Israel David 1,234.80$ Airfares Airfares/ Trains Expense - Return airfare from Louisiana, New Orleans -

Delta 1403

10/19/2012 Jesse Loffler 25.00$ Airfares Airfares/ Trains Expense - baggage check fee - flight to New Orleans re

trial prep & trial

10/19/2012 Michael B. de Leeuw 25.00$ Airfares Airfares/ Trains Expense - baggage fee - Travel to New Orleans

10/20/2012 David Yellin 25.00$ Airfares Airfares/ Trains Expense - baggage fee - Travel to New Orleans

Subtotal 9,579.98$

DATA RESEARCH - WESTLAW/LEXIS


Page 7 of 10


Exhibit B

8/8/2012 Michael B. de Leeuw 143.96$ Data Research - Westlaw

8/19/2012 Jesse Loffler 103.83$ Data Research - Westlaw

8/21/2012 Jesse Loffler 75.04$ Data Research - Westlaw

8/31/2012 David Yellin 85.50$ Data Research - Westlaw

8/31/2012 Jesse Loffler 16.31$ Data Research - Lexis

9/1/2012 Erica Sollie 16.31$ Data Research - Lexis


9/27/2012 Erica Sollie 32.63$ Data Research - Westlaw



Subtotal 1,293.69$

DATA RESEARCH - MANAGING ATTORNEY'S OFFICE


8/10/2012 Managing Attorney 65.32$ Data Research - MA - Colby Attorneys Servi Co. Inc.

9/18/2012 Managing Attorney 26.67$ Data Research - MA - Court Alert Ferrand et al vs. Tom Schedler, et. al.

9/30/2012 Managing Attorney 49.60$ Data Research - MA - Pacer Service Center - 7/1/12 - 9/30/12

9/30/2012 Managing Attorney 73.70$ Data Research - MA - Pacer Service Center - 7/1/12 - 9/30/12

10/17/2012 Managing Attorney 16.20$ Data Research - MA - Court Alert; Ferrand v. Schedler

10/17/2012 Managing Attorney 5.99$ Data Research - MA - Court Alert; Ferrand v. Schedler

11/29/2012 Managing Attorney 14.97$ Data Research - MA - Court Alert - Ferrand v. Schedler

12/18/2012 Managing Attorney 11.98$ Data Research - MA - Court Alert - Ferrand v. Schedler

12/31/2012 Managing Attorney 49.60$ Data Research - MA - Pacer Service

Subtotal 314.03$

COURIER SERVICE/POSTAGE


8/27/2012 New York Office 0.45$ Postage

9/14/2012 FEDEX NY 91.80$ Courier Service - Tracking#: 801360188139 DOUG LAS CADE 628 N 4TH STREET

BATON ROUGE LA

9/14/2012 FEDEX NY 95.14$ Courier Service - Tracking#: 801360188117 CELIA CANGELOSI 918 GOVERNMENT

STREET BATON ROUGE LA

9/14/2012 FEDEX NY 91.80$ Courier Service - Tracking#: 801360188128 CELIA ALEXANDER/EBONI

TOWNSEND 627 N. 4TH STREET BATON ROUGE LA

9/18/2012 Erica Sollie 148.80$ Lawyers & Consultants - Reimbursement of Ronald L. Wilson for fedex charges.

9/21/2012 FEDEX NY 39.08$ Courier Service - Tracking#: 899685271620 SARAH BRANNON 1350 EYE STREET

NW WASHINGTON DC

9/21/2012 FEDEX NY 28.14$ Courier Service - Tracking#: 899685271630 DALE HO 9 HUDSON ST. NEW YORK

CITY NY


10/4/2012 FEDEX NY 17.21$ Courier Service - Tracking#: 801050803600 CELIA R. CANGELOSI 918

GOVERMENT STREET BATON ROUGE LA

10/4/2012 FEDEX NY 12.83$ Courier Service - Tracking#: 801050803585 CELIA MARIE WILLIAMS- ALEXANDE

627 NORTH 4TH STREET BATON ROUGE LA

Page 8 of 10


Exhibit B

10/4/2012 FEDEX NY 12.83$ Courier Service - Tracking#: 801050803655 DOUGLAS L. CADE 628 N. 4TH

STREET BATON ROUGE LA

10/4/2012 FEDEX NY 8.05$ Courier Service - Tracking#: 801050803552 NAACP LEGAL DEFENSE & EDUCATIO

99 HUDSON STREET NEW YORK CITY NY

10/4/2012 FEDEX NY 12.83$ Courier Service - Tracking#: 801050803541 HON. JANE TRICHE MILAZZO 500

POYDRAS STREET NEW ORLEANS LA

10/8/2012 FEDEX NY 12.83$ Courier Service - Tracking#: 801048105935 JOZE F BOROS 701 POYDRAS STREET

NEW ORLEANS LA

10/12/2012 FEDEX NY 53.82$ Courier Service - Tracking#: 801048105843 ROLAND L. WILSON 701 POYDRAS ST

NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA


NEW ORLEANS LA

10/18/2012 FEDEX NY 32.02$ Courier Service - Invoice#: 206470350 Tracking#: 801131174932 ERICA SOLLIE

ONE NEW YORK PLZ NEW YORK CITY NY

10/18/2012 FEDEX NY 33.64$ Courier Service - Invoice#: 206470350 Tracking#: 801131174884 ERICA SOLLIE 1

NEW YORK PLZ FL 22 NEW YORK CITY NY




NEW YORK PLZ NEW YORK CITY NY



10/18/2012 FEDEX NY 32.02$ Courier Service - Invoice#: 206470350 Tracking#: 801131174900 ERICA SOLHE 1

NEW YORK PLZ FL 22 NEW YORK CITY NY


NEW YORK PLZ NEW YORK CITY NY


Page 9 of 10


Exhibit B

Subtotal 1,674.37$

FILING FEES


8/15/2012 Jesse Loffler 200.00$ Filing Fees Expense - Ronald L. Wilson

9/11/2012 Jesse Loffler 100.00$ Lawyers & Consultants - Reimbursement of filing fees to Ronald L. Wilson.

Subtotal 300.00$

COURT REPORTING


10/18/2012 Jesse Loffler 2,381.40$ Court Reporting - Susan A. Zielie, RMR, FCRR - 10/15-17 trial transcripts

Subtotal 2,381.40$

MISCELLANEOUS


8/13/2012 Frank Herbert 5.00$ Dues Subscriptions and Dues Expense - Obtain a certificate of good standing on

behalf of Israel David.

8/13/2012 Frank Herbert 4.50$ Out of Town Local Transportation - Travel to the Appellate Division, 2d

Department to obtain a certificate of good standing on behalf of I. David.

10/9/2012 Jesse Loffler 43.50$ Specialty Supply Purchases

10/12/2012 SEC.SERV. 60.00$ Secretarial Overtime - Russo, Amanda

10/30/2012 Jesse Loffler 1,237.50$ Miscellaneous - Jozef Boros- Litigation Support for Trial Technology

Subtotal 1,350.50$

TOTAL COSTS & EXPENSES: 49,838.96$

Page 10 of 10


UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF LOUISIANA

LUTHER SCOTT, JR. and theLOUISIANA STATE CONFERENCE OFTHE NAACP, for themselves and all otherpersons similarly situated,

Plaintiffs, Civil Action No. 2:H-cv-00926-JTM-JCW

V.

TOM SCHEDLER in his official capacityas the Louisiana Secretary of State, SUZYSONNIER, in her official capacity asSecretary of the Louisiana Department ofChildren & Family Services, and BRUCED. GREENSTEIN, in his official capacityas Secretary of the Louisiana Department ofHealth & Hospitals,

Defendants.

DECLARATION OF CYRUS MEHRI

I, Cyrus Mehri, hereby declare the following:

1. I have been asked by attorneys for Project Vote to provide information,

based on my personal knowledge and belief, and my opinions regarding the

reasonableness of the hourly rates that they seek to have recognized in the petition for

attorneys’ fees in this case.

2. I have served as co-lead class counsel in some of the largest and most

significant race and gender cases in U.S. history, achieving innovative programmatic

relief in settlements. Roberts v. Texaco Inc., ($176 million; S.D.N.Y. 1997); Ingram v.

The Coca-Cola Company ($192 million; N.D. Ga. 2001); Robinson v. Ford Motor

Company ($10 million and 279 apprentice positions; S.D. Ohio 2005); August-


Johnson v. Morgan Stanley ($47 million; D.D.C. 2007); Amachoev v. Smith Barney ($34

million; N.D. Cal. 2008); Norfiet v. John Hancock Life Insurance Co. ($24 million; D.

Conn. 2009), and Carter v. Wells Fargo Advisors, LLC ($32 million; D.D.C. 2011).

3. I also serve on the judicial nominations committees for the American

Constitution Society and the National Employment Lawyers Association. In addition, I

serve on the Cornell Law School Advisory counsel.

4. My firm, Mehri & Skalet (M&S), of which I am a founding partner, is a

leading class action and complex litigation firm. Our practice includes representing

employees, consumers, investors, small businesses and others in high-impact cases.

Lawyers at M&S have achieved landmark employment and civil rights victories. The

firm also has achieved substantial results for consumers from companies such as Hewlett

Packard, Ford, Kellogg, and Dell Computers. With this practice, our firm routinely

makes fee applications in federal court. To best of my knowledge, our fee petitions

have been approved by the Courts without criticism.

5. I am familiar with Project Vote and its well-established history of

empowering, educating, and mobilizing underrepresented voters. I hold the attorneys at

Project Vote in high esteem for their legal skills, analytic ability, and professionalism. I

mooted their attorneys in an appellate case and witnessed their skill first hand. I have

also read a number of the legal opinions stemming from their very important work. All of

the attorneys I have encountered at Project Vote bring an extraordinary degree of

competence, knowledge, skill, and expertise to their voting rights law practice.

6. I am generally familiar with hourly rates charged by attorneys nationwide

in finns that litigate civil rights class actions and similar matters of significant complexity


at the trial level. I am aware of those rates because they are published in court opinions,

the legal press, and surveys. As my firm is based in Washington, DC, I am particularly

familiar with the prevailing rates charged by law firms in that market.

7. I understand that the following table reflects the current hourly rates being

sought by Project Vote attorneys who participated in the above-captioned matter, Scott v.

Schedler:

Law School Year Rate per hourProject Directors $600Assistant Counsel 2005 $475Assistant Counsel 2011 $280Paralegals $175Legal Assistants / Law Clerks $125

8. In my opinion, these hourly rates are generally below the current market rates for

litigation attorneys in Washington, D.C. of comparable experience, ability, skills, and

reputation in civil rights class actions and other similarly complex litigation in federal

trial courts.



Executed on: February 25, 2013


1





NAACP,

Plaintiffs,

v.








Health & Hospitals,

Defendants.


JCW

Section ―H‖

LR 54.2 DECLARATION OF

SARAH BRANNON

SARAH BRANNON, declares pursuant to 28 U.S.C. § 1746 as follows:

1. I am an attorney admitted pro hac vice to practice before this Court, and I

am the Director of the Public Agency Voter Registration Program at Project Vote. Project Vote

served as counsel for Plaintiffs, Luther Scott, Jr. and Louisiana State Conference of the NAACP,

(―Plaintiffs‖). I submit this declaration in support of Plaintiffs’ motion to set attorneys’ fees and

costs.

2. This declaration is based on my personal knowledge, my consultation with

colleagues at Legal Defense and Educational Fund (―LDF‖); Project Vote, Fried, Frank, Harris,

Shriver & Jacobson LLP (―Fried Frank‖), and attorney Ronald Wilson, and a review of

documents related to this action. I have personal knowledge of the facts set forth herein.


2

3. This litigation was filed on April 19, 2011. I am fully familiar with all

aspects of the case.

4. Plaintiffs filed this civil rights action against Defendants on April 19,

2011, against a backdrop of many years of non-compliance with the National Voter Registration

Act, 42 U.S.C. §1973gg-5 (―NVRA‖). Plaintiffs sought declaratory and injunctive relief,

including a permanent injunction requiring Defendants, their agents and successors in office, and

all persons working in concert with them, to implement practices and procedures in compliance

with Section 7 of the NVRA.

5. Project Vote has been involved in all aspects of the litigation. This case is

a large and complex case, and required considerable resources. Project Vote, LDF, Ronald

Wilson and for the purpose of trial Fried Frank, partnered together in order to prosecute the case

most effectively. All served as co-counsel for Plaintiffs.

6. It is worth noting that Plaintiffs tried to settle this case on numerous

occasions, including before suit was even filed. Before filing, Plaintiffs attempted to resolve the

issues without litigation by serving Defendants with a notice letter in January 2011, advising

Defendants of their non-compliance with federal law, and requesting a meeting with Defendants.

These efforts were unsuccessful as Defendants failed to provide any meaningful response to

Plaintiffs’ request for a meeting at that time. Plaintiffs then attempted to settle this case on

numerous other occasions as litigation progressed. All of the Plaintiffs’ attempts to reach a

settlement were rebuffed and unsuccessful, including the Court ordered-mediation in May 2012

with Magistrate Judge Wilkinson. Plaintiffs were ready to engage in meaningful negotiations,

but like all previous attempts, settlement discussions were unsuccessful. On the morning the

mediation was scheduled, Defendants filed a motion seeking an interlocutory appeal of this


3

Court’s order on Partial Summary Judgment and came to the settlement conference with no

interest in even discussing settlement.

7. Plaintiffs are entitled to costs and fees under this Court’s Order, dated

January 22, 2013. Doc. 436. On January 22, 2013, this Court rendered its Findings of Fact and

Conclusions of Law finding that all three defendants had violated the voter registration

obligations under Section 7 of the NVRA in numerous different respects. See Doc. 436 at 20

(DHH); 25-26 (DCFS); and 28 (SOS). This Court entered judgment for Plaintiffs and awarded

Plaintiffs reasonable attorneys fees, litigation expenses, and costs.

8. Project Vote is a non-partisan, non-profit organization based in

Washington D.C. Project Vote has been counsel in numerous other cases similar to the current

case, seeking compliance of Section 7 of the NVRA. These cases include Valdez v. Squier, 676

F.3d 935 (10th Cir. 2012); Black Political Empowerment Project v. Aichele, Civ. No. 12-cv-

03808 (E.D.Pa. 2012); GA NAACP v. Kemp, 11-cv-1849 (N.D.Ga. 2012); NAACP v. Gargano,

09-cv-849 (S.D.Ind. 2011); Harkless v. Brunner, No. 06-CV-2294 (N.D.Ohio 2009); and Ass’n

of Comm. Orgs. For Reform Now v. Levy, 08-4084-CV (W.D.Mo. 2009). Additionally, Project

Vote has been counsel regularly in other voting rights cases, such as Project Vote v. Long, 682

F.3d 331 (4th Cir. 2012) (challenging public access to voter registration files); Voting for

America v. Andrade, -- F. Supp. 2d --, 2012 WL 3155566 (S.D. Tex. 2012) (currently on appeal

in the Fifth Circuit) (challenging restrictions on voter registration drives); and Arcia v. Detzner, -

- F. Supp. 2d --, 2012 WL 6212564 (S.D. Fla. 2012) (currently on appeal in the Eleventh Circuit)

(challenging pre-Election Day purges of suspected non-citizens from the voting rolls).

9. Project Vote provides representation to clients, such as the Plaintiffs in

this case, who are unable to pay for the legal services required to litigate their claims and


4

vindicate their federally-protected rights. We, therefore, do not generally bill clients for our

legal services, and we obtain no compensation unless we are successful. Based upon information

regarding the prevailing rates charged by attorneys in Washington D.C. of similar experience,

skills, and reputation in civil rights cases and other similarly complex litigation in federal trial

courts, the hourly rates for Project Vote staff are reflected in the chart below. I believe the

following rates are reasonable:

Law School Year Rate per hour

Project Director – Nicole Kovite Zeitler and

Sarah Brannon

2006, and 1999

respectively

$600

Assistant Counsel – Niyati Shah 2005 $475

Assistant Counsel – Michelle Rupp 2011 $280

Paralegals/Policy Analyst – Kelly Gerlach $175

10. I am admitted to practice law in Maryland, having been first admitted in

1999. I graduated from the University of Maryland School of Law in 1999. I have more than 10

years of litigation experience, including handling numerous large complex litigations addressing

civil rights, civil liberties and election law claims. I was previously employed as a staff attorney

at the Fair Elections Legal Network, where my work included serving as counsel representing

plaintiffs in Common Cause of Colorado v. Bernie Buescher, Civil No. 08-CV-2321 JKL, filed

in United States District Court for the District of Colorado. In that case, Plaintiffs alleged

Colorado’s voter purging practices violated the National Voter Registration Act—the litigation

was resolved after successful settlement of 3 of the 4 claims. My most recent complex litigation

experience before coming to Project Vote involved serving as one of the counsel for more than

300 plaintiffs in a toxic tort case against Exxon Mobile Corporation. I was responsible for

overseeing all the evidence related to plaintiffs’ injuries, including plaintiffs’ depositions. That

case ultimately resulted in a 1.5 billion dollar jury verdict awarded in 2011.


5

11. I am currently the Director of the Public Agency Voter Registration

Program at Project Vote and have been in this position since March 2012. In this position, my

work at Project Vote specifically includes supervising efforts around the country to ensure

effective implementation of Section 7 of the NVRA. My NVRA work includes litigation against

states for failure to comply with the NVRA, advice and technical assistance regarding

compliance with the NVRA to cooperative states, and research and writing on NVRA

implementation. I have performed legal work related to a number of other NVRA cases similar

to the case before this Court.

12. Attached as Exhibit A is a true and correct statement of the hours and

services I have rendered in this case. I prepared this statement based upon a review of my

contemporaneous time records. It is my practice to keep regular records of the time I spend on

litigation matters in a time tracking system upon the completion of the task that I have rendered

for which I intend to bill.

13. I believe the hours I am claiming are reasonable.

14. In my capacity as Director of the Public Agency Voter Registration

Program, I am familiar with this case, including the pleadings and other papers filed in the case,

as well as depositions, hearings and the trial conducted therein. In my capacity as Director, all

members of Project Vote's legal staff, including attorneys, interns, policy analyst and paralegal,

working on this case are under my supervision and report their activities to me regularly. Project

Vote requires staff to keep contemporaneous time records in all legal cases. I have reviewed the

legal time records filed as Exhibits B-E, which are time records for Nicole Kovite Zeitler, Niayti

Shah, Michelle Rupp and Kelly Gerlach. The records attached are a true and accurate reflection

of Project Vote's work on this case.


6

15. Nicole Kovite Zeitler was the Director of Project Vote’s Public Agency

Voter Registration Program from October 2008 through February 2012. In that capacity, her

work at Project Vote specifically involved efforts around the country to ensure effective

implementation of Section 7 of the NVRA. Her NVRA work included litigation against states

for failure to comply with the NVRA, advice and technical assistance regarding compliance with

the NVRA to cooperative states, and research and writing on NVRA implementation. She

performed legal work related to a number of other NVRA cases similar to the case before this

Court. She graduated from the Washington School of Law in 2006 and is a member of the

Washington State Bar. Attached as Exhibit B is an accurate and contemporaneous itemization

for the hours that Ms. Zeitler expended in this litigation.

16. Niyati Shah has been an Election Counsel at Project Vote since July 2010.

I supervise her. In that capacity, she performs legal work related to the above captioned case and

other federal election litigation. Her work at Project Vote specifically involves efforts around

the country to ensure effective implementation of Section 7 of the NVRA. Her NVRA work

includes litigation against states for failure to comply with the NVRA, advice and technical

assistance regarding compliance with the NVRA to cooperative states, and research and writing

on NVRA implementation. She graduated from the Rutgers University School of Law –

Camden in 2005 and is a member of the New Jersey bar since 2005 and the New York bar since

2006. Prior to working at Project Vote, she worked at the New York City Department of

Consumer Affairs as staff counsel and at the Legal Services of Northwest Jersey. Attached as

Exhibit C is an accurate and contemporaneous itemization for the hours Ms. Shah expended in

this matter


7

17. Michelle Rupp has been Election Counsel and Assistant General Counsel

with Project Vote since the summer of 2011. I supervise her. In that capacity, she performs legal

work related to the above-captioned case and other federal election litigation. Her work at

Project Vote specifically involves efforts around the country to ensure effective implementation

of Section 7 of the NVRA. Her NVRA work includes litigation against states for failure to

comply with the NVRA, advice and technical assistance regarding compliance with the NVRA

to cooperative states, and research and writing on NVRA implementation. Ms. Rupp graduated

from Georgetown University Law Center in 2011. While in law school, she served as Editor in

Chief of the Georgetown Immigration Law Journal and was Vice President of the school’s

Election Law Society. Before joining Project Vote as Election Counsel, Ms. Rupp interned for 3

semesters at the Lawyers Committee for Civil Rights Under the Law and Project Vote. Ms.

Rupp holds Bachelor of Arts degrees in Political Science and History from Arizona State

University, where she graduated summa cum laude. Attached as Exhibit D is an accurate and

contemporaneous itemizations for the hours that Ms. Rupp expended in this litigation.

18. Kelly Gerlach works as a Policy Analyst for Project Vote. She has held

this position since fall 2011. I supervise her. In this position, she coordinates and analyzes data

on state compliance with federal laws for the NVRA program. Previously, Ms. Gerlach worked

for Missouri Secretary of State Robin Carnahan's office, where she administered state and federal

elections. Ms. Gerlach has a Master of Public Administration from Southern Illinois University,

which she earned in 2010. Attached as Exhibit E is an accurate and contemporaneous

itemizations for the hours that Ms. Gerlach expended in this litigation.

19. Below is a chart summarizing the total number of hours and correlating

fees for each Project Vote staff person for whom Plaintiffs seek compensation:


8

Person Hourly

Rate

Hours

Billed

Hourly

Fees Due

Travel

Hours

Travel Fees

Due

Total Fees

Due

Sarah Brannon $600 612.4 $367,440 89.7 $26,910 $394,310

Nicole Kovite

Zeitler

$600 593.3 $355,980 45.5 $13,650 $369,630

Niyati Shah $475 710.9 $337,677.5 71 $16,862.5 $354,540

Michelle Rupp $280 522.5 $146,300 37.5 $5215 $151,515

Kelly Gerlach $175 22 $3,850 - - $3,850

Sum $1, 273,845

- 10%

TOTAL $1,146,460

20. The above chart breaks out the time spent by Project Vote’s staff solely

for travel. As part of Plaintiffs’ effort to ensure that this fee petition is fair and reasonable,

Project Vote is only seeking to recover for travel time at 50% of any given staff person’s hourly

rate.

21. At all times, Project Vote attorneys conducted their representation of

Plaintiffs as efficiently and economically as possible within the bounds of our duty to pursue our

client’s claims zealously.

22. Plaintiffs wish to be reasonable and fair in seeking fees, and therefore,

Project Vote did not necessarily record time for every conference call or meeting with members

of Plaintiffs’ legal team, either in whole or in part. Accordingly, the work logs of others may

reflect meetings or calls that we attended or in which Project Vote attorneys or staff participated

but for which Project Vote attorneys or staff did not separately bill or billed for a lesser time

period. Any such discrepancy reflects a decision to exercise billing judgment in recordation of

time, rather than an inaccuracy in time records.


9

23. Because Plaintiffs wishes to be reasonable and fair in seeking fees, Project

Vote has voluntarily lowered the hours billed in several instances. Those instances include: 1)

excluding all time related to pre-suit survey investigation, which included approximately 66

hours of time spent by Project Vote’s investigator, Michael Richards and 25 hours by Nicole

Kovite Zeitler; 2) excluding all time expended by Project Vote’s more senior staff, such as the

General Counsel, who provided limited but meaningful oversight, advice and supervision as the

case progressed; 3) excluding all time of Project Vote’s paralegal–the work by Project Vote’s

paralegal in this matter was mostly administrative, but still very useful; 4) the time of Michelle

Rupp, Project Vote’s least experienced election counsel, was reduced by almost 100 hours to

account for any potential concern about duplication of efforts; 6) for any depositions or court

appearances (other than trial, where all attorney’s present were actively involved and necessary)

if more than 2 Project Vote attorneys were present, all time for the additional third attorney as

excluded and 5) Project Vote’s legal interns contributed over 100 hours of work to this matter,

none of which has been included in this fee petition.

24. Additionally, any time spent by Project Vote staff on this fee petition or in

with respect to the defense of any re-depositions of witness has been excluded.

25. In addition, as part of our goal of being reasonable and fair, Project Vote is

lowering the actual amount it is seeking in fees by 10% across the board. This reduction is

documented in the chart above. This is being done in part to account for any potential concerns

about duplicative work or efforts by Project Vote’s staff.

26. Plaintiffs seek compensation for the costs and expenses expended by

Project Vote in connection to this litigation. Attached in Exhibit F to this Declaration are

accurate records detailing the costs and expenses incurred related to this litigation. The total


Exhibit A

Sarah Brannon (Time Records)

Date Last name Task Note Hours

23-Mar-12 Brannon Review and exchange e-mails prep 0.10

26-Mar-12 Brannon Review and exchange e-mailsabout oppn to secondmotion to strike 0.10

26-Mar-12 Brannon Review and exchange e-mailsre: draft of summaryjudgment 0.10

26-Mar-12 Brannon Review and analyzecourt's order regardingmotion to strike 0.10

27-Mar-12 Brannon Review and analyze legal research 0.10

27-Mar-12 Brannon Review and exchange e-mailsre: motion for additionaldiscovery 0.20

27-Mar-12 Brannon

Review and analyze filing bydefendant/defendants 0.30

28-Mar-12 Brannon Review and exchange e-mailsre: oral argumentpreparation 0.10

28-Mar-12 Brannon Review and exchange e-mailsrelated to oppn to motionfor discovery 0.20

29-Mar-12 Brannon

Participate in telephoneconference call

re: opposition to motionfor leave 0.30

29-Mar-12 Brannon Review and exchange e-mails leave 0.20

29-Mar-12 Brannon Research summary judgment 0.30

29-Mar-12 Brannon Review and revise draft oppn to motion for leave 0.30

29-Mar-12 Brannon

Review and analyze filing bydefendant/defendants motion for leave 0.20

30-Mar-12 Brannon Review and revise draft re: motion for leave 0.80

30-Mar-12 Brannon Review and analyze [redacted] 0.20

30-Mar-12 Brannon Review and exchange e-mails re: motion for leave 0.50

30-Mar-12 Brannon Review and revise draft re: summary judgment 0.50

30-Mar-12 Brannon Review and exchange e-mails about [redacted] 0.20

30-Mar-12 Brannon Review and analyzedraft oppn to motion tostrike 0.30

30-Mar-12 Brannon Review and revise draft oppn to motion for leave 0.50

2-Apr-12 Brannon Review and revise draftoppn to motion fordiscovery 0.50

2-Apr-12 Brannon Review and exchange e-mailsoppn to motion fordiscovery 0.50

2-Apr-12 Brannon Review and exchange e-mails re: oppn motion to strike 0.30

2-Apr-12 Brannon Review and revise draft oppn to strike 0.30

2-Apr-12 Brannon Review and revise draft surreply 0.50

3-Apr-12 Brannon Review draft court filings

reviewed final edits tooppn to motion foradditional discovery 0.50



reviewed motion forleave to file newdeclaration from Rev.Taylor and proposedorder 0.20


reviewed and editeddraft of Pls surreply filedin response to SoS replyto submit additionalevidence 1.20

3-Apr-12 Brannon Review and exchange e-mailsoppn motion additionaldiscovery 0.50

3-Apr-12 Brannon Review and exchange e-mails declaration 0.40

3-Apr-12 Brannon Review and revise draft surreply 0.70

4-Apr-12 Brannon Review and exchange e-mails re: discovery responses 0.40

4-Apr-12 Brannon Review and exchange e-mailspreparation for oralargument 0.10

6-Apr-12 Brannon Review and exchange e-mails about discovery 0.10

6-Apr-12 Brannon Review and exchange e-mailsabout preparation fororal argument 0.20

9-Apr-12 Brannon Review and exchange e-mails re: summary judgment 0.20

9-Apr-12 Brannon

Participate in telephoneconference with litigation team

re motion for summaryjudgment 0.50

9-Apr-12 Brannon Prepare for oral argument [redacted] 1.50


11-Apr-12 Brannon Review and analyze court order 0.10

13-Apr-12 Brannon Review and exchange e-mails summary judgment 0.20

15-Apr-12 Brannon Review and exchange e-mails regarding [redacted] 0.20

15-Apr-12 Brannon

Review and analyze filing bydefendant/defendants

Def. Schedler's rule56(d) motion 0.40

16-Apr-12 Brannon Review and exchange e-mails about rule 56(d) motion 0.40

16-Apr-12 Brannon Review and revise draftoppn to Def. Schedler'srule 56 (d) motion 2.20


17-Apr-12 Brannon

Review and analyze filing bydefendant/defendants 0.20

19-Apr-12 Brannon travel timeto New Orleans for oralargument 4.50

20-Apr-12 Brannon Attend oral argument regarding PSJM 2.60

20-Apr-12 Brannon travel time from New Orleans 4.50

23-Apr-12 Brannon Research re: [redacted] 0.30

23-Apr-12 Brannon Review and revise draft summary judgment 0.20

23-Apr-12 Brannon Review and exchange e-mails re summary judgment 0.30

23-Apr-12 Brannon


regarding Court's orderand [redacted] 0.90

23-Apr-12 Brannon Review and exchange e-mails about [redacted] 0.10

23-Apr-12 Brannon Prepare for depositions 0.50

23-Apr-12 Brannon Review and revise draft [redacted] 0.10

23-Apr-12 Brannon Review and analyze Court's order 0.10

24-Apr-12 Brannon Draft memo and research [redcted] 1.20


24-Apr-12 Brannon Review and exchange e-mails

with litigation team aboutschedule meet andconfer; and schedulingsettlement conferencewith magistrate judge. 0.40

24-Apr-12 Brannon

Draft oppn to motion forsummary judgment worked [redacted] 0.20

25-Apr-12 Brannon Review and exchange e-mailsre: filing for magistratejudge 0.20

25-Apr-12 Brannon Research and prepare filing for Mag. judge 0.50

25-Apr-12 Brannon Review and exchange e-mails proposal 0.20

26-Apr-12 Brannon Review and exchange e-mails regarding settlement 0.20

26-Apr-12 Brannon Review and analyzeproposed settlementagreement 0.20

27-Apr-12 Brannon Review and exchange e-mailsabout submission formagistrate judge 0.30

27-Apr-12 Brannon Prepare for depositions [redacted] 0.50

29-Apr-12 Brannon Review and revise draft [redacted] 2.20

30-Apr-12 Brannon Prepare for depositions [redacted 0.30

30-Apr-12 Brannon Attorney work productreviewed draft letter[redacted] 0.40

1-May-12 Brannon Review and analyze settlement proposal 0.60

1-May-12 Brannon Review and exchange e-mailsabout settlementproposals 0.20

2-May-12 Brannon

Participate in telephoneconference with litigation team [redacted] 1.00

2-May-12 Brannon

Prepare for telephoneconference call

with defense counsel formeet and confer aboutsettlement 0.50

2-May-12 Brannon Review and exchange e-mails 0.60

2-May-12 Brannon Review and analyze draft settlement proposal 0.60

3-May-12 Brannon Attorney work productdiscussion with N. Shahabout [redacted] 0.20

3-May-12 Brannon Review and analyze

opinion from Court grantPartial Sum Judge forPls. 0.70

3-May-12 Brannon


confer call with allcounsel 0.50

3-May-12 Brannon


with all parties regardingsettlement 0.40

3-May-12 Brannon Review and revise draft

letter and chart for Mag.Judge regardingsettlement conference 0.60

4-May-12 Brannon Review and revise draft

letter and chart for Mag.Judge for settlementconference 0.30

4-May-12 Brannon Prepare for depositions [redacted] 0.50

8-May-12 Brannon Review and exchange e-mails about settlement 0.30

8-May-12 Brannon Review and exchange e-mails depositions 0.50


8-May-12 Brannon travel time for mediation 6.70

9-May-12 Brannon Prepare for court conferencemeet with co-counselabout mediation 0.70

9-May-12 Brannon Attend court conference court order mediation 1.00

9-May-12 Brannon draft e-mail about next steps 0.20

9-May-12 Brannon Review and exchange e-mails about [redacted] 0.30

9-May-12 Brannon Attend meeting about [redacted] 0.50

9-May-12 Brannon Review and exchange e-mailsabout motion forimmediately appeal/stay 0.40

9-May-12 Brannon

Review and analyze filing bydefendant/defendants for immediate appeal 0.50

9-May-12 Brannon Attend meeting with [redacted] 0.50

10-May-12 Brannon Review and exchange e-mailsabout Def's filing reappeal request 0.20

10-May-12 Brannon

Participate in telephoneconference call about depositions 0.50

10-May-12 Brannon Review and exchange e-mails about depositions 0.40

10-May-12 Brannon travel time from LA 3.20


14-May-12 Brannon Review and exchange e-mailsabout motion forappeal/stay 0.40

14-May-12 Brannon Review and exchange e-mails re: depositions 0.20

15-May-12 Brannon Draft and review to do list for next steps 0.50

15-May-12 Brannon

Participate in telephoneconference with litigation team 0.60

15-May-12 Brannon Review and analyze deposition prep 0.40

16-May-12 Brannon Review and exchange e-mailsabout depositiontranscript 0.20

16-May-12 Brannon Review and revise draft appeal 0.70

16-May-12 Brannon Researchre: oppn to motion forappeal 0.40

16-May-12 Brannon Review and analyze [redacted] 0.30

17-May-12 Brannon Review and exchange e-mailsabout schedulingdepositions 0.40

17-May-12 Brannon Review and analyzedocuments fordeposition prep 1.20

17-May-12 Brannon Review and exchange e-mailsabout discoverydocuments 0.10

17-May-12 Brannon Attorney work productmeeting and emailsregarding [redacted] 0.50

18-May-12 Brannon Review and analyzematerials related todepositions prep 0.60


18-May-12 Brannon



21-May-12 Brannon Review and exchange e-mails about schedule 0.50


21-May-12 Brannon Attorney work product

reviewed emails anddocuments related to[redacted] 1.20

21-May-12 Brannon Draft discovery summaries 0.80

22-May-12 Brannon Attend meeting

with PV staff aboutdepositions and nextsteps 1.50

22-May-12 Brannon

Review and analyze filing bydefendant/defendants re: discovery request 0.30


22-May-12 Brannon Prepare for depositions [redacted] 0.30

23-May-12 Brannon


23-May-12 Brannon Review and analyze draft letter to the judge 0.30

23-May-12 Brannon Review and exchange e-mails status conference 0.20

23-May-12 Brannon Review and exchange e-mails DHH discovery requests 0.20

23-May-12 Brannon Review and analyze discovery responses 0.50

23-May-12 Brannon


regarding statusconference. 0.30

24-May-12 Brannon


with the Judge regardingstatus 0.20


24-May-12 Brannon

Participate in telephoneconference with litigation team about status call 0.30


24-May-12 Brannon Review and exchange e-mailsabout oppn to motion forappeal 0.50


with PV staff aboutdepositions and statusconference with thecourt 0.50

24-May-12 Brannon Review and exchange e-mailsabout discoveryresponses 0.20

24-May-12 Brannon review discovery responses 0.70

25-May-12 Brannon Draft witness and exhibit list 2.20

25-May-12 Brannon draft e-mail regarding witness list 0.20


regarding drafting ofmotion for summaryjudgment 0.50

29-May-12 Brannon Review and exchange e-mails re: witness list 0.60

29-May-12 Brannon Review various e-mails appeal 0.10

29-May-12 Brannon

Participate in telephoneconference call 1.00

29-May-12 Brannon Research and preparememo regarding[redacted] 1.20

29-May-12 Brannon Review and exchange e-mails regarding depositions 0.10

30-May-12 Brannon Review and exchange e-mails about [redacted] 0.20

31-May-12 Brannon Review various e-mailsfrom Ron Wilson about[redacted] 0.30


31-May-12 Brannon Attend meetingwith N. Shah and M.Rupp about [redacted] 0.50

31-May-12 Brannon Review and exchange e-mails [redacted] 0.40

1-Jun-12 Brannon Attend meeting with PV LA team 1.00

1-Jun-12 Brannon Review and exchange e-mails about depositions 0.30

4-Jun-12 Brannon


5-Jun-12 Brannon travel timeto New Orleans for Pls.depositions 4.70

5-Jun-12 Brannon Prepare for depositions [redacted] 2.50

6-Jun-12 Brannon Attend depositions

defendant Dr. Johnsonand Rev. Taylor indeposition - (all day)and prep [redacted] 8.50

7-Jun-12 Brannon Attend depositions [redacted] 3.50

7-Jun-12 Brannon Review and revise draftPlaintiffs witness andexhibit list 2.30

7-Jun-12 Brannon Attend meetingwith the team afterdepositions 2.50

8-Jun-12 Brannon travel time from New Orleans 5.00

10-Jun-12 Brannon

Participate in telephoneconference with litigation team [redacted] 0.70

10-Jun-12 Brannon draft e-mail re: edits to [redacted] 0.20

10-Jun-12 Brannon Review and revise draft motion to [redacted] 0.70

11-Jun-12 Brannon

Participate in telephoneconference call with D. Ho 0.30

11-Jun-12 Brannon Review and exchange e-mails motion [redacted] 1.20

11-Jun-12 Brannon Review various e-mails [redacted] 0.20

11-Jun-12 Brannon Review and revise draft motion [redacted] 1.50

11-Jun-12 Brannon draft e-mailto defense counsel about[redacted] 0.40

12-Jun-12 Brannon Review various e-mails

from defense counselabout motion to adjustschedule 0.20

12-Jun-12 Brannon draft e-mailto defense counselregarding scheduling 0.10

12-Jun-12 Brannon Review various e-mailsregarding depositiontranscripts 0.10

12-Jun-12 Brannon Review and exchange e-mailsregarding motion toadjust schedule 0.80

13-Jun-12 Brannon Review and exchange e-mailsregarding motion toadjust schedule 0.50

13-Jun-12 Brannon Review and revise draft schedule 0.40

13-Jun-12 Brannon Review various e-mailsfrom defense counselabout scheduling 0.10

14-Jun-12 Brannon Review and exchange e-mails re [redacted] 0.20

15-Jun-12 Brannon Review and revise draft motion to expedite 0.50

15-Jun-12 Brannon Review and revise draft [redacted] 0.20

15-Jun-12 Brannon Review and exchange e-mails re: [redacted] 0.30


15-Jun-12 Brannon Review and exchange e-mails about filing [redacted] 0.80

17-Jun-12 Brannon Review and exchange e-mails next steps 0.10

18-Jun-12 Brannon


regarding schedulingand [redacted] 0.50

18-Jun-12 Brannon Review and exchange e-mailsregarding motion toexpedite 0.20

18-Jun-12 Brannon

Participate in telephoneconference call with court 0.10

18-Jun-12 Brannon Attend meetingwith PV team about[redacted] 0.50

18-Jun-12 Brannon Review and revise draft letter to court 0.20

19-Jun-12 Brannon Review and analyze letter to court 0.10

19-Jun-12 Brannon Review and exchange e-mails about[redacted] 0.30

19-Jun-12 Brannon Review and exchange e-mails re letter to court 0.30

19-Jun-12 Brannon

Participate in telephoneconference with litigation team about next steps 1.00

20-Jun-12 Brannon

Participate in telephoneconference with litigation team about sum. judgment 0.50

20-Jun-12 Brannon Review and exchange e-mails related to [redacted] 0.20

21-Jun-12 Brannon

Review and revise draftdiscovery responses 0.80

21-Jun-12 Brannon Attorney work productfinalize and filediscovery response 0.20

21-Jun-12 Brannon Review and exchange e-mails court conference 0.40

22-Jun-12 Brannon Review and analyzediscovery requests fromSOS to NAACP 0.20

22-Jun-12 Brannon


regarding newscheduling order anddrafting motion forsummary judgment 0.40

22-Jun-12 Brannon

Review and revise draft motionfor summary judgment 4.00

22-Jun-12 Brannon


discussed preparing forstatus conference withcourt 0.50

22-Jun-12 Brannon


with the Court andopposing counselregarding case schedule 0.50

23-Jun-12 Brannon Review and exchange e-mailswith PV staff about draftmotion for summ. judg. 0.20

23-Jun-12 Brannon


25-Jun-12 Brannon Review and exchange e-mails about [redacted] 0.40

25-Jun-12 Brannon Review and revise draft case/briefing schedule 0.30

25-Jun-12 Brannon Review and exchange e-mailsabout case/briefingschedule 0.60

25-Jun-12 Brannon Review and exchange e-mails [redacted] 0.30

25-Jun-12 Brannon Review various e-mails [redacted] 0.50

25-Jun-12 Brannon Review and exchange e-mailsabout SOS latestdiscovery request 0.40


26-Jun-12 Brannon


26-Jun-12 Brannon Review and exchange e-mailsabout summ jud. andnext steps 0.60

26-Jun-12 Brannon Review various e-mailsabout research re:[redacted] 0.50

26-Jun-12 Brannon Review various e-mailsabout exhibits for summjud. 0.40

27-Jun-12 Brannon Review and exchange e-mailsabout response to[redacted] 0.70

27-Jun-12 Brannon


27-Jun-12 Brannon Review various e-mailsabout scheduling[redacted] 0.20

27-Jun-12 Brannon Attorney work productreview exhibits for summjud motion 1.20

27-Jun-12 Brannon Review and exchange e-mailsabout scheduling andbriefing schedule 0.30

27-Jun-12 Brannon Draft letter to [redacted] 1.80

27-Jun-12 Brannon Review and exchange e-mailsabout exhibits for summjud. 0.30

28-Jun-12 Brannon Review and exchange e-mailsabout edits to statementof facts 0.80

28-Jun-12 Brannon draft e-mail [redacted] 0.10

28-Jun-12 Brannon Review and revise draftstatement of factsrelated to Summ Jud 2.70

28-Jun-12 Brannon Review and exchange e-mails about cites in summ jud 0.50

28-Jun-12 Brannon Review and exchange e-mailsabout next steps forfinish edits to sum jud 0.30

28-Jun-12 Brannon Review and exchange e-mails about edits to [redacted] 0.40

28-Jun-12 Brannon Review and incorporate edits to letter to [redacted] 0.70

28-Jun-12 Brannon Review various e-mailsfrom N. Shah about[redated] 0.10

28-Jun-12 Brannon Review and exchange e-mails about citation [redacted] 0.80

29-Jun-12 Brannon Attorney work productreview email from def.counsel about deposition 0.10

29-Jun-12 Brannon Review and revise draftrelated to motion summjud 0.60

29-Jun-12 Brannon Review and exchange e-mailsabout edits to motion forsumm jud 0.70

29-Jun-12 Brannon Review and exchange e-mails about [redacted] 0.20

29-Jun-12 Brannon Review and exchange e-mailswith co-counsel aboutscheduling [redacted] 0.20

29-Jun-12 Brannon


30-Jun-12 Brannon Review and exchange e-mailswith co-counsel aboutscheduling [redacted] 0.30

30-Jun-12 Brannon



1-Jul-12 Brannon draft e-mail

to defense counsel aboutscheduling [redacted]deposition 0.10

1-Jul-12 Brannon Review and exchange e-mailswith co-counel about[reacted] 0.80

2-Jul-12 Brannon draft e-mailwith long summary[redacted] 0.90

2-Jul-12 Brannon Prepare for depositions [redacted] 1.00

2-Jul-12 Brannon

Participate in telephoneconference call with Pls. [redacted] 0.70

2-Jul-12 Brannon Review and exchange e-mails judg 0.50

2-Jul-12 Brannon Research motion to quash 0.30

2-Jul-12 Brannon Review and exchange e-mailswith co-counsel aboutdrafting motion to quash 0.50

2-Jul-12 Brannon Review and exchange e-mailswith co-counsel about[redacted] 0.40

2-Jul-12 Brannon


notice of deposition forMr. Heckard 0.10

2-Jul-12 Brannon Review and exchange e-mailswith co-counsel aboutscheduling [redacted] 0.30

2-Jul-12 Brannon

Review and revise draft motionfor summary judgment

and reviewed othersedits to motion 5.10

2-Jul-12 Brannon Review and exchange e-mailswith defense counselabout scheduling 0.10

2-Jul-12 Brannon Review and revise draftstatement of facts forsumm judg. 1.40

3-Jul-12 Brannon Review and exchange e-mailsabout filing of Motion forsumm jud 0.10

3-Jul-12 Brannon Review and revise draftMotion for SummaryJudgment 2.20

3-Jul-12 Brannon Review and exchange e-mails

about collectingadditional discoverydocuments from pls. 0.70

3-Jul-12 Brannon Attorney work product

followed-up on gettingtranscript from call withCourt 0.20

3-Jul-12 Brannon Review and exchange e-mailsabout transcript from callwith court 0.10

3-Jul-12 Brannon Review and exchange e-mails about [redacted] 0.30

6-Jul-12 Brannon Review discovery responses and [redacted] 1.50

6-Jul-12 Brannon Review and incorporate editsto draft motion to quashsubpoena 0.60

6-Jul-12 Brannon


attempted to call theCourt to discuss Court'sorder regarding briefingschedule 0.10


related to Court's orderregarding briefingschedule 2.50


6-Jul-12 Brannon


with co-counselregarding Court's orderregarding briefingschedule 0.40

7-Jul-12 Brannon

Review and revise draftdiscovery responses including [redacted] 4.50

7-Jul-12 Brannon Draft motionto quash Rule 45subpoena 2.10

7-Jul-12 Brannon Review and exchange e-mails about SOS motion 1.20

8-Jul-12 Brannon Review and revise draft

motion for extension oftime to respond tomotion to compel 0.70

8-Jul-12 Brannon Review and exchange e-mails regarding [redacted] 0.50

8-Jul-12 Brannon Draft letter [redacted] 0.50

8-Jul-12 Brannon Review and analyzemotion to compel filedby SoS 0.40

8-Jul-12 Brannon Review and exchange e-mailsabout drafting responseto [redacted] 1.50

9-Jul-12 Brannon Review and analyze [redacted] 0.40

9-Jul-12 Brannon Review and exchange e-mails [redacted] 0.40

10-Jul-12 Brannon Review and revise draft motion to quast 0.80

10-Jul-12 Brannon Review and exchange e-mails quash 0.50

10-Jul-12 Brannon Review and revise draftmotion forreconsideration 0.70

10-Jul-12 Brannon Review and exchange e-mailsregarding rulred re[redacted] 0.50


10-Jul-12 Brannon Review and exchange e-mails motion to expedite 0.20

10-Jul-12 Brannon Review and exchange e-mails discovery issues 0.50

11-Jul-12 Brannon travel timewith N. Shah to BatonRouge for deposition. 4.50

11-Jul-12 Brannon Review and exchange e-mailsabout filing motion toquash 0.30

11-Jul-12 Brannon


about filing motion toquash 0.20

11-Jul-12 Brannon Review and revise draftmotion to quashsubpoena for documents 0.80

12-Jul-12 Brannon Review and analyzemotion to extenddiscovery by SoS 0.20

12-Jul-12 Brannon Review and revise draftextend discoverydeadline 2.50

12-Jul-12 Brannon Review and analyzeSOS opposition tomotion to quash 0.20

12-Jul-12 Brannon

Participate in telephoneconference call [redacted] 1.00


12-Jul-12 Brannon Prepare for depositions {redacted] and defendant 4.50

13-Jul-12 Brannon Draft letter [redacted] 0.80

13-Jul-12 Brannon


Rupp regarding[redacted] 0.90



with litigation teamregarding drafting[redacted] 0.70

13-Jul-12 Brannon travel time

travel from Baton Rougefor deposition of NAACPtreasurer 6.00



15-Jul-12 Brannon Review and revise draftoppn to motion tocompel filed by SOS 1.30


15-Jul-12 Brannon Attorney work product sent e-mail [redacted] 0.30

16-Jul-12 Brannon Review and revise draftoppn to motion tocompel filed by SOS 0.20

17-Jul-12 Brannon


18-Jul-12 Brannon

Telephone conference call withteam

regarding discoveryissues 1.30

18-Jul-12 Brannon Telephone conference call

re [redacted], and N.Korgaonkar about[redacted] (call andpreparation) 0.60

20-Jul-12 Brannon

Telephone conference call withteam

regarding Courtconference call 1.00

20-Jul-12 Brannon

Participate in telephoneconference with litigation team regarding Court call 0.30

20-Jul-12 Brannon

Participate in telephoneconference call with the Court 0.40

22-Jul-12 Brannon Review and revise draftoppn to motion to extenddiscovery 1.80

22-Jul-12 Brannon Review and revise draftoppn to 2nd motion tocompel 0.80


23-Jul-12 Brannon

Participate in telephoneconference with litigation team re: [redacted] 0.50

23-Jul-12 Brannon Review discovery responses and review [redacted] 2.50


23-Jul-12 Brannon Attorney work product prepared [redacted[] 3.50

23-Jul-12 Brannon draft e-mail

and sent emails todefendants producingdocuments responsive toSOS discovery requests 2.20

23-Jul-12 Brannon Research [redacted] 1.50

23-Jul-12 Brannon

Review and revise draftdiscovery responses 1.50

23-Jul-12 Brannon Review and exchange e-mailsletter regardingdiscovery responses 0.50

24-Jul-12 Brannon Review and exchange e-mailswith defendants aboutdiscovery responses 0.30

24-Jul-12 Brannon Review and revise draft compel 1.80

24-Jul-12 Brannon draft e-mailto litigation team aboutdiscovery documents 0.50

24-Jul-12 Brannon Review and exchange e-mails compel 2.10

25-Jul-12 Brannon Review and exchange e-mailswith defendants aboutdiscovery responses 0.30

25-Jul-12 Brannon Review and exchange e-mails about next steps 0.30

25-Jul-12 Brannon Review and exchange e-mails with [redacted] 0.50

25-Jul-12 Brannon

Participate in telephoneconference with litigation team regarding next steps 1.00


relate to follow-upregarding documentproduction 0.50

26-Jul-12 Brannon


with client aboutdiscovery documents 0.10

26-Jul-12 Brannon Review and exchange e-mailsdiscovery documentsand clients 0.10

27-Jul-12 Brannon Review and exchange e-mailswith Defendant aboutdocument production 0.80

1-Aug-12 Brannon Review and analyze

order from J. Wilkinsonregarding 2nd motion tocompel 0.30

2-Aug-12 Brannon Review and analyze draft DHH witness list 0.30


2-Aug-12 Brannon Review and exchange e-mails about [reacted] 0.50

3-Aug-12 Brannon Review and analyzesupplement discoveryresponses from DCFS 0.50

3-Aug-12 Brannon Review and exchange e-mails

emails with DCFScounsel aboutsupplemental discoveryresponses 0.60

3-Aug-12 Brannon


about next steps fordrafting pre-trialstatement, SJ reply 0.50


about scheduling anddue dates for pre-trialstatement and counselconference 0.50


communication Defensecounsel about DCFSsupplemental production 0.10

7-Aug-12 Brannon Review and analyzedraft of oppn to motionto strike 0.40


witness preparation chartfor DCFS related to pre-trial statement and trialpreparation. 0.60

8-Aug-12 Brannon

Participate in telephoneconference with litigation team related to [redacted] 1.10

8-Aug-12 Brannon

Participate in telephoneconference call [redacted] 0.50

9-Aug-12 Brannon Review and analyze draft witness chart 0.70


with litigation team aboutproposed pre-trialschedule 0.20

10-Aug-12 Brannon Review and revise draftwitness chart about Plsfor pre-trial statements 0.20

10-Aug-12 Brannon Review and revise draft

witness chart for DCFSwitnesses related to pre-trial statement and trialprep 0.60

10-Aug-12 Brannon Attorney work product

meeting with N. Shahabout witness chart forDCFS witness for pre-trial statement 0.30

10-Aug-12 Brannon Review various e-mails

from Defense Counselabout schedulingcounsel of conferenceand exchange of draftpre-trial statements 0.40

13-Aug-12 Brannon Review and revise draft exhibit list 0.50

13-Aug-12 Brannon Draft

part of the DCFS witnesschart related to pre-trialstatement and trial prep 1.20


14-Aug-12 Brannon

Participate in telephoneconference with litigation team about pre-trial statement 0.50


followed-up with N. Shahabout confidential DCFSdocuments on exhibit list 0.40


about following-up withDefense counsel aboutscheduling pretrialconference of counsel 0.50

15-Aug-12 Brannon Review and exchange e-mailswith Fried Frank aboutexhibit list 0.40


started review of Defs'oppn to motion forsummary judgment 0.80


follow-up with Eric Sollieand N. Shah aboutexhibit list 0.40

15-Aug-12 Brannon Draft

email about the witnesslists for pre-trialstatement and sent to E.Sollie 0.50

16-Aug-12 Brannon


about Defendants' oppnsto motion for judgment 1.00


about schedulingconference of counselfor PTO 0.50

17-Aug-12 Brannon Review and analyzediscovery responsesfrom Defendants 1.20


with PV staff aboutscope of discoveryresponses fromdefendants 0.40


scheduling conference ofcounsel for PTO wthdefendants 0.70


emails about researchregarding discoveryresponses fromDefendants. 0.20

17-Aug-12 Brannon Draft letter

to court about schedulingof the conference ofcounsel for PTO 1.50

17-Aug-12 Brannon Review and exchange e-mailswith N. Korgaonkar[redacted] 0.50

17-Aug-12 Brannon Review and revise draft motion to strike 1.00

17-Aug-12 Brannon Research and prepare draft reply for sum. jud. 0.30

17-Aug-12 Brannon Review and analyzeemail about assignmentsfor trial team 0.10




with PV staff aboutstructure of motion tostrike 0.60

18-Aug-12 Brannon Review and exchange e-mailsabout edits to the replybrief 0.30

18-Aug-12 Brannon

Review and revise draft replymotion related to summ jud. 2.20

18-Aug-12 Brannon Review and exchange e-mails abou[redacted] 0.30

19-Aug-12 Brannon


with D. Ho about[redacted] 0.50

19-Aug-12 Brannon Draft reply motion related to summ. jud. 2.10

19-Aug-12 Brannon Review and revise draft Motion to strike 2.50

19-Aug-12 Brannon Review and exchange e-mailswith N. Korgaonkarabout [rdeacted] 0.50

19-Aug-12 Brannon draft e-mailto M. Rupp and N. Shahabout [redacted] 0.30

20-Aug-12 Brannon Review and exchange e-mailswith N. Shahabout[redacted] 0.20

20-Aug-12 Brannon Draft email about [redacted] 0.40

20-Aug-12 Brannon Review and exchange e-mailsabout exhibits to motionto strike 0.20


edits to letter to courtabout schedulingconference of counsel;and sent same 0.20


follow-up on researchregarding discoveryrelated to PTO 0.30

20-Aug-12 Brannon Review and analyzeDCFS of reply summ.jud. 0.30


DCFS email regardingconference of counselfor PTO 0.10

20-Aug-12 Brannon Review and analyze draft motion to strike 0.40

20-Aug-12 Brannon Review and exchange e-mails re: motion to strike 0.70

20-Aug-12 Brannon Review and analyzelatest draft of replyrelated to summ. jud. 0.30

20-Aug-12 Brannon


20-Aug-12 Brannon Review various e-mails re: [redacted] 0.30

21-Aug-12 Brannon


22-Aug-12 Brannon Review and exchange e-mails reply SJM 0.30


22-Aug-12 Brannon Review and exchange e-mails strike 1.75

22-Aug-12 Brannon Review and exchange e-mails about content of PTO 0.50

23-Aug-12 Brannon Review and exchange e-mails rely to motion to strike 0.10

23-Aug-12 Brannon Review and exchange e-mails reply sjm 0.50

23-Aug-12 Brannon Review and revise draft reply sjm 2.20


24-Aug-12 Brannon Review and analyzeresearch regarding replysjm 1.50

24-Aug-12 Brannon Review and exchange e-mails prep for oral argument 0.20

24-Aug-12 Brannon Review and exchange e-mails exhibit reply sjm 0.50


24-Aug-12 Brannon Review and exchange e-mails rely sjm 1.50

25-Aug-12 Brannon Review and exchange e-mails declaration 0.10


26-Aug-12 Brannon Attorney work product re: declaration 0.30


27-Aug-12 Brannon Attorney work product declarations 0.40

27-Aug-12 Brannon Review and exchange e-mails declaration 0.20

27-Aug-12 Brannon Review and exchange e-mailsfiling deadline for sjmreply 0.20

27-Aug-12 Brannon Research exhibits for reply sjm 0.50

27-Aug-12 Brannon Review and exchange e-mails exhibits for reply sjm 0.50

28-Aug-12 Brannon

Participate in telephoneconference with litigation team summ jud. (several calls) 2.00

28-Aug-12 Brannon Review and exchange e-mails exhibits to reply sjm 0.20


28-Aug-12 Brannon draft e-mailto defendants regardingpto 0.30

28-Aug-12 Brannon Review and exchange e-mailsre communication withdefendants about pto 0.30



30-Aug-12 Brannon

Participate in preparation for oralargument 1.50

30-Aug-12 Brannon Prepare for oral argument 1.50

31-Aug-12 Brannon


31-Aug-12 Brannon draft e-mail

to R. Wilson aboutscheduling of conferenceof counsel for PTO 0.10

31-Aug-12 Brannon


about motion to strikeoppns 0.50

31-Aug-12 Brannon Review and exchange e-mailsabout filing of replyrelated to summ judg 0.10

31-Aug-12 Brannon Review and exchange e-mailsabout oppn to motion tostrike 0.60

31-Aug-12 Brannon


response to motion tostrike 0.40

31-Aug-12 Brannon draft e-mailabout DCFS oppn tomotion to strike 0.20

31-Aug-12 Brannon


DCFS oppn to motion tostrike 0.20

31-Aug-12 Brannon

Participate in telephoneconference with litigation team oppn to motion to strike 0.50


2-Sep-12 Brannon Review and exchange e-mails

regarding reply memo insupport of Plaintiffsmotion to strike and oralargument 0.50

2-Sep-12 Brannon Review and analyzemotion to strike replyexhibits filed by SOS 0.30

2-Sep-12 Brannon Prepare for oral argument

re motion to strike andmotion for summaryjudgment 1.90

2-Sep-12 Brannon Review and revise draftreply memo in support ofPlaintiffs motion to strike 2.50

3-Sep-12 Brannon Prepare for oral argument [redacted] 5.00

3-Sep-12 Brannon Review and revise draftoppn to SOS motion tostrike reply exhibits 0.50

3-Sep-12 Brannon Review and revise draftreply in support ofPlaintiffs motion to strike 0.80

3-Sep-12 Brannon Review and exchange e-mailsregarding SOS motion tostrike reply exhibits 0.20

3-Sep-12 Brannon Attorney work productregarding oral argumentschedule and details 0.30

3-Sep-12 Brannon Draft motionrequesting oral argumenton motion to strike 0.50

3-Sep-12 Brannon Attorney work product

filed request for oralargument on motion tostrike 0.20

3-Sep-12 Brannon Review and exchange e-mailsregarding filing oppn toSOS surreply 0.10

4-Sep-12 Brannon Review and revise draftoppn to surreply filed bySOS 0.50

4-Sep-12 Brannon Prepare for oral argument motion to strike 2.30

4-Sep-12 Brannon Review and exchange e-mailsabout filing oppn tosurreply 0.20

4-Sep-12 Brannon travel time

travel to New Orleans forsumm judgment oralargument 5.50

4-Sep-12 Brannon Review and analyze surreply filed by SOS 0.40

4-Sep-12 Brannon Review and exchange e-mailsregarding all plaintiffsfilings for today 0.20

5-Sep-12 Brannon Attend court conferencere: motion to strike andsumm. 1.00

5-Sep-12 Brannon Attend court conference

after motion forsummary judgment todiscuss next steps. 2.30

5-Sep-12 Brannon Prepare for oral argument re: motion to strike 2.50

6-Sep-12 Brannon travel timefrom motion forsummary judgment 5.10

7-Sep-12 Brannon Review and analyzeemail from D. Ho about[redacted] 0.20


7-Sep-12 Brannon


about SOS commentsabout possiblesettlement discussions 0.50

7-Sep-12 Brannon Review various e-mails about exhibit list 0.10

7-Sep-12 Brannon Review various e-mails

and attachment from FFre: on-going violations vsother violations forpotential settlement 0.40

7-Sep-12 Brannon Review and analyzedraft section regardinglaw for PTO 0.70

7-Sep-12 Brannon Draft proposed injunction 4.00

7-Sep-12 Brannon Review and exchange e-mailsabout scheduling DCFScaseworkers depo 0.20

7-Sep-12 Brannon Review and analyzeemail from FF re SOSsettlement discussions 0.10

8-Sep-12 Brannon Draft proposed injunction 3.50

8-Sep-12 Brannon Review and exchange e-mailsabout proposedinjunction and next steps 0.10

9-Sep-12 Brannon Review various e-mailsabout facts section forPTO 0.20

9-Sep-12 Brannon Review and analyzeemail from D. Ho about[redacted] 0.20

10-Sep-12 Brannon Review and exchange e-mailsabout schedulingcaseworker depositions 0.20

10-Sep-12 Brannon


with E. Sollie aboutdepositions of caseworkers 0.40

10-Sep-12 Brannon Attorney work product

follow-up and review e-mails about getting alldiscovery documents toFF for printing exhibits 0.70


with co-counsel aboutpotential settlementdiscussions withdefendants - 0.80


with E. Sollie and D. Hoabout depositions ofcaseworkers 0.20

10-Sep-12 Brannon


11-Sep-12 Brannon Review and exchange e-mailsregarding printing trialexihibits 0.50

12-Sep-12 Brannon Prepare for depositions of L. Scott case workers 2.50

12-Sep-12 Brannon travel timeto New Orleans fordepositions 5.50

12-Sep-12 Brannon Attend meetingdeposition ofcaseworkers 0.50


13-Sep-12 Brannon travel time

travel from New Orleansafter depositions ofcaseworkers 5.10

13-Sep-12 Brannon Conduct depositionsof L. Scott case workersand prepared in morning 3.70

14-Sep-12 Brannon Review and revise draft

letter to defendantsregarding additionalexhibits 0.30

14-Sep-12 Brannon Review and revise draft pre-trial order 1.50

14-Sep-12 Brannon Review and exchange e-mails schedule 0.50


regardingcommunication /wdefendants aboutscheduling 1.50

14-Sep-12 Brannon Review and exchange e-mailsdocuments related totrial exhibits 1.10

14-Sep-12 Brannon Review and exchange e-mails additional exhibits 0.20

14-Sep-12 Brannon Review and exchange e-mails trial prep; pre-trial order 0.70

14-Sep-12 Brannon Review and exchange e-mails DCFS trial exhibits 0.80

14-Sep-12 Brannon Review and exchange e-mails all trial exhibits 1.20

15-Sep-12 Brannon Review and revise draft proposed pre-trial order 3.75

15-Sep-12 Brannon Draft

letter to defendantsregarding additionalexhibits 0.30

15-Sep-12 Brannon Review various e-mailsfrom Defendants aboutPTO and exhibits 0.50

15-Sep-12 Brannon Review and exchange e-mailsproducing additionaldocuments 0.50

15-Sep-12 Brannon Review and analyzeadditional documents forexhibits 1.20

15-Sep-12 Brannon Review and exchange e-mails re: pto 1.50

15-Sep-12 Brannon Attorney work productmail additional exhibitsto Defendants 0.50


16-Sep-12 Brannon Review various e-mailsregarding PTO andschedule 1.00

17-Sep-12 Brannon Review and exchange e-mailsrelated to motions inlimine 0.20


17-Sep-12 Brannon Review and exchange e-mailsabout trial exhibits fromDefendants 0.30

17-Sep-12 Brannon Review and analyzeSOS portions of the pre-trial brief 0.50

17-Sep-12 Brannon Attorney work productcite checked DCFS factsof pretrial brief 1.70

17-Sep-12 Brannon Review and exchange e-mails about the post trial brief 1.20

17-Sep-12 Brannon Review and exchange e-mails pre-trial insert from DHH 0.20

17-Sep-12 Brannon

Participate in telephoneconference call regarding PTO 1.00


18-Sep-12 Brannon

Participate in telephoneconference with litigation team about next steps 1.00

18-Sep-12 Brannon Review and revise draft

oppn to SOS motion forin-person pretrialconference 0.70

18-Sep-12 Brannon Review and analyzeDCFS proposed trialexhibits 1.50

18-Sep-12 Brannon Review and analyze motion [redacted] 0.50


about SOS motion forinperson pre-trialconference 0.60

18-Sep-12 Brannon Review and exchange e-mails about [redacted] 0.40

18-Sep-12 Brannon Review and analyzeSoS proposed inserts topre-trial brief 0.70

18-Sep-12 Brannon Review and exchange e-mailsDCFS proposed pre-trialinserts 0.90

19-Sep-12 Brannon


regarding met andconfer with Defendantsabout PTO 1.00

19-Sep-12 Brannon Review and revise draftlist of objections to[redacted] 0.70

19-Sep-12 Brannon Review and revise draft pre-trial order 4.50

20-Sep-12 Brannon Attend meeting

conference call withDefendants about PTOand preparation 6.00

21-Sep-12 Brannon

Participate in telephoneconference call regarding PTO 0.50

21-Sep-12 Brannon Review and revise draft PTO 3.60

21-Sep-12 Brannon Review and exchange e-mails pto 2.70

21-Sep-12 Brannon Review various e-mailsfrom defense counselregarding PTO 0.50

22-Sep-12 Brannon Review and exchange e-mails PTO 2.50

22-Sep-12 Brannon Review various e-mailsand edits fromdefendants re: PTO 0.50

22-Sep-12 Brannon Review and revise draft pto 3.50


23-Sep-12 Brannon Review and exchange e-mails about PTO 2.50

23-Sep-12 Brannon Review various e-mailsand edits fromDefendants re: PTO 1.80

24-Sep-12 Brannon Review and revise draft letter to court 0.10

24-Sep-12 Brannon Review and exchange e-mails about letter to court 0.50


24-Sep-12 Brannon Review various e-mailsand proposed edits fromdefendants about PTO 0.50

24-Sep-12 Brannon Review and exchange e-mailswith defendantsregarding PTO 1.50

24-Sep-12 Brannon Review and exchange e-mails about pto 2.50

25-Sep-12 Brannon Review and analyzeproposed findings of factand law 0.50


25-Sep-12 Brannon Attorney work productreview materials abouttrial witnesses 0.50

25-Sep-12 Brannon Review and exchange e-mails about trial witnesses 0.50

25-Sep-12 Brannon Review and exchange e-mailsproposed findings offacts and law 0.50

25-Sep-12 Brannon


25-Sep-12 Brannon Review and exchange e-mails about PTO 0.50

25-Sep-12 Brannon Review and exchange e-mails letter to court 0.50

25-Sep-12 Brannon


26-Sep-12 Brannon Review and exchange e-mails deposition designations 0.30

26-Sep-12 Brannon

Prepare for telephoneconference call regarding trial witnesses 1.50

26-Sep-12 Brannon Review and exchange e-mails timing of next steps 0.20

26-Sep-12 Brannon Draft letterabout depositiondesignations 0.50

26-Sep-12 Brannon Review and exchange e-mails trial prep as to witnesses 0.50

26-Sep-12 Brannon Review and exchange e-mailsletter to SOS aboutdeposition designations 0.30

27-Sep-12 Brannon Attend court conference pre-trial conference 1.40

27-Sep-12 Brannon Attend meeting

conferred with litigationteam about next stepsfollowing pre-trialconference 0.50

27-Sep-12 Brannon travel time 5.10

28-Sep-12 Brannon Review and exchange e-mails proposed injunction 0.50

28-Sep-12 Brannon travel time 6.10

28-Sep-12 Brannon Review and revise draft injunction 1.50

28-Sep-12 Brannon Review and exchange e-mailsproposed findings of factand law 0.50

28-Sep-12 Brannon Review various e-mailsscheduling PTO follow-up 0.20

1-Oct-12 Brannon Attorney work product trial preparation work 5.50

1-Oct-12 Brannon

Participate in telephoneconference with litigation team about trial 0.90

1-Oct-12 Brannon


with Defendants aboutPTO 0.50

2-Oct-12 Brannon Attorney work product trial preparations 6.50

2-Oct-12 Brannon

Participate in telephoneconference with litigation team about trial 1.20

3-Oct-12 Brannon

Participate in telephoneconference with litigation team trial exhibits 0.30

3-Oct-12 Brannon


with Court and J. Lofflerabout trial exhibits 0.20

3-Oct-12 Brannon Attorney work product trial preparation 7.50

4-Oct-12 Brannon Attorney work product preparation for trial 6.50

5-Oct-12 Brannon Attorney work product trial preparation work 7.50

6-Oct-12 Brannon Attorney work product trial prep 6.50


7-Oct-12 Brannon Attorney work product trial preparation 9.50

8-Oct-12 Brannon travel timeto New Orleans for[redacted] 4.00

8-Oct-12 Brannon Attorney work productprepared for and meetwith [redacted] 4.00

8-Oct-12 Brannon

Participate in telephoneconference with litigation team about witness and trial 1.00

8-Oct-12 Brannon Review and exchange e-mails about witness lists 0.40

8-Oct-12 Brannon Attorney work product

follow-up on trial prep byPV paraglegal S.Khan,include [redacted] 0.20

8-Oct-12 Brannon Review and exchange e-mailsabout edits to motions inlimine 1.20

8-Oct-12 Brannon Review and revise draft motions in limine 1.50

8-Oct-12 Brannon Review various e-mailsabout filing of motions inlimine 0.20

9-Oct-12 Brannon Review various e-mails about witness lists 0.30

9-Oct-12 Brannon Review and exchange e-mailswith PV staff about trialprep tasks 0.50

9-Oct-12 Brannon Review and exchange e-mailsregarding testimony by[redacted[l 0.50

9-Oct-12 Brannon


all motions in limine filedby defendants 1.50

9-Oct-12 Brannon Attorney work productprepared for and meetwith [redacted 3.50

9-Oct-12 Brannon travel timereturn from New Orleansafter witness prep 5.30

9-Oct-12 Brannon Review and exchange e-mails abou [redacted] 0.40

10-Oct-12 Brannon Review and analyze proposed stipulation 0.50

10-Oct-12 Brannon Review and exchange e-mailsabout SOS proposedstipulation 0.50

10-Oct-12 Brannon Review and exchange e-mails SOS 0.40

10-Oct-12 Brannon


about SOS proposedstipulation and motionsin limine 0.50

10-Oct-12 Brannon Review various e-mails about [redacted] 0.20

10-Oct-12 Brannon


with D. Ho about[redacted] 0.30

10-Oct-12 Brannon Review and exchange e-mails about [redacted[ 0.30

10-Oct-12 Brannon Draftwitness examinationoutlines 1.40

10-Oct-12 Brannon Review and exchange e-mails about [redacted] 0.50

10-Oct-12 Brannon Attorney work productreviewed witnessexamination outlines 1.20

10-Oct-12 Brannon Attorney work product list 0.10

10-Oct-12 Brannon Attorney work product [redacted] 0.80

10-Oct-12 Brannon Review and analyzedraft supplemental filing[redacted] 0.30


10-Oct-12 Brannon Review and exchange e-mailsabout filing regarding[redacted] 0.40

10-Oct-12 Brannon Attorney work product worked on [redacted] 0.70

10-Oct-12 Brannon Review and analyzedraft oppn to motion inlimine 1.20

10-Oct-12 Brannon Review and exchange e-mailsabout witness list andexhibit list 0.50

10-Oct-12 Brannon Attorney work product reviewed exhibit list 0.50

10-Oct-12 Brannon Review and analyze motion filed by SOS 0.50

11-Oct-12 Brannon Attorney work productreviewed witnessexamination outlines 0.50

11-Oct-12 Brannon Attend meetingrelated to preparingwitness examination 3.50

11-Oct-12 Brannon Review and revise draft oppn to motion in limine 1.20


11-Oct-12 Brannon Attorney work productworked on trial prep[redacted 0.50

11-Oct-12 Brannon Review and exchange e-mailsabout oppn to judicialnotice motion 0.50

11-Oct-12 Brannon Review and revise draft oppn to judicial notice 0.50

11-Oct-12 Brannon Attorney work productabout order trialtranscripts 0.20

11-Oct-12 Brannon Attorney work productabout process server[redacted] 0.50

11-Oct-12 Brannon Review and exchange e-mailsabout edits to oppn tomotion in limine 1.50


follow-up on organizingfiles for travel to NOLAfor trial 0.50

11-Oct-12 Brannon Review and exchange e-mails about propose stipulation 0.40

11-Oct-12 Brannon Review and analyze proposed stipulation 0.20

11-Oct-12 Brannon Attorney work product finalized trial exhibit list 0.50

11-Oct-12 Brannon Review and exchange e-mails about exhibit list 0.50

11-Oct-12 Brannon Attorney work productdrafted witnessexamination outlines 2.50

12-Oct-12 Brannon


regarding trialpreparation 1.00


12-Oct-12 Brannon Review and exchange e-mailsabout handling of finalexhibit list 0.20


12-Oct-12 Brannon Review and exchange e-mails about final witness lists 0.30

12-Oct-12 Brannon Review and exchange e-mails stipulation 0.30

12-Oct-12 Brannon Review and analyzeedits to proposedstipulation 0.10

12-Oct-12 Brannon Attorney work productworked on trial prep[redacted] 0.50

12-Oct-12 Brannon Review and exchange e-mails about trial transcripts 0.10

12-Oct-12 Brannon Attorney work product trial prep - [redacted] 5.75



prep for witnessexamination of DCFSwitnesses 5.50

13-Oct-12 Brannon Attorney work producttrial prep, including[redacted[ 3.50

13-Oct-12 Brannon Attorney work producttrial prep related toDCFS witnesses 3.25

13-Oct-12 Brannon travel time 5.00

14-Oct-12 Brannon Prepare for oral argument re: motions in limine 3.50

14-Oct-12 Brannon Attorney work productprep for examination ofDCFS witnesses 2.50

14-Oct-12 Brannon Attorney work product trial prep - [redacted] 8.50

15-Oct-12 Brannon Attorney work productprep for examination ofDCFS witness next day 1.75

15-Oct-12 Brannon Attorney work producttrial prep - prepared forDCFS witnesses 2.75


prep for [[redacted]attended andparticipated in trial 8.50

15-Oct-12 Brannon Attorney work product witness prep r[redacted] 2.50


trial - 8:00 am till 5:15,1.5 for lunch, plus trialprep for the day 9.50

16-Oct-12 Brannon Attorney work productprepared for potentialDCFS witnesses 2.25

17-Oct-12 Brannon Attorney work product prep for DCFS witnesses 0.40

17-Oct-12 Brannon Attorney work product attended trial and prep 3.75

17-Oct-12 Brannon Attorney work product trial prep [redacted] 1.10

19-Oct-12 Brannon Review and analyze email about [redacted] 0.10

19-Oct-12 Brannon Review and analyzeemail form D. Ho aboutpost trial brief 0.10

19-Oct-12 Brannon travel timefrom New Orleans aftertrial 3.90

21-Oct-12 Brannon Review and analyzeemails from co-counselabout [redacted] 0.20

23-Oct-12 Brannon Review and exchange e-mails

with co-counsel aboutmotion to amend casecaption 0.10

23-Oct-12 Brannon Review and exchange e-mailswith co-counsel abouttrial transcripts 0.20

24-Oct-12 Brannon Attorney work productreviewed and worked onoutline for post trial brief 0.50

25-Oct-12 Brannon Attorney work productreviewed and worked onpost trial brief 0.70

25-Oct-12 Brannon Review and exchange e-mails trial transcripts 0.10

25-Oct-12 Brannon Review and exchange e-mails changing case caption 0.10

25-Oct-12 Brannon Review and exchange e-mailsregarding motion toadmit facts 0.30

26-Oct-12 Brannon Review and exchange e-mails changing case caption 0.10


26-Oct-12 Brannon Review and exchange e-mailsabout filing motion toadmit facts 0.20

26-Oct-12 Brannon Review and exchange e-mails post trial brief 0.40

26-Oct-12 Brannon Review and exchange e-mails trial transcripts 0.10

26-Oct-12 Brannon Review and revise draft post trial brief 0.80

27-Oct-12 Brannon Attorney work product call to [readcted] 0.10

27-Oct-12 Brannon Attorney work productdiscussion with M. Ruppabout [redacted] 0.30

27-Oct-12 Brannon Review and exchange e-mailsre: corrections to trialtranscript 0.10

27-Oct-12 Brannon Review and exchange e-mails

re: memorandum foradmissions of disputesfacts from Def. earlyfilings 0.70

27-Oct-12 Brannon Review and revise draft post-trial brief 0.50

29-Oct-12 Brannon Review and exchange e-mails post trial brief 0.80

29-Oct-12 Brannon Review and revise draft post-trial brief 0.80

29-Oct-12 Brannon Research post trial brief 0.50

30-Oct-12 Brannon Review and exchange e-mails about post trial brief 0.30

30-Oct-12 Brannon Review and exchange e-mails about trial transcripts 0.10

31-Oct-12 Brannon Draftand edited portions ofthe post-trial brief 2.40

31-Oct-12 Brannon Review and exchange e-mails about post trial brief 0.30

1-Nov-12 Brannon Attorney work productreviewed proposed[redacted] 0.10

1-Nov-12 Brannon Review and exchange e-mailswith litigation team aboutpost trial brief 0.40

1-Nov-12 Brannon Draftand edited portions ofthe post trial brief 0.20

1-Nov-12 Brannon Review and exchange e-mails [redacted] 0.10

2-Nov-12 Brannon Review and exchange e-mails [reacted] 0.10

2-Nov-12 Brannon Review and exchange e-mails post trial brief 0.30


8-Nov-12 Brannon

Participate in telephoneconference with litigation team re: post trial brief 1.30

8-Nov-12 Brannon Review and analyze draft of post trial brief 0.40

9-Nov-12 Brannon Review and revise draft post trial brief 0.20

9-Nov-12 Brannon Review and exchange e-mails [readcted] 0.10

9-Nov-12 Brannon


with M. Rupp regarding[redacted] 0.40

9-Nov-12 Brannon Review and exchange e-mailsre: filing case captionchange 0.20

9-Nov-12 Brannon Review and exchange e-mails re: post trial brief 0.20



13-Nov-12 Brannon Review and exchange e-mails trial transcripts 0.10

13-Nov-12 Brannon Review and revise draft case caption motion 0.10

13-Nov-12 Brannon Review and analyze [redacted] 0.60



14-Nov-12 Brannon Review and analyze [redacted 0.60

14-Nov-12 Brannon Review various e-mails case caption motion 0.10


15-Nov-12 Brannon

Participate in telephoneconference call re: post trial brief 0.50





19-Nov-12 Brannon Review various e-mails filing post trial brief 0.10

20-Nov-12 Brannon

Review and analyze filing bydefendant/defendants re: case caption 0.10

20-Nov-12 Brannon Review various e-mailsfiling related to casecaption 0.10

22-Nov-12 Brannon

Telephone conference call withteam about post trial brief 0.50

27-Nov-12 Brannon Attorney work product [redacted] 0.40

27-Nov-12 Brannon


evidence in post trialbrief 0.20


28-Nov-12 Brannon

Participate in telephoneconference with litigation team about [redacted] 0.70


29-Nov-12 Brannon Draft [redacted] 2.50


30-Nov-12 Brannon Review and revise draft [redacted] 1.20

total 702.1

89.7 of which is travel time


Nicole Kovite Zeitler Time Sheet

EXHIBIT B - Nicole Zeitler Time Records

Date

Staff

name Task and description hours

1/3/2011 Zeitler

Review and draft retainer agreements for

individual and organizational plaintiffs. 1

1/3/2011 Zeitler

Review and draft letter to state notifying

of Section 7 violations [redacted] 1

1/3/2011 Zeitler

Conference call with [redacted] re: case

strategy. 0.5

1/4/2011 Zeitler [redacted] Attorney work product 0.5

1/4/2011 Zeitler Meeting with [redacted] litigation team 0.2

1/4/2011 Zeitler

Draft correspondence to [redact] re: co-

counsel agreement 0.1

1/4/2011 Zeitler Receipt and review of emails [redacted] 0.2

1/4/2011 Zeitler [redact] complaint drafting 0.2

1/4/2011 Zeitler

Tel conference [redact] re: development

of case 0.6

1/4/2011 Zeitler

Receipt and review of information sent

from DHH in response to request for

information [redacted] 2

1/4/2011 Zeitler

Draft correspondence [redact] litigation

team. 0.1

1/5/2011 Zeitler

Tel conference [redact] re: notice letter

and case development 0.4

1/5/2011 Zeitler

multiple emails to [redact]; [redact];

and [redact] re: notice letter and

meetings re: same. 0.5

1/11/2011 Zeitler Receipt and review of email [redact] 0.5

1/11/2011 Zeitler Draft correspondence[redact] 0.2

1/18/2011 Zeitler

Receipt and review of email

correspondence [redact] 0.2


2/3/2011 Zeitler

Correspondence to and from [redact]

litigation team re: meetings with client

and case strategy 0.4

2/4/2011 Zeitler

Correspondence to and from [redact] re:

meetings with client and timeline. 0.3

2/7/2011 Zeitler

Telephone call to Cecilia Cangelosi re:

SOS response to letter and draft

correspondence to [redact] re: same 0.2

2/8/2011 Zeitler

Draft email to [redact] re: call to C.

Cangelosis of SOS office. 0.1

2/9/2011 Zeitler Draft Complaint 0.4

2/9/2011 Zeitler

Participate in strategy conference calls

[redact] 1.1



2/9/2011 Zeitler

Meeting with [redact] re: strategy for

drafting of complaint and draft email

correspondence re: same 0.2

2/9/2011 Zeitler

Correspondence from [redact] re: plaintiff

correspondence and response thereto 0.2

2/9/2011 Zeitler

Draft correspondence to [redact] re:

efforts to connect with Office of Secretary

of State re: notice letter 0.1

2/10/2011 Zeitler

Receipt and review correspondence

from[redact] enclosing draft of complaint

and review of same 0.4


2/10/2011 Zeitler

Correspondence to C. Cangelosi -

response to her call 0.1



2/16/2011 Zeitler [redact] 1.5

2/17/2011 Zeitler Conf call with [redact] re: next steps 0.3

2/17/2011 Zeitler

Review emails from[redact] re: plaintiff

information 0.2

2/17/2011 Zeitler

Draft email to [redact] re: [redact] for

possible preliminary injunction motion 0.1

2/17/2011 Zeitler Email to [redact] re: discovery [redact] 0.1

2/17/2011 Zeitler

Email to [redact] re: meeting with plaintiff

for facts for complaint 0.1

2/18/2011 Zeitler

Receipt and review of letter from SOS re:

response to notice letter and meeting

with[redact] re: same and draft

correspondence to [redact]and draft

correspondence to [redact] re: same and

receipt and review of responses

from[redact] 0.6

2/18/2011 Zeitler

Meeting with [redact] re: data from

survey in order to respond to letter from

SOS 0.6

2/18/2011 Zeitler

Draft emails to [redact] re: response to

SOS 0.2

2/18/2011 Zeitler

Draft letter in response to SOS reply to

notice letter 0.6

2/18/2011 Zeitler

Conf call with [redact] re: [redact]

responding to SOS reply to notice letter 0.5

2/18/2011 Zeitler

Meeting with [redact] re: [redact]

responding to SOS reply to notice letter 0.1

2/18/2011 Zeitler

Draft emails to[redact] re: information

from client surveys in order to draft

response to SOS reply to notice letter 0.2



2/22/2011 Zeitler

Continue to draft response letter to

SOS,[redact] 3.5

2/22/2011 Zeitler Draft email [redact] 0.3

2/22/2011 Zeitler

Emails [redact] re: survey data including

phone surveys in order to drat response

to SOS 0.4

2/23/2011 Zeitler

Receipt and review of email from [redact]

enclosing edits to draft letter and review

of enclosed and response thereto 0.3

2/23/2011 Zeitler

Draft emails and receipt and review of

emails from [redact] re: sending out SOS

response and content 0.3

2/23/2011 Zeitler

Meeting with [redact] Re: edits to

Complaint and draft email re: same 0.2

2/23/2011

Receipt and review of emails from

[redact] re: SOS reply and review of edits

and draft response 0.4

2/23/2011 Zeitler Email from [redact] re: response to SOS 0.1

2/24/2011 Zeitler

Meeting [redact] re: [redact] response to

SOS and draft email to [redact] re same 0.2

2/24/2011 Zeitler

Review benefits forms and other

information available on Louisiana

websites in order to draft complaints, and

multiple emails back and forth with

[redact] re: same and response to SOS 1.3

2/25/2011 Zeitler

Multiple emails back and forth with

[redact] re: response letter to SOS and

draft same 1.5

2/25/2011 Zeitler

Meetings with [redact] re: data and facts

and drafting complaint 0.4

2/28/2011 Zeitler

Emails[redact] for drafting complaint

[redact] 0.3

2/28/2011 Zeitler

Emails from [redact] re: timeline for

drafting complaint [redact] 0.3

3/1/2011 Zeitler

Emails back and forth with [redact] re:

meetings with clients 0.2

3/1/2011 Zeitler Call to Client and conference [redact] 0.2

3/2/2011 Zeitler Emails back and forth with[redact] 0.3

3/8/2011 Zeitler

Preparation for and meeting with [redact]

in preparation for drafting complaint and

to discuss facts of case. 1

3/18/2011 Zeitler

Draft email to [redact] requesting

information for purposes of drafting

compliant and receipt and review of

response email 0.2

3/18/2011 Zeitler Draft Complaint 5

3/19/2011 Zeitler Emails to and from [redact] re: complaint 0.3



3/21/2011 Zeitler

Draft email to [redact] re: motion for

preliminary injunction 0.1

3/21/2011 Zeitler

Correspondence to [redact]enclosing

information from PV survey for purposes

of drafting complaint 0.1

3/21/2011 Zeitler


correspondence from [redact] 0.1

3/23/2011 Zeitler Travel to NOLA 4

3/23/2011 Zeitler

Visit DCFS and DHH offices in anticipation

of filing complaint 3

3/24/2011 Zeitler


of filing complaint 4

3/25/2011 Zeitler


of filing complaint 3.4

3/25/2011 Zeitler Travel from NOLA 4


4/1/2011 Zeitler

Tel conference with [redact] re:

complaint draft 0.3

4/4/2011 Zeitler Continue to edit complaint 2

4/4/2011 Zeitler

email correspondence to and from

[redact] re: complaint 0.2

4/4/2011 Zeitler review of state election statutes [redact] 0.6

4/4/2011 Zeitler

Receipt and review of email re: filing of

complaint [redact] 0.2

4/4/2011 Zeitler

Receipt and review of emails [redact] for

filing complaint and defendants 0.3

4/5/2011 Zeitler

Meeting [redact] and review of local rules

re: filing complaint and draft


4/5/2011 Zeitler

Draft correspondence [redact] for filing

complaint and communicating with

clients. 0.1

4/5/2011 Zeitler

Draft email to [redact] re: filing

complaint [redact] 0.3

4/5/2011 Zeitler

Email [redact] enclosing letter to client

and response re: same 0.2

4/5/2011 Zeitler

Email [redact] enclosing draft complaint

and response thereto 0.2

4/6/2011 Zeitler

Conference call with co-counsel to discuss

strategy 1

4/6/2011 Zeitler

Meeting [redact]to discuss strategy for

discovery and preliminary injunction 0.5

4/6/2011 Zeitler

Continue to draft motion for expedited

discovery 0.3

4/6/2011 Zeitler

Email [redact] re: timeline for filing

compliant [redact] 0.3

4/7/2011 Zeitler

Continue drafting motion for expedited

discovery 0.2



4/7/2011 Zeitler

Correspondence to [redact] enclosing

draft of motion for expedited discovery 0.1

4/7/2011 Zeitler Draft emails [redact] 0.4

4/7/2011 Zeitler Conference call [redact] 0.8

4/7/2011 Zeitler Meeting with [redact] 0.3

4/7/2011 Zeitler Emails [redact]re: discovery [redact] 0.3

4/7/2011 Zeitler Draft initial interrogatories to DCFS 4.5

4/8/2011 Zeitler

Email correspondence from [redact] re:

plaintiffs and response thereto 0.2

4/8/2011 Zeitler

Email correspondence from [redact]

enclosing client communication and

response thereto 0.2

4/8/2011 Zeitler conference with co-counsel re: [redact] 0.3

4/8/2011 Zeitler

Emails from and to [redact] re: finalizing

complaint 0.3

4/11/2011 Zeitler

Continue to finalize complaint including

meetings [redact] 3

4/11/2011 Zeitler

Conference call with [redact] re:

complaint and strategy 0.5

4/11/2011 Zeitler Emails to and from [redact] r: complaint 0.2

4/11/2011 Zeitler

Conference calls with [redact] re: survey

data for purposes of finalizing complaint 0.4

4/11/2011 Zeitler Continue to edit complaint 0.2

4/11/2011 Zeitler

Communication with [redact] for

purposes of finalizing complaint 0.1

4/12/2011 Zeitler

Conference call with [redact] re: filing of

complaint and motion for expedited

discovery 0.2

4/12/2011 Zeitler

Emails to [redact] and [redact] re: SNAP

application data in complaint 0.3

4/12/2011 Zeitler

Review of possible additional SNAP

application data [redact] for inclusion in

complaint 0.5

4/12/2011 Zeitler Email from [redact] re: filing of complaint 0.1

4/12/2011 Zeitler

Conference calls with [redact] re: data in

complaint 0.4

4/12/2011 Zeitler Work on Complaint 3

4/12/2011 Zeitler

Meetings with [redact] for purposes of

creating graphs and inputting information

on facts of case into complaint 2

4/12/2011 Zeitler

Emails from [redact] re: client and filing

compliant 0.3

4/13/2011 Zeitler

Phone conference with [redact] re:

motion for expedited discovery 0.1

4/13/2011 Zeitler

Meeting with [redact] re: [redact]

preliminary injunction motion 0.3



4/13/2011 Zeitler Conf call with [redact] 0.2

4/13/2011 Zeitler Emails to [redact] 0.3

4/14/2011 Zeitler

Legal research in preparation for motion

for expedited discovery 0.7

4/14/2011 Zeitler Conference call with [redact] 1

4/15/2011 Zeitler Conf calls with [redact] 0.7

4/17/2011 Zeitler Conf call with [redact] 0.4

4/18/2011 Zeitler Continue to work on complaint - [redact] 0.4

4/18/2011 Zeitler Emails and calls with [redact] 0.9

4/19/2011 Zeitler conf call with co-counsel [redact] 0.6

4/19/2011 Zeitler

Emails, calls, to co-counsel and final

review of complaint prior to filing. 0.7

4/19/2011 Zeitler

Draft notice of 30(b)(6) deposition of

DCFS 0.4

4/20/2011 Zeitler

Emails from [redact] re: filing of

complaint and review of filed documents

and email [redact] 0.5

4/20/2011 Zeitler Receipt and review of email from [redact] 0.3

4/20/2011 Zeitler Emails to and from co-counsel [redact] 0.4

4/25/2011 Zeitler


enclosing receipt of summons 0.1

4/25/2011 Zeitler


re: motion to expedite discovery; edit

motion; draft responses thereto 0.6

4/25/2011 Zeitler

Review of preliminary injunction hearing

transcript from case involving similar

claims for purpose of properly drafting

discovery requests in preparation for

motion for preliminary injunction 2.4

4/26/2011 Zeitler Conf call with co-counsel [redact] 0.5

4/26/2011 Zeitler

Email correspondence from [redact] re:

discovery timelines and response thereto 0.2

4/26/2011 Zeitler Continue to edit interrogatories to DCFS 1

4/27/2011 Zeitler Emails from [redact] 0.2

4/27/2011 Zeitler

Draft letter to opposing counsel RE;

expedited discovery and draft email to

[redact] 0.7

4/27/2011 Zeitler

Email from [redact] re: correspondence

to opposing counsel re: expedited

discovery 0.1

4/27/2011 Zeitler Continue to draft interrogatories to DCFS 1

4/27/2011 Zeitler

Draft Requests for Admission to DCFS and

meet with [redact] re: same 1.2



4/28/2011 Zeitler


re: additional edits to interrogatories to

DCFS and draft additional edits and draft

email response to [redact] re: same 0.4

4/28/2011 Zeitler

Draft requests for production of

documents to DCFS 0.7

5/4/2011 Zeitler Emails from [redact] 0.2

5/4/2011 Zeitler

Draft notice of 30(b)(6) deposition for

DCFS 0.5

5/6/2011 Zeitler

Conference call with [redact] re:

[redact] expedited discovery 0.4

5/6/2011 Zeitler

Email from [redact] re: upcoming

magistrate conference and response re:

same 0.3

5/6/2011 Zeitler

Emails re: discovery and upcoming

conference with magistrate with [redact]. 0.3

5/9/2011 Zeitler


re: magistrate conference. 0.1

5/9/2011 Zeitler

Conf call with [redact] re: conference

with court and next steps. 0.3

5/9/2011 Zeitler

receipt and review of emails from

[redact] re: letter to o/c and next steps 0.2

5/10/2011 Zeitler

Receipt and review of orders by the court

granting Def motion for additional time to

answer and docket entry re: status

conference 0.2

5/10/2011 Zeitler Call to Client [redact] 0.1

5/10/2011 Zeitler

Conf call with [redact] re: letter to o/c

re: discovery schedule 0.1

5/10/2011 Zeitler

Conference with [redact] re: letter to o/c

re: discovery schedule 0.1

5/10/2011 Zeitler

Participate in conference call with Client

[redact] 0.3

5/10/2011 Zeitler Edit letter to o/c re: discovery schedule 0.4

5/10/2011 Zeitler


to client [redact] 0.1

5/10/2011 Zeitler

Draft email to [redact] enclosing edits to

letter to O/C re: discovery timeline 0.1

5/16/2011 Zeitler

Emails from and to [redact] re: next

steps 0.2

5/16/2011 Zeitler

Continue to draft Request for Admission

to SOS 0.3

5/18/2011 Zeitler

Emails to [redact] re: next steps :

request for meeting and confer with o/c

and responses thereto 0.4



5/19/2011 Zeitler

Conf call with [redact] re: strategy for

discussions with o/c re: meet and confer 0.2

5/20/2011 Zeitler

Receipt and review of correspondence

from o/c re: request for meet and confer

and emails back and forth with [redact]

re: same and review of edits from

[redact] re: 30(b)(6) notice of deposition

to SOS and draft email re: same and set

meeting with co-counsel [redact] 0.6

5/23/2011 Zeitler

Prepare for strategy call with co-counsel

re: next steps in talks with o/c and meet

with [redact] 0.8

5/23/2011 Zeitler


re: meet and confer with o/c and draft


5/23/2011 Zeitler

Draft initial 26(a)(1) and 26(f) disclosures

and research related thereto 2.5

5/23/2011 Zeitler

Draft email to [redact] re: draft of

disclosures; meetings with [redact] re:

same 0.3

5/23/2011 Zeitler

Receipt and review of motion to enroll and

motion to enroll and substitute lead

counsel and order from court granting

motion to enroll Amy Colby as lead

counsel 0.3

5/24/2011 Zeitler prepare for 26(f) conference with o/c 0.4

5/24/2011 Zeitler Participate in 26(f) conference with o/c 0.5

5/24/2011 Zeitler

Conference call with co-counsel re:

strategy and next steps re: 26(f)

submission 0.6

5/25/2011 Zeitler

Conference call with [redact] re: 26(f)

submission and strategy 0.2

5/25/2011 Zeitler Draft 26(f)submission 2

5/26/2011 Zeitler


enclosing draft 26(f) submission and

continue to edit draft and emails to

[redact] re: same 0.6

5/26/2011 Zeitler


re: 26(f) submission and call to o/c and

draft response to same 0.2

5/27/2011 Zeitler

Receipt and review of correspondence

from C. Cangeliosi and draft

correspondence to co-counsel [redact] 0.5

5/31/2011 Zeitler

Meetings with [redact] re: draft 26(f)

submission [redact] 0.7

5/31/2011 Zeitler

Meeting with [redact] re: case law and

strategy for conference with court 0.2



5/31/2011 Zeitler

Tel calls with [redact] re: 26(f)

submission 0.4

5/31/2011 Zeitler

Tel calls with [redact] re: 26(f)

submission 0.4

5/31/2011 Zeitler

Meeting with [redact] re: 26(f)

submission 0.5

5/31/2011 Zeitler


correspondence sent by C. Cangeliosi and

receipt and review of email from [redact]

re: same and respond to same 0.3

5/31/2011 Zeitler

Tel call with [redact] re: response to

Cangelosi issues re: 26(f) submission and

email to and from [redact] re: same 0.4

5/31/2011 Zeitler

Review and analysis of May 26 letter from

SOS and [redact] draft response letter

requesting information 3.3

6/1/2011 Zeitler

Review of case law in preparation for

Monday conference with court and

participation in conference with co-

counsel re: strategy 1.5

6/1/2011 Zeitler

Continue to draft response to o/c re:

documents 1.2

6/1/2011 Zeitler

Review of email from Cangelosi enclosing

drafts of 26(f) and draft email to [redact]

re: same 0.4

6/2/2011 Zeitler

Email to [redact] re: communication with

clients and receipt and review of response

thereto 0.2

6/2/2011 Zeitler

Receipt and review of edits to May 26

response [redact] 0.3

6/2/2011 Zeitler

Draft email to [redact] issue raised in

briefing 0.2

6/2/2011 Zeitler

emails from [redact] re: 26(f) submission

and letter to counsel and response to

same 0.3

6/2/2011 Zeitler

Draft email to [redact] re: letter to o/c in

response to May 26 letter and receipt and

review of response thereto 0.2

6/2/2011 Zeitler


re: status of discovery requests and draft

email re: same and receipt and review of

response 0.3

6/2/2011 Zeitler

Emails re: Request for Admission to DCFS

and edit same in light of May 26 letter 0.5

6/2/2011 Zeitler

Receipt and review of DCFS Motion to

Withdraw counsel 0.1



6/2/2011 Zeitler

Receipt and review of motion to dismiss

filed by DCFS and draft email to [redact]

Re; same 0.5

6/2/2011 Zeitler

Receipt and review of DHH motion and

filed papers relating to motion to dismiss

and meetings with [redact] 1.5

6/2/2011 Zeitler


[redact] and C Cangelosi re: 26(f)

submission 0.2

6/2/2011 Zeitler

Draft edits to correspondence to SOS re:

response to May 26 letter [redact] 0.7

6/2/2011 Zeitler

Edit discovery requests to update

information provided by SOS in May 26

letter and draft email to [redact] re:

same 1

6/2/2011 Zeitler

Receipt and review of motion to dismiss

filed by SOS and meeting with [redact] 1

6/3/2011 Zeitler

Receipt and review of emails and

meetings with [redact] re: filing of

complaint and review of final draft of

complaint 0.8

6/3/2011 Zeitler Participation in conference call [redact] 0.8

6/3/2011 Zeitler

Meeting with [redact] for the purpose of

drafting set of discovery for DHH and

creating draft of response to motion to

dismiss 0.5

6/3/2011 Zeitler

Receipt and review of final drafts of

discovery documents for DCFS from

[redact] and draft final edits and


6/6/2011 Zeitler

Legal research [redact]; development of

argument and preparation for 26(f)

conference with the magistrate judge,

emails and meetings with [redact] re:

same 3

6/6/2011 Zeitler

Participation in conference with

magistrate judge 1

6/6/2011 Zeitler

Participation in conference call with co-

counsel [redact] 0.5

6/6/2011 Zeitler

Meeting with [redact] re: next steps for

complying with orders from court an

discovery and motions 0.3

6/6/2011 Zeitler

Emails to and from [redact] re: strategy

and discovery next steps 0.3

6/6/2011 Zeitler Draft discovery requests to DHH 1.5



6/6/2011 Zeitler

Research [redact]in order to response to

issues raised by C. Cangelosi during

conference in anticipation of settlement

conference and issues related to discovery 0.5

6/7/2011 Zeitler

Emails and meetings re: discovery going

forward 1

6/8/2011 Zeitler

Tel conference [redact] re: conversation

with opposing counsel [redact] 0.4

6/8/2011 Zeitler Meeting with [redact] [re: settlement] 0.4

6/8/2011 Zeitler

Multiple emails, phone calls, and drafting

of edited discovery requests 1

6/8/2011 Zeitler Finalize discovery 3

6/8/2011 Zeitler

Tel conference with C. Cangelosi re:

notice of submission date and settlement

possibilities 0.3

6/9/2011 Zeitler

Meeting with [redact] re: research

[redact] 0.3

6/9/2011 Zeitler


enclosing [redact] [research]. 0.2

6/9/2011 Zeitler

Call to A. Colby re: notice of submission

date 0.1

6/9/2011 Zeitler


enclosing draft of RFA for DHH and edit

same and draft email response re: same 0.4

6/9/2011 Zeitler

Call to D. Cade re: notice of submission

date 0.1

6/10/2011 Zeitler

Tel conference with [redact] re: next

steps and discovery 0.2

6/10/2011 Zeitler DCFS Discovery 2.5

6/10/2011 Zeitler DHH Discovery 2.5

6/13/2011 Zeitler

Conference with [redact] re: motion for

extension 0.1

6/13/2011 Zeitler Email to [redact] re: extension motion 0.1

6/13/2011 Zeitler

Participation in conference call with

Mediator 0.5

6/13/2011 Zeitler

Meetings with [redact] legal research

[redact] 2.5

6/14/2011 Zeitler

conference call with [redact] re: next

steps an documents sent by state. 1

6/15/2011 Zeitler

Draft section on [redact] in response to

defendant motion to dismiss 2

6/15/2011 Zeitler

Meetings with [redact], [redact], and

[redact] re: legal research in order to

draft response to motion to dismiss 1

6/15/2011 Zeitler


motion to continue 0.4



6/16/2011 Zeitler

Receipt and review of order from court

setting status conference. 0.1

6/16/2011 Zeitler

Draft email to [redact] re: status of

motion 0.1

6/21/2011 Zeitler

Emails and meetings and draft letter to

o/c 1.5

6/21/2011 Zeitler

Draft reply to D's opposition to P's motion

to continue 1.5

6/22/2011 Zeitler Emails and calls re: reply brief 0.5

6/22/2011 Zeitler Call with court 0.3

6/22/2011 Zeitler Conf call with co-counsel [redact] 0.7

6/22/2011 Zeitler

Numerous emails and calls re: letter to

court re: discovery and send same

message 2.3

6/23/2011 Zeitler Emails and meetings re: letter to court 0.5

6/23/2011 Zeitler response motion, calls, meeting 5

6/23/2011 Zeitler Draft settlement proposal 3

6/24/2011 Zeitler

Emails from C. Cangelosi re: letter to

court and emails to and from co-counsel

and calls re: same 1

6/24/2011 Zeitler

Receipt and review of minute order from

court and email from co-counsel re: same 0.3

6/27/2011 Zeitler

Receipt and review of scan of letter from

DCFS to clients and emails and calls re:

same 1.5

6/27/2011 Zeitler

Emails from C. Cangelosi re: extension

and emails and calls with Co-counsel re:

same 0.5

6/28/2011 Zeitler

Calls with co-counsel and emails re:

discovery 0.6

6/28/2011 Zeitler Email from A. Colby 0.1

6/29/2011 Zeitler Emails [redact] [discovery] 0.7

6/29/2011 Zeitler Legal research [redact] 2.5

6/29/2011 Zeitler

Receipt and review of objections from

DCFS 0.4

6/29/2011 Zeitler

Receipt and review of objections from

DHH 0.4

6/30/2011 Zeitler Draft response to motion to dismiss 4

6/30/2011 Zeitler Receipt of motion to extend 0.1

6/30/2011 Zeitler Receipt of motion to extend 0.1

6/30/2011 Zeitler

Receipt and review of motion for time to

extend 0.1

7/6/2011 Zeitler

Preparation for settlement negotiations

with Defendants 1.5

7/6/2011 Zeitler

participation in settlement negotiation

with defendants and conference with

plaintiffs counsel re: same 1.5



7/12/2011 Zeitler

Participation in conf call with [redact] re:

preparation for settlement conference. 1.3

7/13/2011 Zeitler

Conf call with co-counsel regarding

strategy and meeting [redact] 0.5

7/13/2011 Zeitler

Work on Settlement draft and emails back

and forth with co-counsel re: same and

draft email enclosing proposal to

Defendants 0.5

7/13/2011 Zeitler

Conf call with [redact] re: strategy for

settlement 0.3

7/14/2011 Zeitler

Travel to New Orleans for Negotiation -

TRAVEL 4

7/14/2011 Zeitler Travel to and attend meeting with clients 2.5

7/14/2011 Zeitler

Discuss case and strategy meetings with

co-counsel in preparation for negotiation

and status conference with judge 2.5

7/15/2011 Zeitler

Preparation for and participation in

settlement negotiations with opposing

counsel 4

7/15/2011 Zeitler

Preparation for and participate in status

conference with judge and debrief

afterward for purpose of strategy 1.5

7/15/2011 Zeitler

TRAVEL to BWI from negotiations meeting

- TRAVEL 5

7/18/2011 Zeitler

Draft changes to settlement proposal

following negotiations. 2.4

7/18/2011 Zeitler

Email from D. Cade Re; initial disclosures

agreement and response thereto 0.2

7/18/2011 Zeitler

Receipt and review of email from C.

Cangelosi re: EAC contact for purposes of

settlement and response thereto and draft

email to co-counsel re: same 0.3

7/25/2011 Zeitler Conf call with [redact] [re:] discovery 0.5

7/25/2011 Zeitler

Review of order on discovery motions

from Magistrate for the purpose of

redrafting discovery requests per the

order and redraft discovery 0.9

7/25/2011 Zeitler

Draft email to co-counsel enclosing re-

drafted discovery requests and receipt

and review of email re: same 0.2

7/25/2011 Zeitler

Receipt of voicemail from A. Colby re:

proposed meeting and call A. Colby re:

same 0.2

7/26/2011 Zeitler

Conf call with [redact] and draft email to

[redact] re: strategy meeting 0.5

7/26/2011 Zeitler Conf call with Co-counsel [redact] 0.2



7/26/2011 Zeitler

Multiple emails back and forth with co-

counsel re: revisions to discovery and

draft revisions 0.5

7/26/2011 Zeitler

Emails from Defendants re: proposed next

negotiation time and confer with co-

counsel re: same and draft response

email to Defendants re: same 0.4

7/26/2011 Zeitler

Emails from [redact] re: meeting with

Client 0.2

7/26/2011 Zeitler

Tel conference with A. Colby re: proposed

meeting and call [redact] re: same and

send email to [redact] re: same 0.3

7/27/2011 Zeitler

Continue to revise discovery and draft

email to Defendants enclosing revisions in

discovery and draft emails to co-counsel

re: same 0.7

8/1/2011 Zeitler

Emails from C. Cangelosi re: email and

sent interrogatories and responses to

same and emails back and forth with


8/1/2011 Zeitler

Emails to and from [redact] re: client

calls [redact] 0.4

8/1/2011 Zeitler

Emails and calls back and forth with

[redact] re: initial disclosures [redact] 0.5

8/8/2011 Zeitler Preparation for negotiation with state 2

8/8/2011 Zeitler participate in negotiation with state 1.5

8/8/2011 Zeitler Post-call strategy with co-counsel 0.5

8/8/2011 Zeitler Email screenshots of Medicaid to [redact] 0.1

8/9/2011 Zeitler

Emails to and from [redact] re:

deposition notices 0.3

8/9/2011 Zeitler

Receipt and review of DHH Responses to

RFA 0.2

8/9/2011 Zeitler

Receipt and review of SOS Responses to

RFA 0.2

8/10/2011 Zeitler


discovery strategy 0.4

8/10/2011 Zeitler

Review of responses to RFAs and other

documents produced by defendants and

draft notices of deposition 2.5

8/10/2011 Zeitler Tel call with Doug Cade re: discovery 0.1

8/11/2011 Zeitler

Email from and to [redact] re: discovery

strategy for depositions 0.2

8/11/2011 Zeitler

Email from [redact] and response re:

discovery 0.2



8/11/2011 Zeitler

Receipt and review of email enclosing

response to documents request from C.

Cangelosi and draft email to [redact] re:

same 0.3

8/12/2011 Zeitler


responses to requests for production and

receipt and review of responses for

requests for production 1.5

8/15/2011 Zeitler

Emails w [redact] re: discovery and

meeting with [redact] re: same 0.7

8/15/2011 Zeitler

Receipt and review of email from D.

McCay requesting discovery document

and draft response re: same 0.2

8/15/2011 Zeitler

Conf call with [redact] and [redact] re:

discovery 0.3

8/15/2011 Zeitler

Email to o/c re: time to meet for

resuming negotiations 0.1

8/15/2011 Zeitler

Receipt and review of email from D.

McCay requesting discovery document

and draft response re: same 0.2

8/15/2011 Zeitler

Review of documents and draft second

RFA to Def Johnson and Meeting re:

[redact] 2.5

8/15/2011 Zeitler


discovery documents from SOS 0.4

8/16/2011 Zeitler

Email response from K. Humbles re:

negotiation meeting 0.1

8/16/2011 Zeitler

Review documents and draft outline for

discovery responses 0.7

8/16/2011 Zeitler

Emails to and from [redact] re: discovery

strategy 0.2

8/16/2011 Zeitler

Conf call with [redact] re: discovery

strategy 0.6

8/16/2011 Zeitler

Draft documents and begin organization

of documents produced by defendants in

anticipation of further discovery and

emails to and from [redact] re; same 0.5

8/16/2011 Zeitler


enclosing edits to RFA to DCFS and

continue to draft same 0.5

8/16/2011 Zeitler

Emails to [redact] and response there to

re: discovery from SOS 0.4

8/17/2011 Zeitler

Emails to [redact] re: discovery

preparation. 0.2

8/17/2011 Zeitler Draft deposition notice for DCFS 0.4

8/17/2011 Zeitler


[redact] re: deposition notice for DCFS

and draft changes related to same 0.4



8/17/2011 Zeitler


Cangelosi enclosing privilege log and

review of enclosure. 0.2

8/17/2011 Zeitler

Email from C. Cangelosi re: availability for

phone conference 0.1

8/18/2011 Zeitler

Emails and meeting with [redact] re:

deposition notices and attached discovery

documents 0.7

8/18/2011 Zeitler

Meetings with [redact] re: DCFS depo

notice and attached discovery requests

and strategy and current drafts and draft

email to [redact] re: same and receipt

and review of response thereto 1.5

8/18/2011 Zeitler

Email from [redact] re: discovery docs

from SOS and response thereto 0.2

8/18/2011 Zeitler

Receipt and review of email [redact] re:

receipt of SOS docs [redact] 0.3

8/18/2011 Zeitler

Meeting with [redact] re: cataloguing of

discovery documents received from SOS

and emails re: same 0.4

8/18/2011 Zeitler

Emails from [redact] re: documents

produced by SOS [redact] 0.5

8/18/2011 Zeitler

Emails to and from [redact] re: SOS

deposition notices 0.3

8/18/2011 Zeitler

Email from [redact] re: documents

produced by SOS 0.1

8/19/2011 Zeitler

Email and meetings with [redact] [re

discovery] 0.5

8/19/2011 Zeitler

Review of all DCFS documents produced

[redact] 5

8/19/2011 Zeitler

Emails from and to [redact] re:

documents produced by DCFS 0.4

8/19/2011 Zeitler Review of DHH documents [redact] 1.4

8/22/2011 Zeitler Email [redact] re: discovery review. 0.1

8/22/2011 Zeitler

Review of all DCFS documents produced

and draft summary of relevance and draft

strategy for use in upcoming depositions 6

8/22/2011 Zeitler

Receipt and review of privilege log from

SOS 0.2

8/22/2011 Zeitler

Email from [redact] [re discovery

summaries] 0.5

8/22/2011 Zeitler

Receipt and review of privilege log from

SOS 0.2

8/23/2011 Zeitler


negotiations with the state 0.3



8/23/2011 Zeitler


Cangelosi enclosing motion to transfer

and review of same and meeting with co-

counsel re: same and draft and receive

emails from co-counsel re: same and draft

[redact] 1.5

8/23/2011 Zeitler Email from [redact] re: deposition notices 0.1

8/23/2011 Zeitler

Continue review of all documents

produced by DCFS and draft outlines

[redact] 4.5

8/23/2011 Zeitler


re: discovery review of DHH docs and

response re: same 0.2

8/24/2011 Zeitler

Draft SOS and DCFS deposition notices

and email [redact] re: same 0.8

8/24/2011 Zeitler Email from [redact] [depositions] 0.4

8/24/2011 Zeitler

Emails back and forth with [redact] and

meetings re: SOS deposition notices 0.6

8/24/2011 Zeitler

Receipt and review of motion to enroll as

counsel for Schedler 0.1

8/24/2011 Zeitler

Review of documents for purpose of

drafting SOS deposition notices and draft

email to [redact] 0.5

8/25/2011 Zeitler Email to o/c re: negotiation meeting 0.1

8/25/2011 Zeitler

Email from A. Colby re: negotiation

meeting and email to [redact] re: same 0.2

8/25/2011 Zeitler

Review of DCFS documents and review of

case law and state regulations for

purposes of preparing for depositions and

numerous emails to co-counsel re: same 3

8/26/2011 Zeitler

prep and participate in call with opposing

counsel and post-call with [redact] [co-

counsel] 1.5

8/26/2011 Zeitler

Emails to and from C. Alexander re;docs

produced by Def Johnson 0.3

8/26/2011 Zeitler

Phone call with D. Cade re: documents

produced by DHH and emails to and from


8/29/2011 Zeitler

Receipt and review of motion to enroll as

counsel for Schedler 0.1

8/30/2011 Zeitler

Emails from and to [redact] re: discovery

drafts 0.4

8/30/2011 Zeitler


enclosing revised depositions notices 0.3

8/30/2011 Zeitler

Participate in conf call with [redact] re:

discovery strategy 0.8



8/30/2011 Zeitler Meeting with [redact] re: discovery 0.2

8/30/2011 Zeitler Email to [redact] re: discovery 0.1

8/30/2011 Zeitler

Receipt and review of emails [redact] re:

DHH doc review and review of enclosed

document outline 0.6

8/30/2011 Zeitler


enclosing caseworker deposition notice

and attachments and review of same and


8/30/2011 Zeitler

Email to [redact] re: documents

produced by SOS and response thereto

and email re: same 0.3

8/30/2011 Zeitler

Email from C. Cangelosi re: documents

produced by SOS and emails to [redact] 0.5

8/31/2011 Zeitler

Receipt and review of lengthy emails and

strategy outlines from [redact] and draft

response and email to [redact] re: same 0.7

9/7/2011 Zeitler

Draft email to [redact] re: discovery and


9/7/2011 Zeitler

Email from [redact] re: depositions and


9/8/2011 Zeitler

Draft outline of plan [redact] [for

depositions] 2.4

9/8/2011 Zeitler Meetings with [redact] re: [research] 0.7

9/8/2011 Zeitler

Edits and meetings and emails re: edits to

DCFS deposition notices 0.5

9/8/2011 Zeitler Draft Greenstein RFP 0.4

9/9/2011 Zeitler TEL call with [redact] re: discovery 0.5

9/9/2011 Zeitler Emails re: depositions with [redact] 0.2

9/12/2011 Zeitler

Emails from and to [redact] re:

deposition notices and discovery and edit

notices and meetings re: same 1

9/12/2011 Zeitler

Review of documents and discovery

responses from DCFS and draft outline of

documents that we need and other

outlines for use in depositions 4.5

9/13/2011 Zeitler Emails re: discovery with [redact] 0.3

9/13/2011 Zeitler Participate in conf call with [redact] 1.5

9/14/2011 Zeitler

Emails and meetings with [redact] re:

Deposition notices and RFA and RFP for

DHH and draft edits to all 4

9/14/2011 Zeitler

Emails from [redact] re: deposition notice

for SOS and meeting with [redact] re:

same 0.4

9/14/2011 Zeitler SOS depo notice meetings and emails 0.3

9/15/2011 Zeitler Finalize DCFS deposition notices 0.8



9/15/2011 Zeitler

Calls with [redact] re: finalizing DHH

depo notices and review of drafts and

email for finalize. 0.5

9/16/2011 Call with [redact] re: deps 0.2

9/16/2011 Zeitler

Research [redact] and review of

documents produced by SOS and draft

updated discovery 3.5

9/16/2011 Zeitler Call Amy Colby re: deps 0.1

9/16/2011 Zeitler Call Celia Cangelosi re: deps 0.1

9/19/2011 Zeitler Emails to [redact] re: depos 0.2

9/19/2011 Zeitler

call from A. Colby re: deps and email to


9/19/2011 Zeitler call from C. Cangelosi re: deps 0.1

9/21/2011 Zeitler


enclosing letter to DHH re: supplement

and emails to [redact] 0.4

9/22/2011 Zeitler

Review of documents produced by SOS

[redact] 3

9/23/2011 Zeitler

Numerous emails and calls with [redact]

re: depositions and meetings with

[redact] 1

9/23/2011 Zeitler

Continued review of documents from SOS

and draft summary of same for purposes

of discovery 4

9/23/2011 Zeitler

Review of options for deposition and

meeting with [redact] re: same [redact] 0.7

9/23/2011 Zeitler call to C. Cangelosi re: deps 0.1

9/26/2011 Zeitler conf call with [redact] 0.4

9/26/2011 Zeitler Email to A. Colby re: depos 0.1

9/26/2011 Zeitler

Review of documents produced by DCFS

and Draft letter to supplement and

meetings and emails with co-counsel re:

same 1.5

9/26/2011 Zeitler Tel call with C. Cangelosi 0.1

9/26/2011 Zeitler

Review of docs produced by SOS for

purposes of request to supplement; draft

request for supplement and emails and

meetings with co-counsel re: same 1

9/26/2011 Zeitler

Draft second request for admission to

SOS and emails to and from co-counsel

re: same 0.9

9/26/2011 Zeitler

Email to C. Cangelosi enclosing letter re:

supplement 0.1

9/27/2011 Zeitler Tell call to [redact] re: deps 0.1

9/27/2011 Zeitler

Numerous emails re: Depositions and

meetings with [redact] re: same 0.5

9/27/2011 Zeitler

Meetings with [redact] re: depo strategy

and emails to [redact] re: same 0.4



9/27/2011 Zeitler tel call with A Colby re: depos 0.3

9/27/2011 Zeitler

Draft letter to C. Cangelosi re: incomplete

interrogatories and email to [redact] and


9/27/2011 Zeitler

Draft email to C. Cangelosi enclosing

letter re: interrogatories 0.1

9/27/2011 Zeitler

Thorough review of EAC data produced by

SOS for purpose of drafting Second RFA

and draft of same 3

9/27/2011 Zeitler

Draft second RFP to SOS and emails to

and from [redact] re: same 1.6

9/28/2011 Zeitler

Emails and meeting [redact] re:

additional DCFS discovery and continue to

draft edits [redact] 1.2

9/28/2011 Zeitler

Emails to and from A Colby re;

depositions 0.2

9/28/2011 Zeitler Emails from C. Cangelosi 0.1

9/29/2011 Zeitler

Continue to draft additional discovery for

all defendants and emails and meetings

re: same 1

9/29/2011 Zeitler

Draft edits to RFA for DHH and meeting

with [redact] and email re: same 0.5

9/29/2011 Zeitler

Email to [redact] re: discovery to DHH


9/30/2011 Zeitler

Continue to draft discovery request for all

defendants and meetings an emails re:

same 3

9/30/2011 Zeitler Email to o/c enclosing discovery 0.1

9/30/2011 Zeitler

Email from A. Colbly re: dcfs tech depo

and email to [redact] re: same 0.2

9/30/2011 Zeitler

Review of documents produced by SOS

and meeting with [redact] and email re:

same for purpose of discovery 0.8

9/30/2011 Zeitler

Continue to draft discovery to SOS and

meetings and emails with [redact] re;

same 2.4

10/3/2011 Zeitler Calls with [redact] re: depositions 0.5

10/3/2011 Zeitler


deposition prep work 0.3

10/3/2011 Zeitler [redact] [deposition prep] 1.5

10/3/2011 Zeitler Email to A. Colby re: depositions 0.1

10/4/2011 Zeitler Emails to and from [redact] re: depos. 0.2

10/4/2011 Zeitler

Email to C. Cangelosi requesting discovery

requests in word format 0.1

10/5/2011 Zeitler Email from A. Colby re: depositions 0.1



10/5/2011 Zeitler

Review of materials to set SOS

depositions and send emails to [redact]

re; same 0.5

10/5/2011 Zeitler

Review of documents and determination

of deponents for SOS and draft email to


10/6/2011 Emails and meetings with [redact] 1

10/6/2011 Zeitler Meeting with [redact] 0.5

10/7/2011 Zeitler

Review of email from D. Cade re: DHH

discovery 0.1

10/7/2011 Zeitler

Receipt of email from C. Cangelosi

enclosing letter response and email to

[redact] re; same 0.2

10/7/2011 Zeitler

Receipt of email from C. Cangelosi

enclosing additional letter response and

email to [redact] re: same 0.2

10/10/2011 Zeitler

Emails from C. Cangelosi and emails with


10/11/2011 Zeitler

Email from and to [redact] re: response

to RFP 0.2

10/11/2011

Email from [redact] re: interrogatories

from SOS 0.1

10/11/2011 Zeitler Email to C. Cangelosi re: deps 0.1

10/11/2011 Zeitler

Email from [redact] re: SOS RFP and

responses thereto 0.2

10/11/2011 Zeitler

Email from C. Cangelosi re: depo schedule

and email to [redact] re; same 0.2

10/11/2011 Zeitler Draft interrogatory responses to SOS. 2.5

10/13/2011 Zeitler

Email from [redact] re: discovery prep

schedule and response thereto 0.2

10/13/2011 Zeitler Email to [redact] re: depo docs 0.1

10/13/2011 Zeitler


documents for production 0.4

10/13/2011 Zeitler

Send documents to [redact] for use in

production 0.4

10/13/2011 Zeitler Draft interrogatory responses to DCFS 8

10/14/2011 Zeitler

Emails to and from [redact] re; discovery

cutoffs and motions 0.4

10/14/2011 Zeitler

preparation for and participation in

meeting with [redact] re: deposition

prep 1

10/14/2011 Zeitler Meetings and emails with [redact] 0.7

10/14/2011 Zeitler

Review of documents and emails for

purposes of production 2.5

10/14/2011 Zeitler legal research [redact] 0.7

10/14/2011 Zeitler

Email to A. Colby re: depositions and

responses thereto and send email to




10/14/2011 Zeitler

Email to [redact] enclosing DHH docs for

purpose of production 0.1

10/14/2011 Zeitler Email to C. Cangelosi re: deps 0.1

10/14/2011 Zeitler

Response email from C. Cangelosi re:

deposition schedule and draft response

thereto and emails to [redact] re: same 0.4

10/14/2011 Zeitler

Additional email from C. Cangelosi re:

schedule and emails to [redact] re:s ame 0.4

10/14/2011 Zeitler

Email to [redact] re: depo schedule and

resonse thereto and email to C. Cangelosi

and T. Joes re: same 0.3

10/17/2011 Zeitler [redact] preparation for depositions 3

10/17/2011 Zeitler

Email from [redact] re: call with D. Cade

setting dpost 0.1

10/17/2011 Zeitler

Draft response to interrogatories from

SOS 2.5

10/17/2011 Zeitler

Emails to and from C. Cangelosi and

[redact] re: depositions schedule and

meeting re: same 0.5

10/17/2011 Zeitler


scheduling for SOS depos 0.3

10/17/2011 Zeitler

Email to C. Cangelosi re: meeting with

magistrate re: setting depos 0.1

10/17/2011 Zeitler

Emails with T. Jones and [redact] re:

scheduling 0.4

10/18/2011 Zeitler

Review of documents [redact] [and depo

prep] 4

10/18/2011 Zeitler

[redact] [depo prep] and draft outline for

tech depositions 3

10/18/2011 Zeitler

Emails to and from [redact] re: notices of

depositions 0.3

10/18/2011 Zeitler

Emails from [redact] re:production of

documents from deponents 0.3

10/18/2011 Zeitler

Meeting and emails with [redact] re:

creating outlines for DCFS depos 0.5

10/18/2011 Zeitler Deposition prep 2

10/18/2011 Zeitler

Emails to [redact] re: DCFS failure to

supplemnet and responses thereto 0.4

10/18/2011 Zeitler

Emails from [redact] enclosing draft

outlines for DCFS meeting re: same and

review same 0.5

10/18/2011 Zeitler Email from T. Jones re: depositions 0.1

10/18/2011 Zeitler

Continue to draft interrogatory responses

to SOS and meeting with [redact] re:

same 3

10/18/2011 Zeitler

Emaisl from T. Jones re: depositions and




10/18/2011 Zeitler

Meeting and emails with [redact] re: SOS

deposition subpoenas 0.4

10/18/2011 Zeitler

Meetings with [redact] re: SOS

Subpoenas 0.3

10/18/2011 Zeitler Emails to T. Jones re; depo start 0.2

10/18/2011 Zeitler

Emails back and foth with [redact] re:

production to SOS and review of

documents re: same 0.7

10/19/2011 Zeitler Emails and calls with [redact] re privilege 0.5

10/19/2011 Zeitler Legal research [redact] 0.9

10/19/2011 Zeitler Email to [redact] re: deposition notices 0.1

10/19/2011 Zeitler [redact] [depo prep] 2

10/19/2011 Zeitler Email to [redact] re: outlines 0.1

10/19/2011 Zeitler Draft outlines for deposition prep 2

10/19/2011 Zeitler

Draft letter to DCFS re: failure to

supplemnet and multiple emails with


10/19/2011 Zeitler

Review of DCFS documents and draft

outlines for depositinos 2.5

10/19/2011 Zeitler Email to [redact] re; DCFS documents 0.1

10/19/2011 Zeitler

Email to A. Colby enclosing letter re:

supplement 0.1

10/19/2011 Zeitler Draft outline for tech deposition for DCFS 2

10/19/2011 Zeitler

Email to [redact] re: caseworker outlines


10/19/2011 Zeitler


deposition notices and subpoenas for

production of documents 0.4

10/19/2011 Zeitler

Meetings with [redact] re: deposition

outlies 0.8

10/19/2011 Zeitler

Email from [redact] enclosing draft

outlines for caseworker deps and review

of same and meeting re: same 0.7

10/19/2011 Zeitler

Email from and to [redact] re:

deposiitons for DCFS 0.2

10/19/2011 Zeitler

Email to and from C. Alexander re:

supplemental production and draft email

to [redact] re: same 0.3

10/19/2011 Zeitler

Emails and calls with [redact] re:

prodcution to SOS 0.5

10/19/2011 Zeitler

Receipt and reiew of email from [redact]

enclosing draft rrogs to SOS and review of

same and response 0.8

10/20/2011 Zeitler

Meetings with [redact] re: deposition

notices and requests for production for

deponents 0.4



10/20/2011 Zeitler


depositions 0.3

10/20/2011 Zeitler


re: deposition notices 0.1

10/20/2011 Zeitler

Continue to draft outlines for deposition

drafts [redact] 3

10/20/2011 Zeitler

Emails to and from [redact] re: privilege

log for production to SOS 0.3

10/20/2011 Zeitler

Continue to draft interrogatories to SOS

and review of documents in order to

complete same and have several

meetings with [redact] 2.5

10/20/2011 Zeitler


for SOS and meetings re: same 0.6

10/21/2011 Zeitler [redact] preparing for Depos 2.5

10/21/2011 Zeitler

Receipt and review of notice of judge

change from court and emails and

meetings re: same 0.4

10/21/2011 Zeitler

Meeting with [redact] re: depositions and

email re: same with [redact] 0.6

10/21/2011 Zeitler Email from [redact] re: depo notices 0.1

10/21/2011 Zeitler Email to A. Colby re: tech depo 0.1

10/21/2011 Zeitler

Email to A. Colby enclosing final notices of

depositions 0.1

10/21/2011 Zeitler

Emails to and from [redact] re: DHH

discovery 0.3

10/21/2011 Zeitler

Calls with and emails re: process server

for purpose of serving Elsie Cangelosi and

Donna Durand 0.7

10/21/2011 Zeitler

Email from [redact] re: interrogatories to

SOS 0.1

10/21/2011 Zeitler


[redact] discovery for SOS 0.5

10/21/2011 Zeitler

Email to process server re: SOS service

and tel call re: same and email to


10/21/2011 Zeitler

Finalize SOS interrogatory responsonses

and emails to [redact] and meetings re:

same 2.5

10/24/2011 Zeitler

Emails to [redact] and receipt and review

of responses thereto re: strategy 0.3

10/24/2011 Zeitler Email to [redact] re: depos 0.1

10/24/2011 Zeitler

Meeeting with [redact] re: notices of

deposition and documents 0.3

10/24/2011 Zeitler Email from A. colby re: depos 0.1

10/24/2011 Zeitler

Email to process server re: service on

Cangelosi and Durand and response

thereto 0.2



10/24/2011 Zeitler


discovery responses to SOS 0.6

10/24/2011 Zeitler

Continue to finalize discovery responses

to SOS including emails and meetings

with [redact] re: same and draft edits 3

10/24/2011 Zeitler

Email from process server re: service on

Cangelosi 0.1

10/24/2011 Zeitler

Tel call with process server re: serving

Cangelosi 0.1

10/24/2011 Zeitler

Email to C. Cangelosi and T. Jones

enclosing depo notices and schedule 0.1

10/24/2011 Zeitler

Email to C. Cangelosi and T. Jones re:

schedule 0.1

10/25/2011 Zeitler Email to [redact] re; depo schedule 0.1

10/25/2011 Zeitler Email to and from [redact] 0.3

10/25/2011 Zeitler

Email from [redact] enclosing draft

outline and review of same and email to


10/25/2011 Zeitler

Email to [redact] enclosing outline and

emails re: same 0.4

10/25/2011 Zeitler

Review and edit outline [redact] and

send edits to [redact] 1.2

10/25/2011 Zeitler

Review of intro outline and email [redact]

re: same 0.5

10/25/2011 Zeitler Receipt and review of trial set by court 0.1


10/25/2011 Zeitler Email to A. Colby re: depos 0.1

10/25/2011 Zeitler Prepare for depositions 4.5

10/25/2011 Zeitler

Review of all documents and create

outlines for depositions 4

10/25/2011 Zeitler Email from and to A Colby re: depos 0.2

10/25/2011 Zeitler Emails to and from [redact] re: DHH docs 0.2

10/25/2011 Zeitler

Call from T. Jones and return call and

convo re: discovery 0.3

10/25/2011 Zeitler

Email to and from C. Cangelosi re: E.

Cangelosi address for service 0.2

10/25/2011 Zeitler

Receipt and review of response to RFA

from SOS and email to [redact] re: same 0.5

10/26/2011 Zeitler


[redact] re: outlines and edits 0.7

10/26/2011 Zeitler

legal research in preparation for

deposiitons 0.3

10/26/2011 Zeitler

Email from [redact] re: documents for

depositions and response thereto 0.2

10/26/2011 Zeitler

Email to [redact] re: depositions and




10/26/2011 Zeitler


deposition prep 0.5

10/26/2011 Zeitler Prepare for depositions 3

10/26/2011 Zeitler

Email from process server re: service on

Cangelosi and response thereto 0.2

10/26/2011 Zeitler

Tc from Elsie Cangelosi and emails


10/27/2011 Zeitler

Emails from [redact] re: MSJ outline and

tel call re: same 0.5

10/27/2011 Zeitler

Email to C. Alexander re: supplemental

docs 0.1

10/27/2011 Zeitler

Meetings with [redact] re: organizing

policies for DCFS VR in preparation for

depos 0.7

10/27/2011

Review of documents BATES numbered

for purposes of determining which

documents will be used in depos 2.5

10/27/2011 Zeitler

tc to C. Cangelosi re: depositions and


10/27/2011 Zeitler Tel conf with C. Cangelosi re: depos 0.1

10/27/2011 Zeitler

Emails to and from [redact] re: SOS

depos 0.3

10/28/2011 Zeitler

Email from [redact] enclosing PSJ outline

and review of same and edit same 0.5

10/28/2011 Zeitler

Email from [redact] enclosing index of

BATES numbered docs for purposes of use

in Depos and review of same for purpose

of preparing for depos 0.4

10/28/2011 Zeitler Email to [redact] re: deposition notices 0.1

10/28/2011 Zeitler

Call from and to process server re:

cangelosi 0.2

10/29/2011 Zeitler Email from [redact] re: DCFS depos 0.1

10/30/2011 Zeitler

prepare for depos including review and

revision of outlines for caseworker depos 3

10/30/2011 Zeitler

review of outlines and additional

documents in preparation for depositions 2

10/31/2011 Zeitler Meetings with [redact] re dcfs depos 0.5

10/31/2011 Zeitler

Emails to and from [redact] re: outlines

for DHH depos 0.2

10/31/2011 Zeitler

Review of responses from DHH to

discovery 0.5

10/31/2011 Zeitler

email from process server re: serviece for

SOS depos and response thereto 0.2

11/1/2011 Zeitler

Emails from and to [redact] re: depo

outlines 0.2

11/1/2011 Zeitler

Meetings with [redact] in preparation for

depositions 0.6



11/2/2011 Zeitler

Receipt and review of motion for partial SJ

and meetings re: same 1.5

11/2/2011 Zeitler

Work on documents for depositions and

send email to [redact] re: same 0.6

11/3/2011 Zeitler Numerous Emails with [redact] re: depos 0.7

11/3/2011 Zeitler Tel conference with [redact] re: strategy 0.7

11/3/2011 Zeitler

Emails to and from C. Alexander re: depos

and emails to [redact] re: same 0.4

11/3/2011 Zeitler Emails to [redact] re: tech depos 0.2

11/3/2011 Zeitler Email to [redact] re: discovery from SOS 0.1

11/4/2011 Zeitler

Meeting with [redact] re: strategy and


11/4/2011 Zeitler Tel call with C. Alexander re: depos 0.3

11/6/2011 Zeitler

Prepare for depos including total review

and organiztion of documents and outlines 5

11/7/2011 Zeitler Travel for DCFS Depos 5

11/7/2011 Zeitler Strategy meetings for dpos 3

11/8/2011 Zeitler Take DCFS Depos 6

11/9/2011 Zeitler Take DCFS Depos 6

11/10/2011 Zeitler DCFS depos 5

11/10/2011 Zeitler Travel 4

11/11/2011 Zeitler Call with [redact] re: DHH Depos 0.4

11/14/2011 Zeitler Travel to LA for DHH Depos 4

11/15/2011 Zeitler prepare for and take DHH tech depo 6

11/16/2011 Zeitler prepare for and attend depos 6

11/17/2011 Zeitler Prepare for and take DHH tech depo 3

11/17/2011 Zeitler Attend DHH depos 3

11/17/2011 Zeitler TRAVEL HOME FROM DHH DEPOS 4

11/18/2011 Zeitler Meeting with [redact] re: strategy 0.5

11/28/2011 Zeitler Emails to [redact] 0.2

11/28/2011 Zeitler

Meeting with [redact] re: motions and

strategy 0.6

11/28/2011 Zeitler

Receipt and review of Motion for Partial SJ

- SOS 0.5

11/28/2011 Zeitler

review research on issues related to

responding to motios from state. 0.5

11/28/2011 Zeitler

Reeipt and review of Motion for Partial SJ

from DCFS 0.5

11/29/2011 Zeitler

Receipt and review of order from court re:

set for oral argument re: PSJ 0.2

11/29/2011 Zeitler


enclosing draft of PSJ response and

review of enclosure 0.2

11/29/2011 Zeitler

Email from C. Cangelosi and emails to




11/30/2011 Zeitler

Emails with co-counsel re: new oral

argument date and need to extend 0.3

11/30/2011 Zeitler

Receipt and review of [redact] depos

from DCFS in preparation for creating MSJ 0.5

12/1/2011 Zeitler

Schedule/plan and strategize for MSJ and

email [redact] re: same 0.7

12/1/2011 Zeitler

Tel conf with E. Cangelosi re: date of

deposition 0.1

12/1/2011 Zeitler

Email to [redact] Re; serving E.

Cangelosi 0.1

12/2/2011 Zeitler

Meeting with [redact] re: response to M.

Partial SJ 0.5

12/2/2011 Zeitler

Emails with [redact] re: deposition

[redact] 0.3

12/2/2011 Zeitler

[redact] send emails re: deposition

summaries [redact] 0.8

12/2/2011 Zeitler

Review of deposition transcripts and

create strategy for summaries in

preparation for drafting MSJ 0.8

12/3/2011 Zeitler Review docs for SOS depos 3.5

12/4/2011 Zeitler Emails with [redact] re: PSJ response 0.3

12/4/2011 Zeitler

Edit motion for partial summary judgment

response 1.5

12/5/2011 Zeitler


communications with o/c and date of oral

argument 0.2

12/5/2011 Zeitler Receipt and review of client email 0.1

12/5/2011 Zeitler

Call and email to A. Colby re: moving date

of oral argument 0.2

12/5/2011 Zeitler

Call and email to C. Cangelosi re: moving

date of oral argument and response

thereto and draft response 0.4

12/6/2011 Zeitler [redact] [co-counsel conference call] 1

12/6/2011 Zeitler Call with [redact] 0.2

12/6/2011 Zeitler [redact] [deposition summaries] 0.5

12/6/2011 Zeitler

Email from [redact] re: deadlines for case

and response 0.2

12/6/2011 Zeitler Call to C. Cangelosi 0.1

12/6/2011 Zeitler

Call with C. Cangelosi and T. Jones re:

depos 0.3

12/6/2011 Zeitler

meeting with [redact] re: William

Crawford 0.2

12/6/2011 Zeitler Draft outlines for SOS depos. 5

12/7/2011 Zeitler

Email from Ebony Townsend enclosing

interrogatories 0.3

12/7/2011 Zeitler

Emails to and from Co-counsel re outlines

for depos 0.5



12/7/2011 Zeitler Calls with [redact] re: SOS depos 0.2

12/7/2011 Zeitler

Emails from T. Jones re: depositions and

W. Crawford and emails/call with co-

counsel re: same 1

12/7/2011 Zeitler Emails with [redact] re: depos 0.4

12/8/2011 Zeitler

Emails and calls with [redact] re: motion

to extend time for PSJ 0.5

12/9/2011 Zeitler Edit Motion response to PSJ 4

12/9/2011 Zeitler

Review of document in preparation for

Joanne reed depo 3

12/10/2011 Zeitler Continue drafting response to PSJ 4

12/10/2011 Zeitler

review of documents for purposes of

drafting outline for deposition for Joanne

reed. 1.5

12/12/2011 Zeitler

work on outlines and go through all

exhibits for SOS depos 6

12/13/2011 Zeitler Email to [redact] re: depos 0.1

12/13/2011 Zeitler

Email to C. Cangelosi and T. Jones re:

depos of Durand and Reed 0.1

12/13/2011 Zeitler

Meeting with [redact] re: strategy for

depositions and documents needed from

SOS 0.4

12/13/2011 Zeitler Prepare for depositions 3.5

12/13/2011 Zeitler

Emails to and from [redact] re: depos

and documents 0.4

12/13/2011 Zeitler email to T. Jones re: meeting 0.1

12/13/2011 Zeitler

Emails with [redact] and C. Cangelosi

re:depo schedules. 0.3

12/13/2011 Zeitler

Email to C. Cangelosi re: timing of Rogers

depo 0.1

12/14/2011 Zeitler

Call to and from T. Jones re: stipulation

and documents 0.2

12/14/2011 Zeitler


stipulation 0.4

12/14/2011 Zeitler Meeting with [redact] re: tech depo 0.2

12/14/2011 Zeitler

Emails with C. Cangelosi re: deposition

logistics 0.3

12/14/2011 Zeitler Draft outline for Joanne Reed Depo 2.5

12/15/2011 Zeitler prepare for depositions 6

12/15/2011 Zeitler

Numerous emails and phone call meeting

with [redact] RE: deposition strategy 0.5

12/15/2011 Zeitler

calls to C. Cangelosi and T. Jones re:

depositions and production 0.2

12/15/2011 Zeitler

Meeting with [redact] re: subpoenas for

E. Cangelosi deposition and emails with




12/15/2011 Zeitler

Meeting and email [redact] re:

information/data produced by SOS in

preparation for depositions 0.4

12/16/2011 Zeitler

Email from T. Jones re: documents for

production and emails from and to

[redact] re: same and draft response to

T. Jones re: same 0.4

12/16/2011 Zeitler

Prepare for deposition of Joanne Reed and

Diana Durand 4

12/16/2011 Zeitler

Email to T. Jones and C. Cangelosi re:

depos 0.1

12/16/2011 Zeitler meetings and emails re: depos for SOS 1.5

12/18/2011 Zeitler Travel to LA for depositions of SOS - 5

12/18/2011 Zeitler Preparation for LA SOS depositions 2

12/19/2011 Zeitler Depose Diana Durand 4.5

12/19/2011 Zeitler Depose Joanne Reed 4

12/19/2011 Zeitler

Strategy discussions with Co-counsel re:

Depositions of SOS 1

12/20/2011 Zeitler Attend deposition of Cate McRitchie 4

12/20/2011 Zeitler Attend Deposition of William Crawford 1

12/20/2011 Zeitler

Travel to Washington DC from SOS

Depositions 4

12/21/2011 Zeitler Emails to [redact] re: PSJ 0.4

12/21/2011 Zeitler

Email to E. Townsend re: discovery

request and receipt of response thereto 0.2

12/22/2011 Zeitler

Review of surveys for purposes of

responding to DCFS discovery 2.5

12/22/2011 Zeitler Call with [redact] re: discovery 0.2

12/26/2011 Zeitler

Email from [redact] re: PSJ brief and


12/27/2011 Zeitler Emails to [redact] re: PSJ 0.4

12/29/2011 Zeitler

Review surveys in order to draft

responses to DCFS and DHH [redact] 2

1/2/2012 Zeitler

Draft discovery responses to DHH and

DCFS 8

1/3/2012 Zeitler


responses 0.3

1/3/2012 Zeitler

Emails from and to [redact] re: response

to Motion for Partial SJ 0.2

1/3/2012 Zeitler

Receipt and review deposition of Donna

Durand for purposes of drafting MSJ 0.5

1/3/2012 Zeitler

Work on Discovery responses for DHH and

DCFS 3.5

1/3/2012 Zeitler


enclosing draft RFA response to DCFS and

review of same and edit and send back

response 0.4

1/4/2012 Zeitler Emails re: discovery submissions 0.3



1/4/2012 Zeitler


PSJ and review deposition transcripts re:

same 2.3

1/5/2012 Zeitler Emails and meetings [redact] 0.5

1/5/2012 Zeitler

Telephone Call to Elsie Cangelosi and

emails re: same 0.3

1/6/2012 Zeitler Review PSJ brief and edit same 2

1/6/2012 Zeitler Work on DCFS RFA 0.5

1/6/2012 Zeitler Work on DCFS rogs 1

1/7/2012 Zeitler emails to and from [redact] re: PSJ brief 0.3

1/8/2012 Zeitler

Emails and meetings with [redact] and

[redact] re: PSJ brief 0.5

1/9/2012 Zeitler

Meetings with [redact] and emails and

review of depositions for purpose of

editing PSJ brief 3

1/11/2012 Zeitler

Prepare for and participate in scheduling

conference with the court and meeting

with co-counsel re: same 0.9

1/11/2012 Zeitler Emails re: priv log for DHH 0.3

1/12/2012 Zeitler

emails re: new dates and deadlines

[redact] 0.4

1/13/2012 Zeitler Emails and meetings re: [redact] 0.5

1/17/2012 Zeitler Emails re: client 0.2

1/17/2012 Zeitler Call to E. Cangelosi and emails re: same 0.3

1/17/2012 Zeitler

Email from C. Cangelosi re: depos and

emails and meetings with Co-counsel re:

same 0.5

1/18/2012 Zeitler Emails re: depo requests from SOS 0.4


1/25/2012 Zeitler

Review of deposition transcripts for

purposes of MSJ 3.5

1/29/2012 Zeitler

Review surveys in order to draft

responses to DCFS and DHH Surveys 2

TOTAL 638.8

45.5 of which is travel time


Exhibit C - Niyati Shah Time Records


3-Jan-11 Shah

co counselconf call 0.5

3-Jan-11 Shah

edit witnessdeclaration 0.5

3-Jan-11 Shah edit notice ltr 0.5

10-Feb-11 Shah

edit/reviewquestionaire 0.4

25-Feb-11 Shah review ltr 0.4

21-Mar-11 Shah

review/editcomplaint 0.8

22-Mar-11 Shah

discuss SOSliability 0.3

29-Mar-11 Shah

review LAcomplaint 0.66

5-Apr-11 Shah

call rediscoverytimeline 1

5-Apr-11 Shah

researchchief electionofficial 0.4

7-Apr-11 Shah


7-Apr-11 Shah

reviewinterogatories 0.75

11-Apr-11 Shah

complaintreview 0.3

11-Apr-11 Shah


12-Apr-11 Shah

discussdiscoverscope 0.4

12-Apr-11 Shah

research PIlaw 0.66

12-Apr-11 Shah

review andeditdiscoverybrief 0.8

13-Apr-11 Shah

review andeditdiscoverybrief 0.8

14-Apr-11 Shah

email rediscoverydemand/scope 0.5

15-Apr-11 Shah


15-Apr-11 Shah review Rogs 0.75


17-Apr-11 Shah


19-Apr-11 Shah


21-Apr-11 Shah

reviewexpediteddiscoverybrief 0.75

26-Apr-11 Shah

co counselconf call 1

27-Apr-11 Shah

review ltr toopp counsel 0.4

27-Apr-11 Shah review RFA 0.6

28-Apr-11 Shah review RFP 0.6

4-May-11 Shah

review30(b)(6) 0.66

5-May-11 Shah

reviewinterogatories 0.7

10-May-11 Shah

review ltr todefendants 0.5

12-May-11 Shah

review SOSdiscoverydocs 0.2

13-May-11 Shah

reviewdiscoverydocs 0.66

23-May-11 Shah


23-May-11 Shah

discoverydocs 0.66

27-May-11 Shah

discussresponse toState 0.3

31-May-11 Shah


31-May-11 Shah

discuss 26(f)submission 0.5

1-Jun-11 Shah


1-Jun-11 Shah review ltr 0.1

3-Jun-11 Shah

discoverydocs 0.5

6-Jun-11 Shah


6-Jun-11 Shah review ltr 0.5

16-Jun-11 Shah MTD drafting 1.9

17-Jun-11 Shah MTD Drafting 1.4

21-Jun-11 Shah reply brief 2.2





27-Jun-11 Shah

reviewsettlemntagreement 0.8

27-Jun-11 Shah

discusscontinance 0.3

28-Jun-11 Shah

reviewsettlementagreement 0.8

29-Jun-11 Shah

review ltr tocounsel 0.4


1-Jul-11 Shah

reviewagreement 1.4

1-Jul-11 Shah

review ltr toopp counsel 0.1

5-Jul-11 Shah


5-Jul-11 Shah


6-Jul-11 Shah

settlementconferencecall 1.25

6-Jul-11 Shah

co counselconf call 1

6-Jul-11 Shah

settlementconferencecall 1.25

6-Jul-11 Shah

motion forextensin 0.8

6-Jul-11 Shah

motion forextension 0.4

8-Jul-11 Shah

reviewsettlementagreement 0.3

14-Jul-11 Shah

review/draftinitialdisclosures 0.9

19-Jul-11 Shah

review/editchanges tosettlementagreement 1

26-Jul-11 Shah review rogs 0.75

5-Aug-11 Shah

co counselsettlementprep 1.75

8-Aug-11 Shah



8-Aug-11 Shah

settlmentconf call 1.5

17-Aug-11 Shah

reviewdiscovery 4

18-Aug-11 Shah

reviewdiscovery 4

19-Aug-11 Shah

reviewdiscovery 4

22-Aug-11 Shah

reviewdiscovery 4

30-Aug-11 Shah


7-Sep-11 Shah


8-Sep-11 Shah

reviewdiscvoerydocs 0.2

14-Sep-11 Shah

discovery/depo docs 1.3

15-Sep-11 Shah

discovery/depo docs 0.3

22-Sep-11 Shah

deporesearch 0.2

26-Sep-11 Shah


26-Sep-11 Shah

review/discuss ltr rediscovery 0.4

27-Sep-11 Shah


28-Sep-11 Shah

reviewdiscoverydocs 1

18-Oct-11 Shah

draft depooutline 1.3

19-Oct-11 Shah

draft depooutline 1.4

19-Oct-11 Shah

discoverydraft review 0.5

20-Oct-11 Shah

subpoenareview 0.75

20-Oct-11 Shah review 0.2

27-Oct-11 Shah

email rerepresentation 0.2

31-Oct-11 Shah depo outline 2.4


1-Nov-11 Shah Depo Prep 1.8


2-Nov-11 Shah Review PSJ 0.8


6-Nov-11 Shah Depo Prep 7

7-Nov-11 Shah travel 5


8-Nov-11 Shah

Depos andDepo Prep 9

9-Nov-11 Shah

Depos andDepo Prep 9

10-Nov-11 Shah Depos 5

10-Nov-11 Shah travel 4

17-Nov-11 Shah PSJ 0.5



29-Nov-11 Shah Order 0.3

5-Dec-11 Shah

Review andexchange e-mails 0.20

5-Dec-11 Shah

Review andanalyze filingbydefendant/defendants 0.40

6-Dec-11 ShahReceivestatus update 0.20

6-Dec-11 Shah


6-Dec-11 Shah

Preparewitness fordeposition 0.50

7-Dec-11 Shah

Participate intelephoneconferencewith litigationteam 1.00

7-Dec-11 Shah


7-Dec-11 Shah


7-Dec-11 Shah

Reviewdiscoveryresponses 0.40


9-Dec-11 ShahResearchand prepare 0.40

9-Dec-11 Shah


10-Dec-11 ShahReview andrevise draft 0.70

12-Dec-11 Shah


12-Dec-11 Shah

Reviewdocumentsproduced indiscovery 0.50

13-Dec-11 Shah


13-Dec-11 Shah


14-Dec-11 ShahReview andanalyze Court Order 0.30

14-Dec-11 Shah


14-Dec-11 Shah


14-Dec-11 ShahReview andrevise draft 0.60

15-Dec-11 ShahReview andanalyze 0.60

16-Dec-11 Shah

Reviewdiscoveryresponses

EmployeeRecords 5.00

16-Dec-11 Shah


21-Dec-11 Shah


9-Jan-12 Shah



11-Jan-12 Shah


11-Jan-12 Shah

Participate intelephoneconferencecall w/ Court 0.50

12-Jan-12 ShahReview andanalyze

motion tocompel 0.30

12-Jan-12 Shah



CourtReschedulingOrder 0.20

13-Jan-12 Shah


16-Jan-12 Shah



motion tocompel, 3rdrfps 0.80

17-Jan-12 ShahPrepare fordepositions 3.50

18-Jan-12 Shah

Review andexchange e-mails

production ofdiscovery 0.50


follow up rediscovery 0.30

19-Jan-12 Shah



20-Jan-12 Shah

Review andincorporateedits 0.10

23-Jan-12 Shahoralargument PSJ 0.20

23-Jan-12 Shah

Draftdiscoveryresponses 0.40


24-Jan-12 ShahTalk withPlaintiffs 0.20


24-Jan-12 Shah



24-Jan-12 Shah


25-Jan-12 Shah


25-Jan-12 ShahReview andrevise draft

Outstandingdiscovery 0.30

25-Jan-12 Shah


25-Jan-12 ShahReview andrevise draft 0.30


25-Jan-12 Shah


26-Jan-12 Shah


26-Jan-12 Shah


27-Jan-12 Shah


27-Jan-12 Shah


27-Jan-12 Shah


27-Jan-12 Shah


29-Jan-12 Shah


29-Jan-12 ShahAttenddepositions Travel 4.50

30-Jan-12 Shah



30-Jan-12 ShahAttenddepositions 7.00

31-Jan-12 Shah


31-Jan-12 ShahAttenddepositions 4.00

31-Jan-12 ShahAttenddepositions travel 4.50

1-Feb-12 ShahReview andanalyze 0.50

1-Feb-12 ShahTalk withPlaintiffs 0.50

1-Feb-12 Shah


2-Feb-12 Shah Draft motion 1.60


2-Feb-12 Shah


2-Feb-12 Shah



2-Feb-12 Shah



2-Feb-12 Shah


3-Feb-12 Shah



3-Feb-12 Shah


3-Feb-12 Shah





7-Feb-12 Shah


7-Feb-12 Shah Research 0.50

7-Feb-12 Shah


7-Feb-12 Shah


7-Feb-12 Shah


8-Feb-12 Shah


8-Feb-12 Shah


9-Feb-12 Shah


10-Feb-12 Shah


10-Feb-12 Shah


13-Feb-12 Shah

Reviewdiscoverysummaries 0.40

13-Feb-12 Shah


14-Feb-12 Shah


15-Feb-12 Shah




16-Feb-12 Shah

Participate inpreparationfor oralargument 1.50

16-Feb-12 Shah


20-Feb-12 Shah


21-Feb-12 Shah


21-Feb-12 Shah


22-Feb-12 ShahReview andrevise draft 0.40

22-Feb-12 Shah


22-Feb-12 Shah


22-Feb-12 Shah


23-Feb-12 Shah


23-Feb-12 ShahResearchand prepare 0.66

23-Feb-12 Shah




24-Feb-12 Shah

Prepare forcourtconference 1.00


24-Feb-12 ShahAttend courtconference 1.00





28-Feb-12 Shah


29-Feb-12 Shah


1-Mar-12 Shah


1-Mar-12 Shah


2-Mar-12 Shah


2-Mar-12 Shah


5-Mar-12 Shah


6-Mar-12 Shah

Review andrevise draftmotion forsummaryjudgment 2.60

6-Mar-12 Shah


7-Mar-12 ShahReview andrevise draft 1.75

7-Mar-12 Shah


7-Mar-12 ShahReview andanalyze 0.66


8-Mar-12 Shah


8-Mar-12 Shah


9-Mar-12 Shah


9-Mar-12 Shah Draft motion 2.20

9-Mar-12 Shah


10-Mar-12 Shah


12-Mar-12 Shah


12-Mar-12 Shah


12-Mar-12 Shah


13-Mar-12 Shah


14-Mar-12 Shah


16-Mar-12 Shah


16-Mar-12 Shah


16-Mar-12 Shah



20-Mar-12 ShahReview andanalyze 0.50

21-Mar-12 ShahTalk withPlaintiffs 0.20

21-Mar-12 Shah


26-Mar-12 ShahResearchand prepare 0.30

26-Mar-12 Shah


27-Mar-12 Shah Research 2.66

27-Mar-12 Shah


28-Mar-12 Shah Draft memo 2.20

28-Mar-12 Shah Research 2.75

28-Mar-12 Shah


29-Mar-12 Shah


29-Mar-12 Shah


29-Mar-12 Shah Draft memo 2.30

29-Mar-12 Shah


29-Mar-12 Shah


30-Mar-12 ShahReview andrevise draft 0.66

30-Mar-12 ShahReview andrevise draft SJM 0.70

30-Mar-12 ShahReview andanalyze

ScottRelease 0.40

30-Mar-12 ShahReview andrevise draft MTS 0.75


30-Mar-12 Shah


30-Mar-12 Shah

Review andincorporateedits

Newdiscovery 0.66

2-Apr-12 ShahReview andrevise draft Surreply 0.75

2-Apr-12 Shah

Review andincorporateedits declaration 0.40

2-Apr-12 Shah Draft memo MTS Reply 0.70

2-Apr-12 Shah


2-Apr-12 ShahReview andrevise draft

Opp to Add'ldiscovery 0.66


Opp to Add'lDiscovery 0.66


Motion toStrike 0.60

4-Apr-12 Shah


6-Apr-12 Shah


6-Apr-12 ShahReview andrevise draft ltr re rogs 0.40

9-Apr-12 Shah


9-Apr-12 Shah


10-Apr-12 Shah


10-Apr-12 Shah



11-Apr-12 ShahReview andanalyze Order 0.50

13-Apr-12 Shah


13-Apr-12 Shah


13-Apr-12 ShahReview andanalyze order 0.40

15-Apr-12 Shah


15-Apr-12 Shah


16-Apr-12 Shah


16-Apr-12 ShahReview andrevise draft 0.75


17-Apr-12 Shah


17-Apr-12 Shah


17-Apr-12 Shah


17-Apr-12 Shah


18-Apr-12 ShahResearchand prepare 0.20

18-Apr-12 Shah


19-Apr-12 Shah travel time 4.50


20-Apr-12 ShahAttend oralargument 2.60

20-Apr-12 Shah travel time 4.50


23-Apr-12 Shah


23-Apr-12 Shah



24-Apr-12 Shah


25-Apr-12 Shah


25-Apr-12 Shah

Review draftsettlementagreement 0.75

26-Apr-12 Shah


27-Apr-12 ShahPrepare fordepositions 0.70

27-Apr-12 ShahReview andrevise draft 0.40

27-Apr-12 Shah


30-Apr-12 Shah



1-May-12 Shah


1-May-12 Shah



2-May-12 Shah


2-May-12 ShahTalk withPlaintiffs 0.20

3-May-12 Shah


3-May-12 Shah

Participate intelephoneconferencecall

meet andconfer 0.50

3-May-12 Shah Draftmeet andconfer 1.20

3-May-12 ShahReview andanalyze order 0.75

3-May-12 Shah


3-May-12 ShahResearchand prepare 0.75

4-May-12 Shah


4-May-12 ShahPrepare fordepositions 1.30

4-May-12 ShahReview andanalyze

deponotices/subpoenas 0.20




8-May-12 Shah Research 0.50

8-May-12 Shah travel time 4.00

8-May-12 Shah



9-May-12 ShahAttend courtconference 1.00


9-May-12 Shah


10-May-12 ShahAttenddepositions 4.00



11-May-12 Shah travel time 5.00

14-May-12 ShahReview andrevise draft 0.80

14-May-12 ShahAttorneywork product 0.20


15-May-12 Shah


15-May-12 ShahAttendmeeting

w/ SB andMR 0.15





18-May-12 Shah


18-May-12 Shah




22-May-12 ShahReview andanalyze discovery 0.40

22-May-12 ShahDraft motionfor sum jud 0.80


23-May-12 Shah


23-May-12 Shah



23-May-12 Shah


23-May-12 Shah




24-May-12 Shah


24-May-12 Shah

Participate intelephoneconferencecall w/ Court 0.25


24-May-12 Shah


24-May-12 Shah

Review andrevise draftdiscoveryresponses 0.40

25-May-12 Shah Draft 0.75

29-May-12 Shah






31-May-12 Shah Draft witness lists 0.40

1-Jun-12 ShahReview andanalyze

research rereconsideration 0.60

1-Jun-12 Shah


1-Jun-12 Shah


1-Jun-12 Shah


3-Jun-12 ShahReview andrevise draft SJ 0.50

3-Jun-12 ShahReview andrevise draft witness list 0.50

3-Jun-12 ShahPrepare fordepositions 0.40

3-Jun-12 Shah


4-Jun-12 Shah


4-Jun-12 ShahReview andanalyze order 0.20

4-Jun-12 Shah



4-Jun-12 Shah Draft letter 0.66

5-Jun-12 Shah travel time 4.00


5-Jun-12 Shah



6-Jun-12 ShahReview andanalyze Order 0.20

7-Jun-12 ShahReview andrevise draft witness list 2.30

7-Jun-12 ShahAttenddepositions 3.00

7-Jun-12 Shah


7-Jun-12 Shah


8-Jun-12 Shah travel time 4.00


8-Jun-12 Shah


9-Jun-12 ShahReview andrevise draft 0.40

10-Jun-12 Shah



10-Jun-12 Shah



11-Jun-12 Shah


12-Jun-12 Shah


12-Jun-12 Shah






15-Jun-12 ShahResearchand prepare 0.66

15-Jun-12 Shah


16-Jun-12 Shah



18-Jun-12 Shah


19-Jun-12 ShahReview andrevise draft letter 0.50

19-Jun-12 Shah


20-Jun-12 Shah


20-Jun-12 Shah


21-Jun-12 ShahDraft motionfor sum jud 2.30



22-Jun-12 Shah

Participate intelephoneconferencecall

CourtConference 0.25


22-Jun-12 Shah


22-Jun-12 Shah


22-Jun-12 ShahReview andanalyze RFP 0.66

23-Jun-12 Shah


25-Jun-12 ShahResearchand prepare 0.30

25-Jun-12 ShahReview andanalyze

DepoObjections 0.50

26-Jun-12 Shah



26-Jun-12 ShahResearchand prepare

depositionreview 2.30


27-Jun-12 Shah Draft letter 0.75



28-Jun-12 ShahReview andrevise draft

ltr re depoobjections 0.50





1-Jul-12 ShahDraft motionfor sum jud 0.75


1-Jul-12 ShahPrepare fordepositions 0.40



2-Jul-12 ShahResearchand prepare 1.20

2-Jul-12 Shah



3-Jul-12 Shah


3-Jul-12 Shah


3-Jul-12 ShahResearchand prepare 0.50

4-Jul-12 Shah


4-Jul-12 Shah


5-Jul-12 ShahReview andanalyze Orders 0.75

5-Jul-12 Shah


6-Jul-12 Shah


6-Jul-12 ShahReview andanalyze 0.50

6-Jul-12 ShahReview andrevise draft 0.75

7-Jul-12 Shah




7-Jul-12 Shah


8-Jul-12 Shah


9-Jul-12 Shah



9-Jul-12 Shah Research 1.20



11-Jul-12 ShahReview andanalyze Order 0.40


11-Jul-12 Shah travel time 4.00

12-Jul-12 Shah



12-Jul-12 Shah


12-Jul-12 Shah


12-Jul-12 ShahDefenddepositions 1.20

12-Jul-12 Shah



13-Jul-12 Shah travel time 4.00

13-Jul-12 ShahReview andanalyze order 0.30


13-Jul-12 Shah


13-Jul-12 ShahReview andanalyze

3rd rfpresponse 1.00

16-Jul-12 Shah


16-Jul-12 Shah



17-Jul-12 Shah


17-Jul-12 Shah




17-Jul-12 Shah Draft 0.20

18-Jul-12 Shah


18-Jul-12 Shah


18-Jul-12 Shah


18-Jul-12 ShahReview andanalyze order 0.40

19-Jul-12 Shah

Review andexchange e-mails Court email 0.60

19-Jul-12 Shah



20-Jul-12 Shah


20-Jul-12 Shah

Participate intelephoneconferencecall w/ court 0.75




23-Jul-12 Shah Draft memo 0.75


23-Jul-12 Shah





24-Jul-12 Shah


24-Jul-12 Shah Draft motion 7.50

25-Jul-12 Shah


25-Jul-12 ShahResearchand prepare RFPs 0.40

25-Jul-12 ShahReview andanalyze SOS ltr 0.20

26-Jul-12 Shah



26-Jul-12 Shah

Review andrevise draftdiscoveryresponses 1.75



27-Jul-12 ShahReview andanalyze SOS email 0.10

27-Jul-12 Shah


31-Jul-12 Shah


1-Aug-12 ShahReview andanalyze Order 0.30

1-Aug-12 Shah


2-Aug-12 Shah


3-Aug-12 Shah


3-Aug-12 Shah


3-Aug-12 Shah


6-Aug-12 Shah


8-Aug-12 Shah


8-Aug-12 ShahAttorneywork product trial 0.75

9-Aug-12 ShahAttorneywork product trial prep 0.40

9-Aug-12 ShahAttorneywork product trial prep 0.40

10-Aug-12 Shah

Prepare fortelephoneconferencecall

pre trialconference 0.20

13-Aug-12 ShahAttorneywork product Trial prep 1.30


14-Aug-12 Shah


14-Aug-12 Shah

Review andexchange e-mails Pre trial conf 0.20

15-Aug-12 Shah


15-Aug-12 Shah


16-Aug-12 Shah


16-Aug-12 Shah


16-Aug-12 ShahReview andrevise draft 0.20

16-Aug-12 Shah

Review andexchange e-mails pre trial conf 0.20

16-Aug-12 Shah


17-Aug-12 ShahDraft replymotion 0.75

17-Aug-12 Shah Draft motion 0.75


19-Aug-12 Shah


19-Aug-12 ShahReview andrevise draft SJM 5.00


20-Aug-12 Shah


20-Aug-12 Shah


20-Aug-12 Shah


21-Aug-12 Shah Draft PTO 1.75


21-Aug-12 Shah


21-Aug-12 Shah


21-Aug-12 ShahReview andanalyze sos ltr to ct 0.20

22-Aug-12 ShahReview andrevise draft MTS 1.75

22-Aug-12 ShahReview andanalyze order 0.20

22-Aug-12 Shah

Draftdiscoverysummaries 1.20

22-Aug-12 Shah


23-Aug-12 Shah Draft memo MSJ 1.20

23-Aug-12 ShahReview andanalyze Order 0.30

24-Aug-12 Shah


25-Aug-12 ShahReview andrevise draft MSJ 4.00

27-Aug-12 Shah

Review andexchange e-mails PTO 0.30


27-Aug-12 ShahReview andrevise draft MSJ 0.75

28-Aug-12 Shah


28-Aug-12 ShahResearchand prepare PTO 1.00

28-Aug-12 Shah

Review andincorporateedits Scott Dec 0.40

28-Aug-12 Shah


28-Aug-12 Shah

Review andincorporateedits SJM 3.00

13-Sep-12 ShahAttorneywork product

trial prep -order of proof 4.30

14-Sep-12 ShahReview andrevise draft PTO 3.20

14-Sep-12 ShahReview andanalyze Settlement 0.50

14-Sep-12 Shah


15-Sep-12 Shah

Review andincorporateedits for pto 3.00

15-Sep-12 Shah


16-Sep-12 Shah

Review andincorporateedits PTO 1.30

17-Sep-12 Shah



17-Sep-12 ShahReview andanalyze PTO 1.10

18-Sep-12 ShahReview andrevise draft M&C ltr 0.20


18-Sep-12 Shah


18-Sep-12 ShahResearchand prepare MILs 0.30

18-Sep-12 Shah

Review andanalyze filingbydefendant/defendants PTO Exhibits 2.50

18-Sep-12 Shah


18-Sep-12 ShahReview andrevise draft

Opp to StatConf 0.40

19-Sep-12 Shah


19-Sep-12 ShahReview andanalyze

PTOObjections 3.30

19-Sep-12 ShahReview andanalyze Order 0.20

20-Sep-12 ShahAttendmeeting M&C re PTO 6.00


Refusal tosign 0.20

21-Sep-12 ShahReview andrevise draft 0.50

21-Sep-12 ShahReview andrevise draft

ConsolidatedPTO 3.50








24-Sep-12 Shah


PTOresponse 2.30

24-Sep-12 Shah


25-Sep-12 Shah



M toContinue 0.40

25-Sep-12 Shah Draft motion

ProposedFindings ofFact &Conclusionsof Law 0.66

26-Sep-12 Shah


ProposedInjunction 0.75

26-Sep-12 Shah


26-Sep-12 Shah

Review andanalyze filingbydefendant/defendants

DHH &DCFS M toContinue 0.30

26-Sep-12 ShahAttorneywork product trial prep 0.66

27-Sep-12 ShahReview andanalyze Order 0.20

27-Sep-12 ShahAttend courtconference 1.40

27-Sep-12 Shah travel time 4.00

27-Sep-12 Shah

Review andincorporateedits PFOF 2.10

28-Sep-12 Shah travel time 4.00

28-Sep-12 ShahReview andrevise draft PFOF 2.66

28-Sep-12 ShahReview andrevise draft SOF 2.40

29-Sep-12 ShahReview andrevise draft PCOL 2.50


30-Sep-12 ShahReview andrevise draft PCOL 2.50


1-Oct-12 Shah


meet andconfer 0.20

1-Oct-12 Shah

Participate intelephoneconferencecall 0.50

1-Oct-12 Shah


2-Oct-12 ShahReview andrevise draft

ProposedInjunction 1.30

2-Oct-12 ShahAttorneywork product trial prep 0.50

2-Oct-12 ShahReview andrevise draft PTO 2.20

2-Oct-12 ShahReview andrevise draft MILs 0.80

3-Oct-12 ShahReview andrevise draft PCOL 1.30




5-Oct-12 ShahReview andrevise draft APTO 3.20

5-Oct-12 Shah


5-Oct-12 Shah


6-Oct-12 Shah




8-Oct-12 ShahAttorneywork product Trial prep 5.75

8-Oct-12 Shah


9-Oct-12 ShahReview andanalyze Order 0.20

9-Oct-12 ShahAttorneywork product Trial Prep 3.50

9-Oct-12 Shah


10-Oct-12 Shah

Review andincorporateedits MILS 1.40

10-Oct-12 Shah


10-Oct-12 Shah

Review andanalyze filingbydefendant/defendants Witness lists 2.20


10-Oct-12 ShahReview andanalyze Stipulations 0.75

10-Oct-12 Shah


10-Oct-12 Shah


Omnibusmotion 1.66

10-Oct-12 Shah






11-Oct-12 Shah



11-Oct-12 Shah


11-Oct-12 Shah


12-Oct-12 Shah



12-Oct-12 ShahReview andrevise draft Stipulations 0.40

13-Oct-12 Shah travel time 4.00




15-Oct-12 ShahAttorneywork product Trial 8.00


16-Oct-12 ShahAttorneywork product trial 7.50

17-Oct-12 ShahAttorneywork product trial 3.75



19-Oct-12 Shah travel time 4.00

22-Oct-12 Shah Research Re Standing 0.30

23-Oct-12 Shah


re casecaption 0.10

23-Oct-12 ShahReview andanalyze

preliminarycourttranscripts 1.66


M to Admit Dfacts 0.50

25-Oct-12 Shah Researchvoterregistration 0.75

26-Oct-12 Shah

Review andexchange e-mails Errata Sheet 0.10

26-Oct-12 Shah

Review andexchange e-mails Case Caption 0.10

26-Oct-12 Shah


M to Admit DFacts 0.30

31-Oct-12 Shah


DHH DCFSObjections totheAdmissioninto EvidenceofStatementsContained inRec. Docs.138-1 and 0.40


Post TrialBrief 1.75

1-Nov-12 Shah Draft Sheets 2.10

1-Nov-12 Shah

Review andexchange e-mails VR precincts 0.10

1-Nov-12 ShahReview andrevise draft post trial brief 1.30

2-Nov-12 ShahReview andrevise draft

ErrataSheets 0.75

4-Nov-12 ShahReview andrevise draft Errata sheets 0.30

4-Nov-12 Shah


Closing PP toDs 0.20

5-Nov-12 Shah DraftAnd senderrata sheets 0.20


8-Nov-12 Shah


8-Nov-12 Shah ResearchScott pollingplace 0.30

8-Nov-12 Shah

Review andexchange e-mails Case caption 0.20

9-Nov-12 Shah


Closing PP toDs 0.40

9-Nov-12 ShahReview andrevise draft

Post trialbrief 0.40

12-Nov-12 ShahReview andanalyze


14-Nov-12 Shah



15-Nov-12 Shah


15-Nov-12 Shah



19-Nov-12 Shah



19-Nov-12 Shah



19-Nov-12 Shah

Review andanalyze filingbydefendant/defendants post trial brief 0.50

20-Nov-12 Shah


Opp tochange casecaption 0.30


27-Nov-12 Shah


Objection tonewevidence 0.66

27-Nov-12 Shah Researchjudicial noticepost trial 1.20

27-Nov-12 ShahAttorneywork product

opp to dmotionobjecting tonewevidence 0.20

28-Nov-12 Shah Researchpost trialevidence 1.20

28-Nov-12 Shah Draft memo

Opp to D min opp to posttrial evid 3.50

28-Nov-12 Shah


29-Nov-12 Shah


P opp to Dobjection topost trial evid 0.75

30-Nov-12 Shah


Ps opp to Dsobjection topost trial evid 1.00

TOTAL 781.9

71 of which is travel time


Exhibit D - Michelle Rupp Time Records


18-Oct-11 Rupp Draft

depo outlineon formdistributionpolicy &practice 4.30

18-Oct-11 RuppReview andrevise draft

depooutlines 1.50


notices,subpoenas,andattachments 2.30

21-Oct-11 Rupp


21-Oct-11 Rupp Draft depo notices 1.00

24-Oct-11 Ruppattorneywork product

read DCFSdiscovery,used it towriteexpectedanswers forJohnnieTyson depo 6.80


caseworkerdepo outline 4.50

10-Nov-11 Rupp


17-Nov-11 Rupp


doc reviewfor remotetransactionsinfo 9.00

18-Nov-11 Rupp



21-Nov-11 Rupp



22-Nov-11 Rupp




23-Nov-11 Rupp



19-Dec-11 RuppAttendmeeting

discussion ofdepostrategies 1.00

1-Jan-12 RuppReview andrevise draft

proofreadingPSJ 2.25


reviewedmemo onDCFSpolicy,startedadding moredetail onDCFS policyto PSJ 2.00


reviewingDCFS docs& addingdetail onDCFS policyto PSJ 4.50

9-Jan-12 Ruppattorneywork product

citechecking /correctingPSJ sectionon DCFSpolicy 1.50


combiningconflictingversions 1.50


checkingpage cites inPSJ 2.00

9-Feb-12 Rupp

Participatein telephoneconferencecall

re: SOSwithholdingof employeeevaluations;sentsummary ofconvo toNiyati &Dale 0.50

10-Feb-12 RuppAttend courtconference

re: SOSemployeeevaluations 1.30

13-Feb-12 Rupp

Reviewdiscoveryresponses doc review 5.00


21-Feb-12 RuppReview andrevise draft

motion tocompel DHHprivilege log 0.30

23-Feb-12 Rupp


w/ Niyati &Ron 0.20

23-Feb-12 RuppAttendmeeting w/ Niyati 0.20

23-Feb-12 Rupp


w/ Niyati andDale 2.00


re: SOSmotion tostrike 2.00


statusconference 0.30

28-Feb-12 Rupp


28-Feb-12 Rupp Research

re: SOSMotion toStrike 6.00

29-Feb-12 Rupp


29-Feb-12 Rupp Research

& drafting re:SOS motionto strike 8.00

1-Mar-12 Rupp


5-Mar-12 Rupp

Review andrevise draftreply motion

motion tocompel(DHH) 0.30

5-Mar-12 Rupp


6-Mar-12 Rupp


7-Mar-12 Rupp



8-Mar-12 Rupp

Review andrevise draftreply motion

PSJ(includessomeresearchtime) 5.00

8-Mar-12 Rupp


9-Mar-12 Rupp


9-Mar-12 Rupp

Review andrevise draftreply motion PSJ 1.00

16-Mar-12 Rupp


20-Mar-12 Rupp


w/ Niyati &Dale 1.00

21-Mar-12 Rupp


w/ Niyati &Dale 0.50

21-Mar-12 Rupp


22-Mar-12 Rupp


23-Mar-12 Rupp


26-Mar-12 Rupp


27-Mar-12 Rupp


28-Mar-12 Rupp


29-Mar-12 Rupp


30-Mar-12 Rupp



2-Apr-12 Rupp


3-Apr-12 Rupp


4-Apr-12 Rupp


6-Apr-12 Rupp


9-Apr-12 Rupp


w/ Niyati andDale 0.50

10-Apr-12 Rupp

Participateinpreparationfor oralargument

moot forDale 2.00

10-Apr-12 Rupp


11-Apr-12 Rupp


13-Apr-12 Rupp


15-Apr-12 Rupp


16-Apr-12 Rupp


16-Apr-12 RuppAttorneywork product

deposummariesfor Reed &Weatherford 4.00

17-Apr-12 Rupp


17-Apr-12 Rupp


moot forDale 2.00

18-Apr-12 Rupp



23-Apr-12 Rupp


23-Apr-12 RuppAttendmeeting

w/ Sarah &Niyati 0.25

23-Apr-12 Rupp

Telephoneconferencecall withteam 1.00

24-Apr-12 Rupp

Reviewvarious e-mails SJ 0.10

27-Apr-12 Rupp


27-Apr-12 RuppTalk withPlaintiffs Rev. Taylor 0.25

30-Apr-12 Rupp Research

Legalstandardsfor fullsummaryjudgmentmotion 2.00

30-Apr-12 RuppAttorneywork product

Review ofdraft letter &associatedemails to MJWilkinson 0.10

30-Apr-12 Rupp

Preparewitness fordeposition

Phone callw/ Rev.Taylor 0.50

1-May-12 Rupp

Reviewdocumentsproduced indiscovery

Revieweddocumentsproduced byPlaintiffLouisianaStateConferenceof theNAACP inpreparationfor defenseof Rev.Taylor'sdeposition. 4.00

1-May-12 Rupp



2-May-12 Rupp

Participatein telephoneconferencewith litigationteam

re:tomorrow'smeet andconfer w/defendant'sattorneys 1.10

2-May-12 Rupp


Doc reviewof LA-NAACPdocs inpreparationfor defenseof Rev.Taylor'sdeposition 5.80

3-May-12 Rupp


meet &confer forsettlementconference 0.40

3-May-12 Rupp


3-May-12 RuppReview andrevise draft

letter toJudgeWilkinson 0.20

3-May-12 Rupp


PV-onlydiscussionafter meet &confer 0.30

3-May-12 Rupp


discussionwith LDFafter meet &confer 0.60

3-May-12 Rupp


ReviewedLA-NAACPdocs inpreparationfor Rev.Taylordeposition 4.00

4-May-12 Rupp



letter andchart toMagistrateJudge 0.30


4-May-12 Rupp


ReviewingLA-NAACPdocs inpreparationfordefendingRev.Taylor's 1.60

7-May-12 Rupp


ReviewedLA-NAACPdocs inpreparationfor defenseof Rev.Taylor'sdeposition 0.90

8-May-12 Rupp Researchlegalstandards 4.20

8-May-12 Rupp


9-May-12 Rupp


9-May-12 RuppTalk withPlaintiffs Rev. Taylor 1.25

10-May-12 Rupp


11-May-12 Rupp


14-May-12 Rupp


15-May-12 Rupp


15-May-12 Rupp


15-May-12 RuppAttendmeeting

w/ Sarah &Niyati 0.25


opp tocertificationbrief 1.10

17-May-12 Rupp

Reviewvarious e-mails 0.10


18-May-12 RuppAttorneywork product

readingproposed SJoutline 0.10

18-May-12 Rupp

Telephoneconferencecall withteam call w/ LDF 1.10

21-May-12 Rupp


22-May-12 RuppTalk withPlaintiffs

called Rev.Johnson toconfirmdepositiondate 0.10

22-May-12 Rupp



internaldiscussionre: discoveryandexhibit/witness lists 1.50

23-May-12 Rupp


23-May-12 Rupp


23-May-12 Rupp


24-May-12 Rupp


24-May-12 Rupp

Telephoneconferencecall withteam

call with LDFafter statusconference 0.30


internaldiscussion 0.50


compilingwitness list 5.00

24-May-12 RuppAttend courtconference

Statusconferencewith allparties &Court re:motion forcertification 0.25



w/ Sarah &Niyati re: SJoutline 1.00


GoingthroughDCFSConfidentialdocumentsfor helpfulexhibits;enteringthem onspreadsheet.Preparationfor exhibitlist. 3.00

27-May-12 Rupp


28-May-12 Rupp


29-May-12 Rupp


29-May-12 Rupp


30-May-12 Rupp



re: SJ +witness &exhibit lists 0.50

31-May-12 Rupp


1-Jun-12 Rupp


1-Jun-12 Rupp


w/ Ron &Natasha 1.00

1-Jun-12 RuppTalk withPlaintiffs

call w/ Dr.Johnson 1.00

2-Jun-12 Rupp



3-Jun-12 Rupp


4-Jun-12 Rupp


4-Jun-12 Rupp


5-Jun-12 RuppTalk withPlaintiffs 2.50

5-Jun-12 Rupp


5-Jun-12 Rupp travel time

flight fromDC to NewOrleans 5.00

5-Jun-12 Rupp

Preparewitness fordeposition Dr. Johnson 0.75

5-Jun-12 RuppAttendmeeting w/ Natasha 0.75

6-Jun-12 Rupp


6-Jun-12 RuppAttenddepositions 6.00

7-Jun-12 RuppAttorneywork product

& meetingw/ Niyati &Sarah re:witness &exhibit list 2.30

7-Jun-12 RuppAttorneywork product

working onexhibit lis 4.00

7-Jun-12 Rupp


8-Jun-12 Rupp travel time

Flight (withlayover inAtlanta)from NewOrleans toDC 6.50

8-Jun-12 Rupp


9-Jun-12 Rupp



10-Jun-12 Rupp


10-Jun-12 Rupp


10-Jun-12 RuppReview andrevise draft

motion toadjustschedule 0.90

11-Jun-12 Rupp


11-Jun-12 RuppReview andrevise draft

motion tomodifyschedulingorders 0.50

12-Jun-12 Rupp


13-Jun-12 Rupp


15-Jun-12 Rupp


16-Jun-12 Rupp


18-Jun-12 Rupp


18-Jun-12 Rupp


internal PVdiscussion 0.50

18-Jun-12 Rupp


19-Jun-12 Rupp


19-Jun-12 Rupp


20-Jun-12 Rupp


20-Jun-12 Rupp



21-Jun-12 Rupp


22-Jun-12 Rupp


22-Jun-12 Rupp


22-Jun-12 RuppAttend courtconference


22-Jun-12 RuppReview andrevise draft SJ 1.60

23-Jun-12 Rupp


25-Jun-12 Rupp


26-Jun-12 Rupp


26-Jun-12 Rupp


27-Jun-12 Rupp


28-Jun-12 Rupp


29-Jun-12 RuppReview andrevise draft SJ SOF 1.70

29-Jun-12 RuppReview andrevise draft SJ memo 1.30

29-Jun-12 Rupp


30-Jun-12 Rupp


2-Jul-12 Rupp


2-Jul-12 RuppReview andrevise draft SJ SOF 0.70

2-Jul-12 Rupp

Reviewvarious e-mails SJ brief 1.20


3-Jul-12 Rupp


5-Jul-12 Rupp


5-Jul-12 RuppReview andrevise draft

oppn to SOSmotion forextension oftime toopposemotions forSJ 0.50

6-Jul-12 RuppAttend courtconference 0.50

6-Jul-12 Rupp


6-Jul-12 RuppReview andanalyze 1.00

7-Jul-12 Rupp


8-Jul-12 Rupp Draft 0.80

8-Jul-12 Rupp Draftmotion toextend time 2.00


oppn to SOSmotion tocompel 0.60

9-Jul-12 Rupp



oppn to SOSmotion tocompel 0.80


motion forextension oftime 0.20

10-Jul-12 Rupp


10-Jul-12 Rupp Draft

motion &order toquashsubpoenaduces tecum 0.90



memo insupport ofmotion toquashsubpoenaduces tecum 0.80

11-Jul-12 Rupp


12-Jul-12 Rupp


12-Jul-12 Rupp



oppn to SOSmotion toextenddiscovery 0.50

13-Jul-12 Rupp



oppn tomotion tocompel 1.20

13-Jul-12 Rupp


re:opposition tomotion tocompel 0.40

13-Jul-12 RuppAttorneywork product

re: SOScatalog ofobjections 0.50

14-Jul-12 Rupp Research 2.00

14-Jul-12 Rupp


re:opposition tomotion tocompel 0.20


opposition tomotion tocompel 2.00

14-Jul-12 RuppAttorneywork product 0.40

15-Jul-12 Rupp



opposition tomotion tocompel 1.00


17-Jul-12 Rupp


17-Jul-12 Rupp


18-Jul-12 Rupp


18-Jul-12 Rupp


19-Jul-12 RuppReview andrevise draft 0.80

19-Jul-12 Rupp


20-Jul-12 RuppAttend courtconference

telephonicstatusconference 0.50

20-Jul-12 Rupp


20-Jul-12 Rupp


22-Jul-12 Rupp


22-Jul-12 RuppReview andrevise draft letter 0.20

23-Jul-12 Rupp draft e-mail

to co-counsel re:protectingsensitivefinancial info 0.10

23-Jul-12 RuppAttorneywork product

legalresearch re:protectingsensitivefinancial info 1.40

23-Jul-12 Rupp


23-Jul-12 Rupp

Review andrevise draftdiscoveryresponses

to SOS 3rdRFP 0.30


24-Jul-12 Rupp


24-Jul-12 RuppReview andanalyze

discoverymaterials 0.70


opposition to2nd motionto compel 5.50

25-Jul-12 Rupp


25-Jul-12 Rupp


26-Jul-12 Rupp


26-Jul-12 RuppReview andanalyze

documentspertaining toNAACPfinancials 1.00

27-Jul-12 Rupp


31-Jul-12 Rupp


1-Aug-12 Rupp


2-Aug-12 Rupp


2-Aug-12 RuppAttorneywork product

working onexhibit list 1.50

3-Aug-12 Rupp


3-Aug-12 Rupp


6-Aug-12 RuppAttorneywork product witness chart 5.20

8-Aug-12 Rupp


intro callwith FF 1.10

9-Aug-12 Rupp



10-Aug-12 Rupp


13-Aug-12 RuppAttorneywork product 0.20

13-Aug-12 Rupp


13-Aug-12 RuppAttorneywork product

DCFSwitness chart 1.32

13-Aug-12 RuppAttorneywork product exhibit list 1.60

14-Aug-12 Rupp


14-Aug-12 Rupp


15-Aug-12 Rupp


16-Aug-12 Rupp


re: D's oppn& our reply 1.00

16-Aug-12 Rupp


17-Aug-12 Rupp


18-Aug-12 Rupp


18-Aug-12 Rupp Draftmotion tostrike 4.00

19-Aug-12 Rupp


20-Aug-12 Rupp Draftmotion tostrike 1.10

20-Aug-12 Rupp


21-Aug-12 Rupp


21-Aug-12 Rupp



21-Aug-12 RuppReview andrevise draft 0.70

22-Aug-12 Rupp


22-Aug-12 RuppReview andrevise draft

motion tostrike 0.80

23-Aug-12 Rupp


23-Aug-12 RuppReview andrevise draft SJ 1.60

24-Aug-12 Rupp


25-Aug-12 Rupp


26-Aug-12 Rupp


26-Aug-12 RuppReview andrevise draft SJ 2.70

27-Aug-12 Rupp


28-Aug-12 Rupp


28-Aug-12 Rupp


28-Aug-12 Rupp


28-Aug-12 Rupp

Review andrevise draftreply motion SJM 2.30

29-Aug-12 Rupp


30-Aug-12 Rupp


31-Aug-12 Rupp



31-Aug-12 Rupp


2-Sep-12 Rupp Research 2.00

2-Sep-12 Rupp


2-Sep-12 Rupp

Review andrevise draftreply motion 0.60

3-Sep-12 Rupp


3-Sep-12 Rupp


moot forDale 2.00

3-Sep-12 RuppReview andrevise draft 1.00

3-Sep-12 RuppReview andrevise draft

oppn to SOSmotion tostrikeevidence onPs reply tomotion forSJ 0.30

4-Sep-12 Rupp travel time

DC toNOLA;includeslayover 6.00

4-Sep-12 Rupp


5-Sep-12 Rupp

Reviewvarious e-mails


5-Sep-12 RuppAttend courtconference


6-Sep-12 Rupp travel time

NOLA toDC; includeslayover 7.50

6-Sep-12 Rupp


7-Sep-12 Rupp


8-Sep-12 Rupp



9-Sep-12 RuppReview andrevise draft injunction 1.10

10-Sep-12 Rupp


10-Sep-12 Rupp Draft exhibit list 4.00

10-Sep-12 RuppAttorneywork product 0.60

10-Sep-12 Rupp


11-Sep-12 Rupp



12-Sep-12 Rupp



list ofcontinuingviolations asrequested byopposingcounsel 0.50

12-Sep-12 RuppReview andrevise draft exhibit list 5.80


13-Sep-12 RuppReview andrevise draft injunction 1.00

13-Sep-12 RuppAttorneywork product

order ofproof / depoexcerpts 3.80

13-Sep-12 Rupp


14-Sep-12 Rupp


14-Sep-12 Rupp Draft letter

to Ds re:additionalexhibits 0.10

15-Sep-12 Rupp

Review andexchange e-mails PTO 1.00

15-Sep-12 RuppReview andrevise draft PTO 3.00

16-Sep-12 Rupp




17-Sep-12 Rupp


17-Sep-12 Rupp



18-Sep-12 Rupp


18-Sep-12 RuppReview andanalyze 0.75



reviewingexhibits forobjections 1.30

18-Sep-12 RuppReview andanalyze PTO insert 1.30

19-Sep-12 Rupp


19-Sep-12 RuppReview andrevise draft exhibit list 2.10


19-Sep-12 Rupp


19-Sep-12 RuppReview andanalyze PTO insert 2.00

20-Sep-12 Rupp


21-Sep-12 Rupp


22-Sep-12 Rupp


23-Sep-12 Rupp


23-Sep-12 RuppReview andanalyze PTO 1.60


24-Sep-12 Rupp


24-Sep-12 RuppReview andrevise draft letter 0.20

25-Sep-12 Rupp


25-Sep-12 Rupp


25-Sep-12 Rupp


26-Sep-12 Rupp



chart of factsDefendantspreviouslyadmitted,now deny 5.80

26-Sep-12 Rupp


27-Sep-12 Rupp



proposedFOF 3.50

28-Sep-12 Rupp


29-Sep-12 Rupp


29-Sep-12 RuppReview andrevise draft FOF&COL 4.00

30-Sep-12 RuppReview andrevise draft COL 0.60

30-Sep-12 Rupp


1-Oct-12 Rupp


w/ Skip re:PTO 0.50


1-Oct-12 Rupp


1-Oct-12 Rupp



proposedinjunction 1.40

2-Oct-12 Rupp


2-Oct-12 Rupp


re: trialexhibits 0.30

2-Oct-12 Rupp


3-Oct-12 Rupp



motions inlimine 1.50


motion inlimine 0.20

4-Oct-12 Rupp


4-Oct-12 RuppReview andrevise draft COL 3.20

5-Oct-12 Rupp


5-Oct-12 Rupp


6-Oct-12 Rupp


6-Oct-12 RuppAttorneywork product

witnessoutlines prep 4.50

7-Oct-12 Rupp


8-Oct-12 Rupp


8-Oct-12 Rupp


re: witness &trial 1.00


9-Oct-12 Rupp


10-Oct-12 Rupp



Brookswitnessoutline 1.30


oppn to SOSomnibus 0.50

11-Oct-12 Rupp



Brookwitnessoutline 0.40

11-Oct-12 RuppAttendmeeting

direct/crossprep w/ FF&LDF viateleconference 3.00


oppn tojudicialnotice 0.30

11-Oct-12 Rupp Research

oppn tojudicialnotice 0.70

12-Oct-12 Rupp


12-Oct-12 Rupp


13-Oct-12 Rupp travel time

from DC toNOLA;includeslayover +drive fromBiloxi 7.00


trying to gettrial prepboxes fromFedEx b/cthey weren'tdelivered asscheduled 1.50



trial prep -discussing/practicingMotions inLimine 1.50


reviewingDale'sopening andopeningcharts;makingsuggestionsforimprovement 0.40

13-Oct-12 Rupp


w/ litigationteam re:opening &charts 0.20

14-Oct-12 Rupp



trial prep,includingorganizing ofexhibits andtrial binders,as well asexaminationpractice 8.00

15-Oct-12 RuppAttend courtconference

trial: 8:25am-12pm,1:35pm-6pm 8.00

15-Oct-12 RuppAttorneywork product trial prep 5.00


trial: 8:10am-12:30pm,2:10pm-5:20pm 7.50

16-Oct-12 RuppAttorneywork product trial prep 4.80


trial: 8:35am-11:50am,1:30pm-2pm 3.75

19-Oct-12 Rupp


19-Oct-12 Rupp Research 0.40

19-Oct-12 Rupp travel timefrom NOLAto DC 5.50


20-Oct-12 Rupp


w/ litigationteam re:standingresearch 0.10

21-Oct-12 Rupp


w/ litigationteam re:post-trialbrief 0.10

22-Oct-12 Rupp


re: casecaption 0.10

22-Oct-12 Rupp


re: post-trialbrief outline 0.10

23-Oct-12 Rupp


w/ litigationteam re:preliminarytrialtranscripts 0.10

23-Oct-12 Rupp


w/ litigationteam re:case caption 0.10

24-Oct-12 Rupp


w/ litigationteam re:motion toadmit factsfrom D'sSMFs 0.10

25-Oct-12 Rupp



25-Oct-12 Rupp ResearchScottstanding 5.00

25-Oct-12 Rupp


re: motion toadmit factsfrom D'sSMFs 0.20

25-Oct-12 Rupp


re: erratasheet 0.10

26-Oct-12 Rupp




section onScottstanding forpost-trialbrief 1.40


26-Oct-12 Rupp


re: motion toadmit factsfrom D'sSMFs 0.30

26-Oct-12 Rupp



26-Oct-12 RuppAttendmeeting

re: edits topost trialbrief 0.30


section onScottstanding forpost-trialbrief 1.40

29-Oct-12 Rupp


re: post-trialbrief 0.20


Scottstanding 2.00


chart ofobjections +checkingtranscript forerrors 2.30

31-Oct-12 Rupp


re: erratasheets 0.30

31-Oct-12 Rupp draft e-mail

to intern re:judicialnotice 0.10

31-Oct-12 Rupp Researchstandingissues 4.70

31-Oct-12 Rupp



1-Nov-12 Rupp



1-Nov-12 Rupp ResearchPost-trialbrief 1.20

1-Nov-12 RuppReview andrevise draft

post-trialbrief 0.40

2-Nov-12 Rupp



2-Nov-12 Rupp


w/ litigationteam re:errata sheets 0.10


2-Nov-12 Rupp


w/ intern re:judicialnotice 0.20

3-Nov-12 Rupp


w/ litigationteam re:stipulation &errata sheet 0.10

4-Nov-12 Rupp


re: closingppt & to-dolist 0.20

5-Nov-12 Rupp


re: post-trialbrief &closing ppt 0.20

7-Nov-12 Rupp


re: motion toamendcaption 0.10

8-Nov-12 Rupp


8-Nov-12 Rupp


re: post trialbrief 0.30

8-Nov-12 Rupp


re: casecaption (andresponse toSOS) 0.20

9-Nov-12 Rupp


re: exhibitsfor post-trialbrief 0.20

9-Nov-12 Rupp


re:stipulations 0.10

9-Nov-12 Rupp


re: closingtrialdemonstrative 0.10

9-Nov-12 Rupp


re: exhibitsfor post-trialbrief 0.40

9-Nov-12 Rupp



9-Nov-12 Rupp


w/ litigationteam re:post-trialexhibits 0.10




9-Nov-12 Rupp


re: changeof casecaptionchange (&response toSOS) 0.40

12-Nov-12 Rupp



13-Nov-12 Rupp



13-Nov-12 Rupp


w/ litigationteam re:case caption 0.10

14-Nov-12 RuppAttorneywork product

dealing withexhibits forpost-trialbrief 0.30



14-Nov-12 Rupp



15-Nov-12 Rupp





15-Nov-12 Rupp


re: post-trialbriefing 0.50

16-Nov-12 Rupp


from Dale &Sarah re:post-trialbriefing 0.10

19-Nov-12 Rupp


from Dalere:Defendant'spost-trialbrief 0.10

20-Nov-12 Rupp


w/ litigationteam re:Defendants'post-trialbriefs 0.10

20-Nov-12 Rupp


w/ litigationteam re:objection tocaptionchange 0.10


27-Nov-12 RuppAttendmeeting

w/ Niyati andSarah re:oppn motiontoDefendants'objection topost-trialevidence 0.50

27-Nov-12 Rupp


w/ litigationteam re:oppn motiontoDefendants'objection topost-trialevidence 0.20

28-Nov-12 Rupp


re: oppnmotion toDefendants'objection topost-trialevidence 0.70

29-Nov-12 Rupp




oppn motiontoDefendants'objection topost-trialevidence 1.50


oppn motiontoDefendants'objection topost-trialevidence 0.30


30-Nov-12 Rupp



TOTAL 560

37.5 of which is travel


Exhibit E - K. Gerlach Time Records

Date

Task and

description Last name Hours

1-5-2011

researchmedicaidapplications Gerlach 5

1-6-2011

researchSNAPapplications Gerlach 5

4-May-12

Attendmeeting Gerlach 2.00

7-2-2012

researchregardingdata forSum. Judge Gerlach 7

7-12-2012

research LAcensus data Gerlach 3

TOTAL 22

(no travel billed)


DATE DESCRIPTION COST

2012/2011 -

621.25

11,860.15

12,828.86

Postage & Courier

Airfare

Project Vote1350 I Street, N.W., Ste 1250


Lodging

OFF: 888.546.4173 FAX: 202.629.3754

EML: [email protected]

JOB

New Orleans, Louisiana - Ferrand vs Schedler

Research Fees

4,102.58

101.95

848.13

540.00

226.03

-

31,128.95$

Supplies

TOTAL

Ground transportation

Printing

Other Professional Services

Other Expense

Exhibit FCase 2:11-cv-00926-JTM-JCW Document 446-22 Filed 02/26/13 Page 1 of 2

Louisiana - Project code 180

Date

Research

Fees Date Paid

Postage &

Courier Date paid Airfare Date paid Lodging Date paid

Ground

transportation Date paid

Other

Expense Date Paid Printing Date Paid

Other

Professional

Services Date paid Supplies Total

9/30/2012 352.23 1/31/2012 461.20 4/30/2012 221.68 1/6/2012 18.75 5/31/2012 12.95 12/31/2012 183.21 12/31/2012 226.0312/31/2012 242.63 4/30/2012 8.00 4/30/2012 221.68 3/1/2012 10.00 12/31/2012 129.78

4/30/2012 8.00 4/30/2012 221.68 5/31/2012 377.834/30/2012 563.20 5/31/2012 648.98 5/31/2012 112.944/30/2012 563.20 5/31/2012 648.98 5/31/2012 20.004/30/2012 374.10 5/31/2012 207.46 6/1/2012 157.605/31/2012 8.00 6/30/2012 389.82 6/1/2012 32.485/31/2012 8.00 6/30/2012 389.82 6/30/2012 776.215/31/2012 402.2 6/30/2012 389.82 7/31/2012 12.755/31/2012 402.2 7/31/2012 227.28 7/31/2012 318.69 10/31/2012 19.005/31/2012 402.2 7/31/2012 227.28 8/31/2012 462.45 10/31/2012 25.005/31/2012 8.00 8/31/2012 120.56 8/31/2012 66.00 10/31/2012 25.005/31/2012 636.20 9/30/2012 205.18 8/31/2012 119.63

9/30/2012 50.009/30/2012 16.009/30/2012 16.16

10/31/2012 10.0010/31/2012 10.0010/31/2012 55.0010/31/2012 24.00

5/31/2012 581.40 9/30/2012 205.18 12/31/2012 104.085/31/2012 8.00 9/30/2012 8.00 12/31/2012 60.005/31/2012 8.00 9/30/2012 157.63 12/31/2012 21.007/31/2012 8.00 9/30/2012 8.007/31/2012 7.00 9/30/2012 8.007/31/2012 623.20 9/30/2012 8.007/31/2012 368.40 10/31/2012 117.597/31/2012 8.00 10/31/2012 129.277/31/2012 661.20 10/31/2012 8.008/31/2012 8.00 10/31/2012 8.008/31/2012 406.20 10/31/2012 8.009/30/2012 360.70 10/31/2012 1,813.959/30/2012 360.70 10/31/2012 1,575.459/30/2012 403.70 10/31/2012 1,575.459/30/2012 353.20 10/31/2012 200.489/30/2012 353.20 10/31/2012 200.48

10/31/2012 308.2010/31/2012 486.20 10/31/2012 189.2810/31/2012 486.20 10/31/2012 189.2810/31/2012 486.2010/31/2012 144.60

6/10/2011 21.35 7/14/2011 379.10 3/25/2011 287.56 11/9/2011 20.00 11/21/2011 20.00 11/14/2011 535.14 2/2/2011 540.009/6/2011 5.04 11/10/2011 20.00 7/15/2011 137.67 11/11/2011 18.00

11/10/2011 492.68 11/15/2011 377.8311/15/2011 369.51 11/21/2011 545.5011/15/2011 370.60 12/22/2011 251.9012/22/2011 179.0012/22/2011 179.00

- 621.25 10,320.70 12,345.80 4,064.80 101.95 848.13 540.00 226.03 29,068.66

New Orleans - Project code 181

Date

Research

Fees Date

Postage &

Courier Date paid airfare Date paid lodging Date paid

ground

transportation Date paid other Date paid Printing Date paid

Other

Professional

Services Date paid Supplies Total

8/31/2012 341.20 9/30/2012 115.28 8/31/2012 6.009/30/2012 268.20 9/30/2012 8.00 9/30/2012 31.78

11/30/2012 269.70 12/31/2012 124.6011/30/2012 8.00 10/31/2012 117.5912/31/2012 4.95 10/31/2012 117.59

5/31/2012 631.405/31/2012 8.008/31/2012 8.00

- - 1,539.45 483.06 37.78 - - - - 2,060.29

GRAND TOTAL - 621.25 11,860.15 12,828.86 4,102.58 101.95 848.13 540.00 226.03 31,128.95

Exhibit FCase 2:11-cv-00926-JTM-JCW Document 446-22 Filed 02/26/13 Page 2 of 2