Precision Seed Cleaners Inc. v. Country Mutual Insurance Company, No. 3:2010cv01023 - Document 251 (D. Or. 2013)

Court Description: OPINION & ORDER: Plaintiff's motion for attorney fees and prejudgment interest 221 is granted in part and denied in part. Plaintiff is awarded $539,443.20 in attorney fees and $148,671.55 in prejudgment interest. See 56-page opinion & order with attachments. Signed on 10/1/2013 by Judge Marco A. Hernandez. (Attachments: # 1 Attachment 1, # 2 Attachment 2) (mr)

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Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 2/15/10 2/15/10 Draft letter of representation to Dan Thenell. Left voice mail requesting Client call for appointment; Left message for Don Kelley to provide additional phone number to reach Paul Kloft. 08 0.1 Fred Millard Heidi Gross $350 $50 0.4 - Excessive All - Clerical 0.4 00 $140.00 $0.00 2/16/10 Left voice mail requesting Client call; Left message for Don Kelley to provide additional contact information RE: Paul Kloft. Left voice mail at work and alternative phone number asking client to call for appointment. Prepare for and conduct meeting with Paul Kloft to discuss insurance claim process and duty to cooperate with insurance company and to review with Paul Kloft in detail Dan Thenell's letter of December 29, 2009 and his 13 requests for documents. Prepare for and conduct telephone call with Kyle Smith at Smith, Freed discussing status of claim. Review correspondence from Kyle Sturm regarding request for documents; Confer with Fred Millard regarding correspondence and request for documents. Telephone call with James Kloft RE: he is unable to reach Paul Kloft and was not aware of the documents he was to provide; Suggested that Paul Kloft provide him with the list created during last office visit. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 39 Fred Millard $350 39 $1,365.00 03 Fred Millard $350 03 $105.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 3/5/10 Telephone call with Paul Kloft; E-memo Fred Millard with details. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 3/8/10 3/8/10 Draft letter to Dan Thenell regarding discovery requests. Draft letter to Paul Kloft RE: requesting information pertaining to response of December 29, 2009 correspondence from Dan Thenell. 05 0.6 Fred Millard Fred Millard $350 $350 05 0.6 $175.00 $210.00 3/10/10 Review and analyze March 10, 2010 correspondence, and other documents from Dan Thenell including insurance policy and correspondence and draft letter to Paul Kloft RE: new discovery requests and outstanding discovery issues. Telephone call with Paul Kloft RE: CPA and paperwork; E-memo Fred Millard and Doug Bragg; Update file. Review Client's voice mail; Forward to Heidi Gross to schedule meeting. 10 Fred Millard $350 10 $350.00 0.1 Heidi Gross $50 00 $0.00 02 Fred Millard $350 02 $70.00 Left a message with James Kloft requesting Paul Kloft call to schedule an office visit; Email same. Review correspondence from Thenell regarding status of the claim. 0.1 Heidi Gross $50 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 20 Doug Bragg Erin Stefonick $280 $110 0.1 20 $28.00 $220.00 09 Fred Millard $350 09 $315.00 3/30/10 Draft e-memo to Fred Millard regarding status of claim. Review 10 binders of documents produced by Client for purposes of identifying privileged material. Matter conference with Client Review 10 binders of collating documents for submittal to Country. Coordinate document production with Claire Frye and Erin Stefonick. 0.1 Heidi Gross $50 0.1 $5.00 3/30/10 Review with Client 10 binders of documents to be submitted to Country. 02 Heidi Gross $50 02 $10.00 3/31/10 Review and analyze 10 binders of documents produced by Client for privileged information. Update Doug Bragg RE: contents of documentation. Draft letter to Dan Thenell re: delivery of documents and prepare documents for delivery. Telephone call with Rush Processing to make arrangements for delivery of documents. 13 Erin Stefonick $110 13 $143.00 02 03 Erin Stefonick Erin Stefonick $110 $110 All - Clerical 02 00 $22.00 $0.00 0.1 Erin Stefonick $110 All - Clerical 00 $0.00 2/17/10 2/24/10 2/24/10 3/3/10 3/3/10 3/12/10 3/22/10 3/24/10 3/25/10 3/25/10 3/30/10 3/30/10 3/31/10 3/31/10 3/31/10 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Clerical Page 1 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Read note stating Client called and that there are no additional documents; E-memo staff. Phone call with Kyle Sturm confirming documents received. Review Complaint filed by Ionian Corp. and Country's Answer to same. 0.1 Heidi Gross $50 All - Clerical 0.1 0.1 Doug Bragg Doug Bragg $280 $280 Meeting with Fred Millard to review and analyze landlord's lawsuit against Country and Country's request to withhold documents from landlord. Review Ionian Corp v. Country Complaint; Review Preston's email message; Telephone call with Preston obtaining copies of lease agreements; Review policy for language pertaining to Right to Bring Legal Action; Review April 1, 2010 correspondence from Country Office of General Counsel. Meeting with Doug Bragg to review and analyze landlord's lawsuit against Country and Country's request to withhold documents from landlord. Review lease and security information regarding a cylinder separator from Wand Maddoux and Preston, LLC. Meeting with Fred Millard to further review and analyze lease and security information regarding a cylinder separator from Wand Maddoux and Preston, LLC. Meeting with Doug Bragg to review and analyze lease and security information regarding a cylinder separator from Wand Maddoux and Preston, LLC. Phone call with Kyle Sturm regarding Building Owner's access to the property. Draft e-memo to Fred Millard regarding telephone conversation with Kyle Sturm RE: Building Owner's access to the property. 02 Doug Bragg $280 15 Fred Millard 02 4/27/10 Explanation Hrs Awarded Amount 00 $0.00 0.1 0.1 $28.00 $28.00 00 $0.00 $350 15 $525.00 Fred Millard $350 02 $70.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 02 Fred Millard $350 02 $70.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 Prepare for and conduct telephone call with Cal Souther attorney RE: status of claim against Country concerning his client's deed. 0.6 Fred Millard $350 0.6 $210.00 4/27/10 Review e-memo from Doug Bragg regarding his telephone conversation with Kyle Sturm RE: Building Owner's access to the property. 0.1 Fred Millard $350 0.1 $35.00 4/30/10 Update Fred Millard regarding case status, analyze with Fred Millard strategy for dealing with Landlord's claims, access to building and subrogation claim. Review and analyze correspondence RE: subrogation from Dan Thenell. 03 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 4/30/10 Draft e-memo to Fred Millard regarding Dan Thenell's correspondence RE: subrogation and release of property to Ionian.. 0.1 Doug Bragg $280 00 $0.00 4/30/10 Review e-memo from Doug Bragg RE: Dan Thenell's correspondence RE: subrogation and release of property to Ionian. 0.1 Fred Millard $350 0.1 $35.00 4/30/10 03 Fred Millard $350 03 $105.00 03 Fred Millard $350 03 $105.00 4/30/10 5/3/10 Matter conference with Doug Bragg regarding case status and strategy for dealing with Landlord's claims, access to building and subrogation claim. Telephone call with Don Kelley RE: Bank's demand for index of Client submittals to insurer and copy of proof of loss. Draft e-memo to staff regarding Bank's demand. Confer with Fred Millard regarding document request from Don Kelley. 0.1 0.1 Fred Millard Doug Bragg $350 $280 0.1 00 $35.00 $0.00 5/3/10 Direct Claire Frye to forward documents. 0.1 Doug Bragg $280 3/31/10 4/1/10 4/2/10 4/5/10 4/5/10 4/5/10 4/6/10 4/6/10 4/6/10 4/27/10 4/27/10 4/30/10 4/30/10 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All- Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard 0.1 $28.00 Page 2 of 161 Date 5/3/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/4/10 5/5/10 5/5/10 5/5/10 5/5/10 5/5/10 5/5/10 5/6/10 5/6/10 5/7/10 5/7/10 5/7/10 5/7/10 5/10/10 5/10/10 5/12/10 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Matter conference with Doug Bragg RE: document request from Don Kelley. Phone call to Paul Kloft RE: Dan Thenell's request for Examination Under Oath's of Paul Kloft and James Kloft and Craig Collins, left voicemail. 02 Fred Millard $350 02 $70.00 0.1 Claire Frye $50 00 $0.00 Analyze with Fred Millard potential amended lawsuit by landlord naming Precision Seed. Review correspondence from Dan Thenell regarding Examination Under Oaths. Review Proposed First Amended Complaint naming Precision Seed. 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Review lease agreement and insurance policy. Review and analyze with Fred Millard the insurance policy provisions relating to replacement of building. Review and analyze with Fred Millard and Rich Brown the lease agreement's applicability post termination. Telephone call with Kyle Sturm RE: documents to be submitted by Country. Review and analyze documents provided by Dan Thenell. Telephone call with Don Kelley RE: analyzing claim status. Matter conference with Doug Bragg analyzing insurance policy provisions relating to building. Matter conference with Doug Bragg analyzing Precision Seed's lease and insurance contract. Review and analyze with Fred Millard coverage for the building and options for resolving issues with landlord. Conference with Rich Brown regarding options for dealing with Landlord's claims and obtaining coverage for building. Review and analyze insurance policy. Draft e-memo to Fred Millard regarding Landlord's claims and insurance policy coverage. Confer with Fred Millard regarding scope of building coverage. 02 08 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 02 Doug Bragg $280 02 $56.00 02 Fred Millard $350 02 $70.00 12 0.4 08 Fred Millard Fred Millard Fred Millard $350 $350 $350 12 0.4 08 $420.00 $140.00 $280.00 02 Richard Brown $125 00 $0.00 0.7 Doug Bragg $280 0.7 $196.00 0.1 Doug Bragg $280 0.1 $28.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Confer with Doug Bragg regarding scope of building coverage. Draft e-memo to Fred Millard regarding Examination Under Oath of James Kloft. Prepare for and conduct phone call with Paul Kloft regarding Examination Under Oath's and regarding the inclusion of James Kloft as a corporate officer. Confer with Fred Millard regarding Examination Under Oath for James Kloft. Review Secretary of State listing of officers and directors for Precision Seed. Compose and forward email to Kyle Sturm requesting basis for taking the Examination Under Oath of James Kloft. Prepare for and conduct phone call with Kyle Sturm regarding Ionian's Motion to Amend and Examination Under Oath for James Kloft. 02 0.1 Fred Millard Doug Bragg $350 $280 All - Duplicative; billed to Millard 02 00 $70.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Receive message from Craig Collins RE: Examination Under Oath; Ememo Doug Bragg. Prepare for and conduct phone call with Kyle Sturm regarding Examination Under Oath dates and basis for taking the Examination Under Oath of James Kloft. Draft letter to Kyle Sturm regarding Examination Under Oath schedule. 0.1 Claire Frye $50 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Clerical Page 3 of 161 Date 5/21/10 5/21/10 5/21/10 5/24/10 5/26/10 5/27/10 5/27/10 6/1/10 6/1/10 6/1/10 6/1/10 6/1/10 6/1/10 6/1/10 6/2/10 6/3/10 6/3/10 6/3/10 6/3/10 6/3/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 6/9/10 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Commence preparation for upcoming Examination Under Oath's examining documents (10 binders) provided to insurer. Review May 21, 2010 correspondence from Dan Thenell. Phone call with Cal Souther (503-981-0155) RE: Reiling Farms lost seed. 4.1 Fred Millard $350 4.1 $1,435.00 0.1 03 Fred Millard Fred Millard $350 $350 0.1 03 $35.00 $105.00 Telephone call with Cal Souther (503-981-0155) RE: Reiling Farms lost seed. Review and analyze Complaint from Reiling Farms, Inc. Review and analyze Reiling Farm's Complaint Review and respond to Don Kelley's email request for documents; Email documents to Don Kelley. Review correspondence from Dan Thenell regarding status of investigation. Phone call to Kyle Sturm regarding change of location for Examination Under Oaths. Confer with Fred Millard regarding change of location for the Examination Under Oaths. Draft letter to Dan Thenell regarding change of Examination Under Oath location. Telephone call with Don Kelley, left voice mail RE: Country Examination Under Oath's. Telephone call with Paul Kloft voice mail RE: Examination Under Oath's. 05 Fred Millard $350 05 $175.00 0.1 0.4 03 Doug Bragg Fred Millard Fred Millard $280 $350 $350 0.1 0.4 03 $28.00 $140.00 $105.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Fred Millard $350 0.1 $35.00 Matter conference with Doug Bragg RE: Objection to moving Examination Under Oath location, multiple representatives being present. Legal research on the reasonableness Examination Under Oath process. 02 Fred Millard $350 02 $70.00 0.7 Fred Millard $350 0.7 $245.00 Phone call from Paul Kloft; Schedule appointment to meet with Fred Millard; E-memo Fred Millard. Telephone call with Client RE: Examination Under Oath process. 0.1 Claire Frye $50 00 $0.00 08 Fred Millard $350 08 $280.00 Telephone call with Dan Thenell RE: Examination Under Oath's, left voice mail. Draft letter to Dan Thenell RE: Examination Under Oath's. Telephone call with Client RE: Examination Under Oath's, left voice mail. Phone call from Becky at Dan Thenell's office RE: Examination Under Oath time on Friday; E-memo Staff; Phone call to Client. Review and analyze with Fred Millard RE: revised proof of loss and additional submittals. Confer with Fred Millard Re: draft of letter to Dan Thenell RE: schedule revisions. Draft letter to Daniel Thenell regarding revisions to schedules. Research Federal Rules of Evidence regarding use of felony convictions. 0.1 Fred Millard $350 0.1 $35.00 0.6 0.1 Fred Millard Fred Millard $350 $350 0.6 0.1 $210.00 $35.00 02 Claire Frye $50 All - Clerical 00 $0.00 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 Confer with Fred Millard RE: Research findings regarding felony convictions. Matter conference with Client RE: Examination Under Oath preparation. 0.1 Doug Bragg $280 0.1 $28.00 2.4 Fred Millard $350 2.4 $840.00 Review and analyze with Doug Bragg RE: Revised proof of loss and additional submittals. Telephone call with Craig Collins to schedule office visit and confirm Examination Under Oath. Run OJIN reports on Paul Kloft and Precision Seed. 05 Fred Millard $350 05 $175.00 0.1 Heidi Gross $50 00 $0.00 Richard Brown $125 Explanation 02 ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Clerical 02 $25.00 Page 4 of 161 Date Hrs Awarded Amount $350 08 $280.00 Fred Millard $350 20 $700.00 02 Richard Brown $125 02 $25.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 6/11/10 Confer with Fred Millard regarding revised schedules; Direct Heidi Gross to scan revised schedules. Email Kyle Sturm revised schedules. Confer with Fred Millard regarding rescheduling the Examination Under Oath of Paul Kloft. Email Kyle Sturm regarding potential Examination Under Oath dates. 0.1 Doug Bragg $280 0.1 $28.00 6/14/10 Confer with Fred Millard regarding status of Examination Under Oaths. 0.1 Doug Bragg $280 0.1 $28.00 6/15/10 Telephone call with Client RE: Examination Under Oath continuance. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 6/15/10 Left voice mail for Kyle Sturm RE: Examination Under Oath schedule; Email same; E-memo Doug Bragg. Phone call with Kyle Sturm regarding continuation of Paul Kloft's Examination Under Oath and case status of Ionian Corp's Motion to Amend. Phone call to Client RE: new date for Examination Under Oath; Left voice mail; E-memo Doug Bragg. Review correspondence from Dan Thenell regarding new Examination Under Oath dates for Paul Kloft; Direct Claire Frye to confirm Aug. 31 date. Phone call from Client RE: Examination Under Oath date. Call to Dan Thenell's office to schedule Examination Under Oath on August 2nd. Telephone call with Don Kelley RE: Examination Under Oath's, left message. Matter conference with Fred Millard RE: telephone call with Cal Souther RE: Reiling Farms suit over its lost seed. Telephone call with Cal Souther RE: Reiling Farms suit over its lost seed. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 0.1 Claire Frye $50 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 0.1 Claire Frye Claire Frye $50 $50 00 00 $0.00 $0.00 0.1 Fred Millard $350 0.1 $35.00 09 Doug Bragg $280 00 $0.00 02 Fred Millard $350 02 $70.00 Matter conference with Doug Bragg RE: telephone call with Cal Souther RE: Reiling Farms suit over its lost seed. Review and analyze insurance policy regarding Demand of Intentions. 09 Fred Millard $350 09 $315.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 09 Doug Bragg $280 09 $252.00 7/12/10 Confer with Fred Millard regarding demand for status of claim per policy. Confer with Fred Millard RE: insurance policy regarding Demand of Intentions. Confer with Doug Bragg regarding demand for status of claim per policy. 0.1 Fred Millard $350 0.1 $35.00 7/13/10 7/13/10 Draft intentions demand letter to Country. Confer with Fred Millard analyzing intentions demand letter to Country. 09 02 Doug Bragg Doug Bragg $280 $280 09 00 $252.00 $0.00 7/13/10 7/13/10 Revise intentions demand letter to Country. Review and revise letter to Daniel Thenell RE: Intentions Demand. 02 02 Doug Bragg Fred Millard $280 $350 02 02 $56.00 $70.00 6/10/10 6/10/10 6/10/10 6/11/10 6/11/10 6/11/10 6/16/10 6/22/10 6/22/10 6/24/10 6/24/10 6/30/10 7/9/10 7/9/10 7/9/10 7/12/10 7/12/10 7/12/10 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze legal authority on issues related to Examinations Under Oath Prepare for and conduct conference with Craig Collins RE: Examination Under Oath preparation. Research scope of permitted examination at an Examination under Oath, specifically in regards to presentation of video; LexisNexis Research RE: the same; Research Couch on Insurance RE: the same; Direct Claire Frye to copy pertinent portions of Couch. 08 Fred Millard 20 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Clerical All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 5 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 7/13/10 Matter conference with Doug Bragg RE: intentions demand letter. 02 Fred Millard $350 02 $70.00 7/20/10 Review and analyze correspondence from Dan Thenell responding to request for decision. Review and analyze with Fred Millard Dan Thenell's response to Request for Decision. Review and analyze with Doug Bragg Dan Thenell's response to Request for Decision. Review July 20, 2010 correspondence from Dan Thenell; Forward to Paul Kloft for review. Review correspondence from Daniel Thenell regarding status of investigation. Review letter from Daniel Thenell regarding continued investigation. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Update Fred Millard regarding case status to assist in his preparation for Client meeting. Review faxed Complaint from Don Kelley. Confer with Fred Millard analyzing litigation strategy. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 0.1 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 02 00 $56.00 $0.00 Prepare for, travel to and from, and conduct meeting with Client and Don Kelley RE: claim status and litigation strategy. Matter conference with Doug Bragg RE: case status in preparation for Client meeting. Matter conference with Doug Bragg RE: analyzing litigation strategy. 30 Fred Millard $350 30 $1,050.00 03 Fred Millard $350 03 $105.00 0.1 Fred Millard $350 0.1 $35.00 Confer with Rich Brown regarding research on insurance policy provision requiring Country to state its position within 30 days of proof of loss. Matter conference with Doug Bragg RE: research in Millers/ISO forms RE: research on insurance policy provision requiring Country to state its position within 30 days of proof of loss. Matter conference with Doug Bragg in preparation for research RE: Miller's Standard Insurance Policies Annotated RE: policy interpretation questions. Travel to and from Multnomah County Law Library; Research policy interpretation issues in Miller's Standard Insurance Policies Annotated. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Richard Brown $125 00 $0.00 0.1 Richard Brown $125 0.1 $12.50 12 Richard Brown $125 12 $150.00 02 Doug Bragg $280 02 $56.00 8/3/10 Direct Rich Brown regarding research on interpretation of policy language. Review and analyze caselaw interpreting notice of intention language. 0.6 Doug Bragg $280 0.6 $168.00 8/4/10 Update Fred Millard regarding notice of intent research. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 8/4/10 Review and analyze with Fred Millard RE: complaint for lost leased equipment. Review insurance policy for possible coverages for leased equipment. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.4 Doug Bragg $280 0.4 $112.00 Update Fred Millard and Rich Brown regarding possible coverages for leased equipment complaint. Direct Rich Brown to research coverage under General Liability provision. Review and analyze Financial Leasing Complaint. Receive update on research from Doug Bragg and Rich Brown RE: Tender on liability coverage, demand to pay as additional insured and other theories. 0.1 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 03 0.7 Fred Millard Fred Millard $350 $350 03 0.7 $105.00 $245.00 7/20/10 7/20/10 7/21/10 7/22/10 7/26/10 7/28/10 7/28/10 7/28/10 7/28/10 7/28/10 7/28/10 7/30/10 7/30/10 8/2/10 8/2/10 8/3/10 8/4/10 8/4/10 8/4/10 8/4/10 8/4/10 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 6 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 8/4/10 Review and analyze cases identified by Miller's Standard Insurance Policies Annotated RE: notice of intentions policy language. 0.7 Richard Brown $125 0.7 $87.50 8/4/10 Update Doug Bragg RE: analysis of caselaw RE: notice of intentions policy language. Receive instructions from Doug Bragg RE: coverage for leased equipment research. Update Doug Bragg and Fred Millard RE: coverage for leased equipment research. Review Miller's Standard Insurance Policies Annotated Standard Property Coverage form for right to sue language at request of Doug Bragg. Prepare for and conduct phone call with Don Kelley and Fred Millard regarding Financial Pacific Leasing, LLC. Draft Demand Letter to Country Mutual Insurance for coverage of Financial Pacific Leasing, LLC. Prepare for and conduct telephone call with Don Kelley RE: Lease payment demand to Country. Matter conference with Doug Bragg analyzing Lease payment demand to Country. Matter conference with Doug Bragg analyzing liability for damaged equipment. Research Client's noncontractual liability for damage to equipment. 0.1 Richard Brown $125 0.1 $12.50 0.1 Richard Brown $125 All - Duplicative; billed to Bragg 00 $0.00 02 Richard Brown $125 All - Duplicative; billed to Millard 00 $0.00 0.1 Richard Brown $125 0.1 $12.50 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Fred Millard $350 02 $70.00 0.6 Fred Millard $350 0.6 $210.00 03 Fred Millard $350 03 $105.00 0.4 Richard Brown $125 0.4 $50.00 analyze with Doug Bragg RE: Client's noncontractual liability for damage to equipment. Analyze with Doug Bragg on "right to sue" investigation into Client's policy. Research "Legal Action Against Us" through Miller's Standard Insurance Policies Annotated Analyze with Fred Millard choice of venue for lawsuit. 02 Richard Brown $125 02 $25.00 0.1 Richard Brown $125 0.1 $12.50 03 Richard Brown $125 03 $37.50 08 Doug Bragg $280 00 $0.00 8/11/10 8/11/10 8/12/10 Analyze with Doug Bragg venue selection. Telephone call with Don Kelley discussing venue selection. Research Couch's treatise RE: whether incomplete Examination Under Oath precludes right of Plaintiff to file lawsuit against Insurer. 08 0.4 10 Fred Millard Fred Millard Richard Brown $350 $350 $125 08 0.4 10 $280.00 $140.00 $125.00 8/13/10 0.4 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.4 Fred Millard $350 0.4 $140.00 02 Fred Millard $350 02 $70.00 8/15/10 8/16/10 Review and analyze with Fred Millard regarding issues for complaint and choice of venue. Attend phone conference with Don Kelley and Fred Millard analyzing choice of venue. Review and analyze with Doug Bragg regarding issues for complaint and choice of venue. Attend phone conference with Don Kelley and Doug Bragg analyzing choice of venue. Begin draft of Complaint. Review and analyze draft of Complaint with Fred Millard. 0.4 05 Doug Bragg Doug Bragg $280 $280 0.4 00 $112.00 $0.00 8/16/10 Review and analyze August 17, 2010 correspondence from Dan Thenell. 02 Fred Millard $350 02 $70.00 8/16/10 8/16/10 Review draft of Complaint with Doug Bragg. Review and analyze issues to be addressed in Complaint as well as future issues in litigation. Review and analyze with Fred Millard regarding damages for the Complaint. 05 05 Fred Millard Fred Millard $350 $350 05 05 $175.00 $175.00 05 Doug Bragg $280 00 $0.00 8/4/10 8/4/10 8/4/10 8/5/10 8/5/10 8/5/10 8/5/10 8/5/10 8/5/10 8/5/10 8/9/10 8/10/10 8/11/10 8/13/10 8/13/10 8/13/10 8/17/10 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 7 of 161 Date 8/17/10 8/17/10 8/17/10 8/17/10 8/18/10 8/18/10 8/20/10 8/20/10 8/20/10 8/20/10 8/23/10 8/24/10 8/24/10 8/25/10 8/25/10 8/26/10 8/26/10 8/26/10 8/27/10 8/30/10 8/30/10 8/30/10 8/30/10 8/31/10 8/31/10 8/31/10 8/31/10 8/31/10 8/31/10 8/31/10 8/31/10 9/1/10 9/1/10 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review revised schedules for damages calculations; Calculate damages; Revise Complaint RE: damages. Email draft Complaint to Don Kelley for Client's review. Continue drafting Complaint. Review and analyze with Doug Bragg regarding damages. Review rules regarding methods of service. Update Fred Millard regarding service of the Complaint. Review correspondence from Dan Thenell. Check Calendar to confirm Examination Under Oath date, review correspondence file to confirm Examination Under Oath date and email Dan Thenell to confirm Examination Under Oath date has not changed. 10 Doug Bragg $280 10 $280.00 0.1 13 05 02 02 0.1 0.1 Doug Bragg Doug Bragg Fred Millard Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $350 $280 $280 $280 $280 0.1 13 05 02 02 0.1 0.1 $28.00 $364.00 $175.00 $56.00 $56.00 $28.00 $28.00 Prepare for and conduct phone conference with Gordon Carey RE: claim against insurance carrier. Prepare for and conduct client meeting, Review policy with Client and request for production of documents; Travel to/from site visit. 05 Fred Millard $350 05 $175.00 30 Fred Millard $350 30 $1,050.00 Review email from Dan Thenell confirming examination under oath date. Review and prepare civil cover sheet. Review correspondence from Daniel Thenell. Prepare for and conduct phone call with Paul Kloft regarding Complaint. 0.1 Doug Bragg $280 0.1 $28.00 02 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 02 $56.00 $28.00 $56.00 Prepare for and conduct meeting with Paul Kloft analyzing Complaint, insurance coverages, and damages. Direct assistant to draft letter tendering Reiling Farms' Complaint. 15 Doug Bragg $280 15 $420.00 0.1 Doug Bragg $280 0.1 $28.00 Review August 25, 2010 correspondence from Don Kelley. Review and analyze Reiling Farms' Complaint. Revise Complaint. Receive direction from Fred Millard regarding revisions to draft Complaint. Review and analyze draft of Complaint. Revise various causes in draft Complaint Direct Doug Bragg to revise Complaint. Revise Complaint. Analyze with Fred Millard draft Complaint. Phone conference with Paul Kloft regarding factual assertions in Complaint. Prepare summons, civil cover sheet, and Complaint for filing and service. 0.1 09 0.6 02 Fred Millard Fred Millard Doug Bragg Doug Bragg $350 $350 $280 $280 0.1 09 0.6 00 $35.00 $315.00 $168.00 $0.00 0.4 03 02 0.7 0.1 0.1 Fred Millard Fred Millard Fred Millard Doug Bragg Doug Bragg Doug Bragg $350 $350 $350 $280 $280 $280 0.4 03 02 0.7 0.1 0.1 $140.00 $105.00 $70.00 $196.00 $28.00 $28.00 02 Doug Bragg $280 All - Clerical 00 $0.00 Conference with Fred Millard analyzing Examination Under Oath and case status. Review notice of filing of the Complaint. Conference with Doug Bragg analyzing Examination Under Oath and case status. Travel to/from Examination Under Oath; Attend and defend Examination Under Oath of Paul Kloft. Prepare for and conduct phone call with Mike Carney to discuss his possible use as Private Investigator in Precision Seed. Update Fred Millard regarding my phone call with Mike Carney and receive update on Fred Millard's recent phone call with Paul Kloft analyzing issues for discovery and anticipated affirmative defenses from Country. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 03 Doug Bragg Fred Millard $280 $350 0.1 03 $28.00 $105.00 85 Fred Millard $350 85 $2,975.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 8 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Confer with Fred Millard analyzing questions / answers from Examination Under Oath and likely defenses from Country. Matter conference with Doug Bragg analyzing Issues from Examination Under Oath. Telephone call with Paul Kloft Review issues that arose in Examination Under Oath. Phone call with Kyle Sturm regarding a copy of the examination under oath transcript for Paul Kloft. Draft e-memo to Fred Millard regarding Examination Under Oath transcript for Paul Kloft. Review e-memo from Doug Bragg RE: Examination Under Oath transcript for Paul Kloft. Review notice of intent to appear from Dan Thenell. Review correspondence from Daniel Thenell regarding additional Examination Under Oaths and request for computer records. 05 Doug Bragg $280 All - Duplicative; billed to Millard 05 Fred Millard 0.6 9/3/10 9/7/10 Explanation Hrs Awarded Amount 00 $0.00 $350 05 $175.00 Fred Millard $350 0.6 $210.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 0.1 Fred Millard $350 0.1 $35.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 Email Paul Kloft regarding computer record requests from Country. 0.1 Doug Bragg $280 0.1 $28.00 Listen to voicemail from Client regarding Country's request for additional examinations under oath and computers. Review correspondence from Dan Thenell regarding appearance and request for examination under oath and computers. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Phone call with Paul Kloft regarding request for examination under oath and computers. Phone call with James Kloft regarding computer request. Begin draft letter to Dan Thenell regarding various requests from Country. Phone call to Dan Thenell regarding request for computer, left voicemail. Review proof of service for Country. Prepare for and conduct phone call with Don Kelley regarding case status. Phone call with Kyle Sturm regarding status of the Answer, Examination Under Oath for the bookkeeper, and request for computers. 02 Doug Bragg $280 02 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 02 Doug Bragg $280 02 $56.00 9/20/10 Draft letter giving Country Mutual notice of intent to file for default. 02 Michele Barbara $125 02 $25.00 9/22/10 0.1 Doug Bragg $280 0.1 $28.00 9/27/10 Review correspondence from Dan Thenell regarding request for computer inspection. Attend phone conference with Gordon Carey regarding case status. 02 Doug Bragg $280 00 $0.00 9/27/10 Telephone call with Gordon Carey RE: Ionian's claim against Country. 0.1 Fred Millard $350 0.1 $35.00 9/27/10 10/1/10 Telephone call with Gordon Carey. Draft letter to Dan Thenell regarding copying of the computer and examination under oath of the bookkeeper. Phone call with Kyle Sturm regarding Complaint. Review and analyze Answer. Review and analyze affirmative defenses with Fred Millard. 02 02 Fred Millard Doug Bragg $350 $280 02 02 $70.00 $56.00 0.1 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.1 00 $28.00 $28.00 $0.00 Review and analyze affirmative defenses with Doug Bragg. Review fax from Dan Thenell denying coverage for property damage claim. 02 0.1 Fred Millard Doug Bragg $350 $280 02 0.1 $70.00 $28.00 9/1/10 9/1/10 9/1/10 9/2/10 9/2/10 9/2/10 9/3/10 9/3/10 9/7/10 9/7/10 9/7/10 9/7/10 9/7/10 9/13/10 9/17/10 9/20/10 10/4/10 10/4/10 10/4/10 10/4/10 10/7/10 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 9 of 161 Date 10/8/10 10/8/10 10/11/10 10/11/10 10/11/10 10/11/10 10/11/10 10/11/10 10/12/10 10/14/10 10/14/10 10/14/10 10/14/10 10/14/10 10/14/10 10/14/10 10/18/10 10/18/10 10/19/10 10/20/10 10/20/10 10/20/10 10/20/10 10/20/10 10/22/10 10/26/10 10/27/10 10/28/10 10/29/10 10/29/10 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Prepare for and conduct phone call with Paul Kloft RE: Answer and Affirmative Defenses. Review correspondence from Dan Thenell regarding status of claim and request for hard drive. Review/respond to email from Kyle Sturm regarding discovery. Receive directions from Fred Millard regarding discovery plan. 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 Review Ionian Corp. v. Country Summary Judgment ruling. Meet with Doug Bragg analyzing discovery plan. Telephone conversation with Smith Freed to schedule Federal Rules of Civil Procedure 26 Conference. Compose and forward emails with Smith Freed RE: Examination Under Oath Transcript of Paul Kloft. Phone call with Kevin regarding status of Precision's claim with Country and possible intervention by his leasing company for leased items lost in the fire. Prepare for and conduct phone call with Don Kelley regarding Reiling Farms issues. Phone call with Gordon Carey regarding summary judgment and tender of check on building. Draft e-memo to Fred Millard regarding summary judgment and tender of check on building. Review and analyze Ionian's Motion for Summary Judgment. Review email from Dan Thenell regarding possible settlement of building portion of the claim. Review e-memo from Doug Bragg RE: summary judgment and tender of check on building. Telephone conversations with Dan Thenell's office to reschedule Federal Rules of Civil Procedure 26 hearing. Analyze with Fred Millard Building Coverage settlement issues. 02 0.1 0.1 Doug Bragg Fred Millard Michele Barbara $280 $350 $125 All - Clerical 02 0.1 00 $56.00 $35.00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 0.1 Fred Millard $350 0.1 $35.00 03 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Analyze with Doug Bragg Building Coverage settlement issues. Prepare for and conduct phone conference with Kyle Sturm regarding scheduling in preparation of FRCP 26 hearing. Meeting with Client and Fred Millard regarding case status, 26(a)(1) disclosures, and case scheduling. Phone call with Kyle Sturm and Gordon Carey regarding distribution of the building coverage. Confer with Fred Millard regarding phone call with Kyle Sturm and Gordon Carey on building coverage. Matter conference with Doug Bragg RE: his phone conference call with Kyle Sturm and Cordon Carey on building coverage. Meeting with Client and Doug Bragg regarding case status, 26(a)(1) disclosures, and case scheduling. Draft letter to Dan Thenell confirming obligations to cooperate are superceded by civil process. Phone call with Client regarding 26(a)(1) disclosures. Meet with Client regarding FRCP 26(a)(1) disclosures. Phone call with Paul Kloft regarding witness contact information for 26(a)(1) disclosures. Review/revise Rule 26 Report; Email draft to Kyle Sturm for review. 02 0.4 Fred Millard Doug Bragg $350 $280 02 0.4 $70.00 $112.00 1.6 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 03 Fred Millard $350 03 $105.00 1.6 Fred Millard $350 1.6 $560.00 03 Doug Bragg $280 03 $84.00 0.1 15 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 15 0.1 $28.00 $420.00 $28.00 0.6 Doug Bragg $280 0.6 $168.00 Continue preparing and formatting Federal Rules of Civil Procedure 26 Report for court. 0.7 Michele Barbara $125 0.7 $87.50 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 10 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review correspondence dated October 28, 2010 from Gordon Carey RE: status of landlord's case against Country. Review/respond to email from Kyle Sturm regarding 26(f) Report. 0.1 Fred Millard $350 0.1 $35.00 02 Doug Bragg $280 02 $56.00 11/9/10 Telephone call with Don Kelley RE: status of litigation needed for negotiations with lender. Matter conference with Client RE: case status and litigation strategy. 03 Fred Millard $350 03 $105.00 05 Fred Millard $350 05 $175.00 11/10/10 11/12/10 Review proposed Joint Rule 26(f) Report. Phone call with Gordon Carey regarding distribution of Coverage A. 05 0.1 Fred Millard Doug Bragg $350 $280 05 0.1 $175.00 $28.00 11/12/10 Analyze with Fred Millard Precision's claim on Building Coverage A. 02 Doug Bragg $280 00 $0.00 11/12/10 11/12/10 11/12/10 Phone call to Gordon Carey, left voicemail. Review correspondence from Gordon Carey. Phone call with Gordon Carey regarding building coverage distribution. 0.1 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.1 02 $28.00 $28.00 $56.00 11/12/10 Analyze with Doug Bragg Precision's claim on Building Coverage A. 02 Fred Millard $350 02 $70.00 11/17/10 Matter conference with Fred Millard regarding case status and to analyze litigation status and advantages/disadvantages of mediation. 02 Doug Bragg $280 00 $0.00 11/17/10 Attend conference with Doug Bragg regarding case status and to analyze litigation status and advantages/disadvantages of mediation. 02 Fred Millard $350 02 $70.00 11/19/10 Prepare for and conduct phone call with Don Kelley RE: case status. 02 Fred Millard $350 02 $70.00 11/29/10 11/30/10 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 11/30/10 Phone call with Kyle Sturm regarding status of 26(f) filing. Review 26(f) comments from Fred Millard to prepare for phone conference. Phone call with Kyle Sturm regarding 26(f) report, left voicemail. 0.1 Doug Bragg $280 0.1 $28.00 11/30/10 12/2/10 Review 26(f) report, comments to Doug Bragg. Confer with Fred Millard to analyze issues with Ionian Corp. 02 0.1 Fred Millard Doug Bragg $350 $280 02 00 $70.00 $0.00 12/2/10 12/3/10 Confer with Doug Bragg to analyze issues with Ionian Corp. Review/respond to email from Kyle Sturm regarding waiver of 26(a)(1) disclosures. Prepare for and conduct telephone call with Client RE: claim relating to building. Review/respond to email from Don Kelley RE: tenant improvements. 0.1 0.1 Fred Millard Doug Bragg $350 $280 0.1 0.1 $35.00 $28.00 05 Fred Millard $350 05 $175.00 0.4 Fred Millard $350 0.4 $140.00 Draft e-memo to Diego Conde requesting research on ownership of tenant improvements absent written contract. Meeting with Kyle Sturm regarding Scheduling Conference Report. 02 Fred Millard $350 02 $70.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 12/10/10 12/10/10 Review revised proposed schedule; Confirm that Kyle Sturm is authorized to file same. Review Joint Status Report filing. Confer with Fred Millard to analyze building coverage issue. 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 12/10/10 Draft confirming email to Dan Thenell regarding building coverage. 0.1 Doug Bragg $280 0.1 $28.00 12/10/10 12/10/10 Confer with Doug Bragg to analyze building coverage issue. Review and analyze filed Joint Rule 26(f) Report. 02 0.4 Fred Millard Michele Barbara $350 $125 02 0.4 $70.00 $50.00 11/1/10 11/3/10 11/5/10 12/6/10 12/6/10 12/6/10 12/7/10 12/8/10 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 11 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Millard 12/13/10 Confer with Fred Millard to analyze scope of building coverage. 0.1 Doug Bragg $280 12/13/10 Review and analyze insurance policy regarding scope of building coverage A. Draft e-memo to Fred Millard analyzing scope of insurance coverage for Building and Coverage A. Confer with Doug Bragg to analyze scope of building coverage. Review Doug Bragg's email RE: building coverages. Attend meeting with Fred Millard and Paul Kloft to analyze building coverage issues and discuss strategy for resolving issue. 02 Doug Bragg $280 02 Doug Bragg $280 0.1 0.1 15 Fred Millard Fred Millard Doug Bragg $350 $350 $280 12/15/10 Conduct meeting with Doug Bragg and Paul Kloft to analyze building coverage issues and discuss strategy for resolving issue. 15 Fred Millard $350 12/16/10 Confer with Fred Millard to analyze electrical claim. 02 Doug Bragg $280 12/16/10 Attend meeting with Fred Millard and Client to analyze building coverage issues. Conduct meeting with Doug Bragg to analyze electrical claim. Conduct meeting with Doug Bragg and Client to analyze building coverage issues. Attend meeting with Fred Millard and Doug Bragg analyzing coverage and proceeds. Phone call with Kevin Preston, representative of a creditor of Precision Seed, regarding case status. Conduct meeting with Fred Millard and Diego Conde to analyze building coverage proceeds distribution. Phone call with Client regarding contract modification. Meeting with Doug Bragg and Diego Conde analyzing coverage and proceeds. Draft Request for Admissions. Draft Request for Production of Documents. Draft Request for Interrogatories. Prepare for and conduct phone call with Client regarding building coverage issues. Confer with Diego Conde to analyze building coverage issues. Draft e-memo to Fred Millard analyzing options for building coverage dispute. Review and analyze liability provisions of the insurance policy. Draft e-memo to Fred Millard regarding liability coverage limits. 02 Doug Bragg $280 02 02 Fred Millard Fred Millard $350 $350 13 Diego Conde $125 02 Doug Bragg $280 13 Doug Bragg $280 0.1 13 Doug Bragg Fred Millard 0.6 0.6 08 03 12/13/10 12/13/10 12/13/10 12/15/10 12/16/10 12/16/10 12/20/10 12/20/10 12/20/10 12/20/10 12/20/10 12/22/10 12/22/10 12/22/10 12/22/10 12/22/10 12/22/10 12/22/10 12/22/10 12/22/10 1/9/11 1/20/11 1/21/11 1/21/11 1/21/11 1/21/11 1/26/11 3:10-cv-01023-HZ Hrs Awarded Amount 00 $0.00 02 $56.00 0.1 Duplicative; billed to Millard 0.1 $28.00 All - Duplicative; billed to Millard 0.1 0.1 00 $35.00 $35.00 $0.00 15 $525.00 All - Duplicative; billed to Millard 00 $0.00 All - Duplicative; billed to Millard 00 $0.00 02 02 $70.00 $70.00 00 $0.00 02 $56.00 00 $0.00 $280 $350 0.1 13 $28.00 $455.00 Diego Conde Diego Conde Diego Conde Doug Bragg $125 $125 $125 $280 0.6 0.6 08 03 $75.00 $75.00 $100.00 $84.00 02 0.4 Doug Bragg Doug Bragg $280 $280 02 0.4 $56.00 $112.00 0.4 02 Doug Bragg Doug Bragg $280 $280 0.4 02 $112.00 $56.00 Review correspondence from Gordon Carey regarding building coverage issues. Begin Research on Work Product, and Attorney-Client Privilege Issue. 0.1 Doug Bragg $280 0.1 $28.00 10 Erin Priest $110 10 $110.00 Review letter from Gordon Carey regarding potential interpleader of money and Precision Seed. Confer with Fred Millard analyzing case status. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 Review/respond to emails relating to Ionian / Country dispute and building coverage issue. Telephone call with Dan Thenell RE: coverage liability, interpleader, and tax lien. Confer with Doug Bragg analyzing case status. Review IRS notice of tax lien sent to Country Insurance. 02 Doug Bragg $280 02 $56.00 0.4 Fred Millard $350 0.4 $140.00 0.1 0.1 Fred Millard Doug Bragg $350 $280 0.1 0.1 $35.00 $28.00 ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 12 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 0.4 0.1 Fred Millard Heidi Gross $350 $50 1/27/11 1/27/11 1/27/11 Review and analyze IRS documents forwarded by Dan Thenell. Per Fred Millard, left voicemail on Client's cell, spoke with James Kloft to pass on the same request and sent email. Review scheduling order and various deadlines. Research Amendment to Answer. Review file and check District Court website for calendaring dates. All - Clerical 0.4 00 $140.00 $0.00 02 0.1 0.4 Doug Bragg Doug Bragg Michele Barbara $280 $280 $125 All - Clerical 02 0.1 00 $56.00 $28.00 $0.00 1/31/11 Draft email to Dan Thenell requesting update on coverage analysis. 03 Fred Millard $350 03 $105.00 1/31/11 Review and analyze various documents confirming issues having to do with coverage limits. Phone call with Kyle Sturm regarding discovery and settlement status. 0.6 Fred Millard $350 0.6 $210.00 0.1 Doug Bragg $280 0.1 $28.00 3/3/11 Prepare for and conduct phone call with Don Kelley regarding defense of Reiling Farms and the status of a lawsuit filed by West Coast Bank. 02 Doug Bragg $280 02 $56.00 3/9/11 Draft e-memo to Fred Millard RE: Reiling Farms and status of lawsuit filed by West Coast Bank. Confer with Fred Millard to analyze upcoming payment from Country and possible liability for seed of others. Telephone call with Brian Born, counsel for PNC. Confer with Doug Bragg to analyze upcoming payment from Country and possible liability for seed of others. Review Doug Bragg's email RE: Reiling Farms and West Coast Bank. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 0.1 Fred Millard Fred Millard $350 $350 02 0.1 $70.00 $35.00 0.1 Fred Millard $350 0.1 $35.00 Discuss telephone call with Brian Born RE: upcoming payment from Country and possible liability for seed of others. Email Kyle Sturm regarding status of partial payment, request for letter advising as to the status of the investigation, and request King's file. 0.1 Fred Millard $350 0.1 $35.00 0.1 Doug Bragg $280 0.1 $28.00 Meeting with Fred Millard and Client to analyze case status, settlement status and additional potential claims. Review Paul Connolly's March 4, 2011 correspondence; Telephone call with same (message with Erin) requesting return call to discuss his policy copy request. Matter conference with Kyle Sturm and Gordon Carey RE: Prehearing conference. Prepare for and conduct client meeting with Doug Bragg to analyze case status, settlement status and additional potential claims. 20 Doug Bragg $280 05 $140.00 0.1 Fred Millard $350 0.1 $35.00 0.6 Fred Millard $350 0.6 $210.00 15 Fred Millard $350 15 $525.00 3/10/11 Review email from Brian Born RE: PNC claim; Telephone call with Don Kelley, left voicemail ; Telephone call with Brian Born, left voicemail. 0.1 Fred Millard $350 0.1 $35.00 3/11/11 Confer with Fred Millard to analyze discovery issues. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 3/11/11 3/14/11 Confer with Doug Bragg to analyze discovery issues. Meeting with Doug Bragg to analyze discovery to be sought through Requests for Production, Requests for Admission and Interrogatories. 02 05 Fred Millard Diego Conde $350 $125 All - Duplicative; billed to Bragg 02 00 $70.00 $0.00 3/15/11 Review file in preparation for draft of Request for Production, Request for Admissions and Interrogatories. Draft Request for Production to be served to Country Mutual Insurance Co. (Fed Case). Draft First Set of Interrogatories to be served to Country Mutual Insurance Co. (Fed Case). 0.4 Diego Conde $125 0.4 $50.00 1.4 Diego Conde $125 1.4 $175.00 12 Diego Conde $125 12 $150.00 1/26/11 1/26/11 3/2/11 3/9/11 3/9/11 3/9/11 3/9/11 3/9/11 3/10/11 3/10/11 3/10/11 3/10/11 3/10/11 3/15/11 3/15/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 1.5 Duplicative; billed to Millard Page 13 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Continue working on draft of First Set of Interrogatories to be served to Country Mutual Insurance Co. (Fed Case). Meeting with Diego Conde to analyze discovery to be sought through Requests for Production, Requests for Admission and Interrogatories. 1.1 Diego Conde $125 1.1 $137.50 05 Doug Bragg $280 05 $140.00 3/16/11 Review and analyze email from Kyle Sturm regarding partial settlement. 02 Doug Bragg $280 02 $56.00 3/17/11 1.7 Diego Conde $125 1.7 $212.50 3/17/11 Review and edit First Set of Interrogatories to Country as per Fred Millard's corrections and input. Confer with Doug Bragg to analyze draft Interrogatories to Country. 02 Diego Conde $125 00 $0.00 3/17/11 Confer with Diego Conde regarding draft Interrogatories to Country. 02 Doug Bragg $280 02 $56.00 3/17/11 3/18/11 Review/revise draft interrogatories to Country. Review draft Request for Production and Request for Interrogatories to Country. Review and analyze West Coast Bank / Precision Seed workout agreement. Draft e-memo to Fred Millard analyzing West Coast Bank / Precision Seed workout agreement. Review and analyze draft of West Coast loan workout agreement assigning claim benefits. Confer with Doug Bragg on issue and claim preclusion research. Analyze with Fred Millard case status. 0.4 0.4 Fred Millard Doug Bragg $350 $280 0.4 0.4 $140.00 $112.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 09 Fred Millard $350 09 $315.00 0.7 0.1 Diego Conde Doug Bragg $125 $280 All - Duplicative; billed to Millard 0.7 00 $87.50 $0.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 4/6/11 Phone call with Kyle Sturm RE: case status. Draft e-memo to Fred Millard regarding phone call with Kyle Sturm RE: case status. Review e-memo from Doug Bragg RE: conversation with Kyle Sturm. 0.1 Fred Millard $350 0.1 $35.00 4/6/11 4/11/11 Receive update from Doug Bragg regarding case status. Analyze with Doug Bragg issue and claim preclusion research. 0.1 0.7 Fred Millard Diego Conde $350 $125 All - Duplicative; billed to Bragg 0.1 00 $35.00 $0.00 4/11/11 4/11/11 Analyze with Diego Conde issue and claim preclusion research. Prepare for and conduct telephone call with Smith Freed for scheduling of telephone conference. Analyze with Doug Bragg Re: issue preclusion doctrine as applicable to the matters of Precision v Country and Ionian v Country v Precision. 0.7 0.4 Doug Bragg Michele Barbara $280 $125 All - Clerical 0.7 00 $196.00 $0.00 03 Diego Conde $125 All - Duplicative; billed to Bragg 00 $0.00 4/12/11 Analyze with Diego Conde RE: issue preclusion doctrine as applicable to the matters of Precision v Country and Ionian v Country v Precision. 03 Doug Bragg $280 03 $84.00 4/12/11 Confer with Michelle Barbara to return Jim King's document production to Smith Freed. Review letter to Smith Freed RE Jim King's document production. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Update Doug Bragg RE: return of Jim King's document production to Smith Freed. Letter to Smith Freed RE: Jim King's document production. Phone call with Kyle Sturm regarding discovery request. Draft email to Kyle Sturm regarding production extension. Review/respond to email from Kyle Sturm regarding discovery extension. Review/respond to email from Kyle Sturm regarding discovery responses. 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 0.1 02 02 0.1 Michele Barbara Doug Bragg Doug Bragg Doug Bragg $125 $280 $280 $280 All - Clerical 00 02 02 0.1 $0.00 $56.00 $56.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 3/15/11 3/15/11 3/18/11 3/18/11 3/21/11 4/6/11 4/6/11 4/6/11 4/6/11 4/12/11 4/12/11 4/12/11 4/12/11 4/14/11 4/14/11 4/15/11 4/20/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All- Duplicative; billed to Bragg Page 14 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 4/28/11 5/3/11 Phone call with Dan Thenell regarding possible settlement. Review documents from James King's file regarding policy creation. 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 5/3/11 Client meeting to review facts surrounding claim, discussion concerning preceding agreements with Ionian. Review/analyze responses to discovery requests from Country. Compose and forward email to Nicholas Thede regarding status of discovery. Review and analyze production from Country Insurance consisting of 945 pages. Receipt and review of Substitution of Attorney for Nicholas Thede. 2.1 Fred Millard $350 2.1 $735.00 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 0.6 Doug Bragg $280 0.6 $168.00 0.1 Michele Barbara $125 00 $0.00 Review and analyze production from Country Insurance consisting of 945 pages. Review correspondence from Country regarding requests for documentation. Draft letter to Dan Thenell regarding supplemental production. Confer with Doug Bragg to prepare letter to Smith Freed requesting any and all reports and Examination Under Oath's obtained in this matter. 23 Doug Bragg $280 23 $644.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 03 Doug Bragg Michele Barbara $280 $125 0.1 00 $28.00 $0.00 5/24/11 Confer with Doug Bragg to prepare letter to Smith Freed requesting any and all reports and Examination Under Oath's obtained in this matter. 02 Michele Barbara $125 00 $0.00 5/25/11 5/25/11 5/25/11 Review discovery status. Draft First Request for Admissions to Country Insurance. Email Dan Thenell regarding depositions, discovery requests and discovery cut off date. Review email from Dan Thenell regarding discovery setover. Review production from Country in relation to Request for Admissions. 0.1 03 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 03 0.1 $28.00 $84.00 $28.00 0.1 0.4 Doug Bragg Doug Bragg $280 $280 0.1 0.4 $28.00 $112.00 Draft Second Request for Interrogatories. Draft Second Request for Production. Review/respond to email from Dan Thenell regarding continuance of scheduling order. Draft Stipulated Motion to continue scheduling order timeline. Email Dan Thenell regarding Motion to Amend Scheduling Order. 03 02 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 02 0.1 $84.00 $56.00 $28.00 05 0.1 Doug Bragg Doug Bragg $280 $280 05 0.1 $140.00 $28.00 Review email from Nick Thede regarding Motion to Amend Scheduling Order; Direct Michele Barbara to file same. Review/respond to email from Dan Thenell regarding Motion to Amend Scheduling Order. Phone call with Client regarding payment on Seed of Others and the discovery schedule. File Stipulated Motion to Amend Scheduling Order with court. Review notice from Court regarding trial schedule. Review Court's scheduling orders to verify dates, oral argument, etc. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 0.1 0.4 Michele Barbara Doug Bragg Michele Barbara $125 $280 $125 00 0.1 00 $0.00 $28.00 $0.00 Phone call with Nick Thede regarding availability of Business Interruption Coverage. Review and analyze email from Nick Thede regarding discovery requests. Phone call to Nick Thede regarding discovery requests. Review and analyze Country's Answer to Interrogatories. Draft email to Nick Thede RE: Deposition of Country Mutual and scheduling. 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 02 05 02 Doug Bragg Diego Conde Diego Conde $280 $125 $125 02 05 02 $56.00 $62.50 $25.00 5/4/11 5/4/11 5/5/11 5/5/11 5/6/11 5/9/11 5/9/11 5/12/11 5/25/11 5/25/11 5/25/11 5/25/11 5/29/11 6/1/11 6/2/11 6/3/11 6/3/11 6/3/11 6/3/11 6/13/11 6/15/11 6/27/11 6/27/11 6/27/11 6/28/11 6/28/11 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Clerical; Duplicative of 5/24/11 entry; Excessive when considered with 5/24/11 entry All - Clerical All - Clerical All - Clerical Page 15 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.1 Diego Conde 6/28/11 Review email from Nick Thede requesting dates for Country's deposition. Review and analyze Country's Answer to Request for Admissions. $125 0.1 $12.50 05 Diego Conde $125 05 $62.50 6/28/11 Review and analyze Country's Answer to Request For Production. 05 Diego Conde $125 05 $62.50 6/28/11 Confer with Doug Bragg to analyze discovery responses from Country. 02 Diego Conde $125 00 $0.00 6/28/11 Review/respond to emails from Nick Thede regarding discovery and depositions. Confer with Diego Conde to analyze discovery responses from Country. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Analyze correspondence and notices, and calendar deadlines for PreTrial and Trial. Phone call with Nick Thede regarding discovery schedule and dispositive motion schedule. Phone call to Nick Thede regarding Motion to Continue Discovery Dates, left voicemail. Confer with Michele Barbara to see if Declaration is necessary for responsive documents. Confer with Michele Barbara to see if Declaration is necessary for responsive documents. Review Documents [Irrevocable Escrow Agreement]; Draft outline for discussion with counsel. Telephone conversation with Nick Thede RE: depositions for organizational and Precision Seed personnel. Direct Michele Barbara to prepare 7-day notice letter to Country Mutual. Review and execute notice 7-day letter to Country Mutual requesting response to Amended Complaint. Confer with Michele Barbara about scheduling depositions. Prepare Notice of Organizational Deposition for Country Mutual. 05 Michele Barbara $125 00 $0.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Diego Conde $125 0.1 $12.50 0.1 Doug Bragg $280 0.1 $28.00 08 Fred Millard $350 08 $280.00 02 Michele Barbara $125 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 05 Doug Bragg Michele Barbara $280 $125 All - Clerical 0.1 00 $28.00 $0.00 7/8/11 Prepare letter to Dan Thenell requesting response to Amended Complaint filed on May 25, 2011 within 7 days from today. 02 Michele Barbara $125 All - Clerical 00 $0.00 7/8/11 Fax letter to Dan Thenell RE: requesting response to Amended Complaint filed on May 25, 2011 within 7 days from today. Confer with Doug Bragg about scheduling depositions. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 Compose and forward email to Holly Weeks requesting clarification for August 4, 2011 depositions. Review and analyze Defendant's Request for Interrogatories and Request for Production. Prepare Notice of Taking Deposition for Jim King. Compose and forward emails to Holly at Smith Freed to confirm times of depositions. Telephone conversation with Paul Kloft to schedule time to bring in additional documents on fire claim with additional discovery and scheduling depositions . Telephone call to Nick Thede to confirm which depositions he is scheduling. Compose and forward email to Lisa at Smith Freed to prepare Response to their discovery. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 03 Doug Bragg $280 03 $84.00 02 02 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 6/28/11 6/28/11 6/29/11 6/30/11 6/30/11 7/6/11 7/6/11 7/6/11 7/6/11 7/8/11 7/8/11 7/8/11 7/8/11 7/8/11 7/8/11 7/11/11 7/11/11 7/11/11 7/11/11 7/11/11 7/11/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Clerical All - Clerical Page 16 of 161 Date Hrs Awarded Amount 0.7 $87.50 All - Clerical 00 $0.00 $125 All - Clerical 00 $0.00 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 02 02 Michele Barbara Doug Bragg $125 $280 All - Clerical 00 02 $0.00 $56.00 Prepare for and conduct phone call with Paul Kloft regarding deposition schedule and case status. Review proposed Motion to Amend scheduling order. Compose and forward email to Nick Thede regarding deposition schedule. Phone call with Nick Thede regarding Judicial Settlement Conference and discovery. Compose and forward email to Nick Thede regarding Motion to Amend Scheduling Order and Judicial Settlement Conference. Confer with Fred Millard regarding Judicial Settlement Conference scheduling. Discuss Judicial Settlement Conference scheduling with Doug Bragg. 05 Doug Bragg $280 05 $140.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 02 Fred Millard $350 02 $70.00 Compose and forward emails with Lisa at Smith Freed to schedule and reschedule depositions. Update with Doug Bragg regarding deposition schedule. 03 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 Phone call with Nick Thede regarding Answer to Complaint. Phone call with Don Kelley regarding Bank Instructions. Letter to Client enclosing Jim King's Notice of Taking Deposition and Subpoena for Deposition. Phone call with Don Kelley regarding Bank Instructions. Phone call with Nick Thede regarding deposition schedule. Conference with Fred Millard to analyze RE: status of litigation and discovery. Conduct conference with Doug Bragg to analyze status of litigation and discovery. Review and analyze facts to date concerning Country's affirmative defenses, discovery deadlines and outstanding discovery issues. 0.1 02 0.1 Doug Bragg Doug Bragg Michele Barbara $280 $280 $125 All - Clerical 0.1 02 00 $28.00 $56.00 $0.00 02 02 10 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 All - Duplicative; billed to Millard 02 02 00 $56.00 $56.00 $0.00 10 Fred Millard $350 10 $350.00 12 Fred Millard $350 12 $420.00 7/18/11 7/18/11 Compose letter to Client advising him of trial date. Compose and forward email from Lisa at Smith Freed RE: depositions. 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 7/18/11 Telephone conversation with Nick Thede RE: scheduling depositions. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 7/18/11 Confer with Doug Bragg to contact Paul Kloft to schedule his and his brother's depositions at end of August, 2011. Confer with Michele Barbara RE: depositions. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 7/11/11 7/11/11 7/11/11 7/11/11 7/12/11 7/12/11 7/12/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/13/11 7/14/11 7/15/11 7/15/11 7/18/11 7/18/11 7/18/11 7/18/11 7/18/11 7/19/11 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Prepare draft of Plaintiff's Responses to Defendant's First Interrogatories and Request for Production. Compose and forward email to Lisa at Smith Freed to clarify depositions in this matter. Confer with Doug Bragg to see if Smith Freed will accept service for Jim King. Telephone call to Jim King to schedule deposition and obtain address to send subpoena since he is retired and that he will accept the subpoena via mail. Telephone call from Nick Thede from Smith Freed advising us to subpoena Jim King. Telephone call to Vicky Smith's office to advise her I contacted Jim King personally in error and to advise her of his deposition. Revise Civil Subpoena and Notice of Taking Deposition. Review update from Michele Barbara regarding deposition schedule. 0.7 Michele Barbara $125 03 Michele Barbara $125 02 Michele Barbara 03 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 17 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 03 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 Telephone conversation with Paul Kloft RE: depositions. Amend Notice of Taking Deposition for Jim King. Voicemail to Paul Kloft for Kim Ellingson's contact information. Telephone call from Paul Kloft for contact information for Kim Ellingson and James Kloft. Telephone calls to both Kim Ellingson and James Kloft to schedule their depositions and obtain contact information for subpoenas. 0.1 02 0.1 0.1 Michele Barbara Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 $125 All - Clerical All - Clerical All - Clerical All - Clerical 00 00 00 00 $0.00 $0.00 $0.00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 7/20/11 Compose and forward email to Nick Thede for tentative deposition date and contact information for Kim Ellingson and James Kloft. 02 Michele Barbara $125 All - Clerical 00 $0.00 7/20/11 Telephone call from Earl Dorman of Eugene and says he is the wrong CPA - try Earl Doman of Woodburn. Telephone call from Nick Thede for contact information on Kim Ellingson and confirming that James Kloft is not an employee. Review and analyze letter from Smith Freed and subpoena to Earl Doman. Telephone calls to Lisa and Holly at Smith Freed to let them know date on subpoena is incorrect and to confirm that they have requested the court reporter for Jim King as letter says they will not. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 7/21/11 Prepare letter to Paul Kloft enclosing Dan Thenell's letter dated July 20, 2011 with Earl Doman's subpoena and advising him he is able to attend all depositions and error in date/time for Earl Doman's deposition. 02 Michele Barbara $125 All - Clerical 00 $0.00 7/21/11 Compose and forward email to Nick Thede to follow-up on getting Declaration of Charles Strube notarized. Prepare for and conduct meeting with Paul Kloft to review responses to Request for Production and Request for Interrogatories. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 30 Doug Bragg $280 30 $840.00 7/27/11 Compose and forward email to Fred Millard and Doug Bragg RE: Dan Thenell's telephone call RE: rescheduling Jeff Frenette's deposition and Dan Thenell's request for settlement discussions. 2.6 Fred Millard $350 0.6 $210.00 7/27/11 Review message from Dan Thenell RE: Settlement Conference Proposal. 0.1 Fred Millard $350 0.1 $35.00 7/27/11 Conference with Paul Kloft to prepare documents for responses to discovery requests and responses. Begin preparing Response to First Request for Production. Telephone call from Dan Thenell to reschedule Jeff Frenette's deposition and organizational deposition to August 31, 2011 and noting his request for settlement discussions with Fred Millard and Doug Bragg. 15 Michele Barbara $125 15 $187.50 08 0.1 Michele Barbara Michele Barbara $125 $125 08 00 $100.00 $0.00 7/19/11 7/19/11 7/19/11 7/19/11 7/19/11 7/19/11 7/19/11 7/19/11 7/20/11 7/20/11 7/20/11 7/20/11 7/21/11 7/21/11 7/27/11 7/27/11 7/27/11 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze workout agreement with Bank regarding unpaid collateral. Draft revisions to workout agreement. Compose and forward email workout agreement revisions to Fred Millard for review. Compose letter to Nick Thede RE: scheduling depositions. Compose and forward email Amended Notice to Amy Kilburg from Bodyfelt Mount since fax is not working. Confer with Doug Bragg RE: depositions. 02 Doug Bragg 02 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason 2.0 Vague/Excessive All - Clerical Page 18 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 7/27/11 Compose and forward email to Fred Millard and Doug Bragg RE: Dan Thenell's telephone call RE: rescheduling Jeff Frenette's deposition and Dan Thenell's request for settlement discussions. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 7/27/11 Compose and forward email to/from court reporter to confirm deposition. Amend Notice of Taking Deposition for Organizational Individual. 02 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 Prepare letter to Client enclosing Amended Notice for Taking Deposition. Phone call to Dan Thenell regarding possible settlement, left voicemail. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Telephone call to Holly at Smith Freed to confirm start time of Paul Kloft's deposition. Review electronic discovery (945 pages) to find letter dated January 11, 2010 from Country. Finish draft Responses to Request for Production. Continue looking for January 11, 2010 letter from Country. Photocopy documents for preparation of a duplicate binder with divider tabs of Precision Seed Cleaner's Inc. "Original Paperwork." 0.1 Michele Barbara $125 All - Clerical 00 $0.00 05 Michele Barbara $125 All - Clerical 00 $0.00 10 10 10 Michele Barbara Michele Barbara Tracey Poole $125 $125 $115 All - Clerical All - Clerical 10 00 00 $125.00 $0.00 $0.00 45 Doug Bragg $280 45 $1,260.00 1.6 4.1 03 Fred Millard Fred Millard Michele Barbara $350 $350 $125 1.6 4.1 00 $560.00 $1,435.00 $0.00 03 Doug Bragg $280 03 $84.00 8/4/11 Review and analyze Jim King's file to assist Fred Millard in preparing for deposition. Review and analyze documents for Deposition of Jim King. Defend Deposition of Earl Doman with travel. Confirm Jim King's deposition with Holly at Smith Freed, Annie at Bodyfelt Mount and court reporter. Prepare for and conduct phone call with Paul Kloft regarding discovery requests, depositions and possible settlement. Assist Fred Millard in preparation for deposition of James King. 0.7 Doug Bragg $280 00 $0.00 8/4/11 Review and analyze potential exhibits for James King's deposition. 0.4 Doug Bragg $280 0.4 $112.00 8/4/11 Confer with Fred Millard to analyze deposition of James King. 0.4 Doug Bragg $280 00 $0.00 8/4/11 Compose and forward email to Dan Thenell and Nick Thede requesting extension on Response to Request for Production. Conduct Deposition of Jim King with travel (24 miles). Confer with Doug Bragg to analyze RE: James King's deposition. Continue preparing for James King's Deposition. Confer with Fred Millard to continue analyzing deposition of James King. 0.1 Doug Bragg $280 0.1 $28.00 5.1 0.4 2.7 03 Fred Millard Fred Millard Fred Millard Doug Bragg $350 $350 $350 $280 5.1 0.4 2.7 00 $1,785.00 $140.00 $945.00 $0.00 8/5/11 Review/respond to email from Dan Thenell regarding discovery extension, Second Amended Complaint and possible settlement. 0.1 Doug Bragg $280 0.1 $28.00 8/5/11 Confer with Doug Bragg to continue analyzing deposition of James King. 03 Fred Millard $350 03 $105.00 8/8/11 8/11/11 8/11/11 8/11/11 8/12/11 8/12/11 8/12/11 Review and analyze deposition transcript of James King. Phone call to Paul Kloft regarding discovery, left voicemail. Review email regarding discovery documents from Precision. Draft email to Dan Thenell regarding possible stay. Review email from Dan Thenell regarding case status. Review and analyze document production from Client. Matter conference with Fred Millard to analyze document production, case status and possible stay. 1.1 0.1 0.1 02 0.1 2.1 05 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 $280 $280 1.1 0.1 0.1 02 0.1 2.1 00 $308.00 $28.00 $28.00 $56.00 $28.00 $588.00 $0.00 7/27/11 7/27/11 7/28/11 7/28/11 7/29/11 7/29/11 7/29/11 7/29/11 8/2/11 8/3/11 8/3/11 8/3/11 8/4/11 8/4/11 8/4/11 8/4/11 8/5/11 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All- Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 19 of 161 Date 8/12/11 8/15/11 8/15/11 8/15/11 8/15/11 8/15/11 8/15/11 8/15/11 8/15/11 8/16/11 8/16/11 8/16/11 8/16/11 8/16/11 8/16/11 8/16/11 8/16/11 8/17/11 8/17/11 8/17/11 8/17/11 8/17/11 8/18/11 8/18/11 8/18/11 8/19/11 8/19/11 8/19/11 8/19/11 8/19/11 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Matter conference with Doug Bragg to analyze document production, case status and possible stay. Conduct research on attorney fees and analysis of effect of contingency fees. Draft memo Re: Research findings on attorney fees and an analysis of the effect of contingency fees. Confer with Michele Barbara RE: additional discovery documents. 05 Fred Millard $350 05 $175.00 20 Christopher Fanning $110 20 $220.00 05 Christopher Fanning $110 05 $55.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Doug Bragg to analyze issues for purposes of draft a policy limits settlement demand. Update Doug Bragg regarding phone call with Don Kelley on case status. 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 Confer with Doug Bragg to analyze stay and issues that need resolution for attempted settlement. Meet with Paul Kloft RE: additional discovery documents. Confer with Doug Bragg RE: meeting with Paul Kloft and analyzing additional discovery documents. Review and analyze documents from Client's accountant. Review/revise Draft Response to Defendant's Request for Production and Request for Interrogatories. Review and analyze research memo on contingent attorney fees under 742.061. Review and analyze discovery documents (2083 pages). Compose and forward email to Dan Thenell and Nick Thede regarding discovery responses. Review and analyze email from Dan Thenell regarding stay of the lawsuit to allow for settlement discussions. Assist Fred Millard and Doug Bragg in preparing for depositions. 05 Fred Millard $350 05 $175.00 0.1 0.6 Michele Barbara Michele Barbara $125 $125 0.1 00 $12.50 $0.00 03 08 Doug Bragg Doug Bragg $280 $280 03 08 $84.00 $224.00 02 Doug Bragg $280 02 $56.00 08 0.1 Doug Bragg Doug Bragg $280 $280 08 0.1 $224.00 $28.00 02 Doug Bragg $280 02 $56.00 10 Michele Barbara $125 All - Vague 00 $0.00 Prepare document production (2083 pages) for bates numbering and production. Research Attorney Fees under ORS 742.061 in contingency cases. 28 Michele Barbara $125 All - Clerical 00 $0.00 05 Christopher Fanning $110 05 $55.00 Review interrogatories and organizing documents (2083 pages) for responses to discovery requests. Review and analyze documents for production (2083 pages). Revise draft Responses to Interrogatories and Requests for Production to referenced bates numbers. Make revisions to Responses to First Request for Production and Interrogatories. Review/Revise draft Responses to Requests for Production. Review and respond to Dan Thenell's email RE: potential stay. Scan bates numbered documents (2083 pages )and proof that all documents were scanned. Review and analyze additional discovery documents. Amended Response to answer to request for documents. Continue with amending Response to Answer to Request for Documents. Attend meeting with Client and Fred Millard to review and analyze Responses to Requests for Production, trial preparation and discuss possible stay of proceedings to pursue settlement. 20 Christopher Fanning $110 20 $220.00 22 08 Doug Bragg Doug Bragg $280 $280 22 08 $616.00 $224.00 1.4 Michele Barbara $125 All - Clerical 00 $0.00 1.1 02 20 Doug Bragg Fred Millard Michele Barbara $280 $350 $125 All - Clerical 1.1 02 00 $308.00 $70.00 $0.00 12 0.7 10 Christopher Fanning Christopher Fanning Christopher Fanning $110 $110 $110 12 0.7 10 $132.00 $77.00 $110.00 52 Doug Bragg $280 00 $0.00 Revise draft Responses to Request for Production and Interrogatories. 05 Doug Bragg $280 05 $140.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical; time billed to Bragg All - Duplicative; billed to Millard Page 20 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 8/19/11 Prepare for and conduct meeting with Client and Doug Bragg to review and analyze Responses to Requests for Production, trial preparation and discuss possible stay of proceedings to pursue settlement. 52 Fred Millard $350 52 $1,820.00 8/19/11 05 Michele Barbara $125 05 $62.50 15 45 15 Michele Barbara Michele Barbara Doug Bragg $125 $125 $280 00 00 00 $0.00 $0.00 $0.00 8/23/11 Meet with Paul Kloft to go over additional documents (655 pages) for production. Prepare additional (655 pages) discovery for production. Analyze and index bates number binders #1 - #3 of 5 binders. Meeting with Paul Kloft and Fred Millard to analyze possible stay for settlement discussions. Review/revise Supplemental Response to Request for Production. 02 Doug Bragg $280 02 $56.00 8/23/11 Review and analyze additional documents from Client (339 pages) 02 Doug Bragg $280 02 $56.00 8/23/11 Direct Michele Barbara to bates number for supplemental production. 0.1 Doug Bragg $280 0.1 $28.00 8/23/11 Meeting with Client and Doug Bragg to analyze potential stay for settlement discussions. Continue indexing Precision's production binders #4 - #5. Meet with Paul Kloft to go over receipts and additional documents for discovery (339 pages). Bates number documents and prepare for binder and document production. Begin draft Supplemental Response to Request for Production. Review/respond to emails from Holly at Smith Freed RE: documents produced. Advised her that we put them on a CD. Phone call to Don Kelley RE: potential stay and IRS issues, left message. 15 Fred Millard $350 15 $525.00 10 03 Michele Barbara Michele Barbara $125 $125 All - Clerical 00 03 $0.00 $37.50 12 Michele Barbara $125 All - Clerical 00 $0.00 03 03 Michele Barbara Michele Barbara $125 $125 All - Clerical 03 00 $37.50 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Analyze and index additional documents received from Client. Phone call with Kevin Preston from American Leasing regarding status of payment on the claim. Phone call with Nick Thede regarding discovery issues (Defendants need to produce Paul Kloft's recorded statement and Examination Under Oath transcript). Phone call with Dan Thenell regarding Examination Under Oath transcripts for Paul Kloft. Confer with Fred Millard analyzing phone call with Dan Thenell RE: discovery issue and Request for Settlement Demand. Review and analyze file regarding policy limits for purposes of draft Settlement Demand. Confer with Fred Millard to further analyze policy limits for purposes of draft Settlement Demand . Confer with Doug Bragg analyzing policy limits for purposes of draft settlement demand. Review Country's discovery documents (945 pages) to find Paul Kloft's Examination Under Oath and recorded statement. Compose and forward emails from Dan Thenell attaching Paul Kloft's Examination Under Oath; Prepare letter to Paul Kloft enclosing two parts of his Examination Under Oath. Phone call with Dan Thenell regarding status of the stay. Confer with Fred Millard analyzing stay and issues that need resolution for attempted settlement. Direct Tracey Poole to review discovery to prepare a spreadsheet on the damages. Review and analyze tax lien documents. 03 02 Michele Barbara Doug Bragg $125 $280 03 02 $37.50 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 0.7 $196.00 02 Doug Bragg $280 00 $0.00 02 Fred Millard $350 02 $70.00 08 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 05 Doug Bragg Doug Bragg $280 $280 All -Duplicative; billed to Millard 0.1 00 $28.00 $0.00 02 Doug Bragg $280 02 $56.00 Doug Bragg $280 02 8/19/11 8/22/11 8/23/11 8/23/11 8/23/11 8/23/11 8/23/11 8/23/11 8/24/11 8/24/11 8/25/11 8/25/11 8/25/11 8/25/11 8/25/11 8/25/11 8/25/11 8/25/11 8/25/11 8/26/11 8/26/11 8/26/11 8/26/11 3:10-cv-01023-HZ 02 ATTACHMENT 1 All - Vague All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard $56.00 Page 21 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Hrs Awarded Amount 02 00 $56.00 $0.00 8/26/11 8/26/11 Phone call with Don Kelley regarding case status. Confer with Fred Millard analyzing telephone conversation with Don Kelley regarding case status and issues relating to stay. 02 03 Doug Bragg Doug Bragg $280 $280 8/26/11 Confer with Doug Bragg analyzing stay and issues that need resolution for attempted settlement. Confer with Doug Bragg regarding case status. Review and analyze our recent discovery response for location of pertinent bates numbered documents for information necessary to create spreadsheet of coverage/damages (3077 pages). 05 Fred Millard $350 05 $175.00 02 0.4 Fred Millard Tracey Poole $350 $115 02 0.4 $70.00 $46.00 02 Tracey Poole $115 All - Duplicative; billed to Bragg 00 $0.00 8/29/11 Discussion with attorney Doug Bragg regarding instructions for preparation of a spreadsheet which provides various claims and the different coverages under each and other necessary information to be inputted into spreadsheet. Confer with Fred Millard to analyze stipulated stay. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 8/29/11 8/29/11 Confer with Tracey Poole analyzing damages spreadsheet. Review, analyze, respond, and revise Motion for Stay for 60 Days. 02 0.7 Doug Bragg Fred Millard $280 $350 02 0.7 $56.00 $245.00 8/29/11 8/29/11 Confer with Doug Bragg analyzing stipulated stay. Review and analyze Unopposed Motion to Stay Litigation and Declaration of Dan Thenell in support thereof. Review and analyze pertinent bates number documents for information to be inserted into coverage/damage spreadsheet and create spreadsheet and begin inputting information. Compose and forward email to Holly at Smith Freed for the need to cancel depositions with court reporter; Compose and forward email to Zaro & Zaro to cancel Jeff Frenette's deposition; Compose and forward emails with Dan Thenell and Holly to set up meeting to go over further settlement. Prepare for and conduct Client meeting with Paul Kloft and Fred Millard analyzing scope of loss and analyze settlement position. 0.1 0.1 Fred Millard Michele Barbara $350 $125 0.1 0.1 $35.00 $12.50 1.1 Tracey Poole $115 1.1 $126.50 05 Michele Barbara $125 All - Clerical 00 $0.00 35 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Prepare for and conduct Client meeting with Paul Kloft and Doug Bragg analyzing scope of loss and settlement position. Tally inventory sheets for Client meeting. Attend meeting with Paul Kloft and Fred Millard to analyze settlement issues and obtain figures for settlement. Telephone call to Earl Doman's office to give him billing information for case. Confer with Tracey Poole analyzing settlement numbers and related documents for meeting. Continue inputting information into damages/coverage table. Complete damages/coverage spreadsheet. Review potential subrogation issue pertaining to insurer making partial payment of Client's loss via another's policy. Review e-memo from Michele Barbara RE: seed owner's values. 35 Fred Millard $350 35 $1,225.00 09 28 Heidi Gross Michele Barbara $50 $125 All - Duplicative; billed to Millard 09 00 $45.00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 03 $37.50 20 10 0.1 Tracey Poole Tracey Poole Fred Millard $115 $115 $350 20 10 0.1 $230.00 $115.00 $35.00 0.1 Fred Millard $350 0.1 $35.00 Telephone conversation with Paul Kloft on status of seed owners and values. Compose and forward email to Fred Millard and Doug Bragg RE: status of seed owners and values. Review and analyze Coverage/Damage Spreadsheet and add additional bates numbered pages. 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Duplicative; billed to Millard 00 $0.00 13 Michele Barbara $125 13 $162.50 8/26/11 8/26/11 8/26/11 8/29/11 8/30/11 8/31/11 8/31/11 8/31/11 8/31/11 8/31/11 9/1/11 9/2/11 9/6/11 9/7/11 9/7/11 9/7/11 9/7/11 9/7/11 3:10-cv-01023-HZ ATTACHMENT 1 Page 22 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Continue working on spreadsheet for values of seed and Review bates numbered documents. Re-edit formatting of coverage/damages spreadsheet after Michele Barbara's additions to spreadsheet. Confer with Michele Barbara to analyze new lawsuit against Precision Seed from Lebanon's Seaboard. Review and analyze insurance policies for scheduled and unscheduled coverages. Double check supporting documents for spreadsheet and analyzing claim in preparation for meeting with Dan Thenell. Review and analyze insurance policies to include coverage limits in spreadsheet. Analyze additional damages values and revise spreadsheet. Telephone conversations with Paul Kloft RE: new lawsuit against him from Lebanon's Seaboard Corp. and seed values faxed over. 43 Michele Barbara $125 43 $537.50 02 Tracey Poole $115 02 $23.00 0.1 Fred Millard $350 0.1 $35.00 0.7 Heidi Gross $50 0.7 $35.00 09 Michele Barbara $125 09 $112.50 0.6 Michele Barbara $125 0.6 $75.00 05 0.4 Michele Barbara Michele Barbara $125 $125 05 0.4 $62.50 $50.00 9/9/11 Left message for Don Kelley to obtain seed values of Reiling Farms. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 9/9/11 0.1 Michele Barbara $125 All - Duplicative; billed to Millard 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.5 Doug Bragg $280 05 $140.00 0.1 03 02 Fred Millard Michele Barbara Michele Barbara $350 $125 $125 0.1 03 02 $35.00 $37.50 $25.00 9/12/11 Confer with Fred Millard to analyze new lawsuit against Precision Seed from Lebanon's Seaboard. Compose and forward email with attached Lebanon's Seaboard lawsuit to Fred Millard and Doug Bragg for review. Review and analyze damages chart; Confer with Michele Barbara analyzing the damages chart. Receive update from Michele Barbara RE: check status. Telephone call from Paul Kloft RE: values and signed contracts. Update values on damages spreadsheet based upon comments by Client. Confer with Fred Millard to call for status of check. 0.1 Michele Barbara $125 All - Duplicative; billed to Millard 00 $0.00 9/12/11 Telephone call to Holly at Smith Freed to check on status of check. 02 Michele Barbara $125 All - Clerical 00 $0.00 9/12/11 9/12/11 9/12/11 Review calculations to obtain grand total of claim. Telephone call to Paul Kloft RE: additional values. Additional telephone calls to/from Paul Kloft RE: additional values 0.7 03 0.6 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 0.7 03 0.6 $87.50 $37.50 $75.00 9/12/11 9/13/11 Recalculate worksheets including new values. Prepare letter to Dan Thenell tendering Lebanon Seaboard case to Country Mutual. Phone call with Fred Millard and Don Kelley regarding issues with PNC, the Lebanon Sea Board lawsuit and business interruption coverage. 0.6 02 Michele Barbara Doug Bragg $125 $280 0.6 02 $75.00 $56.00 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Phone call with Fred Millard and Paul Kloft to analyze business interruption coverage. Telephone call with Phil Kelley analyzing tax levy issues. Confer with Michele Barbara requesting meeting with Earl Doman and Client. Phone call with Doug Bragg and Don Kelley regarding issues with PNC, the Lebanon Sea Board lawsuit and business interruption coverage. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 0.1 Fred Millard Fred Millard $350 $350 03 0.1 $105.00 $35.00 05 Fred Millard $350 05 $175.00 Phone call with Doug Bragg and Paul Kloft to analyze business interruption coverage. Confer with Doug Bragg to analyze damages spreadsheet. Finalize claim spreadsheet for meeting with Dan Thenell. 02 Fred Millard $350 02 $70.00 02 03 Michele Barbara Michele Barbara $125 $125 02 03 $25.00 $37.50 9/8/11 9/8/11 9/9/11 9/9/11 9/9/11 9/9/11 9/9/11 9/9/11 9/9/11 9/12/11 9/12/11 9/12/11 9/12/11 9/13/11 9/13/11 9/13/11 9/13/11 9/13/11 9/13/11 9/13/11 9/13/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 23 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Confer with Fred Millard analyzing need for meeting with Client and Earl Doman; Telephone conversations with Earl Doman's office and Paul Kloft to schedule appointment for Thursday, September 29, 2011 at 10:00 a.m. Telephone conversations with Earl Doman's office and Paul Kloft to schedule appointment for Thursday, September 29, 2011 at 10:00 a.m. 0.1 Michele Barbara $125 All - Duplicative; billed to Millard 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 9/14/11 Confer with Michele Barbara to analyze damages of seed of others. 02 Doug Bragg $280 02 $56.00 9/14/11 Review fax from Paul Kloft with additional contracts; Confer with Doug Bragg analyzing additional contracts for purposes of production and impact on seed value and Business Interruption damages; Telephone call to Paul Kloft for explanation of faxed items. 03 Michele Barbara $125 0.1 $12.50 9/14/11 Telephone conversations with Paul Kloft and Karen at Hoffman Farms to discuss seed being sold to Production Service International. 03 Michele Barbara $125 03 $37.50 9/14/11 9/14/11 Finalize damages spreadsheet. Confer with Heidi Gross to double check figures on spreadsheet. 08 02 Michele Barbara Michele Barbara $125 $125 08 02 $100.00 $25.00 9/14/11 Review and analyze email from Dan Thenell and confer with Fred Millard to reschedule meeting to Monday, September 19, 2011. 03 Michele Barbara $125 03 $37.50 9/15/11 Review and analyze CMI and King discovery documents (2073 pages) for documents relating to policy limits. Review and analyze seed damage spreadsheet and re-run the totals. 10 Doug Bragg $280 10 $280.00 0.6 Heidi Gross $50 0.6 $30.00 Review and analyze correspondence from Don Kelley regarding PNC's claim. Phone call with Phil Kelley regarding IRS negotiations. Review and analyze letter from Phil Kelley regarding tax issues. 02 Doug Bragg $280 02 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 Assist Fred Millard to prepare for meeting with Dan Thenell RE: coverages. Prepare for meeting on coverage issues with Dan Thenell. Prepare for meeting with Dan Thenell RE: coverages. Conduct meeting with Dan Thenell RE: coverages. Telephone call with Don Kelley RE: Coordinating payment of various vendors from anticipated partial payment by Country Mutual. 02 Doug Bragg $280 02 $56.00 05 20 2.1 0.7 Doug Bragg Fred Millard Fred Millard Fred Millard $280 $350 $350 $350 05 20 2.1 0.7 $140.00 $700.00 $735.00 $245.00 03 0.4 0.1 20 Fred Millard Fred Millard Fred Millard Fred Millard $350 $350 $350 $350 03 0.4 0.1 20 $105.00 $140.00 $35.00 $700.00 9/27/11 Review and analyze GE Capital Settlement Agreement. Review and respond to Dan Thenell's email RE: Ionian. Notify Client RE: Dan Thenell's email and response thereto. Prepare for and conduct client meeting Review various losses, e.g., seed of others, equipment vendors. Review and analyze correspondence from Phil Kelley RE: IRS lien. 03 Fred Millard $350 03 $105.00 9/27/11 Telephone call to Holly at Smith Freed regarding settlement payment. 0.1 Michele Barbara $125 00 $0.00 9/29/11 Travel to/from Earl Doman's office; Conduct meeting with Earl Doman and Paul Kloft regarding business interruption loss analysis. 25 Doug Bragg $280 25 $700.00 9/30/11 Telephone call with Paul Kloft RE: the checks received by Country Mutual; Schedule appointment to discuss creditor issues. 0.1 Heidi Gross $50 00 $0.00 9/13/11 9/13/11 9/15/11 9/16/11 9/16/11 9/19/11 9/19/11 9/19/11 9/19/11 9/19/11 9/27/11 9/27/11 9/27/11 9/27/11 9/27/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 0.2 - Duplicative; billed to Bragg All - Clerical All - Clerical Hrs Awarded Amount Page 24 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Per Doug Bragg, left message with Don Kelley regarding whether or not he filed an Oregon Rules of Civil Procedure 69 letter RE: Lebanon Seaboard. Left message twice asking Don Kelley to confirm the IRS check is to be sent via courier to his office today. Call returned by Don's office confirming the check is to be sent today. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 Telephone calls with Rush Process (three times) scheduling pickup of the check. Telephone call with Don Kelley re: Lebanon Seaboard default; Don Kelley sent Oregon Rules of Civil Procedure 69 letter to Sullivan & Terranova as well as speak to Brian Sullivan; Notified Doug Bragg. 0.1 Heidi Gross $50 All - Clerical 00 $0.00 02 Heidi Gross $50 All - Clerical 00 $0.00 Prepare and attend meeting with Paul Kloft and Fred Millard analyzing settlement discussions and analyzing distribution of settlement proceeds thus far. Prepare and attend meeting with Paul Kloft and Doug Bragg analyzing settlement discussions and analyzing distribution of settlement proceeds thus far. Review listing of creditors and payoff amounts from Don Kelley. 20 Doug Bragg $280 All- Duplicative; billed to Millard 00 $0.00 20 Fred Millard $350 20 $700.00 02 Doug Bragg $280 02 $56.00 Review emails from Michele Barbara. Prepare payments to Client, GE Capital and Kelley & Kelley. E-memo Doug Bragg RE: payments to Client, GE Capital and Kelley & Kelley. Phone call with Bill Sime (Country Attorney) regarding Lebanon Seed litigation lawsuit. Meeting with Paul Kloft analyzing business interruption coverage damages and case status. Meet with Paul Kloft to analyze leases and documentation for equipment leases and business interruption. Phone call with Don Kelley regarding bank agreement and status of funds. Review and analyze Assignment of Contract Rights. Phone call with Don Kelley regarding issues with partial assignment of claim to Bank. Review document production regarding history of policy limits modifications. Phone call with Don Kelley regarding Bank Assignment issues. Email Don Kelley advising him that United Portfolio Management received the payment for GE Capital in the amount of $8,812.39 on October 17, 2011. Letter to Paul Kloft RE: United Portfolio Management received the payment for GE Capital in the amount of $8,812.39 on October 17, 2011. 0.1 02 0.1 Doug Bragg Heidi Gross Heidi Gross $280 $50 $50 0.1 00 00 $28.00 $0.00 $0.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 10 $280.00 15 Michele Barbara $125 15 $187.50 02 Doug Bragg $280 02 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 10 Doug Bragg $280 10 $280.00 0.1 03 Doug Bragg Michele Barbara $280 $125 All - Clerical 0.1 00 $28.00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 10/24/11 10/24/11 10/25/11 10/25/11 Phone call with Paul Kloft regarding Financial Pacific payout. Email Fred Millard regarding Financial Pacific payout. Draft Request for Production of Information on Linda Cord. Confer with Doug Bragg to analyze and develop additional Requests for Production to Country Mutual Insurance Company. 03 0.1 0.4 02 Doug Bragg Doug Bragg Christopher Fanning Christopher Fanning $280 $280 $182 $182 All - Duplicative; billed to Bragg 03 0.1 0.4 00 $84.00 $28.00 $72.80 $0.00 10/25/11 Confer with Chris Fanning to analyze and develop additional Requests for Production to Country Mutual Insurance Company. 02 Doug Bragg $280 02 $56.00 9/30/11 9/30/11 9/30/11 9/30/11 9/30/11 10/3/11 10/3/11 10/4/11 10/8/11 10/8/11 10/8/11 10/10/11 10/11/11 10/11/11 10/13/11 10/14/11 10/14/11 10/19/11 10/20/11 10/20/11 10/20/11 3:10-cv-01023-HZ Explanation ATTACHMENT 1 All - Clerical All - Clerical Hrs Awarded Amount Page 25 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg 10/26/11 Confer with Doug Bragg to analyze and develop additional discovery requests to Country Mutual Insurance to be sent out on Nov. 1. 02 Christopher Fanning $182 10/26/11 Review and analyze Interrogatories and draft Requests for Production. 09 Christopher Fanning 10/26/11 Confer with Chris Fanning to analyze and develop additional discovery requests to Country Mutual Insurance to be sent out on November 1st. 02 10/26/11 10/26/11 10/26/11 10/28/11 Review and analyze Assignment from bank. Phone call with Don Kelley to analyze Assignment and discuss payment of lessors. Direct Heidi Gross to send check to Don Kelley to pay the bank. Phone call with Fred Millard analyzing Bank Assignment. 10/28/11 10/28/11 10/28/11 10/28/11 10/28/11 10/28/11 10/31/11 10/31/11 10/31/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/1/11 11/2/11 11/2/11 11/2/11 11/2/11 11/2/11 3:10-cv-01023-HZ Hrs Awarded Amount 00 $0.00 $182 09 $163.80 Doug Bragg $280 02 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 Confer with Michele Barbara analyzing status of Bank Assignment. 02 Doug Bragg $280 02 $56.00 Phone call with Don Kelley regarding bank check. Email Heidi Gross regarding bank check. Confer with Doug Bragg to analyze Bank Assignment. Emails to/from Fred Millard RE: signature on revised Assignment from West Coast Bank. Review and analyze prior drafts of agreement and his signature on Irrevocable Instructions and advised Fred Millard on same. Telephone call to Don Kelley regarding payment of Bank. Prepare letter to Don Kelley RE: payment of Bank. Telephone call to Don Kelley's office RE: Assignment and no signature line for Fred Millard to sign. Confer with Doug Bragg to analyze and develop requests for production, interrogatories and admissions. Draft Requests for Production, Requests for Interrogatories, and Requests for Admission. Confer with Michele Barbara regarding reset of depositions and calendaring of new deadlines. Draft cover letter to Dan Thenell regarding case status and discovery requests. Phone call with Don Kelley regarding Bank Assignment and Irrevocable Instructions. Prepare and make phone call to Dan Thenell regarding responding to the court order, left voicemail. Confer with Chris Fanning analyzing and developing Requests for Production, Interrogatories and Admissions. Review/revise draft Request for Production, Interrogatories, and Admissions. Confer with Doug Bragg to forward signed Irrevocable Instructions to Don Kelley. Email to Don Kelley RE: same. Finalize Third Request for Production. Phone call with Court Clerk regarding case status. Draft Email to Dan Thenell regarding reinstating the case. Review/respond to email from Dan Thenell regarding additional delay. 0.1 0.1 02 0.1 Doug Bragg Doug Bragg Fred Millard Michele Barbara $280 $280 $350 $125 0.1 0.1 02 00 $28.00 $28.00 $70.00 $0.00 02 Michele Barbara $125 02 $25.00 02 02 02 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 All - Clerical All - Clerical All - Clerical 00 00 00 $0.00 $0.00 $0.00 02 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 30 Christopher Fanning $182 30 $546.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 09 Doug Bragg $280 09 $252.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 03 02 02 03 Michele Barbara Michele Barbara Doug Bragg Doug Bragg Doug Bragg $125 $125 $280 $280 $280 All - Clerical 00 03 02 02 03 $0.00 $37.50 $56.00 $56.00 $84.00 Review and analyze denial of coverage letter regarding the Lebanon lawsuit. Phone call with Don Kelley analyzing Dan Thenell's request for a further stay and status of creditor negotiations. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 ATTACHMENT 1 All - Duplicative; billed to Millard All - Clerical Page 26 of 161 Date Hrs Awarded Amount 0.1 $28.00 $280 0.1 $28.00 Doug Bragg $280 0.4 $112.00 03 2.1 Fred Millard Fred Millard $350 $350 03 2.1 $105.00 $735.00 Review e-memo (analyzing discussion with Don Kelley and email from Dan Thenell RE: further stay). Email Dan Thenell regarding possible additional payment for the requested stay. Update Fred Millard on case status and recent developments. 0.1 Fred Millard $350 0.1 $35.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 All- Duplicative; billed to Millard 00 $0.00 11/3/11 11/3/11 Email Don Kelley regarding Lebanon Seaboard issues. Matter conference with Fred Millard analyzing settlement discussions and damages, and develop strategy relating to same. 0.1 10 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 11/3/11 11/3/11 11/3/11 Review liability policy relating to Lebanon Seaboard litigation. Draft letter to Don Kelley regarding Lebanon Seaboard lawsuit. Review email from Fred Millard regarding Country's Request for 30 Days. Draft e-memo RE: Country's Request for Further Stay. Confer with Doug Bragg analyzing case status and recent developments. 09 0.7 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 09 0.7 0.1 $252.00 $196.00 $28.00 02 03 Fred Millard Fred Millard $350 $350 02 03 $70.00 $105.00 Matter conference with Doug Bragg analyzing Country's Request for Extension. Draft Motion to Reinstate and Supporting Declaration. Confer with Doug Bragg to analyze Motion to Reinstate and Supporting Declaration. Phone call with Dan Thenell regarding case reinstatement and scheduling order. Update Fred Millard regarding phone call with Dan Thenell on reinstatement of case, analyzing reinstatement. Direct Chris Fanning to prepare Motion to Reinstate. Phone call with Paul Kloft regarding case status and creditor negotiations. Review notices from court regarding filing of Motion to Reinstate. 10 Fred Millard $350 10 $350.00 10 0.1 Christopher Fanning Christopher Fanning $182 $182 10 00 $182.00 $0.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 0.1 02 Doug Bragg Doug Bragg Fred Millard $280 $280 $350 02 0.1 02 $56.00 $28.00 $70.00 11/4/11 11/7/11 Review Motion to Reinstate and Supporting Declaration. Direct Chris Fanning to make corrections and file. Receive update from Doug Bragg regarding phone call with Dan Thenell and analyze case reinstatement. Prepare Amended Organizational Deposition Notice. Revise Motion to Reinstate and request Scheduling Conference. 03 0.4 Michele Barbara Christopher Fanning $125 $182 All - Clerical 00 0.4 $0.00 $72.80 11/8/11 Review/respond to emails from Fred Millard analyzing damages. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 11/8/11 11/9/11 Review/respond to email from Doug Bragg analyzing damages. Phone call with Client regarding discovery and reinstatement status. 03 02 Fred Millard Doug Bragg $350 $280 03 02 $105.00 $56.00 11/10/11 Confer with Fred Millard and Heidi Gross analyzing creditor payments and accounting. 05 Doug Bragg $280 00 $0.00 11/2/11 11/2/11 11/2/11 11/2/11 11/2/11 11/2/11 11/3/11 11/3/11 11/3/11 11/3/11 11/3/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 11/4/11 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Draft e-memo to Fred Millard (analyzing discussion with Don Kelley and email from Dan Thenell RE: further stay). Phone call to Paul Kloft regarding Request for Stay; Left voicemail. 02 Doug Bragg $280 0.1 Duplicative; billed to Millard 0.1 Doug Bragg Phone call with Client regarding case status and Dan's Request for 30 Day Extension. Respond to Don Kelley RE: creditor account summary. Review and analyze Creditor account summary provided by Don Kelley. 0.4 Explanation ATTACHMENT 1 All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 27 of 161 Date Hrs Req Pltf Lawyer Rate 05 Fred Millard $350 05 Heidi Gross $50 0.1 Doug Bragg 02 11/11/11 Confer with Doug Bragg and Heidi Gross analyzing creditor payments and accounting. Confer with Doug Bragg and Fred Millard analyzing creditor payments and accounting. Listened to voicemail from Don Kelley regarding settlement of National's claims relating to destroyed lease equipment. Confer with Heidi Gross analyzing scope of creditor payments and additional settlement. Draft letter to Don Kelley regarding trust fund and creditor payments. 11/11/11 11/11/11 11/10/11 11/10/11 11/11/11 11/11/11 11/11/11 11/11/11 11/14/11 11/14/11 11/14/11 11/14/11 11/14/11 11/14/11 11/14/11 11/14/11 11/15/11 11/15/11 11/15/11 11/15/11 11/16/11 11/16/11 11/16/11 11/16/11 11/16/11 11/16/11 11/16/11 11/16/11 3:10-cv-01023-HZ Hrs Awarded Amount 05 $175.00 00 $0.00 $280 0.1 $28.00 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Draft e-memo to Fred Millard regarding Equipment Lessor payments. 02 Doug Bragg $280 00 $0.00 Phone call to Don Kelley regarding creditor payments; Left message RE: same. Draft e-memo to Doug Bragg analyzing Equipment Lessor payments. 0.1 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 Confer with Doug Bragg analyzing scope of creditor payments and additional settlement. Phone call with Don Kelley regarding payments to creditors. Draft e-memo to Fred Millard and Heidi Gross regarding payments to creditors. Confer with Heidi Gross analyzing creditor payments. Phone call with Earl Doman regarding status of business interruption analysis. Review E-memo RE: settlement of Equipment Lessor claims. Confer with Doug Bragg regarding creditor payments. 02 Heidi Gross $50 All - Duplicative; billed to Bragg 00 $0.00 05 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 05 00 $140.00 $0.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 02 Fred Millard Heidi Gross $350 $50 All - Duplicative; billed to Bragg 02 00 $70.00 $0.00 Review E-memo from Doug Bragg analyzing settlement of Equipment Lessor claims. Telephone calls to Paul Kloft to reschedule appointment and Earl Doman for Business Interruption costs. Email Dan Thenell requesting Country's position on coverages. Confer with Fred Millard analyzing continued settlement discussions with Country Mutual. Draft communication to Dan Thenell outlining Precision's settlement position. Confer with Doug Bragg analyzing continued settlement discussions with Country Mutual. Phone call with Paul Kloft analyzing damages proof and updating on settlement discussions status. Confer with Fred Millard analyzing as to matters discussed in phone calls with Don Kelley and Paul Kloft, case status and coverage dispute. 02 Heidi Gross $50 All - Duplicative; billed to Millard 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 20 Fred Millard $350 20 $700.00 02 Fred Millard $350 02 $70.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 00 $0.00 Review and analyze email from Don Kelley directing payment of Financial Pacific claim. Advise Fred Millard and Heidi Gross regarding same. Phone call with Don Kelley analyzing Lebanon Seaboard lawsuit and coverage issues. Confer with Doug Bragg analyzing matters discussed in phone calls with Don Kelley and Paul Kloft, case status and coverage dispute. 0.1 Doug Bragg $280 0.1 $28.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 02 Fred Millard $350 02 $70.00 Review emails from Don Kelley directing payment of Financial Pacific claim. Finalize letter to Don Kelley RE: analysis of policy for Lebanon Seaboard issue. 0.1 Fred Millard $350 0.1 $35.00 03 Michele Barbara $125 03 $37.50 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 28 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 11/17/11 Review/respond to various emails regarding scheduling conference. 02 Doug Bragg $280 02 $56.00 11/17/11 Review and analyze Order from Court granting Motion to Reinstate. Forward same to Don Kelley. Attend meeting with Paul Kloft and Fred Millard analyzing potential expert witnesses, damages, settlement status and case scheduling. 02 Doug Bragg $280 02 $56.00 1.7 Doug Bragg $280 00 $0.00 11/17/11 11/17/11 11/17/11 Email Dan Thenell analyzing depositions and discovery issues. Draft letter to Paul Kloft regarding experts. Email Cindy at the Court regarding status of Reinstatement Order. 02 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 0.1 $56.00 $28.00 $28.00 11/17/11 Prepare for and conduct Client meeting with Paul Kloft and Doug Bragg analyzing potential expert witnesses, damages, settlement status and case scheduling. Telephone call to Cindy at Judge Jones' office to see if Judge will reinstate. Cindy will send email to schedule scheduling conference. 1.7 Fred Millard $350 1.7 $595.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/17/11 Email to Fred Millard and Doug Bragg RE: to see if Judge will reinstate. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/17/11 Prepare letter to Paul Kloft for names and contact information for seed experts. Phone call with Client regarding expert witnesses. Review prior discovery requests to Country Insurance to determine if additional requests are necessary. Review and analyze pleadings filing status. Review/respond to email from Dan Thenell regarding discovery. 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 Email Dan Thenell RE: status of Country's Answer and provide additional copy of First Amended Complaint. Confer with Fred Millard updating him RE: Country's position on Answer, Discovery and Settlement pursuant to phone call with Dan Thenell. Prepare for and conduct phone call with Dan Thenell regarding status of Country's Answer, Discovery and Settlement. Prepare for and conduct telephone call with Don Kelley RE: expert witnesses; procedural issues and payment obligations to Precision creditors and other seed owners. Prepare for and conduct phone call with Paul Kloft regarding witnesses for damage claims. Confer with Doug Bragg analyzing assignment to Paul Kloft regarding witnesses on damages. Confer with Doug Bragg and Fred Millard analyzing the status of the case. Review correspondence from client identifying possible witnesses for damages. Matter conference with Fred Millard and Christopher Fanning analyzing discovery and declaratory judgment issues. Confer with Michele Barbara analyzing prior pleadings and court orders relating to King as an agent for Country Mutual Insurance Company in relation to coverages issue. Review notice of court resetting Scheduling Conference. Confer with Fred Millard analyzing issues for Joint Scheduling Conference. Compose and forward email to Michele Barbara regarding Joint Scheduling Conference. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 1.1 Fred Millard $350 1.1 $385.00 02 Doug Bragg $280 02 $56.00 02 Heidi Gross $50 02 $10.00 03 Christopher Fanning $182 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 Doug Bragg $280 02 $56.00 11/17/11 11/17/11 11/18/11 11/21/11 11/21/11 11/21/11 11/28/11 11/28/11 11/28/11 11/30/11 12/1/11 12/1/11 12/5/11 12/5/11 12/5/11 12/5/11 12/5/11 12/5/11 12/5/11 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 29 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 12/5/11 Review notice from the court regarding Joint Status Conference. 0.1 Doug Bragg $280 0.1 $28.00 12/5/11 Matter conference with Doug Bragg and Christopher Fanning analyzing discovery and Declaratory Judgment issues. Review fax from Paul Kloft and telephone call to him RE: spelling of names, etc.; Research expert names, addresses and telephone numbers, add contact info to Notes & Addresses. Confer with Doug Bragg analyzing prior pleadings and court orders relating to King as an agent for Country Mutual Insurance Company in relation to coverages issue. Telephone calls with Gordon Carey's office, Holly Weeks at Smith Freed and Michelle Rawson with Judge Hernandez' office to schedule Status Conference. Confer with Nick Priest regarding expert testimony as to value of tenant improvements. Review file and discovery to see if any Request for Admissions were served in Ionian matter for Status Conference hearing. Telephone call to Gordon Carey's office RE: my review of file and discovery to see if any Request for Admissions were served in Ionian matter for Status Conference hearing. Telephone call to Holly Weeks at Smith Freed to schedule Status Conference; Email Holly Weeks at Smith Freed with dates/times. 03 Fred Millard $350 03 $105.00 10 Michele Barbara $125 10 $125.00 02 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 0.4 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 Review email from Michele Barbara regarding possible additional experts for this case. Review email from Michele Barbara regarding possible additional experts for this case. Telephone conversations with Dan Thenell, Holly Weeks and Michelle Rawson with Judge Hernandez' office and emails to schedule status conference. Telephone conversation with Paul Kloft RE: possible experts. E-memo to Fred Millard and Doug Bragg to contact Don Kelley for possible additional experts for this case. Review/analyze Answer regarding affirmative defenses. Draft E-memo to Doug Bragg and Fred Millard analyzing affirmative defenses. Review E-memo from Christopher Fanning analyzing Affirmative Defenses. Review Notice of Filing of Amended Answer; Direct Christopher Fanning to review Affirmative Defenses. Review E-memo from Christopher Fanning analyzing Affirmative Defenses. Review email from Don Kelley regarding additional possible experts. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Fred Millard $350 0.1 $35.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All - Duplicative; billed to Millard 0.1 00 $12.50 $0.00 0.6 0.4 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Millard 0.6 00 $109.20 $0.00 02 Doug Bragg $280 All- Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 0.1 Doug Bragg $280 0.1 $28.00 12/12/11 Conference with Fred Millard analyzing issues related to Declaratory Judgment, Status Conference and Country's Answer. 02 Doug Bragg $280 00 $0.00 12/12/11 Conference with Doug Bragg analyzing issues related to declaratory judgment, status conference and Country's Answer. 02 Fred Millard $350 02 $70.00 12/12/11 Prepare Deposition Subpoena and Notice of Taking Deposition of Linda Cord. Email to Holly Weeks at Smith Freed for dates for Linda Cord's deposition. 0.6 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 12/5/11 12/5/11 12/5/11 12/6/11 12/6/11 12/6/11 12/6/11 12/7/11 12/7/11 12/7/11 12/7/11 12/7/11 12/9/11 12/9/11 12/9/11 12/9/11 12/9/11 12/12/11 12/12/11 3:10-cv-01023-HZ ATTACHMENT 1 All- Duplicative; billed to Millard Page 30 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.1 Hrs Deducted by Court and Reason $28.00 0.1 00 $28.00 $0.00 12/13/11 Confer with Michele Barbara regarding deposition scheduling issues. 0.1 Doug Bragg $280 12/13/11 12/13/11 Email Dan Thenell regarding deposition of Linda Cord. Conference with Fred Millard analyzing discovery and preparing for status conference. Review/respond to email from Dan Thenell regarding Notice of Deposition / Subpoena of Deposition of Linda Cord. Review Notice of Case Reassignment. Phone call with Client regarding upcoming Status Conference, Amended Answer from Country and remaining issues in the case. 0.1 05 Doug Bragg Doug Bragg $280 $280 02 Doug Bragg $280 02 $56.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 Review Subpoena and Notice of Deposition of Linda Cord; Execute same. Conference with Doug Bragg regarding discovery and status conference. 02 Doug Bragg $280 02 $56.00 05 Fred Millard $350 05 $175.00 Email to Holly Weeks at Smith Freed to get dates for organizational deposition in addition to Linda Cord's. Amend Notice and Subpoena for Linda Cord's Deposition; Prepare letter to Ms. Cord. Emails from Dan Thenell and Doug Bragg to forward Civil Subpoena and Notice of Taking Deposition for Linda Cord. Review email from Dan Thenell regarding depositions. Email to Dan Thenell to obtain date for organizational deposition. Finish preparation of Subpoena for Linda Cord and arrange for service. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.4 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 05 Doug Bragg Michele Barbara $280 $125 All - Clerical 0.1 00 $28.00 $0.00 Emails to/from Dan Thenell to assist in scheduling organizational deposition. Review flyer regarding Rye Grass Association meeting. Review and analyze Country's Objections to Plaintiffs' Request for Admissions and Request for Production. Receive hand delivered Responses to Requests for Production, Admissions and Interrogatories. Met with Paul Kloft to review documentation on Rye Grass seed. 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Michele Barbara $125 0.1 $12.50 Letter to Paul Kloft enclosing Dan Thenell's letter dated December 16, 2011, together with Defendant's Objections and Responses to Plaintiff's Third Set of Interrogatories and Requests for Production and Second Request for Admissions. Confer with Fred Millard analyzing Country's discovery requests. 02 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 12/19/11 Review and analyze Country's Response to Plaintiff's Request for Production/Admissions and Interrogatories (mailed edition). 0.1 Doug Bragg $280 0.1 $28.00 12/19/11 Confer with Doug Bragg to analyze Country's discovery responses. 02 Fred Millard $350 02 $70.00 12/19/11 Telephone call to Rush Process to confirm personal service of Civil Subpoena to Linda Cord. Confer with Doug Bragg, Fred Millard and Paul Kloft to analyze potential additional responsive discovery documents. Prepare for and attend meeting with Fred Millard and Paul Kloft to analyze issues for Declaratory Judgment on Policy Limits. 02 Michele Barbara $125 00 $0.00 08 Christopher Fanning $182 08 $145.60 20 Doug Bragg $280 00 $0.00 Prepare for and conduct meeting with Doug Bragg and Paul Kloft to analyze issues for Declaratory Judgment on Policy Limits. 20 Fred Millard $350 20 $700.00 12/13/11 12/13/11 12/13/11 12/13/11 12/13/11 12/13/11 12/13/11 12/13/11 12/14/11 12/14/11 12/14/11 12/16/11 12/16/11 12/16/11 12/16/11 12/16/11 12/19/11 12/20/11 12/20/11 12/20/11 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard Page 31 of 161 Date Hrs Req Pltf Lawyer Rate 02 Doug Bragg $280 12/21/11 Confer with Michele Barbara regarding update on Paul Kloft's check research. Review E-memo RE: checks requested from bank. 0.1 Doug Bragg $280 12/21/11 12/21/11 Confer with Michele Barbara regarding deposition schedule. Phone call with Bryana Blessinger regarding deposition of Linda Cord. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 12/21/11 12/21/11 Review E-memo RE: checks requested from bank. Telephone call from Paul Kloft RE: checks requested from bank. 0.1 0.1 Fred Millard Michele Barbara $350 $125 12/21/11 Email to Doug Bragg and Fred Millard RE: checks requested from bank. 0.1 Michele Barbara 12/21/11 Confer with Doug Bragg and Fred Millard RE: telephone call from Paul Kloft RE: checks requested from bank. analyze with Doug Bragg RE: status of case and upcoming events. 0.1 12/21/11 12/21/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/22/11 12/23/11 12/23/11 12/23/11 12/23/11 12/23/11 12/23/11 12/23/11 12/23/11 12/23/11 3:10-cv-01023-HZ Hrs Awarded Amount 02 $56.00 00 $0.00 0.1 0.1 $28.00 $28.00 All - Clerical 0.1 00 $35.00 $0.00 $125 All - Clerical 00 $0.00 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 03 Michele Barbara $125 0.1 Duplicative; billed to Bragg 02 $25.00 Confer with Michele Barbara regarding supplemental disclosures of documents. Prepare for scheduling/status conference. Attend phone conference with court regarding possible consolidation of cases. Review minute order from court RE: consolidation issue. Confer with Fred Millard regarding conference with court on consolidation. Prepare for and attend conference with Court via telephone RE: consolidation of cases. Prepare for and attend conference with Doug Bragg RE: consolidation of cases. Confer with Doug Bragg RE: supplemental disclosure of documents. 02 Doug Bragg $280 02 $56.00 03 05 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 03 00 $84.00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 15 Fred Millard $350 15 $525.00 15 Fred Millard $350 15 $525.00 02 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 Telephone call to Paul Kloft to request another check for $599 dated in November 2009. Telephone call to Paul Kloft to let him know we did not receive his fax with checks; Prepare letter to Paul Kloft enclosing Request for Production again. Confer with Doug Bragg RE: additional documents Paul Kloft brought in. 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 02 $25.00 Prepare documents with bates numbering and prepare Supplemental Response to Request for Production. Review and analyzing Country's discovery documents (2073 pages). Preparing a timeline of events for coverage issues. Confer with Doug Bragg regarding documents relating to coverage amounts. Review email from Bryana Blessinger regarding Deposition of Linda Cord. Confer with Christopher Fanning regarding documents relating to coverage amounts. Confer with Fred Millard regarding meeting with Linda Cord. 03 Michele Barbara $125 02 $25.00 2.6 Christopher Fanning $182 2.6 $473.20 02 Christopher Fanning $182 00 $0.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Review and analyze Country's First Request for Production. Review additional documents produced by client. Direct Michele Barbara to prepare Supplemental Response to First Request for Production. Confer with Doug Bragg regarding meeting with Linda Cord. 0.1 03 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 03 0.1 $28.00 $84.00 $28.00 02 Fred Millard $350 02 $70.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard 0.1 - Clerical All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 32 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason 0.1 Duplicative; billed to Bragg Hrs Awarded Amount 02 $25.00 12/23/11 Confer with Doug Bragg RE: status of case and upcoming events. 03 Michele Barbara $125 12/23/11 Prepare Supplemental Response to First Request for Production of Documents with additional documents Paul Kloft brought in. 03 Michele Barbara $125 03 $37.50 12/27/11 Review and execute Supplemental Response to Request for Production. 02 Doug Bragg $280 02 $56.00 12/27/11 Finalize Supplemental Response to First Request for Production including additional documents Paul Kloft brought to office. 03 Michele Barbara $125 03 $37.50 12/27/11 Review and analyze all binders (10) for any emails, correspondence with Country RE: payments, invoices, Reports of Values. 15 Michele Barbara $125 All - Clerical 00 $0.00 12/27/11 Update bates numbering binder index with additional documents. 0.4 Michele Barbara $125 All - Clerical 00 $0.00 12/27/11 1.4 Michele Barbara $125 All - Vague 00 $0.00 2.7 Christopher Fanning $182 2.7 $491.40 12/28/11 Review and analyze and index Country's discovery documents to assist with coverages analysis. Review, analyze and index discovery documents for coverage analysis and timeline. Draft e-memo to Fred Millard regarding Linda Cord's deposition. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 12/28/11 Draft e-memo to Fred Millard regarding expert witnesses. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 12/28/11 Confer with Michele Barbara regarding review of Precision's documents relating to coverages. Review and analyze documents in preparation for responding to court's request for position on consolidation. Draft response. Draft e-memo to Fred Millard regarding same. Review email from Michele Barbara RE: Schumacher lawsuit. Review correspondence from Client regarding possible lawsuit from Seed of Others. Review E-Memo RE: Linda Cord's deposition. Review E-Memo RE: expert witnesses. Review email from Michele Barbara RE: Schumacher lawsuit. Confer with Doug Bragg RE: Derek Schumacher's claim. Telephone call from Paul Kloft RE: Derek Schumacher lawsuit; Review fax and e-mail to Fred Millard and Doug Bragg RE: Schumacher lawsuit. 02 Doug Bragg $280 02 $56.00 13 Doug Bragg $280 13 $364.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 0.1 0.1 0.1 02 03 Fred Millard Fred Millard Fred Millard Fred Millard Michele Barbara $350 $350 $350 $350 $125 All - Clerical 0.1 0.1 0.1 02 00 $35.00 $35.00 $35.00 $70.00 $0.00 Confer with Fred Millard and e-mail him amount of Derek Schumacher's claim. Confer with Michele Barbara and Doug Bragg regarding document review in preparation for Motion for Summary Judgment. 02 Michele Barbara $125 0.1 Duplicative; 0.1 billed to Millard 00 $0.00 03 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 12/29/11 Confer with Michele Barbara and Christopher Fanning regarding document review in preparation for Motion for Summary Judgment. 03 Doug Bragg $280 03 $84.00 12/29/11 Review/respond to emails from Fred Millard regarding consolidation issues. Confer with Fred Millard regarding deposition of Linda Cord. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Confer with Fred Millard regarding response to Court's Inquiry regarding consolidation. Draft E-Memo RE consolidation; Review/Respond to emails from Doug Bragg regarding consolidation issues. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Fred Millard $350 03 $105.00 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/28/11 12/29/11 12/29/11 12/29/11 12/29/11 3:10-cv-01023-HZ ATTACHMENT 1 Page 33 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 12/29/11 Confer with Doug Bragg analyzing potential deposition of Linda Cord. 02 Fred Millard $350 02 $70.00 12/29/11 Confer with Doug Bragg regarding response to Court's inquiry regarding consolidation. Continue to review, analyze and index Country's documents. Confer with Christopher Fanning and Doug Bragg regarding document review in preparation for Motion for Summary Judgment. 02 Fred Millard $350 02 $70.00 45 03 Michele Barbara Michele Barbara $125 $125 45 00 $562.50 $0.00 12/30/11 Continue reviewing, analyzing and indexing discovery documents from Country; Begin reviewing, analyzing and indexing Jim King's documents. 40 Michele Barbara $125 40 $500.00 1/3/12 Confer with Michele Barbara regarding cancelling Linda Cord's deposition. Draft e-memo to Gordon Carey and Dan Thenell analyzing the court's inquiry on consolidation. Review draft position paper from Gordon Carey on consolidation issue. 0.1 Doug Bragg $280 0.1 $28.00 05 Doug Bragg $280 05 $140.00 0.2 Doug Bragg $280 02 $56.00 Review and sign tender letter for claim to Country relating to Schumacher's lawsuit. Confer with Fred Millard analyzing response to Court's inquiry on consolidation. Confer with Fred Millard analyzing tender of the Schumacher lawsuit. 0.1 Doug Bragg $280 0.1 $28.00 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 05 Fred Millard $350 05 $175.00 1/3/12 Confer with Fred Millard analyzing Motion for Summary Judgment on coverages. Review and analyze discovery from King relating to coverage changes (approximately 1,000 pages). Confer with Michele Barbara regarding cancellation of Linda Cord's deposition. Confer with Doug Bragg regarding response to Court's inquiry on consolidation. Confer with Doug Bragg regarding tender of the Schumacher lawsuit. 02 Fred Millard $350 02 $70.00 1/3/12 Confer with Doug Bragg regarding Motion for Summary Judgment. 0.1 Fred Millard $350 0.1 $35.00 1/3/12 Confer with Doug Bragg to cancel Linda Cord's deposition; E-mail Dan Thenell and Bryanna Blessinger to cancel deposition; Email court reporter also. Prepare tender letter to Dan Thenell with Derek Schumacher pleadings. 03 Michele Barbara $125 0.1 Duplicative; billed to Bragg; 0.2 Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 Continue Review, analyzing and indexing King's discovery documents (1000 pages). Review and analyze discovery, identify and analyze documents that Doug Bragg requested for possible use in Summary Judgment Motion on Coverages. Draft Response to inquiry from Court on consolidation. Review and analyze Draft Response from Gordon Carey and Dan Thenell's email regarding consolidation issue; Email Gordon and Dan thoughts on Draft Response on consolidation issue. 22 Michele Barbara $125 22 $275.00 10 Christopher Fanning $182 10 $182.00 0.7 03 Doug Bragg Doug Bragg $280 $280 0.7 03 $196.00 $84.00 Telephone call with Paul Kloft Review status of discovery requests, review correspondence from Kelley and attached January 5, 2012 correspondence to Paul Connolly. File Response Brief to Judge Hernandez' Request for Consolidation. 1.1 Fred Millard $350 1.1 $385.00 0.2 Michele Barbara $125 00 $0.00 12/29/11 12/29/11 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/3/12 1/4/12 1/4/12 1/4/12 1/4/12 1/4/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Bragg All - Clerical Page 34 of 161 Date Hrs Req Pltf Lawyer Rate 43 Michele Barbara $125 1/4/12 Continue Review, analyzing and indexing King's documents (1,000 pages). File Response Brief to Judge Hernandez' Request for Consolidation. 02 Michele Barbara $125 1/4/12 Continue analyzing and indexing King's documents (1,000 pages). 3.4 Michele Barbara 1/5/12 Confer with Michele Barbara analyzing status of discovery analysis and index project. Confer with Fred Millard analyzing Ionian's Position on Court's inquiry. 0.1 1/4/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/5/12 1/6/12 1/6/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/9/12 1/10/12 1/10/12 3:10-cv-01023-HZ Hrs Awarded Amount 43 $537.50 00 $0.00 $125 3.4 $425.00 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Confer with Fred Millard analyzing draft position paper in response to Court's inquiry. Revise draft position paper on consolidation issue. Direct Michele Barbara to file same. Phone call with Fred Millard and Paul Kloft regarding position paper on consolidation and Summary Judgment issues. Confer with Doug Bragg analyzing Ionian's Position on Court's inquiry. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 03 $84.00 05 Doug Bragg $280 00 $0.00 0.1 Fred Millard $350 0.1 $35.00 Confer with Doug Bragg analyzing and developing draft position paper in response to Court's inquiry. Phone call with Doug Bragg and Paul Kloft analyzing position paper and summary judgment issues. Confer with Doug Bragg regarding status of Motion for Summary Judgment. Confer with Doug Bragg regarding status of discovery analysis and index project. File consolidation issue document. Review, analyze and index Jim King documents (1,000 pages). Continue Review, analyzing, and indexing King's documents (1,000 pages). Review, analyze and Index Jim King's discovery documents (1,000 pages). Develop a timeline for 2009 based on the King and Country documents (1,000 pages). Confer with Doug Bragg analyzing documents to be used for Summary Judgment. Confer with Fred Millard regarding status of Motion for SJ. Review emails between Thenell and Court analyzing response to Court's inquiry on consolidation issues. Confer with Christopher Fanning analyzing timeline of events relating to coverages. Review and analyze discovery and indexes to identify additional documents relating to coverage issues. Phone call with Don Kelley regarding update on Reiling Farms and lawsuit case status. Confer with Christopher Fanning analyzing documents to be used for Summary Judgment. Draft email communication to Thenell requesting partial payment on claim. Finish Review, analyzing and indexing King's bates numbered documents (1,000 pages). Continue to develop a timeline of events RE: coverages. Review transcripts of James King depositions for Summary Judgment on coverage issues. 02 Fred Millard $350 02 $70.00 05 Fred Millard $350 05 $175.00 02 Fred Millard $350 02 $70.00 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 0.1 03 25 Michele Barbara Christopher Fanning Michele Barbara $125 $182 $125 All - Clerical 00 03 25 $0.00 $54.60 $312.50 3.6 Christopher Fanning $182 All - Duplicative; billed to Barbara 00 $0.00 23 Christopher Fanning $182 23 $418.60 02 Christopher Fanning $182 00 $0.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Fred Millard $350 03 $105.00 20 Michele Barbara $125 20 $250.00 33 1.6 Christopher Fanning Christopher Fanning $182 $182 33 1.6 $600.60 $291.20 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All -Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Bragg; Page 35 of 161 Date Hrs Awarded Amount $280 0.1 $28.00 Doug Bragg $280 02 $56.00 19 Christopher Fanning $182 19 $345.80 0.6 09 Christopher Fanning Christopher Fanning $182 $182 0.6 09 $109.20 $163.80 02 Doug Bragg $280 02 $56.00 39 Christopher Fanning $182 39 $709.80 0.7 0.6 Christopher Fanning Christopher Fanning $182 $182 0.7 0.6 $127.40 $109.20 Confer with Doug Bragg analyzing statement of facts for Motion for Summary Judgment. Confer with Christopher Fanning analyzing statement of facts for Motion for Summary Judgment. Draft Declaration for Paul Kloft in Support of Motion for Summary Judgment on coverages. Phone call with Paul Kloft regarding denial of Schumacher tender, Summary Judgment on coverages and issue with consolidation. 02 Christopher Fanning $182 00 $0.00 02 Doug Bragg $280 02 $56.00 02 Christopher Fanning $182 02 $36.40 02 Doug Bragg $280 02 $56.00 1/20/12 1/20/12 Draft Motion for Summary Judgment on coverages. Draft Declaration for Motion for Summary Judgment on coverages. 13 09 Christopher Fanning Christopher Fanning $182 $182 13 09 $236.60 $163.80 1/20/12 Participate in phone call with Fred Millard and Dan Thenell regarding possible narrowing of issues. Phone call with Don Kelley regarding Schumacher lawsuit. Conference with Fred Millard analyzing Summary Judgment issues and damages dispute. Conference with Doug Bragg analyzing Summary Judgment issues and damages dispute. Attend phone call with Doug Bragg and Dan Thenell regarding possible narrowing of issues. Draft Motion for Summary Judgment RE: coverages issues. Phone call with Bryana Blessinger regarding upcoming interview with Linda Cord. Research the discoverability of the items that an expert uses to form her opinion. Draft Motion for Summary Judgment RE: coverages issues. Draft Motion for Summary Judgment RE: coverages issues. Draft Declarations in Support of Motion for Summary Judgment. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 05 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 02 00 $56.00 $0.00 05 Fred Millard $350 05 $175.00 0.1 Fred Millard $350 0.1 $35.00 48 0.1 Christopher Fanning Doug Bragg $182 $280 48 0.1 $873.60 $28.00 15 Christopher Fanning $182 15 $273.00 08 4.7 25 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 08 4.7 25 $145.60 $855.40 $455.00 Draft Declarations for Paul Kloft and Doug Bragg in Support of Summary Judgment Motion. Analyze and organize documents that support Motion for Summary Judgment. Draft Motion for Summary Judgment. Phone call with Don Kelley regarding document production from Schumacher. Prepare for meeting with Linda Cord regarding events of August, 2009 at King's Office. 1.4 Christopher Fanning $182 1.4 $254.80 09 Christopher Fanning $182 09 $163.80 33 02 Christopher Fanning Doug Bragg $182 $280 33 02 $600.60 $56.00 02 Doug Bragg $280 02 $56.00 1/11/12 1/12/12 1/13/12 1/13/12 1/13/12 1/13/12 1/16/12 1/16/12 1/16/12 1/16/12 1/16/12 1/19/12 1/19/12 1/20/12 1/20/12 1/20/12 1/20/12 1/23/12 1/23/12 1/24/12 1/25/12 1/26/12 1/26/12 1/27/12 1/27/12 1/27/12 1/27/12 1/27/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Phone call to Don Bevins regarding tender of the Schumacher lawsuit. Left voicemail. Phone call to Don Bevins regarding tender of the Schumacher Complaint. Review discovery documents from Country and Jim King (about 2,000 pages). Draft discovery requests. Draft fact section for Motion for Summary Judgment based upon the timeline. Phone call with Paul Kloft regarding Country's recent filing regarding Court's concern of conflicting rulings. Draft portions of the Motion for Summary Judgment on coverages issues. Draft declarations to support Motion for Summary Judgment. Draft declaration for Paul in support of Motion for Summary Judgment. 0.1 Doug Bragg 02 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg Page 36 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 08 Doug Bragg 0.6 1/30/12 1/30/12 Review draft Motion for Summary Judgment; confer with Christopher Fanning regarding revisions to same. Fill-in "Seed of Others" values in Paul Kloft's declaration to Motion for Summary Judgment. Finalize Motion for Summary Judgment. Meeting with Paul Kloft and Doug Bragg to discuss changes. $280 08 $224.00 Michele Barbara $125 0.6 $75.00 02 20 Christopher Fanning Christopher Fanning $182 $182 02 00 $36.40 $0.00 1/30/12 1/30/12 1/30/12 Draft Declarations to Support Motion for Summary Judgment. Review Request for Production from Schumacher. Meeting with client regarding declaration for Summary Judgment. 28 02 22 Christopher Fanning Doug Bragg Doug Bragg $182 $280 $280 28 02 22 $509.60 $56.00 $616.00 1/30/12 Calculate excel spreadsheets prepared by Precision Seed to confirm amounts for Paul Kloft's Declaration for Motion for Summary Judgment. 08 Michele Barbara $125 08 $100.00 1/30/12 1/31/12 1/31/12 Prepare exhibits for Motion for Summary Judgment. Draft Motion for Summary Judgment. Met with Paul Kloft and Doug to analyze things that needed to be added to Summary Judgment Motion. Meet with Client, Fred Millard, Michele Barbara, and Christopher Fanning analyzing declaration for Paul Kloft, revisions to declaration, and Motion for Summary Judgment. Prepare for and conduct conference with Paul Kloft reviewing and analyzing discovery and damages. Telephone call to Holly Weeks at Smith Freed to confirm meeting for Friday with Dan Thenell. Dan is keeping this case after he leaves Smith Freed. Compare and analyze additional documents with documents produced to verify whether or not we have produced them prior to today. 0.4 40 22 Michele Barbara Christopher Fanning Christopher Fanning $125 $182 $182 2.0 Duplicative; billed to Millard 0.4 40 02 $50.00 $728.00 $36.40 20 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 2.6 Fred Millard $350 2.6 $910.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 10 Michele Barbara $125 All - Clerical 00 $0.00 Meet with Paul Kloft to go over supplemental documents for discovery/Motion for Summary Judgment. Prepare exhibits for Summary Judgment. Draft letter to Dan Thenell on behalf of Doug Bragg RE: discovery issues. 0.4 Michele Barbara $125 0.4 $50.00 08 13 Michele Barbara Christopher Fanning $125 $182 08 13 $100.00 $236.60 Finalize Motion for Summary Judgment. Draft Declaration for Douglas Bragg in Support of Motion for Summary Judgment. Confer with Doug Bragg regarding letter to Dan Thenell regarding discovery issues. Confer with Doug Bragg analyzing Memo in Support of Motion for Summary Judgment. Confer with Christopher Fanning analyzing letter to Dan Thenell regarding discovery issues. Review and analyze draft Memorandum in Support of Motion for Summary Judgment. Draft email to Dan Thenell regarding conferral on Motion for Summary Judgment. Confer with Christopher Fanning analyzing draft Memo in Support of Motion for Summary Judgment. Finalize Motion for Summary Judgment. Draft letter to Dan Thenell for Doug Bragg RE: discovery issues. Confer with Doug Bragg analyzing exhibits for Summary Judgment Motion. Confer with Fred Millard analyzing draft Motion for Summary Judgment. 2.6 0.4 Christopher Fanning Christopher Fanning $182 $182 2.6 0.4 $473.20 $72.80 02 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 03 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 0.7 $196.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 4.1 13 02 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 All - Duplicative; billed to Bragg 4.1 13 00 $746.20 $236.60 $0.00 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1/27/12 1/27/12 1/31/12 1/31/12 1/31/12 1/31/12 1/31/12 1/31/12 2/1/12 2/1/12 2/1/12 2/1/12 2/1/12 2/1/12 2/1/12 2/1/12 2/1/12 2/2/12 2/2/12 2/2/12 2/2/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg Page 37 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Phone call with Fred Millard and Dan Thenell conferring on Summary Judgment on coverage issues. Revise Draft Memorandum in Support of Motion for Summary Judgment. Email Dan Thenell draft Memorandum in Support of Motion for Partial Summary Judgment. Confer with Christopher Fanning analyzing exhibits for Summary Judgment Motion. Confer with Doug Bragg analyzing draft Motion for Summary Judgment. 02 Doug Bragg $280 All - Duplicative; billed to Millard 10 Doug Bragg 0.1 Explanation Hrs Awarded Amount 00 $0.00 $280 10 $280.00 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 05 Fred Millard $350 05 $175.00 02 Fred Millard $350 02 $70.00 2/2/12 Phone call with Doug Bragg and Dan Thenell conferring on Summary Judgment on coverage issues. Review and analyze policy for July 24, 2009 to verify reinstatement date. 03 Michele Barbara $125 03 $37.50 2/3/12 2/3/12 Revise letter to Dan Thenell RE: incomplete discovery. Review Motion for Summary Judgment and supporting documents. 10 08 Christopher Fanning Christopher Fanning $182 $182 10 08 $182.00 $145.60 2/3/12 Review and analyze draft letter to Dan Thenell regarding incomplete discovery; Direct Christopher Fanning to revise same. 02 Doug Bragg $280 02 $56.00 2/3/12 Review/respond to email from Kris at Don Kelley's office regarding document production for Schumacher. Phone call with Don Kelley regarding status update on case. Matter conference with Dan Thenell re: possible settlement. Draft Fourth Requests for Production. Telephone call to Paul Kloft for review of Jim King's transcript. Review draft letter to Dan Thenell regarding discovery issues. Direct Michele Barbara to revise same. Meeting with Fred Millard and Paul Kloft analyzing James King's deposition. Review draft Fourth Request for Production. Meeting with Doug Bragg and Paul Kloft analyzing James King's deposition. Finalize Motion for Summary Judgment. Prepare for meeting with Dan Thenell regarding coverage issues. 02 Doug Bragg $280 02 $56.00 02 20 12 0.1 0.1 Doug Bragg Fred Millard Christopher Fanning Michele Barbara Doug Bragg $280 $350 $182 $125 $280 02 20 12 0.1 0.1 $56.00 $700.00 $218.40 $12.50 $28.00 09 Doug Bragg $280 00 $0.00 0.1 09 Doug Bragg Fred Millard $280 $350 0.1 09 $28.00 $315.00 1.4 02 Christopher Fanning Doug Bragg $182 $280 All - Excessive 00 02 $0.00 $56.00 2/9/12 Attend lunch meeting with Fred Millard and Dan Thenell to discuss coverage issues on Summary Judgment and settlement. 15 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 2/9/12 Attend lunch meeting with Doug Bragg and Dan Thenell to discuss coverage issues on Summary Judgment and settlement. 15 Fred Millard $350 15 $525.00 2/10/12 2/10/12 Finalize Motion for Summary Judgment. Confer with Doug Bragg analyzing submission of Aug. 4, 2009 change to Country by James King; Review King's documents relating to same. 23 05 Christopher Fanning Christopher Fanning $182 $182 00 00 $0.00 $0.00 2/10/12 Confer with Christopher Fanning analyzing submission of Aug. 4, 2009 change to Country by James King; Review King's documents relating to same; Direct Christopher Fanning to highlight that timing in the Statement of Facts. Review/respond to email from Dan Thenell regarding mediation. 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 Conference with Fred Millard analyzing Summary Judgment and review of change endorsement timeline. Review draft Motion. 02 Doug Bragg $280 00 $0.00 Doug Bragg $280 2/2/12 2/2/12 2/2/12 2/2/12 2/2/12 2/2/12 2/3/12 2/3/12 2/6/12 2/6/12 2/7/12 2/7/12 2/7/12 2/7/12 2/9/12 2/9/12 2/10/12 2/10/12 2/10/12 3:10-cv-01023-HZ 02 ATTACHMENT 1 All - Duplicative; billed to Millard All - Excessive All - Duplicative; billed to Bragg All - Duplicative; billed to Millard 02 $56.00 Page 38 of 161 Date Hrs Req Pltf Lawyer Rate Conference with Doug Bragg analyzing Summary Judgment and review of change endorsement timeline. Make final revisions to Motion for Summary Judgment and file with Court. Phone call with Paul Kloft regarding Motion for Summary Judgment. 02 Fred Millard $350 1.6 Michele Barbara $125 02 Doug Bragg 02 2/24/12 Review/respond to email from Dan Thenell regarding Summary Judgment. Direct Michele Barbara to e-mail Dan Thenell Summary Judgment documents. Phone call to Dan Thenell regarding Motion to Compel. Email Dan Thenell regarding same. Confer with Fred Millard analyzing Motion to Compel. 2/24/12 2/27/12 2/29/12 3/2/12 2/10/12 2/14/12 2/16/12 2/20/12 2/20/12 2/24/12 3/5/12 3/5/12 3/6/12 3/6/12 3/6/12 3/6/12 3/7/12 3/7/12 3/8/12 3/14/12 3/14/12 3/23/12 3/23/12 3/23/12 3/23/12 3/27/12 3/27/12 3/27/12 3:10-cv-01023-HZ Hrs Awarded Amount 02 $70.00 00 $0.00 $280 02 $56.00 Doug Bragg $280 02 $56.00 02 Fred Millard $350 02 $70.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Confer with Doug Bragg analyzing Motion to Compel. Phone call to Dan Thenell regarding discovery issues. Phone call to Dan Thenell regarding discovery issues. Left voicemail. 02 0.1 0.1 Fred Millard Doug Bragg Doug Bragg $350 $280 $280 02 0.1 0.1 $70.00 $28.00 $28.00 Telephone calls and e-mails to Sarah with Dan Thenell's office to get Motion for Summary Judgment documents. Review / respond to email from Dan Thenell regarding extension on Response to Motion for Summary Judgment. Email Dan Thenell regarding discovery issues and Motion to Compel. 0.4 Michele Barbara $125 00 $0.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Left voicemail for Dan Thenell regarding discovery issues; Email Dan Thenell regarding same. Phone call to Dan Thenell regarding discovery issues. Email Dan Thenell regarding same. Prepare for and conduct meeting with Paul Kloft, Craig Collins and Fred Millard regarding trial prep and Summary Judgment. Prepare for and conduct meeting with Paul Kloft, Craig Collins and Doug Bragg regarding trial prep and Summary Judgment. Phone call with Dan Thenell regarding discovery issues; email Dan Thenell confirming the phone call and requesting that Country supplement its response. Review and annotate Jim King's Deposition Transcript in Support of Summary Judgment Motion on Coverage Limits. Review email from Court regarding oral argument on Summary Judgment motion. Telephone call with Client RE: case status. Telephone call with Don Kelley RE: case status. Phone call with Dan Thenell regarding Country's concession on coverage issue. Email Don Kelley regarding Country's concession on policy limits. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 05 Doug Bragg $280 00 $0.00 05 Fred Millard $350 05 $175.00 03 Doug Bragg $280 03 $84.00 5.7 Fred Millard $350 5.7 $1,995.00 0.1 Doug Bragg $280 0.1 $28.00 10 10 02 Fred Millard Fred Millard Doug Bragg $350 $350 $280 10 10 02 $350.00 $350.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Phone call with Paul Kloft regarding Country's concession on policy limits. Review email from Dan Thenell to Court regarding concession on Summary Judgment issues. Confer with Fred Millard analyzing damages case and Motion for Summary Judgment to draw out factual issues. Telephone call with Client RE: concession by Country and next phase of litigation. Confer with Doug Bragg analyzing damages case and Motion for Summary Judgment to draw out factual issues. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 00 $0.00 08 Fred Millard $350 08 $280.00 0.4 Fred Millard $350 0.4 $140.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical/Vague All - Duplicative; billed to Bragg All - Clerical All- Duplicative; billed to Millard All - Duplicative; billed to Millard Page 39 of 161 Date 3/28/12 3/28/12 3/29/12 3/29/12 3/30/12 3/30/12 4/2/12 4/2/12 4/2/12 4/2/12 Explanation Email Nick Priest regarding possible expert testimony on actual cash value of tenant improvements. Met with Paul Kloft to discuss coverage issues and next phase of litigation. Direct Michele Barbara to update various file information. Research Bratney Company to locate Robert Halsey's e-mail; E-mail Mr. Halsey to let him know we represent Paul Kloft and to schedule meeting with him, Paul Kloft and attorneys. Email Dan Thenell regarding status of Amended Answer to Request for Admissions. Emails with Robert Halsey to set up meeting with Paul Kloft and attorneys. Confer with Fred Millard regarding expert witnesses and case status. Confer with Fred Millard regarding Nick Priest's availability as an expert witness. Telephone call with Greg Mettler RE: Expert testimony on Business Interruption and audit of seed records. Confer with Doug Bragg regarding expert witnesses and case status. Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.2 Doug Bragg $280 02 $56.00 05 Fred Millard $350 05 $175.00 02 0.2 Fred Millard Michele Barbara $350 $125 02 0.1 $70.00 $12.50 0.1 Doug Bragg $280 0.1 $28.00 02 Michele Barbara $125 All -Clerical 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.2 Doug Bragg $280 02 $56.00 08 Fred Millard $350 08 $280.00 02 Fred Millard $350 02 $70.00 Hrs Deducted by Court and Reason 0.1 Clerical 4/2/12 E-mail to Robert Halsey confirming if we are still on for a meeting with Paul Kloft and the attorneys for Thursday at noon. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 4/2/12 E-mail from Doug Bragg to forward to Dan Thenell a copy of our First Request for Admissions and Country's response thereto; E-mail to Dan Thenell RE: same. Confer with Doug Bragg to forward invoices for hardware and improvements to Nick Priest; Compile and organize documents for Nick Priest, and draft letter to Nick Priest RE: same; E-mail to Nick Priest advising him that we are sending him a DVD of the documents. 03 Michele Barbara $125 All - Clerical 00 $0.00 0.5 Michele Barbara $125 0.2 - Clerical 03 $37.50 03 Michele Barbara $125 All - Clerical 00 $0.00 03 Doug Bragg $280 03 $84.00 20 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 20 Fred Millard $350 20 $700.00 2.1 0.1 Fred Millard Doug Bragg $350 $280 2.1 0.1 $735.00 $28.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 4/6/12 E-mail from Dan Thenell to send Second Request for Admission, together with Country's response thereto. Review/respond to email from Michelle Rawson at the USDC for Oregon regarding status of Motion for Summary Judgment. Phone call to Michelle Rawson regarding same, left voicemail. Prepare for and conduct meeting with Paul Kloft, Robert Halsey and Fred Millard RE: equipment valuation. Review email from Dan Thenell revising Response to Second Request for Admissions. Prepare for and conduct conference with Robert Halsey, expert on Machinery lost in fire. Matter conference with Paul Kloft RE: issues for litigation. Email John Poe regarding possible expert testimony on value of business interruption claim. Respond to email from John Poe regarding expert testimony. Phone call with John Poe regarding Business Interruption coverage. Draft e-memo to Fred Millard regarding same. Phone call with Paul Kloft regarding Business Interruption coverage. 02 Doug Bragg $280 02 $56.00 4/6/12 File Notice of Withdrawal of Partial Motion for Summary Judgment. 02 Doug Bragg $280 00 $0.00 4/6/12 Review email from Court regarding Notice of Withdrawal of Motion. 0.1 Doug Bragg $280 0.1 $28.00 4/3/12 4/3/12 4/5/12 4/5/12 4/5/12 4/5/12 4/5/12 4/6/12 4/6/12 4/6/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard 0.1 Duplicative; billed to Millard All - Clerical Page 40 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 4/6/12 Draft Notice of Withdrawal of Partial Motion for Summary Judgment. 02 Doug Bragg $280 02 $56.00 4/9/12 Review E-memo from Doug Bragg RE: Business Interruption Coverage. 0.1 Fred Millard $350 0.1 $35.00 4/10/12 Review/respond to email from John Poe regarding Business Interruption coverage. Phone call to Client regarding retaining John Poe; Left voicemail. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Discussing with staff RE: assignments for trial prep. Review expert witness agreement from John Poe; forward same to Paul Kloft for signature. Phone call with Paul Kloft regarding status of damages review and John Poe's contract. Discussing with staff RE: assignments for trial prep. Review documents in preparation for calculating provable damages. 25 02 Christopher Fanning Doug Bragg $182 $280 25 02 $455.00 $56.00 02 Doug Bragg $280 02 $56.00 25 08 Doug Bragg Fred Millard $280 $350 25 08 $700.00 $280.00 25 Fred Millard $350 25 $875.00 25 02 Michele Barbara Doug Bragg $125 $280 25 02 $312.50 $56.00 4/13/12 4/16/12 Discussing with staff RE: assignments for trial preparation, additional trial preparation tasks. Discussing with staff RE: assignments for trial prep. Phone call with Paul Kloft regarding Business Interruption Coverage Questionnaire. Commence research on trial experts for damages. Phone call with Elson Strubel regarding electrical improvements. 18 0.1 Fred Millard Doug Bragg $350 $280 18 0.1 $630.00 $28.00 4/17/12 4/19/12 Researching bailment. Phone call with Paul Kloft regarding preparation of damages case. 1.4 02 Christopher Fanning Doug Bragg $182 $280 1.4 02 $254.80 $56.00 4/19/12 Conference with Fred Millard regarding status of damages case and possible consequential damages claim for attorney's fees incurred in Ionian litigation. Conference with Doug Bragg regarding status of damages case and possible consequential damages claim for attorney's fees incurred in Ionian litigation. Matter conference with Fred Millard analyzing trial Issues. 15 Doug Bragg $280 00 $0.00 15 Fred Millard $350 15 $525.00 1.1 Doug Bragg $280 00 $0.00 4/20/12 4/24/12 4/24/12 Matter conference with Doug Bragg analyzing trial Issues. Meet with Greg Mettler regarding BI analysis. Review/respond to email from John Poe regarding Business Interruption analysis; Review Business Interruption provision of the insurance policy. 1.1 10 03 Fred Millard Doug Bragg Doug Bragg $350 $280 $280 1.1 10 03 $385.00 $280.00 $84.00 4/24/12 Based upon information from John Poe and review of insurance policy, calculate rough Business Interruption coverage loss. 15 Doug Bragg $280 15 $420.00 4/24/12 Confer with Fred Millard regarding Business Interruption coverage loss. 05 Doug Bragg $280 00 $0.00 4/24/12 0.1 Doug Bragg $280 0.1 $28.00 4/24/12 Confer with Michele Barbara about Summary Judgment and preparing Declarations for seed owners. Confer with Michele Barbara analyzing Declarations for seed owners. 02 Doug Bragg $280 02 $56.00 4/24/12 Confer with Doug Bragg analyzing Business Interruption coverage loss. 05 Fred Millard $350 05 $175.00 4/24/12 Confer with Doug Bragg about Summary Judgment on Damages and preparing declarations for seed owners. Review signed seed values from seed owners. 0.1 Michele Barbara $125 00 $0.00 02 Michele Barbara $125 02 $25.00 4/10/12 4/11/12 4/11/12 4/11/12 4/11/12 4/11/12 4/11/12 4/11/12 4/13/12 4/19/12 4/20/12 4/24/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 41 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg 4/24/12 Confer with Doug Bragg analyzing seed values from seed owners. 02 Michele Barbara $125 4/25/12 Phone call with Paul Kloft regarding status of preparation of damages claim. Review and analyze email from court regarding status conference; email Dan Thenell regarding same. Email Dan Thenell analyzing outstanding discovery and additional depositions. Prepare for and conduct meeting with Paul Kloft regarding damages and expert disclosures. Prepare for and conduct conference with Paul Kloft and Doug Bragg analyzing damages and experts for seed. Email Dan Thenell regarding conference call with Jim King. Review email from John Poe regarding Business Interruption coverage. 03 Doug Bragg 02 Hrs Awarded Amount 00 $0.00 $280 03 $84.00 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 2.1 Doug Bragg $280 00 $0.00 2.1 Fred Millard $350 2.1 $735.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 Email Greg Mettler regarding Business Interruption coverage issues and initial estimate of value of claim. Confer with Fred Millard analyzing issues for Organizational Deposition. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 4/26/12 Email Dan Thenell and Bryana Blessinger regarding Organizational Deposition of Country Mutual Insurance. Confer with Doug Bragg analyzing issues for organizational deposition. 03 Fred Millard $350 03 $105.00 4/27/12 Confer with Michele Barbara RE: seed quantity and value proof. 03 Doug Bragg $280 03 $84.00 4/27/12 Confer with Doug Bragg and review e-mails from Sarah at Dan Thenell's office and Doug Bragg; Prepare Second Amended Notice of Organizational Deposition. E-mails with court reporter and Dan Thenell's office for scheduling deposition, location and time. Gather together all contracts and verify amounts for seed. Confer with Doug Bragg analyzing seed quantity and value proof. 03 Michele Barbara $125 0.2 - Clerical 0.1 $12.50 03 Michele Barbara $125 All - Clerical 00 $0.00 2.1 03 Michele Barbara Michele Barbara $125 $125 All - Duplicative; billed to Bragg 2.1 00 $262.50 $0.00 Email seed values to Craig Edminster. Review and analyze emails from Dan Thenell and Michelle Rawson regarding scheduling conference; Review Order from Court setting same. Prepare for and attend scheduling conference. Confer with Michele Barbara RE: scheduling conference. Confer with Doug Bragg RE: scheduling conference; Prepare letter to client giving him trial dates and other dates related to case that Judge Hernandez scheduled; Calendared dates accordingly. 0.1 02 Michele Barbara Doug Bragg $125 $280 00 02 $0.00 $56.00 05 0.1 0.4 Doug Bragg Doug Bragg Michele Barbara $280 $280 $125 05 0.1 00 $140.00 $28.00 $0.00 Prepare for and conduct meeting with Paul Kloft and Fred Millard analyzing seed damages portion of claim. Review Minute Order regarding scheduling conference; forward same to Don Kelley. Prepare for and conduct meeting with Paul Kloft and Doug Bragg analyzing seed damages portion of claim. Confer with Michele Barbara to forward Seed Valuations to Rod at ProSeed. Confer with Fred Millard to forward Seed Valuations to Rod at ProSeed; E-mail values to Rod at ProSeed. Review email from Dan Thenell regarding choice of mediation judge. 03 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Fred Millard $350 03 $105.00 03 Fred Millard $350 03 $105.00 03 Michele Barbara $125 00 $0.00 02 Doug Bragg $280 02 $56.00 4/25/12 4/25/12 4/25/12 4/25/12 4/26/12 4/26/12 4/26/12 4/26/12 4/26/12 4/27/12 4/27/12 4/27/12 4/27/12 4/30/12 5/1/12 5/1/12 5/1/12 5/2/12 5/2/12 5/2/12 5/2/12 5/2/12 5/3/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Clerical 0.1 Duplicative; billed to Bragg; 0.3 Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 42 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 02 $56.00 00 $0.00 02 $56.00 00 $0.00 0.1 $35.00 02 $25.00 03 Hrs Deducted by Court and Reason $37.50 5/7/12 Review/respond to email from Dan Thenell regarding scheduling of organizational deposition and outstanding discovery requests. 02 Doug Bragg $280 5/7/12 Email from Dan Thenell to reschedule organizational deposition; Email to court reporter RE: same. Review/respond to email from Greg Mettler regarding analysis of business interruption coverage. Review email from Michele Barbara RE: expungement of Paul Kloft's criminal record. Review email from Michele Barbara RE: expungement of Paul Kloft's criminal record. Telephone call to Dan Martin at Al Karpinski's office to confirm facts of expungement; E-mail to Fred Millard and Doug Bragg RE: same. 03 Michele Barbara $125 02 Doug Bragg $280 0.1 Doug Bragg $280 0.1 Fred Millard $350 03 Michele Barbara $125 03 Michele Barbara $125 03 Michele Barbara $125 All - Clerical 00 $0.00 5/9/12 5/10/12 Receive and review Jury Trial Management Order; Prepare letter to client regarding same. Prepare letter to Paul Kloft enclosing Responses to Second Request for Production and Second Request for Admissions. Email Dan Thenell regarding discovery issues. Email to Michelle Rawson to assist in scheduling Settlement Conference. 02 0.1 Doug Bragg Michele Barbara $280 $125 All - Clerical 02 00 $56.00 $0.00 5/14/12 Review email from Court assigning Judge Acosta as mediation judge 0.1 Doug Bragg $280 0.1 $28.00 5/14/12 5/14/12 Review Judge Acosta's resume and mediation instructions. Email from Michelle Rawson advising us that Judge Acosta is willing to conduct settlement conference; Telephone calls to Julie at Dan Thenell's office to schedule and Paul with Judge Acosta's office RE: same; Email to Judge Acosta's deputy clerk to advise them of settlement conference date and check with his schedule RE: same; Telephone call to Paul Kloft RE: same. Traveling to Salem to request Paul Kloft's records. Draft Agreed Upon Chart of Objections to Witness, Joint Submission of Motions in Limine and Plaintiff's Objections to Defendant's Exhibits. 02 03 Doug Bragg Michele Barbara $280 $125 02 00 $56.00 $0.00 1.7 18 Christopher Fanning Michele Barbara $182 $125 1.7 18 $309.40 $225.00 Confer with Michele Barbara RE: invoice from Paul Kloft replacing screens. Receive and review invoice from Paul Kloft replacing screens. Confer with Doug Bragg analyzing invoice from Paul Kloft replacing screens. Telephone conversation with Paul Kloft for any remaining invoices to replace inventory. Paul said he would forward an invoice to replace out house. Review and execute Supplemental Response to Request for Production with replacement cost for certain items. Receive and analyze replacement invoices for items lost in the fire; Bates number new invoices; Prepare letter to Dan Thenell enclosing same. Prepare Supplemental Response to Defendant's First Interrogatories and Requests for Production. Draft e-memo to Fred Millard analyzing changes between certified policies. Review and analyze new certified policy from Country Mutual Insurance. 0.1 Doug Bragg $280 0.1 $28.00 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All - Duplicative; billed to Bragg 0.1 00 $12.50 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Michele Barbara $125 02 $25.00 0.4 Michele Barbara $125 0.4 $50.00 0.1 Doug Bragg $280 00 $0.00 05 Doug Bragg $280 05 $140.00 Review e-memo from Doug Bragg analyzing changes between certified policies. 0.1 Fred Millard $350 0.1 $35.00 5/8/12 5/8/12 5/8/12 5/8/12 5/8/12 5/8/12 5/15/12 5/18/12 5/21/12 5/21/12 5/21/12 5/21/12 5/22/12 5/22/12 5/22/12 5/25/12 5/25/12 5/25/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Duplicative; billed to Millard 0.1 - Clerical All - Clerical 0.1 - Clerical All - Duplicative; billed to Millard Page 43 of 161 Date 5/28/12 5/28/12 5/28/12 5/29/12 5/31/12 5/31/12 6/11/12 6/11/12 6/11/12 6/11/12 6/11/12 6/11/12 6/11/12 6/12/12 6/12/12 6/12/12 6/12/12 6/13/12 6/15/12 6/15/12 6/18/12 6/18/12 6/18/12 6/18/12 6/19/12 6/19/12 6/19/12 6/19/12 6/20/12 6/21/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review and analyze letter from Greg Mettler regarding Business Interruption coverage. Email Dan Thenell regarding Motion to Compel and Motion to Amend Complaint. Email Greg Mettler regarding Business Interruption coverage investigation. Review and analyze Greg Mettler's May 28, 2012 Report on Business Interruption claim. Review and analyze Certified Policy dated March 26, 2012. Draft email to Thenell requesting clarification of changes. Confer with Doug Bragg and Fred Millard to analyze Motion to Compel. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.4 Fred Millard $350 0.4 $140.00 05 0.1 02 Fred Millard Fred Millard Christopher Fanning $350 $350 $182 All - Duplicative; billed to Millard 05 0.1 00 $175.00 $35.00 $0.00 Confer with Doug Bragg and Fred Millard to analyze Motion for Summary Judgment on Damages. Confer with Christopher Fanning and Fred Millard to analyze Motion to Compel. Confer with Christopher Fanning and Fred Millard to analyze Motion for Summary Judgment on Damages. Confer with Christopher Fanning to analyze Motion to Compel and Motion to Amend. Confer with Christopher Fanning and Doug Bragg to analyze Motion to Compel. Confer with Christopher Fanning and Doug Bragg to analyze Motion for Summary Judgment on Damages. Draft Motion for Summary Judgment on damages and analyze damages calculations. Email Greg Mettler regarding status of business interruption loss analysis. Confer with Fred Millard and Paul Kloft in preparation for meeting with experts on seed valuation. Prepare for and conduct conference with client RE: Damages assessment and discuss business interference cause facts. Draft Motion for Summary Judgment on damages. Review letter from Dan Thenell regarding underwriting file. Review and analyze underwriting file (610 pages). Telephone call with Paul Kloft in preparation for tomorrow's meeting; Informed attorneys of meeting. Telephone call with Craig Edminster to schedule meeting; Left voicemail for Paul Kloft. Telephone conversations with Paul Kloft to schedule experts to come in to discuss value of seed. Review, analyze and index underwriting documents (610 pages). 02 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 08 Christopher Fanning $182 08 $145.60 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 30 Fred Millard $350 30 $1,050.00 05 0.1 09 0.1 Christopher Fanning Doug Bragg Doug Bragg Heidi Gross $182 $280 $280 $50 All - Clerical 05 0.1 09 00 $91.00 $28.00 $252.00 $0.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 02 Michele Barbara $125 All -Clerical 00 $0.00 15 Michele Barbara $125 15 $187.50 Prepare for and conduct meeting with Fred Millard, Paul Kloft and Craig Edminster regarding valuation testimony. Matter conference with Expert and client valuation. Assist Fred Millard in preparation for meeting with Craig Edminster and Paul Kloft. Continue Review, analyzing and indexing underwriter's documents (610 pages). Continue Review, analyzing and indexing Underwriting documents (610 pages). Review, analyze and respond to email from Greg Mettler regarding Business Interruption Coverage Analysis. 10 Doug Bragg $280 00 $0.00 5.1 02 Fred Millard Michele Barbara $350 $125 5.1 02 $1,785.00 $25.00 03 Michele Barbara $125 03 $37.50 38 Michele Barbara $125 38 $475.00 02 Doug Bragg $280 02 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 44 of 161 Date 6/21/12 6/28/12 6/28/12 6/28/12 6/28/12 6/28/12 6/28/12 6/28/12 6/29/12 6/29/12 6/29/12 6/29/12 6/29/12 6/29/12 6/29/12 6/29/12 7/2/12 7/2/12 7/2/12 7/3/12 7/5/12 7/5/12 7/5/12 7/5/12 7/5/12 7/5/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Continue Reviewing, analyzing and indexing the Underwriting documents (610 pages). Draft declaration of Paul Kloft for Second Motion for Summary Judgment; Reviewed and analyzed the different documents showing damages and calculated them to include in the declaration. 35 Michele Barbara $125 35 $437.50 39 Christopher Fanning $182 39 $709.80 Confer with Christopher Fanning and Michele Barbara to analyze Motion for Summary Judgment on damages. Phone call with Paul Kloft and Fred Millard to analyze Motion for Summary Judgment on Damages. Confer with Doug Bragg analyzing Summary Judgment on Damages. 05 Doug Bragg $280 05 $140.00 03 Doug Bragg $280 03 $84.00 0.1 Michele Barbara $125 00 $0.00 Identify exhibits for preparation of Paul Kloft's Declaration in Support of Summary Judgment Motion. Telephone calls to Robert Halsey and Craig Edminster regarding their reports; Confirming e-mail to Craig Edminster that he will be discussing native grasses and seed stock in his report. 0.4 Michele Barbara $125 0.4 $50.00 03 Michele Barbara $125 03 $37.50 Prepare exhibits for Motion for Summary Judgments; Finalize spreadsheet for values of seed. Draft argument section of Motion for Summary Judgment. Calculating figures for Paul's Declaration. Draft Paul's Declaration. Draft Motion for Summary Judgment, rework introduction, Statement of Facts. Confer with Michele Barbara RE: status of experts and site visit. Review email from Michele Barbara RE: scheduling experts and status of expert reports and reminder for meeting at Precision Seed. 25 Michele Barbara $125 25 $312.50 1.7 0.7 02 10 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 1.7 0.7 02 10 $309.40 $127.40 $36.40 $182.00 0.1 0.1 Doug Bragg Fred Millard $280 $350 0.1 0.1 $28.00 $35.00 Telephone calls from Paul Kloft RE: scheduling experts and status of expert reports; E-mail to Fred Millard RE: same and reminder for meeting at Precision Seed. Confer with Doug Bragg RE: status of experts and site visit. 03 Michele Barbara $125 All -Clerical 00 $0.00 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 Draft Declaration of Doug Bragg to Support Motion for Summary Judgment. Review draft of Motion for Summary Judgment and making changes before giving to Doug Bragg. Site visit with Client touring facility RE: Cleaning process; Meeting with potential experts on valuing various seeds and equipment - travel 70 miles Roundtrip. Confer with Fred Millard; Telephone call to Paul Kloft RE: obtaining his information on his expertise for his Declaration in Support of Motion for Summary Judgment. Review draft Declaration for Paul Kloft for Summary Judgment Motion. 08 Christopher Fanning $182 08 $145.60 05 Christopher Fanning $182 05 $91.00 6.1 Fred Millard $350 6.1 $2,135.00 02 Michele Barbara $125 02 $25.00 02 Doug Bragg $280 02 $56.00 Telephone calls to Paul Kloft and Greg Mettler. Telephone call with Paul Kloft RE: his schooling and expertise for his Declaration. Revise Paul Kloft's Declaration to include information on his schooling and expertise for his Declaration. Prepare exhibits for Paul Kloft's Declaration. E-mail from Doug Bragg to take out any references related to policy limits from Paul Kloft's Declaration; Revised Declaration and resent to Doug Bragg via e-mail. 03 05 Michele Barbara Michele Barbara $125 $125 00 05 $0.00 $62.50 10 Michele Barbara $125 10 $125.00 10 0.4 Michele Barbara Michele Barbara $125 $125 10 02 $125.00 $25.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Clerical/Vague 0.2 - Clerical Page 45 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Clerical 7/5/12 Prepare letters for Mike Billman, Robert Halsey, Craig Edminster, and Trevor Abbott RE: expert report deadlines and requirements. 0.6 Michele Barbara $125 7/5/12 7/5/12 7/6/12 Confer with Doug Bragg analyzing Paul Kloft's Declaration. Revise Declaration of Paul Kloft. Confer with Michele Barbara analyzing draft Declaration for Paul Kloft. 0.1 02 02 Michele Barbara Michele Barbara Doug Bragg 7/6/12 Continue Review, analyzing and indexing the Underwriting file (610 pages). Revise letters to experts for Fred Millard's signature. Meeting with client, analyzed with Michele Barbara and Doug Bragg, Paul's Declaration for Motion for Summary Judgment. Revise Motion for Summary Judgment to reflect changes made to Paul's Declaration and other changes from meeting. Draft Motion for Summary Judgment. Adding section to memo in Support of Motion for Summary Judgment asking for prejudgment interest. Confer with Fred Millard regarding meeting with experts and follow-up for mediation. Meet with Paul Kloft, Christopher Fanning and Michele Barbara analyzing Declaration of Paul Kloft in Support of Motion for Partial Summary Judgment. Review draft Memorandum in Support of Second Motion for Summary Judgment. Met with Paul Kloft RE: signing his Declaration for Summary Judgment and review of exhibits for Motion for Summary Judgment. 15 7/6/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/9/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 7/10/12 3:10-cv-01023-HZ Hrs Awarded Amount 00 $0.00 $125 $125 $280 0.1 02 02 $12.50 $25.00 $56.00 Michele Barbara $125 15 $187.50 03 1.1 Michele Barbara Christopher Fanning $125 $182 03 0.6 $37.50 $109.20 2.1 Christopher Fanning $182 2.1 $382.20 02 09 Christopher Fanning Christopher Fanning $182 $182 02 09 $36.40 $163.80 02 Doug Bragg $280 02 $56.00 05 Doug Bragg $280 05 $140.00 0.4 Doug Bragg $280 0.4 $112.00 10 Michele Barbara $125 10 $125.00 Scan and e-mail weights information sheets to Precision Seed. E-mails from Craig Edminster; Telephone calls with Craig Edminster RE: expert valuation letter. Revise draft of memo in support of motion for summary judgment. 02 0.4 Michele Barbara Michele Barbara $125 $125 00 0.4 $0.00 $50.00 05 Christopher Fanning $182 05 $91.00 Additional revisions to draft of memo in support of motion for summary judgment per request of Doug Bragg. Revise Doug Bragg's declaration in support of motion for summary judgment. Revise the actual motion for summary judgment. Review draft Motion for Partial Summary Judgment. Review seed valuation from Craig Edminster. Review/respond to email from Dan Thenell regarding second motion for summary judgment. Review/respond to email from Dan Thenell regarding summary judgment filing. Confer with Christopher Fanning regarding FRCP 56(d). Review FRCP 56(d). Phone call to Dan Thenell regarding depositions and summary judgment; left voicemail. Confer with Fred Millard analyzing 56(d) issues raised by Country. 1.4 Christopher Fanning $182 1.4 $254.80 03 Christopher Fanning $182 03 $54.60 0.1 0.7 02 0.1 Christopher Fanning Doug Bragg Doug Bragg Doug Bragg $182 $280 $280 $280 0.1 0.7 02 0.1 $18.20 $196.00 $56.00 $28.00 02 Doug Bragg $280 02 $56.00 02 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 0.1 $56.00 $28.00 $28.00 02 Doug Bragg $280 02 $56.00 Draft email to Dan Thenell analyzing FRCP 56(d) issue, expert discovery and mediation. Phone call with Dan Thenell regarding expert discovery issues and possible motion for summary judgment. Phone calls with experts regarding expert reports. Email Trevor Abbott regarding expert report. 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 05 02 Doug Bragg Doug Bragg $280 $280 05 02 $140.00 $56.00 ATTACHMENT 1 0.5 Duplicative; billed to Bragg All - Clerical Page 46 of 161 Date 7/10/12 7/10/12 7/10/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/11/12 7/12/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Email Greg Mettler regarding expert report. Email Mike Billman regarding expert report. Confer with Christopher Fanning regarding revisions to draft Motion for Partial Summary Judgment. Researching expert disclosures and motions for summary judgment. 0.1 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.1 02 $28.00 $28.00 $56.00 19 Christopher Fanning $182 19 $345.80 Phone call with Paul Kloft regarding additional depositions; left voicemail. Confer with Michele Barbara analyzing additional depositions requested by Country Mutual. Phone call with Mike Billman regarding expert report. Email Billman confirming the phone call and Review requirements for expert report. Phone call to Greg Mettler regarding expert report on or before August 1; left voicemail. Email Dan Thenell regarding proposed early exchange of expert reports, agreement to postpone remaining depositions past Aug. 1, and possible outstanding discovery. File Partial Motion for Summary Judgment regarding damages. Review instructions for settlement conference; begin draft position statement. Email Dan Thenell regarding preparations for settlement conference. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 03 03 Doug Bragg Doug Bragg $280 $280 03 03 $84.00 $84.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 0.7 Doug Bragg Doug Bragg $280 $280 00 0.7 $0.00 $196.00 02 Doug Bragg $280 02 $56.00 E-mails from Dan Thenell regarding deposition scheduling; Confer with Doug Bragg RE: same; Telephone call to Zaro & Zaro to see if Earl Doman's deposition went forward. Telephone call from Sarah with Dan Thenell's office to schedule depositions; Telephone conversation with Paul Kloft RE: scheduling. 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 Telephone conversation with Kim Ellingson RE: scheduling of deposition and confirmation of name and address. Draft mediation statement. Review/respond to email from Mike Billman regarding seed test request. Direct Michele Barbara to locate seed test results and scan to forward to experts. Review email and voicemail from Greg Mettler regarding expert report. 02 Michele Barbara $125 All - Clerical 00 $0.00 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Email Dan Thenell regarding advancing expert disclosures. Email Greg Mettler regarding expert report. Review tables of contents to documents submitted by Precision to Country during claim investigation; Direct Michele Barbara to forward copies of same to various experts to identify additional documents needed for their analysis. Draft e-memo to Fred Millard analyzing expert disclosures and summary judgment. Revise draft mediation statement. Phone call with Craig Edminster analyzing seed valuation opinion. 0.1 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 02 02 $28.00 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 03 0.4 Doug Bragg Doug Bragg $280 $280 03 0.4 $84.00 $112.00 Email Craig Edminster regarding expert report requirements. Phone call to Paul Kloft discussing expert reports. Draft email to experts regarding reports and supporting data. Phone call to Trevor Abbott regarding seed quantities; left voicemail and sent email. 02 10 02 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 02 10 02 02 $56.00 $280.00 $56.00 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical Page 47 of 161 Date 7/13/12 7/13/12 7/13/12 7/13/12 7/13/12 7/16/12 7/16/12 7/16/12 7/16/12 7/16/12 7/16/12 7/16/12 7/16/12 7/16/12 7/17/12 7/17/12 7/17/12 7/17/12 7/17/12 7/18/12 7/18/12 7/18/12 7/18/12 7/18/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Confer with Michele Barbara regarding organizing documents by seed lot for experts. Phone call to Dan Thenell regarding insurance coverage counsel. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Phone call with Trevor regarding cleanout issue. Confer with Doug Bragg; Forward seed tests to Mike Billman, Trevor Abbott and Craig Edminster; E-mail binder indexes to Mike Billman, Trevor Abbott, Craig Edminster and Greg Mettler to see if they would like any additional documents. Confer with Doug Bragg to ask Mike Billman, Craig Edminster and Trevor Abbott to put in the grower and lot numbers when they complete their valuations; E-mail to experts RE: same. Revise draft mediation statement. Phone call with Don Kelley RE: policy interpretation. Draft e-memo to Fred Millard regarding phone call with Don Kelley and insurance policy review. Confer with Michele Barbara regarding status of seed experts' work and questions. E-mails with Mike Billman RE: spreadsheets for seed of others and Precision Seed; Confer with Doug Bragg RE: Billman's request for Seed of Other's spreadsheets; Telephone call to Precision Seed requesting same. 0.1 05 Doug Bragg Michele Barbara $280 $125 0.1 00 $28.00 $0.00 03 Michele Barbara $125 00 $0.00 0.4 05 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.4 05 02 $112.00 $140.00 $56.00 03 Doug Bragg $280 03 $84.00 03 Michele Barbara $125 00 $0.00 E-mail from Mike Billman asking for test results on Lupine; Review binders for tests on Lupine; Telephone call to Paul Kloft RE: Mike Billman to advise him that we do not know the specifics on Lupine, but that it was a 2002 seed. Telephone conversations with James Kloft RE: spreadsheets for seed of others and Precision Seed's seed; Forward spreadsheets of seed to Mike Billman, Trevor Abbott and Craig Edminster. 0.4 Michele Barbara $125 0.4 $50.00 03 Michele Barbara $125 02 $25.00 E-mail from Mike Billman Re: White Primrose seed for $25 per pound; Telephone call to James and Paul Kloft RE: White Primrose inquiry from the Kloft's. Assist Michele Barbara in reviewing Precision's discovery and identifying seed testing documents for a particular lot-numbered seed. 03 Michele Barbara $125 03 $37.50 0.5 Tracey Poole $115 05 $57.50 Listen to voicemail from Greg Mettler regarding expert report. Review fees and costs from Don Kelley for purposes of preparing the mediation statement. Confer with Fred Millard regarding status of expert reports. Revise draft mediation statement. Telephone call from Paul Kloft to confirm flower variety Mike Billman was questioning. Attend meeting with Paul Kloft and Fred Millard regarding case status and mediation; meet with Paul Kloft and Michele Barbara regarding locating records to assist experts on seed values issue. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 08 0.1 Doug Bragg Doug Bragg Michele Barbara $280 $280 $125 02 08 0.1 $56.00 $224.00 $12.50 15 Doug Bragg $280 05 $140.00 Review Expert Disclosures from Country; Email Jillian Hinman regarding same. Review/respond to email from Dan Thenell regarding expert disclosures. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Review notices from court regarding appearance of counsel and change of address for Country Mutual. Attend meeting with Paul Kloft and Doug Bragg regarding case status and mediation. 0.1 Doug Bragg $280 0.1 $28.00 10 Fred Millard $350 10 $350.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical/Duplicative; billed to Bragg All - Clerical/Duplicative; billed to Bragg All - Clerical/Duplicative; billed to Bragg 0.1 Clerical 1.0 Duplicative; billed to Millard Page 48 of 161 Date Hrs Awarded Amount $125 35 $437.50 Michele Barbara $125 0.1 $12.50 10 Michele Barbara $125 10 $125.00 03 Michele Barbara $125 03 $37.50 03 Michele Barbara $125 03 $37.50 0.4 Michele Barbara $125 0.4 $50.00 03 Michele Barbara $125 03 $37.50 03 Doug Bragg $280 03 $84.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 02 Fred Millard $350 02 $70.00 7/24/12 Review and analyze spreadsheets to make sure all seed lots are covered for valuations. Phone call with Dan Thenell and Fred Millard regarding mediation and expert disclosures. Email Dan Thenell regarding deposition schedule. Confer with Fred Millard analyzing intervention by Reiling Farms; Review FRCP 24. Review and respond to Kelley email regarding potential Intervention by Reiling Farms Confer with Michele Barbara regarding preparation for mediation. 03 Doug Bragg $280 03 $84.00 7/24/12 Confer with Fred Millard regarding scope of damages. 03 Doug Bragg $280 00 $0.00 7/24/12 7/24/12 Email Dan Thenell regarding deposition schedule. Review response from Dan Thenell regarding deposition schedule. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 7/24/12 7/24/12 Confer with Doug Bragg regarding scope of damages. Confer with Doug Bragg to prepare documents for mediation. 03 03 Fred Millard Michele Barbara $350 $125 03 00 $105.00 $0.00 7/24/12 Telephone calls to Paul and James Kloft RE: signed contracts related to values and/or quantities. Discussing project related to mediation statement RE: analysis of equipment list provided by Robert Halsey with Doug Bragg. Compare and analyze claim values with Robert Halsey report. Review and analyze draft report from Mike Billman. Email Mike Billman regarding draft expert report. Confer with Fred Millard analyzing Deposition schedule. 22 Michele Barbara $125 22 $275.00 02 Christopher Fanning $182 02 $36.40 1.7 02 Christopher Fanning Doug Bragg $182 $280 1.7 02 $309.40 $56.00 02 Doug Bragg $280 00 $0.00 Phone call to Dan Thenell regarding depositions, he was in a meeting; email Dan Thenell regarding same. Conference with Fred Millard regarding trial preparation, settlement, and motion to amend complaint regarding Ionian v. Precision fees. 0.1 Doug Bragg $280 0.1 $28.00 15 Doug Bragg $280 00 $0.00 Phone call to Greg Mettler regarding mediation statement. Revise draft mediation statement to incorporate comments from Greg Mettler. Confer with Fred Millard and Don Kelley regarding settlement and claim analysis. 03 0.6 Doug Bragg Doug Bragg $280 $280 03 0.6 $84.00 $168.00 10 Doug Bragg $280 00 $0.00 7/18/12 7/18/12 7/18/12 7/19/12 7/20/12 7/20/12 7/20/12 7/23/12 7/23/12 7/23/12 7/23/12 7/25/12 7/25/12 7/25/12 7/25/12 7/25/12 7/25/12 7/25/12 7/25/12 7/25/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Meet with Paul Kloft to go over lot numbers, values, contracts and tests; E-mail experts with contracts and tests. Review e-mail from Mike Billman with information on what he is valuing. Evaluate Mike Billman's list of seed lots he will value and Craig Edminster's list of seed lots he will value and advise them on duplication. Review seed documents to analyze which growers are not covered by the experts; Telephone call to Paul Kloft RE: potential gaps in seed valuation analysis. E-mail from Trevor Abbott RE: additional values he will be assisting us with; E-mail to Craig Edminster and Mike Billman RE: leftover seed we still need assistance on. Voicemail to Mike Billman; Telephone call to Craig Edminster to take remaining seed values for Precision Seed's fire loss; Confirmation e-mail to three experts to confirm that Craig will take remaining seed. 35 Michele Barbara 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 49 of 161 Date 7/25/12 7/25/12 7/25/12 7/25/12 7/26/12 7/26/12 7/26/12 7/26/12 7/26/12 7/26/12 7/26/12 7/27/12 7/27/12 7/27/12 7/27/12 7/27/12 7/27/12 7/27/12 7/27/12 7/30/12 7/30/12 7/30/12 7/30/12 7/30/12 7/30/12 7/31/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Phone call with Dan Thenell regarding deposition schedule; Confer with his assistant regarding deposition schedule. Confer with Doug Bragg analyzing Deposition schedule. Conference with Doug Bragg regarding trial preparation, settlement, and motion to amend complaint regarding Ionian v. Precision fees. 03 Doug Bragg $280 03 $84.00 02 15 Fred Millard Fred Millard $350 $350 02 15 $70.00 $525.00 Confer with Doug Bragg and Don Kelley regarding settlement and claim analysis. Review, analyze and compare Robert Halsey's report to Precision's equipment lists to verify completeness of report. Locate potential duplication and identify equipment not valued. 10 Fred Millard $350 10 $350.00 4.6 Christopher Fanning $182 4.6 $837.20 Confer with Christopher Fanning analyzing the equipment list provided by Robert Halsey. Phone call with Dan Thenell regarding issues separating parties for mediation. Conference with Fred Millard analyzing Dan Thenell's view of the issues separating the parties going into mediation. Email Dan Thenell regarding depositions and issues for mediation. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Christopher Fanning analyzing collateral estoppel, binding authority of district court opinions and analysis of actual cash value on equipment claim. Confirm all seed lot values are assigned and covered; E-mail Trevor Abbott and Craig Edminster with additional clarification and signed pages from other growers. Researching collateral estoppel and offensive collateral estoppel due to similar legal/factual issues with MLM. Researching stare decisis and if it applies to district court holdings due to similar legal/factual issues with MLM. Assist in preparation for mediation. Phone call with Paul Kloft regarding mediation preparation and expert analysis of loss. Confer with Fred Millard analyzing prejudgment interest and Actual Cash Value/Replacement cost value issues. Research caselaw on interpleader to avoid ORS 742.061 attorney fees; Review court order on Ionian v Precision Second Summary Judgment; Email Dan Thenell ruling on Summary Judgment in Ionian v. Precision matter. Phone call to Mike Billman regarding valuation opinion. Email Craig Edminster and Trevor Abbott regarding seed valuation status. Review/respond to email from Dan Thenell regarding Motion to Amend and settlement. Review and analyze updated spreadsheet from Mike Billman. Review and analyze filings by Dan Thenell regarding Motion for Extension of time; Email court clerk regarding opposition. Confer with Fred Millard regarding Motion for Extension filed by Country. Telephone conversation with Trevor Abbott RE: total values and clarify his notes; Begin calculating values. Confer with Doug Bragg RE: lack of seed stock tests; Telephone conversation with Paul Kloft RE: tests for seed stock. Researching FRCP 26(a)(2)(d) for response to Thenell's motion for an extension. Prepare an outline for the response. 03 Doug Bragg $280 03 $84.00 0.6 Michele Barbara $125 0.6 $75.00 08 Christopher Fanning $182 08 $145.60 1.6 Christopher Fanning $182 1.6 $291.20 02 08 Christopher Fanning Doug Bragg $182 $280 00 08 $0.00 $224.00 03 Doug Bragg $280 03 $84.00 0.7 Doug Bragg $280 0.7 $196.00 0.7 0.1 Doug Bragg Doug Bragg $280 $280 0.7 0.1 $196.00 $28.00 03 Doug Bragg $280 03 $84.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 03 Doug Bragg $280 03 $84.00 20 Michele Barbara $125 20 $250.00 02 Michele Barbara $125 02 $25.00 19 Christopher Fanning $182 10 $182.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Vague 0.9 Excessive Page 50 of 161 Date Hrs Awarded Amount $182 1.1 $200.20 Christopher Fanning $182 0.7 $127.40 02 Christopher Fanning $182 02 $36.40 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 1.7 02 03 0.4 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 1.7 02 03 0.4 $476.00 $56.00 $84.00 $112.00 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 0.4 Michele Barbara $125 0.4 $50.00 0.4 Michele Barbara $125 0.4 $50.00 8/1/12 Review/respond to email from Mike Billman regarding expert report and contact from Thenell Law Group on Age of Seed. Confer with Fred Millard analyzing Michael Billman's email and potential issue of both sides utilizing the same expert. Phone call with Mike Billman to analyze draft expert report and Thenell Law Group. Revise mediation statement. Phone call with Craig Edminster to analyze seed values. Confer with Fred Millard to analyze mediation statement. Revise mediation statement to reflect expert valuations and Fred's comments. Confer with Fred Millard to analyze building coverage v. Personal property coverage analysis. Review and analyze motion for extension of time to respond to motion for summary judgment. Prepare draft of Response and Opposition to Defendant's Motion for Extension of Time. Confer with Doug Bragg to analyze spreadsheets for mediation for values of seed. Researching FRCP 56(d) for response to Country's motion for extension. 0.4 Christopher Fanning $182 All - Excessive 00 $0.00 8/1/12 8/1/12 Draft response to Country's motion for extension. Revise response to Motion for Extension per request of Doug Bragg. 25 0.4 Christopher Fanning Christopher Fanning $182 $182 1.5 Excessive 10 0.4 $182.00 $72.80 8/1/12 Confer with Christopher Fanning to analyze Response to Motion for Extension of time filed by Country. Confer with Fred Millard to develop mediation strategy. 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 8/1/12 Phone call with Paul Kloft and Fred Millard regarding Precision's Motion for extension of time and upcoming mediation. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 8/1/12 8/1/12 8/1/12 File opposition to Motion for Extension of Time. Conferred with Doug Bragg to develop mediation strategy. Phone call with Paul Kloft and Doug Bragg regarding Precision's Motion for extension of time and upcoming mediation. Prepare for and conduct phone call with Paul Kloft regarding mediation and status of second summary judgment. Review notice from court granting motion for extension of time. 0.1 10 02 Doug Bragg Fred Millard Fred Millard $280 $350 $350 All - Clerical 00 10 02 $0.00 $350.00 $70.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 8/2/12 Phone call with Paul Kloft regarding seed inventories, seed stock issues, mediation and the second summary judgment motion. 0.6 Doug Bragg $280 0.6 $168.00 8/3/12 8/3/12 Review photographs from client. Telephone conversation with Paul Kloft in preparation for appointment for Monday before mediation; Paul Kloft confirmed that he will be trying to obtain last signature for contract and will bring documents with him on Monday. 02 02 Doug Bragg Michele Barbara $280 $125 02 02 $56.00 $25.00 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 7/31/12 8/1/12 8/2/12 8/2/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze prices in Billman charts for flower seed lots and giving Doug new numbers for mediation statement. Pulling cases on Federal Rules of Civil Procedure 56 for response to Motion for Extension. Confer with Doug Bragg to analyze Response to Motion for Extension of Time to Respond to Motion for Summary Judgment. 1.1 Christopher Fanning 0.7 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 51 of 161 Date Hrs Awarded Amount $182 1.1 $200.20 Christopher Fanning $182 1.1 $200.20 0.6 05 Christopher Fanning Christopher Fanning $182 $182 0.6 00 $109.20 $0.00 05 Doug Bragg $280 05 $140.00 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 Email Dan Thenell regarding scope of the Subpoena Duces Tecum for Earl Doman. Review and analyze email from Dan Thenell regarding subpoena and expert disclosures; respond to same. Meet with Paul Kloft and Fred Millard to prepare for mediation. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 5.4 Doug Bragg $280 00 $0.00 Prepare for and conduct client meeting to prepare for settlement conference. Assist Doug Bragg to prepare for mediation. 63 Fred Millard $350 63 $2,205.00 05 Michele Barbara $125 00 $0.00 8/6/12 Telephone conversations with James Kloft RE: additional photos; Review and analyze e-mail with additional photos of seed. 03 Michele Barbara $125 03 $37.50 8/6/12 Assist Paul Kloft and Doug Bragg with preparation for mediation. 30 Michele Barbara $125 00 $0.00 8/7/12 Travel to and from courthouse; Attended mediation at Federal Courthouse in Portland to assist in identification and explanation of supporting documents for claim. Travel to/from courthouse; attend mediation. Settlement conference with travel and parking. 25 miles round-trip 75 Christopher Fanning $182 75 $1,365.00 75 75 Doug Bragg Fred Millard $280 $350 75 75 $2,100.00 $2,625.00 E-mail to Dan Thenell with additional discovery documents. Attend mediation with Fred Millard and Doug Bragg to assist with identification and explanation of documents proving seed claim document production if needed. Confer with Doug Bragg RE: need to revise interrogatory responses; Review file to see if we have identified Robert Halsey, James Kloft and Humberto Cruz; Confer with Doug Bragg that we have not given Humberto Cruz's information yet; Review file for information on request of tests and confirm that Country has asked for all tests. 0.1 60 Michele Barbara Michele Barbara $125 $125 00 60 $0.00 $750.00 05 Michele Barbara $125 05 $62.50 Prepare draft Notice of Taking Depositions for Byron Slack, Dave Logan and crane operator. Prepare templates for Craig Edminster and Trevor Abbott for expert report letters. Email Greg Mettler regarding expert report. Email Nick Priest regarding expert report. Phone call with Paul Kloft regarding potential additional discovery, expert reports, and settlement. Confer with Fred Millard regarding issues at settlement conference, discovery and expert discovery status. Email Dan Thenell regarding depositions. 0.4 Michele Barbara $125 All - Clerical 00 $0.00 0.4 Michele Barbara $125 All - Clerical 00 $0.00 02 02 0.6 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 0.6 $56.00 $56.00 $168.00 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/6/12 8/7/12 8/7/12 8/7/12 8/7/12 8/7/12 8/7/12 8/7/12 8/8/12 8/8/12 8/8/12 8/8/12 8/8/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review research on collateral estoppel. draft memorandum analyzing collateral estoppel. Researching prejudgment interest and requirements of specifying. 1.1 Christopher Fanning 1.1 Draft memorandum on prejudgment interest issues. Assisting Doug Bragg and Michele Barbara with preparation for mediation. Meet with Michele Barbara to review and analyze claim valuation summaries in preparation for mediation. Draft special terms for mediation. Review and analyze notice of Subpoena Duces Tecum for Earl Doman. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Vague All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Vague All - Clerical Page 52 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review draft Opinion Letter from Mike Billman, make comments and email to Mike Billman for review. Review notice from court regarding settlement status. Confer with Fred Millard analyzing prejudgment interest question. 05 Doug Bragg $280 05 $140.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 8/8/12 Confer with Fred Millard analyzing mediation, possible continuance of mediation and "emotional component" to settlement discussions. 03 Doug Bragg $280 03 $84.00 8/9/12 Email Robert Halsey regarding equipment photos and valuation. 0.1 Doug Bragg $280 0.1 $28.00 8/9/12 8/9/12 Confer with Fred Millard analyzing discovery issues. Direct Michele Barbara to prepare list of equipment requiring expert support. Confer with Fred Millard and Michele Barbara to analyze Robert Halsey's report versus Scheduled and Unscheduled Personal Property lists. Confer with Michele Barbara and Doug Bragg to analyze Robert Halsey's report versus Scheduled and Unscheduled Personal Property lists. 0.6 02 Doug Bragg Doug Bragg $280 $280 0.6 02 $168.00 $56.00 15 Doug Bragg $280 00 $0.00 15 Fred Millard $350 15 $525.00 8/9/12 Confer with Fred Millard and Doug Bragg to analyze Robert Halsey's report versus Scheduled and Unscheduled Personal Property lists. 15 Michele Barbara $125 00 $0.00 8/10/12 Review and analyze list of scheduled and unscheduled equipment which Halsey could not value. Research used seed cleaning equipment dealers. Phone call to West Coast Seed Mill regarding possible valuation and expert testimony on used value of additional equipment. 02 Doug Bragg $280 02 $56.00 05 0.1 Doug Bragg Doug Bragg $280 $280 05 0.1 $140.00 $28.00 8/10/12 Phone call with Dennis Dillon at NW Office Liquidators regarding possible expert testimony on office equipment/supplies/furniture. 03 Doug Bragg $280 03 $84.00 8/10/12 Phone call with Greg Mettler regarding audit and status of Business income analysis. Prepare for and conduct meeting with client regarding Greg Mettler's analysis of Business income and audit of inventory records and requested information. Confer with Fred Millard analyzing status of expert reports on valuation of equipment and inventory. Prepare for and conduct meeting with Paul Kloft and Michele Barbara analyzing additional discovery documents. Prepare office equipment list for submission to Dennis Dillon for review. Email office equipment list to Dennis Dillon. Prepare non-Bratney covered equipment list for Dwayne at West Coast Seed Mill. Email non-Bratney covered equipment list to Dwayne at West Coast Seed Mill for review. Confer with Doug Bragg analyzing status of expert reports on valuation of equipment and inventory. Prepare Supplemental Response to Interrogatories and Request for Production adding Humberto Cruz' name. Confer with Doug Bragg to analyze Robert Halsey's report versus Scheduled and Unscheduled personal property lists. Meet with Paul Kloft and Doug Bragg to analyze claim damages spreadsheets and additional documentation. 0.4 Doug Bragg $280 0.4 $112.00 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 00 $0.00 20 Doug Bragg $280 20 $560.00 03 Doug Bragg $280 03 $84.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 0.1 Doug Bragg $280 0.1 $28.00 0.7 Fred Millard $350 0.7 $245.00 03 Michele Barbara $125 03 $37.50 02 Michele Barbara $125 02 $25.00 20 Michele Barbara $125 00 $0.00 8/8/12 8/8/12 8/8/12 8/9/12 8/9/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 8/10/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 53 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review, analyze, bates number and e-mail new 70 pages of production to Dan Thenell. Prepare Supplemental Response to First Interrogatories and Request for Production. Review, analyze and index additional 70 pages of documents produced by Precision Seed. Researching requirements for expert reports. Draft template of expert report to assist the various experts in this case. 0.7 Michele Barbara $125 0.7 $87.50 05 Michele Barbara $125 05 $62.50 0.6 Michele Barbara $125 0.6 $75.00 02 05 Christopher Fanning Christopher Fanning $182 $182 02 05 $36.40 $91.00 8/13/12 8/13/12 Applying expert findings of Mike Billman to template. Review and analyze expert reports that we have and determining what we need in order to finish the expert reports. 0.7 03 Christopher Fanning Christopher Fanning $182 $182 0.7 03 $127.40 $54.60 8/13/12 Review emails from Dennis Dillon regarding valuation of office equipment. Email Nick Priest analyzing scope of expert report on tenant improvements. Review and analyze proposed subpoena to Earl Doman from Country. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Confer with Christopher Fanning analyzing expert report templates for Trevor Abbott and Craig Edminster. Confer with Christopher Fanning analyzing template for expert reports and review draft template. Strategy meeting with Fred Millard analyzing and developing plan for future settlement discussions. Confer with Fred Millard analyzing subpoena of Earl Doman post- close of discovery. Email Dan Thenell and associates regarding Earl Doman's subpoena and additional depositions post-close discovery. Strategy meeting with Doug Bragg analyzing and developing plan for future settlement discussions. Confer with Doug Bragg analyzing subpoena of Earl Doman post- close of discovery. Travel to/from Brooks plant; Tour plant with James Kloft and meet with Paul Kloft regarding plant operations. Travel to/from Brooks; Prepare for and conduct meeting with Paul Kloft and James Kloft regarding seed storage, movement and documentation. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 03 Fred Millard $350 03 $105.00 02 Fred Millard $350 02 $70.00 30 Doug Bragg $280 30 $840.00 30 Fred Millard $350 30 $1,050.00 8/14/12 Telephone call from Joan Brown with Dan Thenell's office for discovery documents from Precision Seed. They do not have all of the bates numbered documents. Prepared DVD with all bates numbered documents and letter to Joan Brown RE: same. 03 Michele Barbara $125 00 $0.00 8/15/12 Confer with Fred Millard analyzing possibility of recovering damages for building coverage portion of claim as tenant improvements against Country. Prepare for and conduct meeting with Paul Kloft, Greg Mettler, Fred Millard, Earl Doman to analyze Business Interruption claim and underinsured claim. Prepare for and conduct meeting with Paul Kloft, Greg Mettler, Doug Bragg, Earl Doman to analyze Business Interruption claim and underinsured claim. Email from James Kloft with excel spreadsheet for seed lost. 05 Doug Bragg $280 05 $140.00 1.7 Doug Bragg $280 00 $0.00 1.7 Fred Millard $350 1.7 $595.00 0.1 Michele Barbara $125 00 $0.00 8/10/12 8/10/12 8/10/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/13/12 8/14/12 8/14/12 8/15/12 8/15/12 8/15/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Millard All - Clerical Page 54 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Email from Joan with Dan Thenell's office to confirm that they want to take Paul Kloft's deposition and discuss the values of the loss; Forward email to Doug Bragg and Fred Millard and ask for time frame to schedule depositions. Telephone calls with James Kloft discussing additional information on seed lots. Confer with Doug Bragg analyzing two additional pages of discovery related to lot 563-700; Bates number and e-mail same to Dan Thenell. 02 Michele Barbara $125 All - Clerical 05 Michele Barbara $125 03 Michele Barbara $125 Review, analyze and index additional two pages of discovery from Precision Seed. Review Proof of Loss and chart sent by James Kloft. Comparing and analyzing the items claimed with the documents we have to support those lots. Review and revise Precision Seed's seed amounts on weight with James Kloft's spreadsheet, tests and orders. Review and analyzing discovery documents (3,279 pages) and correlate cleaning and testing records with other documents per seed lot claimed lost in the fire. Review and analyzing documents from Jim King (1,128 pages), looking for anything that would show that Precision's seed existed. 0.1 Michele Barbara 12 Explanation Hrs Awarded Amount 00 $0.00 05 $62.50 02 $25.00 $125 0.1 $12.50 Christopher Fanning $182 12 $218.40 70 Michele Barbara $125 70 $875.00 35 Christopher Fanning $182 35 $637.00 0.6 Christopher Fanning $182 0.6 $109.20 13 Christopher Fanning $182 13 $236.60 8/20/12 Review and analyzing select documents from Country Mutual discovery (945 pages) searching for anything that would show that Precision's seed existed. Confer with Christopher Fanning analyzing seed lot documentation. 02 Doug Bragg $280 02 $56.00 8/20/12 Confer with Michele Barbara analyzing seed lot documentation. 02 Doug Bragg $280 02 $56.00 8/20/12 Conference with Doug Bragg analyzing experts and other discovery issues. Draft letter to Experts RE: Disclosures deadline, etc. Continue obtaining documentation for seed of Precision Seed by Review and analyzing all electronic documentation and organizing documentation by seed lot, per Greg Mettler (3,279 pages). 1.1 Fred Millard $350 1.1 $385.00 10 65 Fred Millard Michele Barbara $350 $125 10 65 $350.00 $812.50 Finalize letters to Craig Edminster, Trevor Abbott and Robert Halsey regarding expert disclosures. Email to Craig Edminster, Trevor Abbott and Robert Halsey regarding expert disclosures. Confer with Michele Barbara analyzing status of documentation for seed lots. Confer with Fred Millard analyzing discovery issues and expert disclosures. Continue Review, analyzing and correlating documentation (3,279 pages) by seed lot for Greg Mettler and update spreadsheet. 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 10 $280.00 69 Michele Barbara $125 69 $862.50 Telephone call to James Kloft for cleaning worksheets on lots. Review, analyze and organize documentation for seed of others seed lots (3,279 pages). Analyzing and organizing documentation for seed of others seed lots (3,279 pages). Review draft report from Nick Priest RE: tenant improvements. Email Nick Priest comments regarding draft report and request final report to submit to Country. 0.1 4.7 Michele Barbara Christopher Fanning $125 $182 00 4.7 $0.00 $855.40 12 Christopher Fanning $182 12 $218.40 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 8/15/12 8/15/12 8/16/12 8/16/12 8/17/12 8/17/12 8/20/12 8/20/12 8/20/12 8/20/12 8/20/12 8/20/12 8/20/12 8/21/12 8/21/12 8/21/12 8/21/12 8/22/12 8/22/12 8/22/12 8/22/12 3:10-cv-01023-HZ ATTACHMENT 1 0.1 - Clerical All - Clerical Page 55 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 23 $644.00 05 Doug Bragg $280 00 $0.00 10 Doug Bragg $280 10 $280.00 05 Fred Millard $350 05 $175.00 4.5 Christopher Fanning $182 45 $819.00 Confer with Michele Barbara analyzing backup documentation and updating spreadsheet for seed lots. Confer with Michele Barbara analyzing the documentation of seed lots. 10 Doug Bragg $280 10 $280.00 02 Doug Bragg $280 02 $56.00 8/23/12 Review and analyze client's documents (3,279 pages plus 11 binders) to isolate contracts for the production of seed by Precision. 23 Doug Bragg $280 23 $644.00 8/23/12 1.6 Doug Bragg $280 00 $0.00 8/23/12 Conference with Fred Millard regarding seed bookkeeping issues, status of expert reports, and voir dire. Draft voir dire questions based upon conversations with Fred Millard. 02 Doug Bragg $280 02 $56.00 8/23/12 8/23/12 Phone call with James Kloft regarding seed lot issues. Review and analyze seed inventory documents organization for trial. 03 02 Doug Bragg Fred Millard $280 $350 03 02 $84.00 $70.00 8/23/12 Matter conference with Doug Bragg analyzing seed inventory documents for trial. Confer with Doug Bragg analyzing backup documentation and updating spreadsheet for seed lots. Continue working on binder for Greg Mettler, analyzing backup documentation and preparing spreadsheet for seed lots. Telephone conversation with James Kloft RE: documentation for seed values. Continue Review, analyzing and organizing seed lot records for Greg Mettler (3,279 pages). Confer with Doug Bragg analyzing additional discovery responses. 1.6 Fred Millard $350 1.6 $560.00 10 Michele Barbara $125 00 $0.00 70 Michele Barbara $125 70 $875.00 02 Michele Barbara $125 02 $25.00 60 Michele Barbara $125 60 $750.00 0.1 Michele Barbara $125 0.1 $12.50 0.1 Michele Barbara $125 00 $0.00 8/23/12 Bates number two additional documents for discovery and forward to Dan Thenell via email. Review, analyze and index new discovery (two pages) from Precision. 0.1 Michele Barbara $125 0.1 $12.50 8/23/12 Confer with Doug Bragg analyzing seed claim. 0.1 Michele Barbara $125 00 $0.00 8/23/12 8/24/12 Calculate amount of Precision Seed for values. Searching through the eleven binders of Precision documents that weren't on the server to locate documents supporting the claim for seed of others. Review, analyze and organize documents that I found. 0.4 68 Michele Barbara Christopher Fanning $125 $182 0.4 68 $50.00 $1,237.60 8/24/12 Confer with Christopher Fanning and Michele Barbara analyzing records to support seed of others inventory. Assist in review and analyzing records (3,279 pages) for individual seed lots pursuant to Greg Mettler's instructions. 05 Doug Bragg $280 05 $140.00 1.4 Doug Bragg $280 1.4 $392.00 8/22/12 8/22/12 8/22/12 8/22/12 8/22/12 8/23/12 8/23/12 8/23/12 8/23/12 8/23/12 8/23/12 8/23/12 8/23/12 8/23/12 8/24/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Confer with Michele Barbara analyzing records pertaining to each lot of seed lost. Review and analyze individual document history for seed lots as compiled by Michele Barbara and Christopher Fanning. Confer with Fred Millard analyzing seed inventory review and possible issues relating to verification of certain seed lots. Draft e-memo to Client and Fred Millard analyzing first pass of seed lot verification process. Confer with Doug Bragg analyzing seed inventory review and possible issues relating to verification of certain seed lots. Continuing review and analysis of Precision's documents (about 3,000 pages) to find support for Precision's claim on the seed of others. 02 Doug Bragg 23 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Clerical All - Duplicative; billed to Bragg Page 56 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 02 02 Doug Bragg Doug Bragg Michele Barbara $280 $280 $125 02 02 00 $56.00 $56.00 $0.00 05 Michele Barbara $125 05 $62.50 05 Michele Barbara $125 05 $62.50 0.1 0.1 Michele Barbara Michele Barbara $125 $125 00 0.1 $0.00 $12.50 Confer with Doug Bragg to send Craig Edminster an email RE: expert report. Review, analyzing and organizing documents that support lost seed of others. Identify documents we have and documents we need. 0.1 Michele Barbara $125 0.1 $12.50 39 Christopher Fanning $182 39 $709.80 8/27/12 Prepare for and conduct meeting with James Kloft to analyze and review documentation for Precision Seed and Seed of Others on lot by lot basis. 40 Michele Barbara $125 40 $500.00 8/28/12 Telephone conversation with Paul Kloft related to documents for the valuation projects and Mike Billman's letter with changes. 08 Michele Barbara $125 08 $100.00 8/28/12 Email with Fred Millard advising him that Paul Kloft agrees with him that we should circulate Mike Billman's letter to other experts for their valuation reports. Review, analyze and bates number five additional pages of documentation from Paul Kloft. Send via email to Dan Thenell after bates numbering five additional pages of documents. Review, analyze and organize recent production (5 pages) into the binder for Precision's lost seed. Meet with Paul Kloft to review and analyze documents (3,279 pages, plus 11 binders) to support Precision Seed and Seed of Others seed lots. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 0.1 - Clerical 0.1 $12.50 0.1 Michele Barbara $125 All - Clerical 00 $0.00 05 Christopher Fanning $182 05 $91.00 40 Michele Barbara $125 40 $500.00 Assisting Client with review and analyze client documents to support claims of Seed of Others. Prepare for and conduct meeting with Paul Kloft and Michele Barbara analyzing questions from Greg Mettler on documentation of seed inventory. Confer with Fred Millard analyzing late discovery issues. 1.1 Christopher Fanning $182 1.1 $200.20 30 Doug Bragg $280 30 $840.00 02 Doug Bragg $280 00 $0.00 Meet with Paul Kloft and Christopher Fanning analyzing documentation supporting seed of others. Email Dan Thenell regarding additional discovery documents. Phone call with Dan Thenell regarding possible extension on expert disclosures and Summary Judgment Response as well as request Protective Order to cover tax returns. Phone call to Greg Mettler regarding questions regarding documentation of inventory; Left voicemail. 03 Doug Bragg $280 03 $84.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/24/12 8/27/12 8/28/12 8/28/12 8/29/12 8/30/12 9/4/12 9/4/12 9/4/12 9/4/12 9/4/12 9/4/12 9/4/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Confer with Christopher Fanning and Michele Barbara analyzing verification of seed of others in Book entries. Email James Kloft and Paul Kloft and Greg Mettler analyzing issues with Seed of Others Book Entries. Review email from Fred Millard analyzing financial records for Precision Seed. Email Trevor Abbott analyzing his draft expert report. Email Craig Edminster analyzing his draft expert report. Confer with Doug Bragg and Christopher Fanning to begin on Seed of Others binder for Greg Mettler. Review and analyze client documents and discovery records (3,279 pages) of seed of others lots. Telephone conversations with James Kloft RE: documentation requested. Voicemail to Robert Halsey RE: expert report. Telephone conversation with Craig Edminster about his expert report. 02 Doug Bragg 02 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Clerical All - Duplicative; billed to Millard Page 57 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 9/4/12 9/4/12 Review Motion for Extension of Time filed by Defendant. Email Court Clerk stipulating to 2 week extension to Scheduling Order. 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 9/4/12 9/4/12 Confer with Doug Bragg regarding late discovery. Meet with Paul Kloft analyzing questions from Greg Mettler on documentation of seed inventory. Continue working with Paul Kloft analyzing documentation for Seed of Others seed lots. Review and analyze terms with Client for glossary of important terms for Greg Mettler. Adding new documents (50 pages) to binder for Seed of Others seed lots. Double-checking documents that need to be produced with those that have been produced. Confer with Doug Bragg analyzing supplemental Discovery. 02 30 Fred Millard Michele Barbara $350 $125 02 30 $70.00 $375.00 55 Michele Barbara $125 55 $687.50 20 Christopher Fanning $182 20 $364.00 2.4 Christopher Fanning $182 2.4 $436.80 02 Christopher Fanning $182 00 $0.00 02 Doug Bragg $280 02 $56.00 9/5/12 Phone call with Trevor Abbott analyzing expert report on certain grass seeds. Confer with Christopher Fanning analyzing supplemental Discovery. 02 Doug Bragg $280 02 $56.00 9/5/12 9/6/12 Email supplemental Discovery to Dan Thenell. Preparing a glossary of terms based on notes from meeting with Client. 0.1 43 Doug Bragg Christopher Fanning $280 $182 0.1 43 $28.00 $782.60 9/6/12 Confer with Michele Barbara and Doug Bragg analyzing bates numbering issue. Listen to voicemail from Greg Mettler regarding expert report. Phone call with Greg Mettler regarding analysis of inventory. Phone call with Robert Halsey regarding expert report. Confer with Fred Millard analyzing sufficiency of Mike Billman's draft expert report. Confer with Michele Barbara and Christopher Fanning analyzing bates numbering issue. Draft e-memo to Greg Mettler analyzing and answering various questions about seed inventory. Review and analyze draft Expert Report from Billman analyzing flower seed values. Email comments on draft Report to Mike Billman. Confer with Doug Bragg analyzing sufficiency of Billman's draft expert report. Confer with Chris Fanning and Doug Bragg analyzing issue. 02 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 0.1 02 0.1 05 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 All - Duplicative; billed to Millard 0.1 02 0.1 00 $28.00 $56.00 $28.00 $0.00 02 Doug Bragg $280 02 $56.00 1.6 Doug Bragg $280 1.6 $448.00 03 Doug Bragg $280 03 $84.00 0.4 05 Doug Bragg Fred Millard $280 $350 0.4 05 $112.00 $175.00 02 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 9/6/12 Telephone call to Joan with Dan Thenell's office to advise her that we will just put an "A" after first five pages sent over to give new numbering - duplicative to what we sent over on 8/30/12; Revise document production, rescan and forward same to Dan Thenell. 05 Michele Barbara $125 All - Clerical 00 $0.00 9/6/12 Review, analyze and organize documentation of seed lots; Prepare binder of documents for Seed of Others for Greg Mettler highlighting lot numbers and weights. Matter conference with Doug Bragg, Fred Millard and staff analyzing unscheduled personal property inventory and approach toward securing expert testimony. Review and analyze glossary prepared by Christopher Fanning. Research seed cleaning regulations. Phone call with Paul Kloft regarding seed certification process and possible witness - Jesse Peters. 03 Michele Barbara $125 03 $37.50 15 Christopher Fanning $182 00 $0.00 03 1.1 03 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 1.1 03 $84.00 $308.00 $84.00 9/4/12 9/5/12 9/5/12 9/5/12 9/5/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/6/12 9/7/12 9/7/12 9/7/12 9/7/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 58 of 161 Date Hrs Req Pltf Lawyer Rate Email research on seed cleaning regulations to Greg Mettler for assistance in Review Precision's records. Confer with Fred Millard analyzing issues of proof surrounding nonBratney equipment. Review spreadsheet of non-Bratney equipment to identify individual suppliers and quantities associated with each supplier. 02 Doug Bragg 02 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/7/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 3:10-cv-01023-HZ Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 Review list of equipment to determine values of equipment by supplier. 09 Doug Bragg $280 09 $252.00 Draft e-memo to Fred Millard analyzing equipment valuation outside of Robert Halsey's report. Matter conference with Fred Millard, Christopher Fanning and staff analyzing unscheduled personal property inventory and approach toward securing expert testimony. Review and analyze Unscheduled personal property inventories. 02 Doug Bragg $280 0.1 Duplicative; billed to Millard 0.1 $28.00 15 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 15 Fred Millard $350 15 $525.00 Matter conference with Doug Bragg, Christopher Fanning and staff analyzing unscheduled personal property inventory and approach toward securing expert testimony. Telephone call with Nick Priest voicemail requesting call back. Review e-memo from Doug Bragg analyzing valuation of equipment outside of Robert Halsey's report. Confer with Doug Bragg analyzing which seed lots are certified, foundation, etc. to request documentation from State facilities on values. Telephone call to Paul Kloft RE: which seed lots are certified, foundation, etc. to request documentation from State facilities on values. Review, analyze and organize additional bates numbered documents (50 pages) to the binders of seed lot documentation for expert reports. 15 Fred Millard $350 15 $525.00 0.1 0.1 Fred Millard Fred Millard $350 $350 0.1 0.1 $35.00 $35.00 0.1 Michele Barbara $125 0.1 $12.50 0.1 Michele Barbara $125 0.1 $12.50 18 Michele Barbara $125 18 $225.00 Identify and bates number seven additional pages not produced and email to Greg Mettler and Dan Thenell. Confer with Doug Bragg to analyze valuation of equipment not valued by Robert Halsey. Review and analyze documents related to the non-Bratney equipment that I am attempting to find valuation testimony/evidence for. 02 Michele Barbara $125 0.1 $12.50 0.4 Christopher Fanning $182 0.4 $72.80 2.1 Christopher Fanning $182 2.1 $382.20 Matter conference with Staff analyzing outstanding expert witness requirements. Phone call with Client regarding status of expert reports. Email Dan Thenell regarding mistaken lot number for Steve Rusconi's portion of claim. Review and analyze Craig Edminster's report on certain grass seeds. 12 Christopher Fanning $182 12 $218.40 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 03 Doug Bragg $280 03 $84.00 Email Greg Mettler regarding significance of certified, foundation, registered and breeder seed lots. Email Craig Edminster comments regarding expert report. Email Trevor Abbott a copy of Craig Edminster's report and to check status of his report. Confer with Fred Millard analyzing equipment valuation and strategy for proving actual cash value for non-Bratney equipment. 0.1 Doug Bragg $280 0.1 $28.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 12 Doug Bragg $280 12 $336.00 Confer with Fred Millard analyzing expert reports and preparations for expert submittals. 03 Doug Bragg $280 00 $0.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason 0.1 - Clerical All - Duplicative; billed to Millard Page 59 of 161 Date Hrs Awarded Amount $280 08 $224.00 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 9/10/12 Phone call & email to Nick Priest regarding status of expert report on tenant improvements. Phone call to Craig Edminster regarding expert report, left voicemail. 0.1 Doug Bragg $280 0.1 $28.00 9/10/12 Email and voicemail to Trevor Abbott regarding status of expert report. 0.1 Doug Bragg $280 0.1 $28.00 9/10/12 Phone call to Robert Halsey regarding status of report, left voicemail. 0.1 Doug Bragg $280 0.1 $28.00 9/10/12 Phone call to Mike Billman regarding expert report, talked with assistant and learned he was out until 9/17/12. Phone call to Don Kelley's office regarding Lebanon Seaboard's lost property to include in claim. Email David Del Valle regarding seed bag valuation. Phone call to Fisher Farm & Lawn regarding actual cash value of nonBratney equipment. Phone call to Brian Sullivan regarding valuation of Lebanon Seaboard materials. Meeting with Christopher Fanning and Michele Barbara regarding pretrial schedule, calendar time to start identifying witnesses and prepare witness statements. Matter conference with Staff analyzing outstanding expert witness requirements. Review and analyze draft of Craig Edminster disclosure. Phone call with David Del Valle at Smith Seed regarding bag valuations. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 12 Doug Bragg $280 12 $336.00 09 02 Doug Bragg Doug Bragg $280 $280 09 02 $252.00 $56.00 Confer with Doug Bragg analyzing expert reports and preparations for expert submittals. Confer with Doug Bragg analyzing Edminster's report. Matter conference with Staff analyzing outstanding expert witness requirements. Telephone call from Paul Kloft RE: additional documentation related to foundation, certified lots and incorrect lot number for Steve Rusconi. 03 Fred Millard $350 03 $105.00 02 12 Fred Millard Fred Millard $350 $350 02 12 $70.00 $420.00 03 Michele Barbara $125 03 $37.50 Telephone call from Jesse Peters returning Doug Bragg's telephone call and confer with Doug Bragg RE phone call. Forward foundation and certified seed spreadsheets received from Precision Seed to Greg Mettler. Confer with Doug Bragg RE: foundation and certified seed spreadsheets received from Precision Seed. Met with Doug Bragg and Christopher Fanning analyzing experts needed for trial related to scheduled and unscheduled equipment. 0.1 Michele Barbara $125 0.1 $12.50 0.1 Michele Barbara $125 0.1 $12.50 0.1 Michele Barbara $125 0.1 $12.50 05 Michele Barbara $125 00 $0.00 Review, analyze and organize documentation for values of personal property per vendor to begin contacting them for potential valuation of non-Bratney equipment. Review and analyzing discovery documents and pulling those that are relevant to the equipment that we are seeking expert opinions on. 35 Michele Barbara $125 35 $437.50 22 Christopher Fanning $182 22 $400.40 Calling possible experts about their ability to testify. 20 Christopher Fanning $182 20 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/10/12 9/11/12 9/11/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Meet with Christopher Fanning and Michele Barbara analyzing expert reports and preparation for submittals to Country. Email Greg Mettler regarding status of expert reports on Inventory and Business Interruption coverage. Confer with Fred Millard analyzing Craig Edminster's report. 08 Doug Bragg 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Bragg $364.00 Page 60 of 161 Date Hrs Awarded Amount $182 $280 10 02 $182.00 $56.00 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 0.6 Doug Bragg Doug Bragg $280 $280 0.1 0.6 $28.00 $168.00 Phone call with John at Pape Equipment regarding valuation of Fisher Farm items. Email Robert Halsey comments on report and request as to additional items. Review Scheduled and Unscheduled supporting data to assist in verifying coverage of Robert Halsey's report. Confer with Christopher Fanning analyzing A-1 equipment valuation. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 9/11/12 Confer with Christopher Fanning and Michele Barbara analyzing supporting documents relating to individual equipment items lost in the fire. Phone call with Billet Products Co. regarding used value of pallets. 03 Doug Bragg $280 03 $84.00 9/11/12 Confer with Fred Millard analyzing used valuation of equipment project. 02 Doug Bragg $280 02 $56.00 9/11/12 Confer with Christopher Fanning analyzing obtaining used values for equipment from A-1 Scale, Toyota and Grainger. Phone call with James Kloft regarding equipment questions. Email Robert Halsey regarding electric motor and screens issues. 02 Doug Bragg $280 02 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 Phone call with Michael Rodrigue regarding possible expert testimony on actual cash value for business personal property. Prepare list of actual cash value items to Michael Rodrigue to look over for possible expert opinion. Draft e-memo to Fred Millard analyzing possibility of using an insurance adjuster to value business personal property. Review E-memo from Doug Bragg RE: Michael Rodrigue as an expert on Business Personal Property. Telephone call from Paul Kloft to discuss Doug Bragg's e-mail to David at Smith Seed. Confer with Doug Bragg RE: telephone call from Paul Kloft to discuss Doug Bragg's email to David at Smith Seed. Telephone conversations with James Kloft with Precision Seed to discuss darker receipt for Brooks Hardware and a copy of check related to receipt and discuss names of contact information at various vendors. 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 0.1 $28.00 0.1 Fred Millard $350 0.1 $35.00 02 Michele Barbara $125 02 $25.00 02 Michele Barbara $125 00 $0.00 02 Michele Barbara $125 02 $25.00 Continue working on personal property lists, Review and analyzing documentation, organizing documentation by item. 60 Michele Barbara $125 60 $750.00 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 9/11/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Draft and faxing letter to sales department at Grainger. Phone call with Nick Priest regarding expert report on tenant improvements. Phone call with Charles Fletcher regarding possibility of contacting Jesse Peters as a fact witness. Phone call with Robert Halsey regarding expert report on equipment valuations. Confer with Michele Barbara analyzing documents pertaining to additional purchasers. Confer with Christopher Fanning analyzing records relating to Toyota purchases. Review/respond to email from Charles Fletcher regarding Jesse Peters as a fact witness. Review draft report from Robert Halsey RE: equipment values. Outline comments and questions for Robert Halsey's expert report. 10 02 Christopher Fanning Doug Bragg 02 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason 0.1 Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 61 of 161 Date Hrs Awarded Amount $182 05 $91.00 Christopher Fanning $182 0.6 $109.20 2.7 Christopher Fanning $182 2.7 $491.40 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Email Dan Thenell regarding subpoenaed records from Earl Doman and protective order. Confer with Fred Millard analyzing issue of valuation of miscellaneous business personal property. Review/respond to email from Joan Brown regarding documents from Earl Doman's Subpoena. Review/respond to email from Bekki Duty at Bilet Products regarding pallet valuation. Review A-1 Scale items to verify supporting purchase records. Phone call with Michael Rodriguez analyzing actual cash value of business personal property. Confer with Fred Millard analyzing actual cash value from Michael Rodrigue. Phone call to Earl Doman's office regarding Response to Subpoena of Documents; Left message for Earl. Phone call with Earl Doman regarding status of Response to Country's Subpoena. Review documents produced by Earl Doman subject to Subpoena. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 05 Doug Bragg Doug Bragg $280 $280 0.1 05 $28.00 $140.00 02 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 13 Doug Bragg $280 13 $364.00 Confer with Doug Bragg analyzing actual cash value valuation from Michael Rodriguez. Review, analyzing and organizing client documents by item claimed lost for unscheduled and electrical Business Personal Property. 02 Fred Millard $350 02 $70.00 75 Michele Barbara $125 75 $937.50 9/13/12 9/13/12 Phone call to Jesse Peters, left voicemail. Review and analyze invoices and purchase records from Bratney and compared to list of equipment valued by Robert Halsey. 0.1 10 Doug Bragg Doug Bragg $280 $280 0.1 10 $28.00 $280.00 9/13/12 9/13/12 Phone call with DJ Myers regarding actual cash value of pallets. Email Michael Rodrigue regarding possible expert testimony on claims adjusting general practices and procedures. Phone call with John Poe regarding depreciation application to "net income" analysis for Business Interruption Valuation. Phone call with Greg Mettler regarding status of expert report on Business Interruption Coverage and seed inventory audit. Confer with Fred Millard analyzing conversation with Greg Mettler and status of other expert reports. Confer with Fred Millard analyzing possible issues for trial and question of "How is Country coming at us?" Confer with Doug Bragg analyzing possible issues for trial and question of "how is Country coming at us?" 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Fred Millard $350 02 $70.00 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/12/12 9/13/12 9/13/12 9/13/12 9/13/12 9/13/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Phone call with representative at Hoffman Manufacturing about items purchased by Precision. Drafted letter providing detailed explanation of information that we are seeking. Phone call with representative at Walinga about items purchased by Precision. Drafted letter providing detailed explanation of information that we are seeking. Review and analyzing client's discovery documents (3,357 pages) to determine to what extent a financial motive argument can be made against our clients. Confer with Michele Barbara analyzing business personal property documents. Confer with Christopher Fanning analyzing requests relating to determination of Actual Cash Value of Business Personal Property items. 05 Christopher Fanning 0.6 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 62 of 161 Date 9/13/12 9/13/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/14/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Confer with Doug Bragg analyzing conversation with Greg Mettler and status of other expert reports. Continue review, analyzing and organizing Client discovery by item claimed lost for scheduled and unscheduled equipment. Review, analyzing organizing documents to support existence of equipment that was lost in the fire. Phone call with Jesse Peters regarding her interaction with Precision as a Seed Tester. Phone call with Paula Mills regarding her interaction with Precision Seed as a Seed Tester. Review and analyze research from John Poe regarding depreciation as part of business interruption claim. Research depreciation as part of the calculation of Business Interruption Coverage. Draft email to John Poe and Greg Mettler analyzing Business Interruption claim. Review email from David DelValle regarding Smith bag values. Phone call with Mary at Toyota regarding forklift valuation. Email Greg Mettler regarding conversations with Paula Mills and Jesse Peters RE: seed testing. Status conference with Fred Millard analyzing witness and expert witness discussions relating to claim valuation. Phone call with Paul Kloft RE: status of expert reports, claim valuation and proof of existence of loss. Review email from Mary Warinner regarding forklift pricing; Forward to Michele Barbara for inclusion in books. Status conference with Doug Bragg analyzing witness and expert witness discussions relating to claim valuation. Analyze and review 11 binders for scheduled and unscheduled equipment documentation. Telephone conversation with Paul Kloft regarding analysis of equipment documentation and verification of documentation of items claimed lost. 02 Fred Millard $350 02 $70.00 55 Michele Barbara $125 55 $687.50 3.1 Christopher Fanning $182 3.1 $564.20 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 20 Doug Bragg $280 20 $560.00 0.6 Doug Bragg $280 0.6 $168.00 02 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 02 $56.00 $28.00 $56.00 0.6 Doug Bragg $280 00 $0.00 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 0.6 Fred Millard $350 0.6 $210.00 38 Michele Barbara $125 38 $475.00 02 Michele Barbara $125 02 $25.00 Take notes from Doug Bragg's telephone conference with Jesse Peters RE: Precision Seed's seed inventory. Review notes from Doug Bragg's telephone conference with Jesse Peters and make final corrections. Take notes from Doug Bragg's telephone conference with Paula Mills RE: Precision Seed's seed inventory. Review notes from Doug Bragg's telephone conference with Paul Mills and make corrections and final. Assisting Michele Barbara and the client with Review, analyzing and correlating document for equipment. Review email from Robert Halsey regarding expert report on scheduled and unscheduled equipment. Review and analyze email from Walinga regarding possible valuation. 02 Tracey Poole $115 All - Clerical 00 $0.00 0.1 Tracey Poole $115 All - Clerical 00 $0.00 02 Tracey Poole $115 All - Clerical 00 $0.00 0.1 Tracey Poole $115 All - Clerical 00 $0.00 18 Christopher Fanning $182 All - Vague 00 $0.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Review and analyze email from Greg Mettler regarding Business Interruption loss. Email Greg Mettler regarding Business Interruption analysis. Review/respond to email from Greg Mettler regarding depreciation question. Phone call with Greg Mettler regarding seed inventory project. 02 Doug Bragg $280 02 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 03 Doug Bragg $280 03 $84.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 63 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 9/17/12 Review and analyze seed records with Paul Kloft and Michele Barbara to identify seed lots with 3rd party inventory verification. 1.6 Doug Bragg $280 1.6 $448.00 9/17/12 9/17/12 Email Greg Mettler list of seed lots with 3rd party verification. Review and analyze with Paul Kloft the Oregon Department of Agriculture's record keeping requirements, annotate Receiving and Cleaning Worksheets to show where certain information was kept. 02 03 Doug Bragg Doug Bragg $280 $280 02 03 $56.00 $84.00 9/17/12 Confer with Greg Mettler regarding seed lots with 3rd party verification of quantity and discuss annotation of cleaning/receiving worksheets. 02 Doug Bragg $280 02 $56.00 9/17/12 Matter conference with Fred Millard regarding status of expert reports to support damages. Email Nick Priest regarding expert report on tenant improvements. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Christopher Fanning analyzing inquiries to equipment suppliers and their responses. Phone call with Trevor Abbott regarding status of expert report on certain grass seed lots. Phone call with Mike Billman regarding status of expert report on flower seeds. Phone call to Craig Edminster regarding status of expert report; Left voicemail. Staff meeting analyzing experts and expert reports for damages. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 10 Fred Millard $350 10 $350.00 Telephone calls to seed experts regarding status of reports. Draft email to Poe RE: Insurable interest in Seed of Others. Review and analyze insurance policy requirements to prove insurable interest to recover Seed of Others. Prepare for and conduct meeting with Paul Kloft to analyze scheduled and unscheduled documentation, resolving questions and identify missing documentation. Email James Kloft with clarification questions on equipment documentation. Confer with Doug Bragg to forward Greg Mettler record keeping information from Paul Kloft. Following up with potential equipment valuation experts that I contacted for this claim. Meeting with Fred Millard, Doug Bragg and Michele Barbara analyzing expert reports. Confer with Michele Barbara regarding providing seed valuation experts the seed lot records broken down for use as exhibits. 10 0.4 1.4 Fred Millard Fred Millard Fred Millard $350 $350 $350 10 0.4 1.4 $350.00 $140.00 $490.00 8.1 Michele Barbara $125 8.1 $1,012.50 02 Michele Barbara $125 02 $25.00 0.1 Michele Barbara $125 0.1 $12.50 02 Christopher Fanning $182 02 $36.40 10 Christopher Fanning $182 10 $182.00 02 Doug Bragg $280 02 $56.00 9/18/12 Review and analyze memo from Michele Barbara regarding documentation issues for scheduled and unscheduled equipment. 02 Doug Bragg $280 02 $56.00 9/18/12 9/18/12 Email Mary at Toyota regarding possible valuation of forklifts. Phone call with Michael Rodrigue regarding actual cash value of business personal property. Phone call with Michael Billman analyzing his expert report on flower seeds. Meeting with Fred Millard, Christopher Fanning and Michele Barbara analyzing expert reports to value claim. Review and analyze binders of scheduled and unscheduled equipment documentation. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 0.6 Doug Bragg $280 0.6 $168.00 10 Doug Bragg $280 10 $280.00 0.6 Doug Bragg $280 0.6 $168.00 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/17/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 3:10-cv-01023-HZ ATTACHMENT 1 Page 64 of 161 Date Hrs Awarded Amount $280 05 $140.00 Doug Bragg $280 05 $140.00 0.1 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.1 0.1 $28.00 $28.00 $28.00 10 Fred Millard $350 10 $350.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 05 Michele Barbara $125 All - Clerical 00 $0.00 10 Michele Barbara $125 All - Duplicative; billed to Millard 00 $0.00 03 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 03 Doug Bragg $280 03 $84.00 0.1 10 Doug Bragg Doug Bragg $280 $280 0.1 10 $28.00 $280.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 9/19/12 9/19/12 Review and analyze latest draft of Trevor Abbott's report on certain grass seeds. Email Trevor Abbott final comments on report. Confer with Fred Millard analyzing status of expert reports on valuation. 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 9/19/12 Phone call to Trevor Abbott RE: valuation of certain grass seeds. 0.4 Doug Bragg $280 0.4 $112.00 9/19/12 9/19/12 Confer with Doug Bragg analyzing expert reports on valuation. Telephone call from James Kloft with Precision Seed that he believes we are working off first personal property lists. Send scheduled and unscheduled personal property lists to him for confirmation. 02 02 Fred Millard Michele Barbara $350 $125 02 02 $70.00 $25.00 0.1 Michele Barbara $125 00 $0.00 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/18/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Phone call with Michael Rodrigue analyzing his actual cash value analysis and report. Review and analyze Trevor Abbott's Expert report RE: certain grass seeds. Email comments on report to Trevor Abbott. Phone call to Trevor Abbott regarding expert report. Draft e-memo to Fred Millard analyzing insurable interest of Seed of Others question. Meeting with Doug Bragg, Christopher Fanning and Michele Barbara analyzing expert reports to value claim. Review e-memo from Doug Bragg regarding insurable interest of seed of others question. Confer with Doug Bragg to burn CD's for Mike Billman, Craig Edminster, and Trevor Abbott to review the documentation related to the Seed of Others' claim and Seed of Precision Seed prior to their depositions/trial testimony. Prepare CD's and letters to Mike Billman, Craig Edminster, and Trevor Abbott to review the documentation related to the Seed of Others' claim and Seed of Precision Seed prior to their depositions/trial testimony. Meet with Doug Bragg and Fred Millard to analyze Precision Seed's claim. Meeting with Doug Bragg and Michele Barbara analyzing status of expert reports on valuation, and issues relating to valuation of business personal property. Meeting with Christopher Fanning and Michele Barbara analyzing expert reports on valuation, and issues relating to valuation of business personal property. Review Trevor Abbott's second draft expert report. Review and analyze scheduled and unscheduled lists to verify that there is an expert Review each item. Phone call to Bekki Duty regarding valuation of pallets. Email Michael Rodrigue scheduled list highlighted to identify equipment we need him to value. Email Robert Halsey scheduled equipment list highlighted to confirm coverage of Bratney equipment. Email Nick Priest regarding status of expert report on tenant improvements. Phone call with Craig Edminster regarding status of his report on certain grass seeds. Review/respond to email from Nick Priest regarding asphalt issue. 05 Doug Bragg 05 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason 0.1 Duplicative; billed to Millard All - Duplicative; billed to Millard All - Clerical Page 65 of 161 Date Hrs Awarded Amount $125 02 $25.00 Michele Barbara $125 0.1 $12.50 0.1 02 Michele Barbara Michele Barbara $125 $125 00 00 $0.00 $0.00 Review and analyze unscheduled list and compare to draft reports from Michael Rodrigue and Robert Halsey. Email to Robert Halsey and Michael Rodrigue to confirm coverage of items. Emails to Robert Halsey and Michael Rodrigue with additional information for items as requested by Mr. Halsey. Review and analyze Robert Halsey's valuation letter and attachments. 0.4 Michele Barbara $125 0.4 $50.00 02 Michele Barbara $125 02 $25.00 03 Michele Barbara $125 03 $37.50 0.4 Michele Barbara $125 0.4 $50.00 Review, analyzing and indexing Earl Doman documents. Review and analyze Robert Halsey's report list and the scheduled and unscheduled equipment lists. Confer with Doug Bragg analyzing and verifying complete coverage on actual cash value estimates. Confer with Doug Bragg analyzing Robert Halsey's report. 0.7 55 Christopher Fanning Christopher Fanning $182 $182 0.7 55 $127.40 $1,001.00 0.1 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 03 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 02 0.1 Christopher Fanning Doug Bragg $182 $280 02 0.1 $36.40 $28.00 9/20/12 Confer with Doug Bragg analyzing Robert Halsey's spreadsheet. Review emails from Nick Priest updating on the status of his expert report on tenant improvements. Review report from Robert Halsey regarding valuation of equipment. 02 Doug Bragg $280 02 $56.00 9/20/12 Phone call with Michael Rodrigue regarding equipment valuation report. 0.1 Doug Bragg $280 0.1 $28.00 9/20/12 Review and analyze excel spreadsheet from Michael Rodrigue regarding his actual cash value estimates of business personal property. 02 Doug Bragg $280 02 $56.00 9/20/12 Phone call with Michael Rodrigue regarding actual cash value estimates and written report. Email Nick Priest regarding shower and bathroom fixtures. Confer with Fred Millard analyzing expert reports on business personal property. Compare and analyze final list and Rodrigue's list to verify complete coverage of Business Personal Property items. Email Michael Rodrigue regarding items missing from his spreadsheet. 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 0.7 Doug Bragg $280 0.7 $196.00 03 Doug Bragg $280 03 $84.00 0.4 02 05 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.4 02 05 $112.00 $56.00 $140.00 9/20/12 Phone call with Craig Edminster regarding his expert report. Phone call with Trevor Abbott regarding completed report. Confer with Michele Barbara analyzing latest business personal property documentation from Precision including possible unproduced document. Phone call with Robert Halsey regarding final clarifications on his report. 02 Doug Bragg $280 02 $56.00 9/20/12 Confer with Christopher Fanning analyzing Robert Halsey's report. 03 Doug Bragg $280 03 $84.00 9/20/12 9/20/12 Review annotated Scheduled Equipment list from James Kloft. Email supplemental discovery to Dan Thenell. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/19/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Telephone call from James Kloft with Precision Seed analyzing items on personal property list and to confirm that we are working off the correct lists. Confer with Doug Bragg to contact Robert Halsey for update on his expert letter. Voicemail to Robert Halsey RE: same. Confer with Doug Bragg to review and analyze reports of Robert Halsey and Michael Rodrigue to verify coverage of items on Unscheduled Equipment list marked up master unscheduled list. 02 Michele Barbara 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 66 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 03 $84.00 0.1 $28.00 0.1 Hrs Deducted by Court and Reason $28.00 0.1 0.1 $28.00 $28.00 9/20/12 Compare Scheduled Equipment List to Scheduled Equipment policy limits to verify maximum recovery on Scheduled Equipment. 03 Doug Bragg $280 9/20/12 Draft e-memo to Fred Millard analyzing valuation issues on Scheduled Equipment claim. Email John Poe about tenant improvements / building coverage question. Phone call with Greg Mettler regarding status of report. Confer with Fred Millard regarding status of expert reports. 02 Doug Bragg $280 0.1 Doug Bragg $280 0.1 02 Doug Bragg Doug Bragg $280 $280 Confer with Christopher Fanning regarding status of expansion of Robert Halsey's spreadsheet. Email Robert Halsey regarding spreadsheet revisions. Confer with Christopher Fanning analyzing verification of complete coverage on Actual Cash Value estimates. Confer with Doug Bragg analyzing expert reports on business personal property. Review e-memo from Doug Bragg analyzing valuation issues on Scheduled Equipment claim. Confer with Doug Bragg analyzing status of expert reports on valuation. 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Fred Millard $350 0.1 $35.00 02 Fred Millard $350 02 $70.00 0.1 0.1 60 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 0.1 0.1 60 $12.50 $12.50 $750.00 05 Michele Barbara $125 05 $62.50 05 Michele Barbara $125 00 $0.00 0.4 Christopher Fanning $182 0.4 $72.80 9/21/12 9/21/12 Receive email from Michael Rodrigue needing clarification. Telephone call to Michael Rodrigue RE: clarification. Preparing expert disclosures and underlying data for submittal to Country. Telephone conversations and e-mails with James Kloft RE: documentation supporting valuation of claim. Confer with Doug Bragg analyzing latest business personal property documentation from Precision including possible unproduced document (2 pages). Phone call with Robert Halsey attempting to clear up inconsistencies in his analysis. Revise spreadsheet based on conversation with Robert Halsey. Analyzing revisions to Robert Halsey's spreadsheet with Doug Bragg. 03 02 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Bragg 03 00 $54.60 $0.00 9/21/12 9/21/12 Revise spreadsheet for Robert Halsey. Confer with Doug Bragg analyzing Hoffman's offer to help. 08 0.1 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Bragg 08 00 $145.60 $0.00 9/21/12 0.6 Christopher Fanning $182 0.6 $109.20 0.4 Christopher Fanning $182 0.4 $72.80 9/21/12 Review and analyzing cases cited in Country Mutual's Response to our Motion for Summary Judgment. Pulling cases that were cited to discuss with Fred Millard. Review and analyzing expert report and draft email response to Mike Billet. Review/respond to emails from Nick Priest regarding expert report. 0.1 Doug Bragg $280 0.1 $28.00 9/21/12 9/21/12 Phone call with Michael Rodrigue analyzing his draft report. Confer with Christopher Fanning regarding Hoffman's offer to help. 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 9/21/12 Review and analyze Michael Rodrigue's expert report for any other clarifications or issues. Email Michael Rodrigue specific comments on his draft report. Review and analyze draft report from DJ Myers on Pallet valuation. 02 Doug Bragg $280 02 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 Email Bekki Duty regarding comments on DJ Myers' Pallet valuation report. 02 Doug Bragg $280 02 $56.00 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/20/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 3:10-cv-01023-HZ ATTACHMENT 1 0.1 Duplicative; billed to Millard 0.1 Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 67 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 02 Doug Bragg 02 0.6 9/21/12 Review and analyze draft report from Nick Priest on tenant improvements. Email Nick Priest requesting clarification on his report. Review and analyze Michael Billman's spreadsheet of lot values to verify completeness and accuracy of tallies. Email Mike Billman regarding clarification request to his spreadsheet. $280 02 $56.00 Doug Bragg Doug Bragg $280 $280 02 0.6 $56.00 $168.00 0.1 Doug Bragg $280 0.1 $28.00 9/21/12 Review email from Michael Rodrigue regarding status of expert report. 0.1 Doug Bragg $280 0.1 $28.00 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 Review email with draft report from Greg Mettler. Review and analyze draft report from Michael Rodrigue. Email comments to Michael Rodrigue regarding his report. Review and analyze draft report from DJ Myers. Email comments to Bekki Duty regarding draft report. Review and analyze draft report from Greg Mettler RE: Business Interruption and seed loss. Confer with Fred Millard analyzing draft report from Greg Mettler. 0.1 03 02 02 0.1 03 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 $280 0.1 03 02 02 0.1 03 $28.00 $84.00 $56.00 $56.00 $28.00 $84.00 02 Doug Bragg $280 00 $0.00 Review and analyze Country's response to Motion for Partial Summary Judgment. Phone call with James Kloft regarding Greg Mettler's report. Phone call with Paul Kloft regarding Mettler's report. Review/respond to email from Bekki Duty regarding status of revisions to letter. Review and analyze report from Robert Halsey. Review and analyze report from Craig Edminster. Confer with Christopher Fanning analyzing preparation of spreadsheet for Robert Halsey including quantities from Personal Property list. 03 Doug Bragg $280 03 $84.00 02 02 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 0.1 $56.00 $56.00 $28.00 03 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 02 02 $84.00 $56.00 $56.00 9/21/12 Email Greg Mettler, Mike Billman, Trevor Abbott, and Craig Edminster Country's seed valuation and inventory reports and request analysis. 0.1 Doug Bragg $280 0.1 $28.00 9/21/12 0.1 Doug Bragg $280 0.1 $28.00 9/21/12 9/21/12 9/21/12 Email Robert Halsey and Michael Rodrigue Country's equipment valuation report. Review signed report from Craig Edminster. Phone call with Paul Kloft regarding Greg Mettler's Report. Email Paul Kloft's comments to Greg Mettler regarding the report. 0.1 0.4 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.4 02 $28.00 $112.00 $56.00 9/21/12 9/21/12 9/21/12 Email Robert Halsey comments on schedule for report. Review and analyze draft report from Michael Rodrigue. Confer with Doug Bragg analyzing scheduled equipment valuation. 02 03 0.4 Doug Bragg Doug Bragg Fred Millard $280 $280 $350 02 03 0.4 $56.00 $84.00 $140.00 9/21/12 Confer with Doug Bragg analyzing draft report from Greg Mettler. 02 Fred Millard $350 02 $70.00 9/21/12 Review and analyze Country's response to Motion for Partial Summary Judgment. Receive and review Michael Rodrigue's expert report. Telephone conversation with Michael Rodrigue RE: expert report. 03 Fred Millard $350 03 $105.00 0.1 0.1 Michele Barbara Michele Barbara $125 $125 0.1 0.1 $12.50 $12.50 Prepare expert reports for disclosure. Receive and review Opposition and Declaration of Dan Thenell in Support of Motion for Summary Judgment. Telephone call to Craig Edminster for status of his report. Receive and review email from Craig Edminster with his final report. 20 02 Michele Barbara Michele Barbara $125 $125 20 02 $250.00 $25.00 0.1 0.1 Michele Barbara Michele Barbara $125 $125 00 0.1 $0.00 $12.50 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 9/21/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical Page 68 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Telephone call to Craig Edminster to sign his report and forward same to our office. Returning call to James Kloft to confirm that he will be providing additional documentation this afternoon related to item 121 on unscheduled documentation. Organized final documentation for Seed of Others, Precision's Seed and scheduled and unscheduled equipment; Complete preparation of expert reports and underlying documents for production. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 20 Michele Barbara $125 20 $250.00 0.6 Christopher Fanning $182 0.6 $109.20 39 Christopher Fanning $182 39 $709.80 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 9/24/12 Review and analyze expert reports to make sure everything was covered. Review and analyze Country's Response to our Motion for Summary Judgment and checking factual assertions that it makes in the response with supporting documents. Confer with Christopher Fanning analyzing comparing factual allegations in Response to Motion for Summary Judgment. Confer with Michele Barbara analyzing supporting documents for the Edminster report. Research co-insurance issue raised in Country's Response to Motion for Summary Judgment. Analyze coinsurance penalty and draft reply on coinsurance issue. 03 Doug Bragg $280 03 $84.00 9/24/12 9/24/12 9/24/12 9/24/12 Phone call to Michael Rodrigue regarding status of report. Phone call with Michael Rodrigue regarding report revisions. Review and analyze final expert reports for production. Confer with Fred Millard analyzing expert reports for production. 10 0.4 0.6 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 10 0.4 0.6 00 $280.00 $112.00 $168.00 $0.00 9/24/12 Compare and analyze Michael Rodrigue and Robert Halsey's lists to determine extent of possible overlap on valuation. Review CD's to send in support of expert reports. Draft letter to Dan Thenell to accompany expert reports. Review and analyze expert reports produced by Country Mutual Insurance Company. Review and analyze report from Billet Products. Phone call with Paul Kloft regarding Response to Motion for Summary Judgment. Confer with Fred Millard analyzing case status (expert discovery and Opposition Brief). Confer with Doug Bragg analyzing case status (expert discovery and Opposition brief). Review and analyze sections of Precision's expert disclosures and Country's Response to Precision's Motion for Summary Judgment (Damages and Prejudgment Interest). Organize, review and analyze to confirm which expert reports we have ready to go. Review and analyze Greg Mettler's CV and noticed that MLM is missing from his case list; Confer with Doug Bragg RE: Greg Mettler's CV; Voicemail and email to Greg Mettler RE: Greg Mettler's CV. 05 Doug Bragg $280 05 $140.00 02 02 0.6 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 0.6 $56.00 $56.00 $168.00 02 05 Doug Bragg Doug Bragg $280 $280 02 05 $56.00 $140.00 02 Doug Bragg $280 02 $56.00 02 Fred Millard $350 02 $70.00 09 Fred Millard $350 09 $315.00 10 Michele Barbara $125 10 $125.00 03 Michele Barbara $125 02 $25.00 Assist with preparation of documentation for expert reports for production to Country. Receive, review and forward emails to experts for Country's expert reports and request analysis. 23 Michele Barbara $125 23 $287.50 0.7 Michele Barbara $125 0.6 $75.00 9/21/12 9/21/12 9/21/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 9/24/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 All - Duplicative; billed to Millard 0.1 - Clerical 0.1 - Clerical Hrs Awarded Amount Page 69 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 9/24/12 Review, analyze and organize the expert reports Dan Thenell provided in his filing responding to our Summary Judgment Motion. 05 Michele Barbara $125 05 $62.50 9/25/12 Review and analyze Byron Slack's report, comparing with our expert reports, creating chart showing similarities and differences. 55 Christopher Fanning $182 55 $1,001.00 9/25/12 Confer with Michele Barbara and Christopher Fanning analyzing Country's expert reports and comparison of Country's analysis to Precision's. Phone call to Robert Halsey analyzing Byron Slack's report. Email Robert Halsey regarding rebuttal to Byron Slack's report. Phone call to Michael Rodrigue analyzing Byron Slack's report. Review and analyze Katharyn Thompson's report. Research caselaw cited by Country to oppose prejudgment interest. 0.6 Doug Bragg $280 0.6 $168.00 02 02 02 08 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 02 02 02 08 0.1 $56.00 $56.00 $56.00 $224.00 $28.00 Confer with Fred Millard analyzing expert reports from Country and possible issues for rebuttal reports. Review and analyze Byron Slack's expert report with Fred Millard, and discuss source of "building is too small" claim by Dan Thenell. 0.6 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 9/25/12 Phone call with Michael Rodrigue analyzing Byron Slack's report. 0.6 Doug Bragg $280 0.6 $168.00 9/25/12 Phone call with Craig Edminster analyzing Katharyn Thompson's report on seed valuation. Phone call with Mike Billman analyzing possible response to Katharyn Thompson's Expert report. Phone call to Trevor Abbott analyzing possible response to Katharyn Thompson's report. Email Trevor Abbott, Mike Billman and Craig Edminster analyzing Katharyn Thompson's report. Email Greg Mettler analyzing Katharyn Thompson's report. Matter conference with Fred Millard analyzing and developing trial strategy. Review and analyze Byron Slack's expert report with Doug Bragg, and discuss source of "building is too small" claim by Dan Thenell. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 0.1 1.4 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 1.1 Fred Millard $350 1.1 $385.00 Confer with Doug Bragg analyzing expert reports from Country and possible issues for rebuttal reports. Matter conference with Doug Bragg analyzing and developing trial strategy. Telephone call with Lynn Davis RE: Rebuttal disclosure to Byron Slack's report. Review and analyze Country's Expert Disclosure Reports. Confer with Doug Bragg and Chris Fanning to analyze expert reports received from Country. Review and analyze Country's production documents (945 pages) for any enclosures mentioned in David Logan's report. Confer with Doug Bragg analyzing limited production of Dave Logan's file by Country. Confer with Doug Bragg to analyze seed valuations by Katharyn Thompson, Stanley Miles and our experts. Begin preparing spreadsheet analyzing and comparing seed values. 0.6 Fred Millard $350 0.6 $210.00 1.4 Fred Millard $350 1.4 $490.00 0.6 Fred Millard $350 0.6 $210.00 0.6 0.7 Fred Millard Michele Barbara $350 $125 0.6 0.1 $210.00 $12.50 0.6 Michele Barbara $125 0.6 $75.00 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 02 $25.00 02 Michele Barbara $125 02 $25.00 Confer with Doug Bragg to analyze billing of Byron Slack and David Logan, and forward to Michael Rodrigue for his review. 02 Michele Barbara $125 02 $25.00 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 9/25/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard 0.6 Duplicative; billed to Bragg Page 70 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 00 $56.00 $28.00 $0.00 03 10 Doug Bragg Doug Bragg $280 $280 03 10 $84.00 $280.00 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 0.7 $196.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 15 Doug Bragg $280 15 $420.00 Confer with Michele Barbara analyzing review of Katharyn Thompson's Seed Valuation to Precision's Claim. Review and analyze documentation relating to eleven seed lots found by Katharyn Thompson to be valueless. Matter conference with Fred Millard analyzing Country's expert disclosures. Confer with Fred Millard analyzing Reply to Opposition to Summary Judgment Motion. Confer with Christopher Fanning analyzing reply to objections to Summary Judgment. Phone call with Don Kelley regarding bank's Request for Expert Disclosures. Continue review and analysis of Country expert disclosures. Matter conference with Doug Bragg analyzing Country expert disclosures. Confer with Doug Bragg analyzing Joint ADR Report. Confer with Doug Bragg analyzing Reply to Opposition to Summary Judgment Motion. Continue working on analyzing and comparing seed values of Katharyn Thompson, Stanley Miles and Precision's experts. Revise Joint ADR Report to add signature line for Dan Thenell. File Joint ADR Report with the court. Continue working on Review and analyzing Katharyn Thompson's seed values to identify agreement. Telephone call from James Kloft to discuss Seimens' Motor Control System found in Byron Slack's report. Correcting issues with spreadsheet comparing actual cash value and replacement cash value of equipment per request of Doug Bragg. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 10 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 03 $84.00 0.4 Doug Bragg $280 0.4 $112.00 15 0.6 Fred Millard Fred Millard $350 $350 15 0.6 $525.00 $210.00 02 10 Fred Millard Fred Millard $350 $350 02 10 $70.00 $350.00 15 Michele Barbara $125 15 $187.50 0.1 0.1 10 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 00 00 10 $0.00 $0.00 $125.00 02 Michele Barbara $125 02 $25.00 13 Michele Barbara $125 13 $162.50 9/26/12 Compile and prepare hearing folder for Summary Judgment Hearing. 05 Michele Barbara $125 All - Clerical 00 $0.00 9/26/12 9/27/12 Review docket report for Hearing preparation. Conduct research analyzing the scope of an expert's ability to testify. 0.1 1.4 Michele Barbara Christopher Fanning $125 $182 All - Clerical 00 1.4 $0.00 $254.80 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 9/26/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review/respond to email from Michelle Rawson regarding joint ADR report. Draft Joint ADR Report. Email draft Joint ADR Report to Dan Thenell. Confer with Fred Millard analyzing Joint ADR Report. 02 Doug Bragg 02 0.1 02 Phone call with Paul Kloft analyzing Country's expert reports. Review and analyze comparison spreadsheets of business personal property items prepared by Christopher Fanning to determine any "agreed" issues. Phone call with James Kloft analyzing Byron Slack and Katharyn Thompson's expert reports. Phone call with Mike Billman analyzing Dave Logan's report and possible responses to seed valuation. Review and analyze Katharyn Thompson's report for possible agreement on value of seed lots. Confer with Christopher Fanning analyzing status of response to facts in Opposition to Partial Summary Judgment. Draft Reply to Opposition to Motion for Partial Summary Judgment. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Clerical Page 71 of 161 Date Hrs Awarded Amount $182 2.4 $436.80 Christopher Fanning $182 10 $182.00 08 02 Doug Bragg Doug Bragg $280 $280 08 02 $224.00 $56.00 02 Doug Bragg $280 02 $56.00 19 Doug Bragg $280 19 $532.00 Confer with Fred Millard analyzing issues with Dan Thenell's incorrect reporting of Katharyn Thompson's report in his brief. Prepare list of agreed seed lots for reply to Opposition to Summary Judgment. Confer with Christopher Fanning analyzing challenge to Katharyn Thompson's ability to testify as an expert outside her scope. 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 9/27/12 Email Greg Mettler regarding scope of Forensic Accountant's expertise. 0.1 Doug Bragg $280 0.1 $28.00 9/27/12 Confer with Christopher Fanning analyzing research on scope of forensic accountants. Draft reply to opposition regarding prejudgment interest. Confer with Fred Millard analyzing Reply Brief and agreed seed lots. 02 Doug Bragg $280 02 $56.00 1.6 03 Doug Bragg Doug Bragg $280 $280 1.6 00 $448.00 $0.00 Confer with Doug Bragg analyzing issues with Dan Thenell's reporting of Katharyn Thompson's report in his brief. Confer with Doug Bragg analyzing Reply Brief and agreed seed lots. 02 Fred Millard $350 02 $70.00 03 Fred Millard $350 03 $105.00 9/27/12 Review seed records and exhibits for Paul Kloft's Declaration in response to the 13 lots Katharyn Thompson says she has no documentation. 20 Michele Barbara $125 20 $250.00 9/27/12 Continue Review and analyzing Katharyn Thompson's report to clarify values. Confer with Doug Bragg to analyze Katharyn Thompson's various opinions on seed valuation. Prepare table for values of lots we agree with Katharyn Thompson for Response to Motion for Summary Judgment. Reviewed Brief from Dan Thenell in response to our Motion for Summary Judgment and made notes of specific factual errors to point out in Reply Brief. Research case law and analyze related to scope of expert testimony. 08 Michele Barbara $125 08 $100.00 02 Michele Barbara $125 00 $0.00 10 Michele Barbara $125 10 $125.00 08 Christopher Fanning $182 08 $145.60 0.4 Christopher Fanning $182 0.4 $72.80 Revise Doug Bragg's draft of Reply Brief; Reorganize, draft new sections and outline arguments to be made. Confer with Michele Barbara analyzing summary of agreed seed lots. 4.7 Christopher Fanning $182 4.7 $855.40 02 Doug Bragg $280 02 $56.00 Confer with Christopher Fanning analyzing research on admissibility of expert witnesses parotting other expert witnesses. 02 Doug Bragg $280 02 $56.00 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/27/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze Dan Thenell's response to our Motion for Summary Judgment for factual errors. Comparing and analyzing Precision's replacement cost valuation with Country's replacement cost valuation, Precision's actual cash value and Country's actual cash value for scheduled and unscheduled equipment, and prepared new charts for our reply on the Motion for Summary Judgment. Draft Reply to Opposition to Motion for Summary Judgment. Confer with Christopher Fanning regarding close review of Opposition Brief with supporting documents to verify facts. Confer with Michele Barbara analyzing Katharyn Thompson's seed values. Review and analyze Katharyn Thompson's report to determine seed values as compared with Precision's and Precision's experts. 2.4 Christopher Fanning 10 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 72 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review and analyze caselaw interpreting FRE 702 with regards to experts relying upon other experts. Confer with Christopher Fanning analyzing comparison of Country's brief to expert reports relating to accuracy of reporting, confer regarding organization for Reply Brief, confer analyzing scope of objections to expert witnesses (Byron Slack and Katharyn Thompson). 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 Review and analyze David Logan's report as submitted by Country in Support of its Opposition to Plaintiff's Motion for Partial Summary Judgment. Review and analyze draft declaration for Paul Kloft in support of Reply to Opposition. Phone call to Kevin Loe, left message. Confer with Fred Millard analyzing research on expert testimony relayed through experts and possibility of resolving all seed claims. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 9/28/12 Meeting with Fred Millard and Hertzel Shadian analyzing potential issues relating to non-reporting of inventory on tax forms. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 9/28/12 Email Greg Mettler regarding significance of non-reporting of inventory on tax returns. Confer with Christopher Fanning analyzing Katharyn Thompson's reliance upon other experts under FRE 702. Research assertion of "work product" doctrine in insurance claims. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 Phone call with Paul Kloft analyzing Country's expert reports and schedule office meeting to review their comments. Confer with Fred Millard regarding conversation with Paul Kloft on expert reports. Review and analyze rough draft of Reply to Opposition to Motion for Partial Summary Judgment. Confer with Doug Bragg analyzing research on expert testimony relayed through experts and possibility of resolving all seed claims. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 00 $0.00 0.4 Doug Bragg $280 0.4 $112.00 02 Fred Millard $350 02 $70.00 9/28/12 Meeting with Doug Bragg and Hertzel Shadian analyzing potential issues relating to non-reporting of inventory on tax forms. 02 Fred Millard $350 02 $70.00 9/28/12 9/28/12 Finish table with seed lots we agree with Katharyn Thompson. Confer with Doug Bragg analyzing agreed table with seed lots. 0.6 0.1 Michele Barbara Michele Barbara $125 $125 0.6 00 $75.00 $0.00 9/28/12 Review chart to confirm that the lots Katharyn Thompson gives no opinion of values are in lots we agree on value. Prepare Declaration for Paul Kloft with 13 lots of seed explanation that Katharyn Thompson does not show any documents. 03 Michele Barbara $125 03 $37.50 05 Michele Barbara $125 05 $62.50 9/28/12 9/28/12 Confirm and prepare exhibits for Judge and number same. Review and analyze Country's discovery documents for potential exhibits for Reply on Motion for Partial Summary Judgment (945 pages). 08 0.6 Michele Barbara Michele Barbara $125 $125 08 0.6 $100.00 $75.00 9/30/12 Review and analyze draft Reply to Response to Motion for Summary Judgment. Revise Reply on Motion for Summary Judgment and continuing to draft. 05 Doug Bragg $280 05 $140.00 0.7 Christopher Fanning $182 0.7 $127.40 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 9/28/12 10/1/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 73 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 4.1 Hrs Deducted by Court and Reason $746.20 03 $84.00 10/1/12 Prepare for and conduct meeting with Client to analyze expert reports and issues for Reply on our Motion for Summary Judgment. 4.1 Christopher Fanning $182 10/1/12 Prepare for and conduct meeting with Paul Kloft and Christopher Fanning analyzing issues with Country's Expert Reports. 58 Doug Bragg $280 10/1/12 Phone call with Michael Rodrigue and Paul Kloft analyzing Byron Slack's methodology and Paul Kloft's observations of Byron Slack's approach to examining the loss. Review and analyze comments from John Poe regarding Katharyn Thompson's report. Prepare for and conduct matter conference with Paul Kloft Review Country's expert reports, photographs, etc. Review e-memo from John Poe RE: Business Interruption analysis and Katharyn Thompson's report. Confer with Doug Bragg analyzing Reply Brief. 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 55 Fred Millard $350 55 $1,925.00 03 Fred Millard $350 03 $105.00 02 Christopher Fanning $182 00 $0.00 55 02 Christopher Fanning Doug Bragg $182 $280 55 02 $1,001.00 $56.00 10/2/12 Continue draft Reply for Summary Judgment Motion. Review and analyze additional comments from John Poe regarding Katharyn Thompson's report. Phone call with Paul Kloft regarding possible rebuttal expert Don Herb. 02 Doug Bragg $280 02 $56.00 10/2/12 Review/respond to email from court regarding judge's copies of filings. 02 Doug Bragg $280 02 $56.00 10/2/12 10/2/12 Confer with Christopher Fanning analyzing Reply Brief. Telephone call and email from James Kloft with pictures of air compressor that was not damaged in the fire. Prepare documents for Motion for Summary Judgment to send to court for bench copy. Prepare exhibits for Reply to Response to Summary Judgment. Continue preparing exhibits to file with Reply to Motion for Summary Judgment. Analyze and compare various charts from Katharyn Thompson's report. 02 02 Doug Bragg Michele Barbara $280 $125 02 02 $56.00 $25.00 10 Michele Barbara $125 00 $0.00 10 05 Michele Barbara Michele Barbara $125 $125 10 05 $125.00 $62.50 1.1 Christopher Fanning $182 1.1 $200.20 4.1 08 Christopher Fanning Christopher Fanning $182 $182 4.1 08 $746.20 $145.60 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 10/3/12 Revise Reply in Support of Motion for Summary Judgment. Review and analyze Reply Brief and making notes of the citations that need to be filled in and or changed. Phone call to Kevin Loe; Emailed Kevin Loe asking if he is an expert for Country, and if not if he will talk with me. Phone call with Don Herb regarding possible rebuttal testimony against Katharyn Thompson. Email Don Herb regarding rebuttal report to Katharyn Thompson. 02 Doug Bragg $280 02 $56.00 10/3/12 Phone call with Greg Mettler analyzing Katharyn Thompson's report. 0.4 Doug Bragg $280 0.4 $112.00 10/3/12 2.7 Doug Bragg $280 2.7 $756.00 10/3/12 Prepare for and conduct meeting with Paul Kloft to analyze Katharyn Thompson and David Logan's expert reports. Review and analyze draft rebuttal report from Michael Rodrigue. 03 Doug Bragg $280 03 $84.00 10/3/12 Review Katharyn Thompson's report regarding seed testing results. 02 Doug Bragg $280 02 $56.00 10/3/12 Review/Revise draft Reply to Opposition to Motion for Summary Judgment. Confer with Christopher Fanning analyzing revisions to Paul Kloft's declaration and additional revisions to Reply Brief. 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 10/1/12 10/1/12 10/1/12 10/2/12 10/2/12 10/2/12 10/2/12 10/2/12 10/2/12 10/3/12 10/3/12 10/3/12 10/3/12 10/3/12 10/3/12 3:10-cv-01023-HZ ATTACHMENT 1 5.5 Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Clerical Page 74 of 161 Date Hrs Req Pltf Lawyer Rate Revise draft Reply Brief. Revise draft Reply - revise Reply as to admissibility of Katharyn Thompson and Byron Slack reports. Prepare Exhibits for Reply. Continue to draft/revise Reply. Revise draft Reply analyzing business personal property dispute. 03 38 Doug Bragg Doug Bragg $280 $280 08 48 05 Heidi Gross Christopher Fanning Doug Bragg $50 $182 $280 10 Doug Bragg $280 03 02 03 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 15 Doug Bragg $280 02 Doug Bragg $280 1.1 Fred Millard 10/4/12 Revise draft Reply - clean up and correct citations, create table of authorities and table of contents. Confer with Christopher Fanning analyzing revisions to Reply. Email draft Reply to client to review. Review/revise draft Reply as it pertains to Business Personal Property claim. Revise draft Reply to reorganize document to make it clearer and more concise, per conversation with Fred Millard. Confer with Fred Millard analyzing organization and approach to Reply Brief. Review and analyze draft of Memorandum in Reply to Defendant's Opposition to Plaintiff's Motion for Partial Summary Judgment, adding annotations and edits. Confer with Doug Bragg analyzing Reply to Summary Judgment Motion. 02 10/4/12 Telephone call and email from James Kloft RE: set up of screens. 10/4/12 10/3/12 10/3/12 10/3/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/4/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/5/12 10/8/12 3:10-cv-01023-HZ Hrs Awarded Amount 03 38 $84.00 $1,064.00 00 48 05 $0.00 $873.60 $140.00 10 $280.00 03 00 03 $84.00 $0.00 $84.00 15 $420.00 00 $0.00 $350 1.1 $385.00 Fred Millard $350 02 $70.00 0.1 Michele Barbara $125 0.1 $12.50 Prepare exhibits for Reply to Opposition to Motion for Summary Judgment. Prepare draft of Supplemental Declaration of Douglas M. Bragg in support thereof. Telephone call from James Kloft RE: screens. File Response to Motion for Partial Summary Judgment with Court. 15 Michele Barbara $125 15 $187.50 05 Michele Barbara $125 05 $62.50 0.1 05 Michele Barbara Michele Barbara $125 $125 0.1 00 $12.50 $0.00 Continue preparing hearing binder for Motion for Partial Summary Judgment. Confer with Doug Bragg analyzing comments from Paul Kloft regarding draft Reply. Confer with Michele Barbara to prepare marked version of Byron Slack's report to indicate areas of agreement. Review and analyze draft Reply with Christopher Fanning's changes. 10 Michele Barbara $125 10 $125.00 02 Christopher Fanning $182 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 1.1 Doug Bragg $280 1.1 $308.00 Revise conclusion to Reply Brief. Final review and revisions of Reply Brief, complete table of contents and table of authorities. Revise draft Reply to reorganize document to make it clearer and more concise. Confer with Christopher Fanning analyzing comments from Paul Kloft regarding draft Reply. Review/revise my draft Supplemental Declaration. Confer with Fred Millard analyzing revisions to Reply Brief. 03 05 Doug Bragg Doug Bragg $280 $280 03 05 $84.00 $140.00 0.7 Doug Bragg $280 0.7 $196.00 02 Doug Bragg $280 02 $56.00 02 0.6 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 Research unfair claims settlement practices law and draft brief statement regarding same to insert into Reply Brief. Confer with Doug Bragg analyzing revisions to Reply Brief. Compile, organize and prepare exhibits for Reply. Finalizing Reply Brief. Checking citations, entering changes per Doug Bragg and Fred Millard, final run-through of changes. 02 Doug Bragg $280 02 $56.00 0.6 0.4 5.6 Fred Millard Heidi Gross Christopher Fanning $350 $50 $182 0.6 00 5.6 $210.00 $0.00 $1,019.20 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Clerical All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Clerical Page 75 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Prepare list of questions for experts from meeting with Client from last week. Confer with Fred Millard analyzing rebuttal expert opinions. 0.4 Christopher Fanning $182 0.4 $72.80 02 Doug Bragg $280 00 $0.00 0.1 02 10 0.4 Doug Bragg Fred Millard Michele Barbara Doug Bragg 02 10/9/12 Phone call to Michael Rodrigue regarding rebuttal report. Confer with Doug Bragg analyzing rebuttal expert opinions. Prepare Hearing binder for Motion for Summary Judgment. Phone call with Trevor Abbott analyzing scope of rebuttal report on seed valuation. Phone calls to Craig Edminster and Mike Billman regarding rebuttal reports on seed valuation. Left voicemails. Phone call with Don Herb to confirm receipt of documents to review for rebuttal expert report. Review and analyze revised rebuttal report from Michael Rodrigue. $280 $350 $125 $280 0.1 02 10 0.4 $28.00 $70.00 $125.00 $112.00 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.4 Doug Bragg $280 0.4 $112.00 10/9/12 10/11/12 Phone call with Mike Billman regarding rebuttal expert report. Review email from Trevor Abbot with 2009 standards from OSU. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 10/11/12 10/11/12 Phone call with Paul Kloft regarding discovery issues. Confer with Michele Barbara regarding Request for Depositions by Country. Telephone call from Joan Brown with Dan Thenell's office to schedule depositions. Confer with Doug Bragg and Fred Millard RE: scheduling depositions. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 10/12/12 10/12/12 10/12/12 Confer with Michele Barbara regarding status of expert rebuttal reports from Michael Billman and Craig Edminster. Draft example opening paragraph for rebuttal expert reports. Confer with Michele Barbara analyzing deposition schedule. Confer with Fred Millard analyzing deposition schedule. 0.1 03 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 03 00 $28.00 $84.00 $0.00 10/12/12 10/12/12 Direct Michele Barbara to coordinate deposition schedule. Confer with Michele Barbara analyzing scheduling of depositions. 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 10/12/12 Review and analyze Scotts Contract documents referenced by Country and compare with seed test results for four lots of Seashore Paspalum. 05 Doug Bragg $280 05 $140.00 10/12/12 Review and analyze expert reports regarding Seashore Paspallum valuation. Confer with Doug Bragg analyzing deposition schedule. Confer with Doug Bragg to contact experts RE: status of rebuttal reports. 03 Doug Bragg $280 03 $84.00 02 02 Fred Millard Michele Barbara $350 $125 All - Duplicative; billed to Bragg 02 00 $70.00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 0.1 $12.50 0.1 03 Michele Barbara Michele Barbara $125 $125 0.1 03 $12.50 $37.50 10/12/12 Telephone calls to Mike Billman and Craig Edminster RE: rebuttal expert reports. Email to Doug Bragg RE: status of Mike Billman's and Craig Edminster's reports. Email from Mike Billman on starting point questioning approach to rebuttal reports. Confer with Doug Bragg RE: Mike Billman's inquiry. Prepare email to Mike Billman, Craig Edminster and Trevor Abbott with the highlighted version of Katharyn Thompson's report for their review in preparing their reports. Confer with Doug Bragg RE: deposition scheduling. 03 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 10/12/12 Telephone conversation with Joan Brown on depositions. 0.1 Michele Barbara $125 All - Clerical 00 10/8/12 10/8/12 10/8/12 10/8/12 10/8/12 10/9/12 10/9/12 10/9/12 10/11/12 10/11/12 10/12/12 10/12/12 10/12/12 10/12/12 10/12/12 10/12/12 10/12/12 10/12/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard $0.00 Page 76 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Email to Joan Brown at Dan Thenell's office proposing depositions and dates. Telephone call to Kim Ellingson to run deposition date by her - no Fridays! Confer with Doug Bragg RE: deposition scheduling of Kim Ellingson. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 10/15/12 Telephone call to Joan Brown with Dan Thenell's office to notify her that Kim Ellingson cannot do November 2nd or any Fridays as proposed in our email. Confer with Fred Millard analyzing gaps in expert discovery. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 10/15/12 Research and analyze use of rebuttal expert reports in case in chief. 0.4 Doug Bragg $280 0.4 $112.00 10/15/12 Phone call with Trevor Abbott regarding supplemental report on Seashore Paspallum. Direct Christopher Fanning to scan and email testing results for Seashore Paspallum lots, along with testing standard, to Trevor Abbott. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 10/15/12 Phone call with Paul Kloft regarding cleaning of Seashore Paspallum. 02 Doug Bragg $280 02 $56.00 10/15/12 10/15/12 Confer with Doug Bragg analyzing gaps in expert discovery. Review and analyze seed expert reports RE: potential gaps in coverage. 02 0.4 Fred Millard Michele Barbara $350 $125 02 0.4 $70.00 $50.00 10/15/12 Review and analyze Katharyn Thompson's report to see what lots she agreed with and compare to missing lots from experts. Confer with Doug Bragg analyzing lots missed and Katharyn Thompson shows "no value". Review and analyze emails sent to seed experts RE: distribution and coverage of claim. Review and analyze seed lots and comparing to our expert reports to make sure everything is covered. Prepare documents to send to Steve Gunsolley; Draft letter to accompany the documents RE: materials which would survive the fire. 03 Michele Barbara $125 03 $37.50 02 Michele Barbara $125 02 $25.00 03 Michele Barbara $125 03 $37.50 23 Christopher Fanning $182 23 $418.60 1.6 Christopher Fanning $182 1.6 $291.20 Phone call to Paul Kloft regarding seed valuation issues. Phone call with Steve Gunsolley regarding rebuttal report on Byron Slack's "DNV" Items. Confer with Fred Millard analyzing rebuttal expert report issues. 0.4 05 Doug Bragg Doug Bragg $280 $280 0.4 05 $112.00 $140.00 02 Doug Bragg $280 00 $0.00 Begin compiling information to send to Steve Gunsolley. Confer with Christopher Fanning analyzing compilation of material to send to Steve Gunsolley. Review and analyze seed lot lists to confirm coverage for all seed lots by experts. Phone call to Robert Halsey regarding rebuttal report. Left voicemail. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 02 0.4 Doug Bragg Doug Bragg $280 $280 02 0.4 $56.00 $112.00 10/16/12 Phone call with Craig Edminster regarding rebuttal report. Phone call with Mike Billman analyzing issues for rebuttal report and possible supplemental report. Phone call to Trevor Abbott regarding rebuttal report; left voicemail. 0.1 Doug Bragg $280 0.1 $28.00 10/16/12 Confer with Christopher Fanning analyzing package to Steve Gunsolley. 0.1 Doug Bragg $280 0.1 $28.00 10/16/12 Review Seed Research seed documents. 02 Doug Bragg $280 02 $56.00 10/12/12 10/12/12 10/12/12 10/12/12 10/15/12 10/15/12 10/15/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 10/16/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 All - Duplicative; billed to Millard Hrs Awarded Amount Page 77 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Email Craig Edminster regarding rebuttal report and supplement for certain lots. Email Trevor Abbott regarding supplemental and rebuttal reports. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 10/16/12 10/16/12 10/16/12 10/16/12 Review, analyze and respond to email from Mike Billman regarding rebuttal report. Email Robert Halsey regarding status of rebuttal report. Email Greg Mettler regarding rebuttal report. Phone call to Michael Rodrigue regarding rebuttal report. Review/revise draft letter to Steve Gunsolley regarding rebuttal report. 02 Doug Bragg $280 02 $56.00 0.1 0.1 02 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 0.1 0.1 02 02 $28.00 $28.00 $56.00 $56.00 10/16/12 Phone call with Michael Rodrigue regarding status of rebuttal report. 02 Doug Bragg $280 02 $56.00 10/16/12 Confer with Fred Millard analyzing issues in valuing vegetable seeds. 02 Doug Bragg $280 00 $0.00 10/16/12 Confer with Doug Bragg analyzing issues with rebuttal expert reports. 02 Fred Millard $350 02 $70.00 10/16/12 Confer with Doug Bragg analyzing issues in valuing vegetable seeds. 02 Fred Millard $350 02 $70.00 10/17/12 0.1 Doug Bragg $280 0.1 $28.00 10/17/12 Review Notice from Court regarding evidentiary objections relating to Motion for Partial Summary Judgment. Confer with Fred Millard analyzing Robert Halsey's Rebuttal Report. 02 Doug Bragg $280 00 $0.00 10/17/12 Review and analyze second draft report from Michael Rodrigue. 02 Doug Bragg $280 02 $56.00 10/17/12 Email Michael Rodrigue additional comments on Rebuttal Report. 0.1 Doug Bragg $280 0.1 $28.00 10/17/12 Review, analyze and respond to email from Mike Billman analyzing documentation for seed lot M146-5-546. Phone call with James Kloft analyzing issue on M146-5-546. Second phone call with James Kloft analyzing issue on M146-5-546. 03 Doug Bragg $280 03 $84.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 Phone call with Mike Billman analyzing issue on M146-5-546. Phone call with Michael Rodrigue analyzing rebuttal to Byron Slack's report. Phone call with Robert Halsey regarding status of his Rebuttal Report. 0.1 0.6 Doug Bragg Doug Bragg $280 $280 0.1 0.6 $28.00 $168.00 0.1 Doug Bragg $280 0.1 $28.00 23 Fred Millard $350 23 $805.00 10/17/12 Review and analyze law in preparation to preparing outline for Expert testimony at trial. Confer with Doug Bragg analyzing Robert Halsey's Rebuttal Report. 02 Fred Millard $350 02 $70.00 10/18/12 Review and analyze latest draft Rebuttal Report from Michael Rodrigue. 05 Doug Bragg $280 05 $140.00 10/18/12 Email Michael Rodrigue analyzing comments for Rebuttal Report. 0.1 Doug Bragg $280 0.1 $28.00 10/18/12 Review email from Michael Rodrigue regarding draft Rebuttal Report. 0.1 Doug Bragg $280 0.1 $28.00 10/18/12 Phone call with Michael Rodrigue analyzing draft Rebuttal Report. 02 Doug Bragg $280 02 $56.00 10/19/12 10/19/12 10/19/12 Review final Rebuttal Report from Michael Rodrigue. Review draft Rebuttal Report from Mike Billman. Review and analyze comments from Robert Halsey on Byron Slack's Report. 02 02 05 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 05 $56.00 $56.00 $140.00 10/16/12 10/16/12 10/16/12 10/17/12 10/17/12 10/17/12 10/17/12 10/17/12 10/17/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 78 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 10/19/12 Email Robert Halsey regarding comments and creation of letter from compilation of the comments to submit as his Rebuttal Report. 03 Doug Bragg $280 03 $84.00 10/19/12 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 10/19/12 Email Michael Billman's Rebuttal Report to Trevor Abbott for use as a possible template. Phone call to Paul Kloft regarding status of Rebuttal Report, left voicemail. Review and analyze opposition to objections to evidence filed by Country. Draft e-memo to Fred Millard regarding status of Rebuttal Reports. 0.1 Doug Bragg $280 00 $0.00 10/19/12 Phone call with Mike Billman analyzing finalizing Rebuttal Report. 02 Doug Bragg $280 02 $56.00 10/19/12 10/19/12 Phone call with Trevor Abbott analyzing his Rebuttal Report. Called Craig Edminster regarding Rebuttal Report, left voicemail. 0.4 0.1 Doug Bragg Doug Bragg $280 $280 0.4 0.1 $112.00 $28.00 10/19/12 Phone call to Don Herb regarding Rebuttal Report, left voicemail. 0.1 Doug Bragg $280 0.1 $28.00 10/19/12 0.1 Doug Bragg $280 0.1 $28.00 10/19/12 Phone call to Greg Mettler regarding status of Rebuttal Report, left voicemail. Draft e-memo to Fred Millard regarding status of Rebuttal Reports. 0.1 Doug Bragg $280 00 $0.00 10/19/12 Review e-memo from Doug Bragg regarding status of Rebuttal Reports. 0.1 Fred Millard $350 0.1 $35.00 10/22/12 Researching whether the defense can rely on information that isn't on the record at Summary Judgment and drafted e-mail to Doug Bragg summarizing research to evidentiary objections. Review and analyze Country's response to objections to evidence and checking the citations for accuracy. Draft short e-mail to Doug Bragg analyzing Country's response to objections to evidence. Phone call with Steve Gunsolley analyzing what materials would survive the fire. Draft declaration for Steve Gunsolley regarding Byron Slack's methodology. Confer with Christopher Fanning analyzing research on the record for Summary Judgment. Review additional comments from Robert Halsey analyzing Byron Slack's report. Phone call to Robert Halsey regarding final comments on Byron Slack's report. Review and analyze email from Dan Thenell's office regarding proposed deposition schedule. Confer with Fred Millard analyzing proposed deposition schedule. 0.7 Christopher Fanning $182 0.7 $127.40 2.1 Christopher Fanning $182 2.1 $382.20 0.1 Christopher Fanning $182 00 $0.00 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Email Dan Thenell regarding deposition schedule. Review and analyze amended response to interrogatories from Country Mutual Insurance Company. Research and analyze conditions for a perpetuation deposition. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 05 Doug Bragg $280 05 $140.00 Phone call with Trevor Abbott regarding draft report and 2009 OSU book. Review draft rebuttal report from Trevor Abbott. Phone call with Trevor Abbott regarding draft rebuttal report. 0.1 Doug Bragg $280 0.1 $28.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 10/19/12 10/19/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 79 of 161 Date Hrs Awarded Amount $280 0.1 $28.00 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 10/22/12 Phone call to Greg Mettler regarding Rebuttal Report; not available. Emailed Greg Mettler regarding Rebuttal Report. Met with Paul Kloft to review and comment on his rebuttal report. 03 Doug Bragg $280 03 $84.00 10/22/12 10/22/12 10/22/12 Phone call with Don Herb regarding possible Rebuttal Report. Phone call with Greg Mettler analyzing Rebuttal Report. Phone call to Dan Thenell regarding deposition schedule; Left voicemail. 0.4 02 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.4 02 0.1 $112.00 $56.00 $28.00 10/22/12 Review and analyze Country's Responses to Objections to Evidence. 05 Doug Bragg $280 05 $140.00 10/22/12 Confer with Doug Bragg analyzing proposed deposition schedule. 02 Fred Millard $350 02 $70.00 10/22/12 E-mails with Joan Brown and conversation with Doug Bragg on scheduling depositions. Telephone call to James Kloft to schedule his deposition. Telephone call to Craig Edminster to schedule his deposition. Telephone call to Kim Ellingsen to schedule her deposition. Telephone call to Michael Rodrigue to schedule his deposition. Review and analyze final rebuttal report from Trevor Abbott. Phone call with Trevor Abbott regarding final report. Phone call with Paul Kloft regarding deposition schedule. Draft Voir Dire questions. Review exhibits in support of Robert Halsey's Rebuttal Report. Confer with Fred Millard analyzing Rebuttal Expert Witness Reports. 05 Michele Barbara $125 All - Clerical 00 $0.00 03 03 02 02 02 0.1 02 0.1 0.1 0.1 Michele Barbara Michele Barbara Michele Barbara Michele Barbara Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $125 $125 $125 $125 $280 $280 $280 $280 $280 $280 All - Clerical All- Clerical All - Clerical All - Clerical 00 00 00 00 02 0.1 02 0.1 0.1 00 $0.00 $0.00 $0.00 $0.00 $56.00 $28.00 $56.00 $28.00 $28.00 $0.00 Compare Trevor Abbott's pricing with Katharyn Thompson's seed pricing. Review and analyze research from Christopher Fanning regarding caselaw cited in Country's Response to Objections to Evidence. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 10/23/12 Attend phone conference with Fred Millard and Paul Kloft on status of Rebuttal Reports. Phone call with Greg Mettler regarding Rebuttal Report. Prepare for oral argument on Summary Judgment and analyze use of potential Rebuttal Report not in the record of Kevin Loe to oppose Summary Judgment. Phone call with Craig Edminster regarding his Rebuttal Report. Email Craig Edminster requesting that he analyze impact of seed cleaning on seed values. Confer with Doug Bragg analyzing Rebuttal Expert Witness Reports. 0.1 Fred Millard $350 0.1 $35.00 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 Telephone call to Mike Billman to schedule his deposition. Telephone call to Trevor Abbott to schedule his deposition. Telephone call to Paul Kloft to schedule his deposition. Telephone call to Greg Mettler to schedule his deposition. Telephone call to Nick Priest to schedule his deposition. Receive and review Paul Kloft's CV from his office. Prepare additional exhibits for Trevor Abbott's rebuttal report. Assist Paul Kloft with his Rebuttal Report. 0.1 02 02 0.1 0.1 0.1 0.4 0.4 Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 $125 $125 $125 $125 $125 00 00 00 00 00 0.1 0.4 0.4 $0.00 $0.00 $0.00 $0.00 $0.00 $12.50 $50.00 $50.00 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/22/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 10/23/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review e-mail from Christopher Fanning analyzing issue of scope of record considered on Summary Judgment. Confer with Christopher Fanning analyzing research on record for Summary Judgment. Phone call to Robert Halsey regarding Rebuttal Report; Left voicemail. 0.1 Doug Bragg 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Clerical All - Clerical All - Clerical All - Clerical Page 80 of 161 Date 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/24/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/25/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review draft rebuttal report from Greg Mettler. Review and analyze updated report from Mike Billman. Phone call with Mike Billman regarding updated report and request further revisions. Confer with Paul Kloft regarding zero germination seed and trial presentation concerns. Review version 3 of Michael Billman's report. Confer with Michele Barbara regarding status of deposition scheduling. 02 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 02 $56.00 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 Review comments from Paul Kloft on Byron Slack's report. Begin outline of questions for Byron Slack's deposition. Review and analyze draft rebuttal report for Craig Edminster and email comments to Craig Edminster for consideration. Review and analyze final report from Craig Edminster. Phone call with Greg Mettler regarding possible revisions to Rebuttal Report. Review and analyze draft Rebuttal Report from Paul Kloft. Review and analyze final Rebuttal Report from Greg Mettler. Review and analyze draft Rebuttal Report from Greg Edminster. 0.1 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.1 02 $28.00 $28.00 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 03 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 02 02 $84.00 $56.00 $56.00 Prepare and submit expert Rebuttal Reports to Dan Thenell. Prepare CD with Rebuttal Reports. Prepare letter to Dan Thenell enclosing expert reports. Draft Deposition questions for Security Officers that were guarding the site. Draft Deposition questions for the excavators that worked on the site. 10 02 02 08 Michele Barbara Michele Barbara Michele Barbara Christopher Fanning $125 $125 $125 $182 00 00 00 08 $0.00 $0.00 $0.00 $145.60 08 Christopher Fanning $182 08 $145.60 Confer with Christopher Fanning to prepare outline of depositions of Defendant's witnesses. Outline questions for deposition of Byron Slack. Confer with Fred Millard to prepare for expert depositions. Draft letter to Dan Thenell regarding depositions of experts. Phone call with Bekki Duty at Billet Products regarding deposition availability of DJ Myers. Telephone calls to Craig Edminster to schedule his deposition. Telephone call to DJ Myers to schedule his deposition. Finalize schedule for Doug Bragg for all depositions we are scheduling for our experts. Researching the effect of filing a late expert report. Draft Motion to Strike Country's Rebuttal Expert Reports. Draft Memorandum in Support of Motion to Strike. Draft declaration of Doug Bragg in support of Motion to Strike. Review and analyze Katharyn Thompson's Rebuttal Report. Analyze Katharyn Thompson's report with Doug Bragg. Revise Motion to Strike based on Doug Bragg's comments and the change circumstances. Review and analyze rebuttal report of Byron Slack. Review and analyze rebuttal report from Kevin Loe. Review and analyze rebuttal report from Kathryn Thompson. Confer with Fred Millard regarding his attempt to confer with Dan Thenell over the Motion to Strike. Review email from Dan Thenell on Motion to Strike. Confer with Fred Millard analyzing Dan Thenell's argument that $2 million is a reasonable settlement offer. 02 Doug Bragg $280 02 $56.00 10 03 03 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 10 03 03 0.1 $280.00 $84.00 $84.00 $28.00 02 0.1 02 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 00 00 00 $0.00 $0.00 $0.00 1.1 03 13 03 05 0.1 0.7 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 $182 $182 $182 1.1 03 13 03 05 0.1 0.7 $200.20 $54.60 $236.60 $54.60 $91.00 $18.20 $127.40 02 03 05 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 All - Duplicative; billed to Millard 02 03 05 00 $56.00 $84.00 $140.00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Clerical All - Clerical All - Clerical All - Clerical All - Clerical Page 81 of 161 Date Hrs Awarded Amount $280 05 $140.00 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 Phone call with Dan Thenell regarding deposition schedule. Email Dan Thenell regarding deposition reschedule. Prepare list of questions for Katharyn Thompson's deposition. Assist Michele Barbara in preparing deposition schedule. Confer with Christopher Fanning analyzing deposition questions for Byron Slack. Review and analyze emails from Dan Thenell regarding deposition of Paul Kloft. Phone call with Paul Kloft analyzing Rebuttal Reports. Confer with Fred Millard analyzing Rebuttal Reports and Motion to Strike. Direct Michele Barbara to forward Rebuttal Reports to experts for review. Email Dan Thenell following up on Fred's voicemail to confer on the Motion to Strike Rebuttal Reports. Review declaration of Michele Barbara in Support of Motion to Strike. 03 0.1 1.1 03 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 03 0.1 1.1 03 02 $84.00 $28.00 $308.00 $84.00 $56.00 02 Doug Bragg $280 02 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze Dave Logan's Rebuttal Report. Review and analyze draft motion to strike Rebuttal Reports as incomplete and untimely. Review new David Logan Rebuttal Report. File Motion to Strike Defendant's Rebuttal Opinions/Reports. Confer with Fred Millard analyzing Rebuttal Report from Katharyn Thompson. Review and analyze Rebuttal Reports from Country. Confer with Christopher Fanning analyzing Motion to Strike Rebuttal Reports. Email conferral with Dan Thenell on Motion to Strike Rebuttal Reports as untimely and incomplete. Confer with Doug Bragg regarding preparation for expert depositions. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 03 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 00 00 $56.00 $0.00 $0.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 Doug Bragg $280 02 $56.00 03 Fred Millard $350 03 $105.00 10/26/12 Prepare for and conduct telephone call with Dan Thenell (VM) conferring on Motion to Strike Expert Disclosures due to lateness. 05 Fred Millard $350 05 $175.00 10/26/12 Respond to Dan Thenell's subsequent email RE: settlement and expert disclosures. Matter conference with Doug Bragg RE: Analysis on settlement and their expert disclosures. Email to experts RE: Upcoming Expert deposition. Review and analyze narratives of Country's Rebuttal Reports. 0.1 Fred Millard $350 0.1 $35.00 05 Fred Millard $350 05 $175.00 0.1 05 Fred Millard Fred Millard $350 $350 0.1 05 $35.00 $175.00 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 10/26/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Phone call with James Kloft regarding summary of set up worksheets for screens. Email Dan Thenell regarding expert deposition schedule. Revise declaration of Douglas M. Bragg in support of Motion to Strike. 05 Doug Bragg 0.1 0.1 Phone call with Paul Kloft regarding deposition preparation and schedule. Review, analyze and respond to emails from Dan Thenell regarding Motion to Strike. Confer with Michele Barbara regarding scheduling meeting with experts to prepare for depositions. Research caselaw on conferral. Direct Christopher Fanning to prepare withdrawal of Motion to Strike and email Dan Thenell regarding Withdrawal of Motion to Strike. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard Page 82 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 10/26/12 Matter conference with Staff analyzing upcoming Deposition scheduling. 10 Fred Millard $350 10 $350.00 10/26/12 Draft email to Thenell RE: Paul Kloft deposition RE: Potential protective order and draft Handout for Expert Luncheon Review depositions. 02 Fred Millard $350 02 $70.00 10/26/12 Confer with Doug Bragg to prepare draft Declaration for Michele Barbara to discuss the depositions. Telephone calls and e-mails with Joan Brown with Dan Thenell's office to schedule depositions. Telephone call to all witnesses/experts to schedule depositions, i.e. Trevor Abbott, Craig Edminster, Robert Halsey, Michael Rodrigue, John Poe, Kim Ellingson, Mike Billman, Greg Mettler, Nick Priest, and DJ Myers. E-mails to Nick Priest and John Poe to schedule depositions and change per Joan Brown related to John Poe's/Katharyn Thompson switching around. Discuss expert deposition preparation meeting for Tuesday with Doug Bragg. Create deposition bullet points for deposition preparation meeting. 0.4 Michele Barbara $125 0.1 Duplicative; billed to Bragg 03 $37.50 05 Michele Barbara $125 All - Clerical 00 $0.00 05 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Christopher Fanning $182 03 $54.60 08 Christopher Fanning $182 08 $145.60 Draft withdrawal of motion to exclude expert reports. Review and analyze Byron Slack's rebuttal report and draft additional deposition questions based on his rebuttal report. Research privilege in Oregon to determine if James Kloft is protected. 0.1 1.1 Christopher Fanning Christopher Fanning $182 $182 0.1 1.1 $18.20 $200.20 0.4 Christopher Fanning $182 0.4 $72.80 Review and revise handout for experts to assist with Deposition preparation. Review, analyze and respond to emails with Dan Thenell reaching agreements on issue of untimely expert production. Review email from Christopher Fanning RE: expert deposition preparation. Confer with Doug Bragg to file Motion to Withdraw Motion to Exclude Rebuttal Expert Reports. File Motion to Withdraw Motion to Exclude Rebuttal Expert Reports with Court. Confer with Doug Bragg to e-mail experts with trial date and possible conflict with seed conventions in January. E-mail Mike Billman, Trevor Abbott, and Craig Edminster RE: trial date and possible conflict with seed conventions in January. 02 Christopher Fanning $182 02 $36.40 02 Fred Millard $350 02 $70.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 00 $0.00 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 00 $0.00 Telephone conversation with Paul Kloft RE: depositions, expert reports, lunch with experts. Telephone conversation with Dan Thenell and Doug Bragg to discuss rescheduling the depositions. Telephone conversation with Joan Brown with new dates and shuffling of experts. Confer with Doug Bragg and Heidi Gross RE: scheduling depositions. 03 Michele Barbara $125 03 $37.50 03 Michele Barbara $125 All - Clerical 00 $0.00 0.4 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 Work with Joan Brown, Doug Bragg and experts on rearranging scheduling depositions. Prepare for meeting with experts, draft mock questions, and review reports. Assist with expert meeting in Salem with Doug Bragg, Fred Millard and Precision's various experts to help prepare them for depositions. 30 Michele Barbara $125 All - Clerical 00 $0.00 12 Christopher Fanning $182 12 $218.40 45 Christopher Fanning $182 00 $0.00 10/26/12 10/26/12 10/26/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/29/12 10/30/12 10/30/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Clerical All - Duplicative; billed to Millard Page 83 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Millard 10/30/12 Travel to/from Red Lion in Salem; Meet with experts (Robert Halsey, Michael Rodrigue, Trevor Abbott, Mike Billman and Craig Edminster) and Paul Kloft and James Kloft for deposition preparation. 45 Doug Bragg $280 10/30/12 Review Federal Rules of Civil Procedures as they pertain to expert witness fees and costs. Draft email to Joan Brown at Dan Thenell's office regarding each party's obligation to pay for expert depositions and costs associated with the depositions they request. Review various emails from Dan Thenell's office regarding deposition schedule and rescheduling. Travel to/from Red Lion in Salem; Meet with experts (Robert Halsey, Michael Rodrigue, Trevor Abbott, Mike Billman and Craig Edminster) and Paul Kloft and James Kloft for deposition preparation. 02 Doug Bragg 0.1 Hrs Awarded Amount 00 $0.00 $280 02 $56.00 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 45 Fred Millard $350 45 $1,575.00 E-mail to Nick Priest confirming his deposition. Telephone conversations with Joan Brown, Kim Ellingson, Craig Edminster, Mike Billman, Trevor Abbott, DJ Myers to coordinate depositions. E-mail to Greg Mettler confirming his deposition. Assist with meeting with experts to prepare for their depositions. 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 45 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Duplicative; billed to Millard 00 00 $0.00 $0.00 Compare and analyze Katharyn Thompson's two reports with our seed values. Attempt to discern where there are differences and where we agree. Prepare for and conduct meeting with Fred Millard and Trevor Abbott analyzing issues with his deposition. Draft questions for Kevin Loe's deposition. Meet with Fred Millard and Trevor Abbott in preparation for Mr. Abbott's deposition. Confer with Christopher Fanning analyzing status of comparison of Katharyn Thompson's Rebuttal Report with initial report. 49 Christopher Fanning $182 49 $891.80 1.4 Doug Bragg $280 00 $0.00 10 05 Doug Bragg Doug Bragg $280 $280 10 05 $280.00 $140.00 0.1 Doug Bragg $280 0.1 $28.00 10/31/12 Prepare for and conduct pre-deposition meeting with Trevor Abbott. 05 Fred Millard $350 05 $175.00 10/31/12 10/31/12 Defend deposition of Trevor Abbott. Prepare for and conduct post-deposition meeting with Trevor Abbott. 10 1.4 Fred Millard Fred Millard $350 $350 10 1.4 $350.00 $490.00 10/31/12 10/31/12 Confer with Doug Bragg RE: depositions. Telephone call to Dan Thenell's office to reschedule James Kloft and Paul Kloft's depositions, along with Craig Edminster to no avail. 03 0.1 Michele Barbara Michele Barbara $125 $125 All- Clerical 03 00 $37.50 $0.00 10/31/12 Confer with Mary Beth Bonner RE: rescheduling James Kloft, Paul Kloft and Craig Edminster's depositions. Organize deposition exhibits for ongoing depositions. Prepare Notice of Taking Expert Depositions. Revise master chart of seed lots with Katharyn Thompson's values. Had to update our numbers based on different claims that were found and then compared Katharyn Thompson's values with ours, highlighting the points where we agree and disagree. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.4 0.4 35 Michele Barbara Michele Barbara Christopher Fanning $125 $125 $182 All- Clerical All - Clerical 00 00 35 $0.00 $0.00 $637.00 Locating documents for opposing counsel for Deposition of Kim Ellingson. Review and analyze Country's discovery requests relating to Deposition discovery requests. 08 Christopher Fanning $182 08 $145.60 03 Christopher Fanning $182 03 $54.60 10/30/12 10/30/12 10/30/12 10/30/12 10/30/12 10/30/12 10/30/12 10/31/12 10/31/12 10/31/12 10/31/12 10/31/12 10/31/12 10/31/12 11/1/12 11/1/12 11/1/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard Page 84 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Conferred with Doug Bragg and Fred Millard analyzing issues related to deposition of Kim Ellingsen. Review email from Joan Brown regarding deposition schedule revision, and Jim Brady being out of state. Prepare for and conduct phone call with Michael Rodrigue regarding deposition preparation. Prepare for deposition of DJ Myers. Confer with Michele Barbara regarding revision to deposition schedule. 02 Christopher Fanning $182 All - Duplicative; billed to Millard 0.1 Doug Bragg 08 Explanation Hrs Awarded Amount 00 $0.00 $280 0.1 $28.00 Doug Bragg $280 08 $224.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 10 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All- Duplicative; billed to Millar 00 $0.00 11/1/12 Phone call with Valley Merchant Police, Inc. regarding involvement on fire scene. Prepare for and conduct meeting with Kim Ellingson and Fred Millard to prepare for her deposition and discuss facts relating to book keeping and Paul Kloft's reputation for honesty. Confer with Fred Millard analyzing "good faith and fair dealing" argument and actual cash value maximum depreciation. Confer with Fred Millard analyzing deposition questions for Jim Brady. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 11/1/12 Review/respond to email from court regarding oral argument schedule. 0.1 Doug Bragg $280 0.1 $28.00 11/1/12 Draft deposition questions for Jim Brady based upon discussion with Fred Millard. Confer with Fred Millard and Kim Ellingsen analyzing attorney-client privilege issues. Meeting with DJ Myers in preparation for his deposition. Confer with Fred Millard analyzing deposition of Kim Ellingson. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 0.1 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 03 00 $84.00 $0.00 Review and analyze deposition transcript of Trevor Abbott. Phone call with James Kloft regarding Quick Books. Defend Kim Ellingsen Deposition. Prepare for and conduct meeting with Kim Ellingson and Doug Bragg to prepare for deposition and discuss facts relating to bookkeeping and Paul Kloft's reputation for honesty. Confer with Doug Bragg analyzing "good faith and fair dealing". Confer with Doug Bragg analyzing deposition questions for Jim Brady. 05 03 33 10 Doug Bragg Doug Bragg Fred Millard Fred Millard $280 $280 $350 $350 05 03 33 10 $140.00 $84.00 $1,155.00 $350.00 02 0.1 Fred Millard Fred Millard $350 $350 02 0.1 $70.00 $35.00 02 Fred Millard $350 02 $70.00 0.1 05 Fred Millard Michele Barbara $350 $125 All - Clerical 0.1 00 $35.00 $0.00 03 Michele Barbara $125 0.2 Duplicative; billed to Bragg 0.1 $12.50 11/1/12 Confer with Doug Bragg and Kim Ellingson analyzing attorney-client privilege. Confer with Doug Bragg analyzing deposition of Kim Ellingsen. E-mails with and telephone call with Joan Brown RE: scheduling depositions. Confer with Doug Bragg on scheduling depositions and Review First Amended Notice of Depositions. Receive e-mail from court reporter with Trevor Abbott's transcript. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/1/12 Telephone call to court reporter for assistance in opening transcript. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/1/12 11/1/12 Print out transcript and e-mail to Trevor Abbot. Telephone conversation with Joan Brown on cancelling John Poe's deposition Telephone call to John Poe that his deposition was just cancelled at 4:45 pm and to send me a copy of his bill. Locate 2009 taxes per Dan Thenell's request during Kim Ellingson's deposition. Review and analyze deposition transcript of Trevor Abbott. 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 03 $37.50 Christopher Fanning $182 08 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/1/12 11/2/12 3:10-cv-01023-HZ 08 ATTACHMENT 1 $145.60 Page 85 of 161 Date Hrs Awarded Amount $182 $182 02 1.6 $36.40 $291.20 Christopher Fanning $182 0.4 $72.80 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 03 Doug Bragg $280 03 $84.00 Review/respond to email from Dan Thenell regarding representation of Kim Ellingson. Prepare for and conduct meeting with Michael Rodrigue to prepare for his deposition. Defend deposition of Michael Rodrigue. Review and analyze Defendant's Supplemental Memorandum in Opposition to Motion for Partial Summary Judgment. Confer with Fred Millard analyzing deposition of Michael Rodrigue. 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 0.7 $196.00 25 02 Doug Bragg Doug Bragg $280 $280 25 02 $700.00 $56.00 02 Doug Bragg $280 02 $56.00 11/2/12 Confer with Fred Millard analyzing Supplemental Memorandum in Opposition to Motion for Partial Summary Judgment. 02 Doug Bragg $280 02 $56.00 11/2/12 11/2/12 Confer with Dan Thenell regarding deposition schedule. Confer with Dan Thenell regarding Motion for Protective Order. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 11/2/12 Confer with Christopher Fanning regarding preparation of Motion for Protective Order. Draft email to Dan Thenell and others regarding status of deposition schedule. Review and analyze Defendant's Supplemental Opposition and Declaration. Confer with Doug Bragg to discuss contacting Kim Ellingson and James Kloft RE: Quickbook records. Telephone calls to James Kloft and Kim Ellingson RE: Quickbook records. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Fred Millard $350 03 $105.00 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 02 $25.00 Telephone call with Paul Kloft RE: Trevor Abbot and Kim Ellingson's depositions, his deposition schedule and Country's additional document requests. E-mail from Joan Brown with Dan Thenell's office with location of Jim Brady Telephone call to court reporter to locate an office to take Mr. Brady's deposition in Bloomington, Illinois. Review, organize and index Deposition Exhibits for Experts. Conversation with Doug Bragg and Dan Thenell on scheduling depositions. Confer with Doug Bragg to cancel Michael Rodrigue for Mr. Slack's deposition which has been delayed. Telephone call to Michael Rodrigue to advise him of cancelled deposition. Confer with Doug Bragg to prepare the Declaration for Paul Kloft for Protective Order for James Kloft. Prepare draft Declaration draft Declaration of Paul Kloft in Support of the Motion for Protective Order for James Kloft. Review, organize and compile exhibits for expert depositions. 0.4 Michele Barbara $125 0.2 - Clerical 02 $25.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All- Clerical 00 $0.00 0.4 03 Michele Barbara Michele Barbara $125 $125 All - Clerical 0.4 00 $50.00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 02 $25.00 02 Michele Barbara $125 02 $25.00 Michele Barbara $125 0.4 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze deposition of James King. Review and analyze letter from Judge Hernandez and attempt to provide answers to his questions. Research attorney/client and work product privilege as it relates to experts. Review and analyze Request for Production from Country to determine if Quickbooks were requested. Prepare for and attend phone conference with Judge Hernandez regarding Motion for Partial Summary Judgment. Confer with Fred Millard analyzing phone conference with the court. 02 1.6 Christopher Fanning Christopher Fanning 0.4 Explanation 0.4 ATTACHMENT 1 Hrs Deducted by Court and Reason $50.00 Page 86 of 161 Date Hrs Req Pltf Lawyer Rate Receive and review documents from Dalke Construction. Confer with Doug Bragg RE: telephone call with Tracey from Dalke on Friday. Telephone conversations and e-mails with Joan Brown with Thenell Law Group to schedule depositions. Telephone call to Craig Edminster to schedule his deposition and e-mail to him RE: deposition time and place. Compose a confirmation e-mail to Greg Mettler for his deposition. 0.1 03 Michele Barbara Michele Barbara $125 $125 03 Michele Barbara $125 02 Michele Barbara 02 Telephone conversation with Joan Brown RE: scheduling Paul Kloft and James Kloft's depositions. Telephone calls with Paul Kloft RE: scheduling his deposition. Telephone conversation with Joan Brown RE: scheduling DJ Myers' deposition. Telephone call to DJ Myers RE: scheduling his deposition. Telephone call to Robert Halsey to confirm deposition and to advise him to bring file with him. Telephone call to Trevor Abbott RE: deposition and e-mail to him to request he contact our office. Prepare motion for protective orders for James Kloft and Kim Ellingson. 11/5/12 11/5/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/2/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/5/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 3:10-cv-01023-HZ Hrs Awarded Amount 0.1 03 $12.50 $37.50 All - Clerical 00 $0.00 $125 All - Clerical 00 $0.00 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 02 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 03 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 03 Christopher Fanning $182 03 $54.60 Researching attorney-client privilege and independent contractors in Oregon. Looked at case law on this issue and researched the legislative history on the 2009 amendments to Oregon's rule. 23 Christopher Fanning $182 23 $418.60 Confer with Michele Barbara analyzing documents from Dalke Construction. Phone call with John Dalke regarding excavation at the site. Email John Dalke documents received from Dalke Construction for review. Review and analyze Ryan Fields' photos. Confer with Christopher Fanning regarding legislative history of attorneyclient privilege statute. Review and revise Memorandum in Support of Motion for Protective Order. Phone call with Paul Kloft regarding Declaration in Support of Motion for Protective Order. Phone call with Paul Kloft regarding deposition schedule. Draft Memorandum in Support of Motion for Protective Order. Phone call with Paul Kloft regarding Declaration in Support of Motion for Protective Order. Draft email to Dan Thenell in response to his refusal to produce experts for depositions; Commence review of Paul Kloft's Examination Under Oath transcripts in anticipation of his deposition. Review Trevor Abbott's deposition for consistency with Country's Supplemental Response to Motion for Summary Judgment. 02 Doug Bragg $280 02 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 05 10 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 05 10 02 $140.00 $280.00 $56.00 10 Fred Millard $350 10 $350.00 12 Fred Millard $350 12 $420.00 0.1 Christopher Fanning $182 0.1 $18.20 Draft Declaration of Doug Bragg for Surreply. Prepare and file Surreply. Prepare Surreply for submittal and filing. Attend matter conference with attorneys and staff to prepare for Depositions of Country's experts. Phone call with Trevor Abbott regarding Supplemental Response to Motion for Summary Judgment. 05 05 05 03 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 05 05 05 03 $91.00 $91.00 $91.00 $54.60 0.7 Doug Bragg $280 0.7 $196.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 87 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 11/6/12 11/6/12 Review email from Dan Thenell regarding deposition schedule. Draft Surreply on Second Motion for Partial Summary Judgment. 02 1.6 Doug Bragg Doug Bragg $280 $280 02 1.6 $56.00 $448.00 11/6/12 Phone call with Maribeth Bonner regarding Motion to postpone oral argument on Summary Judgment. Confer with Michele Barbara regarding deposition scheduling. Confer with Christopher Fanning regarding status of Surreply. Review and analyze various emails from Dan Thenell regarding expert deposition scheduling. Review and execute Notices of Deposition. Review and analyze Motion to Postpone oral argument on Summary Judgment Motion. Confer with Fred Millard analyzing response to Motion to Postpone oral argument. Draft Response to Motion to Postpone Oral Argument. Prepare for and conduct conference with attorneys and staff to prepare for Depositions of Country's experts. Continue reviewing and analyzing Paul Kloft's Examination Under Oath transcript in preparation for upcoming deposition. Review, analyze and respond to Dan Thenell's emails regarding depositions; Review and analyze Country briefings on Motion to postpone Summary Judgment hearing. Matter conference with Doug Bragg analyzing Surreply issues. Attend matter conference with Staff to prepare for Depositions of Country's experts. Review and respond to Dan Thenell's email regarding Country's expert depositions. Telephone call with Paul Kloft RE: availability for deposition. Meeting with Doug Bragg to review and analyze lots for tests that Trevor Abbott wrote his expert reports on. Telephone conversations with James Kloft and Paul Kloft RE: depositions, CD's with accounting records, Dalke records and photos from Ryan Fields. Confer with Doug Bragg RE: depositions and analysis of Katharyn Thompson's report. Review and analyze Katharyn Thompson's report to confirm appropriate lots for Scotts. Prepare documents for The Scotts Co. deposition. Telephone call to Lynda Lentz, owner, Valley Merchant Police for list of individuals who worked at fire site. Prepare renotices of depositions. E-mails with Nick Priest on a location for his deposition. Voicemail to Paul Kloft for his and James Kloft's depositions. Attend conference with attorneys and staff to prepare for Depositions of Country's experts. Conferred with Doug Bragg to analyze Seashore Paspallum question. 02 Doug Bragg $280 02 $56.00 02 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.1 02 $56.00 $28.00 $56.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 18 Fred Millard $350 18 $630.00 19 Fred Millard $350 19 $665.00 02 03 Fred Millard Fred Millard $350 $350 02 03 $70.00 $105.00 03 Fred Millard $350 03 $105.00 02 0.4 Fred Millard Michele Barbara $350 $125 02 0.4 $70.00 $50.00 02 Michele Barbara $125 02 $25.00 02 Michele Barbara $125 00 $0.00 03 Michele Barbara $125 03 $37.50 02 0.4 Michele Barbara Michele Barbara $125 $125 02 0.4 $25.00 $50.00 10 02 0.1 03 Michele Barbara Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 $125 00 00 00 00 $0.00 $0.00 $0.00 $0.00 02 Christopher Fanning $182 02 $36.40 Review and analyze documents to locate all Seashore Paspallum contracts. Review and analyze documents and Katharyn Thompson's report and highlight changes for copy being sent to Judge Hernandez. 10 Christopher Fanning $182 10 $182.00 0.6 Christopher Fanning $182 0.6 $109.20 Review and analyze Doug Bragg's Response and adding legal authority to support our position on not extending the time to respond to the motion for summary judgment. 0.6 Christopher Fanning $182 0.6 $109.20 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/6/12 11/7/12 11/7/12 11/7/12 11/7/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Bragg All - Clerical All - Clerical All - Clerical All - Duplicative; billed to Millard Page 88 of 161 Date 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 11/7/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Phone call with John Dalke discussing whether he was able to locate his notebook. Phone call with Dwight Butler. Phone call with Frank Turrey. Begin drafting Opposition to Motion to Continue Hearing by reviewing the procedural history. Research Federal Rules of Civil Procedure 56(d). Draft Opposition to Motion to Continue Hearing Prepare for deposition of Scotts Company. Direct Christopher Fanning to fill in case citations on standards under FRCP 56(d) for Opposition to Motion for Continuance of Hearing. 0.1 Christopher Fanning $182 0.1 $18.20 02 0.1 02 Christopher Fanning Christopher Fanning Doug Bragg $182 $182 $280 02 0.1 02 $36.40 $18.20 $56.00 03 10 1.1 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 03 10 1.1 0.1 $84.00 $280.00 $308.00 $28.00 Phone call to Precision regarding Scotts Company's deposition. Prepare for and conduct meeting with Robert Halsey to prepare for his deposition. Travel to/from Deposition of Robert Halsey. Meet with Robert Halsey post-deposition analyzing deposition questions and potential issues for trial. Review the Scotts Company's contracts produced by Paul Kloft. Review and analyze Country's Request for Production regarding contracts for seed; Direct Michele Barbara to forward contracts to Dan Thenell's office. Confer with Fred Millard analyzing additional contracts. 02 05 Doug Bragg Doug Bragg $280 $280 02 05 $56.00 $140.00 0.4 02 Doug Bragg Doug Bragg $280 $280 0.4 02 $112.00 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Confer with Fred Millard analyzing deposition questions for the Scotts Company. Review Notice from court denying Motion to Postpone hearing on Motion for Partial Summary Judgment. Travel to/from scheduled deposition of The Scott's Company and attend no-show deposition of the Scotts Company. Meet with Dan Thenell regarding potential reschedule of the Scotts Company's deposition. Prepare for and conduct meeting with Christopher Fanning analyzing interviews with excavators and security personnel. Review Notice of Perpetuation Deposition of Kevin Loe. Email Dan Thenell confirming earlier conversation on the Scotts Company's documents and status of reset of the deposition. 03 Doug Bragg $280 0.2 Duplicative; billed to Millard 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 Defend deposition of Robert Halsey. Prepare for depositions of Craig Edminster and Greg Mettler, Review and analyze reports and other materials. Confer with Doug Bragg analyzing additional contracts for seed production. Confer with Fred Millard to prepare for deposition of the Scotts Company. Review Opposition to Motion to Postpone Oral Argument. File Opposition to Continue Hearing with the Court. Revise Notice of Taking Expert Depositions to add Byron Slack's name. 10 2.7 Doug Bragg Fred Millard $280 $350 10 2.7 $280.00 $945.00 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 02 02 02 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 All - Clerical All - Clerical 02 00 00 $25.00 $0.00 $0.00 Prepare subpoenas for depositions of Jim Brady, Katharyn Thompson, Byron Slack, David Logan and Kevin Loe. Confer with Chris Fanning to prepare for interviewing security and excavation personnel. Receive, review and analyze CD of Quickbook records from Precision Seed. 08 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 03 $37.50 0.1 Michele Barbara $125 0.1 $12.50 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 89 of 161 Date 11/7/12 11/7/12 11/7/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 11/8/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Telephone conversations with James Kloft RE: Quickbooks CD of Precision's records. Direct Courtney Pentek to prepare for Katharyn Thompson's exhibit for oral argument. E-mail and telephone call to Office Depot to make sure they received the document and for them to print it out in color. Review and analyze policy and draft explanation of Actual Cash Value and replacement cost. Assist Doug Bragg with preparation for oral argument for Motion for Partial Summary Judgment. Researching standard for avoiding summary judgment. Develop approach for oral argument on the Summary Judgment Motion with Doug Bragg. Conduct meeting with Fred Millard to analyze upcoming summary judgment oral argument. Review and sign First Amended Notice of Depositions and Subpoenas for expert depositions. Direct Christopher Fanning to prepare short memo on Actual Cash Value / Replacement Cost Value question for oral argument. 03 Michele Barbara $125 03 $37.50 02 Michele Barbara $125 02 $25.00 0.1 Michele Barbara $125 00 $0.00 15 Christopher Fanning $182 15 $273.00 0.4 Christopher Fanning $182 0.4 $72.80 10 03 Christopher Fanning Christopher Fanning $182 $182 10 03 $182.00 $54.60 0.4 Doug Bragg $280 0.4 $112.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Fred Millard preparing for depositions scheduled for next week. Meet with Craig Edminster regarding the deposition that was cancelled first thing this morning. Prepare for Hearing on Motion for Partial Summary Judgment - Outline answers to questions from the court. Meeting with Fred Millard analyzing potential issues for Hearing on Motion for Partial Summary Judgment. Prepare for Hearing on Motion for Partial Summary Judgment - Review briefings and exhibits. Confer with Fred Millard analyzing letter from Dan Thenell regarding "agreement" between parties. Review and analyze letter from Dan Thenell to Judge Hernandez regarding scope of agreement between the parties. Review and analyze briefings for Friday's Partial Summary Judgment argument to assist Doug Bragg in preparation for oral presentation and conduct deposition preparation for Nick Priest, draft ememo, etc. 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 0.6 Doug Bragg $280 0.6 $168.00 08 Doug Bragg $280 08 $224.00 30 Doug Bragg $280 30 $840.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 40 Fred Millard $350 40 $1,400.00 Review and analyze Dan Thenell's correspondence to Court responding to its inquiry into agreed upon values. Attend Summary Judgment Hearing. Complete Subpoenas for depositions of all Country's experts and witnesses. Confer with court reporter RE: depositions. Confer with Doug Bragg RE: deposition schedule. E-mails to Joan Brown for documents from Scotts Company's people, Lynn Davis file/photos. E-mail to Joan Brown RE: scheduling issues. E-mails (2) from Joan Brown at Dan Thenell's office RE: court reporter for Jim Brady's deposition. Documents from the Scotts Company. Receive, analyze and review fax letter from Dan Thenell to court on potential areas of agreement. Telephone call to Joan Brown for a scanned version of letter - illegible on last few pages 20 Fred Millard $350 20 $700.00 15 0.4 Fred Millard Michele Barbara $350 $125 All-Duplicative; billed to Bragg All - Clerical 00 00 $0.00 $0.00 0.1 0.1 0.1 Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 All - Clerical All - Clerical All - Clerical 00 00 00 $0.00 $0.00 $0.00 02 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 0.1 Michele Barbara Michele Barbara $125 $125 All- Vague 00 0.1 $0.00 $12.50 0.1 Michele Barbara $125 All - Clerical 00 $0.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical Page 90 of 161 Date 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/9/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Researching Anderson v. Liberty Lobby and related cases analyzing the scintilla rule. Draft documents with bullet points and supporting law for Doug Bragg in preparation of motion for summary judgment hearing. 29 Christopher Fanning $182 29 $527.80 10 Christopher Fanning $182 10 $182.00 Traveling to/from courthouse. Assist Doug Bragg with presentation on motion for summary judgment. Confer with Doug Bragg and Fred Millard analyzing Daubert hearing and other issues. Prepare for Oral Argument on Partial Summary Judgment - Outline factual disputes. Travel to/from courthouse for hearing on Motion for Partial Summary Judgment. Present oral argument for Precision Seed at hearing on Motion for Partial Summary Judgment. Confer with Christopher Fanning and Fred Millard analyzing oral argument, case status, and possible settlement conference. 23 Christopher Fanning $182 All-Duplicative; billed to Bragg 00 $0.00 05 Christopher Fanning $182 All-Duplicative; billed to Bragg 00 $0.00 4.7 Doug Bragg $280 4.7 $1,316.00 08 Doug Bragg $280 08 $224.00 15 Doug Bragg $280 15 $420.00 05 Doug Bragg $280 00 $0.00 Confer with Michele Barbara analyzing reset of the trial date and Daubert Hearing, direct Michele Barbara to reschedule Depositions accordingly. Phone call with Paul Kloft analyzing oral argument on Motion for Partial Summary Judgment. Confer with Christopher Fanning and Doug Bragg analyzing oral argument, case status, and possible settlement conference. Reviewing and analyzing Examination Under Oath transcripts and other Deposition Transcripts in preparation for Paul Kloft's deposition and trial. Review and analyze E-mail from Joan Brown with letter to Judge Hernandez dtd November 8, 2012. Review and analyze E-mails from Fred Millard for directions on legal research on summary judgment and Memorandum on admissibility Requirements for Summary Judgment Affidavits. Confer with Doug Bragg analyzing timing of remaining expert depositions based upon court order at oral argument. Telephone calls with Joan Brown at Dan Thenell's office to reschedule depositions. Confer with Doug Bragg to schedule Mike Billman's and Kevin Loe's depositions. Email to Mike Billman and Trevor Abbott RE: deposition scheduling. 02 Doug Bragg $280 02 $56.00 05 Doug Bragg $280 05 $140.00 05 Fred Millard $350 05 $175.00 3.7 Fred Millard $350 3.7 $1,295.00 03 Michele Barbara $125 03 $37.50 02 Michele Barbara $125 02 $25.00 02 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 Prepare for deposition of Katharyn Thompson with Doug Bragg. Reviewed Kevin Loe's report to add to tables for Katharyn Thompson's deposition. Preparing tables of values for Katharyn Thompson deposition based on discussion with Doug Bragg. Confer with Christopher Fanning to prepare for Katharyn Thompson's deposition. Confer with Fred Millard preparing for deposition of Katharyn Thompson. Confer with Fred Millard analyzing summary judgment issues and possible impacts of Daubert Hearing on trial and settlement. 0.4 03 Christopher Fanning Christopher Fanning $182 $182 0.3 Duplicative - billed to Bragg 0.1 03 $18.20 $54.60 22 Christopher Fanning $182 22 $400.40 03 Doug Bragg $280 03 $84.00 10 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Review and analyze photographs from Lynn Davis of the fire. 02 Doug Bragg $280 02 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 91 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Confer with Fred Millard analyzing the concern that excavators appeared to throw away 4 dumpsters of seed and equipment based upon excavator invoices and photographs. Confer with Michele Barbara analyzing deposition schedule. Research limitations on expert testimony at trial beyond written reports. Confer with Fred Millard analyzing revisions to deposition schedule. 05 Doug Bragg $280 All - Duplicative; billed to Millard 02 18 Doug Bragg Doug Bragg $280 $280 03 Doug Bragg $280 Confer with Doug Bragg analyzing deposition preparation of Katharyn Thompson. Confer with Doug Bragg analyzing summary judgment issues and possible impacts of Daubert Hearing on trial and settlement. 10 Fred Millard 03 Confer with Doug Bragg analyzing concern that excavators appeared to throw away 4 dumpsters of seed and equipment based upon excavator invoices and photographs. Confer with Doug Bragg analyzing revisions to deposition schedule. 11/12/12 11/12/12 Explanation Hrs Awarded Amount 00 $0.00 02 18 $56.00 $504.00 00 $0.00 $350 10 $350.00 Fred Millard $350 03 $105.00 05 Fred Millard $350 05 $175.00 03 Fred Millard $350 03 $105.00 Telephone call from James Kloft and Paul Kloft RE: depositions. Review, analyze and respond to E-mails from Dan Thenell's office and court reporter that Nick Priest's deposition has been rescheduled. 05 03 Michele Barbara Michele Barbara $125 $125 All- Clerical All - Clerical 00 00 $0.00 $0.00 11/12/12 Confer with Doug Bragg RE: reschedule of Nick Priest's deposition. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 Telephone call to Joan Brown with Dan Thenell's office on scheduling depositions. Confer with Doug Bragg analyzing conversations with Joan Brown regarding deposition scheduling. Telephone conversation with Joan Brown at Dan Thenell's office on scheduling depositions. Email to Greg Mettler to ask him for his availability for December 17th for his deposition. Confer with Doug Bragg and Fred Millard on scheduling depositions. 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 03 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 10 Michele Barbara $125 0.2 Duplicative; billed to Bragg; 0.8 excessive compared to Bragg entry 00 $0.00 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 Voicemail to Kim Ellingson to see if she is interested in finishing her deposition. E-mail to all experts/witnesses to advise them of change in trial date. 03 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 Amend Notice of Expert Depositions. Amend Subpoena for Jim Brady. Amend Subpoena for Katharyn Thompson. Amend Subpoena for Kevin Loe. Amend Subpoena for Byron Slack. Telephone call to Greg Mettler regarding deposition reschedule. 02 0.1 0.1 0.1 0.1 0.1 Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara Michele Barbara $125 $125 $125 $125 $125 $125 All - Clerical All - Clerical All - Clerical All - Clerical All - Clerical All - Clerical 00 00 00 00 00 00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 11/12/12 Phone calls with Mike Billman (2) regarding deposition reschedule. 02 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 Phone call with Trevor Abbott regarding deposition reschedule. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 Phone calls (2) with Kim Ellingson regarding deposition reschedule. 02 Michele Barbara $125 All - Clerical 00 $0.00 11/12/12 11/13/12 E-mails with Nick Priest regarding deposition reschedule. Finish chart analyzing agreements and discrepancies in seed valuation in preparation for deposition of Katharyn Thompson. 0.4 1.6 Michele Barbara Christopher Fanning $125 $182 All - Clerical 00 1.6 $0.00 $291.20 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 11/12/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard Page 92 of 161 Date Hrs Req Pltf Lawyer Rate Analyze current difference in value and what it would be if Katharyn Thompson accepted Kevin Loe's numbers. Confer with Doug Bragg and Fred Millard analyzing issues stemming from the summary judgment hearing and other assorted issues. 10 Christopher Fanning $182 09 Christopher Fanning $182 11/13/12 Review order from court resetting pre-trial deadlines, granting Motion for Protective Order and continuing the Summary Judgment. 0.1 Doug Bragg 11/13/12 Confer with Christopher Fanning analyzing status of comparison chart on expert valuations of seed. Confer with Michele Barbara analyzing status of deposition scheduling. 02 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/13/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 3:10-cv-01023-HZ Hrs Awarded Amount 10 $182.00 00 $0.00 $280 0.1 $28.00 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Fred Millard analyzing protective order and analysis of possible additional issues at the deposition of James Kloft. 03 Doug Bragg $280 00 $0.00 Research ORE 503 on "communications between representatives of the client". Confer with Fred Millard analyzing anticipated objections to questions on privilege. Review legislative history of FRE 501's split on privilege basis. Meet with Fred Millard analyzing FRE 501 legislative history in preparation of deposition of Paul Kloft. Meet with Fred Millard and Christopher Fanning analyzing summary judgment oral argument and issues for Daubert hearing. 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 09 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Review updated scheduling order from court. Confer with Doug Bragg analyzing protective order and possible additional issues at the deposition of James Kloft. Confer with Doug Bragg analyzing anticipated objections to questions on privilege. Confer with Doug Bragg analyzing FRE 501 legislative history in preparation of deposition of Paul Kloft. Confer with Doug Bragg and Christopher Fanning analyzing summary judgment oral argument and issues for Daubert hearing. 0.1 03 Doug Bragg Fred Millard $280 $350 0.1 03 $28.00 $105.00 0.1 Fred Millard $350 0.1 $35.00 02 Fred Millard $350 02 $70.00 09 Fred Millard $350 09 $315.00 E-mail to court reporter with a copy of Second Amended Notice of Taking Expert Depositions. E-mail to Joan Brown at Dan Thenell's office for court reporter and videographer for Jim Brady's deposition. Receive and analyze e-mail from court with new dates for trial, pre-trial and other deadlines. Confer with Doug Bragg analyzing new pre-trial schedule. E-mail Michelle Rawson at court for clarification on pre-trial deadlines. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 Michele Barbara $125 0.1 $12.50 02 0.1 Michele Barbara Michele Barbara $125 $125 All - Clerical 02 00 $25.00 $0.00 E-mail to Michelle Rawson for time of Daubert hearing on January 23, 2013. Review and analyze requests for production to determine if they asked for certain bank records. Research timeliness and motions to compel. Research spoliation of evidence. Review email from Joan Brown regarding bank record request. Confer with Christopher Fanning analyzing confirmation of Request for Production from Country as to Bank Record request and our response. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 0.4 Christopher Fanning $182 0.4 $72.80 1.4 05 0.1 02 Christopher Fanning Christopher Fanning Doug Bragg Doug Bragg $182 $182 $280 $280 1.4 05 0.1 02 $254.80 $91.00 $28.00 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 93 of 161 Date 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/14/12 11/15/12 11/15/12 11/15/12 11/15/12 11/15/12 11/15/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review, analyze and respond to email from Joan Brown regarding deposition of Kevin Loe. Review and analyze responses to Requests for Production from Country relating to bank statements. Confer with Christopher Fanning analyzing timeliness of potential Motion to Compel. Prepare for deposition of James Kloft. Confer with Fred Millard and Paul Kloft to prepare for Paul Kloft's deposition and analyze possible motion to strike defenses due to spoliation. Review and analyze photos from the fire by Fields and Davis (500 photos), separating out photos for use in future depositions and for trial. Confer with Fred Millard analyzing apparent photographs of Dan Thenell at the fire scene on August 28, 2009. Draft memo to Fred Millard analyzing attorney-client privilege objections relating to James Kloft's deposition testimony. Confer with Fred Millard analyzing research on attorney-client privilege relating to conversations between Paul Kloft and James Kloft. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.7 12 Doug Bragg Doug Bragg $280 $280 0.7 00 $196.00 $0.00 10 Doug Bragg $280 10 $280.00 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze Examination Under Oath transcripts and expert reports in preparation for upcoming depositions. Prepare for and conduct meeting with Paul Kloft in preparation for deposition. Matter conference with Doug Bragg analyzing photos of fire scene recently provided by Country supporting presence of seed lots. 48 Fred Millard $350 48 $1,680.00 12 Fred Millard $350 12 $420.00 02 Fred Millard $350 02 $70.00 Confer with Doug Bragg and Paul Kloft to prepare for Paul Kloft's deposition and analyze possible motion to strike defenses due to spoliation. Confer with Fred Millard to get all exhibits for Paul Kloft's Examination Under Oath and conversations and e-mail with Joyce at Zaro & Zaro for exhibits. Obtain, analyze, and organize all Examination Under Oath exhibits and index binder for depositions. Review and analyze Examination Under Oath exhibits in binders related to Seed of Others for consistency. Confer with Doug Bragg analysis of Examination Under Oath exhibits. 12 Fred Millard $350 12 $420.00 03 Michele Barbara $125 0.1 - Clerical 02 $25.00 10 Michele Barbara $125 All - Clerical 00 $0.00 0.4 Michele Barbara $125 0.4 $50.00 0.1 Michele Barbara $125 0.1 $12.50 Confer with Doug Bragg regarding information needed from John Dalke and Dalke Excavation. Telephone conversation with John Dalke from Dalke Excavation RE: scheduling deposition and for him to review photos. 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 All - Clerical 00 $0.00 E-mail to John Dalke attaching photos for his review. Review seed value comparison chart to assist with preparation for Katharyn Thompson's Deposition. Email seed experts to ask for input on the upcoming depositions of Katharyn Thompson and Kevin Loe. Prepare for and conduct meeting with James Kloft in preparation for his deposition. Prepare for and conduct meeting with James Kloft analyzing equipment lost in the fire and seed valuation issues. Phone call to John Dalke regarding deposition. Direct Michele Barbara to setup deposition of John Dalke. 0.1 18 Michele Barbara Christopher Fanning $125 $182 All - Clerical 00 18 $0.00 $327.60 0.7 Christopher Fanning $182 0.7 $127.40 03 Doug Bragg $280 03 $84.00 22 Doug Bragg $280 22 $616.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 94 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Defend second-half of deposition of Paul Kloft. Post-deposition conference with Paul Kloft. Prepare for and conduct conference with Paul Kloft and James Kloft in preparation for their depositions. Defend first half of deposition of Paul Kloft. Prepare for and conduct meeting with Paul Kloft and James Kloft to analyze issues relating to their depositions during lunch. 40 03 08 Doug Bragg Doug Bragg Fred Millard $280 $280 $350 40 03 08 $1,120.00 $84.00 $280.00 20 10 Fred Millard Fred Millard $350 $350 20 10 $700.00 $350.00 11/15/12 11/15/12 11/15/12 11/16/12 Telephone calls with John Dalke RE: deposition. Telephone call to Jim Schiess RE: deposition. Assist with preparing exhibits for deposition. Analyze Katharyn Thompson's seed valuation, and spreadsheets prepared comparing her valuation with other experts with Doug Bragg. 02 0.1 03 05 Michele Barbara Michele Barbara Michele Barbara Christopher Fanning $125 $125 $125 $182 00 00 03 00 $0.00 $0.00 $37.50 $0.00 11/16/12 Revise spreadsheet analyzing Katharyn Thompson's valuation and comparison to other experts per discussion with Doug Bragg. 2.4 Christopher Fanning $182 2.4 $436.80 11/16/12 Analyze case needs and status with Fred Millard and Doug Bragg. 0.4 Christopher Fanning $182 0.4 $72.80 11/16/12 Confer with Christopher Fanning analyzing the chart comparing seed valuations between Plaintiff's and Defendant's experts. Confer with Fred Millard analyzing deposition schedule, deposition of Paul Kloft, and deposition of Dalke Construction. Review Second Amended Notice of Depositions from Country. Confer with Michele Barbara analyzing Second Amended Notice of Depositions. Review and analyze latest draft of chart of seed values. Meeting with Fred Millard and Christopher Fanning analyzing logic puzzle (if Katharyn Thompson agrees with Kevin Loe, and Kevin Loe agrees with Precision's experts, then why does Katharyn Thompson disagree with Precision's experts?) relating to seed valuation. 05 Doug Bragg $280 05 $140.00 03 Doug Bragg $280 00 $0.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 05 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 11/16/12 Review and execute notice and subpoena for deposition of John Dalke. 02 Doug Bragg $280 02 $56.00 11/16/12 11/16/12 Review and analyze research on spoliation of evidence. Draft e-memo to Fred Millard analyzing spoliation of evidence issues. 0.4 0.1 Doug Bragg Doug Bragg $280 $280 0.4 0.1 $112.00 $28.00 11/16/12 Confer with Doug Bragg analyzing deposition schedule, deposition of Paul Kloft, and deposition of Dalke Construction. Meeting with Doug Bragg and Christopher Fanning analyzing "logic puzzle" of seed valuation dispute. Telephone call to Jim Schiess with Dalke Construction related to personnel on project and person most knowledgeable related to the paperwork. E-mail to Jim Schiess at Dalke Construction with photos of person driving excavator. Confer with Doug Bragg RE: scheduling depositions for Kevin Loe and David Logan. Email Joan with Dan Thenell's office RE: deposition schedule for Kevin Loe and Dave Logan. Review, analyze, organize and index deposition exhibits for Paul Kloft's deposition. Split photos in 2 separate e-mails to Dalke Construction and phone call to Dalke RE: same. 03 Fred Millard $350 03 $105.00 05 Fred Millard $350 05 $175.00 02 Michele Barbara $125 02 $25.00 0.1 Michele Barbara $125 0.1 $12.50 02 Michele Barbara $125 02 $25.00 0.1 Michele Barbara $125 00 $0.00 10 Michele Barbara $125 10 $125.00 02 Michele Barbara $125 00 $0.00 11/15/12 11/15/12 11/15/12 11/15/12 11/15/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Clerical All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All -Duplicative; billed to M All - Clerical All - Clerical Page 95 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 11/16/12 Email Dalke Construction's documents to Jim Schiess for his assistance in locating the person most knowledgeable related to the records. 0.1 Michele Barbara $125 All - Clerical 00 $0.00 11/16/12 Confer with Doug Bragg analyzing Second Amended Notice of Depositions from Defendant. Email to Joan Brown at Dan Thenell's office for errors in Second Amended Notice and unavailability of Craig Edminster, along with dates for Lynn Davis, Kevin Loe and David Logan. Review Second Amended Notice of Depositions Prepare letter to Paul Kloft regarding Defendant's Second Amended Notice of Depositions. Telephone call to John Dalke to schedule his deposition. Prepare Notice of Deposition for John Dalke's deposition. Prepare Civil Subpoena for John Dalke. Researching the possibility of a fee enhancement as a sanction for spoliation of evidence. Review email from Joan Brown regarding reschedule of Jim Brady's deposition. Review email from Joan Brown confirming new deposition date. 0.1 Michele Barbara $125 All - Duplicative; billed to Bragg 00 $0.00 02 Michele Barbara $125 All - Clerical 00 $0.00 0.1 03 Michele Barbara Michele Barbara $125 $125 All - Clerical All- Clerical 00 00 $0.00 $0.00 02 03 03 1.1 Michele Barbara Michele Barbara Michele Barbara Christopher Fanning $125 $125 $125 $182 All - Clerical All - Clerical All - Clerical 00 00 00 1.1 $0.00 $0.00 $0.00 $200.20 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Fred Millard analyzing possible destruction of evidence by Country and ramifications therefore. Matter conference with Doug Bragg to analyze Spoliation of evidence issue. Telephone call with Client RE: Issues pertaining to discovery, request copies of outstanding bank records, and continue preparing for depositions. Meeting with Doug Bragg and Courtney Pentek to analyze deposition preparation and exhibits. Review documents submitted by Country Mutual and pulling the documents for different depositions. Review and analyze our Requests for Production to see if we ever asked for a Claim Log. Review, analyze and identify exhibits from production for upcoming depositions. E-mailing James Kloft about Rusconi lot and accompanying letter. 0.4 Doug Bragg $280 00 $0.00 0.4 Fred Millard $350 0.4 $140.00 2.7 Fred Millard $350 2.7 $945.00 03 Christopher Fanning $182 00 $0.00 12 Christopher Fanning $182 12 $218.40 0.4 Christopher Fanning $182 0.4 $72.80 38 Christopher Fanning $182 38 $691.60 02 Christopher Fanning $182 02 $36.40 Review Byron Slack's report to determine if he placed value on indent cylinders. Review and analyze deposition outline for Katharyn Thompson. 02 Christopher Fanning $182 02 $36.40 05 Christopher Fanning $182 05 $91.00 11/20/12 Meet with Christopher Fanning and Courtney Pentek analyzing expert deposition schedule and preparation for upcoming depositions. 0.4 Doug Bragg $280 0.4 $112.00 11/20/12 12 Doug Bragg $280 12 $336.00 02 Doug Bragg $280 02 $56.00 11/20/12 11/20/12 Review CMI production documents (945 pages) in preparation for expert depositions. Confer with Christopher Fanning analyzing his review of Country's production and confirm lack of Claim Log. Email Dan Thenell requesting a copy of the Claim Log. Review and revise outline of questions for Jim Brady's deposition. 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 11/20/12 Review and revise outline of questions for Katharyn Thompson. 2.1 Doug Bragg $280 2.1 $588.00 11/20/12 Review/respond to email from Joan Brown regarding reschedule of Jim Brady's deposition. 02 Doug Bragg $280 02 $56.00 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/16/12 11/19/12 11/19/12 11/19/12 11/19/12 11/19/12 11/19/12 11/20/12 11/20/12 11/20/12 11/20/12 11/20/12 11/20/12 11/20/12 11/20/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 96 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 0.1 $28.00 10 Christopher Fanning $182 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 15 Doug Bragg $280 15 $420.00 03 Doug Bragg $280 03 $84.00 05 Doug Bragg $280 05 $140.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 10 Doug Bragg $280 00 $0.00 11/21/12 Review and analyze photographs (500) for potential exhibits in depositions. Review, analyze and respond to email from Maribeth Bonner regarding deposition of Dave Logan. Phone call with Paul Kloft regarding bank record request and depositions of Dave Logan and Katharyn Thompson. Phone call with Sanitation company regarding records. Email Maribeth Bonner, Dan Thenell and Joan Brown regarding bank record request and follow up with request for Claim Log and photograph requests. Confer with Fred Millard analyzing seed quantity issues and possible spoliation of evidence. Phone call with Kurt at Pacific Sanitation regarding dumpster pick-up. 02 Doug Bragg $280 02 $56.00 11/21/12 Phone call with James Kloft regarding clean up of seed post-fire. 02 Doug Bragg $280 02 $56.00 11/21/12 Review slip for delivery of dumpster of seed to Compost Oregon. 0.1 Doug Bragg $280 0.1 $28.00 11/21/12 Confer with Courtney Pentek regarding status of deposition scheduling. 0.1 Doug Bragg $280 0.1 $28.00 11/21/12 02 Doug Bragg $280 02 $56.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 11/21/12 Email Dan Thenell regarding status of The Scotts Company deposition and Jim Brady's deposition. Review email from Client with bank statements. Direct Courtney Pentek to bates number the bank statements for production. Review email from Mike Billman regarding deposition schedule. 0.1 Doug Bragg $280 0.1 $28.00 11/21/12 Review email from Joan Brown regarding Jim Brady's deposition. 0.1 Doug Bragg $280 0.1 $28.00 11/21/12 11/21/12 11/21/12 Execute Amended Notice of Deposition for Jim Brady. Outline deposition questions for David Logan. Confer with Fred Millard and Christopher Fanning analyzing issues relating to inventory of seed, David Logan's recommendation to take an inventory after the fire, and Dan Thenell's apparent decision to not conduct that recommended inventory. 0.1 1.6 10 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 1.6 00 $28.00 $448.00 $0.00 11/21/12 Email Greg Mettler regarding possible supplemental report for consequential damages. Confer with Doug Bragg analyzing seed quantity issues and possible spoliation of evidence. Confer with Doug Bragg and Christopher Fanning analyzing issues relating to inventory of seed, David Logan's recommendation to take an inventory after the fire, and Dan Thenell's apparent decision to not conduct that recommended inventory. 0.1 Doug Bragg $280 0.1 $28.00 10 Fred Millard $350 10 $350.00 10 Fred Millard $350 10 $350.00 11/20/12 11/20/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 11/21/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review/respond to email from Dan Thenell regarding reschedule of Jim Brady's deposition. Email Joan Brown to confirm date for The Scotts Company deposition. 02 Doug Bragg 0.1 Confer with Fred Millard and Doug Bragg analyzing issues relating to inventory of seed, David Logan's recommendation to take an inventory after the fire, and Dan Thenell's apparent decision to not conduct that recommended inventory. Phone call with Maribeth Bonner regarding deposition scheduling. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 97 of 161 Date Hrs Awarded Amount All - Duplicative; billed to Millard 02 0.1 00 $36.40 $18.20 $0.00 $50 All - Clerical 00 $0.00 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 2.7 Fred Millard $350 2.7 $945.00 18 12 Christopher Fanning Christopher Fanning $182 $182 18 12 $327.60 $218.40 03 10 Christopher Fanning Doug Bragg $182 $280 03 00 $54.60 $0.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Meet with DJ Myers and Fred Millard to prepare for DJ Myers' deposition. Meet with Fred Millard to analyze the deposition of DJ Myers. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 10 02 Doug Bragg Doug Bragg $280 $280 10 02 $280.00 $56.00 11/27/12 Confer with Fred Millard to analyze the status of discovery and additional depositions. Revise outline of deposition questions for Jim Brady. Phone call with Dan Thenell regarding Jim Brady deposition and Claim Log. Review email from Dan Thenell regarding status of Claim Log request. 0.1 Doug Bragg $280 0.1 $28.00 11/27/12 11/27/12 Review and analyze redacted Claim Log. Review email from Fred Millard regarding Claim Log. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 11/27/12 Draft e-memo to Fred Millard and Christopher Fanning analyzing potential fraud claim based upon investigation (or lack thereof) from David Logan's report. Matter conference with Doug Bragg to review and analyze Issues pertaining to settlement raised by Country. Meet with DJ Myers and Doug Bragg in preparation for DJ Myers' deposition. Meet with Doug Bragg analyzing deposition of DJ Myers. Meet with Doug Bragg analyzing status of discovery and additional deadlines. Draft email to Doug Bragg regarding Claim Log. Defend DJ Myers' deposition. Compile and organize expert reports for Doug Bragg in preparation of Brady deposition. Review and analyze issues related to breach of the covenant of good faith and fair dealing with Doug Bragg. Prepare and email Client regarding potential damages for breach of the covenant of good faith and fair dealing. Prepared exhibits for Katharyn Thompson's deposition. Finish reviewing and analyzing the Claim Log. 02 Doug Bragg $280 02 $56.00 10 Fred Millard $350 10 $350.00 03 Fred Millard $350 03 $105.00 03 03 Fred Millard Fred Millard $350 $350 03 03 $105.00 $105.00 02 1.1 0.1 Fred Millard Fred Millard Christopher Fanning $350 $350 $182 02 1.1 0.1 $70.00 $385.00 $18.20 0.1 Christopher Fanning $182 00 $0.00 02 Christopher Fanning $182 02 $36.40 10 0.6 Courtney Pentek Doug Bragg $50 $280 00 0.6 $0.00 $168.00 11/23/12 11/23/12 11/26/12 11/26/12 11/26/12 11/26/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/27/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Prepare exhibits for depositions. Direct Courtney Pentek to prepare deposition exhibits. Analyze discovery and spoliation issues with Doug Bragg and Fred Millard. Prepare Amended Deposition Subpoenas for Jim Brady and David Logan, and serve Country. Prepare for and conduct status meeting with staff analyzing Discovery issues and Spoliation. Prepare for and conduct status meeting with staff analyzing Discovery issues and Spoliation. Research issues relating to attorney being a fact witness. Researching attorney-client privilege fraud exception and definition of rendering legal services. Analyze issues with a possible fraud claim with Doug Bragg. Confer with Fred Millard to review and analyze issues relating to settlement raised by Country. Draft letter to Dan Thenell requesting documents for David Logan's deposition. Review David Logan's reports and outline deposition questions. 02 0.1 2.7 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 0.4 Courtney Pentek 2.7 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Clerical Page 98 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Prepare for deposition of Jim Brady, review exhibits, prepare Claim Log exhibit. Confer with Fred Millard analyzing Claim Log. Phone call with Dannielle Booth regarding deposition of Jim Brady. 10 Doug Bragg $280 10 $280.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 11/28/12 Phone call with James Kloft regarding consequential damages for breach of the implied covenant of good faith and fair dealing. 02 Doug Bragg $280 02 $56.00 11/28/12 Confer with Christopher Fanning regarding facts to support damages for the breach of the implied covenant of good faith and fair dealing. 02 Doug Bragg $280 02 $56.00 11/28/12 02 Doug Bragg $280 02 $56.00 11/28/12 Phone call with James Kloft regarding preparation for the deposition of Jim Brady. Travel to/from Dan Thenell's office; Conduct deposition of Jim Brady. 23 Doug Bragg $280 23 $644.00 11/28/12 Phone call with James Kloft analyzing the deposition of Jim Brady. 0.1 Doug Bragg $280 0.1 $28.00 11/28/12 11/28/12 Draft letter to Dan Thenell regarding outstanding discovery. Confer with Fred Millard analyzing the deposition of Jim Brady and upcoming deposition with Katharyn Thompson. Phone call with Paul Kloft and Fred Millard analyzing the deposition of Jim Brady. Phone call with Paul Kloft regarding preparation for the deposition of Katharyn Thompson. Review and analyze documents from James Kloft relating to the preparation for the deposition of Katharyn Thompson. Phone call with James Kloft analyzing issues in preparation for the deposition of Katharyn Thompson. Review and analyze additional documents from James Kloft relating to the preparation for the deposition of Katharyn Thompson. 02 10 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 02 00 $56.00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Second phone call with James Kloft regarding deposition of Katharyn Thompson. Review and analyze Katharyn Thompson's report and compare to actual testing standards as provided by James Kloft in preparation for deposition. Confer with Doug Bragg analyzing Claim Log. Confer with Doug Bragg to analyze deposition of Jim Brady and to assist in preparation for the deposition with Katharyn Thompson. 02 Doug Bragg $280 02 $56.00 08 Doug Bragg $280 08 $224.00 02 10 Fred Millard Fred Millard $350 $350 02 10 $70.00 $350.00 Prepare for and conduct phone call with Paul Kloft and Doug Bragg analyzing deposition of Jim Brady. Prepare for and conduct meeting with Doug Bragg and Paul Kloft to prepare for the deposition of Katharyn Thompson. Review and develop deposition questions for Doug Bragg in preparation of deposition of Katharyn Thompson. Review and analyze David Logan's rebuttal report and draft questions for the deposition. Travel to/from Dan Thenell's office; Review and analyze several bankers boxes of documents made available by Katharyn Thompson to identify potential exhibits to use in Katharyn Thompson's deposition. 02 Fred Millard $350 02 $70.00 15 Fred Millard $350 15 $525.00 02 Christopher Fanning $182 02 $36.40 1.1 Christopher Fanning $182 1.1 $200.20 5.1 Christopher Fanning $182 5.1 $928.20 Researching and analyzing Daubert and shepardizing it for recent decisions. 0.6 Christopher Fanning $182 0.6 $109.20 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/28/12 11/29/12 11/29/12 11/29/12 11/29/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 99 of 161 Date Hrs Awarded Amount 05 $140.00 00 $0.00 $280 09 $252.00 Doug Bragg $280 02 $56.00 1.7 Doug Bragg $280 1.7 $476.00 Travel to/from Dan Thenell's office; Conduct Deposition of Katharyn Thompson. Prepare for deposition of Dave Logan (review and analyze documents for possible exhibits). Travel to/from Dan Thenell's office; Conduct deposition of Dave Logan. 65 Doug Bragg $280 65 $1,820.00 05 Doug Bragg $280 05 $140.00 58 Doug Bragg $280 58 $1,624.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 11/30/12 12/3/12 12/3/12 Phone call with Michael Rodrigue analyzing photographs from cause and origin investigators. Prepare for and conduct meeting with Fred Millard analyzing deposition of Dave Logan. Confer with Doug Bragg analyzing deposition of Dave Logan. Review various emails regarding deposition schedule. Respond to email from Dan Thenell regarding deposition schedule. 03 02 0.1 Fred Millard Doug Bragg Doug Bragg $350 $280 $280 03 02 0.1 $105.00 $56.00 $28.00 12/4/12 Review/respond to email from Joan Brown regarding Dalke deposition. 0.1 Doug Bragg $280 0.1 $28.00 12/5/12 Phone call with James Kloft analyzing photographs of dumpsters at the fire scene. Phone call with Don Kelley regarding trial date. Preparing questions for deposition of custodian of records for Dalke excavation. Researching and analyzing potential enhancement on attorney fees for improper conduct. Review and analyze case with Fred Millard and Doug Bragg. Discussed fee enhancement and strategy for moving forward on spoliation issues. 02 Doug Bragg $280 02 $56.00 02 03 Doug Bragg Christopher Fanning $280 $182 02 03 $56.00 $54.60 15 Christopher Fanning $182 15 $273.00 05 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 Further analyze spoliation and the case in general with Fred Millard and Doug Bragg. Researching ethics opinions and RPC 3.4 regarding spoliation of evidence by attorney. Confirm with Joan Brown the updated deposition schedule. Prepare exhibits for John Dalke's deposition. Prepare email to Michael Billman, Trevor Abbott, and Michael Rodrigue analyzing their attendance at Kevin Loe and Byron Slack depositions. 0.4 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 1.1 Christopher Fanning $182 1.1 $200.20 0.1 20 0.1 Courtney Pentek Courtney Pentek Courtney Pentek $50 $50 $50 All - Clerical All - Clerical All - Clerical 00 00 00 $0.00 $0.00 $0.00 12/6/12 Prepare deposition exhibits for John Dalke's deposition on 12/7/12. 02 Courtney Pentek $50 All - Clerical 00 $0.00 12/6/12 Confer with Christopher Fanning analyzing deposition questions for Dalke's Custodian of Records. Prepare for deposition of John Dalke (review and analyze exhibits and prepare outline of questions). 0.1 Doug Bragg $280 0.1 $28.00 0.4 Doug Bragg $280 0.4 $112.00 11/29/12 11/29/12 11/29/12 11/29/12 11/29/12 11/29/12 11/30/12 11/30/12 11/30/12 11/30/12 12/5/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review Reply Brief in relation to FRE 702 objections for purposes of verifying questions for Daubert Hearing. Prepare for and conduct meeting with Fred Millard and Paul Kloft to prepare for the deposition of Katharyn Thompson. Review and analyze the attachments to David Logan's reports not previously produced ( 848 pages). Email Dan Thenell regarding reschedule of deposition due to late last minute discovery. Prepare for deposition of Katharyn Thompson (develop questions on quality standards, consider additional exhibits, complete review of various seed expert reports as exhibits for deposition). 05 Doug Bragg $280 15 Doug Bragg $280 09 Doug Bragg 02 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard on 11/28/12 All- Duplicative; billed to Millard Page 100 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 02 Hrs Deducted by Court and Reason $56.00 12/6/12 Review, analyze and respond to email from Joan Brown regarding deposition of Kevin Loe, The Scotts Co. and Byron Slack. 02 Doug Bragg $280 12/6/12 Confer with Fred Millard to prepare for the deposition of Byron Slack. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 12/6/12 Review and analyze the case with Fred Millard and Christopher Fanning. Discussed fee enhancement and strategy for moving forward on spoliation issues. Further analysis of spoliation and the case in general with Fred Millard and Christopher Fanning. Confer with Courtney Pentek analyzing deposition schedule. Review and analyze various emails between offices and latest round of notices relating to the deposition schedule. Confer with Doug Bragg to assist with preparations for the deposition of Byron Slack. Review and analyze case with Christopher Fanning and Doug Bragg. Discussed fee enhancement and strategy for moving forward on spoliation issues. Further analysis of spoliation and the case in general with Christopher Fanning and Doug Bragg. Review and analyze documents (1 banker box) that we were given at the David Logan deposition. Analyze spoliation motion with Doug Bragg. 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.4 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 03 Fred Millard $350 03 $105.00 05 Fred Millard $350 05 $175.00 0.4 Fred Millard $350 0.4 $140.00 23 Christopher Fanning $182 23 $418.60 03 Christopher Fanning $182 00 $0.00 Review, analyze and prepare documents in preparation of deposition of Byron Slack. Draft motion to compel deposition of Kevin Loe. Researching rules on expert discovery for Motion to Compel. Prepare deposition exhibits for Byron Slack's deposition. Travel to/from deposition in Salem for John Dalke and Dalke Construction. Conduct deposition of John Dalke and deposition of Dalke Construction. 02 Christopher Fanning $182 02 $36.40 1.6 0.7 10 1.6 Christopher Fanning Christopher Fanning Courtney Pentek Doug Bragg $182 $182 $50 $280 1.6 0.7 00 1.6 $291.20 $127.40 $0.00 $448.00 10 Doug Bragg $280 10 $280.00 Review and analyze emails from James Kloft relating to photographs of equipment in the fire. Review, analyze and respond to emails from Joan Brown regarding scheduling of Kevin Loe's deposition. Confer with Fred Millard analyzing issues in scheduling Kevin Loe's deposition. Confer with Fred Millard analyzing deposition of John Dalke. 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All -Duplicative; billed to Millard 00 $0.00 Confer with Christopher Fanning analyzing Motion for Discovery Sanctions for Spoliation of Evidence. Direct Courtney Pentek to review and identify correspondence to support Motion to Compel deposition of Kevin Loe. Email Dan Thenell regarding motion to compel deposition of Kevin Loe. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Review and analyze documents for use as exhibits in Byron Slack's deposition. Review and revise questions for Byron Slack deposition. Prepare for and conduct phone call with James Kloft analyzing photographs for Byron Slack's deposition. Draft Motion to Compel Deposition of Kevin Loe. Prepare for and conduct phone call with Dan Thenell regarding the deposition of Kevin Loe. 02 Doug Bragg $280 02 $56.00 05 02 Doug Bragg Doug Bragg $280 $280 05 02 $140.00 $56.00 05 02 Doug Bragg Doug Bragg $280 $280 05 02 $140.00 $56.00 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/6/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 12/7/12 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Bragg All - Clerical Page 101 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.1 Doug Bragg 0.1 12/7/12 Phone call with Danielle Booth regarding her lack of authority to discuss the case. Phone call with Dannielle Booth regarding Motion to Compel Deposition of Kevin Loe. Confer with Doug Bragg analyzing issues in scheduling Loe's deposition. $280 0.1 $28.00 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 12/7/12 12/10/12 Confer with Doug Bragg analyzing deposition of John Dalke. Review, compile and organize documents for Byron Slack's deposition. 03 0.6 Fred Millard Christopher Fanning $350 $182 03 0.6 $105.00 $109.20 12/10/12 Review and correct citations in memorandum in support of motion to compel deposition of Kevin Loe, and draft declaration of Doug Bragg. 22 Christopher Fanning $182 22 $400.40 12/10/12 Prepare for and conduct meeting with Doug Bragg and Christopher Fanning analyzing status of discovery, additional requests from Country, and analyze issues for Daubert hearing following Katharyn Thompson and Byron Slack's depositions. Review Katharyn Thompson's deposition transcript. Email Joan Brown Umpqua Bank Statements in response to their request. Arrange and coordinate service for delivery of Judge's copy of Motion to Compel. Confirm with Joan Brown at Dan Thenell's office that Mike Billman and Kim Ellingson depositions are still going forward. Email Greg Mettler regarding rescheduling his deposition. Email Mike Billman, Trevor Abbott and Craig Edminster to verify they will be available for Kevin Loe's deposition. Email court reporter to change Kevin Loe's deposition date and to add videographer. Email Craig Edminster regarding his availability for his deposition. 1.6 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 10 0.1 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 10 00 $182.00 $0.00 02 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 0.1 Courtney Pentek Courtney Pentek $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 Email Nick Priest to reschedule deposition. Prepare Amended Notice of Deposition for Kevin Loe, and serve on Dan Thenell. Review and analyze caselaw relating to Motion to Compel expert deposition and revise draft Motion to Compel Deposition of Kevin Loe. 0.1 05 Courtney Pentek Courtney Pentek $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 15 Doug Bragg $280 15 $420.00 Review notices of depositions and emails relating to deposition scheduling. Prepare for Byron Slack's deposition. Travel to/from Dan Thenell's office; Conduct deposition of Byron Slack. 03 Doug Bragg $280 03 $84.00 10 3.6 Doug Bragg Doug Bragg $280 $280 10 3.6 $280.00 $1,008.00 12/10/12 12/10/12 Phone call with Paul Kloft regarding Byron Slack's deposition. Confer with Fred Millard and Christopher Fanning analyzing status of discovery, additional requests from Dan Thenell, and issues for Daubert hearing following Katharyn Thompson and Byron Slack's depositions. 03 1.6 Doug Bragg Doug Bragg $280 $280 03 00 $84.00 $0.00 12/10/12 Prepare for and conduct meeting with Doug Bragg and Christopher Fanning analyzing status of discovery, additional requests from Country, and analyze issues for Daubert hearing following Katharyn Thompson and Byron Slack's depositions. Continuing research on the possibility of a fee enhancement. Specifically focusing on the factors discussed in ORS 20.075. 1.6 Fred Millard $350 1.6 $560.00 10 Christopher Fanning $182 10 $182.00 12/7/12 12/7/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/10/12 12/11/12 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 102 of 161 Date Hrs Awarded Amount 15 $273.00 0.7 00 00 $127.40 $0.00 $0.00 $280 02 $56.00 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 Confer with Courtney Pentek regarding gathering and organizing documents relating to scheduled and unscheduled equipment valuation. Review, analyze and respond to email from Joan Brown regarding status of additional document requests, and re-request photographs and other documents discussed in recent depositions. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Phone call with Paul Kloft analyzing additional damages due to inability to rebuild. Review final draft of Motion to Compel. Review emails from Maribeth Bonner regarding The Scotts Co. deposition, Kevin Loe's deposition, and document requests. Review/respond to email from Maribeth Bonner regarding deposition of The Scotts Co. Review, analyze and respond to emails from Maribeth Bonner regarding bank records prior to May of 2009. File Expedited Motion to Compel deposition of Kevin Loe. Phone call with Michelle Rawson regarding Expedited Motion to Compel Deposition of Kevin Loe. Phone call with Maribeth Bonner regarding deposition of Kevin Loe. 02 Doug Bragg $280 02 $56.00 0.4 0.1 Doug Bragg Doug Bragg $280 $280 0.4 0.1 $112.00 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 00 0.1 $0.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 12/11/12 Direct Courtney Pentek to cancel Nick Priest's deposition for the 19th, to calendar Kevin Loe's for the 19th, and to prepare another notice of deposition for Kevin Loe for the 19th of December. 0.1 Doug Bragg $280 0.1 $28.00 12/11/12 Review and analyze various emails from Joan Brown and Maribeth Bonner regarding deposition scheduling. Review email from Trevor Abbott regarding attending deposition of Kevin Loe. Review email from Mike Billman regarding attending deposition of Kevin Loe. Confer with Fred Millard analyzing status of discovery issues, motion to compel, and impact of Byron Slack's testimony on spoliation of evidence concern. Confer with Christopher Fanning analyzing Motion to Compel Deposition of Kevin Loe. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 1.1 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 12/11/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze e-mails related to planning deposition of Kevin Loe, and revise Motion to Compel Deposition of Kevin Loe based upon review of emails, as well as update the declaration of Douglas Bragg in Support of the Motion to Compel to include various additional email support. Prepare exhibits for Motion to Compel. Email to Joan at Thenell's office RE: Umpqua Bank Statements. Prepare and organize Robert Halsey, Michael Rodrigue and Byron Slack's Equipment Lists for Doug Bragg to review. Review and analyze emails and time records in November relating to scheduling Kevin Loe's deposition. Review email from Joan Brown requesting additional discovery. 15 Christopher Fanning $182 0.7 0.1 02 Christopher Fanning Courtney Pentek Courtney Pentek $182 $50 $50 02 Doug Bragg 0.1 Confer with Courtney Pentek regarding status of rescheduling Craig Edminster's deposition. Review and analyze Interrogatory No. 3 and begin to draft supplemental response including specific dollar amounts by category. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Clerical All - Clerical All - Duplicative; billed to Millard Page 103 of 161 Date Hrs Awarded Amount $280 02 $56.00 Fred Millard $350 1.1 $385.00 03 0.1 Christopher Fanning Christopher Fanning $182 $182 03 0.1 $54.60 $18.20 Review email from Maribeth Bonner regarding deposition of The Scotts Co.'s person most knowledgeable. Review email from Maribeth Bonner regarding withdrawal of Motion to Compel. Confer with Christopher Fanning regarding withdrawal of Motion to Compel. Respond to email from Maribeth Bonner regarding withdrawal of Motion to Compel. Email Maribeth Bonner and Sara Cotton regarding scope of The Scotts Company deposition. Compare and analyze Michael Rodrigue's and Robert Halsey's valuations as part of review of potential supplement to interrogatory from Country. Review analyze and respond to email from Maribeth Bonner regarding production of photographs. Matter conference with Don Kelley RE: Issues for trial, Tenant improvements, and Ionian Rule 21 issues Identify, organize and prepare documents for Kevin Loe deposition. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 1.4 Doug Bragg $280 1.4 $392.00 02 Doug Bragg $280 02 $56.00 02 Fred Millard $350 02 $70.00 1.7 Christopher Fanning $182 1.7 $309.40 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 12/13/12 Confer with Christopher Fanning analyzing review of David Logan's and Katharyn Thompson's documents for purposes of identifying exhibits for Kevin Loe's deposition. Review and analyze emails from client regarding consequential damages. Update Draft supplemental response to Request for Production to include additional consequential damages. Travel to/from deposition; Conduct deposition of The Scotts Company. 3.4 Doug Bragg $280 3.4 $952.00 12/13/12 12/14/12 Phone call with Dan Hemshorn about seed values. Compile, copy and organize documents for deposition of Kevin Loe. 02 09 Doug Bragg Christopher Fanning $280 $182 02 09 $56.00 $163.80 12/14/12 Review and analyze Robert Halsey's and Michael Rodrigue's equipment lists and input Actual Cash Value totals in table for Doug Bragg to review and analyze. Research and analyze issues for Motion for Sanctions for Spoliation of Evidence. Researching ORPC 3.3 and ORPC 3.4 relating to attorney as witness and spoliation of evidence in attorney's presence. Compile, organize and prepare exhibits for Kevin Loe's deposition. 19 Courtney Pentek $50 19 $95.00 03 Doug Bragg $280 03 $84.00 0.7 Christopher Fanning $182 0.7 $127.40 08 Christopher Fanning $182 08 $145.60 12/17/12 Attend meeting with Fred Millard and Doug Bragg to analyze Motion to Amend Complaint, Motion for Spoliation Sanctions and attorney fees. 10 Christopher Fanning $182 00 $0.00 12/17/12 12/17/12 Meet with Mike Billman to prepare for his deposition. Defend deposition of Mike Billman. 0.6 20 Doug Bragg Doug Bragg $280 $280 0.6 20 $168.00 $560.00 12/11/12 12/11/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/12/12 12/13/12 12/13/12 12/13/12 12/13/12 12/14/12 12/17/12 12/17/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze email from Joan Brown regarding pre-May 2009 bank records for Umpqua account; Review emails from Client regarding Umpqua Bank Records and Respond to email from Joan Brown regarding bank record production. Matter conference with Doug Bragg analyzing status of discovery issues, motion to compel, and impact of Byron Slack's testimony on spoliation of evidence concern. Finish researching attorney fee enhancement. Draft Withdrawal of Motion to Compel Deposition of Kevin Loe. 02 Doug Bragg 1.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard Page 104 of 161 Date 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/17/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/18/12 12/19/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Meet with Mike Billman analyzing his deposition and prepare for the deposition of Kevin Loe. Review and analyze documents to prepare for deposition of Kevin Loe. 10 Doug Bragg $280 10 $280.00 1.7 Doug Bragg $280 1.7 $476.00 Review analyze and respond to email from Dan Thenell regarding deposition of Mike Billman, Deposition of Nick Priest, and possible additional depositions. Email Mike Billman regarding confirmation of his numbers in his report. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Review/respond to email from Joan Brown regarding Quickbooks records. Email Fred Millard and Christopher Fanning analyzing Quickbooks request. Confer with Courtney Pentek regarding deposition of Greg Mettler. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 E-memo to Courtney Pentek regarding possible additional depositions to be scheduled by Country. Review and analyze supplemental report from Katharyn Thompson. 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 Prepare for and conduct meeting with Fred Millard and Christopher Fanning to analyze Motion to Amend Complaint, Motion for Spoliation Sanctions and attorney fees. Attend meeting with Doug Bragg and Christopher Fanning to analyze Motion to Amend Complaint, Motion for Spoliation Sanctions and attorney fees. Review email from Doug Bragg analyzing Quickbooks request. Review and analyze Defendant's discovery requests for Quickbooks. 10 Doug Bragg $280 00 $0.00 10 Fred Millard $350 10 $350.00 0.1 02 Fred Millard Christopher Fanning $350 $182 0.1 02 $35.00 $36.40 Analyze exhibits from Kevin Loe's deposition and update chart of seed lots to include Kevin Loe's latest values. Analyzing case and Daubert preparations with Fred Millard and Doug Bragg. Analyzing and updating seed charts to include Kevin Loe's agreed values with Doug Bragg. Prepare for deposition of Kevin Loe. Travel to/from deposition of Kevin Loe; Conduct deposition of Kevin Loe. Confer with Fred Millard analyzing deposition of Kevin Loe. 03 Christopher Fanning $182 03 $54.60 12 Christopher Fanning $182 12 $218.40 0.4 Christopher Fanning $182 0.1 $18.20 13 43 Doug Bragg Doug Bragg $280 $280 13 43 $364.00 $1,204.00 03 Doug Bragg $280 00 $0.00 Confer with Christopher Fanning analyzing deposition of Kevin Loe and revision to chart to include new agreed upon seed information from Kevin Loe. Review and analyze additional discovery from Byron Slack ( 459 pages). 03 Doug Bragg $280 03 $84.00 0.6 Doug Bragg $280 0.6 $168.00 Research issues relating to failing to produce an expert report or untimely production of expert report. Confer with Fred Millard analyzing possible Motion to Exclude Kevin Loe's testimony based upon failure to comply with expert filing requirements. Confer with Doug Bragg analyzing deposition of Kevin Loe. Confer with Doug Bragg analyzing possible Motion to Exclude Kevin Loe's testimony based upon failure to comply with expert filing requirements. Review and analyze seed lot valuation report and updating chart to show where Kevin Loe agrees based on his deposition. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 03 03 Fred Millard Fred Millard $350 $350 03 03 $105.00 $105.00 2.4 Christopher Fanning $182 2.4 $436.80 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard 0.3 Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 105 of 161 Date Hrs Awarded Amount $182 09 $163.80 Christopher Fanning $182 1.6 $291.20 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze deposition transcripts for purposes of assembling facts to support Motions for Discovery Sanctions and to amend for Bad Faith. Phone call with James Kloft analyzing deposition of Kevin Loe, screen summary, and calculation of damages. Review and analyze Paul Kloft's deposition transcript. Analyzing timeline and facts related to Spoliation Motion and Motion to Amend with Fred Millard and Doug Bragg. Review deposition excerpts in preparation for drafting Motion to Amend our Complaint and Motion for Spoliation Sanctions. Organizing facts and documents to support our fact section in our Motion to Amend Complaint and Motion for Spoliation Sanctions. 28 Doug Bragg $280 28 $784.00 0.6 Doug Bragg $280 0.6 $168.00 10 0.6 Christopher Fanning Christopher Fanning $182 $182 10 00 $182.00 $0.00 1.1 Christopher Fanning $182 1.1 $200.20 08 Christopher Fanning $182 08 $145.60 Email to Court Reporter checking up with status on David Logan's deposition transcript. Confer with Christopher Fanning analyzing his review of Paul Kloft's deposition transcript. Analyzing timeline and facts related to Spoliation Motion and Motion to Amend with Fred Millard and Christopher Fanning. Analyzing timeline and facts related to Spoliation Motion and Motion to Amend with Doug Bragg and Christopher Fanning. Proofread final settlement letter to Dan Thenell and transmit to Dan Thenell. Draft letter to Dan Thenell regarding counter-offer and settlement discussions. Analyze settlement letter with Fred Millard. 0.1 Courtney Pentek $50 00 $0.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 00 $0.00 0.6 Fred Millard $350 0.6 $210.00 0.4 Courtney Pentek $50 00 $0.00 05 Doug Bragg $280 05 $140.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 12/21/12 12/21/12 12/26/12 Review and analyze Settlement letter to Dan Thenell. Analyze settlement letter with Doug Bragg. Compose and send follow up email regarding Dan Thenell's request for additional breakdown of Michael Rodrigue's invoice to expert. 03 03 0.1 Fred Millard Fred Millard Heidi Gross $350 $350 $50 All - Clerical 03 03 00 $105.00 $105.00 $0.00 12/27/12 Review and analyze updated chart from Mike Billman and making sure the numbers match up. Compose and send e-mail to Mike Billman with questions about his latest chart. Calculate and analyze difference between the old numbers from Mike Billman and the new numbers from Mike Billman. Email to Greg Mettler and Nick Priest to verify they are available for January 3rd deposition. Review e-mail from Mike Billman and making sure that the right numbers are in our chart. Review and analyze seed expert charts and to verify accuracy of master seed valuation chart. Review and analyze the difference between Mike Billman's initial chart and his updated chart. Review and responding to e-mails from Fred Millard on deposition schedule. 19 Christopher Fanning $182 19 $345.80 09 Christopher Fanning $182 09 $163.80 02 Christopher Fanning $182 02 $36.40 02 Courtney Pentek $50 00 $0.00 0.4 Christopher Fanning $182 0.4 $72.80 08 Christopher Fanning $182 08 $145.60 0.4 Christopher Fanning $182 0.4 $72.80 0.1 Christopher Fanning $182 00 $0.00 12/19/12 12/19/12 12/19/12 12/19/12 12/19/12 12/20/12 12/20/12 12/20/12 12/20/12 12/20/12 12/20/12 12/20/12 12/20/12 12/21/12 12/21/12 12/21/12 12/27/12 12/27/12 12/27/12 12/28/12 12/28/12 12/28/12 12/31/12 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze deposition transcript of Jim Brady for discussion of the spoliation. Review and analyze deposition transcript from deposition of Paul Kloft for discussion of spoliation. Review notice from court regarding withdrawal of Motion to Compel. 09 Christopher Fanning 1.6 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard All - Clerical All - Clerical All - Duplicative; billed to Millard Page 106 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 12/31/12 Review Dalke deposition transcript and pulling important quotes for the Motion for Leave to Amend and Motion for Spoliation. 1.6 Christopher Fanning $182 1.6 $291.20 12/31/12 Updating fact section on the Motion for Leave to Amend and Motion for Spoliation Sanctions. Follow up with Doug Bragg and Fred Millard regarding Nick Priest's availability to be deposed on January 3, 2013; Fwd email to Fred Millard regarding deposition scheduling for response. 0.7 Christopher Fanning $182 0.7 $127.40 02 Courtney Pentek $50 00 $0.00 Review and responding to email from Christopher Fanning on deposition schedule. Confer with Doug Bragg re: West Coast bank inquiry sent by Don Kelley on Friday, the 27th; Attempt to call Don's office - no voicemail and no one answering the phone; Telephone call with Doug Bragg informing him of the situation; Per Doug Bragg, telephone call to Hunter Emericks from West Coast; neither he nor assistant available; Left voicemail re: unable to provide Kelley the requested information until the 4th. 0.1 Fred Millard $350 0.1 $35.00 03 Heidi Gross $50 All - Clerical 00 $0.00 1/2/13 Compose email to Fred Millard RE: Nick Priest's deposition date. 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1/2/13 Review and respond to emails RE: Nick Priest's deposition and confirming court reporter, date and time. Compose Email to Craig Edminster requesting available dates for deposition in January. Compose Email to Nick Priest attaching his report for use in his deposition. Compose Email to Christina Medina at Dan Thenell's office RE: deposition dates for Greg Mettler. Phone call with Christina Medina at Dan Thenell's office RE: Nick Priest's deposition location, court reporter, etc. Compose Email to Maribeth Bonner at Dan Thenell's office RE: Nick Priest's expert report. Prepare summaries and outlines of Katharyn Thompson's and Kevin Loe's depositions. Confer with Fred Millard in preparation for deposition of Nick Priest. 02 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1.4 Doug Bragg $280 1.4 $392.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1/3/13 1/3/13 Confer with Fred Millard and Nick Priest in preparation for Nick Priest's deposition. Confer with Fred Millard analyzing Dan Thenell's deposition of Nick Priest and review and analyze potential issues for trial. Phone call with Don Kelley regarding case status update. Email Don Kelley case status update and possible settlement update. 0.4 0.4 Doug Bragg Doug Bragg $280 $280 0.4 0.4 $112.00 $112.00 1/3/13 Confer with Heidi Gross analyzing Wells Fargo request per Don Kelley. 0.1 Doug Bragg $280 0.1 $28.00 1/3/13 1/3/13 1/3/13 Prepare for Nick Priest's Deposition. Telephone call with Nick Priest to prepare for his deposition. Review and analyze Nick Priest's report and supporting documents in preparation for his deposition. Confer with Doug Bragg analyzing deposition of Nick Priest. Confer with Doug Bragg analyzing Dan Thenell's deposition of Nick Priest and analyze potential issues for trial. Defend Nick Priest's Depositon at Thenell's office via Skype. Continue review and analysis of Katharyn Thompson's Deposition Transcript. 10 02 09 Fred Millard Fred Millard Fred Millard $350 $350 $350 10 02 09 $350.00 $70.00 $315.00 0.4 02 Fred Millard Fred Millard $350 $350 0.4 02 $140.00 $70.00 19 0.4 Fred Millard Fred Millard $350 $350 19 0.4 $665.00 $140.00 12/31/12 12/31/12 12/31/12 1/2/13 1/2/13 1/2/13 1/2/13 1/2/13 1/2/13 1/3/13 1/3/13 1/3/13 1/3/13 1/3/13 1/3/13 1/3/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical Page 107 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount All - Duplicative; billed to Bragg 00 $0.00 All - Clerical 05 0.1 00 $25.00 $5.00 $0.00 00 0.1 $0.00 $28.00 1/3/13 Confer with Doug Bragg analyzing Wells Fargo request per Don Kelley. 0.1 Heidi Gross $50 1/3/13 1/3/13 1/4/13 Begin research information requested by Wells Fargo. Create spreadsheet for Wells Fargo requests. Email to Craig Edminster RE: confirming 1/8/13 deposition date. 05 0.1 0.1 Heidi Gross Heidi Gross Courtney Pentek $50 $50 $50 1/4/13 1/4/13 Email to Greg Mettler RE: confirming 1/18/13 deposition date. Phone call with James Kloft regarding Response to Financial Records Request from Country as well as discuss depositions review. 0.1 0.1 Courtney Pentek Doug Bragg $50 $280 1/7/13 1/7/13 Review and analyze deposition transcript of David Logan. Analyze Motion to Amend and Motion for Sanctions for Spoliation with Doug Bragg. Re-draft the facts section of the Motion to Amend and Motion for Sanctions for Spoliation to incorporate more direct quotes to ensure accuracy. Email to Craig Edminster informing him to bring entire file with him to deposition, per Country's request. Compose email to Joan Brown and Christina Medina at Dan Thenell's office to correct Greg Mettler's deposition date and location. 22 02 Christopher Fanning Christopher Fanning $182 $182 22 02 $400.40 $36.40 2.4 Christopher Fanning $182 2.4 $436.80 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1/7/13 1/7/13 Email to Greg Mettler confirming deposition date. Email to Joan Brown at Dan Thenell's office to change deposition locations of plaintiff's experts and witnesses to our office. 0.1 0.1 Courtney Pentek Courtney Pentek $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 1/7/13 Email to Christina Medina at Dan Thenell's office regarding James Kloft being unavailable for a deposition on 1/11/13. Request other dates Dan Thenell is available for the deposition. 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1/7/13 Begin Deposition Scheduling Timeline for Doug Bragg for all depositions scheduled since July 2012, including all emails, memos, pleadings, etc. 15 Courtney Pentek $50 All - Clerical 00 $0.00 1/7/13 Review various emails relating to scheduling of additional depositions by Country Mutual Insurance. Confer with Fred Millard analyzing deposition scheduling. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Confer with Courtney Pentek regarding deposition scheduling. Review history of deposition scheduling of James Kloft and Kim Ellingson. Email Dan Thenell et. al. regarding objection to rescheduling James Kloft's and Kim Ellingson's depositions. Review and analyze email from Dan Thenell's office regarding outstanding discovery. Review and analyze emails relating to ongoing problems with scheduling of depositions, and matter conference with staff and analyze opposition to depositions of Kim Ellingson and James Kloft, examining FRCP's, etc.; Review and analyze caselaw concerning Outrageous Conduct Tort. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 2.1 Fred Millard $350 2.1 $735.00 Analyze changes to statement of fact for Motion to Amend and Motion for Spoliation Sanctions with Doug Bragg. Revise statement of facts per request of Doug Bragg. Review deposition transcripts for additional factual support for Motions for Spoliation and Motion to Amend. 02 Christopher Fanning $182 00 $0.00 0.7 Christopher Fanning $182 0.7 $127.40 1/7/13 1/7/13 1/7/13 1/7/13 1/7/13 1/7/13 1/7/13 1/7/13 1/7/13 1/8/13 1/8/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 108 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 1/8/13 Revise statement of facts for Motion to Amend and Motion for Spoliation Sanctions per the comments of Fred Millard and Doug Bragg. 0.6 Christopher Fanning $182 0.6 $109.20 1/8/13 Continue drafting statement of facts for the Motion for Leave to Amend and Motion for Discovery Sanctions. Draft Doug Bragg's Declaration in support of Motion to Amend and Motion for Spoliation Sanctions, and identify and prepare exhibits to Declaration. Confer with Christopher Fanning analyzing fact section for Motion for discovery sanctions and Motion to Amend Complaint. 22 Christopher Fanning $182 22 $400.40 40 Courtney Pentek $50 40 $200.00 02 Doug Bragg $280 02 $56.00 Review photographs produced by Country (about 500). Review email from Client regarding seed cleaned by year from 2007 through present. Forward email from Dan Thenell's office requesting information to Client for review. Review and analyze Dalke Construction records for possible use in Motion for Sanctions and Bad Faith Amendment. Email Michelle Rawson regarding logistics of Daubert Hearing. Review and analyze Craig Edminster's file to prepare privilege log regarding same. Review and analyze Draft Motion for Sanctions for Spoliation. Phone call with Paul Kloft to discuss his declaration in support of Motions to Amend and Spoliation Sanctions. Draft e-mail to James Kloft seeking information on Precision's attempts to investigate the loss. Research and analyze spoliation of evidence for Motion for Sanctions based on spoliation. Outlining Motion for Sanctions, draft introduction for memo on Motion for Sanctions for Spoliation. Draft legal argument for memo on Motion for Sanctions for Spoliation. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 0.4 Doug Bragg Doug Bragg $280 $280 0.1 0.4 $28.00 $112.00 05 05 Fred Millard Christopher Fanning $350 $182 05 05 $175.00 $91.00 0.1 Christopher Fanning $182 0.1 $18.20 0.4 Christopher Fanning $182 0.4 $72.80 0.4 Christopher Fanning $182 0.4 $72.80 19 Christopher Fanning $182 19 $345.80 Outlining legal argument for memo on Motion for Sanctions for Spoliation. Confer with Doug Bragg to review and analyze Motion for Sanctions for Spoliation. Revise the facts section of the Motion for Sanctions for Spoliation. 0.6 Christopher Fanning $182 0.6 $109.20 03 Christopher Fanning $182 0.1 $18.20 03 Christopher Fanning $182 03 $54.60 Draft Declaration of Paul Kloft in support of Motions for Sanctions and to Amend Complaint. Review and edit Memorandum in Support of Motion for Sanctions. 0.6 Christopher Fanning $182 0.6 $109.20 0.4 Christopher Fanning $182 0.4 $72.80 1/9/13 Email to Joan Brown and Christina Medina at Dan Thenell's office RE: deposition availability for Ron Gray and Jeff Frenette for depositions. 0.1 Courtney Pentek $50 00 $0.00 1/9/13 Confer with Christopher Fanning analyzing Motion for Sanctions for Spoliation. Phone call with James Kloft discussing his involvement with the attempt to investigate the scene. Making corrections to Declarations in support of Motion for Spoliation and Motion to Amend of James Kloft and Paul Kloft and sending them to the Kloft brothers. Review and analyze Motion for Spoliation Sanctions and Motion to Amend with Fred Millard and Doug Bragg. 02 Doug Bragg $280 02 $56.00 05 Christopher Fanning $182 05 $91.00 03 Christopher Fanning $182 03 $54.60 0.4 Christopher Fanning $182 0.4 $72.80 1/8/13 1/8/13 1/8/13 1/8/13 1/8/13 1/8/13 1/8/13 1/8/13 1/8/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/9/13 1/10/13 1/10/13 1/10/13 3:10-cv-01023-HZ ATTACHMENT 1 0.2 Duplicative; billed to Bragg All - Clerical Page 109 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Phone call with Paul Kloft discussing changes to Declaration in support of Motion for Spoliation and Motion to Amend. Compose and forward email of amended Declaration in support of Motion for Spoliation and Motion to Amend to Paul Kloft. 0.1 Christopher Fanning $182 0.1 $18.20 0.1 Christopher Fanning $182 0.1 $18.20 Checking and correcting citations in Motion for Sanctions. Draft Declaration of James Kloft in support of Motion for Spoliation Sanctions and Leave to Amend. Review and edit citations where necessary in Draft Motion for Spoliation Sanctions. Continue reviewing citations in Motions for Sanctions and Leave to Amend for accuracy and necessary editing. Compose email to Christina Medina at Dan Thenell's office RE: deposition scheduling. Compose email to Joan Brown at Dan Thenell's office seeking deposition availability for Ron Gray and Jeff Frenette. Review and analyze emails and notices pertaining to Michael Billman, including deposition scheduling since 7/12; Prepare for future review. 0.4 05 Christopher Fanning Christopher Fanning $182 $182 0.4 05 $72.80 $91.00 0.6 Christopher Fanning $182 0.6 $109.20 12 Christopher Fanning $182 12 $218.40 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 20 Courtney Pentek $50 20 $100.00 1/10/13 Email James Kloft regarding his availability for a deposition on 2/19. 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1/10/13 Phone call to James Kloft, left voicemail RE: possible 2/19/13 deposition date. Phone call to John Dalke to check availability to testify at trial on 1/23/13. Informed him that Doug will give him a call to speak with him. 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1/10/13 Compose emails to Jim Schiess RE: availability to testify at hearing on 1/23/13. Informed him that Doug will give him a call to speak with him. 03 Courtney Pentek $50 All - Clerical 00 $0.00 1/10/13 Prepare exhibits for Motion for Sanctions for Spoliation and Motion to Amend per directions from Doug Bragg and Chris Fanning. 33 Courtney Pentek $50 33 $165.00 1/10/13 Confer with Doug Bragg and Chris Fanning RE: Memorandum and Declaration exhibits. Compose and forward email to Greg Mettler RE: Subpoena from Country for appearance at Daubert Hearing. Compose and forward email to Robert Halsey RE: Subpoena from Country for appearance at Daubert Hearing. Compose and forward email to Michael Rodrigue RE: Subpoena from Country for appearance at Daubert Hearing. Review email from Michelle Rawson regarding Daubert Hearing. 02 Courtney Pentek $50 02 $10.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Research and analyze admissibility of mediation communications to oppose fee petition (an issue raised by Dan Thenell at various points following mediation as a potential basis to reduce any attorney fee request in this case). Review and add edited changes to draft Declarations for Paul Kloft and James Kloft in Support of Motion for Discovery Sanctions and Motion for Leave to Amend. Review email from Joan Brown with notice of James Kloft's deposition. 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Compose and forward email to Dan Thenell and Joan Brown regarding inappropriateness of setting depositions prior to confirmation from the witness of availability. 0.1 Doug Bragg $280 0.1 $28.00 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 110 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 03 Fred Millard $350 03 $105.00 1.4 Fred Millard $350 1.4 $490.00 Review and analyze case law supporting position taken RE: Motion for Sanctions. Fixing citations in memorandum in support of motion for sanctions and revise memorandum. Review citations to update and edit them based on Doug Bragg's changes to Memoranda in support of Motions for Sanctions and Leave to Amend. Continue drafting Motion for Sanctions for spoliation. Compose and forward email to Joan Brown and Christina Medina at Dan Thenell's office RE: deposition dates for Ron Gray and Jeff Frenette. 0.4 Fred Millard $350 0.4 $140.00 1.6 Christopher Fanning $182 1.6 $291.20 05 Christopher Fanning $182 05 $91.00 03 0.1 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 03 00 $54.60 $0.00 Compose and forward email to Michael Rodrigue RE: Byron Slack's deposition and exhibits. Make Declaration exhibits in support of Motion for Spoliation Sanctions and Motion to Amend. Prepare all exhibits to Doug Bragg's Declaration in support of Motion for Spoliation Sanctions and Motion to Amend for filing. 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.4 Courtney Pentek $50 0.4 $20.00 05 Courtney Pentek $50 05 $25.00 1/11/13 Gather and prepare additional exhibits to Doug Bragg's Declaration in support of Motion for Spoliation Sanctions and Motion to Amend and prepare appropriate number of photocopies. 30 Courtney Pentek $50 30 $150.00 1/11/13 Review/revise draft Memorandum in Support of Motion for Discovery Sanctions. Review/respond to email from Dan Thenell regarding deposition scheduling. Phone call with Michael Rodrigue regarding subpoena duces tecum for deposition on date of hearing and potential appearance at hearing as witness in opposition to Byron Slack. Review and revise final draft of Motion for Spoliation Sanctions and supporting memorandum. Phone call with Maribeth Bonner regarding conferral on Motion to Amend Complaint and Motion for Discovery Sanctions. 08 Doug Bragg $280 08 $224.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 Review and respond to email from Dan Thenell regarding scheduling of Jeff Frenette and Ron Gray's depositions. File Motion for Spoliation Sanctions. Research and analyze enforceability of Subpoena Duces Tecum sent for a deposition at a courthouse during the date (not time) of a previously arranged hearing. Review and analyze outline Deposition transcripts in anticipation of Daubert Hearings Review and analyze insurance policy language for Fred Millard RE: Replacement value and "like kind" items. 02 Doug Bragg $280 02 $56.00 0.4 03 Doug Bragg Doug Bragg $280 $280 00 03 $0.00 $84.00 9.1 Fred Millard $350 9.1 $3,185.00 02 Christopher Fanning $182 02 $36.40 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/10/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/11/13 1/13/13 1/14/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review, analyze and respond to email from Dan Thenell regarding deposition of James Kloft and Motion to Quash. Compose and forward email to Joan Brown regarding inappropriate Notice of James Kloft's deposition. Review and analyze Notices of Deposition of James Kloft and Greg Mettler. Review, analyze and respond to Dan Thenell's email concerning depositions. Review, analyze and revise draft of Motion for Sanctions (Spoliation of Evidence) and discussing with staff various changes. 02 Doug Bragg 0.1 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical Page 111 of 161 Date 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/14/13 1/15/13 1/15/13 1/15/13 1/15/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Attend meeting with Fred Millard and Doug Bragg to review and analyze case and preparation for Daubert hearing. Review and analyze reply brief in preparation for the Daubert hearing and prepare outline of arguments for Daubert hearing. Analyze Byron Slack's expert testimony to be challenged at the Daubert hearing with Doug Bragg. Compose letter to Judge Hernandez RE: copies of all Motions & Exhibits filed on 1/11/13. Prepare Judge's bench copy to Judge Hernandez of all Motions and Exhibits filed with the court on 1/11/13. Draft Notices of Deposition for Jeff Frenette and Ron Gray. Meet with Doug Bragg to review and sign Notices of Deposition of Jeff Frenette and Ron Gray; Serve on Dan Thenell. Compose and forward email to Court Reporter for court reporting services for 2/20/13 depositions of Ron Gray and Jeff Frenette. 1.4 Christopher Fanning $182 All - Duplicative; billed to Millard 10 Christopher Fanning 05 Explanation Hrs Awarded Amount 00 $0.00 $182 10 $182.00 Christopher Fanning $182 05 $91.00 0.4 Courtney Pentek $50 All - Clerical 00 $0.00 03 Courtney Pentek $50 All - Clerical 00 $0.00 0.4 03 Courtney Pentek Courtney Pentek $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 Work with Christopher Fanning to prepare for Daubert Hearing relating to Katharyn Thompson. Analyze with Fred Millard issues and approach for Daubert Hearing. 03 Doug Bragg $280 03 $84.00 03 Doug Bragg $280 00 $0.00 Review Daubert and analyze caselaw pertaining to Daubert Hearing in preparation for Hearing. Review and final Notices of Deposition for Ron Gray and Jeff Frenette, sign both. Phone call with Michael Rodrigue regarding supplemental report to respond to Byron Slack's investigation. Meet with Paul Kloft regarding recent motions and upcoming Daubert Hearing. Review photographs provided by Country on Jan. 7 with Paul Kloft. (151 photographs) Review and analyze arguments in opposition to admissibility of Byron Slack's opinions on items not in fire. Conduct meeting with Fred Millard and Chris Fanning to review and analyze case and preparation for Daubert hearing. Assist Doug Bragg to prepare for Daubert Hearing. Review and analyze insurance policy RE: Replacement value and "like kind". Attend meeting with Doug Bragg and Christopher Fanning to review and analyze case and preparation for Daubert hearing. Continue with Daubert Hearing preparation; Prepare for and conduct matter conference with staff RE: assignments; Continue with deposition transcripts review, analysis and summarizations; Matter conference with Client RE: Daubert hearing preparation. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 10 $280.00 02 Doug Bragg $280 02 $56.00 05 Doug Bragg $280 05 $140.00 1.4 Doug Bragg $280 00 $0.00 03 03 Fred Millard Fred Millard $350 $350 03 03 $105.00 $105.00 1.4 Fred Millard $350 1.4 $490.00 60 Fred Millard $350 60 $2,100.00 Prepare draft spreadsheet for Wells Fargo; Discuss draft spreadsheet with Doug Bragg and revise accordingly. Review, analyze and forward updated chart from Mike Billman to Dan Thenell. Preparing subpoenas for John Dalke and Jim Schiess for Daubert hearing. Review and edit Mike Billman's report per request of Doug Bragg. 15 Heidi Gross $50 15 $75.00 03 Christopher Fanning $182 03 $54.60 0.6 Christopher Fanning $182 0.6 $109.20 0.1 Christopher Fanning $182 0.1 $18.20 Forward emails received from Michael Billman to Courtney Pentek for privilege log. 0.1 Christopher Fanning $182 0.1 $18.20 ATTACHMENT 1 All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 112 of 161 Date 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 1/15/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review charts and organizing seed expert reports to send to Greg Mettler. Compose and forward email to Greg Mettler RE: expert reports and supplementing his report. Review and analyze deposition transcript of Byron Slack from MLM in preparation for Daubert hearing. Researching and analyzing FRCP 45(a) and motions to quash. Researching Daubert hearings and the proper procedure for filing challenges. Specifically looking at the timing of Daubert challenges. 0.4 Christopher Fanning $182 0.4 $72.80 02 Christopher Fanning $182 02 $36.40 1.4 Christopher Fanning $182 1.4 $254.80 0.4 05 Christopher Fanning Christopher Fanning $182 $182 0.4 05 $72.80 $91.00 Discussing and analyzing arguments for the Daubert hearing with Doug Bragg. Researching timing of Country's proposed Summary Judgment Motion. 02 Christopher Fanning $182 02 $36.40 0.4 Christopher Fanning $182 0.4 $72.80 Locate, review, analyze and organize by date additional emails RE: Michael Billman for potential expert disclosure. Review and analyze all correspondence from July 2012 to October 2012 locating and copying letters to/from Michael Billman for potential expert disclosure. Draft Michael Billman's Client Privilege Log. Compose and forward email to Court Reporter to request a copy of Katharyn Thompson's e-transcript. Phone call to John Dalke regarding hearing testimony, left voicemail. 15 Courtney Pentek $50 15 $75.00 05 Courtney Pentek $50 05 $25.00 25 0.1 Courtney Pentek Courtney Pentek $50 $50 25 00 $125.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Phone call to James Schiess regarding hearing testimony, left message with receptionist. Review and analyze argument regarding Byron Slack in Reply to Response to Motion for Partial Summary Judgment. Review and analyze deposition transcripts of Byron Slack from MLM relating to methodology. Compose and forward email to Dan Thenell regarding phone appearances for John Dalke and Motion to Quash Deposition Subpoenas for experts. Review and analyze 3rd report from Michael Rodrigue. Compose and forward email to Michael Rodrigue regarding revisions to 3rd report. Research FRCP 45 regarding subpoenas of experts. Review, analyze and respond to emails from Dan Thenell regarding issues with his subpoenas. Review and analyze Byron Slack's file documents (459 pages, plus 40 photos) in preparation for Daubert Hearing. Review and analyze Byron Slack's deposition transcript to prepare for Daubert Hearing. Phone call to James Kloft to analyze documents on consequential damages. Phone call to Mike Billman regarding lost flower seed production. 0.1 Doug Bragg $280 0.1 $28.00 0.7 Doug Bragg $280 0.7 $196.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 10 Doug Bragg $280 10 $280.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 03 Doug Bragg $280 03 $84.00 Review email from Dan Thenell regarding possibility of Summary Judgment and Daubert challenges to be filed next week by Country (nonspecific as to basis for either motion). Compose and forward email to Trevor Abbott and Craig Edminster regarding grass seed production in '09 - '12. Review and analyze deposition transcript of Katharyn Thompson in preparation for Daubert Hearing. Review letter from Dan Thenell regarding settlement. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 15 Doug Bragg $280 15 $420.00 Doug Bragg $280 02 Explanation 02 ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical $56.00 Page 113 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Duplicative; billed to Millard 1/15/13 Confer with Fred Millard analyzing settlement letter from Dan Thenell. 02 Doug Bragg $280 1/15/13 Phone call with Greg Mettler regarding Subpoena Duces Tecum. 02 Doug Bragg 1/15/13 Review Dan Thenell's January 15 and 16 Settlement correspondence; Telephone call with Client concerning settlement letter and issues related to Byron Slack's deposition testimony; Continue review and analysis of Byron Slack's Deposition in preparation for Daubert Hearing; Review Federal evidence rules RE: Daubert hearing. Matter conference with Heidi Gross requesting research on federal evidence treatises needed for trial. 5.7 1/15/13 Confer with Doug Bragg analyzing settlement letter from Dan Thenell. 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 Hrs Awarded Amount 00 $0.00 $280 02 $56.00 Fred Millard $350 5.7 $1,995.00 02 Fred Millard $350 02 $70.00 Researching standard appraisal methodology. Researching and analyzing Daubert standards. Sending settlement offer to Client for review. Review settlement offer from Dan Thenell. Review and analyze updated settlement offer from Dan Thenell and noting the differences. Researching the Court's role in deciding admissibility for Daubert. Specifically, what must the Court decide and what can be left to a jury. 02 2.6 0.1 02 02 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 $182 02 2.6 0.1 02 02 $36.40 $473.20 $18.20 $36.40 $36.40 12 Christopher Fanning $182 12 $218.40 Review and analyze Byron Slack's report for problems with his ability to testify as an expert. Review emails from Fred Millard analyzing response to Country's most recent settlement letter. Review emailed price list from James Kloft; Calculate estimated lost seed cleaning revenues for lost Flower Seed Cleaning. 0.6 Christopher Fanning $182 0.6 $109.20 02 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 1/16/13 Compose and forward email to Michelle Rawson regarding transcript of oral argument for Partial Summary Judgment hearing. 0.1 Doug Bragg $280 0.1 $28.00 1/16/13 Meeting with Fred Millard to review and analyze possible response to settlement offer from Dan Thenell. Review and analyze emails from August 2011 between Fred Millard, myself and Dan Thenell regarding stay agreement. Confer with Fred Millard and Christopher Fanning analyzing case theory change in Dan Thenell's settlement letter of Jan 15, 2013. 03 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 Continue Review Katharyn Thompson's deposition transcript in preparation for Daubert Hearing. Draft letter to Dan Thenell analyzing settlement offer and issues with changing legal/factual positions. Review email from Dan Thenell regarding Katharyn Thompson's unavailability for Daubert Hearing. Review email from Court Clerk regarding transcript for Partial Summary Judgment Hearing. Continue with review and analysis of Byron Slack's deposition transcript in preparation for Daubert Hearing. Confer with Fred Millard and Christopher Fanning analyzing argument for Daubert Hearing and relevant evidentiary rules. Review email from Dan Thenell requesting Extension of Time to Respond to Motion for Spoliation Sanctions. 05 Doug Bragg $280 05 $140.00 05 Doug Bragg $280 05 $140.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 12 Doug Bragg $280 12 $336.00 03 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 1/16/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 114 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 1/16/13 Compose and forward e-memo to Doug Bragg analyzing settlement. 02 Fred Millard $350 02 $70.00 1/16/13 Meeting with Doug Bragg analyzing possible response to settlement offer from Dan Thenell. Confer with Doug Bragg and Christopher Fanning analyzing case theory change in Dan Thenell's settlement letter of Jan 15, 2013. 03 Fred Millard $350 03 $105.00 03 Fred Millard $350 03 $105.00 Meeting with Doug Bragg and Christopher Fanning analyzing argument for Daubert Hearing and relevant evidentiary rules. Researching and analyzing Daubert issues. Researching and analyzing parroting of experts and organizing research into pocket brief. Calculate the Actual Cash Value on lost equipment; Verify information in the charts for accuracy; Prepare copies of charts. Continue review of seed charts for accuracy. Discussing and analyzing settlement figures with Fred Millard and Doug Bragg. Review and edit draft letter to Dan Thenell from Fred Millard. Attend meeting with Client, Fred Millard and Doug Bragg to discuss and analyze settlement offer. Draft Deposition Transcript Summary of Byron Slack. Phone call with Greg Mettler to arrange meeting with Fred Millard prior to deposition. Phone call with Dan Thenell, Maribeth Bonner and Dannielle Booth regarding Telephonic appearances of Katharyn Thompson, Greg Mettler and John Dalke, as well as request for additional time on response to Motions for Sanctions and Motion to Amend. 03 Fred Millard $350 03 $105.00 0.7 1.7 Christopher Fanning Christopher Fanning $182 $182 0.7 1.7 $127.40 $309.40 15 Christopher Fanning $182 15 $273.00 02 08 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Millard 02 00 $36.40 $0.00 0.4 15 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Millard 0.4 00 $72.80 $0.00 35 0.1 Courtney Pentek Courtney Pentek $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 0.4 Doug Bragg $280 0.4 $112.00 Compose and forward email and phone call to Greg Mettler regarding telephonic appearance at hearing. Phone call to Paula Smith RE: fire investigation, left voicemail. Confer with Fred Millard analyzing conversation with Dan Thenell analyzing settlement offer and Daubert Hearing. Meet with Paul Kloft, Fred Millard and Christopher Fanning analyzing possible response to settlement demand. Meet with Greg Mettler in preparation for deposition. Defend deposition of Greg Mettler. Prepare for and conduct meeting with Greg Mettler and Fred Millard to discuss and analyze issues arising during deposition and Daubert Hearing. Draft response to Motion to Extend time to respond to Motion for Sanctions. File Opposition to Motion for Extension of Time. Review Motion to Extend Time to Respond to Motion for Sanctions filed by Defendant. Confer with Fred Millard and Christopher Fanning analyzing response to same. Confer with Doug Bragg analyzing conversation with Dan Thenell analyzing settlement offer and Daubert Hearing. Meeting with Greg Mettler and Doug Bragg to discuss and analyze issues arising during deposition and Daubert Hearing. Discussing and analyzing settlement figures with Doug Bragg and Christopher Fanning. Draft letter to Dan Thenell RE: settlement offer. Meeting with Client, Doug Bragg and Christopher Fanning to discuss and analyze settlement offer. 02 Doug Bragg $280 02 $56.00 0.1 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 25 Doug Bragg $280 1.5 Duplicative; billed to Millard 10 $280.00 03 30 10 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 All - Duplicative; billed to Millard 03 30 00 $84.00 $840.00 $0.00 10 Doug Bragg $280 10 $280.00 0.1 03 Doug Bragg Doug Bragg $280 $280 00 03 $0.00 $84.00 02 Fred Millard $350 02 $70.00 10 Fred Millard $350 10 $350.00 08 Fred Millard $350 08 $280.00 03 15 Fred Millard Fred Millard $350 $350 03 15 $105.00 $525.00 1/16/13 1/16/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 1/17/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical Page 115 of 161 Date Hrs Awarded Amount $182 1.4 $254.80 Christopher Fanning $182 02 $36.40 15 Christopher Fanning $182 00 $0.00 Researching and analyzing the distinction between parroting testimony and using it to create your own opinion. Review and review opposition to Defendant's motion to extend time and add/edit citations. Review and analyze summary of Katharyn Thompson's deposition transcript. Review and analyze summary of Kevin Loe's deposition transcript. 0.7 Christopher Fanning $182 0.7 $127.40 0.7 Christopher Fanning $182 0.7 $127.40 0.4 Christopher Fanning $182 0.4 $72.80 02 Christopher Fanning $182 02 $36.40 02 Christopher Fanning $182 02 $36.40 05 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 25 05 Courtney Pentek Courtney Pentek $50 $50 All - Clerical 25 00 $125.00 $0.00 15 Fred Millard $350 15 $525.00 05 Fred Millard $350 05 $175.00 1/18/13 Review and analyze Defendant's Motion for an Extension to Respond to the Motion for Sanctions. Review and analyze Defendant's Motion for an Extension with Fred Millard. Draft Deposition Summary for Katharyn Thompson. Go through docket and highlight any extension/rescheduling that Defendant has made and make a small spreadsheet for Fred Millard to review and analyze. Prepare for and conduct meeting reviewing and analyzing case with Christopher Fanning. Meeting with Christopher Fanning to review and analyze Defendant's Motion for an Extension. Research availability of reference material RE: Federal Evidence. 0.1 Heidi Gross $50 0.1 $5.00 1/21/13 Review case status email from Fred Millard. 02 Christopher Fanning $182 0.1 Duplicative; billed to Millard 0.1 $18.20 1/21/13 Assist Doug Bragg with Daubert preparations. 02 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 1/21/13 Organizing and preparing a fuller, detailed outline of examination of Katharyn Thompson for the Daubert hearing by further review and analysis of deposition excerpts, her reports and other documents. 48 Christopher Fanning $182 48 $873.60 1/21/13 1/21/13 Researching the latest changes to FRE 701 for Fred Millard. Researching and analyzing admissibility of supplemental expert reports. 02 0.7 Christopher Fanning Christopher Fanning $182 $182 02 0.7 $36.40 $127.40 1/21/13 Proofread, revise and final letter to Dan Thenell RE: settlement written by Fred Millard, and send to Dan Thenell. Begin drafting Kevin Loe's Deposition Transcript Summary. Phone call with James Kloft regarding Willamette Turf Seed letter. 05 Courtney Pentek $50 00 $0.00 35 0.1 Courtney Pentek Doug Bragg $50 $280 35 0.1 $175.00 $28.00 20 Doug Bragg $280 20 $560.00 02 Doug Bragg $280 02 $56.00 1/21/13 Review and analyze Kevin Loe's deposition transcript in preparation for Daubert Hearing. Matter Conference with Christopher Fanning analyzing outline of arguments for Daubert Hearing. Review and revise draft letter in response to Country's settlement offer. 0.1 Doug Bragg $280 0.1 $28.00 1/21/13 Phone call with Paul Kloft regarding letters to non-claimed growers. 08 Doug Bragg $280 08 $224.00 1/21/13 Confer with Christopher Fanning analyzing changed methodology from Katharyn Thompson's deposition through present report. 02 Doug Bragg $280 02 $56.00 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/18/13 1/21/13 1/21/13 1/21/13 1/21/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze case law and the notes on FRE 702 for Daubert arguments. Researching and analyzing privilege and whether the fact of what an expert has actually been paid is protected. Attend meeting reviewing and analyzing case with Fred Millard. 1.4 Christopher Fanning 02 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical Page 116 of 161 Date Hrs Req Pltf Lawyer Rate Review and analyze deposition transcript of Robert Halsey in preparation for Daubert Hearing. Review subpoenas from Country to various government entities relating to the fire investigation. Confer with Christopher Fanning analyzing research on "supplemental" expert report. Prepare for and conduct conference with Fred Millard analyzing preparation for Daubert Hearing. Attend matter conference with Doug Bragg analyzing preparation for Daubert Hearing. Draft emails to Doug Bragg and Chris Fanning RE: Country's letters to non-claimed growers and ongoing settlement discussions. 0.4 Doug Bragg 02 1/21/13 1/21/13 1/22/13 1/21/13 1/21/13 1/21/13 1/21/13 1/21/13 1/21/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/22/13 1/23/13 1/23/13 3:10-cv-01023-HZ Hrs Awarded Amount $280 0.4 $112.00 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 00 $0.00 0.6 Fred Millard $350 0.6 $210.00 0.1 Fred Millard $350 0.1 $35.00 Review and analyze research from Christopher Fanning RE: FRE 701. 03 Fred Millard $350 03 $105.00 Summarize Kevin Loe's Deposition transcript. Phone call with James Kloft discussing letters from Country to growers and defamatory statements contained therein. Prepare for Daubert hearing by reviewing Kevin Loe's transcript excerpts and adding to Katharyn Thompson's outline. Prepare scripts for Daubert hearing with Doug Bragg. Organize documents and outlines for different issues that may arise at Daubert hearing. Review Reply on Motion for an Extension of Time and supporting document. Prepare draft of Jeffrey Martin's Deposition Summary for Doug Bragg's review. Prepare hearing binder with index for 1/23/13 Daubert Hearing. 15 02 Fred Millard Christopher Fanning $350 $182 15 02 $525.00 $36.40 13 Christopher Fanning $182 13 $236.60 2.4 60 Christopher Fanning Christopher Fanning $182 $182 2.4 60 $436.80 $1,092.00 02 Christopher Fanning $182 02 $36.40 20 Courtney Pentek $50 20 $100.00 15 Courtney Pentek $50 All - Clerical 00 $0.00 Prepare Exhibits of Kevin Loe's Expert Report and give to Doug Bragg for Daubert Hearing. Phone calls with Michael Rodrigue analyzing possible testimony in Daubert Hearing. Phone call with Dannielle Booth regarding Daubert Hearing and release from subpoenas for Robert Halsey and Michael Rodrigue. 02 Courtney Pentek $50 All - Clerical 00 $0.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze caselaw relating to late-filed supplemental expert report. Review email from Dan Thenell regarding clarification of Counter-offer; Review Fred Millard's response to Dan Thenell's clarified Counter-offer. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 Prepare for Daubert Hearing (outline questions for witnesses based upon expert reports and deposition testimony; Identified potential exhibits for Daubert Hearing). Review, analyze and respond to email from Dan Thenell regarding defamatory statements to non-claimed customers of Precision. 92 Doug Bragg $280 92 $2,576.00 02 Doug Bragg $280 02 $56.00 Review Motion for Extension of Time to Respond to Motion for Sanctions; Review Response to same; Review and analyze Reply in preparation for possible argument tomorrow. Finish summarizing Kevin Loe's Deposition transcript. Travel to/from Daubert Hearing. 0.4 Doug Bragg $280 0.4 $112.00 15 10 Fred Millard Christopher Fanning $350 $182 All - Duplicative; billed to Bragg 15 00 $525.00 $0.00 Attend Daubert hearing and provide assistance to Doug Bragg during hearing 25 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All- Duplicative; billed to Millard Page 117 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 1/23/13 Attend Client meeting to analyze Daubert hearing. 05 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 1/23/13 Draft letter to John Dalke RE: hearing continuance date 2/19/13. 0.4 Courtney Pentek $50 All - Clerical 00 $0.00 1/23/13 1/23/13 1/23/13 1/23/13 Preparation for Daubert hearing Conduct Daubert hearing in Federal Court. Travel time to courthouse. Attend Client meeting to discuss and analyze Daubert Hearing. 10 25 10 05 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 All - Duplicative; billed to Millard 10 25 10 00 $280.00 $700.00 $280.00 $0.00 1/23/13 Prepare for and conduct Client meeting to discuss and analyze Daubert Hearing. Prepare for and conduct meeting with Fred Millard and Doug Bragg analyzing conferral with Dan Thenell on upcoming potential motions (reconsideration of December 17, 2012 expert report from Katharyn Thompson, Summary Judgment and Daubert Challenges). 05 Fred Millard $350 05 $175.00 10 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 1/24/13 1/24/13 Preparing trial subpoena for Dan Thenell. Review and analyze Daubert hearing with Doug Bragg and Fred Millard. 03 10 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Millard 03 00 $54.60 $0.00 1/24/13 Attend meeting discussing and analyzing projects and research for Precision case with Doug Bragg and Fred Millard based upon Doug Bragg's conferral with Dan Thenell. Assist Fred Millard with hearing preparation by gathering and photocopying Greg Mettler's reports and rebuttal report. Assist with hearing preparation by copying and organizing Byron Slack's deposition exhibits and forward same to James Kloft for review. 1.4 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 02 Courtney Pentek $50 All - Clerical 00 $0.00 03 Courtney Pentek $50 All - Clerical 00 $0.00 Listen to Voicemail and review email from Dan Thenell regarding scheduling and "Housekeeping" issues. Confer with Fred Millard analyzing position on upcoming deposition schedule and hearing schedule. Phone call with James Kloft analyzing Daubert Challenge of Byron Slack and potential issues with competency in seed cleaning equipment. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 0.4 Doug Bragg $280 0.4 $112.00 Phone call with James Kloft analyzing photos taken by him of the building after the fire. Phone call with Dan Thenell to confer on upcoming Motion for Summary Judgment, Daubert Motions for Greg Mettler, John Poe, DJ Myers and Robert Halsey, and Motion for Reconsideration on Exclusion of December 17, 2012 Report. Prepare for and conduct meeting with Fred Millard and Christopher Fanning analyzing conferral with Dan Thenell on upcoming potential motions (reconsideration of December 17, 2012 expert report from Katharyn Thompson, Summary Judgment and Daubert Challenges). 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 00 $0.00 Review and analyze Court Order of November 13, 2012 relating to the reset of pre-trial deadlines. Review and analyze photographs and Country's First Request for Production to determine whether any supplementation of the response is necessary. Review and analyze Daubert hearing with Christopher Fanning and Fred Millard. Attend meeting discussing and analyzing projects and research for Precision case with Christopher Fanning and Fred Millard based upon Doug Bragg's conferral with Dan Thenell. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1.4 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 1/24/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard Page 118 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 1/24/13 Review letter from Dan Thenell regarding potential Motion to Compel. 02 Doug Bragg $280 02 $56.00 1/24/13 Prepare for and conduct meeting with Doug Bragg and Christopher Fanning analyzing conferral with Dan Thenell on upcoming potential motions (reconsideration of December 17, 2012 expert report from Katharyn Thompson, Summary Judgment and Daubert Challenges). 10 Fred Millard $350 10 $350.00 1/24/13 Review and analyze Daubert hearing with Doug Bragg and Christopher Fanning. Attend meeting discussing and analyzing projects and research for Precision case with Doug Bragg and Christopher Fanning based upon Doug Bragg's conferral with Dan Thenell. Prepare photocopy of Dan Thenell's correspondence and mail it with the deposition check to Michael Rodrigue. Researching and analyzing the admissibility of an expert at a Daubert hearing to bolster another expert. Review and analyze Country's Daubert challenges with Doug Bragg and Fred Millard. Researching and analyzing standards for getting an attorney disqualified. Further research and analysis RE: ability of one expert to bolster another expert without submitting an expert report. Review and analyze Country's Response on our Motion for Sanctions. 10 Fred Millard $350 10 $350.00 1.4 Fred Millard $350 1.4 $490.00 0.1 Heidi Gross $50 00 $0.00 05 Christopher Fanning $182 05 $91.00 1.4 Christopher Fanning $182 00 $0.00 0.4 Christopher Fanning $182 0.4 $72.80 12 Christopher Fanning $182 12 $218.40 02 Christopher Fanning $182 02 $36.40 1/25/13 1/25/13 Review minutes of Daubert Proceedings. Prepare for and conduct meeting with Fred Millard and Christopher Fanning analyzing Defendant's Daubert Motion and Motion for Reconsideration of Dec. 17, 2012 report's exclusion. 0.1 2.1 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 1/25/13 1/25/13 Review and analyze Defendant's Motion for Reconsideration. Review and analyze Defendant's Motion challenging Robert Halsey, John Poe and DJ Myers under Daubert. Email Michelle Rawson regarding clarification on timeliness of Daubert Challenge. Draft e-memo to Fred Millard and Christopher Fanning analyzing initial response to Daubert challenges. Draft e-memo to Christopher Fanning and Fred Millard analyzing initial response to Motion for Reconsideration. Review and analyze response to Motion for Spoliation Sanctions. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 0.1 Duplicative; billed to Millard 02 $56.00 03 Doug Bragg $280 0.1 Duplicative; billed to Millard 02 $56.00 02 Doug Bragg $280 02 $56.00 1/25/13 Meeting with Fred Millard reviewing and analyzing recently filed responses to Motion for Sanctions and Motion for Leave to Amend. 0.4 Doug Bragg $280 00 $0.00 1/25/13 Review and respond to email from Dan Thenell regarding waiver of review period for Subpoenas. Review and analyze Country's Daubert challenges with Fred Millard and Christopher Fanning. Attend meeting with Doug Bragg and Christopher Fanning analyzing Defendant's Daubert Motion and Motion for Reconsideration of Dec. 17, 2012 report's exclusion. Review e-memo from Doug Bragg analyzing response to Daubert challenges. Review e-memo from Doug Bragg analyzing response to Motion for Reconsideration. 0.1 Doug Bragg $280 0.1 $28.00 1.4 Doug Bragg $280 00 $0.00 2.1 Fred Millard $350 2.1 $735.00 0.1 Fred Millard $350 0.1 $35.00 0.1 Fred Millard $350 0.1 $35.00 1/24/13 1/24/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 1/25/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 119 of 161 Date Hrs Awarded Amount $350 1.4 $490.00 Fred Millard $350 0.4 $140.00 0.1 Heidi Gross $50 00 $0.00 0.6 Christopher Fanning $182 0.6 $109.20 Research and analyze "pre-trial" disclosures and the different phases leading up to trial in Federal Court. Draft Response to Country's Motion for Reconsideration. Outline response to Country's Motion for Reconsideration. Review assertions that Country makes in its Responses to the Motions for Sanctions and Leave to Amend and checking them against the records cited. Review and analyze Court's order and compose email to Doug Bragg with a short summary of 1/29/13. Draft Response to Motion for Reconsideration. Review e-memo RE: Court's Order from Christopher Fanning. Review 1/29/13 Order. Analyze Daubert challenges with Fred Millard. Review Defendant's Motion to Strike Testimony of Plaintiff's Experts and Request for Daubert Hearing; Commence review and analysis of relevant deposition transcripts. Phone call with James Kloft RE: Doug Bragg's assignments. Compose email to John Poe and Robert Halsey about upcoming Daubert hearing. Review expert reports to determine which were timely and which were not timely. Review and analyze all of the expert reports. Review and analyze Daubert challenges from Country Mutual. Draft e-mail to Doug Bragg and Fred Millard RE: review and analysis of Country's Daubert Challenges. Phone call to DJ Myers regarding Daubert Challenge and left a voicemail. 03 Christopher Fanning $182 03 $54.60 18 08 13 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 18 08 13 $327.60 $145.60 $236.60 0.4 Christopher Fanning $182 02 $36.40 0.7 02 0.1 03 25 Christopher Fanning Doug Bragg Fred Millard Christopher Fanning Fred Millard $182 $280 $350 $182 $350 0.7 02 0.1 03 25 $127.40 $56.00 $35.00 $54.60 $875.00 0.1 03 Christopher Fanning Christopher Fanning $182 $182 0.1 03 $18.20 $54.60 12 Christopher Fanning $182 12 $218.40 09 02 02 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 09 02 00 $163.80 $36.40 $0.00 0.1 Christopher Fanning $182 0.1 $18.20 1/31/13 Review various emails from Christopher Fanning analyzing continuation of Daubert Hearing and potential issues with Robert Halsey's availability. 03 Doug Bragg $280 03 $84.00 1/31/13 Review Court Order of 1/29 analyzing Motion to Amend, Motion for Sanctions, Defendant's Motion for Extension of Time and Defendant's Motion for Reconsideration. Review notices of filing of Motion to Extend Time to file Motion for Summary Judgment from Country. Review email from Joan Brown regarding Responses to Subpoenas. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 03 Christopher Fanning $182 03 $54.60 2/1/13 Review and analyze Country's Memorandum in Support of Defendant's Motion to Extend Dispositive Motion Deadline. Review and analyze subpoenas to state and local offices relating to the fire investigation from Dan Thenell's office. Analyzing impact of Court's Order on the case with Fred Millard. 02 Christopher Fanning $182 00 $0.00 2/1/13 Further analysis of Daubert challenges from Country Mutual. 02 Christopher Fanning $182 02 $36.40 1/25/13 1/25/13 1/25/13 1/28/13 1/28/13 1/28/13 1/28/13 1/28/13 1/29/13 1/29/13 1/29/13 1/29/13 1/30/13 1/30/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 1/31/13 2/1/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze Country's Daubert challenges with Doug Bragg and Christopher Fanning. Meet with Doug Bragg to review and analyze recently filed responses to Motion for Sanctions and Motion for Leave to Amend. 1.4 Fred Millard 0.4 Email All Claims RE: the reduced deposition payment sent by opposing counsel. Review and analyze Country's motion for reconsideration, noting assertions that we need to check and checking those assertions. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical 0.2 Duplicative; billed to Bragg All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 120 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review, analyze and respond to e-mail from Robert Halsey regarding Daubert hearing. Review and analyze Country's Motion for an Extension to File Motion for Summary Judgment and accompanying documents. Review notice from Court regarding denial of Motion for Extension of Time to File for Summary Judgment filed by Country. 02 Christopher Fanning $182 02 $36.40 0.4 Christopher Fanning $182 0.4 $72.80 0.1 Doug Bragg $280 0.1 $28.00 2/1/13 Analyzing impact of Court's Order on the case with Christopher Fanning. 02 Fred Millard $350 02 $70.00 2/1/13 Telephone call with Don Kelley RE: Bank note default, status of case, outstanding issues (including Defamation/Libel issues). Compose email to Robert Halsey about testifying at Daubert hearing. 10 Fred Millard $350 10 $350.00 02 Christopher Fanning $182 02 $36.40 Prepare and attend meeting with Doug Bragg and Fred Millard to review and analyze recent court orders and Motions from Country as well as Daubert Hearing strategy. Draft Responses to Daubert challenges. Review, revise and finalize letters to Dan Thenell RE: additional production and prepare Supplemental Disclosures and send to Dan Thenell. Compile and prepare discovery documents for production. Review and analyze fire reports provided by Country in response to their Subpoenas. Review retraction letter from Country to non-claimed customers of Precision Seed Cleaners, Inc. Draft letter to Dan Thenell regarding supplemental discovery responses. 10 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 3.6 03 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 3.6 00 $655.20 $0.00 0.7 03 Courtney Pentek Doug Bragg $50 $280 0.7 03 $35.00 $84.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 Prepare for and conduct meeting with Fred Millard and Christopher Fanning to review and analyze recent court orders and Motions from Country as well as Daubert Hearing strategy. Review email from Michelle Rawson regarding continuation of the Daubert Hearing. Review Country's Motion and Memorandum to support Extension of time for Summary Judgment filing. Phone call with James Kloft regarding Byron Slack's Daubert Hearing and potential use of Gravity Table for impeachment. Prepare and attend meeting with Doug Bragg and Christopher Fanning analyzing recent court orders and Motions from Country as well as Daubert Hearing strategy. Revise Response to Daubert Challenges based on conversation with Doug Bragg. Draft Opposition to Country's Daubert Challenges. Analyze revisions to the Opposition to Country's Daubert Challenges with Doug Bragg. Prepare, compile and organize Deposition transcripts for DJ Myers, John Poe and Robert Halsey in preparation of Daubert Challenge. 10 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 10 Fred Millard $350 10 $350.00 12 Christopher Fanning $182 12 $218.40 3.7 03 Christopher Fanning Christopher Fanning $182 $182 3.7 03 $673.40 $54.60 05 Courtney Pentek $50 00 $0.00 2/5/13 Phone call to DJ Myers RE: Daubert Challenge and left a message. 0.1 Doug Bragg $280 0.1 $28.00 2/5/13 Prepare and attend meeting with Fred Millard to analyze Response to Daubert Challenges. Prepare for and conduct meeting with Doug Bragg to analyze Response to Daubert Challenges. 0.6 Doug Bragg $280 00 $0.00 0.6 Fred Millard $350 0.6 $210.00 2/1/13 2/1/13 2/1/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/4/13 2/5/13 2/5/13 2/5/13 2/5/13 2/5/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard Page 121 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason 10 Christopher Fanning $182 All - Duplicative; billed to Millard 02 Christopher Fanning 05 0.4 2/6/13 Prepare and attend meeting with Client RE: status of Daubert Challenges, settlement discussions and Court Order regarding Defendant's Motion for Summary Judgment. Preparing Declaration for Doug Bragg on the Opposition to Country's Daubert Challenges. Proofreading Opposition to Country's Daubert Challenges. Organizing exhibits for Declaration of Doug Bragg in support of Opposition to Country's Daubert Challenges. Analyzing changes to Daubert Opposition Brief with Doug Bragg. 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/6/13 2/7/13 2/7/13 2/7/13 2/7/13 2/7/13 2/7/13 2/7/13 2/7/13 2/8/13 2/8/13 3:10-cv-01023-HZ Explanation Hrs Awarded Amount 00 $0.00 $182 02 $36.40 Christopher Fanning Christopher Fanning $182 $182 05 0.4 $91.00 $72.80 02 Christopher Fanning $182 02 $36.40 Revise Daubert Opposition per discussions with Doug Bragg. Prepare exhibits to Doug Bragg's Declaration on Opposition Brief. 0.7 03 Christopher Fanning Christopher Fanning $182 $182 0.7 03 $127.40 $54.60 Review email from James Kloft regarding product brochures for lost equipment. Review and analyze completed draft Opposition to Brief Daubert Challenges. Review and analyze Robert Halsey's deposition transcript in relation to response to the Daubert Challenge. Confer with Christopher Fanning analyzing responses to Daubert Challenge on Robert Halsey, John Poe and DJ Myers. Prepare for and conduct phone call with DJ Myers analyzing Daubert Challenge and issues for valuation. Prepare for and conduct meeting with Fred Millard, Christopher Fanning and Paul Kloft analyzing status of Daubert challenges, settlement discussions and Court Order analyzing Defendant's Motion for Summary Judgment. Phone call with James Kloft analyzing possible examples of improper equipment comparisons made by Byron Slack. Prepare and attend meeting with Doug Bragg, Christopher Fanning and Paul Kloft analyzing status of Daubert challenges, settlement discussions and Court Order analyzing Defendant's Motion for Summary Judgment. 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 10 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 10 Fred Millard $350 10 $350.00 Review and revise draft of Daubert Challenge Response. Review and analyze emails between Doug Bragg and Dan Thenell (from July, 2012 to present) for discovery agreements. Compare and analyze Byron Slack's report and the June 2010 Proof of Loss. Prepare for and conduct phone call with Michael Rodrigue regarding continuation of Daubert hearing and possible testimony. 1.1 0.4 Fred Millard Christopher Fanning $350 $182 1.1 0.4 $385.00 $72.80 09 Christopher Fanning $182 09 $163.80 02 Doug Bragg $280 02 $56.00 Confer with Fred Millard analyzing email from Dan Thenell regarding additional discovery outside of the court's schedule. Review email from Dan Thenell regarding additional discovery. Review August 26, 2012 email to Dan Thenell Confirming "discovery agreement". Draft email to respond to Dan Thenell analyzing agreement to no objections to late discovery. Confer with Doug Bragg analyzing email from Dan Thenell analyzing additional discovery outside of the Court's schedule. Assist Doug Bragg with preparation for Daubert hearing with Doug Bragg. Analyze and organize reports for our experts at Daubert hearing. 0.6 Doug Bragg $280 00 $0.00 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 03 Doug Bragg $280 03 $84.00 0.6 Fred Millard $350 0.6 $210.00 0.4 Christopher Fanning $182 0.1 $18.20 05 Christopher Fanning $182 05 $91.00 ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard 0.3 Duplicative; billed to Bragg Page 122 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Meeting with Doug Bragg and Fred Millard analyzing witnesses and evidence that we are going to want to put on at trial. Phone call with Dan Thenell regarding length of trial. Confer with Christopher Fanning analyzing exhibits for Daubert Hearing. 03 Christopher Fanning $182 All - Duplicative; billed to Millard 02 03 Doug Bragg Doug Bragg $280 $280 Prepare rough-draft Witness List for trial to circulate to Fred Millard and Christopher Fanning for review and analysis. Confer with Fred Millard analyzing issue of sufficient time for trial. 02 Doug Bragg $280 03 Doug Bragg $280 0.1 Doug Bragg 0.1 2/8/13 Review email from Dan Thenell to court regarding trial time and Michelle Rawson's response to same. Phone call to Oliver Manufacturing regarding specs for the Oliver 805 gravity table. Review and analyze Byron Slack's file for letter requesting additional information from Country. Meet with Fred Millard and Christopher Fanning analyzing preliminary Witness List. Email Michelle Rawson regarding extension to length of trial. Review and analyze discovery for documents reflecting insufficient information on the part of Byron Slack. Phone call with James Kloft RE: Daubert Hearing for Byron Slack and potential witnesses at trial. Matter conference with staff analyzing Trial witnesses and exhibits. 2/8/13 2/11/13 Explanation Hrs Awarded Amount 00 $0.00 02 03 $56.00 $84.00 0.1 Duplicative; billed to Millard 0.1 $28.00 All - Duplicative; billed to Millard 00 $0.00 $280 0.1 $28.00 Doug Bragg $280 0.1 $28.00 05 Doug Bragg $280 05 $140.00 03 Doug Bragg $280 00 $0.00 0.1 10 Doug Bragg Doug Bragg $280 $280 0.1 10 $28.00 $280.00 02 Doug Bragg $280 02 $56.00 09 Fred Millard $350 09 $315.00 Review and analyze draft Witness List. Draft questions for direct examination for DJ Myers at Daubert Hearing. 0.1 03 Fred Millard Christopher Fanning $350 $182 0.1 03 $35.00 $54.60 2/11/13 Researching ability to testify solely on experience for Daubert Hearing. 0.4 Christopher Fanning $182 0.4 $72.80 2/11/13 Analyze Daubert Challenges to Plaintiff's experts with Fred Millard and Doug Bragg. Confer with Doug Bragg developing outline of questions for presenting experts in Daubert Hearing. Prepare Deposition Summary of Robert Halsey. Analyze Daubert Challenges to Plaintiff's experts with Fred Millard and Chris Fanning. Review Correspondence from Basin Direct regarding status of payment on claim. Review DJ Myers' deposition transcript in preparation for Daubert Hearing. Review email history regarding agreement on rebuttal expert reports. 0.6 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 02 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 10 0.6 Courtney Pentek Doug Bragg $50 $280 All - Duplicative; billed to Millard 10 00 $50.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 03 Doug Bragg $280 03 $84.00 Phone call with Dean Coffee regarding Oliver gravity table. Confer with Christopher Fanning developing outline of questions for presenting experts in Daubert Hearing. Analyze Daubert Challenges to Plaintiff's experts with Doug Bragg and Chris Fanning. Analyze and develop scheduling of witnesses for Daubert hearing with Doug Bragg. Compose email to witnesses Robert Halsey, John Poe and DJ Myers about Daubert hearing and confirming their availability. Continue to draft outline of questions to ask our expert witnesses for Daubert Hearing. Prepare Deposition Summary of DJ Myers. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 0.6 Fred Millard $350 0.6 $210.00 02 Christopher Fanning $182 00 $0.00 05 Christopher Fanning $182 05 $91.00 20 Christopher Fanning $182 20 $364.00 10 Courtney Pentek $50 10 $50.00 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/8/13 2/11/13 2/11/13 2/11/13 2/11/13 2/11/13 2/11/13 2/11/13 2/11/13 2/11/13 2/12/13 2/12/13 2/12/13 2/12/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Bragg Page 123 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 02 Hrs Deducted by Court and Reason $56.00 2/12/13 Confer with Christopher Fanning analyzing Daubert Hearing Schedule. 02 Doug Bragg $280 2/12/13 2/12/13 0.1 03 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.4 03 Doug Bragg Fred Millard $280 $350 0.4 03 $112.00 $105.00 02 Fred Millard $350 02 $70.00 03 Christopher Fanning $182 03 $54.60 2/13/13 Review email from Court regarding trial schedule. Confer with Fred Millard analyzing issue with "non-experts" billing as experts. Confer with Fred Millard analyzing impact of potential late-withdrawal by Dan Thenell upon a trial date. Review Jury Instructions for substantive claims. Confer with Doug Bragg analyzing issue with "non-experts" billing as experts. Confer with Doug Bragg analyzing impact of potential late-withdrawal by Dan Thenell upon a trial date. Review, analyze and respond to e-mail from Fred Millard analyzing withdrawal of an attorney. Revise Daubert hearing outlines per discussion with Doug Bragg. 05 Christopher Fanning $182 00 $0.00 2/13/13 Review and analyze records of when we produced certain documents. 05 Christopher Fanning $182 05 $91.00 2/13/13 Confer with Christopher Fanning analyzing requirements for Daubert Hearing. Confer with Fred Millard analyzing date Country knew or should have known not an intentional loss. Review and analyze notes and exhibits to refine cross-examination of Byron Slack for upcoming Daubert Hearing. Review Table of Billet Orders analyzing average prices and potential issues with DJ Myers' math. Review, analyze and respond to email from Bekki Duty regarding Daubert Hearing. Phone call to DJ Myers analyzing pricing and recent documents relating used v. new pallet sales. Confer with Courtney Pentek analyzing preparation of exhibit list for Daubert Hearing and preparation of exhibits for same. Review and analyze product brochures of equipment and invoices for lost equipment. Confer with Christopher Fanning analyzing date of production of equipment invoices to Country. Analyze Byron Slack's deposition transcript regarding identification of the Blender to compare to product Brochure of the HSR Indent Cylinder Separator. Confer with Christopher Fanning to analyze the possibility of using the original equipment invoices against Byron Slack in Daubert Hearing. 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 2/13/13 2/13/13 Email Robert Halsey regarding Daubert Hearing preparation. Direct Courtney Pentek to add as exhibits for the Daubert Hearing photograph of HSR Indent as well as HSR Indent Brochure. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 2/13/13 Draft e-memo to Fred Millard analyzing additional concerns with regards to Byron Slack's valuation opinion. Prepare for and conduct phone call to DJ Myers and Bekki Duty regarding Daubert Hearing preparation. Conduct trial preparation by reviewing and analyzing documents provided by Country and Uniform Jury Instructions in preparation of trial notebook. Assist in preparing for continuation of Daubert Hearings researching law on evidentiary standards for valuation of loss. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 1.4 Fred Millard $350 1.4 $490.00 20 Fred Millard $350 20 $700.00 2/12/13 2/12/13 2/12/13 2/12/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 2/13/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Bragg All - Duplicative; billed to Millard Page 124 of 161 Date 2/13/13 2/13/13 2/13/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/14/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review and analyze Court's Order on Defense Motion for Reconsideration examining procedural history cited by Court. Confer with Doug Bragg analyzing date Country knew or should have known not an intentional loss. Review e-memo from Doug Bragg RE: ethical obligations of an attorney who is a witness. Analyze invoices from Precision's discovery and comparing to Byron Slack's report. Review, revise and analyze outline of questions for Byron Slack for Daubert Hearing with Doug Bragg. Confer with Fred Millard and Doug Bragg analyzing presentation of Unlawful Claims Handling Practices Act to Jury. Prepare, develop and organize detailed outline for cross-examination of Byron Slack. Compile, organize and prepare Exhibit List for Daubert Hearing and prepare exhibits. Review and revise exhibit list for Daubert Hearing. Review, revise and analyze outline of questions for Byron Slack for Daubert Hearing with Christopher Fanning. Research melting points and combustion points of various materials in preparation for Daubert Hearing. Analyze Byron Slack's photos relating to tires and compare to list of equipment not found in the fire. Review and analyze various treatises entered into evidence by Country at the Daubert Hearing. Confer with Fred Millard analyzing various treatises entered into evidence. Confer with Christopher Fanning analyzing preparation of questions for Gregson Parker relating to the treatises. Confer with Fred Millard and Christopher Fanning analyzing presentation of Unlawful Claims Handling Practices Act to Jury. Confer with Doug Bragg and Christopher Fanning analyzing presentation of Unlawful Claims Handling Practices Act to Jury. Confer with Doug Bragg analyzing various treatises entered into evidence. Prepare detailed outline for cross examination of Byron Slack. Filling in with deposition quotes and other pieces of proof that support the argument that we are making. Confer with Fred Millard and Doug Bragg analyzing whether to use Country's "Actual Cash Value" definition against Byron Slack in Daubert Hearing and need to distinguish Robert Halsey and DJ Myers. 1.1 Fred Millard $350 1.1 $385.00 02 Fred Millard $350 02 $70.00 0.1 Fred Millard $350 0.1 $35.00 10 Christopher Fanning $182 10 $182.00 20 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 0.4 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 1.6 Christopher Fanning $182 1.6 $291.20 40 Courtney Pentek $50 00 $0.00 03 20 Doug Bragg Doug Bragg $280 $280 03 20 $84.00 $560.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 20 Doug Bragg $280 20 $560.00 02 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 00 $0.00 0.4 Fred Millard $350 0.4 $140.00 02 Fred Millard $350 02 $70.00 49 Christopher Fanning $182 49 $891.80 05 Christopher Fanning $182 00 $0.00 Review and revise Reply to Plaintiff's Response on Country's Daubert motions. Revise Exhibit List for Daubert Hearing and compile, organize and prepare additional Exhibits. Call John Dalke to verify what landline number will be good to use for the Daubert Hearing. Phone call with Paul Kloft analyzing Daubert Hearing and possible questions regarding different cleaning equipment for Byron Slack. 02 Christopher Fanning $182 02 $36.40 35 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 02 Doug Bragg $280 02 $56.00 Phone call with James Kloft analyzing Daubert Hearing of Byron Slack and possible questions regarding number of screens lost in the fire. 02 Doug Bragg $280 02 $56.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 125 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 10 Doug Bragg $280 10 $280.00 Review email from Court confirming trial dates for week after April 23rd scheduled trial. Review letter from Dan Thenell regarding settlement discussions and "3 issues blocking settlement". Confer with Fred Millard analyzing possible responses to the settlement letter. Draft letter responding to Dan Thenell on merits of "3 legal issues blocking settlement". Confer with Fred Millard analyzing whether to send a written response or to wait; agree to hold off pending Daubert Hearing. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 2/15/13 Draft questions for Byron Slack relating to his ability to determine what was not lost in the fire. Confer with Fred Millard and Christopher Fanning analyzing whether to use Country's "Actual Cash Value" definition against Byron Slack in Daubert Hearing and need to distinguish Robert Halsey and DJ Myers. 05 Doug Bragg $280 00 $0.00 2/15/13 Review and analyze Exhibits to finalize Exhibit List for Daubert Hearing. 1.1 Doug Bragg $280 1.1 $308.00 2/15/13 Compose email to Court to confirm phone numbers for witnesses appearing telephonically. Confer with Doug Bragg analyzing arguments in Reply and possible ramifications for Daubert Hearings. Confer with Doug Bragg analyzing possible responses to letter from Dan Thenell RE: settlement issues. Confer with Doug Bragg analyzing whether to send a written response or to wait; agree to hold off pending Daubert Hearing. 0.1 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 0.1 Fred Millard $350 0.1 $35.00 02 Fred Millard $350 02 $70.00 2/15/13 Confer with Doug Bragg and Christopher Fanning analyzing whether to use Country's "Actual Cash Value" definition against Byron Slack in Daubert Hearing and need to distinguish Robert Halsey and DJ Myers. 05 Fred Millard $350 05 $175.00 2/18/13 2/18/13 Finalizing outline for Byron Slack's cross examination. Analyze changes to the outline for Byron Slack with Doug Bragg. 13 0.6 Christopher Fanning Christopher Fanning $182 $182 13 00 $236.60 $0.00 2/18/13 Revise outline for Byron Slack's cross examination per discussions with Doug Bragg. Final preparation for Daubert hearing. Compose email to Court Reporter cancelling the depositions of Ron Gray, Jeff Frenette and James Kloft. Compose email to Robert Halsey RE: picture. 1.7 Christopher Fanning $182 1.7 $309.40 12 0.1 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 12 00 $218.40 $0.00 Courtney Pentek $50 All - Clerical 00 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/15/13 2/18/13 2/18/13 2/18/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze Reply brief filed by Country in response to opposition to Country's Daubert challenges. Review Declaration in Support of Country's Reply to Opposition to Country's Daubert Challenge and supporting exhibits. 02 Doug Bragg 02 Confer with Fred Millard analyzing arguments in Reply and possible ramifications for Daubert Hearings. Review and analyze DJ Myers' report and deposition transcript to prepare for Daubert Hearing. Review and analyze Robert Halsey's report and deposition transcript in preparation for Daubert Hearing. Review and analyze Byron Slack's report and draft questions relating to methodology of appraisal (cost and market approaches). Explanation 0.1 ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Bragg $0.00 Page 126 of 161 Date 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/18/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/19/13 2/20/13 2/20/13 2/20/13 2/20/13 2/20/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Compile, organize and prepare Exhibits for Daubert Hearing and finalize Exhibit List and Witness List. Review and analyze with Christopher Fanning outline of issues to use with Byron Slack's cross-examination. Confer with Courtney Pentek to obtain status update of exhibit preparation. Review and analyze Country's Exhibit List for Daubert Hearing. Review and analyze Country's Witness List for Daubert Hearing. Phone call with Robert Halsey to prepare for Daubert Hearing. Review and revise draft Witness List for Daubert Hearing. Prepare for cross-examination of Gregson Parker regarding learned treatises. Review and analyze exhibits with Christopher Fanning in preparation for Daubert Hearing. Direct Courtney Pentek to forward photograph and letter to Robert Halsey to review in preparation for hearing. Review and finalize draft Witness List and Exhibit List and file same. 65 Courtney Pentek $50 All - Clerical 25 Doug Bragg 02 Explanation Hrs Awarded Amount 00 $0.00 $280 25 $700.00 Doug Bragg $280 02 $56.00 02 02 09 0.1 0.4 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 02 02 09 0.1 0.4 $56.00 $56.00 $252.00 $28.00 $112.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Travel to/from Daubert Hearing; Assist Doug Bragg with Daubert Hearing presentation at the Federal Courthouse; Handle Exhibits and locate deposition excerpts as needed. Analyze Daubert Hearing with Doug Bragg and Fred Millard. 4.4 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 08 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 Prepare for second day of Daubert Hearings. Revise Exhibit List for Daubert Hearing and continue to prepare exhibits per Court Order. Phone call to John Dalke to advise that we don't need him to be available tomorrow by phone. Phone call to Robert Halsey to advise him regarding hearing testimony schedule. Prepare for Daubert Hearing - Review Exhibits for Daubert Hearing, review outline of questions for Byron Slack. Continue Daubert Hearing Prep. Travel to/from Courthouse; Conduct Daubert Hearing. 10 30 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 10 00 $182.00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 15 Doug Bragg $280 15 $420.00 25 4.4 Doug Bragg Doug Bragg $280 $280 All Duplicative; billed to Millard 25 00 $700.00 $0.00 Meet with Fred Millard and Christopher Fanning to analyze Daubert Hearing status and remaining issues for tomorrow. Review/respond to emails from Robert Halsey regarding Daubert Hearing preparation. Prepare for Closing Argument on Daubert Challenge of Katharyn Thompson and Byron Slack. Meet with Doug Bragg and Christopher Fanning to analyze Daubert Hearing status and remaining issues for tomorrow. Attend and assist with Daubert challenges, coordinate witnesses with travel. Analyze Daubert Hearing and upcoming briefing with Doug Bragg and Fred Millard. Assisting Doug Bragg at continued Daubert hearing; Includes travel to and from hearing. Prepare for Closing argument on Daubert Challenge of Byron Slack and Katharyn Thompson. Prepare for Closing on Daubert Challenge for DJ Myers and Robert Halsey. Review and analyze briefing on Summary Judgment Motion in preparation for closing argument on Katharyn Thompson. 08 Doug Bragg $280 All Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 02 $56.00 0.7 Doug Bragg $280 0.7 $196.00 08 Fred Millard $350 08 $280.00 4.4 Fred Millard $350 4.4 $1,540.00 1.6 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 40 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 ATTACHMENT 1 Page 127 of 161 Date Hrs Awarded Amount $280 $280 38 02 $1,064.00 $56.00 Doug Bragg $280 0.6 $168.00 1.6 Doug Bragg $280 00 $0.00 1.6 Fred Millard $350 1.6 $560.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Compose email to Michelle Rawson to confirm pre-trial deadlines; Review response to same. Confer with Doug Bragg and Christopher Fanning analyzing pre-trial submissions and deadlines. Review Court order and analyze new deadlines for pre-trial filings. 0.1 Doug Bragg $280 0.1 $28.00 03 Fred Millard $350 03 $105.00 03 Christopher Fanning $182 03 $54.60 12 Christopher Fanning $182 12 $218.40 03 Christopher Fanning $182 03 $54.60 1.1 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 0.1 Courtney Pentek $50 All - Clerical 00 $0.00 1.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 1.1 Fred Millard $350 1.1 $385.00 2/24/13 2/24/13 2/25/13 2/25/13 Researching rules on subpoenaing CFO of Country Mutual, draft analysis for Doug Bragg and Fred Millard. Analyze upcoming deadlines and pre-trial filings with Fred Millard and Doug Bragg. Attend conference with Fred Millard and Doug Bragg to review and assign tasks to be accomplished to comply with Court's pre-trial deadlines. Arrange for Supplemental Brief and Declaration to be delivered to Judge Hernandez. Attend conference with Fred Millard and Christopher Fanning to review and assign tasks to be accomplished to comply with Court's pre-trial deadlines. Prepare for and conduct conference with Doug Bragg and Christopher Fanning to review and assign tasks to be accomplished to comply with Court's pre-trial deadlines. Review email from Dan Thenell regarding settlement. Review email from Dan Thenell regarding settlement. Review and analyze ATF documents. Analyzing pre-trial filings with Doug Bragg and Fred Millard. 0.1 0.1 02 03 Doug Bragg Fred Millard Christopher Fanning Christopher Fanning $280 $350 $182 $182 0.1 0.1 02 00 $28.00 $35.00 $36.40 $0.00 2/25/13 2/25/13 2/25/13 2/25/13 Draft Statement of Agreed Facts for Trial Memorandum. Revise Statement of Facts for Trial Memorandum. Prepare draft Pre-trial Order. Review email from Dan Thenell regarding revision to settlement offer. 22 02 30 0.1 Christopher Fanning Christopher Fanning Doug Bragg Doug Bragg $182 $182 $280 $280 22 02 30 0.1 $400.40 $36.40 $840.00 $28.00 2/25/13 Review correspondence from Dan Thenell regarding documents from the Marion County Sherriff and ATF. Review documents from Marion County Sherriff's office relating to the fire investigation. Review and analyze documents received from ATF. Confer with Fred Millard analyzing draft Proposed Pre-Trial Order. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 08 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 2/20/13 2/20/13 2/20/13 2/20/13 2/20/13 2/21/13 2/21/13 2/21/13 2/21/13 2/21/13 2/21/13 2/22/13 2/22/13 2/22/13 2/22/13 2/22/13 2/22/13 2/22/13 2/25/13 2/25/13 2/25/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Travel to/from Courthouse; Conduct Daubert Hearing day 3. Phone call with Greg Mettler regarding Daubert Hearing and case update. Confer with Fred Millard and Christopher Fanning analyzing Daubert Hearing, Closing Arguments and upcoming briefing. Analyze Daubert Hearing and upcoming briefing with Fred Millard and Christopher Fanning. Analyze Daubert Hearing and upcoming briefing with Doug Bragg and Christopher Fanning. Review and analyze various Notices from the Court regarding Daubert Hearings and revisions to pre-trial schedule. Review Jury Trial Pre-trial Scheduling Order and confirm deadlines for various waves of pre-trial filings. Analyze with Fred Millard and Christopher Fanning pre-trial submissions and deadlines. Compose email to office analyzing pre-trial submission deadlines. 38 02 Doug Bragg Doug Bragg 0.6 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 128 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 2/25/13 2/25/13 Confer with Paul Kloft regarding Pre-Trial Order. Draft email to Paul Kloft regarding damages issues for conversion and breach of implied covenant of good faith and fair dealing claims. 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 2/25/13 03 Doug Bragg $280 03 $84.00 2/25/13 2/25/13 2/25/13 2/25/13 Review and analyze file to ascertain date Country became aware this was not an intentionally caused fire. Review/Revise draft agreed facts. Email draft Pre-Trial Order to Client to review. Review and analyze Claim Log for additional agreed facts. Review and analyze correspondence file for additional agreed facts. 05 0.1 02 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 05 0.1 02 02 $140.00 $28.00 $56.00 $56.00 2/25/13 Analyze pre-trial preparation with Fred Millard and Christopher Fanning. 03 Doug Bragg $280 00 $0.00 2/25/13 Confer with Doug Bragg analyzing draft Proposed Pre-Trial Order. 08 Fred Millard $350 08 $280.00 2/25/13 Analyze pre-trial preparation with Doug Bragg and Christopher Fanning. 03 Fred Millard $350 03 $105.00 2/25/13 2/25/13 2/26/13 2/26/13 2/26/13 Review and analyze Proposed Pre-Trial Order. Confer with Doug Bragg analyzing draft Pre-Trial Order. Draft Proposed Jury Instructions. Prepare draft Exhibit List. Review checklist of pre-trial filings in preparation for March 18 disclosures. Confer with Courtney Pentek analyzing Exhibit List and preparation of exhibits for disclosure on March 18. Confer with Christopher Fanning analyzing Proposed Jury Instructions to submit to Country. Phone call with James Kloft analyzing Pre-trial Order and damages issues. Revise Proposed Pre-Trial Order to include additional damages information from James Kloft. Email Draft List of Economic Damages to Client to review and approve. 03 02 38 05 0.1 Fred Millard Fred Millard Christopher Fanning Courtney Pentek Doug Bragg $350 $350 $182 $50 $280 03 02 38 00 0.1 $105.00 $70.00 $691.60 $0.00 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze motions for additional agreed facts for Proposed Pre-trial Order. Review and analyze draft Pre-Trial Order. Confer with Fred Millard analyzing draft List of Economic Damages. 0.4 Doug Bragg $280 0.4 $112.00 02 03 Doug Bragg Doug Bragg $280 $280 02 03 $56.00 $84.00 2/26/13 2/26/13 2/26/13 Confer with Fred Millard analyzing draft Pre-Trial Order. Revise agreed facts in Pre-Trial Order. Begin identifying exhibits for trial (review and analyze correspondence, and Declarations in Support of Summary Judgment). 02 0.6 0.7 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 0.6 0.7 $56.00 $168.00 $196.00 2/26/13 2/27/13 Draft Itemized List of Economic Damages. Analyze Pre-Trial Order and Jury Instructions with Doug Bragg. 0.4 0.1 Doug Bragg Christopher Fanning $280 $182 0.4 00 $112.00 $0.00 2/27/13 Review and analyze Pre-Trial Order and verifying completeness. 19 Christopher Fanning $182 19 $345.80 2/27/13 2/27/13 2/27/13 Phone call with Court Reporter. Revise Jury Instructions. Phone call with Doug Bragg discussing revisions to Pre-Trial Order. 02 13 02 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 02 13 00 $36.40 $236.60 $0.00 2/27/13 2/27/13 Revise Pre-Trial Order based on Fred Millard's comments. Draft email to Dan Thenell to include draft of the Pre-Trial Order. 0.1 02 Christopher Fanning Christopher Fanning $182 $182 0.1 02 $18.20 $36.40 2/26/13 2/26/13 2/26/13 2/26/13 2/26/13 2/26/13 2/26/13 2/26/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Bragg All - Duplicative; billed to Bragg Page 129 of 161 Date Hrs Awarded Amount $280 20 $560.00 Doug Bragg $280 02 $56.00 05 02 Doug Bragg Doug Bragg $280 $280 05 02 $140.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Christopher Fanning $182 00 $0.00 Reading letter from Thenell Law Group regarding deposition of James Kloft and other matters. Revise Jury Instructions per comments of Fred Millard. Attend matter conference with Fred Millard and staff analyzing Dan Thenell's February 28, 2013 correspondence RE: discovery issues. 0.1 Christopher Fanning $182 0.1 $18.20 03 0.1 Christopher Fanning Christopher Fanning $182 $182 All - Duplicative; billed to Millard 03 00 $54.60 $0.00 Draft Jury Instructions. Compile, organize and prepare certain correspondence from file for use as trial exhibits. Confer with Courtney Pentek regarding preparing binders of seed, seed of others, scheduled and unscheduled equipment documents as exhibits for use at trial. Review and analyze letter from Dan Thenell regarding insufficiency of supplemental production and request for deposition dates for James Kloft. Review and analyze Exhibit List from the Court regarding the Daubert Hearing. Compare Court's Daubert Exhibit List with our records to verify that exhibits entered correctly. Analyze upcoming Pre-trial filings with Chris Fanning. Attend matter conference with Fred Millard and staff analyzing Dan Thenell's February 28, 2013 correspondence RE: discovery issues. 05 15 Christopher Fanning Courtney Pentek $182 $50 All - Clerical 05 00 $91.00 $0.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 2/28/13 2/28/13 Review and analyze draft of Proposed Jury Instructions Review correspondence from Dan Thenell dated February 28, 2013 RE: discovery issues; Matter conference with staff analyzing same. 2.1 03 Fred Millard Fred Millard $350 $350 2.1 03 $735.00 $105.00 3/1/13 Review and analyze changes suggested by Country Mutual on the PreTrial Order. Draft detailed response to Country Mutual's changes and problems with the Pre-Trial Order. Locate documents RE: Value Reporting Forms for Doug Bragg's review and analysis. Arrange and coordinate delivery to Judge Hernandez of a benchcopy of Precision's Reply to Defendant's Opposition. Confer with Christopher Fanning analyzing letter to Dan Thenell regarding inappropriate striking of facts Country has already admitted in this case and inappropriate addition of a defense. 0.6 Christopher Fanning $182 0.6 $109.20 22 Christopher Fanning $182 22 $400.40 0.7 Christopher Fanning $182 0.7 $127.40 0.1 Courtney Pentek $50 00 $0.00 02 Doug Bragg $280 02 $56.00 Review draft letter to Dan Thenell analyzing Agreed Facts. Revise letter to Dan Thenell on Pre-Trial Order problems. Phone call with James Kloft analyzing Exhibits for trial. Review and analyze redlined version of Pre-trial Order from Country. 0.7 20 02 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 0.7 20 02 02 $196.00 $560.00 $56.00 $56.00 2/27/13 2/27/13 2/27/13 2/27/13 2/27/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 2/28/13 3/1/13 3/1/13 3/1/13 3/1/13 3/1/13 3/1/13 3/1/13 3/1/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Review and analyze production from Precision and Country for potential exhibits at trial. Confer with Fred Millard analyzing Pre-trial Order submittal to Country. 20 Doug Bragg 02 Review and analyze draft Proposed Jury Instructions. Confer with Christopher Fanning analyzing draft Proposed Jury Instructions. Confer with Christopher Fanning analyzing Pre-trial Order submittal to Country. Analyze upcoming Pre-trial filings with Doug Bragg. Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Clerical Page 130 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Revise Jury Instructions per request of Doug Bragg. Analyze elements of the different claims in order to determine which documents, witnesses, etc. we need to round up. Analyze outline of claims and points of evidence with Doug Bragg. 02 08 Christopher Fanning Christopher Fanning $182 $182 02 08 $36.40 $145.60 0.6 Christopher Fanning $182 0.6 $109.20 Draft Witness Statement for Paul Kloft and organizing Witness List and Statements. Review and analyze Client documents. Continue analysis and organization of claims and documents that we need to support the different elements. Prepare Binder 11 for use as Trial Exhibit. Confer with Christopher Fanning analyzing and identifying of possible trial exhibits. Revise letter to Dan Thenell and Maribeth Bonner analyzing Proposed Pre-Trial Order. Phone call to James Kloft analyzing witness statements and exhibits for trial. Review notice from court regarding filing of transcript of Daubert Hearing of Jan 23, 2013. Confer with Christopher Fanning analyzing witness statements for Paul and James Kloft. Draft Witness Statement for James Kloft. Confer with Fred Millard analyzing issues with Country's draft of the Proposed Pre-trial order, and possible remedies relating to Country's anticipated persistence in failing to agree to previously admitted facts. 2.1 Christopher Fanning $182 2.1 $382.20 02 09 Christopher Fanning Christopher Fanning $182 $182 02 09 $36.40 $163.80 15 02 Courtney Pentek Doug Bragg $50 $280 00 02 $0.00 $56.00 05 Doug Bragg $280 05 $140.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 08 0.6 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 08 00 $224.00 $0.00 3/4/13 Confer with Fred Millard analyzing exhibits for trial. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 3/4/13 Confer with Courtney Pentek RE: preparation of 5 binders as exhibits (Seed, Seed of Others, Scheduled Equipment, Unscheduled Equipment, and Binder 11). Analyze claims/contentions/evidence for Breach of Contract of Insurance Claims. Review and analyze draft Witness Statement for Paul Kloft. Draft Witness Statement for Dan Thenell regarding his involvement in the investigation of the claim. Draft Witness Statement for Dave Logan regarding his role in the investigation of the claim and the lack of reasonable efforts by Country to evaluate the loss. Confer with Christopher Fanning analyzing draft Jury Instructions. 0.1 Doug Bragg $280 0.1 $28.00 0.6 Doug Bragg $280 0.6 $168.00 0.4 02 Doug Bragg Doug Bragg $280 $280 0.4 02 $112.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 3/4/13 3/4/13 Review Country draft Pre-Trial Order. Confer with Doug Bragg analyzing issues with Country's draft of the Proposed Pre-trial Order, and possible remedies relating to Country's anticipated persistence in failing to agree to previously admitted facts. 02 0.6 Fred Millard Fred Millard $350 $350 02 0.6 $70.00 $210.00 3/4/13 3/5/13 Confer with Doug Bragg analyzing exhibits for trial. Meeting with Client and Doug Bragg to analyze Trial Exhibits. 02 02 Fred Millard Christopher Fanning $350 $182 02 00 $70.00 $0.00 3/5/13 3/5/13 Analyze and outline claims with contentions and elements. Analyze Witness Statement with James Kloft, revise his Witness Statement and Paul Kloft's Witness Statement. Review and analyze photographs and equipment list that James Kloft provided. 05 25 Christopher Fanning Christopher Fanning $182 $182 05 25 $91.00 $455.00 10 Christopher Fanning $182 10 $182.00 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/4/13 3/5/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Bragg Page 131 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Prepare and attend meeting with James Kloft, Paul Kloft, Fred Millard and Doug Bragg analyzing trial preparation, trial presentation, exhibits and witnesses. Compile, organize and prepare Trial Exhibits. Meet with Paul and James Kloft analyzing Witness Statements, trial exhibits, and trial preparation issues. Meet with Paul Kloft to analyze and revise Witness Statement. Revise Witness Statement for Paul Kloft. Meet with Paul Kloft analyzing exhibits for trial. Meet with James Kloft analyzing photographs for use during trial. 1.7 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 60 0.6 Courtney Pentek Doug Bragg $50 $280 All - Clerical 00 0.6 $0.00 $168.00 1.6 0.6 03 03 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 1.6 0.6 03 03 $448.00 $168.00 $84.00 $84.00 3/5/13 Meet with Paul Kloft, James Kloft and Christopher Fanning to review exhibits for trial and identify potential additional exhibits for trial. 12 Doug Bragg $280 12 $336.00 3/5/13 Work with Courtney Pentek and Heidi Gross on exhibit to show screen layouts. Discuss with James Kloft his background, education and experience relating to seed cleaning equipment for purposes of preparing witness statement. Review and analyze discovery for potential additional exhibits. Prepare for and conduct meeting with James Kloft, Paul Kloft, Christopher Fanning and Fred Millard analyzing trial preparation, trial presentation, exhibits and witnesses. Revise draft Exhibit List. Prepare for and conduct meeting with James Kloft, Paul Kloft, Christopher Fanning and Doug Bragg analyzing trial preparation, trial presentation, exhibits and witnesses. Draft and revise Paul and James Kloft's Witness Statements. Search for letter to Ionian in Country Mutual's documents RE: access to property. Finish preparing outline for entire case analyzing each claim, elements needed to prove each claim and contentions for each element. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 03 1.7 Doug Bragg Doug Bragg $280 $280 03 00 $84.00 $0.00 02 1.7 Doug Bragg Fred Millard $280 $350 02 1.7 $56.00 $595.00 09 03 Christopher Fanning Christopher Fanning $182 $182 09 03 $163.80 $54.60 1.7 Christopher Fanning $182 1.7 $309.40 Analyze outline of claims and additional pre-trial preparation with Doug Bragg. Compile, organize and prepare Trial Exhibits. Confer with Christopher Fanning analyzing status of revisions to witness statements for Paul and James Kloft. Review and analyze underwriting file for potential exhibits at trial (610 pages). Continue review and analysis of Country's production for exhibits for trial (over 1500 pages). Review and analyze outline of elements of causes of action prepared by Christopher Fanning. Confer with Christopher Fanning analyzing draft Witness Statements. 03 Christopher Fanning $182 All - Duplicative; billed to Bragg 00 $0.00 55 02 Courtney Pentek Doug Bragg $50 $280 All - Clerical 00 02 $0.00 $56.00 1.4 Doug Bragg $280 1.4 $392.00 08 Doug Bragg $280 08 $224.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 3/7/13 Revise witness statements of James and Paul Kloft, David Logan and Dan Thenell based on comments from Fred Millard and Doug Bragg. 05 Christopher Fanning $182 05 $91.00 3/7/13 Review and analyze case law on attorney fees, specifically, the Strawn line of cases. Compile, organize and prepare exhibits for Trial. Review and analyze ZRZ Realty Co. v. Beneficial Fire and Casualty Insurance Co. relating to fee awards under ORS 742 061. 12 Christopher Fanning $182 12 $218.40 30 02 Courtney Pentek Doug Bragg $50 $280 00 02 $0.00 $56.00 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/5/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/6/13 3/7/13 3/7/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 All- Duplicative; billed to Millard All - Clerical Hrs Awarded Amount Page 132 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/7/13 Review and analyze Strawn v. Farmers regarding determination of reasonable attorney's fees under ORS 742 061. 02 Doug Bragg $280 02 $56.00 3/7/13 Direct Courtney Pentek to include fire reports as exhibits for trial. 02 Doug Bragg $280 02 $56.00 3/7/13 Review email from Maribeth Bonner on response on Pre-trial Order. 0.1 Doug Bragg $280 0.1 $28.00 3/7/13 Examine caselaw on issues pertaining to fee awards Strawn v. Farmers Insurance Company, et al. Review and analyze draft witness statements. Draft witness statements for John Dalke, James King, Jeff Frenette, Jim Brady, Ron Gray. Discussing upcoming projects with Fred Millard and Doug Bragg. 0.6 Fred Millard $350 0.6 $210.00 15 18 Fred Millard Christopher Fanning $350 $182 15 18 $525.00 $327.60 0.6 Christopher Fanning $182 0.6 $109.20 Meet with Fred Millard and Doug Bragg to analyze and outline exhibits and witnesses. Meet with Christopher Fanning and Fred Millard analyzing witness list, causes outline and exhibit list. Confer with Fred Millard analyzing Proposed Joint Jury Instructions. 1.4 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 1.4 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Review/revise draft Jury Instructions (General instructions and breach of insurance contract instructions). Revise Exhibit List. Email Maribeth Bonner draft Proposed Jury Instruction. Review and analyze draft Jury Instructions. Meet with Doug Bragg and Christopher Fanning analyzing witness list, causes outline and exhibit list. Confer with Doug Bragg analyzing Proposed Joint Jury Instructions. 1.4 Doug Bragg $280 1.4 $392.00 0.6 0.1 15 1.4 Doug Bragg Doug Bragg Fred Millard Fred Millard $280 $280 $350 $350 0.6 0.1 15 1.4 $168.00 $28.00 $525.00 $490.00 03 Fred Millard $350 03 $105.00 Phone call with James Kloft analyzing equipment charts. Review and analyze witness statements and determining which witnesses still need statements. Draft witness statements for Lynn Davis, Ryan Fields, and the CEO of Country Mutual. Revise witness statements of Dave Logan, John Dalke, Byron Slack and Jeff Frenette. Revise witness statement of James Kloft to include list of equipment and organizing photographs that James identified. Prepare and compile list of contact information for different growers and send B3749to Doug Bragg. Analyzing Order on Summary Judgment with Fred Millard and Doug Bragg. Review and analyze opinion and order on Motion for Summary Judgment. Review and analyze Byron Slack's production for potential trial exhibits. 0.1 02 Christopher Fanning Christopher Fanning $182 $182 0.1 02 $18.20 $36.40 03 Christopher Fanning $182 03 $54.60 0.7 Christopher Fanning $182 0.7 $127.40 09 Christopher Fanning $182 09 $163.80 0.1 Christopher Fanning $182 0.1 $18.20 0.4 Christopher Fanning $182 00 $0.00 0.6 Christopher Fanning $182 0.6 $109.20 03 Doug Bragg $280 03 $84.00 Confer with Fred Millard analyzing ruling on Summary Judgment Motion. Phone call with James Kloft analyzing photos for James Kloft's testimony at trial. Draft Motion for Reconsideration on Actual Cash Value. Analyzing Order on Summary Judgment with Christopher Fanning and Fred Millard. Review and analyze Dave Logan's production for potential trial exhibits. 0.1 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 38 0.4 Doug Bragg Doug Bragg $280 $280 38 00 $1,064.00 $0.00 09 Doug Bragg $280 09 $252.00 3/7/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/8/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3/11/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 133 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review and analyze Opinion and Order regarding Motion for Partial Summary Judgment. Confer with Doug Bragg analyzing ruling on Summary Judgment Motion. 0.6 Doug Bragg $280 0.6 $168.00 0.1 Fred Millard $350 0.1 $35.00 3/11/13 Analyzing Order on Summary Judgment with Christopher Fanning and Doug Bragg. Review and analyze Court's Opinion and Order on Summary Judgment, draft annotation and comments. Email ruling and request Paul Kloft schedule an office visit to discuss. 0.4 Fred Millard $350 0.4 $140.00 2.1 Fred Millard $350 2.1 $735.00 0.1 Heidi Gross $50 00 $0.00 3/12/13 Review and analyze caselaw cited by Court in its opinion and order. 05 Christopher Fanning $182 05 $91.00 3/12/13 Meet with Paul Kloft, Doug Bragg and Fred Millard to analyze settlement numbers and opinion and order on our Motion for Summary Judgment. 0.7 Christopher Fanning $182 00 $0.00 3/12/13 Review evidence list and determining what needs to be added and what evidence goes to which claim. Review correspondence with Country for Proof of Notice on different claims. Analyzing caselaw from Court's Opinion and additional pretrial projects with Doug Bragg. Review and analyze Country's latest draft of Pre-trial Order. Review and analyze Memorandum in Support of Plaintiff's Motion for Reconsideration of Opinion and Order of March 11, 2013. 20 Christopher Fanning $182 20 $364.00 0.7 Christopher Fanning $182 0.7 $127.40 03 Christopher Fanning $182 03 $54.60 03 09 Christopher Fanning Christopher Fanning $182 $182 03 09 $54.60 $163.80 Draft Motion for Reconsideration. Phone call with Mike Carney regarding assistance with witness interviews of seed of others growers. Review emails from Client analyzing potential additional documents for trial. Email James Kloft regarding summary of seed cleaning revenues and clarification of net damages over 3 year span. Meet with Fred Millard, Paul Kloft and Christopher Fanning analyzing counter-offer to Country. Draft Counter-offer to Country. Phone call to Maribeth Bonner to Confer on Motion for Reconsideration; email Maribeth Bonner and Dan Thenell regarding same. Review/respond to emails from Mike Carney RE: witness interviews. 03 02 Christopher Fanning Doug Bragg $182 $280 03 02 $54.60 $56.00 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 0.7 Doug Bragg $280 00 $0.00 12 0.1 Doug Bragg Doug Bragg $280 $280 12 0.1 $336.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Email list of Seed of Others growers to Mike Carney. Confer with Christopher Fanning analyzing status of preparing exhibits, witness statements, and other Pre-trial filings. Revise draft Proposed Pre-trial Order. Draft letter to Dan Thenell extending counteroffer to Country's February 25, 2013 Offer. Prepare for and conduct Client meeting to discuss Counter-Offer and review status of case post Summary Judgment Ruling. 0.1 03 Doug Bragg Doug Bragg $280 $280 0.1 03 $28.00 $84.00 09 0.7 Doug Bragg Fred Millard $280 $350 09 0.7 $252.00 $245.00 10 Fred Millard $350 10 $350.00 Review and analyze correspondence from Thenell March 12, 2013; Draft email to Thenell's office RE: James Kloft deposition. Prepare photos from Client as exhibits for trial. Telephone call with Nancy (U.S. District Court Reporter) providing update of Nick Priest's deposition transcript. Review and revise draft of Pre-trial Order. 02 Fred Millard $350 02 $70.00 10 0.1 Heidi Gross Heidi Gross $50 $50 00 00 $0.00 $0.00 Christopher Fanning $182 3/11/13 3/11/13 3/11/13 3/11/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/12/13 3/13/13 3:10-cv-01023-HZ Explanation 3.6 ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Clerical All - Clerical 3.6 $655.20 Page 134 of 161 Date Hrs Req Pltf Lawyer Rate Identify exhibits to give to Courtney Pentek to number and add to our Exhibit List. Analyze Pre-trial Order and settlement possibilities with Fred Millard and Doug Bragg. Revise Pre-trial Order based on discussions with Doug Bragg and Fred Millard. Draft and prepare Expert Narratives for first wave of Pre-trial filings. 0.1 Christopher Fanning $182 0.4 Christopher Fanning $182 0.1 Christopher Fanning 08 3/13/13 Revise and fax letter to Dan Thenell. Compile, organize and prepare exhibits for trial. Confer with Christopher Fanning analyzing status of Draft Proposed PreTrial Order and inclusion of facts from Opinion & Order on Summary Judgment. Review exhibits and Exhibit List with Courtney Pentek. Confer with Fred Millard analyzing preparation for first round of pretrial filings. Confer with Christopher Fanning analyzing possible stipulated or agreed facts from Opinion & Order on Summary Judgment. Review order from court regarding Motion for Reconsideration. 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/13/13 3/14/13 3/14/13 3/14/13 3:10-cv-01023-HZ Hrs Awarded Amount 0.1 $18.20 00 $0.00 $182 0.1 $18.20 Christopher Fanning $182 08 $145.60 03 50 02 Courtney Pentek Courtney Pentek Doug Bragg $50 $50 $280 00 00 02 $0.00 $0.00 $56.00 03 02 Doug Bragg Doug Bragg $280 $280 03 00 $84.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Review photographs from Ryan Fields as potential exhibits at trial. 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze email from Mike Carney regarding grower interviews for witness statements. Review, analyze and respond to emails from Mike Carney on conversations with growers. Matter conference with Fred Millard analyzing pre-trial preparations. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 10 Doug Bragg $280 00 $0.00 Confer with Fred Millard and Christopher Fanning analyzing exhibits for trial. Analyzing pre-trial order and settlement possibilities with Fred Millard and Christopher Fanning. Review and analyze draft Exhibit List and revise to ensure evidence sufficient to prove all aspects of Breach of Contract case given Country's failure to make reasonable stipulations of fact. 02 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 00 $0.00 10 Doug Bragg $280 10 $280.00 Review and analyze draft Witness Statements. Review and analyze revised draft Proposed Pre-trial Order. Compose email to Dan Thenell & Maribeth Bonner regarding Pre-trial Order revisions. Confer with Doug Bragg analyzing preparation for first round of pre-trial filings. Matter conference with Doug Bragg analyzing status of pre-trial preparations. Analyzing pre-trial order and settlement possibilities with Doug Bragg and Christopher Fanning. Review, analyze and annotate Witness Statements. Review and edit Trial Brief. Researching admissibility of photographs that were provided by opposing party and by the government. Review and analyze equipment documents to determine pricing of the forklift. Review and analyze correspondence files for potential exhibits for trial. 0.6 0.4 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.6 0.4 02 $168.00 $112.00 $56.00 02 Fred Millard $350 02 $70.00 10 Fred Millard $350 10 $350.00 0.4 Fred Millard $350 0.4 $140.00 2.1 09 0.7 Fred Millard Fred Millard Christopher Fanning $350 $350 $182 2.1 09 0.7 $735.00 $315.00 $127.40 05 Christopher Fanning $182 05 $91.00 09 Christopher Fanning $182 09 $163.80 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 135 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason All - Clerical 3/14/13 Compile, organize and prepare Plaintiff's Exhibit List and Plaintiff's Expert Narratives for filing and production to Country. 70 Courtney Pentek $50 3/14/13 Prepare for and conduct phone call with James Kloft analyzing photographs of fire scene. Confer with Christopher Fanning analyzing expert narratives. Confer with Courtney Pentek analyzing exhibits and exhibit list. 1.6 Doug Bragg 02 02 3/14/13 3/14/13 Review and analyze email from James Kloft regarding summary of farming losses. Continue review and analysis of photographs for use in trial. Confer with Fred Millard analyzing pre-trial filings. 3/14/13 3/14/13 Hrs Awarded Amount 00 $0.00 $280 1.6 $448.00 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 19 02 Doug Bragg Doug Bragg $280 $280 19 00 $532.00 $0.00 Phone call with James Kloft regarding additional photographs for trial. 02 Doug Bragg $280 02 $56.00 Confer with Christopher Fanning analyzing issue of authentication of photographs for trial. Email Dan Thenell regarding stipulation on admissibility of fire reports and photographs. Review, analyze and respond to email from Dan Thenell regarding stipulation on photographs and fire reports. Phone call with James Kloft analyzing seed cleaning line photographs. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 Review email from Mike Carney on Hoffman Farms testimony. Review email from Dan Thenell regarding Ryan Field's report and testimony. Confer with Fred Millard analyzing stipulations with Country on admissibility of fire reports. Confer with Heidi Gross analyzing photographs for exhibits. Confer with Courtney Pentek analyzing trial exhibits identification and preparation status. Draft Trial Memorandum. Review and analyze photos for trial exhibits with Heidi Gross. Discuss missing exhibits with Courtney Pentek. Confer with Christopher Fanning analyzing additional correspondence which may be relevant to claims to be used in trial. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 Doug Bragg $280 00 $0.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 03 02 02 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 03 02 02 02 $84.00 $56.00 $56.00 $56.00 02 02 Fred Millard Fred Millard $350 $350 02 02 $70.00 $70.00 3/14/13 Confer with Doug Bragg analyzing trial preparation. Confer with Doug Bragg analyzing stipulations with Country on admissibility of fire reports. Analyze photos of seed and equipment loss; Prioritize for impact. 20 Heidi Gross $50 20 $100.00 3/15/13 3/15/13 Draft rough draft of Trial Memorandum. Review and analyze correspondence for potential trial exhibits. 42 15 Christopher Fanning Christopher Fanning $182 $182 42 15 $764.40 $273.00 3/15/13 3/15/13 Compile, organize and prepare trial exhibits. Review, analyze and respond to email from Mike Carney regarding grower interviews. Prepare for and conduct phone call with James Kloft analyzing Mike Carney's interviews. Review, analyze and respond to email from Fred Millard analyzing Mike Carney's interviews. Review and analyze correspondence located by Christopher Fanning as potential exhibits. 60 02 Courtney Pentek Doug Bragg $50 $280 00 02 $0.00 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/14/13 3/15/13 3/15/13 3/15/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard Page 136 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.1 Doug Bragg 03 3/15/13 3/15/13 3/15/13 3/15/13 3/15/13 3/15/13 Email final exhibit list to Paul Kloft and James Kloft to review and comment. Prepare for and conduct phone call with James Kloft analyzing exhibit list, witness list, and potential deposition. Prepare for and conduct phone call with James Kloft analyzing his witness statement. Compose email to Client with attached draft witness statements for review and comment. Confer with Heidi Gross regarding status of trial exhibits. Review and analyze potential Trial Exhibits. Review and analyze photograph exhibits for completeness. Make final revisions to Exhibit List. Revise draft Witness Statements. Confer with Fred Millard analyzing status of Pretrial filings. $280 0.1 $28.00 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 15 10 02 0.6 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 $280 $280 0.1 15 10 02 0.6 00 $28.00 $420.00 $280.00 $56.00 $168.00 $0.00 3/15/13 Review, analyze and revise draft Witness Statement for Dave Logan. 0.4 Doug Bragg $280 0.4 $112.00 3/15/13 3/15/13 3/15/13 3/15/13 3/15/13 Confer with Christopher Fanning analyzing draft Pre-trial Brief. Review and analyze Michael Carney's witness report. Compose email to Doug Bragg analyzing witness interviews. Confer with Doug Bragg analyzing status of pretrial filings. Review Court's email re: transcript of 2/20/13; Forward to Doug Bragg. 0.1 10 02 02 0.1 Doug Bragg Fred Millard Fred Millard Fred Millard Heidi Gross $280 $350 $350 $350 $50 All - Clerical 0.1 10 02 02 00 $28.00 $350.00 $70.00 $70.00 $0.00 3/15/13 3/15/13 3/15/13 Prepare photos for use as trial exhibits. Prepare trial exhibits. Assist in preparing trial exhibits for submittal to Court and Country. 05 02 35 Heidi Gross Heidi Gross Heidi Gross $50 $50 $50 All - Clerical All - Clerical All - Clerical 00 00 00 $0.00 $0.00 $0.00 3/16/13 Review, analyze and respond to various emails from Fred Millard analyzing witness statements and exhibits. Revise Witness Statements. Phone call with Mike Carney analyzing witness interviews for Seed of Others growers. Review and analyze Exhibit List, Exhibits, Witness Statements and List of Economic Damages to confirm facts match up correctly. 02 Doug Bragg $280 02 $56.00 28 02 Doug Bragg Doug Bragg $280 $280 28 02 $784.00 $56.00 0.7 Doug Bragg $280 0.7 $196.00 Finalizing Pre-trial documents for Wave #1. Research judicial admissions and draft analysis for Doug Bragg. Review, analyze and make revisions to Pre-trial Brief. Compile, organize and prepare trial exhibit binders for submittal to Court and Country. Revise List of Economic Damages to include Exhibits and Witnesses. 1.6 0.6 05 55 Christopher Fanning Christopher Fanning Christopher Fanning Courtney Pentek $182 $182 $182 $50 1.6 0.6 05 00 $291.20 $109.20 $91.00 $0.00 03 Doug Bragg $280 03 $84.00 3/18/13 3/18/13 Revise Exhibit List. Email Michelle Rawson regarding demonstrative exhibits, electronic copies of exhibits and pre-trial order submittal requirements. 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 3/18/13 Confer with Courtney Pentek regarding status of revisions to Exhibits and Exhibit Lists. Confer with Heidi Gross analyzing addition of two photographs as exhibits. Research caselaw supporting consequential damages for breach of implied covenant of fair dealing. Phone call with James Kloft regarding status of witness statement review. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 3/15/13 3/15/13 3/15/13 3/15/13 3/17/13 3/17/13 3/17/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical Page 137 of 161 Date 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/18/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Revise witness statements upon comments from James Kloft and Paul Kloft. Confer with Fred Millard analyzing Trial Memo. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Confer with Fred Millard analyzing witness statements. Review/respond to email from Michelle Rawson regarding demonstrative exhibits. Review Court copy of filings to insure completeness. Email Michelle Rawson regarding "Disagreed Facts" issue. File Pre-trial documents for wave #1. Review Witness Statements and Expert Narratives filed by Defendant. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 02 02 05 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 02 02 00 02 $56.00 $56.00 $0.00 $56.00 Confer with Fred Millard analyzing Defendant's Witness Statements and Expert Narratives. Revise Witness Statements. Review draft Trial Brief. Review, analyze and revise draft Trial Brief. Phone call with James Kloft regarding revisions to Witness Statements. 02 Doug Bragg $280 00 $0.00 02 02 1.6 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 02 02 1.6 0.1 $56.00 $56.00 $448.00 $28.00 Review/respond to email from Maribeth Bonner regarding the Pretrial Order. Confer with Fred Millard analyzing status of preparation of Pre-trial filings. Confer with Christopher Fanning analyzing revisions to Proposed Pretrial Order and Trial Brief to assure continuity between damages calculations. Review and sign letter to Court including Court copy of Pre-trial filings. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Review FRCPs regarding filing of Proposed Pre-trial Order. File and submit word copy of Proposed Pre-trial Order. Review, analyze and respond to various emails from Dan Thenell analyzing Pre-trial filings, exhibit exchange and his identification as a witness. Confer with Fred Millard analyzing Defendant's Witness List and possible Objections to Witnesses. Confer with Doug Bragg analyzing status of preparation of pre-trial filings. Confer with Doug Bragg analyzing Trial Memo. Review and analyze Draft Trial Memo. Confer with Doug Bragg analyzing Defendant's Witness Statements and Expert Narratives. Confer with Doug Bragg analyzing Defendant's witness list and possible objections to witnesses. Review and analyze Defendant's Trial Memo. Review and analyze Defendant's Witness List. Meeting with Fred Millard and Doug Bragg analyzing and developing voir dire questions. Confer with Fred Millard and Doug Bragg analyzing lack of specificity in Kevin Loe's report and arguments needed for Objection to Mr. Loe and Ms. Katharyn Thompson. Research character evidence and its use against corporations. Review and analyze fire, sheriff and ATF reports. Review and analyze Country's trial memoranda. Review and analyze witness statements. Review and analyze exhibit list. 0.1 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 All - Clerical 0.1 00 02 $28.00 $0.00 $56.00 0.6 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Fred Millard $350 02 $70.00 02 0.6 02 Fred Millard Fred Millard Fred Millard $350 $350 $350 02 0.6 02 $70.00 $210.00 $70.00 0.6 Fred Millard $350 0.6 $210.00 03 02 03 Fred Millard Fred Millard Christopher Fanning $350 $350 $182 All - Duplicative; billed to Millard 03 02 00 $105.00 $70.00 $0.00 03 Christopher Fanning $182 All - Duplicative; billed to Millard 00 $0.00 05 02 0.1 0.1 0.1 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 $182 05 02 0.1 0.1 0.1 $91.00 $36.40 $18.20 $18.20 $18.20 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 138 of 161 Date 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Analyze trial memoranda, witness statements, and exhibit list with Doug Bragg and Fred Millard. Review and analyze Court's order on Motion for Summary Judgment for clarification on Katharyn Thompson. Draft Objections to Country's proposed witness statements. Confer with Doug Bragg analyzing Objections to Witnesses and Expert Narratives. Meeting with Fred Millard and Doug Bragg analyzing Objections to Witnesses. Prepare Plaintiff's copy of trial exhibits. File Amended Proposed Pre-trial Order and Trial Memorandum. 02 Christopher Fanning $182 All - Duplicative; billed to Millard 02 Christopher Fanning $182 0.4 0.6 Christopher Fanning Christopher Fanning $182 $182 10 Christopher Fanning 10 0.1 Review, analyze and respond to email from Mike Carney regarding witness interviews. Direct Courtney Pentek to have Judge's copies of Amended Trial Brief and Amended Proposed Order sent to the Court today. Explanation Hrs Awarded Amount 00 $0.00 02 $36.40 All - Duplicative; billed to Bragg 0.4 00 $72.80 $0.00 $182 All - Duplicative; billed to Millard 00 $0.00 Courtney Pentek Doug Bragg $50 $280 All - Clerical All - Clerical 00 00 $0.00 $0.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 Review and analyze Defendant's Exhibit List. Review and analyze Defendant's Trial Memorandum. Confer with Christopher Fanning analyzing Defendant's Trial Memorandum and potential problems with lack of evidence to support Defendant's arguments. Draft e-memo to Fred Millard analyzing Objections to Witnesses. 02 03 03 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 03 03 $56.00 $84.00 $84.00 0.1 Doug Bragg $280 00 $0.00 Draft Objections to Jeffrey Frenette's testimony. Draft Objections to Ronald Gray's testimony. Email Mike Carney regarding interviewing Kim Ellingsen, Earl Doman, and Paula Smith. Review/respond to email from Maribeth Bonner regarding jury instructions (relating to juror questions and technology). Phone call with Dan Thenell regarding identification of Dan Thenell as witness in witness statements. Dan Thenell threatened a bar complaint for what he believed to be unethical conduct in naming opposing counsel as a fact witness. Dan Thenell threatened ethics complaint. 03 0.1 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 0.1 02 $84.00 $28.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Prepare for and conduct phone call with Helen Hierschbiel at the OSB analyzing ethics of calling opposing counsel. Was told that so long as good cause exists for calling opposing counsel, no ethics concern (i.e. not abusing RPC 3.7 and using it as a means to force disqualification of opposing counsel). Meeting with Fred Millard and Christopher Fanning analyzing and developing voir dire questions. Confer with Fred Millard analyzing ethics issue relating to calling Dan Thenell as a witness. Confer with Fred Millard and Christopher Fanning analyzing lack of specificity in Kevin Loe's report and arguments needed for Objection to Mr. Loe and Ms. Katharyn Thompson. Review/respond to email from Dan Thenell analyzing his appearance as a witness and ramifications under FRCP 11. Confer with Fred Millard and Christopher Fanning analyzing apparent failure to properly number exhibits and failure to properly redact personal information by Defendant in his exhibits. 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 Review email from Michelle Rawson regarding Proposed Pre-trial Order. 0.1 Doug Bragg $280 0.1 $28.00 ATTACHMENT 1 All - Duplicative; billed to Millard Page 139 of 161 Date 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/19/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Prepare revised Pre-trial Order. Prepare Amended Trial Memorandum. Draft objections to Jim Brady's proposed testimony. Review/respond to email from Maribeth Bonner regarding source of Jury Instructions. Confer with Christopher Fanning analyzing Objections to Witnesses and Expert Narratives. Review and analyze Defendant's trial exhibits (provided at 11am this morning). Meeting with Fred Millard and Christopher Fanning analyzing Objections to Witnesses. Meeting with Doug Bragg and Christopher Fanning analyzing and developing voir dire questions. Confer with Doug Bragg and Christopher Fanning analyzing lack of specificity in Kevin Loe's report and arguments needed for Objection to Mr. Loe and Ms. Katharyn Thompson. Review e-memo from Doug Bragg RE: analyzing objections to Defendant's witnesses. Confer with Doug Bragg analyzing ethics issue relating to calling Dan Thenell as a witness. Matter conference with Doug Bragg and Christopher Fanning analyzing Country's witnesses, exhibits and Trial Memo. Review and analyze Country's witnesses, exhibits and Trial Memo. 02 02 0.7 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 02 02 0.7 0.1 $56.00 $56.00 $196.00 $28.00 0.6 Doug Bragg $280 0.6 $168.00 0.4 Doug Bragg $280 0.4 $112.00 10 Doug Bragg $280 00 $0.00 03 Fred Millard $350 03 $105.00 03 Fred Millard $350 03 $105.00 0.1 Fred Millard $350 0.1 $35.00 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 2.7 Fred Millard $350 2.7 $945.00 Meeting with Doug Bragg and Christopher Fanning analyzing Objections to Witnesses. Review and analyze fire reports (120 pgs). Review and analyze trial exhibits from Country. Research whether expert reports may be published to the jury. Research character evidence as it relates to businesses. Analyze case and issues stemming from Country's exhibits with Fred Millard and Doug Bragg. Research habit evidence. Research the available sanctions for failing to cooperate with pre-trial order. Draft outline of Motions in Limine. Draft Objections to Witnesses. Analyze and develop Motions in Limine with Fred Millard and Doug Bragg. Compile, organize and prepare Plaintiff's Impeachment Exhibits. 10 Fred Millard $350 10 $350.00 15 0.7 0.4 08 05 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 $182 15 0.7 0.4 08 05 $273.00 $127.40 $72.80 $145.60 $91.00 02 03 Christopher Fanning Christopher Fanning $182 $182 02 03 $36.40 $54.60 0.4 2.1 05 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 All - Duplicative; billed to Millard 0.4 2.1 00 $72.80 $382.20 $0.00 10 Courtney Pentek $50 All - Clerical 00 $0.00 Review and analyze Defendant's Exhibit binders (4 binders) for potential objections. Confer with Courtney Pentek analyzing preparation of impeachment exhibits. Review, analyze and respond to email from Mike Carney on Production Services contact. Review and analyze Marion County Fire Report. Prepare and attend phone conference with Fred Millard and Don Kelley analyzing Defendant's Exhibit on Seed Value Reporting. 48 Doug Bragg $280 48 $1,344.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 03 Doug Bragg Doug Bragg $280 $280 03 00 $84.00 $0.00 Review, analyze and respond to emails from Mike Carney regarding witness interviews. Confer with Fred Millard analyzing Defendant's inclusion of unredacted Claim Log as a trial exhibit. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 140 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Meet with Fred Millard and Christopher Fanning analyzing Motions in Limine. Confer with Fred Millard analyzing and developing voir dire questions. 03 Doug Bragg $280 All - Duplicative; billed to Bragg 00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 05 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 05 0.1 0.1 $140.00 $28.00 $28.00 0.4 Doug Bragg $280 0.4 $112.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 0.6 15 03 03 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 All - Duplicative; billed to Millard 0.6 15 03 00 $168.00 $420.00 $84.00 $0.00 05 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 03 Fred Millard $350 03 $105.00 03 Fred Millard $350 03 $105.00 02 Fred Millard $350 02 $70.00 05 Fred Millard $350 05 $175.00 03 20 05 Fred Millard Fred Millard Fred Millard $350 $350 $350 03 20 05 $105.00 $700.00 $175.00 0.1 Fred Millard $350 0.1 $35.00 23 Christopher Fanning $182 23 $418.60 3/21/13 Draft Objections to witnesses (Ron Gray). Revise Objections to witnesses (Jim Brady and Jeff Frenette). Phone call with James Kloft regarding photographs to review for impeachment and rebuttal exhibits. Prepare for and conduct phone call with Mike Carney analyzing witness interviews. Review and analyze Examination Under Oaths and Deposition of Paul Kloft regarding seed value reporting forms issue. Prepare for and conduct phone call with James Kloft analyzing other seed storage locations. Review and analyze objections to witnesses drafted by Christopher Fanning and revise draft objections to witnesses. Draft Objections to witnesses (Dave Logan and Ryan Fields). Draft Objections to Exhibits (Binders 1 & 3). Draft Objections to Exhibits (Binder 3). Confer with Fred Millard analyzing Defendant's exhibit relating to seed reporting. Analyze issues stemming from Country's exhibits with Christopher Fanning and Fred Millard. Confer with Doug Bragg analyzing Defendant's exhibit relating to seed report. Attend phone conference with Doug Bragg and Don Kelley analyzing Defendant's Exhibit on Seed Reporting. Confer with Doug Bragg analyzing Defendant's inclusion of unredacted Claim Log as a trial exhibit. Meet with Doug Bragg and Christopher Fanning analyzing and developing Motions in Limine. Confer with Doug Bragg analyzing voir dire questions. Draft Voir Dire Questions. Analyze issues stemming from Country's exhibits with Christopher Fanning and Doug Bragg. Exchange emails with Dan Thenell regarding Defendant's unintentional production of unredacted Claim Log. Review and analyze discovery relating to value of property (about 3,000 pages). Calculating value of seed based on year per request of Doug Bragg. 03 Christopher Fanning $182 03 $54.60 3/21/13 3/21/13 Draft Objections to Evidence. Draft Objections to Witness Statements and Expert Witness Narratives. 0.1 4.7 Christopher Fanning Christopher Fanning $182 $182 0.1 4.7 $18.20 $855.40 3/21/13 Confer with Christopher Fanning analyzing issues relating to value reporting forms and Precision's seed claim. Review, analyze and respond to email from Fred Millard analyzing Country's confusion on settlement valuation. Draft Objections to Exhibits (Binder 4). Review email from Maribeth Bonner regarding Jury Instructions. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 Review emails from Maribeth Bonner and Dan Thenell regarding replacement of Defendant's Exhibit 524 (unredacted Claim Log) due to inadvertent disclosure of attorney client privileged communications. 02 Doug Bragg $280 02 $56.00 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/20/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 All - Duplicative; billed to Millard Hrs Awarded Amount Page 141 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/21/13 3/21/13 Draft Motions in Limine. Confer with Fred Millard analyzing Motions in Limine. 15 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 15 00 $420.00 $0.00 3/21/13 Confer with Fred Millard analyzing objections to Defendant's Exhibits. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 3/21/13 Prepare for and conduct meeting with Paul Kloft and Fred Millard analyzing Impeachment Exhibits and Rebuttal Exhibits. Revise Objections to Exhibits. Review and analyze Defendant's Draft Jury Instructions and email Maribeth Bonner regarding intent to review and respond with any changes tomorrow. Confer with Christopher Fanning analyzing Objections to Witnesses Statements. Compare and analyze disputed Jury Instructions. Prepare for and conduct conference with Doug Bragg and Paul Kloft analyzing issues for trial including value reporting forms. Review drafts of Trial documents. Review/respond to email from Doug Bragg analyzing Country's confusion on settlement valuation. Confer with Doug Bragg analyzing status of Motions in Limine. Confer with Doug Bragg analyzing objections to Defendant's Exhibits. 32 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 02 Doug Bragg Doug Bragg $280 $280 0.1 02 $28.00 $56.00 02 Doug Bragg $280 02 $56.00 03 45 Doug Bragg Fred Millard $280 $350 03 45 $84.00 $1,575.00 20 02 Fred Millard Fred Millard $350 $350 20 02 $700.00 $70.00 02 02 Fred Millard Fred Millard $350 $350 02 02 $70.00 $70.00 Compile, organize and prepare impeachment exhibits. Draft Precision's objections to Country's witnesses. Review, analyze and revise all of Precision's objections to Country's witness statements. Review and revise Motions in Limine. Draft additional Motions in Limine. Prepare Impeachment Exhibits for submittal to Court. Confer with Christopher Fanning analyzing status of Objections to Witness and Expert Statements, Objections to Exhibits, and Motions in Limine. Continue draft Objections to Exhibits (Binder 4). Confer with Christopher Fanning analyzing objections to Dave Logan's expert testimony. Draft Motion in Limine to exclude tax depreciation schedules. Draft Motion in Limine to exclude undisclosed evidence of crimes. 05 10 30 Heidi Gross Christopher Fanning Christopher Fanning $50 $182 $182 00 10 30 $0.00 $182.00 $546.00 10 1.7 65 02 Christopher Fanning Christopher Fanning Courtney Pentek Doug Bragg $182 $182 $50 $280 10 1.7 00 02 $182.00 $309.40 $0.00 $56.00 1.6 02 Doug Bragg Doug Bragg $280 $280 1.6 02 $448.00 $56.00 03 02 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 Review/respond to e-memo from Fred Millard analyzing and developing voir dire questions. Confer with Fred Millard analyzing status of Wave 2 document production. Draft Motion in Limine to exclude reference to reinstatement of policy or timing of policy changes. Email Sarah Cotton regarding permission to interview The Scott's Field inspector. Confer with Fred Millard analyzing and developing voir dire questions and verdict form. Revise jury instructions consistent with phone call with Maribeth Bonner. Phone call with Paul Kloft regarding potential impeachment exhibits for Jay Hoffman and status of trial preparation. Review, analyze and respond to email from Maribeth Bonner regarding the jury instructions and withdrawal of the 2nd Claim for Relief. 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/21/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical All - Clerical All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 142 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/22/13 3/22/13 Confer with Christopher Fanning analyzing Motions in Limine. Email Mike Carney regarding Dave Lambie and Paula Smith interviews. 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 3/22/13 Review and analyze report from Mike Carney regarding witness interview of Paula Smith. Confer with Courtney Pentek analyzing preparation of Impeachment Exhibits. Review and analyze list of Impeachment Exhibits. Confer with Courtney Pentek analyzing Impeachment Exhibits preparation. Confer with Christopher Fanning analyzing Objections to Witnesses. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 05 0.1 Doug Bragg Doug Bragg $280 $280 05 0.1 $140.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Continue review and analysis of disagreed Jury Instructions for possible areas of agreement. Revise Proposed Jury Instructions. Phone call to Maribeth Bonner analyzing Jury Instructions. Email revised version of Jury Instructions to Maribeth Bonner. Confer with Fred Millard analyzing Verdict Form, Jury Instructions and general status on Wave 2. Confer with Courtney Pentek analyzing status of Impeachment Exhibits. 08 Doug Bragg $280 08 $224.00 0.4 0.4 0.1 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 0.4 0.4 0.1 00 $112.00 $112.00 $28.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 Review/revise draft Verdict Form. Review email from Maribeth Bonner regarding version 4 of the Jury Instructions. Review and analyze draft Objections to Lay Witness Statements and Expert Narratives. Review/respond to email from Dan Thenell regarding Dismissal of Second Claim for Relief, count 2. Confer with Doug Bragg analyzing Wave 2 document production. 0.4 0.1 Doug Bragg Doug Bragg $280 $280 0.4 0.1 $112.00 $28.00 0.6 Doug Bragg $280 0.6 $168.00 0.1 Doug Bragg $280 0.1 $28.00 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 02 Fred Millard $350 02 $70.00 3/24/13 Confer with Doug Bragg analyzing status of voir dire questions and verdict form. Confer with Doug Bragg analyzing verdict form, jury instructions and general status on Wave 2. Review and analyze email from Client with Hoffman Farms invoices. 02 Doug Bragg $280 02 $56.00 3/24/13 Review email from Client regarding rat bait and rat bait invoice. 0.1 Doug Bragg $280 0.1 $28.00 3/24/13 Review, analyze and respond to email from Mike Carney on status of witness interviews; email Fred Millard regarding status of witness interviews. Review email from Maribeth Bonner regarding Joint Jury Instructions. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Revise Draft Objections to Defendant's Exhibits. Draft short explanations for jury instructions, include Defendant's explanations. Draft e-memo to Christopher Fanning analyzing revisions to Jury Instructions and Objections to Exhibits. Email Maribeth Bonner regarding status of jury instruction revisions. 2.6 08 Doug Bragg Doug Bragg $280 $280 2.6 08 $728.00 $224.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 3/24/13 Review email from Fred Millard with proposed Voir Dire questions/topics. Review and analyze email from Doug Bragg RE: fire investigation. 02 Fred Millard $350 02 $70.00 3/24/13 Draft Voir Dire Questions. 13 Fred Millard $350 13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/22/13 3/24/13 3/24/13 3/24/13 3/24/13 3/24/13 3/24/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard $455.00 Page 143 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/25/13 3/25/13 Cleaning up jury instructions. Review objections to exhibits and making corrections as appropriate. 1.7 08 Christopher Fanning Christopher Fanning $182 $182 1.7 08 $309.40 $145.60 3/25/13 Final review, revision and preparation of Wave 2 of Pre-Trial filings. 02 Christopher Fanning $182 02 $36.40 3/25/13 3/25/13 0.4 08 Christopher Fanning Christopher Fanning $182 $182 0.4 08 $72.80 $145.60 05 40 Courtney Pentek Courtney Pentek $50 $50 00 00 $0.00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 1.4 03 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 1.4 03 $56.00 $392.00 $84.00 02 Doug Bragg $280 02 $56.00 3/25/13 Review and analyze Country's Motions in Limine. Review and revise Motions in Limine and objections to exhibits and draft declaration of Doug Bragg. Prepare copies for Judge Hernandez of Wave 2 filings. Revise Jury Instructions and compile, organize and prepare exhibits and filings for physical delivery. Review/respond to email from Fred Millard analyzing proposed verdict form. Review and analyze photos from James Kloft. Review/finalize draft Objections to Witnesses and Experts. Draft e-memo to Fred Millard analyzing possible mediator: Judge Gardner from Washington County. Confer with Christopher Fanning analyzing formatting and final revisions of wave 2 of Pre-Trial filings. Confer with Courtney Pentek analyzing status of Impeachment Exhibits. 0.1 Doug Bragg $280 0.1 $28.00 3/25/13 3/25/13 3/25/13 Review and execute impeachment exhibit list. Review and finalize Motions in Limine. Confer with Christopher Fanning analyzing status of jury instructions. 0.1 0.7 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 0.7 02 $28.00 $196.00 $56.00 3/25/13 Confer with Courtney Pentek analyzing completion of Jury Instructions. 0.1 Doug Bragg $280 0.1 $28.00 3/25/13 3/25/13 Review/revise Proposed Voir Dire Questions. Confer with Fred Millard analyzing Wave 2 filings. 03 0.6 Doug Bragg Doug Bragg $280 $280 03 00 $84.00 $0.00 3/25/13 Confer with Christopher Fanning analyzing citations in Objections to Exhibits. Draft Statement of Claims. Review and sign letter to Court to accompany pre-trial filings. Review final draft of jury instructions. Phone call to James Kloft regarding photos for rebuttal exhibits left voice mail; email James regarding photos for rebuttal exhibits. 02 Doug Bragg $280 02 $56.00 03 0.1 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 03 0.1 0.1 0.1 $84.00 $28.00 $28.00 $28.00 Review/respond to email from Maribeth Bonner regarding jury instructions. Review draft voir dire questions. Review email from Maribeth Bonner approving submittal of jury instructions. Phone call with James Kloft regarding photos. Phone call with Maribeth Bonner regarding requirements for service of voir dire questions and verdict form. Confer with Fred Millard analyzing voir dire questions. Review/respond to email from Maribeth Bonner confirming mutual exchange of Voir Dire and Verdict Forms submissions. File wave 2 documents. Review email from Michele Rawson regarding Electronic case filing filings of Voir Dire, Jury Instructions and Verdict Form. Phone call with Mike Carney and Fred Millard analyzing witness statements. Phone call with James Kloft regarding rebuttal exhibits. 02 Doug Bragg $280 02 $56.00 0.6 0.1 Doug Bragg Doug Bragg $280 $280 0.6 0.1 $168.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 03 0.1 Doug Bragg Doug Bragg $280 $280 00 0.1 $0.00 $28.00 0.4 Doug Bragg $280 0.4 $112.00 Doug Bragg $280 02 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3/25/13 3:10-cv-01023-HZ 02 ATTACHMENT 1 All - Clerical All - Clerical All - Duplicative; billed to Millard All - Clerical $56.00 Page 144 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 0.4 Doug Bragg 0.4 3/25/13 3/25/13 Confer with Fred Millard and Christopher Fanning analyzing additional investigation of fire investigation. Prepare for and conduct telephone call with Mike Carney investigator analyzing witness statements Continue drafting Voir Dire questions. Place telephone call to Dan Thenell RE: Settlement conference proposal. $280 0.4 $112.00 Fred Millard $350 0.4 $140.00 0.4 0.1 Fred Millard Fred Millard $350 $350 0.4 0.1 $140.00 $35.00 3/25/13 Matter conference with Doug Bragg final review of Wave 2 submittals 0.6 Fred Millard $350 0.6 $210.00 3/25/13 3/26/13 3/26/13 Review of Country's 2nd Wave submittals. Review and analyze Country's Motions in Limine. Analyze responses to motions in limine with Doug Bragg. 0.6 13 03 Fred Millard Christopher Fanning Christopher Fanning $350 $182 $182 0.6 13 00 $210.00 $236.60 $0.00 3/26/13 Analyze third wave of documents with Fred Millard and Doug Bragg. 08 Christopher Fanning $182 08 $145.60 3/26/13 3/26/13 Draft responses to Motions in Limine. Review Examination Under Oath transcripts and deposition transcripts for Paul Kloft and James Kloft. Review and analyze Defendant's response on our motion for reconsideration. Review and analyze Ryan Fields' report. Research the admissibility of pleadings and briefing. Review and analyze cases cited in Country's Motions in Limine. Prepare filings for Judge Hernandez. Research for Doug Bragg - Review and identify discovery documents (11 binders) relating to Phil Herb on Oregro Seed. Double check filing of expert narratives; file expert narratives. Email Dan Thenell and Maribeth Bonner regarding omission and offer to allow another week for Objections to Expert Narratives. 0.6 0.7 Christopher Fanning Christopher Fanning $182 $182 0.6 0.7 $109.20 $127.40 02 Christopher Fanning $182 02 $36.40 02 0.4 0.6 0.1 45 Christopher Fanning Christopher Fanning Christopher Fanning Courtney Pentek Courtney Pentek $182 $182 $182 $50 $50 02 0.4 0.6 00 45 $36.40 $72.80 $109.20 $0.00 $225.00 03 0.1 Doug Bragg Doug Bragg $280 $280 03 0.1 $84.00 $28.00 Email Dan Thenell and Maribeth Bonner regarding agreement on photo authentication and Dan Thenell's objections to photographs due to lack of authentication. Review and analyze Defendant's Objections to Exhibits. Confer with Christopher Fanning analyzing responses to Defendant's Motions in Limine. Review latest report from Mike Carney RE: Witness Statements. 0.1 Doug Bragg $280 0.1 $28.00 02 05 Doug Bragg Doug Bragg $280 $280 02 05 $56.00 $140.00 0.1 Doug Bragg $280 0.1 $28.00 Begin draft response to Objections to Dan Thenell's testimony. Review and analyze Defendant's Motions in Limine. Confer with Fred Millard and Christopher Fanning analyzing Defendant's Motions in Limines and responses to same. Confer with Fred Millard and Christopher Fanning analyzing rebuttal witness David Lambie. Email Mike Carney analyzing interview with David Lambie. Draft Reply to Response to Motion for Reconsideration. Review Order from Court regarding late filed expert narratives. Confer with Christopher Fanning analyzing research to use pleading/brief by opposing party as an exhibit. Review/respond to email from Mike Carney regarding David Lambie. 20 0.6 12 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 20 0.6 00 $560.00 $168.00 $0.00 02 Doug Bragg $280 02 $56.00 02 09 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 02 09 0.1 0.1 $56.00 $252.00 $28.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Review and analyze Precision's Customer List submitted in Defendant's Exhibit List to confirm Dan Hemshorn and Steve Rusconi were listed. 02 Doug Bragg $280 02 $56.00 3/25/13 3/25/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Clerical All - Duplicative; billed to Millard Page 145 of 161 Date Hrs Awarded Amount $280 02 $56.00 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 05 $56.00 $56.00 $140.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 10 Doug Bragg $280 0.2 Duplicative; billed to Millard 08 $224.00 05 Fred Millard $350 05 $175.00 03 12 Fred Millard Fred Millard $350 $350 03 12 $105.00 $420.00 02 Fred Millard $350 02 $70.00 3/27/13 Confer with Fred Millard analyzing Response to Motion for Reconsideration, potential use of Country's statement that Byron Slack is unreliable in trial, and potential need to supplement objections to Byron Slack. Review and analyze Defendant's Objections to Lay and Expert Witnesses. Confer with Doug Bragg analyzing Defendant's Wave 2 filings. Confer with Doug Bragg and Christopher Fanning analyzing Defendant's Motions in Limines and responses to same. Confer with Doug Bragg analyzing Response to Motion for Reconsideration, potential use of Country's statement that Byron Slack is unreliable in trial, and potential need to supplement objections to Byron Slack. Review discovery documents to locate information on certain witnesses. 02 Christopher Fanning $182 02 $36.40 3/27/13 Confer with Doug Bragg analyzing Responses to Motions in Limine. 02 Christopher Fanning $182 00 $0.00 3/27/13 62 Christopher Fanning $182 62 $1,128.40 3/27/13 Research, analyze and draft responses to Defendant's 26 Motions in Limine. Draft Response to Objection to Byron Slack and Dave Logan's testimony. 0.6 Doug Bragg $280 0.6 $168.00 3/27/13 Confer with Fred Millard analyzing Rebuttal Exhibits. 02 Doug Bragg $280 00 $0.00 3/27/13 Revise draft response to objections to witnesses as it relates to failure to timely disclose. Research issues relating calling opposing expert witness to testify as a lay witness. Confer with Fred Millard analyzing rebuttal witnesses and exhibits. 02 Doug Bragg $280 02 $56.00 15 Doug Bragg $280 15 $420.00 12 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 Confer with Fred Millard analyzing reply to response to Motion for Reconsideration. Revise reply to response to Motion for Reconsideration. Confer with Fred Millard analyzing rebuttal witness statements. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 15 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 15 00 $420.00 $0.00 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 3/27/13 3/27/13 Confer with Fred Millard analyzing objections to Jeffrey Frenette's testimony, and possible rebuttal evidence. Review and analyze recent filings for use as rebuttal exhibits. Review and analyze Defendant's Objections to Plaintiff's trial exhibits. 0.4 03 Doug Bragg Doug Bragg $280 $280 0.4 03 $112.00 $84.00 3/27/13 Draft Response to Defendant's Objections to Plaintiff's Trial Exhibits. 2.6 Doug Bragg $280 2.6 $728.00 3/27/13 3/27/13 3/27/13 Research judicial admissions. Phone call with James Kloft analyzing rebuttal exhibits. Confer with Christopher Fanning analyzing Responses to Motions in Limine. Confer with Fred Millard analyzing Wave 3 filings. 0.4 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.4 02 02 $112.00 $56.00 $56.00 02 Doug Bragg $280 00 $0.00 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/26/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Draft Response to Objections to Witnesses Steve Rusconi and Dan Hemshorn due to prior identification. Review correspondence for Phil Herb's submittal. Draft Response to Objection to Phil Herb as a witness. Review and analyze Defendant's Objections to Lay and Expert Witnesses. Confer with Fred Millard analyzing Defendant's Wave 2 filings. 02 Doug Bragg 02 02 05 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Bragg All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 146 of 161 Date Hrs Req Pltf Lawyer Rate Review and analyze transcript of Daubert Hearing and prepare declaration in support of Motion for Reconsideration. Confer with Doug Bragg analyzing Rebuttal Exhibits. Confer with Doug Bragg analyzing rebuttal witnesses and exhibits. 03 Doug Bragg 02 12 3/28/13 3/28/13 3/28/13 Confer with Doug Bragg analyzing rebuttal witness statements. Confer with Doug Bragg analyzing objections to Jeffrey Frenette's testimony, and possible rebuttal evidence. Matter conference with Doug Bragg analyzing Wave 3 filings. Review drafts of submittals. Matter conference with Doug Bragg analyzing Reply to Motion for Reconsideration. Review and analyze investigation reports for Rebuttal Witness selection, and review and analyze Defendant's Lay Witness Statements and Expert Narratives. Review and revise responses to objections to witnesses. Analyze response to motions in limine with Doug Bragg. Analyze Pre-Trial filings with Fred Millard and Doug Bragg. 3/28/13 3/28/13 3/28/13 3/28/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/27/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3:10-cv-01023-HZ Hrs Awarded Amount $280 03 $84.00 Fred Millard Fred Millard $350 $350 02 12 $70.00 $420.00 02 03 Fred Millard Fred Millard $350 $350 02 03 $70.00 $105.00 02 3.6 02 Fred Millard Fred Millard Fred Millard $350 $350 $350 02 3.6 02 $70.00 $1,260.00 $70.00 25 Fred Millard $350 25 $875.00 12 03 02 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 12 0.1 00 $218.40 $18.20 $0.00 Continuing to draft Responses to Motions in Limine. Revise Response to Objections to witnesses. Revise Response to Motions in Limine per discussions with Doug Bragg. 25 20 1.1 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 25 20 1.1 $455.00 $364.00 $200.20 Assist Doug Bragg by compiling, organizing and preparing rebuttal exhibits for submittal to Court and Country. Draft Rebuttal Witness Statements. Conference with Christopher Fanning and Courtney Pentek analyzing Wave 3 filings. Phone call with James Kloft analyzing rebuttal exhibits and witness statements. Confer with Fred Millard analyzing rebuttal exhibits and witnesses. 45 Courtney Pentek $50 00 $0.00 1.7 03 Doug Bragg Doug Bragg $280 $280 1.7 03 $476.00 $84.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 Confer with Courtney Pentek regarding rebuttal exhibits as identified by Fred Millard. Confer with Courtney Pentek to identify documents showing names and contact information for rebuttal witnesses submitted during claim process. Email draft rebuttal witness statements to Mike Carney to review for accuracy and for specific fact checking. Email draft rebuttal witness statements to Client for review and fact checking. Email Sara Cotton regarding interview with Scott's Seed Employee. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 Confer with Courtney Pentek regarding status of identification of prior notice to Country of rebuttal witnesses. Confer with Christopher Fanning analyzing Responses to Motions in Limine. Draft Responses to Objections to Trial Exhibits. Phone call with James Kloft analyzing his rebuttal witness statement and rebuttal photographs. Draft rebuttal witness statement for James Kloft. Draft rebuttal witness statement for Paul Kloft. Draft rebuttal witness statements for Jim Brady, Ron Gray and Jeffrey Frenette. Confer with Heidi Gross analyzing photos for rebuttal exhibits. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 03 Doug Bragg Doug Bragg $280 $280 02 03 $56.00 $84.00 09 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 09 0.1 0.1 $252.00 $28.00 $28.00 Doug Bragg $280 03 Explanation 03 ATTACHMENT 1 Hrs Deducted by Court and Reason 0.2 Duplicative; billed to Bragg All - Duplicative; billed to Bragg All - Clerical All - Duplicative; billed to Millard $84.00 Page 147 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/28/13 Confer with Fred Millard analyzing status of Wave 3 of Pre-Trial filings. 03 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 3/28/13 Confer with Fred Millard analyzing Defendant's Proposed Jury Verdict Form. Continue working on draft rebuttal witness statements. Review and analyze draft response to Motions in Limine. Confer with Christopher Fanning analyzing revisions to Draft Responses to Motions in Limine. Phone call with Mike Carney regarding interview with David Lambie and office meeting. Review/respond to emails from Mike Carney regarding interview with David Lambie. Meet with Fred Millard to analyze rebuttal exhibits. 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 0.1 05 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.1 05 02 $28.00 $140.00 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 08 02 Doug Bragg Doug Bragg $280 $280 08 02 $224.00 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Fred Millard $350 0.1 $35.00 03 02 Fred Millard Fred Millard $350 $350 03 02 $105.00 $70.00 03 10 Fred Millard Christopher Fanning $350 $182 03 10 $105.00 $182.00 03 0.4 0.1 03 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 03 0.4 0.1 03 $54.60 $72.80 $18.20 $54.60 03 Christopher Fanning $182 03 $54.60 3/29/13 3/29/13 3/29/13 Confer with Courtney Pentek analyzing additional rebuttal exhibits and revision to rebuttal exhibit list. Review/respond to email from Mike Carney about David Lambie meeting and status of Production Services witness. Email draft rebuttal witness statements to Client for review and comment. Draft Responses to Objections to Trial Exhibits. Review/respond to email from Dannielle Booth regarding potential duplication in Robert Halsey's report. Phone call with James Kloft regarding revisions to rebuttal witness statement. Phone call with Mike Carney regarding David Lambie's request to be paid for an in-person interview. Confer with Doug Bragg analyzing rebuttal exhibits and rebuttal witnesses. Confer with Doug Bragg analyzing status of Wave 3 filings. Confer with Doug Bragg analyzing Defendant's Proposed Jury Verdict Form. Meet with Doug Bragg to analyze rebuttal exhibits. Draft supplemental declaration for Doug Bragg in support of Pre-Trial filings. Draft declaration of Paul Kloft in support of Pre-Trial filings. Identify and analyze exhibits for Declarations. Identify and analyze rebuttal exhibits. Review and analyze Country's objections to our expert witness narratives. Review and analyze Robert Halsey's expert report to verify duplication that Country is complaining about. Prepare subpoena for David Lambie. Draft response to Country's objections to our witnesses. Analyze Wave 3 filings with Fred Millard and Doug Bragg. 02 1.7 0.4 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 02 1.7 02 $36.40 $309.40 $36.40 3/29/13 3/29/13 3/29/13 Review and revise response to objections to exhibits. Draft Declaration of Fred Millard in Support of Pre-Trial filings. Revise Plaintiff's Responses to Defendant's Objections to Witnesses. 1.6 03 09 Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 1.6 03 09 $291.20 $54.60 $163.80 3/29/13 Compile, organize and prepare Rebuttal Exhibits for submittal to Court and Country. Review and analyze updated report from Mike Carney regarding Earl Doman, Production Services, and Doerfler Farms. 55 Courtney Pentek $50 00 $0.00 02 Doug Bragg $280 02 $56.00 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/28/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard 0.2 Duplicative; billed to Millard All - Clerical Page 148 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 3/29/13 Phone call with Paul Kloft regarding rebuttal witness statements. 0.1 Doug Bragg $280 0.1 $28.00 3/29/13 Confer with Christopher Fanning analyzing objections to expert witnesses filed by Country. Continue draft responses to Defendant's Objections to Plaintiff's Trial Exhibits. Meet with Mike Carney, David Lambie and Fred Millard regarding Mr. Lambie's potential testimony at trial. Confer with Courtney Pentek analyzing rebuttal exhibits. Review and analyze defendant's objections to Plaintiff's Expert witnesses. Confer with Christopher Fanning and Fred Millard analyzing Wave 3 filings. Confer with Christopher Fanning analyzing revisions to Response to Objections to lay witnesses. Confer with Fred Millard and Christopher Fanning analyzing settlement strategy and case status. Research obligations of attorney's of record. Confer with Fred Millard analyzing scheduling a mediation, and direct Heidi Gross to contact Judge Gardner analyzing setting up a mediation. 02 Doug Bragg $280 02 $56.00 12 Doug Bragg $280 12 $336.00 25 Doug Bragg $280 00 $0.00 02 02 Doug Bragg Doug Bragg $280 $280 02 02 $56.00 $56.00 02 Doug Bragg $280 00 $0.00 0.7 Doug Bragg $280 0.7 $196.00 02 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 02 02 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 02 00 $56.00 $0.00 Phone call with Judge Gardner regarding mediation. Email confirmation of mediation and pre-mediation statement to counsel and Judge Gardner. Revise Responses to Motions in Limine. Confer with Christopher Fanning analyzing Wave 3 Pre-Trial filings. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 02 02 Doug Bragg Doug Bragg $280 $280 02 00 $56.00 $0.00 Draft response to Motion in Limine objecting to Greg Mettler. Confer with Christopher Fanning and Doug Bragg analyzing Wave 3 filings. Confer with Doug Bragg and Christopher Fanning analyzing settlement strategy and case status. Confer with Doug Bragg analyzing scheduling a mediation. Phone call with Dan Thenell RE: mediation. Prepare for and conduct meeting with Mike Carney, David Lambie and Doug Bragg regarding David Lambie's potential testimony at trial. 0.6 02 Doug Bragg Fred Millard $280 $350 0.6 02 $168.00 $70.00 02 Fred Millard $350 02 $70.00 02 02 25 Fred Millard Fred Millard Fred Millard $350 $350 $350 02 02 25 $70.00 $70.00 $875.00 3/29/13 3/29/13 Prepare additional exhibits (photographs). Telephone call with Judge Gardner to check his availability for mediation on April 4th; Telephone call with Fred Millard confirming the mediation. 05 0.1 Heidi Gross Heidi Gross $50 $50 All - Clerical All - Clerical 00 00 $0.00 $0.00 3/29/13 Telephone call with James Kloft requesting he be sure that Paul knows of the mediation; E-memo Client twice - with confirmation and details of mediation. Review and analyze Expert Narrative for Paul Kloft and revise responses to objections to Paul Kloft's expert narrative. Review comments from Paul Kloft and James Kloft regarding rebuttal witness statements, and revise rebuttal witness statements. 02 Heidi Gross $50 All - Clerical 00 $0.00 05 Doug Bragg $280 05 $140.00 0.4 Doug Bragg $280 0.4 $112.00 Review/respond to email from Mike Carney regarding witness subpoenas and witness statements for lay witnesses. Revise Rebuttal Witness Statement of David Lambie based upon conversation with Mr. Lambie. Revise Rebuttal Exhibit List. 0.1 Doug Bragg $280 0.1 $28.00 0.6 Doug Bragg $280 0.6 $168.00 0.1 Doug Bragg $280 0.1 $28.00 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/29/13 3/31/13 3/31/13 3/31/13 3/31/13 3/31/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 149 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 03 Doug Bragg 0.1 3/31/13 Revise Rebuttal Witness Statements - include occupation information for each witness. Email Mike Carney regarding the occupations for some of the grower witnesses for rebuttal expert witness statements. Draft e-memo to Fred Millard analyzing Wave 3 filings. $280 03 $84.00 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 3/31/13 3/31/13 3/31/13 Review and analyze draft Response to Objections to Exhibits. Revise Rebuttal Exhibit list. Review, analyze and revise draft Response to Objections to Witnesses. 03 0.1 03 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 03 0.1 03 $84.00 $28.00 $84.00 3/31/13 3/31/13 4/1/13 Review and analyze draft Response to Objections to Experts. Review e-memo from Doug Bragg analyzing Wave 3 filings. Meeting with Doug Bragg to analyze Wave 3 filings. 02 0.1 0.1 Doug Bragg Fred Millard Christopher Fanning $280 $350 $182 02 0.1 00 $56.00 $35.00 $0.00 4/1/13 09 Christopher Fanning $182 09 $163.80 05 0.6 Christopher Fanning Christopher Fanning $182 $182 05 0.6 $91.00 $109.20 4/1/13 Review and analyze filings and Doug Bragg's Declaration to verify accuracy. Review exhibits to Declarations to make sure they are correct. Making final corrections to citations in the different Wave 3 filings based on the final Declarations. Review and revise Reply Brief on our Motion for Reconsideration. 02 Christopher Fanning $182 02 $36.40 4/1/13 Review and analyze Country's Responses to our Motions in Limine. 05 Christopher Fanning $182 05 $91.00 4/1/13 4/1/13 05 05 Christopher Fanning Christopher Fanning $182 $182 00 05 $0.00 $91.00 4/1/13 4/1/13 4/1/13 4/1/13 File third wave of Pre-trial filings. Review and analyze Country's responses to our challenges of its witnesses. Draft mediation statement. Review and analyze response to objections to exhibits. Review and analyze response to objections to witnesses. Review and analyze response to objections to expert narratives. 03 05 0.1 02 Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning $182 $182 $182 $182 03 05 0.1 02 $54.60 $91.00 $18.20 $36.40 4/1/13 4/1/13 4/1/13 Review and analyze Responses to Motions in Limine. Finish preparing rebuttal exhibits for submittal to Court. Email to Michelle Rawson RE: Impeachment and Rebuttal Exhibits. 0.1 40 0.1 Christopher Fanning Courtney Pentek Courtney Pentek $182 $50 $50 0.1 00 00 $18.20 $0.00 $0.00 4/1/13 4/1/13 Email to Kim Ellingson RE: her deposition transcript. Review email from James Kloft regarding response to specific statements in Defendant's Lay and Expert Witness statements. Review email from Mike Carney regarding occupation of Bernie Bielenberg. Revise rebuttal witness statements to include occupation of Bernie Bielenberg. Review email from Mike Carney regarding Wallace Zielinski's witness statement. Draft e-memo to Fred Millard and Heidi Gross analyzing mediation statement preparation. Draft single page list of all witnesses. Final review and analysis of Responses to Motions in Limine. Review email from Mike Carney regarding Wallace Zielinski's information for Rebuttal Witness list. Review email from Mike Carney regarding Edward Merced, Neil Cooper and Bernie Bielenberg information for rebuttal witness statements. 0.1 0.1 Courtney Pentek Doug Bragg $50 $280 00 0.1 $0.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 02 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 0.1 $56.00 $56.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 3/31/13 3/31/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Duplicative; billed to Millard All - Duplicative; billed to Bragg All - Clerical All - Clerical All - Clerical All - Clerical Page 150 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 4/1/13 Revise rebuttal witness statements to include additional information on Wallace Zielinski, Edward Merced, Neil Cooper and Bernie Bielenberg. 0.1 Doug Bragg $280 0.1 $28.00 4/1/13 0.1 Doug Bragg $280 0.1 $28.00 09 0.1 Doug Bragg Doug Bragg $280 $280 09 0.1 $252.00 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 4/1/13 Review email from James Kloft with comments on Defendant's Lay Witness Statements and Expert Narratives. Phone call to Client analyzing rebuttal witness statements. Revise Rebuttal witness statements based upon comments from James Kloft. Review email from Mike Carney analyzing Dan Keeley information for rebuttal witness statements. Revise rebuttal witness statements to include updated information for Dan Keeley. Email rebuttal witness statements and rebuttal exhibit list to client for review. Confer with Christopher Fanning analyzing responses to objections to exhibits. Confer with Fred Millard analyzing Wave 3 filings. 02 Doug Bragg $280 00 $0.00 4/1/13 Confer with Courtney Pentek analyzing Response to Motions in Limine. 0.1 Doug Bragg $280 0.1 $28.00 4/1/13 Confer with Christopher Fanning analyzing additions to Fred Millard's declaration in support of responses to objections to exhibits. 0.1 Doug Bragg $280 0.1 $28.00 4/1/13 Prepare exhibit of Mike Billman's updated schedule for submittal with declaration. Review draft declaration of Douglas M. Bragg in support of pre-trial filings. Confer with Christopher Fanning analyzing revisions to draft Declaration for Doug Bragg in Support of Pre-Trial Filings, and identification of rebuttal witnesses. Phone call with Paul Kloft analyzing rebuttal witness statements. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 Review additional comments from James Kloft regarding his rebuttal witness statement and revise accordingly. Confer with Fred Millard analyzing rebuttal exhibits. 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 4/1/13 Review email from Client regarding revision to rebuttal statement for Hyrum Laney. Revise rebuttal witness statements to include updated information for Hyrum Laney and finalize for filing. Confer with Fred Millard analyzing rebuttal exhibit list. 0.1 Doug Bragg $280 00 $0.00 4/1/13 Confer with Courtney Pentek analyzing additions to rebuttal exhibits. 0.1 Doug Bragg $280 0.1 $28.00 4/1/13 4/1/13 4/1/13 4/1/13 Confirm status of Wave 3 filings. Review letter to court with Wave 3 filings; Execute same. Draft mediation statement. Review and analyze Defendant's Response to Plaintiff's Witness Objections. Review/respond to email from Mike Carney about confirmation of witness statements and subpoenas. Review emails from Dan Thenell and Judge Gardner confirming mediation. 0.1 0.1 0.7 02 Doug Bragg Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 $280 0.1 0.1 0.7 02 $28.00 $28.00 $196.00 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Duplicative; billed to Millard All - Duplicative; billed to Millard All - Duplicative; billed to Millard Page 151 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Phone call with Kim Ellingson regarding her subpoena for trial testimony, discussed options for preparing for trial testimony and recommended that she tell the truth, whatever that is and regardless of whether or not it would "hurt" Precision. Review billings to analyze recoverable attorney fees. Confer with Fred Millard to analyze mediation statement. Confer with Christopher Fanning analyzing draft mediation statement. 02 Doug Bragg $280 02 $56.00 0.4 02 0.1 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 0.4 02 0.1 $112.00 $56.00 $28.00 Phone call to Client regarding Rebuttal Witness Statements. Revise Rebuttal Witness Statement to correct Wallace Zielinski's statement. Review and analyze drafts of Wave 3 Submittals providing comments and annotations. Review and analyze submittals by Country for Wave 3; Commence review of Depositions to prepare for cross-examinations. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 0.1 0.1 $28.00 $28.00 2.1 Fred Millard $350 2.1 $735.00 4.1 Fred Millard $350 4.1 $1,435.00 4/1/13 Review and analyze draft of Mediation Statement, and work with Chris Fanning and Doug Bragg to redraft and revise sections of Mediation Statement, conduct matter conference with staff to analyze revisions and participate in redrafting sections of Mediation Statement, and review e-memo from Doug Bragg RE: Mediation preparation. 2.4 Fred Millard $350 2.4 $840.00 4/1/13 4/1/13 4/1/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 Confer with Doug Bragg analyzing Wave 3 filings. Confer with Doug Bragg analyzing rebuttal exhibits. Confer with Doug Bragg on analyzing exhibit list. Draft mediation statement. Analyze changes to mediation statement with Fred Millard. Review and analyze mediation statement revisions. Revise mediation statement. Review and analyze billings for attorney fee claim for mediation. 02 0.1 0.1 38 05 0.6 03 28 Fred Millard Fred Millard Fred Millard Christopher Fanning Christopher Fanning Christopher Fanning Christopher Fanning Doug Bragg $350 $350 $350 $182 $182 $182 $182 $280 02 0.1 0.1 38 05 0.6 03 28 $70.00 $35.00 $35.00 $691.60 $91.00 $109.20 $54.60 $784.00 4/2/13 Confer with Christopher Fanning analyzing mediation statement. 02 Doug Bragg $280 02 $56.00 4/2/13 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 23 02 Doug Bragg Doug Bragg $280 $280 23 02 $644.00 $56.00 02 03 05 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 03 05 $56.00 $84.00 $140.00 08 0.1 35 Doug Bragg Doug Bragg Christopher Fanning $280 $280 $182 08 0.1 35 $224.00 $28.00 $637.00 4/3/13 Confer with Fred Millard analyzing mediation statement and approach to legal fees for Don Kelley in related litigation due to non-payment by Country. Confer with Christopher Fanning analyzing approach to "additional legal fees" in mediation statement. Review/respond to email from Michelle Rawson regarding rebuttal and impeachment exhibit numbering issue. Draft mediation statement. Phone call with Michael Rodrigue regarding status of trial and preparation for witness testimony. Confer with Fred Millard analyzing mediation statement. Review draft mediation statement. Meet with Fred Millard and Christopher Fanning to analyze draft mediation statement. Revise draft mediation statement. Email Judge Gardner the mediation statement. Compile, organize and prepare trial documents (exhibits and relevant briefings) in preparation for mediation. Phone call to Paul Kloft and draft e-mail to Paul Kloft RE: mediation. 02 Christopher Fanning $182 02 $36.40 4/3/13 Assist in preparation for mediation - prepare documents for mediation. 40 Courtney Pentek $50 00 $0.00 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/1/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 4/2/13 4/3/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Clerical Page 152 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount 15 02 Doug Bragg Doug Bragg 03 0.4 4/4/13 4/4/13 4/4/13 4/5/13 Finish initial review of billing entries. Confer with Christopher Fanning and Courtney Pentek analyzing documents for mediation. Mediation preparation. Organize and compile pictures and deliver them to settlement conference. Assisting at settlement conference. Prepare for and attend mediation. Prepare for and attend Mediation. Pulling case (Missouri v. Jenkins ) for Fred Millard RE: Attorney Fees. $280 $280 15 02 $420.00 $56.00 Fred Millard Christopher Fanning $350 $182 03 0.4 $105.00 $72.80 12 70 70 02 Christopher Fanning Doug Bragg Fred Millard Christopher Fanning $182 $280 $350 $182 12 70 70 02 $218.40 $1,960.00 $2,450.00 $36.40 4/5/13 Email and call witnesses to let them know that the case settled. 0.4 Christopher Fanning $182 0.4 $72.80 4/5/13 Phone call with Mike Carney regarding settlement and no need for subpoenas and direct him to alert witnesses that trial will not go forward. Review/respond to emails from Court and Dan Thenell regarding status conference for April 23. Review/respond to email from Dannielle Booth regarding formal settlement agreement and status of settlement payment. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 4/18/13 Review/respond to email from Dannielle Booth regarding settlement agreement and availability of checks. Review and analyze draft Settlement Agreement from Country. 03 Doug Bragg $280 03 $84.00 4/18/13 Confer with Fred Millard analyzing draft Settlement Agreement. 0.1 Doug Bragg $280 All - Duplicative; billed to Millard 00 $0.00 4/18/13 4/18/13 Review email from Dan Thenell regarding settlement. Confer with Fred Millard analyzing email from Dan Thenell on settlement payment and Settlement Agreement. Review and analyze insurance policy as it pertains to loss payees. 0.1 0.6 Doug Bragg Doug Bragg $280 $280 All - Duplicative; billed to Millard 0.1 00 $28.00 $0.00 02 Doug Bragg $280 02 $56.00 Review draft email to Dan Thenell analyzing settlement payment and breach of settlement agreement. Confer with Doug Bragg analyzing draft Settlement Agreement. Confer with Doug Bragg analyzing email from Dan Thenell on settlement payment and Settlement Agreement. Review and analyze draft of Country's formal Agreement comparing it to the handwritten version; Review and respond to Dan Thenell's email concerning comparison of formal and handwritten Settlement Agreement; Telephone call with Paul Kloft regarding Settlement Agreement issues; Telephone call with Don Kelley RE: Outstanding Creditors. Review emails from Dan Thenell, Judge Gardner and Fred Millard analyzing Settlement Agreement and additional payees on settlement payment. Confer with Fred Millard analyzing settlement issues. Phone call with Don Kelley analyzing settlement issues. Review and analyze email from Dan Thenell disregarding Judge Gardner's instructions regarding single payee on checks. Review and analyze emails from Fred Millard responding to Dan Thenell. 02 Doug Bragg $280 02 $56.00 0.1 0.6 Fred Millard Fred Millard $350 $350 0.1 0.6 $35.00 $210.00 0.7 Fred Millard $350 0.7 $245.00 02 Doug Bragg $280 02 $56.00 02 02 02 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 02 02 $56.00 $56.00 $56.00 02 Doug Bragg $280 02 $56.00 Confer with Fred Millard analyzing response to Dan Thenell's email regarding Settlement Agreement issues. 0.4 Doug Bragg $280 0.4 $112.00 4/3/13 4/3/13 4/3/13 4/4/13 4/5/13 4/17/13 4/18/13 4/18/13 4/18/13 4/18/13 4/18/13 4/18/13 4/19/13 4/19/13 4/19/13 4/19/13 4/20/13 4/20/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 153 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Submit Country's version of Settlement Agreement and our redlined Settlement Agreement to Judge Gardner. Review and analyze emails from Judge Gardner and Fred Millard regarding settlement. Confer with Fred Millard analyzing redlined version of the formal agreement. Revise redlined version of the agreement pursuant to conversation with Fred Millard. Phone call with Don Kelley in preparation for upcoming phone conference with Judge Gardner. Confer with Fred Millard in preparation for phone conference with Judge Gardner on mediation. Attend phone conference with Judge Gardner and Dan Thenell analyzing issues with settlement agreement. Confer with Fred Millard analyzing revisions to Settlement Agreement pursuant to phone conference with Judge Gardner. Phone call with Don Kelley analyzing declaration analyzing paid loss payees. Revise draft Settlement Agreement pursuant to phone conversation with Mediator, Fred Millard and Dan Thenell. Email revised draft Settlement Agreement to Dan Thenell and Dannielle Booth. Confer with Fred Millard in preparation for conference call with the Court. Draft email to Michelle Rawson regarding reset of status conference due to pending "formal" agreement. Telephone call with Paul Kloft to inform him there will be a phone conference this afternoon with Mark Gardner; E-memo attorneys. 03 Courtney Pentek $50 All - Clerical 02 Doug Bragg 03 Explanation Hrs Awarded Amount 00 $0.00 $280 02 $56.00 Doug Bragg $280 03 $84.00 03 Doug Bragg $280 03 $84.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 03 Doug Bragg $280 03 $84.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 0.1 Heidi Gross $50 00 $0.00 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.4 Doug Bragg $280 0.4 $112.00 02 Doug Bragg $280 02 $56.00 4/23/13 Review and analyze latest draft of the Settlement Agreement, and draft e-memo to Fred Millard analyzing same. Phone call with Paul Kloft regarding status of settlement agreement and release of funds. Phone call with Fred Millard analyzing issues with settlement agreement. Attend phone conference with Court regarding remaining issues and settlement. Confer with Fred Millard analyzing status conference and potential issues with settlement agreement. Research basis for costs under Federal Rule 54(d) and 28 USC 1920. 03 Doug Bragg $280 03 $84.00 4/23/13 Draft email to Dan Thenell analyzing revisions to Settlement Agreement. 03 Doug Bragg $280 03 $84.00 4/23/13 Phone call with Paul Kloft regarding Settlement Agreement issues. 02 Doug Bragg $280 02 $56.00 4/23/13 Phone call to Don Kelley regarding American Lease Fund, left message. 0.1 Doug Bragg $280 0.1 $28.00 4/23/13 Phone call with Don Kelley analyzing proof of satisfaction of loss payees claims. Review email from Don Kelley confirming payoff for American Lease Fund. Draft email to Dan Thenell regarding payoff to American Lease Fund and status of Settlement Agreement. Review, analyze and respond to email from Dan Thenell regarding revisions to Settlement Agreement. 02 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/22/13 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 3:10-cv-01023-HZ ATTACHMENT 1 All - Clerical Page 154 of 161 Date Hrs Awarded Amount $280 $280 $280 0.1 0.1 0.1 $28.00 $28.00 $28.00 Doug Bragg $280 09 $252.00 02 05 0.1 Doug Bragg Fred Millard Doug Bragg $280 $350 $280 02 05 0.1 $56.00 $175.00 $28.00 Calculate prejudgment interest in preparation for motion regarding same. Draft communication to Bob Bonaparte RE: potential association. 02 Doug Bragg $280 02 $56.00 02 Fred Millard $350 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 10 02 Doug Bragg Doug Bragg $280 $280 All - Unreasonable; All - Unreasonable; 00 00 $0.00 $0.00 02 Doug Bragg $280 All - Unreasonable 00 $0.00 4/30/13 Email Dan Thenell regarding status of replacement checks and instructions on the non-conforming checks. Review correspondence from Hunter Emerick regarding West Coast Bank Assignment and payoff. Phone call with Bob Bonaparte analyzing fee petition issues. Confer with Fred Millard analyzing phone call with Bob Bonaparte and fee petition. Review, analyze and respond to email from Bob Bonaparte analyzing fee petition. Review and analyze draft stipulated motion for additional payee. 02 Doug Bragg $280 02 $56.00 4/30/13 Review and analyze emails and correspondence relating to "costs". 02 Doug Bragg $280 02 $56.00 4/30/13 Draft e-memo to Fred Millard analyzing Country's unilateral modification of the Settlement Agreement for its purposes but unwillingness to modify for Precision. Review, analyze and respond to email from Bob Bonaparte analyzing documents to assist in preparation for meeting on fees. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 00 $0.00 4/30/13 Confer with Fred Millard analyzing Settlement Agreement "modification" to include costs and additional payees on the check. 03 Doug Bragg $280 03 $84.00 4/30/13 Email Judge Gardner analyzing agreement modification to correct mutual errors - costs and additional payee. Confer with Fred Millard analyzing response to proposed Stipulated Motion analyzing payment of settlement funds. Email Dan Thenell and Dannielle Booth regarding payment of remaining settlement funds and proposed stipulated motion. Confer with Heidi Gross re: West Coast bank inquiry sent by Don Kelley on Friday, the 27th. Prepare and attend meeting with Fred Millard and Bob Bonaparte analyzing attorney fee portion of the case. Phone call to Dan Thenell regarding resolution of remaining payment issues, left voicemail. Prepare and attend meeting with Doug Bragg and Bob Bonaparte analyzing attorney fee portion of the case. Phone call to Dan Thenell regarding settlement agreement issues (Country's ongoing breach pending modification of payment terms), left voicemail. Review and analyze filing regarding stipulated motion for order regarding loss payee. 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 03 Doug Bragg $280 03 $84.00 13 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 13 Fred Millard $350 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 02 Doug Bragg $280 02 $56.00 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 4/23/13 4/24/13 4/24/13 4/24/13 4/25/13 4/25/13 4/29/13 4/29/13 4/29/13 4/30/13 4/30/13 4/30/13 4/30/13 5/1/13 5/1/13 5/1/13 5/2/13 5/2/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Email Judge Gardner regarding cost issue. Review response from Judge Gardner on cost issue. Phone call to Paul Kloft regarding Settlement Agreement and left message to come in. Prepare for and conduct meeting with Paul Kloft to review Settlement Agreement. Scan and email final signed release to Dan Thenell. Matter conference with Client to review Settlement draft. Email Dan Thenell regarding replacement Scheduled Equipment checks. 0.1 0.1 0.1 Doug Bragg Doug Bragg Doug Bragg 09 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Unreasonable; All - Unreasonable All - Unreasonable All - Unreasonable Page 155 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount $0.00 $56.00 $0.00 5/2/13 5/2/13 5/2/13 Email Bob Bonaparte analyzing fee related discovery. Research inclusion of certain costs in attorney fees. Telephone call with Client discussing retaining experts and co-counsel on issues analyzing fee petition and prejudgment interest. 02 02 0.6 Doug Bragg Doug Bragg Fred Millard $280 $280 $350 All - Unreasonable All - Unreasonable 00 02 00 5/2/13 Matter conference with Doug Bragg analyzing retaining experts and cocounsel on issues analyzing fee petition and prejudgment interest. 05 Fred Millard $350 All - Unreasonable 00 $0.00 5/3/13 Review and analyze defense counsel's tactics that increased litigation expenses. Telephone call with Paul Kloft regarding the release of funds; E-memo Doug Bragg and Fred Millard re: Paul Kloft's request to pick up funds. 05 Christopher Fanning $182 05 $91.00 0.1 Heidi Gross $50 All - Clerical 00 $0.00 5/7/13 5/7/13 Phone call with Bob Bonaparte analyzing attorney fee issues. Phone call with Bob Bonaparte analyzing issues for fee petition. 0.1 12 Doug Bragg Doug Bragg $280 $280 All - Unreasonable All - Unreasonable 00 00 $0.00 $0.00 5/7/13 Client meeting regarding status of payment of settlement funds and issues raised as a result of the continuing delay. Review, analyze and respond to email from Court regarding Stipulated Motion regarding payment of settlement funds. Review and analyze draft declaration by paralegal expert from Bob Bonaparte. Email Bob Bonaparte comments regarding draft declaration of paralegal expert. Review and analyze draft declaration for Michele Barbara. Email Bob Bonaparte analyzing draft declaration for Michele Barbara. 03 Doug Bragg $280 03 $84.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 Doug Bragg $280 02 $56.00 02 0.1 Doug Bragg Doug Bragg $280 $280 02 0.1 $56.00 $28.00 5/7/13 Review correspondence from Bob Bonaparte to Gary Berne regarding expert testimony on reasonableness of work performed. 0.1 Doug Bragg $280 0.1 $28.00 5/7/13 5/7/13 Review notice of appearance filed by Bob Bonaparte. Review letter from Bob Bonaparte to Dan Thenell regarding attorney fee phase of litigation and potential mediation. Email Bob Bonaparte regarding Don Kelley's fees and inclusion of his office staff in fee petition. Review and analyze email from Dan Thenell to Court regarding purpose of stipulated motion. Email Don Kelley regarding payment to bank and discuss association of Shenker & Bonaparte. Phone call with Bob Bonaparte analyzing issues for fee petition. 0.1 0.1 Doug Bragg Doug Bragg $280 $280 All - Unreasonable 00 0.1 $0.00 $28.00 0.1 Doug Bragg $280 All - Unreasonable 00 $0.00 02 Doug Bragg $280 02 $56.00 0.2 Doug Bragg $280 0.1 Unreasonable 0.1 $28.00 1.2 Doug Bragg $280 All - Unreasonable 00 $0.00 Client meeting regarding status of payment of settlement funds and issues raised as a result of the continuing delay. Review, analyze and Respond to email from Court regarding Stipulated Motion regarding payment of settlement funds. Review and analyze draft declaration for paralegal expert. 0.3 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.2 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.2 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 Email Bob Bonaparte comments regarding draft declaration of paralegal expert. Review and Analyze draft declaration for Michele Barbara in support of fee petition. Email Bob Bonaparte analyzing draft declaration for Michele Barbara in support of fee petition. 0.2 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.2 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.1 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 5/6/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 5/7/13 3:10-cv-01023-HZ ATTACHMENT 1 Page 156 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded 5/7/13 Review correspondence from Bob Bonaparte to Gary Berne regarding expert testimony on reasonableness of work performed. 0.1 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 5/7/13 Review notice of appearance filed by Bob Bonaparte. 0.1 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 5/7/13 Review letter from Bob Bonaparte to Dan Thenell regarding attorney fee phase of litigation and potential mediation. Email Bob Bonaparte regarding Don Kelley's fees and inclusion of his office staff in fee petition. Review and analyze email from Dan Thenell to Court regarding purpose of Stipulated Motion. Review email from court granting stipulated motion regarding additional payees. Review and analyze draft Request for Production to Country regarding attorney fee phase of litigation. Email Bob Bonaparte regarding comments on draft Request for Production. Review, analyze and respond to emails from Bob Bonaparte regarding fee petition issues. Review Bob Bonaparte's correspondence to Thenell Law Group; Draft email to Bonaparte concerning same. Matter conference with Bob Bonaparte and Arden Shenker analyzing issues regarding recovery of attorney fees and discussing factual issues for prejudgment interest recovery Telephone call with Client regarding his questions concerning mediation and other issues associated with payment of settlement amount, prejudgment interest, and Fees Attend meeting with Bob Bonaparte, Fred Millard, Arden Shenker and Christopher Fanning reviewing factual history of case as it relates to attorney fees and prejudgment issues and analyze those issues in preparation for briefing for the court. Review and analyze email from Dan Thenell regarding potential mediation of remaining issues. Review email from Dan Thenell regarding status of remaining payment. 0.1 Doug Bragg $280 All- Duplicative of Same Day Entry 00 $0.00 0.1 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.2 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.1 Doug Bragg $280 0.1 $28.00 0.3 Fred Millard $350 00 $0.00 0.1 Fred Millard $350 0.1 $35.00 2.1 Fred Millard $350 00 $0.00 0.6 Fred Millard $350 0.6 $210.00 2.1 Doug Bragg $280 00 $0.00 0.2 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 Review time entries from inception of the case through end of 2011 in preparation for conference with Bob Bonaparte and Arden Shenker on attorney fee phase of litigation. Review and analyze draft Motion for Attorney Fees. Draft memorandum to court regarding prejudgment interest. Review Deposition transcript of Kevin Loe to verify date of employment and amount of time needed to analyze seed values. 1.2 Doug Bragg $280 12 $336.00 0.2 1.6 0.3 Doug Bragg Doug Bragg Doug Bragg $280 $280 $280 02 1.6 03 $56.00 $448.00 $84.00 Phone conference with Bob Bonaparte analyzing fee petition issues and potential concerns. Draft e-memo to Bob Bonaparte analyzing interrelationship between Ionian v. Country and Precision v. Country matters. Review, analyze and revise draft declaration for Fred Millard in support of Petition for Attorney's fees. Review, analyze and revise draft Memorandum in Support of Motion for Attorney fees. Review, analyze and respond to emails from Bob Bonaparte and Kayla Bronson regarding mediation on fee petition and prejudgment interest issues. 0.5 Doug Bragg $280 All - Unreasonable 00 $0.00 0.2 Doug Bragg $280 All - Unreasonable 00 $0.00 0.9 Doug Bragg $280 09 $252.00 0.5 Doug Bragg $280 05 $140.00 0.2 Doug Bragg $280 02 $56.00 5/7/13 5/7/13 5/9/13 5/9/13 5/9/13 5/9/13 5/9/13 5/9/13 5/9/13 5/10/13 5/10/13 5/10/13 5/10/13 5/16/13 5/16/13 5/16/13 5/16/13 5/22/13 5/30/13 5/30/13 6/3/2013 3:10-cv-01023-HZ ATTACHMENT 1 All - Unreasonable All - Unreasonable All - Unreasonable/Duplicative Amount Page 157 of 161 Date 6/3/2013 6/3/2013 6/3/2013 6/3/2013 6/3/2013 6/3/2013 6/3/2013 6/3/2013 6/5/2013 6/5/2013 6/5/2013 6/5/2013 6/5/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 6/7/2013 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Confer with Fred Millard analyzing mediation scheduling and impact on briefing schedule. Review and analyze draft letter to Gary Berne regarding impact of aggressive defense tactics upon litigation costs. Email Bob Bonaparte comments on draft letter to Gary Berne. Phone call with Bob Bonaparte regarding fee petition preparation. 0.1 Doug Bragg $280 0.1 $28.00 0.2 Doug Bragg $280 02 $56.00 0.1 0.4 Doug Bragg Doug Bragg $280 $280 0.1 00 $28.00 $0.00 Review and analyze timeline of key dates in avoiding or minimizing the risk of attorney fees. Email Bob Bonaparte revisions to timeline of key dates in avoiding attorney fees. Review emails from Bob Bonaparte to Dan Thenell regarding responsive filings to fee petition and non-disclosure agreement and impact on fee petition. Phone call with Bob Bonaparte analyzing hourly rates in the 2012 Economic Survey. Review, analyze and comment on the procedural matrix developed by Bob Bonaparte. Review order from court granting motion for extension of page limit for brief. Review and analyze Isler v. Shuck and related cases in relation to prejudgment interest analysis. Review, analyze and revise draft brief relating to prejudgment interest. 0.2 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.2 Doug Bragg $280 All - Unreasonable 00 $0.00 0.3 Doug Bragg $280 All - Unreasonable 00 $0.00 0.1 Doug Bragg $280 0.1 $28.00 0.3 Doug Bragg $280 03 $84.00 0.4 Doug Bragg $280 0.4 $112.00 Analyze value of prejudgment interest claim and calculate reasonable amount for purposes of mediation. Phone call with Gary Berne, attorney fee expert, to discuss time spent on the case. Draft declaration in support of Motion for Attorney Fees and Prejudgment Interest. Review and analyze revisions to Memorandum in Support of Motion for Attorney Fees and Prejudgment Interest. Review and analyze revisions to Memorandum in Support of Motion for Attorney fees and prepare Declaration of Douglas M. Bragg in Support of same to support various statements within the Memorandum. 0.2 Doug Bragg $280 02 $56.00 0.4 Doug Bragg $280 0.4 $112.00 0.4 Doug Bragg $280 0.4 $112.00 0.1 Doug Bragg $280 0.1 $28.00 2.9 Doug Bragg $280 29 $812.00 Attend meeting with Gary Berne reviewing litigation history to assist with his analysis of the reasonable amount of time. Draft e-memo to Bob Bonaparte confirming time summaries requested by Gary Berne. Review and analyze defendant's Motion for Protective Order. Review, analyze and revise memorandum in support of fee petition. 1.0 Doug Bragg $280 10 $280.00 0.2 Doug Bragg $280 00 $0.00 0.1 1.3 Doug Bragg Doug Bragg $280 $280 0.1 13 $28.00 $364.00 Phone call with Bob Bonaparte regarding project for Gary Berne, status of memorandum in support of petition for attorney fees, and response to Motion for Protective Order. Draft e-memo to Bob Bonaparte regarding revisions to memorandum and draft declaration for myself. Review and analyze time categorization by Tracy Poole. Review breakdown of Pre-Lit Claim Investigation time to Gary Berne. 0.3 Doug Bragg $280 All - Unreasonable 00 $0.00 0.2 Doug Bragg $280 All - Unreasonable 00 $0.00 0.3 0.2 Doug Bragg Doug Bragg $280 $280 03 02 $84.00 $56.00 Review, analyze and compile time sheets by category of activity per Gary Berne's request. 1.2 Doug Bragg $280 12 $336.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Unreasonable All- Unreasonable All - Unreasonable Page 158 of 161 Date 6/10/13 6/11/2013 6/11/2013 6/11/2013 6/11/2013 6/11/2013 6/11/2013 6/11/2013 6/11/13 6/12/2013 6/12/2013 6/12/2013 6/12/2013 6/12/2013 6/12/13 6/13/2013 6/13/13 3:10-cv-01023-HZ Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Meeting with Doug Bragg RE: analysis and breakdown of time records for Gary Berne; Begin reviewing, analyzing and compiling time records (Appx 4,500 time entries) into specific categories for Gary Berne's future evaluation. Review, analyze and compile breakdowns of time spent on different types of activities to assist Gary Berne with his analysis. 4.0 Tracey Poole $115 40 $460.00 3.3 Doug Bragg $280 33 $924.00 Phone call with Bob Bonaparte analyzing revisions to memorandum in support of fee petition. Revise draft declaration for Fred Millard in support of fee petition. 0.1 Doug Bragg $280 00 $0.00 1.0 Doug Bragg $280 10 $280.00 Review, analyze and revise Motion for Fees and Prejudgment Interest as pertaining to prejudgment interest issue. Revise draft declaration in support of petition for attorney fees. 0.2 Doug Bragg $280 02 $56.00 0.6 Doug Bragg $280 0.6 $168.00 Review and analyze responses to request for production (attorney fee phase). Draft e-memo to Bob Bonaparte regarding responses to request for production. Continue analyzing, reviewing and compiling time entries into task categories for Gary Berne's analysis and review. Continue to categorize billing entries per Gary Berne's request and to assist in analysis of reasonable hours on various aspects of the case. 0.2 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 00 $0.00 3.5 Tracey Poole $115 35 $402.50 3.6 Doug Bragg $280 3.6 $1,008.00 Review, analyze and revise draft declaration in support of Motion for Attorney Fees and Prejudgment Interest. Analyze revisions to declaration in support of attorney fees and prejudgment interest with Tracey Poole. Prepare summary of time by category. Compose email to Gary Berne regarding billing entries by category summary and supporting documents. Receive instructions from Doug Bragg regarding revisions, formatting and exhibits needed for Declaration of Douglas M. Bragg in Support of Plaintiff's Motion for Attorney Fees and Prejudgment Interest; Revise draft Declaration of Douglas M. Bragg in Support of Plaintiff's Motion for Attorney Fees and Prejudgment Interest and direct Courtney Pentek to email draft of same to Bob Bonaparte for review and analysis. Review Declaration and Court Docket Report for docket numbers of exhibits already filed with the Court and add docket numbers to Declaration. Also begin gathering, compiling and organizing exhibits to be filed with Declaration of Douglas M. Bragg. 1.5 Doug Bragg $280 15 $420.00 0.6 Doug Bragg $280 0.6 $168.00 0.8 0.2 Doug Bragg Doug Bragg $280 $280 08 02 $224.00 $56.00 5.5 Tracey Poole $115 55 $632.50 Review and analyze draft memorandum regarding prejudgment interest and identify and compile necessary exhibits to support the brief. Continue locating court docket numbers from OJIN Report to replace exhibits referenced in Declaration of Douglas M. Bragg in Support of Plaintiff's Motion for Attorney Fees and Prejudgment Interest and continue editing same; Continue compiling Exhibits to Declaration; Continue editing Declaration; Multiple discussions with Doug Bragg RE: Exhibits and revisions to Declaration. 0.6 Doug Bragg $280 0.6 $168.00 5.2 Tracey Poole $115 52 $598.00 Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason All - Unreasonable All - Unreasonable Page 159 of 161 Date Hrs Req Pltf Lawyer Rate Hrs Awarded Amount Review/respond to emails from Gary Berne regarding fee categories. Review docket and files to further cite appropriate portions of the record to support factual assertions in my declaration. 0.2 Doug Bragg $280 02 $56.00 1.4 Doug Bragg $280 1.4 $392.00 Draft portion of my declaration dealing with estimated additional time relating to attorneys fees as well as setting out time spent on the fee petition phase to date. Phone call with Gary Berne regarding clarification of time breakdowns. Revise draft memorandum relating to prejudgment interest to correct citations. Review and analyze the deposition transcript of Kevin Loe for statements relevant to the process used and areas of agreement with Plaintiff's seed valuation experts for use in prejudgment interest analysis. Review and analyze final exhibits for my declaration in support of the motion for attorneys fees and prejudgment interest. 0.2 Doug Bragg $280 02 $56.00 0.1 Doug Bragg $280 0.1 $28.00 0.6 Doug Bragg $280 0.6 $168.00 0.6 Doug Bragg $280 0.6 $168.00 0.2 Doug Bragg $280 02 $56.00 6/14/13 Complete final revisions to Doug Bragg's Declaration; Finalize Exhibits, marking, scanning and naming same for filing ready. 3.6 Tracey Poole $115 2.6 Clerical 10 $115.00 6/18/13 0.2 Doug Bragg $280 All - Unreasonable 00 $0.00 6/18/13 Phone call with Bob Bonaparte regarding Berne's opinion on the reasonableness of the time. Phone call with Bob Bonaparte regarding need to isolate conferrals. 0.2 Doug Bragg $280 All - Unreasonable 00 $0.00 6/18/13 Review and analyze 4,500 time records to break down conferral time. 1.2 Doug Bragg $280 12 $336.00 6/18/13 0.4 Doug Bragg $280 0.4 $112.00 0.6 Doug Bragg $280 0.6 $168.00 0.1 Doug Bragg $280 All - Unreasonable 00 $0.00 0.2 Doug Bragg $280 $0.00 0.2 Doug Bragg $280 00 $0.00 6/18/13 Review and analyze 4,500 time records to break down conferral time. 1.2 Doug Bragg $280 All - Unreasonable/Duplicative of Same Day Entry All - Unreasonable/Duplicative of Same Day Entry All - Duplicative of Same Day Entry 00 6/18/13 Draft e-memo to Gary Berne explaining method to breaking out conferral time. Review and analyze declaration of Gary Berne in support of reasonableness of time spent in this case. Draft e-memo to Bob Bonaparte regarding proposed revisions and comments on Mr. Berne's draft declaration. Phone call with Bob Bonaparte regarding Berne's opinion on the reasonableness of the time. Phone call with Bob Bonaparte regarding need to isolate conferrals. 00 $0.00 6/18/13 Draft e-memo to Gary Berne explaining method to breaking out conferral time. Review and analyze declaration of Gary Berne in support of reasonableness of time spent in this case. Draft e-memo to Bob Bonaparte regarding proposed revisions and comments on Mr. Berne's draft declaration. Phone call with Bob Bonaparte and Gary Berne analyzing time spent and potential reductionsfor conferrals and for Christopher Fanning's time. 0.4 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.6 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.1 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.7 Doug Bragg $280 0.7 $196.00 Phone call with Paul Kloft regarding status of prejudgment interest and attorney fees filings. Analyze conferral time and calculate fees based upon recommendations by Gary Berne. 0.3 Doug Bragg $280 03 $84.00 0.3 Doug Bragg $280 03 $84.00 6/14/2013 6/14/2013 6/14/2013 6/14/2013 6/14/2013 6/14/2013 6/14/2013 6/18/13 6/18/13 6/18/13 6/18/13 6/18/13 6/19/13 6/19/13 6/19/13 3:10-cv-01023-HZ Explanation ATTACHMENT 1 Hrs Deducted by Court and Reason Page 160 of 161 Date Explanation Hrs Req Pltf Lawyer Rate Hrs Deducted by Court and Reason Hrs Awarded Amount 6/19/13 Phone call with Bob Bonaparte and Gary Berne analyzing time spent and potential reductionsfor conferrals and for Christopher Fanning's time. 0.7 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 6/19/13 Phone call with Paul Kloft regarding status of prejudgment interest and attorney fees filings. Analyze conferral time and calculate fees based upon recommendations by Gary Berne. 0.3 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 0.3 Doug Bragg $280 All - Duplicative of Same Day Entry 00 $0.00 6/19/13 TOTAL 3:10-cv-01023-HZ ATTACHMENT 1 $518,663.20 Page 161 of 161

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