Court: Texas State, Dallas County, 191st District Court
Docket: DC-20-10214
Firm: Baker Botts
2020-09-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.6 — Served document subpoena on ORG ; began drafting proposed protective order
2020-09-29T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.6 — Began reviewing draft push letter to defendants counsel on their deficient discovery responses; call with
2020-09-29T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.9 — Finalized draft protective order; participated in call with
2020-09-30T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.7 — Reviewed and revised draft push letter to defendants counsel regarding their discovery responses; reviewed and revised draft agreed protective order; finalized and sent same to opposing counsel; asked secretary to prepare letter requesting privilege log and providing notice of intent to use defendants records in trial of matter
2020-10-01T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.3 — Reviewed correspondence from defendants counsel on proposed limitations on bank subpoenas; discussed with team and responded to defendants counsel s proposal as to ORG subpoena; finalized and sent letter providing notice of intent to use documents received in discovery in trial of case and requesting privilege log
2020-10-01T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial —  — Reviewed and analyzed ORG proposed limitations on bank subpoenas; worked on response to same; participated in conference call with defendants counsel
2020-10-02T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.0 — Studied Defendants amended answer and emailed PERSON regarding same
2020-10-03T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.2 — Reviewed and analyzed WORK_OF_ART response to motion for summary judgment
2020-10-05T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.4 — Began reviewing defendants response to motion for summary judgment
2020-10-06T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.3 — Reviewed defendants response to motion for summary judgment and motion for protection from bank subpoenas; reviewed defendants proposed edits to agreed protective order and worked with PERSON to finalize and file same; call with client to discuss next steps
2020-09-22T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.3 — Prepared outline for hearing on motion to compel; conferred with counsel regarding agreed resolution; drafted LAW agreement letter
2020-09-23T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.4 — Updated client on reviewed eerreseneneepd from
2020-09-24T00:00:00 — M. D. McElvy (Partner) — pre-trial — 2.1 — Prepared and served amended notices of deposition on ORG and ORG ; worked on drafting push letter to defendants in response to their deficient discovery responses
2020-09-24T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.6 — Prepared for and conducted call with _; asked PERSON to get status update from ORG counsel on timing of receipt of documents in response to subpoena; call with PERSON to have her draft push letter to defendants on deficiencies in current discovery responses and other action items in case
2020-09-25T00:00:00 — M. D. McElvy (Partner) — pre-trial — 2.1 — Participated incan discussed document production timing with ORG representative; drafted letter to defendants pushing for substantive responses to plaintiffs discovery requests
2020-09-25T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.9 — Call with PERSON regarding CARDINAL had PERSON pun and prepare draft for our case; scheduled follow up call with
2020-09-01T00:00:00 — M. D. McElvy (Partner) — discovery — 0.4 — Analyzed claims appropriate for summary judgment
2020-09-01T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 0.8 — Call with C regarding agreed temporary injunction order; contacted court
2020-09-02T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.6 — Analyzed claims appropriate for summary judgment; researched issue
2020-09-04T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 5.6 — Worked on researching and drafting motion for partial summary judgment
2020-09-07T00:00:00 — M. D. McElvy (Partner) — discovery — 0.2 — Began reviewing draft motion for summary judgment to file against Defendants
2020-09-08T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.3 — Worked on drafting declarations for PERSON PERSON and PERSON in support of plaintiffs motion for partial summary judgment
2020-09-09T00:00:00 — M. D. McElvy (Partner) — discovery — 0.2 — Began reviewing draft motion for summary judgment
2020-09-09T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 4.7 — Drafted and revised motion for partial summary judgment and supporting declarations based on direction from PERSON ; began drafting document subpoena to serve on ORG ; prepared notices of deposition for PERSON and ORG
2020-09-10T00:00:00 — M. D. McElvy (Partner) — discovery — 1.5 — Reviewed and revised draft deposition notices; conferred with PERSON about the motion for summary judgment
2020-10-06T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 5.5 — Discussed reply brief with PERSON ; researched reply brief issues
2020-10-06T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.2 — Analyzed PERSON response to motion for summary judgment with PERSON and discussed strategy for ORG reply; researched issues related to reply and worked on drafting same; coordinated with PERSON on addressing outstanding research questions
2020-10-07T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.3 — Reviewed emails followed up with PERSON regarding same and status of draft reply brief
2020-10-07T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 1.5 — Researched reply brief issues
2020-10-07T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 8.7 — Researched drafted and edited reply in support of motion for partial summary judgment; coordinated with PERSON on research issues
2020-10-08T00:00:00 — N. Kennedy () — pre-trial — 0.5 — Provided cases to PERSON and PERSON
2020-10-08T00:00:00 — M. D. McElvy (Partner) — pre-trial — 3.4 — Reviewed and revised reply brief in support of summary judgment motion and worked with PERSON to finalize and file same; continued reviewing briefing and caselaw in preparation for hearing with court; updated client regarding joining hearing through PRODUCT
2020-10-08T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.8 — Researched reply brief issues
2020-10-08T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 6.1 — Continued working on reply in support of motion for summary judgment including addressing comments edits and revisions from PERSON ; researched and analyzed cases cited by ORG ; proofread cite checked and filed reply
2020-10-09T00:00:00 — M. D. McElvy (Partner) — pre-trial — 9.5 — Finished preparing for and presented oral argument to court on plaintiffs motion for partial summary judgment; reviewed order granting same and worked with PERSON to file with court; call with call with opposing counsel regarding invocation of th amendment privilege in response to plaintiffs discovery ; call with PERSON regarding
2020-10-09T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 4.0 — Prepared for and participated in hearing on partial motion for summary judgment; analyzed cases cited by defendants; prepared draft order at judge s request
2020-10-11T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.8 — Researched and drafted response to Defendants motion for limited protection from bank subpoenas
2020-10-12T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.6 — Reviewed and revised response to Defendants motion for limited protection and sent same to PERSON to work on; attention to PERSON
2020-10-12T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 4.1 — email from clerk setting motion for emergency hearing; call with emailed PERSON to research various legal issues law surrounding
2020-10-12T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.3 — Worked on response to motion for limited protection from bank subpoenas; communicated with court regarding setting motion for hearing; drafted and filed notice of hearing
2020-10-13T00:00:00 — M. D. McElvy (Partner) — pre-trial — 2.0 — Corresponded with PERSON with opposing counsel regarding withdrawing same and passing on hearing and need to reschedule depositions in light of invocation of LAW privilege; and call with PERSON regarding same
2020-10-13T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.8 — Identified deficiencies in ORG discovery responses; coordinated with ORG bank regarding ORG withdrawal of their motion for protection
2020-10-14T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.5 — Researched GPE law surrounding
2020-10-15T00:00:00 — R. Pravata () — pre-trial — 0.8 — Research litigation information for PERSON
2020-10-15T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 3.5 — Researched GPE law surrounding ; conferenced with team regarding research
2020-10-15T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.5 — Worked with PERSON on research related to ; discussed findings with team; prepared for and participated in call with opposing counsel to discuss discovery dispute; directed PERSON on drafting
2020-10-16T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 1.1 — Began drafting_
2020-10-18T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.0 — Assessed defendants discovery requests and prepared notes on documents to gather for production
2020-10-19T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.8 — Continued researching GPE law surrounding
2020-10-19T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.3 — Worked on ; discussed same with PERSON
2020-10-20T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 1.0 — Completed drafting
2020-10-20T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.5 — Reviewed
2020-10-21T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — Call with PERSON regarding review of banking records received in response to subpoena; began reviewing motion for attorneys fees on motion for partial summary judgment; corresponded with defendants counsel to confirm date for defendants depositions
2020-10-21T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 1.9 — Researchedh
2020-10-26T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 4.1 — Conducted further research into r
2020-10-26T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.3 — Edited and revised ; began preparing responses to defendants discovery requests
2020-10-27T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.6 — Reviewed and revised draft responses to defendants discovery requests to PERSON PERSON and PERSON in preparation for reviewing with client; reviewed research from PERSON regarding subpoenaed bank records
2020-10-27T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 3.0 — Reviewed subpoenaed bank records
2020-10-27T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 5.0 — Drafted responses and objections for PERSON PERSON and PERSON to ORG requests for admission requests for production and interrogatories; identified categories of documents for clients to gather for production; emailed PERSON regarding same
2020-10-28T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — Corresponded with defendants counsel regarding deadline to respond to discovery requests; finalized edits to and sent drafts of responses to discovery requests to clients for review and discussion; reviewed and revised draft corporate representative deposition notice for ORG
2020-10-28T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.1 — Continued reviewing subpoenaed bank records
2020-10-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.8 — Continued working on ORG discovery responses based on comments from PERSON ; prepared response to ORG request for disclosure; began gathering documents for production; coordinated with PERSON in litigation support regarding same; discussed discovery responses with PERSON and PERSON
2020-10-30T00:00:00 — B. Baxter () — pre-trial — 0.8 — Conferenced with PERSON regarding data processing; loaded processed and imaged documents
2020-10-30T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.4 — Prepared for and conducted call with PERSON regarding document review; call with PERSON to finalize and incorporate edits into same
2020-10-30T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.3 — Drafted and revised motion for attorneys fees and declaration by PERSON in support of same; participated in call with PERSON and PERSON ; coordinated with PERSON regarding preparation of emails for production
2020-09-10T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 3.0 — Returned call to ORG representative to discuss subpoena; served notices of deposition on defendants; researched motion for summary judgment context and prepared evidence in support of motion for partial summary judgment
2020-09-11T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 2.6 — Finalized PERSON subpoena duces tecum; worked on preparing exhibits for motion for partial summary judgment; began preparing_
2020-09-14T00:00:00 — M. D. McElvy (Partner) — discovery — 0.7 — Call with opposing counsel regarding deposition scheduling and potential payment to PERSON in exchange for deferring deposition; reviewed and revised draft ORG subpoena
2020-09-14T00:00:00 — R. Pravata () — discovery — 0.5 — Research for PERSON
2020-09-14T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 4.5 — Prepared deposition of ORG and ORG corporate representative; drafted deposition outline; identified and gathered deposition exhibits; coordinated with PERSON to prepare exhibits
2020-09-15T00:00:00 — N. Kennedy () — discovery — 2.5 — Assisted PERSON in finalizing documents for use at defendants depositions and arranged for printing the documents
2020-09-15T00:00:00 — M. D. McElvy (Partner) — discovery — 0.8 — Call with opposing counsel regarding defendants depositions and related matters; call with PERSON to provide update on same and discuss i finalizing motion for summary judgment; ii preparing response to motion to quash and motion to compel defendants depositions; and iii finalizing PERSON subpoena
2020-09-15T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.6 — Continued preparing for deposition of ORG and ORG corporate representative
2020-09-16T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 2.0 — Reviewed defendants motion to quash; drafted response to motion to quash and motion to compel depositions
2020-09-17T00:00:00 — M. D. McElvy (Partner) — discovery — 5.0 — Revised and finalized PERSON subpoena; revised and finalized draft motion for partial summary judgment on breach of contract conversion and money had and received claims; worked with PERSON to file same
2020-09-17T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 4.6 — Reviewed defendants discovery responses; revised and finalized response to motion to quash and motion to compel; prepared and finalized motion for summary judgment exhibits; revised finalized and filed motion for partial summary judgment
2020-09-21T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.0 — Reviewed letter regarding depositions from defendants and responded to same; call with PERSON to discuss strategy regarding same