Court: Texas State, Dallas County, 191st District Court
Docket: DC-20-10214
Firm: BAKER BOTTS LLP
2021-06-04T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.1 — Discussed with clerk setting of show because hearing regarding motion for contempt
2021-04-20T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.6 — Call with lawyer for ORG to discuss low balance of Rogers ORG account and next steps in garnishment action; discussed same with PERSON in light of the freeze order prohibiting withdrawal from ORG account
2021-05-18T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.1 — Reviewed and revised letter to court requesting date for motion for contempt of temporary injunction and sent same to PERSON
2021-05-18T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.9 — Corresponded with opposing counsel to confer on factual bases for motion for contempt of temporary injunction
2021-07-02T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.5 — Called clerk and spoke with her to set show because hearing
2021-07-06T00:00:00 — K. M. McElvy () — pre-trial — 0.1 — Call with court to confirm hearing date on order to show because
2021-07-29T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.0 — Followed up with ORG on issuance of amended show because order; served amended order on counsel for defendants;
2021-08-23T00:00:00 — K. M. McElvy () — pre-trial — 0.3 — Reviewed and revised proposed order on plaintiff s motion for
2021-08-13T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.2 — prepared WORK_OF_ART presentation for use at hearing on motion for contempt
2021-08-16T00:00:00 — K. M. McElvy () — pre-trial — 2.3 — Worked on preparing for hearing on motion for contempt including overseeing preparation of binders with briefing and key cases; identified and analyzed key cases regarding civil and criminal contempt
2021-08-17T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.4 — Reviewed motion for contempt and response and legal authorities supporting motion in preparation for hearing on motion for contempt
2021-08-17T00:00:00 — K. M. McElvy () — pre-trial — 1.0 — Studied PERSON response brief and drafted email to PERSON with our key rebuttal points
2021-08-18T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 3.0 — Prepared for and covered hearing on motion for contempt; updated PERSON regarding results of same and sent outline of key points for order granting motion for contempt
2021-08-20T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.7 — Prepared new proposed order of contempt per judge s instructions
2021-04-23T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 0.5 — Discussed contempt motion with PERSON ; researched available penalties for a contempt motion
2021-04-23T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.9 — Worked with PERSON on preparing motion for contempt and motion for sanctions in response to PERSON violation of the temporary injunction with respect to the ORG account
2021-04-24T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.3 — Began drafting contempt motion
2021-04-25T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 2.9 — Continued drafting contempt motion
2021-04-26T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 0.6 — Discussed contempt motion with PERSON ; continued drafting contempt motion and circulated draft
2021-04-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.3 — Reviewed PERSON edits to contempt motion; revised contempt motion
2021-04-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.5 — Edited and revised motion for contempt and motion to compel based on input and comments from PERSON
2021-04-30T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 1.3 — Researched issues involved with contempt motion
2021-04-30T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.8 — Prepared show because order to accompany motion to contempt; reviewed applicable rules and authorities to motion for contempt and prepared to comply with same; called court regarding available hearing dates and discussed same with PERSON
2021-05-03T00:00:00 — M. D. McElvy (Partner) — pre-trial —  — Discussed updated draft motion for contempt and opposing counsel regarding same and of same with PERSON and PERSON ; conferred with
2021-05-03T00:00:00 — C. E. Tutunjian (Associate) — pre-trial — 0.7 — Reviewed PERSON revisions to contempt motion; discussed case status with PERSON and PERSON
2021-05-04T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial —  — Revised motion for contempt and affidavit in support; drafted letter
2021-05-05T00:00:00 — M. D. McElvy (Partner) — pre-trial — 2.0 — Continued reviewing and revising motion for contempt of temporary injunction in preparation for associate filing same
2021-05-06T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — Finalized edits to motion for contempt of temporary injunction and discussed same with PERSON ; signed and sent declaration in support of motion for contempt after reviewing same
2021-05-06T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.3 — Incorporated final comments to motion for contempt from PERSON ; proofread and finalized motion for contempt and show because order and prepared to file same
2021-05-07T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.5 — Gathered and prepared exhibits to motion for contempt including excerpted same to comply with CARDINAL page limit and coordinated filing of same; called court to discuss setting a hearing
2021-05-11T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.7 — Revised motion to contempt
2020-07-21T00:00:00 — R. Pravata () —  — 3.1 — Corresponded with library to also run searches on pending litigation against redacted for review; corresponded with PERSON regarding other tasks to do on case including drafting discovery
2020-07-21T00:00:00 — M. L. Wittenmyer (Associate) —  — 6.1 — Discussed redacted ; began incomplete
2020-07-22T00:00:00 — M. D. McElvy (Partner) —  —  — incomplete
2020-07-23T00:00:00 — K. A. Clark () —  — 2.7 — incomplete
2020-07-23T00:00:00 — M. D. McElvy (Partner) —  — 1.0 — incomplete
2020-07-23T00:00:00 — M. L. Wittenmyer (Associate) —  — 2.0 — incomplete
2020-07-30T00:00:00 — M. D. McElvy (Partner) — pleading — 0.5 — Reviewed and revised draft application for temporary restraining order and temporary injunction; sent same to client with various other updates
2020-07-30T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 0.9 — Edited and revised application for temporary restraining order; gathered information on; discussed case strategy with PERSON
2020-07-31T00:00:00 — K. A. Clark () — pleading — 1.3 — Corresponded with PERSON regarding revisions to draft application for temporary restraining order and possible hearing date sent updated draft application to the client with request to return signed verifications; call with plaintiffs counsel; and updated client call with; notified client; plan to file amended pleading together with application on DATE
2020-07-31T00:00:00 — M. D. McElvy (Partner) — pleading — 2.6 — Worked on first amended petition and application for temporary restraining order and temporary injunction; discussed temporary injunction hearing and next steps with PERSON
2020-07-24T00:00:00 — K. A. Clark () —  — 0.6 — Call with PERSON regarding strategy for discovery requests
2020-07-24T00:00:00 — M. D. McElvy (Partner) —  — 3.9 — Calls with client and PERSON regarding question about strategy including requests for production interrogatories and requests for admission; edited and revised petition based on input from PERSON and clients; redacted exhibits to petition where needed
2020-07-24T00:00:00 — M. L. Wittenmyer (Associate) —  —  — ORG gathering and preparing exhibits to petition; began drafting discovery requests
2020-07-25T00:00:00 — M. L. Wittenmyer (Associate) —  — 1.5 — Researched and analyzed potential claims
2020-07-27T00:00:00 — M. D. McElvy (Partner) —  — 3.4 — Revised and finalized draft petition and circulated same to client for final review; edited petition based on feedback from client; worked with PERSON to finalize and file petition and serve discovery; finalized same; finalized discovery requests; oversaw filing of petition exhibits and discovery requests
2020-07-27T00:00:00 — M. L. Wittenmyer (Associate) —  — 4.1 — Reviewed and revised draft discovery to plaintiff; added exhibits to petition; discussed strategy and next steps with PERSON
2020-07-29T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 1.7 — Researched and discussed with PERSON ; researched and drafted application for temporary restraining order and temporary injunction; discussed case strategy and next steps with PERSON
2020-07-06T00:00:00 — M. D. McElvy (Partner) —  —  — Call with to discuss nature of dispute with ORG and corresponded with PERSON regarding
2020-07-09T00:00:00 — M. D. McElvy (Partner) —  —  — Corresponded with client to
2020-07-10T00:00:00 — M. D. McElvy (Partner) —  —  — Drafted demand letter and sent same to client; revised draft engagement letters; call with PERSON regarding updated draft demand letter based on additional information provision and sent same to client
2020-07-13T00:00:00 — M. D. McElvy (Partner) —  —  — Conferred with clients to ; finalized and had secretary send demand letter to PERSON
2020-07-14T00:00:00 — M. D. McElvy (Partner) —  —  — Called and left message with PERSON to confer regarding payment; updated client regarding
2020-07-15T00:00:00 — M. D. McElvy (Partner) —  —  — Call with PERSON and sent client update on ; call with clients to discuss emailed PERSON proposal to arrange CARDINAL way call with ORG bank
2020-07-17T00:00:00 — M. D. McElvy (Partner) —  —  — Various calls and correspondence with ORG regarding promised wire transfers; updates to client regarding
2020-07-20T00:00:00 — M. D. McElvy (Partner) —  — 1.08 — Reviewed recent correspondence from PERSON and communicated with client regarding ; call with PERSON to have her begin work on pleadings
2020-07-20T00:00:00 — M. L. Wittenmyer (Associate) —  —  — Discussed dispute and litigation strategy with PERSON ; studied client documents including communications with PERSON
2020-08-05T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 1.1 — Conducted legal research on preparation for hearing
2020-08-06T00:00:00 — M. D. McElvy (Partner) — pleading — 1.0 — Calls with client regarding various calls with opposing counsel and client regarding; continued preparing for temporary restraining order hearing
2020-08-06T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 8.4 — Worked on preparations for hearing; coordinated hearing time with court; drafted and noticed amended notice of hearing; conferred with PERSON regarding hearing and case strategy; prepared chronology and demonstratives for hearing; researched
2020-08-07T00:00:00 — J. Aquino () — pleading — 5.1 — Assist attorneys with requesting and delivering bond to the court
2020-08-07T00:00:00 — M. D. McElvy (Partner) — pleading — 0.7 — Finished preparing for and conducted hearing on plaintiffs temporary restraining order; worked with client and PERSON to finalize and file revised order granting same and also to obtain and file the bond with the court
2020-08-07T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 5.5 — Prepared for temporary restraining order hearing including reviewing presentation preparing documents and assisting PERSON ; participated in hearing; prepared revised order based on judge s instruction; coordinated getting bond in place
2020-08-11T00:00:00 — M. D. McElvy (Partner) — pleading — 4.8 — Call with opposing counsel to get update on transfer of funds to PERSON ; call with
2020-08-13T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 0.9 — Researched in preparation for temporary injunction hearing
2020-08-17T00:00:00 — M. D. McElvy (Partner) — pleading — 2.4 — Continued researching and analyzing in preparation for temporary injunction hearing; Emailed with PERSON regarding same; coordinated with court Clerk regarding temporary injunction hearing
2020-08-17T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 1.0 — Worked with PERSON regarding draft proposed order extending temporary restraining order; call with opposing counsel regarding any update on ORG intention to pay back PERSON ; updated client regarding
2020-08-18T00:00:00 — M. D. McElvy (Partner) — pleading — 2.7 — Discussed new hearing date with court coordinator; drafted and filed motion to extend temporary restraining order and reschedule temporary injunction hearing plus proposed order per court s instruction; worked on preparing non party subpoenas for ORG and ORG
2020-08-18T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 3.0 — Reviewed and revised draft subpoenas to banks and sent edits and comments on same to PERSON ; call with PERSON regarding
2020-08-19T00:00:00 — S R Bickel () — pleading — 0.7 — reviewed and revised proposed order extending temporary restraining order requested by the court and sent same to client for
2020-08-19T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 3.1 — before we would file agreed temporary injunction order
2020-08-20T00:00:00 — S R Bickel () — pleading — 0.2 — Drafted agreed temporary injunction and letter to court regarding same; coordinated filing
2020-08-26T00:00:00 — M. D. McElvy (Partner) — discovery — 1.5 — Call with PERSON and PERSON regarding confirmed deposition date for PERSON and ORG with opposing counsel; finalized and worked with PERSON to file agreed temporary injunction order and serve bank subpoena on ORG bank and coordinate with co counsel on serving bank subpoena on ORG
2020-08-26T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 0.5 — Finalized subpoenas to ORG bank and ORG ; coordinated service on ORG
2020-08-28T00:00:00 — M. D. McElvy (Partner) — discovery — 0.5 — Call with ORG ; corresponded with PERSON regarding ORG bank subpoena
2020-08-28T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 0.1 — Accessed and reviewed correspondence from ORG regarding subpoena
2020-08-31T00:00:00 — M. D. McElvy (Partner) — discovery — 0.2 — Call with ORG regarding ORG
2020-09-11T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.5 — served notices of deposition on defendants; researched motion for summary judgment context and prepared evidence in support of motion for partial summary judgment
2020-09-14T00:00:00 — M. D. McElvy (Partner) — 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 — R. Pravata () — 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 — M. L. Wittenmyer (Associate) — discovery — 0.5 — Research for PERSON corporate and ORG of PERSON deposition for
2020-09-15T00:00:00 — N. Kennedy () — discovery — 4.5 — Prepared corporate representative; drafted deposition outline; identified and gathered deposition exhibits; coordinated with PERSON to prepare exhibits
2020-09-15T00:00:00 — M. D. McElvy (Partner) — 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. L. Wittenmyer (Associate) — discovery — 0.4 — 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
2020-09-16T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 0.8 — Continued preparing for deposition of ORG and ORG corporate representative
2020-09-17T00:00:00 — M. D. McElvy (Partner) — discovery — 1.6 — Reviewed defendants motion to quash; drafted response to motion to quash and motion to compel depositions
2020-09-17T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 2.0 — 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
2020-09-21T00:00:00 — M. D. McElvy (Partner) — pre-trial — 4.0 — 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. L. Wittenmyer (Associate) — pre-trial — 5.0 — Reviewed letter regarding depositions from defendants and responded to same; call with PERSON to discuss strategy regarding same
2020-09-21T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.0 — Discussed ; drafted and filed notice of hearing on motion to compel; conducted legal research on
2020-08-02T00:00:00 — M. D. McElvy (Partner) — pleading — 1.5 — Reviewed text message exchange between PERSON and PERSON ; updated PERSON regarding same; reviewed draft first amended petition and application in support of temporary restraining order and temporary injunction
2020-08-02T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 3.0 — Drafted and revised amended petition; reviewed and gathered additional evidence in support of petition and application for temporary restraining order
2020-08-03T00:00:00 — M. D. McElvy (Partner) — pleading — 2.3 — Called client to obtain copies of wire transfer confirmations; coordinated with PERSON regarding filing of amended petition and application for temporary restraining order and temporary injunction
2020-08-03T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 5.0 — Worked on application for temporary restraining order; incorporated edits and comments to same from PERSON ; prepared verifications and exhibits; oversaw filing; coordinated with clerk regarding setting hearing
2020-08-04T00:00:00 — M. D. McElvy (Partner) — pleading — 10.0 — Followed up with PERSON regarding hearing date and time updated client and opposing counsel regarding ; corresponded with PERSON regarding
2020-08-04T00:00:00 — M. L. Wittenmyer (Associate) — pleading — 3.0 — Prepared materials for judge and court reporter in advance of hearing; gathered and analyzed case law to be used by PERSON during hearing studied
2020-08-05T00:00:00 — M. D. McElvy (Partner) — pleading — 2.3 — Reviewed caselaw in support of temporary restraining order and temporary injunction hearing; began preparing oral argument for same; call with opposing counsel regarding attempt to pay clients to avoid temporary restraining order hearing; updated clients regarding
2020-09-22T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — PERSON ; discussed same with PERSON
2020-09-22T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.1 — Reviewed defendants rule CARDINAL motion to dismiss and letter proposing to limit scope of depositions; call with PERSON to discuss strategy around
2020-09-23T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — Drafted and revised
2020-09-23T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 1.3 — ORG ; provided brief update to clients
2020-09-24T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.4 — Reviewed and revised drait
2020-09-24T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.1 — ; call with opposing counsel and further email correspondence regarding same; discussed next steps for case with PERSON
2020-09-25T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.6 — Prepared outline for hearing on motion to compel; conferred with counsel regarding agreed resolution; drafted LAW agreement letter
2020-09-25T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.1 — Updated dieat on
2020-09-28T00:00:00 — M. D. McElvy (Partner) — pre-trial — 0.9 — reviewed corresponenpdte from
2020-09-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 0.6 — 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
2020-09-28T00:00:00 — M. D. McElvy (Partner) — pre-trial — 1.2 — Prepared for and conducted call with
2020-09-28T00:00:00 — M. L. Wittenmyer (Associate) — pre-trial — 2.4 — ; 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
2020-09-01T00:00:00 — M. D. McElvy (Partner) — discovery — 0.4 — GPE with had PERSON
2020-09-01T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 0.8 — regarding agreed temporary injunction order; Contacted court anaiyzed
2020-09-02T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.3 — Analyzed claims appropriate for summary judgment; researched issues
2020-09-04T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 9.0 — Worked on researching and drafting motion for partial summary judgment Began reviewing draft motion for summary judgment to file against Defendants
2020-09-07T00:00:00 — M. D. McElvy (Partner) — discovery — 4.7 — Worked on drafting declarations for PERSON PERSON and PERSON in support of plaintiffs motion for partial summary judgment
2020-09-08T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 2.5 — Worked on drafting declarations for PERSON PERSON and PERSON in support of plaintiffs motion for partial summary judgment Began reviewing draft motion for summary judgment
2020-09-09T00:00:00 — M. D. McElvy (Partner) — discovery — 4.0 — 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
2020-09-09T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 1.0 — Reviewed and revised draft deposition notices; conferred with PERSON regarding same
2020-09-10T00:00:00 — M. L. Wittenmyer (Associate) — discovery — 3.0 — Returned call to ORG representative to discuss subpoena
2020-09-29T00:00:00 —  () — pre-trial — 1.6 — Began reviewing draft push letter to defendants counsel on their deficient discovery responses; call
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 ofintent to use defendants records in trial of matter