EXHIBIT A 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 1 of 50
TIMEKEEPER HOURS (GrayRobinson, P.A.) 

Elio F. Martinez, Jr.: 53.6 total hours at a rate of $525.00 

Robert R. Jimenez: 12.9 total hours at a rate of $380.00 

Maday Cohen: 0.8 total hours at a rate of $150.00 

BIOGRAPHIES (GrayRobinson, P.A. timekeepers) 

Elio F. Martinez, Jr. 

Elio F. Martinez, Jr. is a shareholder in the Miami office of GrayRobinson, P.A., focusing his 

practice on intellectual property litigation, specifically infringement of trademarks, patents and 

copyrights, as well as protection of trade secrets. He also has extensive experience in commercial 

litigation and financial services litigation. He has represented lenders in multi-million dollar 

litigation and work-out of complex troubled loans, and securities brokers in FINRA arbitration 

hearings. In addition to his trial experience, he has argued numerous appeals. 

For more than 30 years, Elio has been litigating matters of trademark counterfeiting, trademark 

infringement, copyright infringement, patent infringement and trade secret misappropriation. His 

intellectual property experience also extends to helping clients, owners of world renown 

trademarks, develop and implement anti-piracy efforts in the United States and abroad. His clients 

have included many of the best-known brands in the world, as well small businesses seeking to 

develop and protect their intellectual property. 

Robert R. Jimenez 

Robert R. Jimenez is a senior associate in the Miami office of GrayRobinson, P.A. His practice 

includes intellectual property and commercial litigation, electronic discovery, and appellate 

matters. He has experience representing trademark and copyright owners, financial institutions, 

and commercial clients across varying areas in both state and federal court. Robert routinely 

counsels businesses on electronic discovery and information governance issues, supporting clients 

across every phase of the Electronic Discovery Reference Model. He has experience in 

multijurisdictional data collections, in negotiating e-discovery protocols, and in leading discovery 

teams and vendors. Additionally, Robert is a Certified E-discovery Specialist, holds the Ediscovery Practice Certificate from the Electronic Discovery Institute, and has significant appellate 

experience. 

Maday Cohen 

Maday Cohen is a hybrid paralegal in the Miami office of GrayRobinson, P.A. She is a seasoned 

professional with 15 years of experience managing various cases, including litigation support in 

both federal and state court matters. She routinely works on commercial and intellectual property 

cases, as well as arbitration disputes. 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 2 of 50
TIMEKEEPER HOURS (Jeffer Mangels Butler & Mitchell LLP) 

Rod S. Berman: 10.5 total hours at a rate of $945.00 

Gregory C. Cordrey: 7.2 total hours at a rate of $750.00 

Brennan C. Swain: 4.3 total hours at a rate of $675.00 

Jessica Bromall Sparkman: 13.2 total hours at a rate of $655.00 

Remi Salter: 0.8 total hours at a rate of $395.00 

Shiloh Filin: 1.6 total hours at a rate of $395.00 

BIOGRAPHIES (Jeffer Mangels Butler & Mitchell LLP timekeepers) 

Rod S. Berman 

Rod Berman is a Partner in the Los Angeles office of Jeffer Mangels Butler & Mitchell LLP, where 

he is chairperson of the Firm's Intellectual Property Law Group. His practice focuses on patent, 

trademark, trade dress, copyright, unfair competition and internet responsibilities, and includes 

counseling, litigation, opinions, licensing, acquisition and prosecution. He represents many 

nationally and internationally known clients, and has been involved in a number of published 

patent, trademark and copyright cases in a wide variety of industries. 

Rod has worked on a broad range of matters including those involving aircraft, apparel, 

automotive, beauty care, bicycles, biotechnology, cannabis products including CBDs, hemp and 

extraction techniques, celebrity endorsement, computer-related business methods, dietary and 

nutritional supplements, electrochemistry, food and restaurants, health care, inflatables, 

insecticides, jewelry, medical devices, packaging, pharmaceuticals, polymers, pressure sensors, 

retail, special effects, sports and entertainment, and toys. 

In addition to being a registered patent attorney, Rod is a court-recognized expert in patent and 

trademark law, and has successfully argued before the Federal Circuit and the Ninth Circuit. He 

was also successful in resolving a U.S. Supreme Court petition for certiorari. 

Rod also has a strong business background, and received a Master of Science Degree from Indiana 

University. He has participated in numerous symposia and published several legal and technical 

papers on patent, trademark and copyright issues. He has particular expertise in strategy and tactics 

involving intellectual property disputes and design arounds, as well as internet and cyber law. 

Gregory C. Cordrey 

Greg is a Partner in the Orange County office of Jeffer Mangels Butler & Mitchell LLP, where 

he is a member of the firm's Patent Litigation Group and PTAB Trial Group. 

In his nearly 25 years as a lawyer, Greg has focused on litigating patent infringement matters and 

other disputes involving complex technology, as well as representing patent owners and 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 3 of 50
challengers before the Patent Trial and Appeal Board (PTAB). Greg also has extensive 

experience with licensing intellectual property, including successfully negotiating numerous 

license agreements, and advising clients regarding their IP litigation and acquisition strategy. 

He has litigated patent cases throughout the United States, including popular patent venues in the 

Northern and Central Districts of California, and the Eastern District of Texas. In addition, Greg 

has represented clients before the Court of Appeals for the Federal Circuit and PTAB. Greg's 

clients come from a wide variety of industries, including semiconductor and LCD 

manufacturing, medical devices, computer software, computer accessories, automotive, aircraft 

(avionics and interiors), and consumer products (packaging and paper products). 

Brennan C. Swain 

Brennan Swain is a Partner in the Los Angeles office of Jeffer Mangels Butler & Mitchell LLP, 

where his legal practice emphasizes patent and trademark law, including prosecution, litigation 

and client counseling. With over 20 years' experience as a patent attorney, Brennan has drafted 

and/or prosecuted over 1000 patents and patent applications in the U.S. and around the world. Over 

time he has developed unique relationships with the U.S. Patent Office Examiners reviewing patent 

applications he has filed for clients. These relationships often result in faster time from filing to 

issuance of a patent. Brennan's experience in patent litigation also helps in obtaining strong, 

defensible patents with broad claims. 

Brennan also has significant experience in Patent Trial and Appeal Board post grant proceedings, 

including filing and successfully completing several Inter Partes Reviews. 

In the trademark field Brennan has experience in prosecution, opinions, counseling and portfolio 

management as well as disputes before the Trademark Trial and Appeal Board of the USPTO. 

Jessica Bromall Sparkman 

Jessica Bromall Sparkman is a Partner in the Los Angeles office of Jeffer Mangels Butler & 

Mitchell LLP, where she represents clients in a variety of industries in all facets of trademark, 

copyright, and trade secret law, including selection and acquisition, protection, federal trademark 

application and registration, opinions, portfolio management, enforcement, co-existence and 

settlement agreements, domain names, and litigation. She has experience managing portfolios of 

more than two thousand trademark registrations, has applied for or maintained trademark 

registrations in more than 150 countries, and has managed a global trademark monitoring and 

enforcement program involving hundreds of proceedings and negotiations in more than 50 

countries. 

Jessica counsels clients about agreements to acquire, sell, and protect intellectual property, 

including assignments, acquisitions, licenses, and non-disclosure and confidentiality agreements, 

and has performed due diligence for clients in numerous large transactions. She also litigates 

trademark, unfair competition, copyright, patent, trade secret, and privacy rights cases in state 

and federal court, and has extensive experience practicing before the Trademark Trial and 

Appeal Board of the USPTO. 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 4 of 50
Jessica has experience working in a variety of industries, including alcoholic beverages, apparel, 

footwear, cigars, toys, sports and fishing equipment, restaurants, jewelry, packaging, retail, 

entertainment, and international educational organizations. 

Remi Salter

Remi Salter is an associate in the Firm’s Litigation Group. Her practice focuses on general 

commercial litigation, corporate defense and investigation matters, and intellectual property 

litigation. Remi has represented clients in a variety of industries and cases, including contract 

disputes, construction defect disputes, trademarks, patents, and probate and trust matters. She has 

been involved in all aspects of litigation, including pre-lawsuit investigations, conducting 

discovery, drafting pleadings and motions, conducting depositions, and preparing for trial. 

Shiloh Filin 

Shiloh Filin has been with the Firm since 2006 and is a paralegal in the firm's Intellectual 

Property department. Her responsibilities emphasize trademark prosecution including both U.S. 

and foreign trademark applications and assisting with the management of trademark portfolios. 

Prior to joining the Intellectual Property department, Shiloh worked in the Firm's Litigation and 

Labor departments as a paralegal and legal secretary. Throughout her career in the legal industry, 

which has included numerous trials in state and federal courts, she has worked on cases in a wide 

range of areas, including litigation of trademark and trade secret cases, land use disputes, 

environmental litigation, eminent domain and employment defense. She was part of the trial 

team of a complex labor dispute involving one of the largest labor unions in the country tried in 

the Southern District of New York. Shiloh is an expert at calculating class-action damages and 

implementing practice support programs. 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 5 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number.

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

July 2, 2020

FILE # 301822 - 1

Invoice # 10948031 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the 

date of the last transaction shown on this invoice. Any transactions, including credits or receipts 

processed after that date will be reflected on a future statement. 

CURRENT FEES: $ 8,132.00 

CURRENT DISBURSEMENTS: $ 549.20 

 LESS TRUST FUNDS $-5,000.00 

CURRENT BALANCE DUE: $ 3,681.20 

 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 6 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

July 2, 2020

FILE # 301822 - 1

Invoice # 10948031 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the 

date of the last transaction shown on this invoice. Any transactions, including credits or receipts 

processed after that date will be reflected on a future statement. 

CURRENT FEES: $ 8,132.00 

CURRENT DISBURSEMENTS: $ 549.20 

 LESS TRUST FUNDS $-5,000.00 

CURRENT BALANCE DUE: $ 3,681.20 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 7 of 50
10948031 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 2 

Professional Services: 

06/01/20 EM Analyze draft Complaint re ascertaining background 

prior to revising and preparing Complaint for filing in 

Southern District of Florida. 

0.50 $ 250.00

06/01/20 EM Multiple written communications with R. Berman re 0.50 $ 250.00

06/01/20 EM Prepare additional Count in Complaint for violation of 

Florida's Deceptive and Unfair Trade Practices Act. 

1.00 $ 500.00

06/01/20 EM Telephone conference with R. Berman re 0.20 $ 100.00

06/01/20 EM Analyze multiple Court filings from California lawsuit, 

including Amended Complaint and Motion for leave to 

serve by e-mail, re information needed to add Dezhou 

as party to Florida lawsuit. 

0.40 $ 200.00

06/01/20 EM Analyze motion to serve Dezhou by email in 

California action re possibly seeking similar relief in 

Florida. 

0.20 $ 100.00

06/01/20 EM Communications with R. Berman re 0.20 $ 100.00

06/02/20 RJ Draft of motions to appear pro hac vice, certificates, 

and proposed orders; correspondences on same. 

1.50 $ 540.00

06/02/20 EM Revise Complaint to add Defendants and to 

supplement facts as to FDUPTA claim. 

1.50 $ 750.00

06/02/20 EM Analyze Patent Certificate to be attached as Exhibit to 

Complaint. 

0.30 $ 150.00

06/02/20 EM Communications with co-counsel R. Berman re 0.20 $ 100.00

06/03/20 RJ Review of draft complaint and correspondences 

regarding filing same. 

0.20 $ 72.00

06/03/20 EM Further revisions to Complaint. 0.80 $ 400.00

06/03/20 EM Revisions to Civil Cover Sheet and Summonses. 0.30 $ 150.00

06/04/20 RJ Review of court correspondence RE: pro hac vice; 

revisions to motions to appear pro hac vice and order; 

correspondence to co-counsel on same. 

0.70 $ 252.00

06/04/20 EM Finalize Complaint, Summonses and Civil Cover Sheet 

and prepare for filing. 

0.50 $ 250.00

06/04/20 EM Communications with R. Berman and G. Cordrey re 0.30 $ 150.00

06/04/20 EM Analyze confirmation of filing of Complaint, Civil 

Cover Sheet and summonses with District Court, 

Southern District of Florida. 

0.20 $ 100.00

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 8 of 50
10948031 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 3 

06/04/20 EM Communications with R. Berman re 0.20 $ 100.00

06/04/20 MC Preparation of Exhibit in connection to Complaint. 0.20 $ 30.00

06/05/20 EM Analyze filed Complaint and engage in several 

communications with co-counsel re 

0.30 $ 150.00

06/05/20 EM Conference with process server re service of process. 0.20 $ 100.00

06/05/20 MC Coordinate service of Summons and Complaint with 

process server. 

0.20 $ 30.00

06/08/20 EM Communications with process server re status of 

service on Golovan at Miami location. 

0.20 $ 100.00

06/09/20 EM Multiple communications (written and oral) with 

process server re service of process in North Miami 

Beach and language of Return if Service. 

0.50 $ 250.00

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 9 of 50
10948031 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 4 

 

 

06/24/20 EM Analyze file re preparation of Certificate of Interested 

Parties. 

0.30 $ 150.00

06/24/20 RJ Research local rules and FRCP RE: deadlines and 

correspondences on same; correspondence from OC 

RE: extension. 

0.30 $ 108.00

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 10 of 50
10948031 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 5 

06/26/20 EM Analyze file re filing of Certificate of Interested 

Parties. 

0.20 $ 100.00

 

 Current Fees: $ 8,132.00

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 14.20 $ 500.00 $ 7,100.00 

Jimenez, Robert 2.70 $ 360.00 $ 972.00 

Cohen, Maday 0.40 $ 150.00 $ 60.00 

 

 17.30 $ 8,132.00 

Disbursements: 

06/04/20 PAYEE: Clerk of the Court, Miami-Dade County (FL); 

REQUEST#: 1010778; DATE: 6/5/2020. - ePortal 

$ 400.00

06/09/20 VENDOR: DLE Process Servers, Inc. INVOICE#: DLE2020023137 DATE: 6/9/2020 Summons and Complaint 

served on: Defendant, GOLOVAN LTD., d/b/a GETKRAFT. 

$ 80.00

06/09/20 VENDOR: FedEx ERS INVOICE#: 326729355 DATE: 

6/15/2020 Tracking #770664887430 From: GRAY 

ROBINSON PA, 333 SE 2ND AVE, SUITE 3200MIAMI, FL 

331312191 To: GOLOVAN LTD., 198 DIZENGOFF, TEL 

AVIV, 294 

$ 50.44

06/09/20 VENDOR: FedEx ERS INVOICE#: 703701758 DATE: 

6/12/2020 Tracking #770664654411 From: GrayRobinson, 

P.A., 333 S.E. 2nd Avenue, MIAMI, FL 33131 To: Attn; Roy 

D. Gross, Esq., The Roy Gross Law Firm, LLC, 50 Washington 

Street, NORWALK, CT 06854 

$ 18.76

 

 Current Disbursements: $ 549.20

Summary of Disbursements: 

 DESCRIPTION AMOUNT 

Express Mail $ 69.20 

Filing Fee $ 400.00 

Service of Process $ 80.00 

 $ 549.20 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 11 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number.

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

August 5, 2020

FILE # 301822 - 1

Invoice # 10955717 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the 

date of the last transaction shown on this invoice. Any transactions, including credits or receipts 

processed after that date will be reflected on a future statement. 

CURRENT FEES: $ 2,130.00 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 2,130.00 

 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 12 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

August 5, 2020

FILE # 301822 - 1

Invoice # 10955717 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the 

date of the last transaction shown on this invoice. Any transactions, including credits or receipts 

processed after that date will be reflected on a future statement. 

CURRENT FEES: $ 2,130.00 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 2,130.00 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 13 of 50
10955717 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 2 

Professional Services: 

07/06/20 EM Communications with R. Berman re 0.30 $ 150.00

07/06/20 EM Analyze file re preparation of corporate disclosures. 0.20 $ 100.00

07/17/20 EM Analyze file re deadline for filing of Scheduling 

Report. 

0.30 $ 150.00

07/17/20 EM Written communications with R. Berman re 0.20 $ 100.00

07/17/20 EM Telephone conference with R. Berman re 0.20 $ 100.00

07/17/20 EM Prepare Theragun's Corporate Disclosures Statement. 0.50 $ 250.00

07/17/20 EM Prepare letter to R. Berman re 0.10 $ 50.00

07/17/20 MC Draft Plaintiff Theragun, Inc.’s Corporate Disclosure 

Statement. 

0.20 $ 30.00

07/24/20 EM Communications with R. Berman re 

 

. 

0.30 $ 150.00

07/29/20 EM Analyze file, including pleadings and return of service, 

and calculate deadline for Scheduling Meeting. 

0.40 $ 200.00

07/31/20 EM Prepare letter to R. Berman re 0.20 $ 100.00

07/31/20 EM Revise Corporate Disclosure Statement. 0.20 $ 100.00

07/31/20 EM Communications with R. Berman re 0.30 $ 150.00

07/31/20 EM Analyze Rules and file re 0.20 $ 100.00

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 14 of 50
10955717 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 3 

07/31/20 EM Analyze Court's paperless Order granting Golovan's 

Motion for extension of Time. 

0.10 $ 50.00

 

 Current Fees: $ 2,130.00

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 4.20 $ 500.00 $ 2,100.00 

Cohen, Maday 0.20 $ 150.00 $ 30.00 

 

 4.40 $ 2,130.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 15 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number.

GRAYROBINSON

Attorneys At Law 

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

September 3, 2020

FILE # 301822 - 1

Invoice # 10960701 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

CURRENT FEES: $ 10,334.00 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 10,334.00 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 16 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to: 

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law 

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

September 3, 2020

FILE # 301822 - 1

Invoice # 10960701 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

CURRENT FEES: $ 10,334.00 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 10,334.00 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 17 of 50
10960701 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 2 

Professional Services: 

08/03/20 EM Analyze Plaintiff's Corporate Disclosure Statement prior to 

finalizing and filing. 

0.20 $100.00 

08/03/20 EM Analyze Court's confirmation of filed Corporate Disclosure 

Statement. 

0.10 $50.00 

08/03/20 EM Analyze emails from Paka Harp and Kraftgun re 0.30 $150.00 

08/03/20 EM Communications with R. Berman re 0.20 $100.00 

08/04/20 EM Analyze file re preparation of Joint Scheduling Report and 

deadline for same. 

0.30 $150.00 

08/04/20 EM Written communications with R. Berman re 0.20 $100.00 

08/04/20 EM Conference with R. Berman re s 0.20 $100.00 

08/07/20 EM Communications with R. Berman re 0.20 $100.00 

08/07/20 EM Analyze file re deadline to hold joint scheduling conference 

re possible extension on same. 

0.20 $100.00 

 

 

 

 

 

 

08/07/20 EM Analyze Court Order extending time to hold joint 

scheduling conference and new deadlines. 

0.20 $100.00 

08/07/20 EM Prepare letter to R. Berman re 0.10 $50.00 

08/10/20 EM Analyze electronic notification of Court's resetting 

deadlines for Joint Scheduling Conference and submission 

of Joint Scheduling Report. 

0.10 $50.00 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 18 of 50
10960701 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 3 

08/18/20 EM Several communications with R. Berman re 0.30 $150.00 

08/18/20 EM Analyze file re preparation of motion to serve Dezhou by 

email. 

0.30 $150.00 

08/18/20 EM Communications with G. Cordrey re 0.20 $100.00 

08/18/20 EM Analyze recent Curt Orders re impact of settlement with 

Golovan on submission of Joint Scheduling Report and 

related filings. 

0.20 $100.00 

 

 

08/19/20 EM Communications with R. Berman and G. Cordrey (various) 

re 

0.30 $150.00 

08/19/20 EM Analyze motion for electronic service on Dezhou filed in 

California case re preparation of same in Florida case. 

0.30 $150.00 

08/19/20 EM Analyze Order re electronic service on Dezhou in California 

case re preparation of same in Florida case. 

0.20 $100.00 

08/19/20 EM Analyze Declaration of G. Cordrey in California case re 

electronic service on Dezhou re preparation of similar 

Declaration in Florida case. 

0.20 $100.00 

08/19/20 EM Conduct on-line research re operations of Dezhou re

preparation and execution of Declaration in support 

electronic service. 

1.00 $500.00 

08/19/20 EM Prepare Declaration of Elio F. Martinez Jr. re Motion for 

electronic Service on Dezhou in Florida case. 

0.60 $300.00 

08/19/20 EM Prepare proposed Order re electronic service on Dezhou. 0.40 $200.00 

08/19/20 EM Analyze relevant case law re electronic service on Dezhou. 0.60 $300.00 

08/19/20 EM Prepare Motion for Electronic Service on Dezhou in Florida 

case. 

0.80 $400.00 

08/19/20 EM Communications with G. Cordrey re 0.20 $100.00 

08/19/20 EM Analyze Affidavit of Celeste Ingals re motion for electronic 

service on Dezhou. 

0.30 $150.00 

08/20/20 RJ Case law research and correspondences re: email service 

upon Chinese defendant. 

0.60 $216.00 

08/20/20 EM Revise Motion for Electronic Service on Dezhou. 0.20 $100.00 

08/20/20 EM Revise Declaration of Elio F. Martinez, Jr. re electronic 

service on Dezhou. 

0.20 $100.00 

 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 19 of 50
10960701 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 4 

08/20/20 EM Communications with R. Berman and G. Condrey re 0.30 $150.00 

08/20/20 EM Analyze e-mail communications between Dezhou and 

California counsel for Theragun re California lawsuit, for 

inclusion in Motion for electronic service on Dezhou. 

0.20 $100.00 

08/20/20 EM Commence research re Southern District of Florida law on 

electronic service of process. 

0.50 $250.00 

08/21/20 RJ Additional case law research re: service on Dezhou and 

correspondences on same. 

1.30 $468.00 

08/21/20 EM Analyze case law from Southern District of Florida re 

service on Chinese company through electronic means. 

1.50 $750.00 

08/21/20 EM Revise Declaration of F. Martinez, Jr. to incorporate 

additional information received from co-counsel re with 

Dezhou. 

0.50 $250.00 

08/21/20 EM Revise Motion for Electronic Service on Dezhou, 

incorporating additional case law and new information from 

co-counsel re 

1.00 $500.00 

08/21/20 EM Several communications with co-counsel re 0.30 $150.00 

08/21/20 EM Prepare letter and package for R. Berman re 0.20 $100.00 

 

 

 

 

 

 

08/24/20 EM Analyze communication from R. Berman re 0.10 $50.00 

08/24/20 EM Analyze file re finalization of Motion for electronic service 

on Dezhou. 

0.30 $150.00 

08/25/20 EM Final analysis of Motion for electronic service on Dezhou 

and supporting Declaration prior to filing with Court. 

0.20 $100.00 

08/25/20 EM Analyze Court's confirmation of filed Motion for electronic 

discovery on Dezhou and supporting declaration. 

0.10 $50.00 

08/25/20 EM Analyze communication with Court re submitted proposed 

Order on Motion for electronic service on Dezhou. 

0.10 $50.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 20 of 50
10960701 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and Dezhou Create Fitness 

Equipment Co. Ltd. 

Page 5 

08/25/20 EM Communications with R. Berman re 0.30 $150.00 

08/31/20 EM Analyze deadlines for Joint Scheduling Meeting and Report 

re possible motion for extension. 

0.20 $100.00 

08/31/20 EM Analyze file re information needed for preparation of 

Motion for extension of time on Joint Scheduling Meeting 

and Report. 

0.40 $200.00 

08/31/20 EM Prepare Motion for extension on Joint Scheduling Meeting 

and Report. 

0.70 $350.00 

08/31/20 EM Prepare proposed Order on Motion for extension on Joint 

Scheduling Meeting and Report. 

0.30 $150.00 

08/31/20 EM Communications with R. Berman re 0.20 $100.00 

 

 Current Fees: $10,334.00

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 19.30 $ 500.00 $ 9,650.00 

Jimenez, Robert 1.90 $ 360.00 $ 684.00 

 

 21.20 $ 10,334.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 21 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

October 2, 2020

FILE # 301822 - 1

Invoice # 10965795 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 16,145.20 

 

CURRENT FEES: $ 3,517.00 

CURRENT DISBURSEMENTS: $ 32.18 

CURRENT BALANCE DUE: $ 3,549.18 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 19,694.38 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 22 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

October 2, 2020

FILE # 301822 - 1

Invoice # 10965795 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 16,145.20 

 

CURRENT FEES: $ 3,517.00 

CURRENT DISBURSEMENTS: $ 32.18 

CURRENT BALANCE DUE: $ 3,549.18 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 19,694.38 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 23 of 50
TheraGun, Inc. Invoice No. 10965795 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: October 2, 2020 

Page 2 

Professional Services: 

09/01/20 EM Analyze Court confirmation of filed Motion for Extension 

of Time re Scheduling Conference and Report. 

0.10 $52.50 

09/01/20 EM Analyze communication to Court re proposed Order on

Motion for Extension of Time. 

0.10 $52.50 

09/01/20 EM Analyze Court's paperless Order granting Motion for 

Extension of Time. 

0.10 $52.50 

09/01/20 EM Communication with R. Berman re 0.10 $52.50 

09/01/20 EM Analyze Court notice re resetting deadlines for Joint 

Scheduling Conference and submission of Joint Scheduling 

Report. 

0.10 $52.50 

09/08/20 EM Communications with R. Berman re 0.20 $105.00 

09/08/20 EM Analyze Court Orders re new deadline for Joint Scheduling 

Report and filing of Certificate of Interested Parties. 

0.20 $105.00 

09/09/20 EM Analyze file re preparation of Certificate of Interested 

Parties. 

0.30 $157.50 

09/09/20 EM Prepare Certificate of Interested Parties. 0.30 $157.50 

09/09/20 EM Analyze file re information needed for Joint Scheduling 

Report and date due. 

0.10 $52.50 

09/10/20 EM Finalize Certificate of Interested Parties. 0.10 $52.50 

09/10/20 EM Analyze Court conformation of receipt of Certificate of 

Interested Parties. 

0.10 $52.50 

09/11/20 EM Communications with R. Berman re 0.20 $105.00 

09/17/20 RJ Review court order granting service; service 

correspondence to defendant in China; registration on 

Alibaba site for purposes of effecting service as per court 

order and message with attachments to defendant; creation 

of screenshots as confirmations and internal 

correspondences on same. 

1.00 $380.00 

09/17/20 RJ Draft of service declaration. 0.50 $190.00 

09/17/20 EM Analyze Court Order granting Motion for Electronic service 

on Dezhou. 

0.20 $105.00 

09/17/20 EM Communications with R. Berman re 0.20 $105.00 

09/17/20 EM Strategize re effecting electronic service on Dezhou. 0.30 $157.50 

09/17/20 EM Analyze confirmation of service on Dezhou by email and 

posting in alibaba.com. 

0.20 $105.00 

09/17/20 EM Communications with R. Berman re 0.20 $105.00 

09/17/20 EM Analyze and revise Declaration of Service (on Dezhou) for 

Robert Jimenez. 

0.20 $105.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 24 of 50
TheraGun, Inc. Invoice No. 10965795 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: October 2, 2020 

Page 3 

09/17/20 EM Communications with R. Berman re 0.20 $105.00 

09/18/20 RJ Revisions to declaration and correspondences on same; 

filing of declaration and service upon Chinese defendant. 

0.70 $266.00 

09/18/20 EM Analyze filed Declaration of service on Dezhou and Court's 

electronic confirmation of same. 

0.20 $105.00 

09/29/20 RJ Correspondences RE: letter to defendant; preparation and 

revision to letter for service and service on Chinese 

defendant; submission of letter and message to defendant 

on Alibaba website; additional correspondences on same. 

0.70 $266.00 

09/29/20 EM Analyze file and Court's Orders re deadline for Dezhou to 

file response to Complaint and deadline to hold joint 

scheduling meeting and file Joint Scheduling Report. 

0.30 $157.50 

09/29/20 EM Prepare letter to Dezhou re deadline for Joint Scheduling 

Meeting. 

0.20 $105.00 

09/29/20 EM Analyze confirmation of service of letter on Dezhou re Joint 

Scheduling Meeting by email and Alibaba.com. 

0.10 $52.50 

09/29/20 EM Communication with R. Berman re 0.20 $105.00 

09/29/20 EM Communication with R. Berman re 0.10 $52.50 

 

 Current Fees: $3,517.00

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 4.60 $ 525.00 $ 2,415.00 

Jimenez, Robert 2.90 $ 380.00 $ 1,102.00 

 

 7.50 $ 3,517.00 

Disbursements: 

08/21/20 Computer Research Westlaw - JIMENEZ $ 32.18 

 

 Current Disbursements: $ 32.18 

Summary of Disbursements: 

 DESCRIPTION AMOUNT 

Computer Research $ 32.18 

 $ 32.18 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 25 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

November 4, 2020

FILE # 301822 - 1

Invoice # 10972598 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 5,679.18 

 

CURRENT FEES: $ 7,062.50 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 7,062.50 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 12,741.68 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 26 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

November 4, 2020

FILE # 301822 - 1

Invoice # 10972598 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 5,679.18 

 

CURRENT FEES: $ 7,062.50 

CURRENT DISBURSEMENTS: $ 0.00 

CURRENT BALANCE DUE: $ 7,062.50 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 12,741.68 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 27 of 50
TheraGun, Inc. Invoice No. 10972598 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: November 4, 2020 

Page 2 

Professional Services: 

10/02/20 EM Analyze file re possible preparation of Unilateral 

Scheduling Report 

0.20 $105.00 

10/05/20 EM Analyze file, including present status of court docket and 

upcoming deadlines, re 

0.30 $157.50 

10/06/20 RJ Correspondences RE: motion for default. 0.10 $38.00 

10/06/20 EM Analyze file and court docket re deadlines for response to 

Complaint by Dezhou 

0.30 $157.50 

10/06/20 EM Communications with R Berman re 0.30 $157.50 

10/08/20 EM Communications with G. Cordrey re 0.20 $105.00 

10/08/20 EM Analyze file re formulation of strategy on motion for 

default final judgment. 

0.30 $157.50 

10/09/20 RJ Research RE: Clerk's default in email service cases; draft of 

request for Clerk's Default; correspondences on same. 

1.00 $380.00 

10/09/20 EM Conference with G. Cordrey re 0.30 $157.50 

10/09/20 EM Prepare for strategy conference with G. Cordrey re motion 

for default final judgment, including analysis of Complaint 

and related court filings re relief to be sought in motion. 

0.50 $262.50 

10/09/20 EM Analyze file re non-response to Complaint by Dezhou and 

moving for default. 

0.20 $105.00 

10/12/20 RJ Research similar email case on Pacer. 0.50 $190.00

10/12/20 EM Analyze and revise Motion for Entry of Clerk's Default 

against Dezhou. 

0.20 $105.00 

10/12/20 EM Analyze proposed Order on Clerk's default against Dezhou. 0.10 $52.50 

10/12/20 EM Research re issue of seeking damages as part of final default 

judgment against Dezhou. 

1.00 $525.00 

10/12/20 EM Analyze Clerk's Default entered against Dezhou. 0.10 $52.50 

10/12/20 RJ Posting of documents filed on defendant Alibaba website 

and create screenshot confirmations and correspondences 

on same. 

0.20 $76.00 

10/12/20 RJ Filing of motion for default and service on Chinese

defendant. 

0.20 $76.00 

10/12/20 RJ Draft of proposed Clerk's Default and correspondences on 

same. 

0.50 $190.00 

10/13/20 EM Analyze court docket re preparation of Motion to excuse 

compliance with Rule 16(b) requirements. 

0.40 $210.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 28 of 50
TheraGun, Inc. Invoice No. 10972598 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: November 4, 2020 

Page 3 

10/13/20 EM Prepare Motion to Excuse compliance with Rule 16(b)

requirements. 

0.50 $262.50 

10/13/20 EM Prepare Order on Motion to excuse compliance with Rule 

16(b) requirements. 

0.10 $52.50 

10/13/20 EM Additional research re requirements for damages in default 

judgment against Dezhou. 

0.30 $157.50 

10/13/20 EM Communications with G. Cordrey re 0.20 $105.00 

10/13/20 MC Create cover page and compile exhibits in connection with 

Plaintiff’s Motion to Excuse Compliance. 

0.20 $32.00 

10/14/20 RJ Correspondences and upload of filed motion to defendant's 

Alibaba website. 

0.20 $76.00 

10/14/20 EM Communications with G. Cordrey re 0.20 $105.00 

10/14/20 EM Revise and finalize Motion to be excused from Rule 16(b) 

requirements. 

0.30 $157.50 

10/14/20 EM Communications with R. Berman re 0.20 $105.00 

10/14/20 EM Analyze Court's confirmation of filed Motion to excuse 

compliance with Rule 16(b) requirements. 

0.10 $52.50 

10/20/20 RJ Correspondences Re: from co-counsel and internally Re: 0.20 $76.00 

10/20/20 EM Analyze file re deadline for compliance with Rule 16 

requirements. 

0.10 $52.50 

10/20/20 EM Communications with R. Berman and G. Cordrey 0.20 $105.00 

10/20/20 EM Communications with G. Cordrey re 0.30 $157.50 

10/21/20 RJ Service correspondence to Chinese defendant and upload of 

documents plus message on Defendant's Alibaba portal. 

0.30 $114.00 

10/21/20 EM Analyze and revise Motion for Default Judgment against 

Dezhou. 

0.60 $315.00 

10/21/20 EM Analyze and revise proposed Order on Motion for Default 

Judgment. 

0.20 $105.00 

10/21/20 EM Analyze confirmation of filed Motion for Default 

Judgment. 

0.10 $52.50 

10/21/20 EM Analyze communication to Court submitting proposed 

Order on Motion for Default Judgment. 

0.10 $52.50 

10/21/20 EM Communications with G. Cordrey re 0.20 $105.00 

10/21/20 EM Analyze confirmation of electronic service of Motion for 

Default on Dezhou. 

0.10 $52.50 

10/22/20 RJ Review judicial order on scheduling report and judge's draft 

order. 

0.30 $114.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 29 of 50
TheraGun, Inc. Invoice No. 10972598 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: November 4, 2020 

Page 4 

10/22/20 EM Analyze file re preparation of Unilateral Scheduling Report 

and proposed Order. 

0.20 $105.00 

10/22/20 RJ Draft of proposed unilateral scheduling report and 

correspondence on same. 

1.20 $456.00 

10/23/20 RJ Correspondences RE: unilateral scheduling report, review 

proposed order, and service of filing through Alibaba 

defendant website. 

0.40 $152.00 

10/23/20 EM Revise Unilateral Scheduling Report. 0.30 $157.50 

10/23/20 EM Revise proposed Scheduling Order. 0.20 $105.00 

10/23/20 EM Communications with G. Cordrey and R. Berman 0.10 $52.50 

10/23/20 EM Analyze Court confirmation of filed Unilateral Scheduling 

Report. 

0.10 $52.50 

10/23/20 EM Analyze communication to Court submitting proposed 

Scheduling Order. 

0.10 $52.50 

10/23/20 EM Prepare communication to G. Cordrey and R. Berman 0.10 $52.50 

10/23/20 EM Prepare communication to G. Cordrey and R. Berman 0.10 $52.50 

10/26/20 EM Analyze several communications from Dezhou on 

Alibaba.com confirming receipt of Summons, Complaint 

and other documents served. 

0.30 $157.50 

 

 Current Fees: $7,062.50

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 9.70 $ 525.00 $ 5,092.50 

Jimenez, Robert 5.10 $ 380.00 $ 1,938.00 

Cohen, Maday 0.20 $ 160.00 $ 32.00 

 

 15.00 $ 7,062.50 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 30 of 50
1784 REMITTANCE COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

December 3, 2020

FILE # 301822 - 1

Invoice # 10978064 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 12,741.68 

 

CURRENT FEES: $ 954.00 

CURRENT DISBURSEMENTS: $ 30.60 

CURRENT BALANCE DUE: $ 984.60 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 13,726.28 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 31 of 50
1784 CLIENT COPY

PAYMENT IS DUE UPON RECEIPT 

To ensure timely allocation to amounts due, please wire payment to:

Wells Fargo Bank, NA 

GrayRobinson, P.A. Operating Account 

Please reference your File or Invoice Number. 

Page 1 

GRAYROBINSON

Attorneys At Law

Post Office Box 3068 

Orlando, Florida 32802 

Telephone (407) 843-8880 

Benjamin Nazarian.CEO 

Theragun, Inc. 

6100 Wilshire Blvd., Inc. 

Los Angeles, CA 90048 

December 3, 2020

FILE # 301822 - 1

Invoice # 10978064 

Re: Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan Golovan and 

Dezhou Create Fitness Equipment Co. Ltd. 

This summary includes all transactions on the above matter processed up to and including the date of the 

last transaction shown on this invoice. Any transactions, including credits or receipts processed after that 

date will be reflected on a future statement. 

PRIOR BALANCE: $ 12,741.68 

 

CURRENT FEES: $ 954.00 

CURRENT DISBURSEMENTS: $ 30.60 

CURRENT BALANCE DUE: $ 984.60 

 

TOTAL BALANCE DUE: 

(Prior balance included) 

$ 13,726.28 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 32 of 50
TheraGun, Inc. Invoice No. 10978064 

Theragun, LLC v Golovan Ltd. d/b/a GetKraft, Ivan 

Golovan and Dezhou Create Fitness Equipment Co. Ltd. 

Invoice Date: December 3, 2020 

Page 2 

Professional Services: 

11/05/20 EM Prepare communication to client re 0.20 $105.00 

11/20/20 RJ Review signed order on default, correspondences on same 

and upload to defendant's Alibaba website and 

correspondence to defendant on same. 

0.30 $114.00 

11/20/20 EM Analyze Final Default Judgment entered by Court against 

Dezhou. 

0.20 $105.00 

11/20/20 EM Analyze notice of Court's notification to USPTO re Final 

judgment entered against Dezhou. 

0.20 $105.00 

11/20/20 EM Analyze file and Rules re deadline for filing Motion for 

Attorneys' Fees against Dezhou. 

0.30 $157.50 

11/20/20 EM Prepare letter to R. Berman re 0.30 $157.50 

11/20/20 EM Analyze confirmation of service of Judgment electronically 

upon Dezhou re deadline for Dezhou to comply with 

requirements of Judgment. 

0.20 $105.00 

11/30/20 EM Communications with R. Berman re 0.20 $105.00 

 

 Current Fees: $954.00

 Summary of Professional Fees: 

NAME HOURS RATE AMOUNT 

Martinez, Elio 1.60 $ 525.00 $ 840.00 

Jimenez, Robert 0.30 $ 380.00 $ 114.00 

 

 1.90 $ 954.00 

Disbursements: 

10/09/20 Computer Research Westlaw - JIMENEZ $ 30.60 

 

 Current Disbursements: $ 30.60 

Summary of Disbursements: 

 DESCRIPTION AMOUNT 

Computer Research $ 30.60 

 $ 30.60 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 33 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 206 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

Our Matter # 76840-9042 For Services Through May 31, 2020 

v. Golovan Ltd.

05/08/20 Review Kraft website; capture webpages; review chart to determine if 

details are up to date; research re 

KraftGun relationship to Golovan Ltd. 

 

Shiloh Filin 1.40 hrs. 395.00/hr $ 553.00 

05/08/20 Correspondence re purchase of infringing goods. 

Remi Salter 0.30 hrs. 395.00/hr 118.50 

05/08/20 Exchange e-mail with client . 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/08/20 Review infringement analysis and conference with associate re 

obtaining samples (.3); preparation of e-mail to client (.1). 

 

Rod S. Berman 0.40 hrs. 945.00/hr 378.00 

05/08/20 Review email from R. Berman (.1); check Kraft website and other 

related 

online pages to determine continuing infringement and any changes 

since last review (.2); 

 

Brennan C. Swain 0.60 hrs. 675.00/hr 405.00 

05/11/20 Exchange e-mail 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

05/11/20 Prepare for and participate in conferences with R. Berman and S. Filin 

re sellers, importer/exporters and manufacturers and connections 

thereto (.2); 

 

Brennan C. Swain 0.90 hrs. 675.00/hr 607.50 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 34 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 207 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

05/12/20 Review KRAFTGUN websites and social media presence (.8); 

research re KRAFTGUN entity and U.S. presence (.4); research re

Golovan (.3); review and analyze KRAFTGUN product and relevant 

patents (.3); initiate work on Complaint (.3). 

 

Jessica Bromall Sparkman 2.10 hrs. 655.00/hr 1,375.50 

05/13/20 Conference with B. Swain 

(.1); conference with G. Cordrey re potential infringement claims and 

preparation of e-mail to client (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/13/20 Conference with J. Bromall Sparkman re venue for lawsuit and 

allegations re old and new Kraft models. 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/13/20 Initial review of new Kraft version (.1); preparation of e-mail 

 and conference with colleague re patent analysis (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/13/20 Review e-mails re Kraft investigation and conference with associate 

re same. 

 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

05/13/20 Analyze Kraftgun 2.0 for infringement (.6); draft summary of same 

for R. Berman (.5). 

 

Greg Cordrey 1.10 hrs. 750.00/hr 825.00 

05/13/20 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 35 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 208 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

05/14/20 Review emails and information about Dezhou and work on Dezhou 

strategy (.5); research re U.S. entity (.2); consider strategy for 

additional defendants (.3); work on draft complaint (1.6). 

 

Jessica Bromall Sparkman 2.60 hrs. 655.00/hr 1,703.00 

05/14/20 Review and revise e-mail to client 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/14/20 

 

05/14/20 

 

05/15/20 Analyze issue of service on Dezhou (1.2); confer with R. Berman re 

same (.2). 

 

Greg Cordrey 1.40 hrs. 750.00/hr 1,050.00 

05/15/20 Review complaint. 

Brennan C. Swain 0.30 hrs. 675.00/hr 202.50 

05/15/20 Work on draft complaint (1.9); work on strategy for service and for 

naming defendants (.5). 

 

Jessica Bromall Sparkman 2.40 hrs. 655.00/hr 1,572.00 

05/16/20 

 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 36 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 209 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

05/16/20 Draft email to client re 

 (.6); emails to investigator re further investigation 

of Golovan's U.S. connections and Fulfillmint and Miami warehouse 

(.2). 

 

Jessica Bromall Sparkman 0.80 hrs. 655.00/hr 524.00 

05/17/20 Work on strategy for complaint (.2); consider service issues (.2). 

Jessica Bromall Sparkman 0.40 hrs. 655.00/hr 262.00 

05/18/20 Confer with R. Berman re naming Dezhou as a defendant in the 

Kraftgun lawsuit. 

 

Greg Cordrey 0.20 hrs. 750.00/hr 150.00 

05/18/20 Evaluate service issues and inclusion of Dezhou; conference with B. 

Nazarian ; exchange e-mail with local Florida counsel. 

 

Rod S. Berman 0.40 hrs. 945.00/hr 378.00 

05/18/20 Review and analyze information re potential 

defendants (.4); work on strategy for naming Dezhou (.1); revise 

complaint (.1). 

 

Jessica Bromall Sparkman 0.60 hrs. 655.00/hr 393.00 

05/19/20 Conference with J. Bromall Sparkman re preparation of complaint and 

service issues. 

 

Rod S. Berman 0.30 hrs. 945.00/hr 283.50 

05/19/20 Research re Golovan, Miami warehouse owner, and Kraft Gun 

locations and analysis of service and jurisdiction options (1.1); work 

on strategy for same (.6). 

 

Jessica Bromall Sparkman 1.70 hrs. 655.00/hr 1,113.50 

05/20/20 Review and revise draft Kraft complaint including evaluation of 

potential defendants (.3) and preparation of e-mail to client 

(.1). 

 

Rod S. Berman 0.40 hrs. 945.00/hr 378.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 37 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 210 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

05/20/20 Interview local Miami counsels and preparation of e-mail to client 

Rod S. Berman 0.50 hrs. 945.00/hr 472.50 

05/20/20 Research re warehouse owner/operator (Fulfilmint and AIMS) (.8); 

revise complaint (.9); email re same and re strategy for naming

defendants (.4); work on strategy for naming defendants (.5). 

 

Jessica Bromall Sparkman 2.60 hrs. 655.00/hr 1,703.00 

05/21/20 Conference with Greg re Dezhou’s manufacture of Kraftgun. 

Brennan C. Swain 0.10 hrs. 675.00/hr 67.50 

05/22/20 

 

05/22/20 

 

05/22/20 

 

05/25/20 Exchange e-mails with local counsel re complaint. 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

05/25/20 Conference with client re (.1); 

preparation of e-mail to local counsel re same (.1). 

 

 Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

 Total Fees for Professional Services for this Matter for this Invoice ............. $ 20,513.50 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 38 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

June 10, 2020 

Invoice 1787735 

Page 211 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

 (** Less Courtesy Discount ............................................................................ $ 2,013.55) 

 Total Fees Less Courtesy Discount ................................................................ $ 18,499.95 

 Total Fees and Costs for this Matter for this Invoice ...................................... $ 18,499.95 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 39 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

July 16, 2020 

Invoice 1790607 

Page 204 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

Our Matter # 76840-9042 For Services Through June 30, 2020 

v. Golovan Ltd.

06/01/20 Conference with Florida counsel re adding Dezhou create fitness 

equipment (.1) and preparation of email re same (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr $ 189.00 

06/01/20 Exchange email with opposing attorney re filing. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/02/20 Review Kraft final complaint and exchange emails re same (.2); 

conference with G. Cordrey re unfair competition claim (.1). 

 

Rod S. Berman 0.30 hrs. 945.00/hr 283.50 

06/03/20 Exchange email with Florida counsel re imminent filing. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/04/20 Review filed complaint and email from local counsel and preparation 

of email to client re . 

 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/08/20 Conference with H. Solton regarding 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/10/20 Exchange email with Florida counsel regarding service. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/15/20 Conference with (.1) 

and preparation of email to client (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 40 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

July 16, 2020 

Invoice 1790607 

Page 205 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

06/17/20 Determine which patents that have issued since filing of complaint 

and which, if any, should be included in possible amended complaint 

(.1); conference with Greg regarding same. (.1). 

 

Brennan C. Swain 0.20 hrs. 675.00/hr 135.00 

06/19/20 Conference with G. Codrey regarding next steps. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/19/20 Exchange email with opposing counsel regarding extension (.1) and 

with client (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

06/21/20 Review email from potential defendant lawyer and preparation of 

email to client . 

 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

06/23/20 Correspondence regarding purchase of Kraftgun. 

Remi Salter 0.30 hrs. 395.00/hr 118.50 

06/24/20 Correspond with (.1); conference with 

Rod regarding Kraft stopping sales and call with Ben (.2). 

 

Brennan C. Swain 0.30 hrs. 675.00/hr 202.50 

06/25/20 Exchange email (.1) and with opposing attorney 

regarding extension and information for settlement demand (.1).

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

06/25/20 Review email from opposing attorney and extension papers (.1); 

preparation of email to local Florida counsel and client regarding 

 (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 41 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

July 16, 2020 

Invoice 1790607 

Page 206 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

06/26/20 Correspondence regarding sale and purchase of Kraftgun. 

 Remi Salter 0.10 hrs. 395.00/hr 39.50 

 Total Fees for Professional Services for this Matter for this Invoice ............. $ 2,385.50 

 (** Less Courtesy Discount ............................................................................ $ 238.55) 

 Total Fees Less Courtesy Discount ................................................................ $ 2,146.95 

 Total Fees and Costs for this Matter for this Invoice ...................................... $ 2,146.95 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 42 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

August 14, 2020 

Invoice 1792999 

Page 184 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

Our Matter # 76840-9042 For Services Through July 31, 2020 

v. Golovan Ltd.

07/02/20 Exchange email with opposing attorney re disclosure (.1); preparation 

of email to client re (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr $ 189.00 

 

 

07/05/20 Analysis of damages 

Rod S. Berman 0.40 hrs. 945.00/hr 378.00 

07/05/20 Preparation of email to client re 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/06/20 Correspond re settlement possibility and patents 

infringed by the KraftGun. 

 

Brennan C. Swain 0.20 hrs. 675.00/hr 135.00 

 

 

07/11/20 Preparation of email to client re 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/17/20 Review email from Florida local counsel (.1); preparation of email to 

client (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 43 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

August 14, 2020 

Invoice 1792999 

Page 185 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

07/23/20 Emails with attorneys re Golovan settlement, asin listing; review chart 

re same. 

 

Shiloh Filin 0.20 hrs. 395.00/hr 79.00 

 

 

 

 

07/23/20 Conference with C. Moncrief re 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

07/24/20 Conference with local counsel re status of case and settlement. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/28/20 Review patent claims and new Kraft massage gun (.2); conference 

with B. Swain re infringement issue (.1). 

 

Rod S. Berman 0.30 hrs. 945.00/hr 283.50 

07/28/20 Conference with Ben Nazarian and C. Moncrief re 

 (.1); conference with C. Moncrief re 

 (.1);

preparation of draft response to Golovan (.4) and exchange email with 

Ms. Moncrief re (.1). 

 

Rod S. Berman 0.70 hrs. 945.00/hr 661.50 

07/28/20 Review email from Christina re (.2); analyze device and 

compare to issued patents and pending applications (.7); prepare email 

 (.2); prepare for and participate in conference with R. 

Berman, B. Nazarian and C. Moncrief (.6). 

 

Brennan C. Swain 1.70 hrs. 675.00/hr 1,147.50 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 44 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

August 14, 2020 

Invoice 1792999 

Page 186 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

07/29/20 Review email from client re and preparation of 

email to Florida counsel re same. 

 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/29/20 Exchange email with local counsel re making appearance. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/29/20 Exchange email with opposing attorney re extension. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/29/20 Review email from local counsel and preparation of email to C. 

Moncrief re . 

 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

07/31/20 Review motion to extend and exchange email with local Florida 

counsel re same (.1); preparation of email to client re 

 (.1). 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

07/31/20 Exchange emails re corporate disclosure statement. 

 Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

 Total Fees for Professional Services for this Matter for this Invoice ............. $ 5,569.00 

 (** Less Courtesy Discount ............................................................................ $ 556.90) 

 Total Fees Less Courtesy Discount ................................................................ $ 5,012.10 

 Total Fees and Costs for this Matter for this Invoice ...................................... $ 5,012.10 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 45 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

September 18, 2020 

Invoice 1796240 

Page 200 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

Our Matter # 76840-9042 For Services Through August 31, 2020 

v. Golovan Ltd.

08/03/20 

 

08/03/20 Review emails from Florida counsel and email from customer; 

exchange email with Florida counsel re same; preparation of email to 

client re 

 

Rod S. Berman 0.30 hrs. 945.00/hr 283.50 

 

 

 

 

 

 

08/07/20 Conference with C. Moncrief re exchange 

email with Florida counsel re court date extensions. 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

08/18/20 Correspond with Florida counsel re motion to serve Dezhou by 

electonic means. 

 

Greg Cordrey 0.30 hrs. 750.00/hr 225.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 46 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

September 18, 2020 

Invoice 1796240 

Page 201 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

08/18/20 Conference with client re exchange email with Florida 

counsel re same and Dezhou default. 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

08/18/20 Exchange email with local counsel re dismissal and re serving 

Dezhou; review executed agreement; preparation of email to client re 

 

Rod S. Berman 0.30 hrs. 945.00/hr 283.50 

08/20/20 Review motion to serve Dezhou by electronic means and provide 

comments and related correspondence from Dezhou to Florida 

counsel. 

 

Greg Cordrey 0.50 hrs. 750.00/hr 375.00 

08/20/20 Review emails re service on Dezhou; review draft motion and 

conference with G. Cordrey re same. 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

08/21/20 Preparation of email to client re 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

08/25/20 Review stipulation of dismissal and court order; review motion to 

serve Dezhou; exchange email with Florida counsel and preparation 

of emails to C. Moncrief re 

 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

08/28/20 Correspondence re Kraftgun goods. 

Remi Salter 0.10 hrs. 395.00/hr 39.50 

08/31/20 Review motion to extend time for scheduling conference (.1) and 

confer with local counsel re same (.1). 

 

Greg Cordrey 0.20 hrs. 750.00/hr 150.00 

08/31/20 Exchange email with Florida counsel re motion to extend re Dezhou. 

 Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 47 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

September 18, 2020 

Invoice 1796240 

Page 202 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

 Total Fees for Professional Services for this Matter for this Invoice ............. $ 3,471.50 

 (** Less Courtesy Discount ............................................................................ $ 347.15) 

 Total Fees Less Courtesy Discount ................................................................ $ 3,124.35 

 Total Fees and Costs for this Matter for this Invoice ...................................... $ 3,124.35 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 48 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

November 13, 2020 

Invoice 1800743 

Page 247 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

Our Matter # 76840-9042 For Services Through October 31, 2020 

v. Golovan Ltd.

10/05/20 Confer with B. Swain re infringement of newly issued patents. 

Greg Cordrey 0.30 hrs. 750.00/hr $ 225.00 

10/06/20 Exchange email with Florida counsel re next steps. 

Rod S. Berman 0.10 hrs. 945.00/hr 94.50 

10/09/20 Telephone conference with local counsel re moving for default 

judgment on Dezhou (.3); confer with R. Berman re same (.3). 

 

Greg Cordrey 0.60 hrs. 750.00/hr 450.00 

10/14/20 Confer with client re 

Greg Cordrey 0.30 hrs. 750.00/hr 225.00 

10/19/20 Draft motion for default judgment. 

Greg Cordrey 1.40 hrs. 750.00/hr 1,050.00 

10/20/20 Draft motion for default judgment (.3); confer with local counsel re 

finalizing and filing same (.1); draft proposed Final Default Judgment 

and Permanent Injunction (.2). 

 

Greg Cordrey 0.60 hrs. 750.00/hr 450.00 

10/20/20 Review email re motion for default judgment and review same. 

Rod S. Berman 0.20 hrs. 945.00/hr 189.00 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 49 of 50
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW

1900 Avenue of the Stars, 7th Floor 

Los Angeles, California 90067-4308 

T: (310) 203-8080 F: (310) 203-0567

Attn: Benjamin Nazarian, CEO 

TheraGun, Inc. 

November 13, 2020 

Invoice 1800743 

Page 248 

 PLEASE INDICATE INVOICE AND MATTER # WITH REMITTANCE

10/23/20 Correspond with local counsel re unilateral scheduling motion (.2); 

correspond with client re and motion for default judgment (.1). 

 

 Greg Cordrey 0.30 hrs. 750.00/hr 225.00 

 Total Fees for Professional Services for this Matter for this Invoice ............. $ 2,908.50 

 (** Less Courtesy Discount ............................................................................ $ 290.85) 

 Total Fees Less Courtesy Discount ................................................................ $ 2,617.65 

 Total Fees and Costs for this Matter for this Invoice ...................................... $ 2,617.65 

Case 1:20-cv-22327-DPG Document 33-1 Entered on FLSD Docket 01/11/2021 Page 50 of 50