1

Date of service Page # /

Line #

Described service provided Hours

expended

Basis for Objection

2/15/2012 1 /22 Review criminal records of Pleas, Jones,

Smith, Lewis

1 Plaintiffs in civil suit 11 C 7718 settled by

counsel for same incident

2/15/2012 1/26-29 Telephone conferences with Pleas,

Lewis, Jones, Smith

1.2 Plaintiffs in civil suit 11 C 7718settled by

counsel for same incident

4/20/2012 2/26 Review answer from City 0.3 Monell-related; claim dismissed

6/18/2012 2/46 Review answer to amended complaint 0.3 Monell – related; claim dismissed

7/5/2012 2/50 Telephone call to courtroom deputy 0.2 Unnecessary

7/26/2012 3/5 Conf. with attorney G Yamin 0.4 Monell – related; claim dismissed

10/3/2012 3/9 Review def motion to compel 0.4 Motion to compel filed because Plaintiffs had

not responded to written discovery requests;

Issue created by counsel

10/4/2012 3/10 Review def motion to withdraw and

determine def representation

0.1 Unnecessary

10/16/2012 3/13 Telephone conf with Court Deputy 0.2 Unnecessary

10/16/2012 3/16 Draft response to motion to compel 1.1 Issue created by counsel by not responding to

written discovery requests

10/17/2012 3/19 Review attorney appearances (3) and

correlating with defendants

0.1 Unnecessary

11/1/2012 3/26 Telephone conf with attorney Vanorney 0.3 Monell – related; claim dismissed

11/4/2012 3/27 Review email from attorney Yamin 0.1 Monell – related; claim dismissed

11/26/2012 3/39 Telephone conf with attorney Cook 0.1 Unnecessary

11/26/2012 3/40 Telephone conf with attorney Vanorney 0.1 Monell – related; claim dismissed

1/2/2013 3/46 Review def Motion to Compel 0.3 Monell – related; claim dismissed; Issue

created by counsel

1/6/2013 3/47-49 Draft notice and motion to reset and

email def attorneys

0.7 Monell – related; claim dismissed

DEFENDANTS’ OBJECTIONS TO DYMKAR FEES

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2

1/7/2013 3/50 Review court order 0.1 Monell – related; claim dismissed; related to

counsel’s motion

1/9/2013 3/51 Review court order 0.1 Monell – related; claim dismissed

1/10/2013 3/52 Review motion to withdraw 0.1 Unnecessary

1/13/2013 4/2-12 3.4 Monell – related; claim dismissed; related to

defense Motion to Compel P on Monell

discovery

1/31/2013 –

2/1/2013

4/14-16 Telephone calls and emails with court

deputy

0.6 Unnecessary

2/21/2013 4/31 Review def Motion to Compel 0.3 Motion to Compel Plaintiffs’ depositions;

issue created by counsel

2/22/2013 4/33-34 Draft notice and motion to reset 0.6 Related to motion to compel Plaintiff’s

depositions; issue created by counsel

2/22/2013 4/40 Draft K. Thornton subpoena 0.2 Unnecessary work created by counsel when

she knew Keith Thornton was residing out of

the state in California

2/26/2013 4/46-47 Draft Notice and Motion to Stay

Discovery

0.6 Counsel’s motion to stay discovery

2/28/2013 5/2,3,5,6 Depositions of Graney, Mangan,

Garcia, Gorzkowski

4.8 Defendants dismissed by Plaintiffs with each

side bearing its own costs and fees

3/15/2013 5/20 Draft RTP 1.7 Discovery stayed on counsel’s motion

3/18/2013 5/21 Telephone conf 0.3 Discovery stayed on counsel’s motion

4/23/2013 5/22-25 Emails with defense counsel / file

review

0.9 Discovery stayed on counsel’s motion

4/25,26, 29/2013 5/26-20 Communication with defense counsel 0.5 Discovery stayed on counsel’s motion

4/30/2013 5/30-32 Discovery review and drafting motion

to compel

2.3 Discovery stayed on counsel’s motion

5/1-2/2013 5/34-36 Legal research / draft motion to

compel

6 Related to discovery issues while discovery

was stayed on counsel’s motion

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3

5/2/2013 5/37-38 Keith Thornton correspondence 0.6 Discovery violation by counsel as never

produced

5/3/2013 5/39 Review defendants’ response to

Motion to Compel

0.4 Unnecessary work created by Plaintiffs

5/4/2013 5/42 Review FOIA request responses 2.1 Discovery violation – documents never

produced; improper means of obtaining

records during pending litigation if related to

litigation. If not related to litigation not

recoverable.

5/4-5/5/2013 5/43,44,46 Emails with Keith Thornton 0.6 Discovery violation – documents never

produced

5/6/2013 5/48,49 Statement for Keith Thornton

deposition

0.4 No service of the subpoena for deposition

was obtained on Keith Thornton; thus,

counsel knew that Keith Thornton would not

show for deposition. Additionally, at that

time, counsel was aware Keith Thorton was

residing in California; discovery issue created

by counsel

5/19/2013 6/27-29 Motion to compel and request to

admit

4.1 Plaintiffs did not prevail on the majority of

these issues

5/19/2013 6/30 Email to Keith Thornton 0.3 Discovery violation – document never

produced

5/22-23/13 6/32-34 Motions and notice of motion 0.7 Related to motions that Plaintiffs did not

prevail upon

5/27/2013 6/36 Email to Keith Thornton 0.2 Discovery violation – document never

produced

5/30/2018 6/44-46 Motion for rule to show cause 3.7 Motion denied; Court instructed counsel it

was sloppy

5/31/2013 6/47 Telephone call to court t deputy 0.1 Unnecessary

5/31/2013 6/50 Motion hearing on rule to show cause 1.7 Unsuccessfully motion

5/31/2013 7/1 Telephone conf with Court Deputy 0.1 Unnecessary

5/31/2013 7/2 Letter to multiple witnesses 0.8 Discovery violation – never produced

6/3/2013 7/12 Email to Keith Thornton 0.2 Discovery violation – never produced

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4

6/4/2018 7/13 Draft re-notice of motion 0.1 Motion denied

6/4/2013 7/14 Letter to five witnesses 1.0 Documents never produced

6/6/2013 7/20 Email to Keith Thornton 0.1 Never produced

6/6/2013 7/21 Email to 2 court deputies 0.1 Unnecessary

6/6/2013 7/22-24 Motion for protective order and

quashing dep notice

2.8 Related to deposition of Keith Thornton;

Unnecessary and baseless motion and issue

created by counsel because counsel knew

Keith Thornton had not been served with

the subpoena for deposition counsel earlier

issued

6/6/2013 7/25 Telephone conference with court

deputy

0.1 Unnecessary

6/7/2013 7/30 Hearing on emergency motion 1.0 Motion denied. Additionally, related to

deposition of Keith Thornton; unnecessary

and baseless motion

6/7/2013 7/31 Telephone conference with court

deputy

0.2 Unnecessary

6/7/2013 7/32,34 Draft re-notice of motion 0.2 Motions denied

6/7/2013 7/33 Hearing on emergency motion 0.9 Motion denied

6/7/2013 7/35 Review Court orders 0.1 Motions denied

6/12/2013 7/41 Review Court Order 0.2 Motion denied

6/12/2013 7/42 Prepare for motion hearing 0.8 Motion denied; vague entry; excessive time

6/12/2013 7/43 Motion hearing 1.4 Motion denied

6/15/2013 8/2-7 Drafting multiple motions 4.0 Motions denied

6/19/2013 8/9-12 Preparation and hearing on multiple

motions; review court orders

3.2 Plaintiffs’ motions denied; defendants

motion granted

6/20/2013 8/13 Review notice of motion 0.1 Motion denied

6/25/2013 8/24 Review Court order 0.1 Motion denied

7/5/2013 8/40 Review defendants’ motion to bar

witnesses

0.8 Unnecessary motion practice. Counsel

previously represented witnesses and billing

records reveal counsel had contact with

these witnesses. However, defendants

were unable to serve these witnesses and

counsel later (i) represented some at their

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5

respective deposition and (ii) listed all on

Plaintiffs’ witness list at trial

7/5/2013 8/41 Review defendants’ motion to stay

financial disclosures

0.7 Defendants’ motion granted; Unnecessary as

Plaintiffs ultimately traded costs for

punitives at trial

7/8/2013 8/43 Telephone conference with court

deputy

0.1 Unnecessary

7/11/2013 8/56 Draft response to motion for more

than ten depositions

2.2 Counsel unnecessarily objected to this

motion and then listed these individuals as

trial witnesses on the pre-trial order

7/11/2013 8/57 Draft response to motion to bar

witnesses

3.8 Defendants’ motion based on inability to

serve witnesses Plaintiffs’ counsel (i)had

contact and access to, (ii) represented some

at depositions, and (iii) listed all on Plaintiffs’

witness list at trial.

7/11/2013 8/58 Draft response to motion to stay

financial disclosures

1.9 Defendants’ motion granted; Unnecessary as

Plaintiffs ultimately traded costs for

punitives

7/16/2013 9/19 Review reply to response to motion for

more than ten depositions

0.4 Counsel unnecessarily objected to this

motion and then listed these individuals as

trial witnesses

7/17/2013 9/27 Telephone conf. With court deputy 0.2 Unnecessary

8/16/2013 10/11 Review defendants motion to compel 0.5 Motion to compel depositions of witnesses

disclosed by Plaintiff that were the subject of

the motion to bar. Defendants’ motion to

bar was based on inability to serve witnesses

Plaintiffs’ counsel (i)had contact and access

to, (ii) represented some at depositions, and

(iii) listed all on Plaintiffs’ witness list at trial.

8/20/2013 10/14-15 Multiple emails to court and defense 0.4 Unnecessary

8/22/2013 10/18 Draft response to motion to compel 3.3 Motion to compel depositions of witnesses

disclosed by Plaintiff that were the subject of

the motion to bar. Defendants’ motion to

bar was based on inability to serve witnesses

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6

Plaintiffs’ counsel (i)had contact and access

to, (ii) represented some at depositions, and

(iii) listed all on Plaintiffs’ witness list at trial.

8/23/2013 10/25 Telephone conf. With LeCharn Lewis 0.5 One of witnesses that was subject of Motion

to compel / bar. Defendants’ motion to bar

was based in part on inability to serve

witness LeCharn Lewis. Plaintiffs’ counsel

(i)had contact and access to Mr. Lewis, (ii)

represented Mr. Lewis at his deposition, and

(iii) listed Mr. Lewis on Plaintiffs’ witness list

at trial.

9/12/2013 10/40-41 Draft letter to witnesses LeSharn Lewis

and Shawn Smith

0.2 Witnesses that were subjects of Motions to

compel and bar. Defendants’ motion to bar

was based in part on inability to serve

witness LeCharn Lewis. Plaintiffs’ counsel

(i)had contact and access to Mr. Lewis, (ii)

represented Mr. Lewis at his deposition, and

(iii) listed Mr. Lewis on Plaintiffs’ witness list

at trial.

9/16/2013 10/48 Telephone conf with witness Shawn

Smith’s other

0.2 One of the witnesses that was the subject of

the motion to compel / bar. Defendants’

motion to bar was based in part on inability

to serve witness Shawn Smith. Plaintiffs’

counsel (i)had contact and access to Mr.

Smith, (ii) represented Mr. Smith at his

deposition, and (iii) listed Mr. Smith on

Plaintiffs’ witness list at trial.

9/24/2013 11/8-9 Conference with LeCharn Lewis and

review of his criminal history

1.3 One of the witnesses that was the subject of

Defendants’ motion to compel / motion to

bar and was Plaintiffs’ counsel’s client in this

case as well as in related resolved lawsuit.

Counsel contributed to the delay and wasted

litigation to have this witness deposed.

Unnecessary review of his criminal history

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7

and previously billed for 2/15/12.

Unnecessary conference as Mr. Lewis did not

have relevant information regarding

Plaintiffs’ claims in this case.

9/25/2013 11/16-17 Conference / deposition of LeCharn

Lewis

2.1 One of the witnesses that was the subject of

the motion to compel / motion to bar and

was Plaintiffs’ counsel’s client in this case

and in related resolved lawsuit. Counsel

contributed to the delay and wasted

litigation to have this witness deposed.

Unnecessary – Mr. Lewis did not have

information relevant to Plaintiffs’ claims in

this case.

9/30-10/1/2013 11/21-23 Motion to compel 2.2 Motion stricken by court

10/3/2013 11/27 Review motion to withdraw 0.1 Unnecessary

10/16/2013 11/36 Draft letter to witness Shawn Smith 0.2 Witness subject of Motion to compel / bar;

correspondence never produced despite

counsel’s assertions that she did not

represent Mr. Smith at the time Defendants

were attempting to serve Mr. Smith.

10/21/2013 11/39-40 Draft. Motion to extend 0.6 Unnecessary

11/1/2013 11-48-50 Phone calls and letters to LAPD 0.7 Related to witness Keith Thornton; materials

never produced in discovery

11/21/2013 12/16-17 Draft motion to strike defendants rule

56.1 statement of facts

0.7 Unnecessary; motion denied

12/4-12/6/2013 12/38-41 Review defendants response to motion

to strike; draft reply to response to

motion to strike

1.6 Motion denied

13/1, 2,

10, 15, 20,

23, 25, 32,

33, 34, 51

14.5 hours Vague, redundant, unnecessary billing

entries – telephone conferences with

deputy, “transcript reviews”, unnecessary

motion s to extend

5/5/2014 14/14-15 Draft notice and motion to strike 1.2 Unsuccessful motion

10/2/2014 14/30-31 Emails with court deputy 0.2 hours Unnecessary emails

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10/2/2014-7/6/2015 14/33, 34,

35, 37, 38,

39-45

Review of order, motion to reconsider 11.9 hours Vague billing entries “further review of

order”, unnecessary repetitive work, Motion

to reconsider denied

9/10/2015 15/4 Conference with attorney Hamilton 0.5 Attorney Hamilton did not file an

appearance on this case until 1/20/2016

9/16/2015 15/5 Phone call with court deputy 0.2 Unnecessary

9/18/2015;

10/6/201510/9/2015;

10/12/2015

15/19, 27,

34, 41

Emails and conferences with Attorney

Hamilton

1.0 Attorney Hamilton did not file an

appearance on this case until 1/20/2016

10/12 -13/2015 15/42, 43,

46, 47

Draft motions in limine 11.2 Motions denied

10/15, 27/2015;

11/18/2015

16/12, 17,

38, 39

Emails and conferences with Attorney

Hamilton

1.0 Attorney Hamilton did not file an

appearance on this case until 1/20/2016

10/19, 21, 22/2015 16/14, 15,

16

Multiple “Review of Court order” 0.3 Excessive, unnecessary, duplicative, vague

11/9/2015 16/25, 26 Draft notice and motion to strike 1.2 Motion denied

17/5, 8,

14, 16, 17,

21, 26-29,

32, 34-35,

38, 40-41

Multiple “Review of Court Order” 3.3 Excessive, unnecessary, duplicative, vague

17 /6, 12,

24,

Multiple conferences or telephone

calls with Attorney Hamilton

0.6 Attorney Hamilton did not file an

appearance on this case until 1/20/2016;

excessive, unnecessary

17/6, 49,

50

Multiple telephone calls or emails with

Court Deputy

0.3 Excessive, unnecessary, vague

3/23/2016 17/23-24 Draft notice and motion to set aside 2.4 Motion denied

6/30/2016 17/36 Draft email to Brian Orozco 0.1 Unnecessary, vague, unrelated to this case.

Mr. Orozco has never been counsel of record

in this civil action.

8/17/2016 18/2 Motion for referral to resolve

audiotape issue

1.4 Motion to resolve issue lost in part

8/18/2016 18/4, 5 Telephone calls with court deputy and

ACC Vanorney

0.5 Unnecessary, vague, as to Vanorney, Monell

claims had been dismissed

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8/18/2016 18/9, 13,

14, 21, 24,

25, 28, 37,

40, 46,

Multiple “review court order” 1.4 Unnecessary, vague, excessive

8/18/2016 18/10 Review motion to withdraw 0.1 Unnecessary

18/12, 20,

32, 36, 42,

47

Multiple conferences and emails with

co-counsel

3.3 Excessive, vague, unnecessary

8/18/2016 18/18 Review attorney appearance and

determine party representation

0.1 Vague, unnecessary

8/18/2016 18/30, 51 Review court transcripts 0.4 Vague, unnecessary, excessive

8/18/2016 18/36, 37 Draft notice and motion for additional

discovery

1.0 Motion denied

19/4, 5, 8,

11, 15, 17,

21, 26, 27,

34, 35, 38,

49

Multiple conferences / emails /

telephone calls with co-counsel

3.5 Vague, excessive

19/9, 14,

18, 22, 24,

28, 29, 36,

Multiple emails / phone calls /

conferences with courtroom staff

1.0 Vague, excessive, unnecessary

3/28/2017 19/32 Review attorney appearance and

determine party representation

0.1 Vague and unnecessary

19/33, 39,

44

Review Court Orders 0.3 Vague, excessive, unnecessary

20/13, 15,

20, 26, 27,

32, 46

Multiple “Review Court Orders” 0.7 Vague, unnecessary, excessive

20/ 14, 22,

29, 37, 38,

39, 47, 49

Multiple emails, phone calls,

conferences with co-counsel

6.3 Vague, excessive, unnecessary

20/16, 17,

19

Legal research / memorandum of law

regarding use of Keith Thornton

deposition at trial

3.1 Useless motion as Plaintiffs used Keith

Thornton’s deposition at trial

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10

20/28, 30,

31,

Multiple emails with courtroom staff 0.3 Vague, excessive, unnecessary

21/2, 3, 8,

15, 16, 22,

26

Multiple reviews of court orders, files,

transcripts; legal research

3.6 Vague, excessive, unnecessary

21/4, 5, 7,

9, 10

Multiple conferences with co-counsel 5.8 Vague, excessive, unnecessary

21/17 Email to Shawn Smith 0.2 This witness was the subject of motions to

compel and bar because unable to be served

for deposition. Correspondence never

produced despite counsel’s assertions that

she did not represent Mr. Smith at the time

Defendants were attempting to serve Mr.

Smith. Unnecessary as Mr. Smith did not

have information relevant to Plaintiffs’

claims.

21/20, 21 Telephone call and email with

courtroom staff

0.4 Excessive, vague, unnecessary

22/3, 4,

10, 24, 27,

32, 33, 36,

37, 42

Multiple conferences / meetings /

emails with co-counsel

4.4 Excessive and vague

22/5, 6, 7,

8, 9, 13,

14, 15

Additional Motions in Limine 5.4 Motions either denied or stricken as moot

22/20, 21,

29, 35, 43,

44

Review of requests to admit, motions

regarding reading admissions at trial

9.5 Motions denied

22/9, 14,

23, 29, 49

Multiple “review court order” 0.9 Vague, excessive, unnecessary

22/23, 26,

28

Multiple “review deposition transcript

abstracts

3.3 Vague, excessive, unnecessary

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11

22/12, 22,

34, 38, 41,

50

Trial preparation 11.8 Trial preparations for September 2017 trial

date which was continued on Plaintiffs’

motion due to Plaintiffs’ illness

23/1, 24,

26, 27, 28,

29, 39, 42,

46,

Multiple “review court order” and

“review court transcript” entries

2.3 Vague, excessive, unnecessary

23/2-3 Witness regarding defendant Valentin 0.5 Vague entry; Witness never disclosed;

23/4, 15,

17, 38, 43,

44,

Multiple texts, emails, phone calls and

conferences with co-counsel

2.3 Excessive and vague

23/5, 6, 7,

8, 9, 11,

20, 33,

Trial preparation 7.7 Apparent trial preparations when September

2017 trial continued on Plaintiffs’ motion

due to Plaintiffs’ illness

23/12, 13,

14, 16, 18,

19, 21, 22

Work related to financial depositions

of defendants

6.0 Plaintiffs traded punitives for costs, thus,

unnecessary

23/23 Related to motion regarding requests

to admit

0.7 Motion denied

23/34, 35,

36, 37

Draft notice and motions to file not

under seal and to bar

2.5 Motions denied

23/48, 49 Emails with courtroom staff 0.1 Vague, unnecessary

24/3, 8,

14, 33, 39,

41, 47

Multiple entries “review court order” 0.9 Vague, excessive, unnecessary

24/5, 22,

46,

Multiple emails and calls to courtroom

staff

0.5 Vague, excessive, unnecessary

24/6, 11,

30, 31, 34,

35, 43, 45,

49

Multiple emails, calls, conferences,

meetings with co-counsel

2.1 Vague, excessive, unnecessary

11/17/2017 24/21 Trial prep 1.2 Parties had already agreed to continue

December trial date

1/23/2018 24/43 Review statement regarding Valentin 0.1 Vague

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12

25/1, 2, 10 Review of court orders, motions to

withdraw, appearances

0.4 Vague, excessive, unnecessary

25/3, 4, 5,

6, 12, 21,

36, 37

Multiple emails, conferences,

regarding trial strategy and tasks

4.2 Excessive, vague, unnecessary

25/34, 35,

46,

Scene visit, review photographs,

compare photographs

3.3 Excessive time; duplicative work

26/1, 2, 3,

14, 18, 19,

45, 46,

Multiple emails, conferences and

telephone calls with co-counsel

3.6 Excessive, vague

26/9, 10,

11

Scene visit, photograph review, map

review

3.4 Excessive time; duplicative work

26/20, 21,

29, 30, 34,

35

Work related to motion in limine

regarding lost wages and judicial notice

of governmental website

5.2 Lost wages table not admitted at trial; public

website information not admitted at trial

26/48, 49,

50, 51

Work related to motion to bar Silva,

Garcia, show-up

2.5 Motions denied

27/12, 16,

22, 33, 43,

50

Multiple emails and conferences with

co-counsel

3.6 Excessive, vague

27/37, 38,

39, 40, 44,

45, 46, 47,

48, 49,

Work related to motions in limine

regarding Silva and Garcia testimony,

show-up testimony, chart of lost wages

8.2 Motions denied; duplicative work of motions

referenced in page 26 of time and work

records

7/17/2018 During jury trial counsel produced

records that were not disclosed during

discovery causing a delay in the trial

and unnecessary sidebars

0.3 Discovery violation due to undisclosed

documents resulting in wasted / delayed

time during trial.

7/21/2018 27/42 Legal research regarding trial issues 0.4 Vague

28/7, 13,

14

Multiple “review of court order” 0.4 Excessive, duplicative

28/17, 21,

23, 30, 32,

33, 34

Multiple emails and conferences with

co-counsel

1.9 Excessive, unnecessary

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13

28/15, 16,

18

Phone calls with courtroom deputy,

witness Brown-Lawrence, and Anthony

Pleas

0.8 Excessive, unnecessary; phone call to Pleas

appears to be offering legal advice or

counseling unrelated to the prosecution of

this lawsuit

28/38, 43 Legal research 2.3 Vague

29/3, 5, 7,

8

Review of timesheets 13 hours Excessive hours for task

29/22, 23 Legal research 2.9 Vague, excessive

Total objected hours 288.5

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