1

LISTED PARALEGAL

HOURS

Date of service Page # / Line # Described service provided Hours

expended

Basis for Objection

1/1, 5, 21 Multiple discussions of case strategy

with co-counsel

0.5 Vague, excessive, unnecessary

3/23/2016 1/9 Motion to set aside order 2.5 Motion denied

8/17/2016 1/10 Send FOIA request to IPRA 0.3 Documents never produced in discovery

by Plaintiff; FOIA request rather than

subpoena

8/24/2016 1/14 Review FOIA response from IPRA 0.3 Documents never produced in discovery

by Plaintiff; FOIA request rather than a

subpoena

1/15, 16, 18 Court appearances 1.5 Not yet licensed as attorney; co-counsel

billed for these appearances

10/27/2016 and

11/1/2016

2/2, 3 Multiple meetings with co-counsel to

discuss case strategy

1.3 Vague, excessive, unnecessary

Disputed hours 6.4

LISTED ATTORNEY HOURS

1/1, 3, 13, 20 Review of transcripts and responses 1.9 Vague, excessive, unnecessary

1/ 4, 5, 7, 10,

15, 17

Multiple meetings with co-counsel to

discuss case strategy

5 Vague, excessive, unnecessary

1/11, 12, 16,

19

Compile hours, update charts, draft

letters, conduct research

3.3 Clerical / administrative; should be

billed at paralegal rate

11/22/2016 1/14 Court appearance 2.6 Duplicative hours; billed by co-counsel

11/23/2016 1/18 Review FOIA information; telephone

conference with LAPD

0.5 Discovery violation – materials never

produced in discovery; FOIA instead of

subpoena

2/ 1, 2, 6, 7,

18, 31

Transcribe OEMC audio, draft letters,

telephone calls, review docket, draft

subpoena

3.7 Clerical / administrative; should be

billed at paralegal rate

DEFENDANTS’ OBJECTIONS TO REGENSCHEIT FEES

Case: 1:12-cv-01132 Document #: 561-4 Filed: 11/16/18 Page 1 of 4 PageID #:8507
2

2/ 3 Fax documents to LAPD 0.2 Discovery violation – materials never

produced in discovery

2/4, 8, 11, 15,

22, 30

Multiple meetings with co-counsel

discussing case strategy

1.0 Vague, excessive, unnecessary

2/21 Review and compare transcript 1.1 Duplicative; excessive time for task

3/ 1, 2, 4, 12,

13, 20, 22, 24,

28, 29, 30

Telephone calls, draft letters, draft

subpoenas, serve subpoenas

2.6 Clerical / Administrative; should be

billed at paralegal rate

3/ 3, 5, 6 Review transcripts, review status

report, review OEMC audio

1.3 Vague, duplicative of other billing

entries; excessive time for task

performed

3/ 9, 11, 14,

17, 18, 19, 23,

27

Multiple meetings and discussions

with co-counsel

2.2 Excessive, vague, unnecessary

2/22/2017 3/ 10 Court appearance 1.2 Duplicative; co-counsel billed for this

court appearance

4/ 1 – 6, 8, 12,

14, 33

Telephone calls, review exhibits, draft

letters

3.1 Clerical / administrative; should be

billed at paralegal rate

4/7, 10, 13,

15, 18 – 24,

27, 29

Multiple reviews of deposition

transcripts, OEMC audio

10.6 Vague, excessive, duplicative

4/ 9, 25, 26,

28, 30, 32,

Multiple discussions and meetings

with co-counsel

2.1 Vague, excessive, unnecessary

4/25/2017 4/25/2017 Court appearance 0.9 Duplicative; co-counsel billed for this

court appearance

5/ 1, 2, 3, 8,

11, 12, 19

Draft letters, telephone calls, edit

transcript, request records

4.1 Clerical / administrative; should be

billed at paralegal rate

5/ 4, 5, 6, 7, 9,

13, 16, 26, 27,

28, 31, 32

Multiple meetings and discussions

with co-counsel

3.9 Vague, excessive, unnecessary

5/ 10, 17, 18 Review of documents and transcripts 2.6 Vague, excessive

6/1, 11, 20,

21, 27,

Review of various documents 4.3 Vague, excessive

Case: 1:12-cv-01132 Document #: 561-4 Filed: 11/16/18 Page 2 of 4 PageID #:8508
3

6/2, 4, 7, 8,

10, 17, 26, 29,

32, 34, 35, 36

Multiple conversations and meetings

with co-counsel

4 Vague, excessive, unnecessary

6/ 3, 5, 12, 22,

23, 24, 25, 30,

31

Draft emails, telephone calls, draft

notice of deposition

2.0 Clerical / administrative; should be

billed at paralegal rate

6/13/2017 6/13, 14 Court appearance 4.7 Duplicative; co-counsel billed for this

court appearance

7/13/2017 6/33 Create Google maps 2.6 Duplicative – multiple billing entries for

making maps

6/28 Deposition of Jill Maderak 1.4 Duplicative – deposition taken by cocounsel

7/1, 6, 8, 9,

10, 17, 20, 21,

22, 23, 24, 29

Multiple meetings / discussions /

conversations with co-counsel

8.8 Vague, excessive, unnecessary

7 / 3, 4 Email to Alex Zeier regarding

courtroom technology; create Google

maps

1.4 Duplicative of entries by co-counsel

7/5, 15, 27 Review of records, documents,

transcripts

1.2 Duplicative, vague

8/8/2017; 8/17/2017 7/7, 27 Court appearances 7.2 Duplicative as co-counsel billed for these

court appearance

7/11, 12, 13,

26, 28

Telephone calls, draft letters, draft

subpoenas, edit transcripts

3.6 Clerical / administrative; should be

billed at paralegal rate

8/2, 12, 21,

23, 28,

Telephone calls, edit transcripts, draft

letters

1.0 Clerical / administrative; should be

billed at paralegal rate

8/3, 4, 11, 17,

25, 26,

Review of documents, legal research,

review of court orders

5.0 Duplicative, excessive, vague

8/5, 7, 16, 22,

24, 31

Multiple conversations / meetings /

discussions with co-counsel

2.5 Vague, excessive, unnecessary

9/1/2017 8/9, 10 Court appearance 3.0 Duplicative as co-counsel billed for same

court appearance

Case: 1:12-cv-01132 Document #: 561-4 Filed: 11/16/18 Page 3 of 4 PageID #:8509
4

8/29, 32, 33,

34, 35

Work related to financial depositions

of defendant officers

4.9 Unnecessary litigation as plaintiffs did

not pursue punitive damages at trial;

traded costs for punitive damages

10/18/2017 9/14 Court appearance 1.1 Duplicative as co-counsel billed for same

court appearance

10/27/2017 9/18 Court appearance 1.1 Duplicative as co-counsel billed for same

court appearance

11/21/2017 9/32 Court appearance 1.0 Duplicative as co-counsel billed for same

court appearance

11/30/2017 9/33 Court appearance 0.9 Duplicative as co-counsel billed for same

court appearance

9/1 -5, 7-10,

12-13, 15

Work related to financial affidavits

and depositions of defendant officers

5.6 Unnecessary litigation as plaintiffs did

not pursue punitive damages at trial;

traded costs for punitive damages

9/6, 17, 20, 29 Review of documents, transcripts,

rulings, records

1.6 Vague, duplicative, unnecessary

9/11, 21, 22,

34, 35

Telephone calls, draft letters, review

documents

2.2 Clerical / administrative; should be

billed at paralegal rate

9/16, 19, 23,

27, 31,

Multiple conversations regarding case

strategy with co-counsel

1.1 Vague, excessive, unnecessary

1/10/2018 10/12 Court appearance 0.8 Duplicative as co-counsel billed for the

same court appearance

12/1/2017 10/1 Review letter received from

anonymous witness regarding

defendant Valentin

0.3 Vague; document never produced or

disclosed in discovery

10/2, 4, 5 Multiple discussions and

communications with co-counsel

0.3 Vague, excessive, unnecessary

10/3, 6, 7, 8, 9 Draft letters, telephone calls, office

meetings

1.9 Clerical / administrative; should be

billed at paralegal rate

Disputed hours 101.7

Hours that should be billed at

paralegal rate

27.5

Case: 1:12-cv-01132 Document #: 561-4 Filed: 11/16/18 Page 4 of 4 PageID #:8510