1

DEFENDANTS’ OBJECTIONS TO HAMILTON FEES

Date of Service Page # /

Line #

Described service provided Hours

expended

Basis for Objection

9/10/2015-11/18/2015 1/1-23 Multiple tasks 3.3 Attorney Hamilton did not file an appearance

on this case until 1/20/2016

1/20/2016 – 4/12/2016 1/28, 30,

31,

Multiple entries involving review of

co-counsel’s filings

0.3 Excessive and unnecessary

2/11, 30, Review of co-counsel Dymkar’s

motions

0.7 Excessive and unnecessary

2/18, 19,

26, 32, 33,

36, 39, 40,

41

Emails between co-counsel and

defense or court

0.9 Excessive and unnecessary

11/22/2016 2/29 Attend status hearing 1.5 Excessive and duplicative as co-counsel also

billed for this hearing

3/2,18, 28, Review of co-counsel Dymkar’s filings

and other work

0.3 Excessive and unnecessary

2/22/2017 3/3 Attend status hearing 1.0 Excessive and duplicative as co-counsel also

billed for this hearing

3/5,7, 8,

10, 11, 12,

14, 16, 18,

19, 21, 22,

27, 30, 31,

32, 33

Review of emails between co-counsel

and defense or court staff

1.7 Excessive and unnecessary

4/3, 4, 7,

10, 11, 12,

15, 25, 26,

38

Multiple emails between co-counsel

and courtroom staff

1.0 Excessive and unnecessary

8/8/2017 4/35 Attend status hearing 3.2 Excessive and duplicative as co-counsel also

billed for this hearing

Case: 1:12-cv-01132 Document #: 561-2 Filed: 11/16/18 Page 1 of 3 PageID #:8499
2

5/1, 2, 11,

13, 18, 19,

27

Multiple emails with co-counsel /

courtroom staff / defense counsel

0.8 Excessive and necessary

5/17 Status hearing 3.0 Excessive and duplicative as co-counsel also

billed for this hearing

8/23/2017 5/24, 26 Emails with Chris Shepherd 0.2 Excessive and duplicative

6/3, 4, 22,

24, 26, 27,

33

Multiple emails between co-counsel

and court or defense counsel

0.7 Excessive and unnecessary

6/30, 36,

37

Review of prior rulings and cocounsel filings and notes2.2 Excessive, vague, duplicative

7/1, 2, 3, 5,

6, 7, 8, 9,

10, 11, 12,

13, 14, 15,

16, 18, 19,

20,

Emails and other work (including

depositions) related to defendants’

finances

3.2 Work related to punitive damages which were

ultimately traded for costs and not pursued by

Plaintiffs

7/4, 21, 29,

34, 36, 40

Multiple emails between co-counsel

and defense counsel

0.5 Excessive and duplicative

7/39 Review of motion filed by co-counsel

Dymkar

0.1 Duplicative and unnecessary

8/8, 11, 35 Multiple emails between co-counsel

Dymkar and defense counsel

0.3 Excessive and duplicative

6/27/2018 9/1 Review attorney appearance for City 0.1 Duplicative – billed by co-counsel

9/20,21,

22, 23, 25,

28, 29, 33,

37

Multiple emails between co-counsel

and defense counsel or courtroom

staff

0.9 Duplicative and unnecessary

7/11/2018 10/2 Email related to defendants’ financial

affidavit

0.1 Punitives traded for costs and not pursued by

Plaintiffs

7/11-7/13/2018 10/4, 5, 6,

11, 12, 13,

14, 15, 16,

18, 20, 22,

Multiple emails between co-counsel

and defense counsel or courtroom

staff

1.6 Duplicative and unnecessary

Case: 1:12-cv-01132 Document #: 561-2 Filed: 11/16/18 Page 2 of 3 PageID #:8500
3

23, 27, 30,

32

7/12/2018 10/17 Review work of co-counsel Dymkar 0.1 Duplicative and unnecessary

7/14-7/16/2018 11/6, 7, 9,

10, 16, 17,

23

Multiple emails between co-counsel

to witnesses or courtroom staff

0.7 Duplicative and unnecessary

7/17-7/20/2018 12/4, 7, 17,

22, 28, 30,

31, 33, 34,

35

Multiple emails between co-counsel

to witnesses, courtroom staff or

defense counsel

1.1 Duplicative and unnecessary

7/21-22/2018 13/8, 29 Multiple emails concerning

testimony of Silva and Garcia and CPS

salary chart

0.2 Related to Motions in Limine that were denied

13/16, 20 Multiple emails between co-counsel 0.3 Excessive and duplicative

7/23-9/6/2018 14/1, 2, 3,

12, 13, 14,

15, 16, 18,

19, 20

Multiple emails between co-counsel

and defense counsel and court staff

1.1 Excessive and duplicative

9/13/2018 14/21 Create trial book 4.5 Excessive, duplicative, trial was over

Total disputed hours 34.6

Case: 1:12-cv-01132 Document #: 561-2 Filed: 11/16/18 Page 3 of 3 PageID #:8501