1

DEFENDANTS’ OBJECTIONS TO DASGUPTA FEES

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

expended

Basis for Objection

10/11/2016 –

7/27/2017

1/1-21; 2/1-20 Multiple meetings with co-counsel

regarding case strategy; multiple court

appearances

15.3 Vague, excessive, duplicative; Ms.

DasGupta did not have an appearance on

file in this case until 7/28/2017; Billed for

court appearances where co-counsel also

billed for appearance

7/28/2017-8/16/2017 2/21-28 Multiple meetings with co-counsel

regarding case strategy

0.9 Vague, excessive, duplicative

8/22/2017 3/1, 2, 4, 9,

13, 18, 19, 28,

33, 34,

Multiple discussions of case strategy

with co-counsel

2.2 Vague, excessive, duplicative

8/22, 24/2017 3/3, 16 Telephone conference re trial

technology

0.2 Trial continued on Plaintiffs’ motion

3/5, 6, 8, 10,

11, 12, 14, 15,

17, 20, 22, 23,

25, 29, 35, 36,

37

Telephone calls to clients; letters to

witnesses; trial contact information list;

telephone calls to witnesses; attempts to

locate witnesses, compiling lists of

motions in limine, reviewing / editing

pre-trial order; review voir dire

questionnaire; review transcript

8.7 Clerical or administrative work that should

be billed at paralegal rate

3/7, 21, 26,

31, 32,

Multiple calls to courtroom staff 0.6 Unnecessary, vague, excessive

4/1, 9, 10, 16,

21, 25, 26

Multiple meetings with co-counsel

regarding case strategy

3 Vague, excessive, unnecessary

4/2, 3, 4, 6, 7,

8, 11, 12, 13,

14, 15, 17, 18,

20, 22, 24, 27,

30, 31, 32

Telephone calls, subpoena drafting,

preparing exhibits, reviewing documents

7.3 Clerical or administrative work that should

be billed at paralegal rate.

4/19 Drafting motion regarding requests to

admit

1.2 Motion denied

Case: 1:12-cv-01132 Document #: 561-3 Filed: 11/16/18 Page 1 of 5 PageID #:8502
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4/28 Telephone call regarding “anonymous

witness” and defendant Valentin

0.4 Vague; information never disclosed in

discovery

5/1, 7, 9, 11,

12, 15, 17, 19,

20, 21, 23, 24,

25, 28, 29, 31,

35, 37

Telephone calls, drafting tables,

preparing exhibit books, drafting letters

9.6 Clerical or administrative; should be billed

at paralegal rate

5/2, 3, 13, 14,

16, 22, 27, 32,

33, 36

Multiple meetings and discussions with

co-counsel regarding case strategy

4.4 Vague, excessive, unnecessary

5/26 Telephone call regarding “anonymous

witness” and defendant Valentin

0.2 Vague; duplicative; information never

disclosed in discovery

5/30, 34 Making Google maps 2.7 Duplicative and unnecessary

5/38 Notice of financial depositions 02. Plaintiffs did not pursue punitive damages

at trial as they traded punitives for costs

6/1, 7, 10, 13,

19, 20, 22, 23,

25, 28, 31, 33,

34, 35, 37

Multiple meetings and discussions with

co-counsel regarding case strategy

1.8 Vague, excessive, unnecessary

6/2, 5, 17 Related to financial depositions of

defendants

0.7 Plaintiffs did not pursue punitive damages

at trial as they traded punitives for costs

6/3, 4, 6, 9,

11, 12, 14, 15,

16, 18, 27, 29,

32

Telephone calls, emails, letters 3.0 Clerical or administrative; should be billed

at paralegal rate.

6/8 Motion regarding requests to admit 0.3 Motion denied

10/18/2017 and

10/27/2017

6/21, 24 Court appearances 1.6 Duplicative; co-counsel billed for these

appearances

6/26 Telephone call regarding “anonymous

witness” and defendant Valentin

0.1 Vague, duplicative, information never

disclosed in discovery

7/1, 4, 5, 6, 7,

11, 15, 17, 18,

20, 22, 23, 24,

Multiple conferences with co-counsel

discussing case strategy

3.2 Vague, excessive, unnecessary

Case: 1:12-cv-01132 Document #: 561-3 Filed: 11/16/18 Page 2 of 5 PageID #:8503
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26, 28, 30, 33,

34, 36

7/2, 3, 9, 10,

12, 14, 19, 21,

27, 29, 31, 32,

35

Telephone calls, contacting witnesses

regarding new trial date, sending

subpoenas

5.4 Clerical or administrative; should be billed

at paralegal rate

11/30/2017 7/16 Review letter from anonymous witness

regarding defendant Valentin

0.2 Vague, duplicative, information never

disclosed in discovery

1/10/2018 7/25 Court appearance 0.6 Duplicative; co-counsel billed for this court

appearance

8/3, 6, 9, 11,

12, 14, 17, 22,

30

Multiple conferences with co-counsel

regarding case strategy

5.7 Vague, excessive, unnecessary

8/1, 2, 5, 7,

10, 13, 16, 18,

19, 20, 21, 23,

24, 25, 26, 27,

28, 29

Draft subpoenas, draft emails, schedule

witnesses

7.3 Clerical or administrative; should be billed

at paralegal rate

9/1, 2, 19, 23,

26, 27, 33, 34

Telephone calls, emails, drafting

subpoenas, preparing exhibit books

2.1 Clerical or administrative; should be billed

at paralegal rate

9/3, 9, 15, 24,

35

Multiple conferences with co-counsel

regarding case or trial strategy

4.2 Vague, excessive, unnecessary

9/6, 7, 10, 11,

13, 14, 16, 17,

18, 29, 30

Trial preparations regarding witnesses

not called or deemed duplicative at trial

7.1 Excessive, duplicative

7/12/2018 9/22, 31 Meet with Alex Zeier regarding

courtroom equipment

0.6 Duplicative of line 8; excessive

10/2, 5, 10,

11, 12, 14, 15,

17, 19, 20, 22,

23, 24, 27, 28,

29, 30, 31, 39,

40

Telephone calls, prepare exhibits books,

load trial lap top, write letters, prepare

exhibit folders

15.3 Clerical or administrative; should be billed

at paralegal rate

Case: 1:12-cv-01132 Document #: 561-3 Filed: 11/16/18 Page 3 of 5 PageID #:8504
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10/3, 8, 12,

13, 18, 26, 38

Multiple meetings with co-counsel

regarding case / trial strategy

2.6 Vague, excessive, unnecessary

10/4, 21, 32,

34, 35

Trial preparations 2.9 Duplicative of previous entries; excessive

hours for tasks involved

11/2, 11, 12,

19, 22, 27, 28,

35

Multiple meetings with co-counsel

regarding case / trial strategy

5.1 Vague, excessive, unnecessary

11/5, 25 Trial preparations 0.9 Duplicative of previous entries; excessive

hours for the task involved

11/6, 10, 15,

18, 24, 32, 39

Exhibit books, telephone calls, load

laptop for trial

1.9 Clerical or administrative; should be billed

at paralegal rate

11/33, 34, 35,

36, 37, 38

Tasks related to Motion to Bar Garcia

and Silva and Motion for Admission of

Wage Chart

5.1 Motions denied at trial

12/1, 10, 12,

15, 21, 24, 25,

27, 29, 30, 31,

32

Draft emails, prepare jury books,

compile jury instructions for Powerpoint,

compile receipts and invoices, order

transcripts, telephone calls

6.4 Clerical or administrative; should be billed

at paralegal rate

12/ 4, 5, 8, 23 Review transcripts and prepare trial

questions; draft Motion related to

Requests to Admit; Load lap top;

Compile receipts

5.7 Excessive, unnecessary, related to

witnesses not called or motions lost;

duplicative of previous entries

12/6, 11, 16,

19, 22, 26, 28

Multiple meetings with co-counsel

regarding case / trial strategy

1.9 Vague, excessive, unnecessary

13/ 1, 3, 8, 22,

26, 29

Multiple meetings with co-counsel

regarding case / trial strategy

1.5 Vague, excessive, unnecessary

8/24/2018 13/5 Prepare for court 0.3 Duplicative of previous entry; excessive

time for task

13/ 9, 10, 11,

12, 13, 15, 16,

17, 18, 19, 20,

21

Telephone calls, drafting documents 1.8 Clerical or administrative; should be billed

at paralegal rate

9/26/2018 13/25 Review time sheets for Angela Zaroff 0.9 Unrelated to this case

Disputed hours 85.6

Case: 1:12-cv-01132 Document #: 561-3 Filed: 11/16/18 Page 4 of 5 PageID #:8505
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Hours that should be billed at paralegal

rate

68.8

Case: 1:12-cv-01132 Document #: 561-3 Filed: 11/16/18 Page 5 of 5 PageID #:8506