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Law Offices of Kevin J. Dolley, LLC

2726 S. Brentwood Blvd.

St. Louis, MO 63144

Date By Service Summary Hours/Rate Amount

In Reference To: Cosentino v. Transcend (Matters)

03/26/2012 MJO Telephone call with Debra Tolles, re: employment with

Transcend Services, Inc.

0.80 $220.00

03/26/2012 MJO Telephone call with Mary Kleppen, re: discuss employment

with Transcend Services, Inc. for purposes of drafting

Complaint

0.50 $137.50

03/26/2012 MJO Telephone call with Stacey Kirsh, re: discuss employment with

Transcend Services, Inc.

0.80 $220.00

03/26/2012 MJO Telephone call with Karla Ockerby, re: discuss employment

with Transcend Services, Inc.

0.40 $110.00

03/26/2012 MJO Telephone call with Shirley Carwright, re: discuss employment

with Transcend Services

0.80 $220.00

03/26/2012 MJO Telephone call with Diane Burgbacher, re: discuss

employment with Transcend Services, Inc.

0.50 $137.50

03/26/2012 MJO Draft emails to Debra Tolles, Mary Kleppen, Stacey Kirsh, Karla

Ockerby, Shirley Carwright, and Diane Burgbacher, re: client

agreements

0.40 $110.00

03/27/2012 MJO Telephone call with Lisa Edwards, re: discuss employment

with Transcend Services, Inc.

1.00 $275.00

03/27/2012 MJO Phone call with Debra Tolles, re: follow-up to discuss

employment with Transcend Services, Inc.

0.70 $192.50

03/27/2012 MJO Phone call with Linda Armstrong, re: discuss employment with

Transcend Services, Inc.

0.40 $110.00

03/27/2012 MJO Phone call with Theresa Cosentino, re: discuss employment

with Transcend Services, Inc. for purposes of drafting

Complaint

0.70 $192.50

03/27/2012 MJO Draft email to potential client Angel Foskey, re: employment

with Transcend Services

0.20 $55.00

03/28/2012 MJO Telephone call with Deborah Waldman, re: discuss

employment at Transcend Services, Inc.

0.50 $137.50

03/28/2012 MJO Phone call with Stacia Cornog, re: discuss employment with

Transcend Services, Inc.

0.50 $137.50

03/29/2012 MJO Telephone call with Judy Freeman, re: discuss employment

with Transcend Services, Inc.

0.50 $137.50

03/29/2012 MJO Draft email to potential client Judy Freeman, re: employment

with Transcend Services, Inc.

0.20 $55.00

03/29/2012 MJO Telephone call with Linda Matthias, re: discuss employment

with Transcend Services, Inc.

1.00 $275.00

03/30/2012 MJO Phone call to Mary McClelland, re: discuss employment with

Transcend Services

0.50 $137.50

03/30/2012 MJO Phone call to Candace Primeaux, re: discuss employment with

Transcend

0.50 $137.50

03/30/2012 MJO Phone call with Dawn Pence, re: discuss employment with 0.80 $220.00

Invoice # N/A

Invoice Date 04/11/2016

For Services Through 04/11/2016
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04/02/2012 MJO

Transcend

Phone call with Patricia Clunk, re: discuss employment with 1.20 $330.00

Transcend Services, Inc.

04/03/2012 MJO Call potential clients Debra Tolles, Mary Kleppen, Stacey Kirsh,

Karla Ockerby, Shirley Carwright, Sandy Lykins, and Diane

Burgbacher, re: consent forms

1.80 $495.00

04/03/2012 MJO Call potential clients Lisa Edwards, Debra Tolles, Linda

Armstrong, and Theresa Cosentino, re: consent forms

1.20 $330.00

04/03/2012 MJO Phone calls to potential clients Deborah Waldman, Stacia

Cornog, Judy Freeman, Linda Mathias, Mary McClelland,

Candace Primeaux, Dawn Pence, and Patricia Clunk, re:

consent forms and active employment at Transcend Services

2.80 $770.00

04/04/2012 MJO Perform research across all federal circuits pertaining to

medical transcription work and employer knowledge of offthe-clock work, re: for purposes of drafting Complaint in

Cosentino v. Transcend Services

6.00 $1,650.00

04/05/2012 MJO Research across all federal circuits for purposes of drafting

Complaint, re: off-the-clock work from home

1.50 $412.50

04/06/2012 MJO Review notes for purposes of drafting Complaint 0.50 $137.50

04/06/2012 MJO Draft Complaint, re: Nature of the Claim; Jurisdiction and

Venue; The Parties; Common Factual Allegations

8.00 $2,200.00

04/09/2012 MJO Draft/calculate pay rates and hours for clients 1.80 $495.00

04/09/2012 MJO Review client emails, re: status of lawsuit 0.30 $82.50

04/09/2012 MJO Draft Complaint, re: common factual allegations 1.30 $357.50

04/09/2012 MJO Phone call with Linda Mathias, re: status of Complaint and

lawsuit

0.50 $137.50

04/10/2012 KJD Draft, Edit Complaint 4.00 $1,800.00

04/10/2012 MJO Draft Complaint, re: common factual allegations; collective

action allegations; Count I- Failure to pay minimum wage;

Count II-Failure to pay overtime compensation

8.00 $2,200.00

04/11/2012 KJD Draft, Edit Complaint 2.00 $900.00

04/11/2012 MJO Edit/revise Complaint in accordance with instructions of

Attorney K. Dolley

3.50 $962.50

04/11/2012 MAS Reviewed Complaint. 0.25 $56.25

04/12/2012 KJD Draft, Edit, Email Complaint to Clients 0.50 $225.00

04/12/2012 KJD Review, Respond Emails from Clients RE: Complaint. 2.00 $900.00

04/12/2012 MJO Meeting with Attorney K. Dolley, re: venue for filing 0.50 $137.50

04/12/2012 MJO Review/revise/update Consent Forms 0.30 $82.50

04/12/2012 MAK Revised/ edited initial complaint. 0.30 $67.50

04/13/2012 MJO Edit Complaint, re: common factual allegations and Count I 1.50 $412.50

04/15/2012 KJD Email to Client. 0.25 $112.50

04/15/2012 KJD Prepare for Phone conference w/clients. 1.50 $675.00

04/16/2012 KJD Call with Plaintiffs preparing facts for complaint. 3.00 $1,350.00

04/16/2012 KJD Call with Local Counsel RE: filing. 0.25 $112.50

04/17/2012 KJD Prepare for Phone conference w/ Clients. 1.50 $675.00

04/17/2012 KJD Research Clients information meeting with clients. 2.00 $900.00

04/17/2012 KJD Prepare for phone conference with clients. 1.50 $675.00

04/17/2012 KJD Draft and Edit Complaint. 1.50 $675.00

04/17/2012 KJD Call with Class Members Review Complaint. 1.00 $450.00

04/17/2012 MJO Conference Call with Cosentino, et al, re: filing lawsuit 1.80 $495.00

04/18/2012 KJD Call to Local Counsel RE: Nature of Claims. 0.50 $225.00

04/18/2012 KJD Call to MAS RE: Status 0.10 $45.00

04/18/2012 MJO Phone call with Linda Matthias, re: filing Cosentino lawsuit 0.50 $137.50

04/18/2012 MJO Phone call with Lisa Edwards, re: filing of Cosentino lawsuit 0.80 $220.00

04/18/2012 MJO Update client database 0.50 $137.50

04/19/2012 KJD Review extended defense research, review co-counsel. 0.50 $225.00

04/19/2012 MJO Meeting with Attorney K. Dolley, re: employer knowledge 1.00 $275.00

04/20/2012 KJD Review, edit complaint call with Clients. 1.00 $450.00

04/26/2012 MJO Draft email to Plaintiff Linda Armstrong 0.20 $55.00
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04/26/2012 MJO Draft email and conduct various phone calls to Plaintiffs, re:

attorney/client privilege

1.50 $412.50

04/27/2012 KJD Draft, Edit complaint, File Documents. 2.00 $900.00

04/27/2012 MJO Draft email to Patricia Clunk 0.20 $55.00

04/27/2012 MJO Review full Complaint 1.30 $357.50

04/29/2012 KJD Email to Local Counsel. 0.50 $225.00

04/29/2012 KJD Review, Edit complaint. 1.50 $675.00

04/29/2012 MJO Scan and email consent forms 0.80 $220.00

05/01/2012 KJD Call with Local Counsel. 0.20 $90.00

05/01/2012 MJO Phone call with Linda Mathias 0.30 $82.50

05/01/2012 MJO Draft correspondence to medical transcriptionist Amanda (last

name unknown)

0.30 $82.50

05/03/2012 MJO Draft/update Complaint, re: common factual allegations 1.00 $275.00

05/07/2012 MJO Review/draft Complaint and Northern District of Illinois filing

materials before filing Complaint

3.00 $825.00

05/08/2012 KJD Draft, Edit filing documents email and calls with Local

Counsel.

3.00 $1,350.00

05/09/2012 KJD Review local counsel agreement and send email; draft and edit

email.

0.50 $225.00

05/11/2012 MJO Draft email to Cosentino, re: filing of Complaint 0.50 $137.50

05/12/2012 MJO Draft email to potential putative class members for Transcend

lawsuit

2.00 $550.00

05/13/2012 MJO Phone call with potential class member 0.50 $137.50

05/14/2012 KJD Calls with opt-in class members. 2.00 $900.00

05/14/2012 MJO Phone call with Attorneys K. Dolley and R. Riggan, re: filing of

Complaint

0.50 $137.50

05/14/2012 MJO Phone calls with potential class members to join Cosentino

lawsuit

1.50 $412.50

05/14/2012 MJO Phone calls/Emails with potential clients 6.00 $1,650.00

05/15/2012 MJO Phone calls/Emails with potential class members 7.00 $1,925.00

05/16/2012 MJO Phone call with co-counsel R. Riggan, re: status of case 1.50 $412.50

05/17/2012 MJO Phone calls and emails with clients, including T. Cosentino 5.00 $1,375.00

05/21/2012 MJO Phone call with medical transcriptionist Marla Johnson 0.80 $220.00

05/22/2012 MJO Phone call with potential class member 0.50 $137.50

05/23/2012 MJO Draft emails to clients including T. Cosentino, re: update on

status of lawsuit

0.80 $220.00

05/28/2012 KJD Draft and edit attorney fee splitting agreement. 0.25 $112.50

05/30/2012 MJO Phone call with lead Plaintiff T. Cosentino 1.25 $343.75

05/31/2012 MJO Phone calls and emails to clients, re: update on lawsuit 2.00 $550.00

06/01/2012 KJD Draft EOA; draft memo of filing. 0.50 $225.00

06/04/2012 MJO Draft email to all Plaintiffs, update with information re: lawsuit 0.50 $137.50

06/04/2012 MJO Telephone call with Cosentino 0.50 $137.50

06/05/2012 MJO Phone calls to all clients 1.00 $275.00

06/08/2012 KJD Prepare entry/ memo of filing. 0.50 $225.00

06/08/2012 MJO Phone calls to clients 1.00 $275.00

06/13/2012 KJD call with cler -- memo of filing summons and consents. 0.25 $112.50

06/14/2012 KJD Email to OC RE: conditional cert opt in forms; research, review

venue issues.

3.25 $1,462.50

06/17/2012 KJD Email OC. 0.25 $112.50

06/20/2012 KJD Draft, edit scheduling plan; email to OC RE; scheduling. 0.75 $337.50

06/21/2012 KJD Review and prepare scheduling plan. 0.50 $225.00

06/26/2012 MJO Draft Declarations for Plaintiffs Theresa Cosentino, Linda

Armstrong, Joy Bargerstock, Diane Burgbacher

4.50 $1,237.50

06/28/2012 MJO Draft Declarations of Interest for Patricia Clunk, Lisa Edwards,

Mary Kleppin, Judith Lugo, Linda Mathias, Dawn Pence, Jackie

St. Georges, Debra Tolles, and Deborah Waldman

8.00 $2,200.00

07/05/2012 MJO Conference call with all clients 0.80 $220.00

07/06/2012 MJO Draft email to class, re: update on status of lawsuit 0.50 $137.50
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07/11/2012 KJD Review declarations; communications with OC; email to OC

RE: possible scheduling plan change.

1.75 $787.50

07/19/2012 MJO Phone call with T. Cosentino 0.50 $137.50

07/20/2012 KJD Meeting with OC, set scheduling order, prep for conference. 0.50 $225.00

07/20/2012 MJO Research all federal circuits on topic of conditional

certification, re: common questions for group of medical

transcriptionists across the nation

8.00 $2,200.00

07/24/2012 KJD Travel to Chicago. 4.00 $1,800.00

07/25/2012 KJD Prep for status conference, hearing. 1.00 $450.00

07/25/2012 KJD Travel to St. Louis. 4.00 $1,800.00

07/31/2012 KJD Draft email to clients re: case status. 0.25 $112.50

07/31/2012 MJO Draft email to all clients, re: Scheduling Order 1.00 $275.00

07/31/2012 MJO Draft First Set of Interrogatories and Requests for Production

Directed to Defendant

8.20 $2,255.00

08/02/2012 KJD Review Request for documents; Draft, edit letter to OC. 3.10 $1,395.00

08/02/2012 MJO Draft discovery responses for Plaintiff T. Cosentino 6.50 $1,787.50

08/03/2012 KJD Review and edit Discovery Request 0.50 $225.00

08/07/2012 KJD Call with OC Reviewed Discovery. 0.50 $225.00

08/08/2012 MJO Draft discovery responses for Linda Mathias 5.00 $1,375.00

08/09/2012 KJD Draft, edit discovery request-- send out. 2.00 $900.00

08/09/2012 MJO Draft/revise discovery responses for Plaintiff T. Cosentino 2.00 $550.00

08/10/2012 MJO Research all federal circuits for allowable discovery techniques

in FLSA collective actions

2.50 $687.50

08/28/2012 MJO Draft/edit letter to opposing counsel, re: objections to third

party subpoenas to Defendant

0.40 $110.00

08/28/2012 MJO Draft/edit Plaintiff's objections to interrogatories and RFPs, re:

incorporate co-counsel's suggestions into Plaintiff's objections

to interrogatories and RFPs

0.90 $247.50

08/28/2012 MJO Draft objections to third party subpoenas for each opt-in

plaintiff, joint objections to request for production and

interrogatories for representative plaintiff; joint objections to

RFP and Interrogatories

3.50 $962.50

08/28/2012 MJO Phone call with local counsel to discuss filing motion to

quash and motion to extend discovery due date

0.20 $55.00

08/28/2012 MJO Draft Responses to Defendants Interrogatories and RFP for T.

Cosentino

1.50 $412.50

08/28/2012 MJO Phone call with client J. Bargerstock, re: interrogatory and

RFP responses

0.30 $82.50

08/28/2012 MJO Draft email to J. Bargerstock, re: documents needed to

respond to interrogatories and requests for production

0.30 $82.50

08/28/2012 MJO Draft Responses to RFP and Interrogatories for Bargerstock 0.50 $137.50

08/28/2012 MJO Draft Declaration for Bargerstock 0.50 $137.50

08/28/2012 MJO Draft correspondence in response to opposing counsel, re:

discovery deadlines

0.40 $110.00

08/28/2012 MJO Draft Response and Objections to First Set of Interrogatories

for Plaintiff Edwards

3.10 $852.50

08/28/2012 MJO Draft Declaration of Interest, re: incorporate co-counsel red

line suggestions into declaration of interest

1.70 $467.50

08/28/2012 MJO Phone call with Attorneys K. Dolley and R. Riggan, re:

defendant's discovery

0.40 $110.00

08/29/2012 MJO Draft Motion to Quash Defendants Third Party Subpoenas and

Notice of Deposition

1.90 $522.50

08/29/2012 MJO Draft Motion to Quash Defendants Third Party Subpoenas and

Notice of Deposition, re: Introduction; Facts; efforts to resolve

dispute under Local Rule 37.2

3.20 $880.00

08/29/2012 MJO Draft/revise discovery letter to opposing counsel, re:

subpoenas and notice of deposition

3.60 $990.00

08/29/2012 MJO Draft/revise discovery letter to opposing counsel, re:

subpoenas and notice of deposition

3.60 $990.00

08/29/2012 MJO Review opposing counsel's 8/28/12 email; our 8/29 letter to 1.00 $275.00
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Defendant, re: discovery; Defendant's interrogatories and

document requests; and our objections to Defendant's

interrogatories and document requests in order to write

Motion for Extension of Time to Provide Answers and

Objections to Defendant's Discovery

08/29/2012 MJO Draft and edit content and organization of our

correspondence to Defendant, re: discovery responses

2.90 $797.50

08/29/2012 MJO Research scope of discovery in federal court; purpose of FLSA

cases; and scope of discovery in FLSA cases for purposes of

writing Memorandum in Support of Plaintiffs' Motion to Quash

1.20 $330.00

08/29/2012 MAK Completed Pro Hac Vice Form and all necessary

documentation to enter my appearance pro hac.

0.50 $112.50

08/29/2012 MJO Wrote Analysis section of Plaintiffs' Memorandum in Support

of Motion to Quash

3.60 $990.00

08/30/2012 MJO Draft Section B of the Analysis Section in Plaintiffs'

Memorandum in Support of Plaintiffs' Motion to Quash

2.30 $632.50

08/30/2012 MJO Draft/provide final editing to Plaintiffs' Memorandum in

Support of Motion to Quash

1.60 $440.00

08/30/2012 MJO Phone call with attorneys K. Dolley, R. Riggan, and opposing

counsel, re: notice of deposition

0.70 $192.50

08/30/2012 MJO Draft/prepare answers and responses to Defendant's First Set

of Interrogatories Directed to Lisa Edwards, reviewed

numerous emails between Edwards and supervisors

3.60 $990.00

08/30/2012 MJO Draft Analysis section B and C of Memorandum in Support of

Plaintiffs' Motion to Quash

2.50 $687.50

08/30/2012 MJO Review/edit content and organization of Memorandum in

Support of Plaintiff's Motion to Quash

1.00 $275.00

08/30/2012 MJO Draft correspondence to opposing counsel, re: memorializing

proposed solution to discovery dispute

1.30 $357.50

08/31/2012 MJO Draft/complete draft to answers to first set of Interrogatories

and RFP for Plaintiff Theresa Cosentino to be used as template

for all Plaintiffs

5.20 $1,430.00

09/04/2012 KJD Call with OC in a conference call, 2nd call with oc on my line,

discovery dispute, amended written discovery and deposition

scheduling; call with local counsel instructions for appearance

joint motion, review edit and prepare motion for filing.

1.00 $450.00

09/04/2012 MJO Draft Response to Defendant's Interrogatories and RFP, re:

Linda Mathias and Dawn Pence

4.00 $1,100.00

09/04/2012 MJO Draft, edit Declarations of Interest for Plaintiff Teresa

Cosentino

1.30 $357.50

09/04/2012 MJO Filed Parties' Joint Motion for Extension 0.40 $110.00

09/04/2012 MJO Phone call with client Clunk, re: discovery responses 0.40 $110.00

09/05/2012 KJD Email to local counsel prepare motion for presentation; review

letter RE: discovery agreement, email to Russ regarding letter.

0.75 $337.50

09/05/2012 MJO Draft Responses to RFP for Plaintiff Dawn Pence 1.60 $440.00

09/05/2012 MJO Phone call with Joy Bargerstock, re: discovery responses 0.60 $165.00

09/05/2012 MJO Draft/revise Pence Response to Defendant's Interrogatories

and RFP

2.40 $660.00

09/05/2012 MJO Draft, edit, and finalize First Request for Production and

Interrogatories to Directed to Defendant

4.70 $1,292.50

09/05/2012 MJO Draft/exchange emails with client T. Cosentino, re: discovery

questions

0.30 $82.50

09/05/2012 MJO Phone call with client, re: answers to defendants first set of

interrogatories

0.80 $220.00

09/05/2012 MJO Draft Declaration of Interest on behalf of Plaintiff 1.80 $495.00

09/05/2012 MJO Draft/revise First Set of Interrogatories Directed to Defendant 2.50 $687.50

09/05/2012 MJO Review Responses and Objections to Defendants First Set of

Interrogatories Directed to Pence, Responses and Objections

to Request for Production

0.70 $192.50

09/06/2012 KJD Review letter from OC call with Russ on compliance, review

with Kristen on the response; call with OC RE: reset hearing to

2.50 $1,125.00
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next week, conference with court, call with Opposing Counsel

to re-set attempt to get heard by phone; review discovery

status hearing position with Russ on how to proceed; call with

OC RE: call on discovery responses; call with St. George and

other who care not for discovery with discovery responses

trying to round them up; call with OC RE: discovery status

email with OC RE: responses to current information.

09/06/2012 MJO Draft Responses to Defendants' First Set of Interrogatories for

client Armstrong

2.40 $660.00

09/06/2012 MJO Phone call with client Tolles re: responses and objections to

Interrogatories

0.80 $220.00

09/06/2012 MJO Draft email to Tolles, re: checklist of documents 0.30 $82.50

09/06/2012 MJO Draft Responses to Defendants First Set of Interrogatories for

Armstrong

1.30 $357.50

09/06/2012 MJO Draft email to Cosentino, re: responses to discovery requests 0.20 $55.00

09/06/2012 MJO Draft Responses and Objections to First Set of Interrogatories,

re: Tolles

1.20 $330.00

09/06/2012 MJO Draft sample email to Plaintiffs Burgbacher and St. Georges 0.10 $27.50

09/06/2012 MJO Draft correspondence to opposing counsel, re: plaintiffs

objections and to interrogatories and documents

1.60 $440.00

09/07/2012 KJD Review discovery status responses with local counsel review

letter to Opposing Counsel; draft email on plan to present to

court RE: discovery;

1.25 $562.50

09/07/2012 MJO Review emails sent from client T. Cosentino and compile them

for use as Response to Defendant's Request for Production of

Documents

0.70 $192.50

09/07/2012 MJO Draft Declaration of Interest for Tolles 1.20 $330.00

09/07/2012 MJO Analyzed and examined numerous emails to be used in Tolles'

responses to requests for production

0.50 $137.50

09/07/2012 MJO Draft Response and Objections to Defendants' First Set of

Production Directed to Tolles

0.30 $82.50

09/07/2012 MJO Phone call and email with client T. Cosentino, re: documents

produced

0.20 $55.00

09/07/2012 MJO Draft sample email to Nolan for review of attorney K. Dolley 0.20 $55.00

09/07/2012 MJO Draft email to plaintiff T. Cosentino, re: ADP log-in info 0.10 $27.50

09/07/2012 MJO Draft/review letter to opposing counsel, re: discovery 0.10 $27.50

09/10/2012 MJO Telephone call with opt-in Plaintiff Ratliff, re: subpoena

documents requested and declaration of interest

0.60 $165.00

09/10/2012 MJO Telephone call with opt-in Plaintiff Isham, re: subpoena

documents requested and declaration of interest

0.40 $110.00

09/10/2012 MJO Draft email to co-counsel, re: objections to RFP 0.10 $27.50

09/10/2012 MJO Left plaintiff Perryman a voicemail re: subpoena 0.10 $27.50

09/10/2012 MJO Left opt-in Plaintiff McLemore voicemail re: subpoena 0.10 $27.50

09/10/2012 MJO Phone call with Plaintiff Haworth, re: subpoena documents

requested

0.50 $137.50

09/10/2012 MJO Phone call with Plaintiff Haworth, re: subpoena documents

requested

0.50 $137.50

09/10/2012 MJO Phone call with Plaintiff Fallon, re: third party subpoena

documents requested

0.40 $110.00

09/10/2012 MJO Phone call and email to co-counsel, re: discovery responses 0.40 $110.00

09/10/2012 MJO Prepared file for attorney K. Dolley for purposes of Chicago

trip

0.30 $82.50

09/10/2012 MJO Phone call and email to client Sheila Reeser, re: subpoena

documents requested

0.20 $55.00

09/10/2012 MJO Draft responses and objections to defendant's request for

production directed to opt-in Plaintiff Karen Milan

2.80 $770.00

09/10/2012 MJO Draft email to Plaintiff Lisa Smith, re: subpoena 0.10 $27.50

09/10/2012 MJO Draft responses and objections to defendant's request for

production directed to opt-in Plaintiff Lisa Smith

1.50 $412.50

09/11/2012 MJO Draft email to clients for review of Attorney K. Dolley 0.40 $110.00
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09/11/2012 MJO Draft email to clients for review of Attorney K. Dolley 0.40 $110.00

09/11/2012 MJO Draft responses and objections to interrogatories for Plaintiff

T. Cosentino

0.90 $247.50

09/11/2012 MJO Draft emails to clients, re: third party subpoenas 0.20 $55.00

09/11/2012 MJO Phone call and email to Mary Hall, re: subpoena 0.10 $27.50

09/11/2012 MJO Phone call and email to Margaret Thorpe, re: subpoena 0.10 $27.50

09/11/2012 MJO Draft email to co-counsel, re: objections to RFP 0.30 $82.50

09/11/2012 MJO Phone call with Plaintiff Joy Bargerstock, re: verification page

and signature page

0.40 $110.00

09/11/2012 MJO Phone call with Plaintiff Shara Martin, re: subpoena

documents requested

0.80 $220.00

09/11/2012 MJO Draft/edit responses and objections to Defendant's First Set of

RFP and Interrogatories Directed to Plaintiff Pence

0.80 $220.00

09/11/2012 MJO Draft/edit responses and objections to Defendant's First RFP

and Interrogatories Directed to Plaintiff Cosentino

1.80 $495.00

09/11/2012 KJD Travel to hearing. 3.00 $1,350.00

09/11/2012 KJD Travel from court. 3.00 $1,350.00

09/11/2012 KJD Prepare for hearing on joint motion to extend conditions. 1.00 $450.00

09/12/2012 MJO Phone call with co-counsel, re: verification pages to Plaintiff's

responses and objections to Defendant's discovery requests

0.10 $27.50

09/12/2012 MJO Draft responses and objections to defendant's subpoenas

directed to opt-in Plaintiff Milan

0.40 $110.00

09/12/2012 MJO Draft responses and objections to defendant's subpoenas

directed to opt-in Plaintiff Smith

0.40 $110.00

09/12/2012 MJO Phone call with opt-in Plaintiff Isham, re: subpoena

documents requested

0.10 $27.50

09/12/2012 MJO Draft responses and objections to subpoenas directed to optin plaintiff Isham; review emails sent by client0.30 $82.50

09/12/2012 MJO Phone call with Plaintiff Edwards, re: interrogatories 0.10 $27.50

09/12/2012 MJO Draft responses and objections to defendant's subpoena

directed to Plaintiff Smith

0.30 $82.50

09/12/2012 MJO Draft email to Plaintiff Hall, re: subpoena and call scheduling 0.20 $55.00

09/12/2012 MJO Draft Responses and Objections to Defendants subpoenas

directed to opt-in plaintiff martin and howard

1.50 $412.50

09/12/2012 MJO Phone call with Plaintiff Thorpe, re: subpoena documents

requested

0.20 $55.00

09/12/2012 MJO Phone call with Deborah Waldman, re: first set of RFPs 0.20 $55.00

09/12/2012 MJO Draft responses and objections to Defendant's First set of RFP,

re: Deb Waldman

0.60 $165.00

09/13/2012 MJO Draft objections to third party subpoenas for each plaintiff 1.30 $357.50

09/13/2012 MJO Draft objections and responses to defendant's third party

subpoenas directed to Isham

0.70 $192.50

09/13/2012 MJO Draft plaintiff Waldman's responses and objections to RFP 0.90 $247.50

09/13/2012 MJO Draft/revise co-counsel's drafts of responses and objections to

Defendant's First Set of RFPs and Interrogatories

1.10 $302.50

09/13/2012 MJO Draft/revise co-counsel's drafts of responses and objections to

Defendant's First Set of RFPs and Interrogatories

2.90 $797.50

09/13/2012 MJO Meeting with Attorney K. Dolley, re: depositions and travel

time

0.50 $137.50

09/13/2012 MJO Final edits to objections and responses to defendant's first set

of interrogatories and requests for production directed to

clients

3.30 $907.50

09/13/2012 MAK Discussion with KJD and MJO regarding the strategy and

process for traveling to defend each plaintiff in the transcend

litigation.

0.50 $112.50

09/14/2012 KJD Draft and edit letter on discovery responses to OC; Call with

Russ RE: Discovery Responses; Review entire discovery

responses.

3.25 $1,462.50
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09/17/2012 MAK Conference with attorney Russ Riggan and Sam Moore about

the strategy of scheduling the travel for defending

depositions; conferred with clients Judith Lugo and Deborah

Waldman regarding their depositions upcoming; processed

defendant's notice of deposition for Judith Lugo and Deborah

Waldman and emailed them to Judith Lugo and Deborah

Waldman; conferred with clients through telephone to answer

questions pertaining to their deposition.

2.25 $506.25

09/18/2012 MAK Read the book " Making and meeting objections II" to prepare

for defending the depositions of Judith Lugo and Deborah

Waldman.

2.00 $450.00

09/18/2012 MAK Conferred with opposing counsel Greg Mersol regarding the

rescheduling of the deposition of Dawn Pence; phone

conference with attorneys KJD and MJO concerning the

deposition strategy of Plaintiffs.

1.25 $281.25

09/19/2012 MJO Phone call with Judith Lugo, re: preparation for deposition 0.60 $165.00

09/19/2012 MJO Draft deposition preparation template, re: key areas of

information covered in deposition

0.50 $137.50

09/19/2012 MJO Draft Supplementary Responses and Objections to

Interrogatories and RFP for Plaintiff Dawn Pence

2.70 $742.50

09/19/2012 MJO Phone call with Plaintiff Linda Matthias, re: deposition

preparation

1.20 $330.00

09/19/2012 MJO Phone call with Plaintiff Patricia Clunk, re: deposition

preparation

1.10 $302.50

09/19/2012 MJO Draft email to opt-in Plaintiff Lisa Smith, re: conditional

certification

0.20 $55.00

09/19/2012 KJD Research off the clock conditional cert class. 1.50 $675.00

09/19/2012 MAK Conferred with Esquire Reporting Services through telephone

to inquire as to their policy for a 24-hour turnaround time for

transcript; conferred with attorneys KJD and MJO about

strategy in defending depositions; emailed Judy Lugo and

Deborah Waldman concerning when i will arrive in Florida and

when and where i will meet with them.

1.00 $225.00

09/20/2012 MJO Phone call with Linda Mathias, re: emails to produce for

supplemental discovery

0.20 $55.00

09/20/2012 MJO Draft email to Plaintiff Linda Mathias, re: supplemental

discovery

0.10 $27.50

09/20/2012 MJO Draft Supplementary Responses and Objections to Defendant's

First Set of RFP Directed to Lisa Smith; added, produced, and

consulted numerous additional emails

1.60 $440.00

09/20/2012 MJO Draft and edit Declaration of Interest for Lisa Edwards and

emailed to her for her verification

1.80 $495.00

09/20/2012 MJO Drafted Declaration of Interest for Plaintiff Karen Milan and

emailed to her for verification

2.20 $605.00

09/20/2012 MJO Draft and edit Supplementary Responses and Objections to

Interrogatories and RFP for Plaintiff Dawn Pence

1.40 $385.00

09/21/2012 MJO Final edit to Declaration of Interest for opt-in Plaintiff Karen

Milan

0.50 $137.50

09/21/2012 MJO Final edit to Declaration of Interest for opt-in Plaintiff Karen

Milan

0.50 $137.50

09/21/2012 MJO Annotated documents in preparation for prepping Plaintiff

Waldman for her deposition

2.10 $577.50

09/21/2012 MJO Draft/edit co-counsel's draft of a Declaration of Interest for

Plaintiff Waldman

0.50 $137.50

09/21/2012 MJO Draft supplementary discovery responses and objections, re:

Plaintiff Lisa Smith

0.90 $247.50

09/21/2012 MJO Draft email to Deborah Waldman, re: TAT or OTAT

terminology

0.10 $27.50

09/21/2012 MJO Draft email to Teresa Cosentino, re: MKM Time 0.20 $55.00

09/21/2012 MJO Draft email to opposing counsel, re: Lisa Edwards verification

page

0.20 $55.00
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09/21/2012 MJO Draft email to opposing counsel, re: Lisa Edwards verification

page

0.20 $55.00

09/21/2012 MJO Phone call with co-counsel, re: deposition of Judy Lugo and

Deborah Waldman

0.50 $137.50

09/23/2012 MAK Traveled to Florida to defend the depositions of Judith Lugo

and Deborah Waldman; Conferred with Judith Lugo in person

and prepared her for her deposition; defended Juith Lugo's

deposition; conferred with Deborah Waldman in person and

prepared her for her deposition

11.00 $2,475.00

09/24/2012 MJO Draft extensive notes while sitting in via conference during

deposition of Judith Lugo

6.40 $1,760.00

09/24/2012 MJO Drafted extensive updated deposition outline for co-counsel 2.00 $550.00

09/25/2012 MJO Draft calendar/schedule for depositions, reviewed most

current notices of deposition to draft calendar

1.20 $330.00

09/25/2012 MJO Draft calendar/schedule for depositions, reviewed most

current notices of deposition to draft calendar

1.20 $330.00

09/25/2012 MJO Phone conference with co-counsel, re: deposition strategy

and deposition schedule

0.70 $192.50

09/25/2012 MJO Draft opt-out documents for Mary Kleppin 0.20 $55.00

09/25/2012 KJD Review schedule call to OC depos set. 0.25 $112.50

09/25/2012 MAK Conferred with Deborah Waldman in person and prepared her

for her deposition.

3.00 $675.00

09/25/2012 MAK Defended Debra Waldman's Deposition. 7.00 $1,575.00

09/26/2012 MJO Draft memorandum re: deposition availability of remaining

Plaintiffs for Attorney K. Dolley and updated calendar to

reflect this

2.60 $715.00

09/26/2012 MJO Emailed and called Plaintiff Clunk re: depo availability 0.20 $55.00

09/26/2012 MJO Emailed and called Plaintiff Milan re: depo availability 0.20 $55.00

09/27/2012 MJO Draft email to Plaintiff Clunk, re: deposition schedule 0.10 $27.50

09/27/2012 MJO Draft email to Plaintiff Clunk, re: deposition schedule 0.10 $27.50

09/27/2012 MJO Draft detailed email to opposing counsel for review of

Attorney K. Dolley, re: deposition dates scheduled for TN and

MA

0.80 $220.00

09/27/2012 MJO Draft email to co-counsel, re: pro hac vice entries 0.20 $55.00

09/27/2012 MJO Draft/edit Declaration of Interest for Karen Milan 0.30 $82.50

09/27/2012 MJO Draft/edit Declaration of Interest for Theresa Cosentino 0.50 $137.50

09/27/2012 MJO Draft/edit Declaration of Interest questionnaire for remaining

opt-in Plaintiffs to fill out and submit

0.80 $220.00

09/27/2012 MJO Draft email to opt-in Plaintiffs, re: information for completion

of Declaration of Interest

0.40 $110.00

09/27/2012 MJO Research case law, re: motion for conditional certification in

off the clock case in the Northern District of Illinois

2.40 $660.00

09/27/2012 MJO Research case law, re: motion for conditional certification in

off the clock case in the Northern District of Illinois

2.40 $660.00

09/27/2012 MJO Draft Declaration of Interest for plaintiff Howard; consulted

the questionnaire she submitted

2.70 $742.50

09/27/2012 KJD Draft and send email to OC depo scheduled. 0.10 $45.00

09/28/2012 MJO Phone call with Plaintiff Edwards, re: time entry, deposition

questions from other plaintiffs

0.20 $55.00

09/28/2012 MJO Phone call with co-counsel, re: deposition strategy 0.80 $220.00

09/28/2012 MJO Draft email to Plaintiff Lisa Edwards, re: timekeeping concerns 0.20 $55.00

09/28/2012 MJO Draft/send emails to co-counsel, re: evidence of employers'

willful violation of the FLSA

0.70 $192.50

09/28/2012 MJO Review/read and partially complete annotating the deposition

of Plaintiff Judith Lugo. Highlighted text in pdf form in the

transcript and added notes to the margins regarding the

deposition strategy.

3.50 $962.50

09/28/2012 MAK Emailed Debra Tolles information about her upcoming

deposition.

0.25 $56.25

09/29/2012 MJO Draft email to Nancy Haupt, re: update on case 0.10 $27.50
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09/30/2012 MJO Draft list of questions for supervisors to answer in preparation

for Team Lead Declarations of Interest

0.90 $247.50

09/30/2012 MJO Finalized annotation of Judith Lugo's deposition transcript;

highlighted text in pdf form in the transcript and added notes

to the margins regarding our deposition strategy for

answering the following topics of questions

3.20 $880.00

10/01/2012 MJO Draft email to co-counsel, re: pro hac vice entry 0.10 $27.50

10/01/2012 MJO Finalized questions for team leads for affidavits in support of

plaintiff's motion for conditional certification

0.50 $137.50

10/01/2012 MJO Drafted Motion to Conditionally Certify class 0.80 $220.00

10/01/2012 MJO Began drafting Plaintiffs' Memorandum in Support of Motion

for Conditional Certification, preliminary statement and factual

background

4.60 $1,265.00

10/01/2012 MAK Traveled from St. Louis by plane to Detroit, MI and drove

from Detroit to Toledo.

6.50 $1,462.50

10/01/2012 MAK Examined and anaylzed Responses and Objections to

Defendant's first set of interrogatories directed to Deborah

Tolles and Plaintiff's responses and objections to Defendant's

request for production of documents directed to Deborah

Tolles and all accompying documents; conducted phone

conference with Deborah Tolles to prepare her for her

deposition.

2.00 $450.00

10/02/2012 MJO Phone call with co-counsel, re: deposition schedule 0.10 $27.50

10/02/2012 MJO Drafted Plaintiffs' Memorandum in Support of Motion for

Conditional Certification, re: statement of relevant facts

6.30 $1,732.50

10/02/2012 MAK Met with Deborah Tolles in person to prepare her for her

deposition.

2.00 $450.00

10/02/2012 MAK Defended Debra Tolles Deposition. 4.00 $900.00

10/03/2012 MJO Drafted Plaintiffs' Memorandum in Support of Motion for

Conditional Certification, re: statement of relevant facts

5.50 $1,512.50

10/03/2012 MJO Drafted Plaintiffs' Memorandum in Support of Motion for

Conditional Certification, re: statement of relevant facts

6.80 $1,870.00

10/03/2012 MAK Travel from Toledo, Ohio to Detroit, Michigan. Travel from

Detroit, Michigan to St. Louis, MO.

5.00 $1,125.00

10/04/2012 MJO Drafted Plaintiffs' Memorandum in Support of Motion for

Conditional Certification, re: statement of relevant facts

6.80 $1,870.00

10/05/2012 MJO Drafted Plaintiffs' Memorandum in Support of Motion for

Conditional Certification, re: statement of relevant facts

5.60 $1,540.00

10/05/2012 MJO Draft email to opposing counsel, re: deposition cancellation 0.20 $55.00

10/05/2012 MAK Conferred with Dawn Pence via telephone about deposition;

emailed jacquiline Ratliff and Pat Clunk information about

their deposition; printed and prepared copies of the Complaint

and Notices of Deposition for depositions.

1.75 $393.75

10/06/2012 MJO Draft email to co-counsel, re: amended notice of deposition 0.30 $82.50

10/06/2012 MJO Phone call with client Patricia Clunk, re: deposition

verification

0.20 $55.00

10/06/2012 MJO Phone call with client, re: deposition location change 0.90 $247.50

10/08/2012 MAK Spoke with Attorney Mark Obermeyer over the phone

regarding Dawn Pence Depo; informed attorney MJO about

questions opposing counsel asked about strategies for

preparing clients for depo and cond. certification.

1.25 $281.25

10/08/2012 MJO Meeting with Attorney C. McCullough, re: drafting legal

section of Memorandum in Support of Conditional

Certification

0.30 $82.50

10/08/2012 MJO Draft emails to Steven Martin, Shara Howard, Lisa Smith, and

Karen Milan, re: notices of deposition

0.40 $110.00

10/08/2012 MJO Revised affidavits for two plaintiffs, email to co-counsel 0.80 $220.00

10/08/2012 MJO Drafted and edited Declaration of Interest-Howard 2.40 $660.00

10/08/2012 MJO Drafted and edited Declaration of Interest-Lisa Smith 2.20 $605.00

10/08/2012 MJO Research, begin drafting legal section of Memorandum of Law 3.30 $907.50
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10/08/2012 MAK

in Support of Motion for Conditional Certification

Defended the deposition of Dawn Pence. 6.50 $1,462.50

10/08/2012 MAK Defended the deposition of Dawn Pence. 6.50 $1,462.50

10/09/2012 MJO Review, edit, draft Affidavits for submission in support of

Motion for Conditional Certification

4.00 $1,100.00

10/09/2012 MJO Draft email to client Patricia Clunk, re: deposition location 0.30 $82.50

10/09/2012 MJO Phone call with Plaintiff Armstrong, re: deposition and

additional documents

0.70 $192.50

10/09/2012 MJO Drafted Declaration of Interest for former Transcend team

leader Stacey Kirsh

2.80 $770.00

10/09/2012 MJO Phone conference with Attorneys K. Dolley and opposing

counsel, re: depo scheduling

0.20 $55.00

10/09/2012 MJO Drafted/revised and edited preliminary statement and

statement of relevant facts for Memorandum of Law in

Support of Motion for Conditional Certification

1.10 $302.50

10/09/2012 MAK Travel from Rapid City, South Dakota to St. Louis, MO 8.00 $1,800.00

10/10/2012 MAK Prepared and processed documents and information to travel

to Norfolk, VA; Printed and prepared documents for

preparation of Pat Clunks deposition.

0.75 $168.75

10/10/2012 MJO Revised Declaration of Interest for Plaintiff Linda Armstrong 0.70 $192.50

10/10/2012 MJO Revised Declaration of Interest for Plaintiff Joy Bargerstock 0.60 $165.00

10/10/2012 MJO Revised Declaration of Interest for Plaintiff Pat Clunk 0.70 $192.50

10/10/2012 MJO Draft/revise Declaration of Interest for Plaintiff Cosentino 0.80 $220.00

10/10/2012 MJO Draft/revise Declaration of Interest for Plaintiff Edwards 0.80 $220.00

10/10/2012 MJO Draft/revise Memorandum of Law in Support of Motion for

Conditional Certification, re: factual background

1.80 $495.00

10/10/2012 MJO Draft/revise Declaration of Interest for Plaintiff Howard 0.60 $165.00

10/10/2012 KJD Draft depo- remade OC RE: gulley depo 0.50 $225.00

10/11/2012 MJO Drafted declaration of interest for team leader Kirsh, added

various different sections to declaration

3.20 $880.00

10/11/2012 MJO Phone call with co-counsel, re: preparation for deposition

defense

0.50 $137.50

10/11/2012 MJO Draft/revise Declaration of Interest for representative Plaintiff

Mathias

0.70 $192.50

10/11/2012 MJO Revised Declaration of Interest for Judith Lugo 0.50 $137.50

10/11/2012 MJO Revised Declaration of Interest for Steven Martin 0.70 $192.50

10/11/2012 MJO Revised Declaration of Interest for Karen Milan 0.60 $165.00

10/11/2012 MJO Revised Declaration of Interest for Dawn Pence 0.80 $220.00

10/11/2012 MJO Revised Declaration of Interest for Lisa Smith 0.40 $110.00

10/11/2012 MJO Revised Declaration of Interest for Debra Tolles 0.40 $110.00

10/11/2012 MAK Traveled from St. Louis, MO to Baltimore, MAryland then from

Baltimore to Norfolk, Virginia.

9.00 $2,025.00

10/11/2012 MAK Conferred with Pat Clunk via telephone to prepare her for her

deposition scheduled for October 12,2012; examined and

anaylzed responses and objections to defendant's first set of

interrogatories directed to Pat Clunk and document

production directed to Pat Clunk.

2.50 $562.50

10/12/2012 MJO Revised/drafted Declaration of Interest for Plaintiff Waldman 2.80 $770.00

10/12/2012 MJO Draft email to co-counsel, re: discovery 0.10 $27.50

10/12/2012 MJO Phone call with Plaintiff Mathias, re: deposition 0.40 $110.00

10/12/2012 MJO Draft and revise Memorandum of Law in Support of Motion for

Conditional Certification

1.80 $495.00

10/12/2012 MAK Traveled to Norfolk, VA to defend the deposition of Pat Clunk. 10.00 $2,250.00

10/13/2012 MJO Draft Notice of Deposition for Cindy Gulley 0.70 $192.50

10/13/2012 MJO Draft email to opposing counsel, re: deposition of Cindy

Gulley

0.20 $55.00

10/13/2012 MJO Began preparing deposition outline for Cindy Gulley 0.60 $165.00

10/13/2012 MAK Traveled from Norfolk, VA to Baltimore, Maryland to St. Louis,

MO after defending deposition of Pat Clunk.

7.00 $1,575.00
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10/14/2012 MJO Draft email to opt-in Steven Martin and Shara Howard, re:

forwarding emails

0.10 $27.50

10/14/2012 MJO Draft email to Plaintiff Lisa Smith, re: deposition 0.10 $27.50

10/14/2012 MJO Draft email to Plaintiffs Deb Tolles and Joy Bargerstock, re:

supplementary documents

0.20 $55.00

10/14/2012 MJO Third Party Supplementary Responses and Objections to

Defendants Third Party Subpoena

1.70 $467.50

10/15/2012 MAK Downloaded and printed over 450 documents in preparation

for depositions; organized over 450 documents in preparation

for depositions including copies of the complaint, Answer,

notices of Depos, and documents produced through

discovery.

3.00 $675.00

10/15/2012 MJO Phone call with Lisa Smith, re: deposition 0.50 $137.50

10/15/2012 MJO Draft third set of responses and objections to Defendants third

party subpoena for documents directed to opt-in plaintiff

smith; analyzed and examined approximately 100 documents

1.50 $412.50

10/15/2012 MJO Analyzed and examined approximately 300 supplementary

documents for T. Cosentino

1.10 $302.50

10/15/2012 MJO Draft supplementary responses and objections to defendants

first set of interrogatories and requests for production directed

to Tolles

0.70 $192.50

10/15/2012 MJO Draft proposed notice to class of medical language specialists 0.80 $220.00

10/15/2012 MJO Draft, edit, and revise Memorandum of Law in Support of

Motion for Conditional Certification, re: medical language

specialists are similarly situated

0.70 $192.50

10/15/2012 MJO Proofread and re-organized Memorandum of Law in Support

of Motion for Conditional Certification

5.00 $1,375.00

10/16/2012 MAK Traveled from St.Louis to Baltimore, Maryland to Manchester

Virginia; conferred with Lisa Smith via telephone to prepare

her for her deposition scheduled 10/17; conferred with Karen

Milan via telephone for her deposition scheduled 10/17;

examined and analyzed discovery documents in preparation

for drafting golden rule letter.

11.25 $2,531.25

10/16/2012 MJO Review Petition to prepare deposition outline for Cindy Gulley 0.50 $137.50

10/16/2012 MJO Draft deposition outline for Cindy Gulley, re: Introduction,

Corporate Structure of Transcend, MLS position, and July 11

email

7.00 $1,925.00

10/16/2012 MJO Draft/revise/edit content of letter to opposing counsel, re:

deficiencies in document production

0.30 $82.50

10/16/2012 MJO Draft Memorandum of Law in Support of Plaintiff's Motion for

Conditional Certification

6.40 $1,760.00

10/16/2012 MJO Draft supplemental responses and objections to third party

subpoenas directed to steven martin and shara howard sent to

opposing counsel

1.20 $330.00

10/16/2012 MJO Phone call with T. Cosentino, re: declaration of interest and

supplemental document production

0.50 $137.50

10/16/2012 MJO Edit and revise response letter to opposing counsel, re:

alleged discovery deficiencies

0.20 $55.00

10/16/2012 MJO Email to Dawn Pence, re: supplemental document production 0.10 $27.50

10/16/2012 KJD Call with OC, review, correspondence, discovery deficiencies. 0.50 $225.00

10/17/2012 MJO Draft response letter to opposing counsel request that we

produce deposition preparation documents

0.20 $55.00

10/17/2012 MJO Edit content of letter to opposing counsel in response to

discovery dispute

0.40 $110.00

10/17/2012 MJO Draft deposition outline for Cindy Gulley, re: the July 11 email

and miscellaneous sections of Transcend Corporate Structure

and Gulley's role at Transcend as a decision-maker

5.00 $1,375.00

10/17/2012 MJO Prepared exhibits for Gulley deposition 0.30 $82.50

10/17/2012 MJO Read and reviewed deposition transcript for Plaintiff

Bargerstock to cross-reference for accuracy with her

Declaration of Interest

1.80 $495.00
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10/17/2012 MJO Drafted Memorandum of Law in Support of Motion for

Conditional Certification

5.30 $1,457.50

10/17/2012 MJO Drafted email for review of attorney K. Dolley, re: 4 pages of

documents supplements

0.30 $82.50

10/17/2012 KJD Call and emails with Ellerson - Prep Deposition of Gulley. 5.00 $2,250.00

10/18/2012 MAK Traveled from New Hampshire to Baltimore for Baltimore to

Alabama. Then traveled from Birmingham to athens, alabama;

examined and analyzed documents produced by steve martin

and Shara Howard in preparation for defending their

depositions; conferred with Shara via telephone to prepare her

for her deposition scheduled for 10/19; Conferred with Steve

Martin via telephone to prepare him for his deposition

scheduled for 10/19.

13.25 $2,981.25

10/18/2012 MJO Prepared supplemental documents for opt-in Plaintiff Shara

Howard

1.20 $330.00

10/18/2012 MJO Prepared supplemental documents and pleadings for plaintiff

J. Bargerstock

0.30 $82.50

10/18/2012 MJO Draft Memorandum of Law in Support of Motion for

Conditional Certification, re: quotas, timekeeping, uniform

policy, hands on keyboard

7.80 $2,145.00

10/18/2012 MJO Edit/draft deposition outline for Cindy Gulley 1.80 $495.00

10/18/2012 KJD Depo prep - Gulley. 3.00 $1,350.00

10/18/2012 KJD Call with Russ, dicovery, status, gulley depo prep. 0.25 $112.50

10/19/2012 MAK Defended Depositions of Steve Martin and Shara Howard. 7.50 $1,687.50

10/19/2012 MJO Travel time to and from Kansas City, MO for deposition of

Cindy Gulley; attend deposition of Cindy Gulley

11.00 $3,025.00

10/19/2012 MJO Prepare table of cases and statutes for draft Motion for

Conditional Certification

0.50 $137.50

10/19/2012 MJO Completed first draft of Memorandum of Law in Support of

Motion for Conditional Certification; completed sections

discussing how Plaintiff similarly situated and fulfills the first

step of the analysis

5.80 $1,595.00

10/19/2012 MJO Prepared supplemental documents for Plaintiff Mathias 0.40 $110.00

10/19/2012 MJO Prepare supplemental documents for opt-in plaintiff Lisa Smith 0.60 $165.00

10/19/2012 MJO Prepare supplemental documents for T. Cosentino 2.00 $550.00

10/19/2012 KJD Gulley Depo Prep - Deposition 4.00 $1,800.00

10/20/2012 MAK Traveled from Athens,, Alabama to Birmingham, AL to St.

Louis, MO.

7.00 $1,575.00

10/22/2012 MAK Began drafting Golden Rule letter. 4.50 $1,012.50

10/22/2012 MJO Research case law in all federal circuits, re: compensable work

time, and draft section to add legal analysis synthesizing case

law from various districts

4.60 $1,265.00

10/23/2012 MAK Prepared final draft of Golden Rule letter; Revised and edit

Golden Rule letter.

4.75 $1,068.75

10/23/2012 MJO Research case law in northern district of Illinois re: conditional

certification in FLSA cases and overtime in piece rate wage

cases

0.90 $247.50

10/23/2012 MJO Revised content and organization of letter to opposing

counsel, re: deficiencies in Defendant's interrogatory

responses

1.90 $522.50

10/23/2012 KJD Review and edit entire letter to OC RE: deficient

interrogatories.

0.50 $225.00

10/23/2012 KJD Call with Fore, and Sarah on status and witness list. 0.25 $112.50

10/24/2012 MJO Research FLSA cases involving medical transcriptionists across

all federal circuits

0.90 $247.50

10/24/2012 MJO Draft/revise Memorandum of law in support of motion for

conditional certification to reflect changes Russ

recommended; added sections to memorandum of law in

support of motion for conditional certification

6.20 $1,705.00

10/24/2012 MJO Edit and revise motion for conditional certification to reflect 0.80 $220.00
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10/26/2012 MAK

changes co-counsel R. Riggan recommended

Drafted first draft of Plaintiff's Motion to Compel against 1.50 $337.50

Defendant.

10/26/2012 MJO Revise Memorandum of Law in Support of Motion for

Conditional Certification, re: sections on MLS job title and

duties, defendants corporate structure, defendant's

production quotas, defendant's uniform timekeeping policy

6.30 $1,732.50

10/27/2012 MJO Review, analyze, and examine approximately 500 pages of

supplemental documents for Plaintiff Mathias

3.20 $880.00

10/27/2012 KJD Reviewed letter from response for ellerson discovery request

and email to co-counsel.

0.50 $225.00

10/28/2012 MJO Review, analyze, and examine approximately 30 pages of

supplemental documents for Plaintiffs Howard and Martin

0.70 $192.50

10/28/2012 MJO Draft/revise Memorandum of Law in Support of Motion for

Conditional Certification, re: reflect suggested/recommended

changes from attorney K. Dolley; provided headings to

sections throughout statement of relevant facts

6.80 $1,870.00

10/29/2012 MJO Draft Motion for Leave to Exceed Page Limitations for

Memorandum of Law in Support of Motion for Conditional

Certification

0.50 $137.50

10/29/2012 MJO Draft/revise/edit Memorandum of Law in Support of Motion

for Conditional Certification, re: edit all sections throughout

document; cite check Exhibits 1-59

9.40 $2,585.00

10/29/2012 MJO Review/revise Motion for Leave to Exceed Page Limitations re:

Memorandum in Support of Motion for Conditional

Certification

0.50 $137.50

10/30/2012 MJO Review proposed notice and court opinion from Espenscheid

in order to revise and edit our proposed Notice

1.00 $275.00

10/30/2012 MJO Revised and edited proposed notice- reorganized the order of

existing content, changed/added section headers; added

content to sections on purpose of Notice, Description of

Lawsuit, How and When to Join this Suit

2.10 $577.50

10/30/2012 MJO Draft/revise motion for conditional certification in line with

attorney K. Dolley's suggestion re: class definition and

common policy

0.80 $220.00

10/30/2012 MJO Draft/revise Memorandum of Law in Support of Motion for

Conditional Certification, re: definition of MLS class; add facts

and citations to sections

5.80 $1,595.00

10/30/2012 MJO Draft Proposed Order for J. Guzman, re: conditional

certification

0.40 $110.00

10/30/2012 MJO Draft/revise notice to class and revised notice section of

memorandum of law to reflect changes and adherence to

approved form of notice

2.40 $660.00

10/30/2012 KLH Final proofread of fifteen Declarations to be used as exhibits

for plaintiffs motion for conditional certification added exhibit

stickers and converted declarations into PDFs.

3.00 $675.00

10/30/2012 KJD Review exhibits, declarations from clients; review gulley

deposition pull page to incorporate in memo; review

defendants amended answers pull paragraph to incorporate in

memo; Review and edit entire notice to class; review and edit

entire memo of law;

6.00 $2,700.00

10/31/2012 MJO Revised memorandum of Law in Support of Motion for

Conditional Certification, re: provide extensive cite check to

citations and 62 exhibits referenced, checked cases cited and

each page referenced by an exhibit

3.60 $990.00

10/31/2012 MJO Draft Index for Exhibits; organized 62 exhibits; prepared

binder for exhibits

3.50 $962.50

10/31/2012 KLH Added exhibit stickers to 50 exhibits for plaintiff's motion for

conditional certification; formatted table of contents and table

of authorities in plaintiffs memo in support of motion for

conditional certification; proofread plaintiffs proposed notice

to potential class members; made edits and revisions to

5.20 $1,170.00
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electronic version; proofread plaintiffs proposed notice to

potential class members; made edits and revisions to

electronic version.

11/01/2012 MJO Final revision to Motion for Conditional Certification

Memorandum of Law, re: revised and added list of ways

plaintiffs are similarly situated, revised notice to be issued by

Plaintiffs, double check citations cross-referenced binder of

exhibits with citations; drafted notice of motion to exceed

N.D. Ill. page limitations for memorandum

7.40 $2,035.00

11/01/2012 MJO Final revision to Motion for Conditional Certification

Memorandum of Law, re: revised and added list of ways

plaintiffs are similarly situated, revised notice to be issued by

Plaintiffs, double check citations cross-referenced binder of

exhibits with citations; drafted notice of motion to exceed

N.D. Ill. page limitations for memorandum

7.40 $2,035.00

11/01/2012 KLH Proofread our proposed notice. 0.30 $67.50

11/01/2012 KJD Review and edit entire memo of law and notice. 3.50 $1,575.00

11/02/2012 MJO Electronically filed motion for conditional certification

memorandum of law in support of motion for conditional

certification, notice of filing motion to exceed page limit;

emailed proposed order to J. Guzman; made minor changes in

proposed class notice spoke with co-counsel on phone

regarding changes; drafted email to opposing counsel, re:

changes to Ex. 60

4.00 $1,100.00

11/02/2012 MJO Printed and stapled all 62 exhibits accompanying

memorandum of law in support of motion for conditional

certification

1.30 $357.50

11/03/2012 KJD Review and prepare documents and edit document and review

for filing; review #75 docket entry.

2.10 $945.00

11/05/2012 KJD Call with OC re: request for page extension; call regarding

classification on pdf #76; email to sciara- documents not

have to appear on motion hearing on Thursday.

0.30 $135.00

11/06/2012 MJO Prepared supplementary documents for Plaintiff Mathias for

sending to opposing counsel; drafted letter to opposing

counsel outlining supplementary documents; burned

documents to 2 sets of discs to send to opposing counsel

1.50 $412.50

11/09/2012 MJO Phone conversation with potential opt-in plaintiff who

contacted the office; emailed potential opt-in plaintiff; began

searching through discovery documents from defendant

which were produced in response to plaintiffs' first set of

request for production

3.20 $880.00

11/13/2012 MAK Began drafting Plaintiffs' Response to defendant's Motion to

Compel.

4.00 $900.00

11/13/2012 KLH Researched privilege log contents attorney client privilege

work product time drafted responses to section B of

defendants motion to compel which seeks a privilege log

researched production of ESI, metadata, sedona principles

and glossary regarding ESI; drafted response to section C of

defendants motion to compel which seeks metadata

13.00 $2,925.00

11/13/2012 KJD Review and edit response motion to compel; review motion to

strike and compel

4.00 $1,800.00

11/14/2012 MAK Assisted in final drafting of Plaintiffs' response to Defendant's

Motion to compel.

3.50 $787.50

11/14/2012 CA researched. Drafted response to motion to strike declaration 9.75 $2,193.75

11/14/2012 KLH Revised content and organization of section I (A) of our

response to defendants motion to compel; drafted factual

background section of our response to defendants motion to

compel; electronically filed our response and sixteen exhibits.

12.75 $2,868.75

11/14/2012 KJD Research- motion to strike declarations; prep resonse motion;

prepare review exhibits for response motion to compel;

3.50 $1,575.00

11/15/2012 MAK Conferred with attorneys KLH and KJD concerning strategy

and status of case.

0.75 $168.75
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11/15/2012 CA edit and organized exhibits for response to motion; 5.50 $1,237.50

11/15/2012 KJD Travel to Chicago from St. Louis. 3.00 $1,350.00

11/15/2012 KJD Prep for hearing. 2.00 $900.00

11/15/2012 KJD Travel back to St. Louis from Chicago. 3.00 $1,350.00

11/15/2012 KJD In court room hearing motion to compel; reviewed defendants

motion to strike declarations.

1.50 $675.00

11/16/2012 KJD Email co-counsel regarding motion hearing; prepare notes and

email status of hearing to co-counsel; review written discovery

responses; emails with OC; review entire motion to strike

response comment to change and add to sections.

1.70 $765.00

11/24/2012 KLH Edited and revised the content and organization of the factual

background section of plaintiffs response to defendants

motion to strike declaration.

1.50 $337.50

11/26/2012 KLH Researched rule language regarding work product doctrine

and declarations sham affidavit rule and motion for

conditional cert.

0.80 $180.00

11/26/2012 KJD Detailed review and editing of entire response to plaintiff

motion to strike declarations.

1.00 $450.00

11/27/2012 KLH Final proofread of our response to defendants motion to strike

declarations; electronically filed response and exhibits.

0.50 $112.50

11/27/2012 KJD Detailed review and edit response to motion to strike. 1.00 $450.00

11/27/2012 KJD Email with expert nicholls status will schedule detailed

meeting in December.

0.25 $112.50

11/30/2012 MAK Assisted in printing out all documents related to defendants

response to plaintiffs motion for conditional certification.

1.50 $337.50

11/30/2012 MJO Read Defendant's response to Plaintiff's Motion for conditional

certification

1.00 $275.00

11/30/2012 KLH Reviewed defendants response to plaintiffs motion for

conditional certification and exhibits in order to discuss with

KD and MO how to prepare our reply.

1.00 $225.00

11/30/2012 KJD Review with Russ how to prepare reply. 0.25 $112.50

12/01/2012 MJO Meeting with co-counsel, re: Defendant's Response to

Plaintiffs' Motion for Conditional Certification

1.50 $412.50

12/01/2012 KLH Discussed reply to defendants to plaintiffs motion for

conditional certification overarching theme and tone of reply

and response to specific arguments made by defendants.

2.50 $562.50

12/06/2012 MJO Phone call with potential opt-in 0.50 $137.50

12/06/2012 KLH Developed outline of reply; reviewed case law in order to draft

reply; begin drafting reply- overarching rule language for

conditional certification; rule language for conditional

certification; rule language explanation sections on illegal

company policy and individualized inquires.

7.50 $1,687.50

12/07/2012 KLH Continued working on reply, reviewed case law and drafted

rule language.

2.00 $450.00

12/09/2012 KLH Continued working on reply, reviewed case law and drafted

rule language.

2.50 $562.50

12/09/2012 KJD Email with Nichols status expert report reviewed. 0.25 $112.50

12/10/2012 KLH Continued working on reply, compiled exhibits from PI's

motion for conditional certification into spread sheet; drafted

application/factual sections RE: defendants common policy or

plan that violates the FLSA.

11.75 $2,643.75

12/11/2012 KJD Detailed review and edit of reply motion for conditional

certification.

2.00 $900.00

12/11/2012 MJO Draft and file notice for consent to become party plaintiff for

Darcy Wingler

0.30 $82.50

12/11/2012 MJO Review and revise reply to Defendants' Response in Opposition

to Conditional Certification, researched case law and language

regarding off the clock cases in N.D. Ill.

1.50 $412.50
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12/11/2012 KLH Continued working on reply- formatted point headings; edited

point headings and conclusion to match; inserted missing

citations; drafted introduction; proofread and edited entire

draft.

3.00 $675.00

12/12/2012 MJO Phone call with potential client Jennifer Hohman 0.50 $137.50

12/12/2012 KLH Reviewed defendants response and exhibits. Exhibits for more

evidence of a central, corporate policy that violated the FLSA;

reviewed defendants reply to defendants motion to strike

declaration inserted footnote into pls reply to motion for

conditional certification; edit content of reply to cut out 300

words in order to meet the 15 page limit.

5.30 $1,192.50

12/14/2012 KLH Reviewed co-counsel's edits to and thoughts on our reply;

telephone with co-counsel to discuss those edits; researched

caselaw where employees were instructed to alter their

timesheets or underreport hours; made co-counsel suggested

edits; revised introduction section; inserted conclusion

section; controverted case citations to footnotes.

2.80 $630.00

12/14/2012 KJD Detailed review and edit of reply in support of conditional

cert.

2.50 $1,125.00

12/17/2012 KJD Draft email to clerk - whether need to file motion for leave

reply out of time.

0.25 $112.50

12/20/2012 MJO Draft email update to clients to co-counsel for review 0.50 $137.50

12/26/2012 MJO Update transcriptionists contact sheet, put together all email

addresses for all current representative and opt-in plaintiffs

0.50 $137.50

12/26/2012 KJD Draft and send email on status of defense litigation to

Plaintiffs.

0.50 $225.00

01/02/2013 MJO Phone calls with potential clients 0.50 $137.50

01/03/2013 MJO Phone calls with potential clients 0.50 $137.50

01/10/2013 KJD Travel from St. Louis to Chicago to court; prepare for motions

hearings. Review all motions filed, create hearing preparation

outline; Hearing before Judge Rowland, re: pending motions;

Drafted status report to all Plaintiff's counsel specific to results

of the motionhearing conference; researched Brown v. West

company, sited by Judge as it related to ESI protocol; Drafted

email to Greg Mersol; Travel back from Chicago to St. Louis.

10.40 $4,680.00

02/25/2013 MJO Phone call with former team lead and MLS re: what team

leaders knew regarding when MLSs were working

0.80 $220.00

03/06/2013 MJO Draft email to plaintiff Karen Milan regarding update on status

of lawsuit

0.10 $27.50

03/06/2013 MJO Attempted calling 2 potential opt-in plaintiffs and left

voicemails

0.10 $27.50

03/20/2013 MJO Meeting re: response to email, additional state law claims in

California

0.50 $137.50

03/20/2013 MJO Drafted email to opposing counsel for review, re: time to

discuss proposed notice/consent form

0.20 $55.00

03/20/2013 MJO Drafted email to Plaintiffs, re: update on case and impact of

being granted conditional certification

0.20 $55.00

03/20/2013 MJO Email to opposing counsel, reviewed email to class members

re: conditional certification

0.70 $192.50

03/20/2013 KJD Draft and edit email to opposing counsel regarding notice and

counsel form and class list; draft detailed clients email on cont

order; draft responses email to oc regarding proposed notice

of damages.

1.00 $450.00

03/20/2013 KJD Review and analyze court order granting conditional cert. 0.50 $225.00

03/22/2013 MJO Emailed Mathias, re: removing privileged communications

from online forums

0.20 $55.00

03/22/2013 MJO Draft Notice of Filing Consent to Become Party Plaintiff for

Carol Failla

0.40 $110.00

03/22/2013 MJO Draft email to Carol Failla, re: verified receiving Plaintiff

consent form

0.10 $27.50

03/26/2013 MJO Phone call with Plaintiff Nancy Haupt, re: off-the-clock duties 0.50 $137.50
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04/01/2013 MJO Phone call with potential opt-in Plaintiff, re: gathered

information regarding her work experience, including

compensation rate and hours worked

0.70 $192.50

04/02/2013 MJO Review following materials in preparation for phone

conference with opposing counsel, 4/3/13: Plaintiff's

2.50 $687.50
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proposed Notice; Defendant's Response in Opposition to

Plaintiff's Notice; Plaintiff's Reply to Defendant's Response;

Espenscheid case; court-approved notice in Espenscheid;

Defendant's red-lined version of Plaintiff's proposed notice

04/02/2013 MJO Email co-counsel, re: telephone conference scheduled for

4/3/2013

0.20 $55.00

04/02/2013 MJO Telephone call with co-counsel, re: telephone conference

concerning notice

0.40 $110.00

04/02/2013 MJO Emailed co-counsel materials in preparation for telephone

conference concerning Plaintiffs' proposed Notice

0.20 $55.00

04/02/2013 MJO Emailed co-counsel materials in preparation for telephone

conference concerning Plaintiffs' proposed Notice

0.20 $55.00

04/03/2013 MJO Review Reply brief, Defendant's Response, and exemplar

conditional certification notice to prepare for conference call

with opposing counsel

0.50 $137.50

04/03/2013 MJO Telephone call with potential opt-in plaintiff, re: hours worked

and wages earned while employed with Transcend

0.80 $220.00

04/03/2013 MJO Telephone conference with co-counsel Russ Riggan and

opposing counsel, re: notice to class

0.70 $192.50

04/03/2013 MJO Telephone call with Russ Riggan, re: follow-up to phone

conference

0.30 $82.50

04/03/2013 MJO Draft follow-up email summarizing phone conference with

opposing counsel to K. Dolley and R. Riggan

1.80 $495.00

04/03/2013 MJO Draft email to co-counsel, re: revising ideas on Notice Section

2

0.10 $27.50

04/03/2013 MJO Telephone call with potential opt-in plaintiff, re: wages,

overtime rate, timekeeping policy implemented by Transcend

0.70 $192.50

04/04/2013 MJO Attempted calling co-counsel, re: form of Notice 0.10 $27.50

04/04/2013 MJO Phone call with R. Riggan, re: proposed Notice to class

members

0.50 $137.50

04/05/2013 MJO Draft revised Notice, re: Description of the Lawsuit section and

specific allegations

0.50 $137.50

04/05/2013 MJO Revised Section 2 of Notice, re: Description of the Lawsuit 0.10 $27.50

04/07/2013 MJO Responded to emails from co-counsel, re: proposed Notice to

class members

0.10 $27.50

04/08/2013 MJO Draft Notice memorandum for attorneys K. Dolley and R.

Riggan, re: purpose of notice; Defendant's objection to

providing class members' email addresses; Defendant's

objection to Plaintiffs' proposed description of the lawsuit;

Defendant's objections regarding how and when to join the

lawsuit

2.00 $550.00

04/08/2013 KJD Review notice dispute prepare for conference tomorrow. 1.00 $450.00

04/09/2013 KJD Research N.D. ill approved notice for FLSA class, review order

on email, descriptions in notice.

2.00 $900.00

04/10/2013 MJO Review materials in preparation for phone conference, re:

revised Notice and email from opposing counsel

0.70 $192.50

04/10/2013 MJO Phone call with co-counsel R. Riggan, re: preparation for

phone conference with opposing counsel

0.10 $27.50

04/10/2013 MJO Phone conference with co-counsel and opposing counsel, re:

notice to class members

0.50 $137.50

04/10/2013 MJO Phone call with co-counsel R. Riggan, re: review of progress

made on Notice with opposing counsel

0.30 $82.50

04/10/2013 MJO Draft email to opposing counsel, re: description of the lawsuit

section of the proposed Notice

0.30 $82.50

04/11/2013 MJO Draft Plaintiffs' Memorandum in Support of Disseminating the

proposed Notice to Class Members Through U.S. Mail and

Electronic Mail and Allowing Class Members a Period of 90

days in which they may Opt-in to Join the Lawsuit; re: set

forth Defendant's objections to disseminating Notice via US

Mail and e­mail; discussed Espenscheid rule on e-mail and US

Mail notice

1.70 $467.50
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04/11/2013 MJO Draft Plaintiffs' Memorandum in Support of Disseminating the

proposed Notice to Class Members Through U.S. Mail and

Electronic Mail and Allowing Class Members a Period of 90

Days in which they may opt-in to join the lawsuit, re:

dissemination of notice by both US Mail and email is

supported by substantial precedent and practical

considerations for notifying this particular class; an opt-in

period of 90 days is appropriate for a class of this size

1.30 $357.50

04/11/2013 MJO Draft Plaintiffs' Memorandum in Support of Disseminating the

proposed Notice to Class Members Through U.S. Mail and

Electronic Mail and Allowing Class Members a Period of 90

days in which they may opt-in to join the lawsuit; re: research

case law in all federal courts regarding email dissemination

and the role played by the class members' familiarity with

email communication

0.80 $220.00

04/11/2013 MJO Draft Plaintiffs' Memorandum in Support of Disseminating the

proposed Notice to Class Members Through US Mail and

Electronic Mail and Allowing Class Members a Period of 90

days in which they may opt-in to join the lawsuit, re: an optin period of 90 days is appropriate

0.70 $192.50

04/11/2013 MJO Draft Parties' Joint Report, re: what remains at issue between

the parties; added details as to why email notification is

particularly appropriate in this case; researched 90 day opt-in

period in all federal courts; researched correlation between

class size and 90 day opt-in period in all federal courts

2.30 $632.50

04/12/2013 MJO Draft email to opposing counsel, re: issuing joint filing to the

court in a single document

0.30 $82.50

04/12/2013 MJO Revise Joint report to reflect the notice as Exhibit A 0.10 $27.50

04/12/2013 MJO Phone call with opposing counsel, re: filing of the Joint

Report

0.20 $55.00

04/12/2013 MJO Emailed local counsel, re: courtesy copy of Joint Position

Statement

0.20 $55.00

04/15/2013 MJO Emailed local counsel, re: courtesy copy of Joint Statement to

N.D. Ill.

0.10 $27.50

04/15/2013 MJO Phone call with potential opt-in plaintiff from PA, re: work

time, compensation for overtime and time worked

0.50 $137.50

04/16/2013 MJO Emailed co-counsel, re: the content of the Court's April 16,

2013 order re: notice

0.40 $110.00

04/16/2013 KJD review order notice and email mark. 0.50 $225.00

04/17/2013 MJO Emailed co-counsel R. Riggan, re: confusion on notice issues 0.50 $137.50

04/18/2013 MJO Emailed co-counsel R. Riggan, re: confusion on notice issues 0.50 $137.50

04/18/2013 MJO Called co-counsel R. Riggan, re: class notice 0.10 $27.50

04/19/2013 MJO Draft email to co-counsel, re: notice issue 0.20 $55.00

04/19/2013 MJO Draft email to opposing counsel for Attorney K. Dolley review,

re: production of the class information

0.80 $220.00

04/24/2013 MJO Attempted calling opposing counsel, re: class list; left

voicemail

0.10 $27.50

04/25/2013 MJO Phone conference with opposing counsel, re: class list and

phone number issue

0.50 $137.50

04/25/2013 MJO Draft email to opposing counsel, re: class list 0.20 $55.00

04/25/2013 MJO Draft email to co-counsel, re: phone call with opposing

counsel and class list

0.50 $137.50

04/29/2013 MJO Emailed opposing counsel, re: class list 0.20 $55.00

04/30/2013 MJO Attempted returning phone call of potential opt-in, left

voicemail

0.10 $27.50

04/30/2013 MJO Telephone call with potential opt-in Plaintiff, re: Transcend

lawsuit

0.60 $165.00

04/30/2013 MJO Emailed opposing counsel, re: class list 0.20 $55.00

05/01/2013 MJO Emailed co-counsel, re: assistance with sending Notice out to

class members

0.20 $55.00

05/01/2013 MJO Phone call with co-counsel, re: logistics behind sending 0.50 $137.50
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05/01/2013 KJD

Notice to class members

Detailed review of class list. 0.50 $225.00

05/02/2013 MJO Final review of final Notice and Consent form; altered email

addresses for communication with Attorney K. Dolley for optin members

0.50 $137.50

05/02/2013 MJO Final review of final Notice and Consent form; altered email

addresses for communication with Attorney K. Dolley for optin members

0.50 $137.50

05/02/2013 CA create optin@dolleylaw.com email address for class 0.50 $112.50

05/03/2013 MJO Draft email to co-counsel, re: mediation and class members'

dates of employment

0.20 $55.00

05/03/2013 MJO Draft email to co-counsel R. Riggan, re: strategy for the opt-in

period and mailing notice

0.70 $192.50

05/03/2013 MJO Draft email to co-counsel R. Riggan, re: strategy for the opt-in

period and mailing notice

0.70 $192.50

05/10/2013 CA make envelopes. 2.10 $472.50

05/13/2013 CRM Assist with administrative process for sending out notice

to class members

3.70 $1,017.50

05/14/2013 CRM Assist with administrative process for sending out notice

to class members

3.50 $962.50

05/14/2013 CA make envelopes. 4.70 $1,057.50

05/16/2013 CA make envelopes. 5.30 $1,192.50

05/19/2013 CA make envelopes. 2.25 $506.25

05/20/2013 CA Deliver stamped envelopes to Riggan and stamp more

envelopes.

6.75 $1,518.75

05/20/2013 CA Envelope stamping. 2.25 $506.25

05/21/2013 MJO Draft summary of Order granting conditional certification and

Order approving class notice for dissemination to class

members

1.30 $357.50

05/21/2013 CA Deliver stamped envelopes to Riggan and stamp more

envelopes.

6.10 $1,372.50

05/22/2013 MJO Draft email to potential putative class member Gena Hopper,

re: eligibility to join lawsuit

0.20 $55.00

05/23/2013 MJO Draft Notice of Filing Consent to Become Party Plaintiff,

Attorney Entry of Appearance Form for opt-in Plaintiff Jennifer

Jo Chandler

0.40 $110.00

05/23/2013 MJO Telephone call with potential opt-in plaintiff Anna Brewer, re:

eligibility to join lawsuit, questions about lawsuit

0.50 $137.50

05/23/2013 MJO Telephone call with potential opt-in Plaintiff Stacey Myers, re:

eligibility to join lawsuit

0.40 $110.00

05/23/2013 MJO Draft email to potential opt-in plaintiff Gena Hopper, re: ability

to opt-in to lawsuit

0.30 $82.50

05/23/2013 MJO Emailed potential opt-in plaintiff Julie Wright, re: eligibility to

join lawsuit

0.20 $55.00

05/23/2013 MJO Emailed former team leader Stacey Kirsh, re: research on

lawsuit and opt-in period

0.20 $55.00

05/23/2013 MJO Draft Notice of Filing Consent to Become Party Plaintiff

Attorney Entry of Appearance Form for opt-in Plaintiff Theresa

Chubb

0.30 $82.50

05/23/2013 MJO Telephone call with potential opt-in plaintiff Anne Brinzea re:

eligibility to join lawsuit

0.30 $82.50

05/24/2013 MJO Draft Notice of Intent to Opt-in and Attorney Appearance Form

for Jo Ellen Carnes

0.30 $82.50

05/24/2013 MJO Draft Notice of Intent to Opt-in and Attorney Appearance form

for Michelle Hughes

0.30 $82.50

05/26/2013 MJO Draft template for co-counsel for purposes of handling

telephone calls from potential opt-in plaintiffs

0.60 $165.00

05/26/2013 MJO Draft reply to email from potential opt-in Plaintiff Julie Wright,

answered numerous questions involving lawsuit

0.40 $110.00

05/26/2013 MJO Drafted list/chart for verifying information for returned

envelopes, in accordance with Court Order

0.20 $55.00
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05/26/2013 MJO Draft template verification email to send to potential opt-in

plaintiffs with inaccurate addresses

0.20 $55.00

05/27/2013 MJO Returned phone call of potential opt-in plaintiff Mary Bonella,

left voicemail re: questions about lawsuit

0.10 $27.50

05/27/2013 MJO Returned call of potential opt-in plaintiff Betty Bente, left

voicemail re: questions about Transcend lawsuit

0.10 $27.50

05/27/2013 MJO Returned call of potential opt-in plaintiff Anne Wagner, left

voicemail re: questions about Transcend lawsuit

0.10 $27.50

05/27/2013 MJO Returned call of potential opt-in plaintiff Kimberly Elder, left

voicemail re: questions about Transcend lawsuit

0.10 $27.50

05/27/2013 MJO Draft email reply to inquiry from potential opt-in Plaintiff

Laura Denio, re: inquiry concerning lawsuit against Transcend

and compensation practices applied to Team Leads

0.20 $55.00

05/27/2013 MJO Draft Notice of Filing Consent To Become Party Plaintiff and

Attorney Appearance Form for opt-in Plaintiff Vickie Astudillo

0.30 $82.50

05/27/2013 MJO Draft Notice of Filing Consent To Become Party Plaintiff and

Attorney Appearance Form for opt-in Plaintiff Judith Bean

0.30 $82.50

05/27/2013 MJO Draft Notice of Filing Consent To Become Party Plaintiff and

Attorney Appearance Form for opt-in Plaintiff Cheryl

Beauchamp

0.30 $82.50

05/27/2013 MJO Draft Notice of Filing Consent To Become Party Plaintiff and

Attorney Appearance Form for opt-in Plaintiff Mary Christine

Bryant

0.30 $82.50

05/27/2013 MJO Compiled list of opt-ins for whom we received returned

envelopes to verify addresses; consulted class master list for

email addresses of opt-ins to abide by Court Order

1.20 $330.00

05/27/2013 CA Scan and upload Transcend opt-in forms. 2.00 $450.00

05/28/2013 MJO Phone call with potential opt-in Plaintiff Mary Bonella, re:

employment at Transcend

0.30 $82.50

05/28/2013 MJO Phone call with potential opt-in Plaintiff Faith Mobsby, re:

employment at Transcend

0.30 $82.50

05/28/2013 MJO Phone call with potential opt-in Plaintiff Joy Atwell, re:

employment at Transcend

0.30 $82.50

05/28/2013 MJO Draft Notice of Consent to Become Party Plaintiffs for 68 new

opt-in class members; draft Attorney Appearance form for 68

new opt-in class members

3.50 $962.50

05/29/2013 MJO Draft email reply to question from Plaintiff Lisa Edwards 0.20 $55.00

05/29/2013 MJO Telephone call with potential opt-in Plaintiff Beth Cummer, re:

answered questions about the lawsuit

0.50 $137.50

05/29/2013 MJO Telephone call with potential opt-in Plaintiff Kimberly Elder,

re: answered questions about the lawsuit

0.40 $110.00

05/29/2013 MJO Attempted calling potential opt-in Plaintiff Stacy Hargrave, left

voicemail re: returning phone call concerning Transcend

lawsuit

0.10 $27.50

05/29/2013 MJO Attempted calling potential opt-in Plaintiff Anne Wagner, left

voicemail re: returning phone call concerning Transcend

lawsuit

0.10 $27.50

05/29/2013 MJO Draft Notice of Filing to Opt-in and Attorney Appearance forms

for opt-in Plaintiffs Kimberly Moore and Sherry Martin

0.50 $137.50

05/29/2013 CA Enter Plaintiff filing information into N.D. III. Website. 0.50 $112.50

05/30/2013 MJO Replied to email from potential opt-in Plaintiff Susan Lell, re:

mailed submission of notice and consent form

0.20 $55.00

05/30/2013 MJO Draft email in response to potential opt-in plaintiff Dianan

Cannon-Iseminger's inquiry concerning the lawsuit against

Transcend

0.20 $55.00

05/30/2013 MJO Draft email in response to potential opt-in plaintiff Ben Scott's

inquiry concerning the lawsuit

0.30 $82.50

05/30/2013 MJO Draft email in response to potential opt-in plaintiff Ben Scott's

inquiry concerning the lawsuit

0.30 $82.50

05/30/2013 MJO Draft email in response to potential opt-in plaintiff Roberta

Bianchini's inquiry concerning the lawsuit

0.30 $82.50
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05/30/2013 MJO Draft email in response to inquiry of potential opt-in Plaintiff

Margo McNeil, re: lawsuit against Transcend and numerous

questions regarding fee, status of case

0.50 $137.50

05/30/2013 MJO Draft Notice of Intent to File Consent as Party Plaintiff and

Attorney Appearance Forms for 28 opt-in Plaintiffs

2.50 $687.50

05/31/2013 MJO Telephone call with potential opt-in Plaintiff Anne Wagner, re:

questions about the lawsuit including costs and

deposition/discovery responsibilties

0.20 $55.00

05/31/2013 MJO Updated and compiled list of addresses verified by opt-in

Plaintiffs

0.50 $137.50

05/31/2013 MJO Drafted response email to potential opt-in Plaintiff Royann

Rairdon, re: standing to opt-in to join the lawsuit

0.20 $55.00

05/31/2013 MJO Responded to email from potential opt-in Plaintiff Susan Lell,

re: opting-in to join lawsuit

0.20 $55.00

05/31/2013 MJO Responded to email inquiry from potential opt-in Plaintiff Rita

Carr, re: cost-shifting if Transcend prevails

0.20 $55.00

05/31/2013 MJO Drafted response email to potential opt-in Plaintiff Ellen Buffy,

re: numerous questions about the status of the case and

responsibilities of the opt-in Plaintiff

0.50 $137.50

05/31/2013 MJO Responded to email inquiry from potential opt-in Plaintiff

Jacqueline Linville, re: cost-shifting if Transcend prevails

0.20 $55.00

05/31/2013 MJO Responded to email inquiry from potential opt-in Plaintiff Kelly

Ustinovich, re: responsibilities of opt-in Plaintiffs

0.20 $55.00

05/31/2013 MJO Replied to follow-up email from potential opt-in Plaintiff

Margo McNeil, re: cost-shifting and participation in lawsuit

0.30 $82.50

05/31/2013 MJO Telephone call with Plaintiff Linda Mathias, re: off-the-clock

work as a Medical Language Specialist for purposes of

gathering information concerning the lawsuit

0.40 $110.00

05/31/2013 MJO Draft Notice of Filing Consent to Become Party Plaintiff for

approximately 80 additional Plaintiffs; drafted Attorney Entry

of Appearance forms for approximately 80 additional Plaintiffs

4.00 $1,100.00

05/31/2013 MJO Draft Notice of Filing Consent to Become Party Plaintiff for

approximately 80 additional Plaintiffs; drafted Attorney Entry

of Appearance forms for approximately 80 additional Plaintiffs

4.00 $1,100.00

06/01/2013 MJO Emailed co-counsel, re: total number of Plaintiffs who have

opted-in to suit thus far

0.20 $55.00

06/01/2013 MJO Emailed co-counsel, re: Transcend opt-in consent forms and

process

0.30 $82.50

06/01/2013 MJO Responded to email inquiry from potential opt-in Plaintiff

Kimberly Coleman (Lauffer) re: statute of limitations for

joining the lawsuit

0.30 $82.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Nancy Dombrowski by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Robin C. Browning by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Joyce Yvonne-Claxton by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Denyse Fallon Janek by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Carol A. Garmon by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Lisa Strobel by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Lynn Ellis by telephone call

0.10 $27.50

06/01/2013 MJO Attempted verifying address information for potential opt-in

Plaintiff Jessica Stark by telephone call

0.10 $27.50

06/02/2013 MJO Conduct research of relevant California federal case law

involving claims of minimum wage/overtime violations under

the California Labor Code; read numerous cases, including

Cardensas v. McLane Food Services, Inc; Quezada v. Con-Way

2.50 $687.50
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Freight, Inc.; and relevant sections of the California Division

of Labor Standards Enforcement Policies and Labor

Interpretations Manual

06/03/2013 MJO Phone call with potential opt-in Plaintiff Ms. Susan

Cunningham, re: Transcend instructions to put less hours on

timecard and failure to pay for all hours worked

0.50 $137.50

06/03/2013 MJO Draft Notice of Filing Intent to Become Party Plaintiff and

Attorney Appearance form for approximately 120 consent

forms and new opt-in plaintiffs

3.00 $825.00

06/03/2013 CA Scan and record plaintiff consent forms. 2.00 $450.00

06/04/2013 MJO Draft Notice of Filing Intent to Become Party Plaintiff and

Attorney Appearance form for approximately 17 consent forms

and new opt-in plaintiffs

0.50 $137.50

06/05/2013 MJO Phone call with potential opt-in Rita DeFino, re: confirming

we received consent form

0.20 $55.00

06/05/2013 MJO Analyzed and examined unanswered emails with questions and

inquiries from potential opt-in plaintiffs

0.50 $137.50

06/05/2013 MJO Drafted response email to potential opt-in Plaintiff Deanna

Garcia, re: Transcend buyout by Nuance and minimum wage

requirement for piece rate pay

0.20 $55.00

06/05/2013 MJO Drafted response email to potential opt-in Plaintiff Kimberly

Bullock, re: requirements for opt-ing in to join the lawsuit

0.20 $55.00

06/05/2013 MJO Drafted response email to potential opt-in Plaintiff Kathy

Sanders, re: potential financial burden to attorneys or

defendant by opting-in to suit

0.30 $82.50

06/05/2013 MJO Drafted response email to potential opt-in Plaintiff Deloris

Hamilton, re: potential termination/retaliation and recourse for

joining the lawsuit

0.20 $55.00

06/05/2013 MJO Draft Notice of Intent to Opt-in as Plaintiff and Attorney

Appearance for 11 new opt-in plaintiffs

0.50 $137.50

06/06/2013 MJO Draft email response to opt-in Plaintiff Nancy Haupt, re: status

of lawsuit

0.20 $55.00

06/06/2013 MJO Draft Notice of Intent to Opt-in as Plaintiff and Attorney

Appearance for 32 new opt-in Plaintiffs

1.00 $275.00

06/06/2013 MJO Draft Notice of Intent to Opt-in as Plaintiff and Attorney

Appearances for 52 new opt-in Plaintiffs

3.00 $825.00

06/06/2013 KJD Call Mersol to discuss possibility of mediation after end of optin period.0.10 $45.00

06/07/2013 KJD Review mediation notes from Chicago discussion, email

opposing counsel re: portability of mediation after the opt-in

period ends.

0.25 $112.50

06/08/2013 CA Scan and record plaintiff consent forms. 1.50 $337.50

06/10/2013 MJO Draft email response to inquiry from potential opt-in member

Deloris Hamilton, re: current employees involved in suit

0.20 $55.00

06/10/2013 MJO Draft email response to inquiry from potential opt-in class

member Katherine Tate, re: answered several questions

concerning participation in the lawsuit and status of the

lawsuit

0.30 $82.50

06/10/2013 MJO Draft email response to inquiry from potential opt-in class

member Janet Harper, re: answered several questions

concerning participation in the lawsuit and status of the

lawsuit

0.30 $82.50

06/10/2013 MJO Drafted email response to inquiry from potential opt-in class

member Tracy Harrod, re: answered several questions

concerning participation in the lawsuit and status of the

lawsuit

0.30 $82.50

06/10/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 33 new opt-in Plaintiffs

1.50 $412.50

06/10/2013 KJD Call with Bersol RE: mediation process and upcoming

scheduling conference.

0.25 $112.50

06/10/2013 CA Scan and record plaintiff consent forms. 0.75 $168.75
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06/11/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 8 new opt-in plaintiffs

0.50 $137.50

06/11/2013 CA Scan and record plaintiff consent forms. 1.40 $315.00

06/12/2013 MJO Phone call with opt-in Plaintiff Beth Colbert, re: joining

lawsuit

0.30 $82.50

06/12/2013 MJO Draft email to co-counsel, re: mediation 0.20 $55.00

06/12/2013 MJO Draft email to co-counsel, re: mediation 0.20 $55.00

06/12/2013 MJO Draft email to opt-in Plaintiff Christina Hendricks, re: opting-in

to lawsuit

0.20 $55.00

06/12/2013 MJO Draft email to opt-in Plaintiff Christina Hendricks, re: detailed

overview of potential obligations due to opting-in to join the

lawsuit

0.30 $82.50

06/13/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 18 new opt-in plaintiffs

0.70 $192.50

06/13/2013 KJD Draft and edit email to counsel re: conversation with opposing

counsel, plan of action on mediation.

0.50 $225.00

06/13/2013 CA Scan and record plaintiff consent forms. 0.80 $180.00

06/14/2013 MJO Phone call with opt-in plaintiff Alice Gillespie, re: requirements

for opting-in to join lawsuit

0.30 $82.50

06/14/2013 MJO Draft updated transcriptionists' contact sheet and chart

containing the names and contact information of

approximately 70 new opt-in plaintiffs who have joined the

suit since May 21, 2013; consulted consent forms and Doc.

#120 for information concerning new opt-in plaintiffs

1.50 $412.50

06/16/2013 MJO Draft updated transcriptionists' contact sheet and chart

containing the names and contact information of

approximately 50 new opt-in plaintiffs who have joined the

suit since May 29, 2013; consulted consent forms and Docs.

#121 for information concerning new opt-in plaintiffs

1.00 $275.00

06/16/2013 MJO Draft email to Plaintiff Susan Haworth, re: requirements for

opting-in to join lawsuit

0.20 $55.00

06/18/2013 CA Scan and record plaintiff consent forms. 1.00 $225.00

06/19/2013 KJD Email and response, re: coordinate new dates for scheduling

conference for August with the court and opposing counsel.

0.25 $112.50

06/21/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 25 new opt-in plaintiffs

1.50 $412.50

06/22/2013 CA Scan and record plaintiff consent forms. 0.90 $202.50

06/25/2013 MJO Respond to email from Plaintiff Julie Wright, re: updated

address and joining lawsuit

0.20 $55.00

06/25/2013 MJO Review emails sent by opt-in Plaintiff Brigette Zirn 0.30 $82.50

06/25/2013 MJO Draft email to plaintiff Zirn, re: emails and MKM time

manipulation

0.20 $55.00

06/25/2013 MJO Draft response email to potential opt-in plaintiff Sandy Theis,

re: questions regarding uncompensated work time

0.30 $82.50

06/25/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 39 new opt-in plaintiffs

2.00 $550.00

06/25/2013 MJO Phone call to court, re: notification of docket entry

concerning status hearing

0.10 $27.50

06/25/2013 MJO Draft updated transcriptionists' sheet and chart containing the

names and contact information of approximately 50 new optin plaintiffs who joined the suit since May 21, 2013;

consulted consent forms and Dkt. #121, #123 for

information concerning new opt-in plaintiffs

1.50 $412.50

06/25/2013 MJO Draft memorandum to opt-in plaintiffs, re: questions

concerning their employment with Transcend, experience with

Transcend

1.20 $330.00

06/26/2013 MJO Phone call with opposing counsel, re: moving dates for status

hearing

0.20 $55.00

06/26/2013 MJO Phone call with Judge Guzman's chambers, re: moving dates

for status hearing

0.20 $55.00
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06/26/2013 MJO Emails with opposing counsel, re: moving dates for status

hearing

0.20 $55.00

06/27/2013 MJO Multiple calls to clerk with Northern District of Illinois, left

voicemails, re: re-scheduling status hearing to July 22

0.50 $137.50

07/01/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 21 new opt-in plaintiffs

1.50 $412.50

07/01/2013 MJO Email Plaintiff Lisa Smith, re: updated contact information and

update on status of lawsuit

0.20 $55.00

07/01/2013 MJO Email Plaintiff Laura Denio, re: emails Plaintiff preserved 0.20 $55.00

07/02/2013 MJO Analyzed and examined verification chart for purposes of

compiling list of potential opt-ins who need to have addresses

verified

0.50 $137.50

07/08/2013 MJO Analyzed and examined emails sent to opt-in account, emailed

response to opt-in Plaintiff Julie Cowell

0.30 $82.50

07/08/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 21 new opt-in Plaintiffs

1.50 $412.50

07/10/2013 MJO Telephone call with potential opt-in plaintiff Leslie, re:

responded to questions concerning timeframe for opting-in to

join lawsuit

0.20 $55.00

07/10/2013 MJO Attempted calling potential opt-in plaintiff Jennifer Lockman,

re: responding to message she left concerning questions she

has about Transcend lawsuit

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Tracey Kayoum, re:

responding to message she left concerning questions she has

about Transcend lawsuit; left voicemail

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Tracy L. Harmeyer

to verify address, no answer

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Becky Jean Holland

to verify address, recording stated her number is no longer in

service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Nan M. Lambert, to

verify address, left voicemail, re: verifying her address for the

lawsuit

0.10 $27.50

07/10/2013 MJO Updated opt-in return mail chart to reflect telephone

verification attempts for Tracy Harmeyer, Becky Jean Holland,

and Nan M. Lambert

0.20 $55.00

07/10/2013 MJO Attempted calling potential opt-in plaintiff Tiffany Lyn Larson

to verify address, number no longer in service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Vicky L. Lawson to

verify address, number no longer in service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Cynthia Lee Flint to

verify address, number no longer in service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Beverly Ann Pitts to

verify address, number disconnected

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Michelle R. Adams

to verify address, number disconnected

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Dawne Smith to

verify address, no answer and left voicemail re: verifying her

address for the lawsuit

0.10 $27.50

07/10/2013 MJO Updated opt-in return mail chart to reflect telephone

verification attempts for Tiffany Lyn Larson, Vicky L. Lawson,

Cynthia Lee Flint, Beverly Ann Pitts, Michelle R. Adams, and

Dawne Smith

0.20 $55.00

07/10/2013 MJO Attempted calling potential opt-in plaintiff Michelle Lynn

Huggins to verify address, no answer, phone just rang

0.10 $27.50

07/10/2013 MJO Phone call with potential opt-in plaintiff Jennifer Hall, re:

verifying address for purposes of the lawsuit; verified new

address as 109 Southwood Drive, Dickson, TN 37055

0.20 $55.00

07/10/2013 MJO Updated opt-in return mail chart to reflect telephone

verification attempts for Michelle Lynn Huggins, Jennifer Hill,

and Patricia Meja

0.20 $55.00
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07/10/2013 MJO Attempted calling potential opt-in plaintiff Patricia Meja to

verify address, no answer and left voicemail re: verifying

address for lawsuit

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Karla Denise Gress

to verify address, no answer and left voicemail re: verifying

address for lawsuit

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Tamera Lynn Morris

to verify address, no answer and left voicemail re: verifying

address for lawsuit

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Melba Joy

Sheppard to verify address, phone number on file no longer

in service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Sean Richard

Higgins to verify address, phone number on file no longer in

service

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Veronica Joyce

James to verify address, no answer and left voicemail re:

verifying her address for the lawsuit

0.10 $27.50

07/10/2013 MJO Phone call with potential opt-in Plaintiff Tammy Lynn

Robinson, re: verifying address; she refused to provide

address

0.20 $55.00

07/10/2013 MJO Attempted calling potential opt-in plaintiff Amy Lynne

Crutchfield to verify address, phone number on file no longer

in service

0.10 $27.50

07/10/2013 MJO Phone call with potential opt-in plaintiff Karen Lynne

Amelung, re: verification of address for lawsuit; verified

updated address as 1427 Trabue Woods Blvd., Columbus, OH

43228

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Christina Haltom

Farrar to verify address, phone number on file no longer in

service

0.10 $27.50

07/10/2013 MJO Updated opt-in return mail chart to reflect telephone

verification attempts for Karla Denise Gress, Tamera Lynn

Morris, Melba Joy Sheppard, Sean Richard Higgins, Gail

Carpenter, Veronica Joyce James, Tammy Lynn Robinson, Amy

Lynne Crutchfield, Karen Lynn Amelung, Christina HaltomFarrar

0.30 $82.50

07/10/2013 MJO Phone call with potential opt-in plaintiff Linda Boles, re:

verification of address for lawsuit; verified updated address as

131 Halliburton Street, Apt. A, Ripley, TN 38063

0.20 $55.00

07/10/2013 MJO Attempted calling potential opt-in plaintiff Melanie Lee to

verify address, informed she no longer lives at this address

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Shanda Witham to

verify address, no answer and left voicemail re: verifying her

address for the lawsuit

0.10 $27.50

07/10/2013 MJO Attempted calling potential opt-in plaintiff Rachel Zenobia

Billington to verify address, number no longer in service

0.10 $27.50

07/11/2013 MJO Phone call with potential opt-in plaintiff Tracey Kayoum, re:

requirements for participating in lawsuit

0.50 $137.50

07/16/2013 MJO Re-filed Attorney Appearance for 13 opt-in Plaintiffs entered

on July 15, 2013

0.20 $55.00

07/16/2013 MJO Phone call with opt-in Plaintiff Deanna Garcia, re: questions

about lawsuit and potential effect of bankruptcy

0.30 $82.50

07/16/2013 MJO Phone call with opt-in Plaintiff Deanna Garcia, re: questions

about lawsuit and potential effect of bankruptcy

0.30 $82.50

07/17/2013 MJO Emailed opposing counsel re: status conference July 22, 2013 0.20 $55.00

07/17/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 7 new opt-in plaintiffs

0.80 $220.00

07/17/2013 KJD Call with Gary Mersal- discuss status prior to status conference

with the court.

0.25 $112.50

07/18/2013 MJO Draft informational outline for use of Attorney K. Dolley in

preparation for status hearing, re: class size; tallied number of

0.70 $192.50
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opt-in plaintiffs total and number of individuals who have

opted-in since the beginning of the class period May 20

07/18/2013 MJO Draft informational outline for use of Attorney K. Dolley in

preparation for status hearing, re: detailed how Plaintiffs have

been retaining and recording undeliverable notices and

verifying addresses in accordance with the court order; also

outlined update on mediation and Defendant's unwillingness

to participate

0.50 $137.50

07/18/2013 MJO Draft informational outline for use of Attorney K. Dolley in

preparation for status hearing, re: detailed how Plaintiffs will

survive de-certification motion which will likely be filed by

Defendant if mediation fails; researched standard for decertification in 7th Circuit and all federal circuits; examined

and analyzed numerous cases, including Russell v. Illinois Bell

1.30 $357.50

07/18/2013 MJO Phone call with opt-in Plaintiff Terri Eriksen, re: verification

that we received consent form and questions concerning

participation in the lawsuit

0.30 $82.50

07/19/2013 MJO Prepare folder for status hearing 0.50 $137.50

07/19/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 5 new opt-in plaintiffs

0.60 $165.00

07/22/2013 KJD Prep for hearing status conference, prepare statements review

info on class, notice and case progress; Travel to Chicago

courts and back to St. Louis.

8.00 $3,600.00

07/26/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 15 new opt-in plaintiffs

1.50 $412.50

08/01/2013 MJO Telephone call with opt-in Plaintiff Cathy Haines, re: questions

concerning the status of the lawsuit

0.40 $110.00

08/02/2013 MJO Review emails and consent forms; updated addresses of

several opt-in class members; review detailed correspondence

from opt-in class members including Dana Morgan and Karen

Amelung

1.20 $330.00

08/03/2013 MJO Attempted returning call of opt-in plaintiff Patti Rapp; emailed

Ms. Rapp re: responding to her inquiry concerning documents

helpful to lawsuit

0.20 $55.00

08/03/2013 MJO Attempted returning call of opt-in plaintiff Mary Cruz, re:

lawsuit against Transcend

0.10 $27.50

08/03/2013 MJO Respond to email from opt-in Plaintiff Trinka Osborne, re:

participation in the lawsuit

0.20 $55.00

08/03/2013 MJO Respond to email from opt-in Plaintiff Diane Joyner, re:

participation in the lawsuit

0.20 $55.00

08/03/2013 MJO Respond to email from potential opt-in plaintiff Jana Morse,

re: joining lawsuit

0.20 $55.00

08/03/2013 MJO Respond to email from potential opt-in plaintiff Sherry

Doratio, re: questions concerning participation in the lawsuit

and potential damages

0.20 $55.00

08/03/2013 MJO Respond to email from opt-in Plaintiff Dawn O'Connor, re:

confirmation that we received consent form and filed with the

court

0.20 $55.00

08/03/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 26 new opt-in plaintiffs

2.00 $550.00

08/07/2013 MJO Phone call with potential opt-in Plaintiff Barbara Magliochetti,

re: hours worked with Transcend and directions to change

timesheets while employed with Transcend

0.30 $82.50

08/09/2013 MJO Phone call with potential opt-in Plaintiff Mary Cruz, re:

discussed similarities between Transcend and Nuance pay

practices and her experience at Transcend not making

minimum wage

0.40 $110.00

08/13/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 17 new opt-in plaintiffs

1.50 $412.50

08/15/2013 MJO Draft and revised Joint Proposed Scheduling Plan initially

drafted by co-counsel; revised size of class which has opted-in

during 90 day notice period, mediation referral

0.70 $192.50
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recommendation by Court, and drafted substantive comments

for review of Attorney K. Dolley

08/15/2013 MJO Edit/revise Joint Proposed Scheduling Plan to reflect changes

recommended by Attorney K. Dolley

0.50 $137.50

08/16/2013 MJO Phone call with co-counsel, re: Joint Proposed Scheduling

Order

0.50 $137.50

08/16/2013 MJO Phone call with co-counsel, re: Joint Proposed Scheduling

Order

0.50 $137.50

08/16/2013 MJO Revise Plaintiffs' Proposed Scheduling Order, re: removed any

reference to scheduling order being a joint motion

0.50 $137.50

08/16/2013 MJO Draft email to opposing counsel, re: scheduling order 0.20 $55.00

08/16/2013 MJO Draft email to opposing counsel, re: proposed scheduling

order

0.20 $55.00

08/19/2013 KJD Travel to Chicago from office for court hearing. 3.00 $1,350.00

08/19/2013 KJD Review, notes re: defendant's proposed scheduling plan;

review scheduling docs opt-in information, prepare for court

hearing.

1.00 $450.00

08/19/2013 MJO Prepare file for Attorney K. Dolley for status hearing in

Chicago set for Aug. 20; revise cheat sheet of preparation

material

0.50 $137.50

08/19/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 5 new opt-in Plaintiffs

0.50 $137.50

08/19/2013 MJO Analyze and examine Defendant's proposed scheduling order;

draft detailed email to co-counsel, re: thoughts and reaction

to couterassertions of Defendant at status hearing

0.80 $220.00

08/19/2013 MJO Analyze and examine Defendant's proposed scheduling order;

draft detailed email to co-counsel, re: thoughts and reaction

to couterassertions of Defendant at status hearing

0.80 $220.00

08/20/2013 KJD Prep for status hearing before court, conference with

opposing counsel to discuss scheduling under court ordered

parameters, re: call back with court further discuss and set

schedule in open cont.

1.50 $675.00

08/20/2013 KJD Travel Chicago to STL 3.00 $1,350.00

08/20/2013 MJO Meeting with Attorney K. Dolley, re: status hearing on

8/20/13

0.70 $192.50

08/20/2013 MJO Meeting with Attorney K. Dolley, re: status hearing on

8/20/13

0.70 $192.50

08/20/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 2 new opt-in Plaintiffs

0.40 $110.00

08/20/2013 MJO Draft Notices of Intent to Opt-in as Plaintiff and Attorney

Appearances for 2 new opt-in Plaintiffs

0.40 $110.00

08/20/2013 MJO Telephone call with Plaintiff Linda Romanek, re: lawsuit

update

0.50 $137.50

08/20/2013 MJO Telephone call with Plaintiff Linda Romanek, re: lawsuit

update

0.50 $137.50

08/20/2013 MJO Draft detailed email outlining Aug. 20 status hearing, re:

Judge Guzman's specific orders concerning scope of discovery

in case going forward

1.00 $275.00

08/21/2013 MJO Phone calls with Northern District of Illinois chambers of

Judge Cox, Judge Guzman, and Judge Rowland, re: mediation

dates and process of mediation referral

0.70 $192.50

08/21/2013 MJO Phone calls with local counsel, re: potential mediators in

Chicago area

0.20 $55.00

08/21/2013 MJO Review professional profiles of several potential mediators in

Chicago-area provided by ADR Systems, Inc.

0.50 $137.50

08/21/2013 MJO Phone call with co-counsel, re: status hearing and strategy for

moving case forward with mediation

0.70 $192.50

08/21/2013 MJO Phone call with Chicago-based wage and hour attorney Doug

Werman, re: recommended mediators in Chicago-area and

nationally

0.40 $110.00

08/21/2013 MJO Draft email to co-counsel, re: updates on available mediators 0.30 $82.50
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08/22/2013 MJO

in Chicago-area and nationally

Phone calls to following potential mediators to gather dates 0.80 $220.00

for mediations in Sept. and Oct.: Rebecca Bromet, Joel Rice,

Ken Gage, Morton Denlow, Hunter Hughes, Hon. Mary

Rowland

08/22/2013 MJO Draft email to co-counsel, re: initial status conference before

Magistrate Judge Rowland

0.10 $27.50

08/22/2013 MJO Phone calls with CA mediators Mark Rudy and Michael Loeb as

to availability for mediation

0.20 $55.00

08/22/2013 MJO Phone calls with Rebecca Bromet's assistant from Seyfarth

Shaw, re: mediator Rebecca Bromet's availability for phone

conference

0.20 $55.00

08/22/2013 MJO Draft email for review to opposing counsel, re: potential

mediators

0.20 $55.00

08/22/2013 MJO Phone call with mediator Michael Dickstein, re: mediation

availability and status of case

0.30 $82.50

08/23/2013 MJO Left voicemail for Greg Mersol, re: telephone hearing with

Judge Rowland

0.10 $27.50

08/23/2013 MJO Phone call with opposing counsel, re: telephone hearing with

Judge Rowland

0.20 $55.00

08/23/2013 MJO Phone call with opt-in Plaintiff, re: compensation and work

time while employed with Transcend

0.50 $137.50

08/23/2013 MJO Phone call with T. Cosentino, re: mediation availability and

explanation of mediation process

0.30 $82.50

08/23/2013 MJO Phone call with opt-in Plaintiff Susan McCrimmon, re: failure

to receive opt-in forms during opt-in period and work

experience at Transcend

0.50 $137.50

08/23/2013 MJO Attempted calling potential opt-in Plaintiff Rene Padula, re:

responded to email inquiry concerning her failure to receive

opt-in forms

0.10 $27.50

08/23/2013 MJO Phone call with mediator Rebecca Bromet, re: availability for

mediation and experience performing mediation

0.30 $82.50

08/23/2013 MJO Draft letter to class members updating them on the case and

explaining upcoming developments requiring their

participation in the case

1.30 $357.50

08/24/2013 MJO Review/revise letter drafted to class members, re: revise

descriptions of discovery process going forward and

depositions to be taken going forward; added conclusion

section

0.50 $137.50

08/24/2013 MJO Draft outline for use of attorney K. Dolley during status

hearing with J. Rowland on Aug. 26

0.50 $137.50

08/26/2013 KJD Prepare for status/ settlement conference; settlement

conference scheduling for phone w/ Magistrate Rowland

discussions of dates and process.

1.00 $450.00

08/26/2013 MJO Participate in telephonic status hearing on behalf of Plaintiffs

with Attorney K. Dolley before Hon. Mary Rowland

0.50 $137.50

08/26/2013 MJO Phone call with potential mediator Ken Gage, re: available

dates for mediation

0.20 $55.00

08/26/2013 MJO Email co-counsel, re: update on status conference before

Judge Rowland

0.20 $55.00

08/26/2013 MJO Revise Notice of Intent to opt-in as Party Plaintiff and attorney

appearance form for Susan Jones

0.30 $82.50

08/27/2013 MJO Phone call with potential opt-in plaintiff, re: deadline for

opting-in to join lawsuit

0.20 $55.00

08/27/2013 MJO Phone call with Meagann Smith from ADR systems, re:

potential mediation dates and available mediators for

Transcend in Chicago

0.20 $55.00

08/28/2013 MJO Phone call with co-counsel, re: mediation status and hearing

before Hon. Mary Rowland on Aug. 26

0.50 $137.50

08/30/2013 MJO Left voicemail for Hunter Hughes, re: confirming mediation

date

0.10 $27.50
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08/30/2013 MJO Draft email to opposing counsel, re: confirming travel to

Atlanta for mediation

0.20 $55.00

08/30/2013 MJO Emailed Plaintiff Lisa Edwards and left voicemail, re:

availability to attend mediation on Oct. 8 in Atlanta

0.30 $82.50

08/30/2013 MJO Emailed assistant for Mediator H. Hughes, re: style of case for

conflicts check and confirming Oct. 8 for mediation date

0.20 $55.00

09/10/2013 MJO Revise email to class members, re: update on lawsuit and

mediation

0.60 $165.00

09/11/2013 MJO Draft emails/responses to emails from mediator Hunter

Hughes, re: mediation agreement and procedures

0.30 $82.50

09/18/2013 MJO Email co-counsel, re: mediation logistics and strategy 0.30 $82.50

09/18/2013 MJO Draft questionnaire for dissemination to class members, re:

draft questions concerning dates of employment,

compensation, piece rate compensation, hands on keyboard

time, flexing time, and supervisor knowledge of work time for

purposes of gathering information to respond to discovery

requests from Defendant

1.00 $275.00

09/19/2013 MJO Draft/revise questionnaire to disseminate to class members, re:

drafted additional questions concerning specific time spent

working, specific time spent performing specific tasks,

timekeeping methods/policies

1.00 $275.00

09/20/2013 MJO Phone call from Plaintiff Barbara Vaughn, re: update on

lawsuit

0.20 $55.00

09/20/2013 MJO Draft questionnaire to disseminate to class members, re:

added numerous specific questions concerning personal

information, employment with Transcend, compensation rate,

and practices encountered while employed with Transcend

2.50 $687.50

09/20/2013 MJO Draft questionnaire to disseminate to class members, re:

added numerous specific questions concerning opt-in

plaintiffs' hours worked at Transcend, including scheduled

shift, amount of hours worked performing specific tasks,

amount of time worked in excess of shift, job duties

performed while working extra hours, reporting extra hours

worked, timekeeping used while working extra hours,

supervision while working extra uncompensated hours,

indicating hours worked in an average week, total number of

hours worked per week

2.50 $687.50

09/20/2013 MJO Draft questionnaire to disseminate to class members, re: draft

numerous detailed questions concerning hands on keyboard

time, time flexing, and make up pay policy

1.50 $412.50

09/20/2013 MJO Draft questionnaire to disseminate to class members, re: draft

list of 14 specific topics of documents and emails that class

members may have and should forward to attorneys

1.00 $275.00

09/20/2013 MJO Phone call with co-counsel, re: requesting updated and

additional electronic payroll registers for each class member

from Defendant

0.40 $110.00

09/20/2013 MJO Draft and send emails to approximately 100 class members,

re: updating class members on lawsuit and attaching

questionnaire for information-gathering purposes in

preparation for mediation and second-phase of discovery

0.50 $137.50

09/21/2013 MJO Draft and send emails to class members alphabetically from

Barbara Ciulla to Dale Johnson (Medina), re: updating class

members on lawsuit and attaching questionnaire for

information-gathering purposes in preparation for mediation

and second-phase of discovery

1.50 $412.50

09/21/2013 MJO Draft and send emails to class members alphabetically from

Catherine Johnson-Berger to Patricia J. Stefanik, re: updating

class members on lawsuit and attaching questionnaire for

information-gathering purposes in preparation for mediation

and second-phase of discovery

1.50 $412.50

09/21/2013 MJO Draft and send emails to class members alphabetically from

Leida Stewart to Carole Zmuda, re: updating class members

1.00 $275.00
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on lawsuit and attaching questionnaire for informationgathering purposes in preparation for mediation and secondphase of discovery

09/21/2013 MJO Draft and send emails to named Plaintiffs and initial opt-in

class members prior to May 20, 2013, re: updating class

members on lawsuit status

0.50 $137.50

09/22/2013 MJO Review completed questionnaires and/or draft response emails

to following class members re: questions concerning lawsuit:

Penny Zimmerman, Julene Logue, Penelope Neal, Dawn

O'Connor, Donna Jackson, Rita DeFino, Randi Gray, Lorraine

Jackson, Carey Miller, Brenda Shelton, Susan K. Lanzen, and

Kathy Murphy

1.20 $330.00

09/22/2013 MJO Draft email response to Plaintiff Clunk, re: questions

concerning lawsuit and updates to lawsuit

0.20 $55.00

09/22/2013 MJO Draft email response to Plaintiff Pence, re: questions

concerning lawsuit and updates to lawsuit

0.20 $55.00

09/22/2013 MJO Draft email response from Plaintiff Nancy Haupt, re:

information gathering for purposes of mediation

0.20 $55.00

09/23/2013 MJO Phone call with opt-in Plaintiff Nancy Haupt, re:

compensation at Transcend

0.40 $110.00

09/23/2013 CA Go through optincluded email re print off emails,

questionnaires and any other attached documents.

1.40 $315.00

09/24/2013 MJO Phone call with Susan Cunningham, re: questions concerning

information gathering phase of lawsuit

0.20 $55.00

09/24/2013 MJO Phone call with Susan Cunningham, re: questions concerning

information gathering phase of lawsuit

0.20 $55.00

09/24/2013 MJO Phone call with opt-in Plaintiff Jacqueline Linville, re:

information and document gathering for second phase of

discovery

0.30 $82.50

09/24/2013 MJO Responded to emails concerning information gathering for

purposes of discovery from the following opt-in plaintiffs:

Wanda Taylor, Cathy Haines, Carol Failla, Barbara Vaughn,

Elaine Shortall, Jessalynn Myers, Sherry Doratio

0.70 $192.50

09/25/2013 MJO Responded to emails from opt-in class members Cindy

Conwell, Julie Jones, Wanda Taylor, Naomi Joslin, Barbara

Vaughn

0.30 $82.50

09/26/2013 MJO Review completed informational questionnaires returned by

clients Barbara Vaughn, Cindy Conwell, Connee Williams,

Janet Harper, Mary McClelland, Patricia Schmutz, Robin York,

Stephanie Dewitt; began preliminary analysis of hours worked

1.50 $412.50

09/27/2013 MJO Emailed opt-in plaintiff Kim Claeys, re: information gathering

for discovery

0.20 $55.00

09/27/2013 MJO Emailed opt-in class member Julie Wright, re: questionnaire

and document gathering process

0.20 $55.00

09/27/2013 MJO Exchanged emails with opt-in class member Kim Claeys, re:

information gathering for purposes of mediation

0.20 $55.00

09/27/2013 MJO Review/analyzed and examined hundreds of pages of

documents and questionnaire produced by opt-in Plaintiff

Cathi Moore for purposes of gathering information to draft

mediation memo

1.50 $412.50

09/29/2013 MJO Draft emails to class members and reviewed

information/documents provided by numerous class members,

including but not limited to Diane Martin, Veronica Vitari, Jo

Ellen Carnes, Cheri Kline, Mary Hall, Susan Janzen, Lynsi

Henson, re: information gathering for purposes of calcluating

damages in mediation

1.50 $412.50

09/29/2013 MJO Draft confidential mediation memorandum, re: introduction

and procedural posture of case, included facts concerning

parties attending mediation; filing of lawsuit in Northern

District of Illinois; filing of motion for conditional certification;

court's order conditionally certifying class; court's order

concerning opt-in period

1.50 $412.50
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09/29/2013 MJO Draft confidential mediation memorandum, re: factual

background of lawsuit; job duties of MLSs; failure to

compensate MLSs for certain tasks performed; allegations of

the two sub-classes of Plaintiffs; various ways in which

Plaintiffs similarly situated

2.00 $550.00

10/01/2013 MJO Drafted Plaintiff's Settlement Conference Statement, re:

Procedural Posture of case, including the numerous ways in

which the Court outlined the similarly situated nature of the

class in the Order dated March 19, 2013; Factual Background

of Plaintiffs, Plaintiffs' job duties/title with Defendant; and

Plaintiffs' common injury allegations

2.00 $550.00

10/01/2013 MJO Drafted Plaintiffs' Settlement Conference Statement, re:

Argument section, this class will not be decertified;

individualized circumstances do not lead to de-certification of

class; common questions of similar injury predominate

favoring certification

0.50 $137.50

10/02/2013 MJO Phone call with T. Cosentino, re: possible attendance at

settlement conference scheduled for Oct. 21

0.30 $82.50

10/02/2013 MJO Phone call with Lisa Edwards, re: lawsuit update 0.10 $27.50

10/02/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during the settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in Plaintiffs Stephanie Dewitt, Janet Harper, Kathleen

Simons, and Robin York while configuring chart and damages

calcluation

2.00 $550.00

10/03/2013 MJO Emailed opposing counsel, re: mediation and settlement

conference dates

0.10 $27.50

10/03/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in Plaintiffs Janet Harper, Bobbi McMillin, and Carey Miller

while configuring chart and damages calculations

1.00 $275.00

10/03/2013 MJO Phone call with co-counsel, re: calculating damages on classwide basis0.50 $137.50

10/03/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in Plaintiffs Patricia Schmutz, Barbara Vaughn, and Carla

Weiss while configuring chart and damages calcluation

0.70 $192.50

10/04/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in Plaintiffs Cheri Kline, Christy Scott, Cindy Conwell, and

Connee Williams while configuring chart and damages

calculation

1.50 $412.50

10/04/2013 MJO Review email from opposing counsel, re: settlement

conference

0.10 $27.50

10/04/2013 MJO Draft response email to opposing counsel, re: settlement

conference

0.40 $110.00

10/04/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Debbie Friess, Diane Joyner, Diane Martin,

Diane Spencer, Mary Hall, and Mary McClelland while

configuring chart and damages calculation

1.50 $412.50

10/04/2013 KJD Review defendant's discovery deficiencies. 1.50 $675.00

10/05/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

1.20 $330.00
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conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Donna Jackson, Elaine Leach, Elaine Shortall,

Gina Rogers, Janeen DeBoard, and Janet Harper while

configuring chart and damages calculation

10/05/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Jeanette Chipka, Jessalynn Myers, Julene

Logue, Julie Jones, Kandace Chancey, Kathryn Lacey, and

Kathy Simons while configuring chart and damages

calculation

1.50 $412.50

10/05/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Kimberly Keevy, Linda Carucci, Linda Reid,

Lorraine Jackson, Lynsi Henson, and Margaret Mackey while

configuring chart and damages calculation

1.50 $412.50

10/06/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Mindy Faieta, Naomi Joslin, Penelope Neal,

Penny Zimmerman, Randi Gray, Susan Brown, and Tammy

Martinez while configuring chart and damages calculation

1.20 $330.00

10/06/2013 MJO Created/drafted formulas for calculation of damages on classwide basis for unpaid minimum wage and unpaid overtime

compensation

2.00 $550.00

10/06/2013 MJO Drafted Settlement Demand Letter addressed to opposing

counsel, re: damages for unpaid minimum wage; provided

detailed assessment of calculation of damages for unpaid

minimum wage on class-wide basis

1.50 $412.50

10/06/2013 MJO Draft Settlement Demand letter addressed to opposing

counsel, re: damages for unpaid overtime; provided detailed

assessment of calculation of damages for unpaid overtime on

class-wide basis

1.00 $275.00

10/07/2013 MJO Analysis and examination of law in Northern District of Illinois

and other federal circuits, re: formulation of damages in FLSA

collective action on class-wide basis

1.00 $275.00

10/07/2013 MJO Draft demand letter to opposing counsel for purposes of

presentation at settlement conference, re: damages for

Plaintiffs' unpaid minimum wage and overtime claims; provide

raw calculation of damages for unpaid minimum wage and

overtime; provided analysis of Defendant's common policies in

violation of FLSA minimum wage and overtime provisions; and

conclusion paragraph with total damages and initial demand

2.50 $687.50

10/07/2013 KJD Research, review issues specific to trial formula and

representative sample; call mersol re: follow up on settlement

conference and wage and hour record issues; reviewed

settlement demand, detailed connections, changes needed for

damages deficiencies.

3.10 $1,395.00

10/08/2013 MJO Calculated total damages for unpaid minimum wage, unpaid

overtime, attorneys' fees, and costs, and added calculation to

settlement conference demand letter

0.70 $192.50

10/08/2013 MJO Telephone conference with opposing counsel 0.40 $110.00

10/08/2013 MJO Draft email to opposing counsel for review of Attorney K.

Dolley; consult notes from conference call with opposing

counsel while drafting email

0.80 $220.00

10/08/2013 KJD Review demand letter, edit, amend; call opposing counsel re:

mileage from Russ.

1.10 $495.00

10/09/2013 MJO Draft email to class, re: update on status of lawsuit, reset 0.50 $137.50
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10/09/2013 MJO

mediation date, and reminder to fill out questionnaire

Emailed all 705 class members, re: update on status of 1.70 $467.50

lawsuit, reset mediation date, and reminder to fill out

questionnaire

10/09/2013 MJO Review questionnaires submitted by opt-in Plaintiffs Joanne

Cimo and Amy Bruce

0.40 $110.00

10/09/2013 KJD Detailed review analysis; review, edit email to class as a whole. 1.25 $562.50

10/10/2013 MJO Phone call with Plaintiff Deanna Garcia, re: documents to

produce and filling out the questionnaire

0.30 $82.50

10/10/2013 MJO Phone call with Judge Rowland's chambers, re: minute entry

concerning status hearing scheduled for 11/4

0.20 $55.00

10/10/2013 MJO Telephone call with opt-in Plaintiff Rita Defino, re: documents

to produce and filling out the questionnaire

0.30 $82.50

10/10/2013 MJO Attempted calling and left voicemail for opt-in Plaintiff Debra

Sills

0.10 $27.50

10/10/2013 MJO Telephone call with Plaintiff Rita Defino, re: additional

documents/logs/journal entries from term of employment with

Transcend

0.30 $82.50

10/10/2013 MJO Draft email to opt-in class members Jamie Tullock, Lisa Smith,

Emily Oates, Deloris Hamilton, Vicki Heinecke, Cathy Haines,

Randi Gray, re: update on lawsuit

0.80 $220.00

10/10/2013 MJO Analyzed and examined questionnaires for purposes of

calcluating damages for mediation for the following opt-in

Plaintiffs: Dawn O'Connor, Marie Plum, Jacqueline SpiresPurdy, Alice Gillespie, Kim Dent, Rita Defino, Joanna Hardin,

Eileen Roff, Francine Gorskie, Amy Ford, Joyce Ratajczak,

Elizabeth Carithers, Parrish Ritchie, Deborah Schneider, Laura

Denio, Brenda Bain, Theresa Crane, Diane Birrer, Barbara

Keenan, Emily Oates, Paige Singleton, Jodi Kabalin, Renee

Nichols, Patsy Hayes, Sandy Bruce, Arlene Crofton

2.50 $687.50

10/10/2013 KJD Review email opposing counsel re: production of documents. 0.25 $112.50

10/17/2013 MJO Respond to emails from opt-in Plaintiffs including Tracy

Harrod, Deanna Matthews, Kay Bone, Cathy Haines, Wendolyn

Smith, and Lisa Edwards

1.00 $275.00

10/17/2013 MJO Analyzed and examined questionnaires submitted by opt-in

Plaintiffs including but not limited to Tangela Tyran, Linda

Todd Dittmar, Karen Lynne Berezoski, Kimberly Moore, Marilyn

Wilson, Sharon Cook, Debra Seuell, and Alane Barnes Garvik

2.00 $550.00

10/17/2013 MJO Review approximately 50-100 emails from opt-in Plaintiff

Deanna Garcia

1.50 $412.50

10/21/2013 MJO Review payroll records of opt-in plaintiffs sent by Defendant

for the year 2010

1.00 $275.00

10/21/2013 MJO Draft email to opposing counsel, re: mediation 0.20 $55.00

10/21/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during settlement

conference and demand letter addressed to Defendant prior to

settlement conference; consulted information provided by

opt-in plaintiffs Patricia Lawson, Charlene Palmer, Krissy

Reynolds, Marilyn Bower, Debbie Campbell, Karen Colburn,

Debra Seuell, Marilyn Wilson, while configuring chart and

damages calcluation

1.50 $412.50

10/21/2013 MJO Draft Plaintiffs' Second Set of Interrogatories Directed to

Defendant, re: outlined questions directed to Defendant

covering methods of compensation and timekeeping

applicable to all opt-in Plaintiffs

0.50 $137.50

10/22/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during mediation; consulted

information provided by opt-in Plaintiffs Karen Berezoski, Kim

Moore, Tangela Tyran, Linda Dittmar, and Linda Morton while

configuring chart and damages calculation

1.30 $357.50

10/22/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during mediation; consulted

0.80 $220.00
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information provided by opt-inPlaintiffs Wendolyn Smith, Kay

Bone, Debra Jones, Dawn O'Connor while configuring chart

and damages calculation

10/22/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during mediation; consulted

information provided by opt-inPlaintiffs Jacqueline SpiresPurdy, Alice Gillespie, Kim Dent, Rita Defino, Joanna Hardin,

Eileen Roff, Francine Gorskie, Amy Ford, Joyce Ratajczak,

Elizabeth Carithers, Parrish Ritchie, Deborah Schneider, while

configuring chart and damages calculation

1.80 $495.00

10/22/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during mediation; consulted

information provided by opt-inPlaintiffs Laura Denio, Brenda

Bain, Theresa Crane, Diane Birrer, Barbara Keenan, Emily

Oates, PaigeSingleton, Jodi Kabalin, ReneeNichols, while

configuring chart and damages calculation

1.50 $412.50

10/22/2013 MJO Draft itemized opt-in class member damages chart for

purposes of presentation and use during mediation; consulted

information provided by opt-inPlaintiffs Patsy Hayes, Sandra

Bruce, Arlene Crafton, Angela Aldridge, Cynthia Harp, Cynthia

Gibson, Les Rinehart, Joanne Cimo, Amy Bruce, Joy Sharp,

Maureen Hicks, Susan Silver, Laura Hammersley, Kathy Lucas,

Melinda Griffus while configuring chart and damages

calculation

1.80 $495.00

10/23/2013 MJO Draft Mediation Memorandum, re: Procedural Posture,

provided date and timing of lawsuit; specific contents and

claimsin Plaintiffs' Complaint; the extent of discovery

conducted during conditional certification phase; length of

opt-in period and current status of case

2.20 $605.00

10/23/2013 MJO Draft Mediation Memorandum, re: Factual background of case; included facts concerning class members' job title; class

members' primary duties; uniform production quotas

applicable to class members; uniform production-based

compensation rates applicable to class members; roles of

Team Leaders and Regional Managers and

monitoring/supervision of class members and MLSs by Team

Leaders, Regional Managers, and Transcend officials

1.80 $495.00

10/23/2013 MJO Draft Mediation Memorandum, re: Factual Background of case;

Defendant's instructions to alter timesheets to reflect no more

than 40 hours were worked per work week; detailed email

provided by Team Leader Amanda Lakin; detailed Defendant's

uniform time flexing policy

1.50 $412.50

10/23/2013 MJO Revised Mediation Memorandum, re: re-arranged Factual

Background structure tofit Defendant's policies and practices

at issue outlinedin court's order granting conditional

certification

1.00 $275.00

10/23/2013 MJO Calculated standardized damages formula to apply across all

class members; calculated itemized damages for Angela

Aldridge, Brenda Bain, Karen Berezoski, Diane Birrer, Kay

Bone, Marilyn Bower for purposes of mediation and drafting

Mediation Memorandum

1.50 $412.50

10/24/2013 MJO Calculated standardized damages formula to apply across all

class members; calculated itemized damages for Angela

Aldridge, Brenda Bain, Karen Berezoski, Diane Birrer, Kay

Bone, Marilyn Bower, Amy Bruce, Sandra Bruce, Debbie

Campbell, Elizabeth Carithers, Kandance Chancey, Jeannette

Chipka for purposes of mediation and drafting Mediation

Memorandum.

1.50 $412.50

10/24/2013 MJO Calculated itemized damages for Joanne Cimo, Karen Colburn,

Cindy Conwell, Sharon Duhe Cook, Arlene Crafton, Theresa

Crane, Janeen DeBoard, Rita Defino, Laura Denio, Kim Dent,

Stephanie Dewitt,Linda Dittmar, Mindy Faieta, Amy Ford,

Debbie Friess, Cynthia Gibson,Alice Gillespie, for purposes of

mediation and drafting mediation memo.

2.20 $605.00
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10/24/2013 MJO Calculated itemized damages for Francine Gorskie, Randi Gray,

Melinda Griffus, Mary Hall, Laura Hammersley, Joanna Hardin,

Cynthia Harp, Janet Harper, Patsy Hayes, Lynsi Henson,

Maureen Hicks, Donna Jackson, Lorraine Jackson, Debra

Jones, Julie Jones, Naomi Joslin, Diane Joyner for purposes of

mediation and drafting mediation memo.

1.50 $412.50

10/24/2013 MJO Calculated itemized damages for Jodi Kabalin, Barbara Keenan,

Patricia Lawson, Elaine Leach, Julene Logue, Kathy Lucas,

Bobbi McMillin, Diane Martin, Tammy Martinez, Carey Miller,

Cathi Moore, Linda Morton, Jessalyn Myers, Penelope Miller,

Renee Nichols, Emily Oates, Charlene Palmer, Marie Plum,

Joyce Rataczak, Linda Reid, Parrish Ritchie for purposes of

mediation and mediation memo.

2.00 $550.00

10/24/2013 MJO Calculated itemized damages for Leslie Robertson, Eileen Roff,

Gina Rogers, Patricia Schmutz, Debra Seuell, Joy Sharp, Susan

Silver, Kathleen Simons, Paige Singleton, Wendolyn Smith,

Diane Spencer, Jacqueline Spires-Purdy, Tangela Tyran,

Barbara Vaughn, Carla Weiss, Connee Williams, Marilyn

Wilson, Robin York, Penny Zimmerman for purposes of

mediation and mediation memo.

1.50 $412.50

10/25/2013 MJO Left voicemail with Lisa Edwards, re: mediation. 0.10 $27.50

10/25/2013 MJO Calculated itemized damages for Kathryn Lacey, Mary

McClelland, Margaret Mackey, Kimberly Moore, Dawn

O’Connor, Catherine Probst, Krissy Reynolds, Les Rinehart,

Deborah Schneider, Christy Scott, Elaine Shortall; consulted

Transcend payroll records for payroll register/gross wages

earned and times of employment for purposes of mediation

and mediation memo.

3.50 $962.50

10/25/2013 MJO Drafted mediation memorandum, re: Damages; Plaintiff’s

calculation of damages for unpaid minimum wage and

overtime; the method Plaintiffs used to calculate damages for

unpaid minimum wage and overtime; the results of Plaintiffs

calculations based on Plaintiffs in the statistical reference

group of 101 class members.

2.00 $550.00

10/25/2013 MJO Drafted mediation memorandum, re: Damages; revised

minimum wage damages and overtime damage calculations

and explanations of the method by which damages for

minimum wage and overtime were calculated.

1.50 $412.50

10/26/2013 MJO Revised calculations of damages for all opt-in Plaintiffs who

worked the full statute of limitations period to reflect correct

number of weeks applicable to opt-in Plaintiffs since May

2010.

1.00 $275.00

10/26/2013 MJO Telephone call with named Plaintiff Lisa Edwards, re: updates

on lawsuit for purposes of preparing client for mediation

scheduled in Atlanta for 10/30.

0.50 $137.50

10/27/2013 MJO Revised/edited mediation memorandum, re: conducted

detailed sentence-by-sentence final examination of mediation

memorandum and implemented revisions to entire mediation

memorandum.

1.50 $412.50

10/27/2013 MJO Drafted opening statement for use of Attorney Kevin Dolley

during mediation scheduled for 10/30 in Atlanta.

1.50 $412.50

10/27/2013 MJO Analyzed and examined file for purposes of gathering useful

materials for use during mediation; consulted pleadings,

Plaintiff’s Motion for Conditional Certification and attached

exhibits, and numerous emails and communications received

from opt-in Plaintiffs since the close of the opt-in period.

2.00 $550.00

10/27/2013 MJO Analyzed and examined approximately 105 responses to

questionnaires received from opt-in Plaintiffs since the close

of the opt-in period for purposes of preparing for mediation;

analyzed and examined specific answers and gathered

questionnaire responses for use during mediation.

2.00 $550.00

10/28/2013 MJO Drafted discovery plan for stage 2 discovery. 1.00 $275.00

10/29/2013 KJD Travel St. Louis to Atlanta for mediation. 2.50 $1,125.00
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10/29/2013 KJD Prep for mediation, review damage calculations; prepare

opening.

5.00 $2,250.00

10/30/2013 KJD Prepare for mediation; review damages; opening; how to get

where we need to be; prepare strategy; Mediation in Atlanta

with Hunter Hughes; Travel back to St. Louis.

9.50 $4,275.00

11/01/2013 MJO Telephone call with chambers of Hon. Mary Rowland, re:

status hearing on Monday, Nov. 4.

0.20 $55.00

11/01/2013 MJO Drafted email to class members, re: updating class as to status

of lawsuit after mediation on Oct. 30.

0.50 $137.50

11/02/2013 MJO Drafted and sent email to class members updating them re:

status of lawsuit post-mediation.

0.80 $220.00

11/04/2013 MJO Telephone status hearing with Hon. Mary Rowland. 0.20 $55.00

11/04/2013 MJO Phone call with Linda Mathias, re: case status update. 0.50 $137.50

11/05/2013 MJO Instructed contract attorney Joseph Leach, re: status of case

and background information; gathering list of 15 proposed

deponents and creating file for each.

0.50 $137.50

11/05/2013 MJO Analyzed and examined numerous emails and documents sent

from opt-in Plaintiff Rebecca Nagy.

0.50 $137.50

11/05/2013 CA Examined memo and began analyzing client questionnaires for

the purpose of organizing deposition candidates; finished up

making client files; determined the final 15 deposition

candidates; searched optin email address for additional

correspondence from clients; printed off correspndence and

put correspondence

8.50 $1,912.50

11/07/2013 MJO Drafted email for attorney Kevin Dolley, re: response to

opposing counsel follow-up inquiry concerning our list of

individuals for deposition.

0.40 $110.00

11/07/2013 MJO Meeting with attorney Josh Leach, re: provided instructions

concerning updated deficiency letter to send to opposing

counsel and drafting Second Set of Interrogatories and

Requests for Production to Defendant.

0.50 $137.50

11/07/2013 MJO Drafted Memorandum to attorney Josh Leach, re: provided

instructions for drafting updated deficiency letter.

0.50 $137.50

11/07/2013 CA Examined interrogatories and responses to interrogatories for

the purpose of drafting a deficiency letter.

5.25 $1,181.25

11/08/2013 MJO Drafted memorandum to attorney Josh Leach, re: drafting

Plaintiff’s Second Set of Interrogatories and Requests for

Production.

0.50 $137.50

11/08/2013 MJO Meeting with Josh Leach, re: drafting Plaintiff’s Second Set of

Interrogatories and Requests for Production; discussed

relevant interrogatories and requests for production.

0.50 $137.50

11/08/2013 MJO Drafted revisions to updated deficiency letter, re: remaining

deficiencies in Defendant’s responses to Interrogatories 2, 3,

4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 19, 20.

2.50 $687.50

11/08/2013 CA Continued drafting deficiency letter. Examined interrogatories

and responses to interrogatories, as well request for

production and the response to request for production for the

purpose of drafting a second set of interrogatories and a

second set of requests for documents.

6.75 $1,518.75

11/09/2013 MJO Revised deficiency letter addressed to opposing counsel, re:

marked up changes to be made to deficiencies in Defendant’s

response to Interrogatories No. 2, 3, 4, 19, and 20 and sent

back to attorney Josh Leach for correction.

0.80 $220.00

11/09/2013 MJO Revised deficiency letter addressed to opposing counsel, re:

marked up changes to be made to deficiencies in Defendant’s

response to Interrogatories No. 2, 3, 4, 19, and 20 and sent

back to attorney Josh Leach for correction.

0.80 $220.00

11/09/2013 CA Continued drafting Second set of requests for documents.

Clean up on secnd set of interrogatories.

3.25 $731.25

11/10/2013 CA Clean up on second set of of request for documents. Revise

deficiency letter.

2.25 $506.25

11/12/2013 MJO Meeting with attorney Josh Leach, re: adding names to 0.20 $55.00
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damages spreadsheet and strategy for calling former regional

manager of Transcend who is opt-in class member.

11/12/2013 MJO Telephone conversation with opt-in plaintiff Claudia Franklin,

re: update on status of lawsuit.

0.30 $82.50

11/12/2013 MJO Emailed opt-in Plaintiff Claudia Franklin, re: initial

questionnaire and update on lawsuit.

0.10 $27.50

11/12/2013 MJO Drafted and revised updated deficiency letter addressed to

opposing counsel, re: revised introduction to letter;

deficiencies in Defendant’s Response to Plaintiff’s First Set of

Interrogatories, No. 2, 3, 4, 5, 7, 8.

1.80 $495.00

11/12/2013 MJO Drafted and revised updated deficiency letter addressed to

opposing counsel, re: revised introduction to letter;

deficiencies in Defendant’s Response to Plaintiff’s First Set of

Interrogatories, No. 9, 10, 11, 12, 13, 14.

1.50 $412.50

11/12/2013 MJO Drafted and revised updated deficiency letter addressed to

opposing counsel, re: revised introduction to letter;

deficiencies in Defendant’s Response to Plaintiff’s First Set of

Interrogatories, No. 15, 16, 19, 20.

1.00 $275.00

11/12/2013 MJO Drafted Plaintiffs’ Second Set of Interrogatories Directed To

Defendant, re: drafted Interrogatories No. 1-12 pertaining to

class members supervisors; all methods of timekeeping applied

to class members; individuals implementing timekeeping

policies; software platforms used by each class member;

individuals responsible for implementing compensation

policies; preservation policies and techniques implemented by

Transcend; individuals in charge of monitoring preservation

techniques/policies; methods used for recording payroll;

identification of electronic custodians.

2.00 $550.00

11/12/2013 MJO Revised email to opposing counsel, re: amendment to

scheduling order and limited individualized discovery.

0.50 $137.50

11/12/2013 CA Updated opt-in plaintiff list in excel: Examined opt-ins not yet

calculated and began to calculate; Updated opt-in plaintiff list

in excel: Examined opt-ins not yet calculated and began to

calculate. Also examined questionnaires for new potential

depo candidates;

5.00 $1,125.00

11/13/2013 MJO Meeting with attorney Josh Leach, re: progress on review of

emails; memorandum detailing conversation with opt-in class

member who was training manager/coordinator.

0.50 $137.50

11/13/2013 CA Updated opt-in plaintiff list in excel: Examined opt-ins not yet

calculated and began to calculate; Updated opt-in plaintiff list

in excel: Examined opt-ins not yet calculated and began to

calculate. Also examined questionnaires for new potential

depo candidates;

7.00 $1,575.00

11/13/2013 CA Drafted memo re: phone conversation with Laurie Leiker. 1.00 $225.00

11/14/2013 MJO Revised dates within deficiency letter and sent to opposing

counsel.

0.20 $55.00

11/14/2013 MJO Emailed opposing counsel, re: amending scheduling plan. 0.10 $27.50

11/14/2013 MJO Examined, analyzed, and annotated Defendant’s Responses

and Objections to Plaintiffs’ First Set of Requests for

Production, re: for purposes of drafting deficiency letter to

opposing counsel for deficiencies in Defendant’s Responses

and Objections to Plaintiff’s Requests for Production.

1.00 $275.00

11/14/2013 MJO Drafted email to opposing counsel for review of Attorney

Kevin Dolley, re: scheduling order for individualized discovery.

0.50 $137.50

11/14/2013 MJO Analyzed and examined questionnaires of Tammy ShulerWilliams, Diane Martin, Parrish Ritchie, Kandance Chancey,

Laura Denio, Barbara Vaughn, Patricia Rapp, Debra Barry, Julie

Wright, and Tanya Mixon for purposes of choosing best

candidates for presentation as witnesses/deponents.

1.00 $275.00

11/14/2013 CA Continued examining email documents of Deanna Garcia.

Continued sorting these documents in categories and folders.

7.75 $1,743.75

11/15/2013 MJO Meeting with attorney Josh Leach, re: how to contact 0.30 $82.50
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11/15/2013 MJO

plaintiffs to inquire concerning depositions.

Drafted/Revised deficiency letter to opposing counsel 1.00 $275.00

concerning deficiencies in response to Plaintiffs’ First Set of

Interrogatories.

11/15/2013 MJO Drafted/revised Email to opposing counsel Tracey Ellerson for

review of Attorney Kevin Dolley.

0.50 $137.50

11/15/2013 MJO Drafted/Revised Plaintiffs’ Second Set of Requests for

Production, re: Requests for Production No. 1-23.

2.50 $687.50

11/15/2013 MJO Drafted outline of Response in Opposition to Defendant’s

Motion to Compel, re: Defendant unnecessarily delayed

initiating individualized discovery; Defendant mistakenly

blames Plaintiffs for its own delay; Defendant Cannot Rely On

Its Untimely Production Of “Payroll Data” As A Justification For

Not Pursuing Individualized Discovery At An Earlier Date;

Plaintiffs Proposed A Reasonable Alternative Plan In Good

Faith; Defendant Provides No Legal Or Factual Basis For

Compelling Plaintiffs To Respond To Written Discovery

Requests In Fifteen (15) Days.

1.50 $412.50

11/16/2013 MJO Meeting with Attorney Michael Kruse, re: provided instructions

concerning drafting Plaintiff’s Motion to Compel Payroll/Time

records.

0.50 $137.50

11/16/2013 MJO Drafted Plaintiffs’ Second Set of Requests for Production

Directed to Defendants, re: drafted Requests for Production

No. 24-69.

3.20 $880.00

11/16/2013 CA Meeting with MJO re update on case; called list of opt in

Plaintiff deposition candidates to determine five candidates

well suited and willing to testify deposition; edit second set of

interrogatories; subtracted and added several interrogatories,

re-wrote several more.

8.00 $1,800.00

11/16/2013 CA Examined opposing counsel's motion to compel and attached

exhibits in preparation of drafting a response to the motion to

compel; began drafting a response to opposing counsel's

motion to compel.

4.50 $1,012.50

11/16/2013 MRK Discussion with MJO re motion to compel in Transcend,

discussion of what was produced on the disks, discussion of

what remained deficient, review of communication between

the parties.

1.40 $315.00

11/17/2013 MJO Drafted outline of Response in Opposition to Defendant’s

Motion to Compel, re: Defendant unnecessarily delayed

initiating individualized discovery; Defendant mistakenly

blames Plaintiffs for its own delay; Defendant Cannot Rely On

Its Untimely Production Of “Payroll Data” As A Justification For

Not Pursuing Individualized Discovery At An Earlier Date;

Plaintiffs Proposed A Reasonable Alternative Plan In Good

Faith; Defendant Provides No Legal Or Factual Basis For

Compelling Plaintiffs To Respond To Written Discovery

Requests In Fifteen (15) Days.

2.50 $687.50

11/18/2013 MJO Emailed local counsel and court reporter, re: transcript for

Aug. 20, 2013 status hearing.

0.30 $82.50

11/18/2013 MJO Telephone call with court reporter, re: transcript for Aug. 20,

2013 status hearing.

0.20 $55.00

11/18/2013 MJO Drafted/revised Plaintiffs’ Response to Defendant’s Motion to

Compel, re: Introduction; Defendant Unnecessarily Delayed

Initiating Individualized Discovery Until Nov. 1, 2013;

Defendant Mistakenly Blames Plaintiffs For Its Own Delay;

Defendant Cannot Rely on its untimely production of “payroll

data” as justification for its delay in pursuing individualized

discovery.

1.50 $412.50

11/18/2013 MJO Drafted/revised Plaintiffs’ Motion to Compel Defendant’s

Production of All Timekeeping And Payroll Information Of

Class Members, re: compliance with Local Rule 37.2;

Introduction; the timekeeping and payroll information

allegedly on Disc One and Disc 2 is wholly deficient; made

1.50 $412.50
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corrections and re-submitted to attorney Michael Kruse for

revisions.

11/18/2013 CRM Revise Response in Opposition to Defendant's Motion to

Compel

0.70 $192.50

11/18/2013 KJD Review and edit response to motion to compel. 1.00 $450.00

11/18/2013 CA Meeting with MJO to Discuss updates on response to motion

to compel, and our second set of interrogatories and requests

for production; examined Transcend email folder for new

emails and questionnaires. Added several questionnaires to the

spreadsheet.

6.25 $1,406.25

11/18/2013 MRK Review of email correspondence between parties, review of

spreadsheets produced, review of case law on production

requirements, review of R. 34 to determine if production had

to be useful; drafting of motion to compel relating to the ESI

containing payroll information and timekeeping information

3.40 $765.00

11/19/2013 MJO Revised/drafted Response in Opposition to Motion to Compel

and filed with court.

0.30 $82.50

11/19/2013 MJO Meeting with Attorney Kevin Dolley, re: revisions to make to

Motion to Compel Timekeeping and Payroll Records.

0.50 $137.50

11/19/2013 MJO Drafted/revised Motion to Compel, re: added case law to legal

analysis and inserted foundations for exhibits.

1.00 $275.00

11/19/2013 KJD Review and edit motion to compel. 3.00 $1,350.00

11/19/2013 KJD Review motions response, prepare for status conference. 2.00 $900.00

11/19/2013 CA Finished revising and deleting interrogatories to reduce

number from 21 down to five. Began revising and deleting

requests for production to reduce number by 31; continued

going through previously unread emails of Deanna Garcia and

worked on categorizing them.

8.25 $1,856.25

11/19/2013 MRK Revision of Motion to compel for general stylistic and

content purposes;Final revisions to Motion to Compel;

research re case law on production of payroll and time records

in wage and hour cases, marking and revision of exhibits to

include with motion to compel; Drafting on Motion to Compel

relating to accessibility of discovery responses and

interpretation of documents produced by Defendants;

2.50 $562.50

11/20/2013 MJO Telephone call with Attorney Kevin Dolley, re: re-scheduling of

status hearing.

0.20 $55.00

11/20/2013 MJO Meeting with attorney Josh Leach, re: responding to

Defendant’s Interrogatories and Requests for Production.

0.50 $137.50

11/20/2013 KJD Travel to Chicago for hearing; Appear for hearing, meet with

deputy clerk; Tavel back to STL.

5.50 $2,475.00

11/20/2013 CA Examined numerous emails from Jeannie Purcell; Began

calling Plaintiffs chosen by opposing counsel to answer

discovery requests; took down and transcribed their answers;

began drafting individual responses to interrogatories based

on the plaintiffs who had responded so far.

6.75 $1,518.75

11/21/2013 CA Continued drafting individual responses to interrogatories. 7.00 $1,575.00

11/22/2013 MJO Drafted/revised Plaintiffs’ Second Set of Interrogatories and

Requests for Production Directed To Defendant.

1.30 $357.50

11/23/2013 CA Continued drafting individual responses to interrogatories and

requests for production; meeting with Mark to discuss the

progress of discovery; added two names to the damages

spreadsheet.

4.50 $1,012.50

11/25/2013 KJD Review second discovery requests to defendant. 1.00 $450.00

11/25/2013 CA Called several members of the class and scheduled phone

appointments for interrogatories; interrogatory phone call with

Carla Ingraham; Wrote letters for each person who had not

responded to phone or email messages;

7.00 $1,575.00

11/25/2013 JES Meet on Transcend. 0.40 $90.00

11/26/2013 MJO Meeting with Attorneys Josh Leach and Kyle O'Driscoll, re:

additonal individuals to propose for individualized discovery.

1.00 $275.00
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11/26/2013 MJO Revised cover letters to Melissa Adelson, Kathleen Burke, Jason

Hoffmann, and Teresa Pemerton.

0.50 $137.50

11/26/2013 MJO Telephone call with opt-in Plaintiff Joyce Baena, re: for

purposes of drafting Plaintiff's Responses and Objections to

Defendant's Interrogatories and Requests for Production.

0.70 $192.50

11/26/2013 MJO Emailed OC, re: five remaining proposed individuals fo

rindividualized discovery and telephone call concerning

explanation of payroll records/Microsoft Excel Spreadsheet.

0.20 $55.00

11/26/2013 MJO Prepared for telephone conference with opposing counsel, re:

analyzed and examined payroll registers and Microsoft Excel

printout provided by Defendant for opt-in Plaintiff Janeen

DeBoard.

0.60 $165.00

11/26/2013 CRM Phone hearing re: cross motions to compel 1.80 $495.00

11/26/2013 CRM Relay Motion to compel results to attorney M.

Obermeyer and associates

0.20 $55.00

11/26/2013 KJD Prepare for Motion hearings, Plaintiff's and Defendant's

Motions to Compel; Extended Motion hearing with Magistrate.

Address number of depos for remainder of Discovery of

Plaintiff's and Plaintiff's Motion to compel regarding wage and

hour documents, production/compliance.;

4.00 $1,800.00

11/26/2013 CA Discuss with MJO and Josh what to focus on with Transcend;

Review already completed responses to discovery in prep of

drafting discvery responses; begin drafting responses to

discovery; prep for calling class rep to complete discovery

responses; organize discovery responses by name, already

responded and need responses; prepare list of class members

who need to respond or send documents; Call class members

that we need documents from;

6.50 $1,462.50

11/26/2013 JES Met with KD re: hearing at 10:30 and discovery matters. 2.40 $540.00

11/27/2013 MJO Telephone conference with opposing counsel Greg Mersol and

paralegal Susan Fortune, re: analyzing and making sense of

payroll data provided by Defendant.

1.00 $275.00

11/27/2013 MJO Meeting with Attorneys Josh Leach and Kyle O’Driscoll, re:

status of discovery responses for Joy McLemore, Carla

Ingraham-Gaughan, Mary Hall, Jacqueline St. Georges, Joy

Anderson, Judith Lindquist, Diane Spencer, and Darcy

Wingler.

1.00 $275.00

11/27/2013 MJO Meeting with Attorney Jon Skrabacz, re: allegations in lawsuit,

discovery strategy, properly answering interrogatories and

requests for production for remaining opt-in Plaintiffs.

1.00 $275.00

11/27/2013 MJO Revised/drafted Plaintiff Joy McLemore’s Responses and

Objections to Defendant’s First Set of Interrogatories.

0.70 $192.50

11/27/2013 MJO Revised/drafted Plaintiff Laura Denio’s Responses and

Objections to Defendant’s First Set of Interrogatories.

0.50 $137.50

11/27/2013 MJO Revised/drafted Plaintiff Joy Anderson’s Responses and

Objections to Defendant’s First Set of Interrogatories.

0.50 $137.50

11/27/2013 KJD Review with MJO the depo schedule and discovery status;

Motion in Limine, review and coordinate deposition schedule.

1.00 $450.00

11/27/2013 CA Interrogatory phone call with Jacqueline St. Georges;

Continued drafting individual responses to requests for

production and responses to interrogatories; meeting with

MJO to discuss progress of the interrogatories and requests for

production; sent out emails to individual class members

asking them to review their interrogatories and sign the

verification forms; produced hard copies of individual.

13.90 $3,127.50

11/29/2013 JES Prepared for a phone call with Julie Wright re: discovery by

reading through her questionnaire and preparing the Irrogs

and RFP for her; participated in a phone call with the client in

order to gather information for discovery from her.

2.70 $607.50

12/01/2013 KJD Prepare subpoena of ADP; Prepare rule 30(b) Noted

Transcend payroll/ timekeeping.

5.50 $2,475.00

12/02/2013 JMF Formatting Corp. Rep Depo related to Timesaver; Corp. Rep 10.80 $2,430.00
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Depo related to interrogatory responses; Corp Rep Depo

related o Miscellaneous prior Deposition documents; Collate

and edit and condense and revise all pertinent Corp. Rep.

Depo to 30(b)(6) Designation Draft.

12/02/2013 KJD Draft and edit depo topics; Depo prep, prepare exhibits and

documents; Draft subpeonas and depo topics and prep for

ADP corp and Ferrell Depo.

7.00 $3,150.00

12/02/2013 CA Contact class representative Debra Jones via phone call re

discovery responses; discuss interrogatories with class rep re

information needed; draft word doc of questions that need

responses; review draft with mjo; email list of questions to

Debra Jones; begin drafting response to interrogatories;

Attempted to contact class reps via telephone re discovery

responses; left voicemails; Download documents sent by class

rep Diane Martin from email; convert docs into single pdf;

bate stamp exhibits; Updated/continued working on

interrogatories and requests for production;Interrogatory

phone call with Sheila Reeser;

12.50 $2,812.50

12/03/2013 JMF Corp Rep Depo Prep- drafting and organizing questions

related to power point document; Corp Rep Depo Prep

planning and outlining.

5.70 $1,282.50

12/03/2013 KJD Prep for Corp Rep Depo. 3.00 $1,350.00

12/03/2013 CA Updated/continued working on interrogatories and requests

for production for 5 members due on Dec. 5th; phone calls to

5 members due on Dec 5th asking for verification pages and

information updates; Document collation and bates

numbering for Diane Spencer and Mary Hall.

12.30 $2,767.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Mary Hall, re: revised/edited Interrogatories No. 1-16.

0.80 $220.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Mary Hall, re:

revised/edited RFP No. 1-28.

0.50 $137.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Joy McLemore, re: revised/edited Interrogatories No. 1-16.

1.00 $275.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Joy McLemore, re:

revised/edited RFP No. 1-28.

0.50 $137.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Sheila Reeser, re: revised/edited Interrogatories No. 1-16.

1.00 $275.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Sheila Reeser, re:

revised/edited RFP No. 1-28.

0.50 $137.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Carla Ingraham-Gaughan, re: revised/edited Interrogatories

No. 1-16.

1.00 $275.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Carla IngrahamGaughan, re: revised/edited RFP No. 1-28.

0.50 $137.50

12/04/2013 MJO Phone call with opposing counsel Greg Mersol, re: access to

Earnings Statements for Plaintiffs.

0.30 $82.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Diane Spencer, re: revised/edited Interrogatories No. 1-16.

0.80 $220.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Diane Spencer, re:

revised/edited RFP No. 1-28.

0.50 $137.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Judy Lindquist, re: revised/edited Interrogatories No. 1-16.

1.00 $275.00

12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Judy Lindquist, re:

revised/edited RFP No. 1-28.

1.30 $357.50

12/04/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Diane Martin, re: revised/edited Interrogatories No. 1-16.

0.80 $220.00
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12/04/2013 MJO Drafted/revised Responses and Objections to Defendant’s First

Set of Requests for Production Directed to Diane Martin, re:

revised/edited RFP No. 1-28.

2.00 $550.00

12/04/2013 JMF 30(b)(6) motion - expanded general motion

drafting/editing/revising;

8.00 $1,800.00

12/04/2013 CA Updated/ continued working on interrogatories and requests

for production for 5 members due on Dec. 5th; Repeat phone

calls and emails to 5 members due on Dec 5th asking for

verification pages and information updates; Re-Bates

numbering for Denio; Reviewed Diane Martin docs; began

working on interrogatories and requests for production for

Julie Wright; Phone calls to Patria Rapp and Julie Wright.

12.90 $2,902.50

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

for Mary Hall, re: final revisions to Interrogatories No. 1-16

and Requests for Production No. 1-28.

0.50 $137.50

12/05/2013 MJO Telephone call with opt-in Plaintiff Carla Ingraham-Gaughan,

re: revising and re-drafting Responses and Objections to

Interrogatories No. 1-16.

1.00 $275.00

12/05/2013 MJO Drafted/revised Responses and Interrogatories for Carla

Ingraham-Gaughan, re: Interrogatories No. 1-16.

0.70 $192.50

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

and Requests for Production for Joy McLemore, re: final

revisions to Interrogatories No. 1-16 and Requests for

Production 1-28.

0.50 $137.50

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

and Requests for Production for Sheila Reeser, re: final

revisions to Interrogatories No. 1-16 and Requests for

Production 1-28.

0.50 $137.50

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

and Requests for Production for Diane Spencer, re: final

revisions to Interrogatories No. 1-16 and Requests for

Production 1-28.

0.80 $220.00

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

and Requests for Production for Judy Lindquist, re: final

revisions to Interrogatories No. 1-16 and Requests for

Production 1-28.

1.00 $275.00

12/05/2013 MJO Drafted/revised Responses and Objections to Interrogatories

and Requests for Production for Diane Martin, re: final

revisions to Interrogatories No. 1-16 and Requests for

Production 1-28.

1.50 $412.50

12/05/2013 MJO Drafted 7 emails to opposing counsel, re: discovery responses

for Mary Hall, Carla Ingraham-Gaughan, Joy McLemore, Sheila

Reeser, Diane Spencer, Judy Lindquist, and Diane Martin.

0.50 $137.50

12/05/2013 MJO Drafted correspondence to opposing counsel for attachment

to first set of responses and objections to Defendant’s

discovery requests.

0.20 $55.00

12/05/2013 JMF 30(b)(6) motion - expanded general motion

drafting/editing/revising; status hearing prep - file

organization, review, document pull.

5.00 $1,125.00

12/05/2013 KJD Hearing prep, review docs, records for demonstration of

missing doc production.

1.50 $675.00

12/05/2013 CA Search emails from Diane Marin for information needed to

complete discovery responses; revise irog responses with

additional information; download documents from class rep

Denio; compile into PDF file; batestamp for use as exhibits for

discovery responses; call class rep Diane Martin, re:

verification page; discussion with MJO, re: what needs to be

completed and send out today for Transcend; detailed review

of drafts of discovery responses for grammar and spelling

errors, proper information in prep for sending out.

13.25 $2,981.25

12/06/2013 MJO Meeting with Attorneys Josh Leach and Kyle O’Driscoll, re: 0.50 $137.50
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strategy for conducting written discovery responses for 14

remaining individuals.

12/06/2013 JMF 30(b)(6) motion - expanded general motion

drafting/editing/revising

3.00 $675.00

12/06/2013 KJD Travel STL to airport and cab to court; travel court to airport

to STL office; Hearing before Magistrate, re: Discussion;

Dictate, draft, edit report as to discovery, Defendant

production status following hearing; Draft, edit create report

of scheduling conference.

7.75 $3,487.50

12/06/2013 CA Meeting with MJO; Created word document with the names

and statues of all the current participating members; called

and sent emails out to Tereasa Pemerton, Patricia Rapp and

Patsy Hayes; Bates stamped Patricia Rapp Documents;

examined Patricia Rapp emails; continued working on

interrogatories and requests for production for remaining

members;

12.75 $2,868.75

12/09/2013 MJO Meeting with Attorneys Kyle O’Driscoll and Josh Leach, re:

updated on status of deposition dates for clients and

responses to discovery for clients due 12/18 and 12/19.

0.50 $137.50

12/09/2013 MJO Phone call with Russ Riggan, re: deposition preparation and

scheduling of depositions.

1.00 $275.00

12/09/2013 MJO Drafted deposition schedule for deponents Diane Martin,

Kandace Chancey, Julie Wright, Patsy Hayes, Judy Lindquist,

Laura Denio, Darcy Wingler, Joy McLemore.

0.50 $137.50

12/09/2013 MJO Meeting with Attorney Kevin Dolley and Attorney Jon

Skrabacz, re: deposition scheduling of opt-in Plaintiffs and

strategy for defending depositions.

1.20 $330.00

12/09/2013 MJO Drafted email to co-counsel Russ Riggan, re: deposition

scheduled for Dec. 23 and strategy/schedule for deposing

individuals in Texas.

0.50 $137.50

12/09/2013 CA Draft responses to defendant's discovery request using

information from conversation with class reps; discussion wit

MJO and josh re status of class rep discovery responses,

deposition availability dates; draft responses to defendant's

discovery request using information from conversation with

class reps.; compile docs from class rep Chancey into single

pdf, bates number for use as exhibit in discovery responses;

draft response to request for production for class reps.

14.90 $3,352.50

12/10/2013 MJO Telephone call with Attorney Russ Riggan, re: scheduling

depositions in Texas and Florida.

0.20 $55.00

12/10/2013 MJO Drafted and configured updated deposition schedule for

Plaintiffs Patricia Rapp, Patsy Hayes, Diane Martin, Wendolyn

Smith, Julie Wright, Laura Denio, Darcy Wingler, Sheila

Reeser, Janeen DeBoard, Barbara Keenan, Judy Lindquist, Joy

McLemore, Barbara Vaughn.

1.50 $412.50

12/10/2013 MJO Emailed opposing counsel, re: update on deposition schedule. 0.10 $27.50

12/10/2013 MJO Reviewed/revised Responses and Objections to Interrogatories

and Requests for Production for Plaintiff Kandace Chancey.

1.70 $467.50

12/10/2013 MJO Reviewed/revised Responses and Objections to Interrogatories

and Requests for Production for Plaintiff Jacqueline St.

Georges.

1.50 $412.50

12/10/2013 MJO Drafted email to Greg Mersol for review of Attorney Kevin

Dolley.

0.50 $137.50

12/10/2013 CA Check optin email for any correspondence from class reps;

Responding to defendant’s discovery requests; contacting

class reps re discovery responses; downloading documents

sent in by class reps; drafting responses to interrogatories and

request for production; checking deposition availability dates,

verifying deposition dates; send class reps email, re: discovery

responses and verification page; Discussion with mjo and josh

leach re current status of discovery responses;Contacting class

reps, re: Discovery responses; drafting responses to

interrogatories and request for production; checking

12.50 $2,812.50
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deposition availability dates; send class reps email, re:

discovery responses and verification page; Contact class reps

to verify deposition dates, availability for prep; Called people

on list to confirm individual deposition.

12/11/2013 MJO Revised/drafted Responses and Objections to Interrogatories

and Requests for Production Directed to Patricia Rapp, re:

Interrogatories No. 1­16; Requests for Production No. 1-26.

1.50 $412.50

12/11/2013 MJO Revised/drafted Responses and Objections to Interrogatories

Directed to Darcy Wingler, re: Interrogatories No. 1­16;

Requests for Production No. 1-26.

1.20 $330.00

12/11/2013 MJO Drafted email to opposing counsel, re: discovery responses for

Patricia Rapp Interrogatories No. 1­16; Requests for

Production No. 1-26.

0.30 $82.50

12/11/2013 MJO Revised/drafted Responses and Objections to Interrogatories

Directed to Joy Anderson, re: Interrogatories No. 1­16;

Requests for Production No. 1-26.

1.00 $275.00

12/11/2013 JMF Corp Rep Depo Prep- outline, document review, prep

questions.

7.00 $1,575.00

12/11/2013 CA Check optin email for any correspondence from class reps;

revise interrogatories based on information provided by class

rep Chancey; discussion with MJO re: finalizing discovery

responses; call class rep to verify depo date.

12.70 $2,857.50

12/12/2013 MJO Meeting with Attorneys Kyle O’Driscoll and Josh Leach, re:

Defendant’s document production.

0.50 $137.50

12/12/2013 MJO Telephone call with co-counsel Russ Riggan, re: depositions in

Florida and Texas.

0.50 $137.50

12/12/2013 MJO Emailed co-counsel Russ Riggan, re: depositions in Texas,

Florida, and Georgia.

0.30 $82.50

12/12/2013 JMF Corp Rep Depo Prep- outline, document review, prep

questions.

2.40 $540.00

12/12/2013 CA Download discovery documents provided by defendant;

review documents received from defendant, determine which

documents we were not able to access; print off documents

received from defendant; contact class reps re reviewing

interrogatory responses and completing verification page, left

voicemail for those unable to reach, send email; worked on

Ptsy Hayes RFPs

11.30 $2,542.50

12/13/2013 MJO Revised/drafted Responses to Interrogatories No. 1-5 for

Plaintiff Kandace Chancey.

0.70 $192.50

12/13/2013 MJO Telephone call with opposing counsel Greg Mersol, re:

scheduling depositions.

0.40 $110.00

12/13/2013 MJO Emailed opposing counsel Greg Mersol, re: notice of corporate

designee deposition.

0.30 $82.50

12/13/2013 MJO Drafted/revised Responses to Interrogatories No. 5-16 and

Responses to Requests for Production for Plaintiff Kandace

Chancey.

1.50 $412.50

12/13/2013 JMF Corp Rep Deposition preparation; prepare file of corp Rep

Deposition prep to transfer to Jon.

2.90 $652.50

12/13/2013 CA Phone calls and emails to members of class; document

production printing out and organizing continued working on

interrogatories and requests for production; drafted specific

emails about verification forms and sent them out to each

person we don't have a verification form for. Also drafted an

email for the entire group; created sheet identifying status

updates of class members.

9.30 $2,092.50

12/15/2013 MJO Drafted assignment memorandum for attorneys Josh Leach

and Kyle O’Driscoll, re: review of documents produced by

Defendant to ensure compliance with Dec. 6 court order.

0.50 $137.50

12/16/2013 MJO Telephone call with Russ Riggan, re: deposition scheduling in

FL, TX, and MO.

0.50 $137.50

12/16/2013 MJO Phone call with Patricia Rapp, re: deposition preparation 1.00 $275.00
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availability in Chicago; facts of case specific to Ms. Rapp; Ms.

Rapp’s hours work; Ms. Rapp’s experience with ADP/Timesaver

log-in functions.

12/16/2013 MJO Meeting with attorney Jonathan Skrabacz, re: questions to ask

during representative of Defendant’s corporate representative

concerning redacted payroll documents produced by

Defendant.

0.50 $137.50

12/16/2013 MJO Drafted/reviewed/revised Responses and Objections to

Defendant’s Interrogatories and Requests for Production

Directed to Plaintiff Wendolyn Smith; reviewed approximately

91 pages of documents to be produced by Plaintiff Smith.

1.30 $357.50

12/16/2013 MJO Drafted/reviewed/revised Responses and Objections to

Defendant’s Interrogatories and Requests for Production

Directed to Plaintiff Wendolyn Smith; reviewed approximately

91 pages of documents to be produced by Plaintiff Smith.

1.00 $275.00

12/16/2013 CRM Meeting with Attorney K. Dolley, re: Rule 30(b)(6) Notice 0.30 $82.50

12/16/2013 CRM Revise 30(b)(6) deposition notice drawing on

questionnaire responses and developing ESI topics

2.70 $742.50

12/16/2013 KJD Deposition travel from STL to Hartfod. 4.50 $2,025.00

12/16/2013 JES Started copies of documents for corp rep depo; continued

Lugo; started copies of documents for corp rep

depo; continued Lugo document punch edits; drafted chapter

re: earnings code info for the corp rep depo; drafted chapter

re: equipment loan and software agreement; met with MO re:

questions for documents used in depos; drafted chapter re:

makeup to date report example.

8.00 $1,800.00

12/17/2013 MJO Emailed co-counsel Russ Riggan, re: deposition availability of

FL and TX deponents.

0.70 $192.50

12/17/2013 MJO Emailed opt-in Plaintiff Patricia Rapp, re: notice of deposition

and coordinating time to prep witness on 12/19.

0.20 $55.00

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Barbara Vaughn.

1.20 $330.00

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Janeen DeBoard.

1.00 $275.00

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories Directed to Joy Anderson.

0.80 $220.00

12/17/2013 MJO Phone call with Patricia Rapp, re: deposition preparation

meeting on 12/19 and deposition 12/20.

0.40 $110.00

12/17/2013 MJO Phone conference with Kevin Dolley, re: corporate

representative deposition.

0.80 $220.00

12/17/2013 MJO Reviewed/revised Responses and Objections to Requests for

Production and documents produced by Plaintiff Joy

Anderson.

0.50 $137.50

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Julie Wright.

1.50 $412.50

12/17/2013 MJO Analyzed and examined documents to be produced by

Plaintiff Julie Wright.

0.50 $137.50

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Laura Denio.

1.50 $412.50

12/17/2013 MJO Analyzed and examined documents to be produced by

Plaintiff Laura Denio.

0.50 $137.50

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Patsy Hayes.

0.80 $220.00

12/17/2013 MJO Drafted/revised/reviewed Responses and Objections to First

Set of Interrogatories and Requests for Production Directed to

Jacqueline St. Georges.

1.00 $275.00
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12/17/2013 KJD Prep for Corp Designee Deposition. Extensive document

review related to exhibits for deposition, extensive review of

chapters of questions, detailed preparation of depo questions,

extensive review of docs and detailed review of pleadings.

Defendant written discovery responses, Plaintiff questionnaires

prior depos of Plaintiffs.

14.00 $6,300.00

12/17/2013 CA Examined, categorized, and checked for production

documents produced by Defendant; created sheet listing what

had been produced for each of the 21 deposition candidates;

drafted emails and made phone calls to the remaining persons

we have not been able to contact in regard to their

verification pages and deposition dates; updated verification

list document and deposition list document; organized

previously examined discovery; edited and updated document

production lists, class member information list, and deposition

contact list.

14.50 $3,262.50

12/17/2013 CA Review which class reps have provided verification pages for

discovery responses; contact class reps who have yet to

submit verification; contact new class reps in order to

complete discovery responses, left voicemail, sent email;

continue preparing discovery responses, compiling documents

for class reps, draft responses to irogs/rfp; contact class reps

re verification pages; draft letter to be mailed to class reps

requesting participation with discovery responses.

14.50 $3,262.50

12/17/2013 JES Discussed scanning documents into computer with Morgan;

reviewed D's motion in limine that requires a response from

us; finished final set of questions re: spreadsheets for Corp

Rep Depo; Put scanned documents into folders in dropbox

with corresponding questions; worked on non-document

related questions for corp rep depo; put scanned documents

into folders in dropbox with corresponding questions.

9.10 $2,047.50

12/18/2013 MJO Telephone call with co-counsel Samuel Moore, re: scheduling

FL depositions.

0.30 $82.50

12/18/2013 MJO Telephone call with Attorney Kevin Dolley, re: preparation of

outline for corporate representative deposition.

0.70 $192.50

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Joy Anderson.

0.50 $137.50

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Kandace Chancey.

0.30 $82.50

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Janeen DeBoard.

0.80 $220.00

12/18/2013 MJO Emailed Attorney Sam Moore, re: deposition of Jacqueline St.

Georges in Florida.

0.10 $27.50

12/18/2013 MJO Telephone call with Sam Moore, re: deposition of Jacqueline

St. Georges in Florida.

0.20 $55.00

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Laura Denio.

1.00 $275.00

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Patsy Hayes.

0.50 $137.50

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Wendolyn Smith.

0.80 $220.00

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Jacqueline St. Georges.

0.50 $137.50

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

1.50 $412.50
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12/18/2013 MJO

Plaintiff Barbara Vaughn.

Conducted final revisions to Responses and Objections to 1.00 $275.00

Interrogatories and Requests for Production Directed to

Plaintiff Darcy Wingler.

12/18/2013 MJO Conducted final revisions to Responses and Objections to

Interrogatories and Requests for Production Directed to

Plaintiff Julie Wright.

1.00 $275.00

12/18/2013 MJO Drafted chapters, re: notice of corporate rep deposition

outline, re: chapters and agreement entered between

Transcend and ADP; introduction questions for document

chapters concerning equipment loan and software agreements

and Time Log with Edits documents.

1.50 $412.50

12/18/2013 KJD Prepared for corp. designee depo, reviewed extentive

information related to time, attendance, wage and hour and

payroll information. Drafted 60 Chapters containing detailed

questioning per chapter related to topics for depo. Reviewed

documents that were defendant produced specific to opt-in

plaintiffs. reviewed ADP web portal info. Conduced extensive

prep for depo of corporate designee.

12.00 $5,400.00

12/18/2013 CA Began discovery for 5 additional class members; drafted

individual emails and made phone calls; continued discovery

process, including drafting interrogatories and requests for

production for new chosen members; interrogatory phone call

with Arena Marques.

13.30 $2,992.50

12/18/2013 MRK Drafting on Motion to Compel relating to accessibility of

discovery responses and interpretation of documents

produced by Defendants;Drafting of chapter of questions

addressing topics including storage of information, migration

of data, communication between Beyond and other

timekeeping software, preservation of data in light of

litigation.

8.00 $1,800.00

12/18/2013 JES Redrafted chapters in order to conform to the scope of he

Corp Rep Depo; prepared for and had a phone call with KD re:

Corp Rep Depo; went through corp rep depo notice and

pulled the names of systems/websites etc used by Defendant's

that will be asked about in the deposition; drafted chapter on

ADP Portal/Transcend/Nuance transition; drafted chapter on

retention and maintenance of records; drafted chapter on

support staff specific to ADP sit; record keeping requirements

during and after class period mirroring #42 on notice of

depo. called KD to discuss chapters of Corp Rep Depo;

updated chapters per the corp rep depo.

10.30 $2,317.50

12/19/2013 MJO Travel from St. Louis to Chicago, IL for purposes of defending

deposition of Plaintiff Patricia Rapp.

2.00 $550.00

12/19/2013 MJO Prepared Plaintiff Patricia Rapp for deposition scheduled for

12/20.

4.00 $1,100.00

12/19/2013 KJD Prep for Deposition. 1.00 $450.00

12/19/2013 KJD Deposition from 9-5:30. Deposing witness and preparing and

updating information.

8.50 $3,825.00

12/19/2013 KJD Memo to file regarding outcomes and results of deposition of

corp designee; review results of Corp Rep depo with cocounsel MJO.

0.75 $337.50

12/19/2013 CA Drafted on Beverly McCoy's interrogatories and responses to

requested for production by examining her questionnaire;

drafted and send email to Bev McCoy with her interrogatories

attached requesting her approval; drafted and edited

interrogatories and requests for production for additional

members; phone call to members requesting verification forms

and/or confirmation of depo dates; drafted and sent emails to

members who diMAK't respond; made list of class members

with status updates.

9.50 $2,137.50

12/20/2013 MJO Participated in defending deposition of Plaintiff Patricia Rapp. 5.00 $1,375.00
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12/20/2013 MJO Travelled from Chicago, IL to St. Louis, MO after defending

deposition of Patricia Rapp.

2.00 $550.00

12/20/2013 MAK Draft, edit, create Notice of 30(b)(6) Deposition. 3.00 $675.00

12/20/2013 CRM Revise 30(b)(6) deposition notice based on

recommendations of Attorney K. Dolley

1.40 $385.00

12/20/2013 KJD Review Rapp docs, discovery responses, prepare for

deposition defense.

2.00 $900.00

12/20/2013 KJD Travel from Hartford to Chicago for deposition. 3.00 $1,350.00

12/20/2013 CA Review docs received from class rep, scan into pdf format;

revise rfp based on docs received; drafted and edited

interrogatories and requests for production for additional

members; drafted and sent emails to Teresa Pemerton and

Lynda Romanek; drafted and edited interrogatories and

requests for production for additional members; phone call

with Carol Failla.

4.00 $900.00

12/23/2013 MJO Emailed co-counsel Russ Riggan, re: deposition of Margaret

Anne Thorpe.

0.30 $82.50

12/23/2013 MJO Emailed co-counsel Sam Moore, re: deposition of Plaintiff

Janeen DeBoard.

0.20 $55.00

12/23/2013 MJO Drafted email to Plaintiff Patsy Hayes, re: information

concerning deposition preparation meeting and deposition

scheduled for 12/27.

0.30 $82.50

12/23/2013 CA Prepare Hayes documents for deposition; Conversation with

class reps over phone re depsoition dates and discovery

responses; Continue preparing discovery responses for

participating class reps; contact class reps re discovery

responses, verification pages, documents, deposition deates;

draft responses to interrogatories and rfp; scan documents

sent class reps into pdf format.

8.20 $1,845.00

12/23/2013 CA Called and emailed members, began putting together depo

and discovery list for remaining members; worked on

responses to interrogatories and requests for production;

made phone call to members.

6.50 $1,462.50

12/26/2013 MJO Emailed opposing counsel, re: deposition date for Diane

Spencer.

0.20 $55.00

12/26/2013 MJO Analyzed and examined questionnaire, discovery responses,

and documents produced by Defendant, re: Patsy Hayes, for

purposes of preparing to defend her deposition.

1.50 $412.50

12/26/2013 MJO Drive time from St. Louis, MO to Poplar Bluff, MO for purposes

of defending deposition of Patsy Hayes.

2.50 $687.50

12/26/2013 MJO Prepared client for deposition, re: lines of potential

questioning concerning line rate, work time, overtime rate,

what to expect.

2.00 $550.00

12/26/2013 MJO Drafted updated chart of deposition dates for 17 Plaintiffs we

have set deposition dates for.

0.80 $220.00

12/26/2013 CA Continue preparing discovery responses for participating class

reps; contact class reps re discovery responses, verification

pages, document, deposition dates; draft responses to

interrogatories and rfp; scan documents sent in by class reps

into pdf format.

3.00 $675.00

12/27/2013 CRM Instruct contract attorneys on corporate representative

deposition summary. Follow up on progress

0.20 $55.00

12/27/2013 CRM Discuss Transcend Motions with attorney J. Skrabacz 0.30 $82.50

12/27/2013 CA Called and emailed Diane Spencer about her deposition

location; updated contact list; worked on interrogatories and

requests for production for Serena Marques; worked on

interrogatories and requests for production for for Carol Failla;

typed up deposition summary for corp rep depo.

14.50 $3,262.50

12/28/2013 CRM Research case law on Motion for Contempt. Review local rule

as to same. Draft Motion to Compel and Show Cause.

Discuss same with attorneys K. Dolley and M. Obermeyer.

Revise Motion and draft Notice of same. Email to

6.10 $1,677.50
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12/29/2013 JMF

K. Dolley and M. Obermeyer for review.

Preparing hard copies for filing 206,207,208. 2.50 $562.50

12/30/2013 MJO Meeting with Attorney Jason Finkes, re: preparing for Rule

30(b)(6) deposition.

0.20 $55.00

12/30/2013 MJO Meeting with Attorneys Kyle O’Driscoll and Josh Leach, re:

discovery for remaining deponents/individuals.

0.50 $137.50

12/30/2013 MJO Reviewed/revised Responses and Objections to Interrogatories

for Plaintiff Kathleen Schuster.

0.50 $137.50

12/30/2013 MJO Telephone call with Sam Moore, re: discovery responses for

Reeser, Keenan, McLemore.

0.20 $55.00

12/30/2013 MJO Drafted/revised responses and objections to interrogatories for

Barbara Keenan.

0.50 $137.50

12/30/2013 MJO Drafted/revised responses and objections to interrogatories

and Requests for Production for Plaintiff Barbara Keenan, re:

revised Interrogatories 2­5; 8, 11, 12; analyzed and examined

approximately 100 pages of documents for purposes of

responding to interrogatories and requests for production.

1.50 $412.50

12/30/2013 MJO Examined/analyzed documents for purposes of corporate

representative deposition, re: Timesaver implementation; MLS

work duties; MLS complaints; MLS production-based

compensation.

1.00 $275.00

12/30/2013 MJO Phone call with Attorney Kevin Dolley, re: status conference. 0.40 $110.00

12/30/2013 MJO Drafted email to Judge Rowland for review of attorney Kevin

Dolley, re: documents to be produced by Defendant on classwide basis.

0.40 $110.00

12/30/2013 MJO Telephone call with Plaintiff Kathleen Schuster, re: deposition

availability and date.

0.50 $137.50

12/30/2013 MJO Emailed Kathleen Schuster, re: deposition availability. 0.30 $82.50

12/30/2013 MJO Drafted/revised outline for purposes of defending depositions,

addressed to co-counsel, re: questions/lines of inquiry to

expect when defending stage 2 depositions directed at decertifying class.

1.00 $275.00

12/30/2013 JMF Document duplication, sorting and review in preparation for

Corp Rep Deposition.

4.00 $900.00

12/30/2013 CRM Discuss status conference with Attorney K. Dolley,

discuss case strategy moving forward

0.10 $27.50

12/30/2013 CA Continue preparing discovery responses for participating class

reps; contact class reps re discovery responses, verification

pages, documents, deposition dates; draft responses to

interrogatories and rfp; scan documents sent in by class reps

into pdf format

2.50 $562.50

12/30/2013 CA Call participating class members re responding to

interrogatories, deposition availability; Draft interrogatory

responses and sent to class members for verification.

1.80 $405.00

12/30/2013 CA Call participating class member to verify interrogatory

responses, request verification form be signed and returned,

and discussed deposition availability.

0.30 $67.50

12/30/2013 KJD Travel from STL to Chicago. Hearing to airport,cab to

courthouse; Travel courthouse to airport, travel from Chicago

to STL; Prep for status hearing before Judge Rowland;

Meeting with OC Mersol, outside of courthouse to discuss

settlement, discovery deficiencies of Defendant; Email to

Riggon, re: defendant coverage; Review defendant's responses

to 2nd written discovery requests to defendants.

9.75 $4,387.50

12/30/2013 CA Meeting with Mark; Patty Rapp phone call; began discovery

process for 5 additional, substitute members; began drafting

search term list; continued drafting search term list; call

participating class reps in order to complete discovery, verify

deposition dates; inquire into willingness to participate in

discovery.

8.75 $1,968.75

12/30/2013 JES Filled out and filed the pro hac vice form in the ND of IL; 7.50 $1,687.50
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conferred with client re: rescheduling the location of the Malta

MT deposition; began depo prep for corp rep depo scheduled

for Jan 6, 2014 by drafting a chapter on organizational

structure on during the Class Period; drafted chapter for corp

depo re entities liable for judgment against defendant in this

case; drafted chapter re MLS access to email; drafted chapter

re company-wide file sharing methods/systems; drafted

chapter re location and content of all logging and audit trails

for networks and other systems keeping trac of the online

activity of Plaintiffs.

12/31/2013 MJO Drafted email to Plaintiff Diane Spencer, re: deposition

preparation availability and deposition trip to MD.

0.30 $82.50

12/31/2013 MJO Drafted updated/revised outline for deposition preparation for

use of co-counsel, re: Introduction; Transcend’s objectives

during the stage 2 depositions; discussed Transcend’s

apparent strategy for de-certification and how to combat this

during deposition through making form objections; discussed

the most important information on which we need to prep the

clients on the basis of the content of the first 2 depositions so

far; revised section concerning how to explain to clients the

legal basis of the lawsuit.

2.80 $770.00

12/31/2013 MJO Emailed opposing counsel Tracey Ellerson, re: Defendant’s

production of all court-ordered documents for Diane Martin.

0.30 $82.50

12/31/2013 MJO Drafted updated/revised outline for deposition preparation for

use of co-counsel, re: common lines of questioning featured

in first 2 stage 2 depositions; Plaintiffs’ living arrangement

and work habits; discussion of lawsuit with any other

persons/MLSs; written logs/facebook posts; time flexing

policy; compensation method; unattainable production quotas

within allotted schedule time assigned to MLSs.

1.50 $412.50

12/31/2013 MJO Drafted updated/revised outline for deposition preparation for

use of co-counsel, re: common lines of questioning featured

in first 2 stage 2 depositions; MLS job duties; compensable vs.

non-compensated work time; “hands on keyboard” vs. “hands

off keyboard” non-production time; employer knowledge of

work time and when MLSs working; timekeeping instructions

received by MLSs from team leads/regional managers/those

higher up the corporate chain; overtime compensation.

1.00 $275.00

12/31/2013 JMF Corp Rep Depo Prep, duplication of documents; sort

documents.

6.20 $1,395.00

12/31/2013 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps; contact class reps re discovery

responses, verification pages, documents, deposition dates;

draft responses to interrogatories and rfp; scan documents

sent in by class reps into pdf format

1.20 $270.00

12/31/2013 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps; contact class reps re discovery

responses, verification pages, documents, deposition dates;

draft responses to interrogatories and rfp; scan documents

sent in by class reps into pdf format

1.80 $405.00

12/31/2013 CA Draft interrogatory responses based on information obtained

from phone conversation with class member; email completed

draft and verification page to class member for her review

1.10 $247.50

12/31/2013 CA Burn documents from defendant to disk for mjo 0.20 $45.00

12/31/2013 CA Call class member to complete written discovery responses. 0.50 $112.50

12/31/2013 CA Worked on interrogatories and requests for production for 5

substitute discovery class members

1.50 $337.50

12/31/2013 CA Worked on interrogatories and requests for production for 5 1.50 $337.50
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12/31/2013 CA

substitute discovery class members

Worked on interrogatories and requests for production for 5 1.50 $337.50

substitute discovery class members

12/31/2013 CA Worked on interrogatories and requests for production for 5

substitute discovery class members

0.75 $168.75

12/31/2013 CA Interrogatory phone call with Laurie Leiker 0.50 $112.50

12/31/2013 CA Phone call with Serena Marques 0.25 $56.25

12/31/2013 CA Made requested changes to Sarena Marques interrogatories 0.25 $56.25

12/31/2013 CA Continued drafting search term list 1.50 $337.50

12/31/2013 KJD Draft response motions to compel opt-ins Plaintiffs. 3.00 $1,350.00

12/31/2013 KJD Draft response, Motion for Protective Order, Depo Notice, Ruls

30(b)(6), Corp Designee

2.00 $900.00

01/01/2014 MJO Attempted calling Plaintiff Diane Spencer, re: deposition time;

left voicemail.

0.10 $27.50

01/01/2014 MJO Emailed Diane Spencer, re: availability for deposition prep

time.

0.10 $27.50

01/01/2014 MJO Attempted calling Plaintiff Kathleen Schuster, re: deposition

date confirmation; left voicemail.

0.10 $27.50

01/01/2014 MJO Emailed Kathleen Schuster, re: confirmation of deposition

date.

0.10 $27.50

01/01/2014 MJO Emailed Diane Spencer, re: confirmation of deposition

preparation time.

0.10 $27.50

01/01/2014 MJO Conducted final review/revisions to deposition preparation

outline prior to sending to co-counsel Russ Riggan and Sam

Moore.

0.50 $137.50

01/02/2014 MJO Emailed opposing counsel, re: deposition of Kathleen

Schuster.

0.20 $55.00

01/02/2014 MJO Meeting with Attorneys Josh Leach and Kyle O’Driscoll, re:

discovery responses of Marques, Failla, Schuster, Thorpe,

Plum.

0.50 $137.50

01/02/2014 MJO Emailed Plaintiff Kathleen Schuster, re: availability to prep for

deposition.

0.10 $27.50

01/02/2014 MJO Drafted/revised Plaintiff Sarena Marques’s Responses and

Objections to Defendant’s First Set of Interrogatories and

Requests for Production Directed to Plaintiff, re: detailed

sentence-by-sentence review of both sets of Responses and

Objections.

1.50 $412.50

01/02/2014 MJO Emailed OC Jeff Vlasek, re: deposition logistics for Kathleen

Schuster.

0.20 $55.00

01/02/2014 MJO Drafted emails to co-counsel Russ Riggan and Sam Moore, re:

documents produced by Defendant for purposes of preparing

for defense of depositions.

0.50 $137.50

01/02/2014 MJO Telephone call with Russ Riggan, re: deposition scheduling. 0.50 $137.50

01/02/2014 MJO Telephone call with co-counsel Jonathan Skrabacz, re:

strategy for defending deposition of Diane Martin.

0.30 $82.50

01/02/2014 MJO Drafted/revised Plaintiff Kathleen Schuster’s Responses and

Objections to Defendant’s First Set of Interrogatories and

Requests for Production Directed to Plaintiff, re: detailed

sentence-by-sentence review of both sets of Responses and

Objections.

1.20 $330.00

01/02/2014 JMF Corp Rep Depo Prep, duplication of documents; sort

documents.

8.50 $1,912.50

01/02/2014 CA Meeting with Mark 0.25 $56.25

01/02/2014 CA Worked on interrogatories and requests for production for

remaining discovery class members

0.50 $112.50

01/02/2014 CA Phone Call with Carol Failla 0.50 $112.50

01/02/2014 CA Interrogatory phone call with Janet Moore 0.50 $112.50

01/02/2014 CA Went through Carol Failla's docs, scan them in and updated

her discovery; began drafting Janet Moore's discovery

2.00 $450.00

01/02/2014 CA Examined the edits Laurie Leiker made to her interrogatories 1.25 $281.25
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01/02/2014 CA

and re-did her answers in the correct format

Email correspondence with Carol Failla and Laurie Leiker 0.25 $56.25

01/02/2014 CA Worked on interrogatories and requests for production for

remaining discovery class members

1.50 $337.50

01/02/2014 CA Drafted Janet Moore's discovery 1.50 $337.50

01/02/2014 CA Continue preparing discovery responses and contacting

participating class members re discovery/depositions

0.70 $157.50

01/02/2014 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps; contact class reps re discovery

responses, verification pages, documents, deposition dates;

draft responses to interrogatories and rfp; scan documents

sent in by class reps into pdf format

2.60 $585.00

01/02/2014 CA Discussion with MJO re status of discovery, participating class

reps, deposition availability

0.20 $45.00

01/02/2014 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps

2.30 $517.50

01/02/2014 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps; contact class reps re discovery

responses, verification pages, documents, deposition dates;

draft responses to interrogatories and rfp; scan documents

sent in by class reps into pdf format

1.20 $270.00

01/02/2014 CA Scan, review, and bates number docs sent in by participating

class member

0.40 $90.00

01/02/2014 CA Compile documents from def for class members being

deposed by Russ and Sam in zip files

1.00 $225.00

01/02/2014 JES Travel from Billings, MT to Malta, MT to defend deposition of

Medical transcriptionist; met with client regarding

upcoming deposition scheduled for 1/3/14.

6.00 $1,350.00

01/03/2014 MJO Telephone call with Attorney Jonathan Skrabacz, re: strategy

for defending deposition of Diane Martin and additional

documents produced by Defendant for Diane Martin on

1/2/14.

0.50 $137.50

01/03/2014 MJO Drafted/revised Plaintiff Carol Failla’s Responses and

Objections to Defendant’s First Set of Interrogatories and

Requests for Production Directed to Plaintiff, re: detailed

sentence-by-sentence review of both sets of Responses and

Objections.

2.00 $550.00

01/03/2014 MJO Drafted/revised Plaintiff Anne Thorpe’s Responses and

Objections to Defendant’s First Set of Interrogatories and

Requests for Production Directed to Plaintiff, re: detailed

sentence-by-sentence review of both sets of Responses and

Objections.

1.50 $412.50

01/03/2014 MJO Drafted/revised Plaintiff Marie Plum’s Responses and

Objections to Defendant’s First Set of Interrogatories and

Requests for Production Directed to Plaintiff, re: detailed

sentence-by-sentence review of both sets of Responses and

Objections.

1.00 $275.00

01/03/2014 MJO Telephone call with Attorney Jonathan Skrabacz, re: strategy

for defending deposition of Diane Martin and additional

documents produced by Defendant for Diane Martin on

1/2/14.

0.50 $137.50

01/03/2014 MJO Drafted email to opposing counsel Greg Mersol and Tracey

Ellerson, re: substitution of Marie Plum as Plaintiff.

0.30 $82.50

01/03/2014 MJO Telephone call with co-counsel Sam Moore, re: deposition

strategy for defending deposition of Jacqueline St. Georges.

0.50 $137.50
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01/03/2014 JMF Corp Rep Depo Prep, duplication of documents; sort

documents.

7.00 $1,575.00

01/03/2014 CA Reviewed and edited interrogatories and requests for

production for Laurie Leiker

1.00 $225.00

01/03/2014 CA Reviewed and edited interrogatories and requests for

production for Laurie Leiker and Janet Moore

1.50 $337.50

01/03/2014 CA Reviewed and edited interrogatories and requests for

production for Laurie Leiker and Janet Moore

1.50 $337.50

01/03/2014 CA Contact participating class members re discovery; draft

responses to interrogatories and requests for production;

verify deposition availability with participating class members

2.20 $495.00

01/03/2014 CA Contact participating class member re discovery; draft

responses to interrogatories and requests for production;

verify deposition availability with participating class members.

1.20 $270.00

01/03/2014 CA Print off and prepare documents for MJO for Spencer

deposition

0.50 $112.50

01/03/2014 CA Continue preparing discovery responses for participating class

members; contacting potential class reps re discovery, drafting

responses to interrogatories and requests for production

1.40 $315.00

01/03/2014 CA Worked on remaining interrogatories and requests for

production; took phone calls and responded to emails

2.00 $450.00

01/03/2014 CA Call participating class reps in order to complete discovery,

verify deposition dates; inquire into willingness to participate

in discovery; Continue preparing discovery responses for

participating class reps

1.80 $405.00

01/03/2014 CA Phone call with participating class member re revisions to

interrogatory responses and deposition date; revise response

to interrogatories; verify changes with class rep; send to MJO

0.80 $180.00

01/03/2014 CA Jeanie Purcell interrogatories and requests for production 1.75 $393.75

01/03/2014 CA Meeting with Mark; scanned in Failla documents 0.25 $56.25

01/03/2014 CA Examined Failla documents 0.50 $112.50

01/04/2014 MJO Travel time from St. Louis, Missouri to Baltimore, Maryland for

purposes of defending deposition of Diane Spencer.

7.50 $2,062.50

01/04/2014 MJO Drafted email to Plaintiff Diane Spencer, re: confirmation of

place/time for meeting for purposes of preparing for

deposition.

0.20 $55.00

01/04/2014 MJO Drafted email to Plaintiff Kathleen Schuster, re: confirmation

of place/time for meeting for purposes of deposition

preparation.

0.30 $82.50

01/04/2014 JMF Corp Rep Depo Prep, document review for responsiveness and

separating into chapters; document duplication and review for

responsiveness.

7.00 $1,575.00

01/04/2014 JES Travel from Billings, MT to St. Louis, MO after appearing at

deposition of Medical Transcriptionist.

15.00 $3,375.00

01/05/2014 MJO Drafted email to co-counsel Jonathan Skrabacz, re: provided

instruction/details for defending remaining 3 depositions in FL

and TX.

0.50 $137.50

01/05/2014 MJO Met with Plaintiff Diane Spencer, re: prepared Spencer for

deposition scheduled for 1/6; discussed deposition process

and strategy for answering questions.

2.00 $550.00

01/05/2014 MJO Analyzed and examined approximately 250 supplementary

documents for Plaintiff Darcy Wingler.

3.00 $825.00

01/05/2014 MJO Emails with OC Jeff Vlasek, re: logistics of defending

deposition of Diane Spencer and OC travel difficulties.

0.30 $82.50

01/05/2014 MJO Telephone call with co-counsel Sam Moore, re: strategy for

deposition defense, specifically deposition of Jacqueline St.

Georges set for 1/6.

0.50 $137.50

01/05/2014 MJO Telephone call with co-counsel Russ Riggan, re: provided

advice for setting deposition of Carol Failla in Monroe, NC.

0.20 $55.00

01/06/2014 MJO Defended deposition of Plaintiff Diane Spencer. 4.00 $1,100.00
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01/06/2014 MJO Telephone calls with Attorney Sam Moore, re: depositions of

Darcy Wingler and Sheila Reeser.

0.50 $137.50

01/06/2014 MJO Travel time from Baltimore, MD to Cleveland, OH for purposes

of defending deposition of Plaintiff Kathleen Schuster in

Cleveland, OH.

3.00 $825.00

01/06/2014 JMF Corp Rep Depo preparation of chapters. 8.50 $1,912.50

01/06/2014 CA Worked on interrogatories and requests for production for

backup members

2.00 $450.00

01/06/2014 CA Draft search terms letter 0.90 $202.50

01/06/2014 CA Review documents received from defendant for each class

member; draft list showing what has been received for each

person and what we have not received yet.

1.50 $337.50

01/06/2014 CA Locate and send to MJO any documents received re Reeser 0.20 $45.00

01/06/2014 CA Continue drafting discovery responses and making revisions

based on input from class rep

0.60 $135.00

01/06/2014 CA Download documents sent into email by participating class

member; compile into single pdf file, bates number doc for

discovery

1.70 $382.50

01/06/2014 CA Worked on interrogatories and requests for production for

backup members

2.00 $450.00

01/06/2014 CA Added terms to search term list 0.25 $56.25

01/06/2014 CA Continue drafting discovery responses and making revisions

based on input from class rep; contact class reps to verify/set

deposition dates

1.90 $427.50

01/06/2014 CA Communication with Laurie Leiker 0.25 $56.25

01/06/2014 CA Worked on interrogatories and requests for production for

backup members

1.50 $337.50

01/06/2014 CA Worked on interrogatories and requests for production for

backup members

1.50 $337.50

01/06/2014 CA Sheila Reeser doc review and sending 0.50 $112.50

01/06/2014 CA Examined Jeannie Purcell and Francine Gorskie questionnaires 0.50 $112.50

01/06/2014 CA Draft and send emails to Jeannie Purcell and Francine Gorskie 0.25 $56.25

01/06/2014 KJD Draft and edit key wordsearch letter to OC; revie and send to

OC additional depo topics.

3.00 $1,350.00

01/06/2014 JES Discussed upcoming depos with MJO; called client Sarena

Marques and Janeen DeBoard re: upcoming depo; researched

and booked travel arrangements for depos in Florida.

2.80 $630.00

01/07/2014 MJO Travel time from Cleveland, OH to Canton, OH for purposes of

defending deposition of Plaintiff Kathleen Schuster.

2.50 $687.50

01/07/2014 MJO Meeting with Plaintiff Kathleen Schuster, re: preparation for

deposition scheduled for 1/8/14; discussed potential lines of

questioning related to Defendant’s wage and hour policies;

discussed Plaintiff’s understanding of Defendant’s wage and

hour policies and her experience working with Defendant in

detail.

3.00 $825.00

01/07/2014 MJO Telephone calls with Sam Moore, re: defending depositions of

Plaintiff Darcy Wingler and Jacqueline St. Georges.

0.50 $137.50

01/07/2014 MJO Telephone call with Attorney Kevin Dolley, re: hearing

scheduled before Judge Rowland for 1/10/14.

0.50 $137.50

01/07/2014 JMF Corp Rep Depo prep, documents- Social Media Reports and

documents of Dawn Pence personnel file and timesaver

manager training.

7.20 $1,620.00

01/07/2014 CRM Revise deficiency letter related to Defendant's responses to

Plaintiff's second set of interrogatories. Email to attorney K.

Dolley for review.

0.90 $247.50

01/07/2014 CRM Revise deficiency letter. Email to attorney K. Dolley. 0.30 $82.50

01/07/2014 CRM Revise Motion to Compel. 0.70 $192.50

01/07/2014 CRM Additional review and revision of Motion to Compel re:

Defendant's responses to second set of Interrogatories

0.40 $110.00

01/07/2014 CRM Initial revision to response to Defendant's Motion for

Protective Order

1.10 $302.50
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01/07/2014 CRM Prepare exhibits to Motion to Compel, re: 2nd

Interrogatories for filing. File motions and exhibits with the

court.

0.30 $82.50

01/07/2014 CRM Research case law specific to limiting length of opt-in

deposition for use in protective order motion.

0.50 $137.50

01/07/2014 CRM Review, revise and file Motion for Protective Order 1.60 $440.00

01/07/2014 CRM File Notice of Motion, re: Motion to Compel, Motion for

Protective Order

0.20 $55.00

01/07/2014 CA Revise deficiency letter based off corrections from K. Dolley 0.50 $112.50

01/07/2014 CA Draft motion to compel responses to second interrogatories 0.80 $180.00

01/07/2014 CA Draft motion to compel responses to second interrogatories 1.20 $270.00

01/07/2014 CA Conduct research re protective order to limit depositions 1.30 $292.50

01/07/2014 CA Draft motion for protective order to limit length of depositions 0.90 $202.50

01/07/2014 CA Draft motion for protective order to limit length of depositions 1.20 $270.00

01/07/2014 CA Worked on interrogatories and requests for production for

backup members

0.75 $168.75

01/07/2014 CA Organized discovery and other documents 1.00 $225.00

01/07/2014 CA Made calls and answered emails 0.25 $56.25

01/07/2014 CA Reviewed defendant's motion for protective order and began

drafting response

0.50 $112.50

01/07/2014 CA Meeting with K. Dolley 0.50 $112.50

01/07/2014 CA Drafted Response to protective order 3.00 $675.00

01/07/2014 CA Read through and notate def's motion for protective order re

30(b)(6) deposition

0.70 $157.50

01/07/2014 CA Review def's response to 2nd interrogatories; draft deficiency

letter re def's responses to 2nd interrogatories

2.90 $652.50

01/07/2014 CA Draft motion to compel responses to second interrogatories 0.30 $67.50

01/07/2014 CA Meet with K. Dolley 0.50 $112.50

01/07/2014 CA Began drafting response to Motion to Compel 3.10 $697.50

01/07/2014 CA Check opt-in email for any correspondence from participating

class members

0.30 $67.50

01/07/2014 KJD Draft responses to defendants Motion for Protective Order;

Response Russ Depo letter; Draft deficiency letter, defendant's

response to 2nd set of interrogatories; draft motion to compel

responses to 2nd discovery responses; call with Obermeyer,

discovery issues; draft motion for Protective Order opt-in depo

length. Research court orders supportive of our case.

7.70 $3,465.00

01/07/2014 MRK Review and hand correction of Motion to Compel

Responses to Second Set of Interrogatories directed to

Defendant

0.20 $45.00

01/07/2014 JES Depo prep for client Sarena Marques for Friday's

deposition.

6.80 $1,530.00

01/08/2014 MJO Travel/drive time to pick up Plaintiff Kathleen Schuster for

deposition in Canton, OH.

0.50 $137.50

01/08/2014 MJO Defended deposition of Kathleen Schuster in Canton, OH. 4.00 $1,100.00

01/08/2014 MJO Travel/drive time to drop off Plaintiff Kathleen Schuster after

her deposition in Canton, OH.

0.50 $137.50

01/08/2014 MJO Travel/drive time from Canton, OH to Cleveland, OH for

purposes of returning to St. Louis, MO after defending

deposition of Kathleen Schuster.

1.50 $412.50

01/08/2014 MJO Flight from Cleveland, OH to St. Louis, MO for purposes of

returning home after defending deposition of Kathleen

Schuster in Canton, OH.

3.00 $825.00

01/08/2014 JMF 30(b)(6) General Depo Prep, reviewing, collating, organizing

existing chapters; chapters on ROM/TL supervision, discipline,

Personnel Records, MLS performance.

6.00 $1,350.00

01/08/2014 CA Drafted Response to Motion to Compel 1.50 $337.50

01/08/2014 CA Researched and drafted second version of response to Motion

to Compel

1.50 $337.50

01/08/2014 CA Review Defendant's response to requests for production; Draft 2.20 $495.00
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deficiency letter, re: defendant's response to requests for

production

01/08/2014 CA Researched and drafted second version of response to Motion

to Compel

1.50 $337.50

01/08/2014 CA Research, re: access to database/computer program through

discovery

1.10 $247.50

01/08/2014 CA Draft email to Opposing Counsel, re: access to computer

programs

1.00 $225.00

01/08/2014 CA Check opt-in email for correspondence from class members;

download documents sent in by class members

0.40 $90.00

01/09/2014 MJO Telephone calls with Sam Moore, re: provided advice

concerning depositions of Barbara Keenan and Joy McLemore,

concerning deposition length and relation of length to lines of

questioning.

0.50 $137.50

01/09/2014 MJO Responded to emails from Attorney Sam Moore, re:

depositions of Plaintiffs Marie Plum and Darcy Wingler.

0.50 $137.50

01/09/2014 MJO Emailed Attorney Kevin Dolley, re: hearing with Judge

Rowland scheduled for 1/10/14 and strategy for arguing

against Defendant’s Motion to Compel Participation of OptIns.

0.50 $137.50

01/09/2014 MJO Telephone calls with Attorney Jonathan Skrabacz, re:

depositions of Sarena Marques and Janeen DeBoard.

0.80 $220.00

01/09/2014 MJO Responded to email from Attorney Russ Riggan, re: deposition

of Plaintiff Kandace Chancey.

0.30 $82.50

01/09/2014 MJO Drafted email to co-counsel highlighting Defendant’s specific

remaining discovery deficiencies.

0.80 $220.00

01/09/2014 MJO Analyzed and examined approximately 20 pages of

supplementary documents for Plaintiff Sarena Marques.

0.50 $137.50

01/09/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion to Compel

Specific Opt-ins to Participate in Discovery, re: Procedural

Posture; Plaintiffs Have Not Violated This Court’s Order.

1.50 $412.50

01/09/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion to Compel

Specific Opt-ins to Participate in Discovery, re: Plaintiffs Have

Not Violated This Court’s Order; Any Prejudice Defendant

Alleges It Suffers Is The Result Of Its Own Failures and

Shortcomings.

1.50 $412.50

01/09/2014 MJO Drafted detailed email to co-counsel summarizing the hearing

before Judge Rowland held 1/10/14, re: outstanding

discovery issues.

1.50 $412.50

01/09/2014 JMF Corp Rep Depo Prep, chapters on training, job

duties/description.

1.80 $405.00

01/09/2014 JMF Corp Rep Depo Prep, chapters on Compliance Worker

performance and OT/MKM.

3.60 $810.00

01/09/2014 CA Meeting with Mark; called and emailed Judy Lindquist 0.50 $112.50

01/10/2014 MJO Telephone call with Judy Lindquist, re: provided client with

overview of deposition process, what to expect during

deposition, and issues regarding her employment which she

may be questioned on.

1.00 $275.00

01/10/2014 MJO Meeting with Attorney Josh Leach, re: drafting Plaintiffs’

Motion for Extending Discovery Deadline; reasons discovery

deadline should be extended limited to Plaintiffs.

0.50 $137.50

01/10/2014 MJO Telephone calls with Sam Moore, re: provided advice

concerning deposition of Barbara Keenan and outstanding

documents/emails produced by Keenan.

0.50 $137.50

01/10/2014 MJO Telephone call with Jonathan Skrabacz, re: deposition of

Sarena Marques.

0.50 $137.50

01/10/2014 MJO Analyzed/examined approximately 1,400 pages of documents

produced by Plaintiff Judy Lindquist and discovery responses

for Judy Lindquist, re: preparation for defending client’s

deposition and preparing client for deposition topics.

3.50 $962.50

01/10/2014 JMF Corp Rep Depo Prep, chapters on Report usage, task forces,

review of notice to brainstorm additional topics and verify

2.00 $450.00
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01/10/2014 CRM

breadth of coverage.

Review email from opposing counsel, re: objections to 0.10 $27.50

search terms

01/10/2014 CA Drafted Motion for Extension 1.50 $337.50

01/10/2014 CA Meeting with Mark to go over Motion for Extension 0.50 $112.50

01/10/2014 CA Researched and began drafting Motion for Extension 1.50 $337.50

01/10/2014 CA Drafted Motion for Extension 1.50 $337.50

01/10/2014 CA Drafted Motion for Extension 1.50 $337.50

01/10/2014 CA Drafted and Reviewed Motion for Extension; organized files;

phone correspondence

1.25 $281.25

01/11/2014 JMF Organize, coordinate, integrate chapters for Corp Rep

Deposition.

6.00 $1,350.00

01/11/2014 CA Correspondence with Mark 0.25 $56.25

01/11/2014 CA Converted Barb Vaughn emails to PDFs 2.00 $450.00

01/11/2014 CA Converted Barb Vaughn emails to PDFs 2.00 $450.00

01/11/2014 CA Converted Barb Vaughn emails to PDFs 2.00 $450.00

01/11/2014 CA Converted Barb Vaughn emails to PDFs 2.00 $450.00

01/11/2014 CA Converted Barb Vaughn emails to PDFs; combined emails into

batches and Bates stamped them

1.50 $337.50

01/12/2014 MJO Travel time from St. Louis, MO to Omaha, NE for purposes of

defending deposition of Plaintiff Judy Lindquist.

2.00 $550.00

01/12/2014 MJO Drive/travel time from Omaha, NE to Oconto, NE for purposes

of meeting with Plaintiff Judy Lindquist to prepare her for

deposition on 1/13/14.

4.00 $1,100.00

01/12/2014 MJO Meeting with Plaintiff Judy Lindquist, re: preparation for

deposition; discussed client work duties with Transcend,

hours worked for Transcend, understanding of Transcend

wage and hour policies.

3.50 $962.50

01/12/2014 MJO Drive/travel time from Oconto, NE to North Platte, NE for

purposes of defending deposition of Judy Lindquist scheduled

for 1/13/14.

1.50 $412.50

01/13/2014 MJO Defended deposition of Plaintiff Judy Lindquist. 4.00 $1,100.00

01/13/2014 MJO Drive/travel time from North Platte, NE to Omaha, NE for

purposes of returning to St. Louis, MO on 1/14/14 after

defending deposition of Judy Lindquist.

4.00 $1,100.00

01/13/2014 JMF Prepare and sort folders/documents to redwells; reorganize

documents post-triplication of OC convenience copy,

expanding document chapters; meeting with Kevin to update

on status of Corp Rep Depo; resort and reorganize chapters on

social media monitoring corporate organization, TimeSaver

training, identifying key documents, and creating chapter

folders.

13.00 $2,925.00

01/13/2014 CRM Meeting with attorney K. Dolley, re: contents on Motion to

Compel

0.50 $137.50

01/13/2014 CRM Meeting with attorney K. Dolley, re: status of Motion to

Compel

0.10 $27.50

01/13/2014 CRM Draft and send email re: outstanding ESI search term

protocol

1.00 $275.00

01/13/2014 CRM Draft and send email re: additional topics to Rule 30(b)

(6) deposition notice

0.30 $82.50

01/13/2014 CRM Draft and send email re: location of Friday's Rule 30(b)

(6) deposition

0.20 $55.00

01/13/2014 CA Examined email folder for new questionnaire and documents;

printed out and sorted questionnaires and docs

1.50 $337.50

01/13/2014 CA Examined and added questionnaires to damages spreadsheet 2.00 $450.00

01/13/2014 CA Examined and added questionnaires to damages spreadsheet 2.00 $450.00

01/13/2014 CA Make copies of documents to be used in corp. rep. deposition 4.80 $1,080.00

01/13/2014 CA Check opt-in email for correspondence from class members 0.20 $45.00

01/13/2014 CA Review opposing counsel's deficiency letter in preparation to

respond; begin drafting response to opposing counsel's

0.10 $22.50
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01/13/2014 CA

deficiency letter

Examined and added questionnaires to damages spreadsheet 1.50 $337.50

01/13/2014 CA Went to courthouse and picked up forms 0.60 $135.00

01/13/2014 KJD Prep for Corp Rep Depo; Call Kevin Shaunassey, re: discovery,

deposition location, depo scheduling.

5.25 $2,362.50

01/14/2014 MJO Travel time from Omaha, NE to Denver, CO for purposes of

taking connecting flight from Denver to St. Louis after

defending deposition of Judy Lindquist.

4.00 $1,100.00

01/14/2014 MJO Travel time from Denver, CO to St. Louis, MO for purposes of

returning home after defending deposition of Judy Lindquist.

2.50 $687.50

01/14/2014 MJO Drafted chapters for preparation of deposition of Transcend

corporate designee, re: Ch. 1- Introduction; Ch. 2-

Educational background; Ch. 3- Position and corporate

structure; Ch. 4- MLS position; Ch. 5- Timekeeping policy.

1.50 $412.50

01/14/2014 MJO Drafted chapters for preparation of deposition of Transcend

corporate designee, re: Centralized administration of work;

centralized supervision; MLS offer letter; MLS transition offer

letter; hiring; job titles and duties; platforms; supervision;

training.

3.50 $962.50

01/14/2014 JMF Expanding and preparing exhibits for document based

chapters; expanding chapters/sorting exhibits for document

based chapters; draft and sort chapters on BeyondTXT

handbook/platform.

12.70 $2,857.50

01/14/2014 CRM Direct contract attorney on next portion of Motion to Compel

drafting with respect to non-responsive corporate rep depo

testimony

0.20 $55.00

01/14/2014 CRM Meet with contract attorney to determine status and

staffing of Motion to Compel

0.20 $55.00

01/14/2014 CRM Draft section of Motion to Compel related to deficiencies

with Defendant's responses to Plaintiff's second request for

production

2.60 $715.00

01/14/2014 CRM Review and make hand corrections to motion to

Compel

0.70 $192.50

01/14/2014 CA Call and email Cathy Haines 0.25 $56.25

01/14/2014 CA Finished draft of part 2 of Motion to Compel: Draft part 3 of

Motion to Compel

2.00 $450.00

01/14/2014 CA Draft final part of Motion to Compel 3.00 $675.00

01/14/2014 CA Draft response to opposing counsel's deficiency letter 0.80 $180.00

01/14/2014 CA Examined and added questionnaires to damages spreadsheet 0.75 $168.75

01/14/2014 CA Meeting with K. Dolley 0.25 $56.25

01/14/2014 CA Draft part 2 of Motion to Compel 2.00 $450.00

01/14/2014 CA Assist with preparation of exhibits to prepare for corporate

representative deposition

6.00 $1,350.00

01/14/2014 MRK Revision of 30(b)(6) notice of deposition to comply with court

order; Preparation of questioning for corporate designee

deposition.

8.10 $1,822.50

01/14/2014 MRK Change Motion for Extension of Time into Motion to Compel;

review relevant correspondence; draft section RE compliance

with local rule 37.2; review Rex Brown case

11.20 $2,520.00

01/14/2014 JRR Change Motion for Extension of Time into Motion to

Compel; review relevant correspondence; draft section RE

compliance with local rule 37.2; review Rex Brown case

11.20 $2,520.00

01/15/2014 MJO Travel time from St. Louis, MO to Tampa, FL for purposes of

second-chairing depositions of Defendant’s corporate

designees with Attorney Kevin Dolley.

3.00 $825.00

01/15/2014 MJO Analyzed/examined documents and exhibits to prepare for

deposition of Defendant’s corporate designee, re: Defendant’s

timekeeping policies; Defendant’s payroll policies; Defendant’s

MKM policy; Defendant’s overtime policies; Defendant’s

“hands on keyboard” policies.

1.50 $412.50

01/15/2014 MJO Second chaired deposition of Defendant’s corporate designee 7.00 $1,925.00
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01/15/2014 JMF

Catherine Dundas.

Expanding chapters from updated/finalized 30(b)(6). 5.40 $1,215.00

01/15/2014 CRM Review/revise Motion to Compel. Present to Attorney K. Dolley

for review.

0.90 $247.50

01/15/2014 CRM Review exhibits for motion to compel 0.40 $110.00

01/15/2014 CRM Further revisions to motions to compel 0.50 $137.50

01/15/2014 CRM Review/revise motion to compel. Email to co-counsel for

review.

0.30 $82.50

01/15/2014 CRM Phone call with Attorney K. Dolley, re: changes needed to

motion to compel

0.10 $27.50

01/15/2014 CRM Revise Motion to Compel, removing reference to

individual depos. Re-number exhibits.

0.50 $137.50

01/15/2014 CRM Instruct contract attorney to draft notice of hearing, re:

motion to compel

0.30 $82.50

01/15/2014 CRM Phone call from attorney K. Dolley, re: final revisions

needed on motion to compel

0.10 $27.50

01/15/2014 CA Revise deficiency response based on CRM suggestions 0.80 $180.00

01/15/2014 CA Updated contact info list 0.50 $112.50

01/15/2014 CA Worked on interrogatories for additional members 2.00 $450.00

01/15/2014 CA Added questionnaire to damages spreadsheet 0.25 $56.25

01/15/2014 CA Examined Defendant allegation plaintiffs had deficient

responses and composed list document

1.50 $337.50

01/15/2014 CA Looked up case law for response to Deficiency Letter 0.75 $168.75

01/15/2014 CA Phone call with Cathy Haines 0.25 $56.25

01/15/2014 CA Draft response to opposing counsel's deficiency letter 0.80 $180.00

01/15/2014 CA Review deposition transcripts of opt-in plaintiffs re deficiency

response

1.50 $337.50

01/15/2014 CA Draft response letter to opposing counsel's deficiency letter 2.50 $562.50

01/15/2014 CA Discussion with CRM re deficiency response and suggested

revisions

0.20 $45.00

01/15/2014 KJD Travel from STL Office to Airport to Tamps, FL, pick up rental

car and drive to rented house; Prepare for general corp rep

designee deposition. Detailed review and drafting questions,

extensive document review.

12.00 $5,400.00

01/15/2014 MRK Review and hand correction of motion to compel,

deficiency letter re discovery issues

4.20 $945.00

01/15/2014 JRR Gather and organize exhibits for Motion to Compel. 0.70 $157.50

01/16/2014 MJO Analyzed/examined documents and exhibits to prepare for

deposition of Defendant’s corporate designee, re: BeyondTXT

software platform.

1.50 $412.50

01/16/2014 CRM Instruct contract attorney to revise Motion to Compel based

on instructions from attorney K. Dolley

0.10 $27.50

01/16/2014 CRM Draft cover letter for courtesy copies of Motion to

Compel

0.20 $55.00

01/16/2014 CRM Review and finalize Motion to Compel exhibits and notice

of motion prior to filing

0.50 $137.50

01/16/2014 CRM File Motion to Compel, exhibits and Notice of Motion via

ECF

0.20 $55.00

01/16/2014 CRM Instruct paralegal to overnight courtesy copy of Motion to

Compel to Judge's chambers

0.10 $27.50

01/16/2014 CA Review opt-in plaintiffs' deposition transcript; draft summary

of opt-in plaintiffs' depositions

3.20 $720.00

01/16/2014 KJD Prepare for corp. designee depo (general); Take defendant's

general corp designee deposition; further preparation for corp

designee deposition for transcriptionist platform.

13.00 $5,850.00

01/16/2014 JRR Gather and organize exhibits for Motion to Compel; make

changes and final edits to motion;

6.80 $1,530.00

01/17/2014 MJO Second-chaired deposition of Defendant’s corporate

representative Scott Robertson.

6.00 $1,650.00
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01/17/2014 MJO Travel time from Tampa, FL to Chicago, IL for purposes of

connecting with flight to St. Louis, MO and returning home

after second-chairing Defendant corporate designee

depositions.

2.50 $687.50

01/17/2014 MJO Travel time from Chicago, IL to St. Louis, MO for purposes of

returning home after second-chairing corporate designee

depositions in Clearwater, FL.

1.50 $412.50

01/17/2014 CA Examined Patty Rapp deposition and began drafting

deposition summary

0.75 $168.75

01/17/2014 CA Began drafting summary of discovery 1.00 $225.00

01/17/2014 CA Draft deposition summary for Kathleen Schuster 1.30 $292.50

01/17/2014 CA Review deposition transcript of opt-in plaintiff 1.80 $405.00

01/17/2014 CA Draft deposition summary for opt-in plaintiff 2.40 $540.00

01/17/2014 CA Review deposition transcript of opt-in plaintiff 1.40 $315.00

01/17/2014 CA Compile list of documents produced to Defendant 0.80 $180.00

01/17/2014 KJD Further preparation for corp designee deposition, beyond TXT

platform; Deposition of Defendant corp rep designee,

transcription and Beyond TXT platform; draft document/report

update of Defendant's corp rep depositions.

8.00 $3,600.00

01/17/2014 JRR Draft response to Defendant's January 16, 2014 Motion to

Compel. Send to KJD and MJO for review.

6.90 $1,552.50

01/18/2014 CA Draft summary of discovery 2.50 $562.50

01/19/2014 KJD Travel from Clearwater, FL to airport to STL airport to home. 3.50 $1,575.00

01/20/2014 CRM Discuss status of response to motion to compel with

attorney K. Dolley

0.20 $55.00

01/20/2014 CRM Revise response to Motion to Compel per notes from

Attorney K. Dolley and opt-in discovery prepared by contract

attorney

0.90 $247.50

01/20/2014 CRM Revise response to Motion to Compel and file via ECF 0.90 $247.50

01/20/2014 CA Draft Patty Rapp Deposition summary 2.00 $450.00

01/20/2014 CA Draft Patty Rapp Deposition summary 2.00 $450.00

01/20/2014 CA Draft Patty Rapp Deposition summary 1.25 $281.25

01/20/2014 CA Begin draft of Wendolyn Smith deposition summary 2.75 $618.75

01/20/2014 KJD Prepare for status hearing with Judge Guzman in Chicago;

Review and revise response to Defendant's Motion to Compel.

2.50 $1,125.00

01/21/2014 CA Examined Scott Robertson deposition for good deposition

preparation questions

0.25 $56.25

01/21/2014 CA Draft Wendolyn Smith deposition summary 1.00 $225.00

01/21/2014 CA Compile list of docs produced to Defendant 0.40 $90.00

01/21/2014 CA Review deposition transcript of opt-in plaintiff 1.60 $360.00

01/21/2014 CA Draft deposition summary for opt-in plaintiff 1.80 $405.00

01/21/2014 CA Draft deposition summary for corporate representative 2.40 $540.00

01/21/2014 CA Draft deposition summary for opt-in plaintiff 1.10 $247.50

01/21/2014 CA Draft Wendolyn Smith deposition summary 0.75 $168.75

01/21/2014 KJD Draft, prpare email Plaintiff's counsel information on court

order/hearing today; call with Russ, discuss case, use of

manpower and response to Defendant's compliance; Travel

home to airport, taxi to courthouse; hearing before Judge

Guzman; travel courthouse to airport, travel from Chicago to

STL; review pleadings and prepare for next hearing before

court.

7.75 $3,487.50

01/22/2014 CRM Discuss next litigation steps with attorney K. Dolley 0.80 $220.00

01/22/2014 CRM Phone call with co-counsel re: Defendant's Jan. 21, 2014

ESI explanation letter

0.80 $220.00

01/22/2014 CRM Draft letter to opposing counsel re: ESI research. Focus on

custodians and lack of specificity.

5.50 $1,512.50

01/22/2014 CRM Additional drafting of ESI response letter. Review and revise

suggested custodians to search.

0.20 $55.00

01/22/2014 CA Examined Scott Robertson deposition for good deposition

preparation questions

0.75 $168.75
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01/22/2014 CA Examined Scott Robertson deposition for good deposition

preparation questions

0.25 $56.25

01/22/2014 CA Draft letter requesting production data from opposing counsel 2.50 $562.50

01/22/2014 CA Draft letter requesting production data from opposing counsel 2.00 $450.00

01/22/2014 CA Draft revised search term list 2.75 $618.75

01/22/2014 JES Built out chapter re: platforms used by MLS's for the Corp Rep

Depo; discussed splitting up chapters on BeyondTXT with JF;

drafted a chapter on BeyondTXT- Monitoring of MLS's for the

BeyondTXT Depo

11.60 $2,610.00

01/23/2014 MJO Drafted Plaintiffs’ correspondence in response to Mersol’s

1/21/2104 correspondence; drafted and edited Introduction

and timeline of events leading up to 1/21/2014 hearing and

correspondence.

2.50 $687.50

01/23/2014 MJO Drafted Plaintiffs’ correspondence in response to Mersol’s

1/21/2104 correspondence; drafted and edited Section 1-

Defendant’s Continued Focus On Plaintiffs’ Individual Email

Accounts Violates The Court’s Order Dated January 10, 2014.

1.50 $412.50

01/23/2014 MJO Drafted Plaintiffs’ correspondence in response to Mersol’s

1/21/2104 correspondence; drafted and edited Section 2-

Plaintiffs Requested The Information Defendant Continues to

Withhold Multiple Times Throughout The Discovery Period;

Section 3- Issues Associated With Defendant’s Back-Up,

Retrieval, and Maintenance of ESI.

2.00 $550.00

01/23/2014 MJO Drafted Plaintiffs’ correspondence in response to Mersol’s

1/21/2104 correspondence; drafted and edited Section 4-

Defendant Must Produce Its Litigation Hold Letters; Section 5-

Defendant Must Provide A Reasonable Basis For Their Vastly

Decreased Number Of Discoverable Documents; Section 6-

Reasonableness and Reliability of Purported Search Protocol

and Suggested Protocol.

2.00 $550.00

01/23/2014 JMF Summarize transcript of hearin 1/10 for ESI letter, Drft

introduction of ESI letter.; research on discoverability of

litigation hold letter, draft letter sections incorporating the law

on reasonale search procedures.; finalize ESI letter draft.

11.50 $2,587.50

01/23/2014 CRM Review and revise court order compliance letter. Discuss

with attorney K. Dolley and email to K. Dolley for review.

1.10 $302.50

01/23/2014 CA Researched case law on ESI 0.50 $112.50

01/23/2014 KJD Draft detailed correspondence to Opposing Counsel regarding

BeyondTXt Platform data not produced by defendants to date;

draft of ESI non-compliance letter directed to defendant and

motion being prepared related to ESI; cort order filed today

regarding discovery non-compliance from defendant, granting

plaintiff's motion.

6.60 $2,970.00

01/24/2014 MJO Drafted Plaintiffs’ Motion to Compel Information Related to

Defendant’s Search for Electronically Stored Information

(“ESI”), re: Introduction; Certificate of Compliance; Factual

Background.

2.50 $687.50

01/24/2014 MJO Drafted Plaintiffs’ Motion to Compel Information Related to

Defendant’s Search for Electronically Stored Information

(“ESI”), re: Legal Standard; Argument- Defendant Must

Produce Its Litigation Hold Letters Issued During The Class

Period; Defendant Failed To Identify Significant Information

Associated With Its Back-Up Of ESI, Maintenance Of ESI, And

Attempt To Retrieve ESI From Microsoft.

2.00 $550.00

01/24/2014 MJO Drafted Plaintiffs’ Motion to Compel Information Related to

Defendant’s Search for Electronically Stored Information

(“ESI”), re: Defendant Must Provide A Reasonable Basis

Explaining Why Only Approximately 1,500 Documents Out Of

A Total Of 3,000,000 Reviewed Are Discoverable; Defendant’s

Position That Plaintiffs Comprise Primary Custodians Violates

The Court’s Order Dated January 10, 2014.

2.00 $550.00
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01/24/2014 MJO Drafted Plaintiffs’ Motion to Compel Information Related to

Defendant’s Search for Electronically Stored Information

(“ESI”), re: V. Plaintiffs Requested The Information Defendant

Continues to Withhold Multiple Times Throughout The

Discovery Period; VI. Plaintiffs’ Proposed Individuals And

Search Protocol; Conclusion.

2.00 $550.00

01/24/2014 JMF Convert ESI letter to draft motion, draft and research sections

on preservation of records related to search and production of

hit logs; convert ESI letter to draft motion research on

reasonableness reliability of search protocol, production of

search ledger, production of litigation hold letter, draft

sections on each.

9.00 $2,025.00

01/24/2014 CRM Review and revise letter to opposing counsel regarding

production of platform data. Email to opposing counsel.

1.80 $495.00

01/24/2014 CRM Draft Fourth Motion to Compel production of platform data

and order to show cause.

4.60 $1,265.00

01/24/2014 CRM File Fourth Motion to Compel Production of platform data

and for order to shouw cause. Confirm filing and save.

0.50 $137.50

01/24/2014 CRM Draft and file Notice of Motion for Fourth Motion to

Compel.

0.30 $82.50

01/24/2014 CRM Prepare courtesy copy of Fourth Motion to Compel. Deliver to

FedEx and overnight to Chambers. Draft cover letter regarding

the same.

0.50 $137.50

01/24/2014 CA Draft Wendolyn Smith deposition summary 3.00 $675.00

01/24/2014 CA Put in sites to data document 1.75 $393.75

01/24/2014 CA Draft Wendolyn Smith deposition summary 1.25 $281.25

01/24/2014 KJD Review and revise Beyon TXT deficiency letter to OC; Draft

BeyondTXT Motion to Compel, ESI.

9.00 $4,050.00

01/24/2014 JES Sent Anne Thorpe an email, re: sending the opt-in email her

individual emails.

0.20 $45.00

01/25/2014 MJO Drafted Plaintiffs’ Motion to Compel ESI and For Sanctions, re:

Defendant’s January 21, 2014 Correspondence And Corporate

Designee Admit Defendant Spoliated Massive Amounts of

Discoverable Evidence- Defendant’s Counsel Indicated Deleted

Emails And Email Accounts Were Erased- Platform Destruction

And Resulting Spoliation.

1.50 $412.50

01/25/2014 MJO Drafted Plaintiffs’ Motion to Compel ESI and For Sanctions, re:

Defendant’s Response To This Court’s Order In Terms of the

ESI Search Protocol Defendant Now Seeks to Conduct Is

Insufficient and Improper- Defendant Failed To Reveal Its

Electronic Custodians; Defendant Failed To Reveal The

Timeline Of Its ESI Search And Preservation Efforts; Defendant

Failed To Reveal The Procedure It Used To Search For ESI;

Defendant Failed To Specify Which Product It Used To

Maintain ESI; Defendant Failed To Specify The Methods It

Used To Back-Up ESI; Defendant Failed To Indicate Whether

Or Not It Attempted To Recover Deleted ESI; Defendant Failed

To Produce Platform Information.

2.00 $550.00

01/25/2014 MJO Drafted Plaintiffs’ Motion to Compel ESI and For Sanctions, re:

edited Introduction and Legal Standard; ArgumentDefendant’s Decision To Start E-Discovery After The Close Of

Merits-Stage Discovery Violates This Court’s Case Management

Order; Defendant’s January 21, 2014 Correspondence And

Corporate Designee Admit Defendant Spoliated Massive

Amounts of Discoverable Evidence- Defendant’s Counsel

Indicated Deleted Emails And Email Accounts Were Erased.

1.50 $412.50

01/25/2014 JMF Convert ESI letter to draft motion into second draft- research

on discovery sanctions and standards, shoehorn missing

platform section into ESI, research on Spoliation issues,

Drafting sections 2 through 4 Non production troubling and

inadequate, commencing production now troubling and

inadequate and untimely.

8.50 $1,912.50
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01/25/2014 KJD Review/revise and prpare ESI Motion to Compel. 3.00 $1,350.00

01/26/2014 MJO Drafted Plaintiffs’ Motion to Compel ESI and For Sanctions, re:

edited Introduction; Plaintiffs’ Request for Imposition of

Sanctions On Defendant; Plaintiffs’ Proposed ESI Solution.

1.50 $412.50

01/26/2014 MJO Emailed local counsel, re: delivering courtesy copies of Motion

to Compel and Notice of Hearing to Court.

0.20 $55.00

01/26/2014 KJD Review and edit ESI Motion to Compel. 2.00 $900.00

01/27/2014 CRM Instruct paralegal to arrange for courier service for

courtesy copy of ESI Motion to Compel/Sanctions

0.10 $27.50

01/27/2014 CRM Update attorney M. Obermeyer on status of courtesy copy

of ESI Motion to Compel/Sanctions.

0.10 $27.50

01/27/2014 CRM Update attorney M. Obermeyer on status of courtesy copy

of ESI Motion to Compel/Sanctions.

0.10 $27.50

01/27/2014 KJD Travel from Charlotte, NC to Chicago to hotel for morning

hearing; prepare for hearing regarding Motions to Compel,

regarding ESI and Platform Data; Hearing, regarding status

conference and motion hearing before Judge Guzman; Travel

from court to airport to STL airport to office.

7.75 $3,487.50

01/28/2014 MJO Telephone call with co-counsel Kevin Dolley, re: hearing

before Hon. Ronald Guzman 1/28/14 and Judge Guzman’s

Order concerning Defendant’s production of platform data.

0.50 $137.50

01/28/2014 MJO Drafted email for review of attorney Kevin Dolley to cocounsel, re: update on case after hearing before Judge

Guzman concerning Defendant’s production of platform data.

0.80 $220.00

01/28/2014 MJO Drafted deposition summary for deposition of Corporate

Representative Catherine Dundas, re: drafted summary for

purposes of condensing information for inclusion in response

to Defendant’s pending Motion to De-Certify Class concerning

uniform applicability of Defendant’s wage and hour policies.

1.50 $412.50

01/28/2014 CRM Phone call from attorney K. Dolley re: case status

following hearing.

0.50 $137.50

01/29/2014 MJO Conducted research on issue of responding to Defendant’s

pending Motion to De-Certify Class, re: researched case law in

Seventh Circuit and Northern District of Illinois concerning

legal standard for de-certifying conditionally certified FLSA

collective action as stated in numerous cases including but

not limited to Russell v. Illinois Bell Telephone, Alvarez v. City

of Chicago, Cottle v. Falcon Holdings Management, LLC,

Espenscheid v. DirectSat USA; began drafting legal analysis

section concerning Defendant’s burden of demonstrating

factual dissimilarities exist to justify de-certifying conditionally

certified class.

3.50 $962.50

01/29/2014 MJO Meeting with Attorney Kevin Dolley, re: strategy for litigating

case, including MLS production reports; calculation of MLS

regular rate of pay.

0.50 $137.50

01/29/2014 MJO Drafted deposition summary for deposition of Corporate

Representative Catherine Dundas, re: drafted summary for

purposes of condensing information for inclusion in response

to Defendant’s pending Motion to De-Certify Class concerning

uniform applicability of Defendant’s wage and hour policies.

1.50 $412.50

01/30/2014 MJO Drafted email to co-counsel, re: assistance on responding to

Defendant’s pending Motion for Decertification.

0.80 $220.00

01/30/2014 MJO Drafted summary of deposition of Patti Rapp for purposes of

responding to Defendant’s pending Motion for Decertification,

re: job title; workstation/home office; scheduled shift; job

duties.

1.20 $330.00

01/30/2014 MJO Drafted summary of deposition of Patti Rapp for purposes of

responding to Defendant’s pending Motion for Decertification,

re: hours worked; production/accuracy quotas; line

rate/production-based compensation structure; TimeSaver

timekeeping policy/work hours recorded;

managers/management structure; accounts structure; MKM

prompt; employer knowledge; BeyondTXT; time flexing.

1.50 $412.50
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01/30/2014 MJO Drafted summary of deposition of Diane Martin for purposes

of responding to Defendant’s pending Motion for

Decertification, re: job title; workstation/home office;

scheduled shift; job duties hours worked;

production/accuracy quotas; line rate/production-based

compensation structure; TimeSaver timekeeping policy/work

hours recorded; managers/management structure; accounts

structure; MKM prompt; employer knowledge; BeyondTXT;

time flexing.

2.50 $687.50

01/30/2014 CA Draft deposition summary of corporate representative

deposition

3.00 $675.00

01/30/2014 CA Draft deposition summary of corporate representative

deposition

2.50 $562.50

01/30/2014 CA Draft deposition summary of corporate representative

deposition

1.00 $225.00

01/31/2014 MJO Drafted summary of deposition for Plaintiff Patsy Hayes, re:

description of workstation; scheduled shift; specific job

duties; estimated number of hours worked; production-based

compensation structure; drafted for purposes of responding to

Defendant’s Motion for Decertification.

1.50 $412.50

01/31/2014 MJO Drafted summary of deposition for Plaintiff Patsy Hayes, re:

TimeSaver/recording hours worked; Managers; Accounts;

Employer Knowledge; BeyondTXT; Time flexing; drafted for

purposes of responding to Defendant’s Motion for

Decertification.

1.50 $412.50

01/31/2014 MJO Depo summary for Kathleen Schuster, re: description of

workstation; scheduled shift; specific job duties; estimated

number of hours worked; production-based compensation

structure; drafted for purposes of responding to Defendant’s

Motion for Decertification.

1.50 $412.50

01/31/2014 CA Draft deposition summary 4.70 $1,057.50

01/31/2014 CA Draft deposition summary 2.40 $540.00

01/31/2014 CA Review deposition of opt-in plaintiff in prep of drafting

summary

0.50 $112.50

02/02/2014 MJO Conducted research, re: decertification law specifically

concerning individualized assessment of damages and

Defendant’s ability to present defenses throughout federal

circuits for purposes of responding to Defendant’s Motion for

Decertification; read and annotated numerous cases including

but not limited to Falcon v. Starbucks Corp. (SD Tex.);

Thompson v. Bruister & Associates (MD Tenn.); Prescott v.

Prudential Ins. Co. (D Me.); Nerland v. Caribou Coffee (D.

Minn.); Andrako v. US Steel Corp. (WD Pa.).

2.00 $550.00

02/03/2014 MJO Meeting with Attorneys Kevin Dolley and Conor McCullough,

re: decertification and settlement position/strategy.

1.50 $412.50

02/03/2014 MJO Drafted summary of deposition for Plaintiff Kathleen Schuster,

re: production-based compensation structure;

TimeSaver/hours recorded; Managers; Accounts; BeyondTXT;

time flexing; training; drafted for purposes of responding to

Defendant’s Motion for Decertification.

1.70 $467.50

02/03/2014 MJO Analyzed and examined exhibits from first round depositions

of Patricia Clunk, Deborah Waldman, Teresa Cosentino, Karen

Milan, and Lisa Smith for purposes of gathering exhibits in

response to Defendant’s Motion for Decertification.

1.50 $412.50

02/03/2014 MJO Drafted summary of deposition for Plaintiff Marie Plum, re:

Job title; job duties; schedule/shift; workstation; hours

worked; production/accuracy quotas.

1.00 $275.00

02/03/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s

Motion for Leave to File Instanter Its Memorandum of Law In

Support of Decertification In Excess of 15 pages.

0.80 $220.00

02/03/2014 CRM Meeting with attorneys M. Obermeyer and K. Dolley re: case

status, decertification, and settlement

1.50 $412.50
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02/03/2014 CRM Review Akins case re: propriety of filing second FLSA

collective action while case pending. Further research on

issue.

0.80 $220.00

02/03/2014 CRM Additional research re: second FLSA collective action 0.70 $192.50

02/03/2014 CRM Discuss correspondence from opposing counsel re: platform

data production with attorneys M. Obermeyer and K. Dolley

0.20 $55.00

02/03/2014 CA Draft deposition summaries for opt-in plaintiffs 3.80 $855.00

02/03/2014 CA Draft deposition summaries for opt-in plaintiffs 3.00 $675.00

02/03/2014 CA Draft deposition summaries for opt-in plaintiffs 1.30 $292.50

02/04/2014 MJO Drafted deposition summary for Plaintiff Marie Plum, re:

TimeSaver/hours recorded; Managers; Accounts; BeyondTXT;

time flexing; training; drafted for purposes of responding to

Defendant’s Motion for Decertification.

1.50 $412.50

02/04/2014 MJO Analyzed and examined documents produced by Defendant

dated 2/3/14, re: production reports generated by BeyondTXT

for purposes of preparing Attorney Kevin Dolley for hearing

before Judge Guzman scheduled for 2/7/14.

0.50 $137.50

02/04/2014 MJO Deposition summary for Judy Lindquist, re: Job title; job

duties; schedule/shift; workstation; hours worked;

production/accuracy quotas; TimeSaver/hours recorded;

Managers; Accounts; BeyondTXT; time flexing; training;

drafted for purposes of responding to Defendant’s Motion for

Decertification.

3.00 $825.00

02/04/2014 MJO Emailed co-counsel Sam Moore, re: deposition summary of

Jacqueline St. Georges.

0.20 $55.00

02/04/2014 MJO Analyzed and examined hundreds of pages of documents

produced by Defendant during conditional certification phase

discovery, re: production summaries and reports produced by

Defendant for first set of Plaintiffs and opt­ins; emails

demonstrating uniform policy of rates/compensation

applicable to all MLSs for purposes of inclusion in Response to

Defendant’s Motion for Decertification.

1.50 $412.50

02/04/2014 MJO Drafted deposition summary for Plaintiff Julie Wright, re: read

and annotated relevant parts of 280 pages of deposition

transcript for purposes of responding to Defendant’s Motion

for Decertification.

2.50 $687.50

02/04/2014 CRM Review and revise response to Motion to file in excess of

page limitation. File via ECF.

0.70 $192.50

02/04/2014 CRM Initial review of decertification motion 0.60 $165.00

02/04/2014 CRM Review Defendant's reply to response in opposition to

motion for leave to file in excess of page limitation

0.30 $82.50

02/04/2014 CA Draft deposition summary for Failla 2.00 $450.00

02/04/2014 CA Draft deposition summary for DeBoard 2.40 $540.00

02/04/2014 CA Draft deposition summary for DeBoard 1.20 $270.00

02/04/2014 CA Draft deposition summary for opt-in plaintiff Spencer 2.00 $450.00

02/05/2014 MJO Drafted deposition summary for Plaintiff Julie Wright, re: Job

title; job duties; schedule/shift; workstation; hours worked;

production/accuracy quotas; TimeSaver/hours recorded;

Managers; Accounts; BeyondTXT; time flexing; training;

drafted for purposes of responding to Defendant’s Motion for

Decertification.

1.50 $412.50

02/05/2014 MJO Revised email to opposing counsel drafted by Attorney Kevin

Dolley, re: the Court’s Order to produce report generating data

and information on January 28.

1.50 $412.50

02/05/2014 MJO Drafted email to class for review of Attorney Kevin Dolley, re:

updates on case after the close of the second phase of

discovery.

0.50 $137.50

02/05/2014 MJO Drafted detailed outline for purposes of drafting Response to

Defendant’s Motion for Decertification, re: arguments and

facts to raise in Introduction and Facts section of Response in

Opposition to Defendant’s Decertification Motion.

1.20 $330.00
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02/05/2014 MJO Drafted Response in Opposition to Defendant’s Decertification

Motion, re: Introduction; Facts- Procedural History; briefly

established Plaintiffs’ similarly situated nature; Defendant’s

policies in violation of the FLSA and denying Plaintiffs

compensation for all compensable work time; the weakness of

Defendant’s nit-picking strategy; how Plaintiffs fulfill the three

factors allowing them to survive decertification.

1.20 $330.00

02/05/2014 MJO Analyzed and examined hundreds of pages of documents

produced by Defendant for 35 Plaintiffs subject to

individualized discovery, re: searched offer letters and

personnel files of numerous Plaintiffs including Barbara

Keenan, Patsy Hayes, Carol Failla, Karen Milan, Lisa Smith,

Wendolyn Smith, Kathleen Schuster, and Judy Lindquist for

exhibits demonstrating Plaintiffs similarly situated for purposes

of defeating Defendant’s decertification Motion.

2.00 $550.00

02/05/2014 CRM Revise draft of email to opposing counsel re: platform data

reporting. Email to attorney K. Dolley for review.

0.60 $165.00

02/05/2014 CRM Discuss same email with attorneys K. Dolley and M.

Obermeyer. Implement suggested revisions. Send to opposing

counsel.

0.70 $192.50

02/05/2014 CRM Review and discuss Order denying Defendant's Motion for

Leave to File in Excess of Page Limitation with attorneys K.

Dolley and M. Obermeyer

0.20 $55.00

02/05/2014 CRM Review exhibit re: eBeyondTXT log in/log out data.

Compare with production report data.

0.60 $165.00

02/05/2014 CRM Review response email from opposing counsel. Discuss with

attorney M. Obermeyer.

0.10 $27.50

02/05/2014 CA Draft deposition summary for opt-in plaintiff Spencer 2.50 $562.50

02/05/2014 CA Review deposition and draft deposition summary for opt-in

plaintiff Denio

2.70 $607.50

02/05/2014 CA Draft deposition summary for opt-in plaintiff Denio 1.10 $247.50

02/05/2014 KJD Draft email to OC regarding disclosure failures. 0.50 $225.00

02/06/2014 MJO Analyzed and examined entire electronic file for purpose of

conducting inventory of electronic discovery. Plaintiffs are

receiving on "rolling" basis, re: created 24 separate folders

and sub-folders fo categorization of data, including but not

limited to Defendant's Documents Produced in Response to

Plaintiffs' Second Set of Discovery; ESI Discovery;

Decertification; State 2 Discovery Between Parties; Motions to

Compel; Notice & Opt-in Period; Plaintiffs Contact

information; Depositions; Research; State 1 Discovery Between

Parties; Mediation; Hearing Transcripts; Motions-Other.

3.50 $962.50

02/06/2014 MJO Drafted Response in Opposition to Defendant's Motion for

Decertification, re: Plaintiffs' Factuald and Employement

Settings; detailed facts concerning Plaintiffs' similar job title as

MLS or Medical Transcriptionists; Plaintiffs performed the same

uniform primary job duties of medicl transcription; Plaintiffs

performed the same research duties; Plaintiffs all worked from

their homes and had similar work enviroments with an area or

office dedicated to home transcription work; consulted

numerous deposition transcripts to draft facts section,

including depositions of Janeen DeBoard, Laura Denio, and

Diana Martin.

2.00 $550.00

02/06/2014 CA Save and print documents received from Defendant 1.70 $382.50

02/07/2014 MJO Researched viability of filing second collective action; drafted

memorandum for inter-office circulation concerning filing

second collective action.

0.80 $220.00

02/07/2014 MJO Organized case file, re: correspondence, pleadings, discovery

dating from January and February 2014.

2.00 $550.00

02/07/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Decertification, re: Facts concerning uniform job duties of

MLSs and uniform timekeeping system implemented by

1.50 $412.50
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02/07/2014 MJO

Transcend.

Researched all federal circuits for case law, re: factual 1.50 $412.50

discrepancies and individualized defenses for claims of off-theclock work; read numerous out-of-circuit cases including but

not limited to Wilks v. Pep Boys (MD Tenn.) and Mendez v.

Radec Corp. (WMAKY) demonstrating survival of

decertification in face of inevitable individual variation

between Plaintiffs; research done for purposes of overcoming

steps 1 and 2 of decertification analysis addressed by

Defendant’s Motion to Decertify.

02/10/2014 CA Copy and burn all documents received from Defendant for

MJO

1.50 $337.50

02/10/2014 CA Save all documents received from defendant to external hard

drive; print off documents received from defendant; copy and

burn all documents received from defendant to dvd for MJO

4.80 $1,080.00

02/11/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify Class, re: Plaintiffs’ Uniform Job Duties; added

approximately 7 substantive footnotes to section; consulted

deposition transcripts of Catherine Dundas, Lisa Edwards,

Janeen DeBoard, Patricia Rapp, Barbara Keenan, and Joy

McLemore, and MLS Job Description.

1.20 $330.00

02/11/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify Class, re: Plaintiffs’ Uniform Job Duties; added

approximately 5 substantive factual footnotes to section;

consulted deposition transcripts of Catherine Dundas, Janeen

DeBoard, Laura Denio, Carol Failla, Patsy Hayes, Kandace

Chancey, Barbara Keenan, Judy Lindquist, Joy McLemore,

Serena Marques, Diane Martin, Julie Wright, and Margaret

Thorpe.

1.50 $412.50

02/11/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify Class, re: Uniform Production-Based Compensation

Structure; added approximately 5 substantive factual

footnotes to section; consulted deposition transcript of

Catherine Dundas, Transcend Employee Handbooks, and

Transcend MLS Offer Script for factual support.

1.00 $275.00

02/11/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify Class, re: Uniform Performance, Quality, and

Accuracy Standards; added approximately 5 factual footnotes

to section; consulted deposition transcript of Catherine

Dundas and Transcend Employee Handbooks for support.

0.50 $137.50

02/11/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify Class, re: Uniform Understanding of Piece Rate

Compensation; argued Plaintiffs shared the understanding that

their piece rate method of compensation was not intended to

cover their compensation for all duties; consulted deposition

transcripts of Patsy Hayes, Kathleen Schuster, Darcy Wingler,

Janeen DeBoard, Laura Denio, Kandace Chancey, and

Catherine Dundas; consulted Transcend employee offer letters

and email from DonFrancesco to Dundas, 12/21/2010.

2.00 $550.00

02/11/2014 MJO Emailed co-counsel Sam Moore and Russ Riggan, re:

deposition summaries for Plaintiffs defended.

0.20 $55.00

02/12/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Uncompensated Work Performed By

Plaintiffs; argued and provided introductory general facts in

opposition to Defendant’s “rogue manager” argument;

established facts supporting argument that 35 Plaintiffs from

Montana to New Hampshire with numerous different

supervisors reported the same injury of recording less hours

than actually worked on their TimeSaver timesheet.

1.00 $275.00

02/12/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Uncompensated Work Performed By

Plaintiffs; Plaintiffs Only Reported And Were Only

Compensated For Hands On Keyboard Time; individualized

2.00 $550.00
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bullet-points detailing testimony of Janeen DeBoard, Laura

Denio, Carol Failla, Patsy Hayes, Joy McLemore and facts

concerning their reported time and how much compensable

work they actually performed.

02/12/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Plaintiffs’ Uniform Understanding Of

Defendant’s Definition of Compensable Work Time; provided

additional facts supporting notion thatPlaintiffs understood

they were only compensated for “hands on keyboard” time.

1.00 $275.00

02/12/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Defendant’s Failure to Explain ItsPiece

Rate Compensation Structure; provided additional facts

concerning Defendant’s uniform failure to explain the work

duties itspiece rate was intended to cover to applicants for

MLS position before or uponhiring.

1.00 $275.00

02/12/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Uncompensated Work Performed By

Plaintiffs;Plaintiffs Only Reported And Were Only

Compensated For Hands On Keyboard Time; individualized

bullet-points detailing testimony of Theresa Cosentino, Judy

Lindquist, Serena Marques, Diane Martin, MariePlum, Patricia

Rapp, Kathleen Schuster, Diane Spencer, Jacqueline St.

Georges, Margaret Thorpe, and Julie Wright and facts

concerning their reported time and how much compensable

work they actually performed.

3.00 $825.00

02/13/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Uniform Understanding Of Compensable

Work Time; added testimony of numerousPlaintiffs regarding

their understanding of compensable “production,” or “hands

on keyboard” time; consulted deposition transcripts ofLinda

Armstrong (Minnesota), Joy Bargerstock (Pennsylvania),

Patricia Clunk, (Virginia), Barbara Vaughn (Georgia), Shara

Howard (Tennessee), Lisa Edwards (Georgia), Barbara Keenan

(Florida), Janeen DeBoard (Florida), Laura Denio (Texas),

Carol Failla (North Carolina), Theresa Cosentino (Illinois),

Patsy Hayes (Missouri), Diane Martin (Montana), Joy

McLemore (Georgia), Judith Lugo (Florida), Diane Spencer

(Maryland), Steven Martin (Tennessee), Julie Wright (Texas),

Kandace Chancey (Texas), Kathleen Schuster (Ohio), Judy

Lindquist (Nebraska), Sarena Marques (Florida), MariePlum

(Missouri),Linda Mathias (Colorado), Lisa Smith (New

Hampshire), Dawn Pence (South Dakota), Patricia Rapp

(Illinois), Margaret Thorpe (Texas), Debra Tolles (Ohio),

Wendolyn Smith (Texas), and Sheila Reeser (Florida) for

evidence and passagesin support of Plaintiffs’ uniform

understanding of hands on keyboard time.

3.50 $962.50

02/13/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Defendant’s Failure To Explain ItsPiece

Rate Method Of Compensation; added additional facts and

footnotes concerning Defendant’s corporate representative

testimony thatPlaintiffs and MLSs were not provided an

understanding of OT compensation orpiece rate method of

compensation beforehiring.

1.00 $275.00

02/13/2014 MJO EmailedPlaintiff Lisa Smith, re: update on case. 0.10 $27.50

02/13/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Defendant Instructed And Pressured Plaintiffs To Underreport Their Hours Worked And Change

Their Timesheets; consulted deposition transcripts ofLinda

Armstrong, Joy Bargerstock, Theresa Cosentino, Laura Denio,

Patricia Rapp, Sarena Marques, Diane Martin, Margaret Thorpe,

Julie Wright, Carol Failla, Diane Spencer, Dawn Pence, Lisa

Edwards, Barbara Vaughn, Patricia Clunk, Debra Tolles, Shara

Howard, and JudyLindquist for evidencein support of

common policy of instruction/encouragement to underreport

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hours; argued Defendant implemented common policy telling

MLSs to underreport hours worked; argued extensive

testimony and evidence belies Defendant’s “rogue manager”

argument.

02/13/2014 MJO Sent out class-wide email to first 500 class members, re:

update to casein decertification phase.

1.00 $275.00

02/14/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re:Plaintiffs Often Did Not Receive Overtime

Pay, Or Were Paid Overtime At Less Than Minimum Wage;

consulted deposition transcripts of Theresa Cosentino, Janeen

DeBoard, Diane Martin, Diane Spencer, MariePlum, Patricia

Rapp, Laura Denio, Patsy Hayes, Judy Lindquist, Joy

McLemore, Sarena Marques,Linda Mathias, Judith Lugo,

Kathleen Schuster, Margaret Thorpe, Barbara Vaughn, Joy

Bargerstock, Barbara Keenan, Julie Wright, and Darcy Wingler

for evidence ofPlaintiffs whodid not receive overtime pay

though they testified they worked over 40 hours per workweek.

2.50 $687.50

02/14/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re:Plaintiffs Often Did Not Receive Overtime

Pay, Or Were Paid Overtime At Less Than Minimum Wage;

consulted pay stubs and Earnings Statements of class

members with last names A-M for evidence of overtime rates

being less than $7.25 per hour; discussed pay stubs of Patsy

Hayes, Judy Lindquist, and Sarena Marques as evidence of

Defendant’s common policy payingPlaintiffs under $7.25 per

hour as overtime compensation.

1.50 $412.50

02/14/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Transcend SubjectedPlaintiffs ToA

Uniform Scheduling and Time Flexing Policy Under Which

Plaintiffs Were Expected To WorkA Particular Shift, But If

There Was No Work During Their Shift, They Were Required

To Remain Near Their Computers And Continually Check As To

When Work Became Available; consulted deposition

transcripts of Patsy Hayes, Diane Spencer, Jacqueline St.

Georges, Judy Lindquist, Barbara Vaughn, Theresa Cosentino,

Patricia Clunk, Joy McLemore,Linda Mathias, Diane Martin,

MariePlum, Laura Denio, Patricia Rapp, and Kathleen Schuster

for evidence of impact of time flexing.

2.50 $687.50

02/15/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Defendant Knew Or Should Have Known Plaintiffs Performed Work In Excess Of Their Recorded Time;

argued Defendant could tell when particularPlaintiff was

online typing, and whena particularPlaintiff downloadeda

report for editing, and submitteda completed report;

consulted deposition testimony of corporate representative

Scott Robertson, Defendant’s Editing Proficiency Tutorial,

Editing Proficiency Reports, and deposition transcripts of

Laura Denio and Julie Wright for evidence of Defendant’s

knowledge of whenPlaintiffs were online and working.

3.00 $825.00

02/15/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: conducted detailed review of Facts, and

inserted numerous footnotes into following sections: Plaintiffs’

Factual and Employment Settings; Defendant’s Failure To

Explain ItsPiece Rate Compensation Structure;

Uncompensated Work Performed By Plaintiffs; Defendant

Knew Or Should Have KnownPlaintiffs Were Performing Work

In Excess Of Their Reported Time.

1.00 $275.00

02/16/2014 MJO "Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Analysis, FLSA Decertification Standard;

Courts In The Seventh Circuit UseA Two-Step Analysis To

Determine WhetherPlaintiffs Should Proceed Collectively;

Cited numerous cases from Seventh Circuit determining

appropriate process for2 step analysis at certification stage.

1.00 $275.00
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02/16/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Plaintiffs’ Similar Factual and Employment

Settings; Defendant Ignores Plaintiffs’ Similar Factual and

Employment Settings; cited numerous cases from 7th Circuit

and other federal circuits stating appropriate standard as

“common question” analysis, not Defendant’s nuanced

analysis of miniscule differences between class members, at

decertification stage.

1.50 $412.50

02/16/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: revised Introduction; inserted analysis of

Judge Guzman’s 6 factors for determining Plaintiffs similarly

situated at the conditional certification stage.

0.50 $137.50

02/17/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: examination analysis concerning Judge

Kennelly’s decision denying decertification in Russell v. Illinois

Bell.

1.00 $275.00

02/17/2014 MJO Meeting with Attorney Kevin Dolley, re: settlement talks with

other side and email shared on webpage.

0.30 $82.50

02/17/2014 MJO Telephone call with Plaintiff Dawn Pence, re: online posting

of client communication.

0.40 $110.00

02/17/2014 KJD Review status of case, client responses and settlement

conference possibility. Discuss with co-counsel MJO.

0.20 $90.00

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Plaintiffs’ Similar Factual and Employment

Settings; Defendant Ignores Plaintiffs’ Similar Factual And

Employment Settings; analyzed similarly situated nature of

Plaintiffs within the scope of the Russell v. Illinois Bell

opinion.

1.50 $412.50

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Plaintiffs Labored Under A Common Policy

Or Plan That Led Them To Perform Uncompensated Work;

Plaintiffs’ received uniform instructions to only record “hands

on keyboard” time into TimeSaver.

1.80 $495.00

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Plaintiffs Labored Under A Common Policy

Or Plan That Led Them To Perform Uncompensated Work;

Plaintiffs experienced uniform Instructions And Pressure To

Underreport Hours Worked across regions.

1.00 $275.00

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Defendant’s Overtime Policy; Plaintiffs

Labored Under A Common Policy Or Plan That Led Them To

Perform Uncompensated Work; argued Defendant

implemented uniform policy depriving Plaintiffs of pay for

overtime at a rate of time­and­a­half; discussed lack of clear

and mutual understanding between Plaintiffs and Defendant

concerning piece rate method of compensation and overtime

rate.

1.80 $495.00

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Plaintiffs Labored Under A Common Policy

Or Plan That Led Them To Perform Uncompensated Work;

Plaintiffs across regions testified to flexing their time, and

having to check their computers every 10-15 mins for work.

1.50 $412.50

02/18/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Espenscheid Is Inapposite For Purposes Of

Decertification; argued Defendant fundamentally

misrepresented Judge Crabb’s order decertifying the class in

Espenscheid, which was ordered a month before trial after the

plaintiffs there ignored her order to break class into subclasses and bifurcate.

1.70 $467.50

02/19/2014 MJO Drafted Response In Opposition to Defendant’s Motion for

Decertification, re: Defendant Ignores Plaintiffs’ Similar Factual

And Employment Settings; The “Hands On Keyboard” Policy;

2.00 $550.00
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Instructions And Pressure To Underreport Hours Worked;

Defendant’s Overtime Policy; Defendant’s Time “Flexing” Policy.

02/19/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: The Defenses Transcend Plans To Raise Are

Either Not Unique To EachPlaintiff Or Can Be Resolved By

Bifurcating the Case Into Liability And Damages Phases;

consulted Defendant’s memorandum to outline defenses they

plan on using; consulted case law from federalcircuits to

argue Defendant’s defenses nearly all pertain to common

issues and damages, both of which courts favor trying ona

class-wide basis.

1.50 $412.50

02/19/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Fairness and Procedural Concerns Favor

Trying This Case Collectively; argued notions of fairness and

procedure weigh against decertifying this case at this point.

1.00 $275.00

02/19/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: Facts; Uniform Corporate Structure; added

section to facts detailing Defendant’s corporate chain of

command, all the way down to the MLS.

1.00 $275.00

02/19/2014 MJO Drafted Response In Opposition to Defendant’s Mot

ion for

Decertification, re: conducted detailed sentence-by-sentence

review of pages 1-42 of first draft, and footnotes 1-288 of

first draft for errors, omissions, and grammatical mistakes.

2.50 $687.50

02/27/2014 MJO Left voicemail for

Plaintiff Marci Cooper, re: returning call and

message left concerning update to lawsuit.

0.10 $27.50

03/03/2014 MJO Reviewed email and questionnaire from class member Ruth

Lynn Neely.

0.20 $55.00

03/03/2014 MJO Meeting with Kevin, re: establishing Defendant’s common

policiesinviolation of the FLSA forinclusioninPlaintiff’s

Responsein Opposition to Defendant’s Decertification Motion.

1.00 $275.00

03/03/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Facts; revised procedural history and factual background

section; removedindividual fact headers from factual

background to make factual background section uniformin

presentation.

1.50 $412.50

03/03/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; established four common policies for factual and

legal analysisin analysis section: 1) unattainable production

and accuracy quotas; 2) Defendant’s encouragement of

underreporting hours worked; 3) Defendant’s uniform halftime overtime policy; 4) Defendant’s implementation of an

unending work schedule for Plaintiffs.

1.50 $412.50

03/03/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant’s implementation of unattainable

production and accuracy quotas; consulted deposition

transcript of corporate representative Catherine Dundas for

additional facts concerning Defendant’s implementation of

uniform production standards for full-time and part-time

employees; consulted documents produced by Defendant

during discovery for emails and other communications

demonstratingPlaintiffs could be terminated for not meeting

production standard, and evidence of the production standard

being unattainable.

1.50 $412.50

03/04/2014 MJO Responded to email from class member

Linda Mathias, re:

decertification.

0.20 $55.00

03/04/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant Implemented Unattainable Production

Quotas Which CausedPlaintiffs To Routinely Work In Excess

Of Their Scheduled Shifts- Defendant Imposed Unattainable

Production And Accuracy Quotas; Defendant required

Plaintiffs adhere to strict production and accuracy quotas to

2.50 $687.50
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retain full-time and part-time employment; Defendant actively

monitored which MLSs were meeting production quotas.

03/04/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant Implemented Unattainable Production

Quotas Which CausedPlaintiffs To Routinely Work In Excess

Of Their Scheduled Shifts- Defendant Imposed Unattainable

Production And Accuracy Quotas; Defendant terminated,

demoted, ordisciplined MLSs who could not meet production

quotas.

1.50 $412.50

03/04/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant Implemented Unattainable Production

Quotas Which CausedPlaintiffs To Routinely Work In Excess

Of Their Scheduled Shifts- Defendant Imposed Unattainable

Production And Accuracy Quotas; NumerousPlaintiffs from

across the United States testified to routinely working hoursin

excess of their scheduled part-time and full-time shifts to meet

Defendant’s strict production and accuracy quotas.

1.50 $412.50

03/04/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant adhered toa uniform policy pressuring

Plaintiffs to underreport their hours worked to avoid having to

pay them overtime and Make-Up-To-Minimum time, or “MKM”

time; consulted hundreds of pages of documents produced by

Defendant during discovery demonstrating the understanding

from those at the top of the corporate chain thatPlaintiffs

were only to record “production” time.

2.00 $550.00

03/05/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re: FLSA

Decertification standard.

0.50 $137.50

03/05/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImplementedA Common Policy

EncouragingPlaintiffs To Underreport Hours Worked To Avoid

PayingPlaintiffs Make-Up Pay And Overtime; Defendant’s

Instruction to Underreport Time Worked; Defendant adhered

toa common policy pressuringPlaintiffs to underreport their

hours workedina uniform effort to avoid payingPlaintiffs

overtime and Make-Up-To-Minimum pay, or “MKM” pay.

2.00 $550.00

03/05/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImplementedA Common Policy

EncouragingPlaintiffs To Underreport Hours Worked To Avoid

PayingPlaintiffs Make-Up Pay And Overtime; Defendant’s

Instruction to Underreport Time Worked; Defendant’s

instruction to only record time producing lines or reports predated Defendant’s implementation of TimeSaver as the

uniform timekeeping system for MLSsin February 2010;

Defendant instructedPlaintiffs to only record production time

in TimeSaver.

2.50 $687.50

03/05/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImplementedA Common Policy

EncouragingPlaintiffs To Underreport Hours Worked To Avoid

PayingPlaintiffs Make-Up Pay And Overtime; Defendant’s

Instruction to Underreport Time Worked; Defendant

encouragedPlaintiffs underreport their hours worked to avoid

compensatingPlaintiffs for make-up pay and overtime.

1.80 $495.00

03/05/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImplementedA Common Policy

EncouragingPlaintiffs To Underreport Hours Worked To Avoid

PayingPlaintiffs Make-Up Pay And Overtime; Defendant’s

Instruction to Underreport Time Worked; Plaintiffs’

2.70 $742.50
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03/07/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re: 1.50 $412.50

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Underreporting Of Hours Worked; consulted deposition

transcripts of Patricia Rapp, Kandace Chancey, Barbara

Vaughn, Janeen DeBoard, Margaret Thorpe, Theresa

Cosentino, Sarena Marques, Patsy Hayes, Diane Spencer, Joy

McLemore, and Julie Wright.

03/05/2014 CA Return call to opt-in plaintiff to give update on case. Left

voicemail.

0.10 $22.50

03/06/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Plaintiffs Could Not Meet Defendant’s Quotas Within

Their Part-Time And Full-Time Schedules; consulted

deposition transcripts of Linda Mathias, Patsy Hayes, Theresa

Cosentino, Diane Martin, and Laura Denio.

1.50 $412.50

03/06/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Facts; Plaintiffs’ Factual and Employment Settings; Plaintiffs

and the putative class of MLSs were all similarly situated

within Defendant’s corporate structure; Defendant admitted all

MLSs employed by Transcend were subject to the same

production-based compensation structure; Defendant required

all Plaintiffs utilize the internet-based timekeeping program

TimeSaver to record their hours worked.

2.50 $687.50

03/06/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Defendant Imposed A Common Policy Unlawfully

Compensating Plaintiffs For Pre-Authorized Overtime At A HalfTime Rate; Defendant’s Uniform Half-Time Overtime Policy;

Defendant’s uniform overtime rate frequently led to Plaintiffs

being compensated at an hourly rate less than the federallymandated minimum wage of $7.25 per hour.

2.00 $550.00

03/06/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Defendant Imposed A Common Policy Unlawfully

Compensating Plaintiffs For Pre-Authorized Overtime At A HalfTime Rate; Defendant’s Uniform Half-Time Overtime Policy;

Defendant Provided Plaintiffs No Indication The Piece Rate

Was Intended To Compensate Them For All Hours Worked.

2.30 $632.50

03/06/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Defendant Imposed A Common Policy Unlawfully

Compensating Plaintiffs For Pre-Authorized Overtime At A HalfTime Rate; Defendant’s Uniform Half-Time Overtime Policy;

Defendant’s Overtime Policy Violates The FLSA.

0.70 $192.50

03/07/2014 MJO Drafted Plaintiffs’ Motion for Leave to Exceed Page Limitations

for Plaintiffs’ Response in Opposition to Defendant’s Motion

for Decertification.

0.50 $137.50

03/07/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Defendant Required Plaintiffs To Work An Unending

Work Schedule; Plaintiffs Were Never “Off­The­Clock” While

Working; Defendant admitted Plaintiffs could never work offthe-clock because Defendant expected them to work a neverending work schedule.

2.50 $687.50

03/07/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Defendant Violated The FLSA Through 4 Common

Policies; Defendant Required Plaintiffs To Work An Unending

Work Schedule; Plaintiffs Worked An Unending Shift; argued

Plaintiffs routinely experienced low workloads and had to

“flex” their work time, locking them into an unending work

schedule; Plaintiffs throughout the United States reported that

“flexing” their time required them to work an unending shift,

impacting their ability to leave home and engage in personal

activities.

2.00 $550.00
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/2016

03/10/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re: 1.00 $275.00

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Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant RequiredPlaintiffs To Work An Unending

Work Schedule;Plaintiffs Are Bound AsA Class By Defendant’s

Common Policy Imposing An Unending Work Schedule;

compared case favorably to Russell v.Illinois Bellin analysis

of Defendant’s unending work schedule policy.

03/07/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImposedA Common Policy Unlawfully

CompensatingPlaintiffs For Pre-Authorized Overtime AtA HalfTime Rate; Defendant’s Overtime Policy Violates The FLSA;

compared case favorably to rule set forthin Espenscheid

governing half-time overtime policy.

2.00 $550.00

03/09/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant Implemented Unattainable Production and

Performance Quotas, CausingPlaintiffs To Work Innumerable

Hours In Excess Of Their Scheduled Shifts; Defendant’s

Unattainable Production And Performance Quotas ConstituteA

Common PolicyBinding This Class; compared case favorably

to Russell v.Illinois Bell concerning unattainable quotas

during regularly scheduled shift.

2.20 $605.00

03/09/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant Violated The FLSA Through4 Common

Policies; Defendant ImplementedA Common Policy

EncouragingPlaintiffs To Underreport Hours Worked To Avoid

PayingPlaintiffs Make-Up Pay And Overtime; Defendant’s

Uniform Instructions To Falsify Plaintiffs’ Hours WorkedBinds

The Class; compared case favorably to Monroe v. FTS USA,

LLC, concerning Defendant’s explicit instructions to

underreport hours worked to avoid paying make-up pay and

overtime.

2.00 $550.00

03/09/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Argument; FLSA decertification standard; added substantial

case law concerning Plaintiffs’ ability to demonstrate common

policies from all federal circuits.

0.70 $192.50

03/09/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Defendant’s bases for decertifying the class do not

support decertifying the class; set forth Defendant’s

arguments concerning individualized damages and defenses;

stated substantial case law countering Defendant’s argument

that cases with an individualized assessment of damages

necessitate decertification.

1.50 $412.50

03/10/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; set forth Defendant’s

argumentsin its Brief concerning individualized damages and

defenses; argued Defendant Applies An Erroneous Legal

Standard by applying the Rule 23 standard to an FLSA

collective action post-Genesis.

2.50 $687.50

03/10/2014 MJO Drafted Response to Defendant’s Mot

ion to Decertify, re:

Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; Comcast and Dukes Do Not

Require Decertification Of This Class; argued legal standards

set forth by recent case law interpreting Comcast and Dukes

do notallow for decertification of this class due to concerns

regarding individualized damages; analyzed Butler v. Sears,

Roebuck and Co., 727 F.3d 796, (7th Cir. 2013), Whitlock v.

FLS Mgmt., LLC, No. 3:10-cv-00562-JHM, 2013 WL 5656100

(W.D. Ky. Oct. 16, 2013), and Thompson v. Bruister and

Associates, Inc., No. 3:07–00412, 2013 WL 4507740 (M.D.

Tenn. Aug. 23, 2013) as certifying classesin the context of

individualized damages post-Comcast and Dukes.

3.20 $880.00
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Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; This Case Can Be Bifurcated

Into Liability And Damages Phases To Handle Damage

Calculations.

03/10/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; Plaintiffs May Use

Representative Testimony To Prove Damages, particularly

where Plaintiffs allege Defendant failed to keep accurate time

records.

2.00 $550.00

03/10/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; Espenscheid Is Inapposite;

Courts Do Not Broadly Interpret Espenscheid To Prohibit

Collective Action Certification In Piece Rate Cases.

1.50 $412.50

03/10/2014 MJO Drafted Response to Defendant’s Motion to Decertify, re:

Analysis; Transcend’s Bases for Decertification Do Not Provide

A Basis For Decertifying the Class; Transcend’s Individual

“Defenses” Do Not Preclude Pursuing This Case Collectively.

1.00 $275.00

03/11/2014 MJO Analyzed, examined and gathered exhibits 1-10 to attach to

Response in Opposition to Defendant's Motion to Decertify the

Conditionally Certified Class; drafted Exhibit List.

1.00 $275.00

03/11/2014 MJO Analyzed, examined and gathered exhibits 11-36 to attach to

Response in Opposition to Defendant's Motion to Decertify the

Conditionally Certified Class; drafted Exhibit List.

2.00 $550.00

03/11/2014 MJO Analyzed, examinted and gathered additional documents for

possible inclusion as evidence in support of Plaintiff's

argument for attachment to Response in Opposition to

Defendant's Motion to decertify the Conditionally Certified

Class.

1.50 $412.50

03/11/2014 JES Begin reviewing and analyzing response to decert motion.

Discuss goal of review with KJD. Discuss specific issues with

MJO. Make hand notes regarding agreas of potential

improvement; reviewed and revised Transcend's response

motion for decert.

4.20 $945.00

03/12/2014 CA Call from opt-in plaintiff re case update 0.20 $45.00

03/13/2014 MJO Analyzed and examined documents produced by Plaintiffs Joy

Anderson, Kandace Chancey, Laura Denio, Jacqueline St.

Georges, Barbara Vaughn, and Wendolyn Smith for purposes

of obtaining additional documents demonstrating uniform

corporate policies for use in Plaintiffs’ Response to

Defendant’s Motion to Decertify.

2.00 $550.00

03/13/2014 MJO Telephone call with Russ Riggan, re: Response to

Decertification.

0.60 $165.00

03/13/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s

Motion to Decertify the Class, re: Plaintiffs’ Factual and

Employment Settings; background information concerning

BeyondTXT and TimeSaver.

1.50 $412.50

03/13/2014 CRM Discuss decertification response with attorney M. Obermeyer

and attorney K. Dolley specific to bifurcation and application

of Mt. Clemens standard

0.30 $82.50

03/13/2014 CRM Finish reviewing response to decertification motion. Make

notes as to potential areas of improvement.

1.10 $302.50

03/14/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s

Motion to Decertify the Class, re: Defendant Avoided Paying

Plaintiffs For Make-Up Pay And Overtime At All Costs; drafted

additional analysis of corporate emails written by President

Susan McGrogan and sent to all Regional Operations Managers

and Platform Managers; additional analysis of “sample email

verbiage” sent to Regional Operations Managers/Team Leaders

telling MLSs to change their timesheets to reflect less hours

worked.

2.50 $687.50

03/14/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s 2.00 $550.00
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Motion to Decertify the Class, re: Defendant Imposed A

Common Policy Unlawfully Compensating Plaintiffs For PreAuthorized Overtime At A Half-Time Rate; drafted additional

analysis of Defendant’s “pre­authorization” of overtime, and

Defendant’s illegal half-time overtime policy.

03/14/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s

Motion to Decertify the Class, re: Transcend’s Bases For

Decertification Do Not Support Decertification; Plaintiffs May

Use Representative Testimony To Prove Damages Since

Defendant Failed To Keep Accurate Time Records; added

substantial analysis of Defendant’s decision to ignore analysis

of Anderson v. Mt. Clemens Pottery.

2.00 $550.00

03/14/2014 MJO Drafted Plaintiffs’ Response in Opposition to Defendant’s

Motion to Decertify the Class, re: Transcend’s Bases For

Decertification Do Not Support Decertification; Named Plaintiff

Theresa Cosentino’s Records Reveal Defendant’s Failure To

Keep Accurate Time Records; consulted numerous pages of

electronic payroll and time records for Plaintiff Cosentino and

calculated damages for Jan. 1-Jan. 15, 2011 pay period.

2.00 $550.00

03/14/2014 MRK Review of discovery information and calculation with MJO re

differences in time sheets and production information;

1.00 $225.00

03/15/2014 MJO Inserted citations to Exhibits 1-45 throughout entire draft of

Response to Decertification; sentence-by-sentence review of

document; updated Exhibit List.

3.50 $962.50

03/16/2014 KJD Detailed review and edit of Plaintiff's response to Defendant's

motion to decertify.

1.00 $450.00

03/17/2014 MJO Meeting with Attorney Kevin Dolley, re: revisions to Response

to Decertification; Background; restructuring factual and

employment settings; policies impacting all Plaintiffs.

0.50 $137.50

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Decertification, re: rearranged and restructured legal standard

section and moved to appropriate sections into Analysis;

Plaintiffs’ Factual Similarities Bind Them As A Similarly

Situated Class; Plaintiffs share fundamental underlying factual

similarities.

1.50 $412.50

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Decertification, re: reviewed following deposition transcripts in

detail for additional missing specific facts to include in

discussion of Defendant’s 4 common policies: Linda

Armstrong; Joy Bargerstock; Kandace Chancey; Patricia Clunk;

Theresa Cosentino; Janeen DeBoard; Laura Denio, Lisa

Edwards, Carol Failla, Patsy Hayes, and Shara Howard.

3.00 $825.00

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Decertification, re: drafted analysis of facts for inclusion in

following section: Plaintiffs’ Factual Similarities Bind Them As

A Similarly Situated Class.

0.50 $137.50

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify the Conditionally Certified Class, re: Background;

provided detailed background of procedural posture of case,

including conditional certification.

1.00 $275.00

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify the Conditionally Certified Class, re: Background;

provided detailed background of scope of discovery and

discovery disputes, including Plaintiffs’ Motions to Compel,

Court’s discovery orders during stage 2 discovery, and

remaining discovery issues for Court to decide.

2.00 $550.00

03/17/2014 MJO Drafted Response in Opposition to Defendant’s Motion to

Decertify the Conditionally Certified Class, re: Background;

provided detailed “roadmap” for purposes of outlining

argument in Response Background.

0.50 $137.50

03/17/2014 KJD Review, organize, develop factual arguments, common

policies and legal argument.

2.00 $900.00

03/18/2014 MJO Drafted response to Decertification, re: Background; drafted 1.00 $275.00
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Decertification sections; established and reguted Defendant's

arguments concerning decertification.

03/18/2014 MJO Drafted Response in Opposition to Defendant's Motion for

Decertification, re: reviewed following deposition transcripts in

detail for additional missing specific facts to include in

discussion of Defendant's 4 common policies: Barbara

Keenan, Judy Lindquist, Judith Lugo, Sarena Marques, Diane

Martin, and Steven Martin; added deposition testimony to

Plaintiff's analysis of the 4 common policies Defendant

implemented violating the FLSA.

2.00 $550.00

03/18/2014 MJO Drafted Response in Opposition to Defendant's Motion for

Decertification, re: reviewed following deposition transcripts in

detail for additional misisng specific facts to inlcude in

discussion of Defendant's 4 common policies; Barbara

Vaughn, Lisa Smith, Wendolyn Smith, Deb Tolles, Deb

Waldman, Darcy Wingler, Mrgaret Thorpe, Diane Spencer,

Kathleen Schuster, Jacqueline St. Georges, Sheila Reeser,

Patricia Rapp, Marie Plum, Dawn Pence, Karen Milan, Joy

McLemore, Linda Mathias; added additional deposition

testimony to Plaintiffs' analysis of the 4 common plicies

Defendant implimented violating the FLSA.

3.50 $962.50

03/18/2014 CRM Review updated draft of decertification response. Make notes

regarding potential areas of improvement.

1.20 $330.00

03/18/2014 CRM Discuss decertification response with attorneys K. Dolley

and M. Obermeyer. Discuss structural and content issue.

Dialogue regarding next drafting steps.

0.40 $110.00

03/18/2014 KJD Detailed review and edit of memo in opposition to decertify. 2.00 $900.00

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: implemented grammatical and structural changes into

Background section based on hand corrections of KJD.

1.00 $275.00

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: restructured sections setting forth fatual similarities in

Factual and Employment Settings.

0.50 $137.50

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: outlined and drafted revised version of Defendant's

common policy instructing and encouraging Plaintiffs to

underreport hours worked.

1.50 $412.50

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: outlined and drafted revised version of Defendant's

common policy implementing unattainable production quotas.

0.30 $82.50

03/19/2014 MJO Responded to email from Plaintiff Julie Wright, re: additional

documents found in email recycle bin after close of discovery.

0.20 $55.00

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Background; implemented grammatical and structural

changes to Background section based on hand corrections of

CRM.

0.80 $220.00

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: FLSA Decertification Standard.

0.30 $82.50

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Fairness and Procedural Concerns.

0.30 $82.50

03/19/2014 MJO Drafted response to Defendant's Motion for Decertification, re:

incoroporated testimony of Barbara Keenan, Steven Martin,

Jacqueline St. Georges, Karen Milan, and Judy Lindquist.

1.00 $275.00

03/19/2014 MJO Meeting with KJD, re: individual defenses. 0.50 $137.50

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Individualized Defenses Do Not Preclude Certification;

revised discussion of bifurcated trial and Defendan't

individualized defenses and affirmative defenses.

1.70 $467.50

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: analysis of Wal-Mart v. Dukes and why decertification is

not required after that decision.

1.00 $275.00

03/19/2014 MJO Drafted Response to Defendant's Motion for Decertification, 1.50 $412.50
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re: Analysis of Comcast and why it does not require

decertification.

03/19/2014 CRM Discuss decertification response status with attorney K.

Dolley.

0.10 $27.50

03/19/2014 CRM Review and make hand corrections to background

section of decertification response.

0.80 $220.00

03/19/2014 CRM Review and make hand corrections to Legal Standard

section of decertification response.

0.70 $192.50

03/19/2014 CA Draft table of authorities for brief 3.00 $675.00

03/19/2014 CA Draft table of contents for brief 2.50 $562.50

03/20/2014 MJO Drafted Response to Defendant's Motion for Decertificaiton,

re: inserted deposition testimony of Kathleen Schuster, Lisa

Smith, Wendolyn Smith, Darcy Wingler, Debra Tolles, Julie

Wright, Deborah Waldman in underreporting of time section.

1.20 $330.00

03/20/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Defendant's common policy instructing Plaintiff's to

underreport time worked; drafted additional testimony of

Scott Robertson regarding Defendant's failure to log data

reflecting log-in/log-out times.

1.30 $357.50

03/20/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Defendant's common policy instructing Plaintiffs to

underreport time worked; Defendant's knowledge of times

Plaintiffs worked through software platforms; Defendant's

uniform instructions and encouragement to Plaintiffs to flex

their time.

2.00 $550.00

03/20/2014 MJO Meeting with KJD, re: improving sections on Defendant's halftime overtime policy.0.50 $137.50

03/20/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Defendant's overtime policy constitues a common policy

binding the class; Defendant's uniform hiring system and

employment terms; consulted corporate represenative

testimony for steps in Defendant's recruitment process, and

how Defendant brought on transitional and external new

hires.

2.50 $687.50

03/20/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Defendant's Uniform Half-time Overtime Polic Constitues a

common Policy Binding This Class; drafted legal analysis

concerning Defendant's overtime policy, and the sub-issues

concerning regular rate of pay and offer letters that bind class

together.

1.50 $412.50

03/20/2014 MJO Researched overtime piece rate in Code of Federal Regulations

and all circuits; re: advance agreement necessary to pay a

piece rate employee overtime at a rate of half-time, for

purposes of drafting Response to Defendant's Motion for

Decertification.

0.50 $137.50

03/20/2014 JMF Meeting with KJD for research topics- form contracts and class

cert and regular rate keystone; research on "form contracts

and class cert" & "regular rate as keystone"; draft citations.

2.90 $652.50

03/20/2014 CRM Review and make hand corrections to defenses section of

decertification response.

0.70 $192.50

03/20/2014 CRM Review and revise quota section of decertification response

discussed with attorneys K. Dolley and M. Obermeyer

1.20 $330.00

03/21/2014 MJO Drafted Response to Defendant's motion for Decertification,

re: revised uniform performance and production quotas

section to incorporate changes recommended by CRM.

0.50 $137.50

03/21/2014 MJO Meeting with KJD, re: revising section of Plaintiff's Response

to Defendant's Motion for Decertification pertaining to

Plaintiff's underreporting of time.

0.50 $137.50

03/21/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: underreporting hours worked; drafted factual background

explaining TimeSaver and Defendant's uniform timekeeping

methods.

1.50 $412.50
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03/21/2014 MJO Drafted Response to Defendant's Motion for Decertification,

re: Defendant's common policy instructing and encouraging

Plaintiffs to underreport hours worked; drafted factual

background explaining Defendant's software platforms and

analysis section analyzing Defendant's common policy in the

context of their refusal to keep accurate time.

2.00 $550.00

03/21/2014 MJO Drafted Response to Defendant’s Motion for Decertification re:

revised section pertaining to Defendant’s half-time overtime

policy; added substantive deposition testimony concerning

Plaintiffs’ failure to understand their compensation for

Defendant’s piece rate.

1.00 $275.00

03/21/2014 MJO Read and revised first draft of complete memorandum of law;

made hand correction edits, revisions, and recommendations

throughout entire 54 page initial complete draft of

memorandum of law.

2.00 $550.00

03/21/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

re: added Section B to Appendix concerning specific

testimony regarding time flexing provided by the following

Plaintiffs: Joy Bargerstock, Kandace Chancey, Theresa

Cosentino, Laura Denio, Shara Howard, Judith Lugo, Diane

Martin, Linda Mathias, Joy McLemore, Karen Milan, Marie

Plum, Patricia Rapp, Kathleen Schuster, Diane Spencer,

Jacqueline St. Georges, Margaret Thorpe, Barbara Vaughn.

1.50 $412.50

03/21/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

re: implemented hand correction recommendations made by

Attorney Jon Skrabacz.

1.00 $275.00

03/21/2014 CRM Review and revise quota section of decertification

response

1.40 $385.00

03/21/2014 CRM Review and revise factual sections of decertification

response

2.10 $577.50

03/21/2014 CRM Meeting, re: status of decertification response with

attorneys M. Obermeyer and K. Dolley

0.20 $55.00

03/21/2014 KJD Reviewed and edited drafts of memo in opposition of

decertification.

8.00 $3,600.00

03/21/2014 MRK Formatting memorandum of law to include proper page

numbering

0.20 $45.00

03/22/2014 MJO Meeting with Attorney Kevin Dolley, re: restructuring facts

section in accordance with common policies.

0.70 $192.50

03/22/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

revised and restructured Facts section, re: Plaintiffs Share

Fundamental Factual Similarities; Defendant’s Uniform Hiring

Process; Defendant’s Uniform Timekeeping Process;

Defendant’s Uniform Piece Rate Compensation Structure;

Defendant’s Uniform Half Time Overtime Rate; Defendant’s

Uniform Production and Performance Quotas; Defendant’s

Uniform Requirement That Plaintiffs Underreport Compensable

Work Time; Defendant Knew Or Should Have Known Plaintiffs

Were Performing Unrecorded Compensable Work; Data

Showing Plaintiffs’ Actual Work Time.

2.00 $550.00

03/22/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

re: revised Appendix 1 concerning Plaintiffs’ uniform

testimony of underreporting work time.

1.00 $275.00

03/22/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

revised and restructured Facts section, re: Plaintiffs Share

Fundamental Factual Similarities; Defendant’s Uniform Hiring

Process; Defendant’s Uniform Production and Performance

Quotas.

2.50 $687.50

03/22/2014 MJO Analyzed and examined hundreds of pages of documents

provided by Defendant from entire case file for additional

exhibits to add to Facts section.

1.50 $412.50

03/22/2014 MJO Drafted Response to Defendant’s Motion for Decertification,

revised and restructured Facts section, re: added analysis to

facts regarding additional exhibits, re: Editing Proficiency

4.50 $1,237.50
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Tutorial, emails from Director of Operations Rebecca Stewart,

communications from Director of Operations Cindy Gulley,

Detailed Line Count Reports for Plaintiff Linda Mathias, EIS

Screenshots, additional emails from Catherine Dundas to

Payroll Manager Jennifer Sandy, Max Line Rate Schedule,

Timesheets, Timestamps, and Earnings Statements for Linda

Mathias, BayScribe Platform Data.

03/22/2014 CRM Review and revise first ten pages of decertification

response

0.80 $220.00

03/22/2014 CRM Review and revise pages 11-20 of decertification

response facts

0.60 $165.00

03/22/2014 KJD Reviewed and edited drafts in opposition for desertification

Reviewed exhibits, appendix, documents, corp rep depo

transcripts, researched desertification standard.

14.00 $6,300.00

03/22/2014 JES Talked to KD and MO about what to do on the Response

Motion for decert; read Espenscheid and looked at 7 cases

treating it negatively in order to put any language treating the

case negatively into an email; looked up IL Fed Dist court

cases to see if Guzma or Rowland discussed Comcast, Dukes,

or Espenscheid.

6.60 $1,485.00

03/23/2014 MJO Drafted outline of Defendant’s arguments presented in Motion

for Decertification, re: individualized defenses for inclusion in

Plaintiffs’ Response to Defendant’s Motion for Decertification.

1.00 $275.00

03/23/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, re: analyzed and examined Excel spreadsheets

for damage calculations for inclusion in Appendix.

1.00 $275.00

03/23/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, implemented hand correction changes

recommended by Attorney Kevin Dolley, re: Plaintiffs Share

Fundamental Factual Similarities; Defendant’s Uniform Hiring

Process; Defendant’s Uniform Timekeeping Process;

Defendant’s Uniform Piece Rate Compensation Structure;

Defendant’s Uniform Half Time Overtime Rate; Defendant’s

Uniform Production and Performance Quotas; Defendant’s

Uniform Requirement That Plaintiffs Underreport Compensable

Work Time; Defendant Knew Or Should Have Known Plaintiffs

Were Performing Unrecorded Compensable Work; Data

Showing Plaintiffs’ Actual Work Time.

3.50 $962.50

03/23/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, Argument; implemented hand corrections of

Attorney Kevin Dolley in following sections: Plaintiffs’

Factually Similar Employment And Work Responsibilities Bind

Them Together As Similarly Situated; Defendant’s Common

Policies And Practices Violating the FLSA; Defendant’s Uniform

Policies And Practices Requiring Plaintiffs Underreport Work

Time; Defendant’s Production And Performance Quotas

Constitute A Common Policy Binding Plaintiffs; Defendant’s

Uniform Half-Time Overtime Policy Violates the FLSA.

4.00 $1,100.00

03/23/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, Argument; implemented hand corrections of

Attorney Kevin Dolley in following sections: Transcend’s

Defenses Are Not Sufficiently Individualized To Defeat

Decertification; Courts Regularly Maintain Certification In Cases

Where A Defendant Attempts To Assert Boilerplate Individual

“Defenses;” Plaintiffs’ Relaxed Burden of Proving Damages

Resulting From Defendant’s Failure To Keep Accurate Time

Records; Comcast And Dukes Do Not Support Decertification;

Espenscheid Is Inapposite As Courts Do Not Broadly Prohibit

Collective Action Certification In Piece Rate Cases.

3.00 $825.00

03/23/2014 JMF Review identifying exhibits, identifying exhibits subsumed in

editing process for reincorporation; stamping exhibits,

preparing index of Exhibits.

3.80 $855.00

03/23/2014 MRK Calculation of time worked for plaintiff Linda Mathias 2.80 $630.00
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based on BeyondTXT records for week of January 2, 2011;

calculation of hour rate of pay based on ADP data for the time

period, calculation of overtime hours that were not reported

or paid; Drafting of appendix for attachment in response to

motion for decertification addressing the unpaid overtime and

unpaid minimum wage damages for plaintiff Linda Mathias

including the information used to determine her acctual hours

worked, her hourly rate, and her overtime rate, drafting of

language explaining the method used for making the

calculations and determining the overall damages for the

workweek in which she was not paid overtime or minimum

wages

03/23/2014 MRK Preparation of exhibits 47,67,68,69 with exhibits stamps,

conversion to PDF formatting, drafting of headers for

spreadsheet exhibits for each page of information; Calculation

of time worked for plaintiff Linda Mathias based on

BeyondTXT records for week of January 2, 2011; calculation

of hour rate of pay based on ADP data for the time period,

calculation of overtime hours that were not reported or paid;

Drafting of appendix for attachment in response to motion for

decertification addressing the unpaid overtime and unpaid

minimum wage damages for plaintiff Linda Mathias including

the information used to determine her acctual hours worked,

her hourly rate, and her overtime rate, drafting of language

explaining the method used for making the calculations and

determining the overall damages for the workweek in which

she was not paid overtime or minimum wages;

7.00 $1,575.00

03/24/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, re: analyzed/examined Exhibits 1-70 for filing;

applied redactions where necessary.

1.50 $412.50

03/24/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, re: condensed the following sections to meet

40 page limit established in Court Order: Plaintiffs’ Factually

Similar Employment And Work Responsibilities Bind Them

Together As Similarly Situated; Defendant’s Common Policies

And Practices Violating the FLSA; Defendant’s Uniform Policies

And Practices Requiring Plaintiffs Underreport Work Time;

Defendant’s Production And Performance Quotas Constitute A

Common Policy Binding Plaintiffs; Defendant’s Uniform HalfTime Overtime Policy Violates the FLSA.

3.50 $962.50

03/24/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, re: condensed the following sections to meet

40 page limit established in Court Order: Transcend’s Defenses

Are Not Sufficiently Individualized To Defeat Decertification;

Courts Regularly Maintain Certification In Cases Where A

Defendant Attempts To Assert Boilerplate Individual

“Defenses;” Plaintiffs’ Relaxed Burden of Proving Damages

Resulting From Defendant’s Failure To Keep Accurate Time

Records; Comcast And Dukes Do Not Support Decertification;

Espenscheid Is Inapposite As Courts Do Not Broadly Prohibit

Collective Action Certification In Piece Rate Cases; Procedural

and Fairness Concerns Do Not Preclude Decertification.

2.00 $550.00

03/24/2014 MJO Drafted Plaintiffs’ Response to Defendant’s Motion for

Decertification, re: implemented suggested changes from

Attorneys Jonathan Skrabacz, Michael Kruse, Jason Finkes,

and Joseph Riegerix.

1.50 $412.50

03/24/2014 CRM Detailed review of decertification response. Make hand

corrections. Discuss with attorneys K. Dolley and M.

Obermeyer

2.50 $687.50

03/24/2014 CRM Meeting to discuss decertification response status 0.20 $55.00

03/24/2014 CRM Review part 4 of Appendix. Discuss with attorney K.

Dolley.

0.70 $192.50

03/24/2014 CRM Meeting with attorney K. Dolley, re: possible inclusion 0.10 $27.50
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03/24/2014 CRM

of jury instructions into decertification response.

Review and make hand corrections to Part II. C of 0.30 $82.50

decertification response

03/24/2014 KJD Detailed review of Appendix; detailed review of time records

and testimony specific to appendix; detailed review of draft

memo of law, hand corrections and red-line deletions.

9.00 $4,050.00

03/24/2014 MRK Preparation of exhibits for courtesy copy to be sent to Judge,

review of all exhibits to determine page length of each

exhibit, printing of all exhibits exceeding fifty pages to

prepare for binding for courtesy copy; Revision of appendices

4 and 5 per KJD instruction, including removing any damage

calculation and comparison of TimeSaver information to

Production information on a weekly basis; review of time

records for plaintiffs Cosentino and Mathias, revision of

appendices to reflect only a single day of times recorded

downloading and returning reports, formatting of time data to

include within appendices.; Additional preparation of courtesy

copy of memorandum and exhibits to send to Judge Guzman,

including printing of additional exhibits and drafting and

printing of cover sheets for each volume binder to be sent to

Judge Guzman; Review of documents contained within

binders to ensure they were properly labeled and in the proper

order within the tabbed sections of the binders and how to

organize binders to properly and equally hold all exhibits;

Printing of remaining exhibits for filing as courtesy copy to

Judge Guzman, thorough review of all three volumes of

binders to ensure each exhibit was properly bound with the

appropriate corresponding divider tab, review of all

documents within binder to ensure all documents are within

the courtesy copy;

4.80 $1,080.00

03/24/2014 MRK Review and hand corrections of memo in opposition,

including procedural history, statement of facts, argument,

and conclusion. Changes noted for grammatical and stylistic

changes, changes noted for readability, changes noted re

long/short form citations throughout the memorandum of law

in opposition to decertification; Revision and final review of

Table of Contents for Memorandum of Law In Opposition to

Defendant’s Motion To For Decertification to reflect changes

to page numbers and title headings through final revision,

Revision and final review of Table of Authorities to ensure

cases cited in memorandum in opposition of decertification,

review of table of authorities and cross-reference with

memorandum of law to ensure accurate citation of page

numbers for each authority in the table of authorities, removal

of authorities in table of authorities removed from citation in

final editing of memorandum of law; Preparation of file

stamped memorandum of law, appendix, motion for leave,

and notice of hearing on motion for leave to file Exhibit 47

under seal for courtesy copy to send to Judge Guzman;

preparation of final index of exhibits for courtesy copies; Final

preparation of courtesy copy for overnight shipment to

Chicago for delivery to Judge Guzman.

3.70 $832.50

03/24/2014 JES Read and reviewed response to Motion for Decert one last

time.

3.50 $787.50

03/24/2014 JRR Read and edit Opposition to Decertify. 1.70 $382.50

03/26/2014 MJO Drafted email to class members updating them as to status

lawsuit.

0.50 $137.50

03/26/2014 MJO Telephone call with clerk, re: filing Exhibit 47 to Plaintiff's

Response in Opposition to Decertification; filed Exhibit 47

under seal.

0.40 $110.00

04/01/2014 MJO Updated contact information (addresses, email addresses) for

several MLSs on MLS contact information spreadsheet.

0.50 $137.50

04/01/2014 MJO Sent email updating class members as to status of lawsuit to

all 705 class members through Yahoo and business email

1.00 $275.00
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04/02/2014 MJO

addresses.

Left voicemail for Linda Mathias, re: returning phone call. 0.10 $27.50

04/02/2014 MJO Telephone call with Linda Mathias, re: updates concerning

lawsuit and Motion for Decertification.

0.50 $137.50

04/03/2014 KJD Detailed review of Defendant's Motion to Decertify. 2.00 $900.00

04/06/2014 MJO Meeting with Attorneys Kevin Dolley and Conor McCullough,

re: potential need for Sur-Reply.

0.20 $55.00

04/08/2014 MJO Read/reviewed Defendant’s Reply to Plaintiff’s Response in

Opposition to Decertification, re: began drafting outline of

Defendant’s arguments for inclusion in potential Sur-Reply.

1.50 $412.50

04/08/2014 MJO Telephone call with co-counsel Russ Riggan and Kevin Dolley,

re: filing Sur-Reply.

0.40 $110.00

04/15/2014 MJO Responded to email from class member Julie Wright, re:

settlement discussions and progress.

0.20 $55.00

05/02/2014 MJO Emailed Plaintiff Lisa Smith, re: questions concerning

computer potentially being hacked, and potential effect of

termination/resignation on standing in lawsuit.

0.20 $55.00

05/02/2014 MJO Emailed Plaintiff Julie Wright, re: update on status of lawsuit

and status of decertification.

0.20 $55.00

05/02/2014 MJO Telephone call with Plaintiff Lisa Smith, re: employment with

Nuance, including timekeeping, access to computer through

email system and IM system.

0.70 $192.50

05/05/2014 KJD Call with Kate Sedey, re: possible substitution of counsel. 0.20 $90.00

05/07/2014 MJO Drafted substitution of counsel correspondence to new local

counsel Kate Sedey and former local counsel Anthony Sciara,

re: substituting local counsel in case.

0.50 $137.50

05/12/2014 MJO Drafted Plaintiffs’ Motion for Leave to Substitute Counsel. 0.80 $220.00

05/12/2014 MJO Drafted Notice of Hearing for Motion for Leave to Substitute

Counsel.

0.20 $55.00

05/12/2014 MJO Drafted email to new local counsel Kate Sedey, re: Motion for

Leave to Substitute Counsel and Notice of Hearing.

0.20 $55.00

05/15/2014 JES Called back client regarding status of case. 0.10 $22.50

05/16/2014 MJO Telephone call with Plaintiff Dawn Pence, re: online blog

postings.

0.20 $55.00

05/19/2014 MJO Drafted email to local counsel Kate Sedey, re: Judge Guzman

granting Motion to Substitute Counsel.

0.20 $55.00

06/02/2014 MJO Drafted email to class member Margaret Thorpe, re: updating

as to status of lawsuit.

0.20 $55.00

06/13/2014 MJO Responded to email from Plaintiff Janet Moore, re: case

update.

0.10 $27.50

06/13/2014 MJO Responded to email from Plaintiff Brucette Zirn, re: case

update.

0.10 $27.50

06/13/2014 MJO Responded to email from Plaintiff Debra Seuell, re: case

update.

0.10 $27.50

06/25/2014 MJO Drafted email to class, re: status update as to lawsuit. 0.50 $137.50

06/25/2014 MJO Instructed assistant Morgan Bland, re: sending class update

email to all class members.

0.20 $55.00

07/15/2014 JMF Call from client Beverly McCoy, requesting update,

estimations, and timeframe.

0.40 $90.00

09/08/2014 MJO Drafted email to Plaintiff Deborah Waldman, re: update on

case.

0.20 $55.00

09/26/2014 JES Reviewed and sent draft of email to be sent to the class in

Transcend alerting them of the judge's order grating the

Defendant's decertification motion.

0.20 $45.00

09/29/2014 MJO Revised email to class, re: revised text concerning

decertification being granted.

0.20 $55.00

10/06/2014 MJO Left voicemail for named Plaintiff Linda Mathias, re: case

update.

0.10 $27.50

10/06/2014 MJO Telephone conversation with named Plaintiff Linda Mathias,

re: provided case update and explanation of significance of

de-certification and potential strategy for moving forward with

0.80 $220.00
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10/09/2014 MJO

named plaintiffs.

Drafted email to namedPlaintiff Lisa Edwards, re: update to 0.20 $55.00

lawsuit.

10/28/2014 MJO Researched Seventh Circuit case law, re: equitable tolling of

statute of limitations; read several casesincluding Bergman v.

Kindred Healthcare, Inc. (N.D. Ill.) and Bitner v. Wyndham

Vacation Resorts, Inc., (W.D.Wisc.).

0.70 $192.50

10/28/2014 MJO Researched all federal

circuits for the following key terms for

purposes of drafting Plaintiffs’ Motion for Equitable Tolling

—"decertification"& "flsa"& "opt-in"& "notice"& "equitable"

& "tolling"; read and consulted numerous casesincluding

Green v. Harbor Freight Tools USA, Inc., (D. Kan); Sandoz v.

Cingular Wireless (D. La.).

0.80 $220.00

10/29/2014 MJO Researched equitable tolling

in all federalcircuits and

consulted numerous cases granting equitable tolling to

decertified Plaintiffs,including Smith v. Heartland Auto.

Services, Inc. (D.Minn.), Puffer v. Allstate Ins. Co. (N.D. Ill.),

and Santiago v. Amdocs., Inc. (N.D. Cal.); began drafting

Motion for Equitable Tolling, re: Procedural and Factual

Background concerning decertification ruling and equitable

tolling.

2.30 $632.50

10/30/2014 MJO Drafted Plaintiffs’ Memorandum of Law

in Support of Motion

for Staying the Statute of Limitations for Dismissed Opt-ins,

re: Procedural Posture; detailed procedural posture of case, including significant events throughout course of case, such

as basics of Plaintiffs’ allegations, Court’s Order conditionally

certifying the putative class, and Court’s Order decertifying the

putative class.

1.70 $467.50

10/30/2014 MJO Drafted Plaintiffs’ Memorandum of Law

in Support of Motion

for Staying the Statute of Limitations for Dismissed Opt-ins,

re: Argument— This Court Should Exercise Its Broad

Discretion And Stay The Statute Of Limitations ForA Period

Running From The Date That The Opt-InPlaintiffs Filed Their

Notices To December 25, 2014; argued this Court should invoke the doctrine of equitable tolling to stay the statute of

limitations for opt-in members of the putative class; detailed

legal background and supporting case law concerning when

equitable tollingis appropriatein FLSA collective actions,

including Santiago v. Amdocs, Inc., and Chapman v. Fred’s

Stores of Tennessee, Inc., (N.D. Al. Mar. 15, 2013).

2.50 $687.50

10/31/2014 MJO Drafted Memorandum of Law

in Support of Motion for

Equitable Tolling, re: This Court Should Exercise Its Broad

Discretion And Stay The Statute Of Limitations ForA Period

Running From The Date That The Opt-InPlaintiffs Filed Their

Notices Of Intent To Join This Lawsuit To December 25,

2014.

1.00 $275.00

10/31/2014 MJO Drafted Mot

ion for Staying the Statute of Limitations for

Dismissed Opt-in Plaintiffs, re: asserted reasons why equitable

tolling particularly appropriatein this case featuring 705

Plaintiffs scattered throughout the United States.

0.60 $165.00

11/03/2014 MJO Drafted email to co-counsel Russ Riggan, re: game plan for

pursuing Transcend post-decertification.

0.20 $55.00

11/03/2014 MJO Drafted Mot

ion for Equitable Tolling, re: detailed plans and

strategy for moving case forward to the court,including

Plaintiffs’ counsels’ plans to contact each opt-inPlaintiff again

to ensure that they fully understand their right to pursue

individual litigation for unpaid wages against Defendantif

they haveaclaim for such damages; ensuring that all opt-in

Plaintiffs receive the communication regarding this Court’s

decision and what this means for their wage and hour claim;

also further detailed analysisin argument section setting forth

whyPlaintiffs require an additional several weeks for equitable

tolling.

1.50 $412.50
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11/03/2014 KJD Review, edit motion to stay for dismissed opt-in Plaintiff. 1.00 $450.00

11/06/2014 MJO Gathered file for purposes of preparing for status hearing

scheduled for Friday, Nov. 7.

0.30 $82.50

11/07/2014 MJO Phone call with named Plaintiff Linda Mathias, re: update on

lawsuit.

0.30 $82.50

11/13/2014 MJO Drafted/revised email to class, re: statute of limitations and its

significance/impact for filing individual lawsuit.

0.70 $192.50

11/13/2014 KJD Review, edit class email notice. 0.50 $225.00

11/20/2014 MJO Responded to emails from Transcend opt-in class member

Karen Milan, Lisa Smith, and Shara Howard, re: update on

lawsuit and questions concerning decertification email.

0.70 $192.50

11/21/2014 MJO Drafted Motion for Summary Judgment, re: began drafting

section concerning why Plaintiffs are entitled to summary

judgment on the issue of receiving overtime at a rate of oneand-one-half times their regular rate of pay.

0.50 $137.50

11/21/2014 MJO Drafted Plaintiffs’ Motion for Summary Judgment, re:

researched all federal circuits and secondary sources for case

law pertaining to the agreement which must be entered prior

to piece rate employees earning an overtime rate of half-time

rather than time­and­a­half; researched for purposes of

building out and expanding law in first section of Motion for

Summary Judgment.

2.30 $632.50

11/24/2014 LSG Discuss deadlines for motion to dismiss and issues regarding

continuing response for the same with MJO.

0.30 $82.50

11/25/2014 MJO Drafted email to Greg Mersol, re: changing Motion hearing. 0.10 $27.50

11/25/2014 MJO Telephone call with Carol from Judge Guzman’s chambers, re:

alternate available dates for motion hearing.

0.20 $55.00

11/25/2014 MJO Drafted email to local counsel, re: response due date without

briefing schedule.

0.20 $55.00

11/25/2014 MJO Drafted Joint Proposed Briefing Schedule for submission to

court.

1.00 $275.00

11/26/2014 MJO Emailed Kate Sedey back, re: presentment and due date for

Response to Motion for Disjoinder.

0.20 $55.00

11/26/2014 MJO Emailed opposing counsel Mersol, re: presentment date. 0.20 $55.00

12/02/2014 KJD Review and edit response brief for motion for misjoinder. 3.00 $1,350.00

12/09/2014 MJO Meeting with Attorney Quinton Osborne, re: provided

instruction for drafting Response in Opposition to Defendant’s

Motion for Disjoinder.

0.50 $137.50

12/10/2014 MJO Meeting with Attorney Quinton Osborne, re: questions and

issues concerning Motion for Disjoinder, including

similarities/commonalities binding Plaintiffs.

0.30 $82.50

12/10/2014 CA Mark explained background of the case to new associate 0.40 $90.00

12/10/2014 CA Review defendant's original motion to decertify class 0.60 $135.00

12/10/2014 CA Research cases that state joinder standard is more relaxed than

the second state of decertification standard, such as Insolia v.

Phillip Morris, Smith v. Northeastern, Rochlin v. Cincinnati,

and Nelson v. Chertoff

2.40 $540.00

12/10/2014 CA Research and find cases stating the first prong of joinder

standard can be found if there is a company-wide decision or

policy that was followed, cases like Hohibein v. Heritage and

Resnick v. American Dental Ass'n, and Dean v. City of Chicago

2.10 $472.50

12/10/2014 CA Review Defendant's motion to sever the ten plaintiffs 0.70 $157.50

12/10/2014 CA Research and analyze all cases cited in defendant's motion to

sever pursuant to FRCP 21

1.30 $292.50

12/10/2014 CA Review Plaintiffs response to Defendant's motion to decertify 0.60 $135.00

12/10/2014 CA Review Judge's order to decertify cases 0.40 $90.00

12/11/2014 CA Review Lugo's deposition 0.60 $135.00

12/11/2014 CA Review Debra Tolles' deposition for research time, who her

lead and rooms were, and if she was told about hands-on

time

0.40 $90.00

12/11/2014 CA Review Debra Waldman's deposition for research time, who 0.40 $90.00
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her lead and rooms were, and if she was told about hands-on

time

12/11/2014 CA Complete rules statement for response to motion to sever 1.30 $292.50

12/11/2014 CA Draft first portion of response, arguing Plaintiffs case is similar

to cases that allege company-wide illegal policy

2.40 $540.00

12/11/2014 CA Review Dawn Pence's deposition for research time, who her

lead and rooms were, and if she was told about hands-on

time

0.60 $135.00

12/11/2014 CA Review Mathias deposition, determined if she was paid for

research

0.50 $112.50

12/12/2014 CA Review Mathias' testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.80 $180.00

12/12/2014 CA Review Pence's' testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.40 $90.00

12/12/2014 CA Review Tolle's testimony and determine if she discussed hands

on keyboard, mkm, if they were all MLSs, paid by the line,

flex time, quotas, and if overtime is an issue

0.60 $135.00

12/12/2014 CA Review Waldman's testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.70 $157.50

12/12/2014 CA Review sheet and put all similarities together, edited so

categories are more similar

0.30 $67.50

12/12/2014 CA Review Armstrong's testimony and determine if she discussed

hands-on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.70 $157.50

12/12/2014 CA Review Bargerstock's testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.60 $135.00

12/12/2014 CA Review Clunk's testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.70 $157.50

12/12/2014 CA Review Cosentino's testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.60 $135.00

12/12/2014 CA Review Edwards' testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.60 $135.00

12/12/2014 CA Review Lugo's' testimony and determine if she discussed

hands on keyboard, mkm, if they were all MLSs, paid by the

line, flex time, quotas, and if overtime is an issue

0.70 $157.50

12/12/2014 CA Draft first argument portion of brief, discussing and analyzing

different cases that show even with different facts, joinder can

be proper if there is overlying company policy that is illegal

1.30 $292.50

12/12/2014 CA Draft brief, differentiate cases cited by Defendant in motion to

sever, showing none of them had company-wide policy

2.30 $517.50

12/15/2014 CA Draft and complete section of response to Defendant's motion

to sever: 1. Defendant's Company-Wide Policies That Only

Allowed Plaintiffs To Record Hands-On-Keyboard Time, Along

With Requiring 95% Accuracy Caused FLSA Minimum Wage

and Overtime Violations

2.30 $517.50

12/15/2014 CA Draft and complete section 2 of response to Defendant's

Motion to Sever: All Ten Employees Were Subject To The

Policies That Caused the FLSA Violations

1.10 $247.50

12/15/2014 CA Draft and complete section 3 of response to Defendant's

Motion to Sever: There are other facts that are identical with

each employee, especially since the number of plaintiffs went

from over 700 plaintiffs to only 10.

2.30 $517.50

12/15/2014 CA Draft and complete this section of response to Defendant's

motion to sever: Common Questions Of Law Or Fact Exist In

0.30 $67.50
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12/15/2014 CA

This Lawsuit.

Draft and complete this section of response to Defendant's 1.80 $405.00

motion to sever: Common Questions Of Law Or Fact Exist In

This Lawsuit.

12/15/2014 CA Draft and complete this section of response to Defendant's

motion to sever: Common Questions Of Law Or Fact Exist In

This Lawsuit.

1.20 $270.00

12/15/2014 CA Draft and complete this section of response to Defendant's

motion to sever: A Jury Could Adequately Determine Liability

For Joined Plaintiffs.

1.00 $225.00

12/16/2014 MJO Reviewed/revised Section A of initial draft of Response in

Opposition to Motion for Misjoinder, re: reviewed/revised

Section A concerning whether arises from same series of

transactions or occurrences.

1.50 $412.50

12/16/2014 MJO Researched joinder pursuant to Rule 20, re: researched joinder

of numerous plaintiffs against one Defendant; read and

reviewed numerous cases including Afabor v. Racetrac

Petroleum, Inc., (N.D. Tex), Madison v. Hennepin County (D.

Minn.), Paris v. Lake Carroll Holdings, Inc. (N.D. Ill.).

0.70 $192.50

12/16/2014 MJO Meeting with Attorney Quinton Osborne, re: revisions made to

Section A of Response to Defendant’s Motion for Misjoinder.

0.30 $82.50

12/16/2014 MJO Drafted/revised Plaintiffs’ Response in Opposition to

Defendant’s Motion for Misjoinder, re: reviewed/revised

Section A concerning whether arises from same series of

transactions or occurrences and Section B, concerning

whether the lawsuit arises from common questions of law or

fact.

1.30 $357.50

12/16/2014 CA Review and Discuss Waldman's negative testimony 0.30 $67.50

12/16/2014 CA Insert good case law within analysis throughout brief 0.60 $135.00

12/16/2014 CA Researched and found more rule language for how liberal

misjoinder standard is

0.30 $67.50

12/16/2014 CA Researched and found more rule language regarding how to

find if situations arise out of same situation/occurrence under

the first misjoinder element

0.30 $67.50

12/16/2014 CA Improve and add to analysis explaining how cases cited in

defendant's brief were inapposite to our cases, emphasizing

how we ar arguing a company-wide policy not present in their

cases

0.70 $157.50

12/16/2014 CA Meet with Mark to discuss changes to memo in response to

Defendant's motion to sever

0.40 $90.00

12/16/2014 CA Draft changes to argument section 1.A, included more

analysis

0.60 $135.00

12/16/2014 CA Researched and found joinder cases relating to FLSA cases,

involving company-wide decision-making as common

experience

0.40 $90.00

12/16/2014 CA Draft procedural background and factual background for brief 2.10 $472.50

12/16/2014 CA Meet with Mark to discuss further changes with briefs, adding

analysis and try to find more similarities between all of the

plaintiffs

0.30 $67.50

12/16/2014 CA Revised common questions of law or fact sections, focused on

common policy with entire company

0.60 $135.00

12/16/2014 CA Revise entire brief to correct typos and citations 1.30 $292.50

12/16/2014 CA Research for more FLSA misjoinder cases that found joiner

appropriate at our state of the trial

0.70 $157.50

12/17/2014 MJO Revised Plaintiff’s Response in Opposition to Defendant’s

Motion to Sever and Dismiss, re: reviewed third final draft of

Response drafted by Attorney Quinton Osborne;

reviewed/revised the following sections of Response in

Opposition—Introduction; Procedural Background; Factual

Background; Argument— Plaintiffs Are Appropriately Joined

Under Federal Rule Of Civil Procedure 20 And Their Lawsuit

Should Not Be Severed Pursuant To Rule 21; Legal Standard;

3.00 $825.00
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Plaintiffs’ Claims Arise Out Of The Same Series Of Transactions

Or Occurrences.

12/17/2014 CA Revise based on Mark's corrections for response to

Defendant's Motion to Disjoin Plaintiffs

0.70 $157.50

12/17/2014 CA Finish draft of introduction for brief 0.60 $135.00

12/17/2014 CA Finish draft of conclusion for brief 0.40 $90.00

12/17/2014 CA Reviewed all ten plaintiffs' depositions to find more hands-onkeyboard references1.50 $337.50

12/17/2014 CA Put together flex time similarities between the ten plaintiffs 1.30 $292.50

12/17/2014 CA Included all facts in argument in statement of facts, organized

accordingly

1.20 $270.00

12/18/2014 MJO Drafted/revised Plaintiffs’ Memorandum of Law in Opposition

to Defendant’s Motion to Sever and Dismiss, re:

drafted/revised Argument section—Plaintiffs Present Common

Questions of Fact and Law.

2.50 $687.50

12/18/2014 KJD Review, edit Response to Defendant's motion for misjoinder. 1.50 $675.00

12/19/2014 MJO Drafted Plaintiff’s Response in Opposition to Defendant’s

Motion to Sever and for Misjoinder, re: drafted factual

background concerning Plaintiffs Dawn Pence, Debra Tolles,

and Deborah Waldman.

3.00 $825.00

12/19/2014 CA Meet with Kevin and Mark to discuss what improvements need

to be made, additions to statement of facts and more details

about order

0.40 $90.00

12/19/2014 CA Added facts to brief regarding Armstrong 1.30 $292.50

12/19/2014 CA Added facts to brief regarding and organized for Bargerstock 1.20 $270.00

12/19/2014 CA Added facts to brief regarding and organized for Clunk 1.20 $270.00

12/19/2014 CA Added facts to brief regarding and organized for Cosentino 1.40 $315.00

12/19/2014 CA Added facts and information to order 1.20 $270.00

12/20/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Misjoinder, re: summarized Court’s decertification order in

detail.

1.00 $275.00

12/20/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Misjoinder, re: revised and re-drafted entire Factual

Background for following Plaintiffs—Linda Armstrong, Joy

Bargerstock, Patricia Clunk, Theresa Cosentino, Lisa Edwards,

Judith Lugo, Linda Mathias, Dawn Pence, Debra Tolles, and

Deborah Waldman.

4.00 $1,100.00

12/20/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Misjoinder, re: Plaintiffs Are Appropriately Joined Under

Federal Rule Of Civil Procedure 20 And Their Lawsuit Should

Not Be Severed Pursuant To Rule 21; Plaintiffs’ Claims Arise

Out Of The Same Series Of Transactions Or Occurrences;

Defendant Relies Upon Inapposite Case Law; Common

Questions of Law Or Fact Exist In This Lawsuit.

3.00 $825.00

12/20/2014 CA Finished statement of facts for Armstrong, added she always

used time saver and added her managers and region

0.50 $0.00

12/20/2014 CA Reviewed to make sure all facts in argument section for

Armstrong, Bargerstock, Clunk, Cosentino, and Edwards were

in statement of facts

0.70 $0.00

12/20/2014 CA Finished statement of facts for Bargerstock, added she always

used time saver and added her managers and region

0.40 $0.00

12/20/2014 CA Finished statement of facts for Clunk, added she always used

time saver and added her managers and region

0.40 $0.00

12/20/2014 CA Finished statement of facts for Cosentino, added she always

used time saver and added her managers and region

0.40 $0.00

12/20/2014 CA Finished statement of facts for Edwards, added she always

used time saver and added her managers and region

0.50 $0.00

12/21/2014 MJO Drafted Response in Opposition to Defendant’s Motion for

Misjoinder, re: Introduction; Factual Background; Plaintiffs Are

Appropriately Joined Pursuant to Rule 20; researched Motion

to Sever in 7th Circuit and requirements for severance in 7th

4.00 $1,100.00
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12/21/2014 MJO

Circuit.

Drafted Response in Opposition to Defendant’s Motion for 2.50 $687.50

Misjoinder, re: Plaintiffs’ Claims Should Not Be Severed;

Plaintiffs’ Claims Arise Out Of The Same Transaction Or

Occurrence And Present Common Questions Of Law Or Fact;

Settlement Of The Claims Or Judicial Economy Will Not Be

Facilitated Through Severance; No Prejudice Will Ensue

Through Refusing To Sever Plaintiffs’ Claims; Different

Witnesses And Documentary Evidence Are Not Required.

12/22/2014 MJO Drafted/revised Plaintiffs’ Memorandum of Law in Opposition

to Motion to Sever and Dismiss for Misjoinder, re: edited/cut

text to meet 15-page page limitation, re: made hand

corrections/suggestions for cutting throughout entire

document.

2.10 $577.50

12/22/2014 MJO Drafted/revised Plaintiffs’ Memorandum of Law in Opposition

to Motion to Sever and Dismiss for Misjoinder, re: edited/cut

text to meet 15-page page limitation, re: made hand

corrections/suggestions for cutting throughout entire

document.

1.30 $357.50

12/22/2014 MJO Drafted/revised Plaintiffs’ Memorandum of Law in Opposition

to Motion to Sever and Dismiss for Misjoinder, re: conducted

detailed final review of entire document prior to filing with

United States District Court for Northern District of Illinois.

1.20 $330.00

12/22/2014 KJD Review and edit response brief for motion for misjoinder. 1.00 $450.00

12/29/2014 MJO Drafted response to email from opt-in class member Julie

Wright, re: update to status of lawsuit.

0.20 $55.00

01/06/2015 MJO Researched opt-in class list for purposes of filing additional

suits against Transcend, including highlighting opt-ins from

multiple states including Missouri, California, Florida,

Minnesota, Texas, and Massachusetts.

2.20 $605.00

01/06/2015 MJO Researched opt-in class list questionnaires for purposes of

filing additional suits against Transcend, including

highlighting opt-ins from multiple states including Missouri,

California, Florida, Minnesota, Texas, and Massachusetts.

2.00 $550.00

01/06/2015 MJO Drafted email response to medical transcriptionist Debbie

Schwarm, re: potential lawsuit against Nuance.

0.30 $82.50

01/06/2015 MJO Researched “joinder,” “unpaid overtime,” and “FLSA” claims in

context of FLSA and New York Minimum Wage Act in New

York federal district court, re: read and researched numerous

cases including Lee v. ABC Carpet (2006), Gunawan v. Sake

Sushi Restaurant (2012), and Dragone v. Bob Bruno

Excavating, Inc. (2007)—researched New York “spread of

hours” premium and statute of limitations.

1.20 $330.00

01/09/2015 MJO Researched New York State law, re: filing new lawsuit in New

York; specifically researched New York spread of hours

concept.

0.60 $165.00

01/20/2015 MJO Drafted responses to email inquiries from Alice Gillespie,

Connie Duncan, and Penny Neal.

0.30 $82.50

01/20/2015 MJO Drafted proposed email to class, re: future plans for pursuing

individual lawsuits.

0.50 $137.50

01/22/2015 MJO Gathered documents for meeting with Attorney Kevin Dolley,

re: damages and potential new lawsuits involving opt-in

Plaintiffs.

0.80 $220.00

01/22/2015 MJO Meeting with Attorney Kevin Dolley, re: potential new lawsuits

to be filed.

0.50 $137.50

01/22/2015 MJO Gathered information on all Texas and New York Plaintiffs for

purposes of filing new lawsuit.

1.50 $412.50

01/23/2015 MJO Gathered information on all Missouri Plaintiffs for purposes of

filing new lawsuit.

0.50 $137.50

01/23/2015 MJO Gathered information on all Florida Plaintiffs for purposes of

filing new lawsuit.

0.50 $137.50

01/23/2015 MJO Gathered information on all Missouri Plaintiffs for purposes of 0.90 $247.50
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filing new lawsuit, re: payroll information and weeding out

those without sufficient time worked at Transcend.

01/23/2015 MJO Gathered information on all California Plaintiffs for purposes

of filing new lawsuit, re: payroll information and weeding out

those without sufficient time worked at Transcend.

1.50 $412.50

01/25/2015 MJO Gathered information on all California Plaintiffs for purposes

of filing new lawsuit, re: payroll information and weeding out

those without sufficient time worked at Transcend.

1.20 $330.00

01/25/2015 MJO Gathered information on all Florida Plaintiffs for purposes of

filing new lawsuit, re: payroll information and weeding out

those without sufficient time worked at Transcend.

1.50 $412.50

01/26/2015 MJO Gathered information on all New York Plaintiffs for purposes

of filing new lawsuit, re: payroll information and weeding out

those without sufficient time worked at Transcend; meeting

with Attorney Quinton Osborne for purposes of explaining

remainder of Transcend opt-in project.

0.80 $220.00

01/26/2015 QMO Went through New York Plaintiffs, determined how long they

worked at Transcend and when they worked there,

highlighted if they worked at Transcend for less than 8

months; went through texas Plaintiffs, determined how long

they worked at Transcend and when they worked there,

highlighted if they worked at Transcend for less than 8

months;Went through master list of plaintiffs in Transcend,

copy and pasted all plaintiffs that are outside of

CA/FL/MO/NY/TX into separate spread sheet, if plaintiff was

not included for their respective state and included them;

Went through the "everyone else" word document,

determined how long they worked at Transcend and when

they worked there, highlighted if they worked at Transcend

for less than 8 months.

8.10 $1,822.50

01/27/2015 MJO Meeting with Attorney Quinton Osborne, re: drafting

additional Complaints and non-engaging opt-in Plaintiffs.

0.50 $137.50

01/27/2015 MJO Meeting with Attorney Quinton Osborne, re: progress on nonengagements.0.20 $55.00

01/27/2015 QMO Talked with Mark about what to do with Transcend, told to

draft letter to plaintiffs in Transcend we will not engage, told

to draft accompanying email; Drafted letter to plaintiffs we are

not engaging, included language about the decertification

order, how they are free to find other counsel for their own

individual claims; drafted body of email that would be sent to

all plaintiffs who are we are not going to engage; sent an

email to all plaintiffs in Transcend who we would not engage,

attached a pdf document to each email that was personalized

to each plaintiff; found addresses, wrote the letters and

envelopes for the individuals whose emails came back with an

error.

8.20 $1,845.00

01/28/2015 QMO Researched California law regarding minimum wage law,

found they require an 8.50 minimum wage from 2010 to

2012, allows liquidated damages, SOL of 3 years; Researched

California law regarding overtime law, found they require time

and a half for all hours over 40 in a week, over 8 in a day, or

for the first eight hours on the seventh consecutive day

worked, also found CA requires the minimum wage be paid

for each individual hour worked, don't just take total hours

worked for the week and divide by weekly pay.

3.20 $720.00

01/28/2015 QMO Found and researched CA's unfair practices act, found a

violation of CA' wage and hour law is a violation of this act,

can only get restitutionary benefits, but has a SOL of 4 years;

stated drawing up CA's complaint, entered all of the CA

plaintiffs in the complaint, included when they worked for

Transcend and where they lived.

8.70 $1,957.50

01/29/2015 MJO Reviewed/revised initial draft of Complaint for California

Plaintiffs drafted by Attorney Quinton Osborne, re: made

1.00 $275.00
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01/29/2015 MJO

substantive and grammatical suggestions for correction.

Reviewed/revised initial draft of Complaint for California 0.80 $220.00

Plaintiffs drafted by Attorney Quinton Osborne, re: made

substantive and grammatical suggestions for correction.

01/29/2015 MJO Reviewed/revised initial draft of Complaint for New York

Plaintiffs drafted by Attorney Quinton Osborne, re: made

substantive and grammatical suggestions for correction.

0.80 $220.00

01/29/2015 QMO Added new registered agent for all of the complaints; made

Mark's changes to the Missouri and NY complaints where the

complaints were similar; drafted a list of questions to ask to all

transcend employees I will call; created excel sheet with CA

plaintiffs that includes questions I will ask the potential

plaintiffs.

1.50 $337.50

01/29/2015 QMO Wrote the minimum wage claim for the New York lawsuit,

included relevant statute and regs, NYLL 663; wrote overtime

for the New York lawsuit regarding the state law claim,

included NY statute and laws including 650 et seq. and 12

NYCRR 142­2.2; wrote claim for NY lawsuit arguing Defendant

owes Plaintiffs for spread of hours reasons, Plaintiffs were

entitled to a minimum wage payment if the employee worked

over 10 hours in a given day, included nedcessary facts.

8.60 $1,935.00

01/30/2015 QMO Got contact information for all CA, MO, NY, FL, and TX

plaintiffs in one word document; started calling and leaving

messages for CA plaintiffs until pone system went down, put

their answers in excel sheet; wrote and sent letter to plaintiff

who did not have email address or phone number of filed;

wrote standard email to send to plaintiffs who have phones

that do not work/ did not give us phone numbers, did not

send yet because phones still down; listed out all the people

to email on Monday who do not have phones listed or who

have phones that do not work.

7.20 $1,620.00

02/02/2015 QMO Called back CA plaintiffs that left messages for me over the

weekend; continued calling plaintiffs in CA, left messages for

all who did not answer, finished the CA list; created excel

sheet for NY plaintiffs, went through all NY plaintiffs, called

and/or left message to all potential plaintiffs; sent email to all

NY plaintiffs who either did not have phone or numbers did

not work; created excel sheet for MO, FL, and TX which will

record all responses

8.30 $1,867.50

02/03/2015 QMO Called all people who i did not speak to in CA because phones

were down last Friday.

3.30 $742.50

02/03/2015 QMO Sent personalized emails to all CA plaintiffs who did not

phone numbers; Sent letters to CA plaintiffs that did not have

numbers or emails; started calling Missouri plaintiffs, took

down information in excel sheet; sent emails to all TX

plaintiffs that did not have phone numbers; created and

mailed letters to all TX plaintiffs that did not have email or

phone.

7.60 $1,710.00

02/04/2015 QMO Called FL plaintiffs from 1-26, left messages if no response,

recorded all answers in the FL responses excel;Emailed all FL

plaintiffs so far who do not have phone numbers; sent letters

to the FL plaintiffs who do not have email addresses; Called

the remaining FL plaintiffs, 27-57, recorded answers in the FL

responses excel sheet; Emailed the FL’ plaintiffs whose phones

did not work or did not provide phone number from Plaintiffs

27­57;Mailed letters to individuals whose phones and emails

did not work/not provided;Called back CA and MO plaintiffs

that left me an email or phone message.

9.00 $2,025.00

02/05/2015 QMO Called TX plaintiffs from 1-26, left messages if no response,

recorded all answers in the FL responses excel sheet; Emailed

all TX plaintiffs whose phones did not work or did not provide

phone number;Created and sent letters to plaintiffs whose

phones and emails did not work;Researched FL law for their

10.20 $2,295.00
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complaint, found they have 5 year SOL for wage and hour

claims if willful; Created FL complaint with FL specific law and

plaintiffs; Researched TX law for wage and hour and overtime

issues, found not very helpful, 2 year SOL, must be employed

by them within 2 years which is not true in our case;Sent

follow up email to all plaintiffs from every state who have not

returned my call;Mailed letters to people whose emails did not

work and have not called me back yet

02/06/2015 QMO Morning: started going thru list of all plaintiffs from states

other than CA/TX/MO/NY/FL, determined if they had a good

claim or not, put responses in the everyone else responses

folder; got through 1-60 plaintiffs in morning;Afternoon:

continued going thru this list, got through plaintiffs 61-125,

reported all responses in everyone else responses; Found and

listed the phone numbers for the next 3 pages of everyone

else plaintiffs to call;

10.10 $2,272.50

02/09/2015 QMO Morning: called everyone else plaintiffs 126 – 161, noted

responses in everyone else responses excel sheet; Put all

response sheets for 5 states and everyone else excel sheet in

printable format, shrunk columns for each excel sheet,

changed font size, adjusted columns so they all fit and were

readable within one page, printed and gave to Mark;Found

next 4 pages of phone numbers for everyone else plaintiffs;

Afternoon: called everyone else plaintiffs 162-226, including a

lengthy conversation with Judy Lindquist;Gave brief update

on Transcend to Mark and Kevin

9.30 $2,092.50

02/10/2015 MJO Meeting with Attorney Quinton Osborne, re: disseminating

contingency fee agreements.

0.40 $110.00

02/10/2015 QMO Called Transcend everyone else plaintiffs 226 – 280, reported

all responses in the everyone else responses excel sheet;

Finished calling Transcend everyone else plaintiffs, called

numbers 281-400, reported all responses in the everyone else

responses excel sheet; Created contingency fee agreement for

all plaintiffs we will ask to join the transcend lawsuit, saved in

the Transcend new lawsuit folder; Sent a follow-up email to

all potential transcend plaintiffs who said they might have

emails relevant to the lawsuit, asked them again to look thru

their records and find any emails that may be relevant;

12.40 $2,790.00

02/11/2015 MJO Meeting with Attorney Quinton Osborne, re: update on status

of calls to opt-in Plaintiffs.

0.30 $82.50

02/11/2015 QMO Spent the morning going thru Obermeyer transcend folder,

pulled every single email and document we previously

received from the plaintiffs into one folder, renamed all

documents by last name, first name; Put the emails into the

new Transcend folder, put in the state where the person is

currently located; Went thru all emails for California plaintiffs,

including Alana Barnes Garvic, Cathy Haines, and Pollak,

determined if and which emails would be helpful in lawsuit,

added Barnes to a our potential client list; Went through all of

Patricia Townsend (NY)’s 30 emails, found that only a few

might be relevant in lawsuit against Transcend, added her to

potential client list; Went through emails of MO clients Patsy

Hayes and Marie Plum, determined which ones were relevant,

found Plum might be good potential client; Went through FL

plaintiffs’ emails, including Karen Goodrich, Barbara Keenan,

Sarena Marques, Sheila Reeser, Jacqueline St. Georges, Sherry

Wilson, and Darcy Wingler, found which ones would be

helpful in suit, found Wilson’s and Keenan’s were helpful and

would be good potential clients; Went through 6 TX clients’

emails to determine which ones would be relevant, found

Denio and Wright would be helpful, added to potential client

list.

10.40 $2,340.00

02/12/2015 QMO Called all plaintiffs from 5 main states who still have not

responded and have working phones, included any responses

6.60 $1,485.00
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in their respective state excel sheet in the transcend folder;

went thru CA plaintiffs to make spread sheet printable,

decreased width of column, added title to top of the sheet,

made it so top column was on every printed sheet, lowered

cells so everything in cell was visible; went thru NY plaintiffs

to make spread sheet printable, decreased width of column,

added title to top of the sheet, made it so top column was on

every printed sheet, lowered cells so everything in cell was

visible; went thru MO plaintiffs to make spread sheet printable,

decreased width of column, added title to top of the sheet,

made it so top column was on every printed sheet, lowered

cells so everything in cell was visible; went thru FL plaintiffs to

make spread sheet printable, decreased width of column,

added title to top of the sheet, made it so top column was on

every printed sheet, lowered cells so everything in cell was

visible; went thru TX plaintiffs to make spread sheet printable,

decreased width of column, added title to top of the sheet,

made it so top column was on every printed sheet, lowered

cells so everything in cell was visible; went thru everyone else

plaintiffs to make spread sheet printable, decreased width of

column, added title to top of the sheet, made it so top

column was on every printed sheet, lowered cells so

everything in cell was visible; Met with Mark and Kevin about

update on Transcend, learned I need to send nonenagement

letters to all individuals who expressed they were not

interested in the lawsuit, engagement letters to all plaintiffs of

the 5 states that express interest, separate lists for each state

into people who have given answers and people who have

not gotten back with me; Drafted engagement letter to send

to plaintiffs, approved by Mark and Kevin; sent email to all

everyone else plaintiffs who have not responded to my phone

calls yet, said they should call me for update on lawsuit and

potential for filing new lawsuit against Transcend if they were

interested; Recorded all people whose emails did not work,

updated their respective sheets.

02/13/2015 QMO called Anne Thorpe in the morning and a few other “everyone

else” plaintiffs I said I would call back; Sent out personalized

nonengagement letters to all CA plaintiffs, all came with pdf

with more detailed explanation of Transcend case and how we

are nonengaging them;Sent out personalized nonengagement

letters to all NY plaintiffs, all came with pdf with more detailed

explanation of Transcend case and how we are nonengaging

them; Sent out personalized nonengagement letters to all MO

plaintiffs, all came with pdf with more detailed explanation of

Transcend case and how we are nonengaging them;Sent out

personalized nonengagement letters to all FL plaintiffs, all

came with pdf with more detailed explanation of Transcend

case and how we are nonengaging them

11.70 $2,632.50

02/16/2015 QMO Scanned in the representation agreements we received over

the weekend, organized transcend folders to get ready for

more contracts; Made separate excel sheet for TX plaintiffs,

separated plaintiffs who gave a response from plaintiffs who I

have not gotten ahold of yet; Made separate excel sheet for

“everyone else” plaintiffs, separated plaintiffs who gave a

response from plaintiffs who I have not gotten ahold of yet;

Tried to figure out what to do with “Everyone else” plaintiffs,

organized excel sheet by state, looked through responses;

Sent email to mark and Kevin, attached everyone else excel

sheet, suggested we send out contracts to plaintiffs who are

in states with multiple plaintiffs, like Ohio; Started preparing

to send out nonengagement letters to all plaintiffs who have

not responded to my communications yet, accumulated their

email addresses for plaintiffs; Started making personalized

letters for potential nonengagement clients.

8.40 $1,890.00

02/17/2015 QMO Talked with everyone else client Michelle McComas, added to 0.60 $135.00
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02/25/2015 QMO

excel spreadsheet, sent her an email for any follow-up emails.

Scanned in all representation agreements that had 0.90 $202.50

accumulated since I left, put in proper Transcend folder,

updated respective excel sheets.

02/25/2015 QMO Went through email, responded to all Transcend clients who

emailed me while I was away, send disengage letters to all

individuals who said they were not interested, updated excel

sheets.

1.50 $337.50

02/25/2015 QMO Update Transcend excel sheets, sent nonengage letters to all

people I have spoken to on phone, but not sent nonengage

letter yet. Make sure all clients who have submitted answers

were on one excel sheet, while those who have not responded

were separate.

1.50 $337.50

02/25/2015 QMO Entered Langella's rep agreement, scanned in, updated excel

sheet.

0.20 $45.00

02/25/2015 QMO Called and left message with Mary Hall, Barbara Vaughn.

Talked with Mary Hall on phone, recorded response in excel

sheet. Called and talked with Elizabeth Sennett. Called and left

message for Diane Birrer. Called and gave an update to CA

plaintiff Carol Nigsarian.

1.00 $225.00

02/25/2015 QMO Talked with Ronda Campbell, reported her answers on excel

sheet, send her follow-up email in case she finds in relevant

emails. Call and left a message for Linda Gray. Called and left

a message for Barb Williams. Called and left message for Kelly

Stonovak. Called Renee Nichols and recorded information in

excel sheet.

0.90 $202.50

02/25/2015 JCK Phone call with Barb Wolkins re: message for Quinton to

return call, when available

0.10 $22.50

02/26/2015 QMO Respond to Connie Watson's email, put her on nonengage

list, send nonengagement email. Call Susan Cunningham,

record answers in excel sheet. Call Diane Spencer and left

message.

0.40 $90.00

02/26/2015 QMO Started docketing all of the individual named plaintiffs who

were severed from case and assigned new court numbers.

Docket Clunk and Pence.

0.50 $112.50

02/26/2015 QMO Added 5 new clients to bill4time who were former Transcend

named plaintiffs.

0.60 $135.00

02/26/2015 QMO Talk with Diane Birrer, find out she filed Bankruptcy in 2012,

tell her we will not engage, send nonengage email and add to

nonengage excel sheet.

0.50 $112.50

02/26/2015 QMO Put all excel sheets and printed out for Mark and I to review

and group.

0.40 $90.00

02/26/2015 MJO Meeting with Attorneys Kevin Dolley and Quinton Osborne, re:

filing additional lawsuits

0.30 $82.50

02/26/2015 QMO Started noting clients who filed bankruptcy within last 7

years.

0.70 $157.50

03/02/2015 QMO Go through CA plaintiffs, eliminate all plaintiffs who filed

bankruptcy within past 7 years.

0.80 $180.00

03/02/2015 QMO Start grouping CA plaintiffs, make separate excel sheets in CA

Transcend folder.

0.00 $0.00

03/02/2015 QMO Start grouping NY plaintiffs, make separate excel sheets in NY

Transcend folder.

0.80 $180.00

03/02/2015 QMO Start grouping MO plaintiffs, make separate excel sheets in MO

Transcend folder.

1.00 $225.00

03/02/2015 QMO Start grouping FL plaintiffs, make separate excel sheets in FL

Transcend folder.

0.90 $202.50

03/02/2015 QMO Start grouping TX plaintiffs, make separate excel sheets in TX

Transcend folder.

1.00 $225.00

03/02/2015 QMO Go through all everyone else clients, remove all clients who

have filed bankruptcy within past 7 years per KJD's

instruction.

0.40 $90.00
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03/02/2015 QMO Put all potential groups in printable format, give to Mark. 0.40 $90.00

03/02/2015 QMO Go through Kevin's excel sheet I gave to him last week,

deleted all plaintiffs he did not want to engage and move to

nonengage excel sheet.

0.60 $135.00

03/03/2015 QMO Go through all plaintiff groups, separate out by full time and

part time, and by plaintiffs who were specifically told to

change time. Send email to Mark and Kevin discussing the

different groups, and how I recommend filing the CA lawsuit

first.

1.10 $247.50

03/03/2015 QMO Meet with Mark and Kevin about Transcend. Discuss how to

pursue cases, dismiss Chicago named plaintiffs, file grouped

plaintiffs today with Mark.

1.00 $225.00

03/03/2015 MJO Meeting with Attorneys K. Dolley and Q. Osborne, re: strategy

for pursuing additional lawsuits

1.00 $275.00

03/03/2015 QMO Meet with Mark about Transcend. Determine which plaintiffs

to keep and dismiss in the northern district of Illinois.

1.30 $292.50

03/03/2015 MJO Meeting with Attorney Q. Osborne, re: strategy on breaking up

individual 10 named Plaintiffs and who to dismiss/not dismiss;

review groupings of potential joined class members drafted by

Attorney Q. Osborne;

1.70 $467.50

03/03/2015 QMO Start grouping all everyone else plaintiffs, get through Ohio. 2.30 $517.50

03/03/2015 QMO Grouped remaining everyone else plaintiffs in groups,

finished.

1.60 $360.00

03/03/2015 QMO Discuss Transcend with Mark and Kevin, draft email for Mark's

review to send to Russ about update in case.

0.40 $90.00

03/04/2015 QMO creat model complaint that will be used for all states. Email to

mark the complaint and location.

0.60 $135.00

03/04/2015 QMO Draft complaints for all group lawsuits against Transcend

outside of major 5 states, including North Carolina, Georgia,

Colorado, Ohio, Tennessee, Virginia, Washington, and West

Virginia.

2.70 $607.50

03/04/2015 MJO Draft email to co-counsel Russ Riggan, re: status of case 0.30 $82.50

03/04/2015 QMO Talk with Mark and Kevin about transcend case, grouping

lawsuits.

0.90 $202.50

03/04/2015 QMO Prepare to send out all Transcend agreements to plaintiffs

outside 5 main states, include each of their addresses in the

representation agreement letters, put their names in the

proper places in letters, save as pdf.

2.40 $540.00

03/04/2015 MJO Draft email to Russ Riggan, re: settlement talks with other side

at this point concerning individual lawsuits

0.20 $55.00

03/04/2015 QMO Start emailing out representation agreements to all plaintiffs

not in one of main 5 states, got to Ohio.

1.10 $247.50

03/05/2015 QMO Call and email all CA clients who have not returned

agreements yet.

1.00 $225.00

03/05/2015 QMO Call and email all NY clients who have not returned

agreements yet.

1.00 $225.00

03/05/2015 QMO Call and email all MO clients who have not returned

agreements yet.

1.20 $270.00

03/05/2015 QMO Start Calling and emailing all FL full-time clients who have not

returned agreements yet.

1.30 $292.50

03/05/2015 QMO Call and email all FL part-time clients who have not returned

agreements yet.

1.20 $270.00

03/05/2015 QMO Call and email all TX clients who have not returned

agreements yet.

0.90 $202.50

03/05/2015 QMO Call and email all everyone else clients who have not returned

agreements yet.

2.00 $450.00

03/06/2015 QMO Enter agreements we have received, talk with Barbarah Keenan

for 20 minutes.

0.60 $135.00

03/06/2015 QMO Meet with mark about Transcend complaints, agree to meet

on Saturday about complaints.

0.40 $90.00

03/06/2015 QMO Prepare CA complaint and print out CA complaint for Mark's 1.00 $225.00
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03/06/2015 MJO

review.

Meeting with Attorney Quinton Osborne, re: status of 0.50 $137.50

California complaints

03/06/2015 QMO Call all transcenders who left a message for me, include their

rep. agreements in the corresponding folders.

1.50 $337.50

03/06/2015 QMO Call remaining Transcend plaintiffs I have not contacted yet,

including states of Tennessee, Virginia, Washington, and West

Virginia.

1.80 $405.00

03/06/2015 QMO Nonengaged all plaintiffs who we have not got in touch with

yet or did not seem interested, around 30 plaintiffs, mailed

letters for 5 plaintiffs whose emails did not work.

0.70 $157.50

03/07/2015 MJO Review Complaints drafted by Attorney Quentin Osborne, re:

extensive and detailed review of two complaints for Northern

District of New York and Northern District of Texas

2.80 $770.00

03/09/2015 MJO Review docket entries for upcoming status hearings 0.30 $82.50

03/10/2015 QMO Update and docket all named plaintiffs court dates; create

new word document with all former-named plaintiffs included;

inform attorney M. Obermeyer Mathias needs to be dismiss

soon.

1.20 $270.00

03/10/2015 QMO Talk on phone with potential Virginia client Kim Dent, inform

her of her potential obligations as a plaintiff in a lawsuit.

0.50 $112.50

03/10/2015 QMO Assist and draft California complaints for full-time clients; add

paragraphs regarding joinder.

1.20 $270.00

03/10/2015 QMO Draft and edit California complaint for part-time clients; ensure

substantive changes to California full-time complaint are

included in part-time complaint; include portion about how

joinder is proper for the part-time clients.

2.00 $450.00

03/11/2015 QMO Work on drafting and editing Texas full-time complaint. 0.50 $112.50

03/11/2015 QMO Speak with potential Transcend plaintiff Lisa Sinkler; send her

representation agreement; ask her about make up to minimum

emails; create new potential Michigan group.

1.00 $225.00

03/11/2015 QMO Finish drafting Texas complaints for full-time plaintiffs; add

paragraphs on how joinder is appropriate; email to Attorney

M. Obermeyer.

0.60 $135.00

03/11/2015 QMO Draft Mathias motion to dismiss without prejudice and notice

for hearing; file both documents in Northern District of

Illinois.

0.60 $135.00

03/11/2015 QMO Go through all Transcend named plaintiffs, ensure all joint

status conference reports are docketed.

0.30 $67.50

03/11/2015 QMO Draft Texas complaint with two plaintiffs; add joinder section;

update excel sheet.

0.90 $202.50

03/11/2015 QMO Look to see when exactly Terian Edwards declared

bankruptcy; learn she filed for bankruptcy in 2010;

nonengage Terian Edwards; email Attorney M. Obermeyer

updated complaints with Terian Edwards removed.

0.70 $157.50

03/11/2015 QMO Draft and edit the Texas part-time complaint; add joinder

statements.

0.70 $157.50

03/11/2015 QMO Draft motions to dismiss for all named plaintiffs we are

dismissing from Northern District of Illinois; look up when

each judge holds hearings, and how many days notice are

necessary; draft notices of motions to dismiss without

prejudice.

2.00 $450.00

03/12/2015 MJO Draft email to co-counsel Kate Sedey, re: status of Cosentinospecific lawsuit; review docket entries concerning Motions to

Dismiss and docket said entries; review Motion to Dismiss

without Prejudice and Notice of Hearings for dismissals of

Armstrong, Bargerstock, Lugo, Tolles, and Waldman

0.80 $220.00

03/12/2015 QMO Meet with Attorney M. Obermeyer about plan of attack for

Transcend cases; discuss amending complaints, dismissing

certain clients, and start getting discovery ready for Clunk.

0.60 $135.00

03/12/2015 QMO Print out all motions to dismiss and notices of motion to 1.80 $405.00
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dismiss for all clients we will dismiss in Chicago; give motion

and notices of motions to Attorney M. Obermeyer; change all

notices of our motions so the date is scheduled for Thursday

morning; check all judges to see if they can hold civil motion

hearings on Thursday mornings and when; filed all motions to

dismiss and notices of motion to dismiss for remaining named

plaintiffs.

03/12/2015 MJO Meeting with Attorney Q. Osborne, re: amending complaints

for Pence and Clunk; dismissing Waldman, Tolles, Lugo,

Bargerstock, and Armstrong; and drafting written discovery to

send to the other side for Clunk

0.70 $192.50

03/13/2015 QMO Organize all Transcend named plaintiff filed documents;

ensure all important dates are docketed.

1.50 $337.50

03/13/2015 QMO Speak to client Barbara Vaughn on phone; talk about what

would be involved in bringing individual lawsuit; what is

needed of her.

0.30 $67.50

03/14/2015 MJO Docket notice of hearing dates for motions to dismiss for

Armstrong, Bargerstock, Clunk, Lugo, and Waldman

0.30 $82.50

03/16/2015 KJD Review and edit complaint for full time California Employees 2.50 $1,125.00

03/16/2015 QMO Have meeting with group 2, discuss Transcend complaints. 0.50 $112.50

03/17/2015 QMO Enter Barbara Keenan's representation agreement; mark her

agreement in the Florida excel sheet; return Transcend client

phone call.

0.60 $135.00

03/17/2015 QMO Implement all of Attorney M. Obermeyer's changes to

California part-time complaint; take out all facts and law

related to overtime claims.

1.10 $247.50

03/17/2015 QMO Start implementing facts from Memorandum in Opposition to

Decertification; get through "Plaintiffs Share Fundamental

Factual Similarities" to "Defendant's Uniform Half-Time

Overtime Rate."

2.50 $562.50

03/17/2015 MJO Phone call with Judge Leinenweber's clerk, re: dismissals

without prejudice of Waldman and Armstrong claims

0.30 $82.50

03/17/2015 QMO Call Judge Sharon Johnson Coleman's chambers to make sure

we do not have to appear tomorrow; learn we do not have to

appear; Send email to Attorneys M. Obermeyer and K. Seday;

inform them we do not have to appear tomorrow.

0.70 $157.50

03/17/2015 QMO Start implementing facts from Memorandum in Opposition to

Decertification; get through "Defendant's Uniform Production

Standards" to "Data Showing Plaintiffs' Actual Work Time."

2.90 $652.50

03/17/2015 QMO Call two Transcend clients; record their responses in group

respond sheets.

0.80 $180.00

03/18/2015 QMO Write email to Attorney M. Obermeyer informing him Lugo and

Bargerstock are being dismissed; write response to Judge

Coleman's clerk; return two Transcend client calls.

1.70 $382.50

03/18/2015 QMO Meet with Attorney M. Obermeyer regarding what to do with

California, New York, and Texas Complaints, and plan to send

them to Attorney K. Dolley as soon as possible.

0.80 $180.00

03/19/2015 QMO Draft New York Group 2 complaint; add all plaintiffs; add six

plaintiffs to party names; add joinder facts.

1.20 $270.00

03/19/2015 QMO Draft single Plaintiff complaint for Kim Gersie­Scott; change

Plaintiffs to Plaintiff; change all their/them/they to singular

version; read through complaint to ensure all personal

pronouns are correct.

1.70 $382.50

03/23/2015 QMO Receive and read documentation sent by Transcend client Gail

Riley; scan in and save to her Florida specific folder; describe

the time logs in the Florida group excel sheet.

0.70 $157.50

03/23/2015 QMO Email back and forth with Transcend client Kim Gersie­Scott;

attempt to get ahold of her; call her numerous times; send

email giving her my number and when she can call me.

0.40 $90.00

03/23/2015 QMO Draft Florida complaint for six full-time plaintiffs who were not

specifically told to change their time sheets; added all

plaintiffs' names, dates of employment, residence, and

1.30 $292.50
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03/23/2015 QMO

reasons for joinder.

Draft Florida complaint for seven full-time plaintiffs who were 1.30 $292.50

specifically told to change their time sheets; added all

plaintiffs' names, dates of employment, residence, and

reasons for joinder.

03/23/2015 QMO Draft Florida complaint for part-time plaintiffs; add all

plaintiffs' names, dates of employment, residence, and

reasons for joinder.

1.50 $337.50

03/23/2015 KJD Review and edit complaint and research FLSA elements 1.50 $675.00

03/24/2015 QMO Go through all Transcend lists; make sure all clients who are

not included in a group are on the list to disengage;

disengage all clients who are on disengage list.

2.40 $540.00

03/25/2015 KJD Review and edit complaint for filing 1.00 $450.00

03/25/2015 QMO Draft part-time Florida complaint; add specific information

about Plaintiffs.

1.10 $247.50

03/25/2015 QMO Meeting with Attorney M. Obermeyer about Transcend

Complaints in Florida and Missouri.

0.50 $112.50

03/25/2015 QMO Start working on Missouri complaints; add specific

information; add dates of employment.

0.60 $135.00

03/25/2015 QMO Meeting with Attorneys K. Dolley and M. Obermeyer regarding

Transcend Complaint.

0.50 $112.50

03/25/2015 MJO Meeting with Attorneys K. Dolley and Q. Osborne, re: drafting

and amending Complaints, specifically organizational structure

0.50 $137.50

03/25/2015 QMO Send emails to Alane Barnes Garvic; save all of her emails in

her California Transcend folder; classify emails in the excel

sheet; respond to her email to me.

0.90 $202.50

03/26/2015 QMO Take phone call from potential Transcend client Christy Jones;

ask her the Transcend client questions and record them in the

everyone else excel sheet.

0.40 $90.00

03/26/2015 QMO Draft Missouri part-time complaint; add specific information

about client; when she was at Transcend; make sure the entire

complaint only refers to one plaintiff instead of more than

one.

1.10 $247.50

03/27/2015 KJD Review and edit complaint 3.00 $1,350.00

03/28/2015 QMO Redraft California complaint implementing Attorney K. Dolley's

edits to Pence's complaint; make Plaintiffs plural; read

through draft to ensure everything is properly referring to

Plaintiffs; send email to Attorney L. Spencer Garth informing

her the complaint is ready for her review.

2.40 $540.00

03/30/2015 QMO Talk to potential client Brenda Bain on the phone; discuss her

concerns about lawsuit and what we would do for her.

0.60 $135.00

03/31/2015 MJO Draft email to local counsel Kate Sedey, re: notice of

presentment scheduled for Thursday, April 2

0.20 $55.00

03/31/2015 MJO Draft email to co-counsel Kate Sedey, re: notice of

presentment scheduled for April 2

0.20 $55.00

03/31/2015 QMO Spoke with Deborah Calendine on the phone regarding

Transcend; she spoke regarding her documentation; discussed

returning her representation agreement to us.

0.50 $112.50

04/01/2015 QMO Go through Pence, Clunk, and Cosentino cases; ensure all

relevant deadlines are docketed.

0.80 $180.00

04/02/2015 QMO Speak to potential Texas transcend client Jamie Smith on the

phone; recorded her answers in Texas excel sheet; email her a

representation agreement.

0.80 $180.00

04/03/2015 QMO Email with Debbie Calondine regarding if she should send in a

representation agreement.

0.20 $45.00

04/03/2015 QMO See what changes we can make to complaint to fix

defendant's alleged cures in their motion to dismiss the

complaint.

0.80 $180.00

04/07/2015 QMO Speak to potential client Kim Moore on the phone; inform her

we disengaged her because she worked at Transcend for only

a couple months; also sent her an email.

0.40 $90.00
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04/07/2015 QMO Speak with potential client Christy Jones on the phone

regarding us potentially representing her; record her answers

on excel sheet.

0.40 $90.00

04/09/2015 QMO Meet with Attorney M. Obermeyer on status of Clunk and

Cosentino responses; divy out assignments.

1.50 $337.50

04/11/2015 QMO Begin working on Cosentino's Response to Motion for

Summary Judgment; read through Defendant's statement of

undisputed material facts and their motion; get through first

half of summarizing Cosentino's deposition transcript.

4.50 $1,012.50

04/12/2015 QMO Finish summarizing the deposition transcript of Cosentino. 4.00 $900.00

04/13/2015 QMO Speak to potential client Laura Key on the phone; discuss her

potential case; record information in excel sheet; send her

follow-up email with representation agreement.

0.50 $112.50

04/13/2015 QMO Meet with Attorney M. Obermeyer about working on Response

to Motion for Summary Judgment.

0.50 $112.50

04/13/2015 QMO Go through Transcend response to class decertification; copy,

paste, and rename our exhibits for use in Cosentino.

0.70 $157.50

04/13/2015 MJO Draft Response in Opposition to Defendant's Motion for

Summary Judgment, re: outlined Defendant's arguments in

Defendant's Memorandum of Law in Support of Its Motion for

Summary Judgment; outlined Plaintiff's arguments for

Response to Motion for Summary Judgment; began

researching and reading relevant case law in both Northern

District of Illinois and Western District of Kentucky

3.20 $880.00

04/13/2015 QMO Locate all of the deposition summaries for Transcend's

corporate representatives.

0.40 $90.00

04/13/2015 QMO Read through Defendant's statement of uncontroverted

material facts; copied over to reply word document.

0.60 $135.00

04/13/2015 QMO Speak with Attorney M. Obermeyer about plan of attack for

response to motion for summary judgment.

0.50 $112.50

04/13/2015 QMO Find examples to use in drafting response to motion for

summary judgment.

0.50 $112.50

04/14/2015 QMO Go through the Transcend folder to find all Cosentino emails

and discovery information.

1.40 $315.00

04/14/2015 MJO Draft Response in Opposition to Motion for Summary

Judgment, re: Legal Standard; Argument- Cosentino Comes

Forward With Evidence Demonstrating That Transcend Is

Liable For Her Uncompensated Work As A Result Of Her

Testimony Concerning Her Hours Worked And Defendant’s

Inaccurate Time Records; Plaintiff Presents Record Evidence

Demonstrating That Defendant’s TimeSaver Records Were

Systematically Inadequate And Inaccurate

6.80 $1,870.00

04/14/2015 QMO Draft response to Defendant's Statement of Undisputed

Material Facts; draft answers for questions 1-7.

1.90 $427.50

04/14/2015 QMO Speak with potential Georgia Transcend client on the phone

who now lives in Texas; record answers in excel; send her

representation agreement.

0.30 $67.50

04/14/2015 QMO Speak to Theresa on the phone to update her on case and

discuss what we need from her.

0.50 $112.50

04/14/2015 QMO Draft response to Defendant's Statement of Undisputed

Material Facts; draft answers for questions 8-15.

2.50 $562.50

04/15/2015 QMO Search for Cosentino-specific M*Modal data, which I found in

an old discovery folder.

0.70 $157.50

04/15/2015 QMO Go through Theresa's TimeSaver Records, M*Modal data, and

TimeSaver reports to figure out how best to use the data in

the statement of additional facts in response to summary

judgment.

2.10 $472.50

04/15/2015 MJO Draft Plaintiff's Memorandum in Opposition to Defendant's

Motion for Summary Judgment, re: Plaintiff Presents Record

Evidence Demonstrating That Defendant’s TimeSaver Records

Were Systematically Inadequate And Inaccurate

2.00 $550.00

04/15/2015 MJO Draft Plaintiff's Opposition to Defendant's Motion for Summary 2.40 $660.00
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Judgment, re: Cosentino Comes Forward With Evidence

Demonstrating That She Performed Compensable Work That

Was Not Paid; Defendant’s M*Modal Reports Are Controverted

By Plaintiff’s Experience

04/15/2015 QMO Draft responses to their statement of facts for motion for

summary judgment 20-26.

3.50 $787.50

04/15/2015 MJO Draft Plaintiff's Memorandum of Law in Opposition to

Defendant's Motion for Summary Judgment, re: Plaintiff

Comes Forward With Evidence Controverting Defendant’s

Claim That It Lawfully Paid Plaintiff Overtime At A Half-Time

Rate

1.60 $440.00

04/15/2015 LSG Review and revise complaint in Haines et. al. v. Transcend

lawsuit.

0.80 $220.00

04/15/2015 MJO Draft Response in Opposition to Motion for Summary

Judgment, re: Defendant's actual and constructive knowledge

of Cosentino performing uncompensated work

1.60 $440.00

04/16/2015 LSG Review and revise petition. 1.00 $275.00

04/16/2015 QMO Draft responses to Defendant's statement of material facts in

support of their motion for summary judgment. Draft

responses to facts 26 to 30.

2.50 $562.50

04/16/2015 QMO Speak to Attorneys K. Dolley and M. Obermeyer about status

of new lawsuits; discuss how to start filing and obtaining local

counsel.

0.40 $90.00

04/16/2015 QMO Begin drafting our statement of additional facts in response to

defendant's motion for summary judgment; draft first 20

facts.

3.50 $787.50

04/17/2015 MJO Review Plaintiff's Response to Defendant's Statement of Facts

drafted by Q. Osborne

1.80 $495.00

04/17/2015 MJO Draft Declaration for Theresa Cosentino 1.50 $412.50

04/17/2015 QMO Make changes to Theresa's declaration; call Theresa regarding

declaration and email it to her.

0.60 $135.00

04/17/2015 MJO Draft Plaintiff's Response in Opposition to Motion for

Summary Judgment, re: Plaintiff’s Supervisors Had

Constructive Knowledge Of Plaintiff Performing

Uncompensated Work.

0.50 $137.50

04/17/2015 QMO Go through all exhibits previously used in our memorandum

opposing decertification; implement all facts into statement of

additional facts that help our case.

3.40 $765.00

04/17/2015 MJO Draft email to opposing counsel for review of attorney K.

Dolley

0.30 $82.50

04/17/2015 MJO Draft Response in Opposition to Motion for Summary

Judgment, re: Introduction

1.50 $412.50

04/18/2015 QMO Draft statement of facts in memorandum of law opposing

summary judgment; include most facts in additional statement

of material facts; start looking through Cosentino's payrolls to

find weeks where she was not paid minimum wage.

4.20 $945.00

04/18/2015 MJO Draft/revise Statement of Additional Facts in support of

Response in Opposition to Motion for Summary Judgment

3.50 $962.50

04/19/2015 QMO Calculate how much Cosentino was paid for each week she

was at Transcend; compare with how many hours she

recorded for each week.

4.00 $900.00

04/19/2015 MJO Draft Plaintiff's Response in Opposition to Defendant's Motion

for Summary Judgment, re: Introduction; Factual Background;

Argument- Cosentino Comes Forward With Evidence

Demonstrating That She Performed Compensable Work That

Was Not Paid; Defendant’s M*Modal Reports Are Controverted

By Plaintiff’s Experience

2.30 $632.50

04/19/2015 QMO Draft statement of facts with minimum wage facts included;

draft minimum wage argument section of brief; create pdf

versions for all pay records for 2010, 2011, and 2011 to file

as exhibits.

2.60 $585.00

04/19/2015 MJO Draft Plaintiff's Statement of Additional Facts, re: conducted 2.00 $550.00
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extensive cite check of citations within Statement of

Additional Facts

04/20/2015 QMO Calculated weekly pay totals for all weeks I have not done so

far.

1.30 $292.50

04/20/2015 MJO Draft Plaintiff's Statement of Additional Facts 0.50 $137.50

04/20/2015 MJO Draft/review Plaintiff's Response to Defendant's Statement of

Undisputed Facts, re: conducted extensive review of Plaintiff's

Response to Defendant's Statement of Undisputed Facts, No.

1-30

3.50 $962.50

04/20/2015 QMO Review, check citations, and proofread response to

Defendant's Motion for Summary Judgment, Statement of

Additional Undisputed Material Facts, and Response to their

Statement of Facts.

1.90 $427.50

04/20/2015 QMO Research issue of whether Plaintiff not completely

understanding legal claim has any relevance.

0.90 $202.50

04/20/2015 QMO Gather all exhibits to be used in Cosentino response to motion

for summary judgment. Save all documents in exhibit folder.

1.70 $382.50

04/21/2015 QMO Gather all documentation together for all California (CA)

Plaintiffs, including Alane Barnes Garvik, Cathy Haines, Julie

Jones, Laura Key, and Bobbi Pollak. Documents include

earning statements, excel sheets for pay per day, and

timesaver records for each account.

3.50 $787.50

04/21/2015 QMO Call Alane Barnes Garvik about case; give her update; ask her

more questions about her situation.

0.30 $67.50

04/21/2015 QMO Speak with California (CA) client Cathy Haines about her

situation; ask more questions; update her on case.

0.40 $90.00

04/21/2015 QMO Speak with California (CA) client Julie Jones about her

situation; ask more questions; update her on case.

0.30 $67.50

04/21/2015 QMO Speak with California (CA) client Carol Nigsarian about her

situation; ask more questions; learn she wants to nonengage;

send her nonengage her.

0.40 $90.00

04/21/2015 QMO Speak with California (CA) client Marcela DeBano about her

situation; ask more questions; learn she does not have

minimum wage or overtime claim; send her nonengagement

documents.

0.40 $90.00

04/21/2015 QMO Examine California (CA) client Alane M. Barnes Garvik claim to

add more detail to her California full-time complaint; calculate

her weekly totals for all weeks; find week where she was not

paid overtime and not paid minimum wage.

0.70 $157.50

04/21/2015 QMO Examine California (CA) client Julie Jones claim to add more

detail to her California full-time complaint; calculate her

weekly totals for all weeks; find week where she was not paid

paid minimum wage.

0.90 $202.50

04/21/2015 QMO Make edits to California (CA) full-time complaint with Alane

Barnes Garvik and Cathy Haines; add their specific information

into Complaint, including hours worked, example of overtime,

and example of minimum wage; send copy to Attorney M.

Obermeyer.

1.80 $405.00

04/21/2015 QMO Make edits to California (CA) part-time complaint with Julie

Jones and Bobbi Pollak; add their specific information into

Complaint, including hours worked, and example of minimum

wage violation; send copy to Attorney M. Obermeyer.

1.40 $315.00

04/21/2015 MJO Draft/review Plaintiff's Memorandum of Law in Opposition to

Defendant's Motion for Summary Judgment, re: condensed

argument section to 15 pages

1.50 $412.50

04/22/2015 KJD Review and edit Response for Summary Judgment, Response

Statement of Undisputed Facts, additional Facts and

Memorandum of Law

0.50 $225.00

04/22/2015 QMO Speak with Transcend California Client Bobbi Pollak on the

phone; update her on case; discuss her case in more detail.

0.40 $90.00

04/22/2015 QMO Update Theresa on status of her case; discuss declaration with

her.

0.30 $67.50
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04/22/2015 QMO Go through statement of additional facts and response to

Defendant's statement of facts in support of their motion for

summary judgment; correct all citations so they cite to our

exhibits rather than previous docket entries; add exhibits that

were not already added.

2.10 $472.50

04/22/2015 QMO Help Attorney M. Obermeyer file our exhibits, memorandum in

response to their motion for summary judgment, response to

their statement of facts, and additional facts.

1.70 $382.50

04/22/2015 QMO Go through Cosentino's earning statements and redact all of

her addresses.

1.10 $247.50

04/22/2015 QMO Implement Attorney K. Dolley's corrections to response to

statement of facts.

2.70 $607.50

04/22/2015 QMO Implement Attorney J. Keane's corrections to memorandum in

opposition to Defendant's motion for summary judgment.

0.70 $157.50

04/22/2015 JCK Confer with M. Obermeyer re: review of response to

Defendant's motion for summary judgment; review and draft

edits to response to motion for summary judgment.

0.30 $67.50

04/22/2015 JCK Review and draft edits and corrections to response to

Defendant's motion for summary judgment.

1.40 $315.00

04/22/2015 JCK Review and draft edits and corrections to response to

Defendant's motion for summary judgment.

0.90 $202.50

04/22/2015 MJO Meeting with Attorneys K. Dolley and Q. Osborne, re: revisions

to make to Plaintiff's Responses to Defendant's Statement of

Uncontroverted Facts

0.70 $192.50

04/22/2015 MJO Draft revisions to Statement of Additional Facts, re: conduct

extensive cite check of citations to record in Statement of

Additional Facts as well as Response to Defendant's Statement

of Facts; revise Exhibit List and Statement of Additional Facts

accordingly

3.00 $825.00

04/22/2015 MJO Draft/review Plaintiff's Response to Defendant's Statement of

Undisputed Material Facts, re: review additions made to the

Response by Attorney Q. Osborne

1.80 $495.00

04/22/2015 MJO Review, analyze, examine exhibits 1-34 attached to Plaintiff's

Response in Opposition to Summary Judgment

0.80 $220.00

04/22/2015 MJO Final review Plaintiff's Statement of Additional and

Controverted Facts in Support of Plaintiff's Response in

Opposition to Defendant's Motion for Summary Judgment and

Plaintiff's Response to Defendant's Statement of

Uncontroverted Facts

3.70 $1,017.50

04/23/2015 MJO Draft email to local counsel, re: courtesy copy binders for

Response to Summary Judgment

0.20 $55.00

04/27/2015 QMO Speak with potential Georgia (GA) Transcend Plaintiff Cleo

Diane Joyner. Ask her initial and additional questions; draft

and send representation agreement; add to excel sheet.

0.40 $90.00

04/28/2015 QMO Research rules for central district of California for filing of

California Complaints; read all requirements for complaints

filed there; figured out where we should file lawsuits; research

how to file complaint in central district of California.

1.70 $382.50

04/28/2015 QMO Put California full-time and part-time complaints in proper

California format; made spacing correspond with the 28 lines

on the side; tried to make cover page look like Hernandez

cover page.

2.30 $517.50

04/28/2015 QMO Talk with Attorney M. Obermeyer about finding local counsel

in California; attend conversation with California attorney;

search for attorneys.

1.30 $292.50

04/28/2015 QMO Insert California state law specific claims in full-time

complaint; include Counts III­V; add California claim specific

facts.

1.90 $427.50

04/28/2015 QMO Draft summons and civil filing sheet for California full-time

plaintiffs.

0.60 $135.00

04/28/2015 QMO Draft summons and civil filing sheet for California part-time 0.70 $157.50
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04/29/2015 QMO

plaintiffs.

Call law firms in Los Angeles; work of NELa and NELA 2.30 $517.50

California affiliate list; seek to hire them as local counsel.

04/29/2015 QMO Respond to email from Renee Demmery; look up her

information; give her update on case.

0.20 $45.00

04/29/2015 QMO Give case update to Barbara Vaughn; ask her a few questions

about her particular situation; report in excel sheet.

0.40 $90.00

04/29/2015 QMO Continue to draft part-time California complaint; add in statespecific counts regarding California $8.00 minimum wage;

add in specific facts about Plaintiffs regarding California

minimum wage.

1.60 $360.00

04/30/2015 QMO Keep calling attorneys in L.A. to try to find local counsel for

the Transcend California lawsuits; receive one call from firm

and he will call back tomorrow.

2.10 $472.50

04/30/2015 QMO Respond to Theresa Cosentino's email about supervisor's

knowing when they work.

0.20 $45.00

05/01/2015 QMO Correspond with California local counsel Sam Cleaver about

local counsel agreement and save into California folder.

0.30 $67.50

05/05/2015 QMO Call California attorneys to find opposing counsel; find and

talk to Attorney David Yeremian who may be interested; also

talked to Edwin who may be interested.

0.70 $157.50

05/06/2015 QMO Email Attorney M. Obermeyer regarding local counsel for both

California cases.

0.40 $90.00

05/06/2015 QMO Exchange emails with Linda Carucci about update on

Transcend Lawsuit.

0.30 $67.50

05/11/2015 QMO Speak to Julie Wright on the phone and provide her with

update on the Transcend case.

0.30 $67.50

05/12/2015 QMO Edit Florida full-time complaint of individuals who were not

specifically told to change time; update with new format that

we used in California complaints.

1.40 $315.00

05/12/2015 QMO Obtain all documents for Florida plaintiff Kevin P. Cartwright,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; talk with Kevin and confirm all information.

1.40 $315.00

05/12/2015 QMO Obtain all documents for Florida plaintiff Francine Gorskie,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; speak with her and confirmed information.

1.20 $270.00

05/12/2015 QMO Obtain all documents for Florida plaintiff Linda Kalbac,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; leave message for her and send email.

1.60 $360.00

05/13/2015 QMO Obtain all documents for Florida plaintiff Barbara Keenan,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; speak to her on phone and confirm information.

0.80 $180.00

05/13/2015 QMO Obtain all documents for Florida plaintiff Gail Riley, including

payroll documents, excel pay sheets, timesaver records,

emails, and any other individual documentation and save to

folder; call client and attempt to confirm all information;

speak with her on phone to confirm information; send followup phone call.

1.20 $270.00

05/13/2015 QMO Obtain all documents for Florida plaintiff Lynn E. Rogers,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; left message and sent email.

1.30 $292.50

05/13/2015 QMO Obtain all documents for Florida plaintiff Deborah Waldman, 1.20 $270.00
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including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; speak with Deborah on the phone; update her

excel sheet.

05/13/2015 QMO Go through California full-time complaint where they were not

specifically told to change timesaver hours; added in specific

facts regarding Kevin Cartwright, Francine Gorskie, Linda

Kalbac, Barbara Keenan, Gail A. Riley, Lynn Rogers, and

Deborah Waldman.

2.30 $517.50

05/14/2015 QMO Obtain all documents for Florida plaintiff Darcy Wingler,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; left Darcy an email and phone message.

1.10 $247.50

05/14/2015 QMO Obtain all documents for Florida plaintiff Sherry Wilson,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; spoke with Sherry and updated excel sheet.

1.30 $292.50

05/14/2015 QMO Obtain all documents for Florida plaintiff Sarena Marques,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; talk to attorney M. Obermeyer whether we wand

to include her due to being team lead.

1.40 $315.00

05/14/2015 QMO Obtain all documents for Florida plaintiff Renee Demmery,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; speak to Renee on the phone; update her excel

sheet.

1.30 $292.50

05/14/2015 QMO Edit Florida full-time complaint where they were specifically

instructed to change timesheets; added specific information

about Darcy Wingler, Sherry Wilson, Sarena Marques, and

Renee Demmery.

2.60 $585.00

05/14/2015 QMO Obtain all documents for Florida plaintiff Mindy Faieta,

including payroll documents, excel pay sheets, timesaver

records, emails, and any other individual documentation and

save to folder; call client and attempt to confirm all

information; learn she is no longer interested in lawsuit;

nonengage her.

0.60 $135.00

05/14/2015 QMO Send email to potential local counsel in Florida, David

Yeremian; include complaints and local counsel agreement.

0.40 $90.00

05/15/2015 QMO Call Darcy Wingler and send email to remind her about the

lawsuit; leave message.

0.20 $45.00

05/15/2015 QMO Speak with Florida client Rosemary Wood Langella about her

time at Transcend; update her information; update excel

sheet.

0.90 $202.50

05/15/2015 QMO Speak with Florida client Karen Goodrich about her time at

Transcend; update her information; update excel sheet.

1.30 $292.50

05/15/2015 QMO Speak with Florida client Judith Lugo about her time at

Transcend; update her information; update excel sheet.

1.30 $292.50

05/15/2015 QMO Finish drafting California part-time complaint with Plaintiffs

Karen Goodrich, Rosemary Wood Langella, Lori Smith, and

Judith Lugo; add specific dates they were not paid minimum

wage.

2.30 $517.50

05/18/2015 QMO Respond to email from Sherry Wilson about when she worked

at Transcend; documented email she sent me.

0.20 $45.00

05/18/2015 QMO Respond to email sent from Darcy Wingler about her interest

in lawsuit.

0.10 $22.50

05/18/2015 QMO Send email follow-up to potential Florida client Lori Smith; 0.20 $45.00
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05/18/2015 QMO

inform her she needs to contact me to be included in lawsuit.

Speak to Kathleen Wilcoxson on the phone; learn she is no 0.30 $67.50

longer interested in Transcend case; tell her she is free to

obtain alternative representation; send her nonengagement

email and add to nonengagement excel sheet.

05/18/2015 QMO Speak to Sheila Reeser on the phone; learn she is no longer

interested in Transcend case; tell her she is free to obtain

alternative representation; send her nonengagement email and

add to nonengagement excel sheet.

0.40 $90.00

05/18/2015 QMO Speak to Sarena Marques on the phone; discuss that we have

to nonengage because she was a team lead; tell her she is free

to obtain alternative representation; send her nonengagement

email and add to nonengagement excel sheet.

0.40 $90.00

05/18/2015 QMO Speak to Linda Kalbac on the phone; learn she is no longer

interested in Transcend case; tell her she is free to obtain

alternative representation; send her nonengagement email and

add to nonengagement excel sheet.

0.40 $90.00

05/19/2015 QMO Provide email update to client Diana Cannon-Iseminger. 0.20 $45.00

05/20/2015 QMO Send follow-up email to Darcy Wingler, Florida client; update

her excel sheet.

0.30 $67.50

05/20/2015 QMO Call potential local counsel David Yeremian in California; speak

with his associate; leave message for him.

0.40 $90.00

05/21/2015 QMO Nonengage Gail Riley because she declared bankruptcy too

close to when her claims were from.

0.40 $90.00

05/21/2015 QMO Attempt to find local counsel for Florida Plaintiffs; talk to

attorneys on the phone including Tamara Freeze; Robert

O'dell; Samuel Cleaver; Omid Nosrati, and Molly Durkin.

4.20 $945.00

05/21/2015 QMO Exchange emails with Sam Kleaver about potential counsel for

California cases.

0.40 $90.00

05/22/2015 QMO Nonengage all clients that have not returned their

representation agreements yet.

2.10 $472.50

05/22/2015 QMO Go through all Transcend excel sheets; find all Transcend

potential clients who have not returned the client

representation agreement back to us yet; move their

information to nonengage excel sheet.

1.80 $405.00

05/22/2015 QMO Call Sam Cleaver on the phone; speak with him about

potential local counsel relationship in California; draft local

counsel agreement for us to use with him; exchange emails

with him regarding local counsel agreement.

1.70 $382.50

05/22/2015 QMO Find physical addresses for all individuals whose email did not

work, including Lynn Hackaday, Karen Amelung, Rita Defino,

Karen Gland, Cheryl McAnich, Jamie Smith, and Cynthia

Swaim; drafted and sent nonengagement letters.

1.30 $292.50

05/25/2015 QMO Read email from potential California local counsel; add up

what he wants as total costs and change potential agreement

accordingly; write email to Attorney M. Obermeyer with

potential changes.

1.30 $292.50

05/26/2015 QMO Find Florida plaintiff Darcy Wingler's last pay check; find when

we filed her consent to join lawsuit; used date calculator to

find how many days her statute of limitations are tolled; using

this time, calculated how far back her statute of limitations is

currently at.

0.80 $180.00

05/26/2015 QMO Find Florida plaintiff Sherry Wilson's last pay check; find when

we filed her consent to join lawsuit; used date calculator to

find how many days her statute of limitations are tolled; using

this time, calculated how far back her statute of limitations is

currently at.

0.60 $135.00

05/26/2015 QMO Find Texas plaintiff Alice Elaine Gillespie's last pay check; find

when we filed her consent to join lawsuit; used date

calculator to find how many days her statute of limitations are

tolled; using this time, calculated how far back her statute of

limitations is currently at.

0.90 $202.50
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05/26/2015 QMO Find New York plaintiff Eileen Roff's last pay check; find when

we filed her consent to join lawsuit; used date calculator to

find how many days her statute of limitations are tolled; using

this time, calculated how far back her statute of limitations is

currently at.

0.80 $180.00

05/26/2015 QMO Find Washington plaintiff Linda Carucci's last pay check; find

when we filed her consent to join lawsuit; used date

calculator to find how many days her statute of limitations are

tolled; using this time, calculated how far back her statute of

limitations is currently at.

0.80 $180.00

05/26/2015 QMO Summarize situation for all individuals who are close to

running up on their statute of limitations; send detailed email

to Attorney M. Obermeyer; include information on Darcy

Wingler, Sherry Wilson, Alice Elaine Gillespie, Eileen Roff, and

Linda Carucci.

0.80 $180.00

05/26/2015 QMO Change California Complaints using the template sent by

potential California local counsel; change full time and part

time complaints.

0.90 $202.50

05/26/2015 QMO Find Judy Lindquist's documents and calendars she sent us a

while back; draft letter and email to Ms. Lindquist about

returning her documents; give documents to Barbara to mail

to Ms. Linquist; gather her documents saved online and send

her the documents through email.

1.80 $405.00

05/28/2015 QMO Discuss with Attorney M. Obermeyer how we will go with Sam

Cleaver as local counsel; change representation agreement to

account for initial retainer, different pro hac vice, and added

counsel; draft and send email to local counsel.

0.80 $180.00

05/28/2015 QMO Complete pro hac vice forms for California Group 1 plaintiffs

for Attorney K. Dolley.

0.60 $135.00

05/28/2015 QMO Complete pro hac vice forms for California Group 2 plaintiffs

for Attorney K. Dolley.

0.40 $90.00

05/28/2015 QMO Draft letter to Missouri Clerk of the Missouri Supreme Court

requesting for Certificate of Good Standing for Attorney K.

Dolley.

0.70 $157.50

05/29/2015 QMO Speak to local California counsel about representation

agreement; log the signed agreement in California folder.

0.40 $90.00

06/02/2015 QMO Speak to former client who I nonengaged from Florida Gail

Riley; told we nonengaged due to her bankruptcy; discussed

on phone.

0.40 $90.00

06/02/2015 MJO Meeting with Attorney Q. Osborne, re: individual lawsuits to

bring in Florida, Missouri, New York, and Texas

0.90 $247.50

07/09/2015 QMO Read through order denying Defendant's Motion for Summary

Judgment; discuss with Attorney M. Obermeyer.

0.40 $90.00

07/09/2015 QMO Call Theresa and let her know we prevailed on motion for

summary judgment and what comes next.

0.30 $67.50

07/09/2015 MJO Meeting with Attorney Q. Osborne, re: denial of Motion for

Summary Judgment

0.30 $82.50

07/10/2015 MJO Draft preservation letters for all clients in new Transcend

lawsuits

2.90 $797.50

07/16/2015 QMO Draft update for all Transcend cases for Attorney M.

Obermeyer's review; include details on all cases, issues, and

local counsels.

2.20 $495.00

07/22/2015 MJO Attempt calling oc, re: rescheduling status hearing in Chicago,

IL; check calendar for availability for alternate date for status

hearing

0.20 $55.00

07/22/2015 MJO Phone call with oc, re: rescheduling status hearing before

Judge Guzman set for Aug. 4

0.20 $55.00

08/14/2015 MJO Meeting with Attorney K. Dolley, re: potential trial dates 0.50 $137.50

08/18/2015 QMO Drive Attorney M. Obermeyer to airport. 0.50 $112.50

08/18/2015 MJO Prep for status hearing, re: gather all relevant documents 0.90 $247.50

08/18/2015 MJO Travel time to Chicago for purposes of attending status 3.00 $825.00
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08/19/2015 MJO

hearing before Judge Guzman

Participated in status hearing before Hon. Ronald Guzman, re: 0.50 $137.50

setting trial date

08/19/2015 MJO Travel time from Chicago to St. Louis after status hearing

before Judge Guzman

5.00 $1,375.00

08/19/2015 MJO Draft Response to email from co-counsel, re: trial setting 0.20 $55.00

08/24/2015 MJO Phone call with co-counsel, re: Motion to Withdraw 0.20 $55.00

12/09/2015 QMO Meet with Attorney M. Obermeyer and discuss initial

disclosures in the case.

0.20 $45.00

02/26/2016 QMO Create damage calculations for Theresa Cosentino's case; send

to Attorney K. Dolley.

0.80 $180.00

02/26/2016 QMO Discuss potentially settling case with opposing counsel and

Attorney K. Dolley.

0.30 $67.50

03/01/2016 QMO Speak with Attorney M. Obermeyer about Cosentino trial

preparation; discuss needing Kate Seday at trial.

0.40 $90.00

03/02/2016 MJO Draft emails to local counsel, re: availability for trial/pre-trial

work

0.30 $82.50

03/16/2016 MJO Draft Jury Instructions for purposes of trial preparation 1.70 $467.50

03/17/2016 JCK Confer with M. Obermeyer re: trial preparation; review

Plaintiff's response to Defendant's motion for summary

judgment; research N.D. Ill. local rules for filing trial briefs.

1.20 $270.00

03/17/2016 JCK Draft trial brief. 0.40 $90.00

03/17/2016 MJO Draft Jury Instructions 4.50 $1,237.50

03/17/2016 JCK Draft trial brief; review Plaintiff's declaration, statement of

additional facts, exemplar of trial brief, Court order denying

Defendant's motion for summary judgment.

2.90 $652.50

03/18/2016 QMO Speak with Greg Mersol about potentially settling Transcend;

discuss his settlement demand of $5,000 per MLS, and reason

for such demand.

0.60 $135.00

03/18/2016 MJO Review Trial Brief drafted by Attorney J. Keaney 1.00 $275.00

03/18/2016 MJO Draft Jury Instructions 1.50 $412.50

03/19/2016 QMO Send email to Kevin and Mark about Transcend's settlement

demand and reason behind it.

0.30 $67.50

03/21/2016 KJD Review and edit trial brief. 1.00 $450.00

03/21/2016 MJO Draft Jury Instructions and review file in preparation for trial 6.00 $1,650.00

03/21/2016 QMO Send email to opposing counsel about discussing settlement

of cases tomorrow; set up conference call.

0.30 $67.50

03/21/2016 MJO Draft email to attorney K. Dolley, re: Jury Instructions 0.20 $55.00

03/22/2016 KJD Review possible settlement. 0.20 $90.00

03/22/2016 QMO Draft proposed settlement demand email to opposing counsel;

include estimated calculation of attorneys' fees; discuss case

law as to attorneys' fees awards in similar cases.

1.10 $247.50

03/22/2016 QMO Speak with Attorney K. Dolley about changes to settlement

demand; implement changes; send to opposing counsel.

0.40 $90.00

03/22/2016 MJO Draft pre-trial materials, re: Agreed Statement of Contested

Issues of Fact and Law; Parties' Statement of Uncontested

Facts; Deposition Designations; began annotating, analyzing,

and examining potential exhibits

6.50 $1,787.50

03/23/2016 MJO Draft pre-trial materials, re: deposition designations, read

deposition transcripts of Catherine Dundas, Scott Robertson,

and Ann Burnham and drafted deposition designations

3.70 $1,017.50

03/24/2016 MJO Review, gather, analyze, and examine exhibits for purposes of

trial preparation

3.50 $962.50

03/24/2016 QMO Prepare settlement correspondence for Attorney K. Dolley;

implement his multiple revisions and corrections to settlement

correspondence; send to opposing counsel.

0.80 $180.00

03/24/2016 JCK Confer with K. Dolley re: settlement response. 0.10 $22.50

03/25/2016 MJO Phone calls with Dustin Dow, re: settlement of case 0.50 $137.50

03/25/2016 MJO Draft Notice of Settlement and file same with Court 0.50 $137.50

03/25/2016 JCK Confer with K. Dolley, J. Finkes re: settlement, counteroffer. 0.20 $45.00
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03/25/2016 KJD Review and edit draft "final settlement proposal, finalize

review settlement questions and conversations with opposing

counsel.

2.30 $1,035.00

03/25/2016 JCK Review and edit settlement e-mail stating counteroffer for K.

Dolley.

0.20 $45.00

03/25/2016 JCK Confer with K. Dolley, J. Finkes re: settlement offer,

counteroffer.

0.50 $112.50

03/25/2016 QMO Discuss status of settlement correspondence with Attorney K.

Dolley.

0.20 $45.00

03/25/2016 JCK Confer with K. Dolley re: settlement, counteroffers. 0.10 $22.50

03/25/2016 JCK Phone call with Q. Osborne re: settlement, notice of

mediation, deadline; review case management order for notice

of mediator deadline.

0.20 $45.00

03/29/2016 MJO Phone call with opposing counsel, re: status hearing before J.

Guzman

0.30 $82.50

03/30/2016 MJO Travel to Chicago from St. Louis for purposes of attending

hearing

4.50 $1,237.50

03/30/2016 MJO Travel from Chicago to St. Louis after attending hearing 4.50 $1,237.50

03/30/2016 MJO Meeting with attorney G. Mersol, re: consolidation of cases

and settlement

1.00 $275.00

03/30/2016 MJO Status hearing before J. Guzman 0.50 $137.50

03/31/2016 MJO Draft email to attorney K. Dolley, re: case update after March

30, 2016 hearing

0.50 $137.50

In Reference To: Consentino v. Transcend (Expenses)

05/11/2012 KJD Goldstien & McClintock LLLP $500.00 $500.00

05/11/2012 KJD Anthony Sciara $450.00 $450.00

08/30/2012 KJD St. Louis Post Office - Clayton Branch. $30.20 $30.20

09/11/2012 KJD City Service. $27.85 $27.85

09/11/2012 KJD Parking Terminal 2 - Super Park. $21.00 $21.00

09/11/2012 KJD Harry Carry's. $16.00 $16.00

09/11/2012 KJD Dunkin Donuts. $1.78 $1.78

09/14/2012 KJD St. Louis Post Office - Clayton Branch. $41.19 $41.19

09/23/2012 KJD Dunkin' Donuts $7.59 $7.59

09/23/2012 KJD Chili's- St. Lucie $7.59 $7.59

09/23/2012 KJD Subway Sandwiches & salads. $7.21 $7.21

09/23/2012 KJD Dollar Rent A Car $121.08 $121.08

09/24/2012 KJD Applebee's $25.61 $25.61

09/24/2012 KJD McDonald's $6.55 $6.55

09/24/2012 KJD RaceTrac 553 GAS $40.90 $40.90

09/24/2012 KJD Best Western Plus Downtown Stuart. $76.99 $76.99

09/24/2012 KJD LaQuinta Inn & Suites $72.15 $72.15

09/25/2012 KJD Hampton Inn $88.92 $88.92

09/25/2012 KJD Southwest Airlines $970.08 $970.08

09/25/2012 KJD Ruby chens Rstaurant $8.25 $8.25

09/27/2012 KJD Payment to Attorney Mark Koupal. $467.25 $467.25

09/27/2012 KJD Mileage Payment to Legal Assistant Meagan Johnson. $26.40 $26.40

10/01/2012 KJD Subway Sandwiches $7.50 $7.50

10/01/2012 KJD Dunkin' Donuts $6.29 $6.29

10/01/2012 KJD Thrifty Rental Car. $207.98 $207.98

10/01/2012 KJD Comfort inn $175.10 $175.10

10/01/2012 KJD Boston Market $8.68 $8.68

10/01/2012 KJD Southwest Airlines $327.60 $327.60

10/02/2012 KJD KFC $7.58 $7.58

10/03/2012 KJD Villa Fresh Italian Kitchen $8.67 $8.67

10/03/2012 KJD Shell gas station. $19.09 $19.09
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10/03/2012 KJD Boston Market #0250 $8.68 $8.68

10/03/2012 KJD Mileage Payment to Legal Assistant Meagan Johnson. $29.00 $29.00

10/03/2012 KJD Payment to Attorney Mark Koupal. $216.66 $216.66

10/06/2012 KJD Walmart $18.45 $18.45

10/07/2012 KJD Lambert International Airport. $21.00 $21.00

10/07/2012 KJD Murphy's Pub and Grill $6.79 $6.79

10/08/2012 KJD Murphy's Pub and Grill $22.56 $22.56

10/08/2012 KJD Lambert International Airport. $15.81 $15.81

10/08/2012 KJD Philly Teds Cheesesteak $6.79 $6.79

10/09/2012 KJD American Airlines Baggage Check. $25.00 $25.00

10/09/2012 KJD Hertz Rental Car $130.29 $130.29

10/09/2012 KJD Adoba Eco Hotel $197.14 $197.14

10/09/2012 KJD American Airlines Flight $1,165.20 $1,165.20

10/09/2012 KJD TGI Friday's $13.74 $13.74

10/11/2012 KJD Lambert International Airport- parking. $18.50 $18.50

10/11/2012 KJD Keagan's irish pub $20.00 $20.00

10/11/2012 KJD Dunkin' Donuts $8.53 $8.53

10/11/2012 KJD MArkey Fresh $9.49 $9.49

10/11/2012 KJD Villa Fresh Italian Kitchen $3.17 $3.17

10/11/2012 KJD Hertz Rental Car. $144.53 $144.53

10/11/2012 KJD Southwest Airlines. $584.20 $584.20

10/11/2012 KJD Payment to Attorney Mark Koupal. $493.84 $493.84

10/11/2012 KJD Payment to Attorney Mark Koupal. $372.10 $372.10

10/11/2012 KJD Goldstien & McClintock LLLP. $360.00 $360.00

10/12/2012 KJD Jersey Mike's Subs $13.58 $13.58

10/12/2012 KJD Taco Bell $10.47 $10.47

10/12/2012 KJD Chesapeake Bay Bridge - Tunnel $17.00 $17.00

10/12/2012 KJD Esquire. $970.37 $970.37

10/13/2012 KJD Gas $11.34 $11.34

10/13/2012 KJD Villa Fresh Italian Kitchen $9.95 $9.95

10/13/2012 KJD Panera Bread Cafe $7.49 $7.49

10/16/2012 KJD Cimo's South End Market and Deli. $6.81 $6.81

10/16/2012 KJD Cimo's South End Market and Deli. $3.48 $3.48

10/16/2012 KJD Hampton Inn. $292.12 $292.12

10/16/2012 KJD Hertz Rental Car. $91.81 $91.81

10/16/2012 KJD Southwest Airlines. $433.20 $433.20

10/16/2012 KJD Lambert International Parking Lot D. $32.50 $32.50

10/16/2012 KJD Dunkin Donuts. $8.53 $8.53

10/17/2012 KJD Milanos. $13.15 $13.15

10/17/2012 KJD Milanos. $7.71 $7.71

10/17/2012 KJD Milanos. $2.78 $2.78

10/17/2012 KJD Private Investigator Ecklund & Associates. $95.00 $95.00

10/18/2012 KJD Thirfty Car Rental. $168.71 $168.71

10/18/2012 KJD Quality Inn. $158.78 $158.78

10/18/2012 KJD Hertz Rental Car. $93.99 $93.99

10/18/2012 KJD Dunkin Donuts. $6.41 $6.41

10/18/2012 KJD McDonald's $9.47 $9.47

10/18/2012 KJD Taco Bell. $10.65 $10.65

10/19/2012 KJD Village Pizza. $24.33 $24.33

10/19/2012 KJD Village Pizza. $13.99 $13.99

10/19/2012 KJD Village Pizza. $3.70 $3.70

10/20/2012 KJD Shell Gas Station. $24.47 $24.47

10/20/2012 KJD Quiznos. $4.28 $4.28

10/20/2012 KJD Starbuck's coffee. $4.99 $4.99

10/20/2012 KJD Southwest Airlines. $185.80 $185.80

10/22/2012 KJD Alderson Reporting Company, Inc. $851.05 $851.05
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10/22/2012 KJD E-Z Pass - New Hampshire. $1.50 $1.50

10/22/2012 KJD E-Z Pass - New Hampshire. $1.50 $1.50

10/22/2012 KJD Attorney Payment - Mark Koupal. $685.57 $685.57

10/22/2012 KJD C.M. Court Reporting. $661.00 $661.00

10/23/2012 KJD Attorney Payment - Mark Koupal. $128.38 $128.38

10/24/2012 KJD Payment to NAncy C. LaBella - Official Court Reporter. $9.90 $9.90

11/02/2012 KJD Clayton Branch Post Office. $39.85 $39.85

11/15/2012 KJD Southwest Airlines. $279.60 $279.60

11/15/2012 KJD Globe Taxi. $40.00 $40.00

11/15/2012 KJD Lambert Parking. $20.00 $20.00

11/15/2012 KJD Dunkin Donuts. $1.76 $1.76

11/15/2012 KJD Globe Taxi. $40.00 $40.00

11/15/2012 KJD Taxi back to airport. $3.30 $3.30

11/16/2012 KJD NAncy Labella. $51.00 $51.00

12/03/2012 KJD Kathy Nicholis. $500.00 $500.00

12/10/2012 KJD LaQuinta Inn & Suites $98.05 $98.05

12/11/2012 KJD Hertz Rental Car $144.53 $144.53

02/01/2013 KJD National Court Reporters. $2,912.58 $2,912.58

05/01/2013 KJD Office Depot - Envelopes. $195.08 $195.08

05/01/2013 KJD Office Depot - Envelopes. $118.09 $118.09

05/08/2013 KJD Clayton Branch Post Office. $1,751.22 $1,751.22

05/20/2013 KJD Clayton Branch Post Office. $660.00 $660.00

05/21/2013 KJD Clayton Branch Post Office. $565.60 $565.60

05/21/2013 KJD Clayton Branch Post Office. $660.00 $660.00

07/22/2013 KJD Choice Taxi Association Inc. $95.00 $95.00

07/22/2013 KJD Super Park Termination 1. $20.00 $20.00

07/22/2013 KJD HMShost. $14.78 $14.78

07/22/2013 KJD Priceline - Flight to Chicago and back to St. Louis. $307.80 $307.80

08/19/2013 KJD Taxi back to hotel. $40.00 $40.00

08/19/2013 KJD Dunkin Donuts. $4.05 $4.05

08/19/2013 KJD Burger King. $8.01 $8.01

08/20/2013 KJD Harry Carey's. $21.49 $21.49

08/20/2013 KJD Southwest Airlines - Chicago. $293.80 $293.80

08/20/2013 KJD LaQuinta Inn & Suites. $285.89 $285.89

08/20/2013 KJD Taxi back to airport. $50.00 $50.00

09/07/2013 KJD Delta Airlines, to Atlanta, GA. $927.60 $927.60

09/07/2013 KJD The Westin Peachtree Plaza. $876.92 $876.92

10/29/2013 KJD Burger King Lambert. $15.30 $15.30

10/29/2013 KJD Cab fare from airport to hotel. $50.00 $50.00

10/29/2013 KJD Cab fare from airport to hotel. $50.00 $50.00

10/30/2013 KJD Cab fare from Mediation to airport. $50.00 $50.00

10/30/2013 KJD Cab fare from Mediation to airport. $50.00 $50.00

10/30/2013 KJD Westlin Peachtree Plaza. $5.18 $5.18

10/30/2013 KJD Flight transfer. $526.00 $526.00

11/14/2013 KJD Southwest Airlines to Chicago. $326.80 $326.80

11/20/2013 KJD Parking Super Park Terminal 2 St. Louis Airport $23.00 $23.00

11/20/2013 KJD Southwest Airlines. $490.70 $490.70

11/20/2013 KJD Taxi from airport to breakfast. $50.00 $50.00

11/20/2013 KJD Taxi from breakfast to court. $12.00 $12.00

11/20/2013 KJD Harry Carey's. $35.17 $35.17

11/20/2013 KJD Taxi from court to airport. $60.00 $60.00

11/20/2013 KJD Superpark Terminal 2. $23.00 $23.00

12/05/2013 KJD Deposition by Rogers and Hardin. $3,750.00 $3,750.00

12/05/2013 KJD Clayton Branch Post Office. $48.50 $48.50

12/05/2013 KJD Southwest Airlines to Chicago. $431.80 $431.80

12/06/2013 KJD Parking Super Park Terminal 2 St. Louis Airport. $20.00 $20.00

12/06/2013 KJD Cab fair from airport to court. $40.00 $40.00
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12/06/2013 KJD Cab fair from court to airport. $40.00 $40.00

12/06/2013 KJD Harry Carey's Chicago. $28.07 $28.07

12/16/2013 KJD Airport from St. Louis to Hartford to Chicago. $765.20 $765.20

12/16/2013 KJD Enterprise Car Rental 12-16 through 12-20. $361.54 $361.54

12/16/2013 KJD Chili's - St. Louis Airport. $13.80 $13.80

12/16/2013 KJD Uno Chicago Grill. $54.10 $54.10

12/17/2013 KJD Post Office - South Hadley, MA $19.95 $19.95

12/17/2013 KJD Dunkin Donuts. $2.24 $2.24

12/18/2013 KJD Pizza Days - Burlington. $28.37 $28.37

12/18/2013 KJD Dewey's Pizza. $24.06 $24.06

12/18/2013 KJD Candlewood Suites, Burlington, MA $106.10 $106.10

12/19/2013 KJD Jon and Mark Airfare to and from Chicago. $868.60 $868.60

12/19/2013 KJD Southwest airfare from Chicago to St. Louis. $199.90 $199.90

12/20/2013 KJD Dunkin Donuts. $4.29 $4.29

12/20/2013 KJD Harry Carey's Chicago Midway Airport. $12.71 $12.71

12/20/2013 KJD Illinois Bar and Grill. $49.35 $49.35

12/20/2013 KJD Cab from airport to deposition - Chicago. $50.00 $50.00

12/20/2013 KJD Cab from Lambert to Office. $31.20 $31.20

12/20/2013 KJD Hotel Sax in Chicago 12/19 - 12/20. $138.52 $138.52

12/20/2013 KJD Gas. $50.00 $50.00

12/20/2013 KJD Jensen Litigation Solutions - Deposition of Patricia Rapp. $429.12 $429.12

12/23/2013 KJD Bramanti & Lyons Court Reporting, Inc. $1,834.94 $1,834.94

12/30/2013 KJD Southwest Airfare to Chicago. $431.80 $431.80

12/30/2013 KJD Cab fare from airport to court. $40.00 $40.00

12/30/2013 KJD Cab fare from court to airport. $40.00 $40.00

12/30/2013 KJD Superpark terminal 2. $20.00 $20.00

12/30/2013 KJD Lambert Starbuck's. $2.62 $2.62

01/01/2014 KJD Beers of the World - Lambert Airport. $23.00 $23.00

01/01/2014 KJD Subway - Billings, Montana. $6.10 $6.10

01/01/2014 KJD Sleep Inn Billings, Montana. $264.09 $264.09

01/01/2014 KJD Enterprise Car Rental. $292.71 $292.71

01/02/2014 KJD Great Northn St. $22.50 $22.50

01/03/2014 KJD Conomart - Billings, Montana. $15.16 $15.16

01/03/2014 KJD Great Northern Hotel - Billings, Montana. $75.97 $75.97

01/04/2014 KJD Conomart - Billings, Montana. $22.75 $22.75

01/04/2014 KJD Cat Cora Kitchen Salt Lake City, Utah. $29.12 $29.12

01/04/2014 KJD Jamba Juice Denver, Colorado. $5.69 $5.69

01/04/2014 KJD Delta Flight from Billings to Salt Lake City. $538.50 $538.50

01/04/2014 KJD Southwest Flight from Salt Lake City to Denver to St. Louis. $480.00 $480.00

01/05/2014 KJD Airport Cab to Hilton Garden Inn, Baltimore, Maryland. $65.00 $65.00

01/05/2014 KJD Southwest flight from St. Louis to Baltimore. $340.00 $340.00

01/05/2014 KJD The Green Turtle Restaurant Owings Hill, Maryland. $11.11 $11.11

01/06/2014 KJD McDonalds Airport, Maryland. $6.77 $6.77

01/06/2014 KJD Hilton Garden Inn Owings Mills Marlyand $301.28 $301.28

01/06/2014 KJD Southwest Flight from Baltimore to Cleveland. $243.00 $243.00

01/06/2014 KJD Cab from airport to hotel. $35.00 $35.00

01/06/2014 KJD Hilton Garden Inn Cleveland, OH $167.76 $167.76

01/07/2014 KJD Enterprise Car Rental. $101.46 $101.46

01/07/2014 KJD Ramada Canton Ohio. $90.19 $90.19

01/07/2014 KJD Enterprise Car Rental Cleveland, OH $160.93 $160.93

01/08/2014 KJD Enterprise Car Rental - 1/8/14 - 1/10/14 Panama City, FL $325.33 $325.33

01/08/2014 KJD Fuel - Speedway Brook Park, OH $17.86 $17.86

01/08/2014 KJD Applebee's Neighborhood Grill & Bar - Panama City. $23.25 $23.25

01/08/2014 KJD Pappas Burger - Houston. $30.25 $30.25

01/08/2014 KJD United Airlines - First bag fee. $25.00 $25.00

01/09/2014 KJD I-75 Pizza & Gas - Ocala, FL. $4.56 $4.56
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01/09/2014 KJD Gas - Florida. $40.00 $40.00

01/10/2014 KJD Yellow Cab. $35.00 $35.00

01/10/2014 KJD Super Park Terminal 2 - Lambert Airport. $23.00 $23.00

01/10/2014 KJD Cab fare from Airport to Court. $40.00 $40.00

01/10/2014 KJD Harry Carey's. $31.38 $31.38

01/10/2014 KJD Southwest flight to Chicago. $432.00 $432.00

01/10/2014 KJD Southwest Flight from Tampa to St. Louis. $441.00 $441.00

01/10/2014 KJD Parking Garage - BOA Plaza. $16.00 $16.00

01/12/2014 KJD Southwest roundtrip Omaha, NE to St. Louis. $410.50 $410.50

01/12/2014 KJD Enterprise Omaha, NE $125.33 $125.33

01/13/2014 KJD Taco Bell North Platte NE $5.87 $5.87

01/13/2014 KJD Fuel - Anderson Food Shops Omaha, NE $24.86 $24.86

01/13/2014 KJD Fuel - Cenex South, NE $22.49 $22.49

01/14/2014 KJD Esquire - Deposition of Patsy Hayes on 12/27/13. $523.00 $523.00

01/14/2014 KJD Brazos Cattle Company. $23.26 $23.26

01/14/2014 KJD Great American Bagel - Lambert Airport. $5.77 $5.77

01/14/2014 KJD Car Rental from 1/14 - 1/15 - Houston TX. $205.84 $205.84

01/14/2014 KJD Southwest from St. Louis to Houston and Houston to St.

Louis.

$734.50 $734.50

01/14/2014 KJD Dewey's Pizza. $42.74 $42.74

01/15/2014 KJD Southwest flight to Tampa - Attorney M. Obermeyer. $871.00 $871.00

01/15/2014 KJD Southwest flight to Tampa - Attorney K. Dolley. $860.00 $860.00

01/15/2014 KJD Chili's Tampa Airport. $8.83 $8.83

01/15/2014 KJD Dollar Renta A Car - Tampa, FL. $221.90 $221.90

01/15/2014 KJD Office Depot - Tampa, Florida. $215.77 $215.77

01/15/2014 KJD Walgreens - Clearwater beach, Florida. $43.69 $43.69

01/15/2014 KJD Wifi for Southwest flight to Tampa. $8.00 $8.00

01/15/2014 KJD Shell Gas Station - Hankamer - TX $31.50 $31.50

01/16/2014 KJD Clayton Branch Post Office. $26.25 $26.25

01/16/2014 KJD Transcripts from 12/30/13 to 01/10/13 - Judge Rowland. $183.60 $183.60

01/16/2014 KJD Dunkin Donuts - Clearwater, FL. $8.36 $8.36

01/16/2014 KJD Hooters - Clearwater Beach, FL. $58.64 $58.64

01/16/2014 KJD CVS - Clearwater FL $17.43 $17.43

01/17/2014 KJD Court Transcripts from 1/10/14; 12/30/13; 11/4/13 - Pamela

Warren.

$183.60 $183.60

01/17/2014 KJD Dunkin Donuts. $8.57 $8.57

01/17/2014 KJD Clear Skky Beachside Cafe - Clearwater, FL $83.91 $83.91

01/17/2014 KJD Esquire - Deposition of Kathleen Schuster on 1/8/14. $360.96 $360.96

01/18/2014 KJD Union Burger - Clearwater, FL. $12.65 $12.65

01/18/2014 KJD French's Cafe - Clearwater, FL $65.01 $65.01

01/18/2014 KJD Dunkin Donuts - Clearwater, FL $4.90 $4.90

01/19/2014 KJD Dollar rent a car - Clearwater, FL $155.79 $155.79

01/19/2014 KJD BP - Clearwater, FL $9.54 $9.54

01/19/2014 KJD Super Park Lot C $28.50 $28.50

01/19/2014 KJD Dunkin Donuts - Lambert Airport. $2.27 $2.27

01/19/2014 KJD Wifi for Southwest Flight to St. Louis. $8.00 $8.00

01/19/2014 KJD Cozy Corner - Hotel 1/15 - 1/19. $753.02 $753.02

01/20/2014 KJD Deposition transcripts from D&D Reporting. $4,305.40 $4,305.40

01/21/2014 KJD Cab fare from Court to Airport. $40.00 $40.00

01/21/2014 KJD Cab fare from airport to Court. $40.00 $40.00

01/21/2014 KJD Super park Lambert Airport. $20.00 $20.00

01/21/2014 KJD Southwest Flight to Chicago. $432.00 $432.00

01/23/2014 KJD Lois Lacorte - Transcripts from 11/26 Proceedings. $57.60 $57.60

01/26/2014 KJD Uno's Pizza - Chicago. $11.36 $11.36

01/27/2014 KJD US Airways Carlotte, NC to Chicago. $306.50 $306.50

01/27/2014 KJD US Airways Luggage Fee. $60.00 $60.00

01/27/2014 KJD Sun Taxi - Airport to Hotel. $50.00 $50.00
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01/27/2014 KJD Allerton Hotel, Chicago. $54.26 $54.26

01/27/2014 KJD Allerton Hotel, Chicago. $100.75 $100.75

01/28/2014 KJD Market Creations - Chicago. $7.39 $7.39

01/28/2014 KJD Taxi Town - Court to Hotel. $15.00 $15.00

01/28/2014 KJD Taxi Town - Hotel to Airport. $40.00 $40.00

01/28/2014 KJD Manny's Delhi, Chicago. $8.64 $8.64

01/28/2014 KJD Southwest from Chicago to St. Louis. $216.00 $216.00

01/29/2014 KJD Esquire - Deposition of Darcy Wingler on 1/8/14. $941.80 $941.80

01/31/2014 KJD Professional Court Reporting and Video. $784.50 $784.50

02/04/2014 KJD Esquire - Deposition of Sarena Marques on 1/10/14. $1,093.63 $1,093.63

02/08/2014 KJD Esquire - Deposition of Diane Martin on 1/3/14. $1,115.50 $1,115.50

02/18/2014 KJD Esquire - Deposition of Margaret Thorpe on 1/15/14. $820.90 $820.90

03/24/2014 KJD Fed-ex courtesy copies to Robinson Sharpiro & Shwartz for

delivery to chambers.

$92.79 $92.79

05/09/2014 KJD Local Counsel, the Case Law Firm, LLC. $1,000.00 $1,000.00

11/01/2014 KJD Local Counsel, the Case Law Firm, LLC. $7.50 $7.50

11/04/2014 KJD Southwest Airlines - Chicago. $462.60 $462.60

11/05/2014 KJD USPS - Courtesy Copies to Judge's Chambers. $19.99 $19.99

11/07/2014 KJD Super Park Terminal 2. $20.00 $20.00

11/07/2014 KJD Dunkin Donuts - Lambert Airport. $5.09 $5.09

11/07/2014 KJD Harry Carey's Restaurant. $17.76 $17.76

11/07/2014 KJD Cab from airport to court. $40.00 $40.00

11/07/2014 KJD Cab from court to airport. $40.00 $40.00

12/01/2014 KJD The Case Law Firm (Local Counsel). $86.25 $86.25

12/23/2014 KJD USPS - Courtesy Copies to Judge's Chambers. $19.99 $19.99

05/01/2015 KJD Associate Counsel Fees $127.16 $127.16

05/28/2015 KJD Requesting an original certificate of good standing. $5.00 $5.00

06/02/2015 KJD Postage for returning documents to client. $17.90 $17.90

09/16/2015 KJD Invoice for The Case Law Firm. $316.25 $316.25

04/05/2016 MJO Travel to hearing. $115.57 $115.57

Total Hours: 3,806.10 hrs

Matters: $1,036,478.75

Expenses: $59,533.89

Total Amount: $1,096,012.64