PROPET USA, INC. v. LLOYD SHUGART

C06­0186MAT

EXHIBIT “F”

Hours Spent by Mr. Shugart's Counsel
1420 Fifth Avenue, Suite 2200

Seattle, WA 98101

Lloyd Shugart

Lloyd Shugart Photography / Studio 413

55 So. Atlantic

Seattle WA 98134

March 23, 2008

Invoice submitted to:

In Reference To:

Invoice #3008

Propet USA, Inc. v. Lloyd Shugart

PROFESSIONAL SERVICES:

Hours Amount

1/9/2007 PPM Telephone conferences with client regarding case and fee arrangement. 2.50 1,562.50

Draft contingent fee arrangement.

1/11/2007 PPM Telephone conference with J. Payne regarding substitution of counsel 1.30 812.50

and case history.

1/19/2007 PPM Review client file received from J. Payne. Telephone conference with 2.40 1,500.00

client regarding case facts.

1/31/2007 PPM Review case file. Telephone conference with client. Draft 0.80 500.00

correspondence to J. Phillips regarding discovery issues.

2/2/2007 PPM Review bankruptcy filed by L. Shugart. and correspondence by J. Phillips 0.50 312.50

regarding same. Telephone conference with client regarding same.

2/5/2007 PPM Draft and file Defendant's Motion for Partial Summary Judgment, 2.70 1,687.50

Declaration of L. Shugart and Proposed Order. Organize and assemble

exhibits for L. Shugart's Declaration. Telephone conferences with client

regarding same.

2/10/2007 PPM Review Plaintiff's Motion to Stay Deadlines. Telephone conference with 0.50 312.50

client regarding same.

2/14/2007 PPM Correspondence with J. Phillips regarding bankruptcy motion for relief 0.70 437.50

from stay and settlement. Telephone conference with client regarding

same and factual background.

2/15/2007 PPM Draft and file Defendant's opposition to Plaintiff's Motion to Stay 1.20 750.00

Deadlines. Telephone conferences with client regarding same.

2/22/2007 PPM Review Plaintiff's Reply in Support of its Motion to Stay Deadlines and 0.70 437.50

Court order regarding case scheduling. Conference with client regarding

same.

206-274-5100
Lloyd Shugart Page 2

Hours Amount

2/26/2007 PPM Review Plaintiff's Motion to Compel and supporting materials. Begin draft 0.50 312.50

of opposition to same.

3/5/2007 PPM Draft and file Defendant's Opposition to Plaintiff's Motion to Compel. 2.30 1,437.50

3/7/2007 EYD Review, assemble and organize case materials and documents. 2.00 300.00

3/9/2007 PPM Draft correspondence to J. Phillips regarding case scheduling. 0.20 125.00

3/12/2007 PPM Telephone conference with opposing counsel regarding case scheduling 0.20 125.00

and trial date.

EYD Review Plaintiff's Motion for Summary Judgment and supplemental briefs 2.20 330.00

filed in support. Conference regarding the same.

3/13/2007 PPM Review Plaintiff's reply in support of its Motion to Compel. Review 1.80 1,125.00

plaintiff's motion for summary judgment.

EYD Review Plaintiff's reply in support of its Motion to Compel. 0.10 15.00

3/14/2007 PPM Review and approve Joint Status Report for filing before the court. 0.20 125.00

3/16/2007 EYD Review Second Amended Scheduling Order. Docket deadlines and due 1.50 225.00

dates. Review court order regarding Plaintiff's Motion to Compel. 

Conference regarding same.

PPM Review Court's Order on Plaintiff's Motion to Compel. Conference 0.40 250.00

regarding same.

3/22/2007 EYD Telephone conference with court reporter at Seattle Deposition Reporters 3.50 525.00

regarding L. Shugart's deposition transcript. Review L. Shugart's

deposition transcript.

3/23/2007 PPM Review L. Shugart deposition transcript. Telephone conference with 3.40 2,125.00

client regarding same.

3/29/2007 PPM Telephone conference with client regarding copyright certificates. 0.60 375.00

Review same.

EYD Review and organize copyright registrations received from client. 0.40 60.00

3/30/2007 PPM Conference with J. Payne regarding status of case materials received 2.30 1,437.50

and declaration in opposition to plaintiff's motion for summary judgment. 

Draft J. Payne declaration. Conference regarding posture to responding

to motion.

3/31/2007 EYD Draft opposition to motion for summary judgment. Legal research 5.50 825.00

regarding same.
Lloyd Shugart Page 3

Hours Amount

4/1/2007 EYD Continue draft of defendant's opposition to plaintiff's motion for summary 7.00 1,050.00

judgment. Draft L. Shugart declaration in opposition.

4/2/2007 EYD Conferences with client regarding declaration in opposition to plaintiff's 7.50 1,125.00

motion for summary judgment. Edit and revise same. Review, finalize

and file opposition to motion for summary judgment and declarations of J.

Payne, and L. Shugart. Organize and assemble exhibits for declarations.

PPM Review and revise opposition to motion for summary judgment and 6.00 3,750.00

declaration of L. Shugart. Conferences with client regarding same.

4/3/2007 PPM Review Plaintiff's opposition to Defendant's Motion for Partial Summary 2.50 1,562.50

Judgment, B. Kaser's Declaration, and J. Phillips Declaration, and

supporting exhibits.

4/6/2007 PPM Draft reply in support of Motion for Partial Summary Judgment. File 0.80 500.00

same with the court.

4/10/2007 EYD Draft defendant's second discovery requests. Conference regarding 2.70 405.00

same.

PPM Review second requests for discovery. Conference and telephone 1.50 937.50

conference with client regarding same.

4/12/2007 EYD Review correspondence from client regarding discovery. Review 2.30 345.00

defendant's first discovery and responses to same, and historical

correspondence regarding same. Continue drafting defendant's second

discovery requests regarding same.

4/13/2007 EYD Review Plaintiff's First Requests for Production and Interrogatories. 4.50 675.00

Format and begin answering same. Correspondence with client

regarding discovery. Review information and documents received from

client. Finalize and propound defendant's second discovery requests.

PPM Review and edit defendant's second discovery requests. Telephone 1.90 1,187.50

conference with client regarding same.

4/16/2007 EYD Legal research and review of case law regarding damages. Review 2.60 390.00

client documents and correspondence with client regarding same.

4/17/2007 EYD Review client documents and L. Shugart's comments regarding discovery 5.70 855.00

responses. Bates-label and organize same for production. Review and

finalize discovery responses.

PPM Review client documents to be produced. Revise and edit defendant's 3.60 2,250.00

response to discovery requests. Telephone conference with client

regarding same. Draft correspondence to J. Phillips regarding same.
Lloyd Shugart Page 4

Hours Amount

4/18/2007 EYD Continue review of client documents for responsiveness. Conference 2.40 360.00

regarding same.

4/19/2007 EYD Review, Bates-label, and organize documents for supplemental 4.20 630.00

production.

PPM Review supplemental documents for production. Draft letter to J. Phillips 2.20 1,375.00

regarding same.

5/3/2007 PPM Review court's order regarding summary judgments. Telephone 0.40 250.00

conference with client regarding same.

5/7/2007 EYD Review and organize client documents. Create privilege log regarding 3.60 540.00

documents withheld as privileged.

PPM Review privilege log and draft correspondence to J. Phillips regarding the 1.00 625.00

same.

5/8/2007 EYD Review correspondence from client. Conduct legal research on 0.50 75.00

applicable case law.

5/14/2007 EYD Review plaintiffs response to second request for production and 0.50 75.00

interrogatories. Conference regarding same.

PPM Review plaintiff's response to defendant's second requests for production 0.30 187.50

and interrogatories. Conference and telephone conference with client

regarding same.

5/15/2007 EYD Correspondence with client regarding discovery issues and plaintiff's 0.10 15.00

response to defendant's second discovery requests.

5/16/2007 EYD Draft defendant's motion to compel. Conference regarding same. 0.80 120.00

5/17/2007 EYD Review, format and electronically file defendant's motion to compel. 0.20 30.00

Conference regarding same.

PPM Review, edit and finalize defendant's motion to compel. Conference 0.20 125.00

regarding same.

5/20/2007 EYD Review plaintiff's response to defendant's motion to compel and 0.70 105.00

supplemental documents filed in support.

5/21/2007 EYD Review case law and correspondences to client regarding sub-license 0.60 90.00

agreements.

5/29/2007 PPM Review plaintiff's filing in response to defendant's motion to compel. 0.20 125.00

5/31/2007 EYD Organize and assemble materials per client's request. Correspondence 0.10 15.00

regarding same.
Lloyd Shugart Page 5

Hours Amount

5/31/2007 PPM Draft Correspondence to J. Phillips regarding inspection of documents. 1.20 750.00

Conference regarding the same.

6/1/2007 PPM Draft defendant's reply in support of motion to compel. 0.50 312.50

EYD Review, finalize and file defendant's reply in support of his motion to 0.40 60.00

compel.

6/4/2007 EYD Correspondence with client regarding damages. Conduct legal research 1.00 150.00

regarding same.

6/7/2007 EYD Conduct legal research for summary judgment brief. 2.60 390.00

6/11/2007 EYD Review court's order on defendant's motion to compel. 0.10 15.00

PPM Review court's order on defendant's motion to compel. 0.10 62.50

6/12/2007 EYD Conduct legal research regarding exclusive licenses. Review invoices 3.80 570.00

provided in plaintiff's and defendant's initial disclosures. Compile and

create spreadsheet regarding invoices submitted to plaintiffs.

6/15/2007 EYD Conduct legal research regarding click/shrink-wrap agreements. 2.00 300.00

Conference regarding same.

PPM Conference regarding relevant case law and strategic posture of case. 0.10 62.50

6/16/2007 EYD Draft defendant's motion for summary judgment. 1.50 225.00

6/18/2007 PPM Review and revise defendant's motion for summary judgment for filing. 2.30 1,437.50

EYD Finalize and file defendant's motion for summary judgment. Review 2.60 390.00

plaintiff's motion for summary judgment.

6/19/2007 EYD Review plaintiff's motion for summary judgment. Conferences regarding 1.30 195.00

same.

PPM Review plaintiff's motion for summary judgment. Conference with client 1.50 937.50

regarding same.

7/5/2007 EYD Draft defendant's response to plaintiff's motion for summary judgment. 1.70 255.00

7/6/2007 EYD Email correspondences with with client regarding response to plaintiff's 3.10 465.00

motion for summary judgment. Continue drafting responsive brief. 

Review client's declaration for same.

7/9/2007 PPM Review and revise defendant's response to plaintiff's motion for summary 3.60 2,250.00

judgment. Telephone conference with client regarding same.
Lloyd Shugart Page 6

Hours Amount

7/9/2007 EYD Review, finalize and file defendant's response to plaintiff's motion for 2.10 315.00

summary judgment. Organize exhibits for same.

7/10/2007 EYD Review plaintiff's response to defendant's motion for summary judgment 0.30 45.00

and declaration filed in support.

7/13/2007 PPM Review plaintiff's response to motion for summary judgment. Draft reply 3.50 2,187.50

in support of motion for summary judgment.

EYD Finalize and file defendant's reply in support of summary judgment. 2.50 375.00

Review plaintiff's reply in support of its motion for summary judgment.

8/3/2007 PPM Telephone conferences with client regarding settlement and mediation. 1.50 937.50

Draft correspondences to J. Phillips regarding L. Shugart's settlement

demand and mediation issues.

8/15/2007 PPM Review plaintiff's pretrial statement. Conference regarding same. 0.20 125.00

EYD Review plaintiff's pretrial statement. Conference regarding same. 0.30 45.00

8/17/2007 EYD Telephone conference with Heffner Management. Subsequent telephone 0.10 15.00

conference with E. Loch (model with Heffner Management).

8/20/2007 EYD Organize, assemble and prepare exhibits for defendant's pretrial 4.30 645.00

statement. Begin draft of defendant's pretrial statement.

8/21/2007 EYD Review court's order regarding summary judgment motions and 0.70 105.00

requesting additional briefing. Conference and correspondence to client

regarding same.

PPM Review court's order on summary judgments. Conference regarding 0.20 125.00

same.

8/22/2007 EYD Draft defendant's motions in limine. Conference regarding same. 2.30 345.00

PPM Conference regarding defendant's motions in limine and motion to realign 0.10 62.50

the parties.

8/23/2007 PPM Review and finalize defendant's pretrial statement. Conference regarding 0.30 187.50

same.

EYD Review defendant's pretrial statement and exhibits included. Draft 4.60 690.00

motion to proceed first and continue draft of defendant's motions in

limine. Conference regarding same.

8/24/2007 PPM Review, edit and finalize defendant's motion to proceed first and motions 2.00 1,250.00

in limine.
Lloyd Shugart Page 7

Hours Amount

8/24/2007 EYD Review and file defendant's motion to proceed first and motions in limine. 0.60 90.00

8/26/2007 EYD Review plaintiff's motion in limine. Conference regarding same. 0.10 15.00

PPM Conference regarding plaintiff's motion in limine and posture for 0.10 62.50

responding to same.

8/28/2007 EYD Telephone conference with court clerk regarding rescheduling the 2.10 315.00

pre-trial conference. Draft and file stipulation and proposed order to reset

pretrial conference date. Conference regarding same.

PPM Correspondence with J. Phillips to reset date of pre-trial conference. 0.20 125.00

Review and finalize stipulation to be filed before the court.

8/30/2007 PPM Telephone conferences regarding mediation issues. Review 2.40 1,500.00

correspondence from J. Smith regarding mediation.

JW Review and draft notice of appearance. Conference regarding same. 5.60 2,520.00

Review plaintiff's supplemental brief for summary judgment. Legal

research for opposition brief.

EYD Draft and file notice of appearance for J. Whitaker. Conference regarding 0.80 120.00

same.

8/31/2007 PPM Draft and file supplemental status report on mediation. Review plaintiff's 3.20 2,000.00

supplemental status report and supplemental brief on its motion for

summary judgment. Conference regarding same.

EYD Review supplemental status report and plaintiff's brief regarding its 0.80 120.00

motion for summary judgment. Conference regarding same.

JW Begin draft supplemental brief in opposition to plaintiff's motion for 5.50 2,475.00

summary judgment. Legal research and conferences regarding same.

9/1/2007 EYD Legal research to respond to plaintiff's motion in limine. Conferences 2.00 300.00

regarding same.

9/2/2007 PPM Draft response to plaintiff's motion in limine. 2.30 1,437.50

JW Legal research in support of opposition to plaintiff's motion for summary 2.10 945.00

judgment.

9/3/2007 JW Continue draft of supplemental brief in response to summary judgment. 4.60 2,070.00

Conferences regarding same.

9/4/2007 JW Legal research and continue draft of supplemental brief in opposition to 5.60 2,520.00

motion for summary judgment.
Lloyd Shugart Page 8

Hours Amount

9/5/2007 EYD Meet with opposing counsel to review trial exhibits. 0.50 75.00

9/7/2007 PPM Telephone conference with Chambers and Counsels regarding 5.60 3,500.00

mediation. Conferences regarding next steps and preparation for

settlement conference. Review and edit reply in support of of defendant's

motions in limine. Review and revise response to plaintiff's supplemental

brief in support of its motion in limine.

EYD Draft, and file defendant's reply in support of motions in limine. Review, 6.70 1,005.00

edit and file brief in response to plaintiff's supplemental brief in support of

its motion for summary judgment. Conferences regarding same.

JW Finalize draft of supplemental opposition brief to plaintiff's motion for 5.30 2,385.00

summary judgment. Conference regarding same.

9/10/2007 PPM Begin draft of settlement submission to Judge Glover. Telephone 1.40 875.00

conference with client regarding same.

9/11/2007 PPM Finalize mediation submission to Judge Glover. Conference regarding 1.20 750.00

same.

EYD Review mediation letter to Judge Glover. Telephone conference with 0.80 120.00

Judge Glover's court regarding same.

JW Review mediation letter to Judge Glover. Conference regarding 1.60 720.00

settlement strategy.

9/12/2007 PPM Attend pre-trial conference. Conference regarding case strategy. 2.50 1,562.50

JW Attend pre-trial conference. Conferences regarding case strategy and 3.00 1,350.00

next steps.

9/15/2007 EYD Review proposed jury instructions, edit and revise same with defendant's 7.50 1,125.00

proposed jury instructions. Review model jury instructions.

JW Draft defendant's trial brief. Legal research and conferences regarding 7.00 3,150.00

same.

PPM Review and edit draft of defendant's trial brief. Conferences regarding 4.00 2,500.00

the same.

9/16/2007 JW Continue draft and legal research for defendant's trial brief. Conferences 5.00 2,250.00

regarding same.

PPM Review and conferences regarding defendant's trial brief. 1.20 750.00

EYD Revise and finalize defendant's proposed jury instructions. Draft 7.50 1,125.00

supplemental brief regarding damages. Conferences regarding same.
Lloyd Shugart Page 9

Hours Amount

9/17/2007 JW Finalize defendant's trial brief. Draft supplemental brief regarding 8.60 3,870.00

jurisdiction. Review and revise supplemental brief on damages. Legal

research and conferences regarding same.

EYD Review, format and file defendant's trial brief, supplemental brief on 6.50 975.00

jurisdiction and damages. Legal research and conferences regarding

same. Telephone conference with court clerk regarding delivery to

physical exhibits. Organize and assemble Judge's notebook and extra

copy of trial exhibits for delivery to the Court.

9/18/2007 JW Review plaintiff's trial brief and supplemental brief on jurisdiction and 2.40 1,080.00

damages. Legal research and conference regarding same.

EYD Organize physical trial exhibits and label same. Meet with B. Kaser and 6.30 945.00

J. Phillips to review physical exhibits. Organize and delivery of same to

the Court. Review plaintiff's trial brief and supplemental brief on

jurisdiction and damages. Conferences regarding same.

9/19/2007 EYD Review court order regarding plaintiff's motion for summary judgment and 1.20 180.00

order on motions in limine. Conference regarding same.

JW Review courts orders. Conference regarding same. 1.30 585.00

9/20/2007 EYD Review courts order regarding jury instructions. Conduct legal research 4.00 600.00

for same. Draft supplemental jury instructions. Conference regarding

same and case strategy.

JW Conferences regarding case strategy and presentation of case. 7.60 3,420.00

PPM Conferences regarding trial and case preparation. 6.70 4,187.50

9/21/2007 EYD File supplemental jury instruction. Conference with client regarding trial. 4.50 675.00

JW Review and finalize supplemental jury instructions. Conference with 7.30 3,285.00

client regarding trial and strategy for same.

PPM Conference with client regarding case strategy. Prepare for trial. 7.30 4,562.50

9/23/2007 PPM Outline and prepare for trial. Conferences with client. 10.00 6,250.00

JW Prepare for trial and strategy for presentation of case. Conferences with 10.00 4,500.00

client.

EYD Organize and arrange materials in preparation for trial. Create trial 10.00 1,500.00

notebooks. Conferences with client to prepare for trial

9/24/2007 PPM Conduct trial. Prepare for trial continuation. 10.50 6,562.50
Lloyd Shugart Page 10

Hours Amount

9/24/2007 JW Attend trial. Prepare case for continuation of trial. 10.50 4,725.00

EYD Attend trial. Prepare for continuation of trial 10.50 1,575.00

9/25/2007 PPM Attend and conduct trial. Conferences and preparation of case. Legal 8.50 5,312.50

research regarding damages.

JW Attend trial. Prepare case and conferences regarding case strategy. 16.40 7,380.00

Conduct legal research regarding damages election, double recovery,

and extraterritorial jury instructions as directed by the court. Draft

memorandum to the court regarding same.

EYD Attend trial. Prepare case and strategy. Review final draft of jury 11.60 1,740.00

instructions, and verdict form. Conference regarding same. Legal

research regarding damage election and extraterritorial instruction.

9/26/2007 PPM Attend and prepare for trial. Conferences regarding same. 8.40 5,250.00

JW Prepare and attend trial. Conferences regarding same. 8.40 3,780.00

EYD Attend and prepare for trial. Conferences regarding same. 8.40 1,260.00

9/27/2007 PPM Appear at court to address jury questions and appear for verdict. 4.20 2,625.00

Conferences with client regarding same.

JW Court appearance to address jury question. Appear for jury verdict. 4.20 1,890.00

Conferences with client regarding same and next steps.

EYD Appear at court for jury verdict. Conferences with client and next steps. 3.60 540.00

10/4/2007 JW Review plaintiff's motion for remittitur and equitable defenses. 2.20 990.00

10/5/2007 JW Legal research regarding plaintiff's motion for remittitur and equitable 3.70 1,665.00

defenses. Conferences regarding same.

PPM Review plaintiff's motion for remittitur and equitable defenses. Legal 2.40 1,500.00

research and conferences regarding same.

10/9/2007 JW Review plaintiff's supplemental motion for remittitur provided with 3.40 1,530.00

attachments, and notice of lien. Draft and file brief in response and

conferences regarding same.

PPM Review plaintiff's motion for remittitur and attachments, and lien notice. 2.00 1,250.00

Conferences regarding opposition.

10/10/2007 PPM Draft motion for permanent injunction. Conference regarding same. 3.50 2,187.50

Prepare for oral argument on motion for remitter.
Lloyd Shugart Page 11

Hours Amount

10/10/2007 EYD Review and file motion for permanent injunction. Draft proposed order 2.00 300.00

and conference regarding same.

JW Prepare for hearing on Propet's motion for remitter and equitable 2.50 1,125.00

defenses.

10/11/2007 JW Attend Court hearing on motion for remitter and equitable defenses. 3.00 1,350.00

Conference regarding same.

PPM Attend and provide oral argument in opposition to motion for remitter and 3.20 2,000.00

equitable defenses. Conference regarding same.

10/17/2007 PPM Review Propet's Motion for New Trial and Renewed Motion for Judgment 2.60 1,625.00

as a Matter of Law. Conference regarding same.

JW Review and conference regarding Propet's motion for a new trial and 2.20 990.00

judgment as a matter of law.

10/23/2007 JW Review Propet's response to Shugart's motion for a permanent 1.30 585.00

injunction. Conferences regarding same and election of damages.

PPM Review's response to motion for permanent injunction. Conferences 1.50 937.50

regarding same and damages election.

10/24/2007 JW Review court's order on motion for remitter. 0.50 225.00

10/25/2007 JW Begin draft reply in support of motion for permanent injunction. 2.70 1,215.00

Conference regarding same.

PPM Conference regarding Shugart's motion for permanent injunction. 0.70 437.50

10/26/2007 JW Finalize and file reply in support of motion for permanent injunction. 2.50 1,125.00

PPM Review and finalize reply brief in support of motion for permanent 1.00 625.00

injunction.

10/27/2007 JW Legal research and begin draft of response to motion for new trial and 4.20 1,890.00

JNOV.

10/28/2007 JW Continue draft of response to motion for new trial. 2.50 1,125.00

10/29/2007 JW Finalize and file response to Propet's motion for new trial and JNOV. 5.50 2,475.00

Conferences regarding same.

PPM Review, draft and finalize response to motion for new trial and judgment 4.00 2,500.00

as a matter of law. Conferences regarding same.

10/30/2007 JW Review Propet's Surreply to Shugart's motion for permanent injunction. 0.30 135.00

Conference regarding same.
Lloyd Shugart Page 12

Hours Amount

10/30/2007 PPM Conference regarding Propet's surreply on motion for permanent 0.20 125.00

injunction.

11/5/2007 JW Review Propet's reply in support of its motion for new trial and JNOV. 0.80 360.00

PPM Review reply filed by Propet in support of a new trial and judgment as a 0.60 375.00

matter of law.

11/16/2007 JW Review Plaintiff's Motion for a Protective Order. Conferences regarding 2.00 900.00

the same.

EYD Review and conferences regarding Propet's Motion for Protective Order. 0.60 90.00

PPM Conferences regarding Propet's motion for a protective order. 1.00 625.00

11/26/2007 JW Draft, finalize and file Shugart's response to Propet's protective order. 4.60 2,070.00

PPM Revise and review draft response to Propet's Motion for a Protective 2.40 1,500.00

Order.

11/29/2007 JW Review Propet's reply in support of its motion for a protective order. 3.00 1,350.00

Begin draft of surreply. Conference regarding same.

PPM Review Propet's reply in support of motion for protective order and 2.00 1,250.00

conferences regarding same.

11/30/2007 JW Finalize and file surreply in opposition to Propet's motion for protective 3.70 1,665.00

order. Conference regarding same.

PPM Review and conference regarding surreply to motion for protective order. 1.50 937.50

12/13/2007 JW Review court order on motion for new trial and JNOV, and order on 0.70 315.00

permanent injunction.

EYD Review court orders on motion for new trial, judgment as a matter of law, 0.20 30.00

and permanent injunction.

12/14/2007 JW Draft and file election of damages. Conference with client regarding 1.00 450.00

same.

12/21/2007 JW Review court order on temporary protective order. Conference with client 2.40 1,080.00

regarding same.

PPM Review order granting plaintiff's motion for a protective order. 2.25 1,406.25

Conference regarding same.

12/27/2007 JW Draft response to Court Order regarding proposed entry permanent 4.00 1,800.00

injunction.
Lloyd Shugart Page 13

Hours Amount

12/28/2007 JW Continue draft regarding entry of permanent injunction. 2.00 900.00

1/2/2008 JW Conferences regarding response to Court Order on entry of permanent 4.60 2,070.00

injunction. Finalize and file same with the Court.

PPM Review draft response regarding entry of permanent injunction. 2.50 1,562.50

Conferences regarding same.

1/14/2008 JW Review appeal notices and conference regarding same. 2.00 900.00

PPM Conference regarding appeal and next steps. 2.00 1,250.00

1/17/2008 JW Review Court Order on permanent injunction. Conference regarding 1.00 450.00

same.

PPM Review Court order and conference entering permanent injunction. 1.20 750.00

1/18/2008 PPM Conference regarding motion for attorneys fees. 1.00 625.00

JW Conference regarding motion for attorneys fees and legal research 3.00 1,350.00

regarding same.

1/24/2008 JW Review entry of judgment. Conference with client regarding same and 3.50 1,575.00

appellate proceedures.

PPM Review court's order entering judgment. Conference with client regarding 3.50 2,187.50

same and procedural next steps.

1/29/2008 JW Review Amendment to Appeal. Conference regarding same and motion 3.50 1,575.00

for fees. Legal research regarding fees motion.

PPM Conference regarding Amendment to Appeal and motion for fees. 1.50 937.50

1/31/2008 JW Draft L. Shugart's Motion for Attorneys fees. Legal research regarding 3.25 1,462.50

same. Review catalog materials submitted by Propet. Conference with

client regarding same.

PPM Review Propet's 2008 catalog materials. Telephone conference with 1.00 625.00

client regarding same.

2/1/2008 JW Continue draft of motion for fees. Legal research and conference 1.50 675.00

regarding same.

2/4/2008 JW Legal research regarding motion for attorneys fees. Conference 2.40 1,080.00

regarding same.

PPM Conference regarding motion for fees. Legal research regarding same. 1.20 750.00
Lloyd Shugart Page 14

Hours Amount

2/5/2008 JW Continue and review draft of L. Shugart's motion for attorneys fees. 2.00 900.00

Conference regarding same.

PPM Review and edit motion for attorneys fees and conference regarding 2.00 1,250.00

same.

2/6/2008 JW Review and finalize motion for attorneys fees. File same with the court. 2.75 1,237.50

Conference regarding same. Review Defendant's motion to stay.

PPM Review and revise motion for attorneys fee. Conference regarding same. 1.75 1,093.75

2/7/2008 PPM Review Propoet's motion to stay. Conference with client regarding same. 1.50 937.50

Conference regarding proposed order on motion for fees. Review and

revise same for filing.

EYD Draft and file proposed order on plaintiff's motion for attorneys' fees. 0.50 75.00

2/11/2008 JW Review transcript designation by defendant. Review file and conference 0.75 337.50

regarding testimony designation.

PPM Conference regarding testimony designation and transcript order. 0.50 312.50

2/13/2008 JW Meeting the client regarding Propet catalog materials. Review and 5.00 2,250.00

document same.

PPM Conference with client to discuss continued infringement in Propet's 2008 5.00 3,125.00

catalog.

2/19/2008 EYD Review Transcript Order, Notice of Transcript Designation, and Local 1.50 225.00

Rules regarding same. Telephone conference with legal assistant at

Talmadge Fitzpatrick PLLC regarding designation of testimony of L.

Shugart on 9/25/07. Conference regarding same.

PPM Conference regarding transcript designation of L. Shugart. 0.30 187.50

2/20/2008 JW Email correspondences with client regarding continued infringements. 3.50 1,575.00

Review Propet's response to Shugart's motion for attorneys fees. Draft

reply in support of motion for attorney's fees. Conference regarding

same.

PPM Review Propet's response to motion for fees. Conference regarding 1.50 937.50

same and reply briefing.

2/21/2008 JW Finalize documentation of Propet's continued infringements. Email B. 4.20 1,890.00

Kaser documentation of same. Conference regarding same. Finalize

and file reply in support of Shugart's motion for attorneys fees.

PPM Review reply in support of motion for fees. Conference regarding same. 1.00 625.00
Lloyd Shugart Page 15

Hours Amount

2/22/2008 JW Correspondence with B. Kaser regarding continued infringements. File 1.50 675.00

same with the Court. Conference and correspondence with client

regarding same.

PPM Review correspondence from B. Kaser. Conference regarding same. 0.60 375.00

2/26/2008 JW Email correspondences with B. Kaser regarding continued infringements. 1.20 540.00

Conferences and email correspondences with client regarding same.

PPM Conferences regarding Propet's continued infringements. 0.40 250.00

3/7/2008 JW Review Court order denying motion for fees. Conference regarding same. 1.50 675.00

PPM Conference regarding court's order on motion for fees. Conference 1.00 625.00

regarding same.

3/14/2008 JW Review B. Kaser's Declaration regarding Propet's continued 0.70 315.00

infringements.

For professional services rendered $260,455.00 632.75

EXPENSES:

4/30/2007 In-house photocopying expenses for April, 2007. 35.10

8/17/2007 Photocopying expenses incurred with Sound Legal Copy regarding trial exhibits. 33.81

9/10/2007 Conference room expense regarding attorney conference. 64.00

9/17/2007 Expenses for numbered tabs to create trial notebooks (Sound Legal Copy) 48.79

9/18/2007 Photocopying expenses regarding creation of trial exhibits notebook (Sound Legal Copy) 192.97

Photocopying expenses regarding creation of CDs relating to shoe images (Sound Legal 284.23

Copy)

9/23/2007 Lunch during preparation for trial. 24.70

9/25/2007 Lunch during trial. 25.27

10/18/2007 September 26, 2007 Trial Transcript (Nichole Rhynard). 159.36

Total expenses $868.23

Total amount of this bill $261,323.23
Lloyd Shugart Page 16

 Amount

Balance due $261,323.23
EXHIBIT "D"

TIME RECORDS OF CARNEY BADLEY