Luis P. Diaz, Esq.

 1118 Lombard St.

 Suite 5

 Philadelphia PA 19107

 Ph: 215 733-0293 Fax: 215 627-3183

 Invoice submitted to:

 David Sambolin Esq.

 3214 Hamilton Street

 Philadelphia PA 19104-2517

 May 10, 2004

 In Reference To:Maria Camacho IDEA Attorney's Fees

 Invoice #10253

 Professional services

 Hrs/Rate Amount

 9/1/03 Phone Call To and From 1.20 300.00

 Sambolin re background of 250.00/hr

 case, legal issues and status

 (hearing upcoming Thursday by

 conference call); discussion

 of history.

 9/2/03 Research on IDEA and 1.20 300.00

 Attorney's fees 250.00/hr

 Review documents Memo In 1.50 375.00

 Support of Plaintiffs Answer 250.00/hr

 to Motion and Exhibits, Answer

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 1 of 18
 To Motion

 Phone calls to and from 0.80 200.00

 Sambolin re case facts, 250.00/hr

 strategy and status.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 2 of 18
 David Sambolin Esq. Page 2

 Hrs/Rate Amount

 9/3/03 Devise strategy for 0.67 167.50

 substantive and procedural 250.00/hr

 arguments and court filings

 for 9/04/03 conference call.

 Review faxed documents 2.20 550.00

 (Complaint, Answer To 250.00/hr

 Plaintiffs Complaint, Defense

 Motion to Dismiss, Defendant

 Memorandum of Law In Support

 of Motion)

 Research standard of review 2.50 625.00

 for motion to dismiss in 3r 250.00/hr

 Circuit, appointment of

 magistrates and the policy

 issues behind award of

 attorney's fees.

 Meetings with Michael 1.50 375.00

 Churchill Esq., Barbara 250.00/hr

 Ransom, Esq., of Public

 Interest Law Center of Phila.

 re IDEA attorneys fees,

 negotiation vs. trial, J.

 Fullum's preferences and the

 elements of the Camacho claim

 for attorney's fees.

 Draft Entry of Appearance, 1.50 375.00

 Supplemental Answer, 250.00/hr

 Memorandum of Law Opposing

 Defendant Motion.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 3 of 18
 9/4/03 Continue Drafting Supplemental 3.00 750.00

 Answer, Memorandum of Law 250.00/hr

 Opposing Defendant Motion to

 Dismiss.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 4 of 18
 David Sambolin Esq. Page 3

 Hrs/Rate Amount

 9/4/03 Phone calls to and from Judge 0.40 100.00

 Fullum's clerk regarding 250.00/hr

 participation in conference

 call after entry of appearance

 and filling of Supplemental

 Answer and Motion and

 Memorandum of Law. Judge would

 allow participation but not in

 his chambers but at a phone in

 his reception area at a desk

 with a non-secure line OK.

 (Was not workable)

 9/5/03 Meeting with Sambolin re 0.50 125.00

 strategy, deadline of the 14th 250.00/hr

 and prevailing party issues.

 9/8/03 Meeting with Churchill re 0.50 125.00

 failure to appoint a 250.00/hr

 Magistrate vs Fullum handling

 it directly, strategy.

 9/9/03 Meeting with Churchill re 0.50 125.00

 community standard on attorney 250.00/hr

 hourly rate and CLS survey

 used and accepted in federal

 court. Comments re Catherine

 Carr.

 9/10/03 Research attorney fee cases 2.00 500.00

 and prevailing party. Pre ad 250.00/hr

 post John T.

 Draft letter to G. Hazeltine, 0.30 75.00

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 5 of 18
 Esq., School District 250.00/hr

 9/11/03 Phone call to Catrhy Carr re 0.40 100.00

 attorney fee survey and 250.00/hr

 web-site, arrange delivery.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 6 of 18
 David Sambolin Esq. Page 4

 Hrs/Rate Amount

 9/11/03 Research attorney fee cases 2.00 500.00

 and prevailing party. Pre and 250.00/hr

 post John T.

 Phone calls to and from 0.33 82.50

 Sambolin re John T. not really 250.00/hr

 applicable based on permanent

 relief won by him.

 9/12/03 Review CLS attorney fee 0.50 125.00

 results and Sambolin years out 250.00/hr

 of school and fees for 1997

 through 2002.

 Research FRCP for Scheduling 0.50 125.00

 Orders 250.00/hr

 Draft and file Motion for 3.00 750.00

 Scheduling Order, Memo, Order, 250.00/hr

 Certificate of Service

 9/14/03 Draft outline of Memo on 2.50 625.00

 Standard of proof for 250.00/hr

 prevailing party under IDEA in

 this case.

 Research issue of whether 2.00 500.00

 Administrative proceedings are 250.00/hr

 litigation and degree of

 change in legal relationship

 of Plaintiff. Compare John T

 and School Dist. Maine on

 quality of relief.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 7 of 18
 9/15/03 Phone Call To Judge Fullum's 0.30 75.00

 clerk re availability and 250.00/hr

 desirability of conference

 call on latest motion.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 8 of 18
 David Sambolin Esq. Page 5

 Hrs/Rate Amount

 9/16/03 Phone Calls To and from 0.30 75.00

 Sambolin re Amendment to hours 250.00/hr

 on fees, new address for

 Hazeltine

 Research and Meeting with 1.30 325.00

 Sambolin re additional hours, 250.00/hr

 history of the proceedings,

 statute of limitations on fees.

 9/18/03 Draft memo on Attorney fees 2.00 500.00

 250.00/hr

 9/19/03 Draft memo on Attorney fees 2.30 575.00

 250.00/hr

 Draft memo on Attorney fees 2.30 575.00

 250.00/hr

 9/23/03 Phone Call To and from 0.40 100.00

 Sambolin re amending hours. 250.00/hr

 Phone Calls To and from Court 1.00 250.00

 and Defendant Counsel and 250.00/hr

 phone company, re availability

 for Conference call on

 9/25/03, and from Sambolin re

 amending hours.

 Prepare for conference call, 2.50 625.00

 review pleadings, outstanding 250.00/hr

 motions, case law.

 9/24/03 Phone Calls To and from Phone 1.30 325.00

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 9 of 18
 Company, J.Fullum, C. Reginal 250.00/hr

 Johnson re conference call set

 for 2:30 PM on 9/25/03.

 Discussion with Johnson on

 status, new hours, and

 Parandini issue (separate

 attorney's fees for petition).

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 10 of 18
 David Sambolin Esq. Page 6

 Hrs/Rate Amount

 9/24/03 Phone Calls To and from 0.60 150.00

 Sambolin re conference call 250.00/hr

 and Summary Judgment.

 strategy, establish hours,

 amend, then rate, apprise

 judge of coming Rule 56

 Summary Judgment.

 Research issue of fee petition 2.50 625.00

 representation as part of 250.00/hr

 reasonable fee (Parandini and

 progeny).

 Research motion to amend. 2.00 500.00

 250.00/hr

 9/25/03 Draft Motion to Amend, Memo In 3.50 875.00

 Support, Order, service. 250.00/hr

 Research to Draft Motion for 1.50 375.00

 leave to file Rule 56 Summary 250.00/hr

 Judgment within specified time

 frame.

 Phone Calls To and from C. 1.20 300.00

 Reginal Johnson, Esq., re 250.00/hr

 stipulation and or not

 opposing motion for timing of

 Rule 56 Motion for Summary

 Judgment.

 9/26/03 Draft Motion for leave to file 3.70 925.00

 Rule 56 Summary Judgment 250.00/hr

 within specified time frame.

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 11 of 18
 Memo, Order, service

 9/29/03 Research standards for 2.00 500.00

 granting Rule 56 Motion for 250.00/hr

 Summary Judgment

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 12 of 18
 David Sambolin Esq. Page 7

 Hrs/Rate Amount

 9/30/03 Reasonable fee under statute 2.40 600.00

 and case law as well as cost 250.00/hr

 of litigating attorney's fees.

 Phone Calls To and From 0.80 200.00

 Reginal Johnson re correction 250.00/hr

 on Motion to remove reference

 to stipulation and review

 correspondence from Johnson.

 10/1/03 Draft a correction and file 1.60 400.00

 Motion. 250.00/hr

 10/2/03 Phone Calls To and from David 0.50 125.00

 Sambolin re Judge Fullum's 250.00/hr

 Order denying Motion to

 Dismiss.

 Review cases cited by Johnson 2.00 500.00

 limiting prevailing party 250.00/hr

 status.

 10/3/03 Phone calls to and from 0.67 167.50

 Sambolin on Summary Judgment 250.00/hr

 issues

 10/8/03 Meeting with Sambolin, 6.30 1,575.00

 reconstructing chronological 250.00/hr

 history using time sheets,

 documents and other records.

 10/10/03 Meeting with 0.60 150.00

 Sambolin,reviewing prepared 250.00/hr

 documents in response to Court

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 13 of 18
 Order.

 Draft Response to Court Order 2.00 500.00

 and letter to J. Fullum 250.00/hr

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 14 of 18
 David Sambolin Esq. Page 8

 Hrs/Rate Amount

 10/18/03 Review Record and Draft 2.00 500.00

 Factual Narrative 250.00/hr

 10/19/03 Review Record and Draft 2.00 500.00

 Factual Narrative 250.00/hr

 10/20/03 Review Record and Draft 2.00 500.00

 Factual Narrative 250.00/hr

 Review Record and Draft 3.00 750.00

 Factual Narrative 250.00/hr

 Phone calls to and from David 1.50 375.00

 and corrections to Record and 250.00/hr

 Narrative

 11/1/03 Draft Responsive Memorandum of 6.00 1,500.00

 Law 250.00/hr

 11/2/03 Research and Draft Responsive 6.70 1,675.00

 Memorandum of Law 250.00/hr

 11/3/03 Research and Draft Responsive 8.60 2,150.00

 Memorandum of Law 250.00/hr

 5/8/04 Research Rule 54 Pettition for 4.00 1,000.00

 Attorney's fees and 3rd 250.00/hr

 Circuit case law.

 5/9/04 Draft Rule 54 Pettition for 4.00 1,000.00

 Attorney's fees. 250.00/hr

 -------- ----------

 For professional services rendered 118.87 $29,717.50

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 15 of 18
 Additional charges:

 9/1/03 Copying cost from 9/01/03 60.00

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 16 of 18
 David Sambolin Esq. Page 9

 Amount

 9/1/03 Delivery Cost from 9/01 to 10/20 135.00

 10/19/03 Copy at Kinkos for Record and pick up 199.40

 and delivery

 ----------

 Total costs $394.40

 -------------

 Total amount of this bill $30,111.90

 -------------

 Balance due $30,111.90

 =============

Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 17 of 18
Case 2:02-cv-04336-JF Document 26-2 Filed 05/10/2004 Page 18 of 18