Exhibit C

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 1 of 23
DECLARATION OF PONCHO NEVAREZ PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

EL CAMPO VENTURES, LLC, §

 §

Plaintiff, §

 §

vs. § Civil Action No. 1:20-cv-00560-RP

 §

STRATTON SECURITIES, INC., §

STRATTON OILFIELD SYSTEMS §

TEXAS, LLC, DANIEL STRATTON, §

and SHANNON STRATTON, §

 §

 §

Defendants. §

DECLARATION OF PONCHO NEVAREZ

1. My name is Poncho Nevarez. I have personal knowledge of all

facts herein, and they are all true and correct. This declaration is submitted in

connection with El Campo Ventures, LLC’s Supplemental Memorandum in 

Support of its Motion for Attorney Fees, Prejudgment Interest, Post-judgment 

Interest and Costs filed in the above-styled-and-numbered lawsuit. 

2. I am an attorney duly licensed to practice law in the State of

Texas and the State of Arizona and have practiced continuously for 22 

years. A large portion of my practice has been devoted to litigation of complex

business matters and catastrophic injury cases in state and federal court. I practice 

law in numerous counties and metropolitan areas in Texas, including in Travis 

County, Texas, and within the Western District of Texas, Austin Division 

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 2 of 23
DECLARATION OF PONCHO NEVAREZ PAGE 2

(referenced herein together as “Austin”), where this action is pending. I am 

familiar with prosecuting lawsuits asserting breach of contract claims like those 

Plaintiff has brought in this case. I am also familiar with the character and the 

amount of legal work traditionally expended in prosecuting such an action, as 

well as the fees normally charged. I am further aware of the fees commonly and 

customarily charged in Austin, for legal services rendered in connection with 

such litigation.

3. Ben Gates and I represent El Campo Ventures, LLC (“El Campo”), the 

plaintiff in the above-styled-and-numbered lawsuit. 

3. The revised fee agreement with El Campo was set out in writing by 

letter dated February 24, 2020. Under that agreement, Ben Gates and I, as El 

Campo’s attorneys, agreed to be compensated solely in the form of a contingent 

fee. The contingent fee percentage was 25% of the gross sum recovered prior to 

the commencement of a trial, and 30% of the gross sum recovered after the 

commencement of a trial. In addition, the fee agreement required El Campo’s 

attorneys to advance all costs and expenses in this matter. To date, Mr. Gates 

and I have advanced approximately $60,000.00 of costs and expenses on behalf of 

El Campo. 

4. I am familiar with the average, customary and reasonable 

contingent fee percentages charged by attorneys with similar experience and 

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 3 of 23
DECLARATION OF PONCHO NEVAREZ PAGE 3

expertise in Austin. It is my opinion that El Campo’s 30% contingent fee is at 

the bottom end of the range of usual and customary contingent fees 

charged for similar work in Austin. Contingent fee percentages in Austin (and 

throughout Texas) for business cases range from 30% to 40% depending on

which party pays the expenses, when the case is resolved and the dollar value

of the case. It is my opinion that our 30% contingent fee agreement with El 

Campo in this case is very reasonable considering the approximately $60,000.00 

of costs and expenses that have been advanced by Mr. Gates and myself. 

Typically, I charge clients a 40% contingency fee when I agree to advance all 

costs and expenses associated with a matter. 

5. In addition, when Stratton Securities, Inc. filed its declaratory 

judgment action against El Campo (Case No.: 1:20-CV-00248-RP), Mr. Gates and 

I represented El Campo in that action under the same February 24, 2020 fee 

agreement.

6. I am also familiar with the average, customary and reasonable 

hourly rates charged by attorneys with similar experience and expertise in 

Austin. My standard hourly billing rate is $500 per hour. My opinion is that $500 

per hour is a very reasonable hourly rate for complex commercial litigation in 

Austin. When I bill by the hour, I send the client an invoice each month and

receive payment within 30 days. Typically, clients deposit an amount of money 

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 4 of 23
DECLARATION OF PONCHO NEVAREZ PAGE 4

in my trust account sufficient to cover any costs or expenses associated with their 

legal matter. 

7. Given the contingent nature of this case, it is my opinion that $500 

per hour would not be a reasonable hourly rate for purposes of calculating a 

reasonable fee under the lodestar method in this case. Instead, it is my opinion 

that the loadstar should be calculated at the higher hourly rate of $750 (1.5x the 

normal hourly rate) to account for the risk of loss, the delay in receiving any 

payment for services rendered or recovery of any of the approximately $60,000.00 

in fees and expenses advanced by Mr. Gates and I on behalf of El Campo. I do 

not undertake any of these risks when I bill my normal reasonable hourly rate of 

$500 per hour and therefore these risks justify higher hourly rate in this case.

8. My testimony herein is based on my education, skill, knowledge 

and experience; my review of my time records; my involvement in this case; and 

my knowledge of the work performed in this case.

9. In reviewing my time records in this case and in exercising my 

billing judgment, I would determine what I believed was reasonable given the 

time expended and the services I provided. In this case, I used my billing 

judgment to write-down time entries when I believed too much time was 

expended for a particular task. For purposes of calculating a reasonable 

attorney’s fee using the loadstar method, I spent a total of 379.3 hours and it is 

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 5 of 23
DECLARATION OF PONCHO NEVAREZ PAGE 5

my opinion that this amount of time was reasonably and necessarily expended 

by me in this case in order to help secure a $4,095,300.00 jury verdict in favor of 

El Campo.

I declare under penalty of perjury that the foregoing is true and correct.

EXECUTED on January 5, 2022.

/s/ Poncho Nevarez

______________________________

Poncho Nevarez

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 6 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

12/13/2019 ANC A105 Communicate (in firm) 3.0 3.0 $750.00/Hour $2,250.00

Communicate (in firm) meeting w/ Ben

Gates re case etc in Eagle Pass

12/20/2019 ANC A106 Communicate (with client) 0.4 0.4 $750.00/Hour $300.00

Communicate (with client) spoke with

Gattis

12/23/2019 ANC RR Receipt and Review of 1.8 1.8 $750.00/Hour $1,350.00

Receipt and Review of file up to that

point

12/30/2019 ANC A106 Communicate (with client) 0.4 0.4 $750.00/Hour $300.00

Communicate (with client) spoke with

Rae

02/27/2020 ANC A105 Communicate (in firm) 4.0 4.0 $750.00/Hour $3,000.00

Communicate (in firm) meeting with Ben

re strategy

03/09/2020 ANC RR Receipt and Review of 0.8 0.8 $750.00/Hour $600.00

Receipt and Review of Dec Action filed

by Defendants; sent Ben some notes

03/11/2020 ANC RR Receipt and Review of 0.1 0.1 $750.00/Hour $75.00

Receipt and Review of news article re

lawsuit.

03/11/2020 ANC RR Receipt and Review of 0.1 0.1 $750.00/Hour $75.00

Receipt and Review of email from Dan

Gattis re summons

03/12/2020 ANC A111 Other 0.5 0.5 $750.00/Hour $375.00

Conference call with Rae Powell, Dan

Gattis, and Ben Gates to discuss

litigation strategy

03/16/2020 ANC A105 Communicate (in firm) 0.3 0.3 $750.00/Hour $225.00

Communicate (in firm) Telephone

conference with Ben Gates re: petition.

03/16/2020 ANC L210 Pleadings 2.2 2.2 $750.00/Hour $1,650.00

Pleadings reviewing El Campo Pettion

03/17/2020 ANC L210 Pleadings 1.1 1.1 $750.00/Hour $825.00

Pleadings reviewing El Campo Petition

phone call with Ben re suggestions and

Redline

01/05/2022 02:41 PM Page 1 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 7 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

03/18/2020 ANC L210 Pleadings 0.6 0.6 $750.00/Hour $450.00

Pleadings reviewed El Campo Petition

again more redline

03/19/2020 ANC L210 Pleadings 0.6 0.6 $750.00/Hour $450.00

Pleadings worked on El Campo Petition

spoke with Ben re redlines

03/20/2020 ANC L210 Pleadings 0.6 0.6 $750.00/Hour $450.00

Pleadings reviewed El Campo Petition

with Ben and talked to him about

changes

03/23/2020 ANC L210 Pleadings 0.4 0.4 $750.00/Hour $300.00

Pleadings reviewed the El Campo

Petition more redline spoke with Ben

03/23/2020 ANC A106 Communicate (with client) 0.4 0.4 $750.00/Hour $300.00

Communicate (with client) to confirm

factual allegations in petition and go

over one more time

03/24/2020 ANC L210 Pleadings 0.3 0.3 $750.00/Hour $225.00

Pleadings spoke with Ben about petition

03/26/2020 ANC A103 Draft/revise 0.2 0.2 $750.00/Hour $150.00

Reviewed another draft Emailed draft

petition to Ben Gates, Dan Gattis and

client

03/26/2020 ANC A105 Communicate (in firm) 0.1 0.1 $750.00/Hour $75.00

Communicate/ telephone conference

with Ben Gates re: draft of petition

03/26/2020 ANC A106 Communicate (with client) 0.3 0.3 $750.00/Hour $225.00

Communicate (with client) telephone

conference re: draft of petition

03/26/2020 ANC L210 Pleadings 2.6 2.6 $750.00/Hour $1,950.00

Pleadings reviewed and finalized El

Campo petition spoke with Ben as well

03/30/2020 ANC RR Receipt and Review of 0.4 0.4 $750.00/Hour $300.00

Receipt and Review of petition sent to

clients with Exhibits

01/05/2022 02:41 PM Page 2 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 8 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

03/30/2020 ANC A105 Communicate (in firm) 0.6 0.6 $750.00/Hour $450.00

Communicate (in firm) with Ben

regarding research on some of the legal

issues and possible removal

03/31/2020 ANC A105 Communicate (in firm) 0.4 0.4 $750.00/Hour $300.00

Communicate (in firm) with Ben re

motion to dismiss

04/01/2020 ANC A104 Review/analyze 0.8 0.8 $750.00/Hour $600.00

Review of draft motion to dismiss;

emailed suggested revisions to Ben

Gates.

04/15/2020 ANC RR Receipt and Review of 1.3 1.3 $750.00/Hour $975.00

Receipt and Review of notice of removal,

motion to transfer venue, response to

motion to dismiss, and answer for

Stratton Securities and Stratton Oilfield

A108 Communicate (other $150.00

external)

05/05/2020 ANC 0.2 0.2 $750.00/Hour

Communicate (other external) email

with Mike and Ben re scheduling order

(s)

05/08/2020 ANC RR Receipt and Review of 0.4 0.4 $750.00/Hour $300.00

Receipt and Review of answer for Daniel

Stratton and Shannon Stratton.

Notations and questions

05/11/2020 ANC A104 Review/analyze 0.3 0.3 $750.00/Hour $225.00

Review of proposed scheduling order

and Def's suggested revisions.

05/13/2020 ANC A102 Research 3.2 3.2 $750.00/Hour $2,400.00

Research Motion to Remand and review

petition and factual bases for remand

05/14/2020 ANC A103 Draft/revise 7.5 7.5 $750.00/Hour $5,625.00

Draft/revise Motion to Remand along

with updating case law

05/15/2020 ANC A103 Draft/revise 3.8 3.8 $750.00/Hour $2,850.00

Working on exhibits and drafting El

Campo's response to motion to transfer

venue.

01/05/2022 02:41 PM Page 3 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 9 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

05/18/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Reviewed scheduling order entered by

Judge Ezra

05/19/2020 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed and analyzed Stratton's first

request for production.

05/22/2020 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Receipt and reviewed of Stratton

disclosures, reply to motion to transfer

venue and response to motion to

remand, made some notes and shared

with Ben

05/22/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Reviewed letter from Signor's counsel

A108 Communicate (other $75.00

external)

06/01/2020 ANC 0.1 0.1 $750.00/Hour

Communicate (other external) re depo

dates with counsel

06/02/2020 ANC RR Receipt and Review of 0.1 0.1 $750.00/Hour $75.00

Receipt and Review of email from Mike

Jones re: depos

06/02/2020 ANC A105 Communicate (in firm) 0.4 0.4 $750.00/Hour $300.00

Communicate/Telephone conference

with Ben Gates re: depos

06/02/2020 ANC A106 Communicate (with client) 0.4 0.4 $750.00/Hour $300.00

Communicate (with client) re: request

for production. spoke with Ben on this

06/02/2020 ANC A106 Communicate (with client) 0.3 0.3 $750.00/Hour $225.00

Communicate (with client) Re: request

for production spoke with Ben on this

and made some suggestions on order of

production

06/03/2020 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Review and analyze Stratton's request

for admissions and ROG's

06/24/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Reviewed letter from Mike Jones re: El

Campo document production

01/05/2022 02:41 PM Page 4 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 10 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

07/08/2020 ANC A104 Review/analyze 1.5 1.5 $750.00/Hour $1,125.00

Review/analyze Signor Discovery

07/15/2020 ANC A105 Communicate (in firm) 0.1 0.1 $750.00/Hour $75.00

Communicate with Mike Jones re:

motion to compel

07/24/2020 ANC L320 Document Production 1.2 1.2 $750.00/Hour $900.00

reviewed El Campo's first request for

production to Stratton Defendants.

07/24/2020 ANC A103 Draft/revise 0.7 0.7 $750.00/Hour $525.00

drafted supplemental discovery

responses

07/28/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Review letter from Mike Jones re:

verification

08/06/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyze Stratton's second

request for production; communication

with client re: same

08/07/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed motion for protective order

and had conversation with Ben about it

08/10/2020 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Reviewed 24 documents provided by

Dan Gattis and discussed with Ben

08/24/2020 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed and analyzed Stratton's

responses to El Campo's first request for

production

08/24/2020 ANC A104 Review/analyze 6.0 6.0 $750.00/Hour $4,500.00

Review/analyze recordings. 2 El Campo

and 7 Stratton recordings. There is a lot

there. Spoke with Ben about it.

08/24/2020 ANC A106 Communicate (with client) 0.7 0.7 $750.00/Hour $525.00

Communicate (with client) call with

Gattis re recordings

08/24/2020 ANC A106 Communicate (with client) 0.5 0.5 $750.00/Hour $375.00

Communicate (with client) with Powell

re recordings

01/05/2022 02:41 PM Page 5 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 11 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

08/28/2020 ANC A103 Draft/revise 0.1 0.1 $750.00/Hour $75.00

reviewed letter to Mike Jones re:

Stratton document production

09/02/2020 ANC RR Receipt and Review of 4.0 4.0 $750.00/Hour $3,000.00

Receipt and Review of audio from the

Strattons

09/02/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyzed additional

documents produced by Stratton

09/03/2020 ANC RR Receipt and Review of 5.0 5.0 $750.00/Hour $3,750.00

Receipt and Review of audio from

production. It's a lot of stuff there.

Spoke with Ben about it.

09/08/2020 ANC A103 Draft/revise 0.4 0.4 $750.00/Hour $300.00

Reviewed El Campo's response to

Stratton's second request for production

09/09/2020 ANC L530 Oral Argument 0.2 0.2 $750.00/Hour $150.00

Oral Argument initial call with Judge

Pittman

09/10/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Reviewed letter from Mike Jones re:

missing recordings

09/10/2020 ANC A103 Draft/revise 0.1 0.1 $750.00/Hour $75.00

Reviewed letter to Mike Jones re:

Stratton document production

09/23/2020 ANC RR Receipt and Review of 0.1 0.1 $750.00/Hour $75.00

Receipt and Review of dismissal of

Signor

09/25/2020 ANC A103 Draft/revise 0.2 0.2 $750.00/Hour $150.00

Reviewed 30(b)(6) notices for Stratton

entities

09/26/2020 ANC L330 Depositions 5.0 5.0 $750.00/Hour $3,750.00

Prepare for Depositions of Strattons

09/27/2020 ANC L330 Depositions 2.2 2.2 $750.00/Hour $1,650.00

Prepare for Depositions of Strattons

01/05/2022 02:41 PM Page 6 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 12 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

09/28/2020 ANC L120 Analysis/Strategy 1.7 1.7 $750.00/Hour $1,275.00

Analysis/Strategy meet with Ben re

depositions

09/28/2020 ANC L330 Depositions 10.0 10.0 $750.00/Hour $7,500.00

Travel from Eagle Pass to Savannah,

Georgia for Stratton depositions.

09/29/2020 ANC L330 Depositions 0.5 0.5 $750.00/Hour $375.00

Prepare for Depositions meet with Ben

prior to

09/29/2020 ANC L330 Depositions 6.0 6.0 $750.00/Hour $4,500.00

Attended depositions of Shannon

Stratton and Daniel Stratton

09/29/2020 ANC A103 Draft/revise 0.1 0.1 $750.00/Hour $75.00

Review Draft proposed order re:

extension of scheduling order deadlines

09/30/2020 ANC L330 Depositions 10.0 10.0 $750.00/Hour $7,500.00

Depositions travel from Savannah to

Eagle Pass

10/08/2020 ANC A102 Research 0.4 0.4 $750.00/Hour $300.00

Spoke with Ben re potential audio

experts

10/13/2020 ANC A104 Review/analyze 2.8 2.8 $750.00/Hour $2,100.00

Reviewed enhanced audio clips of April

30, 2019 recording spoke with Ben

about what they mean for the case

10/13/2020 ANC A103 Draft/revise 0.1 0.1 $750.00/Hour $75.00

Reviewed letter to Mike Jones re:

outstanding discovery issues

10/14/2020 ANC A104 Review/analyze 1.6 1.6 $750.00/Hour $1,200.00

Reviewed further audio enhancement of

the end of the April 30, 2019 recording

and spoke to Ben about it

10/14/2020 ANC L120 Analysis/Strategy 0.7 0.7 $750.00/Hour $525.00

Spoke to Ben about this and the

criminal ramifications of bank deception

if any Analyzed file for additional causes

of action

01/05/2022 02:41 PM Page 7 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 13 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

10/15/2020 ANC L210 Pleadings 1.0 1.0 $750.00/Hour $750.00

Pleadings reviewed El Campo First

Amend Complaint

10/16/2020 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Review/analyze Amended Complaint

10/19/2020 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed expert report from Ryan

Anderson spoke with Ben about it

10/20/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed letter from Mike Jones and

analyzed additional document

production labeled Stratton 650-

Stratton 875

10/22/2020 ANC A103 Draft/revise 0.5 0.5 $750.00/Hour $375.00

Reviewed objection to magistrate judge

report re: motion to dismiss declaratory

judgment action and researched what it

means for other causes of action going

forward

10/23/2020 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed and analyzed Stratton 876 -

Stratton 1199

10/23/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Review/analyze obj to magistrate

recommendation

10/27/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyzed Stratton 1200 -

Stratton 1231

10/29/2020 ANC A104 Review/analyze 1.8 1.8 $750.00/Hour $1,350.00

Review/analyze Stratton Depos,

10/29/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyzed Stratton 1232 -

Stratton 1261

10/29/2020 ANC A103 Draft/revise 0.1 0.1 $750.00/Hour $75.00

Drafted email to Mike Jones re:

outstanding discovery issues

01/05/2022 02:41 PM Page 8 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 14 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

11/02/2020 ANC A104 Review/analyze 0.1 0.1 $750.00/Hour $75.00

Reviewed and analyzed email from Mike

Jones re: outstanding discovery issues

11/02/2020 ANC RR Receipt and Review of 0.1 0.1 $750.00/Hour $75.00

Receipt and review of email from Mike

Jones re: additional depositions

11/03/2020 ANC A104 Review/analyze 1.5 1.5 $750.00/Hour $1,125.00

Reviewed Stratton's response to

objection, affidavit of Daniel Stratton,

Rae Powell deposition excerpts, and Dan

Gattis deposition excerpts

11/04/2020 ANC A104 Review/analyze 0.7 0.7 $750.00/Hour $525.00

Reviewed and analyzed Stratton 1262 -

Stratton 1486

11/09/2020 ANC A102 Research 0.7 0.7 $750.00/Hour $525.00

Researched and made

recommendations/spoke to Ben about

potential accounting experts

11/17/2020 ANC A105 Communicate (in firm) 1.3 1.3 $750.00/Hour $975.00

Communicate (in firm) Spoke with Ben

re Don Southerland, provided

documents for review

11/30/2020 ANC A104 Review/analyze 0.8 0.8 $750.00/Hour $600.00

Reviewed Don Southerland's report and

made myself some notes on how this

will help the jury

11/30/2020 ANC A101 Plan and prepare for 0.5 0.5 $750.00/Hour $375.00

Reviewed and helped Prepare expert

disclosures

12/01/2020 ANC A105 Communicate (in firm) 0.5 0.5 $750.00/Hour $375.00

Conference call with Rae Powell, Dan

Gattis and Ben Gates to discuss strategy

12/02/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyzed Stratton 1487 -

Stratton 1493

12/10/2020 ANC A101 Plan and prepare for 6.2 6.2 $750.00/Hour $4,650.00

Prepare for depositions of Jeff Stratton

and Rileigh Knight

01/05/2022 02:41 PM Page 9 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 15 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

12/11/2020 ANC A101 Plan and prepare for 0.7 0.7 $750.00/Hour $525.00

Prepare for deposition of Jeff Stratton

12/11/2020 ANC L330 Depositions 1.7 1.7 $750.00/Hour $1,275.00

Attended deposition of Jeff Stratton

12/11/2020 ANC L330 Depositions 1.1 1.1 $750.00/Hour $825.00

Attended deposition of Rileigh Knight

12/21/2020 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed documents produced by

Justin Hollis made notes

12/21/2020 ANC A101 Plan and prepare for 1.7 1.7 $750.00/Hour $1,275.00

Prepare for deposition of Justin Hollis

12/22/2020 ANC L330 Depositions 0.9 0.9 $750.00/Hour $675.00

Attended deposition of Justin Hollis

12/23/2020 ANC A103 Draft/revise 1.3 1.3 $750.00/Hour $975.00

Review answer to amended complaint in

declaratory judgment action

12/28/2020 ANC L210 Pleadings 0.5 0.5 $750.00/Hour $375.00

Pleadings review answer on Dec

12/29/2020 ANC A104 Review/analyze 0.8 0.8 $750.00/Hour $600.00

Review and analyze motion to exclude

expert testimony and speak to Ben

about it

12/30/2020 ANC A103 Draft/revise 0.4 0.4 $750.00/Hour $300.00

Reviewed El Campo's second request for

production to Stratton defendants

01/04/2021 ANC A101 Plan and prepare for 1.2 1.2 $750.00/Hour $900.00

Plan and prepare for hearing on Motion

to Remand

01/05/2021 ANC A111 Other 0.5 0.5 $750.00/Hour $375.00

Attended Zoom hearing re: motion to

remand

01/05/2021 ANC A102 Research 0.7 0.7 $750.00/Hour $525.00

Legal research and analysis re: grounds

for admission of accounting expert

testimony spoke with Ben on this

01/05/2022 02:41 PM Page 10 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 16 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

01/06/2021 ANC A104 Review/analyze 0.9 0.9 $750.00/Hour $675.00

Review/analyze response to motion to

exclude experts

01/07/2021 ANC A104 Review/analyze 0.4 0.4 $750.00/Hour $300.00

Reviewed and analyzed Stratton 1494 -

Stratton 1505

01/08/2021 ANC L120 Analysis/Strategy 2.0 2.0 $750.00/Hour $1,500.00

Analysis/Strategy and research on the

contract and the surrounding

supporting/refuting docs

01/08/2021 ANC A104 Review/analyze 1.5 1.5 $750.00/Hour $1,125.00

Review/analyze motion to exclude

expert testimony

01/12/2021 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed and analyzed Stratton 1506 -

Stratton 1522

01/13/2021 ANC A104 Review/analyze 0.9 0.9 $750.00/Hour $675.00

Reviewed Stratton's response to

objection, affidavit of Daniel Reviewed

Stratton reply to El Campo's response to

motion to exclude expert testimony

01/20/2021 ANC RR Receipt and Review of 1.8 1.8 $750.00/Hour $1,350.00

Receipt and Review of Gattis and Powell

Deposition

01/21/2021 ANC A101 Plan and prepare for 2.5 2.5 $750.00/Hour $1,875.00

Prepare for depos of Clardy, etc

01/22/2021 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Reviewed and analyzed Stratton 1523 -

Stratton 1558

01/25/2021 ANC A101 Plan and prepare for 1.0 1.0 $750.00/Hour $750.00

Plan and prepare for motion to exclude

hearing

01/25/2021 ANC A101 Plan and prepare for 1.0 1.0 $750.00/Hour $750.00

Plan and prepare for motion to exclude

testimony

01/25/2021 ANC A101 Plan and prepare for 1.0 1.0 $750.00/Hour $750.00

Prepared for deposition of Clardy, etc

01/05/2022 02:41 PM Page 11 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 17 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

01/26/2021 ANC L330 Depositions 1.8 1.8 $750.00/Hour $1,350.00

Depositions attended Luke Clardy

01/26/2021 ANC A109 Appear for/attend 0.5 0.5 $750.00/Hour $375.00

Appear for/attend hearing on motion to

exclude

01/26/2021 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Reviewed and analyzed Stratton 1559 -

Stratton 1601

01/27/2021 ANC L250 Other Written Motions 1.2 1.2 $750.00/Hour $900.00

Reviewed on El Campo's motion for

summary judgment

01/28/2021 ANC A104 Review/analyze 1.8 1.8 $750.00/Hour $1,350.00

Reviewed and analyzed Stratton's

motion for summary judgment including

pulling cases

01/28/2021 ANC A104 Review/analyze 2.5 2.5 $750.00/Hour $1,875.00

Review/analyze Stratton MSJ

01/29/2021 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Reviewed and analyzed Stratton's

responses to El Campo's second request

for production; Stratton 1602 - Stratton

1697

01/29/2021 ANC L250 Other Written Motions 1.2 1.2 $750.00/Hour $900.00

Reviewed El Campo's motion for

summary judgment

02/10/2021 ANC L250 Other Written Motions 1.2 1.2 $750.00/Hour $900.00

Reviewed El Campo's response to

Stratton's motion for summary

judgment

02/11/2021 ANC L250 Other Written Motions 1.3 1.3 $750.00/Hour $975.00

Reviewed El Campo's response to

Stratton's motion for summary

judgment made some more suggestions

02/12/2021 ANC A104 Review/analyze 0.7 0.7 $750.00/Hour $525.00

Reviewed and analyzed Stratton's

response to El Campo's motion for

summary judgment made some notes

01/05/2022 02:41 PM Page 12 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 18 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

02/12/2021 ANC A104 Review/analyze 0.2 0.2 $750.00/Hour $150.00

Reviewed Stratton's stipulation of

dismissal of its declaratory judgment

action against El Campo

02/18/2021 ANC A104 Review/analyze 0.7 0.7 $750.00/Hour $525.00

Reviewed and analyzed Stratton's reply

to El Campo's response to its motion for

summary judgment

02/18/2021 ANC L250 Other Written Motions 1.4 1.4 $750.00/Hour $1,050.00

Worked on El Campo reply to Stratton

response to its motion for partial

summary judgment

02/24/2021 ANC L250 Other Written Motions 1.5 1.5 $750.00/Hour $1,125.00

Worked on El Campo reply to Stratton

response to its motion for partial

summary judgment

03/02/2021 ANC L330 Depositions 3.2 3.2 $750.00/Hour $2,400.00

Depositions prep for John Baxter

03/03/2021 ANC A104 Review/analyze 0.6 0.6 $750.00/Hour $450.00

Reviewed Sunflower Bank's discovery

responses and document production;

SB_000001-SB_000884 spoke to Ben

about this

03/04/2021 ANC A109 Appear for/attend 1.5 1.5 $750.00/Hour $1,125.00

Attend deposition of John Baxter

03/29/2021 ANC A111 Other 0.1 0.1 $750.00/Hour $75.00

Email correspondence with Mike Jones

and Ben Gates re: possible mediation

dates

03/30/2021 ANC A102 Research 0.3 0.3 $750.00/Hour $225.00

Researched potential Dallas-based

mediators spoke with Ben on this

03/30/2021 ANC A111 Other 0.1 0.1 $750.00/Hour $75.00

Email correspondence with Mike Jones

and Ben Gates re: potential mediators

04/02/2021 ANC A104 Review/analyze 0.5 0.5 $750.00/Hour $375.00

Reviewed and analyzed Stratton 1698 -

Stratton 1723

01/05/2022 02:41 PM Page 13 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 19 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

04/12/2021 ANC A111 Other 0.1 0.1 $750.00/Hour $75.00

Email correspondence with Carolina El

Azar scheduling mediation with Judge

Glen Ashworth on May 25, 2021

04/28/2021 ANC A111 Other 0.1 0.1 $750.00/Hour $75.00

Email correspondence with client re:

mediation

05/13/2021 ANC A104 Review/analyze 0.2 0.2 $750.00/Hour $150.00

Reviewed order moving trial date to

September 13; communicate with client

re: same

05/18/2021 ANC A101 Plan and prepare for 2.3 2.3 $750.00/Hour $1,725.00

Plan and prepare for mediation.

Reviewing packet and exhibits to

provide

05/19/2021 ANC A111 Other 0.6 0.6 $750.00/Hour $450.00

reviewed changes to confidential

mediation statement

A107 Communicate (other outside $150.00

counsel)

05/20/2021 ANC 0.2 0.2 $750.00/Hour

Telephone conference with Judge

Ashworth re: mediation

05/24/2021 ANC A101 Plan and prepare for 1.2 1.2 $750.00/Hour $900.00

Prepare for mediation

05/25/2021 ANC A109 Appear for/attend 8.0 8.0 $750.00/Hour $6,000.00

Attend mediation

06/24/2021 ANC A104 Review/analyze 1.2 1.2 $750.00/Hour $900.00

Review and analyze summary judgment

report

07/14/2021 ANC A111 Other 7.3 7.3 $750.00/Hour $5,475.00

Worked on Notice to Court including

but not limited to Limines, Voir Dire,

deposition clips witness lists, expert

designations catch alls

07/15/2021 ANC A111 Other 8.0 8.0 $750.00/Hour $6,000.00

Work on Notice to Court and coordinate

with Ben the issues at bar with Limine

and clips and review Ben's portion

01/05/2022 02:41 PM Page 14 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 20 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

07/16/2021 ANC A111 Other 2.3 2.3 $750.00/Hour $1,725.00

Work on Notice to Court

07/28/2021 ANC A101 Plan and prepare for 1.5 1.5 $750.00/Hour $1,125.00

Prepare for (help Ben) for Pre Trial

hearing

08/06/2021 ANC A101 Plan and prepare for 5.2 5.2 $750.00/Hour $3,900.00

Plan and prepare for direct outlines of

Gattis and Powell

08/09/2021 ANC A104 Review/analyze 3.0 3.0 $750.00/Hour $2,250.00

Review/analyze Clardy deposition and

Hollis made cuts and notations

08/12/2021 ANC A104 Review/analyze 2.2 2.2 $750.00/Hour $1,650.00

Review/analyze and made some

preliminary cuts to banker's depo

08/16/2021 ANC A104 Review/analyze 4.3 4.3 $750.00/Hour $3,225.00

Review/analyze read Strattons'

depositions again and made some

prelim cuts

08/17/2021 ANC A104 Review/analyze 4.0 4.0 $750.00/Hour $3,000.00

Review/analyze cross of Strattons, depo

cuts

08/18/2021 ANC A101 Plan and prepare for 4.5 4.5 $750.00/Hour $3,375.00

Plan and prepare for slides and how to

present documents

08/20/2021 ANC A101 Plan and prepare for 4.0 4.0 $750.00/Hour $3,000.00

Plan and prepare further for cross

examinations of Strattons

08/23/2021 ANC RR Receipt and Review of 1.6 1.6 $750.00/Hour $1,200.00

Receipt and Review of Knight and Jeff

Stratton Depositions

08/25/2021 ANC A101 Plan and prepare for 8.3 8.3 $750.00/Hour $6,225.00

Plan and prepare for trial. Start building

folders and preparing jury selection and

arguments

08/29/2021 ANC A101 Plan and prepare for 2.8 2.8 $750.00/Hour $2,100.00

Plan and prepare for jury selection

01/05/2022 02:41 PM Page 15 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 21 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

09/01/2021 ANC A101 Plan and prepare for 10.0 10.0 $750.00/Hour $7,500.00

Plan and prepare for jury selection

including phone calls with Ben

09/02/2021 ANC A111 Other 4.0 4.0 $750.00/Hour $3,000.00

Travel from Eagle Pass to Austin to

attend jury selection

09/02/2021 ANC A101 Plan and prepare for 4.0 4.0 $750.00/Hour $3,000.00

Prepare for Voir Dire

09/03/2021 ANC A109 Appear for/attend 4.0 4.0 $750.00/Hour $3,000.00

Appear for/attend travel back from ATX

to Eagle Pass

09/03/2021 ANC L450 Trial and Hearing Attendance 4.0 4.0 $750.00/Hour $3,000.00

Trial and Hearing Attendance To Eagle

Pass from Austin travel for jury selection

09/03/2021 ANC L440 Other Trial Preparation 8.0 8.0 $750.00/Hour $6,000.00

Attended jury selection

09/04/2021 ANC L440 Other Trial Preparation 12.0 12.0 $750.00/Hour $9,000.00

Other Trial Preparation and Support

09/05/2021 ANC L440 Other Trial Preparation 9.0 9.0 $750.00/Hour $6,750.00

Other Trial Preparation and Support

09/06/2021 ANC A111 Other 4.0 4.0 $750.00/Hour $3,000.00

Other travel from Eagle Pass to ATX for

Trial

09/06/2021 ANC L450 Trial and Hearing Attendance 4.0 4.0 $750.00/Hour $3,000.00

Trial and Hearing Attendance travel to

Austin from Eagle Pass for trial

09/06/2021 ANC L440 Other Trial Preparation 11.0 11.0 $750.00/Hour $8,250.00

Other Trial Preparation and Support

09/07/2021 ANC L440 Other Trial Preparation 5.0 5.0 $750.00/Hour $3,750.00

Other Trial Preparation and Support

09/07/2021 ANC L450 Trial and Hearing Attendance 8.0 8.0 $750.00/Hour $6,000.00

Trial

09/07/2021 ANC L440 Other Trial Preparation 5.0 5.0 $750.00/Hour $3,750.00

Other Trial Preparation and Support

01/05/2022 02:41 PM Page 16 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 22 of 23
Bill To: El Campo Ventures, LLC

Billable

Billable

Amount

Billable

Time

Timekeeper (Hrs) Rate

Code\Task\

Date Description

Time

Spent

(Hrs)

Case No. 200748

09/08/2021 ANC L440 Other Trial Preparation 4.0 4.0 $750.00/Hour $3,000.00

Other Trial Preparation and Support

09/08/2021 ANC L450 Trial and Hearing Attendance 8.0 8.0 $750.00/Hour $6,000.00

Trial

09/08/2021 ANC L440 Other Trial Preparation 4.0 4.0 $750.00/Hour $3,000.00

Other Trial Preparation and Support

09/09/2021 ANC L440 Other Trial Preparation 2.0 2.0 $750.00/Hour $1,500.00

Other Trial Preparation and Support

09/09/2021 ANC L450 Trial and Hearing Attendance 6.0 6.0 $750.00/Hour $4,500.00

Trial

09/09/2021 ANC A111 Other 4.0 4.0 $750.00/Hour $3,000.00

Travel to Eagle Pass from Austin

12/01/2021 ANC A104 Review/analyze 1.5 1.5 $750.00/Hour $1,125.00

Review/analyze and prepare for hearing

on fees. Review our filing

12/03/2021 ANC L450 Trial and Hearing Attendance 9.0 9.0 $750.00/Hour $6,750.00

Trial and Hearing Attendance including

travel back and forth from Eagle Pass to

Austin

Total Bill To: El Campo Ventures, LLC 379.3 379.3 $284,475.00

Total for Case No. 200748 379.3 379.3 $284,475.00

01/05/2022 02:41 PM Page 17 of 17

Nevarez Law Group, PC

Billable Hours Report

Case 1:20-cv-00560-RP Document 128-3 Filed 01/08/22 Page 23 of 23