Exhibit C-2

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-8 Filed: 02/01/21 Page: 1 of 4 PAGEID #: 3138
Date Description of Services Time

4/5/2018 Prep for and Conference call with co-counsel 1.3

6/21/2018 conference call with co-counsel re R 26(f) report 1.2

7/7/2018 Review Ds Motion to Dismiss (MtD); Legal Reseach 2.5

7/9/2018

Prep for and Conference call with co-counsel re MtD and R26(f) 

draft; updating research on Ohio BC statutes and forwarding to cocounsel Ingelhart 1.5

7/17/2018

Substantive review 1st draft of our Brief in Opposition (BiO) to Ds 

MtD; conducting research on compelled speech issue 2.3

7/18/2018

Prep for and attendance at initial pretrial conference (via phone) 

with Magistrate Vascura 1.2

7/22/2018 Substantive review and edit of revised BiO to Ds MtD 2.5

8/5/2018

Substantive review and edit of our opposition to Ds Motion to Stay 

pending court's ruling on MtD 2.0

10/11/2018

Review of court's decision denying Ds Motion to Stay; conference 

call w/ co-counsel re resuming of discovery and related matters 1.0

10/15/2018 Review draft retainer agreement for potential expert witness 0.5

11/9/2018 Review and finalize protective order 1.0

12/11/2018

Review and sign off on proposed email by D. Carey to Ds re 

discovery status 0.2

1/9/2019

Review of Ds 1st set discovery requests; outline answers and 

objections 1.5

1/14/2019

Conference call with co-counsel re discovery responses & related 

matters 1.0

2/4/2019

Review combined edits and conference call to finalize our discovery 

responses 2.0

2/28/2019

Evaluating settlement possibilities; conference call with Ds counsel 

re settlement week 1.0

3/13/2019

Review of DC's summary of Ds' 1st doc production & EB's summary 

of Ds' 2nd doc production to identify outstanding issues 0.5

Susan Becker

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-8 Filed: 02/01/21 Page: 2 of 4 PAGEID #: 3139
3/21/2019

Preparation for and participation in team call on various discovery 

and case status issues 1.0

4/16/2019 Review of Ds' 2d set ROGs & RFAs 0.5

4/22/2019

Prep for and participate in team call re discovery issues including 

responses to Ds' 2nd set of discovery to Ps 1.0

4/26/2019

Review of draft responses to Ds 2nd discovery and communications 

with co-counsel re same 0.5

5/6/2019 Review of Ds' 3rd set ROGs & 2nd set RPD 0.2

5/24/2019

Review of Proposed Responses to Ds' 3rd set ROGS and 2nd set RPD; 

communications with co-counsel on same 0.2

7/8/2019

Review Ds' Expert Van Meter's Report; CP to P Expert Ettner's 

Report; evaluating need for rebuttal expert; considering various 

possible rebuttal experts 1.8

7/23/2019

Preparation for and participation in conference call with all c-counsel 

re potential rebuttal expert report 1.5

7/23/2019 Call w/ FL, EB re rebuttal 0.4

7/28/2019

Review of draft rebuttal report; compare to Dr. Ettner and Van 

Meter reports and pleadings and motions in the case 4.5

8/8/2019

Ohio legal team discussion of Nagy 30(b)(6) depo, need for 

additional discovery and follow up on previous requests; scheduling 

and logistics of expert and Ps' depo2 0.5

8/12/2019

Preparation for and partification in conference call with all cocounsel re responses to Ds' 4th set of ROGs, 3rd set RFA, and 3rd 

FRPODa 1.0

9/12/2019 Reviewing magistrate's decision denying Ohio's motion to discmiss 0.5

12/22/2019 Editing draft of Ps' SJM and brief; review select depo TRs 4.3

1/2/2020

Reviewing email exchanges with EB & FL re content of MSJ brief and 

depo attachments; reviewing edits proposed by FL 1.1

1/9/2020

Reviewing and editing motion to file deposition Trssuporting SJ 

Motion under seal 1.8

1/20/2020 Reading Ds'- Motion for SJ and outlining legal and factual response 2.0

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-8 Filed: 02/01/21 Page: 3 of 4 PAGEID #: 3140
1/21/2020 Conference call with co-counsel re opposition to Ds' Motion for SJ 0.5

2/5/2020 Editing Ps Opp Motion to D's MSJ 4.2

2/12/2020 Final edits Ps Opp Motion to Ds MSJ 1.8

2/18/2020

Reviewing Ds Brief Opposing Ps' MSJ; Conference call with cocounsel re our reply to Ds brief Opposition to Ps MSJ 2.8

2/25/2020 Editing Ps Reply Brief for Ps MSJ 2.5

Total Time 57.5

Hourly Rate x $ 500.00

Lodestar Fees $ 28,750.00

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-8 Filed: 02/01/21 Page: 4 of 4 PAGEID #: 3141