Exhibit D-2

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-11 Filed: 02/01/21 Page: 1 of 4 PAGEID #: 3148
Date Description of Services Time

4/5/2018

Conference call with ACLU and Lambda personnel regarding case 

status, latest client correspondence, and next steps. 1.1

4/13/2018

Review previous research regarding designation of related cases, 

and correspond with F. Levenson. 0.2

6/21/2018 Call with litigation team regarding initial disclosures. 1.2

6/28/2018 Call with co-counsel regarding case strategy and next steps. 0.9

7/7/2018

Correspond with F. Levenson and other co-counsel regarding case 

strategy and next steps. 0.4

7/9/2018

Conference call with co-counsel regarding next steps and motion to 

dismiss. 1.0

7/10/2018 Discuss MTD w/ ME 0.1

7/16/2018 Review draft opposition to motion to dismiss. 0.5

7/16/2018 Review and revise draft interrogatories and requests for production. 1.2

7/17/2018 Correspond with co-counsel regarding case strategy. 0.5

7/18/2018 Pretrial conference call with Court and all counsel. 1.2

7/18/2018

Call with co-counsel regarding strategy pertaining to motion to 

dismiss. 1.2

7/20/2018

Review and analyze motion for stay of discovery and emergency 

motion for interim stay, outline response arguments for M. Eble, and 

send update to co-counsel. 2.1

7/22/2018 Review and revise draft opposition to motion to dismiss. 2.4

7/24/2018 Review and revise draft opposition to motion for interim stay. 1.8

7/25/2018 Revise draft opposition to motion for interim stay of discovery. 2.8

7/26/2018

Correspondence and discussion with co-counsel regarding 

opposition to motion to dismiss and opposition to motion for 

interim stay. 2.3

8/3/2018 Review and revise draft opposition to motion to stay discovery. 3.5

8/6/2018

Incorporate co-counsel's edits into draft opposition to motion for 

stay of discovery, and circulate new draft to co-counsel. 1.2

10/11/2018 Conference call with co-counsel regarding discovery strategy. 0.4

David Carey

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-11 Filed: 02/01/21 Page: 2 of 4 PAGEID #: 3149
11/13/2018

Correspond with S. Becker and F. Levenson regarding protective 

order and discovery strategy. 0.5

11/14/2018 Draft proposed protective order. 2.5

11/16/2018

Revise draft proposed protective order, and send to opposing 

counsel. 1.0

11/21/2018

Review draft protective order and circulate proposed revisions to cocounsel. 0.8

12/3/2018

Finalize protective order, obtain consent of opposing counsel, and 

send for filing. 1.5

12/5/2018

Correspond with F. Levenson, S. Becker, and E. Bonham regarding 

discovery strategy. 0.4

12/11/2018

Draft and send correspondence to opposing counsel regarding 

discovery progress. 1.1

1/2/2019

Correspondence with co-counsel regarding document processing 

and review. 1.0

1/25/2019

Review documents produced by Defendant, and draft summary for 

co-counsel. 4.8

1/29/2019

Analysis of documents produced by defendants, and discussion with 

co-counsel. 1.5

2/1/2019

Review draft written discovery responses, and make note of 

potential edits. 2.1

2/4/2019 Call with ACLU of Ohio team regarding written discovery responses. 0.4

2/27/2019

Attention to settlement strategy, including review of pleadings and 

discussions with F. Levenson and E. Bonham. 1.3

3/21/2019 Team conference call discussing discovery strategy. 1.0

4/26/2019 Review draft discovery responses, and revise. 1.2

6/24/2019

Correspondence and discussion regarding strategy for supplemental 

authority. 0.4

7/3/2019

Review and analyze opposing expert's opinion, and correspond with 

co-counsel. 3.8

7/23/2019 Correspond with team regarding strategy for expert witness. 1.1

7/25/2019 Review draft expert report. 1.1

7/26/2019

Discussion with E. Bonham regarding case strategy, and legal 

research regarding deference issues. 1.8

8/8/2019

Discussion with co-counsel regarding strategy for discovery 

responses. 0.7

8/8/2019 Review discovery requests. 0.5

8/12/2019

Review discovery requests, make notes regarding potential 

objections, and discuss with co-counsel. 1.7

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-11 Filed: 02/01/21 Page: 3 of 4 PAGEID #: 3150
8/16/2019

Review draft deposition prep outline and send comments to E. 

Bonham. 0.9

8/18/2019

Review background materials, including complaint, discovery 

responses, and expert reports, in advance of witness prep session. 3.5

8/18/2019 Deposition prep for S. Ray. 3.5

8/19/2019 Attend and assist in defending deposition of S. Ray. 4.0

9/12/2019 Review and analyze order denying motion to dismiss. 2.4

9/27/2019 Read defendant's Answer. 1.2

10/14/2019

Correspondence with co-counsel regarding procedures for 

designating and sealing confidential material, and related strategy 

matters. 2.8

11/4/2019

Discussions with co-counsel regarding briefing strategy for summary 

judgment. 1.1

1/8/2020 Review and revise draft summary judgment motion. 3.8

1/8/2020 Call with E. Bonham discussing strategy for summary judgment. 0.7

Total Time 82.1

Hourly Rate x $ 375.00

Lodestar Fees $ 30,787.50

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-11 Filed: 02/01/21 Page: 4 of 4 PAGEID #: 3151