Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS’ FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Annick M. Persinger (SBN 272996) 

Apersinger@tzlegal.com 

TYCKO AND ZAVAREEI LLP 

10880 Wilshire Blvd., Suite 1101 

Los Angeles, CA 90024 

(510)254-6808 

Attorneys for Plaintiffs and the Class 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

JUAN QUINTANILLA VASQUEZ, 

GABRIELA PERDOMO ORTIZ, VICTOR 

HUGO CATALAN MOLINA, and KEVIN 

CALDERON, individually and on behalf of all 

others similarly situated, 

 Plaintiffs, 

 v. 

LIBRE BY NEXUS, INC. and JOHN DOES 

1-50, 

 Defendants. 

Case No. 4:17-cv-00755-CW

DECLARATION OF ANNICK M. 

PERSINGER IN SUPPORT OF 

PLAINTIFFS’ FEE, EXPENSE, AND 

SERVICE AWARD APPLICATION 

Judge: Hon. Claudia Wilken 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 1 of 30
Page 1 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

I, Annick M. Persinger, declare: 

1. I am an attorney admitted to practice before all Courts of the State of California, and 

counsel of record for Plaintiffs and the Class in this case. I have personal knowledge of all of the 

facts set forth in this Declaration unless otherwise stated, and I am competent to testify to these 

facts if called on to do so. 

TYCKO & ZAVAREEI LLP 

2. Tycko & Zavareei LLP was founded in 2002 and has established a long and 

successful record of litigating complex cases. With offices in Washington, DC, Oakland, CA, and 

Los Angeles, CA our lawyers routinely handle large and complex matters throughout the country. 

Our lawyers have achieved remarkable results through trials and settlements in landmark cases of 

great public interest. Our settlements have netted our clients hundreds of millions of dollars in 

monetary relief, and changes in practices by banks and other businesses that have real impacts on 

the day to day lives of our clients. 

3. Tycko & Zavareei has also been named Class Counsel, Lead Counsel, or Settlement 

Class Counsel in consumer class actions styled Kumar v. Safeway, Inc. et al., RG14726707 (Super. Ct. of 

Cal. Cty. of Alameda); Kumar v. Salov North America Corp., et al., 4:14-cv-02411 (N.D. Cal.); Koller v. 

Deoleo USA, Inc., Case No. 3:14-CV-02400-RS (N.D. Cal.); Shannon Schulte, et al. v. Fifth Third Bank, 

No. 1:09-cv-06655 (N.D. Ill.); Kelly Mathena v. Webster Bank, No. 3:10-cv-01448 (D. Conn.); Nick 

Allen, et al. v. UMB Bank, N.A., et al., No. 1016 Civ. 34791 (Cir. Ct. Jackson County, Mo.); Thomas 

Casto, et al. v. City National Bank, N.A., 10 Civ. 01089 (Cir. Ct. Kanawha County, W. Va.); Eaton v. 

Bank of Oklahoma, N.A., and BOK Financial Corporation, d/b/a Bank of Oklahoma, N.A., No. CJ-2010-

5209 (Dist. Ct. for Tulsa County, Okla.); Lodley and Tehani Taulva, et al., v. Bank of Hawaii and Doe 

Defendants 1-50, No. 11-1-0337-02 (Cir. Ct. of 1st Cir., Haw.); Jessica Duval, et al. v. Citizens Financial 

Group, Inc., et al, No. 1:10-cv-21080 (S.D. Fla.); Mascaro, et al. v. TD Bank, Inc., No. 10-cv-21117 (S.D. 

Fla.); Theresa Molina, et al., v. Intrust Bank, N.A., No. 10-cv-3686 (18th Judicial Dist., Dist. Ct. 

Sedgwick County, Kan.); Trombley v. National City Bank, 1:10-cv-00232-JDB (D.D.C.); Jonathan Jones, 

et al. v. United Bank and United Bankshares, Inc., No. 11-C-50 (Cir. Ct. of Jackson County, W. Va.); 

Amber Hawthorne, et al. v. Umpqua Bank, No. 4:11-cv-06700 (N.D. Cal.); Sylvia Hawkins, et al. v. First 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 2 of 30
Page 2 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Tennessee Bank, N.A., No. CT-004085-11 (Cir. Ct. of Shelby County, Tenn.); Jane Simpson, et al. v. 

Citizens Bank, et al., No. 2:12-cv-10267 (E.D. Mich.); Alfonse Forgione, et al. v. Webster Bank, N.A., No. 

UWY-CV12-6015956-S (Super. Ct. Judicial Dist. of Waterbury, Conn.); Sherry Bodnar v. Bank of 

America, N.A., No. 5:14-cv-03224-EGS (E.D. Pa.); Wong v. TrueBeginnings LLC d/b/a True.com, No. 3-

07 Civ. 1244-N (N.D. Tex.); Geis v. Airborne Health, et. al., Civil Action No. 2:07 Civ. 4238-KSH-PS 

(D. N.J.); Dennings, et al. v. Clearwire Corporation, No. 2:10-cv-01859 (W.D. Wash.); In Re: Higher One 

Oneaccount Marketing And Sales Practices Litigation, No. 3:12-md-02407 (VLB) (D. Conn.); Galdamez v. 

I.Q. Data International, Inc., No. 15-cv-1605 (E.D. Va.); Brown v. Transurban USA, No. 15-cv-494 (E.D. 

Va.), Gatinella et al. v. Michael Kors (USA), 14-cv-5731 (S.D.N.Y); Grayson, et al. v. General Electric 

Company, 3:13-cv-1799 (D. Conn.); Farrell, et al. v. Bank of America, N.A., No. 3:16-00492 (S.D. Cal.); 

In re: APA Assessment Fee Litigation, 1:10-cv-01780 (D.D.C.); Griffith v. ContextMedia Health, LLC 

d/b/a Outcome Health, No. 1:16-cv-02900 (N.D. Ill.); Scott, et al. v. JPMorgan Chase & Co., No. 17-cv249 (D.D.C.); In re Think Finance, LLC, et al., No. 17-bk-33964 (Bankr. N.D. Tex.); Gibbs v. Plain 

Green, LLC, No. 3:17-cv-495 (E.D. Va.); Meta v. Target Corp., et al., No. 14-cv-0832 (N.D. Ohio); and 

Petit v. Procter & Gamble Co., No. 15-cv-02150 (N.D. Cal.). Each of these actions has resulted in a 

settlement that has been finally approved. 

EXPERIENCE 

4. Since graduating magna cum laude from U.C. Hastings College of the Law in 2010, I 

have practiced complex litigation in California. I have been managing partner of Tycko & Zavareei’s 

California offices since 2018, and have been recognized as a Super Lawyers Rising Star. Prior to 

joining Tycko & Zavareei, I worked as a litigation associate for Bursor & Fisher, P.A. Like Tycko & 

Zavareei, Bursor & Fisher, P.A. specializes in consumer class action litigation and has been named 

class counsel countless times in state and district courts in California and nationwide. After law 

school, I worked as a legal research attorney for the Hon. John E. Munter in complex litigation, at 

the San Francisco Superior Court. 

5. Representative cases that I have been named class counsel in include: Stathakos v. 

Columbia Sportswear Co., 2017 WL 195706 (N.D. Cal. May 11, 2017) (certifying a class of discount 

clothing shoppers), Melgar v. Zicam, LLC, 2016 WL 1267870 (E.D. Cal. Mar. 31, 2016) (certifying a 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 3 of 30
Page 3 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

class of purchasers of Zicam cold medicine), Dei Rossi v. Whirlpool Corp, 2015 WL 1932484 (E.D. Cal. 

Apr. 28, 2015) (certifying a class of refrigerator purchasers), Forcellati v. Hyland’s, 2013 WL 12121973 

(C.D. Cal. Dec. 19, 2013) (certifying a class of purchasers of homeopathic products marketed for 

children). 

6. My partner, Hassan Zavareei, also worked on this case. Mr. Zavareei graduated from 

the University of California, Berkeley, School of Law in 1995. Prior to that, Mr. Zavareei graduated 

from Duke University in 1990. Mr. Zavareei is admitted to practice in California (Bar No. 181547), 

the District of Columbia (Bar No. 456161), and Maryland (Registration No. 0207150001). Over the 

past twenty-one years, Mr. Zavareei has gained substantial experience handling complex civil 

litigation and class action litigation. He has taken several cases to trial, including jury trials that have 

lasted several months. He has argued appeals in the D.C. Circuit, the Fourth Circuit and the Fifth 

Circuit. Mr. Zavareei has been appointed as Class Counsel in numerous class actions. 

7. My partner, Jonathan Tycko, also worked on this case. Mr. Tycko graduated from 

the Columbia University Law School in 1992. Prior to that, Mr. Tycko graduated from Johns 

Hopkins University in 1989. Mr. Tycko is admitted to practice in the District of Columbia (Bar No. 

445851), New York (Bar No. 2568483), and Maryland (Registration No. 0203260001). 

8. An associate at my law firm, Katherine M. Aizpuru, also worked on this case. Ms. 

Aizpuru graduated cum laude from Harvard Law School in 2014. Ms. Aizpuru completed clerkships 

on the District of Columbia Court of Appeals and the United States District Court of the District of 

Maryland. Since joining Tycko & Zavareei in 2017, she has handled complex civil litigation, 

including numerous class actions. She was named a Rising Star for the Washington, D.C. region in 

2020. 

9. A fellow at my office, Jennifer Thelusma, also worked on this case. Ms. Thelusma 

graduated from Duke University School of Law in 2019. Prior to that, Ms. Thelusma graduated 

from the University of Florida in 2016. Ms. Thelusma is admitted to practice in Florida (Bar No. 

1019776). 

10. Kristen Law Sagafi, a former partner at my law firm, also worked on this case. After 

litigating consumer class actions for over a decade, Ms. Sagafi now teaches complex litigation at 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 4 of 30
Page 4 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Berkeley Law School. Ms. Sagafi graduated from University of California, Berkeley School of Law in 

2002 and started Tycko & Zavareei’s California branch after she spent years as a partner at Lieff 

Cabraser Heimann & Bernstein, LLP. 

11. Prior to starting his own firm, Kaliel PLLC, Jeffrey D. Kaliel also worked on this 

case. Mr. Kaliel earned his law degree from Yale Law School in 2005. He graduated from Amherst 

College summa cum laude in 2000 with a degree in Political Science, and spent one year studying 

Philosophy at Cambridge University, England. Over the last 10 years, Mr. Kaliel has built substantial 

class action experience. He has received “Washington D.C. Rising Stars Super Lawyers 2015” 

recognition. Mr. Kaliel has been appointed lead Class Counsel in numerous nationwide and statespecific class actions. 

12. Sophia (Goren) Gold, a former associate of Tycko & Zavareei, also worked on this 

case. Ms. Goren Gold is a third-generation Plaintiffs’ lawyer. A summa cum laude graduate of 

Wake Forest University and the University of California, Berkeley, School of Law in 2015, Ms. 

Goren Gold is now partnered with Jeffrey Kaliel at PLLC. 

13. Maren Christensen, a former associate of Tycko & Zavareei, also worked on this 

case. Ms. Christensen graduated from Berkeley Law, with distinction, in 2013, and from the 

University of Chicago, with honors, in 2006. Prior to joining Tycko and Zavareei Ms. Christensen, 

worked on a wide range of civil litigation, international arbitration, employment law matters, qui tam 

lawsuits and government enforcement investigations, as well as pro bono immigration matters. 

14. Tanya Koshy, a former associate of Tycko & Zavareei, also worked on this case. Ms. 

Koshy graduated from University of California, Berkeley School of Law in 2010. Prior to joining the 

firm, Ms. Koshy was a staff attorney at the Ninth Circuit Court of Appeals. Ms. Koshy is a member 

of the California, Massachusetts, and New York state bars. 

ATTORNEYS’ FEES AND COSTS 

15. Tycko & Zavareei started working on this case in 2017 when it investigated and filed 

the original complaint in this matter. 

16. In 2017, Tycko & Zavareei prepared a 26(f) report, filed ADR forms, researched 

insurance code claims, researched Libre’s arbitration defense, drafted initial disclosures, prepared 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 5 of 30
Page 5 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

written discovery, prepared responses to written discovery, and worked with opposing counsel to 

file a protective order. Lawyers from Tycko & Zavareei also conducted research to refine Plaintiffs’ 

legal theories and drafted the original, first, and second amended complaints. 

17. Tycko & Zavareei also met with all of the Plaintiffs, as well as their sponsors, who 

were also deposed. Lawyers from Tycko & Zavareei defended all of the Plaintiffs’ depositions in this 

case. I also defended the depositions of all of Plaintiffs’ program sponsors—including Plaintiff 

Calderon. Lawyers from Tycko & Zavareei also prepared for and took a Fed. R. Civ. P. 30(b)(6) 

deposition. 

18. Tycko & Zavareei drafted multiple briefs in this case that lead to successful results, 

and eventually to the instant settlement. For example, Tycko & Zavareei drafted an opposition to 

Libre’s motion to dismiss, an opposition to Libre’s motion to compel arbitration, an opposition to a 

Rule 11 motion, an opposition to Libre’s motion to stay, a motion for leave to amend, a reply in 

support of leave to amend, and a motion for administrative relief. Tycko & Zavareei also appeared 

and argued at the hearing on Libre’s motion to dismiss, and motion to compel arbitration. 

19. Tycko & Zavareei worked hard on settlement. Tycko & Zavareei drafted mediation 

statements, participated in multiple in person meetings with defense counsel, and participated in six 

mediations. In addition, Tycko & Zavareei appeared at regular conferences with Ninth Circuit 

mediators following this Court’s denial of Libre’s motion to compel arbitration. Tycko & Zavareei 

also regularly conferred with opposing counsel to resolve discovery issues, to discuss settlement, and 

to coordinate the drafting of the settlement agreement, as well as the papers filed in support of 

preliminary approval. 

20. Tycko & Zavareei drafted the first draft of the settlement agreement preliminarily 

approved by the Court, as well as the first draft of the notices and proposed orders in connection 

with settlement approval. Tycko & Zavareei then worked to confer and revise the foregoing until in 

final form. Tycko & Zavareei worked on the motion for preliminary approval, and drafted the 

motion for leave to file the motion for leave to amend that was filed along with the motion for 

preliminary approval. I then prepared for and appeared at the hearing on preliminary approval. 

Tycko & Zavareei then worked on preparing a supplemental submission to the Court, which led to 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 6 of 30
Page 6 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

the Court’s decision to preliminarily approve the settlement in this action. 

21. In addition to the work discussed above, lawyers from Tycko & Zavareei drafted 

countless stipulations, notices, and joint reports to the Court. 

22. Tycko & Zavareei provided the support staff for this litigation. Nathan LaPorte, 

Audrey Abate, and Chloe Hyunji Noh served as Tycko & Zavareei’s legal assistants, and they, along 

with Tycko & Zavareei’s paralegal, Collin Hoover, all worked on this case. Tycko & Zavareei’s 

support staff finalized, formatted, and filed stipulations, joint statements, complaints, motions, 

oppositions and more. Tycko & Zavareei’s staff served discovery, as well as responses to discovery. 

Additionally, Tycko & Zavareei’s staff kept the case calendar to support counsel in meeting all 

deadlines. Further, Tycko & Zavareei’s staff arranged court reporters, arranged meeting spaces and 

travel for Plaintiffs’ deposition prep meetings, arranged Plaintiffs’ depositions, and arranged the 

30(b)(6) deposition that a Tycko & Zavareei lawyer took. 

23. We tracked our hours spent on this case using attorney billing software. All staff 

contemporaneously recorded the time they spent working on this case. For each task performed, 

staff accounted for their time in 1/10th of an hour (6-minute) increments or shorter, and included a 

brief narrative description of the work performed. Staff did not “block bill.” 

24. I generated a report summarizing each staff member’s billable time spent on this case 

through August 31, 2020. 

25. I reviewed the time entries, and believe the hours expended were reasonable and 

necessary to securing the result in this case. I also exercised billing judgment by excluding, for 

example, time that Tycko & Zavareei’s lawyers spent traveling to hearings, depositions, and client 

preps. 

26. To avoid unnecessary public disclosures, I redacted certain entries to state only “fact 

investigation” or “consultation” for entries that referenced, for instance, interviews with unnamed 

Class Members or consultations with non-parties. 

27. I have attached a true and correct copy of the time entries as Exhibit A. 

28. The following table represents the time spent by Tycko & Zavareei’s lawyers and 

staff on this case through August 31, 2020, with a total lodestar value of $645,316.50.

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 7 of 30
Page 7 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

The above chart was prepared from contemporaneous detailed daily time records regularly 

prepared and maintained by Tycko & Zavareei utilizing timekeeping software to which all employees 

have access. In my opinion, the time spent by attorneys and staff of Tycko & Zavareei was reasonable 

and necessary. Indeed, by prosecuting this case purely on a contingency basis and not being paid by 

the hour, Tycko & Zavareei attorneys and staff worked efficiently and avoided unnecessary work. The 

hourly rates are based on the typical hourly rates for lawyers of similar experience in the communities 

in which Class Counsel practice. 

32. The hourly rates shown for the attorneys at Tycko & Zavareei are our 2020 rates 

charged as delineated by the Adjusted Laffey Matrix (http://www.laffeymatrix.com/), which provides 

market rates for attorneys working in the Washington, D.C. area. See, e.g., DL v. Dist. of Columbia, 924 

F.3d 585 (D.C. Cir. 2019) (discussing the history and basis of the Laffey matrix). Although the 

Adjusted Laffey Matrix is updated annually, courts have awarded attorneys’ fees consistent with the 

Adjusted Laffey Matrix to my firm in a number of cases. See, e.g., Kumar v. Salov North America Corp., 

Name Title Hours Rate Lodestar 

Annick Persinger Partner 553.70 $759.00 $420,258.30 

Audrey Abate Legal Assistant 18.10 $206 $3,728.60 

Chloe Hyunji Noh Legal Assistant 82.50 $206 $16,995.00 

Collin Hoover Paralegal 31.30 $206 $6,447.80 

Hassan Zavareei Partner 4.70 $914 $4,295.80 

Jeffrey Kaliel Partner 110.80 $759.00 $84,097.20 

Jennifer Thelusma Fellow 7.40 $378.00 $2,797.20 

Jonathan Tycko Partner 2.50 $914 $2,285.00 

Katherine Aizpuru Associate 2.60 $465 $1,209 

Kristen Sagafi Partner 32.10 $759 $24,363.90 

Maren Christensen Associate 59.10 $672 $39,715.20 

Nathan Laporte Legal Assistant 14.10 $206 $2,904.60 

Sophia Gold Associate 77.90 $465 $36,223.50 

Total Hours / Lodestar 996.8 $645,316.5 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 8 of 30
Page 8 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

No. 14-CV-2411-YGR, 2017 WL 2902898 (N.D. Cal. July 7, 2017); Stathakos v. Columbia Sportswear Co., 

No. 15-CV-04543-YGR, 2018 WL 1710075, at *6 (N.D. Cal. Apr. 9, 2018); Meta v. Target Corp., et al., 

No. 14-cv-0832 (N.D. Ohio Aug. 7, 2018), Dkt. 179; In re Think Finance, LLC, et al., No. 17-bk33964 (Bankr. N.D. Tex.); Brown v. Transurban USA, Inc., No. 1:15CV494 (JCC/MSN), 2016 WL 

6909683 (E.D. Va. Sept. 29, 2016); Small v. BOKF, N.A., No. 1:13-cv-01125-REB-MJW (D. Colo.); 

Soule v. Hilton Worldwide, Inc., No. CV 13-00652 ACK-RLP, 2015 WL 12827769 (D. Haw. Aug. 25, 

2015); Beck v. Test Masters Educ. Servs., Inc., 73 F. Supp. 3d 12 (D.D.C. 2014); see also Mancini v. Dan P. 

Plute, Inc., 358 F. App’x 886 (9th Cir. 2009); Harris et al. v. Farmers Insurance Exchange et al., BC579498

(Cal. Super. Ct., L.A. Cty. Aug. 30, 2020) (accepting Adjusted Laffey Matrix as evidence of reasonable 

hourly rates charged by Washington, D.C. attorneys). 

34. The total number of hours is based only on the hours reasonably expended to achieve 

an excellent result for the Settlement Class. Our firm coordinated our efforts in the litigation of this 

case with our co-counsel to ensure that there was no duplicative or unnecessary work. Because our 

firm is experienced in litigating actions of this type, we were able to efficiently divide tasks based on 

expertise. 

35. In my opinion, the time expended and expenses incurred in prosecuting this action 

were reasonable and necessary for the diligent litigation and fair resolution of this matter. The lodestar 

reflected in the above extract does not include all of the time to be devoted to preparing for and 

appearing at the final approval hearing, or dealing with post-hearing matters. 

29. I anticipate that Tycko & Zavareei LLP will devote substantial additional time to this 

case after August 31, 2020, including: (1) finalizing this application; (2) preparing for and attending the 

final approval hearing; (3) monitoring the claims and distribution process; corresponding with the 

claims administrator; (4) managing the extended payment plan; (5) ensuring compliance with the 

injunctive relief; and (6) responding to Class Member inquiries. 

30. Tycko & Zavareei also carried the majority of the costs in this litigation—taking on this 

risk for the putative class members. Specifically. Tycko & Zavareei incurred $45,146.63 in 

unreimbursed case-related expenses, including expenses related to filing, travel, copying, and case 

administration. Expenses are accounted for and billed separately and are not duplicated in my firm’s 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 9 of 30
Page 9 of 9 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW 

PERSINGER DECL. ISO PLAINTIFFS FEE, EXPENSE, AND SERVICE AWARD APPLICATION 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

professional billing rate. TZ has not received reimbursement for expenses incurred in connection 

with this litigation. The actual expenses incurred in the prosecution of this case is reflected on the 

computerized accounting records of my firm prepared by bookkeeping staff, based on receipts and 

check records, and accurately reflect all actual expenses incurred. These expenses were necessary to 

prosecuting litigation of this size and complexity on behalf of the Settlement Class, and they are 

typical of expenses regularly awarded in large-scale class actions. Indeed, because Tycko & Zavareei 

was responsible for advancing all expenses incurred, Tycko & Zavareei had a strong incentive not to 

spend any funds unnecessarily. An itemized list of Tycko & Zavareei’s expenses is attached hereto as 

Exhibit B. 

I declare under penalty of perjury under the laws of California that the foregoing is true and 

correct, and that this declaration was executed in Los Angeles, California, on September 1, 2020. 

 _____________________________ 

 Annick M. Persinger 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 10 of 30
EXHIBIT A

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 11 of 30
03/14/17 Studied case file, and researched applicable law. Annick Persinger 6.30 $759.00 $4,781.70

03/16/17 File declination with AEA. Annick Persinger 0.40 $759.00 $303.60

03/21/17 Conference with KLS regarding case theory, strategy. Annick Persinger 0.60 $759.00 $455.40

03/21/17 Conference with KLS re: case theory. Annick Persinger 0.30 $759.00 $227.70

03/28/17 Conference with KLS re: Libre complaint and 23(g) motion. Annick Persinger 0.60 $759.00 $455.40

03/28/17 Revise first amended complaint. Annick Persinger 2.20 $759.00 $1,669.80

05/01/17 Work on ADR forms, and emails with JK re: same. Annick Persinger 0.90 $759.00 $683.10

05/02/17 Work on finalizing ADR forms. Annick Persinger 0.30 $759.00 $227.70

05/02/17 Work on making additions to, revising, and finalizing Libre complaint. Annick Persinger 3.70 $759.00 $2,808.30

05/03/17 Review final complaint documents. Annick Persinger 1.20 $759.00 $910.80

05/12/17 Work on 26(f) report. Annick Persinger 1.60 $759.00 $1,214.40

05/12/17 Research insurance code claims. Annick Persinger 4.10 $759.00 $3,111.90

05/16/17 26(f) conference. Annick Persinger 0.40 $759.00 $303.60

05/16/17 Discuss case strategy with KLS. Annick Persinger 0.60 $759.00 $455.40

05/16/17 Work on finalizing and filing 26(f) report. Annick Persinger 2.50 $759.00 $1,897.50

05/17/17 Strategy email to JK. Annick Persinger 0.90 $759.00 $683.10

05/17/17 Review recent case law re: arbitration and injunctive relief. Annick Persinger 1.20 $759.00 $910.80

05/17/17 Work on lead counsel motion. Annick Persinger 1.10 $759.00 $834.90

05/17/17 Conference with KLS. Annick Persinger 1.60 $759.00 $1,214.40

05/18/17 Call with JK. Annick Persinger 0.50 $759.00 $379.50

05/22/17 Follow up with opposing counsel re: motion to compel arbitration schedule. Annick Persinger 0.20 $759.00 $151.80

05/23/17 Conference with JK re: case strategy and eliminating claims. Annick Persinger 0.70 $759.00 $531.30

05/23/17 Review joint statement and other material and attend initial conference. Annick Persinger 1.90 $759.00 $1,442.10

05/24/17 Research for amending complaint. Annick Persinger 3.90 $759.00 $2,960.10

05/25/17 Draft amended complaint. Annick Persinger 8.40 $759.00 $6,375.60

05/26/17

Incorporate co‐counsel changes to the complaint, finalize and send to

defendant. Annick Persinger 5.50 $759.00 $4,174.50

05/26/17 Conference call with co‐counsel re: amended complaint. Annick Persinger 0.50 $759.00 $379.50

05/30/17 Email from opposing counsel re: amendment, and emails with JK re: same. Annick Persinger 0.30 $759.00 $227.70

05/30/17 Review complaint for reliance allegations, emails with JK re: same. Annick Persinger 0.90 $759.00 $683.10

05/30/17 Review final amended discovery responses and send changes. Annick Persinger 1.10 $759.00 $834.90

06/01/17 Draft stip and proposed order re: SAC. Annick Persinger 1.50 $759.00 $1,138.50

06/02/17 Finalize and send stip to opposing counsel. Annick Persinger 0.40 $759.00 $303.60

06/07/17 Review discovery requests. Annick Persinger 0.60 $759.00 $455.40

06/07/17 Conference with KLS re: upcoming work assignments. Annick Persinger 0.40 $759.00 $303.60

06/09/17 Work with NL to file SAC. Annick Persinger 0.30 $759.00 $227.70

06/12/17 Initial disclosures. Annick Persinger 2.50 $759.00 $1,897.50

06/12/17 Fact investigation. Annick Persinger 0.30 $759.00 $227.70

06/13/17 Review protective order. Annick Persinger 0.30 $759.00 $227.70

06/13/17 Finalize initial disclosures. Annick Persinger 0.40 $759.00 $303.60

06/14/17 Email memo to JK re: plaintiff depos. Annick Persinger 0.50 $759.00 $379.50

06/14/17 Review email correspondence from centro regarding third‐party depos. Annick Persinger 0.20 $759.00 $151.80

06/21/17 Conference with JK and SJG re: depo scheduling. Annick Persinger 0.50 $759.00 $379.50

06/21/17 Review co‐counsel's research re: foreign language and arbitration. Annick Persinger 0.80 $759.00 $607.20

06/21/17 Emails with co‐counsel re: depo scheduling. Annick Persinger 0.30 $759.00 $227.70

06/23/17 Work on scheduling depo preps with co‐counsel, calendaring same. Annick Persinger 0.60 $759.00 $455.40

06/26/17 Review Rule 11 motion and research re: same. Annick Persinger 2.50 $759.00 $1,897.50

06/26/17 Make sure depo dates calendared. Annick Persinger 0.20 $759.00 $151.80

06/27/17 Draft plaintiff prep outline, review case docs for same. Annick Persinger 2.60 $759.00 $1,973.40

06/27/17 Call with JK and SJG re: Rule 11 motion. Annick Persinger 0.20 $759.00 $151.80

06/28/17 Pre‐prep call with co‐counsel. Annick Persinger 0.60 $759.00 $455.40

06/28/17 Prep call with Vasquez. Annick Persinger 1.40 $759.00 $1,062.60

06/29/17 Prep call with other two clients. Annick Persinger 2.00 $759.00 $1,518.00

07/05/17 Work on researching/drafting response to Rule 11 motion. Annick Persinger 7.10 $759.00 $5,388.90

07/06/17 Finish draft response to Rule 11 motion. Annick Persinger 2.40 $759.00 $1,821.60

07/07/17 Emails with JK re: fraudulent concealment. Annick Persinger 0.10 $759.00 $75.90

07/07/17 Add footnote based on SJG research re: bonds and FDCPA. Annick Persinger 0.30 $759.00 $227.70

07/10/17 Work on prep outline, review client docs for prep. Annick Persinger 2.70 $759.00 $2,049.30

07/10/17 Review final response to Rule 11 letter and circulate to co‐counsel. Annick Persinger 0.40 $759.00 $303.60

07/10/17 Deposition prep. Annick Persinger 4.40 $759.00 $3,339.60

07/11/17 Attend deposition. Annick Persinger 3.10 $759.00 $2,352.90

07/11/17 Work on opposition to motion to dismiss. Annick Persinger 5.10 $759.00 $3,870.90

07/11/17 Deposition prep of two clients. Annick Persinger 3.20 $759.00 $2,428.80

07/12/17 Attend deposition. Annick Persinger 3.90 $759.00 $2,960.10

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 12 of 30
07/12/17 Deposition prep of two clients. Annick Persinger 2.90 $759.00 $2,201.10

07/12/17 Continue drafting and researching opposition to motion to dismiss. Annick Persinger 4.20 $759.00 $3,187.80

07/13/17 Defend deposition. Annick Persinger 6.90 $759.00 $5,237.10

07/13/17

Settlement discussions with co‐counsel; settlement discussion with opposing

counsel; removal of client's ankle monitor. Annick Persinger 3.20 $759.00 $2,428.80

07/13/17 Client depo prep. Annick Persinger 1.00 $759.00 $759.00

07/14/17 Update Rule 11 letter to reflect filing of MTD. Annick Persinger 0.70 $759.00 $531.30

07/14/17

Review docs produced and complaint etc in advance of phone and in‐person

preps. Annick Persinger 1.20 $759.00 $910.80

07/14/17 Client prep calls x 3. Annick Persinger 2.60 $759.00 $1,973.40

07/16/17 Client (Norma) in‐person depo prep. Annick Persinger 1.90 $759.00 $1,442.10

07/17/17 Further research re: mediators. Annick Persinger 0.40 $759.00 $303.60

07/17/17 Review Norma docs. Annick Persinger 0.40 $759.00 $303.60

07/17/17 Email to Nate about briefing deadlines. Annick Persinger 0.20 $759.00 $151.80

07/17/17 Email co‐counsel re: update on Norma prep. Annick Persinger 0.40 $759.00 $303.60

07/18/17 ADR call. Annick Persinger 0.30 $759.00 $227.70

07/18/17 Depo. Annick Persinger 4.10 $759.00 $3,111.90

07/18/17 Client prep. Annick Persinger 3.10 $759.00 $2,352.90

07/18/17 Prep session. Annick Persinger 1.00 $759.00 $759.00

07/19/17 Prep session. Annick Persinger 1.00 $759.00 $759.00

07/19/17 Depo. Annick Persinger 4.20 $759.00 $3,187.80

07/24/17 Review deponent docs and deposition prep. Annick Persinger 1.70 $759.00 $1,290.30

07/25/17 Prep meeting and defend deposition. Annick Persinger 4.60 $759.00 $3,491.40

07/26/17 Coordinate sending plaintiffs checks to co‐counsel. Annick Persinger 0.10 $759.00 $75.90

07/26/17 Check in call with co‐counsel re: depos. settlement, case managers, etc. Annick Persinger 0.30 $759.00 $227.70

07/31/17 Finish draft opposition to MTD. Annick Persinger 6.50 $759.00 $4,933.50

08/01/17 Revise, finalize, and file opp to MTD. Annick Persinger 3.10 $759.00 $2,352.90

08/07/17 Review proposed stipulation. Annick Persinger 0.40 $759.00 $303.60

08/22/17 Put together template for mediation statement. Annick Persinger 0.50 $759.00 $379.50

08/22/17 Review docs and memo re: same. Annick Persinger 1.10 $759.00 $834.90

08/25/17 Review docs/materials for mediation statement, email co‐counsel re: same. Annick Persinger 0.50 $759.00 $379.50

08/29/17 Work on mediation statement. Annick Persinger 2.40 $759.00 $1,821.60

08/31/17 Review plaintiff depo transcripts and draft mediation statement. Annick Persinger 6.60 $759.00 $5,009.40

09/06/17 Review revised draft mediation statement. Annick Persinger 0.90 $759.00 $683.10

09/08/17 Review emails re: mediation status/changes. Annick Persinger 0.20 $759.00 $151.80

09/13/17 Look at mediation deadline issue. Annick Persinger 0.20 $759.00 $151.80

10/10/17 Mediation. Annick Persinger 8.10 $759.00 $6,147.90

11/12/17 Set up and calendar plaintiffs' counsel call. Annick Persinger 0.30 $759.00 $227.70

11/29/17 Review order on motion for protective order. Annick Persinger 0.40 $759.00 $303.60

12/12/17 Emails re setting up mediation. Annick Persinger 0.40 $759.00 $303.60

12/19/17 Coordinated settlement conference Annick Persinger 0.30 $759.00 $227.70

02/08/18 Call re settlement progress and related prep and research Annick Persinger 2.30 $759.00 $1,745.70

02/21/18 Team call re settlement and recission theory Annick Persinger 0.50 $759.00 $379.50

03/22/18

Reviewed case materials to prep for mediation (1.2); lunch meeting re

settlement strategy (0.9); call with KLS and HAZ re same (0.4) Annick Persinger 2.50 $759.00 $1,897.50

03/23/18 Additional correspondence re settlement strategy Annick Persinger 0.40 $759.00 $303.60

03/24/18 Correspondence with KLS and group re scheduling call Annick Persinger 0.40 $759.00 $303.60

03/26/18 Drafted Mediaton Statement Annick Persinger 6.10 $759.00 $4,629.90

03/27/18 Reviewed revised mediation statement Annick Persinger 0.50 $759.00 $379.50

03/27/18 Conference call re mediation Annick Persinger 0.90 $759.00 $683.10

03/29/18

Mediation, including arrived early to fix names on list and touch base with

mediator Annick Persinger 9.10 $759.00 $6,906.90

04/04/18 Calls with HAZ and KLS Annick Persinger 0.50 $759.00 $379.50

04/04/18 Memo to team re settlement Annick Persinger 0.80 $759.00 $607.20

04/10/18 Call with co‐counsel re settlement Annick Persinger 1.50 $759.00 $1,138.50

04/17/18

Responded to inquiries (0.8); call with team re continuing with litigation or

mediation (0.6); emails re same (0.4) Annick Persinger 1.80 $759.00 $1,366.20

06/04/18

Reviewed Rule 11 motion, reviewed motion to compel arb, ECF related to MTD,

calendared, started outlines Annick Persinger 3.20 $759.00 $2,428.80

06/05/18 Call regarding next steps and motion assignments, related prep Annick Persinger 0.90 $759.00 $683.10

06/11/18 Reviewed research/rough draft rule 11 motion and papers Annick Persinger 1.40 $759.00 $1,062.60

06/12/18 Work on Rule 11 Brief Annick Persinger 3.10 $759.00 $2,352.90

06/13/18 Worked on finalizing Rule 11 Brief Annick Persinger 3.10 $759.00 $2,352.90

06/16/18 Emails re motion to compel arbitration brief status and coordination Annick Persinger 0.30 $759.00 $227.70

06/17/18 Reviewed and revised motion to compel Annick Persinger 3.60 $759.00 $2,732.40

06/19/18 Work on finalizing opp to arbitration Annick Persinger 2.10 $759.00 $1,593.90

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 13 of 30
07/12/18 Emails re hearing coverage and emails to mediator Annick Persinger 0.30 $759.00 $227.70

08/14/18 Prep for oral argument Annick Persinger 7.40 $759.00 $5,616.60

09/04/18 Conferred with co‐counsel on issues related to amendment Annick Persinger 0.60 $759.00 $455.40

09/10/18 Worked on issues related to amending the Complaint Annick Persinger 0.60 $759.00 $455.40

09/20/18

Worked on drafting and revising discovery, reviewed plaintiffs' productions for

same (5.6); worked on schedule and sent emails re planning re experts (1.2) Annick Persinger 6.80 $759.00 $5,161.20

09/24/18 Finalized LBN discovery Annick Persinger 0.60 $759.00 $455.40

09/25/18 Researched ninth circuit requirements and deadlines Annick Persinger 0.70 $759.00 $531.30

09/26/18 Drafted mediation questionnaire and related work on LBN appeal Annick Persinger 3.10 $759.00 $2,352.90

09/26/18 Case meeting Annick Persinger 0.30 $759.00 $227.70

10/17/18 Call with co‐counsel re upcoming assignments Annick Persinger 0.30 $759.00 $227.70

10/19/18 Revised/drafted opposition to motion to stay Annick Persinger 5.10 $759.00 $3,870.90

10/24/18 Reviewed subpoenas Annick Persinger 0.50 $759.00 $379.50

10/25/18 Worked on TAC Annick Persinger 3.10 $759.00 $2,352.90

10/25/18 Worked on motion for administrative relief Annick Persinger 4.70 $759.00 $3,567.30

10/26/18

Continued work on motion for admin relief, and worked on motion for leave to

amend Annick Persinger 7.60 $759.00 $5,768.40

10/29/18 Worked on finalizing and filing motion for leave to amend Annick Persinger 3.40 $759.00 $2,580.60

11/05/18 Updated case calendar and strategized re upcoming deadlines Annick Persinger 1.10 $759.00 $834.90

11/05/18 Reviewed opposition to motion for admin relief Annick Persinger 0.70 $759.00 $531.30

11/05/18 Emails re mediation statement and new counsel Annick Persinger 0.60 $759.00 $455.40

11/07/18 Assessment conference and related prep Annick Persinger 2.50 $759.00 $1,897.50

11/07/18 Case meeting Annick Persinger 0.40 $759.00 $303.60

11/14/18

Researched issues related to insurance code and preemption of immigration

bonds Annick Persinger 4.30 $759.00 $3,263.70

11/15/18 Continued drafting reply and research re same Annick Persinger 6.10 $759.00 $4,629.90

11/15/18 Drafted reply ISO motion to amend Annick Persinger 6.80 $759.00 $5,161.20

11/19/18 Reviewed draft RJN and comments edits to reply ISO amend brief Annick Persinger 1.40 $759.00 $1,062.60

11/20/18 Reviewed settlement term sheet and revised, call with co‐counsel re same Annick Persinger 2.60 $759.00 $1,973.40

11/20/18 Reviewed order on admin relief Annick Persinger 0.40 $759.00 $303.60

11/20/18 Finalized and filed reply and RJN Annick Persinger 2.60 $759.00 $1,973.40

12/10/18 Reviewed proposed settlement and edits Annick Persinger 1.80 $759.00 $1,366.20

12/11/18 Prep for call re settlement conference, and review of proposal and analysis Annick Persinger 4.30 $759.00 $3,263.70

12/12/18 Settlement conference and related updates to team Annick Persinger 9.20 $759.00 $6,982.80

12/13/18

Reviewed Rathod notes from settlement meeting (0.5); discussed issues with

HAZ (0.5); call with mediator (0.5) Annick Persinger 1.50 $759.00 $1,138.50

12/17/18 Work related to settlement and stay action Annick Persinger 1.40 $759.00 $1,062.60

12/20/18 Work related to settlement and stay action Annick Persinger 0.80 $759.00 $607.20

01/07/19 Work on term sheet and call with team re same Annick Persinger 2.40 $759.00 $1,821.60

01/08/19 Researched claims related co‐sponsors Annick Persinger 1.80 $759.00 $1,366.20

01/11/19 Settlement call Annick Persinger 2.10 $759.00 $1,593.90

01/24/19 Mediator call and prep Annick Persinger 1.20 $759.00 $910.80

02/04/19 Fact investiagtion (0.5); conferring with team re same (0.6). Annick Persinger 1.10 $759.00 $834.90

02/06/19 Fact investigation (0.5); emailing team re same (0.2); Fact investigation (0.6). Annick Persinger 1.30 $759.00 $986.70

02/08/19 Providing status report to ninth circuit mediator. Annick Persinger 0.30 $759.00 $227.70

02/11/19 Fact investigation. Annick Persinger 0.50 $759.00 $379.50

02/14/19 Working on settlement. Annick Persinger 1.90 $759.00 $1,442.10

02/15/19

Reviewing current draft of term sheet (1.2) Worked on scheduling for meeting

re settlement and schedule in case (0.3); call with Co‐counsel re status of

settlement and LBN's changes (0.9). Annick Persinger 2.40 $759.00 $1,821.60

02/27/19 Reviewing subpoena and coordinating service to LBN with co‐counsel. Annick Persinger 0.80 $759.00 $607.20

03/01/19

Call with co‐counsel re sending changes to settlement term sheet to OC (0.5);

emails re counter (0.2) Annick Persinger 0.70 $759.00 $531.30

03/05/19 Coordinating mediation and mediation briefing. Annick Persinger 0.40 $759.00 $303.60

03/07/19 Outlining mediation brief. Annick Persinger 1.50 $759.00 $1,138.50

03/11/19 Working on draft mediation statement. Annick Persinger 5.60 $759.00 $4,250.40

03/11/19 Research and put together exhibits for Mediaiton Statement Annick Persinger 2.00 $759.00 $1,518.00

03/13/19 Fact invesetigation. Annick Persinger 0.70 $759.00 $531.30

03/14/19

Reviewing status with term sheet and mediation statement to prep for

mediation. Annick Persinger 1.80 $759.00 $1,366.20

03/15/19 Mediation. Annick Persinger 7.60 $759.00 $5,768.40

03/22/19 Reviewing updates re term sheet and negotiations with OC. Annick Persinger 0.70 $759.00 $531.30

03/25/19 Fact investigation. Annick Persinger 1.20 $759.00 $910.80

03/28/19 Reviewing defendant draft . Annick Persinger 0.80 $759.00 $607.20

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 14 of 30
03/29/19

Conferring with co‐counsel regarding D's proposal (0.7); reviewing and

conferring related follow up from OC (0.6). Annick Persinger 0.70 $759.00 $531.30

04/02/19 Fact investigation. Annick Persinger 0.60 $759.00 $455.40

04/09/19 Fact investigation. Annick Persinger 0.80 $759.00 $607.20

04/14/19

Reviewing, revising, and commenting on Centro's latest revisions to terms sheet

(1.4); emailing group re fact investigation (0.4). Annick Persinger 1.80 $759.00 $1,366.20

04/15/19 Reviewing Centro additions to term sheet per my suggestions. Annick Persinger 0.50 $759.00 $379.50

04/16/19

Revising term sheet and cover email (0.3); conferring with Centro re fact

investigation (0.2). Annick Persinger 0.50 $759.00 $379.50

04/16/19 Reviewing calendar and analyzing case status. Annick Persinger 0.30 $759.00 $227.70

04/17/19 Responding to term sheet. Annick Persinger 0.50 $759.00 $379.50

04/17/19 Fact investigation. Annick Persinger 1.80 $759.00 $1,366.20

04/24/19 Working on issues related to outstanding. Annick Persinger 0.70 $759.00 $531.30

05/31/19

Reviewing current term sheet etc for settlement call (0.7); Settlement call (0.5);

call afterward with co‐counsel (0.5); updating case status sheet and calendar

(0.5). Annick Persinger 2.20 $759.00 $1,669.80

06/21/19 Coordinating mediation. Annick Persinger 0.40 $759.00 $303.60

06/26/19 Gathering information for mediator. Annick Persinger 0.60 $759.00 $455.40

07/01/19 Emailing Ninth Circuit mediator. Annick Persinger 0.20 $759.00 $151.80

07/30/19 Conferring with OC re settlement proposal. Annick Persinger 0.90 $759.00 $683.10

08/06/19 Conferring with co‐counsel re settlement proposal. Annick Persinger 0.50 $759.00 $379.50

08/07/19 Reviewing draft mediation statement. Annick Persinger 3.30 $759.00 $2,504.70

08/08/19 Reviewing to finalize of LBN statement. Annick Persinger 2.60 $759.00 $1,973.40

08/09/19

Discussing with HAZ (0.3); emailing with J. Sperber (0.2); emailing with co‐

counsel (0.2). Annick Persinger 0.70 $759.00 $531.30

08/11/19

Conferring with team regarding settlement, upcoming mediation, and

information from LBN about some other case we did not know about. Annick Persinger 1.30 $759.00 $986.70

08/13/19 Discussing term sheet with team. Annick Persinger 0.70 $759.00 $531.30

08/13/19 Discussing upcoming mediation with J. Sperber. Annick Persinger 0.50 $759.00 $379.50

08/15/19 Studying D's submission and term sheet, comparing ours. Annick Persinger 3.10 $759.00 $2,352.90

08/16/19 Attending mediation. Annick Persinger 8.50 $759.00 $6,451.50

08/29/19 Internal call to discuss terms, conferring with co‐counsel as well. Annick Persinger 2.60 $759.00 $1,973.40

08/30/19

Working on settlement and reviewing memos re same, discussing same with

HAZ and MC, discussing same with co‐counsel. Annick Persinger 2.70 $759.00 $2,049.30

09/03/19 Preparing for mediation. Annick Persinger 4.60 $759.00 $3,491.40

09/04/19 Mediation. Annick Persinger 9.20 $759.00 $6,982.80

09/05/19 Reviewing and checking final term sheet. Annick Persinger 0.70 $759.00 $531.30

09/11/19 Conferring with CA team. Annick Persinger 0.40 $759.00 $303.60

09/16/19 Reviwing draft agreement. Annick Persinger 1.10 $759.00 $834.90

09/18/19 Conferring with CA team. Annick Persinger 0.40 $759.00 $303.60

09/18/19 Drafting agreement. Annick Persinger 4.60 $759.00 $3,491.40

09/23/19 Drafting settlement agreement. Annick Persinger 6.10 $759.00 $4,629.90

09/26/19 Reviewing Calderon retainer agreement and sending revisions. Annick Persinger 0.90 $759.00 $683.10

09/30/19 Reviewing stip. Annick Persinger 0.60 $759.00 $455.40

10/02/19 Perparing proposal for call re notice (0.7); call re notice with OC (0.5). Annick Persinger 1.30 $759.00 $986.70

10/07/19 Drafting settlement agreement. Annick Persinger 7.20 $759.00 $5,464.80

11/01/19 Reviewing revisions to settlement agreement. Annick Persinger 0.90 $759.00 $683.10

11/04/19 Revising settlement agreement. Annick Persinger 0.70 $759.00 $531.30

11/05/19 Working on motion for leave to amend. Annick Persinger 0.40 $759.00 $303.60

11/07/19 Continuing to work on settlement agreement. Annick Persinger 2.10 $759.00 $1,593.90

11/13/19 Coordinating schedule with OC. Annick Persinger 0.10 $759.00 $75.90

11/14/19 Discussing with OC (0.5); working on complaint and motion for leave (2.6). Annick Persinger 3.10 $759.00 $2,352.90

11/15/19

Discussing revisions and motion for leave with co‐counsel (0.3); continuing work

on motion for leave and complaint (3.2). Annick Persinger 3.50 $759.00 $2,656.50

11/19/19 Coordinating Fourth amended complaint and motion to amend with co‐counsel. Annick Persinger 0.50 $759.00 $379.50

11/22/19 Fact investigation. Annick Persinger 0.30 $759.00 $227.70

11/25/19 Beginning review of notices. Annick Persinger 0.90 $759.00 $683.10

12/31/19 Reviewing current settlement agreement, responding to co‐counsel. Annick Persinger 2.10 $759.00 $1,593.90

01/02/20 Coordinating new deadlines for preliminary approval. Annick Persinger 0.60 $759.00 $455.40

01/10/20 Working on stipulation and other issues related to finalizing settlement. Annick Persinger 0.90 $759.00 $683.10

01/17/20 Working on class notices. Annick Persinger 5.60 $759.00 $4,250.40

01/23/20 Emailing with co‐counsel re finalizing deal. Annick Persinger 0.60 $759.00 $455.40

02/03/20 Emailing with co‐counsel re seeking extension of stay and status of deal. Annick Persinger 0.40 $759.00 $303.60

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 15 of 30
02/18/20

Reviewing recent emails, reviewing calendar, updating case status sheet, and

evaluating next steps. Annick Persinger 0.80 $759.00 $607.20

02/19/20

Call with co‐counsel re status (0.5); call with OC re same (0.5); reviewing latest

edits from OC (0.6). Annick Persinger 1.60 $759.00 $1,214.40

03/05/20

Checking in on status of settlement and consulting with team re going back to

mediator. Annick Persinger 0.50 $759.00 $379.50

03/09/20 Discussing with co‐counsel re raising issues with mediator. Annick Persinger 0.30 $759.00 $227.70

03/17/20 Working on mediation issues. Annick Persinger 0.70 $759.00 $531.30

03/18/20 Continuing to work on mediation date. Annick Persinger 0.70 $759.00 $531.30

03/26/20 Working on issues related to settlement and motion to enforce term sheet. Annick Persinger 1.20 $759.00 $910.80

03/31/20 Working on submission to court regarding status of settlement. Annick Persinger 1.20 $759.00 $910.80

04/03/20

Reviewing court order regarding motion to enforce term sheet, conferring with

team re same and working on a mediation date. Annick Persinger 1.00 $759.00 $759.00

04/06/20 Researching motion to enforce term sheet. Annick Persinger 1.50 $759.00 $1,138.50

04/06/20 Working on getting mediation date with co counsel and OC. Annick Persinger 0.60 $759.00 $455.40

04/07/20 Conferring with co‐counsel about goals for mediation. Annick Persinger 0.60 $759.00 $455.40

04/09/20 Continuing to work on getting an agreed mediation date. Annick Persinger 0.50 $759.00 $379.50

04/21/20 Organizing mediation. Annick Persinger 0.20 $759.00 $151.80

05/06/20 Working on mediation brief. Annick Persinger 2.10 $759.00 $1,593.90

05/12/20 Mediation prep. Annick Persinger 3.20 $759.00 $2,428.80

05/13/20 Mediation. Annick Persinger 11.00 $759.00 $8,349.00

05/14/20 Working on motion to amend the complaint for settlement purposes. Annick Persinger 1.50 $759.00 $1,138.50

05/15/20

Working on joint report to the court and planning hearing date and work

assignments related to preliminary approval. Annick Persinger 0.90 $759.00 $683.10

05/18/20 Reviewing draft notices. Annick Persinger 0.60 $759.00 $455.40

05/21/20 Working on notice to the court. Annick Persinger 0.60 $759.00 $455.40

05/28/20 Working on motion for leave to amend and amended complaint. Annick Persinger 6.10 $759.00 $4,629.90

06/01/20

Working on motion for preliminary approval and discussions with co‐counsel re

same. Annick Persinger 3.20 $759.00 $2,428.80

06/01/20

Working on declarations in support of preliminary approval and motion for

leave to amend. Annick Persinger 1.00 $759.00 $759.00

06/02/20

Working on preliminary approval motion, proposed orders, declarations,

motion for leave to amend, and related declarations for that motion as well,

finalizing and filing. Annick Persinger 14.90 $759.00 $11,309.10

07/13/20 Working on notice of appearance for hearing with court. Annick Persinger 0.30 $759.00 $227.70

07/18/20 Preparing for preliminary approval hearing. Annick Persinger 3.80 $759.00 $2,884.20

07/21/20

Discussing with co‐counsel and preparing for preliminary approval hearing (5.1);

hearing (0.7); discussing with co‐counsel after (0.8). Annick Persinger 6.60 $759.00 $5,009.40

07/23/20 Working on supplemental submission. Annick Persinger 6.00 $759.00 $4,554.00

07/24/20 Working on supplemental submission. Annick Persinger 4.00 $759.00 $3,036.00

07/27/20 Reviewing supplemental brief and submission. Annick Persinger 3.20 $759.00 $2,428.80

07/28/20 Working on supplemental submission. Annick Persinger 2.10 $759.00 $1,593.90

07/30/20 Conferring re email from possible objector. Annick Persinger 0.50 $759.00 $379.50

08/04/20 Coordinating filing of amended complaint. Annick Persinger 0.40 $759.00 $303.60

08/19/20 Discussions re possible objector. Annick Persinger 0.50 $759.00 $379.50

08/22/20 Discussing fee application. Annick Persinger 0.50 $759.00 $379.50

8/31/2020

Working on fee application and supporting declarations, reviewing time

records. Annick Persinger 8.60 $759.00 $6,527.40

03/01/17 Finalize and file AMP Notice of Appearance. Audrey Abate   0.10 $206.00 $20.60

03/15/17 Finalize and file Consent/Declination to Mag. Judge. Audrey Abate   0.30 $206.00 $61.80

03/17/17 Find and send AMP word doc versions of complaint and doc for drafting report. Audrey Abate   0.20 $206.00 $41.20

03/17/17 Phone call with potential plaintiff Abdul Negedu. Audrey Abate   0.20 $206.00 $41.20

03/23/17 File maintenance. Audrey Abate   0.20 $206.00 $41.20

04/13/17

Emails with JK and NL re: potential plaintiff; phone call to Abdul Malik Negedu

re: class status. Audrey Abate   0.30 $206.00 $61.80

05/01/17 Find and send JK and AMP N.D. Cal. ADR forms for deadline. Audrey Abate   0.20 $206.00 $41.20

05/17/17 Draft 23(g) motion for AMP. Audrey Abate   0.50 $206.00 $103.00

05/18/17 Continue work on 23(g) motion for AMP. Audrey Abate   2.70 $206.00 $556.20

05/19/17 Finish 23(g) draft and send to AMP. Audrey Abate   0.60 $206.00 $123.60

05/19/17 Prepare doc re: JK's declaration for AMP. Audrey Abate   0.20 $206.00 $41.20

05/24/17 Phone call and emails with G. Constantine re: depo location. Audrey Abate   0.20 $206.00 $41.20

05/25/17 Emails with NL re: depo details. Audrey Abate   0.10 $206.00 $20.60

05/31/17 Draft shell docs for stip and proposed order for AMP. Audrey Abate   0.20 $206.00 $41.20

06/05/17 Scan and save first set of RFPs. Audrey Abate   0.30 $206.00 $61.80

06/07/17 Phone calls with NL re: case responsibilities. Audrey Abate   0.10 $206.00 $20.60

06/26/17 Calendar depo dates. Audrey Abate   0.10 $206.00 $20.60

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 16 of 30
07/06/17 Scan and save motion for sanctions Rule 11. Audrey Abate   0.20 $206.00 $41.20

07/06/17 Print Libre depo docs. Audrey Abate   5.00 $206.00 $1,030.00

07/07/17 Finish depo docs. Audrey Abate   1.00 $206.00 $206.00

07/17/17 Email and phone call to M. Dickstein re: September mediation. Audrey Abate   0.20 $206.00 $41.20

07/19/17 Download and save depo exhibits and transcripts. Audrey Abate   0.40 $206.00 $82.40

07/27/17 Call to US Legal Support re: billing. Audrey Abate   0.10 $206.00 $20.60

07/31/17 Email M. Dickstein re: booking Sept. mediation date. Audrey Abate   0.10 $206.00 $20.60

08/01/17 Scand and send AMP depo erratas and instructions for Molina, Ortiz, Vasquez. Audrey Abate   0.20 $206.00 $41.20

08/10/17 Calls and emails to Marriott to book 9/12 conference room. Audrey Abate   0.30 $206.00 $61.80

08/14/17 Emails to M. Dickstein, AMP, JK re: mediation party info. Audrey Abate   0.20 $206.00 $41.20

08/14/17

Call to Justin Moore re: Marriott conference room; sign and return contract for

9/12 meeting. Audrey Abate   0.30 $206.00 $61.80

08/16/17

Phone calls with Oakland Marriott and Rancho Cordova Marriott to book

meeting spaces for 9/12/17. Audrey Abate   0.20 $206.00 $41.20

08/22/17 Email M. Dickstein re: mediation brief rules. Audrey Abate   0.10 $206.00 $20.60

08/23/17 Calls to U.S. Legal Support re: depo billing. Audrey Abate   0.30 $206.00 $61.80

08/31/17 Send Marriott conference details to S. Levine. Audrey Abate   0.10 $206.00 $20.60

09/01/17 Emails with JK, AMP, NL, JJ confirming Dickstein mediation payment. Audrey Abate   0.20 $206.00 $41.20

09/13/17 Sign and return Marriott cancellation doc to Justin Moore. Audrey Abate   0.10 $206.00 $20.60

09/22/17 Update mediation and meeting dates. Audrey Abate   0.10 $206.00 $20.60

09/29/17 Fill out and send ADR participants sheet to C. Conefrey. Audrey Abate   0.20 $206.00 $41.20

10/03/17

Calls to ADR services re: updates to ADR attendance list; follow up emails and re‐

submit ADR forms. Audrey Abate   0.40 $206.00 $82.40

10/03/17 Book Marriott conference room for Oct 9; sign and return confirmation forms. Audrey Abate   0.30 $206.00 $61.80

10/03/17 Emails with JK and AMP re: ADR issues. Audrey Abate   0.20 $206.00 $41.20

10/04/17 Call ADR services to confirm receipt of mediation payment. Audrey Abate   0.10 $206.00 $20.60

10/04/17

Emails re: mediation brief, finalize, file with ADR Services, Inc. and send hard

copy to Judge Lambden. Audrey Abate   0.70 $206.00 $144.20

10/04/17 Sign and return Marriott conference room contract. Audrey Abate   0.20 $206.00 $41.20

11/27/17 Draft Notice of Withdrawal of JK. Audrey Abate   0.20 $206.00 $41.20

11/28/17 File Notice of Withdrawal JK. Audrey Abate   0.20 $206.00 $41.20

01/29/18 Calendar new dates for Annick Chloe Hyunji Noh 0.30 $206.00 $61.80

03/20/18 Libre Lode star and expense excel Chloe Hyunji Noh 3.00 $206.00 $618.00

03/22/18 Gather Libre filings for Mediation Chloe Hyunji Noh 0.30 $206.00 $61.80

04/26/18 Notice of Appearance for Tanya Chloe Hyunji Noh 0.50 $206.00 $103.00

06/08/18 Work on formatting issues of Libre Opp to Rule 11 motion Chloe Hyunji Noh 2.50 $206.00 $515.00

06/12/18 Continue working on Rule 11 Opposition Motion formatting issues, etc. Chloe Hyunji Noh 2.00 $206.00 $412.00

06/13/18 Format and edit, add tables to Rule 11 brief Chloe Hyunji Noh 3.00 $206.00 $618.00

06/14/18 Refile declaration with exhibtis attached Chloe Hyunji Noh 0.50 $206.00 $103.00

06/18/18

Work on reading, comparing, editing depo cites, highlighting transcripts, etc. for

Opp to MTC Arbitration brief Chloe Hyunji Noh 5.50 $206.00 $1,133.00

06/19/18 Finalizing and addding tables, filing OPP MTC Arbitration Chloe Hyunji Noh 2.50 $206.00 $515.00

06/19/18 Format and fix Libre OPP to MTC Arbitration Chloe Hyunji Noh 2.00 $206.00 $412.00

08/13/18 Prepare hearing binders for AMP and TSK Chloe Hyunji Noh 2.00 $206.00 $412.00

08/14/18 Attending libre hearing with AMP and TSK Chloe Hyunji Noh 2.50 $206.00 $515.00

08/20/18 Emails with Sarh S. from New Yorker to send AMP Declaration Chloe Hyunji Noh 0.50 $206.00 $103.00

09/19/18 Set up AMP 9th circuit account and file notice ofappearance, etc. Chloe Hyunji Noh 2.50 $206.00 $515.00

09/19/18 Format and help AMP with discovery Chloe Hyunji Noh 3.00 $206.00 $618.00

09/20/18 Amending all new trial dates Chloe Hyunji Noh 0.40 $206.00 $82.40

09/24/18 Finalize PLtf's 2nd set of RFPs and ROGs and serve Chloe Hyunji Noh 2.00 $206.00 $412.00

09/26/18 Format and finalize mediation questionnaire to file Chloe Hyunji Noh 2.00 $206.00 $412.00

09/26/18 Draft NOA for TK Chloe Hyunji Noh 0.50 $206.00 $103.00

10/22/18 Set up mediation conference for AMP Chloe Hyunji Noh 0.50 $206.00 $103.00

10/23/18 Add tables, finalize, and file Libre opp. to 1292 and motion to stay Chloe Hyunji Noh 3.00 $206.00 $618.00

10/24/18 Work on formatting Libre TAC Chloe Hyunji Noh 2.00 $206.00 $412.00

10/25/18 Work on formatting and help AMP with researching for motion for admin relief Chloe Hyunji Noh 3.50 $206.00 $721.00

10/26/18

Draft J. Rathod Declaration, compare and change all redline changes from

second amended complaint to third amended complaint, then format and

finalize brief Chloe Hyunji Noh 4.50 $206.00 $927.00

10/26/18

Convert pdfs into word documents for proposed order and pltf's motion for

leave to file TAC Chloe Hyunji Noh 1.00 $206.00 $206.00

10/29/18 Finalize, add tables, and format AMP Decl ISO Motion to amend Complaoint Chloe Hyunji Noh 2.80 $206.00 $576.80

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 17 of 30
10/29/18

Work on putting together exhibits, redline version of TAC, clean version of TAC

for Motion for leave to amend Complaint filing Chloe Hyunji Noh 2.00 $206.00 $412.00

10/29/18 File all documents re: motion for admin relief and motion to amend Chloe Hyunji Noh 0.50 $206.00 $103.00

11/07/18 Case meeting with amp and tk Chloe Hyunji Noh 0.40 $206.00 $82.40

11/14/18 Double check local rules on all deadlines Chloe Hyunji Noh 0.30 $206.00 $61.80

11/14/18 Pull state court docket file maintenance from 2008 by calling clerk Chloe Hyunji Noh 1.00 $206.00 $206.00

11/15/18

Format, add tables, finalize DSW Motion for Reconsideration to send opposing

counsel Chloe Hyunji Noh 2.50 $206.00 $515.00

11/20/18

Work on tables and formmating and finalizing REply ISO Motion for Leave to

Amend Chloe Hyunji Noh 3.50 $206.00 $721.00

11/21/18 Fact investigation. Chloe Hyunji Noh 5.00 $206.00 $1,030.00

12/05/18 Libre SAC finalize and file Chloe Hyunji Noh 1.00 $206.00 $206.00

12/10/18 Helped AMP with proposed settlement issues Chloe Hyunji Noh 1.50 $206.00 $309.00

12/11/18 Help AMP with settlement conference Chloe Hyunji Noh 1.50 $206.00 $309.00

12/12/18 Work on lodestar for AMP Settlement conference Chloe Hyunji Noh 1.00 $206.00 $206.00

12/17/18 Recalendar dates for mediation conference Chloe Hyunji Noh 0.30 $206.00 $61.80

12/20/18 Assist AMP with Libre Settlement issues Chloe Hyunji Noh 1.50 $206.00 $309.00

01/07/19 Help AMP research term sheet, etc. Chloe Hyunji Noh 1.00 $206.00 $206.00

02/14/19 Gather all documents and printing and send for AMP meeting Chloe Hyunji Noh 1.20 $206.00 $247.20

02/27/19 Calendar all new deadlines Chloe Hyunji Noh 0.50 $206.00 $103.00

03/15/19 Help AMP prepare for Mediation Chloe Hyunji Noh 2.00 $206.00 $412.00

04/25/19 find out mediator availability Chloe Hyunji Noh 1.00 $206.00 $206.00

06/12/19 Scheduling mediation date Collin Hoover   0.50 $206.00 $103.00

06/21/19 Reservation for Mediation with Jill Sperber. Collin Hoover   0.30 $206.00 $61.80

06/26/19

calendaring mediation, downloading/circulating/saving discovery stay,

coordinating with the mediation case manager Collin Hoover   0.80 $206.00 $164.80

06/28/19 calendaring new deadlines Collin Hoover   0.50 $206.00 $103.00

07/01/19 Reviewing records in prep for mediation scheduling, looking for JPA Collin Hoover   0.40 $206.00 $82.40

07/11/19 lodstar and expenses Collin Hoover   0.60 $206.00 $123.60

07/15/19 email and call with mediator re: fees, brief, participants. Collin Hoover   0.80 $206.00 $164.80

07/22/19 calendaring deadlines for mediation Collin Hoover   0.50 $206.00 $103.00

07/24/19 forwarding invoices for payment Collin Hoover   0.20 $206.00 $41.20

07/26/19 paying for mediation, sending documents to mediator Collin Hoover   0.60 $206.00 $123.60

07/31/19 following up on mediation payments Collin Hoover   0.30 $206.00 $61.80

08/01/19 following up on payment for mediation Collin Hoover   0.30 $206.00 $61.80

08/15/19 calendaring mediation Collin Hoover   0.10 $206.00 $20.60

08/19/19

pulling documents for A Persinger (.1) paying for second round of mediation (.2)

calendaring re same (.2) Collin Hoover   0.50 $206.00 $103.00

08/22/19 calendaring (.1) Collin Hoover   0.10 $206.00 $20.60

08/28/19 following up on paying for second mediation Collin Hoover   0.20 $206.00 $41.20

09/12/19 Calendaring settlement deadlines (.2), case conference with M. Christensen (.1) Collin Hoover   0.30 $206.00 $61.80

09/13/19 Filing notice of appearance for M. Christensen Collin Hoover   0.30 $206.00 $61.80

10/01/19 circulating filing re status report to court (.1) Collin Hoover   0.10 $206.00 $20.60

10/03/19

calendaring case status update and ciruclaƟng order staying case (.2)

Collin Hoover   0.20 $206.00 $41.20

10/15/19

saving retainer for new client (.1)

Collin Hoover   0.10 $206.00 $20.60

11/15/19 Updating deadlines. Collin Hoover   0.10 $206.00 $20.60

01/02/20 reviewing calendar, case conference with M Christensen. Collin Hoover   0.40 $206.00 $82.40

01/10/20 circulating stipulation and request to stay the case. Collin Hoover   0.10 $206.00 $20.60

01/14/20 Calendaring deadlines per ordered stipulation staying case. Collin Hoover   0.20 $206.00 $41.20

02/03/20 Calendaring status report and preliminary motion deadlines. saving order Collin Hoover   0.20 $206.00 $41.20

02/21/20

Circulating filings re staying case, saving for our records. Reviewing calendar,

notices, and courts calendar. Email to team re next deadlines? Collin Hoover   0.40 $206.00 $82.40

03/06/20 Circulating and saving joint status report. Collin Hoover   0.10 $206.00 $20.60

03/09/20 circulating filing, calendaring. Collin Hoover   0.10 $206.00 $20.60

03/18/20 Reaching out to Judicate West for Jill Sperber's availability for mediation. Collin Hoover   0.20 $206.00 $41.20

04/01/20 circulating filing. Collin Hoover   0.20 $206.00 $41.20

04/10/20

emails with A. Persinger re invoices for mediation. Calendaring mediation

deadlines and date. Setting up My JW account for A. Persinger. Collin Hoover   0.30 $206.00 $61.80

04/13/20 circulating filing Collin Hoover   0.10 $206.00 $20.60

04/13/20

Reading emails, circulating mediation video conferencing information, writing

follow up email re confidentiality agreement. Collin Hoover   0.30 $206.00 $61.80

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 18 of 30
04/13/20 Email to H. Reed at Judicate west re agreement. Collin Hoover   0.10 $206.00 $20.60

04/17/20

Reviewing mediation materials and emails. Saving for our records. Setting up JW

account. Paying invoice for mediation fees. Signing confidentiality agreement

and emailing to H. Reed at Judicate West. Collin Hoover   0.70 $206.00 $144.20

04/22/20 Email with J. Rathod re payment for mediation. Collin Hoover   0.10 $206.00 $20.60

04/22/20 email to Heather Reed re mediation fees. Collin Hoover   0.10 $206.00 $20.60

04/22/20 Email to A. Persinger. Emailing co‐counsel re paying invoice. Collin Hoover   0.20 $206.00 $41.20

05/13/20

Calls from Annick Persinger re DocuSigning mediation agreement. Sending

agreement re same. Collin Hoover   0.30 $206.00 $61.80

05/15/20 Saving settlement agreement. Circulating and saving status report. Collin Hoover   0.20 $206.00 $41.20

05/28/20

Emails from A. Persinger re Motion for Preliminary Approval. Email back re

calendaring. Collin Hoover   0.20 $206.00 $41.20

05/29/20 pulling examples of Motion for Preliminary Approval for J. Thelusma. Collin Hoover   0.30 $206.00 $61.80

06/01/20 Prep work on motion for leave to file fourth amended complaint. Collin Hoover   1.70 $206.00 $350.20

06/01/20 Circulating and calendaring deadline to update court re mediation status. Collin Hoover   0.10 $206.00 $20.60

06/02/20 Call to A. Persinger re filing of preliminary motion to Collin Hoover   0.20 $206.00 $41.20

06/02/20

Working on motion for preliminary approval, motion for leave to file fourth

amended complaint. Finalizing and filing same. Collin Hoover   8.30 $206.00 $1,709.80

06/03/20

Saving word versions of preliminary approval order. calendaring hearing date.

Cleaning up file. Collin Hoover   0.30 $206.00 $61.80

06/16/20 circulating and saving def's non opposition to preliminary approval motion. Collin Hoover   0.20 $206.00 $41.20

06/19/20 Email to H. Reed at Judicate West re invoice issue. Collin Hoover   0.20 $206.00 $41.20

06/19/20 Rec'd email from H. Reed at Judicate West re invoice. Reply email. Collin Hoover   0.10 $206.00 $20.60

06/23/20 Email from H. Reed at Judicate West regarding payment. Email response. Collin Hoover   0.10 $206.00 $20.60

06/23/20

forwarding invoice from Judicate West to J. Rathod to split payment. Paying our

half online. Saving invoice for our records. Emailing receipt to J. Jackson. Collin Hoover   0.60 $206.00 $123.60

06/25/20 Responding to email from J. Rathod re payment for mediation. Collin Hoover   0.10 $206.00 $20.60

07/01/20

Received reminder to send payment from Judicate West. Email to J. Rathod re

same. Collin Hoover   0.10 $206.00 $20.60

07/06/20 Received email from co‐counsel re status of payment of invoice. Collin Hoover   0.10 $206.00 $20.60

07/13/20

Saving and calendaring zoom conference info for upcoming hearing. Email to A.

Persinger re same. Collin Hoover   0.20 $206.00 $41.20

07/14/20 Email to court re appearances for plaintiff, emailing documents to A. Persinger. Collin Hoover   0.30 $206.00 $61.80

07/20/20 Received emails from the court re Zoom info. Adding calendar reminder. Collin Hoover   0.10 $206.00 $20.60

07/21/20

Emails with A. Persinger re amended motion for preliminary approval. Calling

court reporters re transcript request. Completing request and filing. Circulating

and saving. Calendaring deadline. Emailing paralegals re deadline coverage. Collin Hoover   1.30 $206.00 $267.80

07/22/20 Circulating and saving transcript. Collin Hoover   0.20 $206.00 $41.20

07/22/20

Email from court reporters re hearing transcript, correspondence re timing of

delivery. Call to J. Jackson re same, email to A. Persinger and J. Jackson re same.

Email from A. Persinger requesting word versions of preliminary approval

motion, pulling and sending. Correspondence re transcript. Collin Hoover   0.90 $206.00 $185.40

07/23/20 Circulating and saving minute order. Collin Hoover   0.20 $206.00 $41.20

08/02/20

Reviewing preliminary approval order, calendaring deadlines and email to A.

Persinger. Collin Hoover   0.30 $206.00 $61.80

08/04/20 Circulating and calendaring request for video recording. Collin Hoover   0.10 $206.00 $20.60

08/07/20

Reviewing and saving recent filings. Email to A. Persinger re filing fourth

amended complaint, prepping filing. Collin Hoover   0.50 $206.00 $103.00

08/10/20

Preparing fourth amended complaint for filing. Email to A. Persinger. Filing

same. Collin Hoover   0.50 $206.00 $103.00

08/11/20 Paying invoice from court reporter. Saving in Net docs. Collin Hoover   0.10 $206.00 $20.60

08/13/20 Calendaring deadline and circulating order re status update to appellate court. Collin Hoover   0.20 $206.00 $41.20

08/25/20

Received email from A. Persinger and co‐counsel re application fee. Pulling

examples and sending. Starting review of time reports. Collin Hoover   1.60 $206.00 $329.60

08/28/20 Call from A. Persinger re case tasks. Collin Hoover   0.10 $206.00 $20.60

03/22/18 T/C with Sagafi and Persinger re mediation. Hassan Zavareei 0.80 $914.00 $731.20

03/26/18 Preparation for mediation. Hassan Zavareei 0.90 $914.00 $822.60

04/03/18 Reviewing mediator statement. Hassan Zavareei 0.40 $914.00 $365.60

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 19 of 30
04/04/18 T/C with K Sagafi re settlement; t/c with Sagafi and Persinger re settlement. Hassan Zavareei 1.80 $914.00 $1,645.20

04/06/18 Conference with Jason Rathod re settlement. Hassan Zavareei 0.50 $914.00 $457.00

06/21/19 Reservation for Mediation with Jill Sperber. Hassan Zavareei 0.30 $914.00 $274.20

05/15/17 Prepare Rule 26f report Jeffrey Kaliel 1.00 $759.00 $759.00

05/18/17 Meeting with Rathod; t/c with Annick Persinger re: CMC Jeffrey Kaliel 1.50 $759.00 $1,138.50

05/23/17 Prepare for and attend CMC Jeffrey Kaliel 2.20 $759.00 $1,669.80

06/12/17 t/c re deposition prep Jeffrey Kaliel 0.70 $759.00 $531.30

06/12/17 T/c with co counsel re: representing third parties; exchange email Jeffrey Kaliel 0.80 $759.00 $607.20

06/21/17

Review documents and prepare for depo; t/c with A Persinger and S Goren re

plaintiff depos. Jeffrey Kaliel 9.50 $759.00 $7,210.50

06/22/17 Prepare for and take 30b6 depo Jeffrey Kaliel 9.50 $759.00 $7,210.50

06/27/17

review Rule 11 motion; t/c with A Persinger; exchamnge email with opposing

counsel re depo scheduling. Jeffrey Kaliel 1.70 $759.00 $1,290.30

06/28/17 T/c with co counsel re depo preparation; t/c with client re depo prep Jeffrey Kaliel 1.90 $759.00 $1,442.10

06/29/17 Depo preparation call with client; Jeffrey Kaliel 2.20 $759.00 $1,669.80

07/10/17 Teravel to Settlement Funds; preparation for plaintiff depo Jeffrey Kaliel 12.00 $759.00 $9,108.00

07/11/17 Plaintiff depo Jeffrey Kaliel 14.00 $759.00 $10,626.00

07/12/17 Plaintiff depo Jeffrey Kaliel 14.00 $759.00 $10,626.00

07/13/17 Plaintiff depo; settlement meeting Jeffrey Kaliel 14.00 $759.00 $10,626.00

07/21/17 investigate whistleblower; exchange emailt Jeffrey Kaliel 0.60 $759.00 $455.40

07/26/17 call with co counsel Jeffrey Kaliel 0.50 $759.00 $379.50

07/27/17

T/c with co counsel; meet and confer with opposing counsel; t/c with

competing bond company. Jeffrey Kaliel 5.50 $759.00 $4,174.50

07/28/17 t/c with opposing counsel Jeffrey Kaliel 0.40 $759.00 $303.60

08/01/17

Exchange email with opposing counsel re mediation agreement; review and

revise MTD opp Jeffrey Kaliel 3.40 $759.00 $2,580.60

08/08/17 Fact investigation Jeffrey Kaliel 8.00 $759.00 $6,072.00

09/06/17 Draft mediation brief Jeffrey Kaliel 5.50 $759.00 $4,174.50

09/07/17 Revise mediation brief Jeffrey Kaliel 1.90 $759.00 $1,442.10

05/28/20 Internal communications re: motion for preliminary approval Jennifer Thelusma 0.10 $378.00 $37.80

05/29/20 drafting declaration iso preliminary approval Jennifer Thelusma 0.90 $378.00 $340.20

05/29/20 Reviewing complaint and case filings Jennifer Thelusma 1.00 $378.00 $378.00

05/30/20 drafting declaration iso motion for preliminary approval Jennifer Thelusma 1.30 $378.00 $491.40

05/31/20 drafting declaration ISO preliminary approval Jennifer Thelusma 1.30 $378.00 $491.40

06/01/20 internal communications re: motion for preliminary approval Jennifer Thelusma 0.10 $378.00 $37.80

06/01/20 Drafting motion iSO preliminary approval Jennifer Thelusma 1.70 $378.00 $642.60

06/01/20 drafting declaration ISO of leave to amend Jennifer Thelusma 0.70 $378.00 $264.60

06/01/20

Internal communications re: declaration ISO leave for fourth amended

complaint Jennifer Thelusma 0.10 $378.00 $37.80

06/01/20 Reviewing edits to declaration ISO motion for preliminary appproval Jennifer Thelusma 0.10 $378.00 $37.80

06/04/20

internal communications with Maren re: libre motion for preliminary approval

filing Jennifer Thelusma 0.10 $378.00 $37.80

11/17/17 Participate in settlement discussion with co‐counsel and opposing counsel. Jonathan Tycko 1.00 $914.00 $914.00

11/21/17

Meeting with J. Rathod, and then follow‐on conference call with all co‐counsel,

regarding status and strategy. Jonathan Tycko 1.50 $914.00 $1,371.00

05/13/20 Draft proposed Final Approval Order. Katherine Aizpuru 0.80 $465.00 $372.00

06/02/20

Review and revise motion for preliminary approval (1.1) and Rathod declaration

(.7). Katherine Aizpuru 1.80 $465.00 $837.00

03/20/17 Confer with AMP re: claims and leadership. Kristen Law Sagafi 0.60 $759.00 $455.40

03/22/17 Confer with AMP re: claims, liability and damges theories. Kristen Law Sagafi 2.00 $759.00 $1,518.00

03/23/17

Call with JKT re: claims, liability and damages theories; confer with AMP re:

strategy and next steps. Kristen Law Sagafi 0.90 $759.00 $683.10

03/29/17 Strategize with HAZ and AMP re: case theory and next steps. Kristen Law Sagafi 0.50 $759.00 $379.50

04/12/17 Confer with Ted Mermin re: legal theories. Kristen Law Sagafi 0.60 $759.00 $455.40

05/02/17 Confer with AMP re: amended complaint. Kristen Law Sagafi 0.70 $759.00 $531.30

05/12/17 Confer with AMP re: potential causes of action; staffing. Kristen Law Sagafi 0.40 $759.00 $303.60

05/16/17

Confer with AMP re: arbitration issues; forward recent authority re: arbitration

of injunctive relief claims. Kristen Law Sagafi 0.70 $759.00 $531.30

05/17/17 Confer wiht AMP re: arbitration motion strategy, schedule and staffing. Kristen Law Sagafi 1.60 $759.00 $1,214.40

05/19/17 Confer with AMP re: leadership structure. Kristen Law Sagafi 0.30 $759.00 $227.70

05/22/17 Discuss workflow with AMP. Kristen Law Sagafi 0.30 $759.00 $227.70

05/23/17 Confer with AMP re: initial case management conference; debrief after hearing. Kristen Law Sagafi 0.70 $759.00 $531.30

05/24/17 Review correspondence to coordinate staffing; emails with AMP re: discovery. Kristen Law Sagafi 0.40 $759.00 $303.60

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 20 of 30
06/07/17 Confer with AMP re: staffing and strategy. Kristen Law Sagafi 0.50 $759.00 $379.50

01/03/18 meeting with AMP re: status; emails with Neha Gupta re: same Kristen Law Sagafi 0.30 $759.00 $227.70

03/22/18

meeting with AMP re status and mediation strategy; call with AMP and HAZ re:

settlement strategy; review SAC and mediation correspondence; research price‐

gouging and 8th AM theories; draft and send analysis to AMP Kristen Law Sagafi 2.50 $759.00 $1,897.50

03/23/18 meeting with A Acuna; draft and circulate memo re next steps Kristen Law Sagafi 1.60 $759.00 $1,214.40

03/24/18 follow up with HAZ re mediation strategy Kristen Law Sagafi 0.10 $759.00 $75.90

03/27/18 Team call re settlement strategy Kristen Law Sagafi 1.40 $759.00 $1,062.60

03/28/18 Libre mediation Kristen Law Sagafi 8.20 $759.00 $6,223.80

04/02/18 emails with team re: mediation outcomes and next Kristen Law Sagafi 0.20 $759.00 $151.80

04/03/18 review letter from mediator and related follow up emails and calls with Kristen Law Sagafi 0.80 $759.00 $607.20

04/04/18 call with HAZ re: settlement strategy . Kristen Law Sagafi 0.90 $759.00 $683.10

04/04/18 phone conference with HAZ and AMP re: settlement strategy and next steps Kristen Law Sagafi 0.40 $759.00 $303.60

04/04/18 meeting with AMP re: settlement strategy Kristen Law Sagafi 0.40 $759.00 $303.60

04/05/18 research standard for 17200 unfairness prong; email Jesse Newmark re: Kristen Law Sagafi 1.40 $759.00 $1,062.60

04/09/18 draft and circulate case analysis to team; emails re same Kristen Law Sagafi 0.60 $759.00 $455.40

04/10/18

phone conference re: settlement strategy; related follow up calls with AMP and

HAZ Kristen Law Sagafi 1.80 $759.00 $1,366.20

04/10/18 prepare and circulate case analysis to team Kristen Law Sagafi 0.60 $759.00 $455.40

04/11/18 call with Ted Mermin Kristen Law Sagafi 0.50 $759.00 $379.50

04/16/18 emails with team re: settlement strategy Kristen Law Sagafi 0.20 $759.00 $151.80

06/18/18 Checking Dep. Cites in brief Kyra Taylor 2.00 $465.00 $930.00

08/15/19 Reviewing mediation submissions in prep for mediation Maren Christensen 0.70 $672.00 $470.40

08/16/19 attended mediation with AP Maren Christensen 8.50 $672.00 $5,712.00

08/29/19 call with AMP and HAZ re next steps in mediation Maren Christensen 0.50 $672.00 $336.00

08/29/19 call with AMP and cocounsel re next steps in mediation Maren Christensen 0.80 $672.00 $537.60

08/29/19

reviewing recent correspondence with co‐counsel re next steps in mediation, in

preparation for team calls Maren Christensen 1.00 $672.00 $672.00

08/29/19 reviewing correspondence with co‐counsel re next steps in mediation Maren Christensen 0.20 $672.00 $134.40

08/30/19

call with AMP and cocounsel re next steps in mediaƟon

Maren Christensen 0.80 $672.00 $537.60

08/30/19

reviewing correspondence with co‐counsel re next steps in mediaƟon

Maren Christensen 0.20 $672.00 $134.40

08/30/19

call with AMP and HAZ re next steps in mediaƟon

Maren Christensen 0.50 $672.00 $336.00

09/03/19

reviewing materials and corresponding with AP and co counsel in prep for

mediation Maren Christensen 1.60 $672.00 $1,075.20

09/03/19 call with AP and co counsel re term sheet and mediation prep Maren Christensen 0.40 $672.00 $268.80

09/03/19 call with mediator, AP, and co counsel re term sheet and mediation prep Maren Christensen 0.40 $672.00 $268.80

09/04/19 participated in mediation Maren Christensen 8.10 $672.00 $5,443.20

09/05/19 reviewing fully executed term sheet Maren Christensen 0.60 $672.00 $403.20

09/09/19 investigating and summarizing case status in CA office case tracking chart Maren Christensen 0.30 $672.00 $201.60

09/09/19 meeting with AMP re next steps Maren Christensen 0.10 $672.00 $67.20

09/10/19 meeting with CH re case calendaring and applicable procedural rules Maren Christensen 0.10 $672.00 $67.20

09/11/19

meeting with HAZ AMP SJS VP CH AA KMA SCK re case status, strategy, and next

steps Maren Christensen 0.20 $672.00 $134.40

09/12/19

call with AMP re drafting settlement complaint and motion for leave to amend

complaint Maren Christensen 0.20 $672.00 $134.40

09/12/19 drafting settlement agreement Maren Christensen 4.20 $672.00 $2,822.40

09/12/19 drafting motion for leave to amend complaint Maren Christensen 1.40 $672.00 $940.80

09/12/19 drafting settlement complaint Maren Christensen 2.70 $672.00 $1,814.40

09/18/19 call with HAZ AMP SJS KMA VP CH AA re case status and next steps Maren Christensen 0.10 $672.00 $67.20

09/18/19 emails with AMP re organization of case calendar Maren Christensen 0.30 $672.00 $201.60

09/20/19 editing Kevin Calderon representation agreement Maren Christensen 1.00 $672.00 $672.00

09/23/19 meeting with AMP re settlement agreement drafting and strategy Maren Christensen 0.60 $672.00 $403.20

09/24/19 call with AMP re retainer agreement for Kevin Calderon Maren Christensen 0.10 $672.00 $67.20

09/27/19 editing draft joint stipulation re settlement and vacating calendar Maren Christensen 0.30 $672.00 $201.60

09/30/19

reviewing and proposing edits for Spanish version of representation agreement

for Kevin Calderon Maren Christensen 0.80 $672.00 $537.60

10/08/19 meeting with AMP re revising draft settlement agreement Maren Christensen 0.30 $672.00 $201.60

10/09/19 meeting with AMP SJS CH VP re case status and next steps Maren Christensen 0.10 $672.00 $67.20

10/31/19 revising settlement agreement and sending same to co counsel Maren Christensen 3.60 $672.00 $2,419.20

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 21 of 30
11/04/19 editing motion for leave to amend complaint Maren Christensen 1.20 $672.00 $806.40

11/06/19 emails with co‐counsel re draft settlement agreement Maren Christensen 0.20 $672.00 $134.40

11/07/19

reviewing co‐counsel edits to settlement agreement, and emails with AMP and

co‐counsel re same Maren Christensen 2.20 $672.00 $1,478.40

11/07/19 emails with AMP and co‐counsel re draft settlement agreement Maren Christensen 1.20 $672.00 $806.40

11/07/19 meeting with AMP re settlement agreement Maren Christensen 0.20 $672.00 $134.40

11/08/19 emails with AMP and co‐counsel re settlement agreement draft Maren Christensen 1.30 $672.00 $873.60

11/08/19 CA office meeting re case status and next steps Maren Christensen 0.30 $672.00 $201.60

11/11/19 emails with co‐counsel re settlement agreement Maren Christensen 0.10 $672.00 $67.20

11/13/19 emails with co‐counsel re scheduling call with OC re settlement agreement draft Maren Christensen 0.20 $672.00 $134.40

11/15/19

reviewing deposition testimony re motion for leave to amend to add Kevin

Calderon as plaintiff Maren Christensen 1.40 $672.00 $940.80

11/15/19 meeting with AMP re case status and next steps Maren Christensen 0.10 $672.00 $67.20

11/22/19 drafting notices to class members Maren Christensen 3.80 $672.00 $2,553.60

11/22/19 drafting final approval order Maren Christensen 0.50 $672.00 $336.00

11/25/19 drafting preliminary and final approval orders Maren Christensen 0.10 $672.00 $67.20

11/26/19 emails with AMP and co‐counsel re settlement agreement next steps Maren Christensen 0.20 $672.00 $134.40

11/26/19

preparing for call with OC and co‐counsel and AMP re settlement agreement

revisions Maren Christensen 0.40 $672.00 $268.80

11/26/19 call with OC and co‐counsel and AMP re settlement agreement draft Maren Christensen 0.70 $672.00 $470.40

12/13/19 reviewing recent emails with co‐counsel re finalizing settlement agreement Maren Christensen 0.10 $672.00 $67.20

12/30/19 meeting with A. Persinger re notice proposal Maren Christensen 0.10 $672.00 $67.20

12/31/19

comms. with co‐counsel re settlement agreement next steps and notice

proposal Maren Christensen 0.10 $672.00 $67.20

01/02/20 comms. with team re case calendar Maren Christensen 0.10 $672.00 $67.20

01/07/20

comms. with team re draft notices, proposed approval order, and settlement

next steps Maren Christensen 0.30 $672.00 $201.60

01/09/20 reviewing draft status report and comms. with A. Persinger re same Maren Christensen 0.20 $672.00 $134.40

01/14/20 meeting with A. Persinger re edits to preliminary approval motion Maren Christensen 0.10 $672.00 $67.20

01/14/20 editing preliminary approval motion draft.  Comms. with co‐counsel re same. Maren Christensen 0.20 $672.00 $134.40

01/15/20 call with A. Persinger re revising class notice Maren Christensen 0.10 $672.00 $67.20

01/16/20 reviewing co‐counsel edits to proposed approval order Maren Christensen 0.10 $672.00 $67.20

01/17/20 comms. with A. Persinger re editing class notice Maren Christensen 0.20 $672.00 $134.40

01/17/20 revising class notice Maren Christensen 1.20 $672.00 $806.40

01/28/20 comms. with A. Persinger re case status and next steps Maren Christensen 0.30 $672.00 $201.60

01/31/20 comms. with team re filing status report to the court Maren Christensen 0.20 $672.00 $134.40

02/18/20

meeting with A. Persinger re case status and next steps, comms. with co‐

counsel re same Maren Christensen 0.20 $672.00 $134.40

02/19/20 call with A. Persinger and co‐counsel re case status and next steps Maren Christensen 0.40 $672.00 $268.80

03/09/20 reviewing order entering joint stipulation Maren Christensen 0.10 $672.00 $67.20

03/18/20 comms. with A. Persinger re case status and next steps Maren Christensen 0.10 $672.00 $67.20

04/03/20 reviewed order setting mediation Maren Christensen 0.10 $672.00 $67.20

05/06/20 comms. with A. Persinger re mediation brief Maren Christensen 0.10 $672.00 $67.20

02/09/17 get JPA signed. Nathan Laporte 0.20 $206.00 $41.20

02/13/17 Format complaint and CLRA decs. Nathan Laporte 2.10 $206.00 $432.60

02/15/17 file complaint Nathan Laporte 1.10 $206.00 $226.60

02/22/17 Calendar deadline dates. Nathan Laporte 0.60 $206.00 $123.60

03/21/17 Enter case mgmt dates and serve order on def. Nathan Laporte 0.60 $206.00 $123.60

03/29/17 File certificate of service. Nathan Laporte 0.60 $206.00 $123.60

05/25/17 Finalize and Serve discovery. Nathan Laporte 0.70 $206.00 $144.20

05/25/17 Calendar Deadlines. Nathan Laporte 0.60 $206.00 $123.60

06/05/17 Calendar deadlines. Nathan Laporte 0.20 $206.00 $41.20

06/07/17 Change depo. location. Nathan Laporte 0.40 $206.00 $82.40

06/08/17 Send amended Deposition Notice. Nathan Laporte 0.50 $206.00 $103.00

06/20/17 Deal with incoming production. Nathan Laporte 0.40 $206.00 $82.40

06/27/17 Register S. Goren for ND Cal. ECF. Nathan Laporte 0.20 $206.00 $41.20

06/28/17 Arrange S. Goren Bar admission to ND Cal. Nathan Laporte 0.40 $206.00 $82.40

06/28/17 Adapt model ESI protocol. Nathan Laporte 0.30 $206.00 $61.80

06/29/17 Draft and file notice of appearance. Nathan Laporte 0.40 $206.00 $82.40

07/05/17 Search production for relevant document. Nathan Laporte 0.40 $206.00 $82.40

07/05/17 Draft ESI documents. Nathan Laporte 0.40 $206.00 $82.40

07/05/17 Send update re case schedule. Nathan Laporte 0.30 $206.00 $61.80

07/06/17 Organize items for printing. Nathan Laporte 0.50 $206.00 $103.00

07/10/17 Proofread, bluebook, and integrate changes into Rule 11 letter. Nathan Laporte 1.70 $206.00 $350.20

08/16/17 send checks to non‐plaintiff deponents. Nathan Laporte 0.40 $206.00 $82.40

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 22 of 30
09/05/17 Integrate changes to mediation statement. Nathan Laporte 0.90 $206.00 $185.40

01/26/18 File S. Goren withdrawal. Nathan Laporte 0.20 $206.00 $41.20

01/23/17 Reviewing retention agreement in ankle monitoring case. Sophia Goren 1.00 $465.00 $465.00

01/24/17 Drafting new case memo for Libre by Nexus case. Sophia Goren 0.50 $465.00 $232.50

06/14/17 Reviewing second amended complaint; joint case management report. Sophia Goren 1.00 $465.00 $465.00

06/21/17 Call with J. Kaliel and A. Persinger re defending named plaintiff depositions. Sophia Goren 0.30 $465.00 $139.50

06/22/17 Researching rules on translators at depositions. Sophia Goren 1.00 $465.00 $465.00

06/23/17 Booking flights to depositions. Sophia Goren 0.60 $465.00 $279.00

06/27/17 Researching availability of sanctions. Sophia Goren 0.20 $465.00 $93.00

06/27/17 Reviewing Rule 11 motion. Sophia Goren 0.50 $465.00 $232.50

06/27/17 Making hotel reservations for deposition. Sophia Goren 0.10 $465.00 $46.50

06/27/17 Call with J. Kaliel and A. Persinger re Rule 11 motion. Sophia Goren 0.20 $465.00 $93.00

06/28/17 Call with named plaintiff re preparing for deposition. Sophia Goren 1.50 $465.00 $697.50

06/28/17 Call with co‐counsel re preparing plaintiffs for depositions. Sophia Goren 0.60 $465.00 $279.00

06/29/17 Calls with named plaintiffs Victor and Gabriela to prepare for deposition. Sophia Goren 2.20 $465.00 $1,023.00

06/30/17 Drafting proposed search terms. Sophia Goren 1.30 $465.00 $604.50

07/07/17 Reviewing draft response to Rule 11 letter. Sophia Goren 0.40 $465.00 $186.00

07/07/17 Researching and revising response to Rule 11 letter. Sophia Goren 2.90 $465.00 $1,348.50

07/07/17 Revising Rule 11 letter. Sophia Goren 0.50 $465.00 $232.50

07/07/17 Responding to J. Kaliel email re alternate lawsuit. Sophia Goren 0.20 $465.00 $93.00

07/09/17 Emailing A. Persinger and J. Kaliel re response to Rule 11 letter. Sophia Goren 0.20 $465.00 $93.00

07/10/17 Reviewing draft deficiency letter. Sophia Goren 0.30 $465.00 $139.50

07/10/17 Conference w. J. Vasquez to prepare for deposition. Sophia Goren 2.30 $465.00 $1,069.50

07/10/17 Reviewing motion to compel arbitration. Sophia Goren 0.30 $465.00 $139.50

07/10/17 Preparing for depositions of named plaintiffs. Sophia Goren 2.00 $465.00 $930.00

07/10/17 Reviewing motion to dismiss. Sophia Goren 0.20 $465.00 $93.00

07/11/17 Deposition of J. Vasquez. Sophia Goren 7.50 $465.00 $3,487.50

07/11/17 Meeting with client G. Ortiz to prepare for deposition. Sophia Goren 3.30 $465.00 $1,534.50

07/11/17 Meeting with client before deposition. Sophia Goren 1.00 $465.00 $465.00

07/11/17 Preparing for deposition of named plaintiff. Sophia Goren 0.30 $465.00 $139.50

07/12/17 Meeting with client before deposition, preparing for deposition. Sophia Goren 1.00 $465.00 $465.00

07/12/17 Deposition of G. Ortiz. Sophia Goren 7.50 $465.00 $3,487.50

07/12/17 Meeting with Victor to prepare for deposition. Sophia Goren 2.00 $465.00 $930.00

07/13/17 Deposition of V. Molina. Sophia Goren 6.00 $465.00 $2,790.00

07/13/17 Meeting with client, preparing for deposition. Sophia Goren 1.00 $465.00 $465.00

07/13/17 Settlement meeting with opposing counsel. Sophia Goren 1.00 $465.00 $465.00

07/13/17 Preparing for settlement meeting, meeting with co‐counsel re same. Sophia Goren 1.50 $465.00 $697.50

07/13/17 Waiting with J. Vasquez for monitor to be removed, reviewing contract re same. Sophia Goren 0.70 $465.00 $325.50

07/13/17 Meeting with co‐counsel after settlement talks to discuss next steps. Sophia Goren 0.50 $465.00 $232.50

07/14/17 Call with N. Rodriguez to prepare for deposition. Sophia Goren 0.90 $465.00 $418.50

07/18/17 Reviewing email re ADR. Sophia Goren 0.10 $465.00 $46.50

07/18/17 Call with N. Laporte re noticing depositions. Sophia Goren 0.30 $465.00 $139.50

07/18/17 Call with A. Persinger re case manager depos. Sophia Goren 0.20 $465.00 $93.00

07/18/17 Reviewing emails re depositions of case managers. Sophia Goren 0.20 $465.00 $93.00

07/18/17 Researching former employee. Sophia Goren 0.30 $465.00 $139.50

07/24/17 Reviewing draft subpoenas. Sophia Goren 0.30 $465.00 $139.50

07/25/17 Reviewing emails re depositions of case managers. Sophia Goren 0.10 $465.00 $46.50

07/25/17

Researching procedure for resolving factual disputes in relation to motion to

compel. Sophia Goren 0.70 $465.00 $325.50

07/26/17 Call with co‐counsel re next steps. Sophia Goren 0.60 $465.00 $279.00

07/26/17 Researching ability to seek sanctions. Sophia Goren 0.60 $465.00 $279.00

07/27/17 Call w/ Gonzalez brothers. Sophia Goren 1.20 $465.00 $558.00

07/27/17 Meet and confer call with opposing counsel. Sophia Goren 0.60 $465.00 $279.00

07/27/17 Researching deadlline to amend pleadings. Sophia Goren 0.10 $465.00 $46.50

07/27/17 Preparing for meet and confer call. Sophia Goren 0.10 $465.00 $46.50

07/28/17 Researching case manager names. Sophia Goren 0.30 $465.00 $139.50

07/31/17 Emailing A. Persinger re opposition to motion to dismiss. Sophia Goren 0.10 $465.00 $46.50

08/01/17 Reviewing and revising opposition to motion to dismiss. Sophia Goren 2.50 $465.00 $1,162.50

08/01/17 Reviewing emails re settlement. Sophia Goren 0.10 $465.00 $46.50

08/07/17 Reviewing redlines to proposed stipulation, emails re same. Sophia Goren 0.20 $465.00 $93.00

08/07/17 Reviewing meet and confer letter; second production from defendants. Sophia Goren 1.20 $465.00 $558.00

08/07/17 Reviewing proposed stipulation. Sophia Goren 0.30 $465.00 $139.50

08/14/17 Reviewing emails re deposition transcripts. Sophia Goren 0.10 $465.00 $46.50

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 23 of 30
08/14/17 Reviewing email from J. Kaliel re mediation. Sophia Goren 0.10 $465.00 $46.50

08/22/17 Reviewing internal powerpoint from whistleblower and emails re same. Sophia Goren 0.20 $465.00 $93.00

08/23/17 Revieing emails re mediation. Sophia Goren 0.10 $465.00 $46.50

08/24/17 Reviewing email from mediator re mediation. Sophia Goren 0.10 $465.00 $46.50

08/24/17 Call with A. Persinger re mediation statement. Sophia Goren 0.20 $465.00 $93.00

08/24/17 Drafting mediation statement. Sophia Goren 1.40 $465.00 $651.00

09/01/17 Reviewing draft mediation brief. Sophia Goren 0.60 $465.00 $279.00

09/05/17 Reviewing and revising mediation brief. Sophia Goren 3.60 $465.00 $1,674.00

09/06/17 Emailing re mediation statement. Sophia Goren 0.20 $465.00 $93.00

09/06/17 Revising and editing mediation statement. Sophia Goren 2.00 $465.00 $930.00

09/07/17 Reviewing draft mediation statement. Sophia Goren 0.30 $465.00 $139.50

09/08/17 Drafting executive summary. Sophia Goren 1.50 $465.00 $697.50

09/08/17 Call with N. Laporte re mediation statement. Sophia Goren 0.10 $465.00 $46.50

09/08/17 Drafting mediation statement. Sophia Goren 1.50 $465.00 $697.50

09/12/17 Reviewing email re deposition errata. Sophia Goren 0.10 $465.00 $46.50

09/13/17 Emailing re mediation. Sophia Goren 0.20 $465.00 $93.00

10/24/17 Fact investigation. Sophia Goren 0.10 $465.00 $46.50

11/13/17 Call with J. Tycko and A. Persinger re case status. Sophia Goren 0.20 $465.00 $93.00

11/17/17 Emaling A. Persinger re call. Sophia Goren 0.10 $465.00 $46.50

11/21/17 Reviewing email re potential class member. Sophia Goren 0.10 $465.00 $46.50

11/27/17 Reviewing draft stipulation of stay. Sophia Goren 0.20 $465.00 $93.00

11/28/17 Reviewing notice of withdrawal. Sophia Goren 0.10 $465.00 $46.50

11/28/17 Call with A. Persinger re status of case. Sophia Goren 0.10 $465.00 $46.50

11/28/17 Reviewing order on protective order. Sophia Goren 0.10 $465.00 $46.50

06/05/18 Prep for Libre Call (review of complaint, Rule 11 mx, MTD) Tanya Koshy 1.10 $672.00 $739.20

06/05/18 TC with Libre team re MTC arb, MTD, and Rule 11 mx Tanya Koshy 0.70 $672.00 $470.40

06/05/18 Rule 11 Mx Response Letter review Tanya Koshy 0.20 $672.00 $134.40

06/06/18 Discsussion and coordination with AMP re: Rule 11 mx Tanya Koshy 0.40 $672.00 $268.80

06/06/18 Review of MTD and Rule 11 mx in preparation of draft of opp to Rule 11 Tanya Koshy 0.50 $672.00 $336.00

06/07/18 Draft of Rule 11 mx opp Tanya Koshy 5.00 $672.00 $3,360.00

06/08/18 Email to Libre team providing MTC drafts Tanya Koshy 0.10 $672.00 $67.20

06/08/18 Draft of Rule 11 mx opp Tanya Koshy 1.50 $672.00 $1,008.00

06/08/18 Email sending Libre team Rule 11 mx sanctions opp draft Tanya Koshy 0.10 $672.00 $67.20

06/11/18 Review and incorporation of co‐counsel's edits to opp to Rule 11 mx Tanya Koshy 0.10 $672.00 $67.20

06/11/18 Review and incorporation of AMP's edits to opp to Rule 11 mx Tanya Koshy 0.20 $672.00 $134.40

06/12/18

Revisions to opp to Libre and review of local rules and standing order re: TOA

and TOCs Tanya Koshy 0.80 $672.00 $537.60

06/12/18

Research into sua sponte sanctions, review of procedural history re: mediation

and stay of discovery, and email to AMP re: revisions Tanya Koshy 0.50 $672.00 $336.00

06/12/18

Additional research re: separate fee motion or motion for sanctions, revisions

to draft, and emails to AMP to discuss Tanya Koshy 0.60 $672.00 $403.20

06/12/18 Email response to AMP re: separate fee motion or motion for sanctions Tanya Koshy 0.20 $672.00 $134.40

06/12/18 Finalize draft opp to Rule 11 mx for AMP review Tanya Koshy 2.40 $672.00 $1,612.80

06/13/18

Final review of motion and supporting documents and coordination with CN re:

filing. Tanya Koshy 0.40 $672.00 $268.80

06/13/18 Review of opp to Rule 11 mx after AMP's edits Tanya Koshy 0.70 $672.00 $470.40

06/13/18 Review of Centro Legal's draft MTC arb opposition Tanya Koshy 0.30 $672.00 $201.60

06/14/18

Coordinate with CN re: re‐filing of Exhibit A and Dec in support of opposition to

Rule 11 mx Tanya Koshy 0.10 $672.00 $67.20

06/15/18

Coordination with AMP about formatting Libre MTC Arb opp. and getting it

ready for filing Tanya Koshy 0.10 $672.00 $67.20

06/15/18 and MTC in prep for draft of intro and background Tanya Koshy 1.50 $672.00 $1,008.00

06/15/18 Email to Libre team re: formatting and filing MTC Arb opp. Tanya Koshy 0.10 $672.00 $67.20

06/15/18 Email to Libre team re: coordinating finalizing document Tanya Koshy 0.10 $672.00 $67.20

06/16/18 Email to co‐counsel re: next steps with draft Tanya Koshy 0.10 $672.00 $67.20

06/16/18

Revisions to Jason's and Jesse's sections of opp to MTC compel arb, draft of

intro and background sections, reformatting; researched Cal Civ C Section 1632 Tanya Koshy 4.10 $672.00 $2,755.20

06/17/18 Revisions to Jesse's section of the opp to MTC Arb; fill in depo cites, editing. Tanya Koshy 6.40 $672.00 $4,300.80

06/17/18 Coordinate with CN and KAT re: looking at depo cites in Opp. to MTC Arb. Tanya Koshy 0.20 $672.00 $134.40

06/18/18

Preparing deposition excerpts for filing (issues with Adobe) and revising AMP

dec Tanya Koshy 1.20 $672.00 $806.40

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 24 of 30
06/18/18

Coordinate with AMP and email to Centro team re:whether to file Mr.

Vasquez's depo under seal. Tanya Koshy 0.20 $672.00 $134.40

06/18/18 Go over looking at depo cites with CN in Opp. to MTC Arb. Tanya Koshy 0.30 $672.00 $201.60

06/18/18 Coordinate with Libre team re: finalizing brief Tanya Koshy 0.20 $672.00 $134.40

06/18/18 Finalizing AMP declaration in support of MTC Arb. Tanya Koshy 0.30 $672.00 $201.60

06/18/18

Prepared clean and redlined versions of MTC Arb for circulation to team and

email to team. Tanya Koshy 0.40 $672.00 $268.80

06/19/18

Preparing deposition excerpts exhibits; making sure deposition excerpts do not

include confidential information; proofreading brief and dec; finalizing brief for

filing Tanya Koshy 5.80 $672.00 $3,897.60

08/09/18 Libre Call Tanya Koshy 0.50 $672.00 $336.00

08/10/18 Review of briefs in libre and prep for motion for sanctions Tanya Koshy 6.00 $672.00 $4,032.00

08/11/18 Review of briefs in libre and prep for motion for sanctions Tanya Koshy 0.70 $672.00 $470.40

08/12/18 Review of briefs in libre and prep for motion for sanctions Tanya Koshy 0.30 $672.00 $201.60

08/13/18

Review of briefs in libre and prep for motion for sanctions; discussion with AMP;

research into stay issues if a denial of MTC appealed. Tanya Koshy 5.80 $672.00 $3,897.60

08/14/18 Hearing Tanya Koshy 2.80 $672.00 $1,881.60

08/14/18 preparation in advance of deposition Tanya Koshy 4.00 $672.00 $2,688.00

09/25/18 Calculated response to discovery deadlines Tanya Koshy 0.10 $672.00 $67.20

09/26/18

Draft and filing of Ninth Circ mediation questionnaire; coordination with CN re:

filing Tanya Koshy 1.50 $672.00 $1,008.00

10/10/18 Draft of the opp to the 1292(b) motion Tanya Koshy 1.50 $672.00 $1,008.00

10/11/18 Draft of brief in opp to 1292(b) mx Tanya Koshy 5.40 $672.00 $3,628.80

10/15/18 Draft of brief in opp to 1292(b) mx and email to AMP re: review Tanya Koshy 4.60 $672.00 $3,091.20

10/17/18 Meeting about next steps in case (discovery, damages, amendment) Tanya Koshy 0.50 $672.00 $336.00

10/18/18

Review of AMP's edits, final review of draft opp to 1292(b) motion and email to

team for review Tanya Koshy 0.50 $672.00 $336.00

10/22/18

Reviewed J Newmark's edits to opp to 1292(b) certification motion and

accepted changes Tanya Koshy 0.20 $672.00 $134.40

10/23/18 Revisions to legal standard in opp to MTC arb Tanya Koshy 0.50 $672.00 $336.00

10/23/18

Final review of word version of opp to 1292(b) certification and email to CN

with same Tanya Koshy 3.10 $672.00 $2,083.20

10/23/18 TC with AMP with re: stay legal standard and issues with opp to MTC arb Tanya Koshy 0.90 $672.00 $604.80

10/26/18

Review of changes to TAC and coordinate with CN re: notice of motion and

motion; calculate date of hrg based on LR Tanya Koshy 0.30 $672.00 $201.60

10/27/18 Edited mx for leave to file TAC and mx for admin relief (disc sched) Tanya Koshy 0.70 $672.00 $470.40

10/28/18

Additional edits, revisions to motion to amend and mx for admin relief; email to

team for review Tanya Koshy 1.30 $672.00 $873.60

10/28/18 TC with AMP re: revisions to motion to amend and mx for admin relief Tanya Koshy 0.20 $672.00 $134.40

10/28/18

Edited mx for leave to file TAC and mx for admin relief (disc sched); email to

AMP re: same Tanya Koshy 4.20 $672.00 $2,822.40

10/29/18 Email to CN re: coordination of TAC filing Tanya Koshy 0.10 $672.00 $67.20

10/29/18 Reviewed co‐counsel's edits to mx for admin relief and emails re: same Tanya Koshy 0.30 $672.00 $201.60

10/29/18

Further review of co‐counsels edits; coordination with CN re: finalizing; emials

to AMP and CN re: finalizing; coordination with CN re: filing Tanya Koshy 1.80 $672.00 $1,209.60

11/05/18 Review dates re: mx for leave to file TAC Tanya Koshy 0.10 $672.00 $67.20

11/06/18 Research into expectations of mediation assessment and email to AMP re: same Tanya Koshy 0.20 $672.00 $134.40

11/07/18 Mediation discussion with 9th circ mediator Tanya Koshy 0.30 $672.00 $201.60

11/18/18 Research into RJN issues Tanya Koshy 0.10 $672.00 $67.20

11/18/18

Research into cases re: prejudice factor re: Rule 15 L2A and email to AMP re:

same Tanya Koshy 0.60 $672.00 $403.20

11/19/18 Draft of RJN in support of reply in support of Mx to Amend TAC Tanya Koshy 0.40 $672.00 $268.80

11/19/18 Additional changes to reply in support of mx for leave to file a TAC Tanya Koshy 0.30 $672.00 $201.60

11/20/18 TC with CC re: term sheet Tanya Koshy 0.50 $672.00 $336.00

11/20/18 Final review of reply and edits; email to CN to prepare tables Tanya Koshy 0.30 $672.00 $201.60

11/20/18 Coordination with CN re: filing of reply Tanya Koshy 0.20 $672.00 $134.40

11/20/18 Final review of reply and compilation of exhibits for RJN Tanya Koshy 0.60 $672.00 $403.20

12/10/18 TC with team re: mediation / settlement term sheet Tanya Koshy 1.00 $672.00 $672.00

12/12/18 Calculated lodestar for libre case Tanya Koshy 0.40 $672.00 $268.80

12/13/18 TC with AMP and HAZ re: Libre settlement Tanya Koshy 0.20 $672.00 $134.40

01/08/19

Review of contract docs for liability of sponsors for GPS monitoring; email to

AMP re: same Tanya Koshy 0.50 $672.00 $336.00

02/04/19 TC with team re: case strategy next steps Tanya Koshy 0.20 $672.00 $134.40

02/04/19 Discussion with APersinger re: research on DOI regs Tanya Koshy 0.10 $672.00 $67.20

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 25 of 30
02/05/19 Fact investigation Tanya Koshy 0.60 $672.00 $403.20

02/05/19

Research into bail agent licensing requirements and email to APersinger re:

same Tanya Koshy 0.80 $672.00 $537.60

02/08/19 Review of order re: mediation status report; email to Apersinger re: same Tanya Koshy 0.20 $672.00 $134.40

03/25/19 Fact invesetigation. Tanya Koshy 0.10 $672.00 $67.20

03/25/19 Email to APersinger re: Fact investigation Tanya Koshy 0.10 $672.00 $67.20

03/26/19 Fact investigation Tanya Koshy 0.40 $672.00 $268.80

04/08/19 Email to APersinger re: Fact investigation Tanya Koshy 0.10 $672.00 $67.20

04/16/19

Call with Danica Rodarmal from LCCR re: bill on immigration detention and

email to JNewmark and APennington re: the same Tanya Koshy 0.40 $672.00 $268.80

04/26/19 Emails to APersinger and JRathod re: draft of opp to motion to stay Tanya Koshy 0.20 $672.00 $134.40

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 26 of 30
EXHIBIT B 

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 27 of 30
7/22/2020 Hearing transcript Client Cost Advanced $282.75

7/21/2020 Judicate West mediation on 6/23/20 Client Cost Advanced $600.00

5/29/2020 Court document retrieval from Pacer Client Cost Advanced $5.20

4/28/2020 Conference calls during Feb 2020 Client Cost Advanced $3.76

4/21/2020 Mediation services by Judicate West Client Cost Advanced $2,525.00

2/26/2020 Pacer court document retrieval during 4th quarter 2019 Client Cost Advanced $6.10

11/25/2019 Court document retrieval from Pacer 3rd quarter 2019 Client Cost Advanced $12.20

10/24/2019 Conference calls in August 2019 Client Cost Advanced $4.50

10/2/2019 Mediation services provided by Judicate West, Santa Ana on 8/28/19 Client Cost Advanced $5,275.00

9/30/2019 Photocopies  155 @ 0.15 Photocopies $23.25

9/24/2019 Travel meal in San Francisco on 8/17/19 Client Cost Advanced $156.20

9/24/2019 Travel meal in San Francisco on 8/16/19 Client Cost Advanced $3.45

9/24/2019 Travel meal in San Francisco on 9/4/19 Client Cost Advanced $3.45

8/31/2019 Photocopies  42 @ 0.15 Photocopies $6.30

8/28/2019 Lyft ride to mediation on 8/16/19 Client Cost Advanced $12.61

8/28/2019 Travel meal in Oakland after mediation Client Cost Advanced $144.18

8/22/2019 Duplicate invoice reversed Client Cost Advanced ‐$100.00

8/21/2019 Mediation services provided by Judicate Wst Santa Monica Client Cost Advanced $5,275.00

7/31/2019 Photocopies  458 @ 0.15 Photocopies $68.70

6/29/2019 Oakland office Oct 2018 through Jun 2019  458 @ 0.15 Photocopies $68.70

2/25/2019 Court document retreival from Pacer Client Cost Advanced $5.70

1/29/2019 Court filing services provided by First Legal Network on 12/27/18 Client Cost Advanced $176.12

12/31/2018 Photocopies  84 @ 0.15 Photocopies $12.60

12/27/2018 Bart‐clipper to settlement conference on 12/12/18 Client Cost Advanced $4.00

12/27/2018 Federal express delivery on 12/8/18 Client Cost Advanced $35.10

12/27/2018 Conference call on 11/20/18 at 3:30 pm Client Cost Advanced $4.48

12/27/2018 Filing fees provided by First Legal Nework on 11/26/18 Client Cost Advanced $258.90

12/1/2018 Westlaw expenses for the month of November 2018 Client Cost Advanced $386.55

11/1/2018 Westlaw expenses during the month of October 2018 Client Cost Advanced $229.72

8/29/2018 Meal during meeting with co‐counsel in Oakland on 8/14/18 Client Cost Advanced $131.77

7/1/2018 Westlaw expenses during the month of June 2018 Client Cost Advanced $122.02

5/30/2018 Conference call on 4/10/18 at 3:00 pm Client Cost Advanced $13.52

4/26/2018 Meal in San Francisco on 3/23/18 Client Cost Advanced $32.02

4/26/2018 Meal in Oakland while preparing for mediation on 3/26/18 Client Cost Advanced $24.15

4/1/2018 Westlaw online research during the month of March 2018 Client Cost Advanced $4.32

3/27/2018 Conference call on 2/21/18 at 4:40 pm Client Cost Advanced $3.96

2/27/2018 Pacer court document retrieval 4th quarter 2017 Client Cost Advanced $0.20

11/29/2017 Pacer court document retrieval Client Cost Advanced $23.70

11/29/2017 Photocopies  84 @ 0.15 Photocopies $12.60

10/27/2017 Supplies at Walgreens in San Francisco on 10/10/17 Client Cost Advanced $2.39

10/27/2017 Bart clipper card for travel in Oakland on 10/11/17 Client Cost Advanced $7.00

10/27/2017 Travel meal on 10/10/17 in San Francisco Client Cost Advanced $10.19

10/27/2017 Hotel in Rancho Santa on 10/10/17 Client Cost Advanced $636.41

10/27/2017 Flight to San Francisco on 10/6/17 Client Cost Advanced $837.30

10/27/2017 Travel meal in Oakland on 10/9/17 Client Cost Advanced $20.48

10/27/2017 Travel meal in Arlington on 10/9/17 Client Cost Advanced $2.75

10/27/2017 Travel meal in Alameda on 10/10/17 Client Cost Advanced $16.91

10/27/2017 Additional flight charges on 10/9/17 Client Cost Advanced $27.98

10/27/2017 Hotel on 10/10/17 Client Cost Advanced $365.04

10/27/2017 Travel meal in San Francisco on 10/10/17 Client Cost Advanced $2.15

10/27/2017 Uber cabs (3) on 10/9/17 Client Cost Advanced $129.16

10/27/2017 Federal express delivery on 10/2/17 Client Cost Advanced $32.32

10/27/2017 Oakland Marriott meeting room on 10/11/17 Client Cost Advanced $723.78

10/27/2017 Flights from San Francisco on 10/8/17 Client Cost Advanced $491.98

10/27/2017 Travel meal in South San Francisco on 10/9/17 Client Cost Advanced $6.03

10/27/2017 Travel meal in Oakland 0515 on 10/9/17 Client Cost Advanced $130.86

10/27/2017 Uber cabs (3) on 10/10/17 Client Cost Advanced $50.23

10/27/2017 Bart Clipper Pleasant hill on 10/10/17 Client Cost Advanced $20.00

9/28/2017 Federal Express delivery on 8/19/17 Client Cost Advanced $52.10

9/28/2017 Oakland Marriott on 9/8/17 for mediation meeting Client Cost Advanced $682.81

9/28/2017 Federal Express delivery on 8/22/17 Client Cost Advanced $22.06

9/27/2017 Mediation services provided ADR Services invoice 17‐4424‐JL‐01 Client Cost Advanced $1,100.00

8/31/2017 Photocopies  2 @ 0.15 Photocopies $0.30

8/29/2017 Bart‐clipper cab in San Francisco on 7/25/17 Client Cost Advanced $20.00

8/29/2017 Meal in San Francisco on 7/19/17 Client Cost Advanced $3.25

8/29/2017 Lyft ride on 7/18/17 Client Cost Advanced $38.32

8/29/2017 Travel meal in Gainesville on 8/7/17 Client Cost Advanced $5.51

8/29/2017 Travel meal in Haymarket on 8/7/17 Client Cost Advanced $5.14

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 28 of 30
8/29/2017 Bart‐Pleasant Hill on 7/17/17 Client Cost Advanced $13.00

8/29/2017 National car rental in Arlington on 8/8/17 Client Cost Advanced $136.14

8/29/2017 Meal in San Francisco on 7/25/17 Client Cost Advanced $3.25

8/29/2017 Meal in San Francisco on 7/18/17 Client Cost Advanced $3.25

8/29/2017 Conference call on 7/26/17 at 2:30 pm Client Cost Advanced $8.88

8/29/2017 Meal in San Francisco on 7/25/17 Client Cost Advanced $30.58

8/29/2017 Meal in San Francisco on 7/18/17 Client Cost Advanced $66.01

8/29/2017 Conference call on 7/14/17 at 2 pm Client Cost Advanced $4.28

8/29/2017 Travel meal on 8/7/17 Client Cost Advanced $89.03

8/29/2017 Uniguest document printing on 8/4/17 Client Cost Advanced $7.50

8/14/2017 Deposition transcript provided by US Legal Support invoice 110068149 Client Cost Advanced $396.45

8/14/2017 Video deposition of N. Y. P. Rodreiguez provided by US Legal Support invoice 110068449 Client Cost Advanced $299.00

8/14/2017 Deposition transcript provided by US Legal Support invoice110068179 Client Cost Advanced $397.05

8/14/2017 Video deposition of A. V. Garcia provided by US Legal Support invoice 110068441 Client Cost Advanced $299.00

8/8/2017 Mediation services deposit to Dickstein Dispute Resolution Client Cost Advanced $7,000.00

8/7/2017 K. Calderon video deposition provided by US Legal Support invoice 110066294 Client Cost Advanced $334.00

8/3/2017 K. Calderon deposition transcript provided by US Legal Support invoice 110065528 Client Cost Advanced $402.35

8/1/2017 Westlaw online legal research for the month of July 2017 Client Cost Advanced $117.00

7/31/2017 Deposition expenses provided by Veritext invoice PA3050273 Client Cost Advanced $400.00

7/31/2017 Photocopies  351 @ 0.15 Photocopies $52.65

7/26/2017 Lyft rides (2) on 7/12/17 Client Cost Advanced $17.03

7/26/2017 DTcom charge on 7/13/17 Client Cost Advanced $90.00

7/26/2017 Hotel in San Francisco on 7/14/17 Client Cost Advanced $467.38

7/26/2017 Uber cabs (2) on 7/14/17 Client Cost Advanced $64.58

7/26/2017 Meal in San Francisco on 7/12 and 7/13/17 Client Cost Advanced $6.50

7/26/2017 San Francisco cab on 7/10/17 Client Cost Advanced $23.07

7/26/2017 Bart‐Pleasant Hills in Walnut Creek on 7/11/17 Client Cost Advanced $11.00

7/26/2017 Bart‐Pleasant Hill in Walnut Creek on 7/12 and 7/13/17 Client Cost Advanced $40.00

7/26/2017 Hotel in San Francisco on 7/12/17 Client Cost Advanced $880.70

7/26/2017 Travel meal on 7/12/17 Client Cost Advanced $7.35

7/26/2017 Conference call on 6/29/17 at 11 am Client Cost Advanced $25.04

7/26/2017 Additional flight charges on 7/10/17 Client Cost Advanced $17.99

7/26/2017 Uber cab on 6/23/17 Client Cost Advanced $9.80

7/26/2017 Lyft ride on 7/11/17 Client Cost Advanced $16.91

7/26/2017 Conference call on 6/28/17 at 11:30 am Client Cost Advanced $19.20

7/26/2017 Travel meal in Oakland on 7/12/17 Client Cost Advanced $85.73

7/26/2017 Travel meal in DC o 7/5/17 Client Cost Advanced $14.96

7/26/2017 BART‐Montgomery on 7/11/17 Client Cost Advanced $9.00

7/26/2017 Supplies from Target on 7/12/17 Client Cost Advanced $52.70

7/26/2017 Travel meal in San Francisco on 7/13/17 Client Cost Advanced $15.85

7/26/2017 Lyft ride on 7/12/17 Client Cost Advanced $9.58

7/26/2017 Trave meals on 7/14/17 Client Cost Advanced $17.09

7/26/2017 Flight on 6/25/17 Client Cost Advanced $539.80

7/26/2017 Lyft rides (3) on 7/13/17 Client Cost Advanced $39.00

7/26/2017 BART‐Montgomery on 7/13/17 Client Cost Advanced $15.00

7/26/2017 Car rental on 7/14/17 Client Cost Advanced $110.06

7/26/2017 Travel meal in San Francisco on 7/13/17 Client Cost Advanced $58.75

7/26/2017 Uber cabs (4) on 7/13/17 Client Cost Advanced $109.25

7/26/2017 Bart ‐ Montgomery on 7/12/17 Client Cost Advanced $5.00

7/26/2017 Uber cab on 7/12/17 Client Cost Advanced $21.10

7/26/2017 Travel meal at Uno Dos Tacos on 7/12/17 Client Cost Advanced $33.18

7/26/2017 Uber cab on 7/15/17 Client Cost Advanced $19.12

7/26/2017 Flight on 6/24/17 Client Cost Advanced $461.20

7/26/2017 Car rental on 7/10/17 Client Cost Advanced $51.25

7/26/2017 Travel meal in Falls Church on 6/23/817 Client Cost Advanced $29.15

7/26/2017 DTcom fee on 6/23/17 Client Cost Advanced $158.98

7/26/2017 Flight on 6/25/17 Client Cost Advanced $596.80

7/26/2017 Flight on 7/14/17 Client Cost Advanced $173.20

7/26/2017 SB Grnsboro cab on 6/22/17 Client Cost Advanced $5.19

7/26/2017 Travel meal in San Francisco on 7/10/17 Client Cost Advanced $168.12

7/26/2017 Travel meal in Dc on 7/15/17 Client Cost Advanced $16.67

7/26/2017 Lyft ride on 7/15/17 Client Cost Advanced $21.38

7/26/2017 Emporio Rulli cab o 7/14/17 Client Cost Advanced $10.49

7/26/2017 Hotel in san Francisco on 7/12/17 Client Cost Advanced $809.28

7/26/2017 Hotel in San Francisco on 7/13/17 Client Cost Advanced $349.34

7/26/2017 Lyft ride in San Francisco on 7/11/17 Client Cost Advanced $24.09

7/26/2017 Travel meal in Arlington on 7/10/17 Client Cost Advanced $5.31

7/26/2017 Uber cabs (4) on 6/22/17 Client Cost Advanced $60.90

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 29 of 30
7/26/2017 Travel meal in Chicago on 7/10/17 Client Cost Advanced $11.53

7/26/2017 Lyft ride on 7/14/17 Client Cost Advanced $29.65

7/26/2017 Travel meal 7/13/17 Client Cost Advanced $13.25

7/26/2017 Uber cabs (2) on 7/11/17 Client Cost Advanced $77.81

7/26/2017 Travel meal in San Francisco on 7/12/17 Client Cost Advanced $76.88

7/26/2017 Hotel in San Francisco on 7/13/17 Client Cost Advanced $354.76

7/26/2017 Lyft ride on 7/13/17 Client Cost Advanced $28.77

7/26/2017 Travel meal in Philadelphia on 7/15/17 Client Cost Advanced $5.51

7/26/2017 Travel meal on 7/11/17 Client Cost Advanced $10.10

7/25/2017 Video deposition of G. Perdomo Ortiz provided by US Legal Suport‐CA invoice 110062642 Client Cost Advanced $789.00

7/25/2017 Transcript of G Perdomo Ortiz deposition provided by US Legal Support‐CA invoice 110061212 Client Cost Advanced $709.75

7/25/2017 Transcript of J Q. Vasquez deposition provided by US Legal Support‐CA invoice 110061152 Client Cost Advanced $800.55

7/25/2017 V. Molina deposition transcript provided by US Legal Support invoice 110061163 Client Cost Advanced $614.75

7/21/2017 Video deposition of V. H. C. Molina provided by US Legal Support invoice 110061714 Client Cost Advanced $544.00

7/21/2017 Video deposition of J. Q. Vasquez provided by US Legal Support invoice 110061872 Client Cost Advanced $666.50

7/17/2017 Video deposition provided by Veritext invoice PA3022679 Client Cost Advanced $867.35

7/17/2017 Postage Postage $0.67

7/12/2017 Postage Postage $0.46

7/1/2017 Westlaw online research during the month of June 2017 Client Cost Advanced $21.05

6/30/2017 Transcript of D. See on 6/22/17 by Veritext invoice PA3019084 Client Cost Advanced $684.55

6/28/2017 Travel meal on 5/23/17 Client Cost Advanced $2.86

6/28/2017 Uber cabs (3) on 5/23*/17 Client Cost Advanced $170.05

6/28/2017 QuikPark in DC on 5/22/17 Client Cost Advanced $20.00

6/28/2017 Gas for rental car on 5/22/17 Client Cost Advanced $40.21

6/28/2017 Travel meal at Potbellin on 5/22/17 Client Cost Advanced $18.04

6/28/2017 Additional flight charges on 5/23/17 Client Cost Advanced $4.99

6/28/2017 Travel meal on 5/23/17 Client Cost Advanced $37.98

6/28/2017 Photocopies  2165 @ 0.15 Photocopies $324.75

6/13/2017 Postage Postage $0.67

6/12/2017 Postage Postage $0.67

6/8/2017 Postage Postage $0.67

6/1/2017 Westlaw online legal research during the month of May 2017 Client Cost Advanced $70.09

5/10/2017 Service of process to Libre by Mexus, Inc. by Capitol Process Services invoice 1526316 Client Cost Advanced $277.75

4/6/2017 Service of process provided by Capitol Process Services invoice 1524003 Client Cost Advanced $150.00

4/3/2017 US Post office certified mail on 2/16/17 Client Cost Advanced $16.26

4/3/2017 Filing fee with US District Court NDCA on 2/15/17 Client Cost Advanced $400.00

3/23/2017 Attempted service of process by Capitol Process Services invoice 1524001 Client Cost Advanced $150.00

2/16/2017 Postage Postage $2.03

$45,146.63

Case 4:17-cv-00755-CW Document 147-2 Filed 09/01/20 Page 30 of 30