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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

JUAN QUINTANILLA VASQUEZ, 

GABRIELA PERDOMO ORTIZ, and 

VICTOR HUGO CATALAN MOLINA, 

individually and on behalf of all others similarly 

situated,

PLAINTIFFS,

vs.

LIBRE BY NEXUS, INC. and JOHN DOES 1-

50,

DEFENDANTS.

Case No. 4:17-cv-00755

DECLARATION OF JASON S. RATHOD 

IN SUPPORT OF PLAINTIFFS’ 

MOTION FOR FEES, COSTS, AND 

SERVICE AWARDS

Hon. Claudia Wilken 

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 1 of 18
DECLARATION OF JASON S. RATHOD IN SUPPORT OF PLAINTIFFS’ MOTION 

FOR FEES, COSTS, AND SERVICE AWARDS

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I, Jason S. Rathod, declare as follows:

1. I am an attorney at law licensed to practice in the District of Columbia and the State 

of Illinois. I am also admitted pro hac vice in this matter and a partner at Migliaccio & Rathod LLP 

(“M&R”), counsel of record for Plaintiffs. I submit this declaration in support of Plaintiffs’ Motion for 

Fees, Costs, and Service Awards. Unless otherwise noted, I have personal knowledge of the facts set 

forth in this declaration and could and would testify competently to them if called upon to do so. 

2. In connection with Plaintiffs’ Motion for Preliminary Approval, I submitted a 

declaration (see Dkt. 134-1, ¶¶ 4-37) that elaborated – in detail and at length – the history of this 

litigation and the role of my firm in prosecuting it. I incorporate those paragraphs by reference here. I 

also attached M&R’s firm resume (see Dkt. 134-1, Exhibit 2 (pp. 93-105 of pdf), and incorporate that 

by reference as well. The firm resume sets forth a number of noteworthy consumer protection, civil 

rights, and wage theft class action lawsuits that the firm successfully prosecuted. It also presents the 

biographies and accomplishments of the attorneys who worked on this case.

3. Since the outset of this case, M&R has spent a total 905.80 hours working on this case, 

including for the work detailed in my previous declaration (see Dkt. 134-1, ¶¶ 4-37), which involved the 

following categories, among other things: (1) investigating the merits of the case; (2) coordinating 

litigation efforts with co-counsel; (3) drafting and revising Plaintiffs’ Complaint and four Amended 

Complaints; (4) engaging in written discovery including writing deficiency letters and engaging in meet 

and confer sessions; (5) attending deposition; (6) drafting and filing motions and memoranda; (7) 

drafting and reviewing mediation statements; (8) negotiating settlement terms; (9) drafting and revising 

settlement documents; (10) presenting argument at the preliminary approval hearing; and (11) 

responding to inquiries from class members. The time this reflects was time actually spent, in the 

exercise of reasonable judgment by lawyers and staff of M&R. Given the ongoing nature of the notice 

program, there will likely be many additional hours not yet recorded for this case, both prior to and 

after final approval. The hourly rates shown in the table below1for the attorneys and staff at M&R are 

1 The table reflects the most recent rates set forth in the adjusted Laffey Matrix, found at 

http://www.laffeymatrix.com/see.html . The hours and rates are consistent with that in my previous 

declaration with a few exceptions, including that I realized some entries from a paralegal (Aema Zaidi) 

were mistakenly attributed to Bruno Ortega-Toledo (a paralegal / law clerk) in my last declaration. 

That error has been corrected. The detailed time entries are appended hereto as Exhibit A. 

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 2 of 18
DECLARATION OF JASON S. RATHOD IN SUPPORT OF PLAINTIFFS’ MOTION 

FOR FEES, COSTS, AND SERVICE AWARDS

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the same as the regular rates – pursuant to the “adjusted Laffey Matrix” – charged by M&R for their 

services in other cases and as have been approved by state and federal courts across the country. For 

example, M&R’s rates were recently approved by Magistrate Judge Ryu in a class action settlement. See 

Carlotti v. Asus Comput. Int'l, No. 18-cv-03369-DMR, 2020 U.S. Dist. LEXIS 108917, at *17 (N.D. Cal. 

June 22, 2020). M&R’s rates were also recently approved in a collective action settlement in the United 

States District Court for the Eastern District of Michigan. See Whitfield v. Trinity Rest. Grp., LLC, No. 

18-10973, 2019 U.S. Dist. LEXIS 182055 (E.D. Mich. Oct. 3, 2019). M&R’s rates were also approved 

in Singer, et al. v. Postmates, No. 4:15-cv-01284-JSW (N.D. Cal. April 25, 2018) (Dkt. 98), where M&R 

served as co-counsel in a multistate wage theft class and collective action.

Timekeeper Position Hours Rate Total

Nicholas Migliaccio Partner 52.75 $759 $40,037.25

Jason Rathod Partner 717.60 $759 $544,658.40

Erick Quezada Associate 97.3 $378 $36,779.40

Ashley Pileika Associate 14.5 $378 $5,481.00

Bruno Ortega Law Clerk 0.5 $103 $103

Dominique Reid Law Clerk 16 $206 $3,296

Aema Zaidi Paralegal 7.15 $206 $1,472.90

TOTAL 905.80 $633,270.25

4. From now through final approval and, if approved, through the date of disbursement, 

there will be significant, additional work that M&R and Class Counsel will need to undertake. We will 

need to ensure that all inquiries from Settlement Class Members are timely and accurately handled. We 

will receive updates from the Settlement Administrator regarding the administration of the settlement

and follow-up as necessary, including with inquiries received from class members. We will prepare for 

and appear at the fairness hearing. If the settlement is approved and fees awarded, we also will oppose 

any appeals that may be filed. Under the terms of the settlement, we will also need to monitor LBN’s 

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 3 of 18
DECLARATION OF JASON S. RATHOD IN SUPPORT OF PLAINTIFFS’ MOTION 

FOR FEES, COSTS, AND SERVICE AWARDS

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finances to determine if it meets the thresholds triggering payments into the settlement fund, and will 

do so. 

5. Expenses are accounted for and billed separately and are not duplicated in my 

professional billing rate. M&R has not received reimbursement for expenses incurred in connection 

with this litigation. As of September 1, 2020, M&R incurred a total of $18,280.242in unreimbursed 

actual third-party expenses in connection with the prosecution of these cases. The actual expenses 

incurred in the prosecution of these cases are reflected on the computerized accounting records of my 

firm, based on receipts and check records, and accurately reflect all actual expenses incurred. These 

unreimbursed costs and expenses were incurred in connection with the effective prosecution of this 

litigation and include mediation, travel, translation and process server fees. I have included a table 

below summarizing 

Court Costs 

(e.g., pro hac 

vice fees)

Translation 

Costs (for 

retainer)

Process 

Server 

Costs (for 

subpoenas)

Travel (e.g., 

Flights, 

Accommodations, 

and Meals)

Mediation 

Costs

Total

$620 $481.50 $946.35 $7,382.95 $8,849.44 $18,280.24

6. In accepting this case, Plaintiffs’ Counsel bore considerable risk. M&R took this case 

on a fully contingent basis, meaning that we were not paid for any of our time, and that we paid all 

costs and out of pocket expenses without any reimbursement to date. During the pendency of this 

case, M&R turned away other work. In evaluating the case at the outset, my partner and I recognized 

that M&R would be contributing a substantial amount of time and advancing significant costs in 

prosecuting a class action, with no guarantee of compensation or recovery, in the hopes of prevailing 

against a highly skilled and well-funded defense. 

I declare under penalty of perjury of the laws of the United States and the State of California 

that the foregoing is true and correct. Executed on September 1, 2020 in Washington D.C. 

2 This amount is slightly less than that presented in my original declaration. In my original accounting, 

I appear to have mistakenly counted amounts attached to internal journal entries in my firm’s 

bookkeeping program as expenses when they were not. The amounts set forth herein are accurate and 

submitted after receiving additional scrutiny.

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 4 of 18
DECLARATION OF JASON S. RATHOD IN SUPPORT OF PLAINTIFFS’ MOTION 

FOR FEES, COSTS, AND SERVICE AWARDS

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Dated: September 1, 2020 Respectfully submitted,

By: /s/ Jason S. Rathod

 Jason S. Rathod

MIGLICACCIO & RATHOD LLP

JASON S. RATHOD, pro hac vice

412 H St NE, Suite 302

Washington, DC 20002

Telephone (202) 470-3520

jrathod@classlawdc.com

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 5 of 18
EXHIBIT A

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 6 of 18
First Name Last Name Position Date Hours Rate Lodestar Task Description

Aema Zaidi Paralegal 6/15/2017 0.75 206 154.5 Assist with processing plaintiff discovery production

Aema Zaidi Paralegal 10/27/2017 1 206 206 Assist with responding to CID 

Aema Zaidi Paralegal 10/30/2017 1.5 206 309 Assist with responding to CID 

Aema Zaidi Paralegal 10/31/2017 1.1 206 226.6 Assist with responding to CID 

Aema Zaidi Paralegal 11/1/2017 2.8 206 576.8 Assist with responding to CID 

7.15 1472.9

Ashley Pileika Associate 12/21/2016 1 378 378 Review investigation materials to prep for intakes and assisting with translating Spanish client intakes.

Ashley Pileika Associate 12/22/2016 1 378 378 Draft and revise intake questions for potential clients and translate to Spanish; research best legal terms in Spanish, as needed.

Ashley Pileika Associate 12/23/2016 1.5 378 567 Intake call with potential client; translate notes into Spanish.

Ashley Pileika Associate 12/28/2016 2 378 756 Intake call with potential client; translate notes into Spanish.

Ashley Pileika Associate 1/12/2017 2 378 756 Intake call with potential client; translate notes into Spanish.

Ashley Pileika Associate 1/26/2017 1.5 378 567 Assist with translatation of client retainer into Spanish.

Ashley Pileika Associate 1/26/2017 3 378 1134 Assist in investigation

Ashley Pileika Associate 1/27/2017 2.5 378 945 Intake call with potential client; translate notes into Spanish.

14.5 5481

Bruno Ortega-Toledo Law Clerk 10/23/2018 0.5 206 103 Assist with exhibit preparation

103

Dominique Reid Law Clerk 2/9/2018 2.25 206 463.5 Researched remedy for violation of california civil code § 1632

Dominique Reid Law Clerk 2/9/2018 0.75 206 154.5 Continued to research section 1632 remedies

Dominique Reid Law Clerk 2/12/2018 3.25 206 669.5 Continued to research remedies for violation of 1632

Dominique Reid Law Clerk 2/13/2018 8.25 206 1699.5 Researched remedies for 1632 violation and wrote memo

Dominique Reid Law Clerk 2/14/2018 1 206 206 Continued to work on 1632 remedies memo

Dominique Reid Law Clerk 2/14/2018 0.5 206 103 Made edits to 1632 memo

16 3296

Erick Quezada Associate 8/31/2018 0.5 378 189 Reviewed Plaintiff's Second Amended Complaint to gather relevant information and documents needed in discovery

Erick Quezada Associate 8/31/2018 0.25 378 94.5 Reviewed Mediation Statement to gather relevant information and documents needed in discovery

Erick Quezada Associate 8/31/2018 0.25 378 94.5 Reviewed Order Denying Motion to Compel Arbitration to gather relevant information and documents needed in discovery

Erick Quezada Associate 8/31/2018 0.5 378 189 Reviewed Motion to Dismiss to gather relevant information and documents needed in discovery

Erick Quezada Associate 8/31/2018 0.5 378 189 Drafted outline for first draft of Plaintiffs' second set of Document requests

Erick Quezada Associate 8/31/2018 0.75 378 283.5 Drafted Plaintiffs' Second Set of requests for document production

Erick Quezada Associate 9/14/2018 1 378 378 Drafted Plaintiff's First Set of Interrogatories

Erick Quezada Associate 9/14/2018 0.5 378 189 Revised Plaintiffs' second set of interrogatories

Erick Quezada Associate 9/14/2018 0.25 378 94.5 Conferred with co-counsel Jason Rathod regarding Plaintiffs' discovery requests

Erick Quezada Associate 9/24/2018 1.5 378 567 Researched FOIA procedures for California Department of Insurance

Erick Quezada Associate 9/24/2018 0.5 378 189 Drafted FOIA requests regarding Libre by Nexus

Erick Quezada Associate 10/11/2018 0.25 378 94.5 Conducted research regarding procedures for third-party subpoenas

Erick Quezada Associate 10/17/2018 0.75 378 283.5 Reviewed Docket and Notes in preparation for drafting third-party subpoenas

Erick Quezada Associate 10/18/2018 0.75 378 283.5 Drafted third-party subpoena to A to Z Bail Bonds

Erick Quezada Associate 10/18/2018 0.25 378 94.5 Edited third-party subpoena to A to Z bonds

Erick Quezada Associate 10/18/2018 0.25 378 94.5 Researched contact information for corporate representative of A to Z Bonds

Erick Quezada Associate 10/19/2018 0.5 378 189 Reviewed Defendant's Motion to Stay

Erick Quezada Associate 10/19/2018 1.25 378 472.5 Drafted outline to Plaintiffs' opposition to motion to stay

Erick Quezada Associate 10/21/2018 0.5 378 189 Drafted Introduction to Plaintiffs' opposition to Motion to Stay

Erick Quezada Associate 10/21/2018 0.25 378 94.5 Drafted legal standard to Plaintiffs' opposition to Motion to Stay

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 7 of 18
Erick Quezada Associate 10/21/2018 0.5 378 189 Drafted argument section A, substantial question analysis to Plaintiffs' opposition to Motion to Stay

Erick Quezada Associate 10/21/2018 0.75 378 283.5 Drafted section B of argument, balance of hardships, to Plaintiffs' opposition to Motion to Stay

Erick Quezada Associate 10/21/2018 1.5 378 567 Conducted research regarding the standards for leave to amend

Erick Quezada Associate 10/21/2018 0.75 378 283.5 Conducted research regarding the good cause requirements for a request for leave to amend

Erick Quezada Associate 10/21/2018 0.5 378 189 Conducted research regarding the undue delay requirements for a request for leave to amend

Erick Quezada Associate 10/21/2018 0.25 378 94.5 Conducted research regarding the undue prejudice requirements for a request for leave to amend

Erick Quezada Associate 10/21/2018 0.5 378 189 Conducted research regarding the futility requirements for a request for leave to amend

Erick Quezada Associate 10/25/2018 0.5 378 189 Conducted Research regarding Motion requirements for Motion for leave to amend

Erick Quezada Associate 8/7/2019 0.25 378 94.5 Confirmed access to Defendant's discovery.

Erick Quezada Associate 8/7/2019 2 378 756 Reviewed and annotated the discovery produced by Defendant Libre

Erick Quezada Associate 8/13/2019 0.25 378 94.5 reviewed prior deficiency letter sent to Libre

Erick Quezada Associate 8/13/2019 4.75 378 1795.5 Reviewed Defendant's production of documents

Erick Quezada Associate 8/13/2019 0.25 378 94.5 Reviewed deficiency letter containing Plaintiff's agreed clarifications and specifications

Erick Quezada Associate 8/13/2019 0.75 378 283.5 Prepared memo regarding notes on Libre's production

Erick Quezada Associate 11/25/2019 0.9 378 340.2 Drafted argument section regarding Rule 23 requirements for motion for preliminary approval of class action settlement.

Erick Quezada Associate 11/25/2019 0.6 378 226.8 Drafted argument section regarding the predominance requirement for motion for preliminary approval of class action settlement.

Erick Quezada Associate 11/25/2019 1.5 378 567 Drafted procedural background section for motion for preliminary approval of class action settlement.

Erick Quezada Associate 11/25/2019 0.7 378 264.6 Reviewed docket for drafting background section for preliminary approval of class action settlement.

Erick Quezada Associate 11/25/2019 0.4 378 151.2 Reviewed settlement agreement to draft motion for preliminary approval.

Erick Quezada Associate 11/25/2019 4 378 1512 Drafted terms of the proposed settlement for motion for preliminary approval of class action settlement.

Erick Quezada Associate 11/26/2019 3.5 378 1323 Conducted research regarding settlement standards in the Northern District of California.

Erick Quezada Associate 11/26/2019 2.5 378 945 Conducted research regarding substantive concerns of class action settlements.

Erick Quezada Associate 11/26/2019 2.1 378 793.8 Drafted argument section regarding substantive concerns for motion for preliminary approval of class action settlement.

Erick Quezada Associate 11/26/2019 1.2 378 453.6 Edited argument section regarding substantive concerns for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/1/2019 5.6 378 2116.8 Drafted argument section for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/2/2019 1.75 378 661.5 Drafted motion for preliminary approval of class settlement.

Erick Quezada Associate 12/3/2019 0.8 378 302.4 Reviewed settlement agreement for motion for preliminary approval.

Erick Quezada Associate 12/3/2019 0.8 378 302.4 Drafted motion for leave to file a fourth amended complaint.

Erick Quezada Associate 12/3/2019 1.2 378 453.6 Drafted procedural concerns section for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/3/2019 2.9 378 1096.2 Drafted substantive concerns section for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/3/2019 2.5 378 945 Conducted research regarding approval of attorney's fees for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/3/2019 2 378 756 Drafted section on the approval of attorneys' fees and expenses for motion for preliminary approval of class action settlement.

Erick Quezada Associate 12/4/2019 5.5 378 2079 Edited Motion for Preliminary Approval

Erick Quezada Associate 12/11/2019 4.6 378 1738.8 Edited preliminary approval motion.

Erick Quezada Associate 12/19/2019 1.9 378 718.2 Reviewed Defendant's counter edits to the settlement agreement.

Erick Quezada Associate 2/3/2020 0.5 378 189 Reviewed edits and comments to the settlement agreement.

Erick Quezada Associate 2/5/2020 1.8 378 680.4 Conducted research regarding standards for approval of class action settlement in the Northern District of California.

Erick Quezada Associate 2/5/2020 0.8 378 302.4 Drafted Notice of motion.

Erick Quezada Associate 2/5/2020 0.4 378 151.2 Edited introduction to motion for preliminary approval of class action settlement.

Erick Quezada Associate 2/5/2020 0.8 378 302.4 Edited procedural background to motion for preliminary approval of class action settlement.

Erick Quezada Associate 2/5/2020 4.3 378 1625.4 Edited argument section to motion for preliminary approval of class action settlement.

Erick Quezada Associate 2/6/2020 1.6 378 604.8 Edited Plaintiff's motion for preliminary approval of class action.

Erick Quezada Associate 2/6/2020 0.8 378 302.4 Added tables to motion for preliminary approval of class action settlement.

Erick Quezada Associate 2/10/2020 1.2 378 453.6 Assisted in drafting declaration of Jason Rathod in support of motion for preliminary approval of class action settlement.

Erick Quezada Associate 2/13/2020 1.8 378 680.4 Drafted joint status report and stipulation staying the case.

Erick Quezada Associate 2/13/2020 0.7 378 264.6 Edited joint status report and stipulation staying the case.

Erick Quezada Associate 2/13/2020 0.4 378 151.2 Reviewed case docket in preparation to draft joint status report and stipulation staying the case.

Erick Quezada Associate 2/13/2020 0.8 378 302.4 Drafted proposed order for the Parties' joint status report and stipulation staying the case.

Erick Quezada Associate 2/14/2020 0.4 378 151.2 Reviewed counsel's comments to Plaintiff's draft of the Settlement Complaint.

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 8 of 18
Erick Quezada Associate 2/14/2020 1.7 378 642.6 Edited Plaintiff's Settlement Complaint.

Erick Quezada Associate 2/14/2020 0.5 378 189 Edited motion for leave to file the fourth amended complaint.

Erick Quezada Associate 5/5/2020 0.2 378 75.6 Reviewd docket for timeline of final approval briefing.

Erick Quezada Associate 5/7/2020 0.4 378 151.2 Reviewed Counsel's comments and edits on Plaintiff's amended Settlement Complaint.

Erick Quezada Associate 6/2/2020 0.4 378 151.2 Edited rates for calculation of attorneys' rates for Plaintiffs' settlement approval brief.

Erick Quezada Associate 6/2/2020 0.7 378 264.6 Reviewed attorneys' hours report worked for Plaintiffs' settlement brief.

Erick Quezada Associate 6/2/2020 0.6 378 226.8 Drafted section on attorneys' fees for Jason S. Rathod's declaration in support of Plaintiffs settlement brief.

Erick Quezada Associate 6/2/2020 1.1 378 415.8 Edited Plaintiffs' settlement brief with additional information from settlement administrator.

Erick Quezada Associate 6/2/2020 0.5 378 189 Conducted research regarding the application of attorneys' fee rates for Plaintiffs' settlement brief.

Erick Quezada Associate 6/2/2020 1.5 378 567 Reviewed Defendant's production of documents to fill in additional information into Plaintiffs' brief in support of Class Settlement and supporting documen

Erick Quezada Associate 7/21/2020 0.8 378 302.4 Reviewed Defendant's production of documents for class members' contracts with Defendant.

Erick Quezada Associate 7/21/2020 0.2 378 75.6 Reviewed notes on Defendant's discovery production.

Erick Quezada Associate 8/31/2020 0.7 378 264.6 Fielded calls from class members regarding settlement administration.

97.3 36779.4

Jason Rathod Partner 11/16/2016 1 759 759 Investigate potential case

Jason Rathod Partner 11/16/2016 1.5 759 1138.5 Investigate potential case, review complaints

Jason Rathod Partner 11/17/2016 1 759 759 Investigate potential case

Jason Rathod Partner 11/17/2016 1 759 759 Investigate potential case, review complaints

Jason Rathod Partner 11/22/2016 2.25 759 1707.75 Follow-up with intakes

Jason Rathod Partner 11/22/2016 0.5 759 379.5 Investigate potential case

Jason Rathod Partner 11/23/2016 1 759 759 Follow-up re potential intakes

Jason Rathod Partner 11/30/2016 3.25 759 2466.75 Investigate potential case

Jason Rathod Partner 11/30/2016 2 759 1518 investigate potential case; research legal claims 

Jason Rathod Partner 12/1/2016 0.75 759 569.25 call with potential client's counsel

Jason Rathod Partner 12/6/2016 0.75 759 569.25 follow-up with potential leads 

Jason Rathod Partner 12/7/2016 0.5 759 379.5 follow-up with nonprofits including centro de legal

Jason Rathod Partner 12/9/2016 0.75 759 569.25 follow-up with nonprofits re leads

Jason Rathod Partner 12/10/2016 0.25 759 189.75 follow-up with nonprofit lead

Jason Rathod Partner 12/12/2016 2.5 759 1897.5 research potential claims, formulate additional intake questions

Jason Rathod Partner 12/13/2016 0.75 759 569.25 follow-up with non-profits re investigation

Jason Rathod Partner 12/18/2016 0.25 759 189.75 follow-up with lead

Jason Rathod Partner 12/19/2016 0.5 759 379.5 follow-up with lead

Jason Rathod Partner 12/21/2016 1 759 759 intake call with potential california client and counsel and prep re same

Jason Rathod Partner 1/10/2017 0.75 759 569.25 Em cocounsel J Kaliel re intake

Jason Rathod Partner 1/11/2017 0.75 759 569.25 intake call

Jason Rathod Partner 1/24/2017 0.5 759 379.5 Investigate potential case including follow-up with intake

Jason Rathod Partner 1/24/2017 1.75 759 1328.25 Emails re retainer

Jason Rathod Partner 1/24/2017 0.5 759 379.5 Follow-up with potential clients and their representatives

Jason Rathod Partner 1/26/2017 3 759 2277 attend immigration cle / talk with counsel for leads

Jason Rathod Partner 1/27/2017 1 759 759 follow-up with nonprofits re status / intakes

Jason Rathod Partner 1/27/2017 2.5 759 1897.5 edit/research complaint

Jason Rathod Partner 1/29/2017 5.25 759 3984.75 edit/research complaint

Jason Rathod Partner 1/30/2017 4.5 759 3415.5 research / edit complaint

Jason Rathod Partner 1/31/2017 1 759 759 coordinating with potential cocounsel re collaboration on case

Jason Rathod Partner 1/31/2017 1.75 759 1328.25 review/edit complaint

Jason Rathod Partner 2/1/2017 0.5 759 379.5 review complaint 

Jason Rathod Partner 2/1/2017 1 759 759 review/edit complaint

Jason Rathod Partner 2/2/2017 1.5 759 1138.5 f/u with additional leads

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 9 of 18
Jason Rathod Partner 2/3/2017 0.75 759 569.25 Emails with J Kaliel / research re complaint / coordinating finalizing client

Jason Rathod Partner 2/6/2017 1.25 759 948.75 Research re complaint, conferences with cocounsel, coordinate translation of complaint

Jason Rathod Partner 2/7/2017 1.25 759 948.75 Review complaint; review and send JPA

Jason Rathod Partner 2/8/2017 1 759 759 Edit complaint; coordinate re JPA, filing

Jason Rathod Partner 2/9/2017 1.5 759 1138.5 Edit complaint, finalize with team

Jason Rathod Partner 2/10/2017 1 759 759 Finalize filing

Jason Rathod Partner 2/12/2017 1.25 759 948.75 Edit and finalize complaint

Jason Rathod Partner 2/13/2017 0.75 759 569.25 Finalize complaint

Jason Rathod Partner 2/15/2017 1.5 759 1138.5 Review complaint filing, circulate to team

Jason Rathod Partner 2/16/2017 0.5 759 379.5 Emails re statements made by Defendant about litigation

Jason Rathod Partner 2/17/2017 0.5 759 379.5 Emails re responding to third party inquiries

Jason Rathod Partner 2/27/2017 1.25 759 948.75 Emails and research re improper communication with clients

Jason Rathod Partner 3/2/2017 0.75 759 569.25 Emails re next steps, including getting more plaintiffs

Jason Rathod Partner 3/3/2017 0.5 759 379.5 Emails re potential Va. client

Jason Rathod Partner 3/3/2017 1 759 759 Emails / calls re Defendant contacts with plaintiffs

Jason Rathod Partner 3/9/2017 0.75 759 569.25 Emails re potential admissions in article

Jason Rathod Partner 4/2/2017 1 759 759 edit amended complaint

Jason Rathod Partner 4/3/2017 4 759 3036 edit amended complaint

Jason Rathod Partner 4/4/2017 6.5 759 4933.5 edit complaint

Jason Rathod Partner 4/13/2017 1 759 759 Emails re amended complaint

Jason Rathod Partner 4/14/2017 0.25 759 189.75 review Molina letter

Jason Rathod Partner 4/17/2017 1 759 759 Draft FOIAs

Jason Rathod Partner 4/21/2017 1 759 759 edit complaint

Jason Rathod Partner 4/24/2017 5.5 759 4174.5 edit complaint

Jason Rathod Partner 4/27/2017 1 759 759 edit complaint

Jason Rathod Partner 4/28/2017 2 759 1518 edit complaint

Jason Rathod Partner 5/2/2017 2 759 1518 review complaint

Jason Rathod Partner 5/12/2017 0.5 759 379.5 Proposal re 1532 claim as loan secured by bracelet

Jason Rathod Partner 5/15/2017 0.25 759 189.75 Review joint cmc

Jason Rathod Partner 5/18/2017 0.5 759 379.5 meeting / f/u call w J. Kaliel

Jason Rathod Partner 5/24/2017 0.5 759 379.5 edits to 30(b)(6)

Jason Rathod Partner 5/25/2017 1 759 759 Edits to RFPs

Jason Rathod Partner 5/25/2017 1.5 759 1138.5 Discussion re peonage/forced labor claims and research re same

Jason Rathod Partner 5/26/2017 0.5 759 379.5 Correspondence re peonage / forced labor claims

Jason Rathod Partner 6/7/2017 0.5 759 379.5 Coordinate with Centro / Aema re plaintiff discovery production

Jason Rathod Partner 6/8/2017 0.15 759 113.85 Coordinating team call

Jason Rathod Partner 6/13/2017 0.25 759 189.75 Email re cosigners and deps

Jason Rathod Partner 6/20/2017 0.25 759 189.75 Review emails re Libre doc production

Jason Rathod Partner 6/21/2017 1.5 759 1138.5 Prep for 30(B)(6) depo

Jason Rathod Partner 6/22/2017 6.5 759 4933.5 Prep and attend 30(B)(6) depo

Jason Rathod Partner 6/23/2017 7.5 759 5692.5 Prepare discovery responses

Jason Rathod Partner 6/26/2017 2 759 1518 Produce discovery responses

Jason Rathod Partner 6/28/2017 0.5 759 379.5 Edit dep prep script to add redirect

Jason Rathod Partner 7/7/2017 1.25 759 948.75 Draft deficiency letter

Jason Rathod Partner 7/7/2017 0.25 759 189.75 Team call

Jason Rathod Partner 7/11/2017 2 759 1518 edit and finalize deficiency letter

Jason Rathod Partner 7/21/2017 3.5 759 2656.5 Prepare and serve third party subpoenas

Jason Rathod Partner 7/25/2017 0.25 759 189.75 Strategy emails re depositions of case managers

Jason Rathod Partner 7/27/2017 1 759 759 Call re discovery deficiencies and prep re same

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 10 of 18
Jason Rathod Partner 8/22/2017 0.75 759 569.25 Research re ankle monitor alternatives

Jason Rathod Partner 8/27/2017 3 759 2277 Insert procedural history in mediation statement

Jason Rathod Partner 9/7/2017 2 759 1518 Edit mediation statement

Jason Rathod Partner 10/6/2017 0.75 759 569.25 Review CFPB CID

Jason Rathod Partner 10/8/2017 0.75 759 569.25 Mediation prep

Jason Rathod Partner 10/9/2017 10 759 7590 Mediation travel, prep, meeting

Jason Rathod Partner 10/10/2017 14 759 10626 Mediation, prep, and travel re same

Jason Rathod Partner 10/11/2017 5.5 759 4174.5 Travel for mediation

Jason Rathod Partner 10/16/2017 0.75 759 569.25 Emails with cocounsel and opposing counsel re CID

Jason Rathod Partner 10/23/2017 1 759 759 Update email re CFPB CID

Jason Rathod Partner 10/23/2017 0.5 759 379.5 Call re CFPB CID

Jason Rathod Partner 10/24/2017 0.75 759 569.25 Coordinate with Centro, Aema (paralegal) re redactions and production for CFPB

Jason Rathod Partner 10/25/2017 1.25 759 948.75 Coordinate with Aema (paralegal), centro re redactions for CFPB

Jason Rathod Partner 10/27/2017 1 759 759 Coordinate with Aema (paralegal), Centro re redactions and production for CFPB

Jason Rathod Partner 10/30/2017 2 759 1518 Read and redact for CFPB

Jason Rathod Partner 10/31/2017 2 759 1518 Review and redact for CFPB

Jason Rathod Partner 11/1/2017 5.5 759 4174.5 Redact and produce to CFPB

Jason Rathod Partner 11/21/2017 1.5 759 1138.5 Strategy call / meeting with co-counsel re next steps

Jason Rathod Partner 12/1/2017 0.25 759 189.75 Emails re follow-up inquiries from detainees unable to communicate with Libre

Jason Rathod Partner 12/5/2017 0.25 759 189.75 Emails re CFPB, other updates

Jason Rathod Partner 1/25/2018 0.25 759 189.75 Review and finalize stipulation

Jason Rathod Partner 2/8/2018 1.5 759 1138.5 Call re new fee schedule, strategy, prep re same

Jason Rathod Partner 2/12/2018 0.75 759 569.25 Confer with Dominique (law clerk) re rescission memo, review same

Jason Rathod Partner 2/13/2018 1 759 759 Confer with Dominique (law clerk) re rescission memo, review same

Jason Rathod Partner 2/14/2018 1 759 759 Confer with Dominique (law clerk) re rescission memo, review same

Jason Rathod Partner 2/19/2018 0.25 759 189.75 Update client

Jason Rathod Partner 2/20/2018 0.75 759 569.25 Emails re strategy for upcoming mediation, receiving supplemental doc production

Jason Rathod Partner 2/21/2018 0.5 759 379.5 Team strategy call and prep re same

Jason Rathod Partner 3/1/2018 0.5 759 379.5 Confer re Libre offer to help pay bond

Jason Rathod Partner 3/20/2018 1 759 759 Call with opposing counsel and co-counsel and prep re same

Jason Rathod Partner 3/21/2018 0.25 759 189.75 Review data request email

Jason Rathod Partner 3/25/2018 4 759 3036 Mediation statement

Jason Rathod Partner 3/26/2018 2 759 1518 Mediation statement

Jason Rathod Partner 3/27/2018 2.25 759 1707.75 Edit and finalize mediation statement

Jason Rathod Partner 3/27/2018 1.25 759 948.75 Strategy call with co-counsel

Jason Rathod Partner 3/28/2018 10 759 7590 Travel for mediation

Jason Rathod Partner 3/30/2018 9 759 6831 prep and attend mediation

Jason Rathod Partner 3/30/2018 0.25 759 189.75 Emails/ recap re mediation

Jason Rathod Partner 4/3/2018 4 759 3036 Research / email re potential angle on UCL claim

Jason Rathod Partner 4/9/2018 1.5 759 1138.5 Review / discuss email from Judge Lambden

Jason Rathod Partner 4/10/2018 1 759 759 Research and email re new potential UCL theory

Jason Rathod Partner 4/11/2018 0.75 759 569.25 Team strategy call and prep re same

Jason Rathod Partner 4/12/2018 1 759 759 Emails re decision on settlement or continuing case

Jason Rathod Partner 4/17/2018 0.5 759 379.5 team call re strategy and next steps

Jason Rathod Partner 4/24/2018 0.25 759 189.75 Emails re details of Libre system 

Jason Rathod Partner 5/11/2018 0.5 759 379.5 new intake

Jason Rathod Partner 5/25/2018 1 759 759 Email re schedule

Jason Rathod Partner 6/5/2018 0.5 759 379.5 call re schedule / strategy, next steps

Jason Rathod Partner 6/8/2018 0.75 759 569.25 research and email re McGill decision for opposition to motion to compel arbitration

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 11 of 18
Jason Rathod Partner 6/11/2018 0.75 759 569.25 Review / edit Rule 11 brief

Jason Rathod Partner 6/11/2018 2.5 759 1897.5 Draft opposition to Motion to Compel arbitration

Jason Rathod Partner 6/12/2018 6 759 4554 Draft opposition to Motion to Compel arbitration

Jason Rathod Partner 6/13/2018 1 759 759 Draft opposition to Motion to Compel arbitration

Jason Rathod Partner 6/14/2018 0.75 759 569.25 Review / edit opposition to motion to compel brief re language translation / fraud in the execution issue

Jason Rathod Partner 6/14/2018 1.5 759 1138.5 Edit opposition to Motion to Compel McGill section

Jason Rathod Partner 6/19/2018 0.2 759 151.8 Review briefing

Jason Rathod Partner 8/9/2018 0.75 759 569.25 Strategy call re discovery, other oressing issues, preparation re same

Jason Rathod Partner 8/10/2018 1 759 759 Emails and research for opposition to motion to compel arbitration to assist cocounsel in preparation for oral argument

Jason Rathod Partner 8/13/2018 1 759 759 Emails to cocounsel re preparation for oral argument on motion to compel arbitration

Jason Rathod Partner 8/14/2018 0.25 759 189.75 Emails to cocounsel re preparation for oral argument on motion to compel arbitration

Jason Rathod Partner 8/28/2018 1 759 759 Emails and conferences with E. Quezada re next steps for discovery in Libre

Jason Rathod Partner 8/31/2018 0.25 759 189.75 Review discovery prepared by E. Quezada

Jason Rathod Partner 9/5/2018 1 759 759 Emails re order and possible amendment for 1632 claim

Jason Rathod Partner 9/5/2018 1.75 759 1328.25 Draft RFPs

Jason Rathod Partner 9/7/2018 1 759 759 Emails re decision on whether to amend 1632 claim

Jason Rathod Partner 9/17/2018 2.5 759 1897.5 Draft interrogatories

Jason Rathod Partner 9/18/2018 1 759 759 Emails re Libre's notice of appeal

Jason Rathod Partner 9/18/2018 1.5 759 1138.5 Draft additional discovery requests

Jason Rathod Partner 9/20/2018 5 759 3795 Research re new common damages theory / DOI regulations. Email to team re same

Jason Rathod Partner 9/20/2018 2 759 1518 Draft additional discovery requests

Jason Rathod Partner 10/10/2018 1 759 759 Review defendant's briefs

Jason Rathod Partner 10/11/2018 0.25 759 189.75 Emails re changing schedule

Jason Rathod Partner 10/17/2018 2 759 1518 Draft amended complaint

Jason Rathod Partner 10/17/2018 2 759 1518 Conference call; prep re same; emails re same concerning exemplar submissions for shortening time

Jason Rathod Partner 10/18/2018 1.5 759 1138.5 Draft amended Complaint

Jason Rathod Partner 10/18/2018 0.5 759 379.5 Conferences with E Quezada re Libre Motion to stay

Jason Rathod Partner 10/19/2018 2 759 1518 Draft third party subpoenas

Jason Rathod Partner 10/21/2018 3 759 2277 Draft amended complaint

Jason Rathod Partner 10/21/2018 2 759 1518 Opposition to motion to stay

Jason Rathod Partner 10/21/2018 1.5 759 1138.5 Draft motion to amend

Jason Rathod Partner 10/21/2018 0.25 759 189.75 Draft and send meet and confer email to defense counsel

Jason Rathod Partner 10/22/2018 2.25 759 1707.75 Draft motion to amend

Jason Rathod Partner 10/22/2018 2.75 759 2087.25 Draft motion to extend

Jason Rathod Partner 10/22/2018 7 759 5313 Draft Opposition to Motion to Stay

Jason Rathod Partner 10/23/2018 6 759 4554 Draft Opposition to Motion to Stay

Jason Rathod Partner 10/23/2018 3.25 759 2466.75 Draft subpoenas, inquire about service

Jason Rathod Partner 10/24/2018 1 759 759 Serve subpoenas

Jason Rathod Partner 10/25/2018 3.75 759 2846.25 Draft motion to amend

Jason Rathod Partner 10/25/2018 2 759 1518 Draft motion to Extend

Jason Rathod Partner 10/26/2018 4 759 3036 Draft motion to extend

Jason Rathod Partner 10/26/2018 4.5 759 3415.5 Draft motion to amend

Jason Rathod Partner 10/26/2018 0.75 759 569.25 Call with defense counsel re motions; prepare re same

Jason Rathod Partner 10/29/2018 2.5 759 1897.5 Draft motion to extend

Jason Rathod Partner 10/29/2018 3.25 759 2466.75 Draft motion for leave to file amended complaint

Jason Rathod Partner 10/30/2018 0.75 759 569.25 Review appeal and motion to stay

Jason Rathod Partner 11/5/2018 1.5 759 1138.5 Settlement meeting with opposing counsel and preparation re same

Jason Rathod Partner 11/7/2018 1.5 759 1138.5 Discussion with opposing counsel re settlement

Jason Rathod Partner 11/7/2018 0.5 759 379.5 Emails re third party subpoena extensions

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 12 of 18
Jason Rathod Partner 11/9/2018 1 759 759 Emails re subpoenas to third parties

Jason Rathod Partner 11/14/2018 2 759 1518 Research and emails re licensure issue

Jason Rathod Partner 11/15/2018 2.5 759 1897.5 Research and emails re licensure issue

Jason Rathod Partner 11/19/2018 2.5 759 1897.5 Read and revise reply brief

Jason Rathod Partner 11/19/2018 2.25 759 1707.75 Edit term sheet document

Jason Rathod Partner 11/19/2018 0.5 759 379.5 Settlement call with opposing counsel

Jason Rathod Partner 11/20/2018 1 759 759 Call re settlement and prep re same

Jason Rathod Partner 11/20/2018 1.75 759 1328.25 revise settlement term sheet

Jason Rathod Partner 11/21/2018 0.75 759 569.25 review/revise term sheet

Jason Rathod Partner 11/21/2018 0.5 759 379.5 Review order on stay

Jason Rathod Partner 11/26/2018 3.75 759 2846.25 Review/revise term sheet

Jason Rathod Partner 11/26/2018 0.5 759 379.5 Call with opposing counsel

Jason Rathod Partner 11/27/2018 0.75 759 569.25 Call with opposing counsel re settlement, prep re same

Jason Rathod Partner 11/28/2018 0.25 759 189.75 Confirm extension

Jason Rathod Partner 11/28/2018 2.5 759 1897.5 Revise and send term sheet

Jason Rathod Partner 11/29/2018 0.5 759 379.5 Mediation call

Jason Rathod Partner 11/29/2018 2.25 759 1707.75 Revise term sheet

Jason Rathod Partner 12/1/2018 0.25 759 189.75 Advise third parties of extension

Jason Rathod Partner 12/3/2018 3.75 759 2846.25 Review and revise term sheet

Jason Rathod Partner 12/4/2018 5.5 759 4174.5 Prep for mediation, revise term sheet; conference with team re same

Jason Rathod Partner 12/5/2018 9.5 759 7210.5 Mediation and preparation re same; recap conference with N. Migliaccio

Jason Rathod Partner 12/6/2018 3.25 759 2466.75 conferences re 12/6 mediation and strategy moving forward

Jason Rathod Partner 12/7/2018 1.5 759 1138.5 Emails re settlement terms; review terms

Jason Rathod Partner 12/9/2018 0.5 759 379.5 mediation preparation

Jason Rathod Partner 12/10/2018 9.25 759 7020.75 Mediation preparation and travel

Jason Rathod Partner 12/11/2018 3.5 759 2656.5 Mediation preparation

Jason Rathod Partner 12/12/2018 15 759 11385 Mediation and mediation travel

Jason Rathod Partner 12/13/2018 7 759 5313 Mediation travel

Jason Rathod Partner 12/17/2018 1 759 759 Emails with team re settlement and monetary demand

Jason Rathod Partner 12/18/2018 0.5 759 379.5 Emails re social media post issue raised by defense counsel; conferencef with N. Migliaccio re same

Jason Rathod Partner 12/18/2018 0.5 759 379.5 Follow-up with third parties re subpoena

Jason Rathod Partner 12/28/2018 2.5 759 1897.5 Review and revise settlement term sheet

Jason Rathod Partner 1/7/2019 3.25 759 2466.75 Edit settlement term sheet

Jason Rathod Partner 1/8/2019 2.75 759 2087.25 Edit settlement term sheet, confer with team re same

Jason Rathod Partner 1/9/2019 0.25 759 189.75 Review stay request

Jason Rathod Partner 1/11/2019 3 759 2277 Settlement call and prep re same

Jason Rathod Partner 1/16/2019 0.25 759 189.75 Review email from defense counsel, request filing of stay request

Jason Rathod Partner 1/24/2019 1 759 759 Mediation call and preparation re same

Jason Rathod Partner 1/31/2019 0.25 759 189.75 Email to third party re subpoena

Jason Rathod Partner 2/4/2019 0.5 759 379.5 Team call and research re DOI

Jason Rathod Partner 2/6/2019 0.75 759 569.25 Call with third party regarding status and email to team re same

Jason Rathod Partner 2/8/2019 0.25 759 189.75 Email to mediator

Jason Rathod Partner 2/11/2019 0.25 759 189.75 Email to team re third party inquiry 

Jason Rathod Partner 2/15/2019 1.5 759 1138.5 Review term sheet, team call re same

Jason Rathod Partner 2/15/2019 0.25 759 189.75 Call with opposing counsel regarding status

Jason Rathod Partner 2/19/2019 0.5 759 379.5 Call with team re mediation, term sheet

Jason Rathod Partner 2/21/2019 0.25 759 189.75 Review stipulation

Jason Rathod Partner 2/27/2019 2 759 1518 Emails re subpoenas, protective order and review of produced docs

Jason Rathod Partner 2/27/2019 1.5 759 1138.5 Edit term sheet

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 13 of 18
Jason Rathod Partner 3/1/2019 0.5 759 379.5 Call re mailing issue in term sheet

Jason Rathod Partner 3/1/2019 1 759 759 Finalize term sheet

Jason Rathod Partner 3/3/2019 6 759 4554 Draft and send mediation statement

Jason Rathod Partner 3/5/2019 1 759 759 Finalize and send term sheet

Jason Rathod Partner 3/6/2019 1.5 759 1138.5 Prepare for mediation

Jason Rathod Partner 3/14/2019 10.5 759 7969.5 Travel and prepare for mediation

Jason Rathod Partner 3/15/2019 10 759 7590 Prep for and attend mediation

Jason Rathod Partner 3/16/2019 5 759 3795 Travel back to DC following mediation

Jason Rathod Partner 3/18/2019 0.8 759 607.2 Call with defense counsel Michael Hassen re mediation post-mortem and email to team re same

Jason Rathod Partner 3/22/2019 0.8 759 607.2 Emails re settlement with defense counsel Mary Donne Peters

Jason Rathod Partner 3/22/2019 0.5 759 379.5 Update to ninth circuit mediator

Jason Rathod Partner 3/26/2019 0.8 759 607.2 review settlement offer from defense counsel

Jason Rathod Partner 3/28/2019 0.5 759 379.5 Emails with team regarding settlement update

Jason Rathod Partner 3/29/2019 0.7 759 531.3 Call with team re Libre's latest proposal; prep re same

Jason Rathod Partner 3/29/2019 0.9 759 683.1 Call with Mary Donne Peters (defense counsel) re settlement and recap to team

Jason Rathod Partner 3/30/2019 0.6 759 455.4 Review Mary Donne Peters (defense counsel) email re settlement

Jason Rathod Partner 4/10/2019 0.6 759 455.4 Prepare and send email to defense counsel re restarting discovery

Jason Rathod Partner 4/11/2019 0.5 759 379.5 Emails to third party subpoenas re lifting of stay

Jason Rathod Partner 4/12/2019 0.4 759 303.6 Review settlement thoughts from Centro; email team re same

Jason Rathod Partner 4/16/2019 1 759 759 Review settlement proposal pitch from Centro

Jason Rathod Partner 4/17/2019 0.8 759 607.2 Emails re DOI production

Jason Rathod Partner 4/22/2019 1.5 759 1138.5 Research MTC, Judge Wilken's rules re same, and model letters in preparation for MTC

Jason Rathod Partner 4/22/2019 0.2 759 151.8 respond to Ninth Circuit mediator re status

Jason Rathod Partner 4/24/2019 0.4 759 303.6 review response to settlement from Libre

Jason Rathod Partner 4/24/2019 1.5 759 1138.5 Draft letter to the court re deficiencies

Jason Rathod Partner 4/24/2019 0.5 759 379.5 Emails to defense counsel re deficiencies

Jason Rathod Partner 4/25/2019 0.4 759 303.6 Update call with Ninth Circuit mediator; prep re same

Jason Rathod Partner 4/25/2019 1 759 759 Emails re discovery deficiencies and third party subpoenas

Jason Rathod Partner 4/25/2019 0.3 759 227.7 Email to defense counsel re mediation before Jill Sperber

Jason Rathod Partner 4/26/2019 1 759 759 Emails re deficient document production and motion to quash

Jason Rathod Partner 4/26/2019 0.4 759 303.6 Review objections in response to third party subpoena from Statewide Bonding

Jason Rathod Partner 5/1/2019 0.5 759 379.5 Emails re scheduling follow up mediation with Jill Sperber

Jason Rathod Partner 5/1/2019 0.6 759 455.4 Prepare and send letter to court sent to defense counsel to meet and confer on

Jason Rathod Partner 5/2/2019 2.5 759 1897.5 identify witnesses to depose and prepare notices

Jason Rathod Partner 5/3/2019 0.2 759 151.8 Serve deposition notices

Jason Rathod Partner 5/3/2019 0.4 759 303.6 follow-up re discovery deficiencies

Jason Rathod Partner 5/7/2019 0.2 759 151.8 Email to third party RLI re enforcing subpoena

Jason Rathod Partner 5/7/2019 0.7 759 531.3 Email to defense counsel re discovery deficiencies, involving court if meet and confer not scheduled

Jason Rathod Partner 5/9/2019 0.3 759 227.7 Email to defense counsel re discovery deficiencies

Jason Rathod Partner 5/10/2019 0.4 759 303.6 Email to defense counsel re discovery deficiencies

Jason Rathod Partner 5/13/2019 1.5 759 1138.5 Meet and confer call with defense counsel re discovery deficiencies and prep re same

Jason Rathod Partner 5/15/2019 1.6 759 1214.4 Call with defense counsel re discovery deficiencies and prep re same

Jason Rathod Partner 5/21/2019 4 759 3036 Draft lengthy deficiency letter detailing compromises and next steps

Jason Rathod Partner 5/21/2019 0.4 759 303.6 Email re defendant's response to deficiency letter

Jason Rathod Partner 5/23/2019 0.4 759 303.6 Draft letter to court in preparation for motion to compel with room for defendant to insert position

Jason Rathod Partner 5/23/2019 0.5 759 379.5 Emails introduction to new defendant counsel and response re outstanding discovery

Jason Rathod Partner 5/24/2019 0.8 759 607.2 Call with new defense counsel and prep re same

Jason Rathod Partner 5/24/2019 0.4 759 303.6 Review stip and proposed order

Jason Rathod Partner 5/29/2019 0.8 759 607.2 Emails re MOU and supplemental discovery

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 14 of 18
Jason Rathod Partner 5/30/2019 0.4 759 303.6 Emails re mediation materials

Jason Rathod Partner 5/31/2019 1.9 759 1442.1 Call re settlement and preparation re same

Jason Rathod Partner 5/31/2019 0.4 759 303.6 Call re doc production

Jason Rathod Partner 6/6/2019 0.3 759 227.7 Follow-up re status of discovery and new term sheet

Jason Rathod Partner 6/14/2019 1 759 759 Emails re document production, mediation status

Jason Rathod Partner 6/17/2019 0.5 759 379.5 Correspond with Erick (associate) re downloading Defendant's document production

Jason Rathod Partner 6/21/2019 0.8 759 607.2 Emails re mediation scheduling

Jason Rathod Partner 6/25/2019 0.3 759 227.7 review stip for extension

Jason Rathod Partner 6/27/2019 0.8 759 607.2 Prepare and send cocounsel "care package" for mediator that has relevant case documents

Jason Rathod Partner 7/2/2019 0.2 759 151.8 Send Libre JPA for mediator

Jason Rathod Partner 7/26/2019 1 759 759 Call with defense counsel Sean Sullivan re settlement and prep re same and recap to team

Jason Rathod Partner 7/30/2019 0.9 759 683.1 Call re settlement and prep re same

Jason Rathod Partner 8/6/2019 3.5 759 2656.5 Draft mediation statement

Jason Rathod Partner 8/7/2019 0.4 759 303.6 Emails to team re settlement terms and negotiation

Jason Rathod Partner 8/8/2019 0.2 759 151.8 Emails to team re settlement terms and negotiation

Jason Rathod Partner 8/9/2019 1.2 759 910.8 Emails to team re refining term sheet and settlement

Jason Rathod Partner 8/9/2019 2.4 759 1821.6 Finalize and send mediation statement

Jason Rathod Partner 8/11/2019 0.8 759 607.2 Call with defense counsel in advance of mediation

Jason Rathod Partner 8/13/2019 1.2 759 910.8 internal team emails re settlement approach at mediation

Jason Rathod Partner 8/13/2019 0.6 759 455.4 Review Defendant's mediation statement

Jason Rathod Partner 8/15/2019 8 759 6072 travel and prep re mediation

Jason Rathod Partner 8/16/2019 10 759 7590 prep and attend mediation

Jason Rathod Partner 8/17/2019 8 759 6072 travel after mediation

Jason Rathod Partner 8/27/2019 0.6 759 455.4 Emails with team re priorities for settlement

Jason Rathod Partner 8/28/2019 1.5 759 1138.5 Emails with team re priorities at mediation

Jason Rathod Partner 8/29/2019 2 759 1518 Emails and calls with team re priorities at mediation

Jason Rathod Partner 8/30/2019 1.5 759 1138.5 Emails and calls with team re priorities at mediation

Jason Rathod Partner 9/2/2019 1.8 759 1366.2 review revised proposal from Libre and Emails/ calls to cocounsel re same

Jason Rathod Partner 9/3/2019 2.5 759 1897.5 Emails with team re mediation priorities / strategy

Jason Rathod Partner 9/4/2019 10.5 759 7969.5 Mediation and prep re same

Jason Rathod Partner 9/9/2019 0.2 759 151.8 Email re notifying 9th circuit mediator of current status

Jason Rathod Partner 9/9/2019 0.2 759 151.8 Call with defense counsel re next steps

Jason Rathod Partner 9/17/2019 0.7 759 531.3 Emails re Kevin Calderon's retention / status as class rep

Jason Rathod Partner 9/24/2019 0.9 759 683.1 Emails re Kevin Calderon and stip for settlement

Jason Rathod Partner 9/30/2019 0.3 759 227.7 emails re revisions to stip for stay

Jason Rathod Partner 9/30/2019 0.3 759 227.7 Emails re retainer for Kevin Calderon

Jason Rathod Partner 10/1/2019 0.3 759 227.7 Emails to defense counsel re proposed edits to stip

Jason Rathod Partner 10/1/2019 0.5 759 379.5 Emails re next steps

Jason Rathod Partner 10/2/2019 0.6 759 455.4 Call re next steps with defense counsel and prep re same

Jason Rathod Partner 11/5/2019 1.2 759 910.8 review settlement agreement; emails to team re same

Jason Rathod Partner 11/7/2019 1.8 759 1366.2 Review settlement agreement; Jesse Newmark's (cocounsel) comments; emails re same

Jason Rathod Partner 11/11/2019 1 759 759 Review settlement agreement and email to defense counsel re same

Jason Rathod Partner 11/13/2019 0.3 759 227.7 Emails re coordinating call with defense counsel

Jason Rathod Partner 11/14/2019 0.8 759 607.2 Call with team and defense counsel; prep re same

Jason Rathod Partner 11/19/2019 0.5 759 379.5 Review proposed amended complaint; email re same

Jason Rathod Partner 11/21/2019 0.5 759 379.5 Direct E. Quezada re drafting preliminary approval motion

Jason Rathod Partner 11/26/2019 1 759 759 Call re finalizing settlement agreement, next steps; prep re same

Jason Rathod Partner 12/4/2019 0.5 759 379.5 edits to preliminary approval motion

Jason Rathod Partner 12/6/2019 2 759 1518 edits to preliminary approval motion

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 15 of 18
Jason Rathod Partner 12/12/2019 0.5 759 379.5 call re finalizing settlement

Jason Rathod Partner 12/12/2019 0.8 759 607.2 Emails re next steps and notice issues

Jason Rathod Partner 12/13/2019 0.5 759 379.5 Emails re notice issues

Jason Rathod Partner 12/20/2019 1 759 759 Edits / comments to settlement agreement to group

Jason Rathod Partner 12/20/2019 2 759 1518 edit preliminary approval brief and send to group

Jason Rathod Partner 1/3/2020 0.5 759 379.5 Emails to group re notice program

Jason Rathod Partner 1/6/2020 0.4 759 303.6 Emails to group re notice program

Jason Rathod Partner 1/7/2020 0.5 759 379.5 Call with proposed settlement administrator

Jason Rathod Partner 1/8/2020 1.4 759 1062.6 Circulate draft of proposed order

Jason Rathod Partner 1/8/2020 0.8 759 607.2 Edit and send notices

Jason Rathod Partner 1/8/2020 0.5 759 379.5 Call with potential claims administrator P&N / Kyle Mason re settlement administration

Jason Rathod Partner 1/9/2020 1 759 759 Draft status report

Jason Rathod Partner 1/10/2020 0.4 759 303.6 review cost estimate from P&N for settlement administration

Jason Rathod Partner 1/16/2020 0.4 759 303.6 Review cost estimate / proposal from JND for administration

Jason Rathod Partner 1/20/2020 0.5 759 379.5 Edit notices; Emails re same

Jason Rathod Partner 1/21/2020 0.2 759 151.8 Emails to group re notice program

Jason Rathod Partner 1/23/2020 0.4 759 303.6 Review Angeion cost proposal

Jason Rathod Partner 1/29/2020 0.5 759 379.5 Emails re notices / settlement agreement edits

Jason Rathod Partner 1/31/2020 0.8 759 607.2 edit and file stip; Emails re same

Jason Rathod Partner 2/2/2020 1.5 759 1138.5 Edits to settlement agreement; send to group

Jason Rathod Partner 2/7/2020 0.5 759 379.5 Edits to motion for preliminary approval brief

Jason Rathod Partner 2/10/2020 1.4 759 1062.6 Call re edits to settlement agreement and prep re same

Jason Rathod Partner 2/11/2020 0.5 759 379.5 Emails re schedule going forward and motion for preliminary approval

Jason Rathod Partner 2/13/2020 0.4 759 303.6 Emails re filing stip

Jason Rathod Partner 2/14/2020 1.2 759 910.8 Emails re settlement agreement / stip

Jason Rathod Partner 2/14/2020 0.6 759 455.4 directing E. Quezada re settlement complaint

Jason Rathod Partner 2/17/2020 0.5 759 379.5 Emails re settlement and motion for leave

Jason Rathod Partner 2/18/2020 0.5 759 379.5 Emails re next steps in light of Libre's obstruction/delay

Jason Rathod Partner 2/19/2020 0.6 759 455.4 call with defense counsel and prep re same

Jason Rathod Partner 2/20/2020 0.5 759 379.5 review communications with JND re capped amount

Jason Rathod Partner 2/23/2020 1.8 759 1366.2 edit settlement agreement and notices and send to team, highlighting potential issues

Jason Rathod Partner 2/24/2020 0.7 759 531.3 finalize and send settlement docs to defense counsel

Jason Rathod Partner 2/27/2020 0.3 759 227.7 Emails with team and defense counsel re status

Jason Rathod Partner 3/1/2020 0.2 759 151.8 Emails with team defendant and status of settlement 

Jason Rathod Partner 3/2/2020 0.5 759 379.5 call with defense counsel regarding status of settlement and prep re same

Jason Rathod Partner 3/4/2020 0.8 759 607.2 draft and send status report

Jason Rathod Partner 3/5/2020 1 759 759 finalize and file status report

Jason Rathod Partner 3/6/2020 0.5 759 379.5 coordinate re filing proposed order

Jason Rathod Partner 3/9/2020 0.2 759 151.8 email to mediator Jill Sperber

Jason Rathod Partner 3/25/2020 0.2 759 151.8 Emails re another possible mediation to resolve outstanding issue

Jason Rathod Partner 3/26/2020 0.3 759 227.7 Emails re mediation timing

Jason Rathod Partner 3/31/2020 1.4 759 1062.6 Send / edit status report

Jason Rathod Partner 4/3/2020 0.4 759 303.6 review court's order re status report; emails re same

Jason Rathod Partner 4/6/2020 0.6 759 455.4 Emails re scheduling mediation

Jason Rathod Partner 4/7/2020 0.5 759 379.5 mediation call

Jason Rathod Partner 4/9/2020 0.2 759 151.8 Emails re mediation scheduling

Jason Rathod Partner 4/10/2020 0.4 759 303.6 review status report and emails re same

Jason Rathod Partner 5/5/2020 0.8 759 607.2 Emails re mediation and mediation statement

Jason Rathod Partner 5/6/2020 1.9 759 1442.1 Edit mediation statement and send; Emails re mediation

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 16 of 18
Jason Rathod Partner 5/12/2020 1.5 759 1138.5 final emails and prep for mediation

Jason Rathod Partner 5/13/2020 14 759 10626 prep and attend mediation

Jason Rathod Partner 5/14/2020 1.4 759 1062.6 Email follow-ups re mediation, next steps

Jason Rathod Partner 5/15/2020 1 759 759 Email follow-ups, including status report

Jason Rathod Partner 5/20/2020 1.5 759 1138.5 edit and send motion for preliminary approval

Jason Rathod Partner 5/22/2020 0.3 759 227.7 Email to Sean (defense counsel) re declaration from claims administrator

Jason Rathod Partner 5/22/2020 0.5 759 379.5 Send email re outstanding exhibits

Jason Rathod Partner 5/26/2020 1 759 759 Emails re final approval briefing

Jason Rathod Partner 5/27/2020 2 759 1518 edit preliminary approval brief and emails re same

Jason Rathod Partner 5/28/2020 0.3 759 227.7 email re amended complaint and motion

Jason Rathod Partner 5/29/2020 0.5 759 379.5 Review settlement complaint and motion and emails re same

Jason Rathod Partner 5/31/2020 2.5 759 1897.5 Prepare declaration in support of approval

Jason Rathod Partner 6/1/2020 12 759 9108 Prepare preliminary approval papers and emails with team re same

Jason Rathod Partner 6/2/2020 6 759 4554 Prepare preliminary approval papers and emails with team re same

Jason Rathod Partner 6/24/2020 0.7 759 531.3 Call re settlement terms and prep re same

Jason Rathod Partner 7/14/2020 0.3 759 227.7 Update Third Circuit mediator and emails with defense counsel re same

Jason Rathod Partner 7/17/2020 4 759 3036 Prep for hearing

Jason Rathod Partner 7/19/2020 3.2 759 2428.8 Prep for hearing

Jason Rathod Partner 7/20/2020 4 759 3036 Prep for hearing

Jason Rathod Partner 7/21/2020 0.5 759 379.5 Call with cocounsel in prep for hearing and individual prep re same to identify possible issues 

Jason Rathod Partner 7/21/2020 6.5 759 4933.5 Prep for hearing

Jason Rathod Partner 7/21/2020 0.8 759 607.2 Attend hearing

Jason Rathod Partner 7/21/2020 0.2 759 151.8 Call with opposing counsel in advance of hearing

Jason Rathod Partner 7/22/2020 0.5 759 379.5 Post-hearing call with defense counsel and prep re same

Jason Rathod Partner 7/22/2020 1 759 759 Emails re next steps

Jason Rathod Partner 7/22/2020 0.5 759 379.5 edit proposed orders

Jason Rathod Partner 7/24/2020 1.5 759 1138.5 review edits to agreement, provide feedback, emails with group re same

Jason Rathod Partner 7/24/2020 0.4 759 303.6 review final versions of settlement documents and send to opposing counsel

Jason Rathod Partner 7/26/2020 3.5 759 2656.5 edit supplemental submission

Jason Rathod Partner 7/27/2020 1 759 759 edit long-form notice

Jason Rathod Partner 7/27/2020 2.5 759 1897.5 edit proposed orders / other settlement documents and emails with team re same

Jason Rathod Partner 7/28/2020 1.8 759 1366.2 review feedback from defense counsel, confer with team and edit settlement documents

Jason Rathod Partner 7/28/2020 6.7 759 5085.3 finalize documents including supplemental brief

Jason Rathod Partner 7/28/2020 0.8 759 607.2 prepare, edit and file status report

Jason Rathod Partner 7/29/2020 10 759 7590 review/edit/finalize/file settlement docs, provide feedback re same to team

Jason Rathod Partner 8/19/2020 1 759 759 Emails and research re settlement question

Jason Rathod Partner 8/25/2020 3 759 2277 Research and prepare service award, fee, and cost brief

Jason Rathod Partner 8/26/2020 4.5 759 3415.5 Research and prepare service award, fee, and cost brief

Jason Rathod Partner 8/27/2020 4.5 759 3415.5 Research and prepare service award, fee, and cost brief

Jason Rathod Partner 8/31/2020 3.5 759 2656.5 Edit service award, fee and cost brief; emails with team re same

717.6 544658

Nicholas Migliaccio Partner 2/10/2017 1.5 759 1138.5 Review complaint

Nicholas Migliaccio Partner 5/2/2017 1.25 759 948.75 Reveiw draft Amended Complaint

Nicholas Migliaccio Partner 10/12/2017 0.75 759 569.25 Conferences with J. Rathod re mediation

Nicholas Migliaccio Partner 3/27/2018 0.75 759 569.25 Review mediation statement

Nicholas Migliaccio Partner 6/15/2018 0.5 759 379.5 Review Opposition to Motion to Compel Arbitration

Nicholas Migliaccio Partner 9/18/2018 1 759 759 Conferences with third party attorney re potential pro bono involvement

Nicholas Migliaccio Partner 10/16/2018 1.25 759 948.75 Review briefs (including for opposition to motion to stay) and conference with J. Rathod re same

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 17 of 18
Nicholas Migliaccio Partner 10/23/2018 0.75 759 569.25 Review draft Opposition to Motion to Stay

Nicholas Migliaccio Partner 11/20/2018 1.25 759 948.75 Review Order denying Motion to Stay; conference with J. Rathod re same

Nicholas Migliaccio Partner 12/3/2018 1.25 759 948.75 Review order granting leave to amend; conference with J. Rathod re same

Nicholas Migliaccio Partner 12/4/2018 3.5 759 2656.5 Prep for mediation; review file and materials in advance; conference with J. Rathod re same

Nicholas Migliaccio Partner 12/5/2018 9.5 759 7210.5 Mediation with opposing counsel and J. Rathod; review materials re same; conference with J. Rathod re same

Nicholas Migliaccio Partner 12/9/2018 1 759 759 Prepare for mediation

Nicholas Migliaccio Partner 12/10/2018 9.5 759 7210.5 Mediation prep and travel; conference with J. Rathod re same

Nicholas Migliaccio Partner 12/11/2018 1.5 759 1138.5 Mediation prep

Nicholas Migliaccio Partner 12/12/2018 13 759 9867 Mediation and return travel to DC

Nicholas Migliaccio Partner 12/17/2018 1.25 759 948.75 Emails re oustanding settlement issues; calls re same; conference with J. Rathod

Nicholas Migliaccio Partner 1/7/2019 1.5 759 1138.5 Review term sheet and call re same

Nicholas Migliaccio Partner 1/11/2019 1.75 759 1328.25 Call with co-counsel re settlement issues; review materials re same; review term sheet

52.75 40037.3

Case 4:17-cv-00755-CW Document 147-1 Filed 09/01/20 Page 18 of 18