Exhibit 11

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 1 of 22 PageID: 20074
2719 ‐ Susman Godfrey, LLP

1 ‐ US Ex Rel v Boston Scientific, et alsTimekeepers' Hours, Years in Practice, Hourly Rates & RoleGWM ‐ Grant W. McGuire ‐ 1,007.50 hours ‐ 24 years practicing ‐ $400.00 hourly rate ‐ PartnerKST ‐ Kelly S. Thomas ‐ 2.60 hours  ‐ 10 years practicing ‐ $150.00 hourly rate ‐ Associate

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Date Initials Hours Rate Fees Description

12/01/15 GWM 0.60            400.00       240.00              Communications with MP re:  potential representation of BC on criminal/traffic issue ‐ munic

12/08/15 GWM 4.60            400.00       1,840.00 Ongoing review of docket re:  Ex Rel  matter where TMW&B will serve as local counsel with S

materials successor counsel will be allowed to review and which materials should be avoided

12/08/15 GWM 1.30            400.00       520.00              Review of draft letter to MCA and communications re:  same (.80); attended to filing letter w

12/09/15 GWM 5.50            400.00       2,200.00          Reviewed docket and internet re:  nature of case;

12/10/15 GWM 2.20            400.00       880.00 Receipt and review defendants submission to court re:  opposition to communications with B

counsel at SG and analysis of substance and manner of response (1.50);

12/15/15 GWM 0.30            400.00       120.00              Communications with AS re:  application to MCA re:  accessibility to BR file;

12/18/15 GWM 4.50            400.00       1,800.00          On‐going review of Bahnsen Docket and research re:  understanding of underlying factual iss12/21/15 GWM 2.40            400.00       960.00 Communications with AS and Court re:  call/conference re:  Blank Rome issue (weekend) (.60

associated with review of BR file (1.80);

12/22/15 GWM 2.90            400.00       1,160.00 Review of complaints; answers and motions including protective order (2.30); communication

(.60);

12/23/15 GWM 4.60            400.00       1,840.00          Prep for 12/30 conference with court ‐ review of pleadings and supporting materials on PACE12/28/15 GWM 1.00            400.00       400.00 Prep for 12/30 conference call with court on issue of what communications we may have wit

light of Court's 11/30/15 order DQing BR on conflict;

12/28/15 GWM 0.60            400.00       240.00              Communications 1/24 ‐ 1/27 among counsel re:  12/30 conference;12/29/15 GWM 3.00            400.00       1,200.00          Reviewed complaint/other pleadings in advance of conference with court on 12/30;12/29/15 GWM 1.00            400.00       400.00              Background RS on Felice B. Galant (defense counsel);

12/30/15 GWM 3.10            400.00       1,240.00

Communications with AS; RS and FG including (evening calls/e‐mails) in advance of conferencwith court re:  BR issues and representation remains prospective (.50); post conference comm

(.60);

01/04/16 GWM 3.30            400.00       1,320.00 Prep for conf call with trial team (.70); conference call with trial team (.50); prep notice of ap

appearance (.20); call w/opposing counsel (.30); e‐mails re:  days business (1.40);

01/04/16 GWM 2.20            400.00       880.00              Reviewed docket re: procedural status and pleadings;

01/04/16 GWM 0.50            400.00       200.00              Attended to protective order and compliance re:  same;

01/05/16 GWM 4.80            400.00       1,920.00 Reviewed key docket entries in advance of 1/11/16 conference with court re:  status ‐ protec

and prior motions to compel;

01/06/16 GWM 2.00            400.00       800.00              Prep for call with BR and SG re:  status of case (1.40); call with BR and SG (.60);

01/06/16 GWM 0.60            400.00       240.00              PHV e‐mails;

01/07/16 GWM 0.80            400.00       320.00 E‐mail from C. DaCosta and revised M. Gerra's Cert in Support of PHV motion (.20); Commun

clients re:  BR discovery (.60);

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 2 of 22 PageID
01/08/16 GWM 6.60            400.00       2,640.00 Communications re:  PHV; deal/agreement with defense counsel re:  materials from Blank Ro

receive/review and initial review of same;

01/08/16 GWM 1.20            400.00       480.00              Prep for 1/11/16 Conference with MJ Wettre re:  discovery;01/11/16 GWM 1.50            400.00       600.00 Prep for 10 a.m. conference call with counsel and court (.60); pre‐conference communication

call with counsel and MJ Wettre (.60);

01/11/16 GWM 5.50            400.00       2,200.00 On‐going review of Bos Sci discovery as provided by Blank Rome and organization of same (4

communications/e‐mail with counsel and clients (1.20);

01/12/16 GWM 5.50            400.00       2,200.00          Reviewed JP dep transcript and plaintiff's rogs and defendant's  rogs;

01/12/16 GWM 0.20            400.00       80.00                Communications re:   BR discovery and transfer re:  same;

01/13/16 GWM 8.00            400.00       3,200.00

Completed review of WB and CF dep transcripts  and notes re:  same (4.80); e‐mails re:  manaexperts (1.10); attended to Substitution of Attorney form and filed same (1.0); attended to PH(1.10);

01/14/16 GWM 7.20            400.00       2,880.00

Communications re:  Rebecca Bush (expert previously engaged by BR) and materials associatereceipt and review e‐mail re:  weekly conference call and task list re:  same (.60); communicaconsultants) (.40); conference call with trial team (.50); reviewed discovery in prep for call wi

01/15/16 GWM 6.40            400.00       2,560.00

Communications with defense counsel re:  met and confer (.30); initial review of priv logs as pBahnsen/Fuentes and issues identified in correspondence re: same (3.30); prep for conferenc

confer re:  discovery disputes (2.80);

01/18/16 GWM 3.60            400.00       1,440.00          Reviewed SG work product re: summary of discovery thus far digested and summaries of CF; 

01/19/16 GWM 3.30            400.00       1,320.00

Conference call with SG team in prep for call with defense counsel on discovery issues (.50); cdiscovery issues (.60); e‐mails re: BR proofs as to legitimate discovery disputes/deficiencies o

communications re:  3rd party vendor (Brattles) efforts (.60); e‐mails re:  AUSA insights/posit

3rd party discovery/former employees whom may be friendly/helpful (.40);

01/19/16 GWM 1.30            400.00       520.00 Reviewed docket re:  rulings as to discovery issues and case management in prep for 1/22 de

MJ Wettre as to status of discovery;

01/20/16 GWM 7.90            400.00       3,160.00

Communications and  review of JC's PHV application (.60); communications and review of daconference call with R.B. (2.90); conference call with Trial team and R.B. on damages and proCommunications with counsel re: 1/21/16 conference call with defense counsel on discovery(1.60); e‐mails re:  additional fact witnesses:  R. Nossa; A. Pierce and R. Garcia and review of d

(1.40);

01/21/16 GWM 7.20            400.00       2,880.00

Prep for call with counsel for defendants re:  discovery issues (2.20); call with defense counse

letter to MJ Wettre (2.0); analysis of documents/discovery re:  damages (2.0); communicationdocuments (.50);

01/22/16 GWM 8.10            400.00       3,240.00

E‐mails and phone communications in prep for filing joint discovery status letter with Court (3and exhibits to draft letter (2.4); review/analysis of underlying discovery and discovery disputcounsel and defense counsel (1.60); filed letter with MJ Wettre (.20); attended to/filed J. Con

01/22/16 GWM 0.50            400.00       200.00              Reviewed "new" interrogatory to be served on defense counsel;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 3 of 22 PageID
01/25/16 GWM 7.10            400.00       2,840.00

Prep for conference with counsel and MJ Vettre at 1:45 (2.50); Communications with trial teacourt (2.90); Conference with Court (.50); Receipt and review order granting JC's PHV admisssame (.20); reviewed info re:  Web Extender data (1.0);

01/26/16 GWM 5.50            400.00       2,200.00

Privi log review/analysis (2.40); Notice re:  clerks entry re:  1/25 conference (.10); analysis re:Arleo that limited additional discovery is necessary and that defendants have not been entire

description of chronology of discovery (3.0);

01/27/16 GWM 3.30            400.00       1,320.00          Prep for call with Judge Arleo re: discovery reviewed underlying disc (as available) and summ

01/28/16 GWM 4.80            400.00       1,920.00 Communications re:  task list, meeting with clients weekend of 1/30/16; review of BR work p

DeAlmeida materials;

01/29/16 GWM 1.80            400.00       720.00              Communications with trial team (.20); ongoing review of damages documents in prep for call

02/01/16 GWM 2.70            400.00       1,080.00          Communications with trial team and review of initial written discovery;

02/02/16 GWM 2.20            400.00       880.00              PHV activity for JC, AS, et als (1.20); Receipt and review agenda for weekly call and prep for sa

02/03/16 GWM 3.00            400.00       1,200.00 Communications with counsel re: discovery issues to address with Court and review of discov

re:  missing pieces not provided by defendants;

02/04/16 GWM 4.50            400.00       1,800.00

AS e‐mail to F.G. re:  extract file as to Medicare claims 2007‐09 and spreadsheet re:  claims ‐ are:  priv log issues and review of summary and prep for conference with MAC re:  same (1.0);

2/4/16 conference call and prep for same (.50); conference call with trial team (.50); e‐mail re(.1); Receipt and review materials re:  BS compliance with Medicare (1.10);

02/05/16 GWM 1.60            400.00       640.00              E‐mails and analysis of priv log (19 separate logs) in context of ongoing disc dispute;02/08/16 GWM 1.40            400.00       560.00              Communications among counsel re: priv. log issues;

02/08/16 GWM 0.40            400.00       160.00              E‐mails re: sources of extract files;

02/10/16 GWM 2.00            400.00       800.00              Review of talking points/all discovery related issues in prep for presentation to Court;

02/11/16 GWM 1.70            400.00       680.00 Communications among counsel re:  discovery issues (.40); Receipt and review task list (week

conference call (.50); conference call with trial team (.50); post conference call with BC (.20);

02/12/16 GWM 3.00            400.00       1,200.00 Reviewed privilege log issues and BS various tactics at providing discovery in advance of filing

R. Nossa outline of questions;

02/16/16 GWM 3.60            400.00       1,440.00

Receipt and review BS Notices re:  intent to serve subpoenas on National Heritage Insurance 

attendant issues ‐ communications with AP on said issues ‐ review of discovery with respect tReceipt and review draft letter to Arleo re:  discovery and communications re:  same/timing a

02/17/16 GWM 3.00            400.00       1,200.00          E‐mails re: letter to Arleo; revisions and attached to filing letter and attachments (2.60); e‐ma

02/18/16 GWM 0.60            400.00       240.00              E‐mails re:   R. Nassa interview and analyses re: same;02/18/16 GWM 0.30            400.00       120.00 Receipt and review order from MJ Wettre scheduling in person conference on discovery issue

same;

02/18/16 GWM 1.10            400.00       440.00              E‐mails re:  agenda for conference call and prep for same (.50); conference call (.60);

02/18/16 GWM 0.20            400.00       80.00                E‐mails with adversary counsel re: reschedule 2/26 conf with court;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 4 of 22 PageID
02/19/16 GWM 3.60            400.00       1,440.00

Communications re:  2/26 conference with adversary counsel and SG (.60); letter from NR re:383 ‐ communications re: same (1.10); reviewed 3rd party subpoenas and lists of documents review/analysis of M. Burns declaration (.40); e‐mails re:  final transfer of BR documents (.30)

02/22/16 GWM 2.70            400.00       1,080.00 Communications w/BR re:  totality of file transfer and sources of information; reviewed e‐ma

itself (2.60); letter from FG re:  2/26 hearing (.10);

02/22/16 GWM 4.20            400.00       1,680.00          Receipt and review defendants objections/response to list of discovery issues and prep for 2/

02/23/16 GWM 2.50            400.00       1,000.00          E‐mails discovery/attaching various discovery requests, disputes and potential resolutions;

02/24/16 GWM 3.30            400.00       1,320.00

Receipt and review amended 30(b)(6) dep notice to corp designee and topics of deposition (.

to 30(b)(6) dep notice (.30); e‐mails re:  BR materials and gaps in review ‐ Adrian Picard e‐maand 2/24 conference with trial team (1.0); conference call with trial team e‐mails re:  hot doc

02/24/16 GWM 3.20            400.00       1,280.00

4/10/14 NR letter re:  sampling and reliance of WebExtender (.60); reviewed agreement betwof WE; may be revisited upon showing of good cause ‐ analysis re:  best way to demonstrate physician orders ‐ alternatively need to preclude NR from late production of POs or other wishave (2.60);

02/24/16 GWM 0.60            400.00       240.00              Conference call with trial team re: 2/26 hearing;

02/25/16 GWM 8.60            400.00       3,440.00 Prep for 2/26 hearing before MJ Wettre; Review/analysis of Brattle data; Conference with tri

mails with trial team Pro Hac Vice for M. Musico;

02/26/16 GWM 6.40            400.00       2,560.00

Travel to/from court for conference with MJ Wettre (1.0); met with MM, AS and MG prior to MJ Wettre and post hearing conference with opposing counsel (2.60); e‐mails and review of Nhearing calls/e‐mails with trial team (2.0);

02/26/16 GWM 0.60            400.00       240.00              Late afternoon/evening emails re: change of focus for week 2/29;

02/29/16 GWM 4.50            400.00       1,800.00

Communications re: coding issues and potential experts (1.40); Communications re:  strategyforward and potential motions to compel (1.30); communications re: pressing for meet and c

expedited fashion (.60); e‐mail to adversary counsel ‐ anytime/anywhere meet and confer (.3admitting MM PHV and communications re: same (.30); communications with BC re: big pictu

03/01/16 GWM 4.10            400.00       1,640.00          Communications with counsel for Bahnsen and review of discovery related matters ‐ Dataflow

03/02/16 GWM 4.10            400.00       1,640.00

Review realtors objections and responses to BS's 3rd NTP and Rogs (1.20); review of draft 30(same (.90); e‐mails re:  dataflow power point and review of same (.60); prep for meet and co

(1.0); meet and confer call (.40);

03/02/16 GWM 3.40            400.00       1,360.00

Communications with counsel post‐meet and confer re:  outstanding discovery issues (.70); c

re:  priv log issues (.70); e‐mail from (AP predecessor counsel) re:  previously missing correspomaterials provided by AP on 3/2/16 (1.30); receipt and review draft letter to Wettre and com

03/03/16 GWM 0.40            400.00       160.00              Communications re:  discovery disputes and letter to MJ Wettre;

03/03/16 GWM 0.50            400.00       200.00              Weekly telephone conference;

03/03/16 GWM 0.40            400.00       160.00              Communications re:  narrowing of discovery issues in advance of letter to MJ Wettre;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 5 of 22 PageID
03/04/16 GWM 6.20            400.00       2,480.00

Communications re: discovery dispute on production of physician's orders and proposed resp3/3/16 (1.10); prep for letter to MJ Clark and communications with SG re:  MJ Clark's prefere

orders/payment to Lawyers protection fund (.20); order from Court re: 3/16/16 deadline for (.30); receipt and review transcript from hearing before MJ Wettre (.60); e‐mails re:  30(b)(2)

notice (.90); draft responses to rogs/ntp and communications re:  same (.80); review and revmails re:  Texas documents (.20); receipt and review Bahnsen 1‐74 (.50);

03/07/16 GWM 6.20            400.00       2,480.00          Communications and document review;

03/08/16 GWM 1.60            400.00       640.00              Communications re:  30(b)(6) notice and with adversary counsel on variety of disc issues;

03/10/16 GWM 1.60            400.00       640.00 Musico email re:  defendant's response to Request 11 (.10) e‐mails among counsel for relator

Extender and 30(b)(6) deps.; review weekly task list;

03/11/16 GWM 1.30            400.00       520.00

Communications re:   MM PHV and request to receive e‐notifications (.20); filed request for M

(.30); receipt and review notice that MM added to list of counsel receiving e‐notices (.10); em

(.30); AS e‐mail re:  30(b)(6) dep (.20); communications with BC re:  status of letter to MJ Clar

03/14/16 GWM 0.50            400.00       200.00 Communications with AS re:  contact with MJ Clark (proposed) (.20); Receipt and review noti

conference (.10); e‐mail from MG re:  search terms (.10); MM e‐mail to L. Robinson re:  depo

03/15/16 GWM 0.40            400.00       160.00              E‐mails re:  disc disputes and in prep for 3/23/16 conference with MJ Clark;

03/16/16 GWM 0.40            400.00       160.00              Communications with defense counsel re:  logistics of status letters;

03/16/16 GWM 2.90            400.00       1,160.00

E‐mails re:  discovery related issues in advance of 3/16 meet and confer deadline for status le

and review defendant's status letter to MJ Clark (.50); Receipt and review draft status letters (1.0);

03/17/16 GWM 1.00            400.00       400.00 Communications with SG re:  courtesy copy to Judge V. (.20); call to Judge V's chambers ‐ dire

(.10); Receipt and review task list (.10); weekly conference call with SG (.50);

03/18/16 GWM 2.60            400.00       1,040.00          Communications re:  variety of disc issues and attachments to e‐mails;

03/21/16 GWM 4.60            400.00       1,840.00

30(b)6 caselaw and issues ‐ communications re: same (1.10); expert witness info and commuattachments re:  Web Extender data for Physicians orders (1.60); e‐mails re: BS billing protocattachments (.70); e‐mails re:  priv issues (.30);

03/22/16 GWM 4.30            400.00       1,720.00          E‐mails; attachments re:  experts; web extended and priv. log

03/23/16 GWM 6.90            400.00       2,760.00

Communications with SG re:  SCS and attached materials (1.0); order from court adjourning 3

and review e‐mails and attachments re: priv log issues and potential motion to compel (4.40)documents associated with deponents/fact witnesses (1.40)

03/24/16 GWM 2.20            400.00       880.00              E‐mails/attachments and analysis re;  priv log issues and clawback arguments from Bos Sci

03/24/16 GWM 3.70            400.00       1,480.00 Analysis re: interloc appeal (.60);  E‐mails re:  web extender data (1.60); e‐mails re: consent to

re:  67 documents designated as invalid priv claims (.80); task list and weekly conf call (.50)

03/28/16 GWM 1.40            400.00       560.00 E‐mails re:  Relator deps in California (.10); e‐mails re:  results from Niordan as to claims data

to be filed with MJ Clark and exhibits (review of same) (.70); arrangements for filing and filing

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 6 of 22 PageID
03/28/16 GWM 0.90            400.00       360.00

E‐mails re:  Mark Underwood deposition (.20); E‐mails re:  defendants objections to current 3deficiencies associated with relators responses to request for written discovery and 3/28/16 

e‐mail from F. Galant re:  defendant's priv log on claw back claims and underlying document 

03/29/16 GWM 6.90            400.00       2,760.00

E‐mails and attachments 3/25 ‐ 3/29 re:  issues associated with missing attachments from deproduction; potential experts for Medicare billing and damages; fact depositions; info from N

draft letter and exhibits to defense counsel in terms of ongoing discovery disputes; questions2007 claims data; order from Court re: 4/7 conference call and deadline for letter respondingprotective order on 30(b)(6) deps e‐mails and proposed dep subpoenas;

03/30/16 GWM 6.60            400.00       2,640.00 Communications with SG and review of documents/issues as to subpoenas for non‐party witn

issues; missing attachments; BS request for protective order and response to relator's reques

03/31/16 GWM 6.80            400.00       2,720.00 E‐mails, attachments and communications re:  Noridian claim data results; expert disclosures

defendant's position on priv log issues and weekly conference call;

04/01/16 GWM 5.90            400.00       2,360.00

E‐mail re:  Physicians orders as produced by BS and attached 3,865 PO's and analysis re:  samdates service, metadata; e‐mail from C. DaCosta and attachments re:  Noridian production, Bsupplemental priv log re:  T.Shubert; e‐mails re:  Noridian's third production; Dep Notices for other dep notice from C. DaCosta and scheduling of same;

04/01/16 GWM 1.70            400.00       680.00 E‐mails re:  Underwood subpoena, issues of timeliness re;  Underwood dep subpoena; e‐mail

issues/conduct and draft response; communications re:  upcoming conference with MJ;

04/04/16 GWM 6.20            400.00       2,480.00

Communications e‐mails/calls re:  ongoing discovery disputes and meet and confers; prep fore‐mails re:  Underwood deposition; e‐mails re:  change (proposed) of 4/7 conference to in pe

retaliation claims; issues re: BSNC's accreditation status; Noridion claims analysis; dep notices

issues;

04/05/16 GWM 3.90            400.00       1,560.00

E/mails/communications re:  retaliation claims; revised drafts re: letter to MJ Clark respondinprotective order on 30(b)(6) topics; controversy re:  documents with missing attachments; 26discovery and draft response to same; arrangements for filing letter to MJ Clark and attachmCourt; 4/5/16 production letter from BSNC and documents;

04/06/16 GWM 3.80            400.00       1,520.00          Communications and document review re: various issues addressed in 4/5 e‐mails and attach

04/07/16 GWM 4.70            400.00       1,880.00

Receipt and review e‐mails/documents circulated among counsel re:  Noridian production; m

ID searches; deposition prep (2.30); Plan and prep for conference call with MJ Clark on variouReceipt and review notice from MJ Clark re:  recusal (.10); communications with trial team readdress discovery issues with MJ Mannion ASAP (.90); weekly trial team conference call (.60)

04/08/16 GWM 4.60            400.00       1,840.00

Communications among counsel:  Hernandez deposition; live stream access for upcoming deconference; Clark's recusal; corp rep topics; clawback issues; efforts to get earlier date for co

subpoena and Noridian data;

04/11/16 GWM 2.10            400.00       840.00 Communications of 4/11 with SG team and review of attachments; Communications with Cou

with MJ Mannion (.20);

04/12/16 GWM 2.00            400.00       800.00 Daily communications; Defendant's dep notice for Underwood and conflict re:  Estrada, W. C

defendants re: fraud billing; Chau dep. topics; highlights from LaManna dep.; clawback issues

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 7 of 22 PageID
04/13/16 GWM 1.10            400.00       440.00

E‐mails re:   moving conference with MJ Mannion to 4/21 (.30); e‐mails re:  priv. issues effect

review defendants priv. log for clawbacks from 4/12 dep (.20); letter and doc production 124

to Palmetto and communications re:  Palmetto letter (.30);

04/14/16 GWM 1.80            400.00       720.00 4/14 e‐mails re:  W. Chau Dep.; Palmetto Docs; moving hearing before MJ Mannion; N. Estrad

over relator's response to BS' 3rd set of rogs;

04/15/16 GWM 1.60            400.00       640.00 4/15 e‐mails re: rog dispute, Verizon subpoena to J. Imter; Underwood dep.; spoliation issues

hearing with MJ Mannion; draft of W. Chau dep transcript; draft of Estrada dep transcript; 30

04/18/16 GWM 6.20            400.00       2,480.00

Communications re  Hernandez depositions; Estrada deposition ongoing drafts of update lettmoving telephone conference from 4/25 to 4/21; Dawn LaMana transcript and Wendy Chan subpoenas; draft e‐mail to defense counsel re:  documents associated with "special project"; clawback documents; e‐mail re  clawback documents; Gutierrez and Chavez rough transcriptsprivilege disputes as to rog responses;

04/19/16 GWM 4.40            400.00       1,760.00

E‐mails and document review re: Estrada dep.; ongoing dispute as to missing attachments froBSNC clawback claims; claims data from Noridian; draft response to submissions to MJ Manntranscript; retaliation claims;

04/20/16 GWM 0.30            400.00       120.00 Communications re: joint letter to MJ Mannion and relators letter with sealed exhibits (.40); f

with sealed exhibits (.20);

04/21/16 GWM 2.00            400.00       800.00              Conference call with MJ Mannion and argument on variety of discovery disputes;

04/21/16 GWM 0.40            400.00       160.00              Post Conference debrief with Trial team;

04/22/16 GWM 0.90            400.00       360.00

JC e‐mail re:  current edition to joint letter to MJ Mannion and review of draft letter (.20); e‐munredacted "Cover Our Butts" e‐mail and review of e‐mail (.10); e‐mails from SG team re  relere: dismissal of retaliation claims (.40);

04/25/16 GWM 3.80            400.00       1,520.00          Daily communications and review of e‐mails and attached docs__________;

04/26/16 GWM 3.60            400.00       1,440.00          Daily communications and re:  disc disputes; ongoing deps/dep transcripts;

04/28/16 GWM 2.60            400.00       1,040.00          Daily e‐mails and communications with SG Team; Galant Cert.; clawbacks and conference cal

04/29/16 GWM 2.00            400.00       800.00              Communications and document review from 4/29;

05/02/16 GWM 2.80            400.00       1,120.00          E‐mails for 5/2/16 and attachments (1.50); prep for conference with court (.80); conference w

05/03/16 GWM 3.60            400.00       1,440.00          5/3 e‐mails and attachments; request for transcript from 5/2 hearing/opinion;

05/04/16 GWM 2.80            400.00       1,120.00          E‐mails and attachments for 5/4/16; filing Joint letter and attachments under seal with MJ M

05/05/16 GWM 1.80            400.00       720.00              Weekly telephone conference and org of weeks materials;

05/10/16 GWM 2.90            400.00       1,160.00          Reviewed dep transcripts and limited video clips;

05/10/16 GWM 0.60            400.00       240.00              5/10 e‐mails;

05/13/16 GWM 0.60            400.00       240.00              E‐mails/communications for 5/13;

05/16/16 GWM 0.80            400.00       320.00              E‐mails/filing for 5/16;

05/19/16 GWM 2.00            400.00       800.00 Communications re:  deadlines/protocols for appeal of MJ Mannions 6/15 order on discovery

as to 30(b)6 deps. (.10); e‐mails re  rescheduled conference call (.10) plan/prep for appeal of 

05/19/16 GWM 0.90            400.00       360.00              Receipt and review defendants amended R.26 disclosures;

05/24/16 GWM 0.60            400.00       240.00              E‐mails and attachments re:  new claims data;

05/25/16 GWM 1.60            400.00       640.00              E‐mails and supporting materials re:  remaining 30(b)6 deps;

05/26/16 GWM 1.20            400.00       480.00              Review daily comments and conference call;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 8 of 22 PageID
05/27/16 GWM 2.20            400.00       880.00              Communications and review of draft appeal from MJ Mannions 5/2 oral decision and 5/16 or

05/31/16 GWM 1.50            400.00       600.00 Receipt and review final draft of appeal of MJ Mannions discovery decision and filed same (.8

(.30); communications with SG counsel re:  appeal (.40);

06/01/16 GWM 2.90            400.00       1,160.00          Comms for day and re:  Appeal of Mannion's 5/16 Order; report re: Burns dep and review rou

06/02/16 GWM 1.40            400.00       560.00              Comms for 6/2/16 and weekly status conf.;

06/06/16 GWM 3.80            400.00       1,520.00 Daily communications for 6/6/16 ‐ transcript issues; settlement position paper drafts and arra

paper and exhibits;

06/07/16 GWM 3.10            400.00       1,240.00          Review, revisions and communications re:  settlement position paper to MJ Mannion;

06/08/16 GWM 1.60            400.00       640.00              Initial prep for settlement conference ‐ facts and law;

06/09/16 GWM 3.10            400.00       1,240.00 Communications for 6/9/16; weekly status call; prep for 6/15 settlement conference and com

counsel re: 6/15 date;

06/13/16 GWM 4.20            400.00       1,680.00 Communications for 6/13; e‐mails and attachments re: discovery dispute letter; settlement c

and diagnosis coding;

06/14/16 GWM 5.80            400.00       2,320.00

Rec/Rev/Edits joint letter to SCM on discovery dispute; exhibits; redaction; arrangements forcommunications with counsel re:  joint letter; comms with counsel and court re:  6/15 settlempresentation;

06/14/16 GWM 1.00            400.00       400.00              Prep for settlement conference;

06/15/16 GWM 6.20            400.00       2,480.00          Prep for and attendance at settlement conference before Judge Mannion;

06/16/16 GWM 4.20            400.00       1,680.00 Drafted motion to seal; communications re:  motion to seal with SG and adversary counsel; c

with SG and adversary counsel;

06/17/16 GWM 0.80            400.00       320.00              Comms for 6/17 on mediator issues; deadlines associated with motion to seal;

06/20/16 GWM 3.90            400.00       1,560.00 Calls/e‐mails for 6/20/16's issues re:  selection of mediator, entered order on motion to seal;

RS on mediators proffered by BS;

06/21/16 GWM 4.20            400.00       1,680.00

Communications for 6/21 among plaintiff's counsel re:  mediation; supplemental discovery; rapplication for additional time to respond to MJ appeal; review/analysis 301.1 re:  90 day staHochberg, Wolin and Pisano backgrounds in false claims cases; comms with potential mediat

06/22/16 GWM 3.70            400.00       1,480.00 Daily communications with SG team; communications with AW and FH as potential mediator

consenting to mediation;

06/23/16 GWM 6.20            400.00       2,480.00 6/23 and 6/24 ‐ E‐mails re: mediator selection; receipt and review draft expert report from D

order extending BS time to respond to MJ appeal; drafts of letter to MJ Mannion re:  consent

06/23/16 GWM 2.30            400.00       920.00              E‐mails re: Medicare applications and supporting materials;

07/05/16 GWM 5.60            400.00       2,240.00 Communications re:  mediation in wake of Pisano appointment/scheduling only post Septem

statement and recent damages discovery for revisions ‐ aim to streamline/simplify;

07/06/16 GWM 0.80            400.00       320.00              Communications re:  mediation;

07/07/16 GWM 2.70            400.00       1,080.00          Communications re: 7/8/16 call with mediator (Wolin) and prep for conference call with coun

07/08/16 GWM 2.90            400.00       1,160.00          Communications re:  mediation; prep for mediation;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 9 of 22 PageID
07/11/16 GWM 4.10            400.00       1,640.00

Communications with counsel at SG re:  mediation (.60); Communications re: production re: Medicaid Services and underlying documents (2.40); review current state of mediation statem

(1.10);

07/12/16 GWM 2.30            400.00       920.00 Comms with counsel at SG and Mannion's chambers re: mediation (Wolin as mediator) (.60);

statement and damages documents (1.70);

07/14/16 GWM 3.30            400.00       1,320.00 Receipt and review order appointing Wolin as mediator (.10); communications re:   Wolin app

mediation (.60); prep for mediation (2.60);

07/15/16 GWM 1.20            400.00       480.00              Communications re:  mediation and prep for same;

07/18/16 GWM 4.30            400.00       1,720.00          Prep for mediation; communications with counsel and mediator re:  mediation; delivered har

07/19/16 GWM 4.60            400.00       1,840.00          Communications re:  mediation and prep for mediation re: damages materials and dep trans 

07/20/16 GWM 2.60            400.00       1,040.00          E‐mails re: mediation and prep for same; translated damages expert info into common sense07/21/16 GWM 5.60            400.00       2,240.00

Comms re:  expert deadlines (.40); reviewed docket re: deadlines (.40); prep for mediation (1activities presuming mediation fails ‐application to reinstate discovery motions and alternativ

trail conference (2.80);

07/22/16 GWM 2.90            400.00       1,160.00          Communications and prep for mediation;

07/25/16 GWM 3.30            400.00       1,320.00          Mediation Prep;

07/26/16 GWM 7.00            400.00       2,800.00

Travel to/from mediation (1.20); attended mediation with Judge Wolin (3.60); post mediation

(.40); post‐mediation comms re: strategy re: expediting expert discovery, path to final pre‐tri(.70); analysis re:  arguments against defendant's ability to proceed on motion for SJ (1.10);

07/27/16 GWM 3.30            400.00       1,320.00 Communications re:  expert discovery (.60); research/analysis re:  achieving expedited trial da

dispositive motion practice would be futile and an exercise in delay/contrary to judicial resou

07/28/16 GWM 3.80            400.00       1,520.00          Post mediation analysis/to do list and analysis re:  in limine motions, renewed appeal of MJ d07/28/16 GWM 1.10            400.00       440.00              Communications with counsel re: expert deadlines;

07/29/16 GWM 3.40            400.00       1,360.00 Comms re: expert deadlines (.60); analysis re:  streamlining case for trial/arguments re: no ne

mechanisms to get appeal of MJ decision and discovery motion adjudicated post‐haste (2.80)

08/01/16 GWM 2.80            400.00       1,120.00 Communications re:  discovery deadlines in wake of failed mediation and review of proposed

orders and current status of discovery/motion practice;

08/01/16 GWM 1.40            400.00       560.00              Ongoing analysis re:  best approach to short‐cut BS's anticipated maneuvering for SJ ‐ too ma

08/02/16 GWM 0.40            400.00       160.00              Comms re: Expert deadlines;

08/03/16 GWM 0.40            400.00       160.00              Communications re:  reinstatement of MJ appeal and discovery motion;

08/04/16 GWM 1.60            400.00       640.00              Analysis/plan/prep for potential inactivity and push for adjudication of MJ appeal and/or disc

08/05/16 GWM 0.30            400.00       120.00              Comms with SG re:  week of 8/8;

08/22/16 GWM 0.50            400.00       200.00              Communications re: deadlines for expert discovery;

08/23/16 GWM 1.60            400.00       640.00              Receipt and review latest draft of Baer report and communications re: same;

08/24/16 GWM 0.40            400.00       160.00              Communications with SG re:  expert deadlines;

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 10 of 22 Pa

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08/25/16 GWM 2.90            400.00       1,160.00 Communications with SG re: expert deadlines and review of draft expert reports and prep for

Mannion re: deadlines in light of no decision on motion;

08/26/16 GWM 1.00            400.00       400.00              Receipt and review order from Mannion re  9/2 deadline for expert reports (.10); comms with

08/29/16 GWM 0.50            400.00       200.00              Communications re: deadlines for expert reports;

08/30/16 GWM 2.80            400.00       1,120.00

Communications with SG re:  Expert deadlines and conference call with NR (.40); prep for cal

(.10); receipt and review order from Mannion (.10); communications with SG re: 9/2 deadlinereports (1.6);

08/31/16 GWM 1.10            400.00       440.00              Reviewed amended reports and comms re: same;

09/01/16 GWM 3.30            400.00       1,320.00          Communications re:   expert reports and reviewed current drafts;

09/02/16 GWM 1.50            400.00       600.00 Communications with counsel and court re:  extension of deadline for affirmative expert repo

reports as drafts

09/06/16 GWM 1.60            400.00       640.00              Comms re:  expert reports and review of same;

09/07/16 GWM 2.60            400.00       1,040.00          Ongoing review of JE Kemmerer report re: econ damages on BS counterclaims and supporting

09/07/16 GWM 0.90            400.00       360.00              Review docket re:  deadlines associated with 8/26/16 order from SCM and plan/prep for com

09/08/16 GWM 2.80            400.00       1,120.00 Plan prep for conference before MJ Mannion and review of submission in response to Court's

electronic data bases and counsel's attempts to obtain same;

09/09/16 GWM 2.00            400.00       800.00 Communications with SG re:  status letter to Court, review re:  various drafts of letter and fili

and review analysis of defendants status letter to Court (.40);

09/13/16 GWM 0.20            400.00       80.00                Comms re:  to do tasks for week;

09/16/16 GWM 1.60            400.00       640.00              Receipt and review initial disclosures re:  defendants experts and initial review re: same;

09/19/16 GWM 3.30            400.00       1,320.00          Background research re:  Wayne van Halem; Timothy Deer and Greg Russo defendant's proff

09/20/16 GWM 1.60            400.00       640.00              Rec and review updated chrono/hot doc list;

09/21/16 GWM 2.30            400.00       920.00 Prep for conf with Judge Mannion ‐ digested conflicting positions from BS re:  existence of ele

Romes efforts to obtain records in question; submissions to court on issue and hot docs. sum

09/22/16 GWM 0.20            400.00       80.00                Comms with MM re: 9/23 hearing;

09/23/16 GWM 7.40            400.00       2,960.00

Prep for conference before MJ Mannion on discovery issues; reviewed all materials filed re:  ee‐mails with SG on issues (2.40); travel to from court for conference (1.40); pre conference m

attended conference (1.50); post conference comms with SG and review of draft subpoenas/

09/26/16 GWM 5.40            400.00       2,160.00

Receipt and review amended scheduling order re:  SC on 11/18 and deadlines for motions forJMV opinions on SJ and SCM/JMV history re:   applications to "prejudge" dispositive motions consent order and review of CO; review of draft subpoenas and attendant issues as to range 

09/30/16 GWM 1.20            400.00       480.00 Calls/e‐mails with SG and defense counsel re:  proposed disc sched/consent order (.80); revie

proposed consent order (.20);

10/03/16 GWM 1.00            400.00       400.00              Background check into Medisoft and Zir Med in terms of connection to BS in prior cases;

10/04/16 GWM 0.40            400.00       160.00 Comms re:  chrono scope of subpoenas (.20); Receipt and review entered consent order from

issues and calendar same (.20);

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 11 of 22 Pa

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10/04/16 GWM 2.20            400.00       880.00 Receipt and review BS's supplemental disclosures and background; Research re:  van Halem; 

comms re:  same;

10/10/16 GWM 0.20            400.00       80.00                E‐mails re:  subpoena to Zirmed/Medisoft;

10/12/16 GWM 0.20            400.00       80.00                Comms re:  Medisoft data.

10/19/16 GWM 3.80            400.00       1,520.00 E‐mail from JC re:  BS flip flop on Medisoft data ‐ reviewed Burns dep on topic and research r

issues potential spoliation/adverse inference charge; 30(b)6 responsibilities;

10/20/16 GWM 0.20            400.00       80.00                Communications with JC re: conference call and reviewed task list for call.

10/20/16 GWM 0.50            400.00       200.00              Reviewed task list and preparation for conference call.

10/20/16 GWM 0.40            400.00       160.00              Conference call re: short term/long term issues.

10/20/16 GWM 1.70            400.00       680.00              Analysis re: issues to be raised in potential motion for SJ.

10/21/16 GWM 0.80            400.00       320.00              Communications with SG team and analysis re: proposed depositions of BS's proffered expor

10/24/16 GWM 3.10            400.00       1,240.00 Comms re: expert depositions and doc productions (.20); review of defendants expert report

applications and/or obvious omissions/contradictions (2.90).

10/25/16 GWM 1.60            400.00       640.00              Emails re; ZirMed supplemental production and initial review of ZirMed materials re: volume

10/27/16 GWM 0.60            400.00       240.00              E‐mail from JC re  task list for 11/27 conference call and prep for same (.40); conference call w10/28/16 GWM 4.60            400.00       1,840.00

Communications re:  issues to be discussed via 10/28 conference call; Zirmed data ongoing ispros/cons of deposing defendant experts; upcoming status/settlement conference with SCMChan and prep for conf. call.

10/28/16 GWM 0.40            400.00       160.00              Comms with defense counsel.

11/01/16 GWM 2.00            400.00       800.00 Communications re:  expert deps. and analysis re: ongoing dispute over Zirmed/Medsoft doc

adverse inference.

11/03/16 GWM 0.50            400.00       200.00              Emails/comments re:  Russo report.

11/04/16 GWM 1.10            400.00       440.00 Emails among counsel re:  Expert dep schedules; defendants PHV application for S.A. Brinkma

for Dr. Rosenthal; conference call with SG team.

11/07/16 GWM 1.00            400.00       400.00 Emails re:  Z. Smith PHV and supporting materials; order re:  Z. Smith PHV application; order r

application.

11/07/16 GWM 0.50            400.00       200.00              Emails re:  Baer dep.

11/08/16 GWM 1.00            400.00       400.00              Emails re:  expert deps.; proposed letter to Court and Zirmed/Medsoft issues.

11/09/16 GWM 1.60            400.00       640.00              Receipt and review email/notice of dep for s. O'Shea; emails/communications re:  Joint Agen

11/10/16 GWM 2.60            400.00       1,040.00 Communications with SG re:  Joint Agenda letter and draft letter review; comms with Norton

revisions re:  same.

11/11/16 GWM 1.20            400.00       480.00 Emails re:  response/objections to Rosenthal dep subpoena; joint agenda letter to SCM; Rose

to Baer and Baer dep prep.

11/14/16 GWM 1.30            400.00       520.00              Emails re: deps and supplemental briefs (as attached); Wolin invoice; Baer report.

11/15/16 GWM 0.90            400.00       360.00              Emails re:  dep issues; defendants revised position re:  Zirmed/Medsoft issues.

11/16/16 GWM 0.30            400.00       120.00              Communications re:  objections to Baer subpoena.

11/18/16 GWM 0.80            400.00       320.00              Attended S.C. before MJ Mannion (.40); Communications with SG re:  SC (.40).

11/21/16 GWM 4.60            400.00       1,840.00          Review/analysis of O'Shea deposition and R. Baer transcript.11/22/16 GWM 2.80            400.00       1,120.00 Comms re:  potential contact with WC and cases/articles supporting contact with WC w/cave

transcript for potential areas of contradiction (1.40);

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 12 of 22 Pa

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11/23/16 GWM 0.30            400.00       120.00              Emails re:  docs supporting Kemmer's testimony and Baer report.

11/28/16 GWM 4.50            400.00       1,800.00

Emails/communications re:   Zirmed production and initial review of materials produced to m

data (1.20); emails re:  BS' requests for Baer materials and analysis of same (1.30); initial analDaubert motion as to Dr. Baer and cross‐application as to Deer (2.0).

11/30/16 GWM 5.20            400.00       2,080.00

Comms with SG; prep for conference call with SG; Conference call with SG re:  Chan and Baermotions defense of Baer and motion against Deer; Russo dep prep issues; supplemental repo

research re:  NJ USDC decisions on Daubert in context of reliance on para work.

12/01/16 GWM 3.40            400.00       1,360.00          Comms with SG re:  depositions and review of Russo supplemental report; prep for conferenc

12/01/16 GWM 2.10            400.00       840.00              Review of JC's outline for Russo dep and emails re:  status of counterclaims.

12/02/16 GWM 4.80            400.00       1,920.00

Emails re:  Russo deposition; issues associated with same; outline of questions; Daubert Analemploy to rehabilitate Russo's testimony on direct (if any); emails re:  draft stip of dismissal; transcript of J. Kemmererces confidential; JC report re:  Russo dep.

12/05/16 GWM 4.60            400.00       1,840.00 Comms re: G. Russo dep.; initial summary of Russo dep.; outlined possible Daubert issues; Va

volume) re:  expert issues/limitations comms re:  Baer review/supplemental report.

12/05/16 GWM 0.40            400.00       160.00              Comms re:  W. Chan issues.

12/06/16 GWM 0.30            400.00       120.00              Communications re:  Wolin Invoice;

12/08/16 GWM 4.20            400.00       1,680.00 Communications re:  Deer deposition; comments re:  same; MM's outline; receipt and review

WVH dep outline and initial review of G.S. Russo dep.

12/09/16 GWM 3.80            400.00       1,520.00

Email from JC and review of Russo dep trans.; emails re:  Van Halem dep and avoidance of imtrial); emails and dep notice for T. Deer dep.; emails re:   Deer dep and outline for Deer; JC re

dep.

12/12/16 GWM 2.20            400.00       880.00              Comms re:  Deer dep. and Deer/Baer doc review; completed review of Van Halene dep. trans

12/20/16 GWM 0.20            400.00       80.00                Emails with Wolin confirming payment;

12/22/16 GWM 3.00            400.00       1,200.00          Comms with Counsel re:  various issues.

12/22/16 GWM 0.60            400.00       240.00              Conference Call with Mag. Judge Mannion.

01/03/17 GWM 0.10            400.00       40.00                Notice from Court re: docket entry as to 12/22/16 telephone conference.

01/06/17 GWM 0.50            400.00       200.00              Comms re:  upcoming motion deadlines.

01/09/17 GWM 1.10            400.00       440.00              Emails re: Van Hanlon deposition and errata sheet review of same.

01/13/17 GWM 0.60            400.00       240.00              Comms among counsel re:  meet and confer issues.

01/16/17 GWM 0.30            400.00       120.00              Comms among counsel re:  meet and confer issues.

01/17/17 GWM 0.40            400.00       160.00              Comms re:  meet on confer.

01/18/17 GWM 0.40            400.00       160.00              Communications with counsel re: meet and confer issues.01/19/17 GWM 0.60            400.00       240.00              Comms with counsel re:  meet and confer issues on application to strike Baer report and draf01/20/17 GWM 0.50            400.00       200.00              Comms re:  dismissal stip and draft stip (.20); comms re: response to BS draft letter post mee01/23/17 GWM 2.40            400.00       960.00 Comms re:  ongoing issues re: BS motion to strike Baer report; prep for meet and confer at 3:

conference call with counsel.

01/24/17 GWM 0.30            400.00       120.00              Comms re: draft stip of dismissal.

01/25/17 GWM 0.50            400.00       200.00 Letter from FG to Court re:  over length brief (.10); reviewed Vasquez' rules re: motion practic

dismissal (.20).

01/26/17 GWM 2.80            400.00       1,120.00 Comms re:  motions to be filed 1/27/16 and review drafts of motion for SJ; Daubert and moti

letter on motion to strike.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 13 of 22 Pa

20086
01/27/17 GWM 7.10            400.00       2,840.00

Communications with SG; receipt and review draft/final materials associated with MSJ; Daubfiled 3 motions; post filing comms with SG and adversary counsel; comms with SG and adverscourt on defendants proposed motion to strike Baer report.

01/30/17 GWM 4.60            400.00       1,840.00 Initial review of Daubert brief and supporting materials from BS; initial review of BS motion fo

comms with SG and NR re:  motions and issues attendant thereof.

01/31/17 GWM 2.30            400.00       920.00              Comms with SG/NR re:  unredacted materials and review of motions.

02/01/17 GWM 3.30            400.00       1,320.00

Comms with counsel re: RR's request for consent to serve subpoena on PACER to determine wmaterials NR inadvertently filed/without redaction and analysis of issue; communications/anand consent for extension for Daubert briefs; comms re:  Zirmed subpoena status; drafts of lereviewed BS briefs on SJ and Daubert.

02/06/17 GWM 1.10            400.00       440.00              Comms re: briefing schedules.

02/07/17 GWM 1.20            400.00       480.00 Comms with FG and SG re: exchange of unredacted materials; comms re:  overpayment to m

for opposition briefs.

02/08/17 GWM 1.10            400.00       440.00              Comms re: stip/letter to JMV for extra briefing time and filing letter/stip.

02/10/17 GWM 0.40            400.00       160.00              Comms re:  status of JMV order as to amended briefing schedule.

02/13/17 GWM 0.20            400.00       80.00                Comms re:  timing of SJ briefing and return date.

02/14/17 GWM 1.00            400.00       400.00              Comms re:  letter to court re:  overlength brief; drafts of same; filed letter; order granting ove

02/16/17 GWM 2.00            400.00       800.00              Review of defendants MSJ and Daubert motion in prep for opposition due 2/24/17.02/17/17 GWM 2.60            400.00       1,040.00          Comms and receipt and review draft opp on MSJ and Daubert; PACER subpoena.

02/20/17 GWM 0.40            400.00       160.00              Comms re:  MSJ supporting aff's from relators; comms with US Attorney's office re: status.

02/21/17 GWM 0.80            400.00       320.00 Receipt and review drafts of opposition papers on Daubert motion and MSJ; comms re:  draft

materials.

02/22/17 GWM 1.50            400.00       600.00 Comms with JC re:  56.1 statements/responses; research/analysis re:  proper content for 56.1

improper opinion/argument.

02/23/17 GWM 2.80            400.00       1,120.00

Communications with JC, et als re:  draft 56.1 response and review of drafts re: same (.50); an

standards associated with Local Rules on 56.1 statements (.90); comms re: optional supplemematerials facts and reviewed initial draft of same (.70); emails/comms re:  motion to seal and

logistics associated with all briefs to be filed on 2/24/17 (.60).

02/24/17 GWM 7.90            400.00       3,160.00

Review opp for MSJ, Daubert and motion to seal; comms with SG re:  same and attended to fmaterials and motion to seal (6.80); comms with FG re:  motion issues (.60); initial receipt andopposition to MSJ; Daubert and motion to seal (.50).

02/27/17 GWM 1.00            400.00       400.00

Notices from Court re:  deadlines associated with motions to seal ‐ no argument (.10); commfilings, courtesy copies and cover letter to JMV (.50); comms re:   issues with exhibits 14 and 3(.40).

02/28/17 GWM 0.80            400.00       320.00 Comms with SG re:  unredacted filings associated with defendants opposition (SJ and Dauber

comms re:  initial analysis of defendants opposition to MSJ and Daubert motions (.40).

03/01/17 GWM 3.10            400.00       1,240.00          Ongoing review/analysis of BS briefs on SJ and Daubert; Comms re:  reply briefs.

03/02/17 GWM 1.60            400.00       640.00 Communications with counsel and court re: Appendix V submissions ‐ to be filed jointly at dir

motion will take place of joint motions to seal.

03/03/17 GWM 2.20            400.00       880.00              Comms with counsel and Court re: Appendix U issues on motions to seal and analysis of comp

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 14 of 22 Pa

20087
03/06/17 GWM 0.50            400.00       200.00 Comms with F. Galant re:  exhibits from SJ motions and provided additional copies (.30); calls

and other potential exhibits associated with reply briefs (.20).

03/13/17 GWM 2.20            400.00       880.00 Comms with SG re:  letter to JMV re:  BS' potential request for overlength brief; Receipt and r

comms re:  same/daubert brief.

03/14/17 GWM 3.10            400.00       1,240.00 Letter from BS to Court requesting overlength brief; comms among counsel re: response to B

letter; arrangements/filing response letter; review draft reply briefs on SJ and Daubert.

03/15/17 GWM 3.00            400.00       1,200.00

Receipt and review 56.1 response on MSJ; comms with SG re:  reply materials and reviewed dcourt granting defendants request for overlength brief and Appendix V issues; received noticunder seal and comms re:  same.

03/16/17 GWM 5.60            400.00       2,240.00 Communications with SG re:  reply briefs on Daubert and MSJ and supplemental 56.1 statem

materials and filed materials.

03/16/17 GWM 1.20            400.00       480.00

Notices re: Defendants filing under seal DEs 325‐328; Comms with counsel re: nature of DEs 3

comms with FG re:  status of Appendix V tables and SCM's request for omnibus motion and wto seal.

03/17/17 GWM 3.80            400.00       1,520.00

Comms with counsel re:  ongoing requests for copies of materials defendants filed under seaColin Huntley affidavit; receipt and review materials filed by defendants on 3/16/17 under se

brief and analysis of reply brief itself in light of potential sur‐reply brief.

03/21/17 GWM 0.40            400.00       160.00              Comms with NR and SG re:  redacted materials and omnibus motion to seal.

03/22/17 GWM 0.50            400.00       200.00              Emails re:  redactions/motion to seal.

03/23/17 GWM 2.00            400.00       800.00 Comms with SG re: letter to JMV and proposed sur‐reply; reviewed drafts; confirmation from

approved filing of proposed sur‐reply with letter to JMV; revisions to letter and sur‐reply and

03/24/17 GWM 2.80            400.00       1,120.00 Receipt and review defendant's 1st draft of omnibus motion and comms with counsel re:  sam

adjournment of 3/27/17 deadline.

03/27/17 GWM 5.40            400.00       2,160.00

Comms with SG re:  omnibus motion to seal and review of our responses to defendant's 1st domnibus motion to seal; investigated inquiry of materials filed under seal and drafted  index oSJ/Daubert motions (moving, opposition and reply).

03/28/17 GWM 2.40            400.00       960.00 Receipt and review filed joint omnibus motion to seal and supporting materials; notice from c

on the papers .

04/04/17 GWM 1.10            400.00       440.00 Receipt and review notice from JMV re: order granting request for sur‐reply and comms with

and review draft sur‐reply and comms with SG re:  same (.90);

04/06/17 GWM 2.80            400.00       1,120.00 Comms with MJ Mannion's law clerk and receipt/review of requested changes to Appendix U

exhibits; comms with counsel re:  same.

04/07/17 GWM 1.80            400.00       720.00 Comm with counsel re: amendments to Appendix U; conference call with adversary counsel a

filed publicly with redactions.

04/11/17 GWM 4.60            400.00       1,840.00 Receipt and review draft appendix U associated with joint motion to seal; comms with SG and

motion appendix U; rec/rev/analysis re:  BS initial filings in support of joint motion to seal.

04/12/17 GWM 6.90            400.00       2,760.00          Comms re: amended Exhibit U; prep and filing of Exhibit U.04/27/17 GWM 0.20            400.00       80.00                Receipt and review notice re:  5/17 telephone conference with court and comms with SG re: 

05/02/17 GWM 2.80            400.00       1,120.00

Receipt and review 5/2 order from SCM re:  motion to seal; analysis of same; comms with SGproblems/errors associated with SCM order; draft letter to SCM re: stay of 5/2 order and douaccuracy of position as to redacted exhibits.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 15 of 22 Pa

20088
05/03/17 GWM 1.60            400.00       640.00 Comms with FG and Court re:  application to reseal; letter from FG to court re:  re‐sealing; an

with redacting materials filed underseal.

05/04/17 GWM 2.70            400.00       1,080.00 Order from Mannion re: temporary seal and 5/11 deadline to brief and redact exhibits; comm

order; plan and prep for submissions to Court by 5/11.

05/09/17 GWM 1.00            400.00       400.00              Receipt and review Petratos 3rd Cir. Opinion and Kolchinski Statement of Interest.

05/10/17 GWM 2.20            400.00       880.00 Comms with FG re;   joint brief and revised/redacted exhibits associated with Appendix U; rev

with SG re:  status of joint brief and revised/redacted exhibits and prep for filing of same.

05/11/17 GWM 2.90            400.00       1,160.00          Comms with FG and review of revised/redacted materials associated with motion to seal; file

05/12/17 GWM 0.20            400.00       80.00 Receipt and review notice from SCM that 5/18/17 conf is adjourned; comms re: same with SG

motion to seal.

07/28/17 GWM 0.40            400.00       160.00              Comms with AS re: status of motions

08/29/17 GWM 1.20            400.00       480.00              Review/analysis of Dzielak v. Whirlpool opinion on issue of Daubert exclusion under 703.

09/01/17 GWM 2.00            400.00       800.00 Reviewed docket for activity and recent Vazquez decisions re:  indication of rate at which he 

analysis re: steps deadlines in event an appeal is taken by either or both sides.

10/17/17 GWM 0.90            400.00       360.00 Comms with Judge Vazquez' Chambers requesting additional copies of motions for SJ/Daube

request and analysis of materials requested.

10/18/17 GWM 0.40            400.00       160.00              Comms re:   courtesy copies to Vazquez.

12/15/17 GWM 2.50            400.00       1,000.00 Receipt and review JMV opinions/orders on Daubert motions and motions for SJ (2.0); comm

(.50).

12/18/17 GWM 0.70            400.00       280.00

Comms with AS re: press inquiries (.20); Receipt and review notice from court re:  1/9 settlem

counsel re:  same (.20); comms with MJ Mannion's chambers ‐ SC on 1/9 is before JMV (.20); conference with JMV (.10).

12/18/17 GWM 0.30            400.00       120.00              Email from FG re:  alternative dates for SC and comms with counsel re:  same.12/19/17 GWM 0.60            400.00       240.00              Comms with trial team re:  dates for settlement conference (.40); comms with FG re:  settlem12/20/17 GWM 1.10            400.00       440.00

Comms among trial team re:  settlement conference availability (.40); comms with FG re: sett

drafted/revised/filed letter to court re:  1/9/18 settlement conference (.20); Receipt and  rev1/18/18 as altern date for SC (.10); comms among trail team re:  response to FG letter (.20).

12/21/17 GWM 0.40            400.00       160.00 Letter to Court re: avail for 1/18/18 (.20); notice from court sched 1/18/18 settlement confer

advising re:  1/18/18 settlement conference (.10).

12/21/17 GWM 0.10            400.00       40.00                Letter from FG re:  1/18 SC and email to trial team re: same and need for 12/22 letter.

12/22/17 GWM 0.40            400.00       160.00 Letter to JMV re: 1/18/18 conference (.20); Receipt and review notice from PACER re: GWM l

(.10); comms re: potential discussion with BS re:  trial dates (.10).

01/17/18 GWM 0.10            400.00       40.00                Email to AS re: 1/18/18 SC before JMV.

01/18/18 GWM 3.70            400.00       1,480.00

Travel to/from USDC for settlement conference with JMV (1.20); pre‐conf meetings with cou

settlement conference before JMV (1.70); Receipt and review tax order re:  letter to be provipotential settlement (.10); emails with counsel re: 2/2/18 letter (.20).

01/22/18 GWM 0.30            400.00       120.00              Comms re:  request for W. Chan materials.

01/23/18 GWM 0.10            400.00       40.00                FR email objecting to production of Chan materials.

02/01/18 GWM 0.50            400.00       200.00              Receipt and review draft letter to JMV re: settlement position and emails re: same.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 16 of 22 Pa

20089
02/02/18 GWM 1.50            400.00       600.00 Comms among counsel re:  drafts of letter to JMV reporting as to status of settlement; review

attachments submitted letter to JMV via email.

02/05/18 GWM 0.80            400.00       320.00 Notice/email from USDC re: JMV's form of PTO and initial review of same (.40); comms with F

email to trial team re:  circumstances re: receipt of JMV's PTO (.20).

02/07/18 GWM 0.30            400.00       120.00              Comms with MM re: pre‐trial order issues.

02/13/18 GWM 0.20            400.00       80.00                Comms with AS re:  status of PTC.

02/14/18 GWM 0.50            400.00       200.00              Comms re:  status of PTC and analysis re:  means to accomplish.

02/20/18 GWM 0.20            400.00       80.00                Comms re: status of Pre‐Trial Conference.

02/21/18 GWM 0.50            400.00       200.00              Comms re: PTC w/SCM.

02/21/18 GWM 0.40            400.00       160.00              Emails re: BSNC's proposal for narrowing damages issues.

02/22/18 GWM 2.80            400.00       1,120.00 Receipt and review order from SCM re: PTC on 4/30/18 and instructions re: same; comms wit

initial prep for drafting PTO.

02/23/18 GWM 2.40            400.00       960.00 Reviewed long form and short for PTO templates from JMV; diaried appropriate dates/deadli

instructions, jury, interrogatories and neutral statement of case and initial prep re: same.

02/27/18 GWM 1.00            400.00       400.00 Comms with FG re: discrepancies between Clark Form PTO and Mannion Form PTO; reviewed

SG re  same.

03/01/18 GWM 0.50            400.00       200.00              Comms with FG and AS re: discrepancies with PTO.

03/01/18 GWM 1.50            400.00       600.00              Comms with NJ counsel re:  JMV PTOs and trial procedure.

03/02/18 GWM 1.30            400.00       520.00              Comms with counsel re:  PTO discrepancies and 3/5 call to court and prep for same.

03/05/18 GWM 2.90            400.00       1,160.00 Comms with counsel re: BS proposal as to claim definition and analysis re:  same; prep for cal

comms re:  WC issue; call to Mannion's chambers.

03/07/18 GWM 1.20            400.00       480.00 Comms with MM, AS and MG re:  letter to SCM and reviewed draft letter to SCM and revision

re:  SCM letter (.20).

03/08/18 GWM 0.10            400.00       40.00                Receipt and review FG email and revised letter to SCM (.20); email from AS re:  WC issue (.10

03/09/18 GWM 0.40            400.00       160.00              Comms with counsel and arrangements for filing joint letter with SCM.

03/19/18 GWM 0.20            400.00       80.00                Email from MG and draft letter to SCM re:  WC issue.

03/20/18 GWM 2.40            400.00       960.00 Receipt and review order from SCM re: correction to pre‐trial order and comms with counsel

PTO and doc/dep review re:  prep of PTO input to SG and pre‐trial motion analysis (2.20).

03/20/18 GWM 0.20            400.00       80.00                Comms with adversary counsel re:  WC as witness.

03/23/18 GWM 1.00            400.00       400.00              Emails re:  WC agreement and analysis of our position ‐ firm ground.

03/26/18 GWM 1.50            400.00       600.00              Email exchanges re:  dep designations and prep for advice on NJ practices as to use of dep de

03/28/18 GWM 1.80            400.00       720.00 Review PTO and prep for PTC and questions re: form of order and conference (1.0); comms re

represented by NR (.80).

04/02/18 GWM 1.50            400.00       600.00              MM emails re: proposed trial exhibits and review of same.04/03/18 GWM 2.50            400.00       1,000.00 Comms re: exhibit list and review of docket/CMO's re: deadline for exhibit list (.40); prep for 

limine issues (2.10).

04/04/18 GWM 1.80            400.00       720.00              Comms with FG and MM re: status of exhibits list for PTO and review of status of PTO deadlin

04/05/18 GWM 1.80            400.00       720.00              Comms with counsel re: trial exhibits and dep designations; Receipt and review initial dep. de

04/06/18 GWM 1.80            400.00       720.00              Comms re:  exhibit list and accessed stickered exhibit database.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 17 of 22 Pa

20090
04/09/18 GWM 3.20            400.00       1,280.00 Comms re:  trial exhibits and review of prior PTOs re: handling/compliance with dep designat

motions, etc.

04/10/18 GWM 2.00            400.00       800.00              Comms among counsel re:  discrepancies as to exhibit lists and prep for meet and confer.

04/11/18 GWM 2.10            400.00       840.00 Comms with counsel on issue of use of dep designations at trial and review of GWM prior PTO

in DNJ re:  reliance on dep designations.

04/13/18 GWM 3.30            400.00       1,320.00 Prep for 4/20 meet and confer on PTO and 4/16 conference call ‐ in limine issues; review of e

potential reductions.

04/16/18 GWM 3.10            400.00       1,240.00

Prep for conference call with adversary counsel re:  Pre‐trial order (.80); conference call with 

order disputes (.50); research analysis re:  excessive exhibit lists; dep designations and identifbase as a single exhibit (1.80).

04/16/18 GWM 2.10            400.00       840.00              Receipt and review (initial) of relators' dep designations.

04/17/18 GWM 3.20            400.00       1,280.00          Ongoing review of dep designations and exhibit lists overall form of PTO ‐ compliance with Lo

04/18/18 GWM 3.60            400.00       1,440.00          Reviewed current draft of pre‐trial order and prep for pre‐trial meet and confer on 4/20.

04/19/18 GWM 3.00            400.00       1,200.00          Prep for meet and confer on PTO ‐ review of current PTO and list of issues to be addressed.04/20/18 GWM 5.60            400.00       2,240.00 Travel to/from S.G. for FPTO meet and confer (3.8); pre and post meetings with AS, MG and M

SG and NR (1.0).

04/23/18 GWM 2.80            400.00       1,120.00 Receipt and review BS section of pre‐trial order and summary of documents BS intends to use

(2.60); comms re:  exhibits and exhibit lists (.20).

04/24/18 GWM 1.20            400.00       480.00              Ongoing review of BS section of PTO and designated docs from Webextender.

04/25/18 GWM 4.10            400.00       1,640.00 Comms re: draft Pretrial order and review/analysis of current draft and consideration of MILs

reaction/arguments against dep designations.

04/26/18 GWM 3.60            400.00       1,440.00 Comms with SG re:  exhibits to PTO and PTO itself; prep exhibits; comms with all counsel re:  

review defendants PTO sections and exhibits and analysis of same.

04/27/18 GWM 4.20            400.00       1,680.00          Pretrial order and exhibits review and filing; comms with counsel re: PTO.

04/30/18 GWM 5.50            400.00       2,200.00

Comms with MJ Mannion's chambers re:  hard copies of PTO to be hand delivered; arrangem

exhibits for SCM; travel to/from USDC DNJ; presented SCM with PTO and exhibits; review PTOFPTC and conferences with counsel for SG re:  same.

04/30/18 GWM 0.10            400.00       40.00                Text order from SCM re: 4/30 FPTC and forwarded to SG.05/01/18 GWM 0.40            400.00       160.00              Notice from clerk re: 4/30 PTC and comms with FG/SG re: same.

05/02/18 GWM 2.40            400.00       960.00 Comms with counsel re:  conference call with SCM re:  DE 407, prep for 5/3/18 conference ca

relators contemplated motions in limine and analysis of same.

05/03/18 GWM 2.90            400.00       1,160.00

Comms with FG and MM re:  call to Mannion's chambers re:  discrepancy in text order; prep fre:  text order discrepancy; post call comms with FG and MM; notice from clerk correcting texconference and comms to SG re:  same; email from Z.S. re: BS objections to relators exhibits a

05/07/18 GWM 2.10            400.00       840.00              Comms among counsel re:  reduction of exhibits and objections to exhibits and review of cur

05/08/18 GWM 2.20            400.00       880.00              Review initial PTO and analysis re:  areas to reduce exhibits and/or witnesses.05/09/18 GWM 2.60            400.00       1,040.00 Comms re:  objections to exhibits and prep for call re:  same (1.0); reviewed dep designations

treatment of dep designations at trial (1.60).

05/10/18 GWM 1.00            400.00       400.00              Comms re:  call with adversary counsel and prep for meet and confer.

05/11/18 GWM 0.80            400.00       320.00              Emails/comms re:  meet and confer on 5/14 and prep for same.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 18 of 22 Pa

20091
05/14/18 GWM 1.70            400.00       680.00 Reviewed notes from F PTC and emails re:  revisions to PTO in prep for meet and confer (.80)

confer telephone conference (.80); email from MM summarizing meet and confer (.10).

05/15/18 GWM 1.50            400.00       600.00              Reviewed current PTO for areas that could be reduced.

05/16/18 GWM 1.00            400.00       400.00              Review PTO for revisions/deletions, review transcript from PTC before SCM.

05/18/18 GWM 1.40            400.00       560.00              Comms re:  joint dispute letter (.40); Receipt  and review transcript from 4/30 hearing before

05/21/18 GWM 0.60            400.00       240.00 Comms with MM and FG re  joint dispute letter and ongoing issues with PTO; reviewed BS's r

5/21/email.

05/22/18 GWM 2.20            400.00       880.00 Email from FG (.10); BS section of joint dispute letter (.30); BS current exhibit list and analysis

exhibit list (1.20); comms with SG and NR re:  joint dispute letter and exhibits (.60).

05/23/18 GWM 2.90            400.00       1,160.00 Comms among counsel re: drafts of joint letter, Amended PTO and exhibits to PTO; review of

letter, PTO and exhibits A‐1 to PTO.

05/24/18 GWM 1.40            400.00       560.00              Review/analysis of joint letter and amended PTO as filed in prep for follow‐up SCM conferenc

05/24/18 GWM 0.30            400.00       120.00              Comms with SG re:  5/23 filings.

05/30/18 GWM 0.20            400.00       80.00                Comms re:  S. Brinkman to Reed Smith.

05/31/18 GWM 1.60            400.00       640.00              Reviewed BS current position on PTO and prep for next FPTC.

06/05/18 GWM 0.20            400.00       80.00                Comms re:  6/6 conference call with SCM.

06/06/18 GWM 3.70            400.00       1,480.00

Prep for conference all with SCM on revised PTO; reviewed initial, and consent PTO and trans

participated in telephonic PTC (.60); reviewed SCM and JMV treatments of PTOs with high levre:  sanctions where documents identified but not used at trial (1.10).

06/08/18 GWM 1.60            400.00       640.00 Text order re:  meet and confer re:   revised PTO; claim material motions and exhibit/dep des

review existing PTO.

06/12/18 GWM 0.60            400.00       240.00              Comms with counsel re: dates/deadlines associated with in limine motions.

06/13/18 GWM 1.80            400.00       720.00 Prep for telephone conference with all counsel re: Motions in limine and amended PTO (.80);

and PTO (.80); call with MM post‐meet and confer re:  proposed deadlines (.20);

06/14/18 GWM 0.20            400.00       80.00                Receipt and review proposed sched for MILs from counsel for BS.

06/19/18 GWM 1.10            400.00       440.00 Comms with counsel re:  MIL Sched and letter to Court; Plan prep for revised PTO and upcom

conference call.

06/20/18 GWM 2.00            400.00       800.00              Comms re:   meet and confer on 6/21 and review of draft PTOs and emails from 5/18 ‐ presen

06/21/18 GWM 1.50            400.00       600.00              Prep for conference call on amended PTO and MIL's; conference call with counsel.

06/22/18 GWM 2.30            400.00       920.00 Comms (emails and calls) among counsel re:  6/22 submission to SCM re: PTO and motions in

revised PTO and joint letter.

07/02/18 GWM 2.30            400.00       920.00              Mail/email and filings from week of 6/25‐6/29.

07/03/18 GWM 0.30            400.00       120.00              Comms re: PHV counsel addition (SB).

07/05/18 GWM 1.60            400.00       640.00              Reviewed docket and calls re: JMV trial schedule for Fall/Winter 2018‐19.

07/06/18 GWM 2.80            400.00       1,120.00          Receipt and review BS motion in limine and supporting materials.

07/09/18 GWM 2.00            400.00       800.00              Review of BS MIL and supporting materials and analysis re: opposition and moving papers for

07/17/18 GWM 1.40            400.00       560.00 Comms re:  meet and confer and prep for same and review of status on MILs ‐ BS brief and du

moving MIL.

07/19/18 GWM 1.00            400.00       400.00              Review of BS MIL; plan prep deadlines/scope/length of opposition.

07/20/18 GWM 1.30            400.00       520.00              Emails and draft of opp to BS MIL re:  universe of claims.

07/24/18 GWM 2.10            400.00       840.00 Comms from adversary counsel re:  intention to file MIL to strike relators exhibit list and dep 

and analysis of BS' positions comms with MM re: same.

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 19 of 22 Pa

20092
07/25/18 GWM 0.90            400.00       360.00              Meet and confer with counsel re: MIL issues; exhibit list and dep designations (.60); post call 

07/26/18 GWM 1.00            400.00       400.00              Plan/prep for filing opp to MIL reviewed current materials and comms with counsel.

07/27/18 GWM 2.90            400.00       1,160.00 Emails re:  follow‐up to meet and confer (.20); Receipt and review updated draft re: oppositio

revisions to MIL and filing (.40); prep and filing MIL opposition (.80); post filing comms with c

07/30/18 GWM 2.00            400.00       800.00 Reviewed MIL brief package and prep for Round 2 of MILs to be filed by 8/10/18 and trial issu

(logistics ‐ dep designations and exhibits).

08/13/18 GWM 2.60            400.00       1,040.00

Receipt and review BS reply on their in limine motion (.60); comms with MM re:  issues with review file in limine motion (relators) and supporting materials  (1.60); email to SCM/JV re: P

(.30).

08/16/18 GWM 0.50            400.00       200.00              Receipt and review NOA by J. Eppensteiner and email to SG re: same (.10) letter to Judge V. r08/17/18 GWM 2.00            400.00       800.00              Receipt and review signed Final pre‐trial; notes/analysis re:  deadlines/logistics associated wi

08/24/18 GWM 2.00            400.00       800.00              Review docket for events the week of 8/27 settlement conference and reply briefs and prep f08/28/18 GWM 1.70            400.00       680.00

Comms re: adjournment of 8/31/18 settlement conference to proceed to mediation (.20); Co

exhibits associated with Relators reply brief on MIL (.20); review of BS opposition to Relators (1.30).

08/29/18 GWM 1.50            400.00       600.00 Comms re: potential redactions to exhibits associated with opposition to BS MIL and review o

comms re:  potential adjournment of 8/31 conf with SCM and BS desire to go forward with co

08/30/18 GWM 2.70            400.00       1,080.00          Comms with SG; Receipt and review opposition to BS MIL; filed opposition.

08/31/18 GWM 2.50            400.00       1,000.00          Conference call with counsel and SCM (.40); Receipt and review BS opposition to Bahnsen MI

09/04/18 GWM 1.80            400.00       720.00              Ongoing review/analysis of BS opposition to inlimine motion.

09/25/18 GWM 2.80            400.00       1,120.00 Receipt and review JMV 9/24/18 opinion and order re: BS motion in limine granted in part/de

counsel re: effect of JMV decision and analysis re: additional briefing on missing CMS 1500 fo

09/26/18 GWM 2.00            400.00       800.00              Analysis/research re:  extra pollution and/or statistical sampling as treated in USDC DNJ.09/27/18 GWM 1.40            400.00       560.00              Reviewed 9/24 JMV opinion and compared to final pre‐trial order re:  scope of damages.

10/02/18 GWM 1.10            400.00       440.00              Plan/prep for upcoming briefing deadlines and review docket as to pending issues and poten

10/04/18 GWM 2.00            400.00       800.00 Receipt and review draft brief as to proposed handling of damages in light of plaintiff's refusa

forms and comms re: same.

10/05/18 GWM 2.30            400.00       920.00

Comms with SG re:  supplemental brief and filing of same (.60); Receipt and review drafts of scalculating damages (1.10); attended to filing brief, MG Decl. and exhibits (.50); email to advecourtesy copy of supp brief (.10).

10/12/18 GWM 0.50            400.00       200.00              Comms re:  letter to JMV requesting trial date and filing of letter to JMV.

10/12/18 GWM 0.90            400.00       360.00              Receipt and review BSNC brief re:  damages calculations and exhibits.

10/15/18 GWM 0.80            400.00       320.00              Reviewed BSNC's brief re:  calculation of damages.

10/15/18 GWM 0.50            400.00       200.00              Comms with counsel re:  BS MTS ‐ consent granted

10/16/18 GWM 0.60            400.00       240.00              Reviewed BS filing underseal on opposition to brief on damages and reviewed local rules for c

Case 2:11-cv-01210-JMV-SCM Document 469-14 Filed 06/21/19 Page 20 of 22 Pa

20093
10/17/18 GWM 2.80            400.00       1,120.00 Comms with MG and review of draft reply brief on damages; arrangements for filing reply bri

redacted materials on 10/18/18; email to adversary counsel re: materials filed underseal.

10/18/18 GWM 1.30            400.00       520.00

Comms with counsel for BS and receipt and review declaration of M. Geist re:  MTS (.20); com(.10); comms with SG re:   need for redactions to exhibits 2 & 3 from MG declaration and inqu

exhibit 1‐recommending exhibit 1 be filed publicly (.50); arrangements/filing exhibits under s

10/19/18 GWM 1.30            400.00       520.00 Refiling Gerva's Certification and comms with counsel re: same (.50); Receipt and review noti

with counsel (.20); reviewed FPTO for deadlines associated with trial date for JCHGS; Voir Dir

10/26/18 GWM 1.00            400.00       400.00              Receipt and review defendants motion to seal and comms with MG re: deadline for Relator's

10/29/18 GWM 0.10            400.00       40.00                Comms with MM re: MTS.

10/30/18 GWM 2.10            400.00       840.00

Comms with MM re: MTS; Receipt and review draft motion to seal; revisions to MTS and drafwith adversary counsel confirming Exhibit 1 to MG Cert under seal and no objections to Exhibseal (.30).

10/31/18 GWM 1.30            400.00       520.00 Revisions to Motion to Seal and filing of MTS (1.0); call from SCM's chambers confirming Exhi

confirmation re: motion to seal (.20).

11/06/18 GWM 0.20            400.00       80.00                Comms with MG re:  change of address.

11/09/18 GWM 0.70            400.00       280.00              Comms with SG team re:   motion to seal and notice to change MG address; filed notice re:  M

11/13/18 GWM 0.20            400.00       80.00                Comms re: mediation 2/22/19.

11/14/18 GWM 0.30            400.00       120.00              Comms re: 2/22 mediation.

11/29/18 GWM 0.30            400.00       120.00              Receipt and review orders from SCM on motions to seal Relator's granted/defendants denied

12/10/18 GWM 0.20            400.00       80.00                Receipt and review notice from USDC re: defendants revised motion to seal and comms with 

01/10/19 GWM 0.20            400.00       80.00                Receipt and review JMV order granting defendants motion to seal and comms with SG re:  sa01/18/19 GWM 0.20            400.00       80.00 Receipt and review 1/18/19 order from JMV and email to SG team re:  same and calendar 3/2

JMV.

01/25/19 GWM 1.00            400.00       400.00              Receipt and review relator's mediation statement and comms with counsel SG and RS re:  me

02/07/19 GWM 0.20            400.00       80.00                Communications re: exchange of mediation statements.

02/08/19 GWM 0.20            400.00       80.00                Comms re: Mediation.

02/11/19 GWM 2.80            400.00       1,120.00 Comms among counsel re:  reply mediation statements (.40); Review/analysis of defendants 

(1.30); Review and analysis of relators rely mediation statement (1.10).

02/26/19 GWM 0.60            400.00       240.00              Comms with SG re;  fees/expenses and provided hard copy back up re:  same.

03/07/19 GWM 2.10            400.00       840.00 Reviewed in limine motions/opposition and briefs re: forming basis of a claim in prep for 3/25

Vazquez.

03/12/19 GWM 0.10            400.00       40.00                Receipt and review order granting NR request to withdraw.

03/25/19 GWM 1.40            400.00       560.00              Preparation for motion hearing re: in limine motions and claim definition motion.

03/25/19 GWM 1.20            400.00       480.00              Travel to/from USDC for hearing.

03/25/19 GWM 0.40            400.00       160.00              Pre‐hearing conference with WC MG, MM & AS.

03/25/19 GWM 3.40            400.00       1,360.00          Attended motion hearings before Judge Vazquez.

03/26/19 GWM 0.10            400.00       40.00                Notice from Court re:  Docket Entry for 3/25/19.

03/28/19 GWM 1.10            400.00       440.00              Receipt and review transcript from hearing before JMV on 3/25/2019.

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03/28/19 GWM 0.30            400.00       120.00              Receipt and review orders from JMV re: M/Ls and claim issue.

03/28/19 GWM 0.30            400.00       120.00              Communications with SG re: JMV orders.

08/10/18 KST 0.70            150.00       105.00              Review and analyze motions in limine to be filed.

08/10/18 KST 0.20            150.00       30.00                Telephone call with M. Musico re: procedural edits to motions in limine.

08/10/18 KST 0.20            150.00       30.00                Another telephone call with M. Musico re: procedural edits to motions in limine.

08/10/18 KST 0.20            150.00       30.00                Review and analyze revised documents re: procedural edits added.08/10/18 KST 0.20            150.00       30.00                Draft Notice of Appearance for KST.

08/10/18 KST 1.10 150.00 165.00 Prepare and file motions in limine.

Total Hours & Fees 1,010.10   403,390.00

Hours Fees

GWM 1,007.50    403,000.00

KST 2.60   390.00

Total Hours 1,010.10   403,390.00

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