Reilly v. Wozniak et al

Filing 203

ORDER that Defendants' Motion for Attorneys' Fees and Costs (Doc. 192) is granted. FURTHER ORDERED Plaintiff shall pay $142,089.00 in attorneys' fees and $3,204.19 in costs to Defendants within 30 days from the date of th is order. FINALLY ORDERED Defendants shall file a notice of satisfaction within 7 days of receipt of the full amount of attorneys' fees and costs contemplated by the order. Signed by Judge Michael T Liburdi on 11/18/21. (Attachments: # 1 Appendix) (SJF)

DATE

ATTY

RATE

Modified Hours

Modified Amount

8/14/18

MAS

$ 325

Correspondence with CCR regarding Reilly matter. No Charge. Review complaint packet and demand
0.80 from Reilly's attorney.

$ 260.00

0.80

$ 260.00

8/20/18

MAS

$ 325

Lengthy telephone call with attorney representing Ralph Reilly v. WOZ U etc. Discuss merits. Further
2.00 review of claim and copyright matters. Follow up correspondence to opposing counsel.No Charge.

$ 650.00

2.00

$ 650.00

8/21/18

MAS

$ 325

Further review of Reilly background and extensive background search to determine involvement in
1.90 previous litigation in preparation of response to opposing counsel.

$ 617.50

1.90

$ 617.50

$ 325

Receive service of process of complaint packet. Telephone call with CCR regarding same. Review
2.00 complaint packet and court docket. Review whether Plaintiff's counsel has been admitted pro hac.

11/28/18

12/10/18

MAS

AMF

$ 300

TIME

5.80

ACTIVITY

Detailed review of all pleadings on file. Review of court docket to confirm the receipt of all pleadings to
date. Review of issues related to service of process and jurisdiction. Review of applicable case law and statutes related to
the claims presented in determination of next step
Review of applicable rules related to default and deadlines for the filing of an Answer or responsive pleading. Preparation
of Motion for Extension of Time to File an Answer. Preparation of draft Order
regarding the same. (Client Courtesy - No Charge).

Amount

Court's Ruling

2.00

$650.00

4.64

$1,392.00

No Charge

N/A

No Charge

No Charge

N/A

No Charge

$ 650.00
Entry reduced by 20%. Block billing.
$ 1,740.00

12/19/18

AMF

$ 300

0.70

12/19/18

MAS

$ 325

Multiple correspondence with opposing counsel regarding answers for various parties and deadlines for
0.50 same regarding stipulations, etc. Follow up AMF regarding same. (Client Courtesy - No Charge).

12/19/18

MAS

$ 325

Review, revise, edit motion for extension of time to file an answer or responsive pleading. Follow up with
1.70 opposing counsel regarding same. Meeting with AMF regarding same.

$ 552.50

1.70

$ 552.50

$ 325

Telephone call with CCR and follow up meeting with AMF regarding Defendants. Discuss motion to
2.00 dismiss regarding same.

$ 650.00

2.00

$ 650.00

Entry reduced by 20%. Block billing.

3.00
1.68

$ 975.00
$504.00

Entry reduced by 20%. Block billing.

2.4

$780.00

12/20/18

1/15/19

1/16/19

MAS

MAS

AMF

$ 325

$ 300

3.00

2.10

Telephone call with CCR regarding this office's representation and defense of all Defendants icluding SCI.
No Charge Meeting with AMF regarding same. Prepare answer to complaint on behalf of all Defendants. Review court
docket regarding same and follow up conference with AMF. No Charge
Review of Complaint in preparation of changes to draft Answer. Review and revise draft Answer. Review of applicable
statutes pertaining to venue. Preparation of changes to draft Answer. Preparation of Motion for Extension of Time to
Answer for Defendant Southern. Preparation of Proposed Order Granting Motion
for Extension of Time to Answer for Defendant Southern.
Receive/review correspondence regarding answer filing. No Charge. Finalize Answer for all Defendants and file same.
Review, revise, edit Motion to Extend Time for Filing Answer and Proposed Order and exhibits thereto. Lengthy discussion
with AMF regarding same. No Charge. Correspondence with
opposing counsel via email and telephone regarding same.

$ 975.00

$ 630.00

1/16/19

MAS

$ 325

3.00

1/22/19

AMF

$ 300

Review incoming pleadings, Order Granting Parties Stipulation for Extension of Time to Answer
0.20 Complaint.

$ 60.00

0.20

$ 60.00

$ 162.50

0.50

$ 162.50

$ 90.00

0.30

$ 90.00

$ 840.00

2.80
5.04

$ 840.00
$1,512.00

$ 1,890.00
$ 60.00
$ 60.00

0.20
0.20

$ 60.00
$ 60.00

$ 487.50

1.50

$ 487.50

$ 150.00

0.50

$ 150.00

0.50

$150.00

0.80
0.40

$ 240.00
$ 120.00

1/23/19

MAS

$ 325

Receive/review Order from Court setting Status Conference/Scheduling Conference for March 12, 2019.
0.50 Discuss with AMF regarding proposed case management report. No Charge

1/23/19

AMF

$ 300

Review incoming pleadings, Order regarding Scheduling Conference, Proposed Case Management plan
0.30 and upcoming hearings.

1/29/19

AMF

$ 975.00

2/5/19
2/19/19
3/4/19

AMF
AMF
AMF

$ 300
$ 300
$ 300

3/5/19

MAS

$ 325

2.80 Detailed review of pleadings in preparation of mandatory initial disclosures and potential discovery.
Preparation of draft electronic preservation letter. Commence preparation of draft mandatory initial disclosures. Detailed
review of case law and statutes pertaining to Plaintiff's claims including defenses to the copyright infringement claims.
Discussion with MAS regarding preemption of Plaintiff's state law
claims.
6.30
0.20 Discussion with MAS regarding Court's Order regarding meet and confer and mandatory disclosures.
0.20 Review incoming pleadings- Motion to Appear Telephonically.
Receive/review Plaintiff's Disclosure Statement and discuss with AMF in detail and work on disclosure
1.50 statement for WOZ U.

$ 300

Review of e-mail discussion with David Weems regarding information needed. Review of draft Mandatory
0.50 Initial Disclosure. E-mail to Jacob and David regarding the same.

$ 150.00

$ 240.00
$ 120.00

3/6/19

AMF

$ 300

3/6/19

AMF

$ 300

Preparation for and participation in telephone call with Jacob and David regarding information needed to
0.50 complete the Mandatory Initial Disclosures.

3/6/19
3/7/19

AMF
AMF

$ 300
$ 300

Review incoming pleadings including Notice of Service of Plaintiff's Mandatory Initial Disclosures, Affirmation of Plaintiff's
counsel, Order regarding Plaintiff's Motion to Appear Telephonically. Review
incoming documents, Plaintiff's Mandatory Initial Disclosure.
0.80
0.40 E-mail discussion with opposing counsel regarding discussion of Joint Report.

Entry reduced by 20%. Block billing.

Review revise and finalize draft responses to Mandatory Initial Disclosures. E-mail communication with
David regarding the same. Preparation of Corporate Disclosure Statements for WOZU Education, WOZU Education
Holdings and Southern Careers Institute. E-mail Discussion with Dave regarding the same.

3/7/19

AMF

$ 300

2.70

3/7/19

AMF

$ 300

E-mail discussion with client regarding Corporate Disclosure Statements. Review and revise Corporate
0.60 Disclosure Statements in accordance with discussion with client.
Review incoming pleadings, Plaintiff's draft Case Management Order. Preparation of revisions and additions thereto
including Defendant's portion of the case management plan. Communications with Plaintiff's counsel regarding the case
management plan and changes to be made thereto. Review of
communications with Plaintiff's counsel in preparation for upcoming hearing.

Entry reduced by 20%. Block billing.

2.16

$648.00

$ 180.00

0.60

$ 180.00

$ 810.00

3/8/19

AMF

$ 300

2.30

$ 690.00

AMF

$ 300

2.30
Review incoming information regarding Southern Careers Institute Corporate Structure. Review revise
0.40 and finalize Corporate Disclosure Statement.

$ 690.00

3/8/19

$ 120.00

0.40

$ 120.00

3/8/19

AMF

$ 300

0.40 Discussions with opposing counsel regarding Case Management Plan.

$ 120.00

0.40

$120.00

3.04
2.32
0.30

$ 912.00
$ 696.00
$ 90.00

Detailed review of file in preparation of written discovery requests. Commence preparation of written discovery requests
including Request for Production of Documents, Request for Admissions and Non
Uniform Interrogatories.

3/12/19
3/12/19
3/12/19

AMF
AMF
AMF

$ 300
$ 300
$ 300

3/13/19

AMF

$ 300

3.80
2.90 Final preparation for and attendance at Hearing regarding Proposed Case Management Order.
0.30 E-mail to opposing counsel regarding proposed deadlines.
Review incoming pleadings, Minute Entry regarding recent Scheduling Conference and additional
0.20 information requested by the court.

Final preparation of Defendant's First Discovery Set to Plaintiff including Request for Production of
3.90 Documents, Request for Admission and Non Uniform Interrogatories.

3/14/19

AMF

$ 300

3/14/19
3/14/19

AMF
AMF

$ 300
$ 300

3/18/19

AMF

$ 300

3/19/19
3/19/19
4/2/19

AMF
AMF
MAS

$ 300
$ 300
$ 325

4/12/19

AMF

$ 300

4/15/19
4/16/19
4/18/19

AMF
AMF
AMF

$ 300
$ 300
$ 300

4/25/19

AMF

$ 300

4/26/19

AMF

$ 300

4/26/19

AMF

$ 300

4/26/19
4/26/19

AMF

$ 300
$ 300

4/29/19
4/29/19

AMF
AB
AMF

$ 95
$ 300

4/30/19

AB

$ 95

5/1/19

AMF

$ 300

5/13/19

AMF

$ 300

5/22/19

AMF

$ 300

5/30/19

AMF

$ 300

Entry reduced by 20%. Block billing.
$ 1,140.00
$ 870.00
$ 90.00
$ 60.00
$ 1,170.00

Entry reduced by 20%. Block billing.
Entry deducted. Clerical.

0.00

$ 0.00

3.12

$936.00

0.20
1.20
0.20

Entry reduced by 20%. Block billing.

$ 60.00
$ 360.00
$60.00

0.20 E-mail discussion with opposing counsel regarding proposed deadlines.
1.20 Preparation of draft protective order.
E-mail discussion with opposing counsel regarding deadlines for expert disclosure and amendment of the
0.20 pleadings.

$ 60.00
$ 360.00

0.40 Telephone call with opposing counsel regarding changes to the Joint Case Management Plan.
0.30 Review of revised Joint Case Management Plan. E-mail to opposing counsel regarding the same.
0.50 Receive/review Rule 16 Scheduling Order as entered by Court. Discussion with AMF regarding same.
0.30 Detailed review of file in preparation of status update to client. Status update to client.
Review incoming documents, Plaintiff's discovery responses. Determination of incomplete and evasive
discovery responses that must be supplemented. Review of applicable case law in determining future actions.

$ 120.00
$ 90.00
$ 162.50

0.40
0.30
0.50

$ 120.00
$ 90.00
$ 162.50

$ 90.00

0.30

$ 90.00

1.30
0.30 Review of research regarding the statute of frauds defense.
0.50 Review of research regarding the applicability of California law to the claims at issue.
Detailed review of Defendant's discovery requests to Plaintiff and Plaintiff's discovery responses in preparation of
correspondence to Plaintiff's counsel regarding discovery disputes. Review of case law rules and statutes relating to
copyright infringement defenses including case law pertaining to matters
which may not be copyrighted, including ideas, facts, names and likenesses.
5.20
Review of applicable case law regarding copyright act preemption of state law claims. Preparation of correspondence to
opposing counsel regarding the copyright act preemption of Plaintiff's state law claims and request for the voluntary
dismissal of the claims for accounting, declaratory relief and money had
and received.
2.30
Review of case law regarding choice of law. Review of applicable sections of the Plaintiff's Complaint.
1.80 Preparation of correspondence to opposing counsel regarding choice of law.

$ 390.00
$ 90.00
$ 150.00

1.30
0.30
0.50

$ 390.00
$ 90.00
$ 150.00

4.16

$1,248.00

$ 690.00

2.30

$ 690.00

$ 540.00

1.80

$ 540.00

$ 240.00
$ 60.00

0.80
0.20

$ 240.00
$ 60.00

$ 95.00
$ 60.00

1.00
0.20

$ 95.00
$ 60.00

0.80 Review of documents disclosed with Plaintiff's discovery requests.
0.20 E-mail communication to David and Jacob regarding status update.
1.00 Draft shell for WOZ U Education LLC's responses to Plaintiff's Initial Discovery.
0.20 E-mail discussion with opposing counsel regarding a meet and confer.
Draft shell for WOZ U Education Holdings LLC's responses to Plaintiff's Initial Discovery. Draft shell for
Steve Wozniak's responses to Plaintiff's Initial Discovery. Draft shell for Southern Careers Institute's responses to Plaintiff's
Initial Discovery.

0.50
Preparation for and participation in telephone conference with opposing counsel regarding meet and
0.40 confer prior to filing Motion to Dismiss.

$ 60.00

Entry reduced by 20%. Block billing.

$ 1,560.00

$ 47.50

0.50

$ 47.50

$ 120.00

0.40

$ 120.00

1.20 Review, revise and finalize Motion to Dismiss Counts II, VI and V of Plaintiff's Complaint.
E-mail discussion with opposing counsel regarding Plaintiff's opposition to the Defendant's Motion to
0.20 Dismiss.

$ 360.00

1.20

$ 360.00

$ 60.00

0.20

$ 60.00

0.50 Review of documents regarding WOZ U in determination of future actions.

$ 150.00

0.50

$ 150.00

5/31/19

AMF

$ 300

5/31/19

AMF

$ 300

0.20 Continued discussion with opposing counsel regarding Reply to Motion to Dismiss.
Review, revise, edit Motion for Extension of Time to Reply to Motion to Dismiss and Order regarding
0.30 same.

6/3/19

AMF

$ 300

Review upcoming deadlines. Email to opposing counsel regarding Request for Extension on the Reply to
0.30 the Motion to Dismiss.

6/5/19

AMF

$ 300

6/6/19

AMF

$ 300

6/7/19

AMF

$ 300

Preparation of Defendants' Reply to its Motion to Dismiss Counts 2,4 and 5 of Plaintiff's Complaint
7.20 including addressing the case law cited by the Plaintiff in his Response.

0.20 Review incoming pleadings, signed Order granting Defendant's Motion for Extension of Time.
Review and analyze case law cited by Plaintiff in Plaintiff's Objection in Response to Defendant's
7.80 Purported Motion to Dismiss Causes of Action 2,4 and 5, including the case law related to accounting claim for monies had
and received, Declaratory Judgment, copy write act and preemption of the same.

6/10/19

AMF

$ 300

Determination of best course of action in eliminating and or resolving Count 1 of the Plaintiff's Complaint
0.50 for breach of implied contract.

6/10/19

AMF

$ 300

Review of draft responses to Plaintiff's Discovery Requests. E-mail to David and Jacob regarding
0.50 information needed to complete responses to Plaintiff's Discovery Requests.
Review draft Discovery Responses. Review of Plaintiff's Complaint and Defendant's Answer in preparation
of revisions to Discovery Responses. Review and revise Defendant's Discovery Responses. E-mail to David and Jacob
regarding the same.

6/11/19

AMF

$ 300

6/12/19

AMF

$ 300

2.40
Review of additional case law regarding Defendant's arguments in support of the dismissal of Plaintiff's
0.30 implied contract claim.

$ 300

Revise draft Motion for Judgment on the Pleadings. Email discussion with opposing counsel regarding
1.20 same.

6/28/19

7/1/19
7/2/19

AMF

AMF
AMF

$ 300
$ 300

Preparation for and participation in telephone call with opposing counsel regarding the filing of a Motion to Dismiss
Counts I and II of the Complaint, the need for a Protective Order and Discovery issues. Review
of file following telephone call with opposing counsel.

$ 60.00

0.20

$ 60.00

$ 90.00

0.30

$ 90.00

$ 90.00

0.30

$ 90.00

$ 60.00

0.20

$ 60.00

6.24

$ 1,872.00

5.76

$ 1,728.00

$ 150.00

0.50

$ 150.00

$ 150.00

0.50

$ 150.00

$ 720.00

2.40

$ 720.00

$ 90.00

0.30

$ 90.00

$ 360.00

1.20

$ 360.00

$ 240.00
$ 120.00

0.80
0.40

$ 240.00
$ 120.00

Entry reduced by 20%. Block billing.
$ 2,340.00
$ 2,160.00

Entry reduced by 20%. Block billing.

7/2/19

AMF

$ 300

0.80
0.40 Meeting with ARC regarding procedural arguments to be raised in the Rule 12(c) Motion.
Review of legal research pertaining to the filing of Defendant's Motion for Judgment on the Pleadings
0.50 regarding Plaintiff's Contract Claims. E-mail to opposing counsel regarding the same.

$ 150.00

0.50

$ 150.00

7/12/19

MAS

$ 325

1.50 Review, revise, edit Motion on the Pleadings as to Count 1. Confernce with AMF regarding the same.

$ 487.50

1.50

$ 487.50

7/12/19

AMF

$ 300

Review, revise and finalize Defendant's Steve Wozniak's Motion for Judgment on the Pleading as to Count
2.30 1 of Plaintiff's Complaint.

$ 690.00

2.30

$ 690.00

8/1/19

AMF

$ 300

Detailed review of Motion for Judgment on the Pleadings and Plaintiff's Response thereto. Review of case
1.80 law cited in the Plaintiff's response.

$ 540.00

1.80

$ 540.00

$ 540.00

1.80

$ 540.00

$ 450.00

1.50

$ 450.00

$ 120.00

0.40

$ 120.00

$ 60.00

0.20

$ 60.00

$ 120.00

0.40

$ 120.00

$ 60.00
$ 60.00
$ 60.00

0.20
0.20
0.20

$ 60.00
$ 60.00
$ 60.00

$ 90.00

0.30

$ 90.00

$ 390.00
$ 90.00

1.30
0.30

$ 390.00
$ 90.00

$ 240.00

0.80

$ 240.00

$ 210.00

0.70

$ 210.00

$ 150.00

0.50

$ 150.00

Determination of issues to be addressed in the Reply to the Defendant's Motion for Judgment on the Pleadings.
Preparation of revisions and changes to the draft of Defendant's Motion for Judgment on the
Pleadings.

8/2/19

AMF

$ 300

8/5/19

AMF

$ 300

1.80
Review of draft Protective Order. Preparation of potential revisions thereto. E-mail discussion with
1.50 opposing counsel regarding draft Protective Order.

8/8/19

AMF

$ 300

Review and revise correspondence to be sent to opposing counsel regarding Plaintiff's inadequate
0.40 discovery responses.

8/9/19

AMF

$ 300

8/28/19

AMF

$ 300

9/9/19
9/9/19
9/18/19

AMF
AMF
AMF

$ 300
$ 300
$ 300

10/22/19

AMF

$ 300

10/24/19
10/25/19

AMF
AMF

$ 300
$ 300

10/25/19

AMF

$ 300

10/29/19

AMF

$ 300

11/4/19

AMF

$ 300

0.20 Review incoming correspondence from opposing counsel regarding potential discovery dispute.
Review incoming e-mail from opposing counsel regarding revised Protective Order. Review of revised
0.40 Protective Order. E-mail to opposing counsel regarding the same.
0.20 Review of filed pleadings, Motion for Protective Order.
0.20 E-mail discussion with opposing counsel regarding Protective Order.
0.20 Review incoming Order regarding reassignment of the case to Judge Liburdi.
0.30 E-mail discussion with opposing counsel regarding potential discovery dispute.
Preparation for and participation in extended telephone conference with opposing counsel regarding Defendant's
discovery responses, Plaintiff's objection thereto, potential future discovery and issues
related to the case that may assist in resolving the claims.
1.30
0.30 Review incoming documents, Plaintiff's Expert Disclosure and Certificate of Service.
Determination of potential documents to be disclosed in the action. Preparation of detailed e-mail to
0.80 Jacob and David regarding the same.
Review incoming e-mails from Jacob regarding the applicable operating agreement for the company. Email to opposing counsel regarding the same and the structure of the relationship with Steve Wozniak. Review of
operating agreement provided by Jacob.

0.70
Review of financial information for WOZU Holdings and related companies in determining affect on
0.50 possible settlement on the action.

11/4/19

AMF

$ 300

11/6/19

AMF

$ 300

11/6/19
11/13/19

AMF
AMF

$ 300
$ 300

0.70
0.20 Telephone call with the court's judicial assistant regarding the status of the two pending motions.
Detailed case analysis including review of all upcoming deadlines. Review of all witnesses and exhibits
disclosed by the Plaintiff. Review of applicable case law and statutes pertaining to the Plaintiff's damage claim and review
of pending motions on file with the court in determining additional pleadings to be filed.

11/13/19

AMF

$ 300

11/19/19

AMF

$ 300

4.70
E-mail discussion with opposing counsel regarding document production and meeting to discuss the
0.20 same.

11/20/19

AMF

$ 300

11/20/19

AMF

$ 300

11/21/19
11/21/19

AMF
AMF
AMF
AB

$ 300
$ 300

11/21/19
11/22/19
11/22/19

AMF

$ 300

$ 300
$ 95

0.20 Review incoming pleadings, Notice of Service of Plaintiff's Disclosure of Expert Testimony.
0.40 Review of draft Second Supplemental Disclosure Statement. Preparations of revisions thereto.
Review of information recently provided to the Plaintiff's attorney. Determination of arguments favoring dismissal of the
Plaintiff's claims. E-mail to Plaintiff's counsel regarding defects in the Plaintiff's claims.

0.20 E-mail discussion with opposing counsel regarding dates for the deposition of the Plaintiff.
Determination of upcoming deadlines. Determination of additional witness to be disclosed and exhibits to be disclosed in
the litigation. Review of case law rules and statutes in preparation of Defendants' Motion to Exclude Plaintiff's Expert
Disclosure. Commence preparation of Defendants' Motion to Exclude Plaintiff's Expert Disclosure. E-mail to Jacob and
David regarding the same and additional information
needed.
6.20
Review of additional case law in support of the Defendants' Motion to Exclude Plaintiff's Expert Witness Disclosure. Review
and revise draft of Defendants' Motion to Exclude Plaintiff's Untimely Expert Opinions.
1.80
1.20 Review of case law rules and statutes in preparing arguments regarding choice of law.
0.20 E-mail discussion with David regarding possible witnesses and information possessed by each.
0.50 Bates label documents to accompany Defendants' Third Supplemental Discovery Responses.
Preparation for and participation in telephone conference with David and Jacob regarding potential
0.70 witnesses and exhibits to be disclosed in the case.

$ 60.00

0.20

$ 60.00

$ 120.00

0.40

$ 120.00

0.70
0
3.76

$ 210.00
$0.00
$1,128.00

$ 210.00
$ 60.00

Entry deducted. Clerical.
Entry reduced by 20%. Block billing.

$ 1,410.00
$ 60.00

0.20

$ 60.00

$ 60.00

0.20
4.96

$ 60.00
$1,488.00

$ 540.00
$ 360.00

1.80
1.20

$ 540.00
$ 360.00

$ 60.00
$ 47.50

0.20
0.50

$ 60.00
$ 47.50

$ 210.00

0.70

$ 210.00

Entry reduced by 20%. Block billing.

$ 1,860.00

Review incoming e-mail from Dave regarding agreement with SCI. Review of agreement with SCI.
Preparation of Defendants' Third Supplemental Disclosure Statement. E-mail to David and Jacob regarding the same.
11/22/19

AMF

$ 300

2.40

$ 720.00

2.40

$ 720.00

11/22/19

AMF

$ 300

0.30 Continued discussion with David regarding issues related to the Third Supplemental Disclosure Statement.

$ 90.00

0.30

$ 90.00
$ 47.50

11/25/19

AB

$ 95

Finalize Defendants' Third Supplemental Discovery. Prepare Notice of Service of Defendants' Third
0.50 Supplemental Discovery for filing.

$ 47.50

0.50

11/25/19

AB

$ 95

0.50 Prepare Proposed Order to Defendants' Motion to Exclude Plaintiff's Untimely Expert Disclosure for filing.

$ 47.50

0.50

$ 47.50

11/25/19

$ 300

0.20

$ 60.00

11/27/19

AMF

$ 300

0.20 Review and revise draft Order granting Defendants' Motion to Exclude.
0.20 Review of Notice of Service of Third Supplemental Disclosures.
Review incoming documents received from David regarding work on preparation of the curriculum
0.40 offered by WOZU. CommeNo Chargee preparation of supplemental disclosure regarding the same.

$ 60.00

11/25/19

AMF
AMF

$ 300

$ 60.00

0.20

$ 60.00

$ 120.00

0.40

$ 120.00

1.20
0.20 E-mail discussion with opposing counsel regarding deposition dates.
0.50 Draft shells for Production of Documents requested in Notice of Deposition.
Review of objections to the request for production of documents contained in the deposition notices directed to WOZ U
Education Holdings, WOZ U Education, Southern Careers Institute and Steve Wozniak.

$ 360.00
$ 60.00
$ 47.50

1.20
0.20
0.50

$ 360.00
$ 60.00
$ 47.50

$ 150.00

0.50

$ 150.00

$ 210.00

0.70

$ 210.00

Review incoming pleadings, Notice of Deposition of Steve Wozniak. Review of documents requested in the Notice of
Deposition. Review of applicable federal rules. E-mail to Jacob and David regarding Notice of Deposition of Steve Wozniak
and potential objections thereto. Determination of additional objections
to be raised to the Notice of Deposition.

11/27/19
12/2/19
12/3/19

AMF
AMF
AB

$ 300
$ 300
$ 95

12/4/19

AMF

$ 300

0.50

12/4/19

AMF

$ 300

0.70

12/10/19

AMF

$ 300

Review incoming pleadings, Plaintiff's response and opposition to Defendants' Motion to Exclude
0.50 Plaintiff's Untimely Expert Disclosure.

$ 150.00

0.50

$ 150.00

12/11/19

AMF

$ 300

Review of the Plaintiff's opposition to Defendants' Motion to Exclude Expert Witnesses. Preparation of
1.50 Defendants' reply to their Motion to Exclude Plaintiff's Untimely Expert Disclosure.

$ 450.00

1.50

$ 450.00

12/18/19
12/18/19

AMF

$ 300
$ 300

$ 60.00
$ 90.00

0.20
0.30

$ 60.00
$ 90.00

$ 60.00
$ 60.00
$ 60.00

0.20
0.20
0.20

$ 60.00
$60.00
$ 60.00

12/19/19
12/20/19
12/20/19

AMF
AMF
AMF
AMF

$ 300
$ 300
$ 300

Review of the rules of civil procedure related to depositions by oral examination determining objections
to be raised. Determination of potential objections to be raised regarding Plaintiff's deposition notices.

0.20 E-mail discussion with opposing counsel regarding upcoming depositions.
0.30 Review case status. Detailed e-mail to David regarding the same and assistance needed.
0.20 E-mail discussion with opposing counsel regarding meet and confer.
0.20 E-mail discussion with David Weems regarding Defendants' availability for their depositions.
0.20 Telephone call with opposing counsel regarding issues related to discovery and upcoming depositions.

12/23/19

AMF

$ 300

12/27/19

AMF

$ 300

12/28/19

AMF

$ 300

E-mail discussion with opposing counsel regarding issues related to the Plaintiff's deposition notices and
0.30 defiencies therein.
Review incoming Amended Deposition Notices. Review incoming deposition notices for the 30(b)(6) witness for SCI, WozU
Education and WozU Education Holdings, LLC. Determination of best course of action moving forward. E-mail to David
and Jacob regarding the next steps with regards to the
depositions.

0.70
Determination of need for additional objections to documents requested in the Amended Deposition
0.30 Notices. E-mail discussion with Jacob regarding the same.

Review incoming e-mail from opposing counsel regarding Plaintiff's First Supplemental Disclosure. Review of exhibits
attached thereto. Review of upcoming deposition schedule. E-mail to David and Jacob regarding the same. Preparation of
detailed e-mail to opposing counsel regarding issues related to the recently disclosed documents. Preparation of
Defendants' Fifth Supplemental Disclosure Statement. Email to David regarding the same.

1/9/20

AMF

$ 300

1/9/20

AMF

$ 300

4.10
E-mail discussion with David regarding the changes to the Fifth Supplemental Disclosure Statement.
0.40 Revise Fifth Supplemental Disclosure Statement. E-mail to David regarding the same.

1/9/20

AMF

$ 300

Review of Objections to Amended Deposition Notices for the 30(b)(6) representative of Southern Careers
0.50 Institute, WozU Education and WozU Education Holdings.

1/9/20

AMF

$ 300

1/10/20

AMF

$ 300

0.20 E-mail discussion with opposing counsel regarding Plaintiff's deposition. (Client Courtesy - No Charge).
Review incoming documents, Notice of Service of Supplemental Initial Discovery Responses filed by the
0.20 Plaintiff.

1/10/20

AMF

$ 300

Review incoming e-mail from opposing counsel regarding issues related to the scheduling of the
0.20 upcoming depositions. E-mail to Jacob and David regarding the same and information needed.

1/10/20

AMF

$ 300

E-mail to Ken Hardesty regarding telephone conference to discuss communications with the Plaintiff.
0.20 (Client Courtesy - No Charge).
Review incoming pleadings, Plaintiff's Letter Concerning Ongoing Discovery Dispute and exhibits attached
thereto. E-mail to Jacob and David regarding the same. Continued e-mail discussion with Jacob and Deb regarding issues
related to the depositions and discovery motion.

1/13/20

AMF

$ 300

1/13/20

AMF

$ 300

1.00
Review of court rules and Order entered in determining how best to respond to the Plaintiff's discovery
0.50 related motion.

$ 90.00

0.30

$ 90.00

$ 210.00

0.70

$ 210.00

$ 90.00

0.30

$ 90.00

3.28

$984.00

$ 120.00

0.40

$ 120.00

$ 150.00

0.50

$ 150.00

No Charge

N/A

No Charge

$ 60.00

0.20

$ 60.00

Entry reduced by 20%. Block billing.

$ 1,230.00

$ 60.00

0.20

$ 60.00

No Charge

N/A

No Charge

$ 300.00

1.00

$ 300.00

$ 150.00

0.50

$ 150.00

1/13/20

AMF

$ 300

Preparation for and participation in telephone conference with Jacob and David regarding issues related
0.70 to depositions and financial documents.

$ 210.00

0.70

$ 210.00

1/13/20

AMF

$ 300

Detailed e-mail to opposing counsel regarding issues related to the 30(b)(6) deposition of the entity
0.40 Defendants. Review incoming e-mail from David regarding depositions and financial disclosures.

$ 120.00

0.40

$ 120.00

1/14/20

AB

$ 95

0.20 Draft Proposed Order regarding Motion to Strike Plaintiff's Letter Concerning Ongoing Discovery Disputes.

$ 19.00

0.20

$ 19.00

Continued e-mail discussion with opposing counsel and David regarding issues related to upcoming
0.20 depositions.

1/14/20

AMF

$ 300

1/14/20

AMF

$ 300

1/14/20

AMF

$ 300

1/15/20 AB

$ 95

1/15/20 AB

$ 95

$ 60.00

0.20

$ 60.00

0.30 Review and revise Motion to Strike Plaintiff's Letter Concerning Ongoing Discovery Dispute.
Review incoming pleadings, Order granting Motion to Strike. E-mail to David and Jacob regarding the
0.30 same.

$ 90.00

0.30

$ 90.00

$ 90.00

0.30

$ 90.00

0.30 Bates label documents WOZU00096-00151.
Bates label documents WOZU00152-00239. Draft Sixth Supplemental Disclosure Statement. Forward
0.50 same to AMF for review.

$ 28.50

0.30

$ 28.50

$ 47.50

0.50

$ 47.50

3.90

$1,170.00

Detailed review of incoming documents including WozU Education Holdings audited financial statements, WozU Education
Holding LLC's agreement with SCI, WozU Education Holding LLC's second amended and updated operating agreement,
WozU Education Holdings license agreement with Steve Wozniak. E-mail discussions with Jonathan Crowley regarding the
same. Detailed e-mail to opposing counsel regarding recently disclosed confidential documents and their relevance to the
Plaintiff's merit-less claims.
1/15/20

AMF

$ 300

1/15/20

AMF

$ 300

3.90
Review and revise the Defendants' Sixth Supplemental Disclosure Statement. E-mail to David Weems
0.40 regarding the same.

$ 1,170.00

1/15/20
1/15/20

AMF
AMF

$ 300
$ 300

$ 120.00

0.40

$ 120.00

0.30 Telephone call with opposing counsel regarding discovery issues.
0.20 Continued discussion with Jonathan Crowley regarding payments received by Wozniak.
E-mail discussion with David Weems regarding telephone call with Plaintiff's counsel and documents
0.30 recently disclosed.

$ 90.00
$ 60.00

0.30
0.20

$ 90.00
$ 60.00

1/16/20

AMF

$ 300

1/16/20

AMF

$ 300

$ 90.00

0.30

$ 90.00

$ 120.00

0.40

$ 120.00

$ 300

0.40 Review incoming documents, Plaintiff's First Supplemental Disclosures.
E-mail discussion with David regarding his confirmation of the cancellation of the deposition scheduled
0.20 for this week.

1/21/20

AMF

1/21/20

AMF

$ 60.00

0.20

$ 60.00

$ 300

0.20 E-mail discussion with opposing counsel regarding meet and confer.

$ 60.00

0.20

$ 60.00

1/22/20

AMF

$ 300

1/22/20

AMF

$ 300

1/23/20

AMF

$ 300

1/24/20 JCS
AMF
1/27/20
1/27/20
AMF

$ 300
$ 300
$ 300

1/28/20

AMF

1/28/20

AMF

1/28/20

AMF

$ 300

1/29/20

AMF

$ 300

1/29/20

AMF

$ 300

1/29/20

AMF

1/30/20

AB

Extended telephone call with opposing counsel regarding issues related to discovery, additional
0.90 document requests and depositions to be scheduled.

$ 270.00

0.90

$ 270.00

0.20 E-mail discussion with David and Jacob regarding the deposition dates for Wozniak and Ken Hardesty.
E-mail discussion with Jonathon Crowley regarding information regarding payments made pursuant to
0.20 the license agreement.

$ 60.00

0.20

$ 60.00

$ 60.00

0.20

$ 60.00

$ 180.00
$ 60.00
$ 60.00

0.60
0.20
0.20

$ 180.00
$ 60.00
$ 60.00

$ 300

0.60 Review financial statements provided by J. Crowley in preparation to send to AMF.
0.20 E-mail discussion with David regarding issues related to discovery and depositions.
0.20 E-mail discussion with opposing counsel regarding issues related to depositions.
Extended telephone call with Ken Hardesty regarding issues related to the Plaintiff's factual allegations
0.50 and deposition.

$ 150.00

0.50

$ 150.00

$ 300

E-mail to David and Jacob regarding telephone call with Ken Hardesty. E-mail to opposing counsel
0.30 regarding the same.

$ 90.00

0.30

$ 90.00

0.20 Continued discussion with opposing counsel regarding the deposition of Steve Wozniak.
Review of objection to the amended request for production of documents contained in the deposition
0.30 notice of Steve Wozniak.

$ 60.00

0.20

$ 60.00

$ 90.00

0.30

$ 90.00

$ 210.00

0.70

$ 210.00

$ 300

0.70 Review of additional documents to be disclosed related to financials for 2017 and 2018
E-mail to Ken Hardesty regarding e-mail communications with the Plaintiff. Commence preparation of
1.20 Affidavit of Ken Hardesty.

$ 360.00

1.20

$ 360.00

$ 95

Bates documents to be included in Seventh Supplemental Disclosure Statement. Draft Seventh
0.30 Supplemental Disclosure Statement. Forward same to AMF for review.

$ 28.50

0.30

$ 28.50

$ 150.00

0.50

$ 150.00

$ 390.00

1.30

$ 390.00

2.50

$750.00

$ 90.00

0.30

$ 90.00

1.10
Extended telephone call with Ken Hardesty regarding revisions to his draft Affidavit. Preparation of
0.70 revisions to draft Affidavit. E-mail to Ken regarding the same.

$ 330.00

1.10
0.70

$ 330.00
$210.00

0.20 E-mail discussion with opposing counsel regarding deposition dates.
Review incoming e-mail from Ken regarding executed notarized Affidavit. Revise and finalize the Defendants' Seventh
Supplemental Disclosure to include the Affidavit. E-mail to opposing counsel
regarding the same.
0.60
0.20 Draft Notice of Service of Seventh Supplemental Responses to Mandatory Initial Discovery for filing.
0.20 Finalize Joint Letter of Pending Motions for filing.
Review incoming documents, seventh supplemental disclosure with verification signed by David Weems.
0.30
E-mail to opposing counsel regarding the same.

$ 60.00

0.20

$ 60.00

$ 180.00
$ 19.00

0.60
0.20

$ 180.00
$ 19.00

$ 19.00

0.20

$ 19.00

$ 90.00

0.30

$ 90.00

1/30/20

AMF

$ 300

Review and revise joint letter of pending motions. E-mail to opposing counsel regarding the same. Review
0.50 of pending motions in preparation of revisions to the same.

1/30/20

AMF

$ 300

Continued preparation of draft Affidavit of Ken Hardesty. Review of file documents in preparation of the
1.30 same. E-mail to Ken regarding draft Affidavit.

1/30/20

1/30/20

AMF

AMF

$ 300

$ 300

2.50

0.30

Review incoming e-mail from opposing counsel regarding stipulation to extend the discovery cut off.
Review of scheduling order in preparation of revisions to the draft stipulation. Review and revise draft stipulation to
extend the discovery cut off. Extensive e-mail discussion with opposing counsel regarding issues related to the same.
Determination of matters to be completed before the discovery cut off.
Review incoming e-mail from opposing counsel regarding the stipulation and order to extend the discovery deadline. Email discussion with opposing counsel regarding joint letter regarding pending
motions.

$ 750.00

Review incoming e-mail from Ken regarding revisions to draft Affidavit. Review of revised Affidavit. Preparation of
additional changes and additions thereto. E-mail to Ken regarding further revisions to the
Affidavit.
1/31/20

AMF

$ 300

1/31/20

AMF

$ 300

1/31/20

AMF

$ 300

1/31/20
2/3/20

$ 300
$ 95

2/3/20

AMF
AB
AB

2/3/20

AMF

$ 300

2/3/20

AMF

$ 300

Review incoming e-mail from opposing counsel regarding joint letter regarding pending motions and
0.30 approval of the same. Finalize joint letter for filing.

$ 90.00

0.30

$ 90.00

E-mail discussion with opposing counsel regarding upcoming depositions. E-mail to David and Jacob
0.30 regarding the same.

$ 90.00

0.30

$ 90.00

$ 90.00

0.30

$ 90.00

No Charge

N/A

No Charge

$ 120.00

0.40

$ 120.00

$ 690.00

2.30

$ 690.00

$ 95

2/3/20

AMF

$ 300

2/3/20

AMF

$ 300

2/3/20

AMF

$ 300

0.30 Revise and finalize Notice of Service regarding the Defendants' Seventh Supplemental Disclosure.
Review incoming pleadings, Order granting Stipulated Motion for Extension of Discovery Deadlines.
0.20 (Client Courtesy - No Charge).

2/4/20

AMF

$ 300

E-mail discussion with opposing counsel, Ken Hardesty and David regarding the deposition of Ken
0.40 Hardesty.

2/4/20

AMF

$ 300

2.30

Commence preparation for the upcoming deposition of Ken Hardesty. Gather and organize documents to be reviewed by
Ken in preparation for his upcoming deposition. Commence preparation of notes
regarding issues to be addressed prior to the deposition.

$ 210.00

2/5/20
2/5/20
2/7/20
2/10/20

AMF
AMF
AMF
AMF

$ 300
$ 300
$ 300
$ 300

2/11/20

AMF

$ 300

2/12/20
2/13/20
2/13/20

AMF
AMF
AMF

$ 300
$ 300
$ 300

2/14/20

AMF

$ 300

Telephone call with Ken Hardesty regarding the scheduling of his deposition and matters related thereto. E-mail to
opposing counsel regarding the deposition of Ken Hardesty. E-mail discussion with opposing
counsel regarding missing e-mails.

0.50
1.30 Continued preparation of upcoming deposition of Ken Hardesty.
0.20 E-mail discussion with opposing counsel regarding upcoming deposition of Ken Hardesty.
0.30 E-mail discussion with opposing counsel regarding issues related to the Ken Hardesty deposition.
Preparation for and participation in telephone conference with Ken Hardesty regarding deposition
1.40 preparation.

$ 150.00
$ 390.00
$ 60.00
$ 90.00

3.00 Travel to San Jose for deposition of Ken Hardesty.
3.10 Meeting with Ken to prepare for deposition. Attendance at deposition of Ken Hardesty.
3.00 Travel time to Phoenix regarding Ken Hardesty deposition.
Review incoming e-mail from Ken regarding additional e-mail communication regarding the Sarta
0.20 convention Wozniak attended in 2011.
Review incoming e-mail from David regarding Ken Hardesty's deposition and case status. Detailed review
of notes from Ken Hardesty's deposition in preparation of response to the same. Detailed e-mail to David and Jacob
regarding Ken Hardesty's deposition and planned future actions.

0.50
1.30
0.20
0.30
1.4

$ 150.00
$ 390.00
$60.00
$90.00

$ 900.00
$ 930.00
$ 900.00

3.00
3.10
3.00

$ 900.00
$ 930.00
$ 900.00

$ 60.00

0.20

$ 60.00

$ 120.00
$ 60.00

0.40
0.20

$ 120.00
$ 60.00

$ 120.00

0.40

$ 120.00

$ 28.50

0.30

$ 28.50

No Charge

N/A

No Charge

$ 180.00

0.60

$ 180.00

0.20

$60.00

$ 420.00

2/18/20
2/18/20

AMF
AMF

$ 300
$ 300

2/18/20

AMF

$ 300

0.40
0.20 E-mail discussion with Ken Hardesty regarding deposition of Steve Wozniak.
Review and revise Defendants' Eighth Supplemental Disclosure. E-mail to David Weems regarding the
0.40 same.

2/19/20

AB

$ 95

Finalize 8th Supplemental Disclosure Statement. Draft Notice of Service for 8th Supplemental Disclosure
0.30 Statement for filing.

2/26/20

AMF

$ 300

3/3/20

AMF

$ 300

0.20 E-mail discussion with David Weems regarding status of the case. (Client Courtesy - No Charge).
Review incoming pleadings, Order granting in part Defendants' Motion to Dismiss. E-mail discussion with David regarding
0.60 the same. Review incoming pleadings, Order setting status conference in the matter.

$ 300

Review incoming e-mail from opposing counsel regarding deposition of Steve Wozniak. E-mail to Ken
0.20 Hardesty regarding the same.

$ 60.00

3/7/20

AMF

$ 420.00

3/10/20

AMF

$ 300

E-mail discussion with David and Jacob regarding e-mail received from opposing counsel regarding the
0.20 deposition of Steve Wozniak.

$ 60.00

0.20

$ 60.00

3/10/20

AMF

$ 300

Review incoming pleadings, Order granting Defendants' Motion to Exclude Plaintiff's Untimely Expert
0.30 Disclosure. E-mail to David and Jacob regarding the same.

$ 90.00

0.30

$ 90.00

$ 300

Review of additional case law to determine the effect of the recent rulings from the court on Plaintiff's
1.10 remaining claims and changes to be made in the planned Motion for Summary Judgment.

$ 330.00

1.10

$ 330.00

$ 360.00

1.20

$ 360.00

$ 90.00

0.30

$ 90.00

3/11/20

AMF

Review incoming e-mail from opposing counsel regarding Joint Letter concerning the deposition of Steve Wozniak. Review
of the draft Joint Letter. Preparation of Defendants' additions to the same. E-mail to
opposing counsel regarding revised Joint Letter.

3/11/20

AMF

$ 300

3/12/20

AMF

$ 300

1.20
Review incoming e-mail from opposing counsel regarding revised Joint Letter. Review of revised Joint
0.30 Letter. E-mail to opposing counsel regarding the same.

3/12/20

AMF

$ 300

Review and revise the Defendants' Ninth Supplemental Disclosure Statement. E-mail to David Weems
0.40 regarding the same.

$ 120.00

0.40

$ 120.00

3/13/20

AMF

$ 300

Review incoming e-mail from opposing counsel regarding further revisions to the Joint Letter to be filed
0.40 with the court. Review of revised Joint Letter. E-mail to opposing counsel regarding the same.

$ 120.00

0.40

$ 120.00

3/13/20

AMF

$ 300

Review incoming pleadings, Ex Parte Motion for Leave to Appear Telephonically filed by the Plaintiff.
0.30 Review incoming e-mail from Plaintiff's counsel regarding Motion to Appear Telephonically.

$ 90.00

0.30

$ 90.00

3/13/20

AMF

$ 300

$ 300.00

1.00

$ 300.00

3/13/20

AMF

$ 300

1.00 Preparation for upcoming status conference with the court.
E-mail discussion and telephone call with Ken Hardesty regarding Steve Wozniak's deposition and recent
0.40 Order by the court.

$ 120.00

0.40

$ 120.00

3/15/20

AMF

$ 300

$ 90.00

3/16/20

AMF

$ 300

0.30 Telephone call with Ken regarding Wozniak deposition. E-mail to opposing counsel regarding the same.
Telephone call with opposing counsel regarding issues to be discussed at the upcoming status conference.
3.80 Preparation for and participation in the status conference with the court.

0.30
3.04

$ 90.00
$912.00

3/16/20

AMF

$ 300

Review incoming Minute Entry regarding status conference and order that the parties engage in good
0.30 faith settlement discussions. E-mail to opposing counsel regarding the same.

$ 90.00

0.30

$ 90.00

3/16/20

AMF

$ 300

Telephone call with Ken regarding issues related to the Wozniak deposition. E-mail to opposing counsel
0.30 regarding the same.

$ 90.00

0.30

$ 90.00

3/16/20

AMF

$ 300

0.40 Continued discussion with opposing counsel regarding issues related to the deposition of Steve Wozniak.

$ 120.00

0.40

$120.00

3/16/20

AMF

$ 300

Continued e-mail discussion with opposing counsel regarding issues related to court ordered settlement
0.30 conference.

$ 90.00

0.30

$ 90.00

3/17/20

AMF

$ 300

0.20 Continued discussion with Ken and opposing counsel regarding dates for the deposition of Wozniak.

$ 60.00

0.20

$60.00

$ 1,140.00

Entry reduced by 20%. Block billing.

3/17/20

AMF

$ 300

E-mail discussion with opposing counsel regarding Joint Request for Appointment of a Magistrate Judge
0.20 to conduct a settlement conference.

$ 60.00

0.20

$ 60.00

3/17/20

AMF

$ 300

Extended telephone call with Ken regarding issues related to the upcoming deposition of Steve Wozniak
0.50 and likely areas of questioning as well as case status and rulings on recent motions.

$ 150.00

0.50

$ 150.00

3/17/20

AB

$ 95

0.50

$ 47.50

AB

$ 95

$ 28.50

0.30

$ 28.50

3/17/20

AMF

$ 300

0.50 Draft Stipulated Motion for Extension of Time regarding discovery. Forward to AMF for review.
0.30 Draft Notice of Deposition for Ralph T. Reilly. Forward same to AMF for review.
Continued discussion with Ken and opposing counsel regarding the dates for the deposition of the
0.30 Plaintiff and Steve Wozniak.

$ 47.50

3/17/20

$ 90.00

0.30

$ 90.00

3/19/20

AB
AB

$ 95

0.20 Finalize Stipulated Motion for Extension of time. Forward same to opposing counsel for review.
0.30 Daft Notice of Deposition of Ralph T. Rielly for filing with the court. Forward to AMF for review.
Review incoming e-mail from court reporter regarding deposition transcript. Review of the deposition
transcript from the deposition of Ken Hardesty. Preparation of notes regarding the same. E-mail to Ken Hardesty regarding
his deposition transcript and possible corrections to be made thereto.
2.40
0.20 Review incoming pleadings, Order regarding status conference and good faith settlement discussions.

$ 19.00

0.20

$ 19.00

$ 28.50

0.30

$ 28.50

$ 720.00
$ 60.00
$ 120.00

2.40
0.20
0.40

$ 720.00
$ 60.00
$ 120.00

3/19/20

3/19/20
3/19/20
3/19/20
3/19/20
3/19/20
3/19/20
3/20/20
3/20/20

AMF
AMF
AMF
AMF
AMF

$ 95

$ 300
$ 300
$ 300

AMF

$ 300
$ 300
$ 300

AMF
AMF

0.40 Preparation of revisions and additions to the draft Joint Stipulation to Extend the Discovery Deadline.
0.30 Review and revise the Notice of Deposition regarding Ralph Reilly.
0.20 E-mail discussion with opposing counsel regarding appointment of magistrate judge.

$ 90.00
$ 60.00
$ 60.00

0.30
0.20
0.20

$ 90.00
$ 60.00
$ 60.00

$ 300

0.20 Review of draft Notice of Deposition of Plaintiff Ralph T. Reilly.
Review incoming e-mail from opposing counsel regarding joint letter to the court. Review and revise joint
0.40 letter. E-mail to opposing counsel regarding the same.

$ 120.00

0.40

$ 120.00

$ 300

Review incoming Order regarding settlement conference with a magistrate judge. E-mail to Jacob and
0.30 David regarding the same.

$ 90.00

0.30

$ 90.00

$ 1,110.00

3.70

$ 1,110.00

$ 60.00

0.20

$ 60.00

$ 90.00

0.30

$ 90.00

0.30 Draft proposed order to Motion for Extension of deadlines. Forward to AMF and file.
E-mail discussion with opposing counsel regarding Stipulated Motion for Extension of the Discovery
0.20
Deadline.

$ 28.50

0.30

$ 28.50

$ 60.00

0.20

$ 60.00

Review of file materials in preparation of Affidavit of Steve Wozniak including documents disclosed and pleadings filed.
Preparation of draft Affidavit of Steve Wozniak. E-mail to Ken Hardesty regarding the
same.

3/26/20

AMF

$ 300

3/27/20

AMF

$ 300

3.70
Review upcoming deadlines. E-mail to opposing counsel regarding the same and contacting the judge for
0.20 the settlement conference.

3/27/20

AMF

$ 300

E-mail discussion with opposing counsel and court's judicial assistant regarding the settlement conference
0.30 and the status of the Order extending the Discovery and Dispositive Motion Deadline.

3/31/20

AB

$ 95

3/31/20

AMF

$ 300

3/31/20
3/31/20
4/7/20

AMF
AMF
AMF

$ 300
$ 300
$ 300

0.20 Review and revise draft Order granting Motion for Extension of Deadlines.
0.20 Review incoming Order granting the requested Stipulation to extend discovery deadlines.
0.20 Communications with court reporter and opposing counsel regarding deposition of the Plaintiff.

$ 60.00
$ 60.00
$ 60.00

0.20
0.20
0.20

$ 60.00
$ 60.00
$ 60.00

4/9/20

AMF

$ 300

0.20 Telephone call with Ken regarding issues related to depositions, discovery and affidavit of Steve Wozniak.

$ 60.00

0.20

$ 60.00

Follow-up telephone call with Ken regarding issues related to the deposition of the Plaintiff and the
0.20 deposition of Steve Wozniak and potential scheduling issues related to the same.

$ 60.00

0.20

$ 60.00

0
0

$0.00
$0.00

4/9/20

AMF

$ 300

4/9/20

AMF

$ 300

4/13/20

AMF

$ 300

4/16/20

AMF

$ 300

0.20

$ 60.00

AMF

$ 300

0.20 Continued discussion with Jacob and David regarding attendance at the settlement conference.
Continued discussion with the court's staff, opposing counsel and clients regarding dates for the
0.50 settlement conference and issues related thereto.

$ 60.00

4/17/20

$ 150.00

0.50

$ 150.00

4/17/20

AMF

$ 300

Continued discussion with the court's staff, opposing counsel and clients regarding issues related to the
0.40 settlement conference.

$ 120.00

0.40

$120.00

Review incoming Order related to the upcoming settlement conference and related deadlines. E-mail to
0.40 clients regarding the same.

$ 120.00

0.40

$ 120.00

4/20/20

AMF

$ 300

4/27/20

AMF

$ 300

4/30/20

AMF

5/7/20

AMF

0.20 E-mail discussion with court's staff regarding scheduling of a settlement conference.
Continued discussion with court's judicial assistant and opposing counsel regarding the scheduling of a
0.20 settlement conference in the matter.

$ 60.00
$ 60.00

Entry deducted. Clerical.
Entry deducted. Clerical.

$ 60.00

0.20

$ 60.00

$ 300

0.20 E-mail discussion with opposing counsel regarding depositions by video conference.
E-mail discussion with opposing counsel regarding discovery and dispositive motion deadlines. Review
0.50 and revise draft stipulation prepared by opposing counsel.

$ 150.00

0.50

$ 150.00

$ 300

E-mail discussion with court's judicial assistant regarding information need for the upcoming settlement
0.20 conference.

$ 60.00

0.20

$ 60.00

0.20

$60.00

5/8/20

AMF

$ 300

0.20 E-mail discussion with opposing counsel regarding issues related to the upcoming settlement conference.

$ 60.00

5/13/20

AMF

$ 300

$ 60.00

0.20

$60.00

5/14/20

AMF

$ 300

0.20 E-mail discussion with David regarding upcoming settlement conference.
Review status of receipt of written settlement offer from the Plaintiff. E- mail to Plaintiff's counsel
0.30 regarding the same.

$ 90.00

0.30

$ 90.00

5/15/20

AMF

$ 300

Review incoming documents, correspondence from opposing counsel regarding Plaintiff's settlement
0.40 demand. E-mail to client regarding the same.

$ 120.00

0.40

$ 120.00

5/15/20

AMF

$ 300

Telephone call with Jacob regarding issues related to the Plaintiff's settlement demand and upcoming
0.20 settlement conference.

$ 60.00

0.20

$ 60.00

5/15/20

AMF

$ 300

$ 30.00

0.10

$ 30.00

2.80

$840.00

5/15/20

AMF

$ 300

5/18/20

AMF

$ 300

0.10 Telephone call with Ken regarding Plaintiff's settlement demand.
Review of file in preparation of draft response to the Plaintiff's settlement demand. Preparation of draft response to
Plaintiff's settlement demand including detailed information regarding the status of the
Plaintiff's claims and the deficiencies regarding the same. E-mail to clients regarding the same.
2.80
Review incoming e-mail from Jacob regarding approval of the Response to Plaintiff's settlement demand.
0.50 Review and revise settlement demand. E-mail to opposing counsel regarding the same.
Review of file materials in preparation of the Defendant's confidential settlement conference memorandum. Review of
court's Order regarding the same. Preparation of Defendants' confidential
settlement conference memorandum. E-mail to clients regarding the same.

5/18/20

AMF

$ 300

5/20/20

AB

$ 95

3.40
Finalize settlement conference memorandum to be delivered to the court. Contact process server to
0.50 deliver memorandum to court.

E-mail discussion with Jacob regarding issues related to the mediation memorandum filed by the Defendants. E-mail
0.30 discussion with Jacob regarding preparing for the upcoming settlement conference.

5/26/20

AMF

$ 300

5/26/20

AMF

$ 300

5/26/20
5/26/20
5/26/20

AMF
AB
AMF

$ 300
$ 95
$ 300

5/27/20

0.20 Continued discussion with Jacob regarding issues related to the upcoming settlement conference.
Review incoming e-mail from opposing counsel regarding Plaintiff's settlement memorandum. Review of
Plaintiff's redacted settlement conference memorandum. Preparation for and participation in telephone conference with
Jacob and David regarding upcoming settlement conference.
1.20
0.50 Prepare settlement conference binder for May 28, 2020 settlement conference.

AMF

$ 300

0.20 Telephone call with Ken regarding issues related to the upcoming settlement conference.
Participation in telephone call with Steve Wozniak regarding issues related to the upcoming settlement
0.30 conference.

5/28/20

AMF

$ 300

Preparation for and participation in court ordered settlement conference. E-mail discussion with clients
2.50 regarding the same and future actions.

6/2/20

AMF

$ 300

6/5/20

AMF

$ 300

0.20 Review incoming pleadings, Minute Entry regarding recent settlement conferernce.
E-mail discussion with opposing counsel regarding Joint Report to the court. E-mail to Ken regarding
0.30 possible deposition of Steve Wozniak.

$ 840.00
$ 150.00

0.50

$ 150.00

3.40

$1,020.00

$ 47.50

0.50

$ 47.50

$ 90.00

0.30

$ 90.00

$ 60.00

0.20

$ 60.00

$ 360.00
$ 47.50
$ 60.00

1.20
0.50
0.20

$ 360.00
$ 47.50
$ 60.00

$ 1,020.00

$ 90.00

0.30

$ 90.00

$ 750.00

2.50

$ 750.00

$ 60.00

0.20

$ 60.00

$ 90.00

0.30

$ 90.00
$ 120.00

6/5/20

AMF

$ 300

Review incoming e-mail from opposing counsel regarding Joint Status Report to the court. Review and
0.40 revise Joint Status Report. E-mail to opposing counsel regarding the same.

$ 120.00

0.40

6/7/20

AMF

$ 300

0.30 E-mail discussion with Ken and opposing counsel regarding deposition of Steve Wozniak.

$ 90.00

0.30

$90.00

6/8/20

AB
AB
AMF

$ 95

0.20 Draft Notice of Deposition of Ralph Reilly. Forward same to AMF for review.
0.20 Draft Notice of Service of Notice of Deposition of Ralph Reilly. File same.
0.30 Continued discussion with opposing counsel and Ken regarding the deposition of Steve Wozniak.

$ 19.00

0.20

$ 19.00

$ 19.00
$ 90.00
$ 60.00

0.20
0.30
0.20

$ 19.00
$ 90.00
$ 60.00

$ 90.00
$ 120.00

0.30
0.40

$90.00
$ 120.00

$ 690.00

2.30

$ 690.00

$ 720.00

2.40

$ 720.00

$ 90.00

0.30

$ 90.00

4.56

$1,368.00

6/8/20
6/8/20
6/8/20

$ 95
$ 300
$ 300

6/8/20
6/9/20

AMF
AMF
AMF

6/9/20

AMF

$ 300

6/9/20

AMF

$ 300

6/10/20

AMF

$ 300

2.40 Preparation of notes and exhibits for the upcoming deposition of Ralph Reilly.
Review case status. E-mail to Jacob and David regarding the same including upcoming depositions and the
0.30 status of the Motion for Summary Judgment.
Continued preparation for deposition of Plaintiff Ralph Reilly. Preparation of additional exhibits for use at
5.70 the deposition. Attendance at the deposition of Ralph Reilly.
Draft Tenth Supplemental Disclosure. Bates label attachments. Sent to AMF for review. E-mail and mail
0.50 to opposing counsel.

6/11/20

$ 300
$ 300

AMF

$ 300

6/15/20

AB

$ 95

6/15/20

AMF

$ 300

6/19/20

AMF

$ 300

6/22/20

AMF

$ 300

6/23/20

AMF

$ 300

0.20 Review of Notice of Deposition of Plaintiff Ralph Reilly.
0.30 Telephone call with Ken Hardesty regarding issues related to the upcoming deposition of Steve Wozniak.
0.40 E-mail to Ken regarding likely issues to be raised at the deposition.
Preparation for and participation in video conference deposition of Steve Wozniak. Telephone call and e2.30 mail to Ken regarding the same.

0.40 Identification of additional documents to be disclosed.
Review of applicable case law rules and statutes in preparation of the Defendants' Motion for Summary
1.30 Judgment.
Detailed review of the transcripts of the deposition of the Plaintiff and Steve Wozniak in preparation of Defendants'
Motion for Summary Judgment. Review of applicable case law regarding Plaintiff's copyright claim and claim for breach of
implied contract and declaratory relief. Commence preparation of additions
to Defendants' Motion for Summary Judgment.

7.90
E-mail discussion with David regarding information needed for an upcoming audit. Review of cases in
0.40 preparation of the same. Preparation of detailed e-mail to David regarding status of current cases.

$ 1,710.00

Entry reduced by 20%. Block billing.

$ 47.50

0.50

$ 47.50

$ 120.00

0.40

$ 120.00

$ 390.00

1.30
Entry reduced by 20%. Block billing.

$ 390.00

6.32

$1,896.00

0.40

$ 120.00

$ 2,370.00
$ 120.00

6/25/20

AMF

$ 300

6/30/20

AMF

$ 300

7/1/20

AMF

$ 300

Continued preparation of Defendants' Motion for Summary Judgment and Statement of Facts in support of Defendants'
Motion for Summary Judgment. Review and revise arguments regarding breach of implied contract, copyright infringement
and declaratory judgement. Review and revise Defendants' Statement of
Facts.

9.20
Continued preparation of Motion for Summary Judgment. Add additional arguments related to the
1.20 Plaintiff's declaratory judgment claim.

Final preparation of revisions to draft Motion for Summary Judgment and Statement of Facts in support thereof.
Preparation of changes to the Defendants' list of exhibits for its Motion for Summary Judgment.
E-mail to David, Jacob and Ken regarding the same.

$ 60.00

0.20
Entry reduced by 20%. Block billing.

$ 60.00

7.36

$2,208.00

$ 2,760.00
$ 360.00

1.20

$ 360.00

4.16

$1,248.00

$ 1,560.00
$ 66.50
$ 28.50
$ 60.00

0.70
0.30
0.20

$ 66.50
$ 28.50
$ 60.00

Entry reduced by 20%. Block billing.

7/12/20
7/13/20
7/13/20
7/13/20

AMF

$ 300
$ 95
$ 95
$ 300

7/13/20

AMF

$ 300

5.20
0.70 Preparation of exhibits 1-9 for Statement of Facts in Support of Motion for Summary Judgment.
0.30 Draft Proposed Order regarding Motion to Page Exceed Page Limit.
0.20 E-mail discussion with David regarding draft Motion for Summary Judgment.
Finalize drafts of the Motion for Summary Judgment, Statement of Facts in Support of Defendants'
1.30 Motion for Summary Judgment and Defendants' Index of Exhibits.

$ 390.00

1.30

$ 390.00

AMF

$ 300

Review incoming e-mails from Jacob, Ken and Steve Wozniak regarding the draft Motion for Summary
0.20 Judgment.

$ 60.00

0.20

$ 60.00

7/14/20

AMF
AB
AB

Brief telephone call with Ken Hardesty regarding status of the Motion for Summary Judgment and
0.20 additional information needed.

7/15/20

AMF

$ 300

Telephone call with Dave and Jacob regarding filing of exhibits under seal. Review of applicable rules.
1.40 Preparation of Motion to File Exhibits 8 and 9 Under Seal. Preparation of Order granting the same.

$ 420.00

1.40

$ 420.00

7/15/20

AMF

$ 300

0.20 Continued discussion with Jacob and Ken regarding issues related to the Motion for Summary Judgment.

$ 60.00

0.20

$ 60.00

8/4/20
8/14/20

AMF
AMF

$ 300
$ 300

$ 60.00
$ 60.00

0.20
0.20
5.52

$ 60.00
$ 60.00
$1,656.00

9/1/20

AMF

$ 300

9/1/20

AMF

$ 300

0.20 Review incoming pleadings, Order Granting the Defendants' Motion to File Under Seal.
0.20 E-mail discussion with opposing counsel regarding filing exhibits under seal.
Continued detailed review of the arguments raised in the Plaintiffs' Response to the Defendants' Motion for Summary
Judgment. Review of the Plaintiffs' Controverting and Additional Statement of Facts.
Continued preparation of the Plaintiffs' Reply to their Motion for Summary Judgment.
6.90
1.10 Continued preparation of the Defendants' Reply to their Motion for Summary Judgment.
Review, revise, supplement and complete draft of the Reply to the Defendants' Motion for Summary
Judgment. Analyze arguments made in the Motion and Plaintiffs' Response thereto and completion of the same. Email to
Jacob, David, Ken and Steve regarding the draft Reply.
6.80
Brief telephone call with Ken regarding the Reply to Defendants' Motion for Summary Judgment and
0.10 likely future actions in the case.

9/2/20
9/3/20

AMF
AMF

$ 300
$ 300

0.30 Review incoming pleadings, Order Granting Motion to Seal and related pleadings.
0.50 Review and revise the Reply to Defendants' Motion for Summary Judgment in preparation for filing.

10/19/20

AMF

$ 300

0.20 Email discussion with David regarding status of the Ruling on our pending Motion for Summary Judgment.

11/4/20

AMF

$ 300

Email discussion with Ken regarding the status of the ruling on the pending Motion for Summary
0.20 Judgment. (Client Courtesy - No Charge).

3/2/21
3/3/21

AMF
AB

$ 300
$ 95

3/3/21

AB

$ 95

3/3/21

AMF

$ 300

3/4/21 AB
AMF
3/4/21
AMF
3/4/21

$ 95
$ 300
$ 300

3/9/21

AMF

$ 300

3/9/21

AMF

3/22/21

AMF

8/25/20
8/31/20

AMF
AMF

$ 300
$ 300

Entry reduced by 20%. Block billing.
$ 2,070.00
$ 330.00

1.10

$ 330.00

5.44

$1,632.00

$ 30.00

0.10

$ 30.00

$ 90.00
$ 150.00

0.30
0.50

$ 90.00
$ 150.00

Entry reduced by 20%. Block billing.
$ 2,040.00

$ 60.00

0.20

$ 60.00

No Charge

N/A

No Charge

1.00 Detailed review of the court's recent Order in determining future actions.
0.30 Draft Joint Stipulation to Continue Trial-Setting conference.
Telephone call to the JA regarding the need to have the March 18, 2021 Trial Setting Conference
0.20 continued.

$ 300.00
$ 28.50

1.00
0.30

$ 300.00
$ 28.50

0.20

$ 19.00

$ 60.00

0.00

$ 0.00

$ 28.50
$ 60.00
$ 60.00

0.30
0.20
0.20

$ 28.50
$ 60.00
$ 60.00

$ 330.00

1.10

$ 330.00

$ 300

0.20 Email discussion with opposing counsel regarding upcoming hearing.
Forward draft of Joint Stipulation to Continue the Trial Setting Conference to AMF for review. Review AMF's changes.
Send draft to opposing counsel for review and permission to sign. Finalize Joint Stipulation to Continue for filing. Email to
court's JA regarding the filing of the Joing Stipulation to
Continue.
0.30
0.20 Review and revise draft Stipulation to Continue and Order granting the same.
0.20 Review incoming Order granting Motion to Continue Trial Setting Conference.
Review of the District Court's recent general orders pertaining to trials. Review of pleadings in preparation of detailed
email to clients regarding ruling on the Motion for Summary Judgment and future
actions.
1.10
Telephone call with Ken Hardesty regarding issues related to the recent rulings and the upcoming trial
0.20 setting conference.

$ 60.00

0.20

$ 60.00

$ 300

Review incoming pleadings, Plaintiff's Motion to Appear Telephonically and signed Order granting the
0.20 Plaintiff's Motion to Appear Telephonically.

$ 60.00

0.20

$ 60.00

$ 19.00
Entry deducted. Clerical.

3/24/21
AMF
3/25/21 JCS

$ 300
$ 300

3/25/21

AMF

$ 300

3/25/21

AMF

$ 300

3/25/21

AMF

$ 300

3/25/21
3/26/21

AMF
AMF

$ 300
$ 300

4/5/21

AMF

4/5/21

AMF

4/6/21

AMF

$ 300

Review incoming pleadings, Plaintiff's Motion for Certification and Plaintiff's Proposed Order regarding his Motion for
Certification. Review of the case law cited in the Plaintiff's Motion. Review of case law in
preparation of a response to the Plaintiff's Motion for Certification.

4.80
0.30 Review email from AMF to client; meet with AMF re: 3 day jury trial.
Review of applicable case law regarding copyright infringement in preparation for upcoming hearing.
2.80 Determination of remaining issues to be decided in the case and work to be performed.

$1,152.00

Entry reduced by 20%. Block billing.

0.30
2.24

$ 90.00
$672.00

$ 1,440.00
$ 90.00
$ 840.00
$ 660.00

2.20

$ 660.00

$ 150.00

0.50

$ 150.00

$ 510.00
$ 660.00

1.70
2.20

$ 510.00
$ 660.00

$ 300

1.70 Continued preparation of the response to the Plaintiff's Motion for Certification.
2.20 Completion of the Defendants' Response to the Plaintiff's Motion for Certification.
Review incoming pleadings, Plaintiff's Reply to Response to the Motion to Amend the Court's Recent
0.40 Ruling.

$ 120.00

0.40

$ 120.00

$ 300

Review of applicable case law rules and statutes in preparation of the Defendants' Motion regarding the
2.10 license agreement.

$ 630.00

2.10

$ 630.00

$ 90.00

0.30
5.44

$ 90.00
$1,632.00

$ 720.00

2.40

$ 720.00

$ 90.00

0.30

$ 90.00

5.84

$1,752.00

1.70

$ 510.00

$ 210.00

0.70

$ 210.00

$ 90.00

0.30

$ 90.00

$ 720.00

2.40

$ 720.00

$ 90.00

0.30

$ 90.00

4/6/21

AMF

$ 300

4/8/21

AMF

$ 300

4/13/21

AMF

$ 300

Review incoming Order denying Plaintiff's Motion to Amend the Court's Order to permit interlocutory
0.30 appeal.
Continued preparation for trial. Review of the court's form for the Joint Proposed Final Pre Trial Order. Determination of
information for the Defendants' portion to be completed. Identification of potential exhibits to be utilized at the trial.
Designation of portions of the deposition transcripts of the Plaintiff, Steve Wozniak and Ken Hardesty that may be used at
trial. Identification of potential witnesses to be called at trial. Commence preparation of the legal issues, contested legal
issues and facts. Commence
preparation of the potential stipulated uncontested facts and law.

4/14/21

AMF

$ 300

4/15/21

AMF

$ 300

7.30
Completed the draft of the Motion in Limine number one regarding Plaintiff's damage calculation. Email
1.70 to opposing counsel regarding Motions in Limine and need to discuss other trial related issues.

$ 300

Determination of additional Motions in Limine to be filed pertaining to SCI and WOZ U Education
0.70 Holdings, LLC. Email to clients regarding potential witnesses for the upcoming trial.

AMF

3.84

2.20 Final preparation for and attendance at pretrial conference.
Review incoming Order regarding final pretrial conference and jury trial. Email to clients regarding the
0.50 same.

0.30 Email discussion with Jacob and David regarding the upcoming trial and issues related thereto.
Continued preparation of Motion in Limine number one regarding the Plaintiff's claimed damages. Review of applicable
rules and statutes in preparation of the same. Commence draft of Motion in Limine number one regarding the exclusion of
Plaintiff's claim for damages under Rule 37. Review of documents disclosed in the litigation to determine potential
exhibits to be used at trial. Continued preparation of Motion in Limine number 2 regarding the license agreement.
Commence preparation of proposed Jury
Instructions.
6.80
Detailed review of the deposition transcript from the deposition of the Plaintiff in determining portions to
2.40 be utilized at the upcoming trial as well as issues to be addressed in the Motions in Limine.

4/15/21

Entry reduced by 20%. Block billing.

Entry reduced by 20%. Block billing.

$ 2,040.00

Entry reduced by 20%. Block billing.

$ 2,190.00
$ 510.00

4/15/21 JCS

$ 300

4/16/21

AMF

$ 300

4/21/21

AMF

$ 300

0.30 Motion in Limine strategy meeting with AMF re: WOZ Holdings and SCI.
Preparation for and participation in meet and confer with opposing counsel regarding potential Motions in Limine to be
filed. Review of case law referenced by opposing counsel during discussion. Commence preparation of Motion in Limine
No. 2 regarding claims against SCI and WOZU Education Holdings for
contributory and vicarious liability on the infringement claim.
2.40
Email discussion with opposing counsel regarding Plaintiff's failure to disclose damage calculation. Review
0.30 of documents received from the Plaintiff regarding the same.

4/26/21

AMF

$ 300

Email discussion with opposing counsel regarding issues related to the Defendants' Proposed Motion in
0.40 Limine No. 1. Review of the scheduling Order in responding to comments raised by opposing counsel.

$ 120.00

0.40

$ 120.00

4/26/21

AMF

$ 300

Continued discussion with opposing counsel regarding the difference between a settlement demand and
0.20 a damage calculation under Rule 26.

$ 60.00

0.20

$ 60.00

$ 300

Review, revise and finalize draft Motion in Limine No. 1 regarding Plaintiff's damage claim. Preparation of
1.70 draft Order granting the same.

$ 510.00

1.70

$ 510.00

4.10

$1,230.00

No Charge

N/A

No Charge

$ 960.00

3.20

$ 960.00

4/27/21

4/27/21

AMF

AMF

4/28/21 AB
5/3/21

AMF

$ 300

Review of case law in preparation of Defendants' Motion in Limine No. 2 regarding contributory and vicarious copyright
infringement. Preparation of additions to Defendants' Motion in Limine No. 2 regarding copyright infringement and
finalize the same. Preparation of draft Order granting Defendants'
Motion in Limine No. 2.

$ 95

4.10
Finalize and file Defendants' Motion in Limine No. 2. Email the same to the Court's JA and opposing
0.20 counsel.(No Charge - Client Courtesy).

$ 300

Review of the Plaintiff's draft of the Final Joint Pre-Trial Order. Preparation of the Defendants' portions of
3.20 the Final Joint Pre-Trial Order. Email to clients regarding issues related thereto.

$ 1,230.00

Preparation for and participation in telephone conference with Jacob and David regarding the potential
witnesses and exhibits to be used at trial and issues related thereto. Telephone call with Ken Hardesty regarding witnesses
and issues of the upcoming trial. Continued preparation of the Defendants' revisions to the draft Joint Pre-Trial Statement.
Preparation of Defendants' revisions to the draft Joint Jury Instructions. Email to opposing counsel regarding witnesses's
and issues related to the Joint Pre-Trail Statement.
5/6/21

AMF

$ 300

5/7/21

AMF

$ 300

5/10/21

AMF
AMF
AMF

$ 300

Entry reduced by 20%. Block billing.

3.12

$936.00

$ 60.00

0

$0.00

No Charge

N/A

No Charge

$ 60.00

0.20

$ 60.00

3.00

$900.00

$ 150.00

0.50

$ 150.00

$ 240.00

0.80

$ 240.00

$ 360.00

1.20

$ 360.00

$ 120.00

0.40

$ 120.00

AMF
AMF

5/17/21

AB

$ 95

5/17/21

AMF

$ 300

Review incoming pleadings, Minute Entry regarding additional telephone conference scheduling by the
0.20 court.

$ 300

$2,184.00

$ 2,730.00

5/17/21

$ 300
$ 300
$ 300

7.28

9.10
Preparation of final revisions, changes and additions to the final Joint Pre-Trial Order and Joint Proposed
3.90 Jury Instructions. Email to opposing counsel regarding the same.
0.20 Email discussion with opposing counsel and the court's clerk regarding final pre-trial conference.
0.20 Review incoming Minute Entry regarding upcoming pre-trial conference.
0.20 Review incoming pleadings, Order regarding Pro Hav Vice Motion filed by counsel for the Plaintiff.
2.90 Preparation of trial pleadings. Draft Joint Proposed Voir Dire Questions.
0.20 Email discussion with the court's deputy clerk regarding juror questionnaires
Email to process server regarding obtaining flash drive regarding juror questionnaires. Review incoming
0.20 email from process server regarding the same. (No Charge - Client Courtesy).

5/10/21
5/14/21
5/17/21

Entry reduced by 20%. Block billing.

Continued preparation of the Defendants' proposed Jury Instructions, Defendants' Verdict Form, Joint
Statement of the case to be read to the jury and Voir Dire Questions. Email to opposing counsel regarding status of his
response to Defendants' changes to the draft Pre-Trial.

5/17/21

AMF

$ 300

5/19/21

AMF

$ 300

3.00
Review incoming pleadings from opposing counsel, Plaintiff's Proposed Joint Statement to be read to the
0.50 Jury. Review and revise Plaintiff's Joint Statement. Email to opposing counsel regarding the same.

Review incoming pleadings, Plaintiff's draft of Voir Dire Questions. Review, revise and draft the Joint draft
0.80 Voir Dire Questions to be asked of the jury. Email to opposing counsel regarding the same.

$ 1,170.00

Entry deducted. Clerical.

$ 60.00

Entry deducted. Clerical.

0

$0.00

0.20
0.20
2.90

$ 60.00
$ 60.00
$ 870.00

$ 60.00
$ 60.00
$ 870.00

$ 900.00

5/19/21

AMF

$ 300

5/19/21

AMF

$ 300

5/19/21

AMF

$ 300

1.20 Completion of Defendants' Proposed Form of Verdict.
Email discussion with opposing counsel regarding revised Joint Statement. Review of revised Joint
0.40 Statement. Email to opposing counsel regarding the same and one additional change thereto.

$ 60.00

0.20

$ 60.00

$ 120.00

0.40

$ 120.00

5/19/21

AMF

$ 300

Email discussion with opposing counsel regarding Plaintiff's exhibit 16 and the untimely disclosure
0.20 thereof.

5/19/21

AMF

$ 300

Review incoming email from opposing counsel regarding revisions to the proposed Voire Dire Questions.
0.40 Review and revise Voire Dire Questions. Email to opposing counsel regarding two remaining issues.

5/19/21
5/19/21

AMF
AMF

$ 300
$ 300

5/20/21

AMF

$ 300

5/20/21

AMF

$ 300

Continued review of Plaintiff's changes to the final pretrial Order. Review of Plaintiff's changes to the
proposed Jury Instructions. Email discussion with opposing counsel regarding the same. Review of issues regarding
upcoming jury selection in preparation for the final pretrial conference.

2.60
0.50 Continued discussion with opposing counsel regarding proposed Jury Instructions and changes thereto.
Review incoming documents, Subpoena directed to Ken Hardesty and Subpoena directed to Steve
0.30 Wozniak. Email to Ken Hardesty regarding the same.

2.40

Commence review of trial exhibits in determining arguments to be made during the upcoming conference with the court.
Preparation for Oral Argument on Defendants' Motion in Limine Number 1. Review of
case law cited therein.
Final preparation for the final pretrial conference and oral argument on Defendants' Motion in Limine
Number 1 and Motion in Limine Number 2. Discussion with the court regarding issues related to trial. Review incoming
Minute Entry regarding final pretrial confereence.

5/21/21
5/21/21
5/21/21

AMF
AMF
AMF

$ 300
$ 300
$ 300

5/24/21

AMF

$ 300

5/24/21

AMF

$ 300

5.70
0.30 Telephone call with Ken Hardesty regarding issues related to the upcoming trial.
0.40 Review of Jury Questionnaires. Email to opposing counsel regarding the same.
0.20 Email discussion with Steve Wozniak regarding acceptance of service of trial Subpoena.
Email discussion with opposing counsel and the court's clerk regarding the Jury Questionnaires and the
0.30 upcoming telephone conference to discuss the same.

5/24/21

AMF

$ 300

Continued email discussion with opposing counsel and the court's clerk regarding the 10am hearing.
0.30 Review incoming Minute Entry regarding the court vacating the 10am hearing.

5/24/21
5/24/21

AMF
AMF

$ 300
$ 300

5/25/21
5/25/21

AMF
AMF

$ 300
$ 300

5/25/21

AMF

$ 300

3.80 Preparation of initial draft of Defendants' Opening Statement to be used at trial.
1.40 Commence preparation of the draft Rule 50 Motion to be raised at trial.
Continued preparation of the Defendants' Rule 50 Motion. Determination of best timing to raise the
issues contained therein. Review of additional case law in support of the arguments to be made in Defendants' Rule 50
Motion.
1.50
2.10 Preparation of direct examination questions for Steve Wozniak, Ken Hardesty and Jacob Mayhew.
Communications with clients regarding trial exhibits and deposition transcripts. Email to Ken and Jacob regarding issues
related to procedural issues for the upcoming trial. Telephone call with Ken regarding
issues related to trial.
0.90

Entry reduced by 20%. Block billing.

2.08

$624.00

$ 780.00
$ 150.00

0.50

$ 150.00

$ 90.00

0.30

$ 90.00

$ 720.00

2.40

$ 720.00

$ 1,710.00
$ 90.00
$ 120.00

5.70
0.30
0.40

$ 1,710.00
$ 90.00
$ 120.00

0.20
0

$ 60.00
$0.00

$ 60.00
$ 90.00

Entry deducted. Clerical.

0

$0.00

$ 1,140.00
$ 420.00

3.80
1.40

$ 1,140.00
$ 420.00

$ 450.00
$ 630.00

1.50
2.10

$ 450.00
$ 630.00

$ 270.00

0.90

$ 270.00

$ 90.00

Entry deducted. Clerical.

5/25/21

AMF

$ 300

Continued preparation of direct examination questions for Ken Hardesty, Steve Wozniak and Jacob
3.10 Mayhew.

5/25/21 JCS
5/26/21 AB

$ 300
$ 95

5/26/21

$ 300

1.40 Review and analysis of Trial Exhibits.
1.00 Prepare exhibits for June 7, 2021 Jury Trial. Prepare courtesy copy binder for the judge.
Review incoming pleadings, Order regarding Defendants' Motion in Limine Number One and Two.
0.50 Detailed email to clients regarding the same.

AMF

$ 930.00

3.10

$ 930.00

$ 420.00
$ 95.00

1.40
1.00

$ 420.00
$ 95.00

$ 150.00

0.50

$ 150.00

5/26/21

AMF

$ 300

Email discussion with opposing counsel regarding witness and exhibit list and proposed schedule for
0.20 witnesses.

$ 60.00

0.20

$ 60.00

5/26/21

AMF

$ 300

0.20 Email discussion with opposing counsel regarding issues related to the scheduling of trial witnesses.

$ 60.00

0.20

$60.00

5/26/21

AMF

$ 300

Telephone call with Jacob regarding issues related to matters that will be presented at trial and recent
0.40 rulings.

$ 120.00

0.40

$ 120.00

1.70
3.28

$ 510.00
$984.00

5/26/21

AMF

$ 300

5/26/21

AMF

$ 300

5/27/21

AMF

$ 300

5/27/21

AMF

$ 300

5/27/21

AMF
AMF

$ 300

5/27/21

$ 300

5/28/21

AMF

$ 300

5/28/21

AMF
AMF
AMF

$ 300

6/1/21
6/1/21
6/1/21
6/1/21
6/1/21
6/1/21

AMF
AMF
AMF
AMF

$ 300
$ 300
$ 300

Review of the court's order regarding exhibits to confirm compliance with the same. Determination of
additional actions needed to comply with the court's pretrial Order with regard to exhibits and witnesses. Preparation of
the exhibit and witness list required by the court.

1.70
Commence preparation of power point presentation for use in opening argument. Obtain copies of
4.10 documents to be utilized with the opening statement.

0.20 Email discussion with Ken regarding photograph of WOZ to be used as an exhibit.
Completed initial draft of the power point to be utilized during the opening statement at the upcoming
2.50 trial. Email to clients regarding the same.
0.30 Email discussion and telephone call with Matthew Hawes regarding issues related to the upcoming trial.
0.20 Email discussion with Jacob regarding the power point presentation. (No Charge-Client Courtesy)
Email discussion with Ken Hardesty regarding trial preparation and requested changes to the opening
0.20 statement.
0.20 Email discussion with Jacob regarding issues related to the opening statement and changes thereto.
0.20 Email discussion with Ken regarding witness preparation.
0.30 Review incoming pleadings, Plaintiff's Exhibit List and Plaintiff's Notice to Court Reporter.

$ 510.00
$ 1,230.00

Entry reduced by 20%. Block billing.

$ 60.00

0.20

$ 60.00

$ 750.00

2.50

$ 750.00

$ 90.00
No Charge

0.30

$ 90.00
No Charge

N/A

$ 60.00

0.20

$ 60.00

$ 60.00

0.20

$ 60.00

$ 60.00
$ 90.00
$ 60.00

0.20
0.30
0.20

$ 60.00
$ 90.00
$ 60.00

$ 300
$ 300

0.20 Email discussion with Ken regarding the charter oak document.
0.70 Preparation of the Defendants' Notice to Court Reporter. Email to court reporter regarding the same.
2.90 Completed draft of direct examination of Steve Wozniak. Email to Ken regarding the same.

$ 210.00
$ 870.00

0.70
2.90

$ 210.00
$ 870.00

$ 300

Telephone call with Ken Hardesty regarding issues related to testimony to be given by Steve Wozniak and
0.30 Ken Hardesty at the trial.

$ 90.00

0.30

$ 90.00

6/1/21

AMF

$ 300

2.30 Preparation of direct examination questions for Ken Hardesty. Email to Ken Hardesty regarding the same.

$ 690.00

2.30

$ 690.00

6/1/21

AMF

$ 300

1.00 Meeting with Steve Wozniak to prepare for trial.
Preparation of direct examination of Matthew Hawes. Email to Matt regarding questions that will be
0.70 asked at trial.

$ 300.00

1.00

$ 300.00

$ 210.00

0.70

$ 210.00

2.20 Completed draft of direct examination of Jacob Mayhew. Email to Jacob regarding the same.
Completed outline for the cross examination of the Plaintiff. Review of trial exhibits and deposition
3.30 transcript in preparation of the same.

$ 660.00

2.20

$ 660.00

6/1/21

AMF

$ 300

6/2/21

AMF

$ 300

6/2/21

AMF

$ 300

6/2/21

AMF

$ 300

6/3/21

AMF

$ 300

6/3/21
6/3/21

AMF

$ 300
$ 300

AMF

0.20 Email discussion with Jacob regarding trial preparation. (No Charge-Client Courtesy)
Review incoming email from opposing counsel regarding trial schedule. Review and revise trial schedule.
0.40 Email to opposing counsel regarding the same.

$ 990.00

3.30

$ 990.00

No Charge

N/A

No Charge

$ 120.00

0.40

$ 120.00

0.30 Email discussion with opposing counsel regarding issues related to exhibits.
0.90 Preparation of detailed objections to Plaintiff's proposed trial exhibits.
Review incoming email from opposing counsel regarding exact copies of the Plaintiff's trial exhibits.
0.70 Review of the copies of Plaintiff's trial exhibits provided.

$ 90.00
$ 270.00

0.30
0.90

$ 90.00
$ 270.00

0.70

$ 210.00

$ 60.00

6/3/21

AMF

$ 300

6/3/21

$ 300

6/3/21
6/3/21
6/3/21

AMF
AMF
AMF
AMF

$ 300
$ 300
$ 300

0.20 Email discussion with the court's clerk regarding exhibits and technology issues.
1.40 Preparation for and participation in trial preparation with Jacob Mayhew.
0.30 Preparation of chart to be used during jury selection.
0.20 Email discussion with Matt Hawes regarding attendance at trial.

6/3/21

Complete preparation of notes to be utilized with the power point presentation for opening statements.
Practice delivering opening statement.

AMF

$ 300

3.80

6/4/21

AMF

$ 300

1.60

6/4/21

AMF

$ 300

Travel to and from court house to discuss issues related to exhibits, depositions, witnesses and check to
confirm technology was working correctly.
0.20 Review incoming Minute Entry regarding public access to the trial.
Review of the incoming email from the court's clerk regarding preliminary and mid trial instructions to be given by the
court. Review of the same in determining whether we will be making any objections thereto.

6/4/21

AMF

$ 300

0.90

$ 210.00

0

$0.00

$ 420.00
$ 90.00
$ 60.00

1.40
0.30
0.20

$ 420.00
$ 90.00
$ 60.00

$ 1,140.00

3.80

$ 1,140.00

$ 480.00

1.60

$ 480.00

0.00

$ 0.00

0.90

$ 270.00

$ 60.00

$ 270.00

Entry deducted. Clerical.

Entry deducted. Clerical.

6/4/21 JCS
AMF
6/6/21

$ 300

6/7/21

AMF

$ 300

6/7/21

AMF

$ 300

6/7/21
AMF
6/7/21 JCS

$ 300
$ 300

6/8/21

AMF

$ 300

6/8/21

AMF

$ 300

$ 300

3.60 Review and analysis of Trial exhibits and depositions; review emails from M. Hawes and AMF.
1.70 Preparation for and participation in trial preparation with Ken Hardesty.
Final preparation for, travel to and from and attendance at trial day one including oral argument, direct
12.10
and cross examination of Ken Hardesty and direct examination of Steve Wozniak.
0.30 Review incoming pleadings, Minute Entry regarding trial day one.
Continue review of legal issues regarding the Plaintiff's damage claim and potential argument regarding
statutory damages. Review of legal issues related to Plaintiff's efforts to admit a copy of the WOZU website.

$ 1,080.00

3.60

$ 510.00

1.70

$510.00

$ 3,630.00

12.10

$3,630.00

0.00

$0.00

2.10
13.40 Trial preparation; trial and post-trial
Preparation of the power point for the Defendants' closing argument. Review of the email from the
court's judicial assistant regarding proposed verdict form and final jury instructions. Preparation of arguments regarding
the same. Preparation of a proposed limiting instruction.
5.20
Preparation of a proposed limiting instruction. Email to the court and opposing counsel regarding the
0.40 same.

$ 630.00
$ 4,020.00

2.10
13.40

$630.00
$4,020.00

$ 1,560.00

5.20

$1,560.00

$ 120.00

0.40

$120.00

$ 90.00

Entry deducted. Clerical.

$1,080.00

Continued preparation for, travel to and from and participation in trial day two. Including direct examination and cross
examination of Steve Wozniak, the direct examination and cross examination of
the Plaintiff and the Defendants' Rule 50 Motion.
6/8/21
AMF
6/8/21 JCS

$ 300
$ 300

10.00
15.40 Trial preparation; trial and post-trial
Preparation, travel to and from and participate in day three of trial including further review of draft jury instructions and
verdict form. Discussion with the court regarding the same. Discussion of proposed limiting instruction. Further
preparation for and delivery of closing statement and jury verdict. Review
incoming pleadings related thereto.

$ 3,000.00
$ 4,620.00

10.00
15.40

$3,000.00
$4,620.00

6/9/21
AMF
6/9/21 JCS

$ 300
$ 300

$ 2,250.00
$ 3,120.00

7.50
10.40

$2,250.00
$3,120.00

$ 95

7.50
10.40 Trial preparation; trial and post-trial
Draft Notice of No Objection to Plaintiff's Motion to Continue on Dismissal Calendar. Forward to AMF for
0.20 review.

$ 19.00

0.20

$19.00

$ 300

Email discussion with Jacob regarding press release. Review and revise potential press release regarding
0.60 the outcome of the case.

6/10/21 AB
6/10/21

AMF

TOTAL HRS

516.40

TOTAL FEES

$ 180.00

0.60

$180.00

$ 152,070.00

480.18

$142,089.00

TOTAL REVISED FEES

$142,089.00