Corbacho Daudinot v. Puig Valdes et al

Filing 62

MEMORANDUM in Support re 52 Defendant's MOTION for Sanctions under Rule 37 Regarding Fees and Costs Pursuant to Court's Instructions at Hearing on 11/5/14 by Yasiel Puig Valdes, Maritza Valdes Gonzalez. (Attachments: # 1 Exhibit Exhibit A)(Andrews, Averil)

EXHIBIT A

Defendants’ Fees and Costs in Pursuing Motion for Rule 37 Sanctions
Date

Name

Hours

Amount

Description

9/12/2014

SRS

.8

$340.00 Review certificate of non-appearance
(plaintiff’s deposition). Research regarding
motion to strike plaintiff’s complaint for failure
to attend deposition.

9/12/2014

AKA

.8

$180.00 Research regarding motion for sanctions for
failing to appear for deposition.

9/15/2014

SRS

.3

$127.50 Research and draft memo to Plaintiff’s
counsel regarding Rule 37 motion and review
response to same.

9/29/2014

AKA

2.8

$630.00 Draft Rule 37 motion for sanctions for failure
to appear for deposition.

10/8/2014

SRS

1.4

$595.00 Revise motion for Rule 37 sanctions against
plaintiff.

10/9/2014

AKA

1.6

$360.00 Research cases for, prepare exhibits for, and
file the motion for Rule 37 sanctions.

10/15/2014

SRS

.2

$85.00 Review plaintiff’s response to motion for Rule
37 sanctions.

10/16/2014

AKA

.2

$45.00 Review plaintiff’s response to motion for Rule
37 sanctions.

10/20/2014

AKA

.7

$157.50 Draft defendants’ reply in support of the
motion for sanctions.

10/22/2014

AKA

2.7

$607.50 Draft defendants’ reply in support of the
motion for sanctions.

10/27/2014

SRS

1.1

$467.50 Revise defendants’ reply in support of the
motion for sanctions.

EXHIBIT A
10/27/2014

AKA

.8

11/5/2014

SRS

2.9

$1232.50 Prepare for and attend hearing on motion for
sanctions.

11/5/2014

AKA

2.3

$517.50 Research for and attend hearing on motion
for sanctions.

TOTAL

18.6

$180.00 Finalize and file reply memorandum in
support of the defendant’s motion for
sanctions.

$5,525.00