LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filing 211

AFFIDAVIT of Ralph A. Weber In Support of Fees and Costs Pursuant to Judge Mayeron's November 30, 2009 Order by Trek Bicycle Corporation. (Attachments: # 1 Certificate of Service)(Weber, Ralph)

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LeMond Cycling, Inc. v. Trek Bicycle Corporation Doc. 211 Case 0:08-cv-01010-RHK-JSM Document 211 Filed 12/11/09 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA LEMOND CYCLING, INC., Plaintiff, v. TREK BICYCLE CORPORATION, Defendant and Third-Party Plaintiff, v. GREG LEMOND, Third-Party Defendant. STATE OF WISCONSIN ) ) SS. MILWAUKEE COUNTY ) Ralph A. Weber, being first duly sworn under oath, deposes and states as follows: 1. I am an adult resident of the State of Wisconsin and am one of the attorneys AFFIDAVIT OF RALPH A. WEBER IN SUPPORT OF FEES AND COSTS PURSUANT TO JUDGE MAYERON'S NOVEMBER 30, 2009 ORDER Case No. 08-CV-1010 (RHK-JSM) representing Trek Bicycle Corporation in this action. 2. I make this affidavit in accordance with Judge Mayeron's November 30, 2009 order granting Trek's request for attorney's fees and costs incurred in bringing and attending its July 14, 2009 motion to compel. 3. Gass Weber Mullins LLC, counsel for Trek Bicycle Corporation, incurred the following attorney's fees and costs related to the July 14, 2009 motion to compel: Dockets.Justia.com Case 0:08-cv-01010-RHK-JSM Document 211 Filed 12/11/09 Page 2 of 4 Date 06/24/09 Timekeeper KSS RAW Status Associate Member Associate Associate Associate Associate Paralegal Associate Associate Description Research re deficiencies in LeMond's discovery responses and draft memos re same. Analyze LeMond's discovery responses and consider grounds for motion to compel. Review and discuss draft letter to Attorney Rahne re discovery responses. Revise letter to Attorney Rahne re discovery responses. Review research and revise letter to Attorney Rahne re discovery responses. Revise letter to Attorney Rahne re discovery responses. Review draft letter to Attorney Rahne re discovery responses. Review and discuss letters exchanged between parties re LeMond's discovery responses. Prepare for and attend meet and confer conference call; draft letter to Attorney Robbins and Attorney Madel re meet and confer. Draft motion to compel; research re same. Revise motion to compel; research re same; correspondence with Attorney Robbins re LeMond responses. Revise motion to compel; research re same; correspond with Ralph Weber and office staff re revisions to motion to compel and exhibits. Review and revise motion to compel. Assist with finalizing motion to compel; draft supporting documents and compile exhibits. Revise, finalize and file motion to compel. Organize materials for motion to compel filing. Confer re response to motion to compel and reply brief. Draft reply brief; research re same. Hours 3.7 1.5 0.2 0.7 1.4 0.2 0.1 0.5 1.6 Fee 925.00 525.00 50.00 175.00 350.00 50.00 12.50 125.00 400.00 06/25/09 KSS CPD 06/26/09 06/29/09 CPD CPD ESZ 07/01/09 07/02/09 KSS KSS 07/08/09 07/09/09 07/10/09 KSS KSS KSS Associate Associate Associate 3.8 2.0 1.1 950.00 500.00 275.00 07/13/09 07/14/09 RAW ESZ KSS ESZ Member Paralegal Associate Paralegal Member Associate 0.7 3.9 0.9 1.4 0.4 1.8 245.00 487.50 225.00 175.00 140.00 450.00 07/20/09 07/23/09 RAW KSS 2 Case 0:08-cv-01010-RHK-JSM Document 211 Filed 12/11/09 Page 3 of 4 Date 07/24/09 07/26/09 07/27/09 07/29/09 06/24/09 07/08/09 07/09/09 07/10/09 07/12/09 07/13/09 07/14/09 07/29/09 Timekeeper KSS ESZ KSS KSS RAW RAW Status Associate Paralegal Associate Associate Member Member Description Draft reply brief; research re same. Review reply brief and emails re same. Revise reply brief; research re same. Revise, finalize and file reply brief. Finalize reply brief. Travel to and from Minneapolis and participate in hearing on motion to compel. Westlaw research charges. Westlaw research charges. Westlaw research charges. Westlaw research charges. Westlaw research charges. Westlaw research charges. Westlaw research charges. Travel expenses to attend hearing. Total fees and costs incurred by Gass Weber Mullins: Hours 1.5 0.3 0.9 1.5 0.7 8.5 Fee 375.00 37.50 225.00 375.00 245.00 2975.00 623.92 70.65 17.12 49.68 15.84 59.93 34.49 270.81 39.3 Total $4130.00 575.00 4875.00 712.50 $ 11,434.94 Timekeeper Ralph A. Weber Christopher P. Dombrowicki Kristal S. Stippich Emily S. Zastrow Title Member Associate Associate Paralegal Hours 11.8 2.3 19.5 5.7 Rate $350.00 250.00 250.00 125.00 4. Halleland Lewis Nilan & Johnson PA, local counsel for Trek Bicycle Corporation, incurred the following attorney's fees and costs related to the July 14, 2009 motion to compel: Date 07/09/09 07/13/09 07/14/09 07/23/09 07/24/09 Timekeeper BJR BJR BJR BJR BJR Status Associate Associate Associate Associate Associate Description Confer with Kristal Stippich re filing motion to compel. Analyze motion to compel and correspond with Kristal Stippich re filing. Assist with filing motion to compel; ensure compliance with local rules. Confer with Kristal Stippich re filing reply brief. Analyze reply brief. Hours 0.2 0.6 2.0 0.1 0.6 Fee 45.00 135.00 450.00 22.50 135.00 3 Case 0:08-cv-01010-RHK-JSM Document 211 Filed 12/11/09 Page 4 of 4 Date 07/27/09 07/28/09 07/29/09 Timekeeper BJR ETS ETS Status Associate Shareholder Shareholder Description Assist with filing reply brief; ensure compliance with local rules. Prepare for hearing. Prepare for and attend hearing on motion to compel. Total fees and costs incurred by Halleland Lewis: Hours 2.2 0.5 1.0 7.2 Total $585.00 1282.50 Fee 495.00 195.00 390.00 $ 1,867.50 Timekeeper Erik T. Salveson Benjamin Rolf Title Shareholder Associate Hours 1.5 5.7 Rate $390.00 225.00 I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed on December 11, 2009. s/Ralph A. Weber Ralph A. Weber Subscribed to and sworn before me this 11th day of December, 2009. s/Joan M. Latawiec Joan M. Latawiec Notary Public, State of Wisconsin My Commission Expires: July 21, 2013 4

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