Capitol Records, LLC v. Redigi Inc.

Filing 329

DECLARATION of Richard S. Mandel in Support re: 319 MOTION for Attorney Fees .. Document filed by Capitol Christian Music Group, Inc., Capitol Records, LLC, Virgin Records IR Holdings, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B).(Mandel, Richard)

EXHIBIT A

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
CITY NATIONAL BANK
400 Park Ave, 21st Fl., New York, NY 10022
Acct No.: 665088073
ABA No.: 026013958; Swift Code: CINAUS6L

August 6, 2012
Invoice# 190241 RSM
Our file# 29503 0003
Billing through 07/31/2012

EMI Music
150 Fifth Avenue, 11th Floor
New York, NY 10011
Attn: Alasdair J. McMullan, Esq.

ReDigi
Balance forward as of invoice dated

July 5, 2012

Payments received since last invoice

$163,705.65
26,777.46
----------------

Accounts receivable balance carried forward
PROFESSIONAL SERVICES
07/02/2012 RSM

$136,928.19
Hours
2.00

1,000.00

07/03/2012

RSM

1.00

500.00

07/05/2012

RSM

4.00

2,000.00

29503

EMI Music

07/06/2012

RSM

07/07/2012
07/09/2012

RSM
RSM

07/10/2012

RSM

07/11/2012

RSM

07/12/2012

RSM

Invoice# 190241

Reviewed cite check to reargument opposition brief;
revised, finalized and executed reargument opposition brief;
arranging for filing of same; drafted letter to Court re
enclosing courtesy copy of opposition brief on reargument;
email to opposing counsel re same; conferences with J.
King re settlement, summary judgment; begin drafting Rule
56.1 statement; outlining and begin drafting summary
judgment brief; conference with J. King and S. Ceresia re
research issues for brief
Drafting summary judgment brief
Conferences with J. King re summary judgment motion;
conference with S. Ceresia re legal research on permanent
injunctions, judicial admissions; legal research re follow up
on Usenet volitional conduct analysis for direct
infringement; drafting summary judgment brief; letter to
opposing counsel enclosing original Ossenmacher
deposition transcript
Conferences with J. King re miscellaneous summary
judgment issues; reviewed T. Kjellberg draft section on
reproduction right; revising and incorporating same in draft
brief; drafting and revising summary judgment brief;
conferences with S. Ceresia re legal research for brief and
reviewing same; reviewing legal research on reproduction
right
Conferences with J. King re issues concerning 56.1
statement and brief; conference with S. Ceresia re legal
research on judicial admissions and reviewing same;
continued drafting and revising summary judgment brief;
conference call with J. King and D. Jacobson re possible
use as expert; conference call with A. McMullan and J.
King re same; reviewing ReDigi reply brief in support of
motion for reconsideration
Conferences with J. King re settlement, summary judgment
issues; conference call with G. Adelman and J. King re
confidentiality issues; conference call with and emails to
and from B. Cohen and C. Hall re analyzing information on
recordings purchased by users other than C. Hall; revising
Hall declaration re same; conference with B. Crawford re
legal research for letter to Court on filing motions under
seal and reviewing same; reviewing Judge rules and
protective order re same; drafted and revised joint letter to
Court requesting permission to file summary judgment
motions under seal subject to subsequent submissions
supporting confidentiality; continued drafting and revising

Page 2

3.50

1,750.00

1.00
4.40

500.00
2,200.00

5.80

2,900.00

6.00

3,000.00

5.50

2,750.00

29503

EMI Music

07/13/2012

RSM

07/15/2012

RSM

07/16/2012

Invoice# 190241

summary judgment brief
Conference with J. King re reviewing excerpts from
Ossenmacher deposition to be incorporated into 56.1
statement; continued drafting and revising summary
judgment brief; reviewing legal research re permanent
injunctions; conferences with S. Ceresia re legal research
for brief; reviewed Judge Sullivan order approving
confidentiality procedures; email to and telephone
conference with client re same; telephone conference with
and emails to and from B. Cohen re proof of other
purchases of Capitol recordings on ReDigi aside from C.
Hall; reviewing documentation re same
Reviewing and revising 56.1 statement; reviewing and
revising brief; revising McMullan and Hall declarations;
conferences with J. King re summary judgment papers;
drafting potential brief point on permanent injunction and
research re same; email to client enclosing draft summary
judgment papers

Page 3

5.70

2,850.00

6.60

3,300.00

RSM

4.60

2,300.00

07/17/2012

RSM

3.50

1,750.00

07/18/2012

RSM

3.80

1,900.00

Reviewing excerpts from Rudolph and Ossemacher
depositions re cross-referencing deposition exhibits to
summary judgment exhibits; conference call with A.
McMullan and J. King re revisions to 56.1 statement;
reviewing A. McMullan comments re same; revising 56.1
statement and conferences with J. King re same; telephone
conferences with and emails to and from B. Hall re
summary judgment papers; revising brief citations to 56.1
statement; reviewing cite check of brief and conference
with S. Ceresia re same; revising summary judgment brief

29503

EMI Music

Invoice# 190241

Page 4

per cite check; conferences with N. Chinda re issues
concerning assembly of summary judgment papers;
conference with J. King re potential amendment to name
individual defendants and reviewed email re same

07/19/2012

RSM

4.00

2,000.00

07/20/2012

RSM

3.80

1,900.00

07/23/2012

RSM

3.00

1,500.00

07/24/2012

RSM

2.50

1,250.00

07/25/2012

RSM

3.80

1,900.00

07/26/2012

RSM

3.30

1,650.00

07/27/2012

RSM

4.60

2,300.00

Telephone conference with B. Cohen re revisions to brief;
reviewing, revising and finalizing summary judgment brief;
drafted letter to Court enclosing courtesy copies of
summary judgment papers; reviewing and finalizing
summary judgment papers and arranging for service and
filing of same; conferences with M. Noble and N. Chinda re
same; brief review of ReDigi summary judgment filing;
conferences with J. King, emails to and from client re same;
conference with B. Crawford re research for motion in
support of continued sealing of Capitol confidential
information

Telephone conference with B. Cohen re revisions to sealing
brief; revised and finalized same and supporting papers;

29503

EMI Music

07/30/2012

RSM

07/31/2012

RSM

Invoice# 190241

letter to Judge Sullivan enclosing courtesy copies of sealing
papers; arranging for filing of sealing papers; reviewed
ReDigi sealing papers; email to client re same; reviewed
Public Knowledge request to file amicus brief; reviewed
and revised draft response to same and conferences with J.
King, emails to and from client re same; finalized and sent
response to Public Knowledge pre-motion letter; drafting
response to ReDigi 56.1 statement; conferences with J.
King re same, other summary judgment issues
Conference call with D. Jacobson and J. King re reviewing
technical issues and possible declaration in opposition to
summary judgment motion; continued drafting response to
Rule 56.1 statement; conferences with J. King re summary
judgment opposition brief and related issues
Completed first draft of response to 56.1 statement;
telephone conference with and email to A. McMullan re
issues concerning Apple agreement references in same;
conference call with J. King and D. Jacobson re reviewing
possible declaration; reviewed draft outline prepared by D.
Jacobson; emails to and from client and conference with J.
King re same; drafted Jacobson declaration; drafted Mandel
declaration; reviewing and revising draft brief points and
conferences with J. King re same; conferences with B.
Crawford and J. King re legal research on advisory opinion
point
Mandel, Richard

Page 5

5.80

2,900.00

6.50

3,250.00

94.70

47,350.00

07/03/2012

JZK

2.50

1,187.50

07/03/2012

JZK

1.80

855.00

07/05/2012

JZK

4.00

1,900.00

07/06/2012

JZK

4.40

2,090.00

07/09/2012

JZK

4.00

1,900.00

07/10/2012

JZK

8.50

4,037.50

07/11/2012

JZK

9.50

4,512.50

07/12/2012

JZK

5.00

2,375.00

29503

EMI Music

Invoice# 190241

Page 6

6.00

2,850.00

2.00
4.00
4.50

950.00
1,900.00
2,137.50

JZK

1.00

475.00

07/18/2012

JZK

3.70

1,757.50

07/19/2012

JZK

4.00

1,900.00

07/20/2012

JZK

0.50

237.50

07/24/2012

JZK

2.50

1,187.50

07/25/2012

JZK

4.00

1,900.00

07/26/2012

JZK

3.00

1,425.00

07/26/2012

JZK

9.20

4,370.00

07/27/2012

JZK

6.30

2,992.50

07/13/2012

JZK

07/14/2012
07/15/2012
07/16/2012

JZK
JZK
JZK

07/17/2012

Revise and edit summary judgment brief.
Continue revising and editing summary judgment brief.
Revising and editing summary judgment brief; meet with R.
Mandel re same.

Revising 56.1 and summary judgment brief; phone
conference with opposing counsel; meet with R. Mandel re
finalizing papers.

Review order denying Public Knowledge amicus
participation; phone conference with D. Jacobson, software
expert, and review draft declaration; meet with R. Mandel
re response to ReDigi 56.1 statement and opposition brief;
draft various sections of opposition brief; review Jacobson
draft.
Review of Apple agreement and EULA and emails re same;
review Public Knowledge pre-motion letter and draft
response and arrange for filing; begin outlining response to
summary judgment motion.

29503
07/30/2012

EMI Music
JZK

07/03/2012
07/05/2012

TK
TK

07/06/2012
07/10/2012
07/13/2012
07/19/2012

TK
TK
TK
TK

06/08/2012
07/09/2012

SPC
SPC

07/10/2012

SPC

07/16/2012

SPC

07/18/2012

SPC

Invoice# 190241

Page 7

Drafting summary judgment opposition brief; phone
conference with D. Jacobson, software expert; conference
with R. Mandel re expert issues and opposition brief.
King, Jonathan Z.

7.30

3,467.50

97.70

46,407.50

2.80
3.20

1,134.00
1,296.00

3.20
3.30
1.00
0.70
14.20

1,296.00
1,336.50
405.00
283.50
5,751.00

0.50
1.10

130.00
286.00

0.90

234.00

0.30

78.00

2.40

624.00

5.20

1,352.00

Research data migration issue
Research fixation/digital first sale issue– review DMCA
Section 104 Report, deposition transcripts; confer with
JZK
Confer with JZK; research “data migration”
Draft reproduction segment for SJ brief
Research first sale doctrine case law in 2d Circuit
Case law research for ReDigi
Kjellberg, Thomas
Conduct research regarding judicial admissions and
regarding permanent injunctions and irreparable harm;
compile relevant caselaw and review.
Conduct research regarding ignorance of the law and
contributory infringement; collect relevant caselaw and
review.
Conduct research regarding judicial admissions and mixed
question of fact/law.
Citecheck summary judgment brief; send revisions to R.
Mandel.
Ceresia, Scott P.

07/12/2012

BAC

1.00

260.00

07/20/2012

BAC

0.20

52.00

07/23/2012

BAC

1.50

390.00

07/24/2012

BAC

2.50

650.00

07/25/2012

BAC

3.50

910.00

07/26/2012
07/27/2012

BAC
BAC

0.20
0.10

52.00
26.00

07/31/2012

BAC

4.00

1,040.00

13.00

3,380.00

0.30

63.00

Crawford, Bridget A.
07/06/2012

JMN

29503

EMI Music

Invoice# 190241

Page 8

07/20/2012

JMN

2.50

525.00

07/27/2012

JMN

0.60

126.00

3.40

714.00

Noble, J. Martin (Managing Clerk)
07/17/2012

NAC

4.20

903.00

07/18/2012

NAC

4.50

967.50

07/19/2012

NAC

5.00

1,075.00

07/20/2012

NAC

5.40

1,161.00

07/23/2012

NAC

2.00

430.00

07/27/2012

NAC

2.90

623.50

24.00

5,160.00

252.20

$110,114.50

Chinda, Nart-Anong (Paralegal)
Current Services

EXPENSES

29503

EMI Music

Invoice# 190241

Current Expenses

Billing Summary
Total professional services

$110,114.50

Total expenses incurred
Total of new charges for this invoice

--------------$115,800.20

Plus net balance forward

$136,928.19

---------------Total balance now due

$252,728.39

Page 9

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
CITY NATIONAL BANK
400 Park Ave, 21st Fl., New York, NY 10022
Acct No.: 665088073
ABA No.: 026013958; Swift Code: CINAUS6L

September 11, 2012
Invoice# 191924 RSM
Our file# 29503 0003
Billing through 08/31/2012

EMI Music
150 Fifth Avenue, 11th Floor
New York, NY 10011
Attn: Alasdair J. McMullan, Esq.

ReDigi
Balance forward as of invoice dated

August 6, 2012

Payments received since last invoice

$252,728.39
136,928.19
----------------

Accounts receivable balance carried forward

$115,800.20

PROFESSIONAL SERVICES
08/01/2012 RSM Reviewed D. Jacobson draft revisions to declaration;
conferences with J. King, telephone conferences with D.
Jacobson re same; revising Jacobson declaration; email to
and conference call with A. McMullan and J. King re same;
emails to and from D. Jacobson; revising response to 56.1
statement to include references to Jacobson declaration;
conferences with J. King re opposition brief; drafted letter
to Court re adjusting summary judgment schedule and
sealing of opposition and reply papers; emails to and from
G. Adelman re same
08/02/2012 RSM Reviewed Jacobson revisions to declaration; telephone
conference with and emails to and from D. Jacobson re
same; emails to and from A. McMullan re same; revising
Jacobson declaration; email to Court containing joint letter

Hours
4.50

2,250.00

4.50

2,250.00

29503

EMI Music

08/03/2012

RSM

08/06/2012

RSM

08/07/2012

RSM

08/08/2012

RSM

08/09/2012

RSM

08/10/2012

RSM

08/16/2012

RSM

08/17/2012

RSM

08/19/2012

RSM

Invoice# 191924

on sealing, extension of summary judgment schedule;
reviewed Court order approving same; drafted brief section
on distribution and first sale doctrine
Drafted brief point on display and performance claims;
revising Mandel declaration re adding specificity on
discovery needed on new iTunes service; reviewing and
revising draft brief points on reproduction
Conferences with J. King re revisions to brief and
preliminary statement; reviewing iTunes terms of use as
additional exhibit; revising Mandel declaration re same;
reviewing email from C. Hall re artwork on ReDigi site;
conferences with J. King re same
Conferences with J. King re revisions to brief and 56.1
response; revising summary judgment brief; email to client
re same; conference call with J. King and A. McMullan re
revisions to brief
Reviewing client comments on draft brief; conference call
with J. King and B. Cohen re same; revising summary
judgment brief and conferences with J. King, emails to and
from client re same; conferences with J. King re revisions
to Rule 56.1 response; reviewing and revising same; email
to client re same
Telephone conferences with B. Cohen, conference call with
A. McMullan and J. King, conferences with J. King re
revisions to 56.1 response; revising 56.1 response;
reviewing cite check to brief; revising brief; conferences
with N. Chinda re redactions and assembly of summary
judgment opposition papers; revised and finalized Mandel
and Jacobson declarations; emails to and from D. Jacobson
re finalizing declaration; reviewing Jacobson and Mandel
declarations for redactions and conferences with J. King re
same
Revising summary judgment opposition brief; conferences
with J. King re reviewing required redactions for 56.1
statement and brief and miscellaneous issues; conferences
with N. Chinda re issues concerning redaction and
finalization of opposition papers for filing; revising 56.1
response; drafted cover letter to court for submission of
opposition papers; conference call with J. King, M. Piibe,
B. Cohen and C. Hall re notifying Apple about public
statements on ReDigi 2.0; telephone conferences with B.
Cohen re miscellaneous issues
Telephone conference with J. King re reviewing strategic
issues concerning reply papers
Reviewing Limewire decision on precluding good faith
evidence; telephone conference with J. King re use of same
in reply and ReDigi attempt to strike Jacobson declaration
Reviewed letter to Court from G. Adelman re Jacobson

Page 2

3.80

1,900.00

1.60

800.00

3.80

1,900.00

4.00

2,000.00

4.70

2,350.00

4.80

2,400.00

0.60

300.00

0.50

250.00

1.90

950.00

29503

EMI Music

Invoice# 191924

declaration; drafted letter responding re same; email to J.
King re same
Revising and finalizing letter to Court responding re
Jacobson and conferences with J. King, emails to and from
client re same; reviewed Court order granting ReDigi
additional pages for reply; emails to and from client re
same; reviewing and analyzing ReDigi summary judgment
opposition papers; reviewing and revising draft reply brief
and conferences with J. King re same

Page 3

5.00

2,500.00

RSM

2.00

1,000.00

08/22/2012

RSM

0.30

150.00

08/23/2012

RSM

1.40

700.00

08/24/2012

RSM

1.30

650.00

08/27/2012

RSM

4.00

2,000.00

08/28/2012

RSM

0.70

350.00

08/29/2012

RSM

0.60

300.00

08/20/2012

RSM

08/21/2012

Revised reply brief based on cite check; reviewing reply
brief for redaction of confidential information and
conference with N. Chinda re same; drafted letter to Judge
Sullivan to enclose reply papers and unpublished opinion;
telephone conference with D. Jacobson re ReDigi 2.0
Telephone conference with B. Cohen re revisions to reply
brief; revising and finalizing reply brief; reviewing redacted
versions; conference with N. Chinda re adding Westlaw
citation for Limewire decision; supervising service and
filing of reply papers
Reviewing and analyzing ReDigi reply papers; email to D.
Jacobson enclosing Rudolph reply declaration; reviewing
relevant portions redacted from reply papers in connection
with sealing motion; drafted memo of law, notice of motion
and supporting declaration re sealing motion; email to
client re same

29503

EMI Music

Invoice# 191924

Mandel, Richard

Page 4
50.00

25,000.00

7.30

3,467.50

3.30

1,567.50

4.30

2,042.50

4.50

2,137.50

3.30

1,567.50

3.20

1,520.00

1.00

475.00

1.50

712.50

5.00

2,375.00

7.50

3,562.50

5.50

2,612.50

0.80

380.00

4.20

1,995.00

08/01/2012

JZK

08/06/2012

JZK

08/07/2012

JZK

08/08/2012

JZK

08/09/2012

JZK

08/10/2012

JZK

08/13/2012

JZK

08/14/2012

JZK

08/15/2012

JZK

08/16/2012

JZK

08/17/2012

JZK

08/19/2012

JZK

08/20/2012

JZK

08/21/2012

JZK

1.00

475.00

08/22/2012

JZK

2.00

950.00

08/23/2012

JZK

0.80

380.00

Revise draft Jacobson declaration; continue drafting
summary judgment opposition brief and research re same;
meet with B. Crawford re 56(d) research; conference with
A. McMullan re Jacobson declaration and revise same;
meet with R. Mandel re opposition papers.
Review and revise summary judgment opposition brief;
review revised Jacobson declaration; meet with R. Mandel
re additions to brief and draft preliminary statement and
other sections.
Complete revisions to opposition brief; meet with R.
Mandel re same; begin revising response to ReDigi 56.1
statement.
Phone conference with B. Cohen; meet with R. Mandel and
revise summary judgment opposition brief; revise response
to 56.1 statement; email re new artwork claim.
Review and revise Mandel opposition declaration and
opposition brief; phone conference with A. McMullan;
revise responses to 56.1 with R. Mandel; preparing
documents for redaction.
Finalizing opposition papers; meet with R. Mandel re same;
testing ReDigi 2.0 service; phone conferences with B.
Cohen; phone conference with M. Piibe, B. Cohen, C. Hall
and R. Mandel.
Phone conference with B. Cohen; final edits to opposition
brief; review redactions.
Revising and finalizing response to 56.1 for filing; finalize
remaining papers and arrange for filing; conference with B.
Cohen.
Reviewing ReDigi opposition papers and emails re same;
begin drafting response to ReDigi counterstatement of
facts.
Researching and drafting reply brief in support of summary
judgment; phone calls with A. McMullan; phone call with
R. Mandel.
Continue researching and drafting reply brief in support of
summary judgment; review ReDigi letter to Court re same;
conference with R. Mandel.
Revise and edit letter to Judge Sullivan re Jacobson
declaration.
Further revision of letter to Judge Sullivan; complete first
draft of reply brief and meet with R. Mandel re same.

29503
08/27/2012

EMI Music

Invoice# 191924

JZK

Page 5
0.40

190.00

55.60

26,410.00

0.40

104.00

0.40

104.00

3.10

806.00

3.10

806.00

1.50

292.50

Olsen, Kevin C. (Paralegal)

1.50

292.50

RE: Cite check, shepardize and Bluebook ReDigi
Opposition Brief (as per R. Mandel).
RE: Cite check and bluebook ReDigi opposition brief;
discuss corrections with R. Mandel.
RE: Check Westlaw cites to Chase v. Public Utility case
and to Rivera v. Salomon Smith Barney case; sent R.
Mandel corrections.
RE: Scan Jacobson Declaration and Mandel Declaration;
redact Jacobson and Mandel Decl.; prepare certificate of
service (as per R. Mandel).
RE: Scan and redact Memo of Law in Opposition to
Defendant's Motion for S.J.; prepare service copies;
organization of service sets; review ECF and non-ECF
electronic versions.
RE: Scan and redact Response to 56.1 Statement; prepare
service copies and organization of service sets; contact ECF
help desk for instructions on filing response to 56.1
Statement; efile opposition papers; prepare CD of sealed
documents; prepare hard copy originals of Response to 56.1
Statement, Jacobson Declaration, Mandel Declaration with
Exhibits 1 and 3, and Memo of Law; refile via ECF the
Response to 56.1 Statement as "Other Answers;" trip to
SDNY to file originals under seal.

2.50

537.50

0.90

193.50

0.20

43.00

2.50

537.50

4.00

860.00

4.80

1,032.00

1.00

215.00

2.00

430.00

0.50

107.50

4.20

903.00

King, Jonathan Z.
08/16/2012

SPC

Ceresia, Scott P.
08/01/2012

BAC

Crawford, Bridget A.
08/24/2012

KCO

08/08/2012

NAC

08/09/2012

NAC

08/09/2012

NAC

08/10/2012

NAC

08/13/2012

NAC

08/14/2012

NAC

08/21/2012

NAC

08/22/2012

NAC

08/23/2012

NAC

08/24/2012

NAC

RE: Cite check, shepardize and Bluebook Reply Memo of
Law (as per R. Mandel).
RE: Cite checked unpublished opinion Arista Records v.
Lime Group, No. 06 Civ. 5936 (KMW); discuss correction
with R. Mandel.
RE: Scan and redact memo of law; make copies of the
same; retrieve opinion dated April 20, 2012 for Arista

29503

EMI Music

Invoice# 191924

Page 6

Records v. Lime Group from Pacerand arrange for Westlaw
retrieval; prepare service sets; arrange for messenger
delivery of service set to Gary Adelman, check ECF files
on I-drive; efile Reply Memo of Law, Reply Declaration,
Exhibits 1 and 2 and Certificate of Service; prepare Judge
Sullivan's courtesy copy set.
08/29/2012

NAC

0.20

43.00

08/30/2012

NAC

1.00

215.00

23.80

5,117.00

134.40

$57,729.50

Chinda, Nart-Anong (Paralegal)
Current Services
EXPENSES

Current Expenses
Billing Summary
Total professional services

$57,729.50

Total expenses incurred
Total of new charges for this invoice

--------------$58,161.30

Plus net balance forward

$115,800.20
----------------

Total balance now due

$173,961.50

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
CITY NATIONAL BANK
400 Park Ave, 21st Fl., New York, NY 10022
Acct No.: 665088073
ABA No.: 026013958; Swift Code: CINAUS6L

October 8, 2012
Invoice# 193388 RSM
Our file# 29503 0003
Billing through 09/30/2012

EMI Music
150 Fifth Avenue, 11th Floor
New York, NY 10011
Attn: Alasdair J. McMullan, Esq.

ReDigi
Balance forward as of invoice dated

September 11, 2012

Payments received since last invoice

$173,961.50
0.00
----------------

Accounts receivable balance carried forward

$173,961.50

PROFESSIONAL SERVICES
09/04/2012 RSM

09/05/2012
09/13/2012

RSM

09/14/2012

RSM

09/18/2012
09/19/2012

RSM
RSM

Organizing and collecting materials for use in preparation
for oral argument
Selecting relevant cases from summary judgment briefing
for review in preparation for oral argument; emails to and
from J. Pariser re oral argument and prior briefing
Reviewing cases re preparation for oral argument
Reviewing and analyzing cases re preparation for oral
argument2.80

500.00

0.10

RSM

Hours
1.00

50.00

0.70

350.00

0.60

300.00

1.50
2.80

750.00
1,400.00

29503

EMI Music

09/20/2012

RSM

09/25/2012

RSM

09/27/2012

RSM

09/28/2012

RSM

09/04/2012

JZK
JZK

09/05/2012

Completed review and analysis of relevant cases in
preparation for oral argument
Detailed review and analysis of Copyright Office DMCA
report re preparation for oral argument; conferences with J.
King re issues concerning oral argument prep
Preparing outline for summary judgment oral argument;
conferences with J. King re issues concerning same and
reviewing materials in connection with same
Continued drafting outline for oral argument, and reviewing
materials and preparation re same
Mandel, Richard

Chinda, Nart-Anong (Paralegal)
Current Services
EXPENSES

Current Expenses
Billing Summary
Total professional services

$10,349.50

Total expenses incurred
---------------

1,400.00

2.50

1,250.00

3.00

1,500.00

17.00

8,500.00

807.50

0.80
0.40
2.90

380.00
190.00
1,377.50
42.00

42.00

430.00

2.00

NAC

2.80

2.00

Noble, J. Martin (Managing Clerk)

1,000.00

0.20

Conference with R. Mandel re ReDigi oral argument.
Conference with R. Mandel re summary judgment motion.
King, Jonathan Z.

2.00

0.20

JMN

09/14/2012

Page 2

1.70

JZK

09/25/2012
09/28/2012

Invoice# 193388

430.00

22.10

$10,349.50

29503

EMI Music

Total of new charges for this invoice
Plus net balance forward

Invoice# 193388
$12,853.68
$173,961.50

---------------Total balance now due

$186,815.18

Page 3

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
CITY NATIONAL BANK
400 Park Ave, 21st Fl., New York, NY 10022
Acct No.: 665088073
ABA No.: 026013958; Swift Code: CINAUS6L

November 6, 2012
Invoice# 194956 RSM
Our file# 29503 0003
Billing through 10/31/2012

EMI Music
150 Fifth Avenue, 11th Floor
New York, NY 10011
Attn: Alasdair J. McMullan, Esq.

ReDigi
Balance forward as of invoice dated

October 8, 2012

Payments received since last invoice

$186,815.18
115,800.20
----------------

Accounts receivable balance carried forward

$71,014.98

PROFESSIONAL SERVICES
10/01/2012 RSM Drafting outline for oral argument; reviewing materials and
preparation re same
10/02/2012 RSM Preparing outline for oral argument on summary judgment
motion; continued review of papers and materials in
connection with same; conferences with J. King re issues
concerning Apple agreement
10/03/2012 RSM Emails to and from Sullivan's chambers re copies of
summary judgment filings; emails to and from BBC
reporter, client re potential response for story; conferences
with J. King re issues for oral argument; completed outline
and reviewing same re preparation for oral argument
10/04/2012 RSM Completed preparation for oral argument; conferences with
J. King re practicing argument and reviewing issues; emails
to and from client, email to BBC re not commenting on

Hours
3.40

1,700.00

2.80

1,400.00

3.50

1,750.00

3.20

1,600.00

29503

EMI Music

10/05/2012
10/10/2012

RSM
RSM

10/11/2012
10/19/2012
10/22/2012

Invoice# 194956

pending litigation
Conducting oral argument on summary judgment motion

2.50
0.30

1,250.00
150.00

RSM

0.10

50.00

RSM
RSM

0.30
0.10

150.00
50.00

16.20

8,100.00

0.40
1.00
2.50
3.90

190.00
475.00
1,187.50
1,852.50

20.10

$9,952.50

Mandel, Richard
10/03/2012
10/04/2012
10/05/2012

Page 2

JZK
JZK
JZK

Conference with R. Mandel re oral argument.
Preparation discussion with R. Mandel re oral argument.
Attend oral argument.
King, Jonathan Z.
Current Services

EXPENSES
Current Expenses
Billing Summary
Total professional services

$9,952.50

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$10,292.88
$71,014.98
----------------

Total balance now due

$81,307.86

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

May 8, 2013

EMI Music
150 Fifth Avenue, 11th Floor
New York, NY 10011

Invoice# 204772 RSM
Our file# 29503 0003
Billing through 04/30/2013

Attn: Alasdair J. McMullan, Esq.

ReDigi

PROFESSIONAL SERVICES
04/01/2013 RSM Reviewed Court decision granting Capitol summary
judgment motion; conferences with J. King, telephone
conferences with and emails to and from A. McMullan re
same and summarizing decision; fielded press inquiries
04/02/2013 RSM Conferences with J. King re follow-up issues concerning
opinion and discussions with G. Adelman; email to client re
same; conference call with A. McMullan, J. King and B.
Cohen re reviewing follow-up issues
04/04/2013 RSM Conferences with J. King re discussions with client,
opposing counsel re settlement and potential mediation
04/05/2013 RSM Conference calls with A. McMullan and J. King re
settlement; conference call with G. Adelman and J. King re
settlement, next steps; conferences with J. King re same
04/08/2013 RSM Conference call with J. King and G. Adelman re next steps
in litigation; conferences with J. King re same and draft
joint letter to Court
04/09/2013 RSM Reviewed and revised draft joint letter to Court;
conferences with J. King, emails to and from client,
opposing counsel re same

Hours
2.00

1,020.00

1.00

510.00

0.20

102.00

1.00

510.00

0.60

306.00

0.50

255.00

29503

EMI Music

04/10/2013

RSM

04/11/2013

RSM

04/12/2013

RSM

04/16/2013

RSM

04/17/2013

RSM

04/24/2013

RSM

04/01/2013

JZK

04/02/2013

JZK

04/04/2013

JZK

04/05/2013

JZK

04/08/2013

JZK

04/09/2013

JZK

04/11/2013

JZK

04/12/2013

JZK

04/16/2013
04/17/2013

JZK
JZK

Invoice# 204772

Emails to and from opposing counsel re follow up on joint
letter
Emails to and from opposing counsel, client; reviewing
opposing counsel mark up of draft joint letter; conferences
with J. King re same and further revisions to letter, research
re certification for appeal standards; revise joint letter
Telephone conference with A. McMullan re draft joint
letter; emails to and from opposing counsel re same;
reviewing additional revisions by opposing counsel;
conferences with J. King re same and further revising and
finalizing joint letter; executing letter and emailing same to
Court; email to client re same
Reviewed draft email to client re verifying ownership on
tracks identified on ReDigi charts
Emails to and from client re updating of charts of
infringements; conference with J. King re same, discussion
with G. Adelman re pulling down of ReDigi 1.0
Conference with J. King re follow up discovery steps;
reviewing email to G. Adelman re same
Mandel, Richard
Review Court's opinion on summary judgment; meet with
R. Mandel re strategy for next steps and advising Court.
Conference with R. Mandel re remaining trial issues;
conference with R. Mandel, A. McMullan and B. Cohen re
next case steps; phone conference with ReDigi counsel.
Review Rudolph transcript and exhibits regarding number
of Capitol tracks offered for sale; phone conference with G.
Adelman; phone conference with A. McMullan; meet with
R. Mandel.
Phone conferences with A. McMullan and R. Mandel;
conferences with R. Mandel re next steps; phone
conference with G. Adelman and R. Mandel.
Conference with R. Mandel re joint letter to Court and draft
same; conference with G. Adelman and R. Mandel;
conference with A. McMullan.
Brief research re statutory damages; review revised draft
letter to Court; conference with R. Mandel re letter to
Court, statutory damages and personal liability.
Conference with G. Adelman re joint letter to Court; review
ReDigi changes to letter; conference with R. Mandel and
revise letter.
Review Redigi's second round of revisions to letter; meet
with R. Mandel and revise same.
Email re collecting damages information.
Emails re compiling damages discovery; phone conference
with G. Adelman re discovery and injunction; email with
client re damages discovery; meet with R. Mandel.

Page 2
0.10

51.00

2.20

1,122.00

1.20

612.00

0.10

51.00

0.20

102.00

0.30

153.00

9.40

4,794.00

1.30

637.00

1.70

833.00

1.40

686.00

1.00

490.00

2.60

1,274.00

1.30

637.00

1.60

784.00

0.60

294.00

0.30
1.00

147.00
490.00

29503

EMI Music

04/24/2013

JZK

04/30/2013

JZK

04/08/2013

SPC

04/09/2013

SPC

Invoice# 204772

Conference with R. Mandel and email to ReDigi counsel re
follow-up discovery.
Conference with opposing counsel re damages/remedy
discovery
King, Jonathan Z.
Conduct research regarding personal liability and copyright
infringement; collect relevant caselaw; begin drafting
research memo.
Complete research memo on personal liability and send to
R. Mandel and J. King.
Ceresia, Scott P.

Current Services
EXPENSES
Current Expenses
Billing Summary
Total professional services

$12,933.00

Total expenses incurred
Total of new charges for this invoice

--------------$13,237.97
----------------

Total balance now due

$13,237.97

Page 3
0.50

245.00

0.50

245.00

13.80

6,762.00

3.60

972.00

1.50

405.00

5.10

1,377.00

28.30

$12,933.00

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

June 6, 2013
Invoice# 206148 RSM
Our file# 29503 0003
Billing through 05/31/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

May 8, 2013

Payments received since last invoice

$13,237.97

0.00
----------------

Accounts receivable balance carried forward

$13,237.97

PROFESSIONAL SERVICES
05/02/2013 RSM Reviewed court order re mediation, case management;
telephone conferences with J. King, A. McMullan re same,
next steps; reviewing draft case management plan; emails
to and from J. King re same; reviewing mediation referral
and background info on mediator; emails re same, case
management plan
05/03/2013 RSM Emails to and from J. King, client and telephone
conferences with J. King re mediation; reviewing draft
mediation statement; email to J. King re revisions to same
05/07/2013 RSM Reviewed court scheduling order; docketing deadlines re
same
05/09/2013 RSM Telephone conference with A. McMullan, conferences with

Hours
0.70

357.00

1.00

510.00

0.20

102.00

0.90

459.00

29503

EMI Music

05/10/2013

RSM

05/13/2013

RSM

05/14/2013

RSM

05/15/2013

RSM

05/16/2013

RSM

05/21/2013

RSM

05/29/2013

RSM

05/30/2013

RSM

05/02/2013

JZK

05/03/2013

JZK

05/09/2013

JZK

05/10/2013
05/13/2013

JZK
JZK

05/14/2013

JZK

05/15/2013

JZK

Invoice# 206148

J. King re mediation and settlement; reviewing final draft of
mediation statement
Travel to and from and attending mediation first session;
conferences with J. King re same
Conferences with J. King re issues concerning ReDigi 2.0
and memo analyzing same; began drafting portion of memo
on strategy options
Completed drafting section of memo re strategic options
and recommendations; conferences with J. King re ReDigi
2.0 issues and portion of memo
Reviewing legal research on contract vs. copyright claims;
conferences with J. King re same and related issues on
ReDigi 2.0; reviewing portions of draft memo no ReDigi
2.0
Reviewing and revising draft memo to client advising re
ReDigi 2.0 and strategic options; conferences with J. King
re same; email to client re same
Telephone conference with B. Cohen re potential effect of
divestiture of labels on claims vs. ReDigi
Emails to and from opposing counsel re discovery;
conferences with J. King re same, mediation; conference
call with A. McMullan and J. King re preparation for
mediation; telephone conference with B. Cohen re
mediation and discovery
Conference with J. King re issues concerning ReDigi 2.0
claims
Mandel, Richard
Review Judge's order re Case Management Plan and
mediation; prepare amended Case Management Plan and
send to opposing counsel; emails and phone conferences re
same; emails with mediator and emails re mediation.
Finalize proposed case management plan and submit to
Court; conference call with opposing counsel and mediator;
numerous emails and phone conferences re scheduling
mediation; phone conference with A. McMullan re
mediation; draft mediation statement.
Finalize mediation statement and send to mediator; email
with mediator; phone call with G. Adelman; meet with R.
Mandel re memo to client; research re ReDigi 2.0 claim.
Meet with R. Mandel and attend first mediation session.
Review summary judgment papers for factual description of
ReDigi 2.0; review Apple agreements; begin outlining
ReDigi 2.0 analysis.
Research and draft memo re ReDigi next steps; meet with
R. Mandel re same.
Continue researching and drafting memo re ReDigi 2.0;
meet with R. Mandel; complete first draft.

Page 2

3.00

1,530.00

1.90

969.00

2.30

1,173.00

1.00

510.00

1.40

714.00

0.20

102.00

0.90

459.00

0.40

204.00

13.90

7,089.00

2.50

1,225.00

5.00

2,450.00

2.50

1,225.00

3.00
3.50

1,470.00
1,715.00

4.50

2,205.00

4.00

1,960.00

29503

Invoice# 206148

EMI Music

05/16/2013

JZK

05/23/2013
05/29/2013

JZK
JZK

05/30/2013

JZK

05/13/2013

TK

05/02/2013
05/07/2013

JMN
JMN

Complete revisions and edits to draft memo re ReDigi
litigation and settlement options; meet with R. Mandel re
same.
Email to opposing counsel following up re discovery.
Emails with mediator re upcoming mediation; email to
opposing counsel re discovery; emails to B. Cohen re
ownership documents; phone conference with B. Cohen;
phone conference with A. McMullan and R. Mandel re
mediation; phone conference with mediator.
Conference with R. Mandel re ReDigi 2.0.
King, Jonathan Z.

Page 3
2.80

1,372.00

0.10
2.00

49.00
980.00

0.30
30.20

147.00
14,798.00

Confer with Mr. King re ReDigi 2
Kjellberg, Thomas

0.50
0.50

207.50
207.50

Docketed ECF notices and calendared deadlines.
Docketed ECF notice and calendared case management
plan dates.
Noble, J. Martin (Managing Clerk)

0.40
0.20

86.00
43.00

0.60

129.00

45.20

$22,223.50

Current Services
Billing Summary
Total professional services

$22,223.50
---------------

Total of new charges for this invoice

$22,223.50

Plus net balance forward

$13,237.97

---------------Total balance now due

$35,461.47

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

July 8, 2013
Invoice# 207794 RSM
Our file# 29503 0003
Billing through 06/30/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

June 6, 2013

Payments received since last invoice

$35,461.47

13,237.97
----------------

Accounts receivable balance carried forward

$22,223.50

PROFESSIONAL SERVICES
06/04/2013 RSM Conducting mediation
06/06/2013 RSM Telephone conference with A. McMullan; reviewed draft
notice of deposition; emails to and from client re same
06/07/2013 RSM Drafted individual deposition notices for Ossenmacher and
Rogel; revised 30(b)(6) notice; email to opposing counsel
serving same
06/11/2013 RSM Emails to and from G. Adelman re status of document
production, scheduling of depositions; conferences with J.
King re same
06/13/2013 RSM Emails to and from opposing counsel re discovery
responses
06/14/2013 RSM Reviewing documents produced by ReDigi; reviewing

Hours
4.00
0.40

2,040.00
204.00

0.60

306.00

0.40

204.00

0.20

102.00

0.60

306.00

29503

EMI Music

06/17/2013

RSM

06/18/2013

RSM

06/19/2013

RSM

06/20/2013

RSM

06/24/2013

RSM

06/25/2013

RSM

06/27/2013

RSM

06/28/2013

RSM

06/29/2013

RSM

06/03/2013
06/04/2013

JZK
JZK

Invoice# 207794

pre-motion letter from opposing counsel re certification;
email to client, conferences with J. King re response to
same
Emails to and from opposing counsel re scheduling
depositions; reviewed and revised draft response to
pre-motion letter on certification for appeal; email to client
re same; email to N. Chinda re converting Lexis citations to
Westlaw per Judge's rules
Conferences with N. Chinda re substituting Westlaw
citations to letter to Judge Sullivan; reviewing cite check of
letter; telephone conference with B. Cohen re revisions to
letter; finalized, signed and sent letter to Court responding
re pre-motion letter; conference with J. King re discussions
with opposing counsel on charts and information
Conference with J. King re reviewing documents produced
by ReDigi and follow up issues re same; email to G.
Adelman re production of financial documents
Reviewed draft email to client re information produced by
ReDigi; conference with J. King re same
Conferences with J. King re issues concerning 7Digital,
depositions, charts produced by ReDigi; reviewing
deposition testimony re 7Digital; conference call with J.
King, B. Cohen and A. McMullan re issues concerning
ReDigi production and 7Digital; reviewed Court order
denying motion for certification; email to client re same;
emails to and from G. Adelman re financial documents and
scheduling of depositions
Reviewed Tenenbaum decision on statutory damages;
reviewed emails to and from opposing counsel re discovery
issues
Reviewing declarations from summary judgment motion on
ReDigi 2.0 re preparation for call with C. Horton;
conference call with J. King, B. Cohen and C. Horton re
ReDigi 2.0; supervising and coordinating review of ReDigi
charts re identification of claimed tracks
Conferences with N. Chinda re analysis of ReDigi charts to
reflect tracks already reviewed by client; telephone
conference with and letter to B. Cohen re same; preparation
for call with client on 7Digital and reviewing information
on 7Digital in connection with same; conference call with J.
King, B. Cohen, J. Fisherman, A. Harrison, B. Stone, R.
Pizano re reviewing facts on 7Digital relationship
Reviewing draft email to opposing counsel seeking
additional documents; email to J. King re same
Mandel, Richard
Emails with mediator and client re tomorrow's mediation.
Attend mediation.

Page 2

0.60

306.00

0.80

408.00

1.20

612.00

0.20

102.00

2.30

1,173.00

0.40

204.00

1.80

918.00

2.20

1,122.00

0.10

51.00

15.80

8,058.00

0.40
4.00

196.00
1,960.00

29503

EMI Music

06/11/2013

JZK

06/14/2013

JZK

06/17/2013

JZK

06/18/2013

JZK

06/19/2013
06/20/2013

JZK
JZK

06/24/2013

JZK

06/25/2013

JZK

06/26/2013
06/27/2013

JZK
JZK

06/28/2013

JZK

06/17/2013

NAC

06/28/2013

NAC

Invoice# 207794

Conference with R. Mandel re damage discovery and
scheduling depositions.
Review documents produced by ReDigi re Capitol sales;
emails with opposing counsel re same; review ReDigi
pre-motion letter re certification and research same.
Draft and research response to ReDigi's pre-motion letter re
certification; phone conference with ReDigi counsel.
Phone conference with opposing counsel re newly produced
documents; conference with R. Mandel re same.
Meet with R. Mandel to review ReDigi tracks information.
Emails to opposing counsel; review Capitol track charts and
draft memo explaining same; send to client.
Review 7Digital agreement with ReDigi and meet with R.
Mandel re same; review deposition testimony of
Ossenmacher and Rudolph; phone conference with A.
McMullan, B. Cohen and R. Mandel; review court order on
certification; phone conference with opposing counsel.
Review financial document production; email to ReDigi
counsel.
Begin preparing Rudolph deposition outline.
Continue review of Rudolph deposition re personal
liability; phone conference with C. Horton, B. Cohen, R.
Mandel; phone conference with opposing counsel.
Drafting Rudolph deposition outline and reviewing charts
of Capitol tracks; phone conference with UMG and EMI
representatives re 7Digital; draft discovery demand re
7Digital documents.
King, Jonathan Z.
RE: Convert lexis cites to westlaw cites re letter to Judge
Sullivan dtd June 19, 2013 - response to June 14, 2013
pre-motion letter from ReDigi.
RE: Compare and confirm songs listed on ReDigi list to
chart on ownership (as per R. Mandel).
Chinda, Nart-Anong (Paralegal)
Current Services

EXPENSES

Current Expenses
Billing Summary
Total professional services

$21,228.00

Page 3
0.40

196.00

2.50

1,225.00

3.80

1,862.00

1.00

490.00

1.00
2.20

490.00
1,078.00

4.00

1,960.00

0.20

98.00

1.50
2.50

735.00
1,225.00

2.30

1,127.00

25.80

12,642.00

0.50

110.00

1.90

418.00

2.40

528.00

44.00

$21,228.00

29503

EMI Music

Invoice# 207794

Total expenses incurred
--------------Total of new charges for this invoice

$21,253.95

Plus net balance forward

$22,223.50
----------------

Total balance now due

$43,477.45

Page 4

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

August 7, 2013
Invoice# 209499 RSM
Our file# 29503 0003
Billing through 07/31/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

July 8, 2013

Payments received since last invoice

$43,477.45

0.00
----------------

Accounts receivable balance carried forward

$43,477.45

PROFESSIONAL SERVICES
07/01/2013 RSM Reviewing chart re undetermined ownership of copyright
recordings; email to B. Cohen re same; conferences with J.
King re issues concerning 7Digital and depositions of
Ossenmacher and Rudolph; gathering materials for
potential use at Ossenmacher deposition
07/02/2013 RSM Emails to and from B. Cohen re copyright information
needed to finalize universe of claimed infringements;
conferences with J. King re chart produced by ReDigi and
issues concerning depositions, ReDigi 2.0 and 7Digital
07/03/2013 RSM Telephone conference with B. Cohen re establishing
copyright ownership for claimed recordings; reviewing and
analyzing ReDigi summary chart of recordings and

Hours
1.00

510.00

0.80

408.00

1.00

510.00

29503

EMI Music

07/08/2013

RSM

07/09/2013

RSM

07/10/2013

RSM

07/11/2013

RSM

07/12/2013
07/17/2013

RSM
RSM

07/22/2013

RSM

07/24/2013

RSM

07/25/2013

RSM

07/26/2013

RSM

07/28/2013

RSM

07/29/2013

RSM

07/30/2013

RSM

07/31/2013

RSM

Invoice# 209499

conferences with J. King re same
Emails to and from opposing counsel re rescheduling
depositions; drafted email to client re changes in Amazon
terms of use and conferences with J. King re same;
reviewing Ossemacher prior deposition testimony in
preparation for deposition; reviewing documents and
materials re same
Reviewing and finalizing selection of exhibits for
deposition of Ossenmacher; drafting outline for
Ossenmacher deposition
Reviewing outline re preparation for Ossenmacher
deposition; reviewing law on statutory damages factors re
preparation for depositions
Reviewing case law on individual liability in preparation
for depositions and revise outline re same; took deposition
of J. Ossenmacher; conferences with J. King re preparation
for Rudolph deposition and follow up issues
Attended deposition of L. Rudolph
Brief review of transcripts of depositions; email to client re
same; telephone conference with B. Cohen re status of
ownership project; telephone conference with A. McMullan
re 7Digital issue and potential assertion of claims regarding
same
Conference with J. King re pre-motion letter and amending
complaint
Reviewed draft email to opposing counsel re discovery
follow up and amendment; revised and sent same re
discovery; email to client re amendment status
Drafting amended complaint; conferences with J. King re
pre-motion letter and complaint; telephone conference with
B. Cohen re ownership issues
Telephone conference with A. McMullan re amended
complaint; reviewing and revising draft letter to Judge
Sullivan; revising amended complaint; conferences with J.
King re revisions to letter and complaint; emails to and
from B. Cohen re ownership issues; email to client with
draft letter and complaint
Email to S. Bauman re sale/license issue and impact of
paragraph in amended complaint on same
Reviewed email from S. Bauman re proposed revision to
language in amended complaint
Conference call with J. King and B. Cohen and follow up
with J. King re issues concerning ReDigi 2.0 and ownership
information for amended complaint; conference call with
Universal and Apple re ReDigi 2.0
Reviewing and analyzing issues concerning ownership and
recordings to be asserted in amended complaint;
conferences with J. King re same

Page 2

4.20

2,142.00

3.80

1,938.00

2.00

1,020.00

4.40

2,244.00

3.00
0.60

1,530.00
306.00

0.20

102.00

0.30

153.00

2.80

1,428.00

1.50

765.00

0.10

51.00

0.10

51.00

1.80

918.00

1.00

510.00

29503

EMI Music

Invoice# 209499

Mandel, Richard
07/01/2013

JZK

07/02/2013

JZK

07/03/2013

JZK

07/08/2013

JZK

07/10/2013

JZK

07/11/2013

JZK

07/12/2013
07/16/2013

JZK
JZK

07/17/2013

JZK

07/22/2013
07/24/2013

JZK
JZK

07/25/2013

JZK

07/26/2013

JZK

07/30/2013

JZK

07/31/2013

JZK

07/22/2013

NAC

Emails to opposing counsel re discovery follow-up;
continue drafting Rudolph deposition outline and reviewing
charts of Capitol tracks; conference with R. Mandel; review
of 7Digital API agreement and terms of use.
Preparing exhibits for Rudolph deposition; phone
conference with opposing counsel; review new documents
provided by ReDigi; meet with R. Mandel re same.
Review Capitol tracks summary sheet; meet with R.
Mandel re same.
Review Amazon's proposed revisions to Amazon download
agreement; conference with R. Mandel re same; revise
response to client re same; revise deposition outline.
Review R. Mandel's Ossenmacher deposition outline;
revise Rudolph deposition outline to account for new
7digital information; correspondence with mediator;
research re statutory damages factor.
Research re individual liability and edit deposition outlines
to incorporate same; emails re Amazon proposed revisions
to terms of service; attend Ossenmacher deposition; revise
Rudolph outline to incorporate today's testimony.
Take L. Rudolph deposition.
Phone conference with B. Cohen re collection of ownership
information.
Review Rudolph transcript re 7digital issues; conference
with R. Mandel re same.
Conference with R. Mandel re motion to amend.
Review Ossenmacher and Rudolph transcript re follow-up
requests for information; begin drafting pre-motion letter
and research re same.
Complete pre-motion letter to Court re amendments;
conference with R. Mandel re same and re amended
complaint.
Edit pre-motion letter; review and revise amended
complaint; meet with R. Mandel re same.
Phone conference with B. Cohen re revised list of tracks
infringed and Apple call; phone conference with D. Ring,
B. Cohen and Apple attorneys.
Detailed analysis of spreadsheet of Capitol owned tracks;
meet with R. Mandel re same; phone conference with B,
Cohen; begin preparing revised exhibit of infringed tracks
for complaint; conference and emails with opposing
counsel re missing tracks; research re suing on pending
application.
King, Jonathan Z.
RE: Uploaded Ossenmacher and Rudolph deposition

Page 3
28.60

14,586.00

5.60

2,744.00

6.80

3,332.00

0.50

245.00

1.50

735.00

2.20

1,078.00

6.00

2,940.00

3.00
0.30

1,470.00
147.00

0.60

294.00

0.20
2.00

98.00
980.00

4.50

2,205.00

2.50

1,225.00

1.80

882.00

6.50

3,185.00

44.00

21,560.00

0.50

110.00

29503

EMI Music

Invoice# 209499

transcripts and exhibits; organize hard copy files.
Chinda, Nart-Anong (Paralegal)

Current Services
EXPENSES

Current Expenses
Billing Summary
Total professional services

$36,256.00

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$36,409.70
$43,477.45
----------------

Total balance now due

$79,887.15

Page 4

0.50

110.00

73.10

$36,256.00

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

September 9, 2013
Invoice# 211124 RSM
Our file# 29503 0003
Billing through 08/31/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

August 7, 2013

Payments received since last invoice

$79,887.15

22,223.50
----------------

Accounts receivable balance carried forward

$57,663.65

PROFESSIONAL SERVICES
08/01/2013 RSM Revising letter to Court; emails to and from client re same;
reviewing and revising exhibits to amended complaint;
email to client re same; reviewing SDNY cases re inability
to sue based on pending application and conference with J.
King re same
08/02/2013 RSM Telephone conferences with B. Cohen re revisions to
amended complaint; revised and finalized same; finalizing
letter to Court and email to Court enclosing letter and
amended complaint; conferences with N. Chinda re review
of registrations; emails to and from and telephone
conferences with B. Cohen re same and follow up issues on
ownership; drafted and sent letter to G. Adelman enclosing

Hours
0.80

408.00

2.40

1,224.00

29503

EMI Music

08/05/2013

RSM

08/06/2013

RSM

08/07/2013

RSM

08/08/2013

RSM

08/09/2013

RSM

08/13/2013

RSM

08/16/2013

RSM

08/22/2013

RSM

08/26/2013

RSM

08/27/2013

RSM

08/28/2013

RSM

08/29/2013

RSM

Invoice# 211124

copies of certificates of registration; reviewed ReDigi
pre-motion letter to Court; emails to and from client re
same, follow up issues for court conference
Reviewing legal research re using investigator downloads
to establish infringement; drafted response to ReDigi
pre-motion letter; email to client, conference with J. King re
same
Emails to and from J. Pariser re ReDigi 2.0; reviewed email
from B. Cohen re revisions to response to ReDigi
pre-motion letter
Reviewing cite check on draft response to ReDigi
pre-motion letter; revised, finalized and sent response to
Judge Sullivan; conference call with A. McMullan, B.
Cohen and J. King re trial strategy and prep for court
conference; reviewed ReDigi response to Capitol
pre-motion letter; emails to and from client
Telephone conference with B. Cohen re reviewing
ownership issues; reviewed email from B. Cohen re same;
preparation for court conference, including review of
pre-motion letters, re-reading Court summary judgment
opinion, reviewing deposition testimony re individual
liability, reviewing chart of recordings re effect of
eliminating 7digital on tracks purchased by Capitol,
organizing materials for conference and preparing outline
of issues
Attended court conference and travel to and from same;
conference call with J. Pariser, B. Ward, C. Horton and J.
King re ReDigi 2.0
Conference with S. Ceresia re legal research on jury trial
issue; telephone conference with B. Cohen re finalizing
exhibit of infringed recordings
Conference with J. King re follow-up issues concerning
amended complaint
Reviewed email from G. Adelman re song tracks; emails to
and from and telephone conference with J. King re same;
reviewed S. Ceresia research memo on jury issue; reviewed
emails to and from opposing counsel re same
Emails to and from and telephone conference with B.
Cohen re finalizing chart of recordings claimed and issues
re same; preparing summons for L. Rudolph and J.
Ossenmacher
Revising exhibits to amended complaint; emails to and
from B. Cohen re same
Telephone conferences with B. Cohen re finalizing
amended complaint and ownership issues re same;
reviewing email from B. Cohen re same
Telephone conferences with and multiple emails to and
from A. McMullan, B. Cohen re analyzing ownership

Page 2

1.80

918.00

0.20

102.00

1.30

663.00

2.60

1,326.00

2.70

1,377.00

0.20

102.00

0.20

102.00

0.50

255.00

0.80

408.00

0.60

306.00

0.40

204.00

1.60

816.00

29503

08/30/2013

EMI Music

RSM

08/01/2013

JZK

08/07/2013

JZK

08/08/2013

JZK

08/09/2013

JZK

08/16/2013
08/20/2013

JZK
JZK

08/22/2013

JZK

08/13/2013

SPC

08/16/2013

SPC

08/19/2013

SPC

08/21/2013

SPC

08/22/2013

SPC

08/19/2013
08/30/2013

JMN
JMN

Invoice# 211124

issues; revising exhibits to amended complaint; reviewed
email from G. Adelman re representation of J.
Ossenmacher; email to client re same
Multiple telephone conferences with and emails to and
from B. Cohen re finalizing list of works claimed; research
on Copyright Office website and Internet re reviewing
ownership of works claimed and appropriate registrations to
be cited; revising and finalizing list of recordings exhibit to
amended complaint; drafted acknowledgement of service
forms for individual defendants; drafted letter to Court re
courtesy copy of amended complaint; emails to G. Adelman
and J. Pizzirusso re enclosing amended complaint and
acknowledgement forms; conferences with M. Noble re
filing of amended complaint
Mandel, Richard
Further research re suing on pending applications;
conference with R. Mandel re same.
Conference with A. McMullan, R. Mandel and B. Cohen re
upcoming conference; review ReDigi's response to
pre-motion letter.
Research re statutory damages; confer with R. Mandel re
same; phone call and emails to opposing counsel.
Attend court hearing; report on results in email to client;
phone conference with J. Pariser, C. Horton, and B. Ward.
Conference with R. Mandel re amended complaint.
Email to opposing counsel re amending complaint, jury
issues, and next steps for trial.
Emails with opposing counsel re amended complaint and
jury trial; conference with R. Mandel re same.
King, Jonathan Z.
Receive assignment from R. Mandel regarding statutory
damages and jury; begin conducting research.
Conduct additional research regarding statutory damages
and jury issue.
Continue researching statutory damages and jury issue;
begin compiling research and summarizing.
Review and supplement research memo regarding jury and
nonjury issues.
Proofread and finalize research memo regarding statutory
damages and jury versus nonjury; send to R. Mandel and J.
King for review.
Ceresia, Scott P.

Docketed ECF notice and calendared deadlines.
File Summons and Amended Complaint. Scanned
amended complaint and emailed to case openings at SDNY.
Docketed filing of Amended Complaint and Summonses.

Page 3

7.00

3,570.00

23.10

11,781.00

1.30

637.00

0.90

441.00

1.30

637.00

3.00

1,470.00

0.20
0.30

98.00
147.00

0.60

294.00

7.60

3,724.00

0.80

216.00

0.90

243.00

2.50

675.00

1.20

324.00

1.20

324.00

6.60

1,782.00

0.20
1.80

43.00
387.00

29503

EMI Music

Invoice# 211124

Page 4

Noble, J. Martin (Managing Clerk)
08/02/2013

NAC

08/07/2013

NAC

2.00

430.00

RE: Review certificates for various songs owned by EMI
and compare to J. King's spreadsheet (as per R. Mandel);
create excel spreadsheet of missing SR certificates and
email to R. Mandel; Bates-number SR certificates listed on
J. King's ReDigi Ownership spreadsheet (CAP 001652 CAP 002050).
RE: Cite check, shepardize and Bluebook Letter to Judge
Sullivan responding to ReDigi 8/12/2013 Pre-Motion
Letter.
Chinda, Nart-Anong (Paralegal)

5.80

1,276.00

1.10

242.00

6.90

1,518.00

46.20

$19,235.00

Current Services
EXPENSES

Current Expenses
Billing Summary
Total professional services

$19,235.00

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$21,723.12
$57,663.65
----------------

Total balance now due

$79,386.77

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

October 7, 2013
Invoice# 212812 RSM
Our file# 29503 0003
Billing through 09/30/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

September 9, 2013

Payments received since last invoice

$79,386.77

57,663.65
----------------

Accounts receivable balance carried forward

$21,723.12

PROFESSIONAL SERVICES
09/03/2013 RSM Email to opposing counsel re copy of letter to Court
enclosing amended pleading
09/06/2013 RSM Emails to and from opposing counsel re call on trial issues
09/09/2013 RSM Reviewed draft revised protective order; executed same;
emails to and from opposing counsel re same
09/10/2013 RSM Conference call with opposing counsel and J. King re next
steps in case; conference with J. King and emails to and
from client re same
09/11/2013 RSM Reviewing and revising draft joint letter to Court;
conferences with J. King, emails to and from client re same
09/13/2013 RSM Reviewed opposing counsel's proposed revisions to joint
letter; emails to and from client, conferences with J. King re

Hours
0.10

51.00

0.10
0.30

51.00
153.00

0.70

357.00

0.50

255.00

0.70

357.00

29503

EMI Music

09/16/2013

RSM

09/17/2013

RSM

09/19/2013

RSM

09/20/2013

RSM

09/23/2013

RSM

09/24/2013

RSM

09/25/2013

RSM

09/26/2013

RSM

09/27/2013

RSM

Invoice# 212812

same; revised draft joint letter; emails to and from opposing
counsel re same
Emails to and from opposing counsel re joint letter to
Court; revised and finalized same; email to Court enclosing
joint letter; email to client re same; reviewed ReDigi
answer to complaint; conference with J. King re same
Conference with J. King re possible motions concerning
ReDigi answer; reviewing S. Ceresia legal research re same
and conference with J. King, S. Ceresia re same; email to
client re same
Reviewed court order re motion to dismiss and discovery;
email to client re same; conferences with J. King re next
steps; conference with S. Ceresia re research on jury
consideration of willfulness; reviewed draft case
management plan prepared by opposing counsel; email to
and telephone conference with client re same and
consideration of jury issue; emails to and from opposing
counsel re revisions to case management plan; reviewing
and analyzing list of recordings re missing registrations and
other information to be supplemented re chain of title issues
Continuing review and analysis of recording list and
registrations re ownership issues to be supplemented;
conference with S. Ceresia re legal research on innocent
infringement and reviewing same; reviewed emails from
opposing counsel re case management plan
Reviewing and analyzing individual defendants' motion to
dismiss; email to client re same; conferences with J. King re
opposition papers; conference with J. King and S. Ceresia
re legal research for opposition; completed analysis of
ownership issues; email to B. Cohen re missing copyright
certificates; email to B. Cohen re copyright owner entities
to be confirmed as EMI entities or exclusive licensors to
EMI
Reviewing and analyzing cases cited in individual
defendants' moving brief
Conferences with J. King re motion to dismiss opposition
and reviewing draft sections of same; conference with S.
Ceresia re additional legal research for opposition;
continued review of cases cited by individual defendants;
prepared chart of registrations without individual track
listings; emails to and from B. Cohen re same and next
steps re ownership proof
Prepared chart re open ownership issues; email to B. Cohen
re same; reviewing S. Ceresia legal research; conferences
with J. King re status of opposition papers and reviewing
draft of same; reviewed court scheduling order; email to
client re same
Reviewing draft opposition to motion to dismiss and

Page 2

0.80

408.00

0.50

255.00

3.60

1,836.00

2.50

1,275.00

2.50

1,275.00

1.80

918.00

1.60

816.00

1.00

510.00

0.50

255.00

29503

EMI Music

09/29/2013

RSM

09/30/2013

RSM

09/10/2013

JZK

09/11/2013

JZK

09/13/2013

JZK

09/16/2013
09/17/2013

JZK
JZK

09/19/2013

JZK

09/20/2013
09/23/2013

JZK
JZK

09/24/2013
09/25/2013

JZK
JZK

09/26/2013

JZK

09/27/2013
09/30/2013

JZK
JZK

09/17/2013

SPC

09/20/2013

SPC

09/23/2013

SPC

09/24/2013

SPC

Invoice# 212812

conference with J. King re sections to be added
Drafting and revising brief in opposition to motion to
dismiss
Drafting and revising brief in opposition to motion to
dismiss; email to client re same
Mandel, Richard
Phone conference with all counsel; conference with R.
Mandel re same.
Draft letter to Judge Sullivan re next anticipated steps for
trial; meet with R. Mandel re same and review his
revisions.
Review comments from individual defendants' markup of
joint letter to Court; conference with R. Mandel re same.
Conference with R. Mandel re letter to Court.
Conference with R. Mandel and S. Ceresia re jury and
amendment issues; review research memos re same; meet
with R. Mandel re same.
Conference with R. Mandel re Court's action re motion;
research re jury issues; review draft case management plan;
research re statutory damages and jury instructions.
Research re individual liability cases in Second Circuit.
Review individual defendants' motion to dismiss; further
research re individual liability; begin drafting response to
motion; meet with R. Mandel re same.
Continue drafting response to motion to dismiss.
Continue drafting and research opposition to motion to
dismiss; meet with R. Mandel re same; meet with S.
Ceresia re research re same.
Continue drafting opposition to motion to dismiss; research
re same.
Continue drafting opposition brief.
Continue drafting, revising and researching opposition brief
and motion to dismiss; conference with R. Mandel.
King, Jonathan Z.
Conduct research regarding revival of right to jury trial and
preserving defenses for appellate review; compile relevant
caselaw; send research summary to R. Mandel and J. King.
Conduct research regarding statutory damages and
"innocent" infringement; collect relevant caselaw.
Receive research assignment from R. Mandel and J. King;
conduct research into issue regarding pro-plaintiff Rule
12(b)(6) standard under Twombly; conduct research
regarding leave to replead under Rule 15; collect relevant
caselaw.
Continue researching for opposition brief on motion to
dismiss; conduct research regarding consideration of

Page 3

2.50

1,275.00

1.80

918.00

21.50

10,965.00

0.60

294.00

2.00

980.00

0.40

196.00

0.30
0.60

147.00
294.00

1.80

882.00

1.50
4.50

735.00
2,205.00

3.00
5.00

1,470.00
2,450.00

4.80

2,352.00

3.00
2.70

1,470.00
1,323.00

30.20

14,798.00

1.90

513.00

1.90

513.00

1.90

513.00

2.10

567.00

29503

EMI Music

09/25/2013

SPC

09/26/2013

SPC

Invoice# 212812

evidence in record; begin summarizing caselaw.
Conduct additional research regarding public records and
motions to dismiss.
Complete research regarding public records and motions to
dismiss; complete research summary for opposition to
motion to dismiss; review and finalize research summary
and send to R. Mandel and J. King for review.
Ceresia, Scott P.

Current Services
EXPENSES

Current Expenses

Billing Summary
Total professional services

$29,003.00

Total expenses incurred
Total of new charges for this invoice

Plus net balance forward

--------------$30,384.27

$21,723.12
----------------

Total balance now due

$52,107.39

Page 4

0.60

162.00

3.60

972.00

12.00

3,240.00

63.70

$29,003.00

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

November 6, 2013
Invoice# 214594 RSM
Our file# 29503 0003
Billing through 10/31/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

October 7, 2013

Payments received since last invoice

$52,107.39

0.00
----------------

Accounts receivable balance carried forward

$52,107.39

PROFESSIONAL SERVICES
10/01/2013 RSM Drafting additional footnotes to brief re distinguishing cases
and inducement claim; email to client re same; emails to
and from opposing counsel re acknowledgement of service
for Rudolph; arranging for service of acknowledgements of
service; conferences with N. Chinda re cite checking brief
10/02/2013 RSM Reviewing cite check of brief and conferences with N.
Chinda re same; revising brief re opposition to motion to
dismiss; reviewing table of contents and Judge Sullivan
rules re unpublished opinions; reviewing EMI v. Karen case
on ownership
10/03/2013 RSM Telephone conference with B. Cohen re ownership issues,
revisions to brief in opposition to motion to dismiss; revised

Hours
0.70

357.00

1.20

612.00

1.00

510.00

29503

EMI Music

10/04/2013

RSM

10/09/2013

RSM

10/10/2013

RSM

10/11/2013

RSM

10/14/2013

RSM

10/15/2013

RSM

10/16/2013
10/17/2013

RSM
RSM

10/18/2013

RSM

10/21/2013

RSM

10/22/2013

RSM

Invoice# 214594

brief in opposition to motion to dismiss; conferences with J.
King re strategy issues
Finalized, signed and arranged for filing of brief in
opposition to motion to dismiss; prepared letter to Judge
Sullivan enclosing courtesy copy and copy of unpublished
decisions; email to opposing counsel re same
Reviewing discovery requests and initial disclosures served
by defendants; conferences with J. King re same and
strategy for objecting; email to client re discovery requests
Conference with S. Ceresia re legal research on collateral
estoppel and discovery issues; reviewing same; drafting
letter to opposing counsel re discovery issues; conferences
with J. King re same
Reviewing J. King revisions to draft discovery letter and
conferences with J. King re same; email to client re draft
letter; telephone conference with B. Cohen re status of
ownership issues and reviewing email from B. Cohen re
same and registration information
Telephone conference with and emails to and from B.
Cohen re changes to draft discovery letter and ownership
issues; revised and sent discovery letter to opposing
counsel; reviewing open issues re ownership and updating
documents to be produced re same
Emails to and from opposing counsel, conference with J.
King re meet and confer on discovery disputes
Email to client re discovery issues and strategy
Conferences with J. King re preparation for meet and
confer call with opposing counsel and joint letter to Court;
conference call with J. King and opposing counsel re meet
and confer on discovery issues; drafting joint letter to Court
and reviewing revisions to same
Reviewing and revising draft joint letter re discovery;
conference with J. King re same; email to client re same;
reviewed defendants' reply brief in support of motion to
dismiss; email to client re same
Telephone conference with A. McMullan re ReDigi site and
issues concerning same; telephone conference with B.
Cohen re same; emails to and from A. McMullan re record
rental amendment issue; emails to and from B. Cohen re
chain of title and discovery issues; reviewed email from
opposing counsel re joint letter and discovery disputes
Emails to and from opposing counsel re discovery dispute;
telephone conference with B. Cohen re reviewing
ownership issues; reviewing Copyright Office website and
registration certificates re same; email to client re same;
reviewed 30(b)(6) deposition notice served by individual
defendants; emails to and from client re same, objections,
scheduling and location of deposition; updating chain of

Page 2

0.60

306.00

0.90

459.00

1.40

714.00

0.60

306.00

0.90

459.00

0.30

153.00

0.10
4.80

51.00
2,448.00

0.80

408.00

0.80

408.00

2.30

1,173.00

29503

EMI Music

10/23/2013

RSM

10/24/2013

RSM

10/25/2013

RSM

10/26/2013

RSM

10/28/2013

RSM

10/29/2013

RSM

10/30/2013

RSM

10/31/2013

RSM

Invoice# 214594

title chart and reviewing open issues re same; reviewing
missing registrations provided by client and conference
with N. Chinda re supplemental production of same
Emails to and from opposing counsel, client re scheduling
and location of deposition; drafting objections to 30(b)(6)
deposition notice; email to client re same; emails to and
from opposing counsel re providing prior document
production and agreement to confidential counsel only
designation for Apple agreement
Conference call with A. McMullan, B. Cohen and J. King
re objections to 30(b)(6) notice; revised, finalized and
served objections; emails to and from opposing counsel,
client re scheduling of deposition; reviewed defendants'
revisions to joint letter; conferences with J. King re same
and legal research on collateral estoppel issue; reviewing
and revising draft joint letter; emails to and from opposing
counsel and client re same; conferences with N. Chinda re
cite checking letter and Westlaw citations for same; letter to
opposing counsel enclosing copy of prior document
production
Reviewed opposing counsel's revisions to joint letter;
conferences with J. King and telephone conference with B.
Cohen re same; finalized and sent joint letter to Court;
reviewing deposition notices and subpoenas; emails to and
from opposing counsel, client and telephone conference
with client, conferences with J. King re same; reviewing
prior produced chain of title documentation and email to B.
Cohen summarizing same
Emails to and from C. Finkelstein, opposing counsel re
accepting service of subpoena
Telephone conferences with and emails to A. McMullan,
conferences with J. King re discovery issues; emails to and
from and telephone conference with opposing counsel re
depositions; email to B. Cohen re spreadsheet of recordings
at issue; conference with S. Ceresia re legal research on res
judicata effect of ReDigi's waiver of affirmative defenses
on individual defendants
Telephone conferences with A. McMullan, B. Cohen re
depositions, chain of title evidence; reviewed RIAA
subpoena served by defendants; emails to client, J. Pariser
re same
Telephone conference with opposing counsel re
depositions; conferences with J. King, emails to and from
A. McMullan re same
Telephone conferences with and emails to B. Cohen, A.
McMullan, conferences with J. King re deposition
scheduling and issues; telephone conference with opposing
counsel re deposition issues and scheduling; reviewing

Page 3

2.00

1,020.00

3.20

1,632.00

3.30

1,683.00

0.10

51.00

1.00

510.00

0.40

204.00

0.50

255.00

1.00

510.00

Invoice# 214594

Page 4

legal research on res judicata to preclude individual
defendants from asserting affirmative defenses waived by
ReDigi
Mandel, Richard

29503

27.90

14,229.00

0.50

245.00

0.80

392.00

0.30

147.00

1.60

784.00

0.30
3.70

147.00
1,813.00

1.00

490.00

1.30

637.00

3.00

1,470.00

2.20

1,078.00

0.60

294.00

0.40
0.50
16.20

196.00
245.00
7,938.00

4.10

1,107.00

1.30

351.00

1.00

270.00

2.50

675.00

EMI Music

10/03/2013

JZK

10/09/2013

JZK

10/10/2013

JZK

10/11/2013

JZK

10/15/2013
10/17/2013

JZK
JZK

10/18/2013

JZK

10/23/2013

JZK

10/24/2013

JZK

10/25/2013

JZK

10/28/2013

JZK

10/30/2013
10/31/2013

JZK
JZK

10/10/2013

SPC

10/11/2013

SPC

10/14/2013

SPC

10/17/2013

SPC

Conference with R. Mandel re opposition brief and
statutory damages issues.
Review ReDigi officers' discovery requests and conference
with R. Mandel re same.
Conference with R. Mandel re discovery dispute; review
research re same.
Revise deficiency letter re new discovery requests; review
research re collateral estoppel; conference with S. Ceresia
re additional research on law of the case doctrine.
Review further correspondence re discovery dispute.
Meet with R. Mandel re discovery dispute; extended
meeting and conference with opposing counsel; revise and
edit joint discovery letter.
Conference with R. Mandel re first edits to discovery letter;
review defendants' reply in support of motion to dismiss.
Review 30(b)(6) topics and conference with R. Mandel re
response; revise and edit written objections to deposition
notice.
Conference with R. Mandel, A. McMullan and B. Cohen re
30(b)(6) deposition; research re preclusion; review letter to
Court re discovery.
Review opposing counsel's changes to joint letter; research
re same; meet with R. Mandel re same; conferences and
emails re subpoenas issued today.
Phone conference with R. Mandel and opposing counsel re
deposition objections; conference with R. Mandel re
discovery.
Conference with R. Mandel re discovery proposal.
Conference with R. Mandel re status of discovery.
King, Jonathan Z.
Conduct research regarding responses due after discovery
deadline; conduct research regarding privity and collateral
estoppel against principals of corporation; collect relevant
caselaw.
Conduct research regarding law of the case; collect relevant
caselaw.
Conduct further issue on law of the case and addition of
new parties; collect additional caselaw and review.
Conduct research regarding unclean hands and copyright
claims; collect relevant caselaw; prepare research summary
regarding law of the case and unclean hands and send to R.
Mandel and J. King.

29503

EMI Music

10/30/2013

SPC

10/31/2013

SPC

10/01/2013

JMN

10/02/2013
10/04/2013

JMN
JMN

10/18/2013

JMN

10/01/2013

NAC

10/02/2013

NAC

10/23/2013

NAC

10/24/2013

NAC

Invoice# 214594

Page 5

Conduct research regarding res judicata and waived
defenses.
Conduct additional research regarding res judicata and
waived defenses; prepare research summary and send to R.
Mandel and J. King.
Ceresia, Scott P.

0.80

216.00

1.10

297.00

10.80

2,916.00

0.20

43.00

0.10
0.30

21.50
64.50

0.30
0.90

64.50
193.50

2.00

440.00

1.00

220.00

2.80

616.00

1.50

330.00

7.30

1,606.00

63.10

$26,882.50

Filed acknowledgment of Service for Ossenmacher via
ECF.
Docketed ECF notice.
FIled Memo in Opposition to Motion to Dismiss via ECF.
Docketed ECF notice and calendared deadline.
Docketed ECF notices.
Noble, J. Martin (Managing Clerk)
RE: Cite check, shepardize and Bluebook Memo of Law in
Opposition to Individual Defendants' Motion to Dismiss
Plaintiff's First Amended Complaint.
RE: Cite check, shepardize and Bluebook Memo of Law in
Opposition to Individual Defendants' Motion to Dismiss
Plaintiffs' First Amended Complaint.
RE: Scan in additional CAP documents; Bates-number the
same; contact IT dep't re burning disks; create disk labels
for the same; print in-house file set (as per R. Mandel).
RE: Arrange for creation of files for Capitol Records
production; review and organize the same.
Chinda, Nart-Anong (Paralegal)
Current Services

EXPENSES

Current Expenses

Billing Summary
Total professional services

$26,882.50

Total expenses incurred
---------------

29503

EMI Music

Invoice# 214594

Total of new charges for this invoice

$28,332.15

Plus net balance forward

$52,107.39

---------------Total balance now due

$80,439.54

Page 6

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

December 5, 2013
Invoice# 216219 RSM
Our file# 29503 0003
Billing through 11/30/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

November 6, 2013

Payments received since last invoice

$80,439.54

21,723.12
----------------

Accounts receivable balance carried forward

$58,716.42

PROFESSIONAL SERVICES
11/01/2013 RSM Telephone conferences with B. Cohen, A. McMullan,
conferences with J. King re deposition issues; conference
call with C. Finkelstein, B. Cohen and J. King re potential
deposition; telephone conference with and email to J.
Pariser re status of RIAA subpoena and potential
deposition; telephone conference with J. Pizzirusso re
deposition issues; reviewed email from J. Pizzirusso re
proof of service on RIAA; emails to and from client re
status of negotiations on depositions
11/04/2013 RSM Telephone conferences with and emails to and from J.
Pizzirusso, A. McMullan re depositions and possible
extension; email to J. Pizzirusso re exhibits to complaint;

Hours
1.90

969.00

0.90

459.00

29503

EMI Music

11/05/2013

RSM

11/06/2013

RSM

11/07/2013

RSM

11/08/2013

RSM

11/11/2013
11/12/2013

RSM
RSM

11/13/2013

RSM

11/14/2013

RSM

Invoice# 216219

reviewed email from J. Pariser re RIAA subpoena;
conferences with J. King re depositions and summary
judgment motions
Telephone conferences with and emails to A. McMullan, B.
Cohen re discovery and chain of title issues; conferences
with J. King re same and draft letter to Court on summary
judgment motions; telephone conference with and email to
J. Pizzirusso re deposition schedule and letter to Court;
reviewing emails between RIAA and opposing counsel re
subpoena and deposition
Emails to and from opposing counsel, client re requested
extension and depositions; reviewing opposing counsel
letter re requested extension; drafting and revising response
letter to Court objecting to certain aspects of extension and
discovery sought; conferences with J. King, telephone
conference with B. Cohen re same; conferences with B.
Crawford re legal research for letter and reviewing same;
finalized and sent letter to Judge Sullivan
Reviewed letter from opposing counsel to Court; emails to
and from client re same; reviewing draft supplemental
initial disclosures and conferences with J. King re same
Telephone conference with and reviewed email from B.
Cohen re supplemental initial disclosures; revised,
finalized, executed and served supplemental initial
disclosures; email to opposing counsel re same; reviewed
and revised draft pre-motion letter re summary judgment;
emails to and from client re same
Drafting responses to document requests and interrogatories
Reviewing cite check of pre-motion letter and conference
with N. Chinda re same; revising pre-motion letter;
telephone conference with and email to B. Cohen re same,
chain of title evidence, deposition schedule; email to Judge
Sullivan's chambers enclosing pre-motion letter; reviewed
ReDigi and Ossenmacher and Rudolph pre-motion letters
Telephone conferences with and emails to and from B.
Cohen re ownership, depositions and pre-motion letters
submitted by defendants; reviewing additional registrations
to be produced; email and letter to opposing counsel
producing additional registrations; drafting response to
individual defendants' pre-motion letter and conferences
with J. King re responses to letters; research re NY laws on
private investigators
Drafting and revising pre-motion response to
Ossenmacher-Rudolph letter re summary judgment;
reviewing cases re constitutionality issue; reviewed and
revised draft response to ReDigi pre-motion letter;
conferences with J. King re legal research on same and
response letters; email to client re draft letters; email to B.

Page 2

0.80

408.00

2.80

1,428.00

0.50

255.00

0.80

408.00

3.80
1.00

1,938.00
510.00

2.00

1,020.00

2.20

1,122.00

29503

EMI Music

11/15/2013

RSM

11/18/2013

RSM

11/19/2013

RSM

11/20/2013

RSM

11/21/2013

RSM

11/22/2013

RSM

11/24/2013
11/25/2013

RSM
RSM

Invoice# 216219

Cohen re chain of title and possible CA filing
Reviewing Youtube decision on DMCA defense; telephone
conferences with and emails to and from B. Cohen; revising
and finalizing responses to ReDigi and individual
defendants' pre-motion letters and conferences with J. King
re same; email to Judge Sullivan's chambers with letter
responses; reviewed individual defendants' response to
Capitol pre-motion letter on summary judgment; emails to
client re same
Telephone conference with and emails to and from B.
Cohen re chain of title production and issues concerning
same, McMullan deposition; reviewing protective order re
same; reviewing spreadsheet re chain of title
Telephone conferences with B. Cohen, A. McMullan and
conferences with J. King re chain of title issues; reviewing
documents provided by client; conferences with N. Chinda
re production of same; detailed analysis and review of open
title issues; reviewing EMI Entertainment v. Karen case
Telephone conferences with B. Cohen, A. McMullan re
chain of title issues; conference call with B. Cohen and R.
Green re reviewing Tooth & Nail chain of title and status;
reviewing documents to be produced; conferences with N.
Chinda re same; email to opposing counsel re McMullan
deposition
Reviewing documents to be produced; conferences with N.
Chinda re same; telephone conference with A. McMullan re
issues concerning conference and scheduling; telephone
conference with and emails to and from B. Cohen re chain
of title issues; gathering, organizing and reviewing
materials for conference; reviewing pre-motion letters,
discovery letters and relevant cases re preparation for
conference
Preparation for conference, including review of cases and
telephone conference with B. Cohen; reviewing Court
orders re scheduling of status conference and cancellation
of post-discovery conference; telephone conference with N.
Giddings, conference with J. King re same; conference call
with N. Giddings and Judge Sullivan's clerk re status of
conference; emails to and telephone conference with B.
Cohen re cancellation of conference and next steps;
reviewing documents to be produced and conferences with
N. Chinda re same; letter to opposing counsel enclosing
additional documents
Reviewing documents to be produced
Reviewing documents to be produced; conferences with N.
Chinda re issues concerning same; letter to opposing
counsel enclosing responsive documents; telephone
conference with opposing counsel re discovery issues;

Page 3

1.50

765.00

0.50

255.00

4.60

2,346.00

3.80

1,938.00

5.60

2,856.00

3.30

1,683.00

2.50
2.30

1,275.00
1,173.00

29503

EMI Music

11/26/2013

RSM

11/27/2013

RSM

11/01/2013

JZK

11/04/2013

JZK

11/05/2013

JZK

11/06/2013

JZK

11/07/2013

JZK

11/08/2013

JZK

11/13/2013

JZK

11/14/2013

JZK

11/15/2013

JZK

11/19/2013

JZK

11/22/2013

JZK

11/01/2013

SPC

Invoice# 216219

emails to and from client re same
Reviewing documents to be produced; conferences with N.
Chinda, telephone conferences with and emails to and from
B. Cohen re same and chain of title issues; letter to
opposing counsel enclosing additional responsive
documents; email to opposing counsel re scheduling of
30(b)(6) deposition
Emails to and from opposing counsel, client re scheduling
of deposition; reviewing status of certificates of registration
produced and supplementing same; updating chain of title
chart; reviewing documents to be produced; letter to
opposing counsel enclosing additional documents
Mandel, Richard
Conference with R. Mandel re third party deposition;
review research re waived affirmative defenses; conference
re summary judgment motion as to affirmative defenses.
Conference with R. Mandel re deposition and summary
judgment letter.
Begin drafting pre-motion letter re summary judgment;
review ReDigi deposition re same.
Continue drafting pre-motion letter re individual liability;
review opposing counsel's proposed letter to Court seeking
extension; revise and edit responsive letter to Court.
Prepare supplemental initial disclosures and send to client;
conference with R. Mandel re same; review letter to Court
objecting to our submission.
Complete draft pre-motion letter re summary judgment;
conference with S. Ceresia re res judicata issues.
Review Redigi's and individual defendants' pre-motion
letters; begin research and drafting response to ReDigi
letter; conference with R. Mandel re response to individual
defendants letter.
Research re constitutional challenges to statutory damages
and innocent infringement reduction; complete responses to
ReDigi pre-motion letter; revise response to individual
defendants' pre-motion letter.
Review individual defendants' response to Capitol's pre
motion letter.
Conference with R. Mandel re ownership issues and
discovery to be produced.
Review Court's two orders; phone conference with ReDigi
counsel; conference with R. Mandel re supplemental
production, conference.
King, Jonathan Z.
Conduct research regarding revived waived defenses;
collect relevant caselaw.

Page 4

2.40

1,224.00

1.80

918.00

45.00

22,950.00

1.60

784.00

0.50

245.00

2.50

1,225.00

3.50

1,715.00

2.00

980.00

3.70

1,813.00

2.00

980.00

2.50

1,225.00

0.40

196.00

0.40

196.00

1.20

588.00

20.30

9,947.00

0.90

243.00

29503
11/08/2013

11/06/2013

EMI Music
SPC

BAC

11/24/2013

SSG

11/25/2013

SSG

11/26/2013

SSG

11/12/2013

NAC

11/14/2013

NAC

11/15/2013

NAC

11/19/2013

NAC

11/20/2013
11/21/2013

NAC
NAC

11/23/2013

NAC

11/24/2013

NAC

11/26/2013

NAC

11/27/2013

NAC

Invoice# 216219

Conduct research regarding res judicata and waived
counterclaims; collect relevant caselaw.
Ceresia, Scott P.
Conduct research regarding estoppel and laches defenses
for use in promotion letter; communicate in firm regarding
same.
Crawford, Bridget A.
Redact various agreements and documents in preparation
for document production.
Redact various agreements and documents in preparation
for document production.
Redact various agreements and documents in preparation
for document production.
Guldan, Sarah S. (Paralegal)
RE: Cite check, shepardize and Bluebook letter to Judge
Sullivan re pre-motion letter in connection with motion for
summary judgment.
RE: Retrieve parallel Westlaw cite for Complex Systems,
Inc. v. ABN Ambro Bank, N.V., 2013 U.S. Dist. LEXIS
155122 (S.D.N.Y. Oct. 25, 2013) as per R. Mandel.
RE: Cite check, shepardize, and Bluebook 1) Response
letter to ID pre-motion letter; and 2) Response letter to
ReDigi pre-motion letter on SJ.
RE: Discuss production of various corporate documents
with R. Mandel; print out documents for review by R.
Mandel; save and combine pdfs; Bates-number the same
(CAP 002088 - CAP 002271); print copyset for file.
RE: Redact various license agreements (folder group 1).
RE: Redact various license agreements (folder group 1);
add CA name change amendment to Capitol Christian
Music Group and various Tooth and Nail documents; save
and organize pdfs for production.
RE: Redact and review various license agreements (folder
group no. 1); prepare documents for production.
RE: Redact and review various agreements (folder group
no. 2 - dtd 11/21/2013); prepare documents for production.
RE: Redact various agreements (Reeves through Korn);
update pdf 1A, 1B, 1C, 2A, 2B (Gorillaz through Pre-72)
with changes including deletions and redactions; prepare
for production.
RE: Review and organize agreements (Caesars through
Korn); print out for R. Mandel's review; Bates-number the
same (CAP 004581 - CAP 005082); burn 2 CDs; give to S.
Lynch to send out.
Chinda, Nart-Anong (Paralegal)

Page 5
1.00

270.00

1.90

513.00

0.60

162.00

0.60

162.00

1.60

360.00

7.40

1,665.00

2.30

517.50

11.30

2,542.50

1.20

264.00

0.10

22.00

1.10

242.00

2.30

506.00

4.30
4.80

946.00
1,056.00

4.00

880.00

6.50

1,430.00

6.00

1,320.00

3.50

770.00

33.80

7,436.00

29503

EMI Music

Invoice# 216219
Current Services

EXPENSES

Current Expenses

Billing Summary
Total professional services

$43,550.50

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$44,845.55
$58,716.42

---------------Total balance now due

$103,561.97

Page 6
112.90

$43,550.50

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

January 13, 2014
Invoice# 217797 RSM
Our file# 29503 0003
Billing through 12/31/2013

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

December 5, 2013

Payments received since last invoice

$73,177.70

28,332.15
----------------

Accounts receivable balance carried forward

$44,845.55

PROFESSIONAL SERVICES
12/01/2013 RSM Reviewing materials re preparation for court hearing
12/02/2013 RSM Preparation for court hearing; travel to and from and
conducted hearing; conferences with J. King re same; email
to client re same; reviewing documents to be produced;
conferences with N. Chinda re same
12/03/2013 RSM Reviewed court order staying discovery pending disposition
of motion to dismiss; reviewing documents to be produced;
letter to opposing counsel enclosing additional documents
12/04/2013 RSM Reviewing documents to be produced; letter to opposing
counsel enclosing same; telephone conferences with B.
Cohen re chain of title issues
12/05/2013 RSM Reviewing documents to be produced; letter to opposing

Hours
1.00
5.60

510.00
2,856.00

0.70

357.00

0.90

459.00

0.80

408.00

29503

EMI Music

12/06/2013

RSM

12/09/2013

RSM

12/10/2013

RSM

12/11/2013

RSM

12/12/2013

RSM

12/16/2013

RSM

12/17/2013

RSM

12/18/2013

RSM

12/19/2013

RSM

12/20/2013

RSM

12/23/2013

RSM

Invoice# 217797

counsel enclosing additional documents; telephone
conferences with and emails to and from B. Cohen re chain
of title issues; reviewed email from J. Pizzirusso to RIAA
re subpoena
Reviewing documents to be produced; emails to and from
B. Cohen re chain of title issues
Reviewing documents to be produced; conferences with N.
Chinda re same; letter to opposing counsel enclosing
documents; emails to and from B. Cohen re miscellaneous
chain of title issues
Reviewing documents to be produced; conference with N.
Chinda re same; letter to opposing counsel enclosing
documents; emails to and from opposing counsel; detailed
review and analysis of chain of title chart and updating
information and open issues re same
Conference call with J. Pizzirusso, G. Adelman and J. King
re discovery issues; telephone conference with and emails
to and from A. McMullan re defendants' request to dismiss
Rudolph as defendant; telephone conference with B. Cohen
re ownership issues and status of document production;
continued review and analysis of ownership issues and
updating chain of title chart re same
Telephone conference with G. Adelman re settlement
concerning Rudolph; continued review and analysis of open
ownership issues and updating chart re same
Reviewing Sinatra agreements to be produced; conference
with N. Chinda re same; telephone conference with B.
Cohen re open ownership issues
Reviewing documents to be produced and conferences with
N. Chinda re same; letter to opposing counsel enclosing
documents; continued updating and revision of ownership
chart; telephone conferences with B. Cohen re ownership
issues
Reviewing transcript from court hearing; email to client re
same; conference with N. Chinda re document production;
email to opposing counsel enclosing omitted signature page
from agreement in document production; continued
updating ownership chart and reviewing open issues re
same
Updating ownership chart and information and reviewing
open issues re same
Emails to and from opposing counsel re redaction of
documents produced; reviewing Smashing Pumpkin
agreements; reviewing email from B. Cohen re Beatles
documents to be produced; emails to and conferences with
N. Chinda re document production; telephone conference
with B. Cohen re open ownership issues
Reviewing and analyzing Beatles ownership documents;

Page 2

1.20

612.00

1.20

612.00

4.40

2,244.00

2.80

1,428.00

1.60

816.00

0.80

408.00

2.80

1,428.00

3.30

1,683.00

1.00

510.00

0.90

459.00

1.20

612.00

29503

12/26/2013

EMI Music

RSM

Invoice# 217797

telephone conferences with B. Cohen re same and
ownership issues; conferences with N. Chinda re document
production; reviewing documents to be produced
Reviewing Pink Floyd license agreement; reviewing
documents to be produced; letter to opposing counsel
enclosing documents
Mandel, Richard

Page 3

0.50

255.00

30.70

15,657.00

12/02/2013

JZK

Attend hearing on discovery dispute and res judicata.
King, Jonathan Z.

2.50
2.50

1,225.00
1,225.00

12/23/2013

IVD

0.90

180.00

12/23/2013

IVD

Redacting Percentages, dollar amounts and units from
licensing agreements.
Scanning documents in preperation for filing.
Duran, Ignacio V. (Paralegal)

0.10
1.00

20.00
200.00

12/02/2013

NAC

0.90

198.00

12/03/2013

NAC

3.50

770.00

12/05/2013

NAC

2.30

506.00

12/09/2013

NAC

2.90

638.00

12/16/2013

NAC

1.00

220.00

12/17/2013

NAC

0.90

198.00

12/23/2013

NAC

3.30

726.00

14.80

3,256.00

49.00

$20,338.00

RE: Review and organize pdfs of scanned license
agreements (David Bowie - OK Go); Bates-number the
same (CAP 005083 - CAP 005727).
RE: Redact various license agreements (Pre-72 through
Yellowcard).
RE: Discuss review of license agreements to be produced
with R. Mandel (Pre-72, REM through Tanya Tucker);
Bates-number the same (CAP 006206 - CAP 006970); burn
2 copysets of CDs; scan in letter to file; sent the same via
fed ex.
RE: Save scanned redacted pdfs from Sunday batch; print
the same for R. Mandel's review; re-Bates-number CAP
006971 - CAP 007131; burn to disk to be sent out.
RE: Redact Sinatra agreements; scan in and Bates-number
(CAP 008144 - CAP 008182); review and print for R.
Mandel's review.
RE: Redact additional Korn agreement; scan in and
Bates-number (CAP 008183 - CAP 008215); review and
print for R. Mandel's review.
RE: Redact Smashing Pumpkins agreement; scan in
Beatles Harrison and Lennon agreements; scan in Smashing
Pumpkins agreement.
Chinda, Nart-Anong (Paralegal)

Current Services
EXPENSES

29503

EMI Music

Invoice# 217797

Current Expenses

Billing Summary
Total professional services

$20,338.00

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$24,968.34
$44,845.55

---------------Total balance now due

$69,813.89

Page 4

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

February 10, 2014
Invoice# 219312 RSM
Our file# 29503 0003
Billing through 01/31/2014

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

January 13, 2014

Payments received since last invoice

$69,813.89

44,845.55
----------------

Accounts receivable balance carried forward

$24,968.34

PROFESSIONAL SERVICES
01/02/2014 RSM Telephone conference with B. Cohen re issues concerning
production of Beatles agreements
01/13/2014 RSM Detailed review of chain of title chart re outlining potential
open issues; email to B. Cohen re Tooth & Nail copyright
assignment
01/14/2014 RSM Continuing outlining of open ownership issues and detailed
review of chain of title chart re same; emails to and from B.
Cohen
01/15/2014 RSM Emails to and from B. Cohen re Tooth & Nail assignment
and reviewing same
01/17/2014 RSM Drafting memo summarizing open ownership/chain of title
issues

Hours
0.20

104.00

1.00

520.00

1.20

624.00

0.20

104.00

1.80

936.00

29503

EMI Music

01/19/2014

RSM

01/22/2014

RSM

01/23/2014

RSM

01/24/2014

RSM

01/27/2014

RSM

01/28/2014

RSM

01/23/2014

01/23/2014

TK

NAC

Invoice# 219312

Email to B. Cohen re issue concerning Decemberists
recording
Drafting and revising memo re open ownership issues;
reviewing evidence re same
Conferences with N. Chinda and T. Kjellberg re obtaining
Word/Amy Grant assignment of copyright from Copyright
Office; continued reviewing chain of title issues and
documents re same; drafting memo re ownership issues
Reviewing schedule to Tooth & Nail copyright assignment;
emails to and from B. Cohen re dissolution of Tooth &
Nail; completing memo re open ownership issues
Telephone conference with B. Cohen re ownership issues;
finalized memo re issues concerning same and email to B.
Cohen enclosing same
Telephone conference with B. Cohen re After the Bombs
recording by Decemberists
Mandel, Richard
Confer with Ms. Chinda, correspond with Robert Roomian
re obtaining copies of documents recorded in Copyright
Office
Kjellberg, Thomas
RE: Discuss obtaining assignments re Amy Grant from
Copyright Office with T. Kjellberg.
Chinda, Nart-Anong (Paralegal)
Current Services

EXPENSES

Current Expenses
Billing Summary
Total professional services

$5,352.50

Total expenses incurred

Total of new charges for this invoice
Plus net balance forward

--------------$5,482.16
$24,968.34
----------------

Total balance now due

$30,450.50

Page 2
0.10

52.00

2.60

1,352.00

1.30

676.00

0.80

416.00

0.50

260.00

0.10

52.00

9.80

5,096.00

0.50

212.50

0.50

212.50

0.20

44.00

0.20

44.00

10.50

$5,352.50

29503

EMI Music

Invoice# 219312

Page 3

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

March 10, 2014
Invoice# 221198 RSM
Our file# 29503 0003
Billing through 02/28/2014

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

February 10, 2014

Payments received since last invoice

$30,450.50

0.00
----------------

Accounts receivable balance carried forward

$30,450.50

PROFESSIONAL SERVICES
02/03/2014 RSM Telephone conference with B. Cohen re Beatles ownership
documents
02/05/2014 RSM Reviewing additional Beatles agreements provided by
client
02/12/2014 RSM Reviewing information forwarded by B. Cohen re
Chrysalis; emails to and from B. Cohen re same and effect
on chain of title analysis
02/13/2014 RSM Emails to and from and telephone conference with B.
Cohen re evaluating chain of title issue concerning
Chrysalis Records Inc.
02/21/2014 RSM Reviewing RIAA memo analyzing ReDigi 2.0
02/22/2014 RSM Reviewed M. Montague memo on ReDigi patent, J. King

Hours
0.10

52.00

0.60

312.00

0.20

104.00

0.50

260.00

0.20
0.30

104.00
156.00

29503

02/26/2014

EMI Music

RSM

02/22/2014

JZK

02/24/2014

JZK

02/26/2014

JZK

02/10/2014

MM

02/14/2014

MM

02/16/2014

MM

02/23/2014

MM

02/04/2014

NAC

Invoice# 221198

email to client re ReDigi 2.0; emails to and from J. King re
same
Reviewing prior memo re ReDigi 2.0 in preparation for call
with client; conference with J. King re same; conference
call with J. King and B. Cohen re ReDigi 2.0
Mandel, Richard
Review M. Montague memo re ReDigi patents; review
RIAA memo re ReDigi 2.0; send email analysis of RIAA
memo to A. McMullan.
Meet with M. Montague re ReDigi patents; review and
revise patent memo.
Phone conference with B. Cohen and R. Mandel re Redigi
2.0; review memos analyzing same.
King, Jonathan Z.
study of ReDigi U.S. Patent No. 8,627,500 to assess
disclosed technique for "Copy-Less" technology
search for other patents/pending applications of ReDigi;
review of pending applications that describe copyless
transfer; preparation of memorandum regarding same
finalizing memorandum regarding ReDigi patenting
relevant to copyless transfer; forwarding to JZK
preparation of revised memo to include discussion of
copying/making available music file on user computer after
transfer to ReDigi server, as discussed in ReDigi
"redirection" patent application; forwarding to J. King
Montague, Mark
RE: Save various Beatles license agreements to I-drive for
possible production; print the same for R. Mandel's review.
Chinda, Nart-Anong (Paralegal)

Current Services
EXPENSES

Current Expenses
Billing Summary
Total professional services

$5,172.50

Total expenses incurred
--------------Total of new charges for this invoice
Plus net balance forward

$5,193.80
$30,450.50

Page 2

0.60

312.00

2.50

1,300.00

1.50

742.50

0.50

247.50

0.60

297.00

2.60

1,287.00

1.00

555.00

2.00

1,110.00

1.00

555.00

0.50

277.50

4.50

2,497.50

0.40

88.00

0.40

88.00

10.00

$5,172.50

29503

EMI Music

Invoice# 221198
----------------

Total balance now due

$35,644.30

Page 3

Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, NY 10036
[phone] Tel
[phone] Fax
www.cll.com
Wire Instructions
IDB Bank
511 Fifth Avenue, New York, NY 10017
Acct No.: 0371047
ABA No.: 026009768; Swift Code: IDBYUS33

April 11, 2014
Invoice# 223079 RSM
Our file# 29503 0003
Billing through 03/31/2014

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attn: Alasdair McMullan
SVP, Legal Affairs

ReDigi
Balance forward as of invoice dated

March 10, 2014

$10,675.96

Payments received since last invoice

0.00
----------------

Accounts receivable balance carried forward

$10,675.96

PROFESSIONAL SERVICES
03/11/2014 RSM Reviewing patent memo and RIAA memo re preparation
for call with RIAA; conference call with G. Borkowski of
RIAA, B. Cohen and J. King re ReDigi 2.0
Mandel, Richard

03/11/2014

JZK

Conference call with R. Mandel, B. Cohen and G.
Borkowski re ReDigi 2.0.
King, Jonathan Z.

Current Services
EXPENSES

Hours
0.80

416.00

0.80

416.00

0.70

346.50

0.70

346.50

1.50

$762.50

29503

EMI Music

Invoice# 223079

Current Expenses
Billing Summary
Total professional services

$762.50

Total expenses incurred
Total of new charges for this invoice
Plus net balance forward

--------------$776.22
$10,675.96
----------------

Total balance now due

$11,452.18

Page 2

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

July 02, 2014
Client:
029503
Matter:
000003
300871
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through May 31, 2014
HOURLY SERVICES
Date

Description of Services

Hours

Amount

05/28/2014

RSM

Reviewed email from client re comments for use with
Ossenmacher at IP subcommittee hearing; conference with J.
King re same; email to client re potential questions for
Ossenmacher.

0.3

$156.00

05/30/2014

RSM

Reviewed J. Ossenmacher hearing testimony; email to A.
McMullan re analyzing same.

0.8

$416.00

1.1

$572.00

Hours
1.1

Amount
$572.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

July 02, 2014
Client:
029503
Matter:
000003
300871
Invoice #:
Resp. Atty:
RSM
Page:
2

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$572.00

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$615.00
$776.22
($776.22)
$615.00

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

October 07, 2014
Client:
029503
Matter:
000003
307103
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through September 30, 2014
HOURLY SERVICES
Date

Description of Services

Hours

Amount

09/02/2014

RSM

Reviewed Court decision denying motion to dismiss; conference
with J. King re same; email to client re same and next steps.

0.4

$208.00

09/03/2014

JZK

Review Court's decision on motion to dismiss; meet with R.
Mandel re next steps.

0.4

$198.00

09/04/2014

JMN

Docketed ECF notice and calendared deadline.

0.2

$43.00

09/08/2014

JZK

Meet with R. Mandel re discovery dispute and possible motion for
summary judgment in ReDigi.

0.4

$198.00

09/08/2014

RSM

Telephone conference with B. Cohen re next steps in litigation;
emails to and from A. McMullan, conferences with J. King re
same; emails to and from opposing counsel re scheduling call to
address next steps and joint letter to court; email to G. Borkowski
updating on decision on motion to dismiss and possible follow up
on RIAA subpoena.

0.8

$416.00

09/10/2014

JZK

Meet with R. Mandel re all pending discovery disputes and
tomorrow's call with opposing counsel.

0.6

$297.00

09/10/2014

RSM

Reviewing and analyzing prior discovery disputes and requests;
outlining open issues re same in preparation for call with opposing
counsel; conference with J. King re reviewing issues and strategy
for call with opposing counsel.

1.8

$936.00

09/15/2014

JZK

Conference call with all counsel re letter to Court; meet with R.
Mandel re same.

0.5

$247.50

09/15/2014

RSM

Conference call with J. King and opposing counsel re joint letter,
next steps; follow up discussion with J. King re same; email to
client re next steps.

0.5

$260.00

09/16/2014

JZK

Conference with R. Mandel re letter to Court and include
defendants' proposed motion to reconsider; review prior letter re
discovery dispute and summary judgment motion; draft joint letter
to Court.

2.3

$1,138.50

October 07, 2014
Client:
029503
Matter:
000003
307103
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

09/16/2014

RSM

Telephone conferences with opposing counsel, conferences with
J. King and emails to and from client re motion for reconsideration,
possible extension of time to answer.

0.3

$156.00

09/17/2014

JZK

Review IDs' motion to reconsider and answer and circulate to
client.

1.0

$495.00

09/17/2014

RSM

Emails to and from client, email to opposing counsel re draft joint
letter to Court.

0.2

$104.00

09/17/2014

JMN

Docketed ECF notices and calendared deadline for opposiiton
papers to motion for reconsideration.

0.2

$43.00

09/19/2014

JZK

Review various revisions to letter to Court and meet with R.
Mandel re same; conference call with R. Mandel and B. Cohen.

1.0

$495.00

09/19/2014

RSM

Multiple emails to and from counsel for ReDigi and individual
defendants re draft lettter to Court; telephone conference with
individual defendants' counsel and conference call with J. King and
individual defendants' counsel re same; reviewing revised drafts of
joint letter to Court and revising same; conferences with J. King re
same; emails to B. Cohen and conference call with B. Cohen and
J. King re joint letter to court, issues on amending complaint;
finalized and sent joint letter to Court re next steps in litigation;
reviewed individual defendants' motion for reconsideration;
conferences with J. King re same.

2.5

$1,300.00

09/22/2014

JZK

Prepare pre-motion letter re amending complaint; begin
researching and drafting opposition to motion to reconsider.

4.5

$2,227.50

09/22/2014

RSM

Reviewing status of copyright ownership of all claimed recordings
re determining changes needed for second amended complaint;
prepared updated exhibit to complaint detailing owners and
deleting tracks no longer claimed; email to B. Cohen summarizing
chain of title issues to be resolved and other informatio needed for
second amended complaint; conferences with J. King re response
to motion for reconsideration.

2.8

$1,456.00

09/23/2014

JZK

Continue drafting opposition to motion to reconsider; conference
with R. Mandel re discovery disputes.

3.5

$1,732.50

09/23/2014

RSM

Reviewed Court order setting deadline for update on discovery
disputes; email to client re same; conferences with J. King re
reconsideration response and responses to discovery requests.

0.3

$156.00

09/24/2014

JZK

Meet with R. Mandel re possible motion to strike; complete first
draft of opposition to motion to reconsider.

1.0

$495.00

09/24/2014

RSM

Revising responses to interrogatories and document requests
served by individual defendants; reviewing and revising response
to motion for reconsideration; conferences with J. King re same,
potential motion to strike affirmative defenses; email to client re
reconsideration opposition; reviewed client comments re same.

1.8

$936.00

October 07, 2014
Client:
029503
Matter:
000003
307103
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

09/25/2014

JZK

Revise opposition to motion to reconsider and recirculate; revise
response to individual defendants' interrogatories and meet with R.
Mandel re same; review prior deposition testimony for purpose of
interrogatory response; conference call with A. McMullan, B.
Cohen and R. Mandel re ReDigi settlement options.

2.5

$1,237.50

09/25/2014

RSM

Reviewed revised brief in opposition to reconsideration motion;
conference call with J. King, B. Cohen and A. McMullan re
settlement.

0.5

$260.00

09/26/2014

JZK

Research re licensee standing to sue for patent infringement; meet
with R. Mandel re same.

1.2

$594.00

09/26/2014

RSM

Conferences with J. King re settlement and implications of
potential patent license from or to ReDigi; reviewing revised
interrogatory responses; email to client re draft discovery
responses; telephone conference with A. McMullan re same.

0.6

$312.00

09/29/2014

JZK

Research re applying injunction to successor and standing of
exclusive patent licensee; draft and send memo summarizing legal
principles and settlement options to A. McMullan.

3.0

$1,485.00

09/29/2014

RSM

Conferences with N. Chinda re cite check of brief in opposition to
reconsideraton; reviewed same and revised citations; telephone
conference with B. Cohen re additional changes to brief; revised
and finalized opposition brief; conferences with J. King re
settlement issues; reviewed emails to and from client re same.

0.7

$364.00

09/29/2014

NAC

RE: Cite check, shepardize and Bluebook Plaintiff's Memorandum
in Opp. to Individual Defendants' Motion for Reconsideration.

1.4

$308.00

09/30/2014

RSM

Executed and arranged for filing of opposition brief to
reconsideration motion; email to client re same; drafted letter to
Court enclosing courtesy copy of brief.

0.4

$208.00

09/30/2014

NAC

Efile brief in opposition to reconsideration matter.

0.2

$44.00

37.5

$18,350.50

Hours
21.9

Amount
$10,840.50

13.6

$7,072.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

NAC

Nart-Anong Chinda

1.6

$352.00

JMN

J. Martin Noble

0.4

$86.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

October 07, 2014
Client:
029503
Matter:
000003
307103
Invoice #:
Resp. Atty:
RSM
Page:
4
DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
PAY THIS AMOUNT

Credit Card Link:

$18,350.50

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$18,359.75
$18,359.75

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

November 06, 2014
Client:
029503
Matter:
000003
308845
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through October 31, 2014
HOURLY SERVICES
Date

Description of Services

Hours

Amount

10/01/2014

RSM

Telephone conference with B. Cohen re status of chain of title
research, discovery responses.

0.1

$52.00

10/02/2014

RSM

Telephone conferences with and emails to and from B. Cohen re
chain of title issues; reviewing files re same; reviewing revised
exhibit to amended complaint listing copyright owners.

0.6

$312.00

10/03/2014

RSM

Emails to and from B. Cohen re Chrysalis merger information;
reviewing certificate of merger re same; email to opposing counsel
re discovery disputes.

0.3

$156.00

10/06/2014

JZK

Review IDS' reply brief on motion to reconsider.

0.3

$148.50

10/06/2014

RSM

Reviewing corporate merger information re Virgin Records
Nashville; updating chain of title chart and exhibit to complaint;
telephone conference with and emails to and from B. Cohen re
chain of title, discovery responses.

0.4

$208.00

10/06/2014

NAC

RE: Docketed ECF notice and Docket No. 154.

0.2

$44.00

10/07/2014

RSM

Emails to and from B. Cohen re corporate information on new
plaintiffs, chain of title information; reviewed and revised draft letter
to Court re seeking permission to amend; email to client re draft
letter.

0.6

$312.00

10/07/2014

NAC

RE: Search document production for all Tooth and Nail
agreements (as per R. Mandel).

0.7

$154.00

10/08/2014

JZK

Conference with A. McMullan and R. Mandel re settlement term
sheet; conference with G. Adelman.

0.5

$247.50

10/08/2014

RSM

Conference call with A. McMullan and J. King re settlement;
conference call with A. McMullan and B. Cohen re chain of title
issues; drafting second amended complaint; reviewing and
analyzing status of chain of title documentation produced for
pre-1972 sound recordings.

2.8

$1,456.00

November 06, 2014
Client:
029503
Matter:
000003
308845
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

10/09/2014

JZK

Draft settlement term sheet and send to A. McMullan.

1.2

$594.00

10/09/2014

RSM

Numerous emails to and from B. Cohen re open chain of title
issues; reviewing additional documents provided by client in
connection with same; conferences with N. Chinda re additional
documents to be produced; email to client re draft second
amended complaint; reviewing draft settlement term sheet and
conference with J. King re revisions to same.

2.4

$1,248.00

10/09/2014

NAC

RE: Review Capitol document production for various docs
produced; add new docs to the documents-to-be-produced I-drive
folder.

0.6

$132.00

10/10/2014

JZK

Meet with R. Mandel re revising discovery responses and
negotiations with opposing counsel re same; draft additional
interrogatory responses.

1.3

$643.50

10/10/2014

RSM

Telephone conference with and emails to and from counsel for
individual defendants regarding discovery disputes, settlement;
emails to and from and telephone conferences with client re same;
conferences with J. King re discovery disputes and responses;
revising interrogaotry responses; emails to and from B. Cohen re
open chain of title issues.

2.6

$1,352.00

10/14/2014

RSM

Telephone conference with A. McMullan re settlement, discovery
responses; emails to and from B. Cohen, A. McMullan re discoveyr
responses.

0.4

$208.00

10/15/2014

RSM

Telephone conference with B. Cohen re reviewing open chain of
title issues; reviewing revisions to discovery responses; revising
and finalizing discovery responses; email to opposing counsel re
discovery responses; telephone conference with A. McMullan re
settlement, amendment.

2.7

$1,404.00

10/16/2014

RSM

Finalizing exhibit to second amended complaint re claimed
recordings and copyright ownership of same; revised draft letter to
Court re amendment; email to client re draft pleading, exhibit and
letter.

0.9

$468.00

10/17/2014

JZK

Review Court's order denying motion to reconsider; review ReDigi
markup of term sheet and conference with B. Cohen re same.

1.0

$495.00

10/17/2014

RSM

Reviewed Court decision denying motion for reconsideration; email
to client re same; reviewed client comments on draft letter to Court
on amendment; revised same; telephone conference with B.
Cohen re amended complaint, chain of title status; drafted joint
letter to Court re open discovery issues; email to client re same.

1.8

$936.00

10/17/2014

JMN

Docketed ECF notice.

0.2

$43.00

10/20/2014

RSM

Emails to and from B. Cohen re draft complaint and discovery
letter; email to opposing counsel re draft joint discovery letter.

0.3

$156.00

10/21/2014

JZK

Conference with B. Cohen re ReDigi term sheet.

0.4

$198.00

November 06, 2014
Client:
029503
Matter:
000003
308845
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

10/21/2014

RSM

Telephone conference with B. Cohen re revisions to second
amended complaint; finalized same; email to Court with letter
seeking pre-motion conference on motion to amend and attached
proposed pleading.

0.4

$208.00

10/22/2014

RSM

Reviewed opposing counsel's mark-up of joint letter; emails to and
from client, opposing counsel re same; revising joint letter re
addition of collateral estoppel/res judicata arguments and other
responsive points; finalized and sent letter to Court; emails to and
from opposing counsel, client re settlement; updated memo re
open chain of title issues and documents to be produced; email to
client re same.

3.0

$1,560.00

10/24/2014

RSM

Reviewed Court order setting conference; email to client re same;
reviewed defendants' responsive letter re motion to amend.

0.3

$156.00

10/27/2014

JZK

Review ReDigi letter opposing amended complaint.

0.3

$148.50

10/27/2014

RSM

Email to client re defendants' response to motion to amend.

0.1

$52.00

10/27/2014

JMN

Docketed ECF notices and calendared conference date.

0.2

$43.00

10/28/2014

RSM

Telephone conference with chambers re request for redline of
amended pleading; reviewed redline and email to chambers
transmitting same; telephone conference with and emails to and
from B. Cohen re open document production/chain of title issues
and status of same.

0.9

$468.00

10/29/2014

RSM

Reviewed Court order granting motion to amend; email to client re
same; finalized and executed second amended complaint;
arranged for filing of same; prepared Rule 7.1 statement for new
plaintiffs and arranged for filing of same; letter to Court enclosing
courtesy copy of new pleading.

0.8

$416.00

10/29/2014

JMN

Filed Second Amended Complaint and Rule 7.1 Statement via
ECF. Docketeed ECF notices and calendared deadline for reply to
Second Amended Complaint.

0.6

$129.00

10/30/2014

RSM

Reviewing email and spreadsheet re availaibility of deposit copies;
telephone conference with B. Cohen re same, production of
additional agreements; reviewing and analyzing additional
documents provided re chain of title; emails to and from B. Cohen
re same; conferences with N. Chinda re preparation of same for
production and reviewing document production.

1.8

$936.00

10/30/2014

NAC

RE: Redact various license agreements (Ennio Morricone,
Gomez, Kooks); Bates-number Bevis document, 3-28-07 Chrysalis
Merger, 12-28-99 Virgin Records Merger, IRS agreement and
redacted license agreements (CAP 008294 - CAP 008532); print
and organize for R. Mandel's review.

4.3

$946.00

10/31/2014

RSM

Reviewing additional documents to be produced re chain of title;
emails to and from B. Cohen re same, open chain of title issues;
conferences with and emails to N. Chinda re document production;
reviewing document production.

0.7

$364.00

10/31/2014

NAC

RE: Save various agreements (EMI America Records, 1/1/1992
Tom Cochrane Artist Agreement.

0.2

$44.00

November 06, 2014
Client:
029503
Matter:
000003
308845
Invoice #:
Resp. Atty:
RSM
Page:
4
HOURLY SERVICES
Date

Description of Services

10/31/2014

NAC

Hours

Amount

1.5

$330.00

37.4

$16,768.00

Hours
5.0

Amount
$2,475.00

23.9

$12,428.00

RE: Redact various license agreements; Bates-number the same
(CAP 008533 - CAP 008625).
Total Professional Services

TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

NAC

Nart-Anong Chinda

7.5

$1,650.00

JMN

J. Martin Noble

1.0

$215.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
PAY THIS AMOUNT

Credit Card Link:

$16,768.00

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$16,923.79
$18,359.75
$35,283.54

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

December 04, 2014
Client:
029503
Matter:
000003
310311
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through November 30, 2014
HOURLY SERVICES
Date

Description of Services

Hours

Amount

11/03/2014

RSM

Reviewed additional documents provided by client; conference
with N. Chinda re production of same; emails to and from B.
Cohen re deposit copies.

0.5

$260.00

11/03/2014

NAC

RE: Review and redact Caesar's Agreement; Bates-number (CAP
008626 through CAP 008631); print for review by R. Mandel.

0.4

$88.00

11/04/2014

RSM

Reviewing additional documents to be produced; emails to and
from B. Cohen re additional documents, timing of discovery to be
addressed at conference; reviewing emails re settlement;
gathering relevant materials for conference.

1.8

$936.00

11/05/2014

RSM

Reviewing deposit copies supplied by client; conferences with N.
Chinda re production of same; reviewing copies of documents to
be produced re same.

0.6

$312.00

11/05/2014

NAC

RE: Scan in various covers/backs of CDs from various artists;
Bates-number the same (CAP 008726 - CAP 008771); meet with
R. Mandel.

1.1

$242.00

11/06/2014

RSM

Reviewing email exchange between A. McMullan and J.
Ossenmacher re settlement; telephone conference with A.
McMullan re same and next steps; emails to and from opposing
counsel, B. Cohen re proposed discovery schedule; organizing
materials for court conference.

0.8

$416.00

11/07/2014

JZK

Attend ReDigi court conference.

2.0

$990.00

11/07/2014

RSM

Preparation for court conference, including review of letters, res
judicata case law and prior document production; email to and
telephone conference with A. McMullan re discovery issues in
preparation for conference; travel to and from Court; conduct
conference; email to client reporting re same.

4.0

$2,080.00

December 04, 2014
Client:
029503
Matter:
000003
310311
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

11/11/2014

RSM

Emails to and from opposing counsel, client re draft stipulation on
preserving right to appeal denial of motion to dismiss without
moving against new complaint; revised stipulation; emails to and
from and telephone conference with A. McMullan re same;
conference with S. Ceresia re legal research on res
judicata/collateral estoppel for upcoming briefs on affirmative
defenses.

0.4

$208.00

11/12/2014

RSM

Reviewing email from client and documents re Enigma recordings;
conference with N. Chinda re preparing same for production;
telephone conference with B. Cohen re status of production;
reviewed revised stipulation on answer; revised and executed
same; emails to and from client, opposing counsel re same.

0.7

$364.00

11/12/2014

NAC

RE: Redact various Enigma agreements; Bates-number the same
(CAP 008872 - CAP 008812); combine pdfs and print in-house
copyset for R. Mandel's review.

1.3

$286.00

11/13/2014

RSM

Reviewing document production; letter to counsel for defendants
enclosing additional responsive documents.

0.4

$208.00

11/13/2014

NAC

RE: Burn 3 disks of supplemental Capitol production (Bates No.
CAP 008294 - CAP 008812); review the same; create CD labels.

1.0

$220.00

11/14/2014

RSM

Updating chain of title chart with information reflecting
supplemental document production; reviewing remaining open
issues to be resolved.

1.8

$936.00

11/18/2014

RSM

Continuing update of chain of title chart with information from
supplemental document production.

1.0

$520.00

11/28/2014

JZK

Emails with A. McMullan re settlement issues.

0.4

$198.00

18.2

$8,264.00

Hours
2.4

Amount
$1,188.00

12.0

$6,240.00

3.8

$836.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

NAC

Nart-Anong Chinda

DISBURSEMENTS
Date

Description of Disbursements

Amount

December 04, 2014
Client:
029503
Matter:
000003
310311
Invoice #:
Resp. Atty:
RSM
Page:
3
DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
PAY THIS AMOUNT

Credit Card Link:

$8,264.00

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$8,384.62
$35,283.54
$43,668.16

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

January 08, 2015
Client:
029503
Matter:
000003
311868
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through December 31, 2014
HOURLY SERVICES
Date

Description of Services

Hours

Amount

12/01/2014

JZK

Phone conference with R. Mandel and G. Adelman; follow-up call
with A. McMullan.

1.0

$495.00

12/01/2014

RSM

Conference call with J. King and G. Adelman re settlement;
conferences with J. King re same; reviewed emails from client re
same.

0.7

$364.00

12/02/2014

JZK

Conference with G. Adelman re ReDigi settlement proposal and
conference with R. Mandel re same; review draft proposal and
send to A. McMullan.

0.4

$198.00

12/02/2014

RSM

Telephone conference with B. Cohen re status; reviewed
settlement proposal from G. Adelman; conferences with J. King re
same; reviewed A. McMullan response re settlement.

0.4

$208.00

12/03/2014

JMN

Docketed ECF notices and calendared transcript deadlines.

0.2

$43.00

12/05/2014

JZK

Review papers re res judicata.

0.6

$297.00

12/05/2014

RSM

Reviwed defendants' brief re res judicata issue; email to client re
same; conference with S. Ceresia re research for response.

0.6

$312.00

12/08/2014

RSM

Reviewing and analyzing defendants' brief and cases cited by
defendant on res judicata; reviewing additional case law on res
judicata; conferences with J. King re opposition to brief and
outlining same.

2.8

$1,456.00

12/09/2014

RSM

Telephone conference with B. Cohen re settlement; conference
with J. King re same; conferences with S. Ceresia re research on
res judicata issues; reviewing and researching cases on unclean
hands, laches and estoppel/waiver/consent defenses; drafting
section of brief addressing merits of such affirmative defenses.

2.4

$1,248.00

12/09/2014

SPC

Begin conducting research on res judicata argument regarding two
actions.

0.7

$199.50

January 08, 2015
Client:
029503
Matter:
000003
311868
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

12/10/2014

SPC

Continue researching arguments regarding res judicata and
collateral estoppel.

0.8

$228.00

12/11/2014

RSM

Conferences with S. Ceresia re legal research for brief and
reviewing same; drafting Mandel declaration re res judicata
motion; reviewing and selecting exhibits to Mandel declaration.

2.0

$1,040.00

12/11/2014

SPC

Further research res judicata and collateral estoppel argument;
review collected research; begin drafting brief section regarding
same.

3.0

$855.00

12/12/2014

SPC

Continue drafting section of brief regarding res judicata, collateral
estoppel and law of the case; conduct research regarding due
process argument and review collected research.

5.7

$1,624.50

12/14/2014

SPC

Continue working on brief sections regarding preclusion and due
process; review and revise.

2.2

$627.00

12/15/2014

RSM

Reviewed legal research and draft sections for brief prepared by S.
Ceresia; drafting and revising brief re res judicata.

7.5

$3,900.00

12/15/2014

SPC

Finalize draft of brief sections and send to R. Mandel for review.

0.7

$199.50

12/15/2014

NAC

RE: Retrieve Aid for Women v. Foulston westlaw cite (2005 US
Dist. LEXIS 8420, D. Kan. 2005) and EEOC v. First Nat'l Bank of
Memphis westlaw cite (1978 US Dist. LEXIS 13740, W.D. Tenn.
1977) for R. Mandel.

0.4

$88.00

12/16/2014

JZK

Settlement conversation with G. Adelman and emails re same;
review and revise brief re res judicata; draft preliminary statement
for brief; meet with R. Mandel re same.

2.5

$1,237.50

12/16/2014

RSM

Conferences with J. King re settlement discussion with G.
Adelman brief on res judicata; reviewed email re same; completed
drafting and revising brief re res judicata/affirmative defenses;
revising Mandel declaration; conferences with S. Ceresia re legal
research; email to client re draft brief; conference with and emails
to and from re status of ReDigi appointment of agent under DMCA.

4.5

$2,340.00

12/16/2014

TXK

Confer with RSM; research Copyright Office Directory of Service
Provider Agents for entry for ReDigi Inc.

0.4

$170.00

12/16/2014

NAC

RE: Cite check, shepardize and Bluebook Plaintiff's Memo of Law
re Application of Res Judicata to Individual Defendant's Affirmative
Defenses.

3.3

$726.00

12/17/2014

RSM

Reviewing cite check of brief and affirmances of various cases
cited; revising brief re same.

1.0

$520.00

12/17/2014

NAC

RE: Check for various Westlaw cites for cases referenced in
Plaintiff's Brief re Res Judicata; retrieve hard copies for Tap
Holdings, Denton, Obabueki, and Price cases; check Peer Int'l
Corp. v. Luna Records cite (as per R. Mandel).

1.5

$330.00

12/18/2014

JZK

Conference with R. Mandel re further caselaw or res judicata.

0.4

$198.00

January 08, 2015
Client:
029503
Matter:
000003
311868
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

12/18/2014

RSM

Reviewing and revising brief; conferences with J. King re same;
selecting relevant exhibits, including deposition excerpts; reviewing
exhibits; reviewing deposition confidentiality designations in
connection with filing; reviewing and revising table of authorities
and contents to brief; telephone conference with B. Cohen re
revisions to brief; email to client re Mandel declaration; revising
and finalizing same; conference with J. King and A. McMullan re
reviewing settlement issues.

4.6

$2,392.00

12/19/2014

JZK

Phone conference with G. Adelman re ReDigi settlement.

0.3

$148.50

12/19/2014

RSM

Emails to and from and telephone conference with G. Adelman re
confidentiality of cited deposition transcripts; drafted letter to Court
re same and courtesy copies; reviewed redactions of confidential
deposition portions for public filing; finalized brief, declaration and
exhibits, courtesy and redacted copies; arranged for filing of brief
and declaration re res judicata issue and delivery of courtesy
copies re same.

2.8

$1,456.00

12/19/2014

JMN

FIled Memo of Law and Declaration of RSM via ECF.

0.4

$86.00

12/22/2014

RSM

Letter to Court enclosing copies of Lexis decisions cited in brief;
email to opposing counsel re same.

0.2

$104.00

12/23/2014

RSM

Reviewing status of open document production issues; email to B.
Cohen summarizing same; follow up email to G. Adelman re
confidentiality of deposition excerpts; reviewed individual
defendants' reply brief re res judicata; email to client re same.

0.9

$468.00

12/30/2014

RSM

Emails to and from G. Adelman re removal of confidentiality
designations on cited Ossenmacher testimony; conferences with
M. Noble re filing of amended declaration including all deposition
excerpts; letter to Court re same.

0.3

$156.00

12/30/2014

JMN

Filed Amended Declaration of RSM in Support of Memo of Law
and Letter to Judge Sullivan via ECF.

0.4

$86.00

55.6

$23,800.50

Hours
5.2

Amount
$2,574.00

30.7

$15,964.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

TXK

Thomas Kjellberg

0.4

$170.00

SPC

Scott P. Ceresia

13.1

$3,733.50

NAC

Nart-Anong Chinda

5.2

$1,144.00

JMN

J. Martin Noble

1.0

$215.00

January 08, 2015
Client:
029503
Matter:
000003
311868
Invoice #:
Resp. Atty:
RSM
Page:
4
DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$23,800.50

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
IDB Bank
Bank Name:
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$24,398.76
$43,668.16
($35,283.54)
$32,783.38

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

February 10, 2015
Client:
029503
Matter:
000003
313753
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through January 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

01/16/2015

JZK

Review prior settlement proposal; conference with A. McMullan
and G. Adelman.

1.0

$495.00

01/30/2015

RSM

Telephone conference with and reviewed email from B. Cohen re
additional chain of title evidence.

0.2

$104.00

1.2

$599.00

Hours
1.0

Amount
$495.00

0.2

$104.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

February 10, 2015
Client:
029503
Matter:
000003
313753
Invoice #:
Resp. Atty:
RSM
Page:
2

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$599.00

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$652.00
$32,783.38
($8,384.62)
$25,050.76

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

March 05, 2015
Client:
029503
Matter:
000003
315327
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through February 28, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/02/2015

RSM

Conference call with A. McMullan and J. King re settlement (.1);
reviewing emails from and documents provided by B. Cohen re
additional chain of title evidence -- Keren Ann, Royksopp, Sinead
O'Connor, Proclaimers, Damon Albarn, Kylie Minogue, Eliza
Doolittle, Danger Mouse, Chiddy Bang (.4).

0.5

$260.00

02/03/2015

JZK

Conference with B. Cohen and R. Pichler re transfer of settlement
agreement (.6); email to A. McMullan re same (.2).

0.8

$396.00

02/05/2015

JZK

Draft and circulate revised settlement term sheet.

1.0

$495.00

02/12/2015

JZK

Review A. McMullan edits to settlement proposal (.2); emails and
phone calls re same (.2).

0.4

$198.00

2.7

$1,349.00

Hours
2.2

Amount
$1,089.00

0.5

$260.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
PAY THIS AMOUNT

$1,349.00
$1,349.00
$25,050.76
$26,399.76

March 05, 2015
Client:
029503
Matter:
000003
315327
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

April 13, 2015
Client:
029503
Matter:
000003
317259
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through March 31, 2015
HOURLY SERVICES
Date

Description of Services

03/02/2015

JZK

Hours

Amount

0.3

$148.50

0.3

$148.50

Hours
0.3

Amount
$148.50

Emails re ReDigi settlement proposal (.2); send out revised
proposal to G. Adelman (.1).
Total Professional Services

TIMEKEEPER RECAP

JZK

Jonathan Z. King
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$148.50

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$148.50
$26,399.76
($24,398.76)
$2,149.50

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

May 12, 2015
Client:
029503
Matter:
000003
318782
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through April 30, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

04/01/2015

RSM

Emails to and from A. McMullan re status and next potential steps;
reviewing Judge Sullivan rules on motions in connection with
same.

0.1

$52.00

04/16/2015

JZK

Conference with G. Adelman re settlement and follow-up email re
same.

0.5

$247.50

0.6

$299.50

Hours
0.5

Amount
$247.50

0.1

$52.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$299.50
$299.50
$2,149.50
($652.00)
$1,797.00

May 12, 2015
Client:
029503
Matter:
000003
318782
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

June 08, 2015
Client:
029503
Matter:
000003
320361
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through May 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

05/18/2015

RSM

Follow up email to G. Adelman re status of settlement.

0.1

$52.00

05/27/2015

RSM

Follow up email to G. Adelman re settlement.

0.1

$52.00

05/29/2015

RSM

Reviewed settlement proposal from ReDigi and emails to and from
client re same.

0.2

$104.00

0.4

$208.00

Hours
0.4

Amount
$208.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$208.00
$208.00
$1,797.00
($1,349.00)
$656.00

June 08, 2015
Client:
029503
Matter:
000003
320361
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

July 08, 2015
Client:
029503
Matter:
000003
321918
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through June 30, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

06/03/2015

RSM

Reviewing and analyzing ReDigi settlement proposal re revisions
to last offer (.5); email to client re analyzing same (.4); follow up
emails to and from client re settlement and status of case (.2);
conference with J. King re settlement status and next potential
steps (.2).

1.3

$676.00

06/09/2015

JZK

Conference with A. McMullan and R. Mandel re settlement (.6);
conference with R. Mandel re settlement (.3); conference with G.
Adelman re settlement (.4).

1.3

$643.50

06/09/2015

RSM

Conference call with A. McMullan and J. King re settlement (.6);
conferences with J. King re follow up issues on same (.3).

0.9

$468.00

06/10/2015

RSM

Telephone conference with B. Cohen re settlement.

0.2

$104.00

06/12/2015

JZK

Conferences with R. Mandel and S. Gerson re securing ReDigi
settlement and injunction.

0.5

$247.50

06/12/2015

RSM

Conference with J. King re settlement (.2); conference with S.
Gerson and J. King re reviewing proposed UCC1 mechanism
proposed by ReDigi (.3); telephone conference with A. McMullan
re settlement (.3).

0.8

$416.00

06/12/2015

SG

Office Conference w/Richard Mandel and Jon King re: security
itnterest/UCC filing.

0.3

$178.50

06/29/2015

RSM

Telephone conference with A. McMullan re settlement (.1);
telephone conference with G. Adelman re settlement (.4).

0.5

$260.00

5.8

$2,993.50

Total Professional Services

July 08, 2015
Client:
029503
Matter:
000003
321918
Invoice #:
Resp. Atty:
RSM
Page:
2
TIMEKEEPER RECAP
Hours
1.8

Amount
$891.00

Richard Mandel

3.7

$1,924.00

Simon Gerson

0.3

$178.50

JZK

Jonathan Z. King

RSM
SG

Total Services
Total Current Charges
Previous Balance
PAY THIS AMOUNT

Credit Card Link:

$2,993.50

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$2,993.50
$656.00
$3,649.50

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

August 06, 2015
Client:
029503
Matter:
000003
323597
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through July 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

07/10/2015

RSM

Emails to and from G. Adelman re settlement.

0.1

$52.00

07/23/2015

RSM

Telephone conferences with G. Adelman, A. McMullan re
settlement.

0.5

$260.00

07/31/2015

RSM

Telephone conference with and email to G. Adelman re
settlement.

0.2

$104.00

0.8

$416.00

Hours
0.8

Amount
$416.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$416.00
$416.00
$3,649.50
($448.00)
$3,617.50

August 06, 2015
Client:
029503
Matter:
000003
323597
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

September 08, 2015
Client:
029503
Matter:
000003
325204
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through August 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

08/11/2015

RSM

Emails to and from G. Adelman re status of settlement.

0.1

$52.00

08/25/2015

RSM

Emails to and from G. Adelman re status of settlement.

0.1

$52.00

08/27/2015

JZK

Review Court opinion on individual defendants' waiver of
affirmative defenses.

0.3

$148.50

08/27/2015

RSM

Reviewed and analyzed court order rejecting individual defendants'
affirmative defenses (.3); email to client re same (.1).

0.4

$208.00

Total Professional Services

0.9

$460.50

Hours
0.3

Amount
$148.50

0.6

$312.00

TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$460.50
$460.50
$3,617.50
($208.00)
$3,870.00

September 08, 2015
Client:
029503
Matter:
000003
325204
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

October 06, 2015
Client:
029503
Matter:
000003
326700
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through September 30, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

09/02/2015

RSM

Telephone conference with G. Adelman re settlement, next steps
in litigation (.2); emails to and from J. Pizzirusso re joint letter to
Court (.1).

0.3

$156.00

09/03/2015

RSM

Telephone conference with G. Adelman re settlement, next
litigation steps.

0.2

$104.00

09/04/2015

RSM

Reviewed email from G. Adelman re settlement proposal (.2);
emails to and from client re same (.1); prepared summary
requested by client of prior settlement negotiations and reviewing
prior settlement communications in connection with same (1.2);
emails to and from G. Adelman, J. Pizzirusso re joint letter,
settlement (.2).

1.7

$884.00

09/08/2015

RSM

Telephone conference with A. McMullan re settlement, joint letter
to Court (.3); reviewed B. Cohen summary of settlement points
(.3); emails to and from and telephone conference with B. Cohen
re rsettlement position and revisions to settlement points summary
(.3); drafted joint letter to Court (.4); emails to and from counsel for
ReDigi, individual defendants re joint letter (.2); emails to and from
client re joint letter (.1).

1.6

$832.00

09/09/2015

RSM

Emails to and from opposing counsel re finalizing joint letter (.2);
email to Court re joint letter (.1); reviwewe Court order re extension
and email to client re same (.1).

0.4

$208.00

09/11/2015

RSM

Telephone conferences with G. Adelman (.1), A. McMullan (.2) re
settlement.

0.3

$156.00

09/17/2015

RSM

Telephone conference with opposing counsel re settlement.

0.2

$104.00

09/22/2015

RSM

Telephone conference with G. Adelman re settlement, next steps
in litigation (.3); email to all counsel re next litigation steps (.1).

0.4

$208.00

October 06, 2015
Client:
029503
Matter:
000003
326700
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

09/24/2015

RSM

Emails to and from G. Adelman and J. Pizzirusso re next steps in
litigation (.1); telephone conference with G. Adelman re settlement
(.2); emails to and from client, G. Adelman re settlement (.1).

0.4

$208.00

09/25/2015

RSM

Emails to and from client, opposing counsel re next steps in
litigation, settlement.

0.2

$104.00

09/28/2015

JZK

Conference call with R. Mandel and opposing counsel re
stipulation and remaining discovery.

0.4

$198.00

09/28/2015

RSM

Conference call with J. Pizzirusso, G. Adelman and J. King re next
steps in litigation (.4); email to client reporting re same (.2).

0.6

$312.00

09/29/2015

JZK

Draft letter to Court re parties' proposal for next stages of case
(1.0); conference with R. Mandel re proposed stipulation for
individual defendants' liability (.4).

1.4

$693.00

09/29/2015

RSM

Conference with J. King re preparation of joint letter to Court and
stipulation on individual liability (.4); reviewing draft joint letter (.1);
conference call with A. McMullan, B. Cohen and G. Adelman re
settlement (.5); telephone conference with A. McMullan re
follow-up on settlement (.3); telephone conference with B. Cohen
re chain of title status (.1); conference with J. King re settlement
(.1).

1.5

$780.00

09/30/2015

RSM

Revised draft joint letter to Court (.2); email to client re same (.1).

0.3

$156.00

9.9

$5,103.00

Hours
1.8

Amount
$891.00

8.1

$4,212.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$5,103.00
$5,103.00
$3,870.00
($2,993.50)
$5,979.50

October 06, 2015
Client:
029503
Matter:
000003
326700
Invoice #:
Resp. Atty:
RSM
Page:
3

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

November 04, 2015
Client:
029503
Matter:
000003
328203
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through October 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

10/02/2015

RSM

Telephone conference with B. Cohen re draft joint letter (.1);
conference with J. King re same (.1); revised letter and emails to
and from J. Pizzirusso re same (.2); emails to and from G.
Adelman, email to client re settlement (.1).

0.5

$260.00

10/04/2015

RSM

Reviewing and analyzing status of chain of title evidence re
potential supplementing of document production.

0.6

$312.00

10/05/2015

RSM

Reviewing and analyzing chain of title on recordings re identifying
open discovery issues (2.0); memo to client re updating open
chain of title questions (.6); email to B. Cohen re same (.2).

2.8

$1,456.00

10/07/2015

RSM

Email to opposing counsel re joint letter to Court.

0.1

$52.00

10/08/2015

JZK

Review proposed changes to letter to Court and emails re same.

0.2

$99.00

10/08/2015

RSM

Reviewed proposed revisions to joint letter from other counsel (.2);
conferences with J. King, emails to and from other counsel re
same (.2).

0.4

$208.00

10/09/2015

JZK

Review and revise letter to Court (1.0); conference and emails with
B. Cohen, R. Mandel and opposing counsel re letter to Court (.7).

1.7

$841.50

10/09/2015

RSM

Reviewing additional proposed revisions to joint letter from other
counsel (.3); conferences with J. King re same (.3); conference
call with J. King and J. Pizzirusso re proposed revisions (.2);
conference call with J. King and B. Cohen re proposed revisions
(.2); revised and finalized letter and emails to and from other
counsel re same (.5); email to Court re joint letter (.1).

1.6

$832.00

10/13/2015

RSM

Reviewed court order re scheduling of trial and other deadlines
(.2); email to client re same (.1); email to G. Adelman re settlement
status (.1).

0.4

$208.00

November 04, 2015
Client:
029503
Matter:
000003
328203
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

10/14/2015

RSM

Emails to and from opposing counsel re status of stipulation,
discovery (.1); telephone conference with and emails to and from
B. Cohen re chain of title issues (.3); reviewing agreements for
Chiddy Bang, Danger Mouse, E. Doolittle, K. Ann; K. Minogue,
Royksopp, The Good, The Bad & The Queen, S. O'Connor, The
Proclaimers for relevant provisions on ownership to be produced
(1.6).

2.0

$1,040.00

10/15/2015

RSM

Reviewing Coldplay 2007 agreement for production re ownership
issues (.4); email to B. Cohen re follow up issues re Coldplay chain
of title (.2); reviewing B. Seger agreement re ownership of pre
1972 recordings (.4); conferences with N. Chinda re production of
agreements on chain of title (.3).

1.3

$676.00

10/15/2015

NAC

RE: Review and prepare various agreements for production
(Chidera, Mouseworks, Eliza Caird, Zeidel) (1.6); conferences with
R. Mandel re same (.3).

1.9

$418.00

10/16/2015

JZK

Review proposed stipulation for individual defendants (.3);
conference with R. Mandel and opposing counsel re same (.6).

0.9

$445.50

10/16/2015

RSM

Reviewing draft stipulation re waiver of individual liability (.3);
conferences with J. King re analyzing same and miscellaneous
issues with draft (.3); conference call with J. King and N. Giddings
re disagreements on draft stipulation (.3); emails to and from
opposing counsel re draft stipulation (.2); conferences with N.
Chinda re supplemental document production (.2).

1.3

$676.00

10/16/2015

IVD

Finalize documents to produce.

0.4

$72.00

10/16/2015

NAC

RE: Review/prepare various agreements for production (Bates
Nos. CAP 008813 - CAP 008864).

1.6

$352.00

10/19/2015

JZK

Review revised stipulation and meet with R. Mandel re same.

0.6

$297.00

10/20/2015

RSM

Reviewing revised draft stipulation on individual liability preparred
by N. Giddings (.2); revised draft stipulation (.2); conferences with
J. King re issues concerning revisions to stipulation (.3); email to
client re revised stipulation (.1).

0.8

$416.00

10/21/2015

JZK

Emails re revisions to stipulation re individual defendants liability.

0.2

$99.00

10/21/2015

RSM

Telephone conference with and reviewed email from B. Cohen re
stipulation on individual liability (.1); emails to and from opposing
counsel re same (.2).

0.3

$156.00

10/26/2015

RSM

Emails to and from defendants' counsel re stipulation on individual
liability (.1); email to G. Adelman re settlement (.1); reviewing
status of open chain of title issues (.4); email to B. Cohen
summarizing same (.4).

1.0

$520.00

10/28/2015

RSM

Reviewed revised stipulation re individual liability (.1); email to
client re same (.1); revised stipulation and email to opposing
counsel re same (.1).

0.3

$156.00

10/30/2015

RSM

Emails to and from N. Giddings re execution of stipulation on joint
liability (.2); email to Judge Sullivan's chambers re stipulation on
individual liability (.1).

0.3

$156.00

November 04, 2015
Client:
029503
Matter:
000003
328203
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

21.2

$9,748.00

Hours
3.6

Amount
$1,782.00

13.7

$7,124.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

NAC

Nart-Anong Chinda

3.5

$770.00

IVD

Ignacio V. Duran

0.4

$72.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$9,748.00

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$9,765.50
$5,979.50
($416.00)
$15,329.00

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

December 07, 2015
Client:
029503
Matter:
000003
329985
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through November 30, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

11/02/2015

RSM

Reviewed court order approving stipulation on individual liability;
email to client re same.

0.1

$52.00

11/04/2015

RSM

Reviewed email from N. Giddings and enclosed draft motion
papers re withdrawal as counsel (.2); emails to and from client,
opposing counsel re same (.1).

0.3

$156.00

11/05/2015

RSM

Reviewed court order re withdrawal of individual defendants'
counsel.

0.1

$52.00

11/06/2015

RSM

Reviewed court order re changed trial date (.1); emails to and from
and telephone conference with A. McMullan, telepohone
conference with G. Adelman re same and seeking to change date
(.3).

0.4

$208.00

11/10/2015

RSM

Emails to and from opposing counsel re trial adjournment.

0.1

$52.00

11/11/2015

RSM

Reviewed draft letter from opposing counsel re trial adjournment
(.1); drafted additional section for letter (.2); telephone conference
with opposing counsel, email to J. King re draft letter (.1).

0.4

$208.00

11/12/2015

JZK

Revise letter to Court re trial schedule.

0.3

$148.50

11/12/2015

RSM

Reviewed J. King revisions to draft letter to Court and email to
opposing counsel re same (.1); reviewed revised version of letter
from opposing counsel (.1).

0.2

$104.00

11/13/2015

RSM

Emails to and from and telephone conference with opposing
counsel re finalizing letter to Court (.1); reviewed final version of
letter and Court order granting adjournment of re-set trial date (.1).

0.2

$104.00

11/16/2015

RSM

Email to client re order on trial date (.1); emails to and from
opposing counsel re same (.1).

0.2

$104.00

11/18/2015

RSM

Telephone conference with S. Matz re confirmatio of trial schedule.

0.1

$52.00

December 07, 2015
Client:
029503
Matter:
000003
329985
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

11/24/2015

RSM

Reviewed excerpts from earlier Coldplay agreement forwarded by
B. Cohen (.2); conferences with N. Chinda re supplementing
document production and reviewed documents to be produced
(.3).

0.5

$260.00

11/24/2015

NAC

RE: Review Coldplay agreements for production and redaction.

1.6

$349.94

11/30/2015

RSM

Telephone conference with G. Adelman re settlement, damage
discovery.

0.2

$104.00

4.7

$1,954.44

Hours
0.3

Amount
$148.50

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

2.8

$1,456.00

NAC

Nart-Anong Chinda

1.6

$349.94

Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$1,954.44

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$1,954.44
$16,026.93
($5,563.50)
$12,417.87

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

January 19, 2016
Client:
029503
Matter:
000003
331829
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through December 31, 2015
HOURLY SERVICES
Date

Description of Services

Hours

Amount

12/01/2015

RSM

Reviewing additional chain of title documents to be produced (.4);
email and letter to G. Adelman re production of same (.2).

0.6

$312.00

12/04/2015

RSM

Email to G. Adelman re settlement.

0.1

$52.00

12/15/2015

RSM

Emails to and from G. Adelman re settlement, discovery.

0.1

$52.00

12/17/2015

RSM

Email to B. Cohen re status of open chain of title issues.

0.1

$52.00

12/18/2015

RSM

Reviewing and analyzing discovery, chain of title issues re
preparation for call with G. Adelman (1.0); email to B. Cohen re
chain of title issues on S. O'Connor and Proclaimers (.2);
telephone conference with G. Adelman re settlement, discovery
and trial issues (.5); conference with J. King re trial strategy and
discovery (.3).

2.0

$1,040.00

2.9

$1,508.00

Hours
2.9

Amount
$1,508.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$1,508.00
$1,508.00
$11,719.94
($9,765.50)
$3,462.44

January 19, 2016
Client:
029503
Matter:
000003
331829
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

February 08, 2016
Client:
029503
Matter:
000003
333095
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through January 31, 2016
HOURLY SERVICES
Date

Description of Services

Hours

Amount

01/08/2016

RSM

Telephone conference with A. McMullan re settlement, trial.

0.2

$108.00

01/11/2016

RSM

Telepohone conference with G. Adelman, telephone conference
with G. Adelman re settlement, discovery (.8); telephone
conferences with B. Cohen re settlement, discovery (.5); email to
G. Adelman re discovery on chain of title (.2).

1.5

$810.00

01/13/2016

RSM

Reviewing open chain of title issues to be finalized in discovery
(.4); telephone conference with and email to A. McMullan re
settlement (.3); telephone conference with G. Adelman re
settlement (.3).

1.0

$540.00

01/19/2016

RSM

Telephone conference with G. Adelman re settlement (.3);
conference with A. McMullan re settlement, trial (.5).

0.8

$432.00

01/20/2016

RSM

Telephone conference with G. Adelman re settlement (.2);
telephone conference with B. Cohen re same (.1); emails to and
from A. McMullan, G. Adelman re settlement discussions (.2);
reviewing label copy document forwarded by B. Cohen re possible
production on chain of title (.2); email to B. Cohen re same (.1).

0.8

$432.00

01/21/2016

RSM

Emails to and from B. Cohen re settlement discussions and
drafting of agreement.

0.2

$108.00

01/27/2016

RSM

Telephone conference with G. Adelman re settlement, issues on
completion of discovery (.3); telephone conference with A.
McMullan re settlement discussions and status (.2); reviewing
settlement issues, ReDigi argument re offering for sale vs. sale
(.3); reviewing prior conference transcript re discussion of offer for
sale issue (.2); emails to and from G. Adelman re same (.1).

1.1

$594.00

01/31/2016

RSM

Reviewing prior settlement negotiations and summary for
preparation of draft settlement agreement (.5); begin drafting
settlement agreement (2.8); reviewing status of documents to be
produced re chain of title (.3); reviewing label copy documents to
be produced re chain of title (.2).

3.8

$2,052.00

February 08, 2016
Client:
029503
Matter:
000003
333095
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

9.4

$5,076.00

Hours
9.4

Amount
$5,076.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel

DISBURSEMENTS
Date

Description of Disbursements

Amount

Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
PAY THIS AMOUNT

Credit Card Link:

$5,076.00

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$5,342.08
$3,462.44
$8,804.52

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through February 29, 2016
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/01/2016

JZK

Meet with R. Mandel re settlement agreement and injunction (.5);
Revise injunction and agreement (.8).

1.3

$689.00

02/01/2016

RSM

Conference with S. Gerson re preparation of UCC provision in
settlement agreement (.3); conferences with J. King re issues
concerning settlement agreement and consent judgment and
revisions to same (.5); drafted consent judgment (1.4); revising
settlement agreement (.6).

2.8

$1,512.00

02/01/2016

SG

Draft security interest proviisions for settlement agreement (.9);
Conference with R. Mandel re: same (.3).

1.2

$714.00

02/02/2016

RSM

Conferences with S. Gerson re issues concerning guarantee and
security interest in settlement agreement (.4); reviewing and
revising draft provisions re guarantee and security interest (.9);
updating and supplementing settlement agreement re
cross-referenced provisions (.4); revising consent judgment (.2).

1.9

$1,026.00

02/02/2016

SG

Further revisions to Settlement Agreement re: guaranty provision
(.5); Review additional revisions by Richard Mandel (.1);
Telephone conference w/Richard Mandel re: issues relating to
"springing" guaranties (.4).

1.0

$595.00

02/03/2016

JZK

Conference with R. Mandel and opposing counsel re pretrial
submissions.

1.0

$530.00

02/03/2016

RSM

Reviewing documents to be produced re label copy and emails to
and from opposing counsel re same (.4); reviewing status of open
chain of title issues and outlining same (.9); preparation for
conference call with opposing counsel on open trial issues (.5);
conference call with G. Adelman, S. Matz and J. King re various
trial issues (.6); conference with J. King re follow-up on trial issues
and next steps (.4); reviewing and revising draft escrow agreement
and guarantee exhibits to settlement agreement (.4); email to
client re draft settlement agreement, status of issues re same and
next steps in litigation (.4).

3.6

$1,944.00

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/03/2016

SG

Draft Escrow Agreement and Springing Guaranty.

3.0

$1,785.00

02/04/2016

RSM

Reviewing and analyzing chain of title re Tooth & Nail recordings
(.8); drafting summary of Tooth & Nail recording status for use in
McMullan trial testimony or declaration (.7); reviewing and
analyzing EMI Christian Music Group copyright ownership issues
and chain of title (.7); drafting summary of same for use at trial or
in declaration (.6); reviewing and analyzing status of copyright
registrations in name of Capitol Records LLC, Capitol Records Inc
or Virgin Recrods America Inc. (.9); drafting summary of same for
trial or declaration on ownership (.6).

4.3

$2,322.00

02/05/2016

RSM

Reviewing and analyzing chain of title status on copyrights in
entities merged into Capitol (.8); prepared summary re same (.5);
reviewing and analyzing chain of title on exclusive licenses to
Capitol (.4); drafted summary re same (.2); reviewing and
analyzing chain of title on MEA inter-company exclusive licenses
(1.0); drafted summary re same (.6); emails to B. Cohen re
reviewing open chain of title issues to be resolved (.6).

4.1

$2,214.00

02/08/2016

JZK

Meet with R. Mandel (.5) and phone conference with A. McMullan
and B. Cohen (.5) re letter to Court and settlement.

1.0

$530.00

02/08/2016

RSM

Reviewing Judge Sullivan rules re requirements for pretrial order
(.2); begin drafting joint pretrial order and outlining information
needed for same (.8); reviewing first Ossenmacher deposition
transcript re designating portions for inclusion in joint pretrial order
(1.6); conferences with J. King re issues concerning preparation
for trial, preparation of joint pretrial order and next steps in litigation
(.5); conference call with A. McMullan, B. Cohen and J. King re
reviewing settlement status and trial prep strategy (.5).

3.6

$1,944.00

02/08/2016

SPC

Begin drafting jury instructions regarding statutory damages and
met with J. King re: same.

0.9

$279.00

02/09/2016

JZK

Draft letter to Court re settlement and discovery (1.0); review jury
charges and meet with S. Ceresia re same (.4); meet with R.
Mandel and revise settlement agreement draft (.7).

2.1

$1,113.00

02/09/2016

RJG

Confer with Richard Mandel re plan of dissolution and language
needed re: ownership of assets held by shareholder.

0.3

$147.30

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/09/2016

RSM

Telephone conference with B. Cohen re status of chain of title
open issues and documents to be collected (.3); reviewing
additional documents to be produced re label copy proof of
contents of recordings (.6); conferences with S. Lubin re
production of same (.2); emails to opposing counsel re production
of additional documents (.2); conference call with B. Cohen and J.
Brazil re status of Tooth & Nail LLC and potential dissolution (.3);
conference with R. Giordanella re effect of dissolution on
ownership of recordings (.3); email to client re same (.2); email to
client re prior assignment from Tooth & Nail to CCMG (.2); review
rules re assignment of right to sue for past infringements (.4);
telephone conference with B. Cohen re revisions to settlement
papers (.2); review client comments on draft settlement papers
(.3); revising consent judgment and settlement agreement and
conferences with J. King re same (1.0); emails to and from client
re revisions to settlement papers (.3); drafting master declaration
re chain of title evidence for use at trial or pre-trial motions (1.3).

5.8

$3,132.00

02/09/2016

SPC

Continue drafting jury instructions (1.5); review samples provided
by client (.3).

1.8

$558.00

02/09/2016

SZL

Reviewed documents to be produced (1.8); confer with R. Mandel
re: same (.2).

2.0

$440.00

02/10/2016

JZK

Designating Rudolph first transcript for trial (1.3); met with R.
Mandel re: same (.2).

1.5

$795.00

02/10/2016

RSM

Completed designations for first Ossenmacher deposition (.6);
emails to and from B. Cohen re settlement status (.1); continued
drafting chain of title master declaration (2.3); continued drafting
portions of joint pretrial order (.8); conferences with J. King re
Rudolph deposition designations (.2).

4.0

$2,160.00

02/11/2016

JZK

Review A. McMullan changes to settlement agreement and meet
with R. Mandel re same (1.0); Continue designating deposition
testimony for trial (.8).

1.8

$954.00

02/11/2016

RSM

Reviewed A. McMullan comments on revised settlement papers
(.2); conferences with J. King re same and potential issues
concerning securing of enhanced payment and revisions to
settlement agreement (.8); revised settlement agreement re
enhanced payment provision definitions and mechanisms,
confidentiality provision, payment terms (1.0); multiple emails to
and from client re revisions to settlement agreement and
settlement authority (.5); email to opposing counsel re draft
settlement agreement (.2); revising draft joint letter to Court (.2);
email to opposing counsel re draft joint letter to Court (.1);
conference with S. Ceresia re jury instructions (.2); email to
opposing counsel re production of additional documents on chain
of title (.2); telephone conference with B. Cohen re settlement
status and trial prep (.2); drafting and revising master declaration
re chain of title (1.8); begin outlining areas of A. McMullan direct
examination for trial (1.0).

6.4

$3,456.00

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
4
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/11/2016

SPC

Review and supplement jury instructions, including on issue of
ownership (1.2); conduct caselaw research on issue of ownership
(0.4); conference with R. Mandel re: jury instructions (0.2).

1.8

$558.00

02/12/2016

JZK

Prepare first draft of voir dire questions and met with R. Mandel re:
same (1.6); review first draft of jury instructions (.4).

2.0

$1,060.00

02/12/2016

RSM

Reviewing draft voir dire questions and conference with J. King re
same (.2); email and telephone call to opposing counsel re joint
letter to Court (.1); reviewing Ossenmacher second deposition
transcript re designating portions to be used at trial (1.0); drafting
and revising master declaration for trial or motion practice re
summary of all chain of title evidence and documents (3.8).

5.1

$2,754.00

02/12/2016

SPC

Further revise and edit jury instructions.

2.4

$744.00

02/15/2016

RSM

Reviewed email from opposing counsel and revised draft of joint
letter to Court (.2); revised joint letter to Court (.2); emails to and
from opposing counsel re status of letter and revisions to same
(.2).

0.6

$324.00

02/16/2016

JZK

Revising jury instructions (.7); revise changes to letter to Court (.3).

1.0

$530.00

02/16/2016

RSM

Reviewed defendants' proposed revisions to joint letter to Court
(.3); multiple emails to and from and telephone conferences with
opposing counsel re issues concerning same and finalizing joint
letter (.7); revised letter (.2); email to Judge Sullivan's chambers re
joint letter (.1); email to client re same and issues concerning
access of individual defendants to counsel only documents (.2);
email to client re summary of chain of title evidence (.2).

1.7

$918.00

02/16/2016

SPC

Update jury instructions to include instructions on nominal and
punitive damages.

1.3

$403.00

02/17/2016

RSM

Reviewing document productions made subsequent to withdrawal
of individual defendants' counsel (.3); email to J. Ossenmacher
and L. Rudolph re non-confidential documents previously
produced and status of confidentiality issue (.2).

0.5

$270.00

02/17/2016

RG

Research applicability of attorneys' eyes only designation to pro se
party.

1.1

$286.00

02/18/2016

JZK

Review Court's order re pretrial matters (.3); revise and draft
additional section of jury instructions and voir dire (2.7).

3.0

$1,590.00

02/18/2016

RSM

Reviewed court order re recordings at issue (.1); emails to and
from client re same (.1); emails to and from G. Adelman re
settlement status and issues on trial prep (.2); reviewed legal
research on production of attorney eyes only information to pro se
parties and conference with R. Ghiselli re same (.4); reviewed and
revised voir dire questions (.4); emails to and from client re same
(.2); conferences with J. King re revisions to voir dire and jury
instructions (.3).

1.7

$918.00

02/18/2016

RG

Research pro se party access to documents protected as
"attorneys' eyes only" (.7); conference with R. Mandel re: same
(.3).

1.0

$260.00

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
5
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/18/2016

SPC

Research question of mandatory nature of statutory damages
(1.0); prepare summary re: same (.4).

1.4

$434.00

02/19/2016

SPC

Revse & update jury instructions re: description of prior findings.

2.5

$775.00

02/20/2016

RSM

Email to individual defendants and ReDigi counsel re plaintiffs'
position on confidential attorneys eyes only documents.

0.3

$162.00

02/22/2016

JZK

Drafting and revising jury instructions.

2.5

$1,325.00

02/23/2016

JZK

Complete revising and drafting jury instructions.

2.2

$1,166.00

02/23/2016

RSM

Email to client re form dissolution for potential use with Tooth &
Nail dissolution (.2); reviewed and revised draft jury instructions
(.4); emails to and from client re draft jury instructions (.2);
telephone conference with and emails to and from A. McMullan re
settlement (.2).

1.0

$540.00

02/24/2016

JZK

Continue designating deposition testimony for trial.

1.0

$530.00

02/24/2016

RSM

Emails to and from B. Cohen re issues concerning Tooth & Nail
dissolution (.2); reviewing draft documentation re same (.2);
telephone conference with B. Cohen re Tooth & Nail dissolution,
Beatles chain of title and jury instructions (.2).

0.6

$324.00

02/25/2016

JZK

Complete designating second Rudolph deposition testimony for
pretrial order.

4.0

$2,120.00

02/25/2016

RJG

Telephone conference with client re documentation for dissolution
of entity (.2); draft proposed plan of dissolution language (.2).

0.4

$196.40

02/25/2016

RSM

Reviewing status of Beatles chain of title issues and reviewing
agreements re same (.4); conferences with N. Chinda re review of
Beatles agreements and redaction of confidential information (.2);
emails to B. Cohen re Beatles agreements to be produced and
missing information re same (.2); telephone conference with B.
Cohen re jury instruction revisions (.1); email to G. Adelman re
joint jury instructions and settlement (.2); conference call with S.
Gold, B. Cohen and R. Giordanella re issues concerning
dissolution of Tooth & Nail (.2); reviewed and revised draft
language re dissolution and emails to and from client re same (.3).

1.6

$864.00

02/25/2016

NAC

Review various license agreements for production and
confidentiality (Bates Nos. CAP 009028 - CAP 009177).

3.2

$720.00

02/26/2016

JZK

Phone conference with R. Mandel and G. Adelman re settlement.

0.4

$212.00

02/26/2016

RSM

Conference call with G. Adelman and J. King re settlement (.4);
telephone conference with A. McMullan re settlement status (.1);
telephone conference with B. Cohen re settlement, status of chain
of title evidence (.2); emails to and from client re advising on same
(.1); email to opposing counsel re production of Beatles
agreements (.2); email to Ossenmacher and Rudolph re
supplementing earlier non-confidential production (.1); conference
with J. King re in limine motions (.2).

1.3

$702.00

02/26/2016

SPC

Conduct research regarding motion in limine and innocent
infringement defense.

0.6

$186.00

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
6
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/27/2016

RSM

Reviewing and analyzing exhibits to be used at trial (2.0); drafting
and revising portions of pretrial order (.7); reviewing deposition
testimony of Ossenmacher and Rudolph re designated portions
and potential use on cross (.8).

3.5

$1,890.00

02/29/2016

JZK

Prepare draft stipulation (.3); phone conference with opposing
counsel re pretrial submission (.3); meet with R. Mandel re pretrial
order (.3).

0.9

$477.00

02/29/2016

RSM

Telephone conference with G. Adelman re status of settlement
(.1); email to client re same (.1); telephone conferences with and
emails to and from B. Cohen re chain of title issues (.2);
conferences with J. King re reviewing pretrial order draft and
revising same (.4); email to opposing counsel re draft pre-trial
order and voir dire (.2); conferences with N. Chinda re preparation
of exhibit list and exhibits for pre-trial order (.4); reviewed draft
stipulations for pretrial order (.3); review and selection of relevant
exhibits for use at trial and outlining same for pretrial order (2.5);
review of Rudolph deposition designations (.3).

4.5

$2,430.00

02/29/2016

SPC

Begin drafting motion in limine.

1.8

$558.00

02/29/2016

NAC

RE: Conference with R. Mandel re: preparation of exhibit list (.4);
begin drafting same (3.1).

3.5

$787.50

115.8

$55,853.20

Hours
0.7

Amount
$343.70

Total Professional Services
TIMEKEEPER RECAP

RJG

Robert J. Giordanella

JZK

Jonathan Z. King

25.7

$13,621.00

RSM

Richard Mandel

58.9

$31,806.00

SG

Simon Gerson

5.2

$3,094.00

SPC

Scott P. Ceresia

14.5

$4,495.00

RG

Ryan A. Ghiselli

2.1

$546.00

NAC

Nart-Anong Chinda

6.7

$1,507.50

SZL

Sandy Lubin

2.0

$440.00

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

March 21, 2016
Client:
029503
Matter:
000003
335573
Invoice #:
Resp. Atty:
RSM
Page:
7

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$55,853.20

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$56,119.90
$8,804.52
($1,954.44)
$62,969.98

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through March 31, 2016
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/01/2016

JZK

Review defendants' markup of settlement agreement and meet
with R. Mandel re same (1.2); conference call with R. Mandel and
opposing counsel re settlement (1.0); conference with R. Mandel,
B. Cohen and Bankruptcy counsel (.5); conference with A.
McMullan re settlement (.5).

3.2

$1,696.00

03/01/2016

RSM

Reviewing and analyzing opposing counsel's proposed revisions to
settlement agreement (.8); conferences with J. King re analyzing
same and potential response (.4); emails to and from client re
proposed revisions to agreement and potential response (.4);
conference call with G. Adelman, S. Andress and J. King re
negotiating and reviewing draft settlement agreement and
proposed revisions (1.0); conference call with J. King and A.
McMullan re reviewing settlement negotiations and next steps (.5);
conference call with bankruptcy counsel, J. King and B. Cohen re
reviewing bankruptcy issues in settlement (.5); emails to and from
client, bankruptcy counsel re issues concerning same (.5);
telephone conference with B. Cohen re chain of title issues on
Beatles and Tooth & Nail (.2); reviewing Beatles appendix 23
document and emails to and from B. Cohen re same (.2);
conferences with N. Chinda re issues concerning preparation of
exhibit list (.4); reviewing and revising exhibit list (.7); reviewing
and analyzing status of ownership in pre-1972 sound recordings
(2.7); emails to and from B. Cohen re issues concerning same (.2).

8.5

$4,590.00

03/01/2016

SPC

Conduct research regarding innocent infringement (1.0) review
relevant caselaw (.6).

1.6

$496.00

03/01/2016

NAC

Review plaintiffs' trial exhibits and prepare exhibit list (4.6);
conference with R. Mandel re: same (.4).

5.0

$1,125.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/02/2016

JZK

Review proposed changes to settlement agreement and emails re
same (1.5); revising settlement agreement and meet with R.
Mandel re same (2.5); phone conference with A. McMullan re
same (.5); phone conference with B. Cohen re same (.5); phone
conference with opposing counsel re same (1.0).

6.0

$3,180.00

03/02/2016

RSM

Reviewing email from bankruptcy counsel re additional advice on
settlement (.1); conferences with J. King and emails to and from
client re same, settlement strategy (.4); reviewing and revising
draft settlement agreement and conferences with J. King re same
(.6); email to client re draft agreement (.1); conference call with B.
Cohen and A. McMullan re terms of download deal (.4); emails to
and from J. King re same (.1); conferences with N. Chinda re
issues concerning selection and supplementation of trial exhibits
(.3); emails to and from B. Cohen re issues concerning chain of
title for Cochrane recordings and status of summary to be provided
to opposing counsel (.2); continued reviewing and revising exhibit
list (.6); continued review and selection of exhibits for trial (.7).

3.5

$1,890.00

03/02/2016

NAC

Review and prepare documents for use as plaintiffs' trial
exhibits(5.5); continue preparation of exhibit list (2.2).

7.7

$1,732.50

03/03/2016

JZK

Conference email with B. Cohen, R. Mandel re settlement
agreement and download deal (.5); revise and circulate revised
download deal (.5); revise settlement agreement to include
additional provision (1.0); phone conference with B. Cohen and A.
McMullan re settlement (1.0); emails and phone calls to opposing
counsel (1.0); prepare verdict form (1.5).

5.5

$2,915.00

03/03/2016

RSM

Conference calls with J. King and B. Cohen re download deal
terms and effect on settlement (.5); reviewing draft most favored
nation provisions from client (.3); telephone conference call with A.
McMullan re most favored nation provision and status of other
settlement issues (.4); revising stipulations re addition of
ownership stipulations, client comments (.6); emails to and from A.
McMullan re additional revisions to stipulations (.2); email to
opposing counsel re draft stipulations for pretrial order (.2);
reviewing additional documentation from client re change of name
to EMI Canada Group (.2); emails to and from client (.1), email to
opposing counsel re production of same (.1); reviewing and
analyzing additional documents re Edith Piaf chain of title (.3);
emails to and from B. Cohen re same (.2); finalized exhibit re
pre-1972 sound recordings claimed and support re back-up
documentation (.3); email to opposing counsel re same (.2);
telephone conference with B. Cohen re revisions to federal chain
of title exhibit (.3); revised same (.2); email to opposing counsel re
chain of title evidence (.2); reviewing, revising and finalizing
plaintiffs' exhibit list and supporting exhibits (1.6); reviewing
sample verdict forms (.2), telephone conference with A. McMullan
with R. Mandel re same (.2); reviewing draft verdict form (.2).

6.5

$3,510.00

03/04/2016

JZK

Conference with R. Mandel re verdict form and motion in limine
(1.1); conference with R. Mandel re and reviewing settlement
agreement (1.9).

3.0

$1,590.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/04/2016

RSM

Telephone conference with B. Cohen re verdict form, strategy for
stipulations on ownership and follow-up on E. Piaf chain of title
(.3); emails to and from B. Cohen re Ten Years After recordings
claimed and status of Chrysalis Productions (.2); reviewing and
revising exhibit list re addition of recently produced documents (.3);
emails to opposing counsel re exhibit list, stipulations on
ownership and additional documents on exhibit list (.2); reviewing
and analyzing prior summary judgment filings and opinion re
strategy for in limine motion on reliance on advice of counsel (.5);
conference with J. King re review of motion in limine strategy and
potential additional motion on ownership (.5); email to S. Ceresia
re preparation of draft in limine motions (.2); reviewing and revising
proposed verdict form and conferences with J. King re same (.6);
emails to and from client re proposed verdict form (.3); conference
call with A. McMullan and J. King re settlement issues and status
of agreement (.3); reviewed client comments on draft settlement
agreement (.3); reviewing and revising draft settlement agreement
and conferences with J. King re same (1.7); emails to and from A.
McMullan re revised settlement agreement (.3).

5.4

$2,916.00

03/04/2016

SPC

Work on motion in limine regarding willful infringement (1.7); begin
drafting motion in limine regarding advice of counsel defense (.7).

2.4

$744.00

03/05/2016

RSM

Revising settlement agreement per A. McMullan comments (1.0);
email to opposing counsel re revised agreement (.3); email to
client re status of ownership evidence and issues concerning
same and in limine motions (.4).

1.7

$918.00

03/06/2016

JZK

Review and revise motion in limine re willfulness.

1.0

$530.00

03/07/2016

JZK

Review and revise motions in limine re willfulness and privilege
(2.0); conference with opposing counsel re pretrial submission (.6).

2.6

$1,378.00

03/07/2016

RSM

Telephone conferences with and emails to opposing counsel re
status of settlement, pretrial papers (.3); reviewing Court's rules re
documentary evidence submission requirements in jury cases (.2);
email to opposing counsel re same (.2); emails to and from B.
Cohen re supplementing production with 2012 MEA side letter
between Virgin Records Ltd and EMI Records Ltd (.2); email to
opposing counsel producing additional MEA document (.2); emails
to opposing counsel re revisions to exhibit list, chain of title exhibit
(.2); drafting McMullan declaration in support of motion in limine re
ownership of recordings (3.5).

4.8

$2,592.00

03/07/2016

SPC

Review relevant caselaw re: notice and update motion in limine
accordingly.

2.2

$682.00

03/07/2016

NAC

Updating revising and reviewing plaintiffs' trial exhibits (3.0);
update exhibit list re: same (.5).

3.5

$787.50

03/08/2016

JZK

Conference call with R. Mandel and opposing counsel re pretrial
submission and settlement agreement (1.3); revising motion in
limine (1.0); preparing deposition excerpt summaries required by
Court (3.0).

5.3

$2,809.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
4
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/08/2016

RSM

Conference call with opposing counsel and J. King re settlement,
pretrial papers (1.3); emails to and from B. Cohen re chain of title
claim via Chrysalis Productions Limited and MEA side letters re
same (.3); reviewed additional documents re same and email to
oppoisng counsel re production of same (.3); reviewing in limine
motions on attorney advice, willlfulness and emails to and from
client re same (.3); conference call with opposing counsel and
Judge Sullivan's chambers re requirements on submission of trial
exhibits and deposition excerpts (.3); revised proposed verdict
form (.2); email to and from client re summarizing status of
stipulations on ownership and verdict form (.3); email to opposing
counsel re proposed verdict form (.1); conferences with N. Chinda
re reviewing findings on recordings offered for sale on ReDigi site
and reviewing evidence re same(.8); drafting and revising
McMullan declaration for in limine motion (2.6); email to client re
same (.1); reviewing cases for in limine ownership motion (.4);
drafting in limine motion re ownership (1.6).

8.6

$4,644.00

03/08/2016

NAC

Review updated pretrial order exhibits list (.1); confirm song titles
from Chain of Title Summary chart with P22 and P33 (.4); prepare
Matrix Exchange Agreement docs for production (Bates No. CAP
9184 -CAP 9188) (.1); conference with R. Mandel re: findings on
recordings charts (.4).

0.9

$202.50

03/09/2016

JZK

Review opposing counsel markup of jury instructions and phone
conference with opposing counsel re same (1.5); revise jury
charge (6.0); phone conference with M. Haddad and B. Cohen re
consent judgment and review draft of same with R. Mandel (.8);
settlement call with G. Adelman and S. Matz (.8).

9.1

$4,823.00

03/09/2016

RSM

Conference call with G. Adelman and J. King re settlement and
new proposal including right of appeal of summary judgment (.8);
emails to and from and telephone conferences with A. McMullan re
same and settlement strategy (.9); conference with N. Chinda re
production of Chrysalis name change document (.1); email to
opposing counsel re same, corrections to plaintiffs' trial exhibits
(.3); emails to and from A. McMullan re revisions to in limine
declaration on ownership (.4); follow up telephone conferences
with and emails to and from G. Adelman re negotiating potential
alternative settlement terms with continuing right of appeal (.8);
drafting terms of potential conditional final judgment for settlement
purposes (2.8); conferences with J. King and email to client re
same (.3); reviewing cite check for in limine motions (.2); revising
in liminte motion re ownership (.4); email to client re same (.1);
review defendants' proposed revisions to jury instructions (.4);
drafted additional jury instruction revisions on ownership (.2).

7.7

$4,158.00

03/09/2016

NAC

Cite check Plaintiffs' Motion in Limine (2.3); conference with R.
Mandel re: document production (.1); prepare certificate of
incorporation for Chrysalis Productions for production (Bates Nos.
CAP 9189 - CAP 9190) (.1); update and revise trial exhibits and list
(3.3).

5.8

$1,305.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
5
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/10/2016

JZK

Settlement call with G. Adelman and R. Mandel (.6); phone calls
and emails with opposing counsel re motion in limine (.5);
settlement negotiations with opposing counsel and conference with
A. McMullan re same (1.8); draft settlement term sheet (1.0);
reviewing depositions to prepare trial exhibits (.3); revise voir dire
per opposing counsel comments (1.0); revising jury instructions
and conference with opposing counsel and R. Mandel re same
(3.0).

8.2

$4,346.00

03/10/2016

RSM

Emails to and from client re additional revisions to pretrial paper,
settlement terms (.6); conference with A. McMullan re reviewing
McMullan declaration, settlement strategy (.7); conference calls
with J. King and opposing counsel re negotiating settlement terms
(.6); multiple telephone conferences with opposing counsel re
revisions to pretrial order and other filings (.8); reviewing
defendants' deposition designations and preparing objections and
cross-designations to same (2.4); reviewing defendants' exhibits
and preparing objections to same (1.4); drafting and revising
additional in limine motion re fair use and license (1.8); multiple
emails to and from opposing counsel re revisions to pretrial order
(.8); conference call with B. Cohen and M. Haddad re issues
concerning conditional judgment settlement (.4); reviewing and
revising propopsed settlement term sheet (.4); emails to and from
and telephone conference with A. McMullan re settlement term
sheet (.3); email to opposing counsel re settlement term sheet (.1);
reviewing opposing counsel revisions to jury instructions and
conferences with J. King re same (.8); reviewing revised jury
instructions (.6); revising pretrial order (.8).

12.5

$6,750.00

03/10/2016

NAC

Prepare summary of plaintiffs' trial exhibits and cross-references to
testimony (2.8); review and prepare plaintiffs' deposition excerpts
and defendants' deposition designations for use at trial (5.3).

8.1

$1,822.50

03/11/2016

JZK

Conference calls with R. Mandel and opposing counsel re pretrial
submission (1.0); revising jury instructions; reviewing research for
same; emails with opposing counsel re same (2.5); revising and
finalizing voir dire questions (.8); reviewing and revising proposed
verdict form (.5).

4.8

$2,544.00

03/11/2016

RSM

Multiple telephone conferences with and emails to and from
opposing counsel re revisions to jury instructions, verdict form,
pretrial order (1.4); conferences with N. Chinda re finalizing
pre-trial submissions and reviewing same (.8); emails to and from
and telephone conference with B. Cohen re final revisions to
papers (.5); letter to Jude Sullivan re pre-trial filings (.3); email to
Judge Sullivan's chambers re jury instructions, voir dire and verdict
form (.2); reviewing additional exhibits for objections (.4); revising
and finalizing pre-trial submissions (2.4).

6.0

$3,240.00

03/11/2016

SPC

Update citations to jury instructions.

1.4

$434.00

03/11/2016

NAC

Cite check jury instructions (2.8); review and prepare joint
proposed pretrial order, proposed jury instructions and voir dire
questions, proposed verdict forms and motion in limines for
service and filing (4.8).

7.6

$1,710.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
6
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/14/2016

JZK

Review Defendants' Pretrial Memorandum and begin drafting
responses to same.

1.5

$795.00

03/14/2016

RSM

Reviewed defendants' pretrial brief (.5); emails to and from client
re same (.2); reviewing Court order and rules re opposition to
pretrial brief arguments (.1); telephone conference with B. Cohen
re settlement status and issues (.2).

1.0

$540.00

03/15/2016

JZK

Draft portions of opposition to pretrial memorandum and
conference with R. Mandel re same.

4.0

$2,120.00

03/15/2016

RSM

Reviewing case law on assignment of right to sue for past
infringements (.6); drafted ownership section of response to
pre-trial memorandum (.9); reviewed and revised other sections of
response to pre-trial memorandum and conferences with J. King
re same (.5); emails to and from client re response to pre-trial
memo, settlement (.2); emails to and from opposing counsel re
settlement (.1).

2.3

$1,242.00

03/17/2016

JZK

Begin reviewing materials for Rudolph cross-examination,
including Jacobson expert declaration (.7); phone conference with
G. Adelman and R. Mandel (.5) and research re settlement and
appeal of court injunction (.5).

1.7

$901.00

03/17/2016

RSM

Reviewed and analyzed settlement counter-offer from opposing
counsel (.5); email to client re settlement counter-offer (.2);
conference call with J. King and G. Adelman re reviewing
settement counter-offer and issues re same (.5); telephone
conference with A. McMullan re response to settlement
counter-offer (.4); telephone conference with B. Cohen re
settlement status (.1); reviewing draft email to opposing counsel
and cases re appealability issue (.3); analyzing recordings offered
for sale and sold re preparation of proposed trial stipulation re
same (1.0).

3.0

$1,620.00

03/18/2016

JZK

Reviewing and annotating Rudolph declaration to prepare for cross
(2.1); conference with R. Mandel and A. McMullan re settlement
(.5); review response to motion in limine (.4).

3.0

$1,590.00

03/18/2016

RSM

Telephone conference with and emails to and from G. Adelman re
status of settlement discussions (.3); telephone conferences with
A. McMullan, B. Cohen and J. King re same (.5); telephone
conference with B. Cohen re revisions to pretrial memo opposition,
potential production of divestiture documents (.3); emails to and
from A. McMullan, B. Cohen re production of Warner assignment
documents (.2); revised and finalized pretrial memo opposition
(.7); letter to Judge Sullivan re courtesy copy of opposition (.2);
email to opposing counsel re same (.1); reviewing and revising
summary of recordings sold and offered for use as proposed
stipulation (.6); email to opposing counsel re proposed stipulation
(.2).

3.1

$1,674.00

03/19/2016

JZK

Continue annotating Rudolph prior testimony for cross (.8); draft
response to Defendants' submission of willfulness (1.5).

2.3

$1,219.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
7
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/19/2016

RSM

Reviewing and analyzing defendants' opposition to motion in limine
(.6); emails to and from client re issues raised regarding MEA (.2);
telephone conferences with B. Cohen re MEA issues (.3);
reviewing MEA agreements produced and additional documents
provided by client (.3); conference with J. King re
willfulness/innocence issue and reviewing draft of same for use in
reply on in limine motions (.3).

1.7

$918.00

03/20/2016

RSM

Reviewing McMullan deposition transcript re preparation of reply
papers on in limine motion (.7); reviewing status of prior document
production re in limine reply papers (.5); drafting McMullan reply
declaration re in limine motion (1.2); begin drafting Mandel reply
declaration re in limine motions (.4).

2.8

$1,512.00

03/21/2016

JZK

Settlement call with all parties (.6); Call with A. McMullan, R.
Mandel re settlement (.8); drafting sections of motion in limine
reply (.8).

2.2

$1,166.00

03/21/2016

RSM

Completed drafting Mandel reply declaration on in limine motion
(.7); emails to and from client re draft reply declarations (.3);
telephone conference with A. McMullan re draft declaration (.1);
revised McMullan reply declaration (.3); reviewing and analyzing
Warner divestiture agreement (.8); telephone conferences with B.
Cohen, A. McMullan and conference call with B. Cohen and S.
Carmel re Warner divestitutre agreement (.6); telephone
conferences with A. McMullan, J. King re settlement (.8);
telephone conference with and emails to and from G. Adelman re
settlement (.2); conference call with A. McMullan, J. King, J.
Ossenmacher, B. Carter and Mischon attorney re negotiating
settlement terms (.6); reviewing cases cited by defendants in
opposition to in limine motion and cases distinguishing same (1.0);
drafting portions of reply brief on use of in limine to dismiss
claims/defenses (2.0); reviewing and analyzing status of divested
vs. retained recordings (.6) and telephone conference with B.
Cohen re same (.2); reviewed Court order rescheduling pre-trial
conference and emails to and from opposing counsel, client re
same (.2).

8.4

$4,536.00

03/22/2016

JZK

Drafting section of reply in support of motion in limine and meet
with R. Mandel re same (1.3); conference with R. Mandel and G.
Adelman re settlement (.5).

1.8

$954.00

03/22/2016

RSM

Drafted ownership section of reply brief on motion in limine (.4);
reviewed and revised other sections of in limine reply brief and
conferences with J. King re same (.8); email to client re draft reply
brief on motion in limine (.1); reviewed cite check of in limine reply
brief (.2); reviewing and analyzing share purchase agreement and
separation agreement re confidentiality requirements and potential
redaction of information in agreements (.8); telephoone
conferences with B. Cohen, A. McMullan re same (.4); emails to
client re relevant confidentiality provisions and production of
documents re divestitutre (.4); conference call with J. King and G.
Adelman re settlement (.5).

3.6

$1,944.00

03/22/2016

NAC

Cite check Plaintiffs' Reply Memo in Further Support of Motion in
Limine.

1.9

$427.50

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
8
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/23/2016

JZK

Continue reviewing prior testimony and materials for Rudolph
cross and preparing Rudolph cross outline (8.0); settlement calls
with opposing counsel, R. Mandel and A. McMullan (1.3).

9.3

$4,929.00

03/23/2016

RSM

Reviewed settlement proposal re damage stipulation from
oppoisng counsel (.2); emails to and from and telephone
conference with opposing counsel and J. King re same (.5);
conference call with J. King and G. Adelman re same (.3); email to
A. McMullan and conference calls with A. McMullan and J. King re
settlement proposal and strategy for response to same (.4); email
to opposing counsel re injunction and settlement (.2); conference
call with B. Cohen and A. Shindler re status of MEA (.3); reviewing
and analyzing MEA termination letters and emails re same (.4);
emails to and from client re production of separation agreement
(.1); revising McMullan reply declaration on in limine motion re
termination of MEA (.5); emails to and from and telephone
conference with A. McMullan re same (.3); conferences with J.
King re Rudolph cross and settlement (.4).

3.6

$1,944.00

03/23/2016

NAC

Updating summary of plaintiffs' trial exhibits and supporting
citations.

4.0

$900.00

03/24/2016

JZK

Continue preparing Rudolph outline (.5); multiple emails to and
from A. McMullan, G. Adelman re settlement (1.0).

1.5

$795.00

03/24/2016

RSM

Conferences with N. Chinda re reviewing production of additional
documents on MEA, separation agreement and reviewing same
(.6); telephone conferences with B. Cohen re same, settlement,
reply papers on in limine motion (.3); emails to and from A.
Shindler re 2012 MEA with Virgin Records Ltd. (.2); email to A.
Lewis re ownership issues (.2); revising and finalizing Mandel reply
declaration and reply brief on in limine motion (.5); multiple
telephone conferences with and emails to and from A. McMullan,
opposing counsel and conferences with J. King re negotiating
terms of potential stipulated judgment (1.7); reviewing A. McMullan
testimony in MP3Tunes case re preparation of McMullan direct
(1.0); drafted email to opposing counsel re stipulations on chain of
title, recordings sold and offered for sale (.5).

5.0

$2,700.00

03/24/2016

NAC

Review Matrix Exchange Agreement letter for production (CAP
9313 - CAP 9314) (1.0); conference with R. Mandel re: same (.6).

1.6

$360.00

03/25/2016

JZK

Revising conditional court judgment to reflect settlement
discussions and conference with R. Mandel re same (1.8);
preparing Rudolph cross outline (.5).

2.3

$1,219.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
9
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/25/2016

RSM

Letter to Judge Sullivan re courtesy copies of reply in limine papers
(.2); conferences with N. Chinda re finalizing reply papers and
reviewed same (.3); finalized and sent email to opposing counsel
re stipulations on ownership and recordings at issue (.2); multiple
telephone conferences with and emails to and from A. McMullan,
opposing counsel re negotiating terms of stipulated judgment (1.2);
reviewing and revising stipulated judgment and conferences with J.
King, emails to and from client re same (1.3); emails to and from
B. Cohen and reviewed email from A. Lewis re ownership
information re divested/retained works (.4); drafting A. McMullan
direct outline (.8).

4.4

$2,376.00

03/25/2016

NAC

Conference with R. Mandel re: finalizing reply papers in further
support of motion in limine (.3); revise and supplent trial exhibits
(2.0); finalize reply papers (.7).

3.0

$675.00

03/26/2016

RSM

Drafting outline for A. McMullan direct testimony (4.6); reviewing,
analyzing and selecting exhibits for use on McMullan direct re
proving Capitol ownership of recordings (2.8); reviewing, analyzing
and selecting materials for use at pre-trial conference (1.0).

8.4

$4,536.00

03/27/2016

RSM

Continued drafting McMullan direct outline (2.7); reviewing and
analyzing multiple agreements and other support for potential use
on redirect if challenge rasied to prima facie proof of ownership
and outlining same (4.5); outlining revisions to exhibits (.8).

8.0

$4,320.00

03/28/2016

RSM

Completed review of potential redirect documents on ownership
(1.0); reviewing agreements and chain of title documents re
pre-1972 recordings for use at trial (1.8); outlining same (.9);
reviewed revised version of stipulated judgment (.3); emails to and
from and telephone conferences with opposing counsel (.6), A.
McMullan (.3) re same; drafting Ossenmacher testimony outline
(1.6); revieiwng deposition testimony re same (.5); reviewing
Copyright Office DMCA report re use at trial (.5); conferences with
N. Chinda re revisions to exhibit list (.3).

7.8

$4,212.00

03/29/2016

RSM

Reviewing and analyzing deposition testimony and exhibits re
preparation of outline for Ossenmacher testimony (2.8); drafting
and revising outline for Ossenmacher testimony (4.7); reviewing A.
McMullan and J. Cho testimony from J. Thomas case (.8).

8.3

$4,482.00

03/30/2016

RSM

Reviewing and analyzing evidentiary issues re admission of trial
exhibits objected to by defendants (1.8); telephone conferences
with and emails to and from G. Adelman, A. McMullan re
settlement (.6); preparation for call with opposing counsel re
stipulations (.7); conference call with M. DeVincenzo and S. Matz
re reviewing potential stipulations on ownership and recordings
sold and offered for sale (1.0); reviewing and analyzing various
alleged deficiencies concerning chain of title alleged by defendants
(2.3); multiple emails to opposing counsel responding re alleged
deficiencies (.8); conferences with and emails to and from T.
Kjellberg re issues concerning copyright certificates (.4); drafted
stipulation re ownership (.6); email to opposing counsel re same
(.2).

8.4

$4,536.00

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
10
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/30/2016

TXK

Confer with RSM re challenged copyright registration certificates
(.4); research registration status from Copyright Office (.2).

0.6

$255.00

03/30/2016

NAC

Search Plaintiffs' Trial Exhibits for proof of sale of recordings and
timing of same (4.5); prepare list re: same (.4); conference with R.
Mandel re: same (.4).

5.3

$1,192.50

03/31/2016

RSM

Multiple emails to and from and telephone conferences with
opposing counsel re evidentiary issues on exhibits and disputes on
chain of title (1.9); reviewing and analyzing open chain of title
issues and emails to and from and telephone conferences with A.
McMullan re same (1.6); telephone conferences with and emails to
and from A. McMullan, opposing counsel re continuing settlement
discussions (1.4); conferences with N. Chinda re evidence on
timing of infringements and reviewing same (.5); reviewed draft
revised stipulation from opposing counsel re ownership (.4);
reviewing and revising summary stipulation re recordings sold and
offfered and email to opposing counsel re same (.6); reviewing
transcripts from prior hearings, prior correspondence and other
documentation re disputed issues in preparation for pre-trial
conference (1.7).

8.1

$4,374.00

294.0

$139,024.00

Amount
$41,499.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

Hours
78.3

RSM

Richard Mandel

153.1

$82,674.00

TXK

Thomas Kjellberg

0.6

$255.00

SPC

Scott P. Ceresia

7.6

$2,356.00

NAC

Nart-Anong Chinda

54.4

$12,240.00

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

April 11, 2016
Client:
029503
Matter:
000003
336680
Invoice #:
Resp. Atty:
RSM
Page:
11

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$139,024.00

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$142,191.71
$62,969.98
($1,508.00)
$203,653.69

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

May 13, 2016
Client:
029503
Matter:
000003
338752
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through April 30, 2016
HOURLY SERVICES
Date

Description of Services

Hours

Amount

04/01/2016

RSM

Conference call with G. Adelman and A. McMullan re settlement
(.3); numerous telephone conferences with and emails to and from
A. McMullan, opposing counsel re negotiating terms of settlement
agreement (5.0); reviewing trial testimony from hubcap RIAA
cases re preparation for trial (1.0); reviewing filing and cases re
preparation for pre-trial conference (3.2).

9.5

$5,130.00

04/01/2016

TXK

Emails to/from Copyright Office re challenged copyright
registration certificates.

0.3

$127.50

04/02/2016

RSM

Telephone conferences with and emails to G. Adelman re
settlement (.5); drafting settlement agreement (2.3), bonded and
unbonded judgment exhibits (1.7) and ownership stipulation exhibit
(.4); multiple emails to and from A. McMullan re settlement and
revisions to settlement papers (1.8); revising settlement papers
(1.2).

7.9

$4,266.00

04/03/2016

RSM

Numerous telephone conferences with and emails to and from
opposing counsel, A. McMullan re final settlement negotiations
(2.2); revising settlement agreement, bonded and un-bonded
judgments (2.8); prepared outline for pre-trial conference (1.0).

6.0

$3,240.00

04/04/2016

JZK

Attend pretrial conference with R. Mandel.

2.0

$1,060.00

04/04/2016

RSM

Telephone conference with and emails to and from opposing
counsel re finalizing and execution of settlement papers (.8);
emails to and from and telephone conference with A. McMullan re
same, reviewing conference (.5); conference call with opposing
counsel and Judge Sullivan's chambers re advising of settlement
(.2); appeared in Court for conference (2.0).

3.5

$1,890.00

04/05/2016

RSM

Reviewed court order (.1); telephone conference with and emails
to and from opposing counsel re same, sealing of transcript (.3).

0.4

$216.00

04/06/2016

RSM

Email to opposing counsel re execution of judgments.

0.1

$54.00

May 13, 2016
Client:
029503
Matter:
000003
338752
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

04/08/2016

RSM

Reviewed proposed redactions to transcript from pre-trial
conference (.2); email to G. Adelman re same (.1).

0.3

$162.00

04/09/2016

RSM

Reviewed ReDigi draft motion to seal transcript from pretrial
conference (.3); emails to and from A. McMullan re same (.1).

0.4

$216.00

04/11/2016

RSM

Email to opposing counsel re comments on draft sealing motion;
reviewing final motion re same.

0.2

$108.00

04/15/2016

RSM

Telephone conferences with opposing counsel re sealing of
transcript, contacting chambers re same.

0.2

$108.00

04/19/2016

RSM

Reviewed Court order granting sealing of pre-trial conference
transcript.

0.1

$54.00

04/20/2016

RSM

Emails to and from A. McMullan, opposing counsel re execution of
corrected judgments.

0.2

$108.00

04/21/2016

RSM

Telephone conference with opposing counsel re proposed letter to
Court clarifying status of appeal period and final judgment.

0.3

$162.00

04/26/2016

RSM

Reviewed ReDigi draft letter to Court re re-opening case for
purposes of entry of judgment (.1); email to opposing counsel re
same (.1).

0.2

$108.00

04/27/2016

RSM

Conference call with S. Matz and M. DeVincenzo re letter to Court
on judgments to be filed.

0.3

$162.00

04/28/2016

RSM

Revising draft letter to Court re submission of judgments,
dismissal (.2); emails to and from opposing counsel re same (.1);
reviewed Court order modifying prior order on dismissal (.1).

0.4

$216.00

32.3

$17,387.50

Hours
2.0

Amount
$1,060.00

30.0

$16,200.00

0.3

$127.50

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

TXK

Thomas Kjellberg

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

May 13, 2016
Client:
029503
Matter:
000003
338752
Invoice #:
Resp. Atty:
RSM
Page:
3

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$17,387.50

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$17,535.02
$203,653.69
($5,342.08)
$215,846.63

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

June 06, 2016
Client:
029503
Matter:
000003
340089
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through May 31, 2016
HOURLY SERVICES
Date

Description of Services

Hours

Amount

05/03/2016

RSM

Email to opposing counsel re status of signed judgments.

0.1

$54.00

05/19/2016

RSM

Email to opposing counsel re execution of judgments.

0.1

$54.00

05/23/2016

RSM

Emails to and from G. Adelman re execution of judgments.

0.1

$54.00

0.3

$162.00

Hours
0.3

Amount
$162.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel

DISBURSEMENTS
Date

Description of Disbursements

Total Disbursements

Amount

June 06, 2016
Client:
029503
Matter:
000003
340089
Invoice #:
Resp. Atty:
RSM
Page:
2

Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$162.00

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$218.00
$215,846.63
($56,119.90)
$159,944.73

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

February 10, 2017
Client:
029503
Matter:
000003
352782
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through January 31, 2017
HOURLY SERVICES
Date

Description of Services

Hours

Amount

01/03/2017

RSM

0.3

$165.00

01/04/2017

RSM

0.4

$220.00

01/05/2017

RSM

0.5

$275.00

01/06/2017

RSM

0.8

$440.00

01/09/2017

RSM

0.5

$275.00

01/09/2017

GXD

0.5

$115.00

01/10/2017

RSM

0.3

$165.00

01/10/2017

GXD

0.5

$115.00

01/11/2017

RSM

0.4

$220.00

.

February 10, 2017
Client:
029503
Matter:
000003
352782
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

1.0

$550.00

01/12/2017

RSM

01/13/2017

RSM

Emails to and from opposing counsel re joint appendix, sealing in
Second Circuit (.2); telephone conference with opposing counsel,
emails to and from client re sealing motion in Second Circuit (.2).

0.4

$220.00

01/14/2017

RSM

Emails to and from opposing counsel re consent to sealing in
Second Circuit.

0.1

$55.00

01/17/2017

RSM

Emails to and from opposing counsel re absence of opposing
papers in response to sealing motion (.1); reviewed motion filed by
opposing counsel in Second Circuit re same (.1).

0.2

$110.00

01/19/2017

RSM

0.5

$275.00

01/23/2017

RSM

Reviewing and analyzing record on appeal and index of joint
appendix prepared by opposing counsel (1.0); telephone
conferences with opposing counsel re same (.2); emails to and
from opposing counsel re revisions to same (.3); telephone
conference with counsel for MPAA re potential amicus
participation in appeal (.3).

1.8

$990.00

01/24/2017

RSM

Telephone conference with and emails to and from A. McMullan re
status of amicus participation (.2); emails to and from M.
Oppenheim re possible participation of book publishers as amicus
(.2); emails to and from B. Sheffner of MPAA re possible
participation as amicus (.1); reviewed revised record on appeal
and index for joint appendix (.2); email to opposing counsel re
same (.1); telephone conference with and reviewed email from
opposing counsel re amicus, joint appendix (.2).

1.0

$550.00

01/25/2017

RSM

Emails to and from opposing counsel re revisions to record, joint
appendix, filing of documents under seal in Second Circuit.

0.2

$110.00

01/26/2017

RSM

Emails to and from opposing counsel re sealing issues, additional
revisions to joint appendix (.3); reviewed revised record on appeal
index (.2);
(.1);
(.1),
(.1)
.

0.8

$440.00

01/27/2017

RSM

0.7

$385.00

10.9

$5,675.00

Hours
9.9

Amount
$5,445.00

(.1);
(.1);
reviewed draft table of materials for joint appendix sent by ReDigi
counsel (.5); emails to and from opposing counsel re same and
issues concerning materials to be included (.3).

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel

February 10, 2017
Client:
029503
Matter:
000003
352782
Invoice #:
Resp. Atty:
RSM
Page:
3
TIMEKEEPER RECAP

GXD

Hours
1.0

George Diaz, Jr.

Amount
$230.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

01/10/2017
01/10/2017

01/10/2017
01/11/2017
01/11/2017
01/31/2017
Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$5,675.00
$

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$5,791.60
$10,341.80
($4,627.80)
$11,505.60

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

March 06, 2017
Client:
029503
Matter:
000003
354327
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through February 28, 2017
HOURLY SERVICES
Date

Description of Services

Hours

Amount

02/02/2017

RSM

Conference call with counsel for Copyright Alliance re amicus brief
(.2); email to counsel for Copyright Alliance re Google, Public
Knowledge amicus requests (.1).

0.3

$165.00

02/07/2017

RSM

Reviewing ReDigi appellate brief.

1.0

$550.00

02/08/2017

RSM

Telephone conference with and email to A. McMullan re ReDigi
Second Circuit brief (.3); reviewing case law on material objects
(.5); reviewed opposing counsel motion re not filing redacted
versions of appendix (.1); emails to and from opposing counsel re
same (.1).

1.0

$550.00

02/09/2017

JZK

Review ReDigi appeal brief (1.3) and confer with R. Mandel re:
same (.2).

1.5

$817.50

02/10/2017

RSM

Conference with N. Chinda re identifying confidential portions of
ReDigi appellate brief (.1); reviewing N. Chinda report re same
(.1); email to client re same and effect on amicus briefs (.1);
conferences with J. King re appelle brief and research (.2).

0.5

$275.00

02/10/2017

NAC

RE: Review ReDigi's appeal brief re: identifying confidential
redactions.

0.5

$115.00

02/14/2017

RSM

Email to A. McMullan re amicus briefs filed in support of ReDigi
(.1); telephone conference with A. McMullan re same, timing of
answering brief and
(.2)

0.4

$220.00

0.4

$220.00

1.0

$230.00

(.1).
02/16/2017

RSM

Emails to and from client re timing of responsive brief (.1); drafted
scheduling request to Second Circuit re appelle brief (.2);
(.1).

02/16/2017

GXD

Prepared letter to Clerk requesting deadline for filing of Brief.

March 06, 2017
Client:
029503
Matter:
000003
354327
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

02/17/2017

RSM

02/22/2017

02/23/2017

RSM

(.1);
telephone conference with S. Bauman re reviewing issues for
appeal (.5).
Total Professional Services

0.3

$165.00

$220.00

0.6

$330.00

7.9

$3,857.50

Hours
1.5

RSM

Amount

0.4

Reviewed 2d Circuit order re briefing schedule and email to A.
McMullan re same (.1); emails to multiple potential amici re
briefing schedule and amicus briefs (.2).

Hours

Amount
$817.50

TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

4.9

$2,695.00

NAC

Nart-Anong Chinda

0.5

$115.00

GXD

George Diaz, Jr.

1.0

$230.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

02/10/2017
Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
PAY THIS AMOUNT

$3,857.50
$11.00
$3,868.50
$11,505.60
$15,374.10

March 06, 2017
Client:
029503
Matter:
000003
354327
Invoice #:
Resp. Atty:
RSM
Page:
3

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

April 10, 2017
Client:
029503
Matter:
000003
355785
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through March 31, 2017
HOURLY SERVICES
Date

Description of Services

Hours
0.2

$110.00

0.1

Telephone conerence with G. Borkowski re RIAA amicus brief.

Amount

$55.00

03/01/2017

RSM

03/07/2017

RSM

03/14/2017

RSM

Reviewing and analyzing appellant brief and amicus briefs from
law professors and American Library Association re preparation for
drafting appellate brief.

1.9

$1,045.00

03/15/2017

JZK

Reviewing and annotating Redigi appellate brief (1.2); conference
with R. Mandel re possible response to "music file" argument (.5).

1.7

$926.50

03/15/2017

RSM

2.9

$1,595.00

(.2);
(.2);

(.1);
(.1); reviewing and analyzing cases cited in
ReDigi brief in preparation for drafting appellate brief (1.8);
conferences with J. King re reviewing issues for appeal (.5).
03/16/2017

JZK

Research re appellate issues re reproduction (1.5); reviewing and
ReDigi appellate papers and citations (2.5).

4.0

$2,180.00

03/16/2017

RSM

Continued review of legal authorities cited in appellant brief (.4);
begin drafting sections of appelle brief -- corporate disclosure,
jurisdictional statement, statement of the case (2.8).

3.2

$1,760.00

03/17/2017

JZK

Review Amicus briefs re 109(a) limitations (1.0); begin outlining
and drafting summary of argument (2.5).

3.5

$1,907.50

03/17/2017

RSM

Completed drafting statement of case (1.9); reviewing appendix re
citations to record for brief (1.3); emails to and from opposing
counsel re failure to include Hall declaration in jionit appendix (.2).

3.4

$1,870.00

03/20/2017

JZK

Continue drafting section of appellate brief on reproduction (3.9);
meet with R. Mandel re reproduction issues in brief (.5).

4.4

$2,398.00

April 10, 2017
Client:
029503
Matter:
000003
355785
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

03/20/2017

RSM

Completed addition of record citations to brief (.6); conferences
with J. King re structure of legal argument (.5); begin drafting
distribution section of legal argument re distribution (2.1).

3.2

$1,760.00

03/21/2017

JZK

Drafting reproduction point of appellate brief.

4.0

$2,180.00

03/21/2017

RSM

3.2

$1,760.00

(.2);
drafting first sale sections of legal argument for 2d Circuit brief
(2.8).

(.2);

03/22/2017

RSM

Reviewing, revising and supplementing sections of reproduction
point in legal argument (2.2); drafting additional sub-sections re
same (1.8).

4.0

$2,200.00

03/23/2017

RSM

Reviewing and analyzing Audio Home Recording Act, Digital
Performance Right in Sound Recording Act and commentaries re
same for response to ReDigi argument (1.5); drafting subsection
of reproduction legal argument point responding to ReDigi
statutory and contractual arguments on reproduction (3.5).

5.0

$2,750.00

03/24/2017

RSM

Revising statement of case in 2d Circuit brief (.2); revising brief
point re effect of distribution on reproduction right (.6); drafted brief
point on judicial admissions on reproduction (3.7).

4.5

$2,475.00

49.2

$26,972.00

Hours
17.6

Amount
$9,592.00

31.6

$17,380.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$26,972.00
$26,972.00
$15,374.10
($5,714.00)
$36,632.10

April 10, 2017
Client:
029503
Matter:
000003
355785
Invoice #:
Resp. Atty:
RSM
Page:
3

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

May 08, 2017
Client:
029503
Matter:
000003
357578
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through April 30, 2017
HOURLY SERVICES
Date

Description of Services

Amount

3.0

$1,635.00

0.4

Conference with R. Mandel re fair use issues and settlement (.6);
researching (1.0) and editing (1.4) appellee brief.

Hours

$216.00

04/03/2017

JZK

04/03/2017

MM

04/03/2017

RSM

(.3);
(.1); conferences with
J. King re revisions to appellate brief and issues concerning same
(.6).

1.0

$550.00

04/04/2017

JZK

Research re application of fair use to Section 109.

0.7

$381.50

04/04/2017

RSM

Reviewing and revising reproduction brief point (.9); continue
drafting and revising first sale legal argument point in brief (2.7);
review RIAA brief in General Motors case for consistency with
ReDigi position (.2); email to A. McMullan re same (.1).

3.9

$2,145.00

04/05/2017

RSM

Reviewing and analyzing Supreme Court first sale cases and
DMCA Report re first sale (1.2); drafting bief sub-point on policy
issues concerning first sale defense (2.8); reviewed outline for
RIAA/MPAA amicus brief and email from G. Borkowski re same
(.2); emails to and from A. McMullan re same (.1).

4.3

$2,365.00

04/06/2017

RSM

Conference call with Copyright Alliance lawyers re reviewing
amicus brief strategy (.5); reviewing Dept. of Commerce Internet
Task Force White Paper on digital first sale proposal (.5);
completing draft of brief section on first sale policy arguments
(1.6); revising brief re additional citations to Star Athletica Supreme
Court case, ReDigi patent (.5); drafting statement of issues
presented for brief (.4);
(.1).

3.6

$1,980.00

04/07/2017

JZK

Reviewing amicus brief re fair use (1.0) and conference with T.
Kjelberg re same (.6).

1.6

$872.00

May 08, 2017
Client:
029503
Matter:
000003
357578
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

04/07/2017

TXK

Confer with JZK re ReDigi appeal.

0.6

$261.00

04/10/2017

JZK

Research re Library Association amicus fair use argument (1.7);
confer with R. Mandel re: same (.3).

2.0

$1,090.00

04/10/2017

RSM

Conferences with J. King re fair use argument in brief.

0.3

$165.00

04/11/2017

JZK

Drafting fair use section of appellate brief.

2.5

$1,362.50

04/11/2017

RSM

Reviewing fair use introduction to argument.

0.2

$110.00

04/12/2017

MM

0.5

$270.00

04/12/2017

RSM

Emails to and from potential amicus American Association of
Publishers (.1); reviewed email from bankruptcy counsel and
enclosed papers filed re lien in patents (.4).

0.5

$275.00

04/13/2017

JZK

Continue drafting fair use section of appellate brief.

1.3

$708.50

04/13/2017

MM

0.5

$270.00

04/13/2017

RSM

0.8

$440.00

04/17/2017

JZK

Drafting fair use section of appellate brief.

1.5

$817.50

04/17/2017

RSM

Drafting and revising summary of argument for 2d Circuit appellee
brief.

1.0

$550.00

04/18/2017

JZK

Continue drafting fair use section of appellate brief.

5.5

$2,997.50

04/19/2017

RSM

Revised fair use legal argument point of Second Circuit brief (1.0);
completed drafting and revising summary of argument (.5); drafted
preliminary statement (.5); reviewed letter from opposing counsel
re motion to expedite appeal (.1); emails to and from and
telephone conference with client re same (.2).

2.3

$1,265.00

04/20/2017

JZK

Reviewing and editing appellate brief (1.2); review re ReDigi
proposed motion to expedite appeal (.1).

1.3

$708.50

04/21/2017

JZK

Complete editing and reviewing appellate brief (2.8) and
conference with R. Mandel re same (.2).

3.0

$1,635.00

04/21/2017

RSM

Reviewing and revising draft Second Circuit brief (.6); conferences
with J. King re same (.2); email to client re draft brief (.1); email to
opposing counsel re rejecting request to expedite appeal (.1);
reviewing 2d Circuit rules re motion requirements and timing (.2).

1.2

$660.00

04/24/2017

RSM

Review cite check of 2d Circuit brief and analyze flagged
authoriteis re negative treatment (.6); begin revising brief re cite
check (.4).

1.0

$550.00

04/24/2017

NAC

RE: Cite check, shepardize and Bluebook ReDigi appellate brief.

5.0

$1,150.00

04/25/2017

JZK

Confer with R. Mandel re: revisions to appellate brief.

0.4

$218.00

(.3);
(.2);
telephone conference with and email to counsel for AAP re amicus
brief (.3).

May 08, 2017
Client:
029503
Matter:
000003
357578
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services

Hours

Amount

04/25/2017

RSM

Reviewed A. McMullan comments on draft Second Circuit brief
(.3); conferences with J. King re issues and follow-up concerning
same and revisions to brief (.4); revising brief re McMullan
comments and completed cite check (1.2); email to client re
revised brief (.2).

2.1

$1,155.00

04/27/2017

RSM

Reviewed email from client re corporate structure (.1); revised
corporate disclosure statement in brief (.1); reviewing and
supplementing cross-reference citations in brief (.5);

0.9

$495.00

0.5

$275.00

53.4

$27,573.00

Hours
22.8

Amount
$12,426.00

(.2).
04/28/2017

RSM

Reviewed S. Bauman comments on draft Second Circuit brief (.2);
revised same (.3).
Total Professional Services

TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

23.6

$12,980.00

MM

Mark Montague

1.4

$756.00

TXK

Thomas Kjellberg

0.6

$261.00

NAC

Nart-Anong Chinda

5.0

$1,150.00

DISBURSEMENTS
Date

Description of Disbursements

Amount

04/21/2017
Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$27,573.00
$27,579.20
$36,632.10
($5,791.60)
$58,419.70

May 08, 2017
Client:
029503
Matter:
000003
357578
Invoice #:
Resp. Atty:
RSM
Page:
4

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

June 09, 2017
Client:
029503
Matter:
000003
359395
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through May 31, 2017
HOURLY SERVICES
Date

Description of Services

Hours

Amount

05/01/2017

JZK

Review S. Bauman comments on brief (.3); conference with R.
Mandel re same(.2).

0.5

$272.50

05/01/2017

RSM

Completed review and final revisions to 2d Circuit brief (1.8);
conference with J. King re same (.2); emails to and from printer re
cover, table of contents/authorities and reviewing draft cover (.3);
reviewed ReDigi motion to expedite oral argument on appeal (3);
(.2).

2.8

$1,540.00

05/02/2017

RSM

2.9

$1,595.00

05/03/2017

RSM

6.5

$3,575.00

05/03/2017

NAC

RE: Cite check Appellee's brief (1.5); update table of authorities
(.4).

1.9

$437.00

05/04/2017

JZK

Read amicus brief by Copyright Alliance.

0.5

$272.50

05/04/2017

RSM

3.0

$1,650.00

(.1); conference with N. Chinda re reviewing proofing
changes to Second Circuit brief (.2); revising 2d Circuit brief (.2);
emails to and from printer re final changes to brief and filing (.2);
(5.8).

Alliance amicus brief (.5).

(.5);
(1.8);
(.2); reviewed draft of Copyright

05/05/2017

JZK

Review RIAA and MPAA amicus brief.

0.7

$381.50

05/05/2017

RSM

Emails to client, emails to and from amici re filing of final appelle
2d Circuit brief (.2); reviewed draft MPAA/RIAA amicus brief (.3).

0.5

$275.00

June 09, 2017
Client:
029503
Matter:
000003
359395
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

05/09/2017

MM

0.3

$162.00

05/09/2017

RSM

1.0

$550.00

05/10/2017

RSM

1.3

$715.00

05/11/2017

MM

0.8

$432.00

05/11/2017

RSM

0.9

$495.00

05/11/2017

GXD

0.5

$115.00

05/12/2017

RSM

0.4

$220.00

05/16/2017

RSM

0.4

$220.00

05/17/2017

RSM

0.3

$165.00

05/18/2017

JZK

Review amicus brief of American Publisher's Association (.8);
conference with R. Mandel re ReDigi appeal, motion to expedite
and bankruptcy proceeding (.2).

1.0

$545.00

05/18/2017

RSM

Reviewed 2d Circuit order re expediting appeal (.1); emails to and
from client re same and likely timing of argument (.1);

0.7

$385.00

(.2);
(.1); email to client re
motion papers and amicus briefs from Copyright Alliance and AAP
(.1).

(.2)

(.3).

June 09, 2017
Client:
029503
Matter:
000003
359395
Invoice #:
Resp. Atty:
RSM
Page:
3
HOURLY SERVICES
Date

Description of Services
Review ReDigi reply brief (1.5); emails to R. Mandel (.5) re same;
review request for oral argument (.2);
(.3).

Hours

Amount

2.5

$1,362.50

0.7

$385.00

05/19/2017

JZK

05/19/2017

RSM

05/30/2017

RSM

Reviewed ReDigi 2d Circuit reply brief.

1.0

$550.00

05/31/2017

RSM

Reviewed email from law professor amici seeking consent to
participate in oral argument; emails to and from client re same.

0.1

$55.00

31.2

$16,355.00

Hours
5.2

Amount
$2,834.00

(.5); conferences with
J. King re oral argument request form and reply brief served by
ReDigi (.2).

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

22.5

$12,375.00

MM

Mark Montague

1.1

$594.00

NAC

Nart-Anong Chinda

1.9

$437.00

GXD

George Diaz, Jr.

0.5

$115.00

DISBURSEMENTS
Date

Description of Disbursements

05/17/2017

Amount

Counsel Press Inc.- - re reproduction APPELLEE'S brief
Total Disbursements
Total Services
Total Disbursements
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

$16,355.00
$18,114.42
$58,419.70
($3,868.50)
$72,665.62

June 09, 2017
Client:
029503
Matter:
000003
359395
Invoice #:
Resp. Atty:
RSM
Page:
4

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

July 10, 2017
Client:
029503
Matter:
000003
360714
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through June 30, 2017
HOURLY SERVICES
Date

Description of Services

Hours

Amount

06/01/2017

RSM

Reviewed rule re amicus participation in oral argument and case
law re same (.2); email to counsel for copyright scholars amici re
not consenting to motion to participate in oral argument (.1);
reviewed letter from opposing counsel to 2d Circuit re Supreme
Court patent exhaustion decision and enclosed decision (.4);
emails to and from client re same (.1).

0.8

$440.00

06/02/2017

JZK

Review Lexmark opinion provided to Second Circuit by ReDigi (.4);
draft responsive letter (1.6); review Copyright Law Scholar motion
for oral argument (.3).

2.3

$1,253.50

06/02/2017

RSM

Review and revise letter to Second Circuit responding re Supreme
Court patent exhaustion decision (.7); conferences with J. King
(.2), emails to and from client (.1) re same; telephone conference
with A. McMullan re mediation, letter to Court (.1); reviewed motion
for oral argument filed by law professor amici and emails to and
from client re same (.1).

1.2

$660.00

06/06/2017

JZK

3.5

$1,907.50

06/06/2017

RSM

0.2

$110.00

06/07/2017

JZK

0.3

$163.50

06/07/2017

RSM

0.9

$495.00

06/08/2017

RSM

0.1

$55.00

July 10, 2017
Client:
029503
Matter:
000003
360714
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

06/09/2017

RSM

0.4

$220.00

06/13/2017

RSM

0.1

$55.00

06/30/2017

RSM

0.2

$110.00

10.0

$5,469.50

Hours
6.1

Amount
$3,324.50

3.9

$2,145.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel
Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$5,469.50

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$5,469.50
$72,665.62
($54,551.20)
$23,583.92

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

August 04, 2017
Client:
029503
Matter:
000003
362336
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through July 31, 2017
HOURLY SERVICES
Date

Description of Services

Hours

Amount

07/06/2017

RSM

(.1);
reviewed Second Circuit notification of argument scheduling and
email to A. McMullan re same (.1).

0.2

$110.00

07/10/2017

RSM

Reviewed and signed completed acknowledgement form and
confer with N. Chinda re same (.1);
(.1).

0.2

$110.00

07/10/2017

NAC

Prepare acknowledgement form (.2) and confer with R. Mandel re
same (.1).

0.3

$69.00

07/12/2017

RSM

Reviewed 2d Circuit order re amicus participation in oral argument;
emails to and from A. McMullan re same.

0.1

$55.00

07/31/2017

RSM

Reviewing, analyzing and annotating record (2.0), amicus briefs
(1.8) re preparation for oral argument.

3.8

$2,090.00

4.6

$2,434.00

Hours
4.3

Amount
$2,365.00

0.3

$69.00

Total Professional Services
TIMEKEEPER RECAP

RSM

Richard Mandel

NAC

Nart-Anong Chinda
Total Services
Total Current Charges
Previous Balance
PAY THIS AMOUNT

$2,434.00
$2,434.00
$23,583.92
$26,017.92

August 04, 2017
Client:
029503
Matter:
000003
362336
Invoice #:
Resp. Atty:
RSM
Page:
2

Credit Card Link:

Credit Card Instructions
https://www.cll.com/credit-card-payments

Wire Instructions
Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

Cowan Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
Telephone: [phone]
Fax: [phone]
http://www.cll.com
Federal Tax I.D. No.: 13-2741990

EMI Music
c/o Universal Music Group
2220 Colorado Avenue
Santa Monica, CA 90404
Attention: Alasdair McMullan, SVP, Legal Affairs

September 06, 2017
Client:
029503
Matter:
000003
363728
Invoice #:
Resp. Atty:
RSM
Page:
1

RE: ReDigi

For Professional Services Rendered Through August 31, 2017
HOURLY SERVICES
Date
08/01/2017

Description of Services
RSM

(.2)

Hours
(.2)

Amount

2.7

$1,485.00

completed reviewing amicus briefs (.3)
and reviewed, analyzed and annotated Commerce Dept. white
paper on digital first sale (1.5) re preparation for oral argument;
begin reviewing cases cited in brief re preparation for oral
argument (.5).
08/02/2017

RSM

Reviewing and analyzing relevant cases re preparation for Second
Circuit oral argument.

3.0

$1,650.00

08/03/2017

RSM

Continued review and analysis of relevant cases and record re
preparation for Second Circuit oral argument.

2.9

$1,595.00

08/07/2017

RSM

Begin preparing outline for Second Circuit oral argument (2.5);
reviewing case materials re same (1.1).

3.6

$1,980.00

08/08/2017

JZK

Conference with R. Mandel re ReDigi argument re Apple
agreement.

0.4

$218.00

08/08/2017

RSM

Continued drafting outline for Second Circuit oral argument (2.8)
and reviewing relevant case materials re same (.9); telephone
conference with S. Bauman re reviewing issues concerning
positions in license vs. sale litigations (.2); conference with J. King
re reviewing issues for oral argument (.4);

4.4

$2,420.00

5.5

$3,025.00

(.1).
08/09/2017

RSM

Completed draft of outline for 2d Circuit oral argument (4.2);
telephone conference with A. McMullan re reviewing issues
concerning Apple agreement and terms of use (.3); reviewing
transcripts from oral arguments on preliminary injunction motion,
summary judgment motion (.4); emails to client re same and
potential hypotheticals for oral argument (.2); conference with J.
King re: preparation for hypotheticals. (.4).

September 06, 2017
Client:
029503
Matter:
000003
363728
Invoice #:
Resp. Atty:
RSM
Page:
2
HOURLY SERVICES
Date

Description of Services

Hours

Amount

08/10/2017

JZK

Conference with R. Mandel re preparation for oral argument.

0.4

$218.00

08/10/2017

RSM

Reviewing and analyzing Apple terms of use (.4); telephone
conference with S. Bauman re same and impact on first sale
arguments (.4); conferences with J. King re oral argument
preparation (.4).

1.2

$660.00

08/11/2017

JZK

Review ReDigi FRAP 28(J) letter and attached opinion (.4); meet
with R. Mandel re same (.3); revisions to letter (.3).

1.0

$545.00

08/11/2017

RSM

Reviewed supplemental letter from ReDigi and cited case (.2);
conferences with J. King re same and response (.3); drafted
response to letter (.3).

0.8

$440.00

08/17/2017

RSM

0.2

$110.00

08/20/2017

RSM

Reviewing and revising outline for 2d Circuit oral argument (2.6);
reviewing copyright articles and opinions by panel members (1.9).

4.5

$2,475.00

08/21/2017

RSM

Completed reviewing outline and case materials re preparation for
2d Circuit oral argument (4.6); practicing argument (1.0).

5.6

$3,080.00

08/22/2017

JZK

Attend Second Circuit argument.

5.0

$2,725.00

08/22/2017

RSM

Attend and conduct oral argument in Second Circuit.

5.0

$2,750.00

08/24/2017

JZK

Emails to/from client re VidAngel case (.1); review and revise letter
to Second Circuit re same (.4); meeting with R. Mandel re: same
(.3).

0.8

$436.00

08/24/2017

RSM

Reviewed 9th Circuit VidAngel decision (.3); emails to and from
client, counsel for Copyright Alliance re same and possible letter to
Court (.2); drafted letter to Second Circuit advising of VidAngel
decision (.6); conferences with J. King and emails to and from
client re revisions to same (.3).

1.4

$770.00

08/25/2017

RSM

Reviewed ReDigi response letter re VidAngel decision; emails to
and from client re same.

0.1

$55.00

48.5

$26,637.00

Hours
7.6

Amount
$4,142.00

40.9

$22,495.00

Total Professional Services
TIMEKEEPER RECAP

JZK

Jonathan Z. King

RSM

Richard Mandel

September 06, 2017
Client:
029503
Matter:
000003
363728
Invoice #:
Resp. Atty:
RSM
Page:
3

Total Services
Total Current Charges
Previous Balance
Less Payments
PAY THIS AMOUNT

Credit Card Link:

$26,637.00

Credit Card Instructions
https://www.cll.com/credit-card-payments
Wire Instructions

Bank Name: IDB Bank
1114 Avenue of the Americas, New York, NY 10036
Address:
0371047
Acct No.:
026009768
ABA No.:
Swift Code: IDBYUS33

Due Upon Receipt. Please include the invoice number on all remittance. Thank you.

$26,637.00
$26,017.92
($18,114.42)
$34,540.50