Ceglia v. Zuckerberg et al

Filing 519

DECLARATION signed by Alexander H. Southwell re 517 MOTION for Attorney Fees And For Recovery Of Expenses filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S)(Snyder, Orin)

EXHIBIT Q

From: Southwell, Alexander H.
Sent: Friday, August 31, 2012 1:04 PM
To: Dean Boland ([e-mail])
Cc: [e-mail]; Benjamin, Matthew; Aycock, Amanda
Subject: Detail on costs related to cancelled depositions

Mr. Boland:
In response to your email requesting further information on the costs and fees incurred by Defendants as a result of
your untimely cancellations of depositions, I am attaching invoices for the experts from whom we have received final
invoices, as well as a summary of costs and fees incurred. Please transmit to my attention the total of $98,640.75 via
check (payable to Gibson Dunn & Crutcher LLP) or wire (we can provide information if you choose this method of
payment) by Tuesday, September 4th.
Alex
Summary of Costs and Fees Incurred:

Travel and Lodging

Friedberg, E.

n/a

Appearance Fee

Witness Prep Time

Attorney Prep Time

TOTALS

$3,412.50

$6,093.75

$6,500.00

$16,006.25

Lesnevich, G.

$2,228.97

$6,400.00

$4,000.00

$2,560.00

$15,188.97

Lyter, A.

$1,286.00

$1,500.00

$4,200.00

$3,500.00

$10,486.00

McMenamin, G.

$3,665.00

$5,000.00

$8,188.00

$11,085.00

$27,938.00

$649.51

$1,662.50

$6,925.00

$5,770.00

$15,007.01

Novak, J.

1

Romano, F.

Tytell, P.
TOTALS

$1,599.52

n/a
$9,429.00

$875.00

$1,700.00 n/a
$20,550.00

$2,500.00

$7,340.00

$12,314.52

$36,755.00

$1,700.00
$98,640.75

n/a
$31,906.75

Below is the itemization for the attorneys’ and witness fees resulting from preparation time expended in anticipation of
the depositions that you untimely cancelled:
Witness (Eric Friedberg)/Attorney
Eric Friedberg
Matthew Benjamin
Alexander Southwell

Hours

Witness (Jason Novak)/Attorney
Jason Novak
Matthew Benjamin
Alexander Southwell

Hours

Witness (Gerald McMenamin)/Attorney
Gerald McMenamin
Gerald McMenamin (cancellation
charge)
Matthew Benjamin
Alexander Southwell

Hours

Witness (Gus Lesnevich)/Attorney
Gus Lesnevich
Sripriya Narasimhan
Matthew Benjamin

Hours

Witness (Al Lyter)/Attorney
Al Lyter
Sripriya Narasimhan
Alexander Southwell

Hours

Witness (Frank Romano)/Attorney
Frank Romano
Sripriya Narasimhan
Matthew Benjamin
Alexander Southwell

Rate
$975.00
$720.00
$910.00

Amount
$6,093.75
$4,680.00
$1,820.00

$475.00
$720.00
$910.00

Amount
$6,887.50
$4,860.00
$910.00

12.75

$250.00

Amount
$3,187.50

10.00
13.50
1.50

$500.00
$720.00
$910.00

$5,000.00
$9,720.00
$1,365.00

Hours

6.25
6.50
2.00
Rate
14.50
6.75
1.00
Rate

Rate

Amount
$1,000.00
$4,000.00
$560.00
$1,120.00
$720.00
$1,440.00

Rate

Amount
$400.00
$4,000.00
$560.00
$1,680.00
$910.00
$1,820.00

Rate

Amount
$2,500.00
$3,360.00
$2,160.00
$1,820.00

4.00
2.00
2.00

10.00
3.00
2.00

10.00
6.00
3.00
2.00

$250.00
$560.00
$720.00
$910.00
2

3