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)

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EXHIBIT Q From: Southwell, Alexander H. Sent: Friday, August 31, 2012 1:04 PM To: Dean Boland (dean@bolandlegal.com) Cc: paul.argentieri@gmail.com; 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

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