Mamadou v. Cho
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Opinion
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division
BINTA P. MAMADOU, et al., ) ) Plaintiffs, ) ) v. ) Civil Action No. 1:20-cv-146 (AJT/IDD) ) STANLEY KYUNGJIN CHO, et al., ) ) Defendants. ) ____________________________________)
ORDER On June 24, 2022, following an entry of default judgment as to liability, Plaintiffs Binta P. Mamadou and Visions Braid Bar, LLC moved for a default judgment as to damages, attorneys’ fees, and costs against Defendants Shadetree Management LLC, Ellen Kim, and Stanley Kyungjin Cho (together, the “Shadetree Defendants”). [Doc. No. 198] (the “Motion”). Plaintiffs sought $32,966.49 in damages, $649,228.50 in attorneys’ fees, and $10,099.43 in litigation costs with post-judgment interest at the statutory rate. Id. The Shadetree Defendants opposed the Motion. [Doc. No. 204]. On March 28, 2023, the Magistrate Judge issued a Report and Recommendation (the “R&R”), [Doc. No. 240], granting the Motion and recommending a total award of $692,294.42 to Plaintiffs. No objection to the R&R has been filed. The Court has conducted a de novo review of the evidence in this case1 and adopts and incorporates the findings and recommendations of the Magistrate Judge with respect to compensatory damages and litigation
1 The Shadetree Defendants did not file an objection to the R&R. While the Court is therefore not required to review the magistrate judge’s factual or legal conclusions if there is no objection, Thomas v. Arn, 474 U.S. 140, 150 (1985), it is nevertheless “free, after review, to accept, reject, or modify any of the magistrate judge’s findings or recommendations.” Wallace v. Hous. Auth. of Columbia, 791 F. Supp. 137, 138 (D.S.C. 1992) (citation omitted). costs, and for the reasons that follow adopts in part the R&R with respect to attorneys’ fees and will instead award $323,625.38 in fees. I. BACKGROUND The Court has previously summarized this case at length, but in relevant part, Plaintiffs
filed suit in 2020 against Bae’s Woodberry, LLC; Chan Hee Bae; and Young Woo Bae (together, the “Bae Defendants”) and the Shadetree Defendants. Centrally, Plaintiffs alleged discrimination and tortious interference with prospective economic relations based on Defendants’ alleged refusal to lease commercial property to Plaintiffs on account of Mamadou’s race and West African ancestry. See [Doc. No. 125] (summarizing the case). On November 6, 2020, the Court granted summary judgment in favor of the Bae Defendants, leaving only the Shadetree Defendants remaining in the case. Id. On February 19, 2021, Plaintiffs moved for default judgment as to liability against the Shadetree Defendants. [Doc. No. 144]. The Magistrate Judge then recommended default judgment be entered against the Shadetree Defendants as to Counts I and II, but limited its recommendation
to those two “discrimination counts in violation of federal law because they are central allegations in this matter, and the facts alleged support a finding of liability.” [Doc. No. 155] at 14-18. The Magistrate Judge did not make any recommendations or findings with respect to Counts III-V as alleged in the Amended Complaint. The Court then declined to adopt the Magistrate Judge’s recommendation, finding “entry of a default judgment is not warranted at this point.” [Doc. No. 163] at 3. However, roughly two months later the Court considered Plaintiffs’ renewed request for entry of default judgment and entered judgment against the Shadetree Defendants as to their liability on Counts I and II—claims under 42 U.S.C. § 1982 and § 1981, respectively. [Doc. No. 178]. Default was not, and has not, been entered against the Shadetree Defendants on the remaining Counts III-V. Plaintiffs later moved for a default judgment as to damages, attorneys’ fees, and costs against the Shadetree Defendants. [Doc. No. 198] (the “Motion”). The Magistrate Judge ultimately recommended granting the Motion and awarding in full the requested $32,966.49 in compensatory damages, $10,099.43 in costs, and $649,228.50 in attorneys’ fees. [Doc. No. 240].
On June 6, 2023, the Court ordered Plaintiffs to advise on their position as to how the case should proceed with respect to the outstanding Counts III-V. [Doc. No. 241]. In response, Plaintiffs proposed “to withdraw Counts III through V in the Complaint so long as doing so does not affect their right to full recovery as recommended by Magistrate Judge Davis.” [Doc. No. 242] at 1. Plaintiffs’ position is based on their assumption that “analysis of the additional counts is not necessary to award full relief,” and they therefore “support the Court’s efforts to preserve resources and accordingly propose to withdraw the additional counts to facilitate resolution of the matter.” Id. at 2. II. LEGAL STANDARD While ordinarily a prevailing party in a civil suit is not entitled to attorneys’ fees, statutory
schemes can provide otherwise. Ohio River Valley Envtl. Coal., Inc. v. Green Valley Coal Co., 511 F.3d 407, 413 (4th Cir. 2007) (quoting Alyeska Pipeline Serv. Co. v. Wilderness Soc’y, 421 U.S. 240, 247 (1975)). In § 1981 and § 1982 actions, courts, “in [their] discretion, may allow the prevailing party . . . a reasonable attorney’s fee.” 42 U.S.C. § 12205. Under Fourth Circuit precedent, to award appropriate attorneys’ fees district courts are to engage in a three-step process by (1) calculating the lodestar by multiplying the reasonable hours worked by a reasonable rate, (2) using the factors from Johnson v. Georgia Highway Express Inc., 488 F.2d 714, 717-19 (5th Cir. 1974)2 to determine the reasonability of the lodestar, and (3)
2 In adopting Johnson, the Fourth Circuit has characterized the twelve factors therein as follows: subtracting hours on unsuccessful claims. McAfee v. Boczar, 738 F.3d 81, 88 (4th Cir. 2013). Notably, McAfee quoted Supreme Court precedent for the proposition that the lodestar’s presumption of reasonableness “can only be overcome ‘in those rare circumstances where the lodestar does not adequately take into account a factor that may properly be considered in
determining a reasonable fee.’” Id. at 88-89 (quoting Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542, 553-54 (2010)). But Perdue was about a 75 percent enhancement that was applied, resulting in an attorneys’ fee award of roughly $10.5 million, which was above the lodestar. Perdue, 559 U.S. at 548. In other words, it was not about a lodestar presumption where a court contemplates reducing attorneys’ fees, and thus is distinguishable from the case now before the Court. Within the twelve-factor test, the Fourth Circuit has declared a plaintiff’s degree of success to be the most crucial component of a fee award inquiry: As the Supreme Court has recognized, ‘the most critical factor’ in calculating a reasonable fee award ‘is the degree of success obtained,’ and when ‘a plaintiff has achieved only partial or limited success, the [lodestar] may be an excessive amount.’ Hensley v. Eckerhart, 461 U.S. 424, 436 (1983) . . . . In accounting for the plaintiff’s limited success, a court should examine ‘the size of the proposed attorney’s fee . . .
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division
BINTA P. MAMADOU, et al., ) ) Plaintiffs, ) ) v. ) Civil Action No. 1:20-cv-146 (AJT/IDD) ) STANLEY KYUNGJIN CHO, et al., ) ) Defendants. ) ____________________________________)
ORDER On June 24, 2022, following an entry of default judgment as to liability, Plaintiffs Binta P. Mamadou and Visions Braid Bar, LLC moved for a default judgment as to damages, attorneys’ fees, and costs against Defendants Shadetree Management LLC, Ellen Kim, and Stanley Kyungjin Cho (together, the “Shadetree Defendants”). [Doc. No. 198] (the “Motion”). Plaintiffs sought $32,966.49 in damages, $649,228.50 in attorneys’ fees, and $10,099.43 in litigation costs with post-judgment interest at the statutory rate. Id. The Shadetree Defendants opposed the Motion. [Doc. No. 204]. On March 28, 2023, the Magistrate Judge issued a Report and Recommendation (the “R&R”), [Doc. No. 240], granting the Motion and recommending a total award of $692,294.42 to Plaintiffs. No objection to the R&R has been filed. The Court has conducted a de novo review of the evidence in this case1 and adopts and incorporates the findings and recommendations of the Magistrate Judge with respect to compensatory damages and litigation
1 The Shadetree Defendants did not file an objection to the R&R. While the Court is therefore not required to review the magistrate judge’s factual or legal conclusions if there is no objection, Thomas v. Arn, 474 U.S. 140, 150 (1985), it is nevertheless “free, after review, to accept, reject, or modify any of the magistrate judge’s findings or recommendations.” Wallace v. Hous. Auth. of Columbia, 791 F. Supp. 137, 138 (D.S.C. 1992) (citation omitted). costs, and for the reasons that follow adopts in part the R&R with respect to attorneys’ fees and will instead award $323,625.38 in fees. I. BACKGROUND The Court has previously summarized this case at length, but in relevant part, Plaintiffs
filed suit in 2020 against Bae’s Woodberry, LLC; Chan Hee Bae; and Young Woo Bae (together, the “Bae Defendants”) and the Shadetree Defendants. Centrally, Plaintiffs alleged discrimination and tortious interference with prospective economic relations based on Defendants’ alleged refusal to lease commercial property to Plaintiffs on account of Mamadou’s race and West African ancestry. See [Doc. No. 125] (summarizing the case). On November 6, 2020, the Court granted summary judgment in favor of the Bae Defendants, leaving only the Shadetree Defendants remaining in the case. Id. On February 19, 2021, Plaintiffs moved for default judgment as to liability against the Shadetree Defendants. [Doc. No. 144]. The Magistrate Judge then recommended default judgment be entered against the Shadetree Defendants as to Counts I and II, but limited its recommendation
to those two “discrimination counts in violation of federal law because they are central allegations in this matter, and the facts alleged support a finding of liability.” [Doc. No. 155] at 14-18. The Magistrate Judge did not make any recommendations or findings with respect to Counts III-V as alleged in the Amended Complaint. The Court then declined to adopt the Magistrate Judge’s recommendation, finding “entry of a default judgment is not warranted at this point.” [Doc. No. 163] at 3. However, roughly two months later the Court considered Plaintiffs’ renewed request for entry of default judgment and entered judgment against the Shadetree Defendants as to their liability on Counts I and II—claims under 42 U.S.C. § 1982 and § 1981, respectively. [Doc. No. 178]. Default was not, and has not, been entered against the Shadetree Defendants on the remaining Counts III-V. Plaintiffs later moved for a default judgment as to damages, attorneys’ fees, and costs against the Shadetree Defendants. [Doc. No. 198] (the “Motion”). The Magistrate Judge ultimately recommended granting the Motion and awarding in full the requested $32,966.49 in compensatory damages, $10,099.43 in costs, and $649,228.50 in attorneys’ fees. [Doc. No. 240].
On June 6, 2023, the Court ordered Plaintiffs to advise on their position as to how the case should proceed with respect to the outstanding Counts III-V. [Doc. No. 241]. In response, Plaintiffs proposed “to withdraw Counts III through V in the Complaint so long as doing so does not affect their right to full recovery as recommended by Magistrate Judge Davis.” [Doc. No. 242] at 1. Plaintiffs’ position is based on their assumption that “analysis of the additional counts is not necessary to award full relief,” and they therefore “support the Court’s efforts to preserve resources and accordingly propose to withdraw the additional counts to facilitate resolution of the matter.” Id. at 2. II. LEGAL STANDARD While ordinarily a prevailing party in a civil suit is not entitled to attorneys’ fees, statutory
schemes can provide otherwise. Ohio River Valley Envtl. Coal., Inc. v. Green Valley Coal Co., 511 F.3d 407, 413 (4th Cir. 2007) (quoting Alyeska Pipeline Serv. Co. v. Wilderness Soc’y, 421 U.S. 240, 247 (1975)). In § 1981 and § 1982 actions, courts, “in [their] discretion, may allow the prevailing party . . . a reasonable attorney’s fee.” 42 U.S.C. § 12205. Under Fourth Circuit precedent, to award appropriate attorneys’ fees district courts are to engage in a three-step process by (1) calculating the lodestar by multiplying the reasonable hours worked by a reasonable rate, (2) using the factors from Johnson v. Georgia Highway Express Inc., 488 F.2d 714, 717-19 (5th Cir. 1974)2 to determine the reasonability of the lodestar, and (3)
2 In adopting Johnson, the Fourth Circuit has characterized the twelve factors therein as follows: subtracting hours on unsuccessful claims. McAfee v. Boczar, 738 F.3d 81, 88 (4th Cir. 2013). Notably, McAfee quoted Supreme Court precedent for the proposition that the lodestar’s presumption of reasonableness “can only be overcome ‘in those rare circumstances where the lodestar does not adequately take into account a factor that may properly be considered in
determining a reasonable fee.’” Id. at 88-89 (quoting Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542, 553-54 (2010)). But Perdue was about a 75 percent enhancement that was applied, resulting in an attorneys’ fee award of roughly $10.5 million, which was above the lodestar. Perdue, 559 U.S. at 548. In other words, it was not about a lodestar presumption where a court contemplates reducing attorneys’ fees, and thus is distinguishable from the case now before the Court. Within the twelve-factor test, the Fourth Circuit has declared a plaintiff’s degree of success to be the most crucial component of a fee award inquiry: As the Supreme Court has recognized, ‘the most critical factor’ in calculating a reasonable fee award ‘is the degree of success obtained,’ and when ‘a plaintiff has achieved only partial or limited success, the [lodestar] may be an excessive amount.’ Hensley v. Eckerhart, 461 U.S. 424, 436 (1983) . . . . In accounting for the plaintiff’s limited success, a court should examine ‘the size of the proposed attorney’s fee . . . award in comparison with the total damage award.’ Thomas v. Peacock, 39 F.3d 493, 506 (4th Cir. 1994) rev’d on other grounds, 516 U.S. 349 (1966). ‘Such comparison promotes the court’s central responsibility to make the assessment of what is a reasonable fee under the circumstances of the case’ . . . . Farrar [v. Hobby], 506 U.S. [103,] 114-15 [(1992)] (quoting Blanchard v. Bergeron, 489 U.S. 87, 96 (1989)).
McDonnell v. Miller Oil Co., Inc., 134 F.3d 638, 641 (4th Cir. 1998) (other citations omitted). After considering the Johnson factors and examining a plaintiff’s degree of success, a court can
(1) The time and labor expended; (2) the novelty and difficulty of the questions raised; (3) the skill required to properly perform the legal services rendered; (4) the attorney’s opportunity costs in pressing the instant litigation; (5) the customary fee for like work; (6) the attorney’s expectations at the outset of the litigation; (7) the time limitations imposed by the client or circumstances; (8) the amount in controversy and the results obtained; (9) the experience, reputation, and ability of the attorney; (10) the undesirability of the case within the legal community in which the suit arose; (11) the nature and length of the professional relationship between attorney and client; and (12) attorneys’ fees awards in similar cases. Barber v. Kimbrell’s Inc., 577 F.2d 216, 226 n.28 (4th Cir. 1978). apply an overall reduction to the lodestar. See, e.g., Smith v. Loudoun County Pub. Schs., No. 1:15- cv-956, 2017 WL 176510, at *5 (E.D. Va. Jan. 17, 2017) (applying a 25 percent reduction in a plaintiff’s attorneys’ fees, in part because “the amount Plaintiff ultimately recovered was small”). III. ANALYSIS
For the reasons that follow, the Court will award in full the compensatory damages and litigation costs, dismiss Counts III-V, and reduce the requested attorneys’ fees. A. Procedural Posture The Court will dismiss Counts III-V because the allegations supporting Counts I and II largely mirror those required to support the other three counts, and whether default judgment is entered on the three remaining counts would not alter the Court’s findings with respect to compensatory damages because Plaintiffs sought damages jointly on all counts based on the evidence proffered. Additionally, the Court would decline to award attorneys’ fees for any work performed in furtherance of Counts III-V at this stage of the litigation.3 Therefore, because requiring Plaintiffs to seek default judgment on the remaining Counts would not meaningfully
assist in the Court’s determination of an attorneys’ fees award and would waste the parties’ and the Court’s resources, the Court will dismiss Counts III – V so as not to unnecessarily and wastefully prolong this litigation. B. Compensatory Damages and Costs Having conducted a de novo review of the record, the Court adopts and incorporates the findings and recommendations of the Magistrate Judge in full with respect to the award of $32,966.49 in compensatory damages and $10,099.43 in costs.
3 It is unclear whether Plaintiffs’ conditional consent to dismiss Counts III-V based on “their right to full recovery,” [Doc. No. 242] at 2, contemplated “full recovery” as measured by the compensatory damage and costs recommended by the Magistrate Judge or also the recommended attorney’s fees. In either event, the Court will dismiss these remaining counts for the reasons stated. C. Attorneys’ Fees The Court will apply the three-step test as outlined in McAfee to determine the attorneys’ fee award in this matter. McAfee, 738 F.3d at 88. i. Lodestar
Plaintiffs’ attorneys, Warren T. Allen II and Ray D. McKenzie, collectively billed 961.8 hours at $675 per hour, equating to a lodestar of $649,228.50 after they applied certain deductions. [Doc. No. 199-J]. Attorneys Allen and McKenzie purported to not request fees related to work performed only with respect to the dismissed Bae Defendants, [Doc. No. 199] at 23; however, they seem to have missed certain line items. See, e.g., [Doc. No. 199-J] at 14 (“Draft follow-up emails to Bae Defendants re: settlement and discovery”); id. at 18 (“Review filings and research re: assertions of work product protection to oppose motion by Bae defendants”). Instances where the Court will not award any fees for certain line items are outlined in greater detail in Exhibit 1 attached to this Order. Additionally, the Court finds the deductions insufficient insofar as work was performed as
to both the Bae and Shadetree Defendants. See, e.g., id. at 1 (“Research potential claims and background information on potential parties and witnesses.”); id. at 3 (“Research cases based on discrimination against individuals of West African descent.”). Simply put, the Court will not permit Plaintiffs to recover attorneys’ fees in full with respect to work performed, even partially, as to Defendants that were awarded summary judgment in their favor. Accordingly, as outlined in Exhibit 1, the Court will reduce line items in the fee request by half where it is either clear that the work applied to both sets of Defendants, or where the billing descriptions are insufficient for the Court to determine how to attribute the work performed. These deductions are consistent with the third McAfee step to subtract fees on unsuccessful claims. The Court will not discount for lodestar purposes any line items that appear to relate solely to the Shadetree Defendants, including all billing entries dated after summary judgment was entered in favor of the Bae Defendants. Ultimately, after applying the aforementioned reductions as outlined in Exhibit 1, the Court finds the lodestar amount to be $431,500.50.
ii. Johnson Factors The Court will next apply the Johnson factors, as adopted by the Fourth Circuit in Barber, notwithstanding the fact that some courts have found certain of these factors less relevant or inapplicable where an application for statutory attorneys’ fees largely relates to discovery issues. See, e.g., United Supreme Council v. United Supreme Council of the Ancient Accepted Scottish Rite for the 33 Degree of Freemasonry, No. 1:16-cv-1103, 2019 U.S. Dist. LEXIS 222731, at *4 (E.D. Va. Jan. 17, 2019). First, as to the time and labor expended, this case was originally filed in February 2020 and Plaintiffs’ attorneys have dedicated considerable time and labor to it. With respect to the Shadetree Defendants, Plaintiffs’ attorneys have, inter alia, opposed a Motion to Dismiss, [Doc. No. 23];
filed an Amended Complaint, [Doc. No. 38]; moved to compel and for sanctions, repeatedly litigated other discovery issues, [Doc. Nos. 43, 63, 76, 91, 97, 132]; and moved for default judgment as to both liability and damages, [Doc. Nos. 144, 198]. Even accounting for the reductions the Court will apply to the lodestar as outlined in Exhibit 1, Plaintiffs’ attorneys expended over 600 hours on work attributable to the Shadetree Defendants. This factor weighs in favor of a significant fee award. With respect to the second and third factors, this case was relatively straightforward and neither contained any particularly novel or difficult questions nor demanded skills above that what would be regularly expected of attorneys appearing before the Court. Plaintiffs sued under frequently litigated state and federal discrimination laws and state business torts. And the litigation did not proceed to trial but instead ended in default judgment based on discovery failures, again a relatively routine legal issue. Therefore, these factors weigh against a substantial fee award.4 As to the fourth factor, it is unclear what the opportunity costs for Plaintiffs’ lawyers might
have been. However, between August 30, 2019 and January 28, 2022—the first and last billing entry dates on the time sheet—together, on average, even before any reductions are applied, Attorneys McKenzie and Allen each spent less than four hours per week on this litigation, which includes all tasks performed, including those related solely to the Bae Defendants.5 See McNeil v. Faneuil, Inc., No. 4:15-cv-81, 2017 WL 9771834, at *5 (E.D. Va. Nov. 8, 2017), report and recommendation adopted, 2018 WL 1411017 (E.D. Va. Mar. 21, 2018) (finding with respect to an attorneys’ fee application that an average of “less than one hour per day [is] not enough time to preclude a great deal of extra work”). Accordingly, this factor weighs against a substantial award. As to the fifth factor, the customary fee for civil rights cases is typically not a contingency based on a percentage, but rather statutory fees determined by a lodestar calculation. Accordingly,
the Court will consider under this fifth factor whether the hourly fee charged by the attorneys is customary. See Coggins v. Davis, No. WGC-05-248, 2007 WL 9782487, at *4 (D. Md. May 11, 2007) (applying the fifth Johnson factor). Plaintiffs’ two attorneys have a combined 47 years of practice, [Doc. No. 199] at 24, which places a $675 fee within the range of reasonable hourly rates for attorneys of like experience in Northern Virginia. See Entegee, Inc. v. Metters Indus., Inc., No. 1:17-cv-499, 2018 WL 3472819
4 While Plaintiffs’ attorneys contend that they “have never had to brief a single opponent’s discovery failures or its repeated failures to comply with court orders so many times or to attend so many hearings over such disputes,” [Doc. No. 199] at 24, this is all accounted for in their hours billed. Even accepting Plaintiffs’ attorneys’ representations as true, the frequency of the Shadetree Defendants’ discovery failures do not speak to the novelty, difficulty, or skills required in this litigation. 5 Plaintiffs’ attorneys accounted for 961.8 fee hours over the span of 126 weeks. This averages to 3.8 hours per attorney per week. (E.D. Va. July 19, 2018) (citing the frequently used hour fee matrix in commercial litigation cases established in Vienna Metro LLC v. Pulte Home Corp., 786 F. Supp. 2d 1090 (E.D. Va. 2011)). As to the sixth factor, it is unclear from the record what the attorneys’ expectations were at the outset of the litigation. However, as reflected in the relatively low compensatory damages,
there is little reason to think that the recovery was expected to be substantially beyond what was presented to the Magistrate Judge. On the other hand, the Shadetree Defendants’ discovery conduct was egregious and required significantly more attorney time than one would typically expect. Accordingly, this factor weighs in favor of a larger fee award than would typically be awarded to obtain a default judgment of less than $35,000 in compensatory damages. Similarly, with respect to the seventh factor, it is unclear what time limitations, if any, were imposed by the client, but the circumstances did require substantially more time litigating discovery disputes than is normal for this type of case. Accordingly, this factor also weighs in favor of a larger fee award. The eighth factor – the amount in controversy and the results obtained – is by far the most
important. McDonnell, 134 F.3d at 641. Here, the Amended Complaint did not include a specific demand, but rather sought both compensatory and punitive damages to be proven at trial. [Doc. No. 38] at 31. But in their Motion for Default Judgment as to Damages, Plaintiffs sought only $32,966.49 in compensatory damages. This can hardly be described as a particularly favorable result for the purposes of seeking twenty times as much in attorneys’ fees. See Thomas, 39 F.3d at 506 (examining “the size of the proposed attorney’s fee . . . award in comparison with the total damage award”); see also Farrar, 506 U.S. at 114-15 (finding that comparing the damage award to the attorneys’ fees “promotes the court’s central responsibility to make the assessment of what is a reasonable fee under the circumstances of the case”) (quotation omitted). Additionally, while this suit is based on federal question jurisdiction, it is worth noting that the compensatory damages are less than half of the required amount in controversy had this action been based on diversity jurisdiction. Accordingly, this factor weighs heavily against the requested attorneys’ fees. Attorneys Allen and McKenzie are experienced and evidenced a level of professionalism,
competence and diligence that speaks well of them. Accordingly, the ninth factor weighs in their favor. As to the tenth factor, civil rights cases are desirable and there are many attorneys who handle such cases in this District. However, the desirability diminishes in cases like this one with such small compensatory damages; therefore, this factor weighs in their favor. With respect to the eleventh factor, the Court has no information as to the nature and length of the professional relationship between Plaintiffs and their attorneys. Finally, as to the twelfth factor, the Court has been unable to locate a similar civil rights case where one set of defendants is granted summary judgment in their favor and the other has a default judgment entered against them essentially based on discovery noncompliance, notwithstanding their limited participation in the litigation, and where the compensatory damages
are five percent of the requested attorneys’ fees. Accordingly, this factor is neutral. Ultimately, upon consideration of the Johnson factors, the Court finds that while certain factors pull in different directions, the most important factor – the results obtained – weighs heavily in favor of an award below the revised lodestar amount. Accordingly, after carefully weighing the Johnson factors, the Court will apply a twenty-five (25) percent reduction to the revised $431,500.50 lodestar6 and award $323,625.38 in attorneys’ fees.
6 Given the circumstances surrounding the dismissal of Counts III-V, the Court will not subtract further from the award based on the third McAfee step, see McAfee, 738 F.3d at 88 (identifying the third step as the subtraction of hours spent on unsuccessful claims), as it did based on the unsuccessful claims against the Bae Defendants. IV. CONCLUSION Accordingly, for the foregoing reasons, it is hereby ORDERED that Counts III-V in the Amended Complaint, [Doc. No. 38], be, and the same hereby are, DISMISSED; and it is further ORDERED based on the Court’s adoption in part of the Magistrate Judge’s Report and Recommendation, [Doc. No. 240], judgment be, and the same hereby is, entered in favor of Plaintiffs and against Defendants Shadetree Management LLC, Ellen Kim, and Stanley Kyungjin Cho, jointly and severally, in the amount of $32,966.49 in compensatory damages, $10,099.43 in costs, and $323,625.38 in attorneys’ fees, for a total judgment of $366,691.30, with post-judgment interest at the statutory rate. The Clerk is directed to enter judgment under Rule 58 in accordance with this Order and forward a copy of this Order to all counsel of record.
August 30, 2023 Alexandria, Virginia
Senior District Judge
Exhibit 1 Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 13 of 41 PageID# 4460
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 8/30/2019 Call with client re: factual background and 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and (with client) potential claims Shadetree Review/analyze 9/1/2019 Research potential claims and background 2.7 2.7 $675.00 $1,822.50Warren T. Allen II 50% $911.25Applies to Bae and information on potential parties and witnesses Shadetree (e.g., tax records, corporate registries, land records, professional licenses, and other public records) Communicate (in 9/2/2019 Call with R. McKenzie re: preliminary research 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and firm) findings related to potential claims and to assign Shadetree follow-up research tasks Communicate (in 9/2/2019 Call with W. Allen re: preliminary research findings 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and firm) related to potential claims and to assign follow-up Shadetree research tasks Research 9/2/2019 Research potential discrimination claims 4.4 4.4 $675.00 $2,970.00Warren T. Allen II 50% $1,485.00Applies to Bae and Shadetree Communicate (in 9/2/2019 Draft correspondence to R. McKenzie re: 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and firm) information obtained from client re: claims and Shadetree research tasks Research 9/2/2019 Research available claims and exhaustion 1.6 1.6 $675.00 $1,080.00Warren T. Allen II 50% $540.00Applies to Bae and requirements Shadetree Communicate 9/2/2019 Draft email to client summarizing initial research 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and (with client) findings Shadetree Communicate 9/3/2019 Draft and revise summary of research on potential 1.8 1.8 $675.00 $1,215.00Warren T. Allen II 50% $607.50Applies to Bae and (with client) claims and findings re: parties obtained from Shadetree public record searches for client Research 9/3/2019 Conduct research regarding potential claims 4.5 4.5 $675.00 $3,037.50Ray D. McKenzie 50% $1,518.75Applies to Bae and available under VA and MD state law for the Shadetree discriminatory acts. Communicate 9/3/2019 Consult with outside Maryland counsel regarding 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and (other outside potential claims available based upon Shadetree counsel) discriminatory acts, specifically claims potentially available pursuant to Maryland state and local law. Research 9/3/2019 Research potential claims and background 3.6 3.6 $675.00 $2,430.00Warren T. Allen II 50% $1,215.00Applies to Bae and information on potential parties and witnesses Shadetree (e.g., tax records, corporate registries, land records, professional licenses, and other public records) Communicate (in 9/4/2019 Draft and respond to emails regarding research 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and firm) into potential claims available under VA and MD Shadetree law for the discriminatory acts, administrative exhaustion requirements under federal, state, and local law, and relevant statutes of limitations. Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 14 of 41 PageID# 4461
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 9/4/2019 Draft and send client a summary of research and 1.8 1.8 $675.00 $1,215.00Warren T. Allen II 50% $607.50Applies to Bae and (with client) factual findings prepared to facilitate discussion Shadetree re: potential claims and to respond to client request for info re: potential claims Plan and prepare 9/5/2019 Draft interview outline to prepare for a call to 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and for obtain factual background from client Shadetree Communicate 9/5/2019 Call with client regarding potential claims 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and (with client) Shadetree Communicate 9/5/2019 Call with client regarding potential claims 1.5 1.5 $675.00 $1,012.50Warren T. Allen II 50% $506.25Applies to Bae and (with client) Shadetree Review/analyze 9/9/2019 Review and revise notes from interview of client in 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and preparation for drafting complaint. Shadetree Review/analyze 9/9/2019 Research sample civil rights complaints to prepare 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and to draft complaint. Shadetree Draft/revise 9/9/2019 Begin drafting civil complaint. 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and Shadetree Draft/revise 9/10/2019 Draft civil complaint 2.6 2.6 $675.00 $1,755.00Ray D. McKenzie 50% $877.50Applies to Bae and Shadetree Research 9/10/2019 Research jury instructions for Section 1981 and 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and 1982 claims Shadetree Draft/revise 9/10/2019 Review electronic mail and notes from client 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and interview to draft narrative to be used in civil Shadetree complaint. Draft/revise 9/11/2019 Draft civil complaint 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and Shadetree Research 9/12/2019 Research principal’s liability for agent’s 0.4 0.4 $675.00 $270.00Warren T. Allen II 100% $0.00Attributable to Bae discrimination to draft complaint only Draft/revise 9/13/2019 Draft civil complaint 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and Shadetree Communicate (in 9/13/2019 Draft email summarizing observations re: claims 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and firm) based on review of materials Shadetree Review/analyze 9/13/2019 Review lease to analyze claims and damages 1.4 1.4 $675.00 $945.00Warren T. Allen II 50% $472.50Applies to Bae and Shadetree Communicate (in 9/14/2019 Draft email responding to W. Allen's observations 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and firm) regarding lease agreement. Shadetree Research 9/16/2019 Research public filings re: potential parties and 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and witnesses Shadetree Research 9/17/2019 Research Maryland cases regarding unreasonably 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and withholding consent of an assignment Shadetree Draft/revise 9/17/2019 Draft civil complaint 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and Shadetree Research 9/18/2019 Research Section 1981 claims 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 15 of 41 PageID# 4462
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 9/18/2019 Call with client re: claims and supporting 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and (with client) documentation (.5); draft related correspondence Shadetree with client re: documentation (.6) Communicate 9/18/2019 Call with client re: claims and relevant 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and (with client) documentation Shadetree Review/analyze 9/18/2019 Review documents from the client and create 3.1 3.1 $675.00 $2,092.50Ray D. McKenzie 50% $1,046.25Applies to Bae and timeline of key events Shadetree Research 9/19/2019 Review S. Cho criminal docket sheet and 0.2 0.2 $675.00 $135.00Ray D. McKenzie 0% $135.00Attributable to judgment. Shadetree only Research 9/19/2019 Research re: Maryland implied covenant of good 1.4 1.4 $675.00 $945.00Ray D. McKenzie 50% $472.50Applies to Bae and faith contractual relationships and proscription Shadetree against unreasonably withholding consent to assignment or sublease. Communicate (in 9/19/2019 Communicate with R. McKenzie re: research 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and firm) findings, preparation for client meeting, and Shadetree factual background Communicate (in 9/19/2019 Communicate with W. Allen re: research findings, 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and firm) preparation for client meeting, and factual Shadetree background Draft/revise 9/19/2019 Review and analyze documents received from 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and client to draft timeline of key events and emails. Shadetree Draft/revise 9/19/2019 Draft civil complaint. 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and Shadetree Draft/revise 9/20/2019 Draft civil complaint 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Communicate 9/20/2019 Meet with client to discuss background, case 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and (with client) developments, and next steps. Shadetree Communicate 9/20/2019 Meet with client to discuss background, case 1.5 1.5 $675.00 $1,012.50Warren T. Allen II 50% $506.25Applies to Bae and (with client) developments, and next steps. Shadetree Communicate 9/20/2019 Draft correspondence to client re: engagement 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) and obtaining supporting documentation to Shadetree facilitate preparation of complaint Research 9/21/2019 Research agency liability issues and admissibility 1.3 1.3 $675.00 $877.50Warren T. Allen II 100% $0.00Attributable to Bae of statements only Research 9/23/2019 Research corporate standing to bring race 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and discrimination claim Shadetree Draft/revise 9/23/2019 Update timeline of key events and emails based 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and upon client meeting Shadetree Draft/revise 9/23/2019 Update Case Memo factual background/timeline 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and Shadetree Research 9/24/2019 Research cases based on discrimination against 2.4 2.4 $675.00 $1,620.00Ray D. McKenzie 50% $810.00Applies to Bae and individuals of West African descent. Shadetree Research 9/24/2019 Research re: Fairfax human rights ordinance 2 2 $675.00 $1,350.00Ray D. McKenzie 50% $675.00Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 16 of 41 PageID# 4463
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Research 9/25/2019 Research Fairfax County Human Rights Ordinance 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and and potential availability of private right of action. Shadetree Communicate (in 9/25/2019 Draft email regarding research re: Fairfax County 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and firm) Human Rights Ordinance and private right of Shadetree action Research 9/26/2019 Research re: section 1982 elements and claims 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and Shadetree Research 9/26/2019 Research legislative history of Virginia statutes 2.3 2.3 $675.00 $1,552.50Warren T. Allen II 50% $776.25Applies to Bae and and county ordinance prohibiting discrimination Shadetree Research 9/27/2019 Research scope of agency liability for 2.3 2.3 $675.00 $1,552.50Warren T. Allen II 50% $776.25Applies to Bae and discrimination Shadetree Research 9/30/2019 Research re: race discrimination claims by 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and business entities Shadetree Draft/revise 9/30/2019 Draft civil complaint 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Shadetree Draft/revise 9/30/2019 Update parties section of case memo 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and Shadetree Draft/revise 10/7/2019 Review relevant materials and draft background 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and on parties in case file memorandum Shadetree Research 10/7/2019 Research spousal privilege under federal common, 2 2 $675.00 $1,350.00Ray D. McKenzie 50% $675.00Applies to Bae and Virginia, and Maryland law Shadetree Research 10/8/2019 Research spousal privilege under federal common 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and law Shadetree Research 10/11/2019 Research elements of Section 1982 claims and 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and update case memo Shadetree Communicate 10/14/2019 Draft email to client re: status of case and 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) documentation to support claims Shadetree Review/analyze 10/14/2019 Review documents received from client 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and Shadetree Review/analyze 10/15/2019 Review documents provided by client and add to 1.9 1.9 $675.00 $1,282.50Ray D. McKenzie 50% $641.25Applies to Bae and timeline of events Shadetree Review/analyze 10/15/2019 Review and analyze background documents 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and provided by client to draft complaint Shadetree Research 10/16/2019 Research Stanley Cho CPA license history and 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to update case memo Shadetree only Review/analyze 10/16/2019 Review documents received from the client and 2.8 2.8 $675.00 $1,890.00Ray D. McKenzie 50% $945.00Applies to Bae and update timeline Shadetree Communicate (in 10/16/2019 Communicate with R. McKenzie re: case strategy 0.5 0.5 $675.00 $337.50Warren T. Allen II 50% $168.75Applies to Bae and firm) and background documents provided by client Shadetree Communicate (in 10/16/2019 Communicate with W. Allen re: case strategy and 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and firm) background documents provided by client Shadetree Communicate 10/17/2019 Draft emails to client regarding next steps and 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (with client) upcoming meeting Shadetree Review/analyze 10/17/2019 Review documents received from the client and 2.9 2.9 $675.00 $1,957.50Ray D. McKenzie 50% $978.75Applies to Bae and update timeline Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 17 of 41 PageID# 4464
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Review/analyze 10/18/2019 Review documents provided by the client and 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and update timeline Shadetree Draft/revise 10/21/2019 Review timeline and draft civil complaint 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and Shadetree Research 10/23/2019 Research application of Maryland long-arm 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and statute and choice of law analysis regarding Shadetree application of local discrimination ordinance. Draft/revise 10/25/2019 Draft C. Williams affidavit 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and Shadetree Draft/revise 10/28/2019 Draft interview outline for C. Williams interview 5.9 5.9 $675.00 $3,982.50Ray D. McKenzie 50% $1,991.25Applies to Bae and Shadetree Draft/revise 10/29/2019 Draft and revise C. Williams affidavit 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and Shadetree Draft/revise 10/29/2019 Review and revise witness interview outline and 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and affidavit to prepare for meeting with witness Shadetree Communicate 10/30/2019 Call with client re: C. Williams interview 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and (with client) Shadetree Appear for/attend 10/30/2019 Conduct C. Williams witness interview 1.4 1.4 $675.00 $945.00Ray D. McKenzie 50% $472.50Applies to Bae and Shadetree Appear for/attend 10/30/2019 Conduct C. Williams witness interview 1.4 1.4 $675.00 $945.00Warren T. Allen II 50% $472.50Applies to Bae and Shadetree Research 10/30/2019 Review filings in upcoming, relevant Supreme 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Court case: Comcast v. NAAAOM. Shadetree Communicate 11/4/2019 Call with client re: C. Williams interview 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) Shadetree Draft/revise 11/5/2019 Draft and revise civil complaint 3 3 $675.00 $2,025.00Ray D. McKenzie 50% $1,012.50Applies to Bae and Shadetree Draft/revise 11/6/2019 Draft and revise civil complaint 3.5 3.5 $675.00 $2,362.50Ray D. McKenzie 50% $1,181.25Applies to Bae and Shadetree Draft/revise 11/10/2019 Draft demand letter 1.7 1.7 $675.00 $1,147.50Ray D. McKenzie 50% $573.75Applies to Bae and Shadetree Draft/revise 11/11/2019 Revise demand letter 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and Shadetree Draft/revise 11/12/2019 Draft and revise complaint 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Draft/revise 11/13/2019 Draft and revise complaint 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Research 11/14/2019 Research availability of punitive damage under 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 50% $540.00Applies to Bae and Virginia and Maryland law Shadetree Draft/revise 11/14/2019 Draft and revise complaint 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 50% $540.00Applies to Bae and Shadetree Research 11/15/2019 Read Supreme Court transcript of Comcast 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and discrimination case and briefing regarding Shadetree applicable pleading standard for Section 1981 claims Draft/revise 11/20/2019 Review and revise complaint 1.7 1.7 $675.00 $1,147.50Ray D. McKenzie 50% $573.75Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 18 of 41 PageID# 4465
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 11/22/2019 Revise demand letters to the defendants 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and Shadetree Communicate 11/22/2019 Place call and draft email to client re: case update 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (with client) and complaint Shadetree Communicate (in 11/25/2019 Call with W. Allen re: proposed revisions to 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and firm) complaint Shadetree Communicate (in 11/25/2019 Call with R. McKenzie re: proposed revisions to 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and firm) complaint Shadetree Draft/revise 11/26/2019 Revise draft complaint 2.2 2.2 $675.00 $1,485.00Ray D. McKenzie 50% $742.50Applies to Bae and Shadetree Draft/revise 11/26/2019 Revise drafts of demand letters 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and Shadetree Draft/revise 11/27/2019 Revise complaint 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and Shadetree Communicate 11/27/2019 Draft email to client re: case update and 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (with client) complaint Shadetree Communicate 11/27/2019 Place call and draft email to C. Williams re: 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (other external) requested document Shadetree Communicate 11/29/2019 Communicate with client re: draft filings 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and (with client) Shadetree Research 12/2/2019 Research admission of adoptive or tacit 3 3 $675.00 $2,025.00Ray D. McKenzie 50% $1,012.50Applies to Bae and admissions as non-hearsay evidence Shadetree Communicate 12/23/2019 Communicate with client re: revisions to draft 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and (with client) complaint Shadetree Communicate 12/23/2019 Communicate with client re: revisions to draft 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and (with client) complaint Shadetree Draft/revise 12/23/2019 Review proposed revisions from client and revise 2.1 2.1 $675.00 $1,417.50Ray D. McKenzie 50% $708.75Applies to Bae and complaint Shadetree Draft/revise 12/31/2019 Revise and edit draft complaint 1.2 1.2 $675.00 $810.00Ray D. McKenzie 50% $405.00Applies to Bae and Shadetree Draft/revise 1/2/2020 Revise and edit draft complaint 3.5 3.5 $675.00 $2,362.50Ray D. McKenzie 50% $1,181.25Applies to Bae and Shadetree Draft/revise 1/2/2020 Review and revise drafts of complaint and 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and demand letters Shadetree Communicate 1/8/2020 Draft email to S. Cho and E. Kim re: demand letter 0.3 0.3 $675.00 $202.50Ray D. McKenzie 0% $202.50Attributable to (other external) and draft complaint Shadetree only Research 1/8/2020 Research sale of Shadetree Management LLC 0.8 0.8 $675.00 $540.00Ray D. McKenzie 0% $540.00Attributable to property Shadetree only Review/analyze 1/11/2020 Review and analyze additional emails provided by 1.4 1.4 $675.00 $945.00Warren T. Allen II 50% $472.50Applies to Bae and witness and compare them to previously obtained Shadetree materials and statement of facts in draft complaint Communicate 1/17/2020 Draft email to S. Cho and E. Kim re: response to 0.6 0.6 $675.00 $405.00Ray D. McKenzie 0% $405.00Attributable to (other external) demand letter Shadetree only Communicate (in 1/18/2020 Call with R. McKenzie re: defendants' response to 0.2 0.2 $675.00 $135.00Warren T. Allen II 50% $67.50Applies to Bae and firm) complaint Shadetree Communicate (in 1/18/2020 Call with W. Allen re: defendants' response to 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and firm) complaint Shadetree Communicate 1/18/2020 Call with client re: defendants' response to draft 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and (with client) complaint Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 19 of 41 PageID# 4466
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 1/20/2020 Draft and revise correspondence to opposing 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and (other external) counsel Shadetree Communicate 1/20/2020 Draft correspondence to client re: settlement 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) status Shadetree Manage data/files 2/11/2020 Prepare final documents for filing; file complaint 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 50% $540.00Applies to Bae and and attendant documents Shadetree Communicate 2/24/2020 Communicate with client re: identification of 0.2 0.2 $675.00 $135.00Warren T. Allen II 50% $67.50Applies to Bae and (with client) opposing counsel and background research Shadetree Communicate 2/25/2020 Compile correspondence files for opposing 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and (other outside counsel and email them to opposing counsel with Shadetree counsel) request for clarification re: who they are representing Appear for/attend 7/14/2020 Attend deposition of Young Woo Bae 6.3 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly attributable to Bae Research 3/4/2020 Research availability of attorneys' fees in 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 100% $0.00Improper to be billed settlements as a prevailing party under 1988 Communicate 3/4/2020 Draft and revise proposed response to 1.7 1.7 $675.00 $1,147.50Warren T. Allen II 100% $0.00Description (other outside defendant's request for counter-offer insufficient to state counsel) which Defendant made settlement offer Research 3/4/2020 Research re: discrimination claims 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and Shadetree Communicate 3/4/2020 Letter to S. Park re: settlement 0.2 0.2 $675.00 $135.00Ray D. McKenzie 100% $0.00Description (other outside insufficient to state counsel) which Defendant made settlement offer Research 3/5/2020 Research attorney fee awards in settled civil rights 1.3 1.3 $675.00 $877.50Warren T. Allen II 100% $0.00Improper to be billed cases to respond to defendants' request for counter offer Communicate 3/5/2020 Revise draft response to opposing counsel's 2.6 2.6 $675.00 $1,755.00Warren T. Allen II 100% $0.00Description (other outside request for a counter offer insufficient to state counsel) which Defendant made settlement offer Communicate 3/6/2020 Email E. Kim, S. Cho, and Shadetree Management 0.2 0.2 $675.00 $135.00Ray D. McKenzie 0% $135.00Attributable to (other external) LLC re: waiver of service of process Shadetree only Research 3/10/2020 Research service of process rules under state law 1.3 1.3 $675.00 $877.50Warren T. Allen II 0% $877.50Attributable to in anticipation of needing to pursue formal service Shadetree only after defendants Kim, Cho, and Shadetree Management LLC did not respond to waiver Communicate 3/10/2020 Draft correspondence to process server re: 0.5 0.5 $675.00 $337.50Warren T. Allen II 0% $337.50Attributable to (other external) serving Defendants Cho, Kim, and Shadetree Shadetree only Management LLC Communicate 3/19/2020 Draft correspondence to client re: case 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) developments Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 20 of 41 PageID# 4467
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Research 4/8/2020 Research and summarize authority re: an 1.3 1.3 $675.00 $877.50Warren T. Allen II 50% $438.75Applies to Bae and unrepresented entity's ability to participate in a Shadetree Rule 26(f) conference, local pre-trial conference procedures, and process for obtaining default ruling against business entity for failing to engage counsel Draft/revise 4/9/2020 Draft discovery checklist 2.1 2.1 $675.00 $1,417.50Ray D. McKenzie 50% $708.75Applies to Bae and Shadetree Communicate 4/10/2020 Communicate with client re: defendant's motion 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) to dismiss, the court's pre-trial order, and case Shadetree developments Communicate 4/10/2020 Draft correspondence to client re: court ruling, 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and (with client) approaching deadlines, and case strategy Shadetree Communicate 4/11/2020 Communicate with client re: case status updates 0.5 0.5 $675.00 $337.50Warren T. Allen II 50% $168.75Applies to Bae and (with client) and defendants' motion to dismiss Shadetree Research 4/11/2020 Conduct research re motion to dismiss 1.9 1.9 $675.00 $1,282.50Ray D. McKenzie 50% $641.25Applies to Bae and Shadetree Research 4/13/2020 Conduct research re motion to dismiss 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and Shadetree Communicate 4/13/2020 Call with client and W. Allen re: case filings, Rule 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and (with client) 26(f) conference, and other case management Shadetree issues Communicate 4/13/2020 Call with client and R. McKenzie re: case filings, 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and (with client) Rule 26(f) conference, and other case Shadetree management issues Review/analyze 7/19/2020 Review Defendants' productions in preparation 2.5 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly for S. Cho deposition attributable to Bae Review/analyze 7/20/2020 Review defendant's productions in preparation for 2 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly S. Cho deposition attributable to Bae Communicate (in 4/14/2020 Call with R. McKenzie re: preparing for Rule 26(f) 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and firm) conference, responding to Defendants' motion to Shadetree dismiss, and case preparation Communicate (in 4/14/2020 Call with W. Allen re: preparing for Rule 26(f) 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and firm) conference, responding to Defendants' motion to Shadetree dismiss, and case preparation Communicate 4/14/2020 Draft correspondence to opposing counsel re: 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (other outside Rule 26(f) conference scheduling and setting Shadetree counsel) motions for argument Draft/revise 4/14/2020 Draft response to defendants' agency arguments 1.7 1.7 $675.00 $1,147.50Warren T. Allen II 50% $573.75Applies to Bae and Shadetree Research 4/14/2020 Conduct research for response to motion to 3.2 3.2 $675.00 $2,160.00Ray D. McKenzie 50% $1,080.00Applies to Bae and dismiss Shadetree Communicate 4/15/2020 Call with R. McKenzie and counsel for Defendants 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (other outside to prepare discovery plan per Rule 26(f) Shadetree counsel) Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 21 of 41 PageID# 4468
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 4/15/2020 Call with W. Allen and counsel for Defendants to 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and (other outside prepare discovery plan per Rule 26(f) Shadetree counsel) Communicate (in 4/15/2020 Call with R. McKenzie re: Rule 26(f) conference 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and firm) and proposed revisions to draft discovery plan Shadetree Communicate (in 4/15/2020 Call with W. Allen to prepare for Rule 26(f) meet 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and firm) and confer Shadetree Draft/revise 4/15/2020 Draft response to motion to dismiss 3.7 3.7 $675.00 $2,497.50Ray D. McKenzie 50% $1,248.75Applies to Bae and Shadetree Research 4/16/2020 Conduct research re response to motion to 4.2 4.2 $675.00 $2,835.00Ray D. McKenzie 50% $1,417.50Applies to Bae and dismiss Shadetree Draft/revise 4/16/2020 Draft response to motion to dismiss 3.9 3.9 $675.00 $2,632.50Ray D. McKenzie 50% $1,316.25Applies to Bae and Shadetree Draft/revise 4/17/2020 Draft response to motion to dismiss 4.6 4.6 $675.00 $3,105.00Ray D. McKenzie 50% $1,552.50Applies to Bae and Shadetree Research 4/17/2020 Conduct legal research re: response to motion to 4.8 4.8 $675.00 $3,240.00Ray D. McKenzie 50% $1,620.00Applies to Bae and dismiss Shadetree Draft/revise 4/17/2020 Revise proposed Rule 26(f) discovery plan 3.8 3.8 $675.00 $2,565.00Warren T. Allen II 50% $1,282.50Applies to Bae and Shadetree Research 4/18/2020 Conduct research re: response to motion to 4.6 4.6 $675.00 $3,105.00Ray D. McKenzie 50% $1,552.50Applies to Bae and dismiss Shadetree Draft/revise 4/19/2020 Draft response to motion to dismiss 5.8 5.8 $675.00 $3,915.00Ray D. McKenzie 50% $1,957.50Applies to Bae and Shadetree Communicate (in 4/19/2020 Call with R. McKenzie re: coordinating discovery 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and firm) and disclosures Shadetree Communicate (in 4/19/2020 Call with W. Allen re: coordinating discovery and 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and firm) disclosures Shadetree Communicate 4/19/2020 Call with client and W. Allen re: initial disclosures, 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and (with client) discovery, case status, and litigation strategy Shadetree Communicate 4/19/2020 Call with client and R. McKenzie re: initial 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and (with client) disclosures, discovery, case status, and litigation Shadetree strategy Draft/revise 4/19/2020 Revise draft of joint discovery plan and review 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and related authorities Shadetree Research 4/20/2020 Conduct research re: response to motion to 5.2 5.2 $675.00 $3,510.00Ray D. McKenzie 50% $1,755.00Applies to Bae and dismiss Shadetree Draft/revise 4/20/2020 Draft response to motion to dismiss 4.5 4.5 $675.00 $3,037.50Ray D. McKenzie 50% $1,518.75Applies to Bae and Shadetree Research 4/21/2020 Conduct research re: response to motion to 3.8 3.8 $675.00 $2,565.00Ray D. McKenzie 50% $1,282.50Applies to Bae and dismiss Shadetree Research 4/21/2020 Research issue re: llc members' liability to respond 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and to motion to dismiss Shadetree Research 4/22/2020 Conduct research re: response to motion to 3.9 3.9 $675.00 $2,632.50Ray D. McKenzie 50% $1,316.25Applies to Bae and dismiss Shadetree Draft/revise 4/22/2020 Revise response to motion to dismiss 2.2 2.2 $675.00 $1,485.00Ray D. McKenzie 50% $742.50Applies to Bae and Shadetree Draft/revise 4/23/2020 Edit and cite-check response to motion to dismiss 4 4 $675.00 $2,700.00Ray D. McKenzie 50% $1,350.00Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 22 of 41 PageID# 4469
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 4/23/2020 Communicate with client re: draft of response to 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) motions to dismiss Shadetree Draft/revise 4/24/2020 Edit and cite check response to motion to dismiss 8.3 8.3 $675.00 $5,602.50Ray D. McKenzie 50% $2,801.25Applies to Bae and Shadetree Draft/revise 4/26/2020 Prepare initial disclosures and review relevant 2.1 2.1 $675.00 $1,417.50Warren T. Allen II 50% $708.75Applies to Bae and requirements Shadetree Draft/revise 4/26/2020 Review and edit initial disclosures 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and Shadetree Draft/revise 4/27/2020 Draft interrogatories for all defendants 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and Shadetree Communicate (in 4/28/2020 Call with R. McKenzie re: coordinating discovery 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and firm) responses and requests Shadetree Draft/revise 4/28/2020 Prepare discovery requests 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and Shadetree Draft/revise 4/28/2020 Draft interrogatories for all defendants 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and Shadetree Communicate (in 4/28/2020 Call with W. Allen re: discovery and case 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and firm) developments Shadetree Communicate 4/28/2020 Review local rules, federal rules, and April 10 1.6 1.6 $675.00 $1,080.00Warren T. Allen II 50% $540.00Applies to Bae and (other outside order; draft revisions to joint discovery plan; and Shadetree counsel) prepare related correspondence to all defendants re: proposed revisions to the plan Draft/revise 4/29/2020 Finalize Rule 26(f) Joint Discovery Plan 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and Shadetree Communicate 4/29/2020 Communicate with potential witnesses 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and (other external) Shadetree Appear for/attend 7/20/2020 Attend deposition of Defendant E. Kim 7 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 4/29/2020 Prepare initial disclosures 2.9 2.9 $675.00 $1,957.50Warren T. Allen II 50% $978.75Applies to Bae and Shadetree Appear for/attend 7/21/2020 Attend deposition of S. Cho 8.6 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 4/29/2020 Draft discovery requests 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Review/analyze 4/29/2020 Review/proofread plaintiffs' initial disclosures 0.1 0.1 $675.00 $67.50Ray D. McKenzie 50% $33.75Applies to Bae and Shadetree Appear for/attend 7/31/2020 Attend C. Williams deposition 6.9 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Review/analyze 4/30/2020 Review defendants' reply briefs 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and Shadetree Draft/revise 4/30/2020 Draft interview outlines for witness interviews 1.9 1.9 $675.00 $1,282.50Ray D. McKenzie 50% $641.25Applies to Bae and Shadetree Communicate 4/30/2020 Interview potential witness 1.2 1.2 $675.00 $810.00Warren T. Allen II 50% $405.00Applies to Bae and (other external) Shadetree Communicate 4/30/2020 Communicate with client re: witness interview 0.2 0.2 $675.00 $135.00Warren T. Allen II 50% $67.50Applies to Bae and (with client) Shadetree Research 5/2/2020 Visit Woodberry Square 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 23 of 41 PageID# 4470
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Plan and prepare 5/4/2020 Review court opinions and briefs to prepare for 7 7 $675.00 $4,725.00Ray D. McKenzie 50% $2,362.50Applies to Bae and for oral argument on defendants’ motions to dismiss Shadetree Draft/revise 5/4/2020 Prepare discovery demands to serve on all 1.42 1.42 $675.00 $958.50Warren T. Allen II 50% $479.25Applies to Bae and defendants Shadetree Plan and prepare 5/5/2020 Review court opinions and briefs to prepare for 7.8 7.8 $675.00 $5,265.00Ray D. McKenzie 50% $2,632.50Applies to Bae and for oral argument on defendants’ motions to dismiss Shadetree Plan and prepare 5/6/2020 Review court opinions and briefs to prepare for 8.7 8.7 $675.00 $5,872.50Ray D. McKenzie 50% $2,936.25Applies to Bae and for oral argument on defendants’ motions to dismiss Shadetree Communicate 5/6/2020 Coordinate attendance at oral arguments with 0.2 0.2 $675.00 $135.00Warren T. Allen II 50% $67.50Applies to Bae and (other external) defendants, court, and client Shadetree Draft/revise 5/6/2020 Draft and revise document production requests 2.1 2.1 $675.00 $1,417.50Warren T. Allen II 50% $708.75Applies to Bae and for all defendants Shadetree Draft/revise 5/6/2020 Draft requests for production and interrogatories 4.9 4.9 $675.00 $3,307.50Warren T. Allen II 50% $1,653.75Applies to Bae and to serve on all defendants Shadetree Draft/revise 5/7/2020 Review and edit requests for production 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Shadetree Communicate (in 5/7/2020 Moot oral argument with co-counsel to prepare 1.5 1.5 $675.00 $1,012.50Warren T. Allen II 50% $506.25Applies to Bae and firm) for hearing on motions to dismiss by all parties Shadetree Communicate (in 5/7/2020 Moot oral argument with co-counsel to prepare 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and firm) for hearing on motions to dismiss by all parties Shadetree Plan and prepare 5/8/2020 Prepare for hearing on motions to dismiss 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and for Shadetree Appear for/attend 5/8/2020 Attend oral argument on motion to dismiss 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and Shadetree Appear for/attend 5/8/2020 Attend oral argument on motion to dismiss 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and Shadetree Draft/revise 5/8/2020 Draft interrogatories to serve on all defendants 1.4 1.4 $675.00 $945.00Warren T. Allen II 50% $472.50Applies to Bae and Shadetree Review/analyze 5/11/2020 Review order denying all defendants' motions to 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and dismiss Shadetree Communicate 5/11/2020 Call to interview potential witness re: claims 3.3 3.3 $675.00 $2,227.50Warren T. Allen II 50% $1,113.75Applies to Bae and (other external) against all defendants Shadetree Communicate 5/11/2020 Call to interview potential witness re: claims 3.3 3.3 $675.00 $2,227.50Ray D. McKenzie 50% $1,113.75Applies to Bae and (other external) against all defendants Shadetree Review/analyze 5/11/2020 Review order denying motions to dismiss 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Shadetree Communicate 5/12/2020 Call with client re: order on motions to dismiss, 1.3 1.3 $675.00 $877.50Warren T. Allen II 50% $438.75Applies to Bae and (with client) case status, and discovery Shadetree Communicate 5/12/2020 Communicate with client re: ruling on motion to 1.3 1.3 $675.00 $877.50Ray D. McKenzie 50% $438.75Applies to Bae and (with client) dismiss and next steps Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 24 of 41 PageID# 4471
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 5/12/2020 Prepare amendment to complaint, motion to 2.6 2.6 $675.00 $1,755.00Warren T. Allen II 50% $877.50Applies to Bae and amend, and related correspondence to update Shadetree name of defendant in light of 7.1 disclosure and court's order on motions to dismiss Communicate 5/14/2020 Draft correspondence to client re: case status 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and (with client) developments and settlement options Shadetree Review/analyze 5/15/2020 Review second interrogatories 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and Shadetree Draft/revise 5/15/2020 Draft Plaintiffs' second set of interrogatories to all 1.1 1.1 $675.00 $742.50Warren T. Allen II 50% $371.25Applies to Bae and defendants Shadetree Draft/revise 5/18/2020 Draft correspondents to potential witnesses re: 1.3 1.3 $675.00 $877.50Warren T. Allen II 50% $438.75Applies to Bae and information about all claims against all defendants Shadetree Communicate (in 5/19/2020 Review and draft email re: correspondence to 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and firm) Woodberry Square tenants and opposing counsel Shadetree Draft/revise 5/19/2020 Draft correspondence to opposing counsel re: 1.2 1.2 $675.00 $810.00Warren T. Allen II 50% $405.00Applies to Bae and mediation Shadetree Communicate 5/19/2020 Communicate with client re: mediation and 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) settlement issues Shadetree Review/analyze 5/22/2020 Review objections to requests for production of 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and documents and interrogatories Shadetree Review/analyze 5/22/2020 Review and analyze discovery objections and 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and requests Shadetree Research 3/3/2020 Research arguments raised by Bae Defendants' 2.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly counsel in correspondence in response to demand attributable to Bae letter only Draft/revise 5/26/2020 Draft protective order 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Draft/revise 5/26/2020 Draft correspondence to opposing counsel re: 2.1 2.1 $675.00 $1,417.50Warren T. Allen II 100% $0.00Attributable to Bae coordinating depositions and Bae Defendants’ only objections to discovery requests Draft/revise 5/27/2020 Draft and revise protective order 2.4 2.4 $675.00 $1,620.00Ray D. McKenzie 50% $810.00Applies to Bae and Shadetree Draft/revise 5/27/2020 Draft correspondence for all defendants re: 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and coordinating deposition schedules Shadetree Communicate 5/28/2020 Draft correspondence to defendants' counsel re: 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and (other outside coordinating depositions Shadetree Review/analyze 5/28/2020 Review and begin prepping objections to 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and defendants' discovery requests Shadetree Communicate 4/13/2020 Call with counsel for Bae's Woodberry re: 0.2 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly (other outside scheduling Rule 26(f) conference, setting attributable to Bae counsel) arguments on motions, and other logistics issues only Draft/revise 5/29/2020 Draft allegations and defenses chart 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 25 of 41 PageID# 4472
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 4/13/2020 Call with counsel for Bae's Woodberry re: 0.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other outside scheduling Rule 26(f) conference, setting attributable to Bae counsel) arguments on motions, and other logistics issues only Draft/revise 5/31/2020 Revise draft joint protective order 1.7 1.7 $675.00 $1,147.50Warren T. Allen II 50% $573.75Applies to Bae and Shadetree Communicate 6/1/2020 Call with R. McKenzie and client re: discovery 1 1 $675.00 $675.00Warren T. Allen II 50% $337.50Applies to Bae and (with client) Shadetree Communicate 6/1/2020 Call with W. Allen and client re: discovery 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and (with client) Shadetree Communicate 6/1/2020 Call with opposing counsel re: discovery 1.6 1.6 $675.00 $1,080.00Warren T. Allen II 50% $540.00Applies to Bae and (other outside objections Shadetree Draft/revise 6/1/2020 Draft requests for admission 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and Shadetree Draft/revise 6/2/2020 Draft summary of meet and confer call 2.1 2.1 $675.00 $1,417.50Warren T. Allen II 50% $708.75Applies to Bae and Shadetree Communicate 6/3/2020 Draft correspondence to client re: discovery 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and (with client) requests and case status Shadetree Review/analyze 4/29/2020 Review documents received from Bae Defendants 2.1 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 6/5/2020 Prepare discovery objections 1.2 1.2 $675.00 $810.00Warren T. Allen II 50% $405.00Applies to Bae and Shadetree Communicate 6/6/2020 Call with client re: case status and discovery 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and (with client) Shadetree Communicate 6/6/2020 Call with client re: case status and discovery 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and (with client) Shadetree Draft/revise 6/8/2020 Draft outline for correspondence with opposing 1.9 1.9 $675.00 $1,282.50Warren T. Allen II 50% $641.25Applies to Bae and counsel re: settlement and approach to resolution Shadetree Communicate (in 6/8/2020 Call with R. McKenzie re: settlement strategy 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and firm) Shadetree Communicate (in 6/8/2020 Call with W. Allen re: settlement strategy 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and firm) Shadetree Communicate 6/8/2020 Draft correspondence to client re: settlement 1.3 1.3 $675.00 $877.50Warren T. Allen II 50% $438.75Applies to Bae and (with client) options Shadetree Draft/revise 6/8/2020 Draft correspondence to opposing counsel 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 50% $540.00Applies to Bae and Shadetree Draft/revise 6/9/2020 Review and revise letter to opposing counsel 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and Shadetree Draft/revise 6/9/2020 Revise settlement letter draft 4.8 4.8 $675.00 $3,240.00Warren T. Allen II 50% $1,620.00Applies to Bae and Shadetree Review/analyze 6/9/2020 Review document production 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 50% $540.00Applies to Bae and Shadetree Review/analyze 6/12/2020 Review and revise communication to opposing 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and counsel re: meet and confer Shadetree Review/analyze 4/29/2020 Review discovery provided by Bae Defendants 0.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly attributable to Bae Review/analyze 4/29/2020 Review Bae defendants' initial disclosures 0.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 26 of 41 PageID# 4473
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Review/analyze 6/12/2020 Review discovery responses 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and Shadetree Communicate 6/12/2020 Draft meet and confer request email to counsel 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to (other external) for Shadetree Defendants due to their failure to Shadetree only respond to discovery requests and failure to file a responsive pleading Communicate 5/22/2020 Draft correspondence to client re: Bae 0.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (with client) Defendants' discovery requests and objections attributable to Bae only Communicate 6/14/2020 Communicate with opposing counsel and third- 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and (other external) party witness re: coordinating attendance at Shadetree deposition Review/analyze 6/15/2020 Review discovery responses from all defendants 2.3 2.3 $675.00 $1,552.50Warren T. Allen II 50% $776.25Applies to Bae and to summarize deficiencies and to prepare meet Shadetree and confer requests Review/analyze 6/16/2020 Review documents received from client 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Shadetree Review/analyze 6/17/2020 Review discovery responses by all defendants and 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and prepare follow-up requests Shadetree Draft/revise 6/17/2020 Draft consent motion for protective order 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and Shadetree Review/analyze 6/17/2020 Review and organize documents for production 2.1 2.1 $675.00 $1,417.50Ray D. McKenzie 50% $708.75Applies to Bae and Shadetree Review/analyze 5/29/2020 Review Bae Defendants' answer to First Amended 1 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly Complaint and compare to First Amended attributable to Bae Complaint only Manage data/files 6/18/2020 Finalize and file consent motion for protective 1.2 1.2 $675.00 $810.00Ray D. McKenzie 50% $405.00Applies to Bae and order Shadetree Review/analyze 5/30/2020 Review Bae Defendants’ Answer to Amended 0.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Complaint and email Shadetree Defendants’ attributable to Bae counsel to ascertain the status of their Answer only Research 6/18/2020 Conduct research re: discovery requests 2.7 2.7 $675.00 $1,822.50Ray D. McKenzie 50% $911.25Applies to Bae and Shadetree Communicate 6/18/2020 Draft email to witness 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and (other external) Shadetree Draft/revise 6/19/2020 Draft correspondence for Shadetree Defendants 4.3 4.3 $675.00 $2,902.50Warren T. Allen II 0% $2,902.50Attributable to summarizing discovery deficiencies. Drafting Shadetree only entailed review of each request, response, and the applicable rules to summarize deficiencies Review/analyze 6/19/2020 Review documents to prepare for production 7.6 7.6 $675.00 $5,130.00Ray D. McKenzie 50% $2,565.00Applies to Bae and Shadetree Draft/revise 6/20/2020 Draft and revise third set of interrogatories and 1.2 1.2 $675.00 $810.00Warren T. Allen II 50% $405.00Applies to Bae and second set of requests for production Shadetree Draft/revise 6/20/2020 Prepare discovery responses 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 27 of 41 PageID# 4474
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Review/analyze 6/20/2020 Review and revise correspondence to counsel re: 1.3 1.3 $675.00 $877.50Ray D. McKenzie 50% $438.75Applies to Bae and discovery deficiencies Shadetree Draft/revise 6/20/2020 Draft follow-up emails to Bae Defendants re: 0.3 0.3 $675.00 $202.50Warren T. Allen II 100% $0.00Attributable to Bae settlement and discovery only Communicate 6/20/2020 Communicate with client re: settlement, discovery 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and (with client) responses, and case status developments Shadetree Review/analyze 6/21/2020 Review and prepare clients’ discovery responses 1.7 1.7 $675.00 $1,147.50Warren T. Allen II 50% $573.75Applies to Bae and Shadetree Communicate 6/21/2020 Call with client re: document production 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and (with client) Shadetree Draft/revise 6/22/2020 Process production documents and draft written 8.7 8.7 $675.00 $5,872.50Ray D. McKenzie 50% $2,936.25Applies to Bae and responses Shadetree Draft/revise 6/5/2020 Finalize discovery objections and send them to 0.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Bae's Woodberry Defendants attributable to Bae only Communicate 6/12/2020 Call with client re: settlement proposal and case 1.3 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (with client) status attributable to Bae Research 6/24/2020 Conduct research re: Motion to Compel 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 0% $1,215.00Attributable to Shadetree only Draft/revise 6/24/2020 Draft deposition notices 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Communicate 6/24/2020 Call with potential witness re: misconduct 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to (other external) allegation regarding S. Cho Shadetree only Draft/revise 6/25/2020 Draft privilege log 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and Shadetree Communicate 6/25/2020 Meet and confer with Shadetree counsel 1.4 1.4 $675.00 $945.00Ray D. McKenzie 0% $945.00Attributable to (other outside Shadetree only Draft/revise 6/25/2020 Draft memo to file re: meet and confer with 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 0% $1,215.00Attributable to Shadetree counsel Shadetree only Communicate 6/25/2020 Call with counsel for Shadetree Defendants to 1.4 1.4 $675.00 $945.00Warren T. Allen II 0% $945.00Attributable to (other outside attempt to narrow the scope of disagreements Shadetree only counsel) ahead of filing a motion to compel Draft/revise 6/25/2020 Draft motion to compel discovery responses from 4.6 4.6 $675.00 $3,105.00Warren T. Allen II 0% $3,105.00Attributable to Shadetree Defendants Shadetree only Research 6/26/2020 Conduct research re: motion to compel discovery 1.6 1.6 $675.00 $1,080.00Ray D. McKenzie 0% $1,080.00Attributable to responses from Shadetree Defendants Shadetree only Draft/revise 6/12/2020 Finalize letter to Bae Defendants re: proposed 1.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly settlement attributable to Bae Draft/revise 6/26/2020 Draft motion to compel productions from 7.7 7.7 $675.00 $5,197.50Warren T. Allen II 0% $5,197.50Attributable to Shadetree Defendants and sanction requests Shadetree only Draft/revise 6/27/2020 Draft motion to compel production from 6.4 6.4 $675.00 $4,320.00Warren T. Allen II 0% $4,320.00Attributable to Shadetree Defendants and sanction request Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 28 of 41 PageID# 4475
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 6/28/2020 Draft motion to compel production from 4.7 4.7 $675.00 $3,172.50Warren T. Allen II 0% $3,172.50Attributable to Shadetree Defendants and cost request Shadetree only Draft/revise 6/28/2020 Review and suggest edits to motion to compel and 3.6 3.6 $675.00 $2,430.00Ray D. McKenzie 0% $2,430.00Attributable to brief in support; finalize draft and exhibits for filing Shadetree only Review/analyze 6/29/2020 Review discovery demands to C. Williams and 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and analyze for objections Shadetree Review/analyze 6/13/2020 Review and analyze Bae Defendants’ document 1.9 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly productions to determine compliance with attributable to Bae requests only Draft/revise 6/29/2020 Draft objections to discovery demands to C. 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 50% $506.25Applies to Bae and Williams Shadetree Communicate 6/17/2020 Draft correspondence to counsel for Bae 0.9 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other outside defendants re: third-party subpoena attributable to Bae counsel) only Communicate 6/30/2020 Communicate with all defendants re: deposition 0.6 0.6 $675.00 $405.00Warren T. Allen II 50% $202.50Applies to Bae and (other outside scheduling, discovery, and motions hearing Shadetree counsel) Draft/revise 6/18/2020 Draft correspondence to counsel for Bae 3.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Defendants summarizing discovery deficiencies attributable to Bae only Draft/revise 6/22/2020 Prepare responses to Bae Defendants’ first 8.4 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly discovery demands attributable to Bae Communicate 7/2/2020 Call with potential witness 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and (other external) Shadetree Communicate 7/3/2020 Call with client re: case status updates, discovery 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and (with client) responses, and vendor payment Shadetree Communicate 6/23/2020 Draft correspondence to counsel for Bae 0.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other external) defendants re: depositions and discovery attributable to Bae responses only Draft/revise 7/3/2020 Draft 30(b)(6) deposition notices 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and Shadetree Communicate 7/3/2020 Call with client re: case status updates, discovery 0.5 0.5 $675.00 $337.50Warren T. Allen II 50% $168.75Applies to Bae and (with client) responses, and vendor payment Shadetree Review/analyze 7/6/2020 Review opposition to motion to compel 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to Shadetree only Review/analyze 7/6/2020 Review Bae's Woodberry 7/6/2020 (Korean 2 2 $675.00 $1,350.00Ray D. McKenzie 100% $0.00Attributable to Bae Language) production only Draft/revise 7/7/2020 Draft additional interrogatories to serve on 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and defendants; finalize 30(b)(6) deposition notices Shadetree Communicate 7/7/2020 Communicate with opposing counsel re: 0.3 0.3 $675.00 $202.50Ray D. McKenzie 50% $101.25Applies to Bae and (other outside deposition notices and arrangements with vendor Shadetree counsel) Draft/revise 7/8/2020 Draft Brief in Reply to Shadetree Defendants' 4.3 4.3 $675.00 $2,902.50Warren T. Allen II 0% $2,902.50Attributable to Response to Motion to Compel Shadetree only Review/analyze 7/8/2020 Review defendants' objections to plaintiffs' latest 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and discovery requests Shadetree Draft/revise 7/9/2020 Identify exhibits and draft deposition outline 2.8 2.8 $675.00 $1,890.00Ray D. McKenzie 50% $945.00Applies to Bae and Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 29 of 41 PageID# 4476
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 7/9/2020 Draft brief in reply 6.4 6.4 $675.00 $4,320.00Warren T. Allen II 0% $4,320.00Attributable to Shadetree only Draft/revise 7/9/2020 Review and edit reply to motion to compel 1.2 1.2 $675.00 $810.00Ray D. McKenzie 0% $810.00Attributable to Shadetree only Plan and prepare 7/10/2020 Review potential deposition exhibits and prepare 3.7 3.7 $675.00 $2,497.50Ray D. McKenzie 50% $1,248.75Applies to Bae and for for deposition Shadetree Communicate 7/10/2020 Email case status update to client 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and Plan a nd prepare 7/11/2020 Draft deposition outline and identify exhibits 5.4 5.4 $675.00 $3,645.00Ray D. McKenzie 100% $0.00Attributable to Bae for only Plan and prepare 7/13/2020 Prepare for deposition 2.3 2.3 $675.00 $1,552.50Warren T. Allen II 100% $0.00Attributable to Bae for only Plan and prepare 7/13/2020 Prepare for deposition, finalize exhibits 5.3 5.3 $675.00 $3,577.50Ray D. McKenzie 100% $0.00Attributable to Bae for only Appear for/attend 7/14/2020 Conduct deposition of Young Woo Bae 6.3 6.3 $675.00 $4,252.50Ray D. McKenzie 100% $0.00Attributable to Bae only Review/analyze 6/26/2020 Review and analyze Bae Defendants revised 0.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly document productions and responses to discovery attributable to Bae requests and concerns only Draft/revise 7/15/2020 Draft requests for admission and interrogatories 5.6 5.6 $675.00 $3,780.00Warren T. Allen II 50% $1,890.00Applies to Bae and to serve on all defendants Shadetree Review/analyze 7/15/2020 Review notes from deposition 1.7 1.7 $675.00 $1,147.50Ray D. McKenzie 100% $0.00Attributable to Bae only Communicate 7/15/2020 Calls with potential witnesses 0.8 0.8 $675.00 $540.00Warren T. Allen II 50% $270.00Applies to Bae and (other external) Shadetree Communicate 7/15/2020 Calls with potential witnesses 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and (other external) Shadetree Draft/revise 7/15/2020 Draft additional discovery requests 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 50% $607.50Applies to Bae and Shadetree Draft/revise 6/29/2020 Draft correspondence to Bae Defendants re: 0.4 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly narrowing scope of disagreements about attributable to Bae discovery and coordinating meet and confer only Review/analyze 6/30/2020 Review supplemental production from Bae 1.5 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly Defendants attributable to Bae Plan and prepare 7/17/2020 Prepare for meet and confer call with J. Huh by 2.9 2.9 $675.00 $1,957.50Warren T. Allen II 0% $1,957.50Attributable to for reviewing correspondence re: open issues, Shadetree only reviewing documents Mr. Huh produced immediately before the call, researching availability of tax information in cases involving punitive damages, and summarizing open areas of dispute Communicate 7/17/2020 Call with J. Huh re: open meet and confer issues 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to (other external) Shadetree only Communicate 7/17/2020 Meet and confer with J. Huh 0.6 0.6 $675.00 $405.00Ray D. McKenzie 0% $405.00Attributable to (other outside Shadetree only Draft/revise 7/17/2020 Draft amended privilege log 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and Shadetree Review/analyze 7/1/2020 Review Bae's Woodberry supplemental 1.1 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly production attributable to Bae Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 30 of 41 PageID# 4477
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Review/analyze 7/2/2020 Review revised discovery responses and 0.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly supplemental production from Bae's Woodberry attributable to Bae only Review/analyze 7/17/2020 Review documents produced by Shadetree 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 0% $1,012.50Attributable to Defendants Shadetree only Review/analyze 7/3/2020 Review Bae's Woodberry supplemental 1.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly production attributable to Bae Communicate 7/16/2020 Prepare response to Bae Defendants’ concerns re: 3.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other outside third-party production and work product attributable to Bae counsel) assertions only Research 7/18/2020 Research discovery issues 6.5 6.5 $675.00 $4,387.50Ray D. McKenzie 50% $2,193.75Applies to Bae and Shadetree Plan and prepare 7/18/2020 Prepare for deposition of Shadetree defendants 5.9 5.9 $675.00 $3,982.50Warren T. Allen II 0% $3,982.50Attributable to for by reviewing document productions, researching Shadetree only authority on potential legal issues, preparing interview outline, and selecting exhibits Plan and prepare 7/19/2020 Prepare for deposition of Shadetree defendants 10.8 10.8 $675.00 $7,290.00Warren T. Allen II 0% $7,290.00Attributable to for by reviewing document productions, researching Shadetree only authority on potential legal issues, preparing interview outline, and selecting exhibits Draft/revise 7/19/2020 Draft supplement to initial disclosures 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and Shadetree Draft/revise 7/19/2020 Draft supplemental privilege log 0.5 0.5 $675.00 $337.50Ray D. McKenzie 50% $168.75Applies to Bae and Shadetree Draft/revise 7/16/2020 Review and suggest edits for correspondence to 1 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly counsel re: discovery; draft supplemental attributable to Bae response to discovery requests only Plan and prepare 7/17/2020 Prepare for meet and confer call with Bae 1.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly for Defendants, including drafting a summary of open attributable to Bae areas of disagreement only Plan and prepare 7/20/2020 Prepare for deposition of Shadetree defendants 6.1 6.1 $675.00 $4,117.50Warren T. Allen II 0% $4,117.50Attributable to for by reviewing document productions, researching Shadetree only authority on potential legal issues, preparing interview outline, and selecting exhibits Appear for/attend 7/20/2020 Conduct deposition of Defendant Ellen Kim 7 7 $675.00 $4,725.00Warren T. Allen II 0% $4,725.00Attributable to Shadetree only Communicate 7/17/2020 Call with counsel for Bae Defendants re: meet and 0.5 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other outside confer over open discovery disputes attributable to Bae counsel) only Plan and prepare 7/21/2020 Prepare for Shadetree defendants’ depositions by 4.7 4.7 $675.00 $3,172.50Warren T. Allen II 0% $3,172.50Attributable to for reviewing background materials, drafting Shadetree only interview outlines, analyzing legal arguments, and selecting exhibits Plan and prepare 7/21/2020 Depose witness S. Cho 8.6 8.6 $675.00 $5,805.00Warren T. Allen II 0% $5,805.00Attributable to for Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 31 of 41 PageID# 4478
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Plan and prepare 7/17/2020 Prepare for meet and confer call with Bae 1.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly for Defendants, including drafting a summary of open attributable to Bae areas of disagreement only Plan and prepare 7/17/2020 Call with counsel for Bae Defendants re: meet and 0.5 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly for confer over open discovery disputes attributable to Bae only Appear for/attend 7/22/2020 Participate in telephonic discovery conference 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to with Judge Davis and parties’ counsel re: motion Shadetree only to compel Research 7/22/2020 Research issues related to potential discovery 1.1 1.1 $675.00 $742.50Ray D. McKenzie 0% $742.50Attributable to dispute Shadetree only Appear for/attend 7/22/2020 Participate in conference with Court and opposing 0.7 0.7 $675.00 $472.50Ray D. McKenzie 0% $472.50Attributable to counsel re: Plaintiffs' Motion to Compel Shadetree only Review/analyze 7/23/2020 Review filings and research re: assertions of work 2.3 2.3 $675.00 $1,552.50Warren T. Allen II 100% $0.00Attributable to Bae product protection to oppose motion by Bae only defendants Communicate 7/21/2020 Draft correspondence to address Bae Defendants’ 0.3 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other external) discovery and disclosure inquiries attributable to Bae only Review/analyze 7/25/2020 Review Shadetree 7/24/20 and 7/25/20 3.9 3.9 $675.00 $2,632.50Ray D. McKenzie 0% $2,632.50Attributable to productions Shadetree only Review/analyze 7/25/2020 Review Bae Defendants' Motions to Compel and 2.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly for Sanctions attributable to Bae Draft/revise 7/27/2020 Draft notice re Shadetree discovery responses 3.3 3.3 $675.00 $2,227.50Ray D. McKenzie 0% $2,227.50Attributable to following motion to compel Shadetree only Draft/revise 7/27/2020 Update Plaintiffs' initial disclosures, document 1.4 1.4 $675.00 $945.00Warren T. Allen II 50% $472.50Applies to Bae and production, and other discovery materials Shadetree Draft/revise 7/26/2020 Draft opposition to Bae Defendants' motions to 5.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly compel and for sanctions against C. Williams and attributable to Bae Light Your Vision LLC only Draft/revise 7/27/2020 Draft and revise notice to Court re: discovery 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 50% $810.00Applies to Bae and dispute and status conference Shadetree Communicate 7/27/2020 Meet and confer with opposing counsel for Bae 0.5 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other external) Defendants re: privilege log disclosures, work attributable to Bae product analysis, and other discovery disputes only Communicate 7/27/2020 Call with witness re: motion to compel and 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to (other external) deposition testimony Shadetree only Appear for/attend 7/28/2020 Appear for status conference with Judge Davis at 0.5 0.5 $675.00 $337.50Warren T. Allen II 0% $337.50Attributable to 3:30 and at 4:00 p.m. Shadetree only Draft/revise 7/28/2020 Draft and revise notice to court re: compliance 2.7 2.7 $675.00 $1,822.50Warren T. Allen II 0% $1,822.50Attributable to with discovery demands pursuant to July 22, 2020 Shadetree only order on motion to compel against Shadetree Defendants Appear for/attend 7/28/2020 Appear for status conference with Judge Davis at 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to 3:30 and at 4:00 p.m. Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 32 of 41 PageID# 4479
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 7/28/2020 Calls with J. Huh and assistant re: judge's order to 0.2 0.2 $675.00 $135.00Ray D. McKenzie 0% $135.00Attributable to (other outside appear for status conference Shadetree only counsel) Review/analyze 7/28/2020 Review transcripts of testimony by Defendants 3.3 3.3 $675.00 $2,227.50Warren T. Allen II 0% $2,227.50Attributable to Cho and Kim Shadetree only Review/analyze 7/28/2020 Review S. Cho and E. Kim deposition transcripts 9 9 $675.00 $6,075.00Ray D. McKenzie 100% $0.00Attributable to Bae and other materials to prepare for C. Bae only deposition Review/analyze 7/29/2020 Review documents to prepare for deposition 9.7 9.7 $675.00 $6,547.50Ray D. McKenzie 100% $0.00Attributable to Bae only Communicate 7/27/2020 Meet and confer with counsel for Bae Defendants 0.6 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly (other outside attributable to Bae Communicate 7/29/2020 Draft correspondence to client re: case status 0.4 0.4 $675.00 $270.00Warren T. Allen II 50% $135.00Applies to Bae and (with client) Shadetree Communicate 7/29/2020 Call with client re: case status 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and (with client) Shadetree Review/analyze 7/29/2020 Review Bae Defendant's 7-22-20 supplemental 0.9 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly production to prepare for C. Bae deposition attributable to Bae only Plan and prepare 7/29/2020 Prepare materials for C. Williams to review for 1.7 1.7 $675.00 $1,147.50Warren T. Allen II 50% $573.75Applies to Bae and for deposition testimony. Shadetree Draft/revise 7/30/2020 Draft brief in opposition to motion to compel 6 6 $675.00 $4,050.00Warren T. Allen II 100% $0.00Attributable to Bae only Draft/revise 7/29/2020 Draft opposition to Bae Defendants' motion to 4.7 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly compel attributable to Bae Draft/revise 7/30/2020 Draft and revise opposition to motion to compel. 7.6 7.6 $675.00 $5,130.00Warren T. Allen II 100% $0.00Attributable to Bae only Appear for/attend 7/30/2020 Depose C. Bae 8 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Appear for/attend 7/31/2020 Attend deposition of C. Williams 6.9 6.9 $675.00 $4,657.50Warren T. Allen II 50% $2,328.75Applies to Bae and Shadetree Communicate 8/2/2020 Prepare client for deposition 2.5 2.5 $675.00 $1,687.50Warren T. Allen II 50% $843.75Applies to Bae and (with client) Shadetree Communicate 8/2/2020 Meet with client for case update and prepare for 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and (with client) upcoming deposition Shadetree Communicate 8/3/2020 Correspondence to client re: materials for 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (with client) deposition preparation Shadetree Review/analyze 8/3/2020 Review latest Shadetree production 4 4 $675.00 $2,700.00Ray D. McKenzie 0% $2,700.00Attributable to Shadetree only Research 8/3/2020 Research objections from defendants to prepare 1.1 1.1 $675.00 $742.50Ray D. McKenzie 50% $371.25Applies to Bae and for meet and confer Shadetree Review/analyze 8/3/2020 Review supplemental documents received from 1.2 1.2 $675.00 $810.00Ray D. McKenzie 50% $405.00Applies to Bae and client Shadetree Communicate 8/3/2020 Meet and confer with I. Khan re discovery issues 0.2 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly (other outside attributable to Bae Communicate 8/4/2020 Draft correspondence to client re document 0.8 0.8 $675.00 $540.00Ray D. McKenzie 50% $270.00Applies to Bae and (with client) production and case status Shadetree Draft/revise 8/4/2020 Draft second supplemental discovery responses 0.7 0.7 $675.00 $472.50Ray D. McKenzie 50% $236.25Applies to Bae and and prepare supplemental document production Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 33 of 41 PageID# 4480
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Appear for/attend 8/5/2020 Appear for B. Mamadou deposition 7.5 7.5 $675.00 $5,062.50Ray D. McKenzie 50% $2,531.25Applies to Bae and Shadetree Appear for/attend 8/5/2020 Attend deposition 7.5 7.5 $675.00 $5,062.50Warren T. Allen II 50% $2,531.25Applies to Bae and Shadetree Plan and prepare 8/5/2020 Prepare for deposition 3.1 3.1 $675.00 $2,092.50Warren T. Allen II 0% $2,092.50Attributable to for Shadetree only Review/analyze 8/5/2020 Review and select exhibits for Shadetree 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 0% $1,012.50Attributable to deposition Shadetree only Communicate 8/5/2020 Meet and confer with J. Huh 0.6 0.6 $675.00 $405.00Ray D. McKenzie 0% $405.00Attributable to (other outside Shadetree only Plan and prepare 8/6/2020 Prepare for Shadetree 30(b)(6) deposition 3.6 3.6 $675.00 $2,430.00Warren T. Allen II 0% $2,430.00Attributable to for Shadetree only Appear for/attend 8/6/2020 Appear for Shadetree deposition 7 7 $675.00 $4,725.00Ray D. McKenzie 0% $4,725.00Attributable to Shadetree only Appear for/attend 8/6/2020 Depose Shadetree Management 6.9 6.9 $675.00 $4,657.50Warren T. Allen II 0% $4,657.50Attributable to Shadetree only Draft/revise 8/6/2020 Draft Motion to Compel Bae Defendants' 6.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly responses to discovery requests attributable to Bae only Draft/revise 8/6/2020 Draft notice to court re: motion to compel status 3.3 3.3 $675.00 $2,227.50Warren T. Allen II 0% $2,227.50Attributable to Shadetree only Draft/revise 8/7/2020 Draft notice re motion to compel 3.6 3.6 $675.00 $2,430.00Warren T. Allen II 0% $2,430.00Attributable to Shadetree only Plan and prepare 8/7/2020 Prepare for oral argument on Bae Defendants' 1.5 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly for motion to compel third-party production attributable to Bae only Draft/revise 8/7/2020 Revise motion to compel discovery responses and 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 0% $1,012.50Attributable to extend discovery deadline Shadetree only Draft/revise 8/7/2020 Revise motion to compel production against Bae 0.9 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Defendants attributable to Bae Research 8/7/2020 Research issues for motion to compel discovery 1.5 1.5 $675.00 $1,012.50Ray D. McKenzie 0% $1,012.50Attributable to responses and extend discovery deadline Shadetree only Appear for/attend 8/7/2020 Join hearing on Baes’ motion to compel third- 0.4 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly party discovery attributable to Bae Appear for/attend 8/7/2020 Attend hearing with Judge Davis re pending 0.4 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly Motion to Compel attributable to Bae Appear for/attend 8/7/2020 Join hearing on plaintiffs’ motion to compel 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to Shadetree Defendants’ discovery responses Shadetree only Appear for/attend 8/7/2020 Attend hearing with Judge Davis re Motion to 0.3 0.3 $675.00 $202.50Ray D. McKenzie 0% $202.50Attributable to Compel Shadetree Shadetree only Review/analyze 8/10/2020 Review Baes' Motion for Protective Order 0.7 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 8/11/2020 Draft response to Baes' Motion for Protective 4.5 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly Order attributable to Bae Draft/revise 8/12/2020 Revise opposition to motion for protective order 1.3 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 8/12/2020 Revise brief in opposition to motion for protective 2.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly order attributable to Bae Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 34 of 41 PageID# 4481
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Review/analyze 8/12/2020 Review Bae Defendants' opposition to Plaintiffs' 0.3 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly motion to compel attributable to Bae Draft/revise 8/13/2020 Edit and file reply in support of motion to compel 0.7 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 8/13/2020 Draft brief in reply to Bae Defendants' opposition 6.3 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly to Plaintiffs' motion to compel attributable to Bae only Draft/revise 8/13/2020 Draft notice re: Shadetree Defendants' discovery 1.3 1.3 $675.00 $877.50Warren T. Allen II 0% $877.50Attributable to deficiencies Shadetree only Draft/revise 8/13/2020 Update privilege log; prepare supplemental 0.6 0.6 $675.00 $405.00Ray D. McKenzie 50% $202.50Applies to Bae and disclosure Shadetree Draft/revise 8/13/2020 Update initial disclosures 0.5 0.5 $675.00 $337.50Warren T. Allen II 50% $168.75Applies to Bae and Shadetree Review/analyze 8/13/2020 Review defendant productions 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and Shadetree Communicate 8/13/2020 Participate in meet and confer call with Bae 0.4 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly (other external) Defendants' counsel attributable to Bae Communicate 8/14/2020 Call with client re: supplemental disclosure 0.2 0.2 $675.00 $135.00Ray D. McKenzie 50% $67.50Applies to Bae and (with client) Shadetree Draft/revise 8/14/2020 Draft supplemental response to document 0.4 0.4 $675.00 $270.00Ray D. McKenzie 50% $135.00Applies to Bae and requests Shadetree Draft/revise 8/14/2020 Draft and revise notice re: Shadetree Defendants' 1.3 1.3 $675.00 $877.50Warren T. Allen II 0% $877.50Attributable to discovery deficiencies Shadetree only Plan and prepare 8/14/2020 Attend hearing on Bae Defendants' Motion to 1.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly for Compel, Bae Defendants' Motion for a Protective attributable to Bae Order, and Plaintiffs' Motion to Compel the Bae only Defendants' productions Appear for/attend 8/14/2020 Appear for motions hearing before Judge Davis 1.1 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Draft/revise 8/17/2020 Draft email to opposing counsel re: proposed 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to path to resolve outstanding and potential Shadetree only discovery disputes Draft/revise 8/17/2020 Draft outline of proposed omnibus resolution of 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to all open discovery disputes to try to facilitate Shadetree only resolution and further negotiation with opposing counsel Communicate 8/18/2020 Meet and confer call with J. Huh re: response to 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to (other outside discovery disputes and requests for sanctions Shadetree only counsel) Review/analyze 8/18/2020 Review document productions to prepare for 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to meet and confer call with J. Huh re: discovery Shadetree only disputes Communicate 8/18/2020 Draft correspondence to client re: case status 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and (with client) developments Shadetree Draft/revise 8/18/2020 Draft brief in opposition to Bae Defendants’ 4.7 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly motion to compel attributable to Bae Communicate 8/18/2020 Meet and confer with J. Huh re: discovery hearing 0.7 0.7 $675.00 $472.50Ray D. McKenzie 0% $472.50Attributable to (other outside on 8/21/20 Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 35 of 41 PageID# 4482
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Research 8/18/2020 Conduct research re: spoliation of evidence 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 0% $1,215.00Attributable to Shadetree only Plan and prepare 8/18/2020 Select trial exhibits in preparation for final pretrial 2.6 2.6 $675.00 $1,755.00Ray D. McKenzie 50% $877.50Applies to Bae and for conference Shadetree Review/analyze 8/19/2020 Review productions and select potential trial 6.7 6.7 $675.00 $4,522.50Ray D. McKenzie 50% $2,261.25Applies to Bae and exhibits Shadetree Research 8/19/2020 Research re: motion to compel plaintiffs' work 0.5 0.5 $675.00 $337.50Ray D. McKenzie 100% $0.00Attributable to Bae product only Draft/revise 8/19/2020 Review and propose edits to opposition to motion 0.5 0.5 $675.00 $337.50Ray D. McKenzie 100% $0.00Attributable to Bae to compel plaintiffs' work product only Draft/revise 8/19/2020 Draft brief in opposition to Bae Defendants 11.7 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly motion to compel attributable to Bae Research 8/19/2020 Review cases on spoliation and circumstantial 4.7 4.7 $675.00 $3,172.50Gary A. Rubin 0% $3,172.50Attributable to proof of spoliation Shadetree only Communicate (in 8/19/2020 Call regarding strategy for sanctions research 0.3 0.3 $675.00 $202.50Gary A. Rubin 0% $202.50Attributable to firm) Shadetree only Review/analyze 8/20/2020 Review productions and select potential trial 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 50% $843.75Applies to Bae and exhibits Shadetree Plan and prepare 8/20/2020 Prepare for oral argument on Bae Defendants' 2.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly for motion to compel Plaintiffs' work product attributable to Bae only Draft/revise 8/20/2020 Draft notice re: motion to compel and status of 4.4 4.4 $675.00 $2,970.00Warren T. Allen II 0% $2,970.00Attributable to Shadetree Defendants compliance with court Shadetree only orders Review/analyze 8/20/2020 Review and analyze cases on spoliation 2.9 2.9 $675.00 $1,957.50Gary A. Rubin 0% $1,957.50Attributable to Shadetree only Draft/revise 8/20/2020 Draft section of spoliation notice 1.9 1.9 $675.00 $1,282.50Gary A. Rubin 0% $1,282.50Attributable to Shadetree only Draft/revise 8/21/2020 Draft and file motion to continue final pretrial 1 1 $675.00 $675.00Ray D. McKenzie 50% $337.50Applies to Bae and conference Shadetree Plan and prepare 8/21/2020 Prepare for oral argument on Bae Defendants' 2.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly for motion to compel Plaintiffs' work product attributable to Bae only Draft/revise 8/21/2020 Draft Notice re Motion to Compel and status of 3.7 3.7 $675.00 $2,497.50Warren T. Allen II 50% $1,248.75Applies to Bae and Shadetree Defendants' compliance with court Shadetree orders Appear for/attend 8/21/2020 Appear for discovery hearing on Defendants' 0.9 0.9 $675.00 $607.50Ray D. McKenzie 50% $303.75Applies to Bae and Motion for Protective Order and Motion to Shadetree Compel Appear for/attend 8/21/2020 Attend discovery hearing on multiple discovery 0.9 0.9 $675.00 $607.50Warren T. Allen II 50% $303.75Applies to Bae and motions Shadetree Appear for/attend 8/21/2020 Appear for discovery hearing on Plaintiffs' Motion 0.6 0.6 $675.00 $405.00Ray D. McKenzie 0% $405.00Attributable to to Compel Shadetree Shadetree only Appear for/attend 8/21/2020 Attend discovery hearing on Motion to Compel 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to Shadetree Shadetree only Communicate 8/26/2020 Draft email to witness C. Williams re: potential 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and (other external) trial schedule and holding dates for testimony Shadetree Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 36 of 41 PageID# 4483
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 8/31/2020 Revise privilege log to provide additional details 6.8 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly per the Court's August 21, 2020 order attributable to Bae only Draft/revise 9/1/2020 Revise privilege log per the Court's August 21, 1.8 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly 2020 order attributable to Bae Draft/revise 9/1/2020 Review and finalize amended privilege log 0.8 0 $675.00 $0.00Ray D. McKenzie 0% $0.00Correctly attributable to Bae Review/analyze 9/8/2020 Review Shadetree defendants' objections to Judge 0.2 0.2 $675.00 $135.00Warren T. Allen II 0% $135.00Attributable to Davis's discovery orders Shadetree only Review/analyze 9/8/2020 Review Bae defendants' objections to Judge 0.2 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Davis's discovery orders attributable to Bae Draft/revise 9/8/2020 Draft and revise errata sheet 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and Shadetree Review/analyze 9/8/2020 Address response to Shadetree rule 72 objection. 2.9 2.9 $675.00 $1,957.50Gary A. Rubin 0% $1,957.50Attributable to Shadetree only Communicate (in 9/9/2020 Call re: strategy for responding to Shadetree 0.5 0.5 $675.00 $337.50Gary A. Rubin 0% $337.50Attributable to firm) objections. Shadetree only Review/analyze 9/9/2020 Prepare response to Shadetree rule 72 objections. 3.1 3.1 $675.00 $2,092.50Gary A. Rubin 0% $2,092.50Attributable to Shadetree only Review/analyze 9/11/2020 Review legal issues regarding Shadetree 2.9 2.9 $675.00 $1,957.50Gary A. Rubin 0% $1,957.50Attributable to objections. Shadetree only Review/analyze 9/12/2020 Review cases on standard of review on issues 5.1 5.1 $675.00 $3,442.50Gary A. Rubin 0% $3,442.50Attributable to raised in Shadetree objections. Shadetree only Draft/revise 9/14/2020 Work on response to Shadetree objections. 3.1 3.1 $675.00 $2,092.50Gary A. Rubin 0% $2,092.50Attributable to Shadetree only Draft/revise 9/15/2020 Prepare deposition errata sheet 5.9 5.9 $675.00 $3,982.50Warren T. Allen II 50% $1,991.25Applies to Bae and Shadetree Draft/revise 9/17/2020 Draft responses to Bae Defendants’ Rule 72 2.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly objections attributable to Bae Draft/revise 9/17/2020 Draft sections of response to Shadetree rule 72 5.8 5.8 $675.00 $3,915.00Gary A. Rubin 0% $3,915.00Attributable to objection Shadetree only Draft/revise 9/18/2020 Draft facts section of Shadetree rule 72 response. 3.9 3.9 $675.00 $2,632.50Gary A. Rubin 0% $2,632.50Attributable to Shadetree only Draft/revise 9/19/2020 Revise draft response to Shadetree Defendants 4.1 4.1 $675.00 $2,767.50Warren T. Allen II 0% $2,767.50Attributable to Rule 72 objections Shadetree only Draft/revise 9/19/2020 Draft argument sections of Shadetree rule 72 6.1 6.1 $675.00 $4,117.50Gary A. Rubin 0% $4,117.50Attributable to response. Shadetree only Draft/revise 9/20/2020 Draft revisions to response to Bae Defendants' 2.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly Rule 72 Objection attributable to Bae Draft/revise 9/20/2020 Prepare materials in support of fee award to 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to respond to Shadetree Defendants Rule 72 Shadetree only objections Draft/revise 9/20/2020 Edit initial draft of Shadetree rule 72 response. 6.2 6.2 $675.00 $4,185.00Gary A. Rubin 0% $4,185.00Attributable to Shadetree only Draft/revise 9/21/2020 Prepare materials in support of fee award to 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to respond to Shadetree Defendants Rule 72 Shadetree only objections Draft/revise 9/21/2020 Draft response to Bae Defendants Rule 72 6.6 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly objections attributable to Bae Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 37 of 41 PageID# 4484
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 9/21/2020 Edit response to Shadetree rule 72 objection. 7.8 0 $675.00 $0.00Gary A. Rubin 0% $0.00Correctly attributable to Bae Draft/revise 9/22/2020 Final review of brief opposing Shadetree 2 2 $675.00 $1,350.00Warren T. Allen II 100% $0.00Description states Objections before filing (not included in fee charge not to be request submissions) included, but fee still billed Draft/revise 9/22/2020 Draft response to Bae Defendants’ objections 3.1 0 $675.00 $0.00Warren T. Allen II 0% $0.00Correctly attributable to Bae Draft/revise 9/22/2020 Draft response to Shadetree Defendants' Rule 72 8.4 8.4 $675.00 $5,670.00Warren T. Allen II 0% $5,670.00Attributable to Objections Shadetree only Draft/revise 9/22/2020 Revise and finalize brief opposing Rule 72 5.7 5.7 $675.00 $3,847.50Ray D. McKenzie 0% $3,847.50Attributable to objections to Davis order denying motion to Shadetree only compel work product production Draft/revise 9/22/2020 Finalize exhibits for Rule 72 response 2.1 2.1 $675.00 $1,417.50Gary A. Rubin 0% $1,417.50Attributable to Shadetree only Draft/revise 9/22/2020 Edit and finalize Rule 72 response 3.1 3.1 $675.00 $2,092.50Gary A. Rubin 0% $2,092.50Attributable to Shadetree only Communicate 9/23/2020 Draft correspondence to client re: case status 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and (with client) update and filings Shadetree Communicate 9/23/2020 Draft proposed correspondence to opposing 0.3 0.3 $675.00 $202.50Warren T. Allen II 50% $101.25Applies to Bae and (other outside counsel re: fee award and local rule requirement Shadetree counsel) Communicate 10/1/2020 Call with J. Huh to confer re: proposed 0.5 0.5 $675.00 $337.50Warren T. Allen II 0% $337.50Attributable to (other outside amendments to the Shadetree Defendants' Shadetree only counsel) responses to RFAs Communicate 10/1/2020 Draft correspondence to counsel for Shadetree 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to (other external) Defendants re: meeting and conferring re: Shadetree only proposed amendments to their RFA responses Communicate 10/1/2020 Meet and confer with J. Huh regarding Shadetree 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to (other outside RFA failures Shadetree only Communicate 10/2/2020 Draft correspondence to client re: case status 0.7 0.7 $675.00 $472.50Warren T. Allen II 50% $236.25Applies to Bae and (with client) updates on request for admissions Shadetree Communicate 10/2/2020 Review correspondence and draft filings from 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to (other external) Shadetree Defendants and respond with Shadetree only comments and proposed revisions Communicate 10/27/2020 Research Rule 7(e) notice requirements for Rule 2.8 2.8 $675.00 $1,890.00Warren T. Allen II 0% $1,890.00Attributable to (other external) 72 objections and draft correspondence to Shadetree only opposing counsel re: same Communicate 10/30/2020 Draft correspondence with opposing counsel 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to (other external) regarding sanctions and settlement Shadetree only Review/analyze 11/2/2020 Review and comment on proposed motion for 0.3 0.3 $675.00 $202.50Gary A. Rubin 0% $202.50Attributable to leave to waive oral argument. Shadetree only Communicate 11/3/2020 Call with J. Huh re: motion to compel and motion 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to (other external) for sanctions Shadetree only Communicate 11/3/2020 Meet-and-confer call with Shadetree's counsel. 0.7 0.7 $675.00 $472.50Gary A. Rubin 0% $472.50Attributable to (other external) Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 38 of 41 PageID# 4485
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 11/9/2020 Call with client re: case developments 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to (with client) Shadetree only Communicate 11/9/2020 Call with client regarding next steps 0.6 0.6 $675.00 $405.00Ray D. McKenzie 0% $405.00Attributable to (with client) Shadetree only Communicate 11/18/2020 Draft correspondence to Defendants and Court re: 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to (other external) rescheduling settlement discussions Shadetree only Communicate 1/4/2021 Draft email to J. Huh regarding his clients' failure 0.7 0.7 $675.00 $472.50Ray D. McKenzie 0% $472.50Attributable to (other outside to comply with ECF No. 103 Shadetree only counsel) Draft/revise 1/20/2021 Draft Rule 37(b) motion based on Shadetree 4.7 4.7 $675.00 $3,172.50Warren T. Allen II 0% $3,172.50Attributable to Defendant's refusal to comply with Court's earlier Shadetree only sanctions order awarding attorneys' fees Communicate 1/21/2021 Draft correspondence to client re: case status 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to (with client) update and discovery motion Shadetree only Draft/revise 1/21/2021 Review and propose edits to motion for sanctions 0.7 0.7 $675.00 $472.50Ray D. McKenzie 0% $472.50Attributable to Shadetree only Draft/revise 1/21/2021 Draft motion for sanctions against Shadetree 4.4 4.4 $675.00 $2,970.00Warren T. Allen II 0% $2,970.00Attributable to Defendants for failure to comply with Court's prior Shadetree only sanctions order Draft/revise 1/21/2021 Review and edit sanctions motion 0.5 0.5 $675.00 $337.50Gary A. Rubin 0% $337.50Attributable to Shadetree only Draft/revise 1/22/2021 Draft motion for further sanctions against the 7.6 7.6 $675.00 $5,130.00Warren T. Allen II 0% $5,130.00Attributable to Shadetree Defendants for refusal to comply with Shadetree only the Court's prior sanctions order Draft/revise 1/22/2021 Review audio files and update record cites; 2.1 2.1 $675.00 $1,417.50Ray D. McKenzie 0% $1,417.50Attributable to propose edits to memo in support of motion for Shadetree only further sanctions; draft motion and proposed order Draft/revise 1/22/2021 Conduct final proofread and file motion for 1.2 1.2 $675.00 $810.00Ray D. McKenzie 0% $810.00Attributable to further sanctions, memorandum in support, Shadetree only proposed order, and notice of hearing Draft/revise 1/22/2021 Review and edit sanctions motion 2.1 2.1 $675.00 $1,417.50Gary A. Rubin 0% $1,417.50Attributable to Shadetree only Communicate 1/26/2021 Draft correspondence to client and nonparty 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to (other external) witness re: case status update Shadetree only Draft/revise 1/27/2021 Draft brief in Reply to Shadetree Defendants 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to opposition Shadetree only Review/analyze 1/27/2021 Review reply brief 0.3 0.3 $675.00 $202.50Gary A. Rubin 0% $202.50Attributable to Shadetree only Draft/revise 1/28/2021 Edit reply brief 1.4 1.4 $675.00 $945.00Gary A. Rubin 0% $945.00Attributable to Shadetree only Plan and prepare 2/5/2021 Prepare for oral argument on motion for further 2.6 2.6 $675.00 $1,755.00Warren T. Allen II 0% $1,755.00Attributable to for sanctions against Shadetree Defendants Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 39 of 41 PageID# 4486
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Appear for/attend 2/5/2021 Attend hearing on motion for sanctions 1.8 1.8 $675.00 $1,215.00Warren T. Allen II 0% $1,215.00Attributable to Shadetree only Communicate 2/5/2021 Draft correspondence to client re: status update 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to (with client) and potential strategic options Shadetree only Communicate 2/5/2021 Draft and revise correspondence with opposing 1.8 1.8 $675.00 $1,215.00Warren T. Allen II 0% $1,215.00Attributable to (other external) counsel re: Shadetree Defendants' sanctions and Shadetree only potential settlement options Draft/revise 2/9/2021 Prepare and file corrected exhibit to reply brief 1.4 1.4 $675.00 $945.00Warren T. Allen II 0% $945.00Attributable to seeking further sanctions against the Shadetree Shadetree only Defendants Draft/revise 2/10/2021 Draft, revise, and file response to Shadetree 1.9 1.9 $675.00 $1,282.50Warren T. Allen II 0% $1,282.50Attributable to Defendants’ request to reduce Plainitiffs’ fees Shadetree only Communicate 2/11/2021 Communicate with client re: case status 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to (with client) developments and settlement Shadetree only Draft/revise 3/5/2021 Draft and revise motion to continue 1.3 1.3 $675.00 $877.50Warren T. Allen II 0% $877.50Attributable to Shadetree only Communicate 3/9/2021 Communicate with client re: rescheduling trial and 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to (with client) case status update Shadetree only Communicate 3/9/2021 Inform witness of rescheduled trial dates 0.1 0.1 $675.00 $67.50Warren T. Allen II 0% $67.50Attributable to (other external) Shadetree only Review/analyze 5/21/2021 Review Judge Davis's recommendation and report 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to and update client re: same Shadetree only Communicate 5/24/2021 Draft correspondence to client re: case status 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to (with client) Shadetree only Research 9/15/2021 Research evidentiary issue in preparation for call 0.3 0.3 $675.00 $202.50Ray D. McKenzie 0% $202.50Attributable to with client regarding next steps Shadetree only Research 9/16/2021 Research evidentiary issue re: use of deposition 1.4 1.4 $675.00 $945.00Warren T. Allen II 0% $945.00Attributable to transcripts Shadetree only Communicate 9/17/2021 Call with client to discuss recent default judgment 1 1 $675.00 $675.00Ray D. McKenzie 0% $675.00Attributable to (with client) order and next steps Shadetree only Communicate 9/17/2021 Call with client re: case status 1 1 $675.00 $675.00Warren T. Allen II 0% $675.00Attributable to (with client) Shadetree only Draft/revise 9/28/2021 Prepare motion for attorneys' fees 3.4 3.4 $675.00 $2,295.00Warren T. Allen II 0% $2,295.00Attributable to Shadetree only Draft/revise 9/30/2021 Draft motion for attorneys fees per order of the 5.6 5.6 $675.00 $3,780.00Warren T. Allen II 0% $3,780.00Attributable to Court Shadetree only Draft/revise 10/3/2021 Draft motion for attorneys' fees 6.6 6.6 $675.00 $4,455.00Warren T. Allen II 0% $4,455.00Attributable to Shadetree only Draft/revise 10/4/2021 Finalize revisions to motion for attorneys' fees 1.4 1.4 $675.00 $945.00Warren T. Allen II 0% $945.00Attributable to Shadetree only Research 10/5/2021 Research potential response to Shadetree 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to Defendants' most recent failures to comply with Shadetree only discovery orders Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 40 of 41 PageID# 4487
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Communicate 10/13/2021 Draft correspondence to client re: motion for 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to (with client) sanctions, case strategy, and case status Shadetree only Draft/revise 10/13/2021 Finalize notice 0.3 0.3 $675.00 $202.50Gary A. Rubin 0% $202.50Attributable to Shadetree only Draft/revise 10/24/2021 Draft correspondence re: upcoming hearing and 0.7 0.7 $675.00 $472.50Warren T. Allen II 0% $472.50Attributable to case status for client and non-party witness Shadetree only Plan and prepare 10/25/2021 Prepare for oral argument by reviewing criminal 1.3 1.3 $675.00 $877.50Warren T. Allen II 0% $877.50Attributable to for contempt standards, prior filings, and available Shadetree only sanctions Draft/revise 10/27/2021 Draft brief in reply to Shadetree Defendants' 7.1 7.1 $675.00 $4,792.50Warren T. Allen II 0% $4,792.50Attributable to opposition brief Shadetree only Draft/revise 10/28/2021 Draft and revise reply brief 1.2 1.2 $675.00 $810.00Warren T. Allen II 0% $810.00Attributable to Shadetree only Plan and prepare 10/28/2021 Prepare for oral arguments on motions for 4.4 4.4 $675.00 $2,970.00Warren T. Allen II 0% $2,970.00Attributable to for sanctions Shadetree only Draft/revise 12/7/2021 Review and revise supplemental briefing regarding 1.3 1.3 $675.00 $877.50Ray D. McKenzie 0% $877.50Attributable to fees Shadetree only Draft/revise 12/7/2021 Draft supplemental memorandum in support of 4.1 4.1 $675.00 $2,767.50Warren T. Allen II 0% $2,767.50Attributable to motion for attorneys' fees per the Court's Shadetree only December 3 order Draft/revise 12/8/2021 Draft supplemental memorandum in support of 2.4 2.4 $675.00 $1,620.00Warren T. Allen II 0% $1,620.00Attributable to motion for attorneys' fees per the Court's Shadetree only December 3 order Draft/revise 12/15/2021 Draft settlement demand correspondence, 3.4 3.4 $675.00 $2,295.00Warren T. Allen II 0% $2,295.00Attributable to including researching ethics issue and researching Shadetree only civil contempt standards Draft/revise 12/17/2021 Prepare revisions to settlement demand language 0.4 0.4 $675.00 $270.00Warren T. Allen II 0% $270.00Attributable to Shadetree only Draft/revise 12/20/2021 Prepare revisions to settlement demand language 0.3 0.3 $675.00 $202.50Warren T. Allen II 0% $202.50Attributable to Shadetree only Communicate 1/5/2022 Respond to settlement offer from Shadetree 0.2 0.2 $675.00 $135.00Warren T. Allen II 0% $135.00Attributable to (other external) Defendants Shadetree only Research 1/5/2022 Research rules re: imposing damages on default 2.2 2.2 $675.00 $1,485.00Warren T. Allen II 0% $1,485.00Attributable to judgment Shadetree only Communicate 1/5/2022 Draft correspondence to client re: settlement 0.2 0.2 $675.00 $135.00Warren T. Allen II 0% $135.00Attributable to (with client) offer and status conference outcome Shadetree only Appear for/attend 1/5/2022 Attend status conference re: damages and trial 0.2 0.2 $675.00 $135.00Warren T. Allen II 0% $135.00Attributable to date Shadetree only Research 1/6/2022 Conduct research in preparation for briefing 2.5 2.5 $675.00 $1,687.50Ray D. McKenzie 0% $1,687.50Attributable to Plaintiffs' position on damages Shadetree only Review/analyze 1/19/2022 Review cases on contempt 1.9 1.9 $675.00 $1,282.50Gary A. Rubin 0% $1,282.50Attributable to Shadetree only Draft/revise 1/20/2022 Draft contempt motion 2.8 2.8 $675.00 $1,890.00Gary A. Rubin 0% $1,890.00Attributable to Shadetree only Case 1:20-cv-00146-AJT-IDD Document 244 Filed 08/30/23 Page 41 of 41 PageID# 4488
Item Date Description WH oo ru kr es d H Feo eu r As p f po .r Rate Total Billed By ReC do uu ctr it o n Court T A otd aju lsted Jus ot nif i dc ea st cio rin p t( ib oa ns )ed Draft/revise 1/21/2022 Draft comments on motion for civil contempt 0.5 0.5 $675.00 $337.50Warren T. Allen II 0% $337.50Attributable to show cause hearing against all Shadetree Shadetree only Defendants Review/analyze 1/22/2022 Review documentation relating to damages to 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 0% $1,215.00Attributable to prepare for drafting position on damages Shadetree only Review/analyze 1/24/2022 Conduct legal and factual research in preparation 2.3 2.3 $675.00 $1,552.50Ray D. McKenzie 0% $1,552.50Attributable to for drafting Plaintiffs' position on damages Shadetree only Draft/revise 1/24/2022 Revise motion for order to show cause 0.9 0.9 $675.00 $607.50Gary A. Rubin 0% $607.50Attributable to Shadetree only Research 1/24/2022 Review cases on rule 37 contempt 1.1 1.1 $675.00 $742.50Gary A. Rubin 0% $742.50Attributable to Shadetree only Draft/revise 1/25/2022 Revise memorandum in support of motion for 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to contempt Shadetree only Draft/revise 1/25/2022 Draft Plaintiffs' position on damages 1.8 1.8 $675.00 $1,215.00Ray D. McKenzie 0% $1,215.00Attributable to Shadetree only Review/analyze 1/25/2022 Address rule 37 and contempt issues 0.3 0.3 $675.00 $202.50Gary A. Rubin 0% $202.50Attributable to Shadetree only Draft/revise 1/26/2022 Edit contempt brief and draft related papers 3.1 3.1 $675.00 $2,092.50Gary A. Rubin 0% $2,092.50Attributable to Shadetree only Draft/revise 1/27/2022 Draft Plaintiffs' position on damages 5.7 5.7 $675.00 $3,847.50Ray D. McKenzie 0% $3,847.50Attributable to Shadetree only Draft/revise 1/28/2022 Draft Plaintiffs' position on damages 2.1 2.1 $675.00 $1,417.50Ray D. McKenzie 0% $1,417.50Attributable to Shadetree only Review/analyze 1/28/2022 Review and analyze damages documentation 3.2 3.2 $675.00 $2,160.00Ray D. McKenzie 0% $2,160.00Attributable to Shadetree only Communicate 1/28/2022 Draft emails to client regarding Plaintiffs' position 0.5 0.5 $675.00 $337.50Ray D. McKenzie 0% $337.50Attributable to (with client) on damages Shadetree only Communicate 1/28/2022 Communicate with counsel for Shadetree 0.6 0.6 $675.00 $405.00Warren T. Allen II 0% $405.00Attributable to (other outside Defendants re: motion for contempt and motion Shadetree only counsel) for default as to liability; draft follow-up correspondence to counsel for Shadetree Defendants documenting substance of call Draft/revise 1/28/2022 Draft final revisions to motion for contempt, 1.2 1.2 $675.00 $810.00Warren T. Allen II 0% $810.00Attributable to related memorandum in support, notice of Shadetree only hearing, and proposed order Total 961.8 $649,228.50 N/A $431,500.50
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Mamadou v. Cho, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mamadou-v-cho-vaed-2023.