Fields v. Secretary of Health and Human Services
Opinion
In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS ******************** * TERESA K. FIELDS, Executrix for * the estate of JAMES T. LAWRENCE,* No. 17-1056V * Special Master Christian J. Moran Petitioner, * * v. * Filed: July 27, 2022 * SECRETARY OF HEALTH * Attorneys’ Fees and Costs, AND HUMAN SERVICES, * Reasonable Number of Hours, * Vague Entries, Remand Respondent. * ******************** * Carol L. Gallagher, Carol L. Gallagher, Esquire LLC, Somers Point, NJ, for Petitioner; Colleen C. Hartley, United States Dep’t of Justice, Washington, DC, for Respondent.
PUBLISHED DECISION ON REMAND AWARDING ATTORNEYS’ FEES AND COSTS1 A November 2, 2021 decision awarded $83,341.89 in attorneys’ fees and costs. After a motion for review was filed, the court denied the motion in part, granted the motion in part, vacated the underlying decision, and remanded for additional findings.
The E-Government Act, 44 U.S.C. § 3501 note (2012) (Federal Management and Promotion of Electronic Government Services), requires that the Court post this decision on its website. This posting will make the decision available to anyone with the internet. Pursuant to Vaccine Rule 18(b), the parties have 14 days to file a motion proposing redaction of medical information or other information described in 42 U.S.C. § 300aa-12(d)(4). Any redactions ordered by the special master will appear in the document posted on the website.
For the work covered by the previous decision, a reasonable amount of fees and costs is $88,861.75. In addition, a reasonable amount of attorneys’ fees and costs for work performed on the motion for review is $9,094.80.
I. Abbreviated Procedural History A. Entitlement According to the timesheets, Attorney Carol Gallagher started work on this case in June 2016. At that time, Ms. Gallagher received an email from “counsel.”
The identity of this person is not otherwise described in the timesheets.
Ms. Gallagher collected and reviewed medical records over several months.
Ms. Gallagher drafted a petition, filed August 4, 2017. On behalf of James Lawrence, Ms. Gallagher alleged in the petition that an influenza vaccine caused him to suffer Guillain-Barré syndrome (“GBS”). As part of the initial processing of this case, the undersigned presented guidance about how attorneys should prepare timesheets for in anticipation of requesting attorneys’ fees. Order, issued Aug. 4, 2017.
About six months before the petition was filed in this case, the Secretary recognized an association between flu vaccines and GBS. 82 Fed Reg. 6294.
When the Secretary reviewed the evidence in this case, the Secretary expressed an interest in resolving it. Resp’t’s Status Rep., filed May 7, 2018. The Secretary’s openness to resolving the case simplified the case because Mr. Lawrence was not obligated to establish that he was entitled to compensation. Ms. Gallagher retained a life care planner. Timesheets (entry for May 7, 2018).
As the parties were attempting to resolve the case, Mr. Lawrence’s mental capacity declined. Accordingly, Ms. Gallagher explored obtaining a guardianship for Mr. Lawrence. Pet’r’s Status Report, filed April 2, 2019; see also entry for April 8, 2019.
Ms. Gallagher learned that Mr. Lawrence passed away on September 25, 2019. See exhibit 16. Mr. Lawrence’s death meant that he would no longer incur unreimbursed medical expenses. However, his estate would be eligible to receive $250,000 if his death was due to an injury the flu vaccine caused. Ms. Gallagher continued to attempt to resolve the case informally. See, e.g., entry for January 28, 2020.
In May 2020, the parties reached a tentative agreement, and after an authorized representative of the Attorney General agreed to the proposal, a decision was issued on August 19, 2020. 2020 WL 5667945. This decision awarded compensation to Janet Fields, who was the executrix of the estate for Mr. Lawrence.
B. Attorneys’ Fees On September 10, 2020, petitioner filed a motion for final attorneys’ fees and costs (“Fees App.”). Petitioner requested attorneys’ fees of $103,287.65 and attorneys’ costs of $11,466.06 for a total request of $114,756.71.
The same day as Ms. Fields requested attorneys’ fees and costs, the Secretary responded. The Secretary submitted his generic response, recommending that “that the Court exercise its discretion” in finding a reasonable amount of attorneys’ fees and costs. Resp’t’s Resp., filed Sep. 10, 2020, at 3.
Ms. Fields was awarded attorneys’ fees and costs. First Fee Decision, filed Nov. 4, 2021. With respect to the amount of attorneys’ fees, the undersigned reduced the amount requested by 30% because of the vagueness of many entries.
There were also “infrequent entries” in which Ms. Gallagher charged for excessive activities or charged at an attorney’s rate for performing paralegal work. As to costs, the undersigned found that Ms. Gallagher claimed an unreasonable amount for food and beverages while she traveled. The total amount awarded was $83,341.89.
Ms. Fields contested the decision by filing a motion for review. She argued that the deductions for both attorneys’ fees and costs were arbitrary and capricious.
She also sought an additional amount of attorneys’ fees for filing the motion for review. Pet’r’s Mot. for Rev., filed Nov. 30, 2021. The Secretary defended the November 4, 2021 decision as reasonable.
The Court came to different outcomes with respect to fees and costs. As to the reduction in costs for excessive charges for food and drink, the Court ruled that the undersigned’s reliance on an objective metric, the 2018 GSA per diem rates, could “hardly qualify as an abuse of discretion.” Opinion and Order, 2022 WL 1573538, at *8. Thus, Ms. Fields’s motion for review was denied in that respect.
On the other hand, the Court ruled that the blanket reduction of 30 percent was not justified. The Court’s review suggested that a 15 percent deduction may be appropriate. However, the Court also indicated that “a more detailed explanation from the Special Master” could substantiate a larger deduction. As such, the Court granted Ms. Fields’s motion for review regarding the award of attorneys’ fees and remanded “for further consideration.” Id. at *7.
Finally, the Court also approved Ms. Fields’s request for compensation regarding for the time she spent on preparing the motion for review. The Court remanded on this point as well.
II. Analysis For determining a reasonable amount of attorneys’ fees, special masters may use the lodestar formula. In the lodestar formula, two factors are multiplied: a reasonable hourly rate and a reasonable number of hours. Opinion and Order, 2022 WL 1573538, at *4, citing Avera v. Sec’y of Health & Hum. Servs., 515 F.3d 1343, 1347 (Fed. Cir. 2008). The reasonable hourly rates were set in the First Fees Decision. Thus, the only issue is a reasonable number of hours.
The finding about a reasonable number of hours in the First Fees Decision was based upon the undersigned’s evaluation of the time records and cost invoices.
Without assistance from the Secretary, the undersigned identified line items in which Ms. Gallagher requested an unreasonable amount of compensation, such as billing a tenth of an hour for leaving a message. The undersigned also identified time entries that were vague. The Court appears to have agreed that reductions and/or elimination of these types of problematic entries was appropriate. 2022 WL 1573538, at *5.
However, the First Fees Decision did not perform the additional step of precisely quantifying the value of those unreasonable entries. This precise quantification did not seem required as fee-adjudicators may reduce by percentages. Special masters have previously reduced fees by 20 percent without conducting a line-by-line analysis. See Abbott v. Sec'y of Health & Hum. Servs., No. 10-485V, 2017 WL 2226614, at *7-8 (Fed. Cl. Apr. 26, 2017) (reducing one attorney’s time by 10 percent and another attorney’s time by 30 percent primarily because of vague entries), mot. for rev. denied, 135 Fed. Cl. 107, 111-12 (2017); Mack v. Sec’y of Health & Hum. Servs., No. 15-0149V, 2017 WL 5108680, at *4- (Fed. Cl. Spec. Mstr. Sept. 28, 2017) (reducing fees by 20 percent for vagueness, impermissible entries, and excessive and duplicative billing without conducting a line-by-line evaluation); Boman v. Sec’y of Health & Hum. Servs., No. 15-0256V, 2017 WL 7362539, *4-*6 (Fed. Cl. Spec. Mstr. Sept. 20, 2017) (reducing fees by percent for vagueness and overbilling); Willett v. Sec’y of Health & Hum.
Servs., No. 15-252V, 2017 WL 3298983, at *4 (Fed. Cl. Spec. Mstr. June 2, 2017) (reducing fees by 20 percent for vagueness); Raymo v. Sec’y of Health & Hum.
Servs., No. 11-654V, 2016 WL 7212323, at *18 (Fed. Cl. Spec. Mstr. Nov. 2, 2016) (reducing fees by 40 percent for one firm and 20 percent for a different firm due to excessive and duplicative billing), mot. for rev. denied, 129 Fed. Cl. 691, (2016); see also Marshall v. Sec’y of Health & Hum. Servs., No. 14-491V, 2017 WL 6763068, *4 (Fed. Cl. Spec. Mstr. Dec. 7, 2017) (reducing fees by 25 percent for vagueness and excessive and duplicative billing); Helton v. Sec’y of Health & Hum. Servs., No. 16-0234V, 2017 WL 4020452, at *5-6 (Fed. Cl. Spec.
Mstr. Aug. 28, 2017) (reducing fees by 25 percent for excessive billing).
Additionally, judges in the Court of Federal Claims have reduced fees by percentages greater than 20 percent without providing line-by-line analysis of the billing entries. See Westdale Northwest Ctr., LP v. United States, 159 Fed. Cl. 851, 865-66 (2022) (reducing fees by 25 percent for lack of success on core claims); Yang v. United States, 156 Fed. Cl. 1, 8 (2021) (reducing total hours from 406.4 by 201.65, slightly over a 50 percent reduction in fees, for unproductive work); Greenhill v. United States, 96 Fed. Cl. 771, 780, 785 (2011) (reducing EAJA fee award by 60 percent for duplicative and excessive billing and limited success); KMS Fusion, Inc. v. United States, 39 Fed. Cl. 593, 603 (1997) (reducing fee award to 40 percent of requested attorneys’ fees for vagueness).
In choosing to reduce the attorneys’ fees by a percentage, the undersigned was mindful that a percentage reduction might achieve the “rough justice,” which the Supreme Court has recognized as a goal in fee adjudication, Fox v. Vice, 563 U.S. 826, 838 (2011), without necessarily consuming an extensive amount of judicial resources. The amount of judicial resources spent on evaluating fee requests is considerable. Since the Government has stopped meaningfully participating in the process of determining a reasonable amount of attorneys’ fees and costs, problems have developed. Previously, a negotiation between the parties led to a compromise in the amount requested in attorneys’ fees and cost. This compromise, in turn, allowed special masters to enter decisions awarding attorneys’ fees and costs quickly. Currently, without the Secretary’s participation in determining a reasonable amount of attorneys’ fees and costs, special masters must resolve each fee motion. McIntosh v. Sec’y of Health & Human Servs., 139 Fed. Cl. 238 (2018). This review, in turn, delays cases, leading to a backlog of unadjudicated fee motions. In addition, the lack of specific objections to amounts requested in fee applications makes adjudicating fee motions more difficult as the potentially problematic entries are not drawn to the special master’s attention.
The Office of Special Masters has effectively replaced the Department of Justice in monitoring the Trust Fund with respect to the payment of attorneys’ fees and costs in the Vaccine Program. See McIntosh, 139 Fed. Cl. at 251-52; but see Savin v. Sec’y of Health & Hum. Servs., 85 Fed. Cl. 313, 319 n.7 (2008) (stating that at oral argument counsel for the Secretary “recognized that respondent has an obligation to challenge items believed to be unreasonable, if for no other reason than to preserve the public fisc”). For example, in the present case, the Secretary did not identify that Ms. Gallagher sought reimbursement for food and beverages far in excess of the amount the GSA determined was reasonable.
While a percentage fee reduction has the advantage of being brief, the brevity could be perceived as arbitrary. Thus, appellate tribunals have required fee-adjudicators to present “a concise but clear explanation” for a fee award. Biery v. United States, 818 F.3d 704, 711 (Fed. Cir. 2016) (finding that the trial court did not err in reducing the number of hours by 30% because of work for claims for plaintiffs that did not succeed).
In the present case, as mentioned above, the Court ruled that a 30 percent reduction was not substantiated. Thus, a remand was required, allowing for “a more detailed explanation.” Accordingly, the undersigned has again reviewed Ms. Gallagher’s time sheets with fresh eyes over the course of many days. The result is presented in the appendix.
Highlights include the following points: 1. Time Spent Requesting Medical Records When an attorney does the work of a paralegal or administrative assistant, he or she should be paid a rate commensurate with the nature of the work. See Valdes v. Sec'y of Health & Human Servs., 89 Fed. Cl. 415, 425 (2009) (noting that “the Special Master exercised appropriate discretion in denying requested costs for work performed by Petitioner’s counsel’s associate” when the special master determined “that the associate’s time spent obtaining medical records was more consistent with paralegal duties.”). The August 4, 2017 order regarding attorneys’ fees specifically advised that tasks that do not require an attorney’s education and training, “such as collecting medical records, should be charged at a lower rate.”
Ms. Gallagher spent approximately nine hours collecting medical records.
The amount of time is reasonable. However, this work should have been charged at paralegal rates. A correction results in a deduction of approximately $2,000.
2. Time Spent Reviewing Medical Records A similar, but slightly different issue is the time spent reviewing medical records. In the undersigned’s experience in reviewing hundreds of fee applications, attorneys who charge relatively high hourly rates delegate the task of a first review of medical records to lower paid staff, such as paralegals. See Saxton v. Sec’y of Health & Human Servs., 3 F.3d 1517, 1521 (Fed. Cir. 1993) (allowing special masters to rely upon their experience in adjudicating fee applications).2 This delegation makes sense because the time of a higher-charging attorney is reserved for tasks that require an attorney’s legal training. After a paralegal identifies the critical medical records and, perhaps, prepares a chronology, the attorney can focus her (or his) review on the most important medical records. Thus, the review of medical records reflects efforts from both an attorney and a paralegal.
Here, Ms. Gallagher has spent more than 80 hours (the equivalent of two standard workweeks) reviewing medical records. Of this time, nearly half (approximately 34 hours) concerned review of records in 2018 when Mr. Lawrence’s health was declining. In 2018, Ms. Gallagher was receiving assistance from Ms. Hurley, who spent approximately 8.5 hours reviewing medical records.
Fee Exhibit C at 3-4.
In the undersigned’s experience, the amount of attorney time at an attorney’s hourly rate was excessive. The combination of the number of hours charged and the hourly rate charged produces an unreasonable amount for review of medical records. See Broekelschen v. Secʼy of Health & Human Servs., 102 Fed. Cl. 719, 733 (2011) (noting that an experienced attorney who charges a relatively high hourly rate may be expected to perform some tasks in less time than inexperienced attorneys with lower hourly rates). To give one example, in June 2018, Ms. Gallagher spent 5.6 hours reviewing 1,420 pages from Essex Nursing Home.
While the number of pages might be large, it is not readily apparent why Ms. Gallagher spent more than half a standard work day in reviewing these records.
The Essex Nursing Home records begins with an alphabetical list of 18 topics, beginning with “Activity Progress Reports” and ending with “Wandering Risk.”
Exhibit 9 at 9-284. More than 300 pages concern the nursing home’s care assessment and screening. Id. at 293-603. Another approximately 250 pages are daily reports, which are not entirely legible. Id. at 620-895. Another section contains a doctor’s periodic review of labs. Id. at 1269-336.3 Given the issues in Mr. Lawrence’s case, an attorney would probably not be required to review this material in detail especially if a paralegal outlined the material in advance.
To fashion a more reasonable amount of compensation on the task of reviewing medical records, the undersigned has credited all the time. However, the Whether Ms. Gallagher has similar access to the invoices of other attorneys is not known.
This range of pages includes some reports that are not lab reviews. undersigned has reduced the hourly rate to a rate below an attorney’s rate and above a paralegal’s rate. The rate above a paralegal’s rate is intended to capture the attorney’s targeted review of critical medical records.4 This adjustment causes a reduction of approximately $17,000.
3. Miscellaneous Items Approximately 25 entries fall into a miscellaneous category, reflecting entries that are excessive, duplicate, or clerical. An adjustment for these items causes a reduction of approximately $1,000.
The three topics discussed above reduce the value of attorneys’ fees from $100,417.65 to $80,032.65.5 These deductions are calculated without taking into account vague entries.
4. Vague To facilitate the process of evaluating the reasonableness of an attorney’s activities, in November 2004, the Office of Special Masters issued revised Guidelines for attorneys. The Guidelines stated: “counsel are advised to maintain detailed contemporaneous records of time and funds expended under the Program.”
Office of Special Masters, Guidelines for Practice under the National Vaccine Injury Compensation Program (Rev. Nov. 2004) at § XIV. The contemporary version of the Guidelines repeats this position: “Contemporaneous time records should indicate the date and specific character of the services performed.”
Guidelines, Section X, Chapter 3.B.1.b. Detailed (or stated another way, non- vague) contemporaneous records are the petitioner’s responsibility and allow the Office of Special Masters to determine the reasonableness of attorneys’ fees requests. See Avgoustis v. Shinseki, 639 F.3d 1340, 1344-45 (Fed. Cir. 2011) (stating that requiring entries which permit effective review of the fees is in accord with cases from the Federal Circuit and the Supreme Court). Fee adjudicators have reduced fee requests due to vagueness. See Abbott v. Sec'y of Health & Human Servs., 135 Fed. Cl. 107 (2017) (holding that the special master acted within his discretion in reducing an award based on vague billing entries); see also Almanza v. United States, No. 13-130, 2018 WL 1704521, at *7 (Fed. Cl. Apr. 9, 2018) Another method would be to keep the hourly rate constant but reduce the number of hours.
Ms. Gallagher separately charged for time spent in travel ($2,870.00). The fees for travel are reasonable. (reducing specific time entries with block billing by 50 percent because the Court could not assess the reasonableness of the activity).
As a precedent from the Federal Circuit, Avgoustis merits careful attention.
There, an attorney created 26 entries for “review[ed] client correspondence” or “draft[ed] client correspondence” and billed 0.2 hours for each entry. Avgoustis, 639 F.3d at 1341. The government opposed compensating the attorney because the entries did not describe the purpose of the communication. Id. The fee- adjudicator, the Court of Appeals for Veterans Claims, rejected an argument that more specificity was not needed due to the attorney-client privilege and reduced the fee award by 2.5 hours. Id. at 1341-42.6 On appeal, the Federal Circuit appeared to agree that the time entries were vague. The Federal Circuit stated that a previous opinion by the Court of Appeals for Veterans Claims, McDonald v. Nicholson, 21 Vet. App. 257, 264 (2007), was in accord with Supreme Court and circuit court cases. Avgoustis, 639 F.3d at 1344. Other examples of too vague entries included “reviewing litigation file,” and “telephone conversations with VA counsel.” Id. The Federal Circuit’s Avgoustis case was cited in the order regarding fees issued in this case on August 4, 2017. This order informed Ms. Gallagher about the need for specificity in time entries. It provided: The entries on the time sheet should stand alone. A rule of thumb is that entries should contain more than 10 words. For example, “review respondent’s expert report to prepare for tomorrow’s status conference” provides more information than “review file.” Even privileged communications should contain more detail than simply saying “Telephone call with client.” See Avgoustis v. Shinseki, 639 F.3d 1340, 1344-45 (Fed. Cir. 2011).
Order, issued Aug. 4, 2017, at 4.
Here, Ms. Gallagher has created many entries for which the purpose is not apparent. Within appendix one, entries are highlighted in orange, and they appear
Because the disputed number of hours totaled 5.2 hours (26 entries at 0.2 hours), a reduction of 2.5 hours was a reduction to nearly half the hours claimed. separately in appendix two. The amount of time for these entries totals 25 hours and the charged value is approximately $10,000.
The question is: what to do with those time entries that are difficult to assess for their reasonableness. Avgoustis supplies one potential answer: reduce them by percent.
However, a reduction of greater than 50 percent is arguably warranted for Ms. Gallagher. Ms. Gallagher has had fees reduced on more than occasion for creating vague entries. See De Souza v. Sec’y of Health & Hum. Servs., No. 17- 100V, 2018 WL 4624249, at *3 (Fed. Cl. Spec. Mstr. July 3, 2018) (reducing number of hours by 35 percent), mot. for rev. denied in relevant part, 141 Fed. Cl. 338, 346 (2018).
When attorneys do not submit reasonable time entries, fee adjudicators may impose a penalty to incentivize the submission of reasonable time requests in the future. See Valdes v. Sec'y of Health & Human Servs., No. 99–310V, 2009 WL 1456437, at *4 (Fed. Cl. Spec. Mstr. Apr. 30, 2009) (warning attorney that penalties may be necessary to motivate him to submit requests for fees that do not contain “erroneous, duplicative, or unreasonable entries”), mot. for rev. granted in non-relevant part and denied in non-relevant part, 89 Fed. Cl. 415 (2009). Without a change in practice, an attorney continually burdens the system with the duty of correcting fee applications, which delays the adjudication of fee applications submitted by other attorneys. Accordingly, Ms. Gallagher is alerted that submission of time entries that contain vague entries may incur a penalty greater than 50 percent.
However, to give Ms. Gallagher the benefit of the doubt, the vague time entries are reduced by 50 percent. This change results in a reduction of approximately $5,000.
In short, a new look at Ms. Gallagher’s timesheets suggests that a reasonable amount of attorneys’ fees is approximately $78,000. This figure is the result of the following calculations: Original request (not including travel costs) $100,417.65 Reduction for attorney's charging for collecting medical $2,070.05 records at an attorney's rate Reduction for excessive time reviewing medical records $17,307.40 at attorney rate Reduction for miscellaneous entries $1,056.35 Reduction for vague entries $5,032.63 Subtotal: Reasonable amount for primary activities $74,951.22 Addition for Travel Time $2,870.00 Total Attorneys' Fees $77,821.22
While the amount of $77,821.22 is approximately 7.5 percent more than the amount previously found to be a reasonable amount ($72,301.36), the amount of $77,821.22 is less than the amount the Court suggested might be reasonable. The Court previously indicated that an overall reduction of 15 percent might be reasonable and a 15 percent reduction plus an award of travel costs produces a loadstar value of $88,225.00.
In a brief on remand, Ms. Fields emphasizes that the Court’s Opinion remanded with instructions “for consideration of the appropriate attorneys’ fees award consistent with this opinion.” Pet’r’s Br., filed July 17, 2018, at 5. Ms. Fields seems to suggest that an award of less than the amount suggested ($88,225.00) would not be consistent with the Court’s Opinion. However, the Court appears not to have determined that outcomes other than a simple reduction of 15 percent could be reasonable because the Court remanded for the undersigned to consider the question of reasonableness again. If the only appropriate reduction were 15 percent, then, it seems, that a remand would not have been necessary.
To this reasonable amount, two items must be added.7 First, the previous decision awarded $11,040.53 in costs and this award was found not arbitrary.
Second, the Court authorized an award for fees incurred in preparing the November 30, 2021 motion for review. For the motion for review, the Secretary did not object to either the proposed hourly rate or the proposed number of hours.
Resp’t’s Resp., filed June 22, 2022. Accordingly, a reasonable amount of compensation for the motion for review is $9,094.80.
In sum, a reasonable amount of attorneys’ fees and costs is $97,956.55.
Attorneys' Fees before Special Master $77,821.22 Costs $11,040.53 Attorneys' Fees for Motion for Review $9,094.80 Total $97,956.55 Although the July 1, 2022 order invited Ms. Fields to request fees for time spent responding to the order, Ms. Gallagher declined. Pet’r’s Br., filed July 17, 2022, at 10 n.3.
III. Conclusion In accord with the Court’s May 10, 2022 Opinion, the undersigned has re- reviewed the submissions regarding the attorneys’ fees and costs. Based, in part, on the undersigned’s experience in reviewing fee applications and oversight of this case, the undersigned has found that $97,956.55 constitutes a reasonable amount of attorneys’ fees and costs.
Pursuant to Vaccine Rule 28.1(a), the Clerk is directed to provide this decision to the assigned judge. The Clerk is further directed to enter judgment in accord with this decision unless a motion for review is filed within the time provided. Information about filing a motion for review, including deadlines, is available on the website for the Court of Federal Claims.
IT IS SO ORDERED.
s/Christian J. Moran Christian J. Moran Special Master
Appendix A: Time Entries
reason time (w/o assess reasona date activity rate subtotal change able subtotal the hr) ment ble time rate Review of email from counsel re: taking case, 6/13/16 0.15 350 $52.50 v 0.15 $350 $52.50 preparation of response Review of email/info from counsel, preparation 6/20/16 0.25 350 $87.50 v 0.1 yes $350 $35.00 of response Preparation of email to counsel, review of 6/27/16 0.10 350 $35.00 v 0 yes $350 $0.00 response Review of email from counsel, preparation of 6/28/16 0.15 350 $52.50 v 0.15 no $350 $52.50 response Review of phone message re: call from Mr. 6/29/16 Lawrence, telephone communication with Mr. 1.00 350 $350.00 1.00 $350 $350.00 Lawrence, memorandum to file Preparation of email to counsel, review of 6/29/16 0.15 350 $52.50 v 0.15 no $350 $52.50 response with response 6/29/16 Review of email from counsel with response 0.10 350 $35.00 v 0.10 no $350 $35.00 Preparation of correspondence to client, review 6/30/16 0.75 350 $262.50 p 0.75 $135 $101.25 of prepared enclosures 7/06/16 Telephone call from client, notes to file 0.50 350 $175.00 p 0.50 $135 $67.50 Review of information from client with notes to 7/11/16 0.40 350 $140.00 p 0.40 $135 $54.00 file 7/11/16 Dictation to secretary 0.00 350 $0.00 0.00 $350 $0.00 Review of correspondence to providers with 8/26/16 0.20 350 $70.00 p 0.20 $135 $27.00 changes Review of file and notes with work 12/15/16 0.30 350 $105.00 0.30 $350 $105.00 memorandum 12/15/16 Three calls to client, note to file--left messages 0.10 350 $35.00 p 0.10 $135 $13.50 12/16/16 Two telephone calls to client—note to file 0.10 350 $35.00 p 0.10 $135 $13.50 Preparation of correspondence to client with 12/16/16 0.60 350 $210.00 p 0.60 $135 $81.00 requests and need for communication Telephone communication with Mr. Lawrence’s 12/22/16 0.75 350 $262.50 0.75 $350 $262.50 daughter, Teresa, notes to file Review of email from Teresa Fields, 2/15/17 preparation of response, review of text with 0.15 363 $54.45 p 0.15 $138 $20.70 response 3/27/17 Review of file, memorandum to secretary 0.20 363 $72.60 0.20 $363 $72.60 Preparation of email to P’s daughter with 3/27/17 0.20 363 $72.60 p 0 20 $138 $27.60 questions Review of records of from Park Terrace Health 3/27/17 1.75 363 $635.25 r 1 75 $175 $306.25 Campus (Pp. 1-91), notes to file 3/27/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of responsive email from Teresa Fields, 3/27/17 0.15 363 $54.45 p 0.15 $138 $20.70 memorandum to file Continued review of records from Park Terrace 4/13/17 1.15 363 $417.45 r 1.15 $175 $201.25 (Pp. 92-148), notes to file Telephone call to Teresa Fields—number 4/13/17 0.10 363 $36.30 p 0.10 $138 $13.80 disconnected Preparation of correspondence to client and 4/13/17 0.75 363 $272.25 0.75 $363 $272.25 Teresa Fields (sent via certified mail) 4/13/17 Drafting of petition 0.30 363 $108.90 0.30 $363 $108.90 Continued review of Park Terrace records (Pp.
4/14/17 1.50 363 $544.50 r 1.50 $175 $262.50 149-260), notes to file Continued review of Park Terrace records (Pp.
4/17/17 1.25 363 $453.75 r 1.25 $175 $218.75 261-407), notes to file Review of file and recent notes, preparation of 5/01/17 0.35 363 $127.05 0 35 $363 $127.05 memorandum to secretary with directives 5/04/17 Dictation to provider 0.00 363 $0.00 0.00 $363 $0.00 Review of prepared correspondence with 5/04/17 0.10 363 $36.30 p 0.10 $138 $13.80 corrections Telephone call from Teresa Fields, 5/08/17 0.75 363 $272.25 0.75 $363 $272.25 memorandum to file 5/08/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of vaccine verification information with 5/08/17 1.20 363 $435.60 1.20 $363 $435.60 preparation of timeline Update to client file re: additional 5/08/17 0.30 363 $108.90 0.30 $363 $108.90 facts/information needed 5/09/17 Review of email from P with response 0.15 363 $54.45 p 0.15 $138 $20.70 5/09/17 Dictation to secretary re: records 0.00 363 $0.00 0.00 $363 $0.00 Review of notes to file from records’ review, 5/09/17 1.20 363 $435.60 1.20 $363 $435.60 preparation of petition 5/10/17 Review of memorandum from secretary 0.10 363 $36.30 0.10 $363 $36.30 5/10/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of emails, and affidavit, preparation of 6/02/17 correspondence to Teresa Fields re: revisions 1.00 363 $363.00 1.00 $363 $363.00 and instructions 6/02/17 Additions to petition 0.15 363 $54.45 0.15 $363 $54.45 6/02/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of memo from secretary re: records 6/09/17 0.10 363 $36.30 p 0.10 $138 $13.80 from Kentucky One problem Review of correspondence from Ciox re: 6/13/17 0.10 363 $36.30 p 0 10 $138 $13.80 records 6/13/17 Note to secretary 0.00 363 $0.00 0.00 $363 $0.00 Continued review of notes and records, 6/26/17 2.20 363 $798.60 2.20 $363 $798.60 preparation of petition 6/26/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of records from Robley VA Medical 7/13/17 2.30 363 $834.90 r 2.30 $175 $402.50 Center (Pp. 1-182), notes to file Continued review of records from Robley VA 7/16/17 1.10 363 $399.30 r 1.10 $175 $192.50 Medical Center (Pp. 183-290), notes to file Continued review of records from Robley VA 7/17/17 Medical Center (Pp. 291-507), notes to file, 2.40 363 $871.20 r 2.40 $175 $420.00 dictation to secretary Continued review of records from Robley VA 7/18/17 1.00 363 $363.00 r 1.00 $175 $175.00 Medical Center (Pp. 508-558), notes to file Continued review of records from Robley VA 7/19/17 1.75 363 $635.25 r 1.75 $175 $306.25 Medical Center (Pp. 559-692), notes to file 7/20/17 Continued review of records from Robley VA 1.60 363 $580.80 r 1.60 $175 $280.00 7/20/17 Additions to petition 1.40 363 $508.20 1.40 $363 $508.20 Telephone call to Kentucky One (lack of 7/20/17 0.10 363 $36.30 p 0.10 $138 $13.80 cooperation – left message Review of telephone message from Sandra from 7/21/17 Kentucky One, returned call and left message to 0.10 363 $36.30 p 0.10 $138 $13.80 call back Continued review of records from Robley VA 7/24/17 1.50 363 $544.50 r 1.50 $175 $262.50 Medical Center (Pp. 804-975), notes to file 7/24/17 Additions to petition 0.35 363 $127.05 0.35 $363 $127.05 Continued review of records from Robley VA 7/25/17 Medical Center (Pp. 976-1146) with notes to 2.00 363 $726.00 r 2.00 $175 $350.00 file Memorandum re: correspondence and call to 7/28/17 0.15 363 $54.45 p 0.15 $138 $20.70 provider Review of records from VA Robley (Pp. 1147- 7/31/17 1.60 363 $580.80 r 1 60 $175 $280.00 1202), notes to file, 7/31/17 Additions to petition 0.30 363 $108.90 0.30 $363 $108.90 Continued review of records from VA Robley 8/01/17 1.75 363 $635.25 r 1.75 $175 $306.25 (Pp. 1202-1296), notes to file 8/01/17 Memorandum and review for filing 0.10 363 $36.30 0.10 $363 $36.30 Continued review of supplemental records from 8/02/17 2.00 363 $726.00 r 2.00 $175 $350.00 VA Robley (Pp. 1296-1415), notes to file Research/review literature re: GBS v. CIDP, 8/02/17 1.10 363 $399.30 1.10 $363 $399.30 notes to file 8/02/17 Review of notes to file, additions to petition 0.75 363 $272.25 0.75 $363 $272.25 Continued review of records from VA Robley 8/03/17 2.50 363 $907.50 r 2.50 $175 $437.50 (Pp. 1416-1642), notes to file 8/03/17 Continued review of notes from records’ review 2.40 363 $871.20 2.40 $363 $871.20 Review of accompanying letter/documents for 8/03/17 0.15 363 $54.45 0.15 $363 $54.45 filing Completion of VA Robley records (Pp. 1643- 8/04/17 2.20 363 $798.60 r 2.20 $175 $385.00 1912) with notes to file Preparation of correspondence to client—sent 8/04/17 0.60 363 $217.80 v 0.60 $363 $217.80 via email Review of 3 ECF’s – Petition, Designation of 8/04/17 0.15 363 $54.45 0.15 $363 $54.45 ECF, Order Preparation of correspondence to client with 8/04/17 0.25 363 $90.75 v 0.25 $363 $90.75 filed petition—sent via email Review of ECF and Scheduling Order, review 8/07/17 0.15 363 $54.45 0.15 $363 $54.45 of ECF and Order 8/07/17 Preparation of email to client 0.10 363 $36.30 v 0.10 $363 $36.30 Preparation of explanatory letter with 8/08/17 0.50 363 $181.50 0.50 $363 $181.50 attachments—sent via email 8/08/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 8/11/17 Review of ECF/Notice of Appearance 0.10 363 $36.30 0.10 $363 $36.30 8/11/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Review of records from Dr. David Charles (Pp.
8/21/17 0.75 363 $272.25 r 0.75 $175 $131.25 1-38), notes to file Telephone call to Kentucky One re: records 08/22/17 from University of Louisville Hospital – left 0.10 363 $36.30 p 0.10 $138 $13.80 message (not cooperating with secretary) 08/22/17 Continued review of Dr. Charles (Pp. 39-120), 1.25 363 $453.75 r 1.25 $175 $218.75 notes to file 08/24/17 Review of recent pleadings, telephone call to 0.20 363 $72.60 0.20 $363 $72.60 Teresa Fields—left message, note to file 08/24/17 Continued review of records from Dr. Charles 1.00 363 $363.00 r 1.00 $175 $175.00 (Pp. 121 – 202), notes to file 08/24/17 Dictation /review of filing Exhibits 1-5/ECF 0.15 363 $54.45 c 0.00 $0 $0.00 08/24/17 Telephone call with Teresa Fields 0.50 363 $181.50 0.50 $363 $181.50 08/25/17 Continued review of records from Dr. Charles 1.75 363 $635.25 r 1.75 $175 $306.25 (Pp. 203-329), notes to file 08/25/17 Continued review of records from U of 1.00 363 $363.00 r 1.00 $175 $175.00 Louisville Hospital (Pp. 48-99), notes to file 08/25/17 Preparation of Affidavit Regarding Damages 1.00 363 $363.00 1.00 $363 $363.00 08/28/17 Review of records from U of Louisville 1.00 363 $363.00 r 1.00 $175 $175.00 08/28/17 Dictation to secretary 0.00 363 $0.00 0.00 $363 $0.00 Preparation of correspondence to client—sent 1/16/18 0.40 400 $160.00 0.40 $400 $160.00 via email 1/16/18 Review of ECF and Motion for Extension 0.10 400 $40.00 0.10 $400 $40.00 Review of text and then telephone call from 1/16/18 Teresa Fields to discuss delay, etc. with notes to 0.35 400 $140.00 0.35 $400 $140.00 file 1/17/18 Review of ECF and R’s Motion for Extension 0.10 400 $40.00 d 0.00 $0 $0.00 1/19/18 Review of ECF and Order 0.10 400 $40.00 0.10 $400 $40.00 3/13/18 Call from Teresa Fields for update, notes to file 0.40 400 $160.00 0.40 $400 $160.00 3/13/18 Follow up email to client confirming call details 0.15 400 $60.00 0.15 $400 $60.00 Review of responsive email from Teresa Fields 3/14/18 with information; Requested, preparation of 0.20 400 $80.00 0.20 $400 $80.00 response Dictation to secretary re: Nursing home and 3/14/18 0.00 400 $0.00 0.00 $400 $0.00 rehab records 3/19/18 Review of ECF and R’s status report 0.10 400 $40.00 0.10 $400 $40.00 3/19/18 Preparation of email to client with attachment 0.10 400 $40.00 0.10 $400 $40.00 3/20/18 Review of correspondence to facility 0.10 400 $40.00 p 0.10 $143 $14.30 3/20/18 Review of ECF – Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 4/03/18 Review of ECF and Formal Notice 0.10 400 $40.00 0.10 $400 $40.00 4/03/18 Review of prepared Notice to Continue/ECF 0.10 400 $40.00 0.10 $400 $40.00 5/07/18 Review of ECF and Status Report 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Teresa Fields and James 5/07/18 0.10 400 $40.00 0.10 $400 $40.00 Lawrence Preparation of email to Colleen Hartley, review 5/07/18 0.10 400 $40.00 0.10 $400 $40.00 of response Preparation of email to potential life care 5/07/18 0.15 400 $60.00 0.15 $400 $60.00 planner with sparse facts Review of responsive email from James 5/07/18 0.10 400 $40.00 0.10 $400 $40.00 Lawrence with response Review of responsive email from life care 5/07/18 0.20 400 $80.00 0.20 $400 $80.00 planner with response Review of another email from James Lawrence 5/07/18 0.10 400 $40.00 0.10 $400 $40.00 with response 5/07/18 Review of ECF and scheduling order 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with Jay Lawrence, 5/08/18 1.10 400 $440.00 1.10 $400 $440.00 follow up memorandum to file Preparation of email to expert re: 5/08/18 0.30 400 $120.00 0.30 $400 $120.00 Medicaid/Medicare issues, etc. Preparation of email to Jay Lawrence with 5/08/18 0.10 400 $40.00 0.10 $400 $40.00 requests for information Review of responsive email from Jay Lawrence 5/08/18 0.10 400 $40.00 0.10 $400 $40.00 with response 5/08/18 Dictation to secretary 0.00 400 $0.00 0.00 $400 $0.00 Five (5) email communications with life care 5/09/18 0.25 400 $100.00 0.25 $400 $100.00 planner with details 5/09/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of email with questions from life care 5/10/18 0.15 400 $60.00 0.15 $400 $60.00 planner, preparation of response 5/10/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 5/10/18 Preparation of email to Jay Lawrence 0.10 400 $40.00 0.10 $400 $40.00 Telephone call from Jay Lawrence, 5/10/18 0.75 400 $300.00 0.75 $400 $300.00 memorandum to file Review of responsive email from Colleen 5/10/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley, preparation of response Preparation of email to potential LCP, review of 5/10/18 0.10 400 $40.00 0.10 $400 $40.00 response Telephone communication with LCP (Roberta 5/11/18 0.25 400 $100.00 0.25 $400 $100.00 Hurley), notes to file 5/11/18 Preparation of 2 emails to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence with 5/11/18 0.15 400 $60.00 0.15 $400 $60.00 questions Review of email from Roberta Hurley with 5/13/18 0.15 400 $60.00 0.15 $400 $60.00 response Review of email from Teresa Fields with 5/14/18 0.20 400 $80.00 0.20 $400 $80.00 questions, preparation of response Review of email from Roberta Hurley with 5/14/18 0.10 400 $40.00 0.10 $400 $40.00 answer Telephone communication with Roberta 5/14/18 0.35 400 $140.00 0.35 $400 $140.00 Hurley, follow up memorandum to file Preparation of correspondence to Roberta 5/14/18 1.00 400 $400.00 1.00 $400 $400.00 Hurley with details of case 5/14/18 Dictation to secretary 0.00 400 $0.00 0.00 $400 $0.00 Review of email from Roberta Hurley, review 5/14/18 0.15 400 $60.00 0.15 $400 $60.00 of notes, preparation of response 5/14/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 5/14/18 Preparation of email to Jay Lawrence and 0.15 400 $60.00 0.15 $400 $60.00 Review of responsive email from Colleen 5/14/18 0.15 400 $60.00 0.15 $400 $60.00 Hartley with 2 replies 5/14/18 Preparation of email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 5/14/18 Preparation of email to Jay Lawrence 0.10 400 $40.00 0.10 $400 $40.00 5/14/18 Preparation of another email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of responsive email from Colleen 5/15/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response and review of her reply 5/15/18 Preparation of 2 emails to Roberta Hurley 0.15 400 $60.00 0.15 $400 $60.00 5/15/18 Preparation of email to Jay Lawrence 0.10 400 $40.00 0.10 $400 $40.00 Review of secretary’s memorandum re: telephone call to Essex Nursing Rehabilitation 5/15/18 0.10 400 $40.00 p 0.10 $143 $14.30 re: records – transferred to four different people, note to call them myself Telephone call to Essex—spoke with 5/16/18 0.10 400 $40.00 p 0.10 $143 $14.30 “Dana”—note to file 5/16/18 Telephone call to Christine in medical records 0.10 400 $40.00 p 0.10 $143 $14.30 5/16/18 Preparation of correspondence to Essex Nursing 0.40 400 $160.00 p 0.40 $143 $57.20 5/16/18 Preparation of email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence and 5/16/18 0.10 400 $40.00 0.10 $400 $40.00 Teresa Fields Telephone call from Christine of medical 5/16/18 0.10 400 $40.00 p 0.10 $143 $14.30 records, follow up note to file Review of responsive email from Jay Lawrence 5/16/18 0.10 400 $40.00 0.10 $400 $40.00 with response Preparation of another email to Roberta Hurley 5/16/18 0.15 400 $60.00 0.15 $400 $60.00 with questions 5/16/18 Preparation of email to Essex Nursing Home 0.15 400 $60.00 0.15 $400 $60.00 Review of another email from Jay Lawrence 5/16/18 0.10 400 $40.00 0.10 $400 $40.00 with response Review of responsive email from Roberta 5/16/18 0.10 400 $40.00 0.10 $400 $40.00 Hurley 5/16/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of responsive email from Colleen 5/17/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response 5/17/18 Preparation of email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence and 5/17/18 0.10 400 $40.00 0.10 $400 $40.00 Teresa Fields Review of responsive email from Roberta 5/17/18 0.10 400 $40.00 0.10 $400 $40.00 Hurley with response Dictation to secretary re: reservations for site 5/17/18 0.00 400 $0.00 0.00 $400 $0.00 visit Telephone call from Christine of Essex 5/17/18 0.10 400 $40.00 p 0.10 $143 $14.30 Nursing, notes to file Telephone communication with Judy Morris of 5/17/18 Essex Nursing Home business office re: 0.20 400 $80.00 0.20 $400 $80.00 Medicaid lien and dates follow up Preparation of email to Roberta Hurley, review 5/17/18 0.15 400 $60.00 0.15 $400 $60.00 of response with rely Review of email from Jay Lawrence with 5/17/18 0.20 400 $80.00 0.20 $400 $80.00 questions, preparation of response Preparation of 2 emails and one text to Roberta 5/17/18 0.20 400 $80.00 0.20 $400 $80.00 Hurley, review of her texts Review of email from Jay Lawrence with 5/17/18 0.10 400 $40.00 0.10 $400 $40.00 response 5/18/18 Review of recent pleadings 0.10 400 $40.00 0.10 $400 $40.00 5/18/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to client, review of 5/18/18 0.10 400 $40.00 0.10 $400 $40.00 response Review of responsive email from Colleen 5/21/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response 5/21/18 Preparation of email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Review of text message and email from Roberta 5/27/18 0.20 400 $80.00 0.20 $400 $80.00 Hurley with 2 responses Review of text from Roberta Hurley with 5/29/18 0.10 400 $40.00 0.10 $400 $40.00 response Review of email from Roberta Hurley with 5/30/18 0.10 400 $40.00 0.10 $400 $40.00 response Preparation of correspondence to Roberta 5/30/18 0.75 400 $300.00 0.75 $400 $300.00 Hurley with enclosures/ details Preparation of correspondence to Roberta 5/31/18 0.35 400 $140.00 0.35 $400 $140.00 Hurley with additional information for site visit Preparation of email to client with update, 5/31/18 0.10 400 $40.00 0.10 $400 $40.00 review of response Review of notes to file and recent emails, 6/05/18 0.40 400 $160.00 0.40 $400 $160.00 preparation of status report 6/05/18 Dictation for filing 0.00 400 $0.00 0.00 $400 $0.00 Review of records from Essex Nursing Home 6/05/18 2.30 400 $920.00 r 2.30 $185 $425.50 (Pp. 1- 321), notes to file Continued review of records from Essex 6/06/18 2.10 400 $840.00 r 2.10 $185 $388.50 Nursing Home (Pp. 232-772 ), notes to file Continued review of records from Essex 6/07/18 2.00 400 $800.00 r 2.00 $185 $370.00 Nursing Home (Pp.773-1005), notes to file 6/07/18 Preparation of email to Roberta Hurley with 0.15 400 $60.00 0.15 $400 $60.00 6/07/18 Preparation of email to Roberta Hurley 0.15 400 $60.00 0.15 $400 $60.00 6/07/18 Dictation for filing Exhibit 0.00 400 $0.00 0.00 $400 $0.00 6/08/18 Review of ECF and Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to client’s son and 6/08/18 0.10 400 $40.00 0.10 $400 $40.00 daughter 6/08/18 Continued review of records from Essex 1.60 400 $640.00 r 1.60 $185 $296.00 Continued review of records from Essex 6/11/18 2.00 400 $800.00 r 2.00 $185 $370.00 Nursing Home (Pp. 1147-1420), notes to file Preparation of email to Jay Lawrence and 6/11/18 0.20 400 $80.00 0.20 $400 $80.00 Teresa Fields with questions Review of notes from prior communication 6/11/18 0.10 400 $40.00 0.10 * $400 $40.00 with Essex re: Medicaid Preparation of 2 more emails to Jay Lawrence 6/11/18 0.15 400 $60.00 0.15 $400 $60.00 and Teresa Fields Preparation of email to Teresa Fields and Jay 6/20/18 Lawrence with questions and contact 0.20 400 $80.00 0.20 $400 $80.00 information Preparation of email to Colleen Hartley, review 6/20/18 0.10 400 $40.00 0.10 $400 $40.00 of response 6/20/18 Preparation of email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Memorandum of information needed for site 6/20/18 0.25 400 $100.00 0.25 $400 $100.00 visit with review of details Preparation of correspondence to Roberta 6/21/18 Hurley with site visit information—sent via 0.75 400 $300.00 0.75 $400 $300.00 email Review of e-mail and information from Jay 6/21/18 0.25 400 $100.00 0.25 $400 $100.00 Lawrence, preparation of response Review of responsive email from Teresa Fields 6/21/18 0.10 400 $40.00 0.10 $400 $40.00 with response Review of responsive email from Roberta 6/21/18 0.10 400 $40.00 0.10 $400 $40.00 Hurley with response Review of information and preparation for site 6/22/18 1.20 400 $480.00 1.20 * $400 $480.00 visit 6/26/18 Telephone communication with Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 6/26/18 Meeting with Roberta Hurley, notes to file 1.00 400 $400.00 1.00 $400 $400.00 6/27/18 Meeting with Roberta Hurley before site visit 0.25 400 $100.00 0.25 $400 $100.00 6/27/18 Site visit from 10:00 to 12:30 pm 2.50 400 $1,000.00 2.50 $400 $1,000.00 Communication with Roberta Hurley re: time 6/27/18 0.30 400 $120.00 0.30 $400 $120.00 frame, insurance, etc. 6/28/18 Review of prepared correspondence to provider 0.10 400 $40.00 p 0.10 $143 $14.30 Review of text from Roberta Hurley with 6/28/18 response and review of response re: delay in 0.20 400 $80.00 0.20 $400 $80.00 flight receipts for Uber etc Preparation of e-mail to Colleen Hartley re: 7/03/18 0.10 400 $40.00 0.10 $400 $40.00 Medicaid lien, review of response with response Email to Roberta Hurley re: need proposed date 7/03/18 0.10 400 $40.00 0.10 * $400 $40.00 for LCP 7/03/18 Review of order, preparation of status report 0.30 400 $120.00 0.30 $400 $120.00 7/03/18 Directive for filing 0.00 400 $0.00 0.00 $400 $0.00 Memorandum re: information for KY Medicaid 7/03/18 0.10 400 $40.00 0.10 $400 $40.00 Office Preparation of e-mail to client’s son re: 7/06/18 Medicaid information review of response with 0.15 400 $60.00 0.15 $400 $60.00 response Preparation of correspondence to Medicaid 7/06/18 0.50 400 $200.00 p 0.50 $143 $71.50 Cabinet for Health Services Dictation to secretary re: including 7/06/18 0.00 400 $0.00 0.00 $400 $0.00 authorization and Medicaid card Communication with Jay Lawrence re: 7/09/18 0.25 400 $100.00 0.25 $400 $100.00 Medicaid information and lien with notes to file 7/12/18 Review of ECF and Order 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Roberta Hurley re: needs 7/30/18 0.10 400 $40.00 0.10 * $400 $40.00 days for LCP Review of memorandum from secretary and 9/05/18 0.10 400 $40.00 0.10 $400 $40.00 review of most recent pleading 9/05/18 Review of past emails from Roberta Hurley and 0.15 400 $60.00 0.15 $400 $60.00 9/05/18 Preparation of email to Colleen Hartley re: 0.10 400 $40.00 0.10 $400 $40.00 Review of email from P’s son re: status of case 9/05/18 0.15 400 $60.00 0.15 $400 $60.00 with response 9/05/18 Preparation of status report 0.25 400 $100.00 0.25 $400 $100.00 9/06/18 Review of information in file for Medicaid lien 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Colleen Hartley, review 9/06/18 0.10 400 $40.00 0.10 $400 $40.00 of response with response 9/06/18 Revisions to status report 0.15 400 $60.00 0.15 $400 $60.00 Review of responsive email from Jay Lawrence 9/06/18 0.10 400 $40.00 0.10 $400 $40.00 with response 9/06/18 Dictation for filing 0.00 400 $0.00 0.00 $400 $0.00 Review of email from client re: records with 9/07/18 0.10 400 $40.00 0.10 $400 $40.00 response 9/10/18 Review of ECF and Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 9/10/18 Review of email from Colleen Hartley re: 0.10 400 $40.00 0.10 $400 $40.00 9/10/18 Preparation of email to Roberta Hurley re: 0.20 400 $80.00 0.20 $400 $80.00 Telephone call with Jay Lawrence regarding 9/11/18 what is needed to file, memorandum of 0.25 400 $100.00 0.25 $400 $100.00 conversation Preparation of email to Jay Lawrence with 9/11/18 0.10 400 $40.00 0.10 $400 $40.00 attachment Preparation of email to Roberta Hurley with 9/11/18 0.10 400 $40.00 0.10 $400 $40.00 review of response Review of Order and emails, preparation of 9/13/18 0.25 400 $100.00 0.25 $400 $100.00 status report 9/13/18 Dictation to secretary for filing 0.00 400 $0.00 0.00 $400 $0.00 Review of email from Roberta Hurley re: timing for reimbursement of her expenses to 9/13/18 0.15 400 $60.00 0.15 $400 $60.00 KY, preparation of response with review of response Review of file and recent notes and emails for 9/13/18 0.30 400 $120.00 0.30 $400 $120.00 Medicaid call 9/13/18 Telephone call to Medicaid re: information 0.10 400 $40.00 0.10 $400 $40.00 9/13/18 Telephone call to Medicaid Open Records re: 0.15 400 $60.00 0.15 $400 $60.00 Dictation to secretary re: revision to letter 9/13/18 0.00 400 $0.00 0.00 $400 $0.00 request and authorization 9/13/18 Preparation of email to Jay Lawrence re: 0.15 400 $60.00 0.15 $400 $60.00 Review of email from Colleen Hartley with 9/14/18 0.10 400 $40.00 0.10 $400 $40.00 response and review of automatic response 9/14/18 Review of Medicaid lien information with 0.30 400 $120.00 0.30 $400 $120.00 Review of responsive email from Colleen 9/14/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response Review of email from Colleen Hartley with 9/15/18 0.10 400 $40.00 0.10 $400 $40.00 response and review of her response 09/17/18 Review of email from Roberta Hurley with 0.15 400 $60.00 0.15 $400 $60.00 09/17/18 Preparation of email to client re: upcoming 0.10 400 $40.00 0.10 $400 $40.00 09/17/18 Review of P’s LCP draft, review of notes from 0.75 400 $300.00 0.75 $400 $300.00 09/17/18 Preparation of email to Roberta Hurley with 0.25 400 $100.00 0.25 $400 $100.00 09/18/18 Preparation of email to Colleen Hartley with 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with Colleen Hartley 09/18/18 0.50 400 $200.00 0.50 $400 $200.00 with follow up memorandum to file Preparation of emails to 2 authorities on 09/18/18 0.60 400 $240.00 0.60 $400 $240.00 Medicaid for planning on behalf of P Review of emails from counsel re: Medicaid 09/18/18 0.25 400 $100.00 0.25 $400 $100.00 planning, etc. with responses and questions 09/18/18 Preparation of email to client re: records 0.10 400 $40.00 0.10 $400 $40.00 Email communications with Colleen Hartley re: 09/18/18 0.15 400 $60.00 0.15 $400 $60.00 perspective of case Preparation of email to Roberta Hurley with 09/18/18 questions, discussion with R, additional 0.30 400 $120.00 0.30 $400 $120.00 information needed for revised LCP, etc. Review of 2 emails from Roberta Hurley re: 09/18/18 additions and clarifications of the LCP, 0.25 400 $100.00 0.25 $400 $100.00 preparation of 2 responses 09/19/18 Review of email from Jay Lawrence with 0.40 400 $160.00 0.40 $400 $160.00 09/19/18 Preparation of email to Roberta Hurley re: 0.15 400 $60.00 0.15 $400 $60.00 issues to discuss on telephone 09/19/18 Preparation of another email to Roberta Hurley 0.10 400 $40.00 0.10 $400 $40.00 Telephone call from Roberta Hurley re: LCP, 09/19/18 0.25 400 $100.00 0.25 $400 $100.00 memorandum to file 09/20/18 Preparation of email to Roberta Hurley with 0.10 400 $40.00 0.10 $400 $40.00 09/20/18 Review of Medicaid information from 0.25 400 $100.00 0.25 $400 $100.00 09/20/18 Telephone call to Oletta Wright of KY 0.10 400 $40.00 0.10 $400 $40.00 09/20/18 Review of information from counsel re: impact 0.25 400 $100.00 0.25 $400 $100.00 09/21/18 Telephone call from Teresa Fields, follow up 0.50 400 $200.00 0.50 $400 $200.00 09/21/18 Review of responsive email from Oletta Wright 0.10 400 $40.00 0.10 $400 $40.00 re: Medicaid with reply Preparation of email to Colleen Hartley with 09/21/18 0.10 400 $40.00 0.10 $400 $40.00 attachment Preparation of email to client with attachment 09/21/18 0.15 400 $60.00 0.15 $400 $60.00 and explanation of lien Dictation to secretary re: filing Medicaid 9/21/18 0.00 400 $0.00 0.00 $400 $0.00 information 9/21/18 Preparation of email to Ms. Wright per phone 0.10 400 $40.00 0.10 $400 $40.00 9/21/18 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Oletta Wright re: 9/21/18 Medicaid, preparation of response with review 0.15 400 $60.00 0.15 $400 $60.00 of her reply Telephone call from Jay Lawrence, follow up 9/21/18 0.60 400 $240.00 0.60 $400 $240.00 memorandum to file Preparation of email to Roberta Hurley re: any 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 word from Linda Curtis?
Preparation of email to Colleen Hartley with 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 attachment Preparation of email to Jay Lawrence with 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 update 9/21/18 Review of email from Roberta Hurley with 0.50 400 $200.00 0.50 $400 $200.00 Review of email with question from Colleen 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response Preparation of email to Jay Lawrence re: dad’s 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 payments prior to Medicaid 9/21/18 Review of responsive email from Roberta 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to Jay Lawrence re: 9/21/18 0.10 400 $40.00 0.10 $400 $40.00 preparing narrative 9/25/18 Dictation/review of filing Exhibit 10 0.00 400 $0.00 0.00 $400 $0.00 9/26/18 Review of ECF 0.10 400 $40.00 0.10 $400 $40.00 9/26/18 Review of email from Roberta Hurley re: efforts 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to Jay Lawrence re: 9/26/18 0.10 400 $40.00 0.10 $400 $40.00 affidavit, review of response, 9/26/18 Dictation to secretary 0.00 400 $0.00 0.00 $400 $0.00 Preparation of another email to Jay Lawrence 9/26/18 0.10 400 $40.00 0.10 $400 $40.00 re: what I need from him Preparation of email to Jay Lawrence re: we 9/27/18 received records but still have not received 0.10 400 $40.00 0.10 $400 $40.00 additional information from him 9/27/18 Preparation of email to Colleen Hartley re: 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence re: 9/28/18 narrative vs. damages affidavit, review of 0.15 400 $60.00 0.15 $400 $60.00 response with response Telephone call from Jay Lawrence, follow up 9/28/18 0.20 400 $80.00 0.20 $400 $80.00 note to file Review of email from Roberta Hurley re: any 10/01/18 response from R’s LC planner, preparation of 0.10 400 $40.00 0.10 $400 $40.00 response Preparation of another email to Roberta Hurley 10/01/18 0.10 400 $40.00 0.10 $400 $40.00 with attachment 10/01/18 Review of VA Shively records (Pp. 1-112), 2.30 400 $920.00 r 2.30 $185 $425.50 Review of responsive email from Roberta 10/01/18 Hurley with questions, preparation of response 0.15 400 $60.00 0.15 $400 $60.00 based on review of above records Continued review of records from VA Shively 10/02/18 1.75 400 $700.00 r 1.75 $185 $323.75 (Pp. 113-211), notes to file Continued review of records from VA Shively 10/03/18 2.00 400 $800.00 r 2.00 $185 $370.00 (Pp. 212-360), notes to file Continued review of records from VA Shively 10/08/18 0.75 400 $300.00 r 0.75 $185 $138.75 (Pp. 361-419), notes to file Continued review of records from VA Shively 10/09/18 1.30 400 $520.00 r 1.30 $185 $240.50 (Pp. 420-496), notes to file 10/09/18 Review of mail from Roberta Hurley, 0.10 400 $40.00 0.10 $400 $40.00 Dictation to secretary re: correspondence and 10/09/18 0.00 400 $0.00 0.00 $400 $0.00 check to Roberta Hurley Continued review of VA Shively (Pp. 497-705), 10/10/18 2.50 400 $1,000.00 r 2.50 $185 $462.50 notes to file Review of email to Roberta Hurley with 10/10/18 0.10 400 $40.00 0.10 $400 $40.00 response Review of filed petition to compare with 10/11/18 0.15 400 $60.00 0.15 $400 $60.00 records’ review Telephone call to Colleen Hartley—left 10/11/18 0.10 400 $40.00 0.10 $400 $40.00 message, note to file Preparation of email to Roberta Hurley with 10/11/18 0.15 400 $60.00 0.15 $400 $60.00 questions Communication with attorney specializing in 10/11/18 0.35 400 $140.00 0.35 $400 $140.00 Medicare, follow up memorandum to file Review of responsive email from Roberta 10/11/18 0.10 400 $40.00 0.10 $400 $40.00 Hurley Telephone call to attorney in KY—left message, 10/11/18 0.10 400 $40.00 0.10 $400 $40.00 note to file Telephone communication with Colleen Hartley 10/11/18 0.10 400 $40.00 0.10 $400 $40.00 with to file Continued review of VA Shively records 10/12/18 2.60 400 $1,040.00 r 2.60 $185 $481.00 (Pp.706-979), notes to file Continued review of VA Shively records (Pp.
10/15/18 2.00 400 $800.00 r 2.00 $185 $370.00 980-1180), notes to file Continued review of VA Shively records (Pp.
10/16/18 0.75 400 $300.00 r 0.75 $185 $138.75 1181-1229), notes to file Continued review of VA Shively records (Pp.
10/17/18 2.20 400 $880.00 r 2.20 $185 $407.00 1130-1600), notes to file Continued review of VA Shively records (Pp.
10/18/18 1.00 400 $400.00 r 1.00 $185 $185.00 1601-1919), notes to file Continued review of VA Shively records 10/19/18 1.20 400 $480.00 r 1 20 $185 $222.00 (Pp.1920-2054), notes to file Continued review of VA Shively records (Pp.
10/20/18 1.30 400 $520.00 r 1.30 $185 $240.50 2054-2205), notes to file Continued review of VA Shively records (Pp.
10/21/18 1.25 400 $500.00 r 1.25 $185 $231.25 2206-2451), notes to file 10/25/18 Review of order 0.10 400 $40.00 0.10 $400 $40.00 10/25/18 Dictation to secretary for filing records 0.00 400 $0.00 0.00 $400 $0.00 Telephone call to KY Attorney Miller—spoke 10/26/18 with his secretary - re: petitioner passed away, 0.10 400 $40.00 0.10 $400 $40.00 note to file Telephone communication with KY Attorney 10/26/18 0.15 400 $60.00 0.15 $400 $60.00 Ellis—note to file 10/26/18 Review of records and beginning of demand 1.20 400 $480.00 1.20 $400 $480.00 Telephone communication with Attorney Ellis, 10/29/18 0.20 400 $80.00 0.20 $400 $80.00 notes to file 10/29/18 Preparation of email to Attorney Ellis with case 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to Colleen Hartley re: 10/29/18 0.10 400 $40.00 0.10 $400 $40.00 demand, review of response Review of information and responsive email 10/30/18 0.20 400 $80.00 0.20 $400 $80.00 from Attorney Ellis with response Preparation of email to client re: demand and 11/06/18 0.15 400 $60.00 0.15 $400 $60.00 input Review of responsive email from Colleen 11/06/18 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response Preparation of email to Oletta Wright re: 11/07/18 0.10 400 $40.00 0 10 $400 $40.00 documentation Review of responsive email from Oletta Wright 11/08/18 and document, preparation of response with 0.10 400 $40.00 0.10 $400 $40.00 review of reply Preparation of email to Colleen Hartley with 11/08/18 0.10 400 $40.00 0.10 $400 $40.00 attachment 11/08/18 Preparation of email to client 0.10 400 $40.00 0.10 $400 $40.00 Review of email from client regarding status of 11/09/18 0.10 400 $40.00 0.10 $400 $40.00 case with response 11/15/18 Review of updated Medicaid lien 0.10 400 $40.00 0.10 $400 $40.00 11/15/18 Dictation/review of filing Exhibit 12/ECF 0.00 400 $0.00 0.00 $400 $0.00 Preparation of email to Colleen Hartley, 11/15/18 0.10 400 $40.00 0.10 $400 $40.00 preparation of response 11/16/18 Review of pleading, preparation of status report 0.20 400 $80.00 0.20 $400 $80.00 11/16/18 Dictation for filing SR, review of ECF 0.00 400 $0.00 0.00 $400 $0.00 11/16/18 Preparation of email to client for update 0.10 400 $40.00 0.10 $400 $40.00 11/19/18 Review of ECF and Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 Telephone call to KY attorney with 12/11/18 0.10 400 $40.00 0.10 $400 $40.00 questions—left message, note to file Review of email from Colleen Hartley re: 12/16/18 additional time to review demand with 0.10 400 $40.00 0.10 $400 $40.00 responsive email 12/17/18 Review of R’s status report/ECF 0.10 400 $40.00 0.10 $400 $40.00 12/17/18 Review of email from Colleen Hartley re: Ms. 0.10 400 $40.00 0.10 $400 $40.00 Review of Medicaid charges for communication 12/17/18 0.20 400 $80.00 0.20 $400 $80.00 with Medicaid 12/17/18 Preparation of responsive email to Colleen 0.10 400 $40.00 0.10 $400 $40.00 12/17/18 Preparation of email to P’s son and daughter re: 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Oletta Wright of KY 12/18/18 0.20 400 $80.00 0.20 $400 $80.00 Medicaid re: discrepancies in bill 12/18/18 Telephone communication with Jay Lawrence 0.25 400 $100.00 0.25 $400 $100.00 Review of responsive email from Oletta Wright 12/20/18 re: she will revise Medicaid lien, preparation of 0.10 400 $40.00 0.10 $400 $40.00 response Preparation of email to Colleen Hartley with 12/20/18 0.10 400 $40.00 0.10 $400 $40.00 update 1/02/19 Review of ECF and Order re: settlement update 0.10 400 $40.00 0.10 $400 $40.00 1/02/19 Communication with Jay Lawrence re: reason 0.30 400 $120.00 0.30 $400 $120.00 1/02/19 Review of demand for email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Colleen Hartley re: why 1/02/19 0.15 400 $60.00 0 15 $400 $60.00 case should settle Review of correspondence and Medicaid lien claim amount from KY Department of 1/02/19 0.30 400 $120.00 0.30 $400 $120.00 Medicaid, comparison with Colleen Hartley’s email and prior lien amount memorandum to 1/02/19 Dictation to assistant for filing Exhibit 0.00 400 $0.00 0.00 $400 $0.00 1/02/19 Review of email from Teresa Fields re: update 0.10 400 $40.00 0.10 $400 $40.00 1/03/19 Review of ECF 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Roberta Hurley with 1/31/19 0.10 400 $40.00 0.10 $400 $40.00 information needed 2/06/19 Review of ECF and R’s status report 0.10 400 $40.00 0.10 $400 $40.00 2/06/19 Dictation to assistant re: updated information 0.00 400 $0.00 0.00 $400 $0.00 2/06/19 Review Roberta Hurley’s response to 01/31/19 0.10 400 $40.00 0.10 $400 $40.00 2/07/19 Review of ECF and scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to client with updated 2/07/19 0.10 400 $40.00 0.10 $400 $40.00 information Review of responsive email from P’s daughter 2/11/19 re: recent decline and ER visit, etc., preparation 0.10 400 $40.00 0.10 $400 $40.00 of response 2/11/19 Dictation to assistant re: updated medical visits 0.00 400 $0.00 0.00 $400 $0.00 Review of email from Colleen Hartley with 3/05/19 0.10 400 $40.00 0.10 $400 $40.00 response 3/05/19 Preparation of email to client 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Colleen Hartley with 3/08/19 0.15 400 $60.00 0.15 $400 $60.00 attachments with response Review of LCP information from Colleen 3/08/19 0.40 400 $160.00 0.40 $400 $160.00 Hartley Preparation of email to Roberta Hurley with 3/08/19 0.15 400 $60.00 0.15 $400 $60.00 attachments from R 3/08/19 Preparation of correspondence to P with 0.60 400 $240.00 0.60 $400 $240.00 Review of responsive email from Colleen 3/08/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley 3/08/19 Review of ECF and R’s Status Report 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Jay Lawrence re: 3/11/19 settlement proposal and telephone conference, 0.15 400 $60.00 0.15 $400 $60.00 preparation of response, review of his response Preparation of email to Colleen Hartley with 3/13/19 0.10 400 $40.00 0.10 $400 $40.00 response Telephone communication with Colleen 3/13/19 0.20 400 $80.00 0.20 $400 $80.00 Hartley, follow up memorandum to file 3/13/19 Preparation of email to Roberta Hurley with 0.15 400 $60.00 0.15 $400 $60.00 Telephone call from Jay Lawrence re: changing 3/14/19 0.10 400 $40.00 c 0.00 $0 $0.00 time for call 3/14/19 Review of demand and LCP, review of 0.60 400 $240.00 0.60 $400 $240.00 3/14/19 Three way conference call with Mr. Lawrence’s s 0.75 400 $300.00 0.75 $400 $300.00 Preparation of email to Oletta Wright re: 3/14/19 0.10 400 $40.00 0.10 $400 $40.00 updated Medicaid lien amount Preparation of email to Colleen Hartley with 3/14/19 0.15 400 $60.00 0.15 $400 $60.00 questions from P Review of responsive email from Colleen 3/15/19 Hartley, preparation of response with review of 0.15 400 $60.00 0.15 $400 $60.00 response Review of responsive email from Oletta Wright 3/18/19 0.10 400 $40.00 0.10 $400 $40.00 re: Medicaid lien with response Preparation of email to Colleen Hartley re: 3/18/19 0.10 400 $40.00 0.10 $400 $40.00 same amount of lien Telephone communication with Colleen Hartley 3/18/19 re: additional information needed for case, 0.40 400 $160.00 0.40 $400 $160.00 follow up memorandum to file 3/18/19 Preparation of email to Jay Lawrence and 0.10 400 $40.00 0.10 $400 $40.00 3/19/19 Review of message from Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of responsive email from Jay Lawrence 3/19/19 0.10 400 $40.00 0.10 $400 $40.00 with response for call Preparation of notes for communication with 3/19/19 0.25 400 $100.00 0.25 $400 $100.00 Jay Lawrence Telephone communication with Jay Lawrence and Teresa Fields (twice) re: competency, 3/20/19 0.75 400 $300.00 0.75 * $400 $300.00 guardianship, monthly payments for LCP, etc., follow up memorandum to file 3/20/19 Preparation of email to Colleen Hartley re: 0.20 400 $80.00 0.20 $400 $80.00 3/20/19 Review of email from Jay Lawrence re: private 0.25 400 $100.00 0.25 * $400 $100.00 Review of responsive email from Colleen 3/20/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response Preparation of email to Jay Lawrence and 3/20/19 Teresa Fields re: guardianship procedure, 0.15 400 $60.00 0.15 $400 $60.00 review of response Review of email from Colleen Hartley with 4/01/19 0.10 400 $40.00 0.10 $400 $40.00 response Preparation of email to client re: counteroffer 4/01/19 0.15 400 $60.00 0.15 $400 $60.00 and progress with guardianship Review of responsive email from Jay Lawrence 4/02/19 re: will accept counteroffer and status of 0.15 400 $60.00 0.15 $400 $60.00 guardianship, preparation of response Preparation of email to Colleen Hartley re: 4/02/19 0.10 400 $40.00 0.10 $400 $40.00 acceptance and progress Review of responsive email from Colleen 4/02/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response 4/02/19 Review of email from Colleen Hartley re: 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence re: 4/02/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship Review of email from Teresa Fields re: 4/08/19 telephone conference preparation of response 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Jay Lawrence re: 4/08/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship attorney Preparation of email to Teresa re: telephone 4/08/19 0.10 400 $40.00 0.10 $400 $40.00 call Research guardianship proceeding in KY and 4/08/19 0.40 400 $160.00 0.40 $400 $160.00 guardianship attorneys Preparation of email to Colleen Hartley re: 4/08/19 0.10 400 $40.00 0.10 * $400 $40.00 guardianship v. power of attorney 4/08/19 Preparation of email to Colleen Hartley re: JSR 0.10 400 $40.00 0.10 $400 $40.00 Telephone call from Teresa Fields, follow up 4/08/19 1.30 400 $520.00 1.30 $400 $520.00 memorandum to file 4/08/19 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of responsive email from Colleen 4/09/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response 4/09/19 Review of order, preparation of status report 0.25 400 $100.00 0.25 $400 $100.00 4/09/19 Dictation to secretary 0.00 400 $0.00 0.00 $400 $0.00 Review of email from Colleen Hartley re: 4/09/19 0.10 400 $40.00 0.10 $400 $40.00 telephone communication with response Telephone call to Colleen Hartley—left 4/09/19 0.10 400 $40.00 x 0.00 $400 $0.00 message, note to file Telephone call to Attorney Meehan re: 4/09/19 guardianship proceeding, left message—note to 0.10 400 $40.00 0.10 $400 $40.00 file Telephone communication with Colleen Hartley 4/09/19 0.25 400 $100.00 0.25 $400 $100.00 with notes to file Review of email from Teresa Fields with 4/09/19 0.15 400 $60.00 0.15 $400 $60.00 response and request for Information Preparation of email to Roberta Hurley re: 4/09/19 0.15 400 $60.00 0.15 $400 $60.00 additional information needed Two telephone communications with Roberta 4/09/19 0.40 400 $160.00 0.40 $400 $160.00 Hurley, follow up memorandums to file Review of email from Teresa Fields with 4/10/19 0.10 400 $40.00 0.10 $400 $40.00 response Review of two emails from Roberta Hurley 4/10/19 0.10 400 $40.00 0.10 $400 $40.00 with response Review of email from Roberta Hurley to Linda 4/10/19 0.10 400 $40.00 0.10 $400 $40.00 Curtis Review of email from Teresa Fields re: 4/15/19 0.10 400 $40.00 0.10 $400 $40.00 alternate nursing with response Review of 2 emails from Colleen Hartley and 4/16/19 revised LCP with comparison to prior LCP and 0.30 400 $120.00 0.30 $400 $120.00 notes to file 4/16/19 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 4/16/19 Preparation of another email to Teresa Fields re: 0.20 400 $80.00 0.20 $400 $80.00 4/16/19 Review of responsive email to Colleen Hartley 0.15 400 $60.00 0.15 $400 $60.00 Telephone communication with Attorney 4/16/19 0.20 400 $80.00 0.20 $400 $80.00 Meehan, memo to file Preparation of email to Colleen Hartley, review 4/16/19 0.10 400 $40.00 0.10 $400 $40.00 of response Preparation of email to Colleen Hartley re: 4/19/19 0.10 400 $40.00 0.10 $400 $40.00 today’s call, review of response 4/19/19 Telephone communication with Colleen 0.15 400 $60.00 0.15 $400 $60.00 Telephone call to Gwen Meehan, Esquire—left 4/19/19 0.10 400 $40.00 x 0.00 $400 $0.00 message, note to file Preparation of email to Teresa Fields re: 4/19/19 0.10 400 $40.00 0.10 $400 $40.00 decision on nursing home placement 4/19/19 Dictation to secretary re: Meehan information 0.00 400 $0.00 0.00 $400 $0.00 Review of email from Teresa Fields re: her dad 4/20/19 0.10 400 $40.00 0.10 $400 $40.00 returning to Essex with response Review of email from Teresa Fields re: her 4/22/19 communication with Gwen Meehan, Esq., and 0.10 400 $40.00 0.10 $400 $40.00 response to my 04/19/19 inquiry with reply Preparation of email to Colleen Hartley with 4/22/19 0.10 400 $40.00 0.10 $400 $40.00 update on P Preparation of email to Attorney Meehan re: 4/22/19 invoice and time and process for the 0.15 400 $60.00 0.15 $400 $60.00 guardianship Review of responsive email from Colleen 4/22/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley with response 4/22/19 Preparation of email to Roberta Hurley re: 0.15 400 $60.00 0.15 $400 $60.00 Review of responsive email from Roberta 4/22/19 0.10 400 $40.00 0.10 $400 $40.00 Hurley with input to questions Preparation of email to law clerk with review 4/23/19 0.10 400 $40.00 0.10 $400 $40.00 of response Review of email from Teresa Fields re: 4/24/19 communication with guardianship attorney, 0.15 400 $60.00 0.15 $400 $60.00 review of response with reply 4/24/19 Telephone call to Attorney Meehan re: invoice 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to Roberta Hurley re: 4/24/19 0.10 400 $40.00 0.10 $400 $40.00 revisions to original LCP Preparation of email to Teresa Fields re: 4/24/19 0.10 400 $40.00 0.10 $400 $40.00 payment at Jefferson Preparation of email to Oletta Wright re: 4/24/19 0.10 400 $40.00 0.10 $400 $40.00 update for Medicaid lien Review of responsive email from Roberta 4/25/19 0.10 400 $40.00 0.10 $400 $40.00 Hurley with response Review of responsive email from Oletta Wright 4/25/19 0.10 400 $40.00 0.10 $400 $40.00 with response 4/25/19 Preparation of email to Colleen Hartley with 0.10 400 $40.00 0.10 $400 $40.00 4/25/19 Preparation of correspondence to Oletta Wright 0.40 400 $160.00 0.40 $400 $160.00 Review of responsive email from Oletta Wright 4/26/19 0.10 400 $40.00 0.10 $400 $40.00 and letter, preparation of response Preparation of email to Colleen Hartley with 4/26/19 0.10 400 $40.00 0.10 $400 $40.00 Medicaid letter 4/26/19 Preparation for Monday’s status conference 0.40 400 $160.00 0.40 $400 $160.00 Status conference with follow up memorandum 4/29/19 0.25 400 $100.00 0.25 $400 $100.00 to file 4/29/19 Preparation of email to client’s daughter re: 0.15 400 $60.00 0.15 $400 $60.00 4/29/19 Review of ECF 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Teresa Fields re: 4/30/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship progress, preparation of response 4/30/19 Dictation to secretary re: transcript 0.00 400 $0.00 0.00 $400 $0.00 5/01/19 Review of ECF and Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Teresa Fields and 5/14/19 0.10 400 $40.00 0.10 $400 $40.00 attorney re: guardianship proceeding 5/20/19 Review of 2 ECF’s re: Transcript 0.10 400 $40.00 0.10 $400 $40.00 5/21/19 Review of transcript 0.10 400 $40.00 0.10 $400 $40.00 5/21/19 Review of email from Roberta Hurley re: status 0.15 400 $60.00 0.15 $400 $60.00 Telephone call to Gwen Meehan re: status of 5/21/19 guardianship— spoke with assistant and left 0.10 400 $40.00 x 0.00 $400 $0.00 message, note to file Preparation of email to Gwen Meehan re: 5/21/19 0.10 400 $40.00 0.10 $400 $40.00 status of guardianship Preparation of email to Teresa Fields re: 5/21/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship Review of responsive email from Teresa Fields re: contacting her brother at the court re: status 5/22/19 0.10 400 $40.00 0.10 $400 $40.00 of guardianship, preparation of Response (lack of cooperation from Attorney Meehan) Preparation of email to Colleen Hartley with 5/22/19 0.10 400 $40.00 0.10 $400 $40.00 status Review of responsive email from Teresa Fields 5/22/19 0.10 400 $40.00 0.10 $400 $40.00 re: remaining procedure for guardianship 6/25/19 Review file for status 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to Teresa Fields re: 6/25/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship Telephone call to Attorney Meehan—left 6/25/19 0.10 400 $40.00 x 0.00 $400 $0.00 message, note to file 6/25/19 Telephone communication with Attorney 0.25 400 $100.00 * 0.25 $400 $100.00 Preparation of email to Colleen Hartley re: 6/25/19 0.10 400 $40.00 0.10 $400 $40.00 guardianship Preparation of email with attachment to Gwen 6/27/19 Meehan explaining what is required for 0.20 400 $80.00 0.20 $400 $80.00 guardianship proceeding 6/27/19 Telephone call from Teresa Fields to discuss 0.40 400 $160.00 0.40 $400 $160.00 Preparation of email to Gwen Meehan to follow 7/01/19 0.10 400 $40.00 0.10 $400 $40.00 up on what I sent last week Preparation of email to Teresa Fields with 7/01/19 0.15 400 $60.00 0.15 $400 $60.00 information for the court Two more attempts to reach Attorney Meehan 7/09/19 0.10 400 $40.00 x 0.00 $400 $0.00 re: guardianship 7/09/19 Preparation of email to Teresa Fields re: can 0.10 400 $40.00 0.10 $400 $40.00 7/09/19 Preparation of email to Attorney Meehan re: 0.15 400 $60.00 0.15 $400 $60.00 Review of past attempts to contact Attorney 7/16/19 0.15 400 $60.00 0.15 $400 $60.00 Meehan Preparation of correspondence to Attorney 7/16/19 1.00 400 $400.00 1.00 $400 $400.00 Meehan—sent certified Preparation of email to Colleen Hartley re: 7/22/19 attempts to find out information on 0.10 400 $40.00 0.10 $400 $40.00 guardianship proceeding Preparation of email to P with copy of 7/22/19 0.10 400 $40.00 0.10 $400 $40.00 correspondence to Gwen Meehan 7/23/19 Review of ECF 0.10 400 $40.00 0.10 $400 $40.00 Review of file and recent notes and emails for 8/01/19 0.20 400 $80.00 0.20 $400 $80.00 email to Colleen Hartley 8/01/19 Preparation of email to Colleen Hartley re: 0.10 400 $40.00 0.10 * $400 $40.00 Communication with secretary re: track the 8/01/19 certified number, review of print out of tracking 0.00 400 $0.00 0.00 $400 $0.00 status Preparation of email to Colleen Hartley with 8/01/19 0.10 400 $40.00 0.10 $400 $40.00 update of letter Preparation of email to Teresa Fields re: no 8/01/19 0.15 400 $60.00 0.15 * $400 $60.00 word from Attorney Meehan and my concerns Review of telephone message from Colleen 8/02/19 Hartley with return call—left message, note to 0.10 400 $40.00 x 0.00 $400 $0.00 file Telephone call with Colleen Hartley, memo to 8/05/19 0.25 400 $100.00 0.25 $400 $100.00 file Preparation of email to Attorney Meehan, Jay 8/05/19 0.15 400 $60.00 0.15 $400 $60.00 Lawrence and Teresa Fields Telephone communication with Attorney 8/05/19 0.25 400 $100.00 0.25 $400 $100.00 Meehan 8/05/19 Memorandum to file 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with Teresa Fields, 8/05/19 0.35 400 $140.00 0.35 $400 $140.00 notes to file 8/05/19 Preparation of email to Jay Lawrence 0.10 400 $40.00 0.10 $400 $40.00 8/06/19 Review of responsive email from Jay Lawrence 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with Colleen Hartley 8/06/19 0.15 400 $60.00 0.15 $400 $60.00 with note to file Directive to secretary re: nursing home for 8/06/19 0.00 400 $0.00 0.00 $400 $0.00 updated records To post office to pick up unaccepted letter of 8/07/19 0.00 400 $0.00 0.00 $400 $0.00 Attorney Meehan Preparation of email to Attorney Meehan re: 8/07/19 0.15 400 $60.00 0.15 $400 $60.00 follow up needed Preparation of email to Teresa Fields re: 8/07/19 0.10 400 $40.00 0.10 $400 $40.00 ongoing efforts 8/08/19 Review of order, preparation of status report 0.35 400 $140.00 0.35 $400 $140.00 8/08/19 Directive to secretary for filing/review of ECF 0.00 400 $0.00 0.00 $400 $0.00 Review of August 9th email from the court and 8/12/19 0.10 400 $40.00 0.10 $400 $40.00 R’s response 8/12/19 Preparation of email to Attorney Meehan 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Teresa Fields and Jay 8/12/19 0.10 400 $40.00 0.10 $400 $40.00 Lawrence Preparation of response to the court, review of 8/12/19 0.10 400 $40.00 0.10 $400 $40.00 reply Review of responsive email from Attorney 8/12/19 0.10 400 $40.00 0.10 $400 $40.00 Meehan with reply Preparation of email to Attorney Meehan re: 8/13/19 0.10 400 $40.00 0.10 $400 $40.00 urgency for phone call Review of responsive email from Teresa Fields 8/15/19 with county attorney contact information, 0.15 400 $60.00 0.15 $400 $60.00 preparation of response 8/19/19 Review of ECF 0.10 400 $40.00 0.10 $400 $40.00 Dictation/review of Notice of Change of 8/20/19 0.00 400 $0.00 0.00 $400 $0.00 Address/ECF Telephone communication with Louisville 08/27/19 County attorney’s office 0.15 400 $60.00 v 0.15 no $400 $60.00 re: communication with Mike O’ Connell, Esquire, follow up memorandum to file 08/27/19 Review of pertinent sections of the Vaccine 0.50 400 $200.00 0.50 $400 $200.00 statute for correspondence to Mike O’Connell 08/27/19 Preparation of certified letter to Mike 1.25 400 $500.00 1.25 $400 $500.00 O’Connell re: delay in guardianship proceeding 08/27/19 Preparation of email to Mike O’Connell with 0.15 400 $60.00 0.15 $400 $60.00 attached letter 08/27/19 Preparation of email to Colleen Hartley with 0.10 400 $40.00 0.10 $400 $40.00 08/27/19 update To post office for mailing certified letter 0.00 400 $0.00 0.00 $400 $0.00 08/27/19 Preparation of email to Attorney Meehan and 0.20 400 $80.00 0.20 $400 $80.00 Teresa Fields with letter and input 08/27/19 Review of telephone message from Gwen 0.10 400 $40.00 0.10 $400 $40.00 Meehan Preparation of email to Colleen Hartley, review 8/29/19 0.10 400 $40.00 0.10 $400 $40.00 of response Preparation of email to the court with review of 8/29/19 0.10 400 $40.00 0.10 $400 $40.00 response 8/29/19 Preparation of correspondence to Attorney 0.50 400 $200.00 0.50 $400 $200.00 8/29/19 Telephone call from Attorney Meehan to 0.35 400 $140.00 0.35 $400 $140.00 Preparation of email to Attorney Meehan for 8/29/19 0.10 400 $40.00 0.10 $400 $40.00 contact information 8/30/19 Preparation of responsive email to the court 0.10 400 $40.00 0.10 $400 $40.00 Review of email from Attorney Meehan with 8/30/19 0.15 400 $60.00 0.15 $400 $60.00 reply 8/30/19 Preparation of email to the court 0.10 400 $40.00 0.10 $400 $40.00 9/04/19 Preparation of email to Attorney Meehan 0.10 400 $40.00 0.10 $400 $40.00 9/04/19 Telephone call from Attorney Meehan re: court 0.25 400 $100.00 0.25 $400 $100.00 Review of email from Attorney Meehan with 9/04/19 0.10 400 $40.00 0.10 $400 $40.00 reply 9/04/19 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 Review of another email from Attorney Meehan 9/04/19 0.10 400 $40.00 0.10 $400 $40.00 with reply Preparation of email to Attorney Meehan re: 9/05/19 0.10 400 $40.00 0.10 $400 $40.00 adding attorney to conference call Preparation of email to Teresa Fields with 9/05/19 0.10 400 $40.00 0.10 $400 $40.00 update re: SC Review of correspondence from Carl Ishmael, 9/06/19 director of Medicaid services, memorandum re: 0.10 400 $40.00 0.10 $400 $40.00 lien and contact information 9/06/19 Review of recent notes to file and emails for SC 0.40 400 $160.00 0.40 $400 $160.00 9/06/19 Status conference with follow up memorandum 0.50 400 $200.00 0.50 $400 $200.00 9/06/19 Preparation of email to Gwen Meehan 0.10 400 $40.00 0.10 $400 $40.00 9/06/19 Preparation of correspondence to Oletta Wright 0.50 400 $200.00 0.50 $400 $200.00 Preparation of email to Teresa Fields re: 9/06/19 0.15 400 $60.00 0.15 $400 $60.00 conference call Telephone call from Colleen Hartley, follow up 9/06/19 0.20 400 $80.00 0.20 $400 $80.00 note to file 9/09/19 Review of ECF and Scheduling Order 0.10 400 $40.00 0.10 $400 $40.00 9/09/19 Preparation of email to Attorney Meehan with 0.15 400 $60.00 0.15 $400 $60.00 Review of responsive email from Oletta Wright 9/10/19 0.10 400 $40.00 0.10 $400 $40.00 with reply Review of another email from Oletta Wright with Medicaid total, preparation of response 9/10/19 0.15 400 $60.00 0.15 $400 $60.00 with request for November 6 letter, review of her response with reply Review of email from the county attorney with 9/16/19 0.10 400 $40.00 0.10 $400 $40.00 response Review of voice message from Jay Lawrence, 9/19/19 0.10 400 $40.00 0.10 $400 $40.00 call to Jay, note to file Preparation of email to Jay Lawrence re: 9/19/19 0.10 400 $40.00 0.10 $400 $40.00 attempts to reach him and update Telephone communication with Jay Lawrence 9/19/19 re: update on P’s dire condition, questions re: 0.60 400 $240.00 0.60 $400 $240.00 settlement, Medicaid lien, etc. with follow up 9/19/19 Preparation of email to Teresa Fields 0.10 400 $40.00 0.10 $400 $40.00 Telephone call from Teresa Fields re: her dad’s condition, settling the case, delayed time frame, 9/24/19 0.75 400 $300.00 0.75 $400 $300.00 lawsuit the family intends to pursue against the KY attorneys, follow up memorandum to file 9/24/19 Preparation of email to Colleen Hartley 0.10 400 $40.00 0.10 $400 $40.00 9/24/19 Telephone communication with Colleen Hartley 0.25 400 $100.00 0.25 $400 $100.00 9/24/19 Telephone communication with Teresa Fields 0.30 400 $120.00 0.30 $400 $120.00 Preparation of memorandum to file re: both 9/24/19 0.20 400 $80.00 0.20 $400 $80.00 calls Preparation of email to Colleen Hartley to 9/25/19 advise of P’s passing and to discuss procedure 0.10 400 $40.00 0.10 $400 $40.00 from here 9/25/19 Telephone call from Colleen Hartley to discuss 0.30 400 $120.00 0.30 $400 $120.00 Review of email from Colleen Hartley with 9/26/19 0.10 400 $40.00 0.10 $400 $40.00 response Preparation of email to counsel re: proper 9/26/19 procedure with death case facts and notification 0.15 400 $60.00 0.15 $400 $60.00 to the court Telephone call from Claudia Smith, head of guardianship division in Louisville, KY, follow 9/26/19 up memorandum to file re: Attorney Meehan 0.30 400 $120.00 0.30 $400 $120.00 never filed paperwork until 08/28/19 (I contacted Meehan on April 9, 2019.)
Preparation of email to the family re: 9/26/19 guardianship proceeding directive for canceling 0.15 400 $60.00 0.15 $400 $60.00 procedure 9/26/19 Review of all attempted contacts and calls to 0.20 400 $80.00 0.20 $400 $80.00 Preparation of email to Roberta Hurley re: 9/26/19 0.10 400 $40.00 0.10 $400 $40.00 passing of P and LCP Preparation of email to Attorney Meehan re: my initial contact with her in April, attempts to reach her, delay in filing petition in a 9/26/19 accordance with communication with Ms. 0.25 400 $100.00 0.25 $400 $100.00 Smith, the fact that the guardianship could have been completed in 7 days on emergency basis, etc. Preparation of 2nd email to Roberta Hurley 9/26/19 0.10 400 $40.00 0.10 $400 $40.00 with additional information 9/26/19 Preparation of status report 0.20 400 $80.00 0.20 $400 $80.00 9/26/19 Directive for filing/review of ECF 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with counsel re: case 9/26/19 0.50 400 $200.00 0.50 $400 $200.00 with memorandum to file Review of email from Colleen Hartley with 9/26/19 0.10 400 $40.00 0.10 $400 $40.00 reply 9/27/19 Review of 2 ECFs and Notice 0.10 400 $40.00 0.10 $400 $40.00 9/27/19 Review of transcript (15 pp.), notes to file 0.35 400 $140.00 0.35 $400 $140.00 Preparation of email to Teresa Fields based on 9/30/19 0.15 400 $60.00 0.15 $400 $60.00 advice of counsel 9/30/19 Review of ECF and scheduling order 0.10 400 $40.00 0.10 $400 $40.00 Telephone communication with Teresa Fields, 9/30/19 0.50 400 $200.00 0.50 $400 $200.00 follow up memorandum to file 9/30/19 Preparation of email to Oletta Wright 0.10 400 $40.00 0.10 $400 $40.00 Telephone call from Teresa Fields to discuss 10/04/19 death certificate, ongoing procedure, etc., 0.50 400 $200.00 0.50 $400 $200.00 follow up memorandum to file 10/08/19 Review of response from Oletta Wright 0.10 400 $40.00 0.10 $400 $40.00 10/08/19 Review of 2nd email from Oletta Wright with 0.10 400 $40.00 0.10 $400 $40.00 Review of text from Teresa Fields re: death 10/15/19 0.15 400 $60.00 0.15 $400 $60.00 certificate with response 10/15/19 Review of mailed Medicaid lien 0.10 400 $40.00 0.10 $400 $40.00 Preparation of email to Colleen Hartley with 10/15/19 0.10 400 $40.00 0.10 $400 $40.00 attachment and question Review of responsive email from Colleen 10/15/19 0.10 400 $40.00 0.10 $400 $40.00 Hartley with reply Preparation of email to Oletta Wright re: 10/15/19 0.10 400 $40.00 0.10 $400 $40.00 itemization of Medicaid lien Preparation of email to Teresa Fields re: 10/15/19 0.15 400 $60.00 0.15 $400 $60.00 Colleen Hartley’s questions Review of responsive email from Teresa Fields 10/16/19 0.10 400 $40.00 0.10 $400 $40.00 with response 10/16/19 Preparation of another email to Teresa Fields re: 0.15 400 $60.00 0.15 $400 $60.00 Review of email from Oletta Wright re: 10/21/19 0.10 400 $40.00 0.10 $400 $40.00 Medicaid lien with response \ 10/21/19 Review of information mailed by Teresa Fields 0.10 400 $40.00 0.10 $400 $40.00 10/21/19 Preparation of email to Teresa Fields re: 0.15 400 $60.00 0.15 $400 $60.00 Preparation of email to client regarding new 10/22/19 0.10 400 $40.00 0.10 $400 $40.00 information Dictation/review of Notice of Change of Phone 10/22/19 0.00 400 $0.00 0.00 $400 $0.00 Number/ECF 10/28/19 Review of Medicaid itemization 0.30 400 $120.00 0.30 $400 $120.00 10/29/19 Review of Exhibit for filing/ECF 0.10 400 $40.00 c 0.00 $0 $0.00 Review of email from Roberta Hurley re: her 10/31/19 0.10 400 $40.00 0.10 $400 $40.00 bill, preparation of reply Review of death benefit cases for settlement 11/05/19 1.20 400 $480.00 1.20 $400 $480.00 negotiations, memorandum to file Preparation of email to Teresa Fields re: status 11/05/19 0.10 400 $40.00 0.10 $400 $40.00 of appointment Review of pleadings, preparation of status 11/05/19 0.40 400 $160.00 0.40 $400 $160.00 report, review of ECF Telephone call from Teresa Fields to discuss 11/06/19 0.50 400 $200.00 0.50 $400 $200.00 proceeding memo to file Review of email from Teresa with date for 11/14/19 0.10 400 $40.00 0.10 $400 $40.00 paperwork with reply Communication with counsel re: pain and 11/14/19 0.25 400 $100.00 0.25 $400 $100.00 suffering and death benefits 11/15/19 Preparation of email to Teresa Fields re: letter 0.25 400 $100.00 0.25 $400 $100.00 11/18/19 Telephone call to Teresa Fields for status of 0.25 400 $100.00 0.25 $400 $100.00 11/18/19 Review of messages for 2 missed calls from 0.10 400 $40.00 0.10 $400 $40.00 Text message to Teresa Fields re: my 11/18/19 0.10 400 $40.00 0.10 $400 $40.00 availability Review of recent emails and notes to file for 11/18/19 0.20 400 $80.00 0.20 $400 $80.00 status conference Communication with the court re: Status 11/18/19 0.10 400 $40.00 0.10 $400 $40.00 conference cancellation note to file Telephone call from Teresa Fields to discuss his hospitalizations, August evaluation from the 11/18/19 0.60 400 $240.00 0.60 $400 $240.00 nursing home, etc. with follow up memorandum to file Review of emails with the court, respondent 11/18/19 and my response, review of ECF with 0.10 400 $40.00 0.10 $400 $40.00 rescheduled status conference Review of text from Teresa Fields re: his past 11/18/19 0.10 400 $40.00 0.10 $400 $40.00 years treaters with response Preparation of email to client with date for 11/18/19 status conference and time- for information 0.10 400 $40.00 0.10 $400 $40.00 requested Preparation of email to Teresa Fields with 11/18/19 0.15 400 $60.00 0.15 $400 $60.00 update of status conference 11/19/19 Status conference with follow up memorandum 0.20 400 $80.00 0.20 $400 $80.00 11/20/19 Review of 2 orders and ECFs 0.10 400 $40.00 0.10 $400 $40.00 12/10/19 Review of invoice from transcript and transcript 0.15 400 $60.00 0.15 $400 $60.00 12/11/19 Review of two (2) ECF’s 0.10 400 $40.00 0.10 $400 $40.00 131.90 HOURS @ $400.00 PER HOUR = $52,760.00 Telephone call from Christine Dennis of Essex 01/02/20 Rehab to discuss number of records, cost of 0.20 424 $84.80 0.20 $424 $84.80 over $2,600, etc., note to file 01/02/20 Preparation of email to Colleen Hartley 0.10 424 $42.40 0.10 $424 $42.40 Telephone communication with Colleen Hartley 01/02/20 0.15 424 $63.60 0.15 $424 $63.60 with follow up memorandum to file Review of death certificate and other pertinent 01/02/20 0.20 424 $84.80 0.20 $424 $84.80 information in file Telephone call to Christine Dennis in records at 01/02/20 Essex for revision to request for records based 0.15 424 $63.60 p 0.15 $152 $22.80 on communication with Colleen Hartley Preparation of email to Colleen Hartley re: 01/02/20 0.10 424 $42.40 0.10 $424 $42.40 status of records Preparation of email to Teresa Fields with 01/02/20 update re: delay, review of her response with 0.15 424 $63.60 0.15 $424 $63.60 reply 3rd telephone communication with Christine 01/02/20 0.15 424 $63.60 p 0.15 $152 $22.80 Dennis re: records Preparation of correspondence to Essex with 01/02/20 0.25 424 $106.00 p 0.25 $152 $38.00 revised records’ request and check Telephone call from Teresa Fields to discuss 1/07/20 Dr. Thomas willingness to write a letter with 0.25 424 $106.00 0.25 * $424 $106.00 memorandum to file 1/07/20 Review of text from Teresa Fields re: contact 0.10 424 $42.40 0.10 $424 $42.40 1/07/20 Preparation of email to Dr. Thomas 0.20 424 $84.80 0.20 $424 $84.80 Review of correspondence re: improper release 1/13/20 0.10 424 $42.40 0.10 $424 $42.40 information Preparation of email to Teresa Fields with 1/13/20 0.10 424 $42.40 0.10 $424 $42.40 explanation and form Two texts from Teresa Fields re: release and 1/15/20 0.15 424 $63.60 0.15 $424 $63.60 letter from Dr. Thomas with two responses 1/15/20 Telephone call from Teresa Fields to discuss 0.30 424 $127.20 0.30 $424 $127.20 Review of Jefferson Rehabilitation records (166 1/15/20 1.30 424 $551.20 r 1.30 $200 $260.00 pp.) with notes to file Review of fax from client, review of 1/16/20 0.10 424 $42.40 0.10 $424 $42.40 correspondence to Norton Review of text from Teresa Fields with 1/20/20 0.10 424 $42.40 0.10 $424 $42.40 response and review of her reply 1/20/20 Telephone call from Teresa Fields re: 0.30 424 $127.20 0.30 $424 $127.20 1/21/20 Review of correspondence from Dr. Thomas 0.10 424 $42.40 0.10 $424 $42.40 1/21/20 Review of ECF/Exhibit filed 0.10 424 $42.40 0.10 $424 $42.40 Preparation of email to Colleen Hartley, review 1/22/20 0.10 424 $42.40 0.10 $424 $42.40 of response Review of records from Essex Nursing & 1/23/20 2.20 424 $932.80 r 2.20 $200 $440.00 Rehab (339 pp.) with notes to file 01/24/20 Review of text from Teresa Fields with reply 0.10 424 $42.40 0.10 $424 $42.40 Preparation of email to Colleen Hartley with 1/28/20 0.10 424 $42.40 0.10 $424 $42.40 question re: demand Preparation of email to Teresa Fields re: 2/06/20 0.10 424 $42.40 0.10 $424 $42.40 current status Review of responsive email from Teresa Fields 2/07/20 0.10 424 $42.40 0.10 $424 $42.40 with reply Review of records from Norton Hospital (Pp. 1- 2/10/20 2.35 424 $996.40 r 2.35 $200 $470.00 402) with notes to file Continued review of records from Norton’s 2/11/20 2.50 424 $1,060.00 r 2.50 $200 $500.00 Hospital (Pp. 403-821) with notes to file 2/11/20 Review of Ex. 20 prior to filing/review of ECF 0.10 424 $42.40 0.10 $424 $42.40 2/11/20 Preparation of text to Teresa Fields re: 0.10 424 $42.40 0.10 $424 $42.40 2/11/20 Preparation of email to Teresa Fields 0.10 424 $42.40 0.10 * $424 $42.40 Review of recent order, preparation of Status 2/11/20 0.25 424 $106.00 0.25 $424 $106.00 Report for filing Telephone call from Teresa Fields re: 2/11/20 0.40 424 $169.60 0.40 $424 $169.60 settlement with memorandum to file 2/12/20 Review of ECF and Scheduling Order 0.10 424 $42.40 0.10 $424 $42.40 Review of medical exhibits and notes from 2/12/20 2.00 424 $848.00 2.00 $424 $848.00 prior reviews for demand 2/12/20 Preparation of demand 1.50 424 $636.00 1.50 $424 $636.00 Preparation of email to Colleen Hartley with 2/12/20 0.10 424 $42.40 0.10 $424 $42.40 attachment 2/12/20 Preparation of status report/review of ECF 0.25 424 $106.00 0.25 $424 $106.00 Review of email with counteroffer from 3/04/20 0.10 424 $42.40 0.10 $424 $42.40 Colleen Hartley Preparation of text to Teresa Fields with review 3/04/20 0.10 424 $42.40 0.10 $424 $42.40 of her response 3/04/20 Review of demand and records substantiating a 0.40 424 $169.60 0.40 $424 $169.60 3/04/20 Telephone call from client to discuss 0.75 424 $318.00 0.75 $424 $318.00 Telephone call to Colleen Hartley—left 3/04/20 0.10 424 $42.40 x 0.00 $424 $0.00 message, note to file 3/04/20 Telephone communication with Colleen Hartley 0.50 424 $212.00 0.50 $424 $212.00 3/04/20 Follow up memorandum to file 0.20 424 $84.80 0.20 $424 $84.80 3/04/20 Three more texts with Teresa Fields 0.15 424 $63.60 0.15 $424 $63.60 3/04/20 Review of ECF and Status Report 0.10 424 $42.40 0.10 $424 $42.40 3/05/20 Review of Exs. 19 and 8 for R’s concerns 0.60 424 $254.40 0.60 $424 $254.40 Review of flu/GBS/death cases for revised 3/05/20 1.50 424 $636.00 1.50 $424 $636.00 demand 3/05/20 Telephone communication with Teresa Fields 0.50 424 $212.00 0.50 $424 $212.00 3/12/20 Review of records for revised demand 1.00 424 $424.00 1.00 $424 $424.00 Preparation of correspondence to Dr. Cardinali 3/12/20 0.75 424 $318.00 0.75 $424 $318.00 with enclosures Preparation of 2 texts to Teresa Fields for 3/12/20 0.15 424 $63.60 0.15 * $424 $63.60 authorizations, review of one reply 3/12/20 Preparation of email to client with attachments 0.20 424 $84.80 0.20 $424 $84.80 Telephone call from Teresa Fields with note to 3/12/20 0.15 424 $63.60 0.15 $424 $63.60 file 3/12/20 Revision to letter as per client 0.10 424 $42.40 0.10 $424 $42.40 Review of email from client for update, 3/20/20 0.15 424 $63.60 0.15 $424 $63.60 preparation of response, review of her response Review of 4 cases for pain and suffering in 3/30/20 1.00 424 $424.00 1.00 $424 $424.00 preparation for revised demand Review of Medicaid lien for diagnoses and 3/31/20 review of notes from recent hospital records’ 1.00 424 $424.00 1.00 $424 $424.00 review for demand 3/31/20 Preparation of demand 0.75 424 $318.00 0.75 $424 $318.00 Preparation of email to Colleen Hartley with 3/31/20 0.10 424 $42.40 0.10 $424 $42.40 revised demand Preparation of email to Teresa Fields with 3/31/20 0.10 424 $42.40 0.10 $424 $42.40 revised demand Telephone communication with Colleen Hartley 3/31/20 0.40 424 $169.60 0.40 $424 $169.60 with follow up memorandum to file Review of 2 text messages from Teresa Fields 4/07/20 0.20 424 $84.80 0.20 $424 $84.80 with 2 responses Review of Norton records and notes from prior 4/08/20 2.30 424 $975.20 2.30 $424 $975.20 review for correspondence to Dr. Turner Preparation of explanatory request to Dr. Turner with enclosures sent via certified and regular 4/09/20 1.75 424 $742.00 x 1.00 $424 $424.00 mail Preparation of email with attachment and text to 4/09/20 0.15 424 $63.60 0.15 $424 $63.60 Teresa Fields Review of email from the court with directions 4/13/20 0.10 424 $42.40 0.10 $424 $42.40 for call and prompts, preparation of response 4/13/20 Preparation of email to client with questions for 0.25 424 $106.00 0.25 $424 $106.00 Status conference (on hold for 5 minutes before 4/13/20 0.15 424 $63.60 0.15 $424 $63.60 SC) Follow up memorandum to file re: future steps 4/13/20 0.20 424 $84.80 0.20 $424 $84.80 and time frame 4/14/20 Review of ECF 0.10 424 $42.40 0.10 $424 $42.40 4/14/20 Preparation of email to Teresa Fields with 0.15 424 $63.60 0.15 $424 $63.60 4/15/20 Review of 04/14 ECF and Scheduling Order 0.10 424 $42.40 0.10 $424 $42.40 Review of responsive email from Teresa Fields 4/15/20 0.10 424 $42.40 0.10 $424 $42.40 with questions Review of file for answer to P’s questions with 4/15/20 0.25 424 $106.00 0.25 $424 $106.00 notations Preparation of responsive email to client with 4/15/20 0.15 424 $63.60 0.15 $424 $63.60 contact information Telephone call to Dr. Cardinali—left message, 4/15/20 0.10 424 $42.40 0.10 $424 $42.40 note to file 4/15/20 Preparation of follow up email to Teresa Fields 0.15 424 $63.60 0.15 $424 $63.60 4/15/20 Telephone call from client to discuss settlement 0.75 424 $318.00 0.75 $424 $318.00 Preparation of email to Colleen Hartley re: 4/15/20 0.15 424 $63.60 0.15 $424 $63.60 expert or mediation 4/15/20 Telephone call from Colleen Hartley to discuss 0.20 424 $84.80 0.20 $424 $84.80 4/15/20 Preparation of text to Teresa Fields 0.10 424 $42.40 0.10 $424 $42.40 Review of email from Colleen Hartley with 4/15/20 0.10 424 $42.40 0.10 $424 $42.40 reply Review of correspondence signed by Dr. 4/16/20 0.10 424 $42.40 0.10 $424 $42.40 Thomas Review of fax from Dr. Cardinali with amended 4/16/20 0.10 424 $42.40 0.10 $424 $42.40 death certificate 4/16/20 Preparation of text to Teresa Fields re: 0.15 424 $63.60 0.15 $424 $63.60 Directive to settlement for filing exhibit/review 4/16/20 0.00 424 $0.00 0.00 $424 $0.00 of ECF 4/16/20 Communication with Teresa Fields, notes to file 0.35 424 $148.40 0.35 $424 $148.40 4/16/20 Preparation of revised demand, preparation of 0.60 424 $254.40 0.60 $424 $254.40 4/16/20 2nd Telephone call from Teresa Fields re: who 0.20 424 $84.80 0.20 $424 $84.80 4/16/20 Telephone call from Colleen Hartley 0.25 424 $106.00 0.25 $424 $106.00 4/16/20 Follow up memorandum to file 0.10 424 $42.40 0.10 $424 $42.40 4/16/20 Preparation of email to client re: telephone call 0.10 424 $42.40 0.10 $424 $42.40 04/21/20 Review of text from Teresa Fields with reply 0.10 424 $42.40 0.10 $424 $42.40 Telephone call from Teresa Fields re: 04/21/20 amendment to death cert, etc., memorandum to 0.35 424 $148.40 0.35 $424 $148.40 file Review of email from Colleen Hartley with 4/24/20 0.10 424 $42.40 0.10 $424 $42.40 response and review of her response 4/24/20 Text to client with review of return text 0.10 424 $42.40 0.10 $424 $42.40 Communication with client re: offer with 4/24/20 0.40 424 $169.60 0.40 $424 $169.60 memorandum to file 4/24/20 Preparation of another email to Colleen Hartley 0.10 424 $42.40 0.10 $424 $42.40 Review of email with response to Colleen 4/27/20 0.10 424 $42.40 0.10 $424 $42.40 Hartley 4/27/20 Review of 2 prior demands sent to R 0.10 424 $42.40 0.10 $424 $42.40 4/27/20 Review of telephone message from Colleen 0.15 424 $63.60 0.15 $424 $63.60 Review of 2 additional emails from Colleen 4/27/20 0.10 424 $42.40 0.10 $424 $42.40 Hartley 4/27/20 Preparation of text to client 0.10 424 $42.40 0.10 $424 $42.40 4/27/20 Telephone communication with Teresa Fields, 0.25 424 $106.00 0.25 $424 $106.00 4/27/20 Preparation of correspondence to Oletta Wright, 0.50 424 $212.00 0.50 $424 $212.00 4/27/20 Review of email from Teresa Fields confirming 0.10 424 $42.40 0.10 $424 $42.40 Preparation of email to Colleen Hartley re: 4/27/20 0.10 424 $42.40 0.10 $424 $42.40 settlement reached 4/27/20 Review of prior petition and pertinent records 0.60 424 $254.40 0.60 $424 $254.40 Preparation of Amended Petition with directive 4/28/20 0.75 424 $318.00 0.75 $424 $318.00 for filing 4/28/20 Review of ECF 0.10 424 $42.40 0.10 $424 $42.40 4/28/20 Preparation of email to Colleen Hartley 0.10 424 $42.40 0.10 $424 $42.40 Review of responsive email from Colleen 4/28/20 0.10 424 $42.40 0.10 $424 $42.40 Hartley with reply Telephone call to Oletta Wright of KY 4/29/20 0.10 424 $42.40 0.10 $424 $42.40 Medicaid—left message, note to file Review of responsive email from Oletta Wright 5/01/20 requesting information, review of notes in file, 0.20 424 $84.80 0.20 $424 $84.80 preparation of response with attachments Preparation of email to Oletta Wright re: 5/04/20 0.10 424 $42.40 0.10 $424 $42.40 confirmation of email 5/05/20 Review of responsive email from Oletta Wright 0.10 424 $42.40 0.10 $424 $42.40 5/05/20 Review of exhibit for filing 0.10 424 $42.40 0.10 $424 $42.40 Review of email from Colleen Hartley with 5/05/20 0.10 424 $42.40 0.10 $424 $42.40 response Preparation of text to Teresa Fields with review 5/05/20 0.10 424 $42.40 0.10 $424 $42.40 of response Review of email from Colleen Hartley to the 5/05/20 0.10 424 $42.40 0.10 $424 $42.40 court re: 15 week order 5/05/20 Review of text from Teresa Fields with request 0.15 424 $63.60 0.15 $424 $63.60 Review of exhibit as requested by R with notes 5/05/20 0.50 424 $212.00 0.50 $424 $212.00 from review Preparation of correspondence to counsel with 5/07/20 0.60 424 $254.40 0.60 $424 $254.40 exhibit on disc as requested by counsel Review of death certificate and transfer to 5/11/20 0.10 424 $42.40 0.10 $424 $42.40 secretary with instructions for filing Preparation of text to Teresa Fields with review 5/11/20 0.10 424 $42.40 0.10 $424 $42.40 of reply Review of 2 ECF’s - Exhibit and Exhibit List 5/12/20 0.10 424 $42.40 0.10 $424 $42.40 filed 7/02/20 Review of email from Roberta Hurley 0.10 424 $42.40 0.10 $424 $42.40 Telephone call with Roberta Hurley regarding 7/02/20 0.15 424 $63.60 0.15 $424 $63.60 invoice Review of email from Colleen Hartley with 8/11/20 0.10 424 $42.40 0.10 $424 $42.40 response Review of Stipulation and cross reference with 8/11/20 0.15 424 $63.60 0.15 $424 $63.60 notes Preparation of text and email to client with 8/12/20 attachment, review of response with reply to 0.15 424 $63.60 0.15 $424 $63.60 text 8/19/20 Review of ECF and filed Stipulation 0.10 424 $42.40 0.10 $424 $42.40 8/19/20 Review of ECF and Decision 0.15 424 $63.60 0.15 $424 $63.60 Preparation of Joint Notice and email to 8/24/20 0.10 424 $42.40 0.10 $424 $42.40 Colleen Hartley Review of responsive email from Colleen 8/24/20 0.10 424 $42.40 0.10 $424 $42.40 Hartley with reply, review of ECF 8/25/20 Review of Judgment/ECF 0.10 424 $42.40 0.10 $424 $42.40 8/25/20 Preparation of email to Teresa Fields with 0.10 424 $42.40 0.10 $424 $42.40 Review of Election to Accept Judgment before 8/25/20 0.10 424 $42.40 0.10 $424 $42.40 filing/ECF 8/25/20 Telephone call from Colleen Hartley 0.10 424 $42.40 0.10 $424 $42.40 Preparation of text and email to client re: SS# 8/25/20 0.10 424 $42.40 0.10 $424 $42.40 (P did not want to Email or text SS#) 8/25/20 Telephone communication with client for SS# 0.10 424 $42.40 0.10 $424 $42.40 8/25/20 Telephone communication with Colleen Hartley 0.10 424 $42.40 0.10 $424 $42.40 Preparation of time and Motion for filing fees 9/09/20 2.50 424 $1,060.00 2.50 $424 $1,060.00 and costs 9/10/20 Review of pleadings for filing 0.10 424 $42.40 0.10 $424 $42.40 48.55 hours @ $424 per hour = $20,585.20 TOTAL $100,417.65 $80,032.65 Travel Fees $2,870.00 $2,870.00 TOTAL FEES WITH TRAVEL: $103,287.65 $82,902.65 Appendix B: vague entries proposed proposed date activity subtotal time rate 8/04/17 Preparation of correspondence to client—sent via email 0.60 $363 $217.80 Preparation of correspondence to client with filed 8/04/17 0.25 $363 $90.75 petition—sent via email 8/07/17 Preparation of email to client 0.10 $363 $36.30 Review of email from Colleen Hartley, review of past emails 1/16/18 0.20 $400 $80.00 and her prior Motion for Extension, preparation of response Review of prior email communications with client, 1/16/18 0.15 $400 $60.00 preparation of email to client with questions 1/16/18 Review of responsive email from Colleen Hartley with 0.10 $400 $40.00 1/16/18 Preparation of correspondence to client—sent via email 0.40 $400 $160.00 3/13/18 Call from Teresa Fields for update, notes to file 0.40 $400 $160.00 3/13/18 Follow up email to client confirming call details 0.15 $400 $60.00 Review of responsive email from Teresa Fields with 3/14/18 0.20 $400 $80.00 information; Requested, preparation of response 3/19/18 Preparation of email to client with attachment 0.10 $400 $40.00 5/07/18 Preparation of email to Teresa Fields and James Lawrence 0.10 $400 $40.00 5/07/18 Preparation of email to Colleen Hartley, review of response 0.10 $400 $40.00 5/07/18 Review of responsive email from James Lawrence with 0.10 $400 $40.00 5/07/18 Review of responsive email from life care planner with 0.20 $400 $80.00 5/07/18 Review of another email from James Lawrence with response 0.10 $400 $40.00 Telephone communication with Jay Lawrence, follow up 5/08/18 1.10 $400 $440.00 memorandum to file Preparation of email to Jay Lawrence with requests for 5/08/18 0.10 $400 $40.00 information 5/08/18 Review of responsive email from Jay Lawrence with response 0.10 $400 $40.00 5/09/18 Five (5) email communications with life care planner with 0.25 $400 $100.00 5/09/18 Preparation of email to Colleen Hartley 0.10 $400 $40.00 Review of email with questions from life care planner, 5/10/18 0.15 $400 $60.00 preparation of response 5/10/18 Preparation of email to Colleen Hartley 0.10 $400 $40.00 5/10/18 Preparation of email to Jay Lawrence 0.10 $400 $40.00 Appendix B: vague entries proposed proposed date activity subtotal time rate 5/10/18 Telephone call from Jay Lawrence, memorandum to file 0.75 $400 $300.00 Review of responsive email from Colleen Hartley, preparation 5/10/18 0.10 $400 $40.00 of response 5/10/18 Preparation of email to potential LCP, review of response 0.10 $400 $40.00 Telephone communication with LCP (Roberta Hurley), notes 5/11/18 0.25 $400 $100.00 to file 5/11/18 Preparation of 2 emails to Roberta Hurley 0.10 $400 $40.00 5/11/18 Preparation of email to Jay Lawrence with questions 0.15 $400 $60.00 5/13/18 Review of email from Roberta Hurley with response 0.15 $400 $60.00 Review of email from Teresa Fields with questions, 5/14/18 0.20 $400 $80.00 preparation of response 5/14/18 Review of email from Roberta Hurley with answer 0.10 $400 $40.00 5/14/18 Preparation of email to Colleen Hartley 0.10 $400 $40.00 5/14/18 Preparation of email to Jay Lawrence and Teresa 0.15 $400 $60.00 5/14/18 Review of responsive email from Colleen Hartley with 2 0.15 $400 $60.00 5/14/18 Preparation of email to Roberta Hurley 0.10 $400 $40.00 5/14/18 Preparation of email to Jay Lawrence 0.10 $400 $40.00 5/14/18 Preparation of another email to Colleen Hartley 0.10 $400 $40.00 Review of responsive email from Colleen Hartley with 5/15/18 0.10 $400 $40.00 response and review of her reply 5/15/18 Preparation of 2 emails to Roberta Hurley 0.15 $400 $60.00 5/15/18 Preparation of email to Jay Lawrence 0.10 $400 $40.00 5/16/18 Preparation of email to Roberta Hurley 0.10 $400 $40.00 5/16/18 Preparation of email to Jay Lawrence and Teresa Fields 0.10 $400 $40.00 5/16/18 Review of responsive email from Jay Lawrence with response 0.10 $400 $40.00 5/16/18 Preparation of another email to Roberta Hurley with questions 0.15 $400 $60.00 5/16/18 Review of another email from Jay Lawrence with response 0.10 $400 $40.00 5/16/18 Review of responsive email from Roberta Hurley 0.10 $400 $40.00 5/16/18 Preparation of email to Colleen Hartley 0.10 $400 $40.00 5/17/18 Review of responsive email from Colleen Hartley with 0.10 $400 $40.00 5/17/18 Preparation of email to Roberta Hurley 0.10 $400 $40.00 Appendix B: vague entries proposed proposed date activity subtotal time rate 6/11/18 Preparation of 2 more emails to Jay Lawrence and Teresa 0.15 $400 $60.00 Preparation of email to Teresa Fields and Jay Lawrence with 6/20/18 0.20 $400 $80.00 questions and contact information 6/20/18 Preparation of email to Colleen Hartley, review of response 0.10 $400 $40.00 6/20/18 Preparation of email to Roberta Hurley 0.10 $400 $40.00 Memorandum of information needed for site visit with 6/20/18 0.25 $400 $100.00 review of details Preparation of correspondence to Roberta Hurley with site 6/21/18 0.75 $400 $300.00 visit information—sent via email Review of e-mail and information from Jay Lawrence, 6/21/18 0.25 $400 $100.00 preparation of response 6/21/18 Review of responsive email from Teresa Fields with response 0.10 $400 $40.00 6/21/18 Review of responsive email from Roberta Hurley with 0.10 $400 $40.00 Preparation of email to Colleen Hartley, review of response 9/06/18 0.10 $400 $40.00 with response 9/11/18 Preparation of email to Jay Lawrence with attachment 0.10 $400 $40.00 9/11/18 Preparation of email to Roberta Hurley with review of 0.10 $400 $40.00 9/14/18 Review of responsive email from Colleen Hartley with 0.10 $400 $40.00 Review of email from Colleen Hartley with response and 9/15/18 0.10 $400 $40.00 review of her response 09/17/18 Review of email from Roberta Hurley with 0.15 $400 $60.00 . response/questions 09/17/18 Preparation of email to client re: upcoming phone call with 0.10 $400 $40.00 . DOJ 09/18/18 Preparation of email to Colleen Hartley with attachment, 0.10 $400 $40.00 review of her response 09/19/18 Review of email from Jay Lawrence with questions, review of notes in file for answers, preparation of response with 0.40 $400 $160.00 attachments 09/19/18 Preparation of email to Roberta Hurley re: issues to discuss 0.15 $400 $60.00 on telephone Appendix B: vague entries proposed proposed date activity subtotal time rate 8/06/19 Review of responsive email from Jay Lawrence 0.10 $400 $40.00 8/06/19 Telephone communication with Colleen Hartley with note to 0.15 $400 $60.00 8/12/19 Preparation of email to Attorney Meehan 0.10 $400 $40.00 8/12/19 Preparation of email to Teresa Fields and Jay Lawrence 0.10 $400 $40.00 08/27/19 Preparation of email to Colleen Hartley with update 0.10 $400 $40.00 8/29/19 Preparation of email to Colleen Hartley, review of response 0.10 $400 $40.00 9/04/19 Preparation of email to Colleen Hartley 0.10 $400 $40.00 Review of voice message from Jay Lawrence, call to Jay, note 9/19/19 0.10 $400 $40.00 to file Preparation of email to Jay Lawrence re: attempts to reach 9/19/19 0.10 $400 $40.00 him and update 9/19/19 Preparation of email to Teresa Fields 0.10 $400 $40.00 9/24/19 Preparation of email to Colleen Hartley 0.10 $400 $40.00 9/24/19 Telephone communication with Colleen Hartley 0.25 $400 $100.00 9/24/19 Telephone communication with Teresa Fields 0.30 $400 $120.00 9/24/19 Preparation of memorandum to file re: both calls 0.20 $400 $80.00 01/02/20 Preparation of email to Colleen Hartley 0.10 $424 $42.40 Telephone communication with Colleen Hartley with follow 01/02/20 0.15 $424 $63.60 up memorandum to file Review of text from Teresa Fields with response and review 1/20/20 0.10 $424 $42.40 of her reply 1/22/20 Preparation of email to Colleen Hartley, review of response 0.10 $424 $42.40 01/24/20 Review of text from Teresa Fields with reply 0.10 $424 $42.40 2/11/20 Preparation of email to Teresa Fields 0.10 $424 $42.40 3/04/20 Three more texts with Teresa Fields 0.15 $424 $63.60 Preparation of 2 texts to Teresa Fields for authorizations, 3/12/20 0.15 $424 $63.60 review of one reply Preparation of email to client with attachments and need for 3/12/20 0.20 $424 $84.80 Signature/approval, review of response with reply Appendix B: vague entries proposed proposed date activity subtotal time rate 3/12/20 Telephone call from Teresa Fields with note to file 0.15 $424 $63.60 4/07/20 Review of 2 text messages from Teresa Fields with 2 0.20 $424 $84.80 4/15/20 Review of responsive email from Teresa Fields with 0.10 $424 $42.40 4/15/20 Review of file for answer to P’s questions with notations 0.25 $424 $106.00 4/16/20 Telephone call from Colleen Hartley 0.25 $424 $106.00 4/16/20 Follow up memorandum to file 0.10 $424 $42.40 4/16/20 Preparation of email to client re: telephone call 0.10 $424 $42.40 4/24/20 Preparation of another email to Colleen Hartley 0.10 $424 $42.40 4/27/20 Review of email with response to Colleen Hartley 0.10 $424 $42.40 Review of telephone message from Colleen Hartley, 4/27/20 telephone communication with Colleen re: revised offer, etc. 0.15 $424 $63.60 with follow up memorandum to file 4/27/20 Review of 2 additional emails from Colleen Hartley 0.10 $424 $42.40 4/27/20 Preparation of text to client 0.10 $424 $42.40 5/05/20 Review of email from Colleen Hartley with response 0.10 $424 $42.40 5/05/20 Preparation of text to Teresa Fields with review of response 0.10 $424 $42.40 5/11/20 Preparation of text to Teresa Fields with review of reply 0.10 $424 $42.40 8/11/20 Review of email from Colleen Hartley with response 0.10 $424 $42.40 8/25/20 Telephone call from Colleen Hartley 0.10 $424 $42.40 TOTAL 25.05 $10,065.25
Case-law data current through December 31, 2025. Source: CourtListener bulk data.