`Case 3:17-cv-05659—WHA Document 660-3 Filed 06/10/21 Page 1 of 60
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`EXHIBIT 1
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`EXHIBIT 1
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`(REDACTED VERSION OF
`(REDACTED VERSION OF
`DOCUMENT SOUGHT TO BE SEALED)
`DOCUMENT SOUGHT TO BE SEALED)
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 2 of 60
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Ingrid M. H. Petersen (SBN 313927)
`ipetersen@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`vs.
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`DECLARATION OF JONATHAN S.
`KAGAN IN SUPPORT OF
`REQUEST FOR FEES AND
`EXPENSES
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`FINJAN, INC., a Delaware Corporation,
`)
`Case No. 3:17-cv-05659-WHA
`)
`Plaintiff,
`)
`)
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`Defendant.
`
`Submitted to the Special Master
`
`DECLARATION OF JONATHAN S. KAGAN IN SUPPORT
`OF REQUEST FOR FEES AND EXPENSES
`Case No. 3:17-cv-05659-WHA
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 3 of 60
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`DECLARATION OF JONATHAN S. KAGAN
`
`
`I, Jonathan S. Kagan, declare as follows:
`1.
`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for
`Juniper Networks, Inc. in Finjan, Inc. v. Juniper Networks, Inc., Case No. C 17-05659 WHA
`(N.D. Cal.). I am a member in good standing of the State Bar of California. I have personal
`knowledge of the facts set forth in this Declaration and, if called as a witness, could and would
`testify competently to such facts under oath.
`2.
`Pursuant to ¶¶ 2-3 of Judge Alsup’s Order re Attorney’s Fees and Costs and
`Appointment of Special Master dated January 9, 2021, (the “Referral Order”) Defendant Juniper
`Networks, Inc. (“Juniper”) hereby presents this detailed declaration setting forth the “itemized
`accounting” of unreimbursed “Travel” and “Expert Witness Fees” expenses (Referral Order ¶ 2),
`as well as a breakdown of “all attorney and paralegal time sought to be recovered.” (Referral
`Order ¶ 3). As set forth in greater detail below, this declaration does not detail the full scope of
`fees and expenses Juniper incurred in connection with Plaintiff Finjan, Inc.’s (“Finjan”) assertion
`of U.S. Patent Nos. 8,677,494 (the “’494 Patent”) and 6,804,780 (the “’780 Patent”) against
`Juniper.
`
`SCOPE OF DECLARATION
`3.
`Although Finjan asserted a total of 9 patents against Juniper at various times during
`its three-year litigation campaign against Juniper, it litigated only three of those patents to a
`conclusion: (1) the ’494 Patent; the ’780 Patent, and U.S. Patent No. 8,141,154 (the “’154
`Patent”) (collectively, the “Adjudicated Patents”). Of these, the ’494 Patent consumed the vast
`majority of legal work, as it was the subject of an early motion for summary judgment, a highly
`contested (and ultimately successful) Daubert challenge to Finjan’s damages expert, and a week-
`long jury trial on infringement. Following the jury trial, the parties began preparing immediately
`for a second trial on the ’494 Patent relating to validity and enforceability issues. The Court then
`postponed that trial, determining that all outstanding issues relating to the ’494 Patent could be
`adjudicated at a later date—in a single trial that would also involve all of the remaining non-
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 4 of 60
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`adjudicated patents. Both of the other Adjudicated Patents were the subject of summary
`proceedings: the ’780 Patent was the subject of two summary judgment motions, and the ’154
`Patent was the subject of an additional summary judgment motion.
`4.
`Pursuant to Judge Alsup’s Order Re Request For Attorneys Fees dated January 9,
`2021, (“Fees Order”) this declaration includes only time entries related to Finjan’s assertion of the
`’494 and ’780 Patents against Juniper. As discussed below, Juniper’s initial submission to the
`Court did not break down or allocate fees on a patent-by-patent basis. By providing this detailed,
`line-by-line submission, the Special Master can verify time entries for the ‘154 Patent (and any
`non-adjudicated patents) have been removed from Juniper’s requests, and any entries involving
`multiple patents have been apportioned so the full amount of those time entries is not being
`charged to Finjan.
`5.
`The records used to produce this declaration are all based on contemporaneous time
`records that are prepared on a monthly basis and were submitted to Juniper for payment. These
`time records are generally prepared within 30 days following the end of the month in which the
`time was expended. Estimates and retroactively-created time records were not used to prepare this
`declaration.
`
`“BILLING JUDGMENT”
`6.
`In an effort to avoid the expense and burden associated with a line-by-line review
`of over three years of time entries in an aggressively-litigated case (including four summary
`judgment motions, complex Daubert issues, and a full jury trial)—Juniper’s initial fees
`submission consisted of summaries of its time entries, organized by phase of the case, with a
`generous amount of reductions to ensure its proposed recovery was fair. The reductions Juniper
`proposed were:
`
`a. Reducing the hourly rates sought for all attorneys below what Juniper
`actually paid;
`b. Excluding fees for attorneys who were not core members of the case team,
`such as attorneys who assisted with isolated tasks or projects in the case;
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 5 of 60
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`c. Omitting fees charged by non-attorneys, such as paralegals and other Irell &
`Manella support staff, and seeking fees for attorney billers only;
`d. Excluding fees related to inter partes review proceedings regarding Finjan’s
`patents;
`e. Excluding fees related to settlement and mediation efforts;
`f. Excluding fees related to preparing Juniper’s pending motion for sanctions
`(Dkt. 409);
`g. Not seeking expert fees or any third party costs;
`h. Exercising reasonable judgment to exclude time spent on administrative or
`internal tasks, such as internal meetings between counsel; and
`i. Exercising reasonable judgment to exclude supervisory time associated with
`having junior attorneys take depositions and/or argue motions.
`7.
`While Judge Alsup’s Fees Order held that Juniper could recover its fees and costs
`related to litigation of the ’780 and ’494, it also provided that Juniper could not recover fees and
`costs relating to the ’154 Patent (nor the non-adjudicated patents). This Order thus precluded the
`summary procedure Juniper had suggested, as Juniper had not broken down its fees and expenses
`by patent. Judge Alsup thus ordered Juniper to produce an itemized accounting of its “Travel” and
`“Expert Witness Fees” (Referral Order ¶ 2), as well as a line-by-line breakdown of all recoverable
`attorney and paralegal time (Referral Order ¶ 3).
`8.
`The Referral Order also requires Junipert to provide proof that it exercised “billing
`judgment” in this declaration, including “adjustments made to eliminate duplication, excess,
`associate-turnover expense and so forth.” (Referral Order ¶ 6).
`9.
`In preparing this declaration, I personally reviewed each and every time entry
`submitted, as well as many that were billed to Juniper but are not included in this submission. In
`addition to writing off all time entries related only to the ’154 Patent (or any non-adjudicated
`patent), I also wrote off a significant number of entries where, in the exercise of my judgment,
`there were inefficiencies in performing the tasks. In addition, I have continued to apply each of
`the reductions described in ¶ 6, above, with the only exception being that I have included third
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`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 6 of 60
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`party costs relating to “Travel” and “Expert Witness Fees” pursuant to ¶ 2 of the Referral Order. I
`have attached as Exhibit A a summary of the amount of time actually billed to Juniper for each
`timekeeper compared with the amount of time sought be recovered. It should be noted that this
`chart only includes information for the core timekeepers involved in this case; it is in addition to
`the entries for timekeepers who billed time to Juniper, but for whom no recovery is being sought.
`PROFESSIONAL QUALIFICATIONS:
`10.
`Pursuant to paragraph 6 of the Referral Order, I have set forth below a summary of
`the qualifications, experience, and role of the various professionals for whom Juniper is seeking
`recovery of fees.
`Jonathan S. Kagan: I am a partner at Irell & Manella and a member of the
`a.
`firm’s Executive Committee. I have nearly thirty years of experience as an intellectual property
`litigator, including significant experience in cases involving cyber security technology, and have
`been recognized as a leading intellectual property litigator by the Daily Journal, the Legal 500, Best
`Lawyers of America, and the Southern California Super Lawyers List. I have also achieved
`significant defense victories for defendants accused of patent infringement, including three that were
`recognized by the Daily Journal on its annual list of top defense victories. I am a former president
`of the Century City Bar Association and serve on the Editorial Advisory Board of the National
`Institute for Trial Advocacy. I served as co-lead counsel for Juniper from the beginning of the case
`through appeal.
`Alan J. Heinrich: Mr. Heinrich is a partner at Irell & Manella and previously
`b.
`served on the firm’s Executive Committee. Mr. Heinrich has thirty years of experience as an
`intellectual property litigator, and has participated in trials that have obtained multi-hundred million-
`dollar judgments on behalf of patent owners and has also successfully defended against multi-
`hundred million-dollar damages claims on behalf of accused infringers. Mr. Heinrich has been
`recognized as a top intellectual property litigator by Southern California Super Lawyers.
`Mr. Heinrich is also an adjunct faculty member at the University of California, Los Angeles, where
`he teaches Patent Intensive, an advanced patent law seminar, and has also taught Patent Law and
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`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 7 of 60
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`Federal Courts at Loyola Law School. Mr. Heinrich was a core member of the December 2018 trial
`and post-trial teams.
`Rebecca Carson: Ms. Carson is a partner at Irell & Manella and has over
`c.
`thirteen years of experience as an intellectual property litigator, including extensive experience in
`cases involving network security and computer software technology. Ms. Carson was recognized
`by the Daily Journal as one of the Top 40 Lawyers Under 40 in 2018 and one of the 75 Top
`Intellectual Property Lawyers in California in 2019. She was also recognized nationally in 2018 as
`one of three “Rising Stars” in technology law by Law360. Ms. Carson has significant trial
`experience, and has been a member of five trial teams for patent cases in various federal courts over
`the past three years, each of which has resulted in a favorable jury verdict for her client. Ms. Carson
`served as co-lead counsel from the beginning of this case through appeal. The December 2018 trial
`in this matter was the first trial in which she served as co-lead trial counsel.
`Josh Glucoft: Mr. Glucoft is currently a partner at Kirkland & Ellis LLP, and
`d.
`was formerly an associate at Irell & Manella. At the time of his work on this matter, Mr. Glucoft
`had four or more years of experience as an intellectual property litigator, including experience with
`patents covering a variety of technologies within the fields of electrical engineering and computer
`science. Mr. Glucoft also has significant experience practicing before the Patent and Trademark
`Office in post-grant proceedings. Mr. Glucoft’s served as a senior associate in this case, providing
`technical analyses of the patents at issue, analyzing prior art, and preparing and taking depositions.
`Casey Curran: Ms. Curran is a former associate at Irell & Manella. At the
`e.
`time of her work on this matter, Ms. Curran had at least four years of patent litigation and federal
`courts experience, including multiple patent trials in federal courts. Ms. Curran was a core member
`of the Irell team during the first round of the “patent showdown” and at the December 2018 trial,
`where she handled oral argument on a number of evidentiary motions and did the direct examination
`of Juniper’s damages expert. Prior to joining Irell, Ms. Curran served as a law clerk for the Hon.
`Garland E. Burrell of the Eastern District of California, and obtained her J.D. from UCLA Law
`School where she was elected to the Order of the Coif. Ms. Curran left Irell in early 2019, and
`currently works for the California Department of Justice.
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`A Registered Limited Liability
`Law Partnership Including
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 8 of 60
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`Sharon Song: Ms. Song is a former associate at Irell & Manella. At the time
`f.
`of her work on this matter, Ms. Song had at least two years of experience as an intellectual property
`and commercial litigator, including experience successfully defending patents in inter partes review
`proceedings. Ms. Song was a core member of the Irell team during the first round of the “patent
`showdown” and at the December 2018 trial. She handled the oral argument for Finjan’s motion to
`dismiss various affirmative defense in this case, which was her first oral argument. Ms. Song
`obtained her J.D. from Harvard Law School.
`Ingrid Petersen: Ms. Petersen is an associate at Irell & Manella. At the time
`g.
`of her work on this matter, Ms. Petersen had at least three years of litigation and federal courts
`experience. Prior to joining Irell, Ms. Petersen served as a law clerk to the Honorable James V.
`Selna on the District Court for the Central District of California, and to the Honorable Karen Nelson
`Moore on the United States Court of Appeals for the Sixth Circuit. Ms. Petersen obtained her J.D.
`from the University of California Irvine, summa cum laude.
`Kevin Wang: Mr. Wang is a former associate at Irell. At the time of his work
`h.
`on this matter, Mr. Wang had at least one year of experience as an intellectual property litigator.
`Mr. Wang was a core member of the Irell team through both rounds of the “patent showdown,” the
`December 2018 trial, and the preparations for the October 2019 trial (before Finjan dismissed its
`claims with prejudice). Mr. Wang argued his first motion during the December 2018 trial, and also
`took his first deposition in this case. Mr. Wang obtained his J.D. from the University of Chicago
`Law School.
`
`HOURLY RATES
`11.
`The parties have been able to agree on the hourly rates that will apply in connection
`with this fees request. These agreed rates are:
`
`Professional
`Jonathan Kagan
`
`Alan Heinrich
`
`Rebecca Carson
`
`Agreed Rate
`$1,095
`
`Timekeeper Code
`KAGN
`
`$1,000
`
`$950
`
`HRCH
`
`RCLI
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`A Registered Limited Liability
`Law Partnership Including
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 9 of 60
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`Josh Glucoft
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`Casey Curran
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`Ingrid Petersen
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`Sharon Song
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`Kevin Wang
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`$750
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`$750
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`$700
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`$650
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`$600
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`JGLC
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`CRRN
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`INPE
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`SSON
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`KWAN
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`SUMMARY OF RECOVERY SOUGHT
`12.
`Pursuant to the instructions contained in paragraph 3 of the Referral Order, I have
`organized the legal work performed defending against Finjan’s ’494 and ’780 Patents into discrete
`projects, each of which is further divided into a number of discrete tasks or items. In some cases,
`where there are a number of related discrete items within a project, I have broken those items out
`as a separate project to allow for an easier review of the data. In all cases, however, the
`underlying time entries describe the work that was performed so the Special Master can determine
`exactly how much time was spent on each discrete project and each discrete item. While I believe
`the method in which I have organized the data complies with the letter and spirit of Judge Alsup’s
`Order, we have the ability to re-organize and re-sort the data in additional ways if the Special
`Master believes it would be useful to see the data organized in an additional or different manner.
`13.
`Because the underlying litigation was so extensive—spanning a total of three years
`with dozens of motions, extensive fact and expert discovery, and a jury trial—I divided the
`litigation into roughly 130 discrete projects. The total cost of all projects relating to Finjan’s
`assertion of the ’494 and ’780 Patents for which Juniper seeks recovery is $6,228,266. I have
`attached a list identifying each project, along with its corresponding cost, as Exhibit B to this
`declaration. The detailed, line-by-line description of work set forth in ¶ 3 of the Referral Order is
`attached as Exhibit C.
`14.
`The only project for which I have not provided a line-by-line description of work is
`“Fees Motions and Submissions to Special Master.” The reason I have not provided that
`information is that Juniper is paying a fixed fee of $150,000 for all work associated with this
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`Law Partnership Including
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 10 of 60
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`motion, as reflected on Exhibit B. The Referral Order provides that the Special Master may
`decide to include these fees as part of Juniper’s recovery. (See Referral Order ¶ 8).
`EXPENSES
`15.
`Pursuant to Paragraph 2 of the Referral Order, I have attached as Exhibit D to this
`declaration an itemized list of unreimbursed expenses for “Travel” and “Expert Witness Fees.”
`These expenses total $1,425,659.24. Travel expenses are broken down into subcategories of “Air
`Transportation,” “Ground Travel,” “Parking,” “Meals” and “Lodging.” The bulk of Juniper’s
`unreimbursed expenses are expert witness fees from two expert witnesses who testified at the ’494
`Patent trial: Dr. Avi Rubin of Harbor Labs ($686,738), Juniper’s technical expert, and Dr. Keith
`Ugone of Analysis Group ($529,844), Juniper’s damages expert. Judge Alsup did not dismiss
`Finjan’s damages case until after Dr. Ugone had prepared his expert report, sat for deposition, and
`testified at trial.
`16.
`I have attached as Exhibit E a summary report showing the overall amount of hours
`(and the value of those hours) each timekeeper billed in connection with the activities for which
`Juniper is seeking recovery. While these numbers illustrate “all timekeepers’ respective
`workloads and roles in the overall case,” as required by ¶ 5 of the Referral Order, they overstate
`the amounts Juniper is seeking to recover because they do not take into account the time Juniper
`has removed from its submission for the ’154 Patent and the non-adjudicated patents.
`Executed on March 22, 2021, at Los Angeles, California.
`I declare under penalty of perjury under the laws of the State of California that the
`foregoing is true and correct.
`
` /s/ Jonathan S. Kagan
`
`Jonathan S. Kagan
`
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`Exhibit D
`
`
`
`
`
`
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 12 of 60
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`Travel
` Air Transportation
` Ground Travel
` Meals
` Lodging
`Travel Sub‐Total
`
`Expert Fees
`
`Total Expenses
`
`$39,195.58
`$9,402.49
`$7,498.67
`$152,980.56
`$209,077.30
`
`$1,216,581.94
`
`$1,425,659.24
`
`Expense Summary
`
`1
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`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 13 of 60
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`Travel
`
`Air Transportation
`
`Timekeeper
`Date
`1/17/2018 JGLC
`
`1/18/2018 JGLC
`
`1/29/2018 RCLI
`
`2/1/2018 RCLI
`
`2/15/2018 RCLI
`
`2/15/2018 RCLI
`
`2/23/2018 RCLI
`
`4/11/2018 JGLC
`
`4/16/2018 JGLC
`
`4/16/2018 JGLC
`
`4/16/2018 KAGN
`
`4/20/2018 RCLI
`
`4/25/2018 RCLI
`
`5/3/2018 RCLI
`
`Description
`Amount
`$197.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180209‐TC; INVOICE DATE: 02/09/2018; ROUNDTRIP
`AIRFARE TO SAN JOSE (INV: 161649) ‐ GLUCOFT/JOSHUA POPIK
`$122.00 VENDOR: Glucoft, Josh; INVOICE#: 0124181423; DATE: 1/24/2018 FLIGHT CHANGE FEE FOR J GLUCOFT
`
`$248.98 VENDOR: Carson, Rebecca; INVOICE#: 0216181552; DATE: 3/28/2018 AIRFARE TO SAN FRANCISCO FOR
`R CARSON RE HEARING ON MOTION TO DISMISS
`$257.98 VENDOR: Carson, Rebecca; INVOICE#: 0216181552; DATE: 3/28/2018 AIRFARE FOR R CARSON RE
`HEARING ON MOTION TO DISMISS
`$248.98 VENDOR: Carson, Rebecca; INVOICE#: 0216181552; DATE: 3/28/2018 AIRFARE TO SAN FRANCISCO FOR
`R CARSON RE CMC
`$257.98 VENDOR: Carson, Rebecca; INVOICE#: 0216181552; DATE: 3/28/2018 AIRFARE FROM SAN FRANCISCO
`FOR R CARSON RE CMC
`$248.98 VENDOR: Carson, Rebecca; INVOICE#: 0216181552; DATE: 3/28/2018 AIRFARE FROM SAN JOSE FOR R
`CARSON RE MEETING AT JUNIPER WITH YULY TENARIO
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐TC; INVOICE DATE: 05/09/2018; TRAVEL AGENCY
`FEE (INV: 174275) ‐ GLUCOFT/JOSHUA POPIK
`$250.98 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐A; INVOICE DATE: 05/09/2018; SOUTHWES
`5261436051032 ‐ AIRFARE‐J GLUCOFT ‐ GLUCOFT, JOSH
`$248.98 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐A; INVOICE DATE: 05/09/2018; SOUTHWES
`5261436067345 ‐ AIRFARE FOR J GLUCOFT ‐ GLUCOFT, JOSH
`$469.96 VENDOR: Kagan, Jonathan S.; INVOICE#: 0522181522; DATE: 5/22/2018 AIRFARE FOR J KAGAN RE TRIP
`TO JUNIPER NETWORKS FOR INTERVIEWS AND DISCOVERY
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0430181259; DATE: 4/30/2018 AIRFARE FROM SJC TO SNA FOR R
`CARSON
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐TC; INVOICE DATE: 05/09/2018; TRAVEL AGENCY
`FEE (INV: 176308) ‐ CARSON/REBECCA LYN
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE YULY TENORIO PREP AND DEPO
`
`Air
`
`2
`
`
`
`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 14 of 60
`
`Air Transportation
`
`Timekeeper
`Date
`5/3/2018 RCLI
`
`5/6/2018 JGLC
`
`5/6/2018 JGLC
`
`5/14/2018 JGLC
`
`5/14/2018 JGLC
`
`5/24/2018 RCLI
`
`5/24/2018 RCLI
`
`5/24/2018 RCLI
`
`5/24/2018 RCLI
`
`5/27/2018 KAGN
`
`6/4/2018 JGLC
`
`6/12/2018 KAGN
`
`6/13/2018 RCLI
`
`6/26/2018 SSON
`
`6/26/2018 SSON
`
`Description
`Amount
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE FROM SAN JOSE FOR R
`CARSON RE YULY TENORIO PREP AND DEPO
`$499.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐TC; INVOICE DATE: 05/09/2018; AIRFARE FROM
`LOS ANGELES TO SAN JOSE; OAKLAND TO LOS ANGELES (INV: 176248) ‐ GLUCOFT/JOSHUA POPIK
`
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180509‐TC; INVOICE DATE: 05/09/2018; TRAVEL AGENCY
`FEE (INV: 176248) ‐ GLUCOFT/JOSHUA POPIK
`$497.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180611‐TC; INVOICE DATE: 06/11/2018; ROUNDTRIP
`AIRFARE TO SAN JOSE (INV: 177010) ‐ GLUCOFT/JOSHUA POPIK
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180611‐TC; INVOICE DATE: 06/11/2018; TRAVEL AGENCY
`FEE (INV: 177010) ‐ GLUCOFT/JOSHUA POPIK
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE DEPO OF JOHN GARLAND
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE FROM SAN JOSE TO
`ORANGE COUNTY FOR R CARSON RE DEPO OF JOHN GARLAND
`$222.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE PREP AND DEPO OF RAJU MANTHENA
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 0514181052; DATE: 6/7/2018 AIRFARE FROM SAN JOSE TO
`ORANGE COUNTY FOR R CARSON RE PREP AND DEPO OF RAJU MANTHENA
`$493.96 VENDOR: Kagan, Jonathan S.; INVOICE#: 0606181114; DATE: 6/6/2018 AIRFARE FOR J KAGAN RE
`CHANDRA DEPO
`$1,227.94 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180710‐A; INVOICE DATE: 07/10/2018; SOUTHWES
`5261453190193 ‐ AIRFARE TO BALTIMORE FOR J GLUCOFT ‐ GLUCOFT, JOSH
`$1,090.60 VENDOR: Kagan, Jonathan S.; INVOICE#: 0615181410; DATE: 6/15/2018 AIRFARE FOR J KAGAN RE AVI
`DEPO
`$1,168.60 VENDOR: Carson, Rebecca; INVOICE#: 0622181129; DATE: 7/11/2018 ROUNDTRIP AIRFARE TO
`HERNDON VA FOR R CARSON RE DEPO OF DR. ERIC COLE
`$811.40 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180710‐TC; INVOICE DATE: 07/10/2018; ROUNDTRIP
`AIRFARE TO SAN FRANCISCO (INV: 184302) ‐ SONG/SHARON SOO HYUN
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180710‐TC; INVOICE DATE: 07/10/2018; TRAVEL AGENCY
`FEE (INV: 184302) ‐ SONG/SHARON SOO HYUN
`
`Air
`
`3
`
`
`
`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 15 of 60
`
`Air Transportation
`
`Timekeeper
`Date
`6/26/2018 SSON
`
`6/28/2018 CRRN
`
`7/3/2018 RCLI
`
`7/3/2018 RCLI
`
`7/6/2018 KAGN
`
`7/13/2018 CRRN
`
`7/13/2018 RCLI
`
`7/13/2018 RCLI
`
`7/13/2018 RCLI
`
`7/13/2018 RCLI
`
`7/16/2018 CRRN
`
`7/16/2018 RCLI
`
`7/25/2018 CRRN
`
`7/25/2018 JGLC
`
`7/25/2018 JGLC
`
`7/25/2018 KAGN
`
`Description
`Amount
`$19.95 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180710‐TC; INVOICE DATE: 07/10/2018; TRAVEL AGENCY
`FEE (INV: 184330) ‐ SONG/SHARON
`$255.96 VENDOR: Curran, Casey; INVOICE#: 0720180959; DATE: 7/20/2018 ROUNDTRIP AIRFARE TO OAKLAND
`FOR C CURRAN RE TRIP TO SAN FRANCISCO FOR HEARING
`$602.79 VENDOR: Carson, Rebecca; INVOICE#: 0622181129; DATE: 7/11/2018 AIRFARE TO BOSTON MA FOR R
`CARSON RE DEPO OF MICHAEL MITZENMACHER
`$711.20 VENDOR: Carson, Rebecca; INVOICE#: 0622181129; DATE: 7/11/2018 AIRFARE FROM BOSTON MA FOR
`R CARSON RE DEPO OF MICHAEL MITZENMACHER
`$297.00 VENDOR: Kagan, Jonathan S.; INVOICE#: 0723181228; DATE: 7/23/2018 AIRFARE CHANGE FEE FOR J
`KAGAN RE AVI RUBIN DEPO
`$505.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; ROUNDTRIP
`AIRFARE TO SAN FRANCISCO ‐ CURRAN/CASEY MAY
`$276.98 VENDOR: Carson, Rebecca; INVOICE#: 0803181144; DATE: 8/3/2018 AIRFARE TO OAKLAND FOR R
`CARSON RE HEARING ON MOTION TO COMPEL AND MOTION TO AMEND
`$276.98 VENDOR: Carson, Rebecca; INVOICE#: 0803181144; DATE: 8/3/2018 AIRFARE FROM OAKLAND FOR R
`CARSON RE HEARING ON MOTION TO COMPEL AND MOTION TO AMEND
`$276.98 VENDOR: Carson, Rebecca; INVOICE#: 0803181144; DATE: 8/3/2018 AIRFARE TO OAKLAND FOR R
`CARSON RE MSJ HEARING
`$252.98 VENDOR: Carson, Rebecca; INVOICE#: 0803181144; DATE: 8/3/2018 AIRFARE FROM SAN FRANCISCO
`FOR R CARSON RE MSJ HEARING
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186555) ‐ CURRAN/CASEY MAY
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186556) ‐ CARSON/REBECCA LYN
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186350) ‐ CURRAN/CASEY MAY
`$505.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; ROUNDTRIP
`AIRFARE TO SAN FRANCISCO (INV: 186352) ‐ GLUCOFT/JOSHUA POPIK
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186352) ‐ GLUCOFT/JOSHUA POPIK
`$505.96 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; ROUNDTRIP
`AIRFARE TO SAN FRANCISCO (INV: 186349) ‐ KAGAN/JONATHAN S
`
`Air
`
`4
`
`
`
`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 16 of 60
`
`Air Transportation
`
`Description
`Amount
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186349) ‐ KAGAN/JONATHAN S
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 180809‐TC; INVOICE DATE: 08/09/2018; TRAVEL AGENCY
`FEE (INV: 186345) ‐ CARSON/REBECCA LYN
`$493.96 VENDOR: Kagan, Jonathan S.; INVOICE#: 1010181552; DATE: 10/10/2018 AIRFARE FOR J KAGAN FOR
`MEETINGS AND INTERVIEWS AT JUNIPER
`$2,049.32 VENDOR: Kagan, Jonathan S.; INVOICE#: 1113181037; DATE: 11/13/2018 AIRFARE FOR J KAGAN RE
`MEDIATION MEETING
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE DEPO OF HARTSTEIN
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 FLIGHT FROM SAN JOSE TO SNA
`FOR R CARSON RE DEPO OF HARTSTEIN
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE DEPO OF ALESSANDRO ORSO
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE FROM SAN JOSE TO SNA
`FOR R CARSON RE DEPO OF ALESSANDRO ORSO
`$1,886.78 VENDOR: Kagan, Jonathan S.; INVOICE#: 1113181037; DATE: 11/13/2018 AIRFARE FOR J KAGAN RE
`GARLAND DEPO
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE DEPO OF MAR‐SPINOLA
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 181211‐TC; INVOICE DATE: 12/11/2018; TRAVEL AGENCY
`FEE (INV: 200626) ‐ KAGAN/JONATHAN S
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE FROM SAN JOSE TO SNA
`FOR R CARSON RE DEPO OF MAR‐SPINOLA
`$523.60 VENDOR: Kagan, Jonathan S.; INVOICE#: 0109191609; DATE: 1/9/2019 AIRFARE FOR J KAGAN RE AVI
`RUBIN DEPO AND PREP
`$15.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 181211‐TC; INVOICE DATE: 12/11/2018; TRAVEL AGENCY
`FEE (INV: 201565) ‐ GLUCOFT/JOSHUA POPIK
`$198.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 181211‐TC; INVOICE DATE: 12/11/2018; ROUNDTRIP
`AIRFARE TO SAN JOSE (INV: 201739) ‐ GLUCOFT/JOSHUA POPIK
`$40.00 VENDOR: WELLS FARGO BANK (CCO); INVOICE#: 181211‐TC; INVOICE DATE: 12/11/2018; TRAVEL AGENCY
`FEE (INV: 201739) ‐ GLUCOFT/JOSHUA POPIK
`
`Timekeeper
`Date
`7/25/2018 KAGN
`
`7/25/2018 RCLI
`
`8/29/2018 KAGN
`
`10/5/2018 KAGN
`
`10/16/2018 RCLI
`
`10/16/2018 RCLI
`
`10/17/2018 RCLI
`
`10/17/2018 RCLI
`
`10/23/2018 KAGN
`
`10/25/2018 RCLI
`
`10/30/2018 KAGN
`
`10/30/2018 RCLI
`
`11/3/2018 KAGN
`
`11/6/2018 JGLC
`
`11/6/2018 JGLC
`
`11/6/2018 JGLC
`
`Air
`
`5
`
`
`
`Case 3:17-cv-05659-WHA Document 660-3 Filed 06/10/21 Page 17 of 60
`
`Air Transportation
`
`Description
`Amount
`$501.96 VENDOR: Wang, Kevin; INVOICE#: 1128181454; DATE: 11/28/2018 AIRFARE TO SAN JOSE FOR K WANG
`RE CHAPEROT DEPO
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE TO SAN JOSE FOR R
`CARSON RE DEPO OF ARST
`$250.98 VENDOR: Carson, Rebecca; INVOICE#: 1130181535; DATE: 11/30/2018 AIRFARE FROM SAN JOSE TO SNA
`FOR R CARSON RE DEPO OF ARST
`$347.40 VENDOR: Kagan, Jonathan S.; INVOICE#: 0109191609; DATE: