Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 1 of 6
`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 1 of 6
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`
`
`EXHIBIT A
`EXHIBIT A
`
`

`

`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 2 of 6
`
`Date
`1/30/2023
`1/30/2023
`
`Billed Hrs Billed Amt
`1.10
`
`638.00
`
`
`1.20
`
`1,434.00
`
`Timekeeper
`Gallwas, Lawrence
`Gregorian, Todd
`
`1/30/2023
`
`
`
`2.00
`
`
`
`2,150.00
`
`Lavin, Chris
`
`Fenwick Anti-SLAPP Entries (Q1 2023)
`Description
`Review and collect authorities cited in BDE's and ECA's anti-slapp motion.
`Attention to anti-Slapp motion in state action.
`Analyze PersonalWeb investors' motion to strike, conduct legal and records research, correspondence with
`team, and draft correspondence to client.
`
`1/31/2023
`
`
`
`0.80
`
`
`
`860.00
`
`Lavin, Chris
`
`Analyze PersonalWeb investors' motion to strike, conduct records research, and correspondence with team.
`
`1/31/2023
`
`
`
`0.30
`
`
`
`174.00
`
`Gallwas, Lawrence
`
`1/31/2023
`2/1/2023
`2/2/2023
`2/2/2023
`
`4.40
`
`
`1.40
`
`0.20
`
`3.10
`
`2,552.00
`
`
`1,673.00
`215.00
`
`
`3,704.50
`
`Gallwas, Lawrence
`Gregorian, Todd
`Becker, Matthew
`Gregorian, Todd
`
`2/2/2023
`
`
`
`0.80
`
`
`
`860.00
`
`Lavin, Chris
`
`2/3/2023
`
`
`
`0.60
`
`
`
`645.00
`
`Lavin, Chris
`
`2/6/2023
`
`
`
`1.00
`
`
`
`1,075.00
`
`Lavin, Chris
`
`2/7/2023
`
`
`
`1.30
`
`
`
`1,397.50
`
`Lavin, Chris
`
`2/7/2023
`2/7/2023
`
`1.00
`
`
`1.00
`
`1,075.00
`
`
`1,075.00
`
`Lavin, Chris
`Lavin, Chris
`
`2/7/2023
`2/9/2023
`2/9/2023
`
`3.00
`
`
`0.30
`
`0.10
`
`2,475.00
`
`358.50
`
`
`107.50
`
`Li, Su
`Gregorian, Todd
`Becker, Matthew
`
`2/10/2023
`2/10/2023
`2/10/2023
`
`1.00
`
`
`1.40
`
`0.70
`
`1,075.00
`
`
`1,505.00
`836.50
`
`
`Becker, Matthew
`Lavin, Chris
`Gregorian, Todd
`
`Assist C. Lavin with secure transmission of PersonalWeb Investors' anti-slapp motion and supporting papers.
`Analyze ECA's document production identify examples of missing attachments and provide summary of same to
`C. Lavin (0.5); review PersonalWeb Investors' anti-slapp motion and collect all cited authorities (1.2); review,
`analyze, and organize the exhibits to PersonalWeb Investors' appendix and request for judicial notice in support
`of their anti-slapp motion. (2.7).
`Attention to discovery and anti-SLAPP issues.
`Discuss Anti-SLAPP motions with T. Gregorian.
`Attention to discovery and anti-SLAPP issues.
`Correspondence and discussions regarding motions to strike with team, opposing counsel, and court, and
`conduct records research.
`Correspondence and discussions regarding motions to strike with team, opposing counsel, and court, and
`conduct records research.
`Draft joint stipulation regarding motions to strike, conduct records research, and correspondence with team
`and opposing counsel.
`Prepare for and participate in meet and confer on motions to strike/motion to compel, conduct legal and
`records research, and correspondence and discussions with team.
`Revise joint stipulation regarding motions to strike, conduct records research, and correspondence with team
`and opposing counsel.
`Conduct legal research regarding anti-SLAPP motion and motion to compel, and discussions with team.
`Read complaint and motions filed for the enforcement of judgment case. Reflect and take notes in preparation
`for drafting responses.
`Team meeting re anti-slapp and other pending tasks.
`Discuss Anti-SLAPP motions with T. Gregorian.
`
`Li, Su
`
`Lavin, Chris
`
`Li, Su
`Becker, Matthew
`
`Lavin, Chris
`
`Rios Ojeda, Adrian Matthew
`
`Participate in team meeting regarding Anti-SLAPP motions (0.6); review documents concerning same (0.4).
`Prepare for and participate in team meeting on motion to strike (Anti-SLAPPs), and analyze the motions.
`Team meeting re anti-SLAPP and other pending tasks.
`Read related article and conduct research on case law for the Opposition to the Anti-SLAPP motion. Attend
`team meeting.
`Draft memorandum on law of the case and Anti-SLAPP for opposition to motion to strike (Anti-SLAPPs), conduct
`legal research, and discussions with team.
`Read related article and conduct research on case law for the Opposition to the Anti-SLAPP motion. Attend
`team meeting.
`Discuss next steps with A. Rios (0.2); continue researching opposition to Anti-SLAPP motions (1.4).
`Revise memorandum on law of the case doctrine and opposition to motion to strike (Anti-SLAPPs), conduct
`legal research, and discussions with team.
`Prepare for and confer with team regarding case posture, Plaintiffs' motion, and response strategy (0.5);
`research caselaw regarding law of the case doctrine, limitations, and potential application (3.2).
`Revise memorandum on law of the case and Anti-SLAPP for opposition to motion to strike (anti-SLAPPs),
`conduct legal and records research, and correspondence with team.
`Lavin, Chris
`Rios Ojeda, Adrian Matthew Research caselaw regarding law of the case doctrine, limitations, and potential application.
`Revise memorandum on law of the case and opposition to motion to strike (Anti-SLAPPs), conduct legal and
`records research, and correspondence with team.
`Review case documents and research case law for opposition to Anti-SLAPP motions.
`Analyze options for possible relief from protective order, and conduct legal research.
`Review filings and researching opposition to Anti-SLAPP motions.
`Analyze options for possible relief from protective order, and conduct legal research.
`Draft memorandum on possible relief from protective order, and conduct legal research.
`Anti-SLAPP Litigation book ordered for Todd Gegorian's client
`Review communications and documents in preparation for team meeting on opposition to Anti-SLAPP motions
`(1.5); participate in team meeting (0.7).
`Becker, Matthew
`Rios Ojeda, Adrian Matthew Prepare for and confer with team regarding work flow, caselaw research, and response strategy.
`Rios Ojeda, Adrian Matthew Research caselaw on Anti-SLAPP fees to determine exposure.
`Review and analyze motion to leave to intervene, court of appeals order, and Anti-SLAPP motion (2.0); research
`caselaw on anti-SLAPP fees awarded to determine exposure and law of the case doctrine to determine strength
`of defense (5.3).
`Revise memorandum on possible relief from protective order, conduct legal research, and correspondence with
`team.
`Assist with oppositions to Anti-SLAPP motions, and correspondence with team.
`Conduct further research on Anti-SLAPP fees awarded and analyze applicability to Plaintiffs' motion to
`determine exposure.
`Rios Ojeda, Adrian Matthew
`Rios Ojeda, Adrian Matthew Research caselaw regarding protected First Amendment activity to determine strength of defense.
`Research case law concerning opposition to Anti-SLAPP motions and oversee research by more junior
`associates.
`Research case law concerning opposition to Anti-SLAPP motions and oversee research by more junior
`associates.
`
`Lavin, Chris
`Becker, Matthew
`Lavin, Chris
`Becker, Matthew
`Lavin, Chris
`Lavin, Chris
`Disbursement
`
`Rios Ojeda, Adrian Matthew
`
`Lavin, Chris
`Lavin, Chris
`
`Becker, Matthew
`
`Becker, Matthew
`
`2/10/2023
`
`
`
`5.00
`
`
`
`4,125.00
`
`2/10/2023
`
`
`
`1.20
`
`
`
`1,290.00
`
`2/11/2023
`2/13/2023
`
`3.00
`
`
`1.60
`
`2,475.00
`
`
`1,720.00
`
`2/13/2023
`
`
`
`0.50
`
`
`
`537.50
`
`2/13/2023
`
`
`
`3.70
`
`
`
`2,719.50
`
`2/14/2023
`2/14/2023
`
`0.80
`
`
`2.30
`
`860.00
`
`1,690.50
`
`
`2/15/2023
`2/15/2023
`2/15/2023
`2/16/2023
`2/16/2023
`2/17/2023
`2/7/2023
`
`2.70
`
`
`3.20
`
`0.30
`
`1.60
`
`0.40
`
`1.50
`
`1.00
`
`2,902.50
`
`
`3,440.00
`322.50
`
`
`1,720.00
`430.00
`
`
`1,612.50
`306.32
`
`
`2/17/2023
`2/17/2023
`2/19/2023
`
`2.20
`
`
`1.20
`
`4.50
`
`2,365.00
`
`882.00
`
`
`3,307.50
`
`2/20/2023
`
`
`
`7.30
`
`
`
`5,365.50
`
`2/21/2023
`2/21/2023
`
`0.80
`
`
`0.30
`
`860.00
`
`
`322.50
`
`2/21/2023
`2/22/2023
`
`3.80
`
`
`3.60
`
`2,793.00
`
`
`2,646.00
`
`2/22/2023
`
`
`
`2.30
`
`
`
`2,472.50
`
`2/23/2023
`
`
`
`5.90
`
`
`
`6,342.50
`
`

`

`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 3 of 6
`
`2/23/2023
`
`
`
`6.00
`
`
`
`4,950.00
`
`Li, Su
`
`Conduct research on N-P doctrine. Discuss with supervising attorney.
`
`2/24/2023
`2/24/2023
`2/24/2023
`2/24/2023
`2/24/2023
`2/24/2023
`2/26/2023
`
`4.30
`
`
`1.90
`
`0.80
`
`4.00
`
`1.30
`
`1.20
`
`3.00
`
`3,160.50
`
`
`2,042.50
`860.00
`
`
`3,300.00
`
`1,397.50
`
`1,434.00
`
`2,475.00
`
`2/27/2023
`
`
`
`5.80
`
`
`
`4,263.00
`
`2/27/2023
`2/27/2023
`2/27/2023
`
`1.60
`
`
`4.90
`
`3.00
`
`1,720.00
`
`
`5,267.50
`
`2,475.00
`
`2/27/2023
`
`
`
`6.50
`
`
`
`6,987.50
`
`2/28/2023
`2/28/2023
`2/28/2023
`2/28/2023
`2/28/2023
`3/1/2023
`3/1/2023
`3/1/2023
`3/1/2023
`
`0.50
`
`
`2.50
`
`4.40
`
`3.70
`
`2.00
`
`1.30
`
`6.20
`
`0.80
`
`1.50
`
`537.50
`
`1,837.50
`
`
`4,730.00
`
`4,421.50
`
`1,650.00
`
`1,397.50
`
`4,557.00
`956.00
`
`
`1,612.50
`
`3/1/2023
`
`
`
`1.70
`
`
`
`1,827.50
`
`3/2/2023
`3/2/2023
`
`0.80
`
`
`5.00
`
`860.00
`
`4,125.00
`
`
`3/2/2023
`3/2/2023
`3/2/2023
`3/3/2023
`
`1.80
`
`
`0.40
`
`11.10
`
`6.60
`
`1,935.00
`
`430.00
`
`
`8,158.50
`
`4,851.00
`
`3/3/2023
`3/3/2023
`3/3/2023
`3/3/2023
`3/5/2023
`3/5/2023
`3/6/2023
`3/6/2023
`
`3.40
`
`
`2.20
`
`0.70
`
`2.00
`
`5.20
`
`0.40
`
`5.10
`
`0.80
`
`3,655.00
`
`
`2,629.00
`752.50
`
`
`1,650.00
`
`5,590.00
`430.00
`
`
`6,094.50
`860.00
`
`
`3/6/2023
`
`
`
`1.00
`
`
`
`1,075.00
`
`3/6/2023
`
`
`
`3.00
`
`
`
`2,475.00
`
`3/6/2023
`
`
`
`3.70
`
`
`
`2,719.50
`
`3/6/2023
`3/7/2023
`
`2.80
`
`
`1.00
`
`3,010.00
`
`735.00
`
`
`3/7/2023
`
`
`
`4.20
`
`
`
`4,515.00
`
`3/7/2023
`3/7/2023
`3/8/2023
`
`2.30
`
`
`4.60
`
`6.20
`
`2,472.50
`
`
`5,497.00
`
`7,409.00
`
`3/8/2023
`
`
`
`0.80
`
`
`
`860.00
`
`Rios Ojeda, Adrian Matthew
`Becker, Matthew
`Becker, Matthew
`Li, Su
`Lavin, Chris
`Gregorian, Todd
`Li, Su
`
`Rios Ojeda, Adrian Matthew
`
`Lavin, Chris
`Becker, Matthew
`Li, Su
`
`Lavin, Chris
`
`Lavin, Chris
`
`Lavin, Chris
`Li, Su
`
`Becker, Matthew
`Gregorian, Todd
`Becker, Matthew
`Li, Su
`Becker, Matthew
`Lavin, Chris
`Gregorian, Todd
`Lavin, Chris
`
`Becker, Matthew
`
`Li, Su
`
`Prepare for and confer with team regarding work flow, caselaw research, and response strategy (1.3); conduct
`further research regarding protected First Amendment activity to determine strength of defense (3.0).
`Research case law for opposition to Anti-SLAPP motions.
`Lead team meeting regarding opposition to Anti-SLAPP motions.
`Conduct research on N-P doctrine. Attend team meeting.
`Analyze Anti-SLAPP motions, conduct legal and records research, and correspondence with team.
`Review research on Anti-SLAPP motion and direct further work; correspond with client re settlement.
`Conduct research on N-P doctrine.
`Prepare for and confer with associate team regarding key research findings, work streams, and strategy (1.4);
`create chart organizing both of Plaintiffs' motions to strike to determine risk (0.8); prepare outline of response
`to motion (3.6).
`Draft stipulation on stay of briefing and page limits for motions to strike (Anti-SLAPPs), conduct legal and
`records research, and correspondence with team and opposing counsel.
`Continue researching and outlining opposition to Anti-SLAPP motions, and discuss with legal team.
`Conduct research on N-P doctrine. Discuss with supervising attorney.
`Revise outline for opposition to motions to strike (Anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Revise outline for opposition to motions to strike (Anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Lavin, Chris
`Rios Ojeda, Adrian Matthew Review key court opinion, analyze applicability, and outline responsive motion.
`Continue researching and outlining opposition to Anti-SLAPP motions.
`Becker, Matthew
`Work on Anti-SLAPP oppositions and attention to related issues and new alter ego DJ complaint.
`Gregorian, Todd
`Conduct research on Anti-SLAPP and participate in writing the outline.
`Li, Su
`Continue to research Anti-SLAPP opposition, and oversee junior associates' work on same.
`Becker, Matthew
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Work on anti-Slapp opposition.
`Gregorian, Todd
`Revise statement of facts, conduct records research, and correspondence and discussions with team.
`Lavin, Chris
`Revise outline for opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence with team.
`Revise, finalize, and coordinate filing stipulation on page limits for motions to strike (anti-SLAPPs), and
`correspondence with team and opposing counsel.
`Draft outline for the motion.
`Revise outline for opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence with team.
`Lavin, Chris
`Continue to research Anti-SLAPP opposition, and oversee junior associates' work on same.
`Becker, Matthew
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Continue drafting outline for Anti-SLAPP opposition; further research and correspondence with team in support
`of same.
`Work on anti-SLAPP motions.
`Continue to research Anti-SLAPP opposition, and oversee junior associates' work on same.
`Revise the drafted outline.
`Continue to research and revise Anti-SLAPP opposition, and oversee junior associates' work on same.
`Revise outline for opposition to motions to strike (anti-SLAPPs), and correspondence with team.
`Work on anti-SLAPP motions.
`Prepare for and participate in team meeting on motions to strike (anti-SLAPPs).
`Continue to research and revise Anti-SLAPP opposition, and oversee junior associates' work on same (0.6);
`discuss same with legal team (0.4).
`Team meeting discussing outline. Discuss next steps division of work with teammates. Respond to comments
`and draft up the motion. Conduct further research for the motion.
`Prepare for and meet with team regarding opposition brief and strategy (1.0); outline and draft opposition
`motion (2.7).
`Revise outline for opposition to motions to strike (anti-SLAPPs), conduct records research, and correspondence
`with team.
`Lavin, Chris
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Analyze opposition to motions to strike (anti-SLAPPs), revise outline, conduct legal and records research, and
`correspondence with team.
`Draft administrative motion for relief from protective order, conduct legal and records research, and
`correspondence with team.
`Work on anti-SLAPP motions and attention to new alter ego declaratory judgment suit.
`Work on protective order and relief from federal protective order motion.
`Revise outline and memorandum to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`
`Rios Ojeda, Adrian Matthew
`
`Lavin, Chris
`
`Lavin, Chris
`Gregorian, Todd
`Gregorian, Todd
`
`Lavin, Chris
`
`3/8/2023
`3/8/2023
`3/9/2023
`
`5.60
`
`
`1.00
`
`0.50
`
`6,020.00
`
`735.00
`
`
`367.50
`
`3/9/2023
`3/9/2023
`3/10/2023
`3/10/2023
`
`2.60
`
`
`0.80
`
`5.40
`
`1.00
`
`2,795.00
`
`860.00
`
`
`6,453.00
`825.00
`
`
`Revise, finalize, and coordinate filing of administrative motion for relief from protective order and supporting
`documents, conduct legal and records research, and correspondence and discussions with team.
`Lavin, Chris
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Continue research in support of Anti-SLAPP opposition.
`Work on anti-SLAPP opposition brief and team meeting re same.
`Work on drafting oppotion to anti-SLAPP motion.
`
`Lavin, Chris
`Becker, Matthew
`Gregorian, Todd
`Li, Su
`
`

`

`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 4 of 6
`
`3/10/2023
`
`
`
`2.50
`
`
`
`2,687.50
`
`3/10/2023
`3/10/2023
`3/11/2023
`3/11/2023
`3/12/2023
`
`7.20
`
`
`9.60
`
`1.10
`
`3.90
`
`6.30
`
`7,740.00
`
`
`7,056.00
`
`1,182.50
`
`4,192.50
`
`6,772.50
`
`3/12/2023
`3/12/2023
`3/12/2023
`
`8.80
`
`
`3.00
`
`3.60
`
`9,460.00
`
`
`2,475.00
`
`4,302.00
`
`Becker, Matthew
`
`Continue to research and revise Anti-SLAPP opposition, and oversee junior associates' work on same.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Lavin, Chris
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), and correspondence with team.
`Lavin, Chris
`Continue to research and revise Anti-SLAPP opposition, and oversee junior associates' work on same.
`Becker, Matthew
`Continue to research and revise Anti-SLAPP opposition, and oversee junior associates' work on same.
`Becker, Matthew
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Work on drafting oppotion to anti-SLAPP motion.
`Work on anti-SLAPP opposition and sanctions motion.
`
`Lavin, Chris
`Li, Su
`Gregorian, Todd
`
`3/13/2023
`3/13/2023
`
`4.00
`
`
`7.80
`
`3,300.00
`
`
`8,385.00
`
`Li, Su
`Becker, Matthew
`
`3/13/2023
`
`
`
`0.60
`
`
`
`645.00
`
`Lavin, Chris
`
`3/13/2023
`
`
`
`0.40
`
`
`
`430.00
`
`Lavin, Chris
`
`3/13/2023
`3/13/2023
`
`10.60
`
`
`9.60
`
`11,395.00
`
`
`11,472.00
`
`Lavin, Chris
`Gregorian, Todd
`
`3/14/2023
`3/14/2023
`3/14/2023
`
`3.30
`
`
`8.30
`
`2.60
`
`3,547.50
`
`
`9,918.50
`
`2,795.00
`
`Lavin, Chris
`Gregorian, Todd
`Becker, Matthew
`
`3/14/2023
`3/15/2023
`3/15/2023
`
`5.80
`
`
`3.00
`
`5.60
`
`6,235.00
`
`
`3,225.00
`
`6,692.00
`
`Lavin, Chris
`Becker, Matthew
`Gregorian, Todd
`
`3/15/2023
`
`
`
`1.80
`
`
`
`1,935.00
`
`Lavin, Chris
`
`3/15/2023
`
`
`
`2.30
`
`
`
`2,472.50
`
`Lavin, Chris
`
`3/15/2023
`
`
`
`5.50
`
`
`
`5,912.50
`
`Lavin, Chris
`
`3/16/2023
`3/16/2023
`
`7.60
`
`12.10
`
`
`4,408.00
`
`14,459.50
`
`
`Gallwas, Lawrence
`Gregorian, Todd
`
`Draft opposition to anti-SLAPP motion. Reply partner's question re the content and case law for the motion.
`Continue to research and revise Anti-SLAPP opposition.
`Analyze oppositions to administrative motion for relief from protective order, conduct legal research, and
`correspondence and discussions with team.
`Draft ex parte motion for extension of time for opposition to motions to strike (anti-SLAPPs), conduct legal and
`records research, and correspondence and discussions with team and opposing counsel.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct factual, legal, and records
`research, and correspondence and discussions with team.
`Work on anti-Slapp opposition briefs and ex parte motion.
`Revise ex parte motion for extension of time for opposition to motions to strike (anti-SLAPPs) and supporting
`documents, conduct legal and records research, and correspondence and discussions with team, court, and
`opposing counsel.
`Work on ex parte application and oppositions to anti-SLAPP motions.
`Continue to research and revise Anti-SLAPP opposition.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), draft supporting documents, conduct
`factual and records research, and correspondence and discussions with team.
`Continue to research and revise Anti-SLAPP opposition.
`Work on anti-slapp opposition briefs.
`Revise, finalize, and coordinate filing of ex parte motion for extension of time for opposition to motions to
`strike (anti-SLAPPs) and supporting documents, and correspondence and discussions with team, court, and
`opposing counsel.
`Prepare for hearing on ex parte motion for extension of time for opposition to motions to strike (anti-SLAPPs),
`conduct legal and records research, and correspondence and discussions with team.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Review Amazon's brief in opposition to the plaintiffs' anti-slapp motions and search for and organize the
`exhibits cited (3.4); draft the declaration of T. Gregorian in support of same (4.2).
`Prepare for and attend ex parte hearing (1.5); work on anti-slapp opposition brief (10.6).
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), assemble accompanying documents,
`conduct legal and records research, and correspondence and discussions with team.
`Lavin, Chris
`Continue to research and revise Anti-SLAPP opposition.
`Becker, Matthew
`Rios Ojeda, Adrian Matthew Draft opposition to anti-SLAPP motion, correspondence and discussions with team.
`Conduct case law research.
`Li, Su
`Prepare for and attend hearing on ex parte motion for extension of time for opposition to motions to strike
`(anti-SLAPPs), conduct legal and records research, and correspondence and discussions with team.
`Search for, analyze, and identify documents in support of Amazon's opposition to Insiders' special motions to
`strike (3.1); review draft opposition and organize exhibits re same (1.8).
`Prepare for and attend continued ex parte hearing; work on anti-slapp opposition brief; direct team work re
`same.
`Correspondence with team regarding Anti-SLAPP opposition.
`
`Lavin, Chris
`
`Gallwas, Lawrence
`
`Gregorian, Todd
`Becker, Matthew
`
`3/16/2023
`3/16/2023
`3/16/2023
`3/16/2023
`
`6.40
`
`
`4.60
`
`3.70
`
`4.50
`
`6,880.00
`
`
`4,945.00
`
`2,719.50
`
`3,712.50
`
`3/16/2023
`
`
`
`2.80
`
`
`
`3,010.00
`
`3/17/2023
`
`
`
`4.90
`
`
`
`2,842.00
`
`3/17/2023
`3/17/2023
`
`3.90
`
`
`0.70
`
`4,660.50
`
`752.50
`
`
`3/17/2023
`
`
`
`2.40
`
`
`
`2,580.00
`
`Lavin, Chris
`
`3/17/2023
`
`
`
`3.40
`
`
`
`3,655.00
`
`Lavin, Chris
`
`3/19/2023
`3/19/2023
`
`1.20
`
`
`4.00
`
`696.00
`
`4,780.00
`
`
`Gallwas, Lawrence
`Gregorian, Todd
`
`3/20/2023
`
`
`
`1.80
`
`
`
`1,044.00
`
`Gallwas, Lawrence
`
`3/20/2023
`3/21/2023
`
`3.20
`
`
`6.80
`
`3,440.00
`
`
`8,126.00
`
`Lavin, Chris
`Gregorian, Todd
`
`3/21/2023
`
`
`
`1.20
`
`
`
`1,290.00
`
`Lavin, Chris
`
`3/22/2023
`3/22/2023
`3/23/2023
`
`0.50
`
`
`4.10
`
`6.00
`
`537.50
`
`4,899.50
`
`
`7,170.00
`
`Becker, Matthew
`Gregorian, Todd
`Gregorian, Todd
`
`3/23/2023
`
`
`
`2.20
`
`
`
`2,365.00
`
`Lavin, Chris
`
`Prepare for and participate in hearing on ex parte motion for extension of time for opposition to motions to
`strike (anti-SLAPPs), conduct records research, and correspondence and discussions with team.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), assemble accompanying documents,
`conduct legal and records research, and correspondence and discussions with team.
`
`Draft declaration of T. Gregorian in support of Amazon's opposition to secured creditors' Anti-SLAPP motions.
`Work on privilege dispute and anti-SLapp opposition brief.
`Prepare for and meet with C. Lavin re Amazon's opposition to the secured creditors' Anti-SLAPP motions and
`collection of evidence in support of same (0.4); revise declaration of T. Gregorian in support of Amazon's
`opposition to secured creditors' Anti-SLAPP motions (1.4).
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct legal and records research, and
`correspondence and discussions with team.
`Work on privilege dispute motion and anti-slapp opposition brief.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), conduct records research, and
`correspondence and discussions with team.
`Continue to research and pull records supporting Anti-SLAPP opposition; email correspondence with team
`regarding same.
`Work on opposition to anti-slapp motion.
`Work on anti-slapp opposition brief.
`Analyze memorandum in opposition to motions to strike (anti-SLAPPs), conduct records research, and
`correspondence and discussions with team.
`
`

`

`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 5 of 6
`
`3/23/2023
`
`
`
`2.40
`
`
`
`2,580.00
`
`Becker, Matthew
`
`3/24/2023
`
`
`
`1.00
`
`
`
`1,075.00
`
`Lavin, Chris
`
`3/24/2023
`3/24/2023
`
`2.00
`
`
`2.50
`
`2,150.00
`
`
`2,987.50
`
`Lavin, Chris
`Gregorian, Todd
`
`3/24/2023
`
`
`
`1.00
`
`
`
`580.00
`
`Gallwas, Lawrence
`
`3/24/2023
`
`
`
`0.90
`
`
`
`967.50
`
`Becker, Matthew
`
`3/27/2023
`3/27/2023
`3/28/2023
`
`8.20
`
`
`1.00
`
`1.60
`
`8,815.00
`
`
`1,195.00
`
`1,912.00
`
`Lavin, Chris
`Gregorian, Todd
`Gregorian, Todd
`
`3/28/2023
`
`
`
`1.40
`
`
`
`1,505.00
`
`Becker, Matthew
`
`3/28/2023
`3/29/2023
`
`3.40
`
`
`5.20
`
`3,655.00
`
`
`6,214.00
`
`Lavin, Chris
`Gregorian, Todd
`
`3/29/2023
`3/29/2023
`
`5.10
`
`
`1.40
`
`2,958.00
`
`
`1,505.00
`
`Gallwas, Lawrence
`Becker, Matthew
`
`3/29/2023
`
`
`
`6.80
`
`
`
`7,310.00
`
`Lavin, Chris
`
`3/30/2023
`3/31/2023
`
`8.80
`
`
`3.60
`
`9,460.00
`
`
`4,302.00
`
`Lavin, Chris
`Gregorian, Todd
`
`3/31/2023
`
`
`
`3.20
`
`
`
`3,440.00
`
`Lavin, Chris
`
`Continue to research and pull records supporting Anti-SLAPP opposition; email correspondence with team
`regarding same.
`Prepare for and participate in team meeting on oppositions to special motions to strike (anti-SLAPPs), and
`correspondence with team.
`Analyze memorandum in opposition to motions to strike (anti-SLAPPs), conduct records research, and
`correspondence and discussions with team.
`Work on anti-slapp opposition brief and privilege motion filing; team meeting re pending tasks.
`Review and collect potential evidence in support of Amazon's opposition to plaintiffs' special motions to strike
`(0.6); transmit materials to Amazon's local counsel, M. Baratz, for review and analysis (0.4).
`Continue to research and pull records supporting Anti-SLAPP opposition; email correspondence with team
`regarding same.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs) and supporting declaration, conduct
`records research, and correspondence and discussions with team.
`Work on antislapp opposition.
`Work on anti-SLAPP opposition briefs.
`Continue to research and pull records supporting Anti-SLAPP opposition; email correspondence with team
`regarding same.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs) and supporting declaration, conduct
`records research, and correspondence and discussions with team.
`Work on anti-SLAPP opposition briefs.
`Review and confirm the accuracy of the legal and factual citations in Amazon's opposition to plaintiff's special
`motion to strike (anti-SLAPP).
`Assist with preparing opposition for sealing, and with related revisions.
`
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), supporting declaration, and exhibits,
`conduct records research, propose redactions to the same, and correspondence and discussions with team.
`Revise supporting declaration in opposition to motions to strike (anti-SLAPPs) and exhibits, conduct records
`research, and correspondence and discussions with team.
`Attend to anti-SLAPP including revise supporting declaration and state court discovery issues.
`Revise memorandum in opposition to motions to strike (anti-SLAPPs), supporting declaration in opposition to
`motions to strike (anti-SLAPPs) and exhibits, conduct records research, and correspondence and discussions
`with team.
`
`

`

`Case 5:18-md-02834-BLF Document 893-4 Filed 07/29/23 Page 6 of 6
`
`Hrs
`
`Date
`1/30/2023
`1/30/2023
`1/31/2023
`2/1/2023
`
`2/2/2023
`
`2/3/2023
`
`2/6/2023
`
`2/7/2023
`
`2/8/2023
`
`2/10/2023
`2/2/2023
`
`2/6/2023
`2/7/2023
`
`2/8/2023
`2/10/2023
`
`2/23/2023
`3/7/2023
`
`3/10/2023
`
`3/14/2023
`3/20/2023
`
`3/24/2023
`
`3/27/2023
`
`3/28/2023
`3/29/2023
`
`3/2/2023
`
`3/24/2023
`
`0.7
`0.5
`0.5
`0.4
`
`2.5
`
`2.6
`
`1.2
`
`1.3
`
`1.7
`
`0.4
`0.5
`
`0.8
`0.5
`
`1.6
`0.5
`
`0.2
`0.1
`
`1.5
`
`0.2
`0.1
`
`3
`
`3
`
`4
`0.2
`
`1
`
`4.7
`
`Rate
`
`950.00
`1,120.00
`1,120.00
`950.00
`
`Amt
`
`Timekeeper
`665.00 Emma Marshak
`560.00 Michael Baratz
`560.00 Michael Baratz
`380.00 Emma Marshak
`
`950.00
`
`2,375.00 Emma Marshak
`
`950.00
`
`2,470.00 Emma Marshak
`
`950.00
`
`1,140.00 Emma Marshak
`
`950.00
`
`1,235.00 Emma Marshak
`
`950.00
`
`1,615.00 Emma Marshak
`
`950.00
`1,120.00
`
`1,120.00
`1,120.00
`
`1,120.00
`1,120.00
`
`380.00 Emma Marshak
`560.00 Michael Baratz
`
`896.00 Michael Baratz
`560.00 Michael Baratz
`
`1,792.00 Michael Baratz
`560.00 Michael Baratz
`
`1,120.00
`1,120.00
`
`224.00 Michael Baratz
`112.00 Michael Baratz
`
`1,120.00
`
`1,680.00 Michael Baratz
`
`1,120.00
`1,120.00
`
`224.00 Michael Baratz
`112.00 Michael Baratz
`
`1,120.00
`
`3,360.00 Michael Baratz
`
`1,120.00
`
`3,360.00 Michael Baratz
`
`1,120.00
`1,120.00
`
`4,480.00 Michael Baratz
`224.00 Michael Baratz
`
`950.00
`
`950.00 Emma Marshak
`
`Steptoe Anti-SLAPP Entries (Q1 2023)
`Description
`Review and analyze anti-Slapp motions
`Review and analyze motion to strike
`Review and analyze motion to strike regarding anti-Slapp and proposed response
`Review and analyze anti-SLAPP motions
`Review and analyze anti-SLAPP motions, including appendix and request for judicial notice;
`prepare pro hac vice application for California state court; prepare pro hac vice application for
`N.D. Cal.
`Review and analyze email correspondence regarding anti-SLAPP motions, anti-SLAPP
`motions, and letters filed in N.D. Cal. case.
`Review and analyze anti-SLAPP motions; review and analyze correspondence related to
`stipulations
`Review and analyze anti-SLAPP motions; confer with A. Schwartz regarding California state
`court anti-SLAPP motions best practices
`Discuss anti-SLAPP motions with M. Baratz; correspond with C. Lavin regarding same; review
`and analyze correspondence; review and analyze anti-SLAPP motions
`Meet with T. Gregorian, C. Lavin, M. Baratz, and other Fenwick attorneys regarding anti-
`SLAPP opposition
`Review and analyze motion to strike regarding SLAPP
`
`Review and analyze emails regarding joint stipulation for receiver reports; review and consider motion to strike
`Review and consider responses to motion to strike
`Prepare and send email to T. Gregorian and C. Lavin regarding consent for service; review and
`analyze motion to strike; confer with E. Marshak regarding opposition to motion to strike.
`Confer with Fenwick regarding response to anti-SLAPP motion
`Prepare and send email to T. Gregorian and C. Lavin regarding page limits for anti-SLAPP brief
`and conferring with opposing counsel; prepare and send email to T. Gregorian regarding
`receiver financing and what occurs if plaintiffs stop funding receivership
`Prepare and send email to T. Gregorian and C. Lavin regarding SLAPP opposition.
`
`Review and consider strategy regarding general denial vs specific denial for Answer and Counterclaim to
`declaratory judgment action; call with E. Marshak regarding Answer and Counterclaim for declaratory
`judgment action; review and analyze stipulated protective order; prepare and send email to T. Gregorian
`regarding suggested revisions on stipulated protective order; review and analyze E. Marshak email regarding
`equitable subordination and gravamen of claim as compared with anti-SLAPP