Case 5:18-md-02834-BLF Document 903-4 Filed 09/15/23 Page 1 of 2
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`Exhibit 3
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`Exhibit 3
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`Case 5:18-md-02834-BLF Document 903-4 Filed 09/15/23 Page 2 of 2
`
`Date
`
`Timekeeper
`
`Hrs
`
`Requested
`Rate
`
`Requested
`Amt
`
`Actual
`Rate
`
`Billed Amt
`
`Description
`
`2/28/2023 Lavin, Chris
`2/28/2023 Michael Baratz
`
`1.50
`
`0.50
`
`
`$743.00
`$955.00
`
`$1,114.50
`$477.50
`
`$1,075.00 $1,612.50 Analyze PersonalWeb investors' complaint, conduct legal research, and correspondence with team.
`Review and analyze complaint regarding alter ego declaration.
`$1,120.00 $560.00
`
`3/1/2023 Michael Baratz
`
`0.50
`
`
`$955.00
`
`$477.50
`
`$1,120.00 $560.00
`
`3/2/2023
`
`Lavin, Chris
`
`3.20
`
`
`$743.00
`
`$2,377.60
`
`$1,075.00 $3,440.00
`
`Review and analyze Amazon complaint; consider strategy regarding protective order.
`Analyze PersonalWeb investors' complaint, conduct legal research, and correspondence and
`discussions with team.
`
`3/2/2023 Michael Baratz
`
`1.10
`
`
`$955.00
`
`$1,050.50
`
`$1,120.00 $1,232.00
`
`3/3/2023
`
`Lavin, Chris
`
`1.60
`
`
`$743.00
`
`$1,188.80
`
`$1,075.00 $1,720.00
`
`3/7/2023
`
`Lavin, Chris
`
`2.50
`
`
`$743.00
`
`$1,857.50
`
`$1,075.00 $2,687.50
`
`3/8/2023
`
`Lavin, Chris
`
`
`
`0.70
`
`$743.00
`
`$520.10
`
`$1,075.00 $752.50
`
`3/9/2023 Michael Baratz
`
`
`
`0.50
`
`$955.00
`
`$477.50
`
`$1,120.00 $560.00
`
`Review and analyze Fenwick strategy email regarding settlement; review and analyze complaint for
`declaratory judgment; plan and prepare for call with T. Gregorian, C. Lavin and E. Marshak regarding
`Amazon strategy; call with T. Gregorian, C. Lavin, and E. Marshak regarding Amazon strategy regarding
`protective order and complaint for declaratory judgment.
`Analyze PersonalWeb investors' complaint, conduct legal research, and correspondence and
`discussions with team.
`Analyze options to consolidate Superior Court actions, conduct legal and records research, and
`correspondence with team.
`Analyze options to consolidate Superior Court actions, conduct legal and records research, and
`correspondence with team.
`
`Prepare and send email to E. Marshak regarding drafting Answer and Counterclaim to declaratory
`judgment action; review and analyze email from T. Gregorian regarding consolidation; review and
`analyze motion for relief from protective order regarding using investor evidence in the superior court
`action.
`
`3/9/2023
`
`Emma Marshak
`
`
`
`2.00
`
`$745.00
`
`$1,490.00
`
`$950.00
`
`3/10/2023 Emma Marshak
`3/16/2023 Emma Marshak
`3/22/2023 Emma Marshak
`3/23/2023 Emma Marshak
`
`5.60
`
`
`0.50
`
`4.90
`
`8.80
`
`$745.00
`$745.00
`$745.00
`$745.00
`
`$4,172.00
`$372.50
`$3,650.50
`$6,556.00
`
`$950.00
`$950.00
`$950.00
`$950.00
`
`$1,900.00 Review and analyze motion for declaratory judgment; review and analyze correspondence.
`Meet with M. Baratz regarding answer to declaratory judgment complaint; draft answer to declaratory
`judgment complaint.
`$5,320.00
`Review and analyze correspondence; draft answer.
`$475.00
`$4,655.00 Draft answer and counterclaim.
`$8,360.00 Draft answer and counterclaim.
`
`3/28/2023 Lavin, Chris
`
`
`
`0.70
`
`$743.00
`
`$520.10
`
`$1,075.00 $752.50
`
`Analyze declaratory judgment complaint, conduct legal and records research, and correspondence and
`discussions with team and opposing counsel.
`
`3/28/2023 Emma Marshak
`
`
`
`1.50
`
`$745.00
`
`$1,117.50
`
`$950.00
`
`$1,425.00 Revise draft answer and counterclaim; call with M. Baratz regarding same.
`
`3/29/2023 Lavin, Chris
`3/29/2023 Emma Marshak
`
`0.80
`
`
`3.60
`
`$743.00
`$745.00
`
`$594.40
`$2,682.00
`
`Draft stipulation extending deadline on declaratory judgment complaint, conduct legal and records
`research, and correspondence and discussions with team and opposing counsel.
`$1,075.00 $860.00
`$950.00
`$3,420.00 Revise answer and counterclaim for declaratory judgment.
`
`3/30/2023 Lavin, Chris
`
`
`
`0.40
`
`$743.00
`
`$297.20
`
`$1,075.00 $430.00
`
`Analyze PersonalWeb investors' discovery, and correspondence with team.
`
`3/30/2023 Gregorian, Todd
`
`
`
`2.00
`
`$649.27
`
`$1,298.54
`
`$1,195.00 $2,390.00 Phone conference and discovery work including attention to new written discovery.
`
`3/30/2023 Michael Baratz
`
`
`
`0.40
`
`$955.00
`
`$382.00
`
`$1,120.00 $448.00
`
`3/31/2023 Lavin, Chris
`
`
`
`1.20
`
`$743.00
`
`$891.60
`
`$1,075.00 $1,290.00
`
`3/31/2023 Lavin, Chris
`
`
`
`0.40
`
`$743.00
`
`$297.20
`
`$1,075.00 $430.00
`
`3/31/2023 Lavin, Chris
`
`1.30
`
`
`$743.00
`
`$965.90
`
`$1,075.00 $1,397.50
`
`Call with T. Gregorian regarding status of settlement conference and declaratory judgment action.
`Coordinate opening new matter, conduct records research, and correspondence and discussions with
`team and client.
`Coordinate responses to PersonalWeb investors' discovery, conduct records research, and
`correspondence with team.
`Draft proposed stipulation to consolidate actions, conduct legal and records research, and
`correspondence with team and opposing counsel.
`
`3/31/2023 Li, Su
`
`
`
`4.00
`
`$419.00
`
`$1,676.00
`
`$825.00
`
`$3,300.00
`
`3/31/2023 Michael Baratz
`
`
`
`0.40
`
`$955.00
`
`$382.00
`
`$1,120.00 $448.00
`
`Conduct research on CA civil procedure (2 hours). Draft email to supervising attorney (0.5). Instruct
`assistant make shells for discovery requests (0.5). Prepare objections to discovery requests (1 hour).
`Review and analyze discovery requests from insiders; prepare and send email to T. Gregorian
`regarding discovery requests.
`
`Total Requested:
`
`$36,886.94
`
`
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