Filing # 194252076 E-Filed 03/18/2024 03:13:37 PM
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`NOT A CERTIFIED COPY
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`B
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/18/2024 03:13:37 PM
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`

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`NOT A CERTIFIED COPY
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`Bill To:
`Richards, Wesley
`1001 SW Charcoal Ave
`Port St. Lucie, FL 34953
`
`Time Entries
`
`Time Entries
`
`2/8/2023
`Review documents from client in preparation for meeting with
`client. Meeting with client to discuss background facts and
`how to proceed.
`2/22/2023
`Review/analyze the Standing Order for Case Management and
`Complaint. Research elements for Fraud in the Inducement;
`Fraudulent misrepresentation; quatum meruit; and unjust
`enrichment.
`2/24/2023
`Review/analyze client's outline of key points for lawsuit
`3/3/2023
`Review additional information from client. Draft Motion to
`Dismiss.
`3/8/2023
`Telephone conference with client re Motion to Dismiss.
`Revise/finalize & file.
`
`Coke Employment Law
`
`Issue Date
`
`1/30/2024
`
`20231010 - Cheney Bros., Inc.
`
`Email
`
`Wes300ZX@gmail.com
`
`Coke, Beth
`
`Rate
`
`$395.00
`
`Hours
`
`2.10
`
`Coke, Beth
`
`$395.00
`
`2.90
`
`Coke, Beth
`
`$395.00
`
`0.75
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`1.70
`
`0.80
`
`Sub
`
`$829.50
`
`$1,145.50
`
`$296.25
`
`$671.50
`
`$316.00
`
`I-326
`
`Page 1 of 4
`
`

`

`Coke, Beth
`
`Rate
`
`$395.00
`
`Hours
`
`0.25
`
`Sub
`
`$98.75
`
`Coke, Beth
`
`$395.00
`
`1.50
`
`$592.50
`
`Coke, Beth
`
`$395.00
`
`0.20
`
`$79.00
`
`Coke, Beth
`
`Coke, Beth
`
`$395.00
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`Coke, Beth
`
`$395.00
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`0.40
`
`Time Entries
`
`3/9/2023
`Review email from O/C re dates for my client's deposition and
`scheduling hearing on motion to dismiss. Confer with client re
`same and how to proceed.
`3/10/2023
`Review Notice of Production from Non-Party, First
`Interrogatories to Defendant and Request for Production to
`Defendant. Outline information/documents needed from client
`for response
`3/13/2023
`Correspond with O/C re setting Motion to Dismiss for hearing
`and Defendant's position that it is inappropriate to respond to
`discovery or take Defendant's Deposition until the MTD is
`ruled on.
`3/20/2023
`Prepare Motion to Stay Discovery pending ruling on MTD.
`3/21/2023
`Correspond with client about the subpoena to Presidential
`Aviation and whether to file an objection. Review request for
`dates for hearing on MTD from office of opposing counsel and
`respond.
`4/11/2023
`Review Plaintiff's Motion to Compel Discovery. Confer with
`client re same.
`5/18/2023
`Hearing on Plaintiff's Motion to Compel and Defendant's
`Motion to Special Set Hearing. Prepare for and argue
`Defendant's Motion to Dismiss. Update client re same.
`5/22/2023
`Begin drafting responses to discovery.
`5/25/2023
`Telephone conference with client regarding responses to
`Interrogatories and documents needed to respond to RFP.
`Continue preparing discovery responses. Review/analyze
`documents provided by client.
`5/26/2023
`Finish draft of discovery responses for client review. Review
`email regarding one correction. Revise per client's email.
`5/30/2023
`Finalize discovery responses and serve. Review email from
`opposing counsel regarding good faith attempt to resolve
`objections raised.
`5/31/2023
`Review Second Interrogatories and 2nd Request for Production
`of Documents to Defendant. Conference with client re same.
`6/1/2023
`Review/Analyze Plaintiff's Amended Complaint. Telephone
`Conference with client re same and filing Motion to Dismiss
`Amended Complaint..
`6/2/2023
`Review Motion to Compel better responses to first set of
`discovery requests.
`6/6/2023
`Correspond with office of O/C re scheduling hearing on Motion
`to Compel Deposition and Better Discovery responses. Review
`Ntc of Hearing.
`6/9/2023
`Drafting Motion to Dismiss Plaintiff's Amended Complaint.
`6/12/2023
`Revise/Finalize and File MTD amended COmplaint.
`
`NOT A CERTIFIED COPY
`
`0.75
`
`0.40
`
`0.40
`
`4.70
`
`1.50
`
`2.70
`
`0.75
`
`0.50
`
`0.75
`
`0.70
`
`$296.25
`
`$158.00
`
`$158.00
`
`$1,856.50
`
`$592.50
`
`$1,066.50
`
`$296.25
`
`$197.50
`
`$296.25
`
`$276.50
`
`$158.00
`
`Coke, Beth
`
`$395.00
`
`0.10
`
`$39.50
`
`Coke, Beth
`
`Coke, Beth
`
`$395.00
`
`$395.00
`
`1.20
`
`0.50
`
`$474.00
`
`$197.50
`
`I-326
`
`Page 2 of 4
`
`

`

`Time Entries
`
`6/22/2023
`Confer with client about supplementing discovery responses
`based on motion to compel and proceeding with deposition.
`6/23/2023
`Correspond with O/C re dates for deposition and supplemental
`discovery responses. Schedule phone call with O/C to
`discuss same.
`6/27/2023
`Telephone conference with opposing counsel to discuss
`possible resolution of discovery disputes. Follow up with client
`re same. Review additional documents provided by client.
`6/28/2023
`Review/analyze additional documents provided by client. Send
`supplemental documents to O/C. Correspond re same.
`7/5/2023
`Preparing responses to second set of discovery. Correspond
`with client re same.
`7/7/2023
`Continue preparing response to second discovery requests.
`Correspond with client re same. Revise and serve second
`discovery responses.
`7/11/2023
`Draft Unopposed Motion to Special Set Hearing on MTD
`7/17/2023
`Meet with client to prepare for deposition.
`7/18/2023
`Prepare for and represent client at deposition (includes 2
`hours drive time)
`12/12/2023
`Prepare for and attend hearing on Motion to Dismiss Amended
`Complaint. Telephone conference with client to update
`regarding same and next steps.
`1/15/2024
`Review Notice of Voluntary Dismissal. Confer with client re
`same.
`1/24/2024
`Send email to opposing counsel regarding whether issue of
`fees can be resolved without filing motion with the court.
`Review response and reply
`1/26/2024
`Send follow up email to O/C re whether there will a response
`to the offer to resolve the issue of attorney's fees without filing
`a motion.
`1/29/2024
`Review email response from O/C regarding not responding to
`request for fees and seeking their fees for defending motion for
`fees.
`1/30/2024
`Research various issues, including the standard for awarding
`attorney's fees under Fla. Stat. 57.105, the affect of voluntary
`dismissal on motion for attorney's fees under Fla. Stat.
`57.105, showing reasonableness of hours and rate. Drafting
`Motion for fees.
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`Coke, Beth
`
`Coke, Beth
`
`$395.00
`
`$395.00
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`NOT A CERTIFIED COPY
`
`Coke, Beth
`
`Rate
`
`$395.00
`
`Coke, Beth
`
`$395.00
`
`Hours
`
`0.90
`
`0.20
`
`Sub
`
`$355.50
`
`$79.00
`
`Coke, Beth
`
`$395.00
`
`1.20
`
`$474.00
`
`Coke, Beth
`
`$395.00
`
`0.80
`
`$316.00
`
`1.30
`
`2.10
`
`0.30
`
`2.00
`
`5.50
`
`1.25
`
`0.25
`
`0.50
`
`Coke, Beth
`
`$395.00
`
`0.10
`
`Coke, Beth
`
`$395.00
`
`0.10
`
`Coke, Beth
`
`$395.00
`
`2.50
`
`$513.50
`
`$829.50
`
`$118.50
`
`$790.00
`
`$2,172.50
`
`$493.75
`
`$98.75
`
`$197.50
`
`$39.50
`
`$39.50
`
`$987.50
`
`Total (USD)
`
`$17,597.25
`
`I-326
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`Page 3 of 4
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