1153860120928000000000011 Docket #1100 Date Filed: …Cont.] CMO 5/4/2012. Communications with Sarah...

Case 11-53860-btb Doc 1100 Entered 09/28/12 16:58:40 Page 1 of 8

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1153860120928000000000011

Docket #1100 Date Filed: 9/28/2012

E X H I B I T 1

E X H I B I T 1

Case 11-53860-btb Doc 1100-1 Entered 09/28/12 16:58:40 Page 1 of 67

Exhibit 1Professionals Summary

NAMES OFPROFESSIONALS/

PARAPROFESSIONALS

YEARGRADUATEDFROM LAW

SCHOOL

HOURS BILLEDCURRENT

APPLICATION

2012RATE

TOTAL FORAPPLICATION

Partners:

Mark A. Hutchsion 1990 2.5 $205 $512.50

Joseph S. Kistler 1976 6.6 $550 $3,355.00

Michael K. Wall 1984 0.2 $205 $41.00

Kumen L. Taylor 1991 99.3 $205 $19,987.50

Scott A. Flinders 1998 2.8 $205 $574.00

Partners Total: 111.4 $24,470.00

Associates:

Jeffrey R. Hall 2005 0.7 $350 $245.00

Christian M. Orme 2006 169.7 $185 $31,394.50

Rik L. Wade 2009 3.7 $185 $684.50

Timothy R. Koval 2010 77.7 $185 $14,374.50

Associates Total: 251.8 $46,698.50

Paraprofessionals:

Seth D. Oxborrow 2012 82.7 $115 $9,510.50

Benjamin J. Trout N/A 8.3 $95 $788.50

Paraprofessionals Total: 91.0 $10,299.00

TOTAL & BLENDEDHOURLY RATE:

454.2 $225.91 $81,467.50


E X H I B I T 2

E X H I B I T 2


LITIGATION MATTERSEXHIBIT 2

FILE # CASE DESCRIPTION ATTY DATE TRANSACTION UNIT RATE AMNT

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] CMO 5/1/2012

Communications with Skyjack re: request for production of documents. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of Plaintiff's Amended Response to Defendant Ahern Rentals, Inc.'s Third Set of Interrogatories. 0.10 $185.00 $18.50

408


Communications with Plaintiff's counsel re: deposition of Callaway's sister and interview by Dr. Asarnow of mother. 0.10 $185.00 $18.50

408


Draft response to Plaintiff's Second Set of Request for Production of Documents to Defendant Ahern Rentals. 0.10 $185.00 $18.50

408


Communications with Kumen Taylor re: expert opinion on machine; receipt, review, and analysis of Plaintiff's Second Set of Request for Production of Documents to Defendant SkyJack, Inc. and Ahern Rentals. 0.50 $185.00 $92.50

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] KLT 5/1/2012

Review and analyze need for expert on design defect given Plaintiff's expert's opinion. 0.20 $205.00 $41.00

408


Analysis of expert witness needs given expert report from Plaintiff. 0.60 $205.00 $123.00

407Ahern adv. Loran Jay Parker CMO 5/1/2012

Communications with Tim Koval re: written discovery to be propounded on Parker to determine causation allegations and expert depositions. 0.30 $185.00 $55.50

407Ahern adv. Loran Jay Parker TRK 5/1/2012

Communicate with Chris Orme re: obtaining an expert medical witness and setting up depositions in this case. 0.20 $185.00 $37.00

416Ahern adv. Native Resources CMO 5/1/2012

Draft and execute Re-Notice of Motion on Plaintiff's Motion for Declaratory Relief. 0.20 $185.00 $37.00

409Ahern adv. Raymond David Jones CMO 5/1/2012

Receipt, review, and analysis of medical and billing records from Med-Care Solutions. 0.20 $185.00 $37.00

413Ahern v. Damelio Commercial Contracting CMO 5/1/2012

Communications with Tim Koval re: motion with court to reconsider previous ruling on motion to dismiss. 0.10 $185.00 $18.50

413Ahern v. Damelio Commercial Contracting TRK 5/1/2012

Communicate with Chris Orme re: drafting and filing a motion requesting that the judge reconsider dismissal. 0.10 $185.00 $18.50




422Legal Consultation [Risk] CMO 5/1/2012

Communications with Sarah Fisher re: Pepsco reimbursement for damaged equipment. 0.30 $185.00 $55.50

408


Communications with Kumen Taylor re: Mark Recard expert testimony; communications with opposing counsel re: expert deadlines and other depositions; communications with opposing counsel re: same; communications with Terry Dineen re: voc rehab and economic loss opinions; communications with Sarah Fisher re: production of operator's manual and parts manual. 1.60 $185.00 $296.00

408


Review of Plaintiff's expert report regarding the design defects. 0.20 $205.00 $41.00

408


Conference with Recard discussing Plaintiff's expert report. 0.30 $205.00 $61.50

408


Conferences with Plaintiff's counsel, with Terrence Dineen, with Sarah, with Skyjack's counsel discussing issues raised in Plaintiff's expert reports and how to prepare responses. 1.60 $205.00 $328.00


Communicate with Chris Orme re: obtaining insurance information in this case. 0.10 $185.00 $18.50


Send e-mail to opposing counsel to follow-up on the stipulation and order to extend the scheduling deadlines (including reviewing and re-sending the proposed pleading), the plaintiff's outstanding responses to discovery, and our provision of insurance information. 0.30 $185.00 $55.50


Communicate with opposing counsel to: (1) obtain information re: the scope of the plaintiff's claimed injuries and his medical expenses, (2) the provision of insurance information, and (3) the status of the case. 0.40 $185.00 $74.00


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 1 re: Plaintiff's Financial Status. 0.10 $185.00 $18.50





Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 2 re: Plaintiff's Prior Back/Hip Injuries. 0.10 $185.00 $18.50


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 5 re: Cumulative Expert Testimony and Limiting Experts to Reports, Job Files, and Deposition Testimony. 0.10 $185.00 $18.50


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 5 re: Empty Chair Argument. 0.10 $185.00 $18.50


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 7 re: Omnibus Motion in Limine. 0.10 $185.00 $18.50


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 8 re: Character Evidence. 0.10 $185.00 $18.50


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 3 re: Plaintiff's Inactive Commercial Driver's License. 0.20 $185.00 $37.00


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 4 re: Any Signs of Warnings Not Related to this Incident. 0.20 $185.00 $37.00


Receipt, review and analysis of Plaintiff's Reply in Support of Motion in Limine No. 9 re: Indemnity Owed by Plaintiff or Failure to Obtain Insurance. 0.30 $185.00 $55.50

408


Communications with Dr. Asarnow re: PTSD and TBI claims. 0.30 $185.00 $55.50

408


Telephone conference with Dr. Asarnow discussing TBI claim and need to set up examination and testing. 0.30 $205.00 $61.50


Communications with client representative re: production of insurance documents. 0.10 $185.00 $18.50


Communications with opposing counsel re: production of insurance documents. 0.20 $185.00 $37.00





Draft and execute Defendant Ahern Rentals, Inc.'s Twenty-Sixth Supplement to the Early Case Conference Disclosure Statement. 0.20 $185.00 $37.00


Draft and execute Defendant Ahern Rentals, Inc.'s Twenty-Seventh Supplement to the Early Conference Disclosure Statement. 0.20 $185.00 $37.00


Communications with opposing counsel re: production of medical records for most recent treatments. 0.10 $185.00 $18.50

408


Communications with Sarah Fisher re: production of manuals for equipment expert. 0.20 $185.00 $37.00

408


Review of correspondence from counsel chosen by Ahern's insurer to associate in as co-counsel. 0.10 $205.00 $20.50

408


Correspondence to insurer's co-counsel designee regarding Ahern's refusal to waive the conflict it has with that firm. 0.10 $205.00 $20.50

408


Telephone call with Sarah discussing conflict of interest with counsel insurer wants to associate in to case and regarding mediation. 0.30 $205.00 $61.50

408


Telephone conference with Jim Carlisle discussing association of counsel and pushing case toward mediation. 0.50 $205.00 $102.50

408


Review and analysis of agreement between Ironshore and Ahern that allows Ahern to use H&S as both SIR and post-SIR counsel, in light of Ironshore's request to associate counsel. 0.60 $205.00 $123.00


Communications with Sarah Fisher re: status of case, association of counsel with Bremer Whyte, and trial preparation. 0.20 $185.00 $37.00


Communications with Kumen Taylor re: status of case, association of counsel with Bremer Whyte, bankruptcy counsel approval, and trial preparation. 0.40 $185.00 $74.00





Communications with bankruptcy counsel re: status of case and association of counsel with Bremer Whyte. 0.40 $185.00 $74.00


Communications with Jim Carlisle re: status of case, association of counsel with Bremer Whyte, and trial preparation. 0.70 $185.00 $129.50

423 Ahern adv. Laura Catha CMO 5/7/2012Communications with Brian Ritz and Sarah Fisher re: new suit filed. 0.10 $185.00 $18.50


Communications with opposing counsel re: motions in limine and pre-trial conference. 0.10 $185.00 $18.50


Communications with Kumen Taylor re: tender of defense to Iron Shore, motions in limine, and communications with insurance counsel. 0.30 $185.00 $55.50

409Ahern adv. Raymond David Jones KLT 5/7/2012

Review correspondence from Sarah regarding discussion with Jim Carlisle and his desire to mediate the case. 0.10 $205.00 $20.50


Correspondence to Sarah and Tim regarding duty to cooperate under insurance policy and Ironshore's position. 0.10 $205.00 $20.50


Telephone call from Jim Carlisle regarding need for information regarding excess carrier. 0.10 $205.00 $20.50


Correspondence to Sarah requesting information regarding excess carrier on this case. 0.10 $205.00 $20.50


Correspondence to Ironshore's counsel regarding availability to discuss facts of case. 0.10 $205.00 $20.50


Review correspondence from Sarah regarding information about Ahern's excess carrier. 0.10 $205.00 $20.50


Correspondence to Jim Carlisle regarding Ahern's excess carrier information. 0.10 $205.00 $20.50


Review correspondence from Ironshore's counsel regarding conversing about case. 0.10 $205.00 $20.50


Correspondence to Ironshore's counsel regarding availability to discuss case. 0.10 $205.00 $20.50


Telephone call from Ironshore's counsel discussing thoughts on case and potential for mediation. 0.40 $205.00 $82.00





Communications with Tim Koval re: motion for reconsideration. 0.30 $185.00 $55.50


Review and evaluate procedural history of the New Jersey litigation in preparation of the motion for reconsideration. 1.20 $185.00 $222.00


Draft motion to reconsider the recent dismissal of the case. 1.70 $185.00 $314.50

400General Counsel Legal Consultation KLT 5/7/2012

(Ahern v. Rough Brothers) Telephone conference with Brian and Ahern's local counsel regarding collection action and responding to counterclaim. 0.60 $205.00 $123.00

408


Communications with Sarah Fisher re: engineering report from Plaintiff's expert. 0.10 $185.00 $18.50

408


Communications with opposing counsel re: NRCP 30(b)(6) depositions. 0.10 $185.00 $18.50

408


Communications with client representatives re: NRCP 30(b)(6) depositions. 0.10 $185.00 $18.50

408


Draft and execute Defendant Ahern Rentals, Inc.'s Eighteenth Supplement to its Early Case Conference Disclosure Statement. 0.20 $185.00 $37.00

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] TRK 5/8/2012

Draft the declaration of Sarah Fisher in support of the motion for partial summary judgment re: the plaintiff's claim for punitive damages. 0.50 $185.00 $92.50

408


Research case law and prior pleadings/templates re: motions for summary judgment on claims of punitive damages. 0.80 $185.00 $148.00

408


Research updated facts of the case in preparation of the motion for partial summary judgment re: the plaintiff's claim of punitive damages. 1.20 $185.00 $222.00

408


Prepare the motion for partial summary judgment re: the plaintiff's claim for punitive damages. 3.40 $185.00 $629.00


Communications with Kumen Taylor re: strategy for trial and opening statements. 0.20 $185.00 $37.00


Communications with Ahern and BK counsel re: new trial date. 0.80 $185.00 $148.00





Preparation for hearing on Plaintiff's motions in limine. 1.80 $185.00 $333.00


Attend hearing on Plaintiff's motions in limine and present arguments against motions. 2.90 $185.00 $536.50


Correspondence to Sarah with copies of agreement with Ironshore to use H&S as post SIR counsel. 0.10 $205.00 $20.50


Review and analysis of arguments for motions in limine. 0.40 $205.00 $82.00


Telephone call from Sarah discussing Ironshore's request to mediate. 0.40 $205.00 $82.00


Preparations for and attendance at hearing on motions in limine and calendar call. 2.80 $205.00 $574.00


Draft and finalize the motion to reconsider the court's dismissal of the case. 2.30 $185.00 $425.50

408


Receipt, review, and analysis of letter from opposing counsel re: NRCP 30(b)(6) deposition. 0.10 $185.00 $18.50

408


Communications with client re: employee to testify for NRCP 30(b)(6) deposition. 0.10 $185.00 $18.50

408


Communications with Kumen Taylor re: NRCP 30(b)(6) deposition designation. 0.10 $185.00 $18.50

408


Review and analysis of motion for summary judgment on punitive damages claim. 0.50 $185.00 $92.50

408


Corresondence to Tim regarding scheduling his deposition in this case. 0.10 $205.00 $20.50

408


Review and revise the motion for partial summary judgment to extinguish the plaintiff's claim for punitive damages. 1.30 $185.00 $240.50


Communications with counsel for Iron Shore re: preparation for mediation. 0.10 $185.00 $18.50


Communications with Kumen Taylor re: motion for reconsideration on hearing to include previous history of medical treatment. 0.30 $185.00 $55.50


Conference with Mark discussing Ironshore's dropping demand to associate counsel. 0.20 $205.00 $41.00


Analysis of how impeaching Plaintiff in view of court's ruling on Plaintiff's motion in limine. 0.20 $205.00 $41.00





Communications with Thomas Fell re: affidavit in support of motion for reconsideration. 0.10 $185.00 $18.50


Communications with Christina Williamson re: affidavit in support of motion for reconsideration. 0.10 $185.00 $18.50


Draft and revise affidavit for Thomas Fell in support of motion for reconsideration. 0.20 $185.00 $37.00


Draft and revise motion for reconsideration on motion to dismiss. 0.30 $185.00 $55.50


Draft and revise affidavit for Christina Williamson in support of motion for reconsideration. 0.40 $185.00 $74.00

408


Communications with all parties re: deposition of Plaintiff's sister. 0.10 $185.00 $18.50

408


Draft and execute Defendant Ahern Rentals, Inc.'s Nineteenth Supplement to its Early Case Conference Disclosure Statement. 0.20 $185.00 $37.00

408


Draft and execute letter to expert Mark Recard. 0.20 $185.00 $37.00

408


Telephone call with Terrence Dineen discussing strengths and weaknesses of defense of case. 0.50 $205.00 $102.50

408


Review and finalize motion for summary judgment re: punitive damages in this case, including additional analysis of the facts to preclude punitive damages in this case. 2.50 $185.00 $462.50


Draft and execute Defendant Ahern Rentals, Inc.'s Twenty-Eighth Supplement to the Early Case Conference Disclosure Statement. 0.20 $185.00 $37.00


Communications with Brian Ritz and Sarah Fisher re: status of case. 0.20 $185.00 $37.00


Communications with Sandy Oster from Iron Shore re: status of case and legal strategy. 0.20 $185.00 $37.00


Document production - Draft/revise Draft and execute Defendant Ahern Rentals, Inc.'s Twenty-Fourth Supplement to the Early Case Conference Disclosure Statement. 0.20 $185.00 $37.00





Review of correspondence from Ironshore adjuster requesting additional treatment records and information regarding Plaintiff. 0.10 $205.00 $20.50


Correspondence to Ironshore adjuster answering questions relating to Plaintiff's injuries. 0.70 $205.00 $143.50


Review of Plaintiff's pre-accident and some post-accident treatment records. 2.60 $205.00 $533.00

408


Draft and execute notice of deposition for Luetta Callaway. 0.20 $185.00 $37.00


Communications with Iron Shore representative re: Plaintiff's medical history and status of matter. 0.20 $185.00 $37.00


Communications with Kumen Taylor re: Plaintiff's medical history and status of matter. 0.30 $185.00 $55.50

408


Receipt, review, and analysis of Defendant Skyjack, Inc.'s Response to Plaintiff's Second Set of Request for Production of Documents. 0.20 $185.00 $37.00


Communications with Iron Shore counsel re: expert depositions and Connie Reyes deposition. 0.20 $185.00 $37.00


Plan and Prepare for - Communications with client representative re: settlement conference, status of case, production of records to Iron Shore. 1.00 $185.00 $185.00

408


Receipt, review, and analysis of Plaintiff's NRCP 30(b)(6) Notice of Deposition for SkyJack re: design of scissor lift. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of Plaintiff's NRCP 30(b)(6) Notice of Deposition for SkyJack re: financial situation. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of entry of order of stipulation and order to extend discovery deadlines. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of Plaintiff's NRCP 30(b)(6) Notice of Deposition for Ahern Rentals, Inc. re: its financial statements for past three years. 0.30 $185.00 $55.50




408


Draft, revise, and execute motion for partial summary judgment on punitive damages. 0.40 $185.00 $74.00

408


Telephone call with Mark Recard discussing logistics for inspection. 0.10 $205.00 $20.50

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] RLW 5/17/2012

Strategize deposition objection with Chris Orme. 0.20 $185.00 $37.00


Communications with Sarah Fisher re: preparation for mediation. 0.10 $185.00 $18.50


Communications with Iron Shore re: production of records for copying and medical history. 0.20 $185.00 $37.00

408


Communications with client re: status of production of documents. 0.10 $185.00 $18.50

408


Communications with client representatives re: NRCP 30(b)(6) depositions of Ahern in regards to its financials. 0.40 $185.00 $74.00

408


Research financial objections to depositions. 1.30 $185.00 $240.50

421Ahern adv. Larry Caudell [Capriati Construction] CMO 5/18/2012

Communications with client re: status of matter. 0.20 $185.00 $37.00

422Legal Consultation [Risk] CMO 5/18/2012

Legal research and analysis re: status of Victor Flores Medina case and whether suit was filed against Ahern. [No Charge]. - $185.00 $0.00

408


Receipt, review, and analysis of Plaintiff's Notice of Taking the Deposition of Ahern Rentals, Inc., Pursuant to NRCP 30(b)(6), Regarding : (A) Inspection Protocols and Procedures for its Scissor Lift Equipment; and (B) Inspection Procedures and Tasks Actually Administered on Equipment in Question. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of plaintiff's notice of taking the NRCP 30(b)(6) deposition of SkyJack, Inc. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of plaintiff's notice of taking the NRCP 30(b)(6) deposition of SkyJack, Inc. 0.30 $185.00 $55.50




408


Communications with client representatives re: Plaintiff's Notice of Taking the Deposition of Ahern Rentals, Inc., Pursuant to NRCP 30(b)(6), Regarding : (A) Inspection Protocols and Procedures for its Scissor Lift Equipment; and (B) Inspection Procedures and Tasks Actually Administered on Equipment in Question. 0.30 $185.00 $55.50

408


Communications with client representative re: Plaintiff's NRCP 30(b)(6) Notice of Deposition to Ahern Rentals re: prior incidents. 0.30 $185.00 $55.50

408


Correspondence to Sarah regarding inspection. 0.10 $205.00 $20.50

408


Review correspondence from Sarah regarding date for Tim's deposition. 0.10 $205.00 $20.50

408


Correspondence to Sarah regarding need to make Tim available for deposition. 0.10 $205.00 $20.50

408


Correspondence to Plaintiff's counsel regarding dates available for PMK deposition. 0.10 $205.00 $20.50

408


Telephone call with Sarah discussing document production. 0.20 $205.00 $41.00

408


Telephone call with Sarah discussing inability to locate 2003 operator manual for subject lift. 0.20 $205.00 $41.00

408


Research financial disclosures and whether they may be compelled through discovery. 1.40 $185.00 $259.00


Receipt, review, and analysis of Notice of Entry of Order granting American Family Mutual Insurance Company's Motion to Intervene. 0.10 $185.00 $18.50


Communications with New Jersey counsel re: affidavit in support of motion to reconsider. 0.30 $185.00 $55.50

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] RLW 5/22/2012 Draft deposition objection letter. 0.80 $185.00 $148.00


Communications with opposing party re: hearing on motion for declaratory judgment. 0.10 $185.00 $18.50





Communications with Kumen Taylor re: hearing on motion for declaratory judgment. 0.10 $185.00 $18.50


Communications with court re: hearing on motion for declaratory judgment. 0.30 $185.00 $55.50

416Ahern adv. Native Resources TRK 5/22/2012

Communicate with Chris Orme re: our strategy for replying to the opposition re: the motion for declaratory judgment. 0.20 $185.00 $37.00


Review and evaluate the opposition to the motion for declaratory relief. 0.70 $185.00 $129.50


Research and evaluate case law re: the defendant's arguments as raised in the opposition to the motion for declaratory relief. 0.80 $185.00 $148.00


Telephone call with Sarah discussing Doty case and Ironshore issues. 0.60 $205.00 $123.00

408


Review correspondence from Mark Recard regarding upcoming inspection. 0.10 $205.00 $20.50

408

Ahern adv. Darren Callaway [Hansen Mech. Cont.] MAH 5/23/2012

Develop discovery strategy and identify discovery tasks. 0.80 $205.00 $164.00

407Ahern adv. Loran Jay Parker MAH 5/23/2012

Evaluate legal issues, discovery tasks, and expert witness requirements for litigation. 0.80 $205.00 $164.00


Review and analysis of contract in support of reply in support of motion for declaratory relief. 0.90 $185.00 $166.50


Communicate with Chris Orme to develop strategy to draft the reply in support of the motion for declaratory relief. 0.70 $185.00 $129.50


Research and evaluate secondary sources and case law re: indemnity requirements under the rental contract. 0.90 $185.00 $166.50


Research and evaluate case law cited by Soil-Tech in support of its opposition to the motion for declaratory relief. 2.90 $185.00 $536.50


Draft the reply in support of the motion for declaratory relief. 5.10 $185.00 $943.50


Meeting with Kumen Taylor re: Iron Shore controversy and its impact with Jones. 0.60 $185.00 $111.00


Telephone call with Tom Fell on conference call with Ironshore to discuss strategy for that meeting. 0.20 $205.00 $41.00





Telephone call with Sarah discussing issues to be addressed with Ironshore in pending conference call. 0.20 $205.00 $41.00

409Ahern adv. Raymond David Jones MAH 5/23/2012

Evaluate litigation issues and tasks, including discovery, motion practice, trial preparations. 0.90 $205.00 $184.50


Communications with New Jersey counsel re: affidavit in support of motion to reconsider. 0.30 $185.00 $55.50


Draft and revise motion for reconsideration. 0.40 $185.00 $74.00

413Ahern v. Damelio Commercial Contracting KLT 5/23/2012

Review and analysis of Motion to Reconsider court's dismissal without prejudice of Ahern's complaint. 0.20 $205.00 $41.00

422Legal Consultation [Risk] KLT 5/23/2012

Teleconference with Ironshore reps and various legal counsel and Ahern discussing how the SIR is governed by Bankruptcy orders in Ahern's bankruptcy case. 1.10 $205.00 $225.50


Conference with Ahern, its Bankruptcy counsel and CA counsel discussing Doty case and Ironshore's insistence on tendering defense to B.T. Mancini. 1.50 $205.00 $307.50

408


Draft and revise objection letter to NRCP 30(b)(6) deposition for Ahern's financial information. 0.30 $185.00 $55.50

408


Review correspondence from Plaintiff's counsel regarding bumping out discovery deadlines. 0.10 $205.00 $20.50

408


Correspondence to Plaintiff's counsel agreeing to extend discovery deadlines to complete proposed discovery. 0.10 $205.00 $20.50

408


Review correspondence from Skyjack's counsel regarding extending discovery deadlines. 0.10 $205.00 $20.50


Finalize draft of the reply brief, incorporating opposing counsel's arguments into the reply. 2.60 $185.00 $481.00


Draft, revise, and execute Plaintiff's Motion for Reconsideration. 0.10 $185.00 $18.50





Conference with Mark Hutchison and Brian Ritz discussing issues to be addressed with Ironshore with the Doty case. 0.40 $205.00 $82.00


Correspondence to Brian Ritz with suggested language in letter to Ironshore. 0.50 $205.00 $102.50


Communications with Sarah Fisher re: declaration in support of Motion for Declaratory Relief. 0.10 $185.00 $18.50


Draft and revise Motion for Declaratory Relief. 0.60 $185.00 $111.00

416Ahern adv. Native Resources KLT 5/25/2012

Review and revise Reply to Native Resource's Opposition to Motion for Declaratory Relief. 1.70 $205.00 $348.50


Telephone call from Brian Ritz discussing letter to Ironshore discussing Doty case. 0.10 $205.00 $20.50

408


Review of correspondence from Mark Recard regarding need to reschedule inspection. 0.10 $205.00 $20.50

403Ahern adv. Frank Rodgriguez CMO 5/30/2012

Communications with insurance adjustor re: status of case and tender to TBR Construction. 0.10 $185.00 $18.50


Draft and execute supplement to reply in support of motion for declaratory relief. 0.40 $185.00 $74.00

408


Draft and execute Notice of Hearing of Ahern Rentals, Inc.'s Motion for Partial Summary Judgment. 0.20 $185.00 $37.00

408


Correspondence to Mark Recard regarding rescheduling inspection of lift. 0.10 $205.00 $20.50

408


Correspondence to all counsel regarding circulating a stipulation and order for extending discovery deadlines. 0.10 $205.00 $20.50

408


Telephone call from Sarah discussing deposition dates for Tim. 0.20 $205.00 $41.00


Communications with client representative re: preparation of case for mediation and communications with Iron Shore. 0.40 $185.00 $74.00


Telephone call from Sarah re Ironshore and Jim Carlisle position on mediation. 0.50 $205.00 $102.50


Correspondence to Sarah with suggested e-mail to Jim Carlisle. 0.60 $205.00 $123.00

408


Review of correspondence from Mark Recard regarding dates for rescheduling inspection of lift. 0.10 $205.00 $20.50




408


Correspondence to Mark Recard regarding available dates for lift inspection. 0.10 $205.00 $20.50

408


Review of stipulation and order to extend discovery deadlines. 0.20 $205.00 $41.00

423 Ahern adv. Laura Catha CMO 6/1/2012

Communications with client representative re: status of Catha matter and communications with Iron Shore. 0.20 $185.00 $37.00

407Ahern adv. Loran Jay Parker KLT 6/1/2012

Correspondence to Sarah regarding questions about claims during policy year 2008-2009. 0.10 $205.00 $20.50


Telephone call to Plaintiff's counsel regarding other claims in his policy year. 0.10 $205.00 $20.50


Telephone call from Plaintiff's counsel discussing issues of bankruptcy and how it may affect his client's claim. 0.20 $205.00 $41.00

403Ahern adv. Frank Rodgriguez CMO 6/4/2012

Communications with insurance representative re: status of case. 0.20 $185.00 $37.00

419 Ahern adv. John Vella CMO 6/4/2012

Communications with bankruptcy counsel re: proof of claim and motion to lift stay. 0.10 $185.00 $18.50

419 Ahern adv. John Vella CMO 6/4/2012Communications with Sarah Fisher re: litigation issues. 0.10 $185.00 $18.50

411Ahern adv. Juan Carlos Fuentes Amezcua CMO 6/4/2012

Communications with Daniel Simon's office, counsel for Plaintiff, re: Ahern dismissal. 0.10 $185.00 $18.50


Communications with bankruptcy counsel re: proof of claim and motion to lift stay? 0.10 $185.00 $18.50


Communications with Nancy Ball re: status of Amezcua matter. 0.20 $185.00 $37.00


Communications with Alan Westbrook, counsel for Stover, re: Ahern dismissal. 0.30 $185.00 $55.50

423 Ahern adv. Laura Catha CMO 6/4/2012Draft status letter to Jim Carlisle of Iron Shore. 1.00 $185.00 $185.00


Draft extensive email to Tim Koval and David Childress re: litigation and discovery tasks that need to be accomplished in the next two weeks, including expert retention, written discovery, medical record review. 0.30 $185.00 $55.50

408


Review correspondence from Sarah regarding PMK depositions for Ahern and Skyjack. 0.10 $205.00 $20.50




408


Correspondence to Plaintiff's counsel regarding status of Skyjack's PMK deposition. 0.10 $205.00 $20.50

408


Correspondence to Sarah regarding Ahern's PMK depositions not going forward next week. 0.10 $205.00 $20.50

408


Review of correspondence from Plaintiff's counsel regarding status of Skyjack PMK deposition. 0.10 $205.00 $20.50

408


Correspondence to Sarah regarding no depositions going forward next week. 0.10 $205.00 $20.50

408


Communications with client representative re: status of case. 0.10 $185.00 $18.50






Telephone call from Plaintiff's counsel regarding proposed settlement. 0.10 $205.00 $20.50


Telephone call from Plaintiff's counsel regarding bankruptcy issues affecting case. 0.40 $205.00 $82.00


Communications with chambers re: hearing for declaratory relief. 0.20 $185.00 $37.00

416Ahern adv. Native Resources KLT 6/11/2012

Correspondence to all counsel regarding new date for hearing on motion. 0.10 $205.00 $20.50




Receipt, review, and analysis of letter from opposing counsel re: opposition to motion for reconsideration. 0.10 $185.00 $18.50


Communications with opposing counsel re: opposition to motion for reconsideration. 0.20 $185.00 $37.00


Receipt, review, and analysis of Opposition to Plaintiff's Motion for Reconsideration. 0.20 $185.00 $37.00

408


Receipt, review, and analysis of notice of vacating the Deposition of Ahern Rentals, Inc. Pursuant to NRCP 30 (b)(6) regarding inspection protocols and procedures for its scissor lift equipment and for the actual equipment. 0.10 $185.00 $18.50




408


Receipt, review, and analysis of notice of vacating the Deposition of Ahern Rentals, Inc. pursuant to NRCP 30 (b)(6) regarding Ahern's knowledge of prior incidents. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of vacating the Deposition of SkyJack re: testing of sliding rail system. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of vacating the Deposition of Ahern Rentals re: financial condition. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of vacating the deposition of Skyjack, Inc. re: financial condition. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of vacating the deposition of Skyjack, Inc. re: prior accidents. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of vacating the deposition of Skyjack, Inc. re: remedial measures for defect or manufacturing defects. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of notice of entry of order granting plaintiff's motion to amend complaint. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of letter from opposing counsel re: status check change. 0.10 $185.00 $18.50

408


Communications with Kumen Taylor in preparation for Luetta Callaway. 0.20 $185.00 $37.00

408


Communications with Dr. Robert Asarnow in preparation for Luetta Callaway. 0.20 $185.00 $37.00

408


Draft deposition outline for Luetta Callaway. 0.70 $185.00 $129.50


Communications with bankruptcy counsel re: status of motion to stay and proof of claim. 0.10 $185.00 $18.50


Communications with bankruptcy counsel re: status of motion to stay and proof of claim. 0.10 $185.00 $18.50





Review and evaluate the opposition to the motion for reconsideration; develop strategy for responding to the same. 0.40 $185.00 $74.00

408


Receipt, review, and analysis of acceptance of service for second amended complaint. 0.10 $185.00 $18.50

408


Communications with Terry Dinneen in preparation for deposition of Luetta Callaway. 0.50 $185.00 $92.50

408


Preparation for Luetta Callaway deposition. 1.00 $185.00 $185.00

408


Attend and present questions at Luetta Callaway deposition. (1st half of deposition) 2.60 $185.00 $481.00

408


Attendance and participation in deposition of Callaway's sister, Luetta. (2nd half of deposition) 1.80 $205.00 $369.00

408


Review and evaluate case law in support of the motion for partial summary judgment re: punitive damages. 0.70 $185.00 $129.50

408


Review and evaluate the plaintiff's opposition to the motion for partial summary judgment re: punitive damages. 0.80 $185.00 $148.00

408


Develop arguments and outline to reply to the plaintiff's opposition to the motion for partial summary judgment re: punitive damages. 1.10 $185.00 $203.50

408


Draft reply in support of the motion for partial summary judgment re: punitive damages. 4.80 $185.00 $888.00


Conference with Sarah discussing Plaintiff's counsel's proposal to mediate with all claimants in that policy year. 0.50 $205.00 $102.50

413Ahern v. Damelio Commercial Contracting BJT 6/13/2012

Conduct legal research in support of arguments for reply to defendant's opposition to motion for reconsideration. 1.50 $ 95.00 $142.50

408


Communications with Sarah Fisher re: medical expert and surveillance. 0.10 $185.00 $18.50

408


Communications with Kumen Taylor re: medical expert and surveillance. 0.20 $185.00 $37.00




408


Draft and execute Defendant Ahern Rentals, Inc.'s Fifth Set of Requests for Production of Documents to Plaintiff. 0.40 $185.00 $74.00

408


Research into locating a medical doctor to review medical bills and perform IME. 0.50 $185.00 $92.50

408


Research into locating a private investigator to do sub rosa work on Plaintiff. 0.70 $185.00 $129.50

408


Draft and execute answer to second amended complaint, including extensive update of affirmative defenses based on new claims asserted by Plaintiff. 1.50 $185.00 $277.50

408


Telephone call with Mark Recard to reschedule inspection of lift. 0.10 $205.00 $20.50


Receipt, review, and analysis of Demand for Computation of Damages for Juan Amezcua by Jeremy Stover. 0.10 $185.00 $18.50


Receipt, review, and analysis of Demand for Computation of Damages for Norma Amezcua by Jeremy Stover. 0.10 $185.00 $18.50


Develop strategy re: medical records and experts. 1.40 $185.00 $259.00


Communicate with various medical offices to develop medical expert strategy and to facilitate expert services. 2.80 $185.00 $518.00


Draft reply to opposition to motion to reconsider; conduct legal research on avenues to argue that the case should be allowed to continue in NV because the NJ suit was dismissed. 4.80 $ 95.00 $456.00


Develop strategy and legal arguments for drafting the reply in support of the motion for reconsideration. 0.40 $185.00 $74.00

408


Communications with personal investigator re: sub rosa of Callaway. 0.20 $185.00 $37.00

408


Receipt, review and analysis of vocational and economic damages report from Terry Dinneen. 0.30 $185.00 $55.50




408


Draft and execute Defendant Ahern Rentals, Inc.'s Sixth Set of Requests for Production of Documents to Plaintiff. 0.30 $185.00 $55.50

408


Communications with office of vocational rehab and economic damages expert re: report. 0.70 $185.00 $129.50

408


Telephone call from Mark Recard regarding date for inspection of lift. 0.10 $205.00 $20.50

408


Correspondence to Mark Recard confirming date and time for inspection of lift. 0.10 $205.00 $20.50

408


Conference with private investigator discussing assignment on this case. 0.20 $205.00 $41.00

408


Correspondence to all counsel regarding dates available for Tim's deposition. 0.20 $205.00 $41.00

408


Telephone call from Sarah discussing available dates for Tim's deposition. 0.30 $205.00 $61.50

408


Telephone call with Sarah discussing date for lift inspection. 0.40 $205.00 $82.00

408


Telephone call with Terrence Dineen discussing his report and alternative theories. 0.60 $205.00 $123.00


Meeting with Kumen Taylor, Tim Koval, and David Childress to discuss expert testimony, depositions, motions in limine, potential mediation, insurance coverage, and trial strategy. 0.70 $185.00 $129.50


Telephone call with Terrence Dineen regarding potential conflict of interest with opposing counsel and retention in this case. 0.20 $205.00 $41.00


Review and analysis of defense medical experts needed and discovery to be completed to get case ready for trial. 0.70 $205.00 $143.50


Communicate with potential expert in this case. (2nd expert) 0.30 $185.00 $55.50


Communicate with potential expert in the case. 0.40 $185.00 $74.00


Develop strategy with Chris Orme and Kumen Taylor to develop expert testimony. 0.70 $185.00 $129.50

408


Communications with medical doctor office re: records review and IME. 0.10 $185.00 $18.50




408


Communications with client representative re: deposition of Ahern PMK. 0.10 $185.00 $18.50

408


Communications with opposing counsel re: IME of Plaintiff. 0.20 $185.00 $37.00

408


Draft and execute notice of deposition for JB Hunt driving school. 0.20 $185.00 $37.00

408


Communications with opposing counsel for Skyjack re: payment of expert fees and costs and status of expert discovery. 0.30 $185.00 $55.50

408


Draft and execute subpoena for education records to JB Hunt. 0.30 $185.00 $55.50

408


Review of correspondence from Plaintiff's counsel to Skyjack's counsel requesting dates for PMK depositions. 0.10 $205.00 $20.50

408


Review of correspondence from Skyjack's counsel regarding availability for Ahern PMK depositions. 0.10 $205.00 $20.50

408


Review correspondence from Plaintiff's counsel regarding Ahern PMK deposition. 0.10 $205.00 $20.50


Review and evaluate discovery responses from the plaintiff. 0.50 $185.00 $92.50


Develop and organize medical records for expert review. 2.40 $185.00 $444.00

328 Bankruptcy CMO 6/18/2012

Communications with Sid Kistler and Mark Hutchison re: payment of Ahern expenses and costs. 0.50 $185.00 $92.50

408


Communications with medical expert office re: scheduling of IME. 0.10 $185.00 $18.50

408


Communications with opposing counsel re: scheduling of IME. 0.10 $185.00 $18.50

408


Draft and execute letter to Dr. Serfestini with all relevant medical records attached. 1.60 $185.00 $296.00

408


Prepare outline and argument for the hearing on the motion for partial summary judgment. 1.60 $185.00 $296.00


Communications with Tim Koval re: groin injuries and medical review of same. 0.10 $185.00 $18.50


Communicate with paralegal re: the production of records to medical experts. 0.20 $185.00 $37.00





Revise, edit, revisions, and research to support draft reply for motion for reconsideration. 2.00 $ 95.00 $190.00


Review and evaluate the opposition to the motion for reconsideration to develop strategy for replying to the same. 1.00 $185.00 $185.00


Draft revisions to and amendments for reply brief in support of the motion for reconsideration. 3.80 $185.00 $703.00

408


Communications with private investigator re: status of case. 0.10 $185.00 $18.50

408


Communications with Sarah Fisher re: investigation of Callaway. 0.10 $185.00 $18.50

408


Preparations for and attendance at hearing on motion for summary judgment. 1.80 $205.00 $369.00

408


Prepare for and attend hearing for motion for partial summary judgment, in which the judge recused herself. 2.10 $185.00 $388.50


Communications with opposing counsel re: recent surgeries by Plaintiff. 0.10 $185.00 $18.50

408


Lenthy communications with insurance representative re: status of case. 0.50 $185.00 $92.50

400General Counsel Legal Consultation KLT 6/21/2012

Conference with Sarah, Tim, Brian and Tom to review GL claims. 2.20 $205.00 $451.00

408


Receipt, review and analysis of notice of entry of order for stipulation to extend discovery dates. 0.10 $185.00 $18.50

408


Review correspondence from Plaintiff's counsel with questions regarding Ahern's PMK depositions. 0.10 $205.00 $20.50

408


Review of correspondence from Skyjack's counsel regarding scheduling PMK depositions of Skyjack representatives. 0.10 $205.00 $20.50

408


Review of correspondence from Plaintiff's counsel discussing timing and scheduling of Skyjack's PMK depositions. 0.10 $205.00 $20.50

408


Review of correspondence from counsel for Skyjack regarding scope of inquiry for PMK depositions. 0.10 $205.00 $20.50




408


Correspondence to all counsel regarding limiting scope of inquiry in PMK depositions. 0.10 $205.00 $20.50

408


Correspondence to Plaintiff's counsel regarding PMK depositions. 0.20 $205.00 $41.00

414Ahern adv. Jeff Harris [Pro Steel Erectors] CMO 6/22/2012

Receipt, review, and analysis of Motion to Withdraw as Counsel of Record by Plaintiff's counsel. 0.10 $185.00 $18.50

408


Telephone call from Mark Recard regarding inspection of lift. 0.20 $205.00 $41.00

404Ahern adv. JD2, Inc. [Laraby/JD2] CMO 6/25/2012

Receipt, review, and analysis of letter to court re: status of bankruptcy. 0.10 $185.00 $18.50


Telephone call with Plaintiff's counsel discussing extension of expert and fact discovery deadlines. 0.60 $205.00 $123.00


Communications with opposing counsel re: proposed order on motions in limine. 0.10 $185.00 $18.50

408


Review and analysis of communications with insurance adjustor and client representative. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of letter from opposing counsel re: medical authorizations. 0.10 $185.00 $18.50

419 Ahern adv. John Vella KLT 6/26/2012

Telephone call from Plaintiff's counsel regarding releasing lift into service. 0.10 $205.00 $20.50

419 Ahern adv. John Vella KLT 6/26/2012Correspondence to Sarah regarding releasing lift into service. 0.10 $205.00 $20.50


Communicate with experts re: the status of the case. 0.20 $185.00 $37.00


Communications with the court re: new hearing date. 0.10 $185.00 $18.50


Communications with arbitrator re: mediation scheduling. 0.10 $185.00 $18.50


Meeting with Kumen Taylor to discuss Jones mediation and trial strategy. 0.40 $185.00 $74.00


Communications with opposing counsel re: mediation scheduling. 0.40 $185.00 $74.00


Communications with client representative re: mediation. 0.80 $185.00 $148.00


Correspondence to Sarah regarding Chris' availability for mediation. 0.10 $205.00 $20.50





Review and analysis of Ironshore insurance policy endorsement. 0.10 $205.00 $20.50


Correspondence to Sarah regarding interpretation of policy endorsement. 0.10 $205.00 $20.50


Telephone call with Sarah discussing Ironshore's intent to control settlement discussions. 0.40 $205.00 $82.00


Telephone call from Sarah concerning mediation. 0.60 $205.00 $123.00

408


Communications with Dr. Robert Asarnow re: status of expert report. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of Order Setting Civil Jury Trial, Pretrial Conference, and Calendar Call. 0.10 $185.00 $18.50

408


Draft and execute expert disclosure for Terrance Dinneen pursuant to NRCP 16.1. 0.50 $185.00 $92.50

408


Conference with Mark Recard discussing issues relating to lift and defense of allegations. 1.20 $205.00 $246.00

408


Attend and participate in inspection of lift. 3.00 $205.00 $615.00

404Ahern adv. JD2, Inc. [Laraby] CMO 6/27/2012

Receipt, review, and analysis of motion to court for telephonic appearance re: status check on bankruptcy matter. 0.10 $185.00 $18.50

404Ahern adv. JD2, Inc. [Laraby] CMO 6/27/2012

Communications with local counsel re: status check on bankruptcy matter. 0.10 $185.00 $18.50


Communications with Ahern bankruptcy counsel re: payment of expert Mark Recard. 0.10 $185.00 $18.50


Draft and execute lengthy letter to Dr. Serfestini re: medical records review and analysis and independent medical examination. 1.50 $185.00 $277.50


Draft and execute letter Troy Watson, M.D. requesting medical and billing records for Plaintiff, with corresponding affidavit and authorization. 0.30 $185.00 $55.50


Draft and execute letter John Sumi, DDS, requesting medical and billing records for Plaintiff, with corresponding affidavit and authorization. 0.30 $185.00 $55.50





Draft and execute letter Dr. Mark Glyman, requesting medical and billing records for Plaintiff, with corresponding affidavit and authorization. 0.30 $185.00 $55.50

408


Communications with Dr. Asarnow re: racing records for Darin Callaway. 0.10 $185.00 $18.50

408


Communications with private investigator re: status of investigation. 0.20 $185.00 $37.00

408


Communications with client re: status of private investigation. 0.20 $185.00 $37.00

408


Communications with Terry Dinnen re: racing records for Darin Callaway. 0.20 $185.00 $37.00

408


Draft and execute letter to investigator re: payment of services. 0.20 $185.00 $37.00

408


Legal research and analysis of racing records for Darin Callaway. 0.30 $185.00 $55.50

408


Receipt, review, and analysis of Luetta Callaway deposition. 0.70 $185.00 $129.50


Communications with bankruptcy counsel Tom Fell re: withdrawal of counsel for Plaintiff. 0.10 $185.00 $18.50


Communications with bankruptcy counsel Tom Fell re: payment of expert fees in bankruptcy. 0.10 $185.00 $18.50


Receipt, review, and analysis of letter from John Soumi re: treatment to teeth. 0.10 $185.00 $18.50


Receipt, review, and analysis of letter from opposing counsel re: demand. 0.20 $185.00 $37.00

412 Ahern v. Buschini Sign CMO 6/28/2012

Review of relevant documents, including complaint allegations, and other filed documents; communications with Anthony Buschini and Brett Whipple, Esq.; communications with client re: same. 0.70 $185.00 $129.50

404Ahern adv. JD2, Inc. [Laraby] KLT 6/29/2012

Conference with Sarah, Tim, Todd and Tom discussing status of case and how to proceed going forward. 0.60 $205.00 $123.00





Communications with opposing counsel re: proposed orders on motions in limine. 0.10 $185.00 $18.50


Review and analysis of communications between Ahern and Iron Shore re: bankruptcy stay. 0.10 $185.00 $18.50


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 1 re: Plaintiff's financial status. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 2 re: Plaintiff's prior injuries. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 3 re: inactive commercial driver's license. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 5 re: cumulative expert testimony. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 6 re: empty chair argument. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 7 re: omnibus motion in limine. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 8 re: character evidence. 0.20 $185.00 $37.00


Receipt, review, and analysis of Order Denying Plaintiff's Motion in Limine No. 9 re: failure to obtain insurance. 0.20 $185.00 $37.00


Communications with Kumen Taylor re: motions in limine. 0.20 $185.00 $37.00


Communications with Kumen Taylor re: most updated supplements from Plaintiff. 0.30 $185.00 $55.50


Receipt, review, and analysis of Order Granting Plaintiff's Motion in Limine No. 4 re: signs or warnings. 0.40 $185.00 $74.00


Review and analyze new damages being asserted by Plaintiff. 0.30 $205.00 $61.50





Review and analysis of proposed orders in limine prepared by Plaintiff's counsel. 0.50 $205.00 $102.50

408


Receipt, review, and analysis of investigative report on Plaintiff. 0.40 $185.00 $74.00


Receipt, review, and analysis of letter from Lexington Insurance Company requesting Medicare information. 0.10 $185.00 $18.50


Draft and execute Ahern Rentals, Inc.'s Twenty-Fifth Conference Disclosure Statement. 0.20 $185.00 $37.00


Review and analysis of motions in limine based on most recent supplement. 0.30 $185.00 $55.50

408


Receipt, review and analysis of letter from JB Hunt re: production of employment records for Darin Callaway. 0.10 $185.00 $18.50

408


Communications with counsel for JB Hunt re: production of employment records for Darin Callaway. 0.10 $185.00 $18.50

408


Receipt, review, and analysis of Notice of Department Reassignment. 0.10 $185.00 $18.50

408


Communications with client representative re: status of investigation. 0.10 $185.00 $18.50

424Ahern adv. Granite Telecommunications CMO 7/3/2012

Communications with Brian Ritz re: status of case. 0.20 $185.00 $37.00

424Ahern adv. Granite Telecommunications CMO 7/3/2012

Review and analysis of status of case; communications with Brian Ritz re: same. 0.30 $185.00 $55.50


Communications with opposing counsel re: motion in limine on value of Hummer. 0.10 $185.00 $18.50


Receipt, review, and analysis of Plaintiff's Eleventh Supplement to Early Case Conference Disclosures of Witnesses and Exhibits Pursuant to NRCP 16.1. 0.90 $185.00 $166.50


Review and analysis of medical records for Plaintiff. 1.60 $185.00 $296.00


Draft and revise motion in limine re: value of Hummer. 2.00 $185.00 $370.00


Communications with Kumen Taylor re: Ahern Rentals, Inc.'s Motion in Limine to Exclude Plaintiff's Future Medical Costs and Future Life Care Plan. 0.20 $185.00 $37.00





Draft and revise Defendant Ahern Rentals, Inc.'s Motion in Limine to Exclude Plaintiff's Future Medical Costs and Future Life Care Plan. 3.40 $185.00 $629.00


Conference with C. Orme. [NO CHARGE] 0.20 $205.00 $0.00

408


Communications with opposing counsel for Skyjack re: voc rehab and economic damages expert. 0.10 $185.00 $18.50

408


Communications with Kumen Taylor re: private investigation status and expert report on voc rehab. 0.20 $185.00 $37.00

408


Communications with private investigator re: status of investigation. 0.30 $185.00 $55.50

408


Communications with Jim Randall re: vocational rehabilitation strategy for introducing a floor for economic damages at trial. 0.30 $185.00 $55.50

424Ahern adv. Granite Telecommunications TRK 7/6/2012

Communicate with the court to place the motion to transfer to district court on for hearing. 0.20 $185.00 $37.00

424Ahern adv. Granite Telecommunications TRK 7/6/2012

Draft 3-day notice of intent to take default against Granite. 0.40 $185.00 $74.00


Receipt, review, and analysis of letter re: St. Rose Dominican Hospital records. 0.10 $185.00 $18.50


Draft letter to Lexington Insurance re: Medicare for Plaintiff. 0.20 $185.00 $37.00


Draft the stipulation and order to extend the expert deadlines and the discovery deadlines in this case. 0.90 $185.00 $166.50


Draft and execute Notice of Entry of Order of Stipulation and Order to Continue Hearing on Plaintiff's Motion for Declaratory Relief. 0.20 $185.00 $37.00


Receipt, review, and analysis of Plaintiff's Thirteenth Supplement to Early Case Conference Disclosure of Witnesses and Exhibits Pursuant to NRCP 16.1. 0.10 $185.00 $18.50


Receipt, review, and analysis of letter from Plaintiff's counsel to counsel for American Family re: production of documents. 0.10 $185.00 $18.50


Communications with Kumen Taylor re: mediation preparation and medical records. 0.20 $185.00 $37.00





Review and analysis of binder number two of medical documents for Plaintiff. 0.40 $185.00 $74.00

409Ahern adv. Raymond David Jones CMO 7/6/2012 Draft and execute mediation brief. 1.00 $185.00 $185.00




Communications to clients re: motion for reconsideration. 0.20 $185.00 $37.00


Receipt, review, and analysis of court order on motion for reconsideration. 0.40 $185.00 $74.00

408


Communications with private investigator re: depositions of Frances and Luetta Callaway. 0.10 $185.00 $18.50


Communications with Tim Koval re: requests for admissions for authenticity. 0.10 $185.00 $18.50


Communicate with vocational rehabilitation practice re: expert issues in this case. 0.10 $185.00 $18.50


Communicate with psychology practice re: expert issues in this case. 0.10 $185.00 $18.50


Review and send documentation to vocational rehabilitation expert. 0.10 $185.00 $18.50


Review and sign the stipulation to extend the expert and discovery deadlines in this case. 0.10 $185.00 $18.50


Communicate with cardiology practice re: expert issues in this case. 0.20 $185.00 $37.00


Communicate with orthopedic practice re: expert issues in this case. 0.20 $185.00 $37.00


Communicate with separate orthopedic practice re: expert issues in this case. 0.20 $185.00 $37.00


Draft letter to opposing counsel re: IME dates. 0.20 $185.00 $37.00


Communicate with Matt Sims re: the status of this case and draft correspondence to establish an evaluation date. 0.30 $185.00 $55.50


Communicate with a psychologist re: expert services. 0.50 $185.00 $92.50


Draft dozens of requests for admission in this matter. 1.70 $185.00 $314.50


Communications with Sarah Fisher re: mediation status. 0.30 $185.00 $55.50





Communications with Kumen Taylor re: mediation status. 0.40 $185.00 $74.00


Review and analysis of medical records for Plaintiff. 2.30 $185.00 $425.50




Review and analysis of settlement agreement from mediator. 0.10 $205.00 $20.50


Telephone call with Sarah discussing her concern with language of settlement agreement. 0.10 $205.00 $20.50

1153860120928000000000011 Docket #1100 Date Filed: …Cont.] CMO 5/4/2012. Communications with Sarah...

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Transcript of 1153860120928000000000011 Docket #1100 Date Filed: …Cont.] CMO 5/4/2012. Communications with Sarah...