Document EFTA 02735453¶
Scholz & Wyler, LLC 961687 Gateway Blvd., Suite 2011 Fernandina Beach, FL 32034 United States 904-261-3693¶
Scholz & Wyler, LLC¶
Dave Aronberg¶
Balance $70,900.27 Invoice # 00409 Invoice Date April 12, 2022 Payment Terms Due Date¶
Aronberg (SAO15) adv. CA Florida Holdings, LLC¶
Time Entries¶
| Date | EE | Activity | Description | Rate | Hours | Line Total |
|---|---|---|---|---|---|---|
| 11/26/2019 | DW | Review | Initial review of summons and complaint. | $425.00 | 1.5 | $637.50 |
| 11/26/2019 | DW | Review | Reviewed motion for pro hac vice and Judge Hafele’ order granting | $425.00 | 0.2 | $85.00 |
| 11/26/2019 | DW | Teleconference | Teleconference w/ Client, re: response to lawsuit | $425.00 | 0.5 | $212.50 |
| 11/26/2019 | DW | Draft | Drafted engagement letter and sent to client | $425.00 | 0.3 | $127.50 |
| 11/26/2019 | DW | Review | Reviewed 15th circuit local rules | $425.00 | 1.0 | $425.00 |
| 11/26/2019 | AJJ | Review | Initial review of complaint | $475.00 | 1.0 | $475.00 |
| 11/26/2019 | AJJ | Meeting | Meeting w/ DAW to discuss lawsuit and strategy | $475.00 | 0.5 | $237.50 |
| 11/26/2019 | DW | Meeting | Meeting w/ AJJ to discuss lawsuit and strategy | $425.00 | 0.5 | $212.50 |
| 11/26/2019 | AJJ | Teleconference | Teleconference w/ Client, re: response to lawsuit | $475.00 | 0.5 | $237.50 |
| 12/02/2019 | DW | Research & Preparation | Research and prep for Motion to dismiss | $425.00 | 2.0 | $850.00 |
| 12/02/2019 | DW | Draft | 1st Draft motion to dismiss | $425.00 | 1.0 | $425.00 |
| 12/02/2019 | DW | Teleconference | Teleconference w/ Client, re: draft motion to dismiss | $425.00 | 0.5 | $212.50 |
| 12/02/2019 | AJJ | Review | Reviewed 1st Draft MTDismiss | $475.00 | 0.3 | $142.50 |
| 12/02/2019 | AJJ | Teleconference | Teleconference w/ client, re: draft motion to dismiss | $475.00 | 0.5 | $237.50 |
| 12/03/2019 | AJJ | Meeting | Meeting w/ DAW, re: motion to dismiss | $475.00 | 0.2 | $95.00 |
| 12/03/2019 | DW | Meeting | Meeting w/ AJJ, re: MTDismiss | $425.00 | 0.2 | $85.00 |
| 12/06/2019 | DW | Draft | Completed final draft of motion to dismiss; filed with Court | $425.00 | 0.7 | $297.50 |
| 12/06/2019 | DW | Teleconference | Spoke w/ client, re: final draft of motion to dismiss | $425.00 | 0.5 | $212.50 |
| 12/06/2019 | DW | Teleconference | Spoke with Clerk’s attorney, re: response | $425.00 | 0.5 | $212.50 |
| 12/06/2019 | AJJ | Review | Reviewed final draft MTDismiss | $475.00 | 0.2 |
Joint Exhibit J32¶
Party JOINT¶
ID# J32 EV# J32¶
| 12/06/2019 | AJ | Review | Reviewed Clerk’s MTDismiss | $475.00 | 0.2 | $95.00 |
|---|---|---|---|---|---|---|
| 12/13/2019 | DW | Review | Reviewed Clerk’s Motion to Dismiss | $425.00 | 0.5 | $212.50 |
| 01/16/2020 | DW | Review | Reviewed Order Setting Hearing █ Defendants’ MTDismiss | $425.00 | 0.1 | $42.50 |
| 01/16/2020 | DW | Review | Reviewed motion for pro hac vice | $425.00 | 0.1 | $42.50 |
| 01/17/2020 | DW | Review | Reviewed PI’s Amended Complaint | $425.00 | 1.0 | $425.00 |
| 01/17/2020 | DW | Teleconference | Spoke with client, re: Amended Complaint | $425.00 | 0.5 | $212.50 |
| 01/17/2020 | DW | Review | Reviewed PI’s notice of filing | $425.00 | 0.1 | $42.50 |
| 01/20/2020 | AJ | Review | Reviewed PI’s Am. Compl | $475.00 | 0.3 | $142.50 |
| 01/21/2020 | DW | Review | Reviewed Judge Marx’s Order Cancelling MTDismiss Hearing | $425.00 | 0.1 | $42.50 |
| 01/21/2020 | DW | Review | Reviewed PI’s Objection to Defendants’ MTDismiss | $425.00 | 0.2 | $85.00 |
| 01/21/2020 | DW | Teleconference | Spoke with client, re: Amended complaint | $425.00 | 0.5 | $212.50 |
| 01/21/2020 | AJ | Meeting | Meeting w/ DAW, re: response to Am. Compl. | $475.00 | 0.2 | $95.00 |
| 01/21/2020 | DW | Meeting | Meeting w/ AJ, re: response to Am. Compl. | $425.00 | 0.2 | $85.00 |
| 01/22/2020 | DW | Review | Reviewed Order granting pro hac vice admission | $425.00 | 0.1 | $42.50 |
| 01/22/2020 | DW | Research & Draft | Researched and drafted response to Amended Complaint | $425.00 | 1.0 | $425.00 |
| 01/23/2020 | DW | Teleconference | Spoke with Clerk’s attorney, re: response to amended complaint | $425.00 | 0.2 | $85.00 |
| 01/24/2020 | DW | Various | Completed Answer/MTDismiss Amended Complaint; filed with Court; sent copy to Client | $425.00 | 1.0 | $425.00 |
| 01/24/2020 | DW | Draft | Drafted and filed Notice of Unavailability | $425.00 | 0.4 | $170.00 |
| 01/24/2020 | AJ | Review | Reviewed final Answer/MTDismiss | $475.00 | 0.2 | $95.00 |
| 01/27/2020 | DW | Review | Reviewed Clerk’s Answer/MTDismiss | $425.00 | 0.3 | $127.50 |
| 02/03/2020 | DW | Review | Reviewed Order setting hearing on Defs’ MTDismiss | $425.00 | 0.1 | $42.50 |
| 02/03/2020 | DW | Teleconference | Spoke w/ client, re: order setting MTDismiss hearing for March 24, 2020 | $425.00 | 0.5 | $212.50 |
| 03/13/2020 | DW | Review | Reviewed PI’s Opposition to Aronberg MTDismiss & Clerk’s MTDismiss | $425.00 | 1.5 | $637.50 |
| 03/13/2020 | AJ | Review | Reviewed PI’s Opposition to Aronberg MTDismiss & Clerk’s MTDismiss | $475.00 | 0.7 | $332.50 |
| 03/18/2020 | DW | Teleconference | Reviewed email from PI’s counsel, re: motion to continue hearing | $425.00 | 0.1 | $42.50 |
| 03/18/2020 | DW | Review | Reviewed PI’s unopposed motion for continuance | $425.00 | 0.1 | $42.50 |
| 03/18/2020 | DW | Emails w/ Clerk’s counsel, re: PI’s request to continue hearing | $425.00 | 0.2 | $85.00 | |
| 03/19/2020 | DW | Reviewed email from PI, re: agreed order & responded | $425.00 | 0.1 | $42.50 | |
| 03/20/2020 | DW | Review | Reviewed Court’s agreed order continuing hearing | $425.00 | 0.1 | $42.50 |
| 04/21/2020 | DW | Review | Reviewed order rescheduling hearing on Defs’ MTDismiss | $425.00 | 0.1 | $42.50 |
| 04/21/2020 | DW | Teleconference | Spoke w/ client, re: order rescheduling MTDismiss hearing for June 3, 2020 | $425.00 | 0.3 | $127.50 |
| 04/21/2020 | AJ | Review | Reviewed Order rescheduling MTDismiss hearing | $475.00 | 0.1 | $47.50 |
| 05/22/2020 | DW | Review | Reviewed order setting Zoom hearing, re: MTDismiss | $425.00 | 0.1 | $42.50 |
| 05/22/2020 | DW | Teleconference | Spoke w/ client, re: hearing will be via Zoom | $425.00 | 0.2 | $85.00 |
|---|---|---|---|---|---|---|
| 05/27/2020 | DW | Review | Reviewed Clerk’s filing: change of atty of record | $425.00 | 0.1 | $42.50 |
| 05/27/2020 | DW | Teleconference | Spoke with Clerk’s new counsel, Nicola Fingerhut | $425.00 | 0.2 | $85.00 |
| 05/28/2020 | DW | Reviewed PI’s email, re: cases and authorities for MTDismiss hearing; responded | $425.00 | 0.1 | $42.50 | |
| 05/29/2020 | DW | Preparation | Began oral argument prep for 6/8 MTDismiss hearing. | $425.00 | 1.0 | $425.00 |
| 06/01/2020 | DW | Reviewed email from Judge Marx’s JA and responded | $425.00 | 0.1 | $42.50 | |
| 06/02/2020 | DW | Various | Reviewed PI’s 500+ page binder, re: MTDismiss & prepped for hearing | $425.00 | 3.0 | $1,275.00 |
| 06/02/2020 | DW | Drafted and sent email to client, re: MTD. hearing tomorrow | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | DW | Attend Hearing | Prepped for and attended MTDismiss hearing via Zoom | $425.00 | 1.5 | $637.50 |
| 06/03/2020 | DW | Teleconference | Spoke w/ Client, re: debrief MTDismiss hearing | $425.00 | 0.5 | $212.50 |
| 06/03/2020 | DW | Emailed courtesy copies of Aronberg’s Answer and MTDismiss to Judge Marx | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | DW | Reviewed response from Client and replied | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | AJJ | Attend Hearing | Attended MTDismiss hearing via Zoom | $475.00 | 1.0 | $475.00 |
| 06/03/2020 | AJJ | Review | Reviewed order granting MTDismiss w/ prejudice | $475.00 | 0.3 | $142.50 |
| 06/08/2020 | DW | Review | Reviewed Court’s Order Granting Defendants MTDismiss Count II w/ Prejudice | $425.00 | 0.5 | $212.50 |
| 06/08/2020 | DW | Various | Shared order w/ Client and spoke w/, re: result and plan going forward, re: 57.105 | $425.00 | 0.5 | $212.50 |
| 06/08/2020 | DW | Various | Researched § 57.105 Fla. Stat., drafted 57.105 demand letter and proposed motion for attorneys’ fees/sanctions; Served PI’s counsel with demand letter and proposed motion. | $425.00 | 2.0 | $850.00 |
| 06/08/2020 | AJJ | Meeting | Meeting w/ DAW, re: Order & 57.105 | $475.00 | 0.3 | $142.50 |
| 06/08/2020 | DW | Meeting | Meeting w/ AJJ, re: Order & 57.105 | $425.00 | 0.3 | $127.50 |
| 06/08/2020 | AJJ | Review | Reviewed 57.105 demand and proposed motion for sanction | $475.00 | 0.2 | $95.00 |
| 06/10/2020 | DW | Various | Reviewed notice of change of attorney, re: Clerk; called and spoke w/ new counsel Cynthia Guerra | $425.00 | 0.3 | $127.50 |
| 06/23/2020 | DW | Various | Reviewed PI’s letter refusing to voluntarily dismiss amended complaint despite 57.105 demand; called and spoke w/ client, re: PI’s refusal & next steps | $425.00 | 1.0 | $425.00 |
| 06/23/2020 | DW | Sent client copy of PI’s letter refusing to dismiss complaint | $425.00 | 0.1 | $42.50 | |
| 06/23/2020 | AJJ | Review | Reviewed PI’s letter refusing to dismiss Count I/Am. Compl. | $475.00 | 0.1 | $47.50 |
| 07/01/2020 | DW | Various | Spoke w/ client, re: filing of 57.105 motion for fees/sanctions; filed motion for attorneys’ fees based on PI’s failure to voluntarily dismiss amended complaint count 1 | $425.00 | 0.5 | $212.50 |
| 07/02/2020 | DW | Email to client, re: affidavit and summary judgment. | $425.00 | 0.1 | $42.50 | |
| 07/08/2020 | DW | Teleconference | Discussed w/ Client drafting and filing Motion for Summary Judgment and MSJ evidence | $425.00 | 0.7 | $297.50 |
| 07/08/2020 | AJJ | Teleconference | Discussed w/ Client drafting and filing Motion for Summary Judgment and MSJ evidence | $475.00 | 0.7 | $332.50 |
| 07/10/2020 | DW | Draft | Created 1st draft of Aronberg Affidavit; shared w/ client | $425.00 | 1.0 | $425.00 |
|---|---|---|---|---|---|---|
| 07/10/2020 | AJJ | Various | Reviewed draft affidavit and discussed w/ DAW | $475.00 | 0.3 | $142.50 |
| 07/10/2020 | DW | Meeting | Discussed draft affidavit w/ AJJ | $425.00 | 0.2 | $85.00 |
| 07/13/2020 | DW | Review | Reviewed PI’s Request to Produce, re: Clerk | $425.00 | 0.1 | $42.50 |
| 07/13/2020 | DW | Teleconference | Spoke w/ Clerk’s counsel, re: Request to Produce | $425.00 | 0.2 | $85.00 |
| 07/27/2020 | DW | Review | Reviewed PI’s Amended Request to Produce, re: Clerk | $425.00 | 0.1 | $42.50 |
| 07/27/2020 | DW | Teleconference | Spoke w/ Clerk’s counsel, re: Amended Request to Produce | $425.00 | 0.1 | $42.50 |
| 07/28/2020 | DW | Draft | Revised Aronberg affidavit | $425.00 | 0.5 | $212.50 |
| 07/29/2020 | DW | Draft | Finalized Aronberg Affidavit and sent to client | $425.00 | 0.5 | $212.50 |
| 07/29/2020 | DW | Research & Preparation | Research and prep for Motion for Summary Judgment | $425.00 | 1.0 | $425.00 |
| 07/30/2020 | DW | Various | Received executed Aronberg Affidavit | $425.00 | 0.1 | $42.50 |
| 07/30/2020 | DW | Draft | Began drafting Motion for Summary Judgment | $425.00 | 2.0 | $850.00 |
| 08/05/2020 | DW | Draft | Continued drafting Motion for Summary Judgment | $425.00 | 1.0 | $425.00 |
| 08/07/2020 | DW | Review | Reviewed email from Plaintiff attempting to set hearing on 57.105 motion for fees/sanctions | $425.00 | 0.1 | $42.50 |
| 08/10/2020 | DW | Sent responsive email to PI’s counsel | $425.00 | 0.1 | $42.50 | |
| 08/17/2020 | DW | Meeting | Discussed draft MSJ w/ AJJ | $425.00 | 0.2 | $85.00 |
| 08/17/2020 | AJJ | Various | Reviewed draft MSJ and met w/ DAW to discuss | $475.00 | 0.5 | $237.50 |
| 08/18/2020 | DW | Draft | Finalized Motion for Summary Judgment; filed w/ court along with Aronberg affidavit | $425.00 | 2.0 | $850.00 |
| 08/27/2020 | DW | Teleconference | Spoke w/ Clerk’s counsel, re: request to produce | $425.00 | 0.1 | $42.50 |
| 09/01/2020 | DW | Various | Reviewed PI’s email and accepted conference call invite for 9/2/20 | $425.00 | 0.1 | $42.50 |
| 09/02/2020 | DW | Review | Reviewed Clerk’s response to request for production | $425.00 | 0.2 | $85.00 |
| 09/02/2020 | DW | Teleconference | Spoke w/ PI’s counsel, re: dispute as to whether MSJ should be heard before 57.105 fee motion or vis versa - call was unsuccessful | $425.00 | 0.5 | $212.50 |
| 09/02/2020 | AJJ | Meeting | Discussed w/ DAW phone call w/ PI’s counsel | $475.00 | 0.2 | $95.00 |
| 09/02/2020 | DW | Meeting | Discussed w/ AJJ phone call w/ PI’s counsel | $425.00 | 0.2 | $85.00 |
| 09/16/2020 | DW | Reviewed email from PI’s counsel requested Aronberg to withdraw sanctions motion w/o prejudice | $425.00 | 0.1 | $42.50 | |
| 09/17/2020 | DW | Meeting | Discussed w/ AJJ filing motion for CMC | $425.00 | 0.1 | $42.50 |
| 09/17/2020 | AJJ | Meeting | Discussed w/ DAW filing motion for CMC | $475.00 | 0.1 | $47.50 |
| 09/18/2020 | DW | Various | Drafted and filed motion to set case management conference; re: MSJ 1st or Fee hearing 1st | $425.00 | 0.5 | $212.50 |
| 09/18/2020 | DW | Responded to PI’s 9/16/20 email and refused to withdraw 57.105 motion; provided copy of motion to set CMC and available dates for hearing | $425.00 | 0.1 | $42.50 | |
| 09/18/2020 | DW | Reviewed PI’s email insisting that 57.105 motion be withdrawn | $425.00 | 0.1 | $42.50 | |
| 09/18/2020 | DW | Replied to PI’s counsel that the 57.105 motion for sanctions will not be withdrawn and asking for response, re: CMC | $425.00 | 0.1 | $42.50 |
| 09/18/2020 | DW | Sent client copy of email exchange w/ PI’s counsel; called and spoke w/ Client | $425.00 | 0.5 | $212.50 | |
|---|---|---|---|---|---|---|
| 09/22/2020 | DW | Various | Drafted and filed Notice of Hearing on 10/15/20; sent up Court Call; spoke w/ client, re: hearing date | $425.00 | 0.7 | $297.50 |
| 10/02/2020 | DW | Review | Reviewed PI’s Memo of Law opposing Aronberg’s 57.105 motion for fees/sanctions | $425.00 | 0.7 | $297.50 |
| 10/02/2020 | DW | Review | Reviewed PI’s Response to Aronberg’s request to schedule 57.105 motion for fees after MSJ | $425.00 | 0.5 | $212.50 |
| 10/02/2020 | AJJ | Review | Reviewed PI’s Memo of Law opposing 57.105 motion | $475.00 | 0.5 | $237.50 |
| 10/02/2020 | AJJ | Review | Reviewed PI’s Response to Aronberg’s request to schedule 57.105 motion after MSJ | $475.00 | 0.4 | $190.00 |
| 10/12/2020 | DW | Research | Research caselaw & statutes, re: response to PI’s Memo of Law | $425.00 | 1.0 | $425.00 |
| 10/13/2020 | DW | Research & Analyze | Continued researching caselaw, re: response to PI’s memo of law | $425.00 | 1.0 | $425.00 |
| 10/13/2020 | DW | Draft | Created 1st draft of Response to PI’s Memo of Law and shared w/ Client | $425.00 | 4.0 | $1,700.00 |
| 10/13/2020 | DW | Meeting | Discussed w/ AJJ caselaw and draft response to memo | $425.00 | 0.5 | $212.50 |
| 10/13/2020 | AJJ | Various | Reviewed draft MSJ, discussed draft w/ DAW and caselaw | $475.00 | 0.7 | $332.50 |
| 10/14/2020 | DW | Draft | Finalized and filed Response to PI’s Memo of Law | $425.00 | 1.0 | $425.00 |
| 10/14/2020 | DW | Telephone | Spoke w/ client, re: memo of law | $425.00 | 0.2 | $85.00 |
| 10/14/2020 | DW | Telephone | Spoke w/ client again, re: response to memo of law | $425.00 | 0.1 | $42.50 |
| 10/15/2020 | DW | Attend Hearing | Attended hearing, re: Motion to Set CMC; called client to discuss | $425.00 | 1.5 | $637.50 |
| 10/15/2020 | DW | Various | Reviewed email and letter from PI, re: settlement. Sent copy to Client and called to discuss. | $425.00 | 0.5 | $212.50 |
| 10/15/2020 | DW | Telephone | Spoke w/ PI’s counsel, re: settlement | $425.00 | 0.1 | $42.50 |
| 10/15/2020 | DW | Telephone | Spoke w/ client, re: PI’s settlement proposal | $425.00 | 0.2 | $85.00 |
| 10/15/2020 | AJJ | Various | Attended hearing, re: motion to set CMC; discussed w/ client | $475.00 | 1.0 | $475.00 |
| 10/15/2020 | AJJ | Various | Discussed PI’s settlement proposal w/ DAW and then w/ Client | $475.00 | 0.4 | $190.00 |
| 10/15/2020 | DW | Meeting | Discussed PI’s settlement proposal w/ AJJ | $425.00 | 0.2 | $85.00 |
| 10/16/2020 | DW | Various | Drafted and shared proposed order w/ PI’s counsel | $425.00 | 0.5 | $212.50 |
| 10/16/2020 | DW | Telephone | Spoke w/ PI’s counsel, re: settlement | $425.00 | 0.2 | $85.00 |
| 10/16/2020 | DW | Telephone | Spoke w/ client, re: PI’s settlement proposal | $425.00 | 0.5 | $212.50 |
| 10/16/2020 | DW | Meeting | Discussed PI’s settlement proposal w/ AJJ | $425.00 | 0.2 | $85.00 |
| 10/16/2020 | AJJ | Meeting | Discussed PI’s settlement proposal w/ DAW | $475.00 | 0.2 | $95.00 |
| 10/19/2020 | DW | Various | Uploaded proposed order, re: CMC for Judge Hafele | $425.00 | 0.1 | $42.50 |
| 10/19/2020 | DW | Telephone | Spoke w/ client, re: PI’s settlement proposal | $425.00 | 0.2 | $85.00 |
| 10/19/2020 | DW | Telephone | Spoke w/ PI’s counsel, re: settlement | $425.00 | 0.1 | $42.50 |
| 10/19/2020 | AJJ | Meeting | Discussed PI’s settlement proposal w/ DAW | $475.00 | 0.2 | $95.00 |
| 10/19/2020 | DW | Meeting | Discussed PI’s settlement proposal w/ AJJ | $425.00 | 0.2 | $85.00 |
| 10/20/2020 | DW | Various | Reviewed email from PI, re: settlement; sent copy to Client and called to discuss | $425.00 | 0.5 | $212.50 |
| 10/20/2020 | DW | Telephone | Spoke w/ client, re: settlement | $425.00 | 0.4 | $170.00 |
|---|---|---|---|---|---|---|
| 10/20/2020 | DW | Telephone | Spoke w/ Pl’s counsel, re: settlement | $425.00 | 0.1 | $42.50 |
| 10/20/2020 | DW | Telephone | Spoke w/ client, re: settlement | $425.00 | 0.1 | $42.50 |
| 10/20/2020 | DW | Meeting | Discussed Pl’s settlement proposal w/ AU | $425.00 | 0.2 | $85.00 |
| 10/20/2020 | AU | Meeting | Discussed Pl’s settlement proposal w/ DAW | $475.00 | 0.2 | $95.00 |
| 10/21/2020 | DW | Various | Drafted and filed Motion to Set Hearing on Aronberg MSJ, drafted proposed order granting motion to set; checked court availability; emailed Pl’s counsel, re: choose date for hearing | $425.00 | 1.0 | $425.00 |
| 10/21/2020 | DW | Review | Reviewed Order, re: CMC unrecessary | $425.00 | 0.1 | $42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | $425.00 | 0.2 | $85.00 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | $425.00 | 0.1 | $42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | $425.00 | 0.1 | $42.50 |
| 10/21/2020 | DW | Sent email w/ Aronberg statement to media | $425.00 | 0.1 | $42.50 | |
| 10/21/2020 | AU | Meeting | Discussed media response w/ DAW | $475.00 | 0.3 | $142.50 |
| 10/21/2020 | DW | Meeting | Discussed media response w/ AU | $425.00 | 0.3 | $127.50 |
| 10/22/2020 | DW | Various | Reviewed Pl’s Notice of Dropping Aronberg as party; spoke w/ Client and AU, re: notice and next steps | $425.00 | 0.5 | $212.50 |
| 10/22/2020 | AU | Various | Reviewed Pl’s Notice of Dropping Aronberg as party; spoke w/ Client and DAW, re: notice and next steps | $475.00 | 0.5 | $237.50 |
| 11/05/2020 | DW | Draft | Draft Amended Motion for Attorneys’ Fees & Costs | $425.00 | 3.0 | $1,275.00 |
| 11/06/2020 | DW | Draft | Continue drafting Motion for Attorneys’ Fees & Costs and Affidavit of Attorneys Fees and Affidavit of Reasonable Attorneys’ Fees, sent to expert for review | $425.00 | 2.0 | $850.00 |
| 11/09/2020 | DW | Various | Call w/ expert, re: affidavit; Call w/ Client, re: filings; filed Motion & Affidavits | $425.00 | 1.0 | $425.00 |
| 12/03/2020 | DW | Draft & File | Draft and File Notice for Non-Jury Trial; email to JA; emails w/ opposing counsel counsel to set meeting | $425.00 | 0.7 | $297.50 |
| 12/09/2020 | DW | Teleconference | TC w/ opposing counsel; meeting w/ AU afterwards | $425.00 | 1.0 | $425.00 |
| 12/09/2020 | AU | Meeting | AU - TC w/ opposing counsel; meeting w/ DAW afterwards | $475.00 | 1.0 | $475.00 |
| 12/10/2020 | DW | Draft & File | Draft and File Amended Notice for Non-Jury Trial | $425.00 | 0.5 | $212.50 |
| 01/28/2021 | DW | Various | Review Order Setting Hearing; emailed to client | $425.00 | 0.2 | $85.00 |
| 03/25/2021 | DW | Review | Review Notice of Change of Counsel | $425.00 | 0.1 | $42.50 |
| 04/22/2021 | DW | Review & Analyze | Review and analyze Pl’s MSJ & Appendix | $425.00 | 1.0 | $425.00 |
| 05/24/2021 | DW | Review | Review Pl’s Motion to Set Hearing | $425.00 | 0.1 | $42.50 |
| 05/25/2021 | DW | Review & Analyze | Review Notice of Appearance & Response to Pl’s Motion to Set | $425.00 | 0.3 | $127.50 |
| 06/11/2021 | DW | Review | Reviewed Agreed Order | $425.00 | 0.1 | $42.50 |
| 07/14/2021 | DW | Preparation | Prep for hearing and trip to West Palm Beach | $425.00 | 2.0 | $850.00 |
| 07/15/2021 | DW | Travel | Travel to West Palm Beach | $425.00 | 5.5 | $2,337.50 |
| 07/16/2021 | DW | Attend Hearing | Prep for and attend hearing | $425.00 | 1.5 | $637.50 |
| 07/16/2021 | DW | Review & Analyze | Review and analyze PI’s memo flaw; draft response outline | $425.00 | 1.5 | $637.50 |
|---|---|---|---|---|---|---|
| 07/16/2021 | DW | Teleconference | Call w/ Client, re: entitlement hearing week of 7/26 | $425.00 | 0.3 | $127.50 |
| 07/16/2021 | DW | Teleconference | Call w/ AU, re: hearing week of 7/26 | $425.00 | 0.1 | $42.50 |
| 07/16/2021 | DW | Teleconference | Call w/ DAW following hearing | $425.00 | 0.1 | $42.50 |
| 07/17/2021 | DW | Travel | Travel back to Amelia Island | $425.00 | 5.5 | $2,337.50 |
| 07/19/2021 | DW | Various | Research, review, and analyze PI’s memo of law; motion for atty fees, begin drafting responsive memo | $425.00 | 2.5 | $1,062.50 |
| 07/20/2021 | DW | Draft | Draft memo of law in support of Amended Motion for Atty Fees | $425.00 | 4.0 | $1,700.00 |
| 07/21/2021 | DW | Draft | Complete 1st draft memo of law in support of amended motion for atty fees | $425.00 | 3.0 | $1,275.00 |
| 07/21/2021 | DW | Meeting | Meeting w/ AU, re: memo of law | $425.00 | 0.5 | $212.50 |
| 07/21/2021 | AU | Various | Review and analyze memo of law; meeting w/ DAW to discuss | $475.00 | 1.0 | $475.00 |
| 07/23/2021 | DW | Various | Complete and File Memo of Law; Meeting w/ AU to discuss; call to JA; call to Client; several emails w/ opposing counsel | $425.00 | 2.0 | $850.00 |
| 07/23/2021 | AU | Meeting | Meeting w/ DAW, re: Memo of Law | $475.00 | 0.5 | $237.50 |
| 07/23/2021 | DW | Email exchange w/ opposing counsel, re: entitlement hearing | $425.00 | 0.2 | $85.00 | |
| 07/23/2021 | DW | Teleconference | Call to Judge Hafale’s JA, re: hearing date | $425.00 | 0.1 | $42.50 |
| 07/26/2021 | DW | Review & Analyze | Review Order Setting hearing for 7/27, review Notice of Appearance, review Order Resetting Hearing for 8/17/21 | $425.00 | 0.5 | $212.50 |
| 07/27/2021 | DW | Various | Review email from Op. Counsel & phone call | $425.00 | 0.4 | $170.00 |
| 07/28/2021 | DW | Draft | Draft updated Memo of Law in support of Motion for Attorneys’ fees | $425.00 | 2.0 | $850.00 |
| 07/29/2021 | DW | Draft & File | Complete drafting and file updated Memo of Law | $425.00 | 2.0 | $850.00 |
| 07/30/2021 | DW | Responded to Op. Counsel’s email | $425.00 | 0.1 | $42.50 | |
| 08/03/2021 | DW | Teleconference | Call w/ Client, re: witnesses and plan for 8/17 hearing | $425.00 | 1.0 | $425.00 |
| 08/04/2021 | DW | Various | Several emails & call w/ opposing counsel & TC, re: motion to continue | $425.00 | 0.7 | $297.50 |
| 08/04/2021 | DW | Teleconference | Call w/ Client, ok to file joint motion to continue | $425.00 | 0.2 | $85.00 |
| 08/05/2021 | DW | Various | Emails w/ opposing counsel, re: Joint Motion to Continue; review motion to continue | $425.00 | 0.5 | $212.50 |
| 08/09/2021 | DW | Various | Review Order Granting Continuance and setting calendar call for 3/4/22; called client to discuss | $425.00 | 0.5 | $212.50 |
| 08/09/2021 | DW | Various | Call w/ Client, re: continuance until March 2022; meeting w/ AU | $425.00 | 0.7 | $297.50 |
| 08/09/2021 | AU | Meeting | Meeting w/ DAW, re: continuance | $475.00 | 0.5 | $237.50 |
| 08/11/2021 | DW | Draft & File | Draft Amended Memo of Law to comply w/ 10 page limit | $425.00 | 3.0 | $1,275.00 |
| 08/12/2021 | DW | Various | Complete draft of Amended Memo of Law & filed; reviewed and responded to several emails w/ opposing counsel | $425.00 | 2.0 | $850.00 |
| 09/09/2021 | DW | Reviewed and replied to op. counsel’s email | $425.00 | 0.2 | $85.00 | |
| 09/10/2021 | DW | Reviewed and replied to op. counsel’s email | $425.00 | 0.2 | $85.00 |
| 09/13/2021 | DW | Accept calendar invite for 9/14 teleconference | $425.00 | 0.1 | $425.00 | |
|---|---|---|---|---|---|---|
| 09/14/2021 | DW | Various | TC w/ opposing counsel, re: multiplier & case law; meeting w/ AIJ afterwards | $425.00 | 1.0 | $425.00 |
| 09/14/2021 | AIJ | Various | TC w/ opposing counsel, re: multiplier & case law; meeting w/ DAW afterwards | $475.00 | 1.0 | $475.00 |
| 09/15/2021 | DW | Review & Analyze | Review emails and case law from opposing counsel | $425.00 | 0.7 | $297.50 |
| 10/01/2021 | DW | Review & Analyze | Review Clerk’s response to MSJ | $425.00 | 0.5 | $212.50 |
| 10/05/2021 | DW | Review & Analyze | Review Order, re: MSJ hearing on 10/22/21 | $425.00 | 0.1 | $42.50 |
| 10/05/2021 | DW | Review & Analyze | Review PI’s Reply in support of MSJ | $425.00 | 0.5 | $212.50 |
| 11/02/2021 | DW | Reviewed several emails b/w opposing counsel | $425.00 | 0.2 | $85.00 | |
| 11/05/2021 | DW | Reviewed several emails b/w opposing counsel | $425.00 | 0.2 | $85.00 | |
| 12/20/2021 | DW | Various | Review & Analyze Final Judgment in favor of Clerk, meeting w/ AIJ, call client to discuss | $425.00 | 1.5 | $637.50 |
| 12/20/2021 | AIJ | Meeting | Meeting w/ DAW, re: MSJ Order | $475.00 | 0.5 | $237.50 |
| 12/21/2021 | DW | Review email from Op. Counsel | $425.00 | 0.1 | $42.50 | |
| 01/04/2022 | DW | Review | Review Clerk’s Motion to Amend Final Judgment | $425.00 | 0.1 | $42.50 |
| 01/04/2022 | DW | Review | Reviewed Clerk’s Notice of Appearance | $425.00 | 0.1 | $42.50 |
| 01/12/2022 | DW | Reviewed and replied to email from Op. Counsel | $425.00 | 0.2 | $85.00 | |
| 01/19/2022 | DW | Review & Analyze | Reviewed and replied to email from Op. Counsel | $425.00 | 0.5 | $212.50 |
| 01/26/2022 | DW | Review | Review Notice of Withdrawing Motion to Amend FJ | $425.00 | 0.1 | $42.50 |
| 01/26/2022 | DW | Emailed Clerk’s Motion for Sanctions to Client | $425.00 | 0.1 | $42.50 | |
| 01/27/2022 | DW | Review | Review PI’s Notice of Appeal | $425.00 | 0.1 | $42.50 |
| 01/28/2022 | DW | Review | Reviewed 4DCA Order, re: abeyance | $425.00 | 0.1 | $42.50 |
| 02/24/2022 | DW | Various | Review and analyze PI’s Response in Opposition to Aronberg Memo of Law & Motion for Atty Fees; meeting w/ AIJ to discuss | $425.00 | 1.5 | $637.50 |
| 02/24/2022 | AIJ | Meeting | Meeting w/ DAW, re: PI’s memo | $475.00 | 0.5 | $237.50 |
| 03/01/2022 | DW | Various | Review and reply to email from op. counsel, re: availability from 3/14 - 5/20; call w/ client; call w/ expert | $425.00 | 1.0 | $425.00 |
| 03/02/2022 | DW | Teleconference | Call w/ Client, re: upcoming hearing on 3/4 | $425.00 | 0.5 | $212.50 |
| 03/02/2022 | DW | Meeting | Meeting w/ AIJ, re: hearing in Palm Beach | $425.00 | 0.5 | $212.50 |
| 03/02/2022 | AIJ | Meeting | Meeting w/ DAW, re: hearing in Palm Beach | $475.00 | 0.5 | $237.50 |
| 03/03/2022 | DW | Reviewed and replied to email from opposing counsel | $425.00 | 0.2 | $85.00 | |
| 03/03/2022 | DW | Travel | Travel to West Palm Beach | $425.00 | 8.0 | $3,400.00 |
| 03/04/2022 | DW | Various | Attend hearing, meet w/ opposing counsel, call to Client, re: hearing date 4/26 and set follow-up call w/ Client | $425.00 | 2.5 | $1,062.50 |
| 03/04/2022 | DW | Travel | Travel back to Amelia island | $425.00 | 5.5 | $2,337.50 |
| 03/08/2022 | DW | Various | Call w/ Client, re: upcoming hearing, experts, plan; Meeting w/ AIJ | $425.00 | 1.0 | $425.00 |
| 03/08/2022 | AIJ | Meeting | Meeting w/ DAW, re: trip to Palm Beach | $475.00 | 0.5 | $237.50 |
| 03/10/2022 | DW | Reviewed and replied to email from Clerk’s counsel | $425.00 | 0.2 | $85.00 |
| 03/25/2022 | DW | Teleconference | Call to expert witness, re: fees, updated affidavits, hearing date | $425.00 | 0.2 | $85.00 |
|---|---|---|---|---|---|---|
| 03/30/2022 | DW | Review | Review Motion to Withdraw | $425.00 | 0.1 | $42.50 |
| 04/07/2022 | DW | Review | Review email from Op. Counsel | $425.00 | 0.1 | $42.50 |
| Totals: | 161.1 | $69,417.50 |
Expenses¶
| Date | EE | Activity | Description | Cost | Quantity | Line Total |
|---|---|---|---|---|---|---|
| 07/15/2021 | DW | Expense | Gas | $42.02 | 1.0 | $42.02 |
| 07/16/2021 | DW | Expense | The Ben West Palm Beach, re: 7/16/21 hearing | $557.46 | 1.0 | $557.46 |
| 07/17/2021 | DW | Expense | Gas | $59.12 | 1.0 | $59.12 |
| 03/03/2022 | DW | Expense | Gas | $70.41 | 1.0 | $70.41 |
| 03/04/2022 | DW | Expense | Hyatt Place West Palm Beach/Downtown, re: 3/4 hearing | $659.92 | 1.0 | $659.92 |
| 03/04/2022 | DW | Expense | Uber to Courthouse | $6.51 | 1.0 | $6.51 |
| 03/04/2022 | DW | Expense | Gas | $87.33 | 1.0 | $87.33 |
| Expense Total: | $1,482.77 |
| Time Entry Sub-Total: | $69,417.50 |
|---|---|
| Expense Sub-Total: | $1,482.77 |
| Sub-Total: | $70,900.27 |
| Total: | $70,900.27 |
| Amount Paid: | $0.00 |
| Balance Due: | $70,900.27 |
NOTA CERTIFIED¶