Opinion
CASE NO: 19-20060
04-05-2021
IN RE: JIMIE DIANNE OWSLEY, Debtor.
CHAPTER 11
MEMORANDUM OPINION
This fee dispute arises from the provision of legal services to the Debtor, Dr. Jimie Dianne Owsley, in connection with a state court family law proceeding. Dr. Owsley retained the applicant, Dale & Klein, LLP, as special litigation counsel to represent her in a suit to modify Dr. Owsley's parent-child relationship. Brian Owsley, Dr. Owsley's ex-husband, objected to Dale & Klein's fee request, asserting that Dale & Klein billed excessively and unnecessarily. In defense of its fee application, Dale & Klein asserts that its fees were, in part, incurred because Mr. Owsley was an uncompromising and "vexatious litigant."
Litigants in divorce and family law proceedings often feel enmity toward one another. Professionalism requires attorneys to strive to minimize—rather than participate in—acrimonious conduct. And when the costs of a family law proceeding are to be borne by a bankruptcy estate, it is incumbent on court-appointed attorneys to remain mindful that the estate must be preserved for the benefit of other creditors. Here, it appears the enmity between the Owsleys affected Dale & Klein's duty to act civilly, which resulted in elevated attorneys' fees. It would be inappropriate to force the estate to bear the burden of this lapse in professionalism.
Dale & Klein is awarded $84,164.29 in fees and expenses, a $45,556.64 reduction from the amount requested.
BACKGROUND
At times, Jimie Dianne Owsley's bankruptcy has seemed like a re-litigation of Dr. Owsley's 2015 divorce, which dissolved her marriage with Brian Owsley. Mr. Owsley has been an activate participant in Dr. Owsley's bankruptcy case, opposing many of the actions taken by Dr. Owsley in her effort to emerge from bankruptcy. In doing so, both Owsleys have attempted to dredge up issues related to their divorce and ongoing familial strife. Unfortunately, when Dr. Owsley sought to modify the parent-child relationship between her, Mr. Owsley, and their two children, cooler heads did not prevail.
Of course, as a party in interest, Mr. Owsley had every right to oppose actions that could affect the estate and its distribution.
Dale & Klein's Employment
Six months after filing for bankruptcy in early 2019, Dr. Owsley applied for authorization to retain Dale & Klein, LLP as special litigation counsel. (See ECF No. 45). Mr. Owsley objected to Dale & Klein's employment. (See ECF No. 52). Mr. Owsley's objection was overruled, and Dr. Owsley was authorized to retain Dale & Klein to provide legal services "limited to issues concerning modification of conservatorship, terms of possession and access, and child support in state court." (ECF No. 66 at 2).
Dale & Klein's Representation
Dale & Klein's authorized representation began on June 17, 2019. (ECF No. 45 at 5). During its representation, Dale & Klein:
[A]ssisted the Debtor in preparing a petition to modify the parent-child relationship and the prosecution of that suit, including conducting discovery and attending hearings, and conferences with Brian Owsley through his counsel; (2) assisted the Debtor in reviewing insurance renewals and proceeding with filing a notice of claim in connection with the malicious prosecution case filed against Debtor by Brian Owsley; (3) reviewed multiple volumes of the Nueces County District Clerk's record of the family law case; and (4) prepared temporary orders for the
modification of the parent-child relationship. Further hearings are set in the suit affecting parent-child relationship for April 2019.(ECF No. 162 at 3-4). While carrying out these tasks, Katie Pearson Klein, of Dale & Klein, attended Dr. Owsley's 2004 examination, which was noticed by Mr. Owsley. (ECF No. 216 at 1). Though, Dr. Owsley was primarily represented at the 2004 examination by her bankruptcy attorney. Ms. Klein also deposed Mr. Owsley as part of the discovery phase of Dr. Owsley's modification proceeding. (Appendix A at Entries 178, 220, 295, 305, 381-82, 403-04, 420, 466, 489, 501, 505-07). Additionally, Dale & Klein began preparing for a possible appeal of the Owsley's divorce decree. (ECF No. 216 at 2). Dale & Klein's representation culminated in a three-day trial on Dr. Owsley's petition to modify the Owsleys' parent-child relationship and the drafting of an order memorializing the state court's ruling on Dr. Owsley's petition. (Appendix A at Entries 560, 567, 572, 574, 577, 586, 589, 593-600, 602-05, 607-09, 612, 614-15, 617-22, 626, 629, 631-32, 635-641, 645-652, 663-66, 669-71, 673).
During Dr. Owsley's 2004 examination, Dr. Owsley was examined under oath by Mr. Owsley. (See ECF No. 233-1). At the 2004 examination, Mr. Owsley questioned Dr. Owsley about her finances. (See generally ECF No. 233-1). Mr. Owsley's questioning also raised issues related to the Owsleys' divorce, as well as other matters unrelated to Dr. Owsley's ability to satisfy her creditors' claims. (See, e.g., ECF No. 233-1 at 16, 31-32, 34-35). Though in attendance, Ms. Klein did not actively participate in Dr. Owsley's 2004 examination.
Although Mr. Owsley was represented by counsel in the state court proceeding, Mr. Owsley is also an attorney, who has at times represented himself in Dr. Owsley's bankruptcy case.
At Mr. Owsley's deposition, Ms. Klein questioned Mr. Owsley on topics related to his relationship with the Owsleys' children, his willingness to bear the children's medical costs, and his ability to parent the children. (See generally ECF No. 229-18). Mr. Owsley's deposition took six hours to complete (the maximum amount of time allowed for a deposition under the Texas Rules of Civil Procedure). (ECF No. 229-18 at 266:10-20). During the deposition, Ms. Klein, Mr. Owsley, and William Dudley, Mr. Owsley's counsel in the modification proceeding, were frequently less than courteous toward each other. (See, e.g., ECF No. 229-18 at 188:19-189:11).
After the three-day trial on Dr. Owsley's modification petition, the District Court for the 319th Judicial District, Nueces County, Texas issued a detailed ruling on Dr. Owsley's request for modification of the terms of her parent-child relationship. (See ECF No. 229-20 at 3-9). The court then left it to the parties to draft a written order memorializing the ruling. (ECF No. 229-20 at 14-15). In directing the parties to draft an agreed order, the court made clear that the order was to be a "regular SAPCR[] order with regular language, your regular conservatorship, your regular child support, transportation, your regular passport language, regular order." (ECF No. 229-20 at 14-16). However, the court left it to the parties to handle the order's treatment of the children's Christmas break. (See ECF No. 229-10 at 20). Despite the clarity of the court's ruling, the parties exchanged 14 drafts of the order, went before the court two additional times, and yet, more than a month after the court issued its ruling, the parties still had not reached an agreement on the form of the order. (See ECF Nos. 229-2-229-16).
"SAPCR" is an acronym for Suit Affecting the Parent-Child Relationship. See TEX. FAM. CODE. ANN. § 101.032 (West 2019).
Dale & Klein asserts that throughout its representation of Dr. Owsley, Mr. Owsley was an uncompromising, "vexatious" litigant. (ECF No. 216 at 4). Dale & Klein also contends that Mr. Dudley was regularly unresponsive, leading to "onerous" negotiations. (ECF No. 216 at 4). These factors, Dale & Klein contends, necessitated a "significant" expenditure of time. (ECF No. 216 at 4).
Dale & Klein's Fee Application
Dale & Klein now seeks fees for its representation under 11 U.S.C. §§ 330(a) and 331. Dale & Klein supports its request with two interim fee applications, one final fee application, and two amended applications. (ECF Nos. 162; 214; 220; 273; 297). Through these applications, Dale & Klein requests $126,128.14 in professional fees and $1,607.79 in expenses. (ECF No. 297 at 4). Dale & Klein also requests $1,995.00 in professional fees for services rendered prior to the effective date of the Order authorizing Dale & Klein's employment. (ECF No. 297 at 7). These compensation applications are supported by Dale & Klein's billing records. (See ECF Nos. 220-1; 297-3). While Dale & Klein's applications request a total of $128,123.14 in professional fees, Dale & Klein's billing records only evidence $127,641.50 in professional fees. (See Appendix A).
Mr. Owsley objected to Dale & Klein's fee request. (See ECF No. 202). Specifically, Mr. Owsley asserts that Dale & Klein: (1) incurred fees for work that was outside the scope of work this Court authorized Dale & Klein to perform; (2) incurred fees prior to receiving authorization to represent Dr. Owsley; and (3) billed excessively to the detriment of the estate. (ECF No. 202 at 3-9).
After Mr. Owsley filed his objection, Dale & Klein's application was set for a hearing. At this hearing, Ms. Klein largely reiterated the bases for Dale & Klein's fee request asserted in Dale & Klein's fee applications. (See generally Aug. 19, 2020 Hearing Recording). Likewise, Mr. Owsley maintained his objection to Dale & Klein's fee request. (See generally Aug. 19, 2020 Hearing Recording). Aside from maintaining their positions on Dale & Klein's fees, the parties chose to raise each other's conduct during the family law proceeding as an issue relevant to the dispute over Dale & Klein's fee request. (See Aug. 19, 2020 Hearing Recording at 8:48:00 AM). This choice led the Court to direct the parties to file copies of their communications, a transcript of Mr. Owsley's deposition, as well as all drafts of the modification order the parties were directed to submit to the state court. (Aug. 19, 2020 Hearing Recording at 8:46:30 AM).
Once both parties filed the requested documents, the Court took the matter under advisement. This Memorandum Opinion resolves the fee dispute.
JURISDICTION
The District Court has jurisdiction over this proceeding under 28 U.S.C § 1334(a). This is a core proceeding under 28 U.S.C. § 157(b)(2)(A) and (B). Pursuant to 28 U.S.C. § 157(a), this proceeding was referred to the Bankruptcy Court by General Order 2012-6.
DISCUSSION
Dale & Klein seeks professional fees and expenses under 11 U.S.C. §§ 328(a), 330(a), 331 for services rendered to Dr. Owsley. Dale & Klein was employed as special counsel under § 327(e). In this capacity, Dale & Klein was to provide legal services to Dr. Owsley related to a state court proceeding involving the "modification of conservatorship, terms of possession and access, and child support." (ECF No. 66 at 2). Brian Owsley, Dr. Owsley's ex-husband, challenges the amount of fees requested by Dale & Klein. Aside from Mr. Owsley's challenge, the Court has an independent duty to examine fee requests. In re King, 546 B.R. 682, 701 (Bankr. S.D. Tex. 2016). Dale & Klein's evidence in support of its fee application supports an award of $82,566.50 in fees and $1,607.79 in expenses.
Professionals employed under § 327 may seek reimbursement for reasonable and necessary fees and expenses under §§ 330(a) and 331. 11 U.S.C. §§ 330(a), 331 (2020). The amount of reasonable and necessary fees to which a professional is entitled is determined using the lodestar method. In re Pilgrim's Pride Corp., 690 F.3d 650, 656 (5th Cir. 2012); In re Cahill, 428 F.3d 536, 539 (5th Cir. 2005). The appropriate amount of compensation, calculated under the lodestar method (the "lodestar amount"), is the number of hours an attorney would reasonably spend on similar work multiplied by the prevailing hourly rate in the community. Cahill, 428 F.3d at 539; In re Lopez, 576 B.R. 84, 92 (Bankr. S.D. Tex. 2017) (citing In re Rodriguez, 517 B.R. 724, 730 (Bankr. S.D. Tex. 2014)). The Court may adjust the number of hours billed and the rates charged when calculating the lodestar amount. 11 U.S.C. § 330(a)(3).
Section 330(a) authorizes compensation for actual and necessary legal services rendered, including services performed by paraprofessionals. § 330(a)(1)(A). The Court considers the reasonableness and necessity of fees requested in light of six factors:
(A) the time spent on such services;11 U.S.C. § 330(a)(3)(A)-(F). The Court may consider additional relevant factors. In re Chapter 13 Fee Applications, MISC. 06-00305, 2006 WL 2850115, at *2 (Bankr. S.D. Tex. Oct. 3, 2006); see also Johnson v. Ga. Highway Express, Inc., 488 F.2d 714, 717-19 (5th Cir. 1974) (providing 12 factors courts may consider when determining an appropriate amount of fees to award). While all relevant factors must be considered, the Court retains "considerable discretion" in adjusting the lodestar amount. Cahill, 428 F.3d at 540. Despite being subject to the Court's discretion, the lodestar amount is presumed to be a reasonable calculation of the compensation award. In re Garza, No. 16-70444, 2020 WL 718444, at *5 (Bankr. S.D. Tex. Feb. 12, 2020) (citing Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542, 552 (2010)).
(B) the rates charged for such services;
(C) whether the services were necessary to the administration of, or beneficial at the time at which the service was rendered toward the completion of, a case under this title;
(D) whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed;
(E) with respect to a professional person, whether the person is board certified or otherwise has demonstrated skill and experience in the bankruptcy field; and
(F) whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under this title.
The party requesting a fee award bears the burden of establishing the reasonableness of its request. Louisiana Power & Light Co. v. Kellstrom, 50 F.3d 319, 324 (5th Cir. 1995) (citing Hensley v. Eckerhart, 461 U.S. 424, 437 (1983)). Meeting this burden requires the requesting party to submit documentation justifying the requested amount—normally, contemporaneous billing records. Id. The reasonableness inquiry centers on the applicant's "billing judgment" (i.e., the applicant's ability to differentiate between compensable and non-compensable fee requests). In re Cole, 18-35182, 2020 WL 4577236, at *10 (Bankr. S.D. Tex. July 20, 2020) (citing Saizan v. Delta Concrete Prod. Co., Inc., 448 F.3d 795, 799 (5th Cir. 2006)).
I. PRE-EMPLOYMENT FEE REQUEST
Dale & Klein seeks $1,995.00 in fees incurred prior to effective date of the Order authorizing Dale & Klein's employment. Bankruptcy courts, as courts of equity, enjoy the discretion to grant a nunc pro tunc order authorizing a professional's employment retroactively. In re Triangle Chems., Inc., 697 F.2d 1280, 1289 (5th Cir. 1983). The Southern District of Texas requires nunc pro tunc employment applications to include:
The Southern District of Texas's Local Rules provide that an approved employment application will be deemed contemporaneous with the beginning of the professional's services if it is filed within 30 days of the services' provision. BANKR. S.D. TEX. LOC. R. 2014-1(a). Dale & Klein's filed its application, which was approved, on July 17, 2019. (See ECF No. 45). Thus, Dale & Klein's approved employment was considered to have started on June 17, 2019. BANKR. S.D. TEX. LOC. R. 2014-1(a).
(A) An explanation of why the application was not filed earlier;
(B) An explanation why the order authorizing employment is required nunc pro tunc;BANKR. S.D. TEX. LOC. R. 2014-1(b). Dale & Klein bore the burden of establishing that it would have been employed under § 327(e) had the application been timely filed, as well as the burden of providing adequate explanations as required by Local Rule 2014-1(b). In re Decloutte, 12-35092, 2018 WL 3078153, at *14 (Bankr. S.D. Tex. June 20, 2018) (citing In re Lyons, 439 B.R. 401, 405 (Bankr. S.D. Tex. 2010)).
(C) An explanation, to the best of the applicant's knowledge, how approval of the application may prejudice any parties-in-interest.
Dale & Klein is not entitled to its pre-employment fees. First, Dale & Klein failed to file an application for a nunc pro tunc employment order. Instead, it simply requested fees incurred prior to its employment date. Such a request skirts the requirements of Local Rule 2014-1(a). Second, the only explanation Dale & Klein provides for its failure to timely file an employment application is that "[u]rgent family matters required advice." (ECF No. 216 at 2). This statement loosely satisfies Rule 2014-1(b)(2)(A). Dale & Klein offers nothing explaining why a nunc pro tunc order is now required. See BANKR. S.D. TEX. LOC. R. 2014-1(b)(2)(B)-(C). Moreover, this "urgency" explanation is undercut by the fact that five weeks elapsed between Dale & Klein's initial consultation with Dr. Owsley and the filing of Dale & Klein's employment application. (Compare Appendix A at Entry 1 with ECF No. 45).
While Dale & Klein's failings are referenced, it should be noted that it was Dr. Owsley's responsibility, through her bankruptcy counsel, to timely seek authorization to employ Dale & Klein. See 11 U.S.C. § 327(e).
Dale & Klein's pre-June 17, 2019 employment did not comply with 11 U.S.C. § 327(e). Despite being afforded the advantages of Local Rule 2014-1(a), Dale & Klein's application failed to cover its full term of employment. After missing the extended deadline provided in Local Rule 2014-1(a), Dale & Klein ignored the requirements for nunc pro tunc employment applications set out in Local Rule 2014-1(b). Yet Dale & Klein still expects the estate to bear its fees and expenses under § 330(a). The deficiencies in Dale & Klein's employment application preclude such an award; the request for $1,995.00 in pre-employment fees is denied. See In re American Hous. Found., 09-20232-RLJ-11, 2014 WL 2504510, at *5 (Bankr. N.D. Tex. June 3, 2014) ("The Bankruptcy Code does not authorize the payment of a professional whose employment has not been properly authorized.").
II. REASONABLE AND NECESSARY PROFESSIONAL FEES
Dale & Klein submitted billing records documenting a total of $125,646.50 in professional fees (excluding pre-employment fees). Nine professionals and paraprofessionals rendered services to Dr. Owsley. These professionals and paraprofessionals billed at hourly rates ranging between $350 per hour to $95 per hour. During its authorized employment, Dale & Klein expended 664.7 hours on Dr. Owsley's case. The following table provides a breakdown of the rates, hours, and requested fees attributable to Dale & Klein's professionals and paraprofessionals:
However, Dale & Klein's application requests $126,128.14 in professional and paraprofessional fees. The additional $481.64 requested in the application, which is unsupported by contemporaneous billing records, is disallowed. See La. Power & Light, 50 F.3d at 324.
| Billing Professional | Hourly Rate | Hours Expended | Fees Requested |
|---|---|---|---|
| Glendy Ogletree | $95/hour | 173.1 | $13,575.50 |
| Diana Staples | $95/hour | 3.2 | $304.00 |
| "Summarizer" | $95/hour | 160 | $15,200.00 |
| Sergio Cooper | $95/hour | 2.0 | $85.50 |
| Johnny Munoz | $95/hour | 2.7 | $209.00 |
| Sergio Garza | $225/hour | 3.8 | $855.00 |
| Uri Heller | $225/hour | 125.1 | $27,832.50 |
| William Mount Jr. | $300/hour | 4.0 | $1,200.00 |
| Katie P. Klein | 190.8 | $66,385.00 | |
| TOTALS | $125,646.50 |
Ms. Klein billed 0.2 hours at $300/hour on 12/8/2019.
In total, Dale & Klein wrote off 33.7 hours (roughly 5% of the total hours expended). The majority of these hours were billed at $95/hour.
A. Ethical Considerations in Awarding Fees Under 11 U.S.C. § 330(a)
The bankruptcy code required Dale & Klein to seek judicial approval of its fees. This requirement allows bankruptcy courts to protect the interests of creditors and debtors against overreaching professionals that will be compensated with estate funds. In re Temple Ret. Cmty., Inc., 97 B.R. 333, 336 (Bankr. W.D. Tex. 1989) (quoting FED. R. BANKR. P. 2017 advisory committee notes on the 1983 amendment). In fact, a court's award of fees "is confirmation that the fees . . . are reasonable and . . . represent compensation for actual and necessary services." Id. (citing In re Consolidated Bancshares, Inc., 785 F.2d 1249, 1255 (5th Cir. 1986)).
It is axiomatic that fees requested under § 330(a) must be reasonable and necessary. See Pilgrim's Pride, 690 F.3d at 656. An applicant's failure to uphold its ethical obligations may undermine the reasonableness and necessity of the fees requested. In re 437 Park Corp., 54 B.R. 326, 329 (Bankr. S.D.N.Y. 1985); see also In re Devers, 12 B.R. 140, 142 (D.D.C. 1981) ("Ethical violations are without question relevant to a fee determination."). In reviewing a fee application, the Court must ensure that court-appointed counsel adhered to "the highest standards of ethical conduct." Temple Ret. Cmty., 97 B.R. at 336 (quoting Consolidated Bancshares, 785 F.2d at 1255 (internal quotation marks omitted)). An applicant's failure to ethically represent the debtor diminishes the value of the applicant's services. Devers, 12 B.R. at 142 ("Unethical conduct on the part of an attorney in many cases will lessen the value of services to a client."). Unethical conduct that diminishes the value of services rendered by court-appointed counsel warrants a commensurate reduction in the fees awarded. See In re Cenargo Intern., PLC, 294 B.R. 571, 596 (Bankr. S.D.N.Y. 2003) ("[The] inquiry into the "value" of a professional's services often is described as a market-driven approach. . . . [O]ne may presume, subject to rebuttal, that the staffing and other practical decisions made by [court-appointed counsel] have been made in good faith in view of the attorneys' legal and ethical responsibilities as officers of the Court." (emphasis added and internal citations omitted)).
Dale & Klein's representation of Dr. Owsley left much to be desired from an ethical perspective. Lawyers, especially those practicing family law, are expected to avoid behavior that is discourteous to opposing counsel or adverse witnesses. See TEX. R. CIV. P. 199.5(d); see also Texas Lawyer's Creed art. III (Tex. & Tex. Crim. App. 1989), https://www.legalethicstexas.com/Downloads/Texas-Lawyers-Creed/Signed-Version-of-Texas-Lawyers-Creed ("A lawyer owes to opposing counsel, in the conduct of legal transactions and the pursuit of litigation, courtesy, candor, cooperation . . . . Ill feelings between clients shall not influence a lawyer's conduct, attitude, or demeanor toward opposing counsel."). Yet Katie Pearson Klein glaringly failed to act courteously during Mr. Owsley's deposition.
Ms. Klein's conduct at Mr. Owsley's deposition diminished the value of Dale & Klein's services. See Devers, 12 B.R. at 14; In re Grant, 14 B.R. 567, 569 (Bankr. S.D.N.Y. 1981) ("In reviewing an attorney's fee to determine whether it is reasonable . . . the Court must consider the nature of the services and the competence of the performance and it also must be guided by ethical considerations." (internal citations omitted)). At Mr. Owsley's deposition, Ms. Klein engaged in conduct inconsistent with Texas Rule of Civil Procedure 199.5 and with the ethical considerations that guide Texas attorneys. For example, Ms. Klein engaged in the following exchange with Mr. Owsley:
Tellingly, Texas saw fit to include an ethical demand in its Rules of Civil Procedure. See Tex. R. Civ. P. 199.5(d).
Q So your testimony is that subsequent to 2016 that you have paid Mr. Dudley over 153,500?(ECF No. 229-18 at 87:6-88:10). Rule 199.5(e), which provides that argumentative objections may be grounds for a deposition's termination or the imposition of sanctions, prohibits such exchanges. See TEX. R. CIV. P. 199.5(e). This was not Ms. Klein's only inappropriate string of objections. Over 100 pages later, the following exchange occurred:
MR. DUDLEY: Objection, form.
Q (Ms. Klein) Is that what you said? Did I understand you correctly?
A What I said is I paid him a lot of money, and it wouldn't shock --
Q Go ahead.
A Do not interrupt me, please. It would not shock me that it is north of $153,000, so --
Q And we're --
A For example, Judge Terrell found that I had spent --
Q Sir, I'm not asking --
A -- in excess of --
MS. KLEIN: Objection, nonresponsive.
A -- in excess of --
MS. KLEIN: Objection, nonresponsive.
A -- in excess --
MS. KLEIN: Objection, nonresponsive.
A -- in excess of --
MS. KLEIN: Objection, nonresponsive.
A -- in excess of $70,000 in attorney's fees.
MS. KLEIN: Objection, nonresponsive.
A It was quite likely more, and that was prior to August 20th of 2018, and I've been paying since then. So, yes, it's quite likely that it's over $153,000.
MS. KLEIN: Okay, sir. Objection, nonresponsive.
Q And is it true that the deductible under your health insurance policy is higher than the deductible under my client's health insurance?(ECF No. 229-18 at 197:17-198:11). Still, these were not the only objections lodged in violation Rule 199.5(e). (See, e.g., ECF No. 229-18 at 198:21-199:16; 208:11-210:11).
A I can't answer that, because I don't have any of the -- I don't have any of -- any -- any of the plan documents, or anything like that regarding your client's health insurance.
Q Okay, Sir --
A All I -- all I know -- all I know is --
MS. KLEIN: Objection, nonresponsive.
A All I know is that --
MS. KLEIN: Objection, nonresponsive.
A All I know is --
MS. KLEIN: Objection, nonresponsive.
A All I know is that when it was discussed, your client's health insurance costs significantly higher than mine for --
MS. KLEIN: Objection, nonresponsive.
A -- about the same coverage.
MS. KLEIN: Objection, nonresponsive.
Ms. Klein also failed to adhere to Rule 199.5(d) in questioning Mr. Owsley and addressing his attorney, William Dudley. Rule 199.5(d) requires oral depositions to "be conducted in the same manner as if the testimony were being obtained in court during trial." TEX. R. CIV. P. 199.5(d). Counsel at a deposition is also directed to "cooperate with and be courteous to each other and to the witness." TEX. R. CIV. P. 199.5(d). Absent from this rule is any provision authorizing retaliation based on opposing counsel's or the witness's conduct. Yet, in the following instances, Ms. Klein acted discourteously toward Mr. Owsley and Mr. Dudley in apparent retaliation:
Q (Ms. Klein) You did not answer my question. I am asking if you have paid any money to Dr. Owsley or to the Corpus Christi Fire Department for any portion of this bill? Yes, or no?(ECF No. 229-18 at 188:19-189:11).
A So --
Q No so, just yes, or no, sir?
A This is before the bankruptcy proceed -- court.
Q I don't care if it's before God, himself, sir. That is not responsive to the question. The question is whether or not --
MR. DUDLEY: Counsel --
MS. KLEIN: Excuse me.
Q (Ms. Klein) The question is --
MR. DUDLEY: Counsel, no, ma'am. I'm not going to allow you to throw God into this deposition. If you cannot --
MS. KLEIN: Oh, try stopping me.
Q Okay. And then it says, if a party incurs healthcare expenses for the children using out-of-network healthcare providers or services, or fails to follow health insurance company procedures or requirements, that party shall pay the healthcare expenses. Are you claiming --(ECF No. 229-18 at 249:11-250:7; see also ECF No. 229-18 at 28:2-29:3; 91:4-92:6).
MR. DUDLEY: Excuse me, Ms. Klein. You did not read what is on the paper accurately.
MS. KLEIN: Mr. -- that is not an appropriate objection as proper responsiveness. Mr. Dudley, you are limited in what you can say on the record.
Q (Ms. Klein) Mr. Owsley --
MR. DUDLEY: I'm instructing Brian Owsley not to answer an abusive question, when the question itself, specifically, says different from what the divorce decree says, and you're now trying to hide the language and go on to a different page.
MS. KLEIN: No, I'm trying to complete my deposition, which you and your client are desperately trying to keep me from doing. So I'll move on to something else, because I don't want to
It is not only these excerpts that are concerning. An air of incivility pervaded Mr. Owsley's deposition. The fact that Ms. Klein was not alone in behaving inappropriately does not excuse her conduct. Frankly, it is impossible to conclude that Ms. Klein would have conducted an examination of Mr. Owsley before a court in the same manner as Ms. Klein deposed Mr. Owsley. See TEX. R. CIV. P. 199.5(d) ("The oral deposition must be conducted in the same manner as if the testimony were being obtained in court during trial.").
Counsel's conduct at Mr. Owsley's deposition suggests that the quality of Dale & Klein's representation does not correlate to the amount of fees Dale & Klein requested. See In re Collida, 270 B.R. 209, 214 (Bankr. S.D. Tex. 2001) (interpreting § 330 as requiring courts to assess the effectiveness, efficiency, and professionalism of fee applicants). This conclusion is reinforced by Dale & Klein's conduct before this Court at a hearing on Dale & Klein's fee application. (See generally Aug. 19, 2020 Hearing Recording). At that hearing, the Court admonished Ms. Klein and Mr. Dudley, informing them that they had chosen to put in issue their professional conduct during the Owsleys' family law proceeding. (Aug. 19, 2020 Hearing Recording at 8:48:00 AM). This choice demands a review of Dale & Klein's fee application that scrutinizes whether Dale & Klein upheld "the highest standards of ethical conduct." Temple Ret. Cmty., 97 B.R. at 336; see also In re APW Enclosure Sys., Inc., 06-11378 (MFW), 2007 WL 3112414, at *4 (Bankr. D. Del. Oct. 23, 2007) (citing In re Penn-Dixie Indus., Inc., 18 B.R. 834, 838-39 (Bankr. S.D.N.Y. 1982)) (noting that the quality of an attorney's representation is valued in "hindsight"). Adherence to these standards bears directly on whether the estate received the full benefit of the fees requested. Cenargo Intern., 294 B.R. at 596.
B. Reduction of Excessive Fees
Dale & Klein requests fees for work not carried out with the requisite effectiveness, efficiency, and professionalism. This deficiency warrants reducing those fee requests that are excessive. Excessive fee requests include fees billed for redundant, duplicative, or unnecessary work. Cole, 2020 WL 4577236, at *13. Fees billed for purely clerical work are also excessive. Symetra Life Ins. Co. v. Rapid Settlements, Ltd., CIV.A. H-05-3167, 2015 WL 6739022, at *8 (S.D. Tex. Nov. 4, 2015) (citing Abrams v. Baylor Coll. of Med., 805 F.2d 528, 535 (5th Cir. 1986)); see also Garza, 2020 WL 718444, at *4, *4 n.36 (disallowing fees for ministerial tasks (i.e., those tasks not requiring specialized legal knowledge)). Dale & Klein was expected to reduce excessive billing entries or, instead, demonstrate that such entries were reasonable and necessary. Saizan, 448 F.3d at 799; see also In re Steinkuehler, 14-34808-H3-13, 2016 WL 921748, at *4 (Bankr. S.D. Tex. Mar. 9, 2016) ("The court should not have to guess or spend excessive court time to justify a fee for an applicant who has not done so for himself or herself."). Nevertheless, Dale & Klein's application contains numerous excessive entries.
1. Excessive, Duplicative, or Unnecessary Fee Requests
Fee requests are excessive when an inordinate amount of time was billed for a specific task. See In re 1002 Gemini Interests LLC, No. 11- 38815, 2015 WL 913542, at *10 (Bankr. S.D. Tex. Feb. 27, 2015) (finding work to be excessive where fewer hours were billed for similar tasks previously undertaken). Requests for fees on account of unnecessary or duplicative work are also excessive. Cole, 2020 WL 4577236, at *13. Dale & Klein bore the burden of proving the necessity of its requests, especially those requests that appear duplicative or redundant. Id. at *12.
The following billing entries are representative of Dale & Klein's excessive, duplicative, and unnecessary fee requests:
| Date | BillingProfessional | Description | FeesRequested | Reason forReduction |
|---|---|---|---|---|
| 6/29/2019 | KPK | Memo regarding "things to do." | $350.00 | Duplicative |
| 6/29/2019 | KPK | Draft correspondence to ChristineCortez. | $105.00 | Duplicative |
| 6/29/2019 | KPK | Memo regarding conference call. | $140.00 | Duplicative |
| 12/13/2019 | KPK | Attend hearing on TemporaryOrders & return travel (150 miles). | $3,850 | Excessive |
| 5/28/2020 | KPK | Prepare for and take the depositionof Brian Owsley | $3,850.00 | Excessive |
| 12/22/2019 | S | Summarizing Vol. I of Clerk'sRecord on Appeal. | $380.00 | Unnecessary |
| 7/21/2020 | UH | Reviewed objection to DK fees. | $90.00 | Non-Compensable |
| 7/21/2020 | UH | Legal research regarding responseto objection fees. | $315.00 | Non-Compensable |
Dale & Klein requests fees that exceed the value of certain services rendered to Dr. Owsley. For instance, on December 13, 2019, Ms. Klein billed $3,850 for the 11 hours it took to attend a hearing and travel 150 miles. First, the entry is "block-billed," which precludes a meaningful assessment of its reasonableness. Gurule, 2017 WL 6761821, at *4. Second, while not uniformly recognized as unreasonable, billing full hourly rates for travel time is a questionable practice. Rodriguez, 517 B.R. at 735 (reviewing cases in which fee awards were reduced for billing travel time at full hourly rates). It is especially difficult to justify charging a full hourly rate for unproductive travel time. See id. (finding that a 50% reduction in fees billed for unproductive travel time to be appropriate). Here, Dale & Klein failed to justify the hourly rate charged on account of Ms. Klein's travel. Without justification, the fee request is unreasonable and excessive. A commensurate reduction in fees is appropriate.
"The term 'block billing' refers to the time-keeping method by which each lawyer and legal assistant enters the total daily time spent working on a case, rather than itemizing the time expended on specific tasks." Gurule v. Land Guardian, Inc., 4:15-CV-03487, 2017 WL 6761821, at *4 (S.D. Tex. Oct. 24, 2017), aff'd, 912 F.3d 252 (5th Cir. 2018) (quoting Robinson v. City of Edmond, 160 F.3d 1275, 1284 n. 9 (10th Cir. 1998)).
Similarly, Dale & Klein's fee requests related to Mr. Owsley's deposition are excessive. An example of this excess is the May 28, 2020 billing entry for the 11 hours Ms. Klein spent preparing for and taking Mr. Owsley's deposition. Dale & Klein requests $3,850.00 on account of this billing entry alone. However, Ms. Klein's conduct at the deposition demonstrates that such an award would be excessive. See Cenargo Intern., 294 B.R. at 596 (noting that ethical considerations may affect the value of the professional services rendered); see also Temple Ret. Cmty., 97 B.R. at 336 (affirming that courts reviewing fee applications should ensure that applicants upheld the "highest ethical standards"). Moreover, at the fee application hearing, it came to light that Dale & Klein was uncompromising in its attempts to depose Mr. Owsley in-person during the early days of the coronavirus pandemic. (Aug. 19, 2020 Hearing at 8:31:00). These facts suggest that the hours expended in pursuit of deposing Mr. Owsley were excessive.
Dale & Klein's billing records disclose an expenditure of at least 28 hours on tasks directly related to Mr. Owsley's six-hour deposition, which covered only a narrow array of topics. Not only does Dale & Klein's conduct suggest excess, so too does the discrepancy between the time expended and the benefit secured by the deposition. Court-appointed counsel must be mindful that its role is to aid the debtor in acting in the best interests of the estate. ICM Notes, Ltd. v. Andrews & Kurth, L.L.P., 278 B.R. 117, 124 (S.D. Tex. 2002), aff'd sub nom. In re ICM Notes Ltd., 324 F.3d 768 (5th Cir. 2003). With respect to Mr. Owsley's deposition, it appears Dale & Klein forgot its role, if not abdicated it entirely.
Appendix A at Entries 178, 220, 295, 305, 381-82, 403-04, 420, 466, 489, 501, 505-07.
Like its efforts to depose Mr. Owsley, Dale & Klein's efforts to reach an agreement on the form of order modifying the Owsleys' parent-child relationship were excessive. The state court made clear that the parties were to draft a "regular SAPCR order with regular language, your regular conservatorship, your regular child support, transportation, your regular passport language, regular order." (ECF No. 229-20 at 14-16). Despite the clarity of the court's ruling, Dale & Klein's first draft order did not include language required by the Texas Family Code. (ECF No. 229-21 at 84-85). Dale & Klein also waited 12 days from the court's oral ruling to send a draft order to Mr. Owsley's counsel, even though the court directed Dale & Klein to provide a draft within ten days of the ruling. (See ECF No. 233-3 at 1). It was not until 18 days after the court's ruling that Dale & Klein sent Mr. Owsley's counsel a draft order containing the language required by the Texas Family Code. (ECF No. 229-21 at 84-85). This left just nine days for Mr. Owsley's counsel to review the proposed order, provide comments, and allow the parties to come to an agreement before the draft order was due to the court. (See ECF No. 229-20 at 15).
Inevitably, the parties did not reach an agreement regarding the form of order by the court-mandated deadline. (See ECF No. 233-5 at 45). This failure meant that the parties had to again appear before the court, where the court attempted to resolve the parties' remaining disagreements. (See ECF No. 233-7 at 7). Yet the parties continued to go back and forth over the order's provisions, necessitating another hearing and further direction from the court. (See ECF Nos. 233-10 at 1-7, 11, 106, 233-12 at 1). More than a month after the state court issued its oral ruling, the parties still could not agree on a form of order. (See ECF No. 233-14 at 2).
Dale & Klein expended 49.40 hours attempting to provide the court with an agreeable draft order modifying the Owsleys' parent-child relationship. This was time expended after Dale & Klein spent more than 70 hours preparing for and attending the trial on Dr. Owsley's petition to modify the parent-child relationship. Perhaps, given Dale & Klein's own uncompromising interactions with Mr. Owsley and his counsel, it is unsurprising that Dale & Klein spent almost 50 hours attempting to draft a "regular SAPCR" order. However, with Dale & Klein's claim of expertise and experience, which it used to justify Ms. Klein's hourly rate, (ECF No. 214 at 6), came an expectation that Dale & Klein would rely on that experience to render professional services efficiently. See Collida, 270 B.R. at 214; see also ICM Notes, 278 B.R. at 124 (noting that professional employed by the estate are expected to remain mindful of the necessity of preserving the value of the estate). Despite this expectation, and consistent with the evidence submitted by the parties and Mr. Dudley's unrebutted testimony before this Court, it appears Dale & Klein failed to work efficiently and professionally in drafting the proposed agreed order. (See August 19, 2020 Hearing at 8:28:30).
Appendix A at Entries 560, 567, 572, 574, 577, 586, 589, 593-600, 602-05, 607-09, 612, 614-15, 617-22, 626, 629, 631-32, 635-641, 645-652, 663-66, 669-71, 673.
See Appendix A.
The only explanation Dale & Klein offers for its inefficiency is that Mr. Owsley was the uncompromising one. (ECF No. 216 at 4). Still, Dale & Klein qualifies this explanation by pointing to Mr. Owsley's actions that necessitated judicial intervention before the state court issued its ruling. (ECF No. 216 at 4). This does nothing to explain the workweek of time expended drafting a "regular SAPCR" order after there had been judicial intervention. Without an explanation, and in light of Dale & Klein's own prior uncompromising conduct, it is appropriate to conclude this expenditure was excessive. See La. Power & Light, 50 F.3d at 324 (holding that a fee applicant must demonstrate the reasonableness of the fees incurred). While litigants' attorneys should zealously advocate for their clients and strive to protect their clients' rights (practices this Court does not intend to chill), Dale & Klein's unprofessional conduct necessarily affects the reasonableness assessment to which Dale & Klein's fee request is subject. See APW Enclosure Sys., 2007 WL 3112414, at *4 (noting that the quality of an attorney's representation is valued in "hindsight").
Excessive fee entries should be excluded or reduced to ameliorate the excess. Cole, 2020 WL 4577236, at *10. Rudeness and repetition prolong depositions. Failing to work diligently and cooperatively with opposing counsel prolongs negotiations. Based on this Court's observations in open Court, Ms. Klein's inappropriate behavior unnecessarily and excessively expanded the number of hours Dale & Klein billed. The estate will not bear the excess resulting from Ms. Klein's unprofessional conduct. Dale & Klein's excessive fee requests are reduced by 50%. See, e.g., In re Skyport Glob. Communications, Inc., 450 B.R. 637, 651 (Bankr. S.D. Tex. 2011) (excluding excessive fee entries entirely); In re Henry S. Miller Com., LLC, 09-34422-SGJ-11, 2010 WL 4638882, at *1 (Bankr. N.D. Tex. Nov. 8, 2010) (reducing fees by 40% overall due in part to the inclusion of excessive fee requests); In re Teraforce Tech. Corp., 347 B.R. 838, 865 (Bankr. N.D. Tex. 2006) (noting the excessiveness of certain billing entries and reducing fees by roughly 25% overall); Lopez, 576 B.R. at 102 (reducing excessive time entries by 25%); Cole, 2020 WL 4577236, at *13 (reducing excessive time entries by 25%). In total, Dale & Klein's fee request is reduced by $9,878.50 on account of excessive billing.
Appendix A at Entries 178, 220, 295, 305, 381-82, 403-04, 420, 466, 489, 501, 505-07, 509-10, 560, 567, 572, 574, 577, 586, 589, 593-600, 602-05, 607-09, 612, 614-15, 617-22, 626, 629, 631-32, 635-641, 645-652, 663-66, 669-71, 673.
The three billing entries from June 29, 2019 are duplicative. Dale & Klein's billing records reflect three separate entries from the same day, with the same description, requesting the same amount of fees. Such entries are blatantly duplicative. These fee requests, as well as the other duplicative requests identified in Dale & Klein's billing records are disallowed. Watkins v. Fordice, 7 F.3d 453, 457 (5th Cir. 1993) (citing Hensley, 461 U.S. at 432) ("[T]he court should exclude all time that is . . . duplicative . . . ."). Accordingly, $2,539.00 in fees is excluded.
See Appendix A at Entries 23-25, 50, 123, 172, 312, 349, 399, 493, 653-59.
Dale & Klein also performed unnecessary work related to a possible appeal. This work was not only unnecessary, it also exceeded the scope of work this Court authorized Dale & Klein to perform. (See ECF No. 66 at 2). Dale & Klein justifies its expenditure of time related to a possible appeal by asserting that Debtor's counsel "discussed the possibility of filing a motion to expand the role of Dale & Klein . . . in handling an appeal on issues that have been stayed . . . ." (ECF No. 216 at 2). Dale & Klein never sought such an expansion.
Despite there only being a "possibility" Dale & Klein's role would be expanded to handle a "possible appeal," Dale & Klein billed $10,260.00 for 108.00 hours spent preparing to litigate an appeal that was never commenced. This prolific expenditure is supported by a single sentence (quoted above) in Dale & Klein's response to Mr. Owsley fee objection, as well as bare billing descriptions similar to the December 22, 2019 example in the above table. No additional evidence contextualizing, much less justifying this request was offered.
See Appendix A at Entries 243, 247, 252-54, 256, 258-59, 264, 266, 269, 272, 275, 278,280, 297, 299, 301-303.
As the applicant, Dale & Klein had to establish the reasonableness and necessity of its fee requests. La. Power & Light, 50 F.3d at 324. Fees that are not proven to be reasonable or necessary must be excluded. Cole, 2020 WL 4577236, at *13. Based on the evidenced offered, Dale & Klein failed to establish that the fees related to a "possible appeal" were reasonable and necessary. Essentially, Dale & Klein could not have concluded that its $10,260.00 expenditure was reasonably likely to benefit the estate based on a mere suggestion that an appeal might be filed. See In re Woerner, 783 F.3d 266, 268 (5th Cir. 2015) (requiring reviewing courts to prospectively consider the reasonableness and necessity of fee requests). Moreover, Dale & Klein knew its employment was limited to rendering services related "to issues concerning modification of conservatorship, terms of possession and access, and child support in state court." (ECF No. 66 at 2). Fees incurred for services not authorized by the Employment Order will be excluded. See, e.g., 1002 Gemini, 2015 WL 913542, at *6-8 (excluding an examiner's fees incurred outside the scope of the examiner's statutory duties); accord In re Senior Living Props., LLC, 02-34243-SAF-11, 2004 WL 1683147, at *3 (Bankr. N.D. Tex. Apr. 28, 2004) (reducing fees an applicant did not have court authorization to incur but allowing a portion of the requested fees because the work "benefitted the estate"); In re Cuisine Magazine, Inc., 61 B.R. 210, 216 (Bankr. S.D.N.Y. 1986) (citing In re Futuronics Corp., 655 F.2d 463, 470 (2d Cir. 1981)) ("[T]he services rendered by [the applicant] . . . were unauthorized and, thus, not compensable. . . . The fact that such unauthorized services may have been beneficial to the estate is immaterial." (internal citations omitted)).
Dale & Klein billed additional time related to background research for the "possible appeal." See Appendix A at Entries 437, 439, 441-43. For this time, Dale & Klein will be afforded some leeway as the record suggests that Debtor's bankruptcy counsel may have sought information from Dale & Klein regarding a possible appeal.
While not, strictly speaking, "unnecessary," certain fees requested by Dale & Klein are not compensable under Baker Botts L.L.P. v. ASARCO LLC, 576 U.S. 121, 135 (2015). ASARCO precludes § 330(a) applicants from recovering fees incurred in defense of a fee application. See id. ("Section 330(a)(1) itself does not authorize the award of fees for defending a fee application, and that is the end of the matter."). The July 21, 2020 entries in the above table provide a couple examples of non-compensable fees requested by Dale & Klein. Dale & Klein requests $3,552.50 in fees in violation of ASARCO, all of which are excluded.
Appendix A at Entries 448, 587-88, 672, 676-77, 680-83, 685-87, 689, 694, 699.
2. Purely Clerical Fee Requests
Dale & Klein seeks fees for non-compensable clerical work. Billing full hourly rates for purely clerical tasks is excessive. Rather, clerical tasks must be billed at a reduced rate. Meadows v. Latshaw Drilling Co., LLC, No. 3:15-CV-1173-N, 2020 WL 291582, at *4 (N.D. Tex. Jan. 21, 2020) (citing Champion v. ADT Sec. Servs., Inc., 2010 WL 4736908, at *6 (E.D. Tex. Nov. 16, 2010)). Some clerical tasks are not compensable at all and are instead considered unrecoverable overhead expenses. In re Garza, 2020 WL 718444, at *4; see also Meadows, 2020 WL 291582, at *4 (citing Carroll v. Sanderson Farms, Inc., 2014 WL 549380, at *17-18 (S.D. Tex. Feb. 11, 2014)) ("Clerical duties consist of, among other things, . . . maintaining files, copying, printing, labeling, and emailing documents, and communicating with court staff."). Writing off non-compensable clerical work is an expectation when it comes to exercising "billing judgment." Carroll, 2014 WL 549380, at *16.
Having paralegals perform clerical tasks does not make fees for those tasks compensable. See In re Contreras, No. 16-34693, 2019 WL 1868622, at *3 (Bankr. S.D. Tex. Apr. 25, 2019) ("Just because . . . paralegals [are] performing secretarial work does not make that work compensable."). Instead, billing paralegal time is appropriate where the paralegal performs legal work. In re Garza, 16-70444, 2020 WL 718444, at *4 (Bankr. S.D. Tex. Feb. 12, 2020).
The below table offers some examples of non-compensable clerical billing entries.
| Date | BillingProfessional | Description | FeesRequested | Reason forReduction |
|---|---|---|---|---|
| 7/3/2019 | GO | Forwarded email to clientrequesting copies of insurancepolicies. | $9.50 | Clerical |
| 5/27/2020 | UH | Set up drop box for supplementaldiscovery. | $90.00 | Clerical |
| 9/24/2020 | GO | Download of multiple attachmentsto correspondence from opposingcounsel regarding Respondent'spayments as per court's order;forwarded same to client; | $38.00 | Clerical |
Appendix A at Entries 10, 13, 29, 31, 58, 91, 101, 126, 138, 158, 164, 170, 180, 200, 246, 310, 470, 504, 571, 585, 707, 711, 719.
Disallowing or reducing fees billed for clerical work is appropriate where an applicant has failed to do so. See, e.g., Symetra, 2015 WL 6739022, at *8 (noting that clerical tasks are generally not compensable and reducing a fee award by 3% on account of clerical work). Dale & Klein requests a mere $432.00 on account of purely clerical billing entries. Many other clerical billing entries were notably written off. Still, the $432.00 should not have been requested and is disallowed. See id.; Alto-Shaam, Inc., 2012 WL 12978015, at *7 (reducing fees by 5% overall on account of clerical fee requests).
However, compensation is sought for many purely clerical tasks through Dale & Klein's block-billed billing records. See, e.g., Appendix at Entries 15, 136, 316.
C. Reduction of Inadequately Documented Fees
Vague and "block-billed" time entries do not offer sufficient evidence of their reasonableness and necessity. Lopez, 576 B.R. at 102 (citing In re Digerati Tech., Inc., 537 B.R. 317, 333 (Bankr. S.D. Tex. 2015)). Vague billing descriptions are those that cannot be "meaningful[ly] review[ed]." La. Power & Light, 50 F.3d at 326 (citing Leroy v. City of Hous., 906 F.2d 1068, 1080 (5th Cir. 1990)). Similarly, block billing prevents the Court from determining whether the time spent on each individual task was reasonable. Gurule, 2017 WL 6761821, at *4. These types of inadequately documented fee requests do not sufficiently demonstrate the reasonableness or necessity of the time expended. Lopez, 576 B.R. at 102.
Again, a reduction in the fee award is appropriate when the fee request is supported by vague or block-billed time entries. Lopez, 576 B.R. at 102. This reduction should be commensurate with the egregiousness of the inadequacy in documentation. See, e.g., Symetra, 2015 WL 6739022, at *7 (noting that both a 10% reduction and a 40% reduction in block-billed time entries were appropriate reductions based on the egregiousness of the block-billing in each instance).
The table below contains a few examples of Dale & Klein's block billing:
| Date | BillingProfessional | Description | FeesRequested | Reason forReduction |
|---|---|---|---|---|
| 4/3/2020 | GO | Various attempts to reach courtreporter on hearing transcripts;forwarded email to client on same;forwarded to client invoice and linkfrom court reporter on payment fortranscripts; forwarded various emailsfrom and to opposing counsel toclient; telephone conference withcourt reporter on transcripts; (2)telephone conferences with Lanawith opposing counsel regardingexchange of child and emailsbetween Mr. Dudley and Ms. Cortezon same; copies to client. | 123.50 | Block Billed |
| 5/13/2020 | KPK | Prepare for hearing; schedulehearing; confer regardingBankruptcy matter & prepare forhearing. | $700.00 | Block Billed |
| 6/24/2020 | GO | Continued working on preparationsfor trial; worked on trial exhibits;visit with client; forwarded email toLindsey with Dr. Kit Harrisonregarding testimony; forwardedvoice message to V. Shuey onrespondent records; telephoneconference with Marilee withNueces District Court regardingexhibits; forwarded deposition pagelines to opposing counsel; efiledsame with court. | $579.50 | Block Billed |
See Appendix A at Entries 15, 18, 26-27, 33, 37, 40, 45, 47, 51, 55, 68, 74-75, 89, 98, 99, 117, 122, 129, 136, 141, 151, 156, 161-62, 171, 175-77, 187, 192-94, 209, 212, 215, 218-19, 224, 226, 232, 238, 241-42, 263, 268, 274, 280, 286, 307, 314, 316, 319-20, 324, 327, 329, 331, 334-35, 343, 347, 354, 360, 371, 377, 379, 388-89, 394, 399, 405, 418, 423, 439-40, 447, 452, 463, 468-69, 474, 476, 478-79, 481, 483, 492, 517, 528, 530, 534-35, 538, 542, 550, 554, 564, 569, 592, 598, 601, 613, 625, 628, 634, 644, 668, 675, 698.
A commensurate reduction is warranted. Because Dale & Klein exercised some judgment in writing off certain clerical work, a middle-ground reduction of 25% applied to block-billed entries is appropriate. See Cole, 2020 WL 4577236, at *13 (citing Lopez, 576 B.R. at 102) (reducing vague and redundant entries by 25%); see also Symetra, 2015 WL 6739022, at *7; In re Ritchey, 512 B.R. 847, 871-72 (Bankr. S.D. Tex. 2014) (reducing fees supported by block-billed descriptions by 75%). This amounts to a disallowance of $5,294.88 in requested fees.
Aside from its block-billing, Dale & Klein also requests fees for vaguely documented work. These descriptions force the Court to guess about the reasonableness and necessity of the fees requested. King, 546 B.R. at 712 (citing In re Evangeline Ref. Co., 890 F.2d 1312, 1326 (5th Cir. 1989) ("The reviewing court should not venture guesses nor undertake extensive investigation to justify a fee for an attorney or trustee who has not done so himself. It is not an overly burdensome task to enlighten the court as to the work undertaken.")). A few exemplary entries are provided in the following table:
| Date | BillingProfessional | Description | FeesRequested | Reason forReduction |
|---|---|---|---|---|
| 10/21/2019 | KPK | Read email. | $105.00 | Vague |
| 10/31/2019 | KPK | Multiple teleconferences. | $525.00 | Vague |
| 12/17/2019 | KPK | Prepared detailed memo regarding"things to do." | $245.00 | Vague |
| 1/20/2020 | S | Deposition Summaries of Owsleycontinued. | $760.00 | Vague |
In total, $14,302.50 is requested on account of vaguely documented billing entries. In both the October 21 and 31 entries, Dale & Klein failed to provide sufficient detail to support a fee award on account of this work. Dale & Klein's billing descriptions do not specify who was involved in the teleconferences, who the emails were from, or even how this time related to Dr. Owsley's case. See, e.g., Digerati Techs, 537 B.R. at 333 (classifying as "vague" billing entries on account of "conferences" that omitted the conference's subject matter and participants).
See Appendix A at Entries 20, 22, 36, 71, 78, 86, 106-08, 137, 143-45, 149, 154, 159, 165-66, 196, 221, 231, 260, 276, 281, 287, 289-90, 292, 298, 304, 306, 333, 340, 350, 358, 373-74, 378, 392, 395, 401, 412, 414, 431-32, 436, 484, 490, 515, 518, 523, 543, 547, 557-59, 562, 590, 523, 692, 697, 701, 712, 726.
The December 17, 2019 entry seeks fees for the preparation of a "detailed memo regarding 'things to do.'" This entry is vague as it does not evidence why Dale & Klein should be awarded $245.00 for a memo regarding the vaguely described subject: "things to do." See Lopez, 576 B.R. at 102. Dale & Klein seeks fees for multiple similar "memos" prepared by Ms. Klein, but nothing in the billing records or Ms. Klein's testimony reveal how these "memos" were used or why they were prepared. The billing records do suggest the "memos" may have been used as a form of interoffice communication. Interoffice communications are generally compensable. Cole, 2020 WL 4577236, at *13. However, fees for unreasonable, inefficient interoffice communications should be written off or reduced. See id. (reducing fee requests for inefficient interoffice communications); see also Collida, 270 B.R. at 214 (noting that the bankruptcy code requires an assessment of a fee applicant's efficiency). Dale & Klein seeks $7587.50 in fees related to the preparation of "memos" that are not supported by sufficiently detailed billing descriptions. The Court will not dictate how lawyers are to communicate with their colleagues. However, Dale & Klein's fee requests for the use and preparation of "memos," which were prepared at full hourly rates, is not reasonable without more justification.
See, e.g., Appendix A at Entries 20, 22, 36, 106, 221, 231, 260, 276, 287, 304, 306, 333, 340, 358, 414, 436, 515, 518, 590, 692.
Compare Appendix A at 333 with Appendix A at 336.
Some of these fees were disallowed or reduced for reasons other than being supported by vague documentation.
Finally, $4,370.00 is requested for 46 hours spent summarizing certain background documents related to the Owsleys' family law proceeding. The January 20, 2020 entry is an example of the descriptions given to support these requests. These entries generally describe what was summarized, but they do not explain why the summaries were necessary or whether the summaries were ever even used by Dale & Klein's professionals. Without an explanation, the sheer volume of time expended raises efficiency concerns, thereby undermining the reasonableness request. See Collida, 270 B.R. at 214.
Appendix A at Entries 281, 290, 395, 401, 412, 543, 547. These entries are differentiated from the disallowed fees related to Dale & Klein's summarization of the appellate record in the Owsleys' case. The entries reduced for vagueness suggest that they may have been related to Dale & Klein's review of the background of the Owsleys' family law proceeding.
Dale & Klein asserts that it was required to review the "lengthy history" of the Owsleys' divorce so Dale & Klein could protect the rights of Dr. Owsley. (ECF No. 216 at 4-5). While reviewing a client's case is of paramount importance, applicants should not spend an excessive amount of time on their review. Cf. Cahill, 428 F.3d at 542 (affirming a finding that an applicant's fee request should be reduced due to "excessive time" spent bringing other lawyers "up to speed" on tasks). The evidence offered in support of Dale & Klein's fee request demonstrates little to no reliance by Dale & Klein's professionals on these voluminous and costly summaries.
Because these fee requests, as well as other vaguely supported fee requests, do not sufficiently demonstrate their reasonableness or necessity, a reduction in fees is appropriate. See Lopez, 576 B.R. at 102 (quoting Digerati Tech., 537 B.R. at 333) ("Time entries that do not provide sufficient detail to determine whether the services described are compensable may be disallowed due to vagueness." (internal quotation marks omitted)). Dale & Klein's fee requests that are supported by vague billing entries are reduced by 25%. See id. (reducing fees by 20% on account of vague billing entries); Cole, 2020 WL 4577236, at *13 (reducing vague fee requests by 25%); Rodriguez, at 736 (reducing vague fee requests by 50%); Teraforce Tech., 347 B.R. at 859 (reducing fee requests for vague billing entries by roughly 15%). Dale & Klein's fees are reduced by $3,575.62.
D. Remaining Fee Requests
Dale & Klein's remaining fee requests were reasonable and necessary. Given the broad scope of factors relevant to a parent-child relationship modification, Dale & Klein reasonably undertook work that may not have been directly related to the parties' family law dispute. See, e.g., Holley v. Adams, 544 S.W.2d 367, 371-72 (Tex. 1976) (enumerating nine factors that bear on whether modification of a parental conservatorship is in the "best interest of the child"); see also, e.g., TEX. FAM. CODE ANN. § 154.123(b) (setting out 17 factors that can be considered in awarding child support that is in the "best interest of the child").
For example, Dale & Klein billed for Ms. Klein's attendance at Dr. Owsley's 2004 examination. (ECF No. 202 at 3). During the 2004 examination, Dr. Owsley was questioned about her finances, a topic which directly affected the adjudication of Dr. Owsley's modification action. See TEX. FAM. CODE ANN. § 154.123(b)(2), (3) ("(2) the ability of the parents to contribute to the support of the child; (3) any financial resources available for the support of the child . . . ."). Another example is the time Dale & Klein spent determining whether Dr. Owsley's insurance would cover the cost of defending a "malicious prosecution" suit. (ECF No. 216 at 2). Dr. Owsley's responsibility for defense costs would bear directly on her ability to contribute to her children's support. See TEX. FAM. CODE ANN. § 154.123(b)(2).
Given the malleable standards governing family law disputes, and the vast array of factors bearing on those standards, Dale & Klein reasonably and necessarily incurred fees for tasks related to those factors.
E. Reasonableness of the Hourly Rates Charged
When taken out of context, Dale & Klein's hourly rates appear reasonable. Under the lodestar method, the reasonableness of a professional's hourly rate is determined in light of the prevailing hourly rates within the community in which the professional practices. Cahill, 428 F.3d at 539. In this case, "professional" is the operative word. Ms. Klein's conduct was less than professional, thereby warranting a reduction in her hourly rate. Devers, 12 B.R. at 142 ("Unethical conduct on the part of an attorney in many cases will lessen the value of services to a client.").
In its employment application, Dale & Klein disclosed its hourly rates. (ECF No. 45 at 3). Mr. Owsley objected to the application but did not take issue with Dale & Klein's hourly rates. (See ECF No. 51). Nor did Mr. Owsley object to Dale & Klein's hourly rates in opposition to Dale & Klein's fee application. (See ECF No. 202). Dale & Klein's rates were approved as reasonable rates prevailing in the community under 11 U.S.C. § 328(a). (See ECF No. 66).
Dale & Klein charged $350 per hour for the work of Ms. Klein, $300 per hour for work done by partners, $225 per hour for the work of associates, and $95 per hour for legal assistants' work. While Dale & Klein offered little evidence to establish the reasonableness of its hourly rates, that evidence is mostly uncontroverted. Based on authority in southeastern Texas, most of Dale & Klein's rates were reasonable. See Coffman v. Coffman, 13-12-00303-CV, 2014 WL 7465596, at *5 (Tex. App.—Corpus Christi Dec. 30, 2014, no pet.) (approving a fee request for fees billed at $350 per hour); Alamo Country Club Owners Ass'n v. Shelton, 13-10-00300-CV, 2012 WL 3792753, at *26 (Tex. App.—Corpus Christi Aug. 31, 2012, no pet.) (acknowledging that testimony regarding $325 per hour being a reasonable hourly rate for an experienced family law practitioner was uncontroverted).
However, the community expects lawyers to charge rates reflecting the value of professional representation. Ms. Klein's failure to adhere to the professional standard of representation prevailing in her community arose after the Court approved Dale & Klein's rates under § 328(a). Section 328(a) provides:
[N]otwithstanding such terms and conditions, the court may allow compensation different from the compensation provided under such terms and conditions after the conclusion of such employment, if such terms and conditions prove to have been improvident in light of developments not capable of being anticipated at the time of the fixing of such terms and conditions.11 U.S.C. § 328(a) (emphasis added). Ms. Klein's inability or unwillingness to act professionally reflects that her hourly rate should be reduced to a rate below the previously approved community rate. § 328(a); see also In re Magna Cum Latte Inc., 07-31814, 2008 WL 2047937, at *8 (Bankr. S.D. Tex. May 9, 2008) (considering the quality of a fee applicant's representation in determining whether its hourly rates were reasonable). Ms. Klein's allowed hourly rate is reduced to $300.00 per hour. Ritchey, 512 B.R. at 868 (quoting In re Weaver, No. 13-10-12204 JA, 2011 WL 867136, at *3 (Bankr. D.N.M. Mar. 11, 2011)) ("The Court has discretion to determine a reasonable hourly rate and can rely on its own experience and knowledge of customary hourly rates in deciding a reasonable hourly rate." (internal quotation marks omitted)). After this reduction, Dale & Klein may recover $45,345.00 for Ms. Klein's work (a $7,547.50 reduction overall).
After other deductions, Dale & Klein would be awarded $52,832.50 in fees for work performed by Ms. Klein billed at $350 per hour (Dale & Klein billed 0.2 hours of Ms. Klein's work at $300 per hour). This amounts to 150.95 hours billed at $350 per hour. Thus, at $300 per hour, Ms. Klein's work amounted to $45,345.00 in professional fees (including the lone 0.2 hours billed at $300 per hour).
III. REASONABLE AND NECESSARY EXPENSES
Dale & Klein seeks $1,607.79 for reasonable and necessary expenses. Generally, applicants may be reimbursed for filings fees, copies, and mailings. Cole, 2020 WL 4577236, at *16 (citing In re Ahmadi, 17-34134, 2018 WL 6523094, at *5 (Bankr. S.D. Tex. Dec. 10, 2018)). Most of Dale & Klein's expenses are for photocopies. (See ECF Nos. 220-1 at 9-12, 26-29, 57-60, 63-64; 297-3 at 6). Dale & Klein also requests reimbursement for filing fees and postage. (See, e.g., ECF Nos. 220-1 at 9, 26, 28-29, 49-50, 57, 59; 297-3 at 6). Finally, Dale & Klein seeks reimbursement for court reporting costs. (ECF Nos. 220-1 at 57; 297-3 at 6). Mr. Owsley did not object to any expenses for which Dale & Klein seeks reimbursement. (See ECF No. 202). All of Dale & Klein's expenses are reimbursable. Ahmadi, 2018 WL 6523094, at *5. Dale & Klein is awarded $1,607.79 for its reasonable and necessary expenses. See 11 U.S.C. § 330(a)(1)(B).
Mr. Owsley does object to the expense of hiring Dr. Kit Harrison as an expert witness. (ECF No. 202 at 7). Dale & Klein does not seek reimbursement for this expense. Presently, the properness of Dr. Harrison's employment is not before the Court.
IV. SUMMARY OF ALLOWED AND DISALLOWED FEES AND EXPENSES
The table below illustrates the allowances and disallowances in Dale & Klein's fees and expenses.
| Requested Fees & Expenses | Amount | Subtotal | Total |
|---|---|---|---|
| Fees | |||
| Requested | $ 128,123.14 | ||
| $ 128,123.14 | |||
| Less | |||
| Unsupported Fees | $ 481.64 | ||
| Unauthorized Fees | $ 1,995.00 | ||
| Excessive Fees | $ 9,878.50 | ||
| Duplicative Fees | $ 2,539.00 | ||
| Unnecessary Fees | $ 10,260.00 | ||
| Non-Compensable Fees | $ 3,552.50 | ||
| Clerical Fees | $ 432.00 | ||
| Block-Billed Fees | $ 5,294.88 | ||
| Vague Fees | $ 3,575.62 | ||
| Reduction in KPK's Rate | $7,547.50 | ||
| $ 45,556.64 | |||
| $ 82,566.50 | |||
| Expenses | |||
| Requested | $ 1,607.79 | ||
| $ 1,607.79 | |||
| Less | $ 0.00 | ||
| $ 1,607.79 | |||
| Allowed Fees & Expenses | $ 84,164.29 |
CONCLUSION
Dale & Klein is awarded $82,566.50 in fees and $1,607.79 in expenses. Dale & Klein received a security retainer of $15,000.00 and was also awarded $25,000.00 in attorneys' fees, to be paid by Mr. Owsley, by the state court. (See ECF No. 297 at 5). The estate is responsible for the remaining $42,566.50 in professional fees, as well as the $1,607.79 in expenses. A separate Order will be issued.
SIGNED 04/05/2021
/s/_________
Marvin Isgur
United States Bankruptcy Judge
Jimie Dianne Owsley - 19-20060
Appendix A
Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 1 6/7/2019 KPK Conference with Dr. Jimmie Owsley, PNC $ 350.00 1.50 $525.00 $0.00 $525.00 UA 2 6/8/2019 KPK Work on memo regarding meeting with Dr. Owsley. $ 350.00 1.00 $350.00 $0.00 $350.00 UA 3 6/9/2019 KPK Complete memo regarding June 7th meeting with Dr. Owsley. $ 350.00 1.00 $350.00 $0.00 $350.00 UA 4 6/11/2019 KPK Confer with Fernando Mancias $ 350.00 0.40 $140.00 $0.00 $140.00 UA 5 6/12/2019 KPK Confer regarding documents needed. $ 350.00 0.20 $70.00 $0.00 $70.00 UA 6 6/12/2019 KPK Confer regarding status of attorney-client $ 350.00 0.20 $70.00 $0.00 $70.00 UA 7 6/13/2019 KPK Confer with Catherine Curtis & Tom Rice. $ 350.00 0.80 $280.00 $0.00 $280.00 UA 8 6/13/2019 KPK Review documents & prepare memo regarding same. $ 350.00 0.60 $210.00 $0.00 $210.00 UA 9 6/17/2019 KPK Follow up regarding status. $ 350.00 0.10 $35.00 $35.00 $0.00 A 10 6/19/2019 GO Forwarded message to Ms. Curtis rregarding approval from bankruptcy court. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 11 6/24/2019 GO Scan and print of documents provided by client. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 12 6/24/2019 KPK Confer regarding filing Designation & contacting co-counsel. $ 350.00 0.20 $70.00 $70.00 $0.00 A 13 6/25/2019 GO Forwarded Client Contract to Ms. Curtis; copy to client. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 14 6/26/2019 GO Confer with attorney regarding lead representation, copy of file and telehonic conference between attorneys. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 15 6/26/2019 GO Telephone conference with client regarding lead representation; memo on same; forwarded voice message to Catherine Curtis on telephonic conference between attorneys; telephone conference with Mary Ann with Mr. Rice's ofl:ice on same. $ 95.00 0.90 $85.50 $64.13 $21.37 BB 16 6/26/2019 KPK Confer regarding Designation. $ 350.00 0.30 $105.00 $105.00 $0.00 A 17 6/27/2019 GO Review of documents provided by client; confer with attorney on same, No charge. $ - 0.80 $0.00 $0.00 $0.00 A 18 6/27/2019 GO Telephone conference with Janie with Thomas Rice regarding lead representation and copy of file; research for records through Nueces County, $ 95.00 0.30 $28.50 $21.38 $7.12 BB 19 6/27/2019 KPK Conference call with C. Curtis and T. Rice. $ 350.00 0.50 $175.00 $175.00 $0.00 A 20 6/29/2019 KPK Memo regarding "things to do." $ 350.00 1.00 $350.00 $262.50 $87.50 V 21 6/29/2019 KPK Correspondence to Christine Cortez. $ 350.00 0.30 $105.00 $105.00 $0.00 A 22 6/29/2019 KPK Prepared memo regarding conference call. $ 350.00 0.40 $140.00 $105.00 $35.00 V 23 6/29/2019 KPK Memo regarding "things to do." $ 350.00 1.00 $350.00 $0.00 $350.00 UN/D see 20 24 6/29/2019 KPK Draft correspondence to Christine Cortez. $ 350.00 0.30 $105.00 $0.00 $105.00 UN/D see 21 25 6/29/2019 KPK Memo regarding conference call. $ 350.00 0.40 $140.00 $0.00 $140.00 UN/D see 22 26 7/2/2019 DPS Teleconference with Amber Fly regarding contract attorney-client contract; emails to & from Ms. Fly; email correspondence to Amber Fly attaching our contract. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 27 7/2/2019 DPS Teleconference with Christine Cortez's office regmding appointment of Amicus Attorney; finalized & sent letter to Ms. Cortez requesting teleconference. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 28 7/3/2019 GO Review of memo on things to do; confer with attorney regarding same. No charge, $ - 0.30 $0.00 $0.00 $0.00 A 29 7/3/2019 GO Forwarded email to client requesting copies of insurance policies. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 30 7/5/2019 GO Confer with attorney regarding affidavit in support of application; print and scan ofbankruptcy documents received from Ms. Fly. No charge. $ - 0.60 $0.00 $0.00 $0.00 A 31 7/5/2019 GO Forwarded email to Amber Fly regarding forms on bankruptcy matter; copy to client; forwarded emall to Ms. Fly on affidavit in support of application; forwarded executed affidavit to Ms. Fly; copy to client. $ 95.00 0.30 $28.50 $0.00 $28.50 C/NC 32 7/8/2019 GO Conferences with attorney regarding State orders, telephonic access, and treatment for daughter, No charge. $ - 0.40 $0.00 $0.00 $0.00 A 39 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 33 7/8/2019 GO Forwarded to client email received from Amber Fly regarding State ordres on Nevada property; review of orders; reply to email from Ms. Amber; copy to client; forwarded orders to Ms. Fly; copy to client; forwarded to client correspondence regarding telephonic across and treatment for daughter; revised and forwarded correspondence to Ms, Cortez regarding same; revised and forwarded correspondence to Mr. Dudley regarding telephonic access and treatment for daughter; copies to client. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 34 7/8/2019 KPK Prepare three letters to Cortez, Dudley, and client. $ 350.00 0.80 $280.00 $280.00 $0.00 A 35 7/9/2019 KPK Read Order regarding Las Vegas home. $ 350.00 0.20 $70.00 $70.00 $0.00 A 36 7/9/2019 KPK Read email & memo regarding Appearance. $ 350.00 0.20 $70.00 $52.50 $17.50 V 37 7/10/2019 GO Reply to email from client regarding telephonic access; forwarded email to Mr. Dudley on same; copy to client; prepared Notice of Appearance of Counsel and Designation of Lead Cotmsel; copy to client. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 38 7/11/2019 GO Confer with attorney regarding bankruptcy hearings and meetings. No charge, $ - 0.30 $0.00 $0.00 $0.00 A 39 7/11/2019 GO Review, print and scan of various emails from client, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 40 7/11/2019 GO Revised and efiled Notice of Appearance of Counsel and Designation of Lead of Counsel; copies to client; forwarded to client Notice of Intent to Travel; reply to email from client on telephonic access. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 41 7/16/2019 GO Confer with attorney regarding hearing setting. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 42 7/16/2019 GO Attempts to contact 319th court coordinator for hearing setting; telephone conference with client. $ 95.00 0.30 $28.50 $28.50 $0.00 A 43 7/16/2019 KPK Confer regarding setting & status. $ 350.00 0.30 $105.00 $105.00 $0.00 A 44 7/17/2019 GO Confer with attorney regarding Records from Dr. Quoc-Hung Tran. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 45 7/17/2019 GO Telephone conference with Sandra with 319th Nueces District Court on hearing setting; attempts to contact Marilee Roberts on same; reply to emails from client. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 46 7/18/2019 GO Confer with attorney regarding medical records and hearing setting. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 47 7/18/2019 GO Various attempts to contact scheduling coordinator for hearing setting; telephoneconferrence with coordinator; forwarded email to Mary Ann with Mr. Rice regarding creditor's meeting; telephone conference with client regarding treatment for Elizabeth; forwarded settlement offer received from opposing counsel to client; forwarded correspondence to client on same. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 48 7/18/2019 UH Reviewed correspondence from client. $ 225.00 0.20 $45.00 $45.00 $0.00 A 49 7/18/2019 KPK Read settlement offer from B. Dudley. $ 350.00 0.20 $70.00 $70.00 $0.00 A 50 7/18/2019 KPK Read settlement letter & correspondence to client. $ 350.00 0.40 $140.00 $0.00 $140.00 UN/D see 49 51 7/19/2019 GO Prepared and forwarded to client affidavit for business medical records for Dr. Quoc-Hung Tran for client to obtain records; reply to email from client regarding rescheduling of hearing $ 95.00 0.40 $38.00 $28.50 $9.50 BB 52 7/20/2019 KPK Read emails from client. $ 350.00 0.60 $210.00 $210.00 $0.00 A 53 7/21/2019 KPK Respond to email from client; email to R. Orsinger & read email from Orsinger & respond. $ 350.00 1.00 $350.00 $350.00 $0.00 A 54 7/22/2019 GO Read client's email on counter-offer. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 55 7/22/2019 GO Prepared and forwarded and correspondence to counsel regarding copy of file; copy to cliet and amicus attorney; forwarded to client email received from Mr. Orsinger regarding appeal; prepared correspondence to Mr. Dudley regarding children's school; copy to client and amicus attorney; reply to email from client regarding counter-offer. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 56 7/22/2019 KPK Confer with R. Orninger regarding Bankruptcy Stay, $ 350.00 0.30 $105.00 $105.00 $0.00 A 57 7/23/2019 GO Confer with attorney regarding file; review of email from Mary Ann with Mr. Rice regarding bankruptcy code, No charge $ - 0.20 $0.00 $0.00 $0.00 A 40 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 58 7/23/2019 GO Forwarded email to MaryAnn with Mr. Rice regarding bankruptcy code. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 59 7/23/2019 KPK Read correspondence from Bankruptcy counsel. $ 350.00 0.30 $105.00 $105.00 $0.00 A 60 7/24/2019 GO Confer with attorney regarding teleconference between attorneys and regarding copy of file. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 61 7/24/2019 GO Telephone conference with Mr. Rice's office setting up teleconforence between attorneys. $ 95.00 0.20 $19.00 $19.00 $0.00 A 62 7/25/2019 GO Forwarded email to Mary Ann with Mr. Rice regarding teleconference between counsel. N/C $ - 0.10 $0.00 $0.00 $0.00 A 63 7/25/2019 GO Confer with attorney regarding teleconference with Mr. Rice. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 64 7/25/2019 UH Reviewed prior motion & sent bankruptcy code to Mrs. Klein. N/C $ - 0.30 $0.00 $0.00 $0.00 A 65 7/25/2019 UH Converted Motion for Temporary Orders to editable format. N/C $ - 0.40 $0.00 $0.00 $0.00 A 66 7/25/2019 KPK Teleconference with Tom Rice. $ 350.00 0.30 $105.00 $105.00 $0.00 A 67 7/25/2019 KPK Correspondence to Judge Rincones. $ 350.00 0.70 $245.00 $245.00 $0.00 A 68 7/26/2019 GO Prepared order setting hearing; revised first amended motion for temporary orders and request for injunction; efiled motion and order; copy to client. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 69 7/26/2019 UH Drafted Amended Motion for Temporary Orders. $ 225.00 0.50 $112.50 $112.50 $0.00 A 70 7/26/2019 UH Revised Amended Motion for Temporary Orders. $ 225.00 0.20 $45.00 $45.00 $0.00 A 71 7/27/2019 KPK Read emails & review photos & respond. $ 350.00 0.80 $280.00 $210.00 $70.00 V 72 7/29/2019 UH Reviewed emails from client. $ 225.00 0.30 $67.50 $67.50 $0.00 A 73 7/29/2019 KPK Correspondence to Christin Cortez; revise correspondence to Judge Rincones. $ 350.00 0.50 $175.00 $175.00 $0.00 A 74 7/30/2019 GO Telephone conference with Janie with Jay Wright's office on copy of client's file, forwarded to client correspondence received from William. Dudley regarding temporary orders setting; revised and forwarded correspondence to cllent; copy to Mr. Gonzalez. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 75 7/30/2019 KPK Read correspondence from Bill Dudley; prepare memo regarding things to do; prepare correspondence to client. $ 350.00 1.00 $350.00 $262.50 $87.50 BB 76 7/30/2019 KPK Read emails from client. $ 350.00 0.50 $175.00 $175.00 $0.00 A 77 7/31/2019 GO Forwarded email to Mary Ann with Mr. Rice regarding status of citation to motion. To modify; copy to client. $ 95.00 0.10 $9.50 $9.50 $0.00 A 78 8/4/2019 KPK Read email & respond. $ 350.00 0.30 $105.00 $78.75 $26.25 V 79 8/6/2019 KPK Read email regarding service effectuated. $ 350.00 0.20 $70.00 $70.00 $0.00 A 80 8/7/2019 KPK Read emails regarding hearing and issues. $ 350.00 0.30 $105.00 $105.00 $0.00 A 81 8/13/2019 GO Review of Brian Owsley's Declaration and Objection to Employ Dale & Klein, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 82 8/13/2019 GO Reply to email from Catherine Curtis Regarding 2004 Examination by Brian Owsley; copy to client. $ 95.00 0.10 $9.50 $9.50 $0.00 A 41 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 83 8/14/2019 GO Review of emails received from client and attorneys. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 84 8/14/2019 KPK Email to C. Curtis. $ 350.00 0.10 $35.00 $35.00 $0.00 A 85 8/23/2019 GO Print copy of client file received from Jay Wright's office for attorney review. No charge. $ - 0.70 $0.00 $0.00 $0.00 A 86 8/23/2019 KPK Read email. $ 350.00 0.30 $105.00 $78.75 $26.25 V 87 8/25/2019 KPK Read email from client. $ 350.00 0.30 $105.00 $105.00 $0.00 A 88 8/26/2019 KPK Conference call with counsel &b client. $ 350.00 1.00 $350.00 $350.00 $0.00 A 89 8/28/2019 GO Telephone conference with bankruptcy court on 2014 Examination; forwarded emails to Mary Ann with Thomas Rice on same for telephonic appearance on examination. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 90 8/29/2019 UH Reviewed emails & teleconference to Catherine Stone Curtis. $ 225.00 0.20 $45.00 $45.00 $0.00 A 91 8/30/2019 GO Forwarded to client Notice of Appearance of Brian Owsley, $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 92 8/30/2019 UH Reviewed reimbursement documents. $ 225.00 0.10 $22.50 $22.50 $0.00 A 93 8/30/2019 UH Reviewed preliminary memorandum of 2004 Hearing $ 225.00 0.40 $90.00 $90.00 $0.00 A 94 8/30/2019 KPK Attend 2004 Examination by teleconference $ 350.00 5.50 $1,925.00 $1,925.00 $0.00 A 95 9/3/2019 GO Confer with attorney regarding telephonic status conference. No charge, $ - 0.30 $0.00 $0.00 $0.00 A 96 9/3/2019 UH Email correspondence to Catherine Curtis; reviewed email from MaryAnn Villa. $ 225.00 0.10 $22.50 $22.50 $0.00 A 97 9/3/2019 KPK Bankruptcy hearing. $ 350.00 1.00 $350.00 $350.00 $0.00 A 98 9/4/2019 UH Revised Order Approving and sent to opposing counsel; made additional revisions; correspondence with opposing. $ 225.00 0.60 $135.00 $101.25 $33.75 BB 99 9/5/2019 UH Sent Order to Bankruptcy attorney; teleconference from bankruptcy attorney. $ 225.00 0.30 $67.50 $50.63 $16.87 BB 100 9/5/2019 UH Prepared revisions to proposed Order. $ 225.00 0.20 $45.00 $45.00 $0.00 A 101 9/6/2019 GO Forwarded information on 2004 Examination to Ms. Curtis; copy to client. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 102 9/6/2019 KPK Teleconference with Catherine Curtis. $ 350.00 0.50 $175.00 $175.00 $0.00 A 103 9/7/2019 DPS Review file; teleconference with client regarding teleconference with Mrs. Klein on Sept. 7th. $ 95.00 0.20 $19.00 $19.00 $0.00 A 104 9/7/2019 KPK Teleconference with client. $ 350.00 1.00 $350.00 $350.00 $0.00 A 105 9/7/2019 KPK Review Bankruptcy Order. $ 350.00 0.30 $105.00 $105.00 $0.00 A 106 9/7/2019 KPK Memo regarding teleconference with client & "things to do." $ 350.00 0.50 $175.00 $131.25 $43.75 V 42 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 107 9/7/2019 KPK Read emails. $ 350.00 0.20 $70.00 $52.50 $17.50 V 108 9/7/2019 KPK Review Request for Reimbursement. $ 350.00 0.20 $70.00 $52.50 $17.50 V 109 9/9/2019 GO Forwarded to client order approving Date & Klein employment signed by Judge. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 110 9/9/2019 KPK Confer with client regarding status. $ 350.00 0.20 $70.00 $70.00 $0.00 A 111 9/11/2019 GO Efiled First Amended Petition to Modify Parent-Child Relationship; copy to client. $ 95.00 0.30 $28.50 $28.50 $0.00 A 112 9/11/2019 UH Reviewed Memorandum & drafted Motion for Child Custody Evaluation. $ 225.00 0.60 $135.00 $135.00 $0.00 A 113 9/11/2019 UH Prepared outgoing discovery. $ 225.00 0.90 $202.50 $202.50 $0.00 A 114 9/11/2019 UH Drafted & revised l st Amended Petition. $ 225.00 1.00 $225.00 $225.00 $0.00 A 115 9/11/2019 KPK Revise Petition to Modify; work on Discovery. $ 350.00 0.80 $280.00 $280.00 $0.00 A 116 9/12/2019 GO Confer with attorney regarding children's weekend visitations and discovery requests to Mr. Owsley. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 117 9/12/2019 GO Worked on motion for enforcement of medical reimbursement; forwarded correspondence to client regarding children's weekend visits; copy to Mr. Orsinger and Mr. Gonzalez; worked on revisions to discovery requests to Mr. Owsley. $ 95.00 1.00 $95.00 $71.25 $23.75 BB 118 9/12/2019 UH Review of file, docket and Order. $ 225.00 0.90 $202.50 $202.50 $0.00 A 119 9/12/2019 UH Reviewed & signed out going discovery. $ 225.00 0.20 $45.00 $45.00 $0.00 A 120 9/12/2019 KPK Correspondence to client & review of visitation Orders. $ 350.00 1.00 $350.00 $350.00 $0.00 A 121 9/12/2019 KPK Prepare interrogatories. $ 350.00 1.00 $350.00 $350.00 $0.00 A 122 9/13/2019 GO Forwarded email to client regarding transportation on chlldren's weekend visitations; prepared order to appear and order setting hearing on enforcement motion; revised, finalized and forwarded discovery requests to respondent; prepared and efiled certificate of written discovery; copies to client. $ 95.00 1.70 $161.50 $121.25 $40.25 BB 123 9/13/2019 UH Reviewed signed outgoing discovery. $ 225.00 0.20 $45.00 $0.00 $45.00 UN/D see 119 124 9/13/2019 KPK Teleconference with Catherine Curtis. $ 350.00 0.40 $140.00 $140.00 $0.00 A 125 9/18/2019 GO Confer with attorney regarding hearing setting; forwarded to attorney correspondence received from court on same. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 126 9/18/2019 GO Finalized and forwarded correspondence to client regarding offer on Las Vegas property; copy to Mr. Gonzalez. $ 95.00 0.20 $19.00 $0.00 $19.00 C/NC 127 9/19/2019 GO Reply to email from court reporter regarding hearing setting; copy to client. $ 95.00 0.10 $9.50 $9.50 $0.00 A 128 9/20/2019 GO Confer with attorney regarding setting case for trial. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 129 9/20/2019 GO Research through court's docket regarding February 8, 2019 hearing: telephone conference with court reporter regarding hearing transcript: prepared and forwarded request for hearing transcript to court reporter Esther Natividad; copy to client; prepared and efiled Motion for Docket Control Conference and Order; copy to client. $ 95.00 1.70 $161.50 $121.25 $40.25 BB 130 9/26/2019 GO Efiled Second Amended Petition to Modify Parent-Child Relationship, $ 95.00 0.30 $28.50 $28.50 $0.00 A 131 9/26/2019 UH Drafted 2nd Amended Petition. $ 225.00 0.40 $90.00 $90.00 $0.00 A 132 9/26/2019 UH Prepared revisions to 2nd Amended Petition. $ 225.00 0.20 $45.00 $45.00 $0.00 A 133 9/26/2019 KPK Revise Second Amended Motion. $ 350.00 0.80 $280.00 $280.00 $0.00 A 134 10/3/2019 GO Confer with attorey regarding extension on discovery responses, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 135 10/3/2019 GO Confer with attorney regarding hearing setting, No charge. $ - 0.20 $0.00 $0.00 $0.00 A 43 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 136 10/3/2019 GO Telephone conference with opposing counsel regarding extension on discovery responses; prepared memo on same; reply to email from Lindsey with Dr. Harrison regarding order on parental rights; review of Final Decree for same; forwarded decree to Dr. Harrison; copy to client, $ 95.00 0.50 $47.50 $35.63 $11.87 BB 137 10/3/2019 KPK Read memo & confer regarding discovery extension. $ 350.00 0.20 $70.00 $52.50 $17.50 V 138 10/4/2019 GO Forwarded email to opposing counsel regarding discovery response deadline extension; forwarded email to client regarding hearing setting status. $ 95.00 0.20 $19.00 $0.00 $19.00 C/NC 139 10/7/2019 GO Reply to email from client regarding respondent's discovery responses. $ 95.00 0.10 $9.50 $9.50 $0.00 A 140 10/15/2019 GO Telephone conference with Lana with William Dudley regarding Rule 11 Agreement; forwarded executed Rule 11 Agreement to Mr. Dudley. $ 95.00 0.20 $19.00 $19.00 $0.00 A 141 10/18/2019 GO Various telephone conferences with Catherine Curtis regarding final decree of divorce and order regarding equity interest on property; forwarded to Ms. Curtis copy of final decree of divorce; copy to client; telephone conference with Mary Ann regarding same; forwarded final decree to Mary Ann. $ 95.00 1.30 $123.50 $92.63 $30.87 BB 142 10/18/2019 KPK Receive communication from Dudley re possession & plane flight; confer with client. $ 350.00 0.40 $140.00 $140.00 $0.00 A 143 10/19/2019 KPK Multiple communications regarding visitation issues. $ 350.00 0.50 $175.00 $131.25 $43.75 V 144 10/20/2019 KPK Confer regarding flights & children. $ 350.00 0.40 $140.00 $105.00 $35.00 V 145 10/20/2019 KPK Read emails. $ 350.00 0.20 $70.00 $52.50 $17.50 V 146 10/21/2019 GO (2) Telephone conferences with Nueces County Court Administrator regarding hearing setting; prepared memo on same. $ 95.00 0.90 $85.50 $85.50 $0.00 A 147 10/21/2019 KPK Follow up on setting. $ 350.00 0.10 $35.00 $35.00 $0.00 A 148 10/21/2019 KPK Teleconference with client regarding transportation, setting & Brankruptcy Court. $ 350.00 0.40 $140.00 $140.00 $0.00 A 149 10/21/2019 KPK Read email. $ 350.00 0.30 $105.00 $78.75 $26.25 V 150 10/22/2019 GO Confer with attorney regarding questions to client from Richard Orsinger; research on same. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 151 10/22/2019 GO Nueces County Court Administrator regarding hearing setting; review of memo on same; forwarded draft to attorney for review; forwarded request for temporary injunction to attorney for same. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 152 10/22/2019 KPK Confer with client regarding potential bill of review. $ 350.00 0.30 $105.00 $105.00 $0.00 A 153 10/22/2019 KPK Receive communication from cllent. $ 350.00 0.40 $140.00 $140.00 $0.00 A 154 10/22/2019 KPK Work on setting. $ 350.00 0.20 $70.00 $52.50 $17.50 V 155 10/23/2019 GO Confer with attorney regarding hearing setting. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 156 10/23/2019 GO Revised and forwarded correspondence to Nueces County Court Administrator; copy to Cameron County court administrator; forwarded to client Brian Owsley's responses to discovery requests, correspondences from opposing counsel regarding hearing and children's Christmas trip, and regarding Las Vegas property and bankruptcy matter. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 157 10/24/2019 GO Review of emails from client. No charge $ - 0.20 $0.00 $0.00 $0.00 A 158 10/24/2019 GO Forwarded various emails to attorney for review regarding Las Vegas property, children's Christmas trip and client's comments on discovery responses from opposing party. $ 95.00 0.30 $28.50 $0.00 $28.50 C/NC 159 10/24/2019 KPK Read email. $ 350.00 0.30 $105.00 $78.75 $26.25 V 160 10/25/2019 GO Confer with attorney regarding hearing setting and notice of attorney vacation, No charge. $ - 0.10 $0.00 $0.00 $0.00 A 161 10/25/2019 GO Attempts to contact court reporter for Judge Rincones on hearing setting; (2) telephone conferences with court reporter; prepared and efiled Notice of Attorney Vacation, $ 95.00 1.20 $114.00 $85.50 $28.50 BB 162 10/28/2019 GO Forwarded email to client regarding show cause order; telephone conference with court administrator for Judge Rincones on hearing setting; prepared memo; forwarded to client hearing notice from Nueces County. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 163 10/28/2019 KPK Confer with Catherine Curtis & correspondence to client. $ 350.00 0.80 $280.00 $280.00 $0.00 A 164 10/29/2019 GO Forwarded to client Notice of Attorney Vacation filed with Court. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 44 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 165 10/31/2019 UH Case history research $ 225.00 0.60 $135.00 $101.25 $33.75 V 166 10/31/2019 KPK Multiple teleconferences. $ 350.00 1.50 $525.00 $393.75 $131.25 V 167 11/1/2019 KPK Email to client. $ 350.00 0.20 $70.00 $70.00 $0.00 A 168 11/3/2019 KPK Prepare Requests for Admissions; confer with client. $ 350.00 1.50 $525.00 $525.00 $0.00 A 169 11/4/2019 GO Review of Florida traffic crash report. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 170 11/6/2019 GO Forwarded corresponclence to Ruben Bonilla regarding malicious prosecution; copy to client. $ 95.00 0.20 $19.00 $0.00 $19.00 C/NC 171 11/6/2019 WMJ Review home renewal documents from Farmers Insurance; review evidence of insurance for mortgage/other interests; prepare notice of claim letters to Farmers Insurance & requesting a defense. $ 300.00 1.50 $450.00 $337.50 $112.50 BB 172 11/7/2019 WMJ Review Home Renewal documents from Farmers Insurance; review Evidence of Insurance for Mortgage/other interests; prepare notice of claim letter to Farmers Insurance & requesting a defense. $ 300.00 1.50 $450.00 $0.00 $450.00 UN/D see 171 173 11/11/2019 GO Worked on requests for admissions to respondent. $ 95.00 0.40 $38.00 $38.00 $0.00 A 174 11/11/2019 KPK Email to client regarding setting in December. $ 350.00 0.30 $105.00 $105.00 $0.00 A 175 11/12/2019 GO Continued working on requests for admissions; eserved requests; copy to client; reply to email from client on same, $ 95.00 0.70 $66.50 $49.88 $16.62 BB 176 11/13/2019 KPK Confer with Catherine Curtis & confer with client; memo regarding discovery. $ 350.00 0.80 $280.00 $210.00 $70.00 BB 177 11/14/2019 GO Telephone conferences with Christina with Farmers Insurance regarding filing of new claim; prepared memo on same; forwarded correspondence to Mr, Dudley regarding deposition dates; copy to all parties; forwarded correspondence to Farmers Insurancence; copy to client. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 178 11/14/2019 UH Drafted letter to opposing counsel regarding deposition dates. $ 225.00 0.10 $22.50 $11.25 $11.25 E 179 11/14/2019 WMJ Prepare correspondence to claims department regarding request for defense. $ 300.00 0.30 $90.00 $90.00 $0.00 A 180 11/15/2019 GO Forwarded to client correspondence regarding deposition of respondent. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 181 11/15/2019 UH Teleconference with Kit Harrison's office regarding designation. $ 225.00 0.20 $45.00 $45.00 $0.00 A 182 11/15/2019 UH Reviewed letter from opposing counsel. $ 225.00 0.10 $22.50 $22.50 $0.00 A 183 11/19/2019 KPK Read emails and respond regarding Elizabeth medications and regarding camp eagle. $ 350.00 0.50 $175.00 $175.00 $0.00 A 184 11/20/2019 GO Forwarded email to Lindsey with Dr. Harrison regarding hearing; copy to client; research through 13th Court of Appeals docket regarding client's record. $ - 0.00 $0.00 $0.00 $0.00 A 185 11/20/2019 GO Confer regarding 13th Court of Appeals clerk's record, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 186 11/21/2019 GO Confer with attorney regarding Farmers Insurance. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 187 11/21/2019 GO Telephone conference with Meredith Ellender with Farmers Insurance regarding claim; prepared memo on same; forwarded correspondence to William Dudley regarding deposition of Brian Owsley; copy to client. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 188 11/21/2019 UH Letter to opposing counsel. $ 225.00 0.10 $22.50 $22.50 $0.00 A 189 11/22/2019 GO Confer with attorney regarding notice of new claim. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 190 11/22/2019 GO Telephone conference with Meredith with Farmers Insurance on filing of new claim. $ 95.00 0.10 $9.50 $9.50 $0.00 A 191 11/25/2019 GO Confer with attorney regarding medical records and affidavits on same, No charge. $ - 0.40 $0.00 $0.00 $0.00 A 192 11/25/2019 GO Review of medical records; forwarded email to Dr. Harrison re hearing; reply to email from client. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 45 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 193 11/26/2019 GO Reply to email froin client regarding affidavit on children's records; Prepared (2) notices for filing medical records; efiled Notice of Filing of Business Medical Records for Drs. McIntyre and Garza. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 194 11/27/2019 GO Reply to email from client regarding Dr. Kit Harrison and hearing; revised and efiled Notice of Filing of Business Medical Records on Driscoll's Children's Hospital; copy to client. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 195 11/27/2019 KPK Confer regarding exhibits for hearing. $ 350.00 0.30 $105.00 $105.00 $0.00 A 196 12/1/2019 KPK Read emails. $ 350.00 0.40 $140.00 $105.00 $35.00 V 197 12/2/2019 GO Confer with attorney regarding Farmers Insurance. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 198 12/2/2019 GO Telephone conference with Meredith with Partners Insurance regarding new claim $ 95.00 0.10 $9.50 $9.50 $0.00 A 199 12/3/2019 GO Confer with attorey regarding counter-petition to modify. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 200 12/3/2019 GO Forwarded to client Counter-Petition to Modify Parent-Child Relationship. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 201 12/3/2019 UH Reviewed Counterpetition $ 225.00 0.10 $22.50 $22.50 $0.00 A 202 12/5/2019 GO Reply to emails from Dr. Harrison regarding upcoming hearing, $ 95.00 0.20 $19.00 $19.00 $0.00 A 203 12/6/2019 UH Reviewed supplemental discovery answers, $ 225.00 0.50 $112.50 $112.50 $0.00 A 204 12/6/2019 UH Reviewed client's email regarding reimburnement. $ 225.00 0.40 $90.00 $90.00 $0.00 A 205 12/8/2019 KPK Confer with client. $ 300.00 0.20 $60.00 $60.00 $0.00 A 206 12/9/2019 GO Confer with attorney regarding respondent's discovery responses. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 207 12/9/2019 KPK Read 2018 Responses to Requests for Admissions, $ 350.00 0.80 $280.00 $280.00 $0.00 A 208 12/10/2019 GO Confer with attorney regarding hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 209 12/10/2019 GO Forwarded to client correspondence from Farmers Insurance on new claim; (2) telephone conferences with Lindsey with Dr. Harrison regarding hearing; forwarded email to Dr. Harrison. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 210 12/10/2019 KPK Hearing preparation & email to Cristine Cortez. $ 350.00 0.40 $140.00 $140.00 $0.00 A 211 12/11/2019 GO Confer with attorney regarding hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 212 12/11/2019 GO Forwarded to client correspondence regarding Farmers Insurance on notice of new claim; telephone conference with Lindsey with Dr. Harrison regarding hearing; forwarded email to Dr. Harrison, $ 95.00 0.30 $28.50 $21.38 $7.12 BB 46 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 213 12/11/2019 WMJ Prepare correspondence to USAA regarding request for defense & indemnification. $ 300.00 0.40 $120.00 $120.00 $0.00 A 214 12/12/2019 GO Confer with attorney regarding preparations for hearing, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 215 12/12/2019 GO Continued worldng on notebook for hearing; forwarded emails to client; telephone conference with Diane with Mr. Orsinger; reply to emails from client; telephone conference with client; forwarded notice of claim to USAA. $ 95.00 5.10 $484.50 $363.38 $121.12 BB 216 12/12/2019 UH Revised proposed Temporary Orders. $ 225.00 0.70 $157.50 $157.50 $0.00 A 217 12/12/2019 UH Teleconference with client & Dr. Kit Harrison. $ 225.00 0.30 $67.50 $67.50 $0.00 A 218 12/12/2019 KPK Confer with Amicus multiple times; teleconference with opposing counsel; emails with client; prepare Temporary Orders; teleconference with expert witness; travel to Corpus Christi, Texas, $ 350.00 6.50 $2,275.00 $1,706.25 $568.75 BB 219 12/13/2019 GO Telephone conference with client regarding hearing; assist with hearing; forwarded to client notice of claim forwarded to USAA; copy to client. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 220 12/13/2019 KPK Attend hearing on Temporary Orders & return travel (150 miles). $ 350.00 11.00 $3,850.00 $1,925.00 $1,925.00 E 221 12/15/2019 KPK Memo regarding revisions to Temporary Orders & regarding Temp. Orders hearing. $ 350.00 1.30 $455.00 $341.25 $113.75 V 222 12/16/2019 GO Conferences with attorney regarding docket control conference. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 223 12/16/2019 DPS Teleconference with Celine Vahidez & her office (twice) $ 95.00 0.20 $19.00 $19.00 $0.00 A 224 12/16/2019 GO Multiple telephone conferences with Marilee with Nueces County Court regarding docket control conference; scheduled (2) docket control conferences through AT&T Conferencing; telephone conference with Mr. Dudley; telephone conference with Ms. Cortez; (2) telephone conferences with Cecilia with Judge Rincones. $ 95.00 2.50 $237.50 $178.13 $59.37 BB 225 12/16/2019 UH Drafted revised Temporary Orders. $ 225.00 1.40 $315.00 $315.00 $0.00 A 226 12/16/2019 KPK Work on Docket Control Conference & memo; participate in Docket Control Conference. $ 350.00 1.00 $350.00 $262.50 $87.50 BB 227 12/17/2019 GO Worked on designating Dr. Kit Harrison as expert witness; forwarded email to Lindsey with Dr. Harrison'on same. $ 95.00 0.40 $38.00 $38.00 $0.00 A 228 12/17/2019 UH Revised Temporary Orders. $ 225.00 0.40 $90.00 $90.00 $0.00 A 229 12/17/2019 UH Reviewed supplemental discovery & began drafting letter to opposing counsel. $ 225.00 0.80 $180.00 $180.00 $0.00 A 230 12/17/2019 KPK Work on Order. $ 350.00 0.30 $105.00 $105.00 $0.00 A 231 12/17/2019 KPK Prepared detailed memo regarding "things to do." $ 350.00 0.70 $245.00 $183.75 $61.25 V 47 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 232 12/18/2019 GO Research through court's docket regarding order on amicus attorney; reply to email from Dr. Kit Harrison; forwarded respondent's discovery responses to client. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 233 12/18/2019 UH Drafted Docket Control Order. $ 225.00 0.30 $67.50 $67.50 $0.00 A 234 12/18/2019 UH Teleconference with Christine Co1tez. $ 225.00 0.20 $45.00 $45.00 $0.00 A 235 12/18/2019 UH Revised Temporary Orders. $ 225.00 0.10 $22.50 $22.50 $0.00 A 236 12/18/2019 KPK Confer with mediator about dates. $ 350.00 0.30 $105.00 $105.00 $0.00 A 237 12/18/2019 KPK Confer regarding revisions to Order. $ 350.00 0.50 $175.00 $175.00 $0.00 A 238 12/19/2019 GO Download of Clerk's Record for summarization; forwarded email to Diane with Mr. Orsinger on same; forwarded email to Michael O'Reilly regarding mediation. availability; copy to client; continued worldng on designation of expert witness; efiled designation; copy to client; prepared and forwarded correspondence to Mr. Dudley requesting deposition dates; copy to client; forwarded correspondence to client regarding USAA claim. $ 95.00 1.70 $161.50 $121.13 $40.37 BB 239 12/20/2019 GO Confer with attorney regarding medical expenses for reimbursement, No charge. $ - 0.20 $0.00 $0.00 $0.00 A 240 12/20/2019 GO Confer with attorney regarding attorney fees, No charge. $ - 0.20 $0.00 $0.00 $0.00 A 241 12/20/2019 GO Telephone conference with Trish with USAA regarding coverage on policy; forwarded correspondence from USAA to client; telephone conference with court reporter regarding hearing transcripts. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 242 12/20/2019 GO Forwarded to client proposed Temporary Orders; forwarded voice message and email to Ms. Curtis regarding attorney fees; forwarded email to Dr. Harrison on new email dates; copy to client. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 243 12/22/2019 S Summarizing Vol. I of Clerk's Record on Appeal. $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 244 12/22/2019 KPK Follow up on Order. $ 350.00 0.20 $70.00 $70.00 $0.00 A 245 12/23/2019 GO Confer with attorney regarding attorney fees. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 246 12/23/2019 GO Forwarded voice message to Ms. Curtis regarding attorney fees. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 247 12/23/2019 S Continue Vol. I $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 248 12/23/2019 UH Teleconference to opposing counsel. $ 225.00 0.10 $22.50 $22.50 $0.00 A 249 12/23/2019 UH Sent Docket Control Order to opposing counsel. $ 225.00 0.10 $22.50 $22.50 $0.00 A 250 12/24/2019 GO Confer with attorney regarding hearing transcripts and attorney fees. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 251 12/24/2019 GO Attempts to contact court reporter on hearing transcripts. $ 95.00 0.10 $9.50 $9.50 $0.00 A 48 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 252 12/24/2019 S Continue Vol. 1 $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 253 12/25/2019 S Continue Vol. I $ 95.00 2.00 $190.00 $0.00 $190.00 UN/D 254 12/26/2019 S Summarizing Vol. II of Clerk's Record on Appeal. $ 95.00 6.00 $570.00 $0.00 $570.00 UN/D 255 12/27/2019 GO Forwarded email to client regarding cost of children's health lnsurance, $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 256 12/27/2019 S Summarizing Vol. II of Clerk's Record on Appeal. $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 257 12/27/2019 UH Revised Temporary Orders & sent to Amicus. $ 225.00 0.20 $45.00 $45.00 $0.00 A 258 12/28/2019 S Summarizing Vol. II of Clerk's Record on Appeal. $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 259 12/29/2019 S Summarizing Vol. II of Clerk's Record on Appeal. $ 95.00 4.00 $380.00 $0.00 $380.00 UN/D 260 12/29/2019 KPK Prepare memo regarding "things to do" $ 350.00 0.50 $175.00 $131.25 $43.75 V 261 12/30/2019 KPK Review Order & review Responses to Requests for Admissions, $ 350.00 1.00 $350.00 $350.00 $0.00 A 262 12/31/2019 GO Confer with attorney regarding bankruptcy hearing, No charge. $ - 0.30 $0.00 $0.00 $0.00 A 263 12/31/2019 GO Efiled Docket Control Order; copy to client and Marilee Roberts with 319th Nueces County Court; forwarded email to client regarding attendance of show cause hearing in bankruptcy court. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 264 12/31/2019 S Summarizing Vol. III $ 95.00 6.00 $570.00 $0.00 $570.00 UN/D 265 12/31/2019 KPK Work on Order; execute & review Requests for Admissions Responses. $ 350.00 0.80 $280.00 $280.00 $0.00 A 266 1/1/2020 S Summarizing Vol. III of Clerk's Record on Appeal. $ 95.00 6.00 $570.00 $0.00 $570.00 UN/D 267 1/2/2020 GO Confer with attorney regarding attorney fees. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 268 1/2/2020 GO Attempts to contact Ms. Cmtis regarding teleconference between counsel; forwarded email to Ms. Curtis on same; telephone conference with Ms. Curtis. $ 95.00 0.20 $19.00 $14.25 $4.75 BB 269 1/2/2020 S Summarizing Vol. IV of Clerk's Record on Appeal. $ 95.00 6.00 $570.00 $0.00 $570.00 UN/D 270 1/2/2020 KPK Confer regarding Bill of Review $ 350.00 0.80 $280.00 $280.00 $0.00 A 49 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 271 1/2/2020 KPK Teleconference with Catherine Curtis. $ 350.00 0.60 $210.00 $210.00 $0.00 A 272 1/3/2020 S Summarizing Vol. IV $ 95.00 2.00 $190.00 $0.00 $190.00 UN/D 273 1/3/2020 KPK Conference call with Bankruptcy lawyers regarding need for timeline, $ 350.00 0.70 $245.00 $245.00 $0.00 A 274 1/6/2020 GO Telephone conference with court reporter regarding hearing transcripts and exhibits on same; revised and forwarded correspondence to opposing counsel regarding discovery supplelllentation. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 275 1/6/2020 S Summary of appellate Court record. $ 95.00 8.00 $760.00 $0.00 $760.00 UN/D 276 1/6/2020 KPK Memo regarding timeline. $ 350.00 0.20 $70.00 $52.50 $17.50 V 277 1/7/2020 GO Forwarded email to client regarding hearing transcripts and costs for same. $ 95.00 0.20 $19.00 $19.00 $0.00 A 278 1/7/2020 S Summary of appellate Court record. $ 95.00 6.00 $570.00 $0.00 $570.00 UN/D 279 1/9/2020 GO Reply to email from court reporter regarding request for hearing transcripts; copy to client. $ 95.00 0.20 $19.00 $19.00 $0.00 A 280 1/10/2020 S Continued summary Court record and deposition summary of parties in case below. $ 95.00 6.00 $570.00 $427.50 $142.50 BB 281 1/12/2020 S Summary of deposition in case below. $ 95.00 6.00 $570.00 $427.50 $142.50 V 282 1/13/2020 GO Confer with attorney regarding temporary orders and hearing transcripts; scan of hearing transcripts provided by client, No charge. $ - 0.90 $0.00 $0.00 $0.00 A 283 1/13/2020 KPK Confer with Catherine Curtis; and confer regarding transcript, $ 350.00 0.80 $280.00 $280.00 $0.00 A 284 1/14/2020 UH Reviewed email from client. $ 225.00 0.20 $45.00 $45.00 $0.00 A 285 1/15/2020 GO Confer with attorney regarding temporary orders. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 286 1/15/2020 GO Research regarding temporary orders; telephone conference with Leah with Ms. Cortez and with Lana with Mr. Dudley regarding signatures to temporary orders. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 287 1/16/2020 KPK Memo regarding "things to do." $ 350.00 0.60 $210.00 $157.50 $52.50 V 288 1/17/2020 GO Prepare memo regarding things to do. $ - 0.10 $0.00 $0.00 $0.00 A 289 1/17/2020 KPK Revise statement. $ 350.00 0.30 $105.00 $78.75 $26.25 V 290 1/20/2020 S Deposition Summaries of Owsley continued. $ 95.00 8.00 $760.00 $570.00 $190.00 V 291 1/20/2020 UH Reviewed prior Orders & conducted legal research. $ 225.00 2.90 $652.50 $652.50 $0.00 A 292 1/20/2020 KPK Confer regarding transcripts & billing $ 350.00 0.30 $105.00 $78.75 $26.25 V 293 1/21/2020 GO Confer with attorney regarding temporary orders and clerk's records on appeal. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 294 1/21/2020 GO Prepared and forwarded correspondence to Ms. Cortez regarding temporary orders; copy to client. $ 95.00 0.20 $19.00 $19.00 $0.00 A 295 1/21/2020 KPK Follow up on Order & deposition. $ 350.00 0.30 $105.00 $52.50 $52.50 E 296 1/22/2020 GO Download of clerk's records and hearing transcripts for summarization. $ - 0.20 $0.00 $0.00 $0.00 A 297 1/22/2020 S Summary of Owsley appellate court records (11 volumes). $ 95.00 8.00 $760.00 $0.00 $760.00 UN/D 50 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 298 1/22/2020 KPK Follow up on transcripts. $ 350.00 0.20 $70.00 $52.50 $17.50 V 299 1/23/2020 S Continued Deposition Summary of Owsley records (11 volumes). $ 95.00 8.00 $760.00 $0.00 $760.00 UN/D 300 1/24/2020 KPK Correspondence to Amber Fly regarding fees. $ 350.00 0.20 $70.00 $70.00 $0.00 A 301 1/27/2020 S Summary of Owsley records. $ 95.00 10.00 $950.00 $0.00 $950.00 UN/D 302 1/28/2020 S Continued Deposition Summary of Owsley appellate court records. $ 95.00 8.00 $760.00 $0.00 $760.00 UN/D 303 1/30/2020 S Conitnued Summary of Owsley court records. $ 95.00 8.00 $760.00 $0.00 $760.00 UN/D 304 2/4/2020 KPK Memo regarding Catherine Curtis & "things to do." $ 350.00 0.60 $210.00 $157.50 $52.50 V 305 2/10/2020 KPK Confer regarding deposition and mediation dates not provided. $ 350.00 0.20 $70.00 $35.00 $35.00 E 306 2/10/2020 KPK Memo regarding conference call. $ 350.00 0.20 $70.00 $52.50 $17.50 V 307 2/12/2020 GO Forwarded voice message to Catherine Curtis regarding status of application on attorneys fees and regarding teleconference call; telephone conference with William Dudley regarding dates for respondent's deposition and mediation; prepared memo for same. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 308 2/12/2020 KPK Confer with client. $ 350.00 0.20 $70.00 $70.00 $0.00 A 309 2/12/2020 KPK Review order prepared by Dudley; review bankruptcy filing. $ 350.00 0.60 $210.00 $210.00 $0.00 A 310 2/13/2020 GO Forwarded to client correspondence from opposing counsel regarding possible settlement proposal. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 311 2/13/2020 KPK Review Bankruptcy documents. $ 350.00 0.30 $105.00 $105.00 $0.00 A 312 2/14/2020 GO Forwarded correspondence to client regarding possible settlement proposal. $ 95.00 0.10 $9.50 $0.00 $9.50 UN/D see 310 313 2/17/2020 GO Confer with attorney regarding discovery supplementation. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 314 2/17/2020 GO Research through court's docket on discovery; forwarded email to client on same. $ 95.00 0.40 $38.00 $28.50 $9.50 BB 315 2/18/2020 GO Confer with attorney regarding bill ofreview on final decree of divorce. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 316 2/18/2020 GO Worked on download of multiple messages between parties from OFW; download of client's previous discovery responses; prepared and emailed supplemental responses to request for production to opposing counsel; copy to client; various attempts to $ 95.00 2.80 $266.00 $199.50 $66.50 BB 317 2/18/2020 UH Reviewed outgoing supplemental discovery. $ 225.00 0.20 $45.00 $45.00 $0.00 A 318 2/19/2020 GO Confer with attorney regarding medical records requests and documents to be requested for discovery. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 319 2/19/2020 GO Forwarded (2) emails to client regarding children's medical records; prepared (2) requests for records from Dr. Wynne and Southwest Psychiatric Physicians; prepared (2) self-proving affidavits for same. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 320 2/24/2020 GO Reply to email from Amber Fly regarding orders and hearing; research through court's docket; forwarded to Ms. Fly Docket Control Order filed with Court; copy to client; forwarded voice message to amicus attorney Ms. Cortez regarding temporary orders; copy to client; reply to email from client on temporary orders. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 321 3/2/2020 GO Confer with attorney regarding temporary orders. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 322 3/2/2020 UH Reviewed & compared our Order with opposing counsel's. $ 225.00 0.80 $180.00 $180.00 $0.00 A 323 3/3/2020 GO Confer with attorneys regarding deadlines before trial. No charge $ - 0.30 $0.00 $0.00 $0.00 A 324 3/3/2020 GO Forwarded email to client regarding discovery supplementation and medical records pertaining to children; prepared and forwarded to opposing counsel petitioner's responses to request for disclosure; copy to client. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 325 3/3/2020 KPK Work on 30 day deadline supplementation. $ 350.00 0.80 $280.00 $280.00 $0.00 A 326 3/4/2020 GO Confer with attorneys regarding discovery and hearing transcripts. No charge, $ - 0.30 $0.00 $0.00 $0.00 A 327 3/4/2020 GO Prepared and forwarded conespondence to opposing counsel regarding petitioner's discovery responses; copy to client; prepared and efiled certificate of written discovery; telephone conference with client regarding hearing transcripts. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 51 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 328 3/5/2020 GO Confer with attorney regarding deposition transcripts. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 329 3/5/2020 GO Attempts to contact court reporter regarding hearing transcripts; forwarded email to court reporter on same; copy to client; forwarded email to client on response from court reporter. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 330 3/6/2020 GO Confer with attorney regarding status of hearing transcripts. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 331 3/6/2020 GO Attempts to contact court reporter; forwarded email to court reporter regarding hearing transcripts; reply to email from court reporter on same. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 332 3/7/2020 KPK Meet with client. $ 350.00 3.00 $1,050.00 $1,050.00 $0.00 A 333 3/9/2020 KPK Further preparation of memo regarding meeting & "things to do". $ 350.00 1.00 $350.00 $262.50 $87.50 V 334 3/10/2020 JM Reviewed D&K's Application for Attorney Fees in the Bankruptcy matter. Obtained & reviewed Mr. Owsley's Response in Opposition to D&K Application. Emails with Curtis re: said motions and hearing on same. $ 95.00 1.00 $95.00 $71.25 $23.75 BB 335 3/16/2020 GO Forwarded correspondence to opposing counsel regarding FM System and offer of settlement; prepared order setting hearing on motion to compel discovery; efiled motion and order. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 336 3/16/2020 UH Reviewed memorandum and file. $ 225.00 0.80 $180.00 $180.00 $0.00 A 337 3/16/2020 UH Drafted Motion to Compel Discovery $ 225.00 0.90 $202.50 $202.50 $0.00 A 338 3/16/2020 UH Drafted & revised letter to opposing counsel. $ 225.00 0.70 $157.50 $157.50 $0.00 A 339 3/16/2020 UH Drafted 2nd Request for Production. $ 225.00 0.40 $90.00 $90.00 $0.00 A 340 3/16/2020 KPK Additions to memo regarding "things to do." for case planning. $ 350.00 0.80 $280.00 $210.00 $70.00 V 341 3/17/2020 GO Revised and forwarded second request for production to respondent; copy to client $ 95.00 0.40 $38.00 $38.00 $0.00 A 342 3/17/2020 KPK Teleconference with Bill Dudley regarding mediation. $ 350.00 0.50 $175.00 $175.00 $0.00 A 343 3/18/2020 GO Telephone conference with court reporter regarding hearing transcripts; forwarded correspondence to client regarding mediation. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 344 3/18/2020 KPK Teleconference with Michael O'Reilly regarding mediation. $ 350.00 0.30 $105.00 $105.00 $0.00 A 345 3/18/2020 KPK Correspondence to client. $ 350.00 0.30 $105.00 $105.00 $0.00 A 346 3/19/2020 GO Confer with attoney regarding deposition and mediation. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 347 3/19/2020 GO Forwarded to client motion to compel discovery; telephone conference with client regarding mediation and deposition; forwarded copy of settlement offer to Ms. Cortez; forwarded correspondence to opposing counsel regardng FM System, deposition and mediation; copy to client, Robert Gonzalez and Ms. Cortez; research on Respondent's employment; attempts to reach staff to his employer. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 348 3/19/2020 KPK Read correspondence from client. $ 350.00 0.30 $105.00 $105.00 $0.00 A 349 3/19/2020 KPK Correspondence to Bill Dudley. $ 350.00 0.60 $210.00 $210.00 $0.00 A 350 3/19/2020 KPK Read letter of March 18th and memo regarding Deposition $ 350.00 0.40 $140.00 $140.00 $0.00 A 351 3/19/2020 KPK Correspondence to Bill Dudley. $ 350.00 0.20 $70.00 $0.00 $70.00 UN/D see 349 352 3/20/2020 GO Revised and forwarded correspondence to opposing counsel regarding mediation and deposition; copy to client and Ms. Cortez. $ 95.00 0.20 $19.00 $19.00 $0.00 A 353 3/23/2020 GO Confer with attorney regarding teleconference between counsel. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 354 3/23/2020 GO Various telephone conferences with Leah with Ms. Cortez regarding teleconference between attorneys; prepared memo on same; forwarded rule 11 agreement to opposing counsel; copy to Ms. Cortez and client; forwarded correspondence addressed to Judge Rincones to opposing counsel; copy to Ms. Cortez, Michael O'Reilly and client. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 355 3/23/2020 KPK Correspondence regarding transportation agreement for visitation. $ 350.00 0.30 $105.00 $105.00 $0.00 A 356 3/23/2020 KPK Confer with Bill Dudley and C. Cottez by phone. $ 350.00 0.30 $105.00 $105.00 $0.00 A 357 3/23/2020 KPK Correspondence regarding passing case & mediation. $ 350.00 0.30 $105.00 $105.00 $0.00 A 358 3/23/2020 KPK Memo regarding days' events & correspondence to client. $ 350.00 0.30 $105.00 $78.75 $26.25 V 359 3/24/2020 GO Confer with attorney regarding cancellation of mediation and regarding deposition and correspondence addressed to Judge Rincones informing of status of case. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 360 3/24/2020 GO Reply to email from opposing counsel and Ms. Cortez regarding revisions to correspondence addressed to Judge Rincones; revised and forwarded sanie to Mr. Dudley and Ms. Cortez for review and signature; copy to client; emailed correspondence to Judge Rincones; copies to all parties. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 361 3/24/2020 KPK Revise correspondence to Mr. Dudley. $ 350.00 0.30 $105.00 $105.00 $0.00 A 52 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 362 3/24/2020 KPK Teleconference with Michael O'Reilly. $ 350.00 0.30 $105.00 $105.00 $0.00 A 363 3/24/2020 KPK Review revisions to correspondence to Judge Ricones $ 350.00 0.30 $105.00 $105.00 $0.00 A 364 3/25/2020 GO Confer with attorney regarding documents to compile for attorney review. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 365 3/25/2020 GO Compiled documents for attorney review regarding temporary orders. $ 95.00 0.40 $38.00 $38.00 $0.00 A 366 3/25/2020 KPK Read correspondence from Bill Dudley. $ 350.00 0.30 $105.00 $105.00 $0.00 A 367 3/25/2020 KPK Correspondence to Bill Dudley. $ 350.00 0.20 $70.00 $70.00 $0.00 A 368 3/27/2020 GO Reply to email from client. $ 95.00 0.10 $9.50 $9.50 $0.00 A 369 3/27/2020 KPK Follow up on attorney fee application. $ 350.00 0.20 $70.00 $70.00 $0.00 A 370 3/31/2020 GO Confer with attorney regarding passing of trial setting. No charge. $ - 0.10 $0.00 $0.00 $0.00 A 371 3/31/2020 GO Forwarded correspondence to client regarding FM System; telephone conference with Cecilia with district court confirming trial date off of court's docket; reply to email from Lindsey with Dr. Harrison on same; copy to client. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 372 4/2/2020 KPK Confer with attorney regarding visitation travel. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 373 4/2/2020 KPK Confer regarding mediation. $ 350.00 0.20 $70.00 $52.50 $17.50 V 374 4/2/2020 KPK Read emails & respond regarding visitation. $ 350.00 0.80 $280.00 $210.00 $70.00 V 375 4/2/2020 KPK Review of OFW email between parties; telephone conference with client regarding travel on exchange of child. $ 350.00 0.20 $70.00 $70.00 $0.00 A 376 4/3/2020 GO Confer with attorney regarding exchange of child and correspondence between counsel. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 377 4/3/2020 GO Various attempts to reach court reporter on hearing transcripts; forwarded email to client on same; forwarded to client invoice and link from court reporter on payment for transcripts; forwarded various emails from and to opposing counsel to client; telephone conference with court reporter on transcripts; (2) telephone conferences with Lana with opposing counsel regarding exchange of child and emails between Mr. Dudley and Ms. Cortez on same; copies to client. $ 95.00 1.30 $123.50 $92.63 $30.87 BB 378 4/3/2020 KPK Confer regarding visitation & email. $ 350.00 0.80 $280.00 $210.00 $70.00 V 379 4/6/2020 GO Forwarded email to client on outcome of weekend visitation; reply to email from client on same; prepared deposition notice for respondent; prepared and forwarded correspondence to opposing counsel regarding response to settlement offer; copies to client. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 380 4/6/2020 KPK Follow up on visitation procedures. $ 350.00 0.20 $70.00 $70.00 $0.00 A 381 4/6/2020 KPK Confer regarding taking deposition and objections. $ 350.00 0.20 $70.00 $35.00 $35.00 E 382 4/6/2020 KPK Prepare Subpoena Duces Tecum. $ 350.00 0.80 $280.00 $140.00 $140.00 E 383 4/7/2020 GO Confer regarding hearing transcripts. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 384 4/7/2020 GO Efiled Rule 11 Agreement on passing of trial date; copy to client. $ 95.00 0.20 $19.00 $19.00 $0.00 A 385 4/8/2020 GO Download of multiple OFW messages between parties. $ 95.00 0.20 $19.00 $19.00 $0.00 A 386 4/13/2020 KPK Coordinate Trial setting. $ 350.00 0.30 $105.00 $105.00 $0.00 A 387 4/13/2020 KPK Review Docket Sheet regarding when Application for Compensation will be heard. $ 350.00 0.20 $70.00 $70.00 $0.00 A 388 4/13/2020 KPK Review Motion to Quash & prepare memo regarding Response to Motion & email to client. $ 350.00 1.00 $350.00 $262.50 $87.50 BB 389 4/14/2020 GO Forwarded to client correspondence regarding trial date; prepared order setting hearing for same; download of hearing transcripts; forwarded same to client and to attorney for review. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 390 4/14/2020 UH Further Drafted Response to Motion to Quash. $ 225.00 1.80 $405.00 $405.00 $0.00 A 391 4/14/2020 KPK Revise Response to Motion to Quash. $ 350.00 0.80 $280.00 $280.00 $0.00 A 392 4/14/2020 KPK Follow up on Bankruptcy hearings scheduled. $ 350.00 0.20 $70.00 $52.50 $17.50 V 393 4/15/2020 GO Print, scan ofrespondent's responses to discovery. No charge, $ - 0.40 $0.00 $0.00 $0.00 A 394 4/15/2020 GO Prepared order setting hearing for reply to response to motion to quash; revised reply; efiled reply and order; copy to client; forwarded to client respondent's responses to second request for production and third supplemental responses to request for production. $ 95.00 1.30 $123.50 $92.63 $30.87 BB 395 4/15/2020 S Summary of Owsley transcript from Enforcement Proceeding. $ 95.00 8.00 $760.00 $570.00 $190.00 V 396 4/15/2020 UH Revised Motion to Quash. $ 225.00 0.30 $67.50 $67.50 $0.00 A 397 4/15/2020 UH Reviewed Responses to 2nd Requests for Production $ 225.00 0.70 $157.50 $157.50 $0.00 A 398 4/16/2020 GO Confer with attorneys regarding deposition of respondent. $ - 0.20 $0.00 $0.00 $0.00 A 399 4/16/2020 GO Forwarded to opposing counsel correspondence regarding respondent's responses to second request for production; copy to client; revised first amended deposition notice of respondent; forwarded to opposing counsel, amicus attorney and court reporter; copy to client; revised and forwarded to opposing counsel and amicus attorney order setting bench trial; copy to client. $ 95.00 1.20 $114.00 $85.50 $28.50 BB 53 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 400 4/16/2020 GO Forwarded correspondence to opposing counsel regarding responses to second request for production; copy to client; revised and forwarded to opposing counsel first amended deposition notice of Brian Owsley; copy to court reporter, amicus attorney and client; revised and forwarded order setting bench trial to opposing counsel and amicus attorney; copy to client. $ 95.00 1.40 $133.00 $0.00 $133.00 UN/D see 399 401 4/16/2020 S Summary of Owsley transcript from Enforcement Proceeding. $ 95.00 8.00 $760.00 $570.00 $190.00 V 402 4/16/2020 UH Drafted letter to opposing counsel regarding defective 2nd production. $ 225.00 0.40 $90.00 $90.00 $0.00 A 403 4/16/2020 KPK Confer regarding re-noticing deposition & revise Notice of Deposition. $ 350.00 0.50 $175.00 $87.50 $87.50 E 404 4/16/2020 KPK Teleconference with U.S.Legal regarding deposition arrangements. $ 350.00 0.30 $105.00 $52.50 $52.50 E 405 4/21/2020 GO Attempt to contact amicus attorney on signature to order setting trial; forwarded email to Ms. Cortez on same; forwarded to client respondent's motion to quash first amended deposition notice of Brian Owsley. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 406 4/21/2020 UH Reviewed Motion to Quash 1st Amended Deposition. $ 225.00 0.20 $45.00 $45.00 $0.00 A 407 4/22/2020 GO Confer with attorney regarding order setting bench trial and regarding teleconference on bankruptcy matter. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 408 4/22/2020 GO Telephone conference with Marie Cortez' office regarding signatuxre to Order Setting Bench Trial. $ 95.00 0.10 $9.50 $9.50 $0.00 A 409 4/23/2020 GO Forwarded (2) hearing transcripts for summarization. $ - 0.20 $0.00 $0.00 $0.00 A 410 4/24/2020 GO Confer with attorney regarding teleconference between counsel on upcoming bankruptcy hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 411 4/24/2020 GO Reply to email from Ms. Curtis regarding teleconference between counsel on upcoming bankruptcy hearing. $ 95.00 0.10 $9.50 $9.50 $0.00 A 412 4/24/2020 S Begin summary of Owsley hearing on Temporary Orders. $ 95.00 4.00 $380.00 $285.00 $95.00 V 413 4/24/2020 KPK Review 2nd Motion to Quash Deposition. $ 350.00 0.30 $105.00 $105.00 $0.00 A 414 4/24/2020 KPK Prepare memo regarding rescheduling deposition for the 14th. $ 350.00 0.30 $105.00 $78.75 $26.25 V 415 4/24/2020 KPK Review Objections to 2nd Request for Production. $ 350.00 0.40 $140.00 $140.00 $0.00 A 416 4/27/2020 GO Confer with attorney regarding upcoming hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 417 4/27/2020 GO Confer with attorneys regarding deadlines before trial. No charge, $ - 0.20 $0.00 $0.00 $0.00 A 418 4/27/2020 GO Reply to email from Catherine Curtis regarding teleconference between counsel on upcoming hearing; copy to client; prepared and efiled order setting hearing on respondent's objections to second request for production. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 419 4/27/2020 UH Drafted email to opposing counsel. $ 225.00 0.20 $45.00 $45.00 $0.00 A 420 4/27/2020 KPK Confer regarding deposition schedule. $ 350.00 0.20 $70.00 $35.00 $35.00 E 421 4/28/2020 GO Review of correspondences from opposing counsel regarding deposition of respondent; confer with attorneys regarding same, $ - 0.30 $0.00 $0.00 $0.00 A 422 4/28/2020 UH Reviewed 2nd letter from opposing counsel. $ - 0.20 $0.00 $0.00 $0.00 A 423 4/28/2020 GO Forwarded correspondence to opposing counsel regarding respondent's deposition; forwarded to client several correspondences between counsel on same; forwarded email to court reporter informing of deposition quashed; reply to email from court reporter regarding rescheduling for same. $ 95.00 0.80 $76.00 $57.00 $19.00 BB 424 4/28/2020 UH Reviewed correspondence from opposing counsel. $ 225.00 0.20 $45.00 $45.00 $0.00 A 425 4/28/2020 UH Reviewed hearing transcript & drafted response to correspondence from Mr. Dudley. $ 225.00 0.80 $180.00 $180.00 $0.00 A 426 4/28/2020 KPK Two Correspondences to Bill Dudley. $ 350.00 0.80 $280.00 $280.00 $0.00 A 427 4/28/2020 KPK Request hearing from court. $ 350.00 0.10 $35.00 $35.00 $0.00 A 428 4/29/2020 GO Confer with attorney regarding respondent's deposition. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 429 4/29/2020 GO Reply to email from client regarding deposition ofrespondent by video. $ 95.00 0.10 $9.50 $9.50 $0.00 A 430 4/30/2020 UH Responded to email from client. $ 225.00 0.20 $45.00 $45.00 $0.00 A 54 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 431 4/30/2020 KPK Confer regarding filing new motion. $ 350.00 0.30 $105.00 $78.75 $26.25 V 432 5/1/2020 KPK Confer regarding setting. $ 350.00 0.20 $70.00 $52.50 $17.50 V 433 5/4/2020 UH Reviewed email from Court. $ 225.00 0.10 $22.50 $22.50 $0.00 A 434 5/4/2020 KPK Confer with Christine Cortez regarding Order & status of negotiations. $ 350.00 0.20 $70.00 $70.00 $0.00 A 435 5/4/2020 KPK Follow up on setting for discovery objections. $ 350.00 0.20 $70.00 $70.00 $0.00 A 436 5/4/2020 KPK Memo regarding status of appeal. $ 350.00 0.20 $70.00 $52.50 $17.50 V 437 5/5/2020 GO Confer with attorney regarding appeal, teleconference with Ms. Curtis on bankruptcy matter and order setting bench trial. $ - 0.20 $0.00 $0.00 $0.00 A 438 5/5/2020 GO Confer with attorney regarding teleconference between counsel on bankruptcy matter, mediation and hearing setting; No charge. $ - 0.60 $0.00 $0.00 $0.00 A 439 5/5/2020 GO Attempts to contact amicus attorney on signature to order setting bench trial; forwarded order to Ms. Cortez; reply to email from Ms. Curtis regarding appeal; copy to client; reply to email from Marilee Roberts with Nueces County Comt regarding hearing setting; copy to all parties and client; efiled osh on bench trial. $ 95.00 0.90 $85.50 $64.13 $21.37 BB 440 5/5/2020 GO Forwarded to client order setting bench trial filed with court; compile of documents for attorney review on temporary orders; download of exhibits on motion to disburse; research court's docket on documents to certify on bankruptcy matter; forwarded email to client regarding mediation setting. $ 95.00 1.60 $152.00 $114.00 $38.00 BB 441 5/5/2020 UH Reviewed Appellate file & case docket. $ 225.00 1.60 $360.00 $360.00 $0.00 A 442 5/5/2020 UH Legal research regarding objection that appeal bond was not paid, $ 225.00 2.30 $517.50 $517.50 $0.00 A 443 5/5/2020 UH Teleconference with Catherine Curtis regarding appeal bond argument, $ 225.00 0.30 $67.50 $67.50 $0.00 A 444 5/5/2020 KPK Confer with Catherine Curtis regarding preparation for Bankruptcy hearing. $ 350.00 0.80 $280.00 $280.00 $0.00 A 445 5/5/2020 KPK Call to Mike O'Reilly regarding mediation May 18th; research regarding supersedeas. $ 350.00 0.50 $175.00 $175.00 $0.00 A 446 5/6/2020 GO Confer with attorney regarding hearing setting and mediation. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 447 5/6/2020 GO Forwarded email to court regarding hearing setting; (2) telephone conferences with opposing cotmsel regarding teleconference with court on same; forwarded and replied to emails from Catherine Curtis on teleconference on bankruptcy hearing; copies to client; forwarded email to client on mediation. $ 95.00 0.90 $85.50 $64.13 $21.37 BB 448 5/6/2020 UH Reviewed documents in file pertaining to Objections regarding attorneys fees. $ 225.00 1.60 $360.00 $0.00 $360.00 C/NC 449 5/7/2020 GO Confer with attorney regarding bankruptcy hearing, trial and pending issues, mediation and summer possession schedules. No charge. $ - 0.50 $0.00 $0.00 $0.00 A 450 5/7/2020 SC Confer with attorney regarding setting mediation. $ - 0.20 $0.00 $0.00 $0.00 A 451 5/7/2020 SC Prepared, scanned and forwarded Rule 11 Agreement to William Dudley. $ - 0.90 $0.00 $0.00 $0.00 A 452 5/7/2020 GO Worked on preparation and settings for trial, bankruptcy hearing and mediation; reply to emails from Mr. Dudley and Ms. Curtis on same; reply and forward emails to client on summer possession desigations. $ 95.00 1.90 $180.50 $135.38 $45.12 BB 453 5/7/2020 SC Phone conference with William Dudley's office regarding Rule 11 Agreement. $ 95.00 0.40 $38.00 $38.00 $0.00 A 454 5/7/2020 SG Research on indemnity & new sales proceeds & reimbursements & constructive trusts in order to provide same to Bankruptcy attorney for distribution of sales proceeds from Vegas home. $ 225.00 3.80 $855.00 $855.00 $0.00 A 455 5/7/2020 WMJ Research regarding indemnification request. $ 300.00 0.30 $90.00 $90.00 $0.00 A 456 5/7/2020 KPK Two teleconferences regarding Indemnification for attorney fees; review Order on Enforcement of Decree. $ 350.00 1.00 $350.00 $350.00 $0.00 A 457 5/7/2020 KPK Work on summer visitation provisions. $ 350.00 0.60 $210.00 $210.00 $0.00 A 458 5/7/2020 KPK Conference call to set up hearings; set up mediation. $ 350.00 0.60 $210.00 $210.00 $0.00 A 459 5/11/2020 UH Legal research regarding 50/50 Vegas Condo issue. $ 225.00 1.80 $405.00 $405.00 $0.00 A 55 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 460 5/11/2020 UH Replied to email from Catherine Curtis. $ 225.00 0.30 $67.50 $67.50 $0.00 A 461 5/11/2020 UH Reviewed & compared competing versions of proposed Temporary orders. $ 225.00 2.20 $495.00 $495.00 $0.00 A 462 5/12/2020 GO Confer with attorney regarding deposition of respondent and pending issues to be heard and trial. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 463 5/12/2020 GO (2) Telephone conferences with Cecilia with 444th District Court regarding hearing and trial dates; drafted rule 11 agreement for same; prepared memo; forwarded to client correspondence regarding respondent's deposition; telephone conference with Lana with Mr. Dudley; worked on preparations for bankruptcy hearing; worked on a discovery notebook for trial; forwarded email to Mr. Dudley and Ms. Cortez regarding hearing setting. $ 95.00 3.80 $361.00 $270.75 $90.25 BB 464 5/12/2020 UH Reviewed Temporary Orders & prepared comparison report. $ 225.00 2.80 $630.00 $630.00 $0.00 A 465 5/12/2020 UH Reviewed December 13th, 2019 hearing transcript. & amended comparison report. $ 225.00 2.20 $495.00 $495.00 $0.00 A 466 5/12/2020 KPK Confer regarding setting of Motion to Compel Deposition $ 350.00 0.20 $70.00 $35.00 $35.00 E 467 5/13/2020 GO Confer with attorney regarding hearing and deposition. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 468 5/13/2020 GO Reply to email from client regarding deposition of respondent; (2) telephone conferences with Ms, Curtis regarding bankruptcy hearing; assist with preparations for hearing; forwarded hearing transcript for summary; telephone conference with client; prepared memo regarding deposition; assist with hearing; reply to email from opposing counsel confirming mediation availability; telephone conference with Leah with Ms. Cortez on mediation; (2) telephone conferences with Cecilia with Judge Rincones regarding hearing; (2) telephone conferences with Marilee with Nueces County; forwarded email to Cecilia with Judge Rangel; efiLed rule 11 agreement on mediation. $ 95.00 2.40 $228.00 $171.00 $57.00 BB 469 5/13/2020 KPK Prepare for hearing; schedule hearing; confer regarding Bankruptcy matter & prepare for hearing. $ 350.00 2.00 $700.00 $525.00 $175.00 BB 470 5/14/2020 GO Forwarded to client (2) orders setting hearing and a rule 11 agreement. $ 95.00 0.20 $19.00 $0.00 $19.00 C/NC 471 5/15/2020 GO Worked on notebok for mediation; telephone conference with Joy with mediator Michael O'Reilly. $ 95.00 4.80 $456.00 $456.00 $0.00 A 472 5/17/2020 KPK Prepare for Mediation. $ 350.00 1.00 $350.00 $350.00 $0.00 A 473 5/18/2020 GO Confer with attorney regarding mediation and hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 474 5/18/2020 GO Continued working on notebook for mediation; forwarded voice message to client; telephone conference with client; assist with mediation; telephone conference with Cecilia with 444th Cameron County Court; telephone conference with Lana with opposing counsel; forwarded to court motions to be heard at hearing. $ 95.00 3.40 $323.00 $242.25 $80.75 BB 475 5/18/2020 UH Calculated child support & attended mediation $ 225.00 1.20 $270.00 $270.00 $0.00 A 476 5/18/2020 KPK Attend Mediation and prepare. $ 350.00 5.00 $1,750.00 $1,312.50 $437.50 BB 477 5/19/2020 GO Confer with attorney regarding zoom hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 478 5/19/2020 GO Telephone conference with Cecilia with 444th Cameron County Court regarding hearing; reply to email from client; worked on preparations for hearing and notebook; download of documents forwarded to Judge Rincones relevant to hearing from opposing counsel. $ 95.00 2.50 $237.50 $178.13 $59.37 BB 479 5/19/2020 GO Reply to email from client; download and print of hearing transcripts for attorney review. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 480 5/19/2020 UH Reviewed transcript of July 2018 attorney's fees prove up. $ 225.00 0.50 $112.50 $112.50 $0.00 A 481 5/19/2020 KPK Prepare for hearing; schedule hearing; confer regarding Bankruptcy matter & prepare for hearing. $ 350.00 2.00 $700.00 $525.00 $175.00 BB 482 5/20/2020 GO Confer with attorney regarding hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 483 5/20/2020 GO Forwarded to client orders setting hearing and rule 11 agreement filed with court; (2) telephone conferences with client; forwarded documents relevant to hearing to Cecilia with 444th Cameron County Court; revised and forwarded correspondence to opposing counsel regarding order on hearing; copy to Ms. Cortez and client. $ 95.00 2.20 $209.00 $156.75 $52.25 BB 484 5/20/2020 KPK Read email. $ 350.00 0.20 $70.00 $52.50 $17.50 V 485 5/20/2020 KPK Prepare for hearing. $ 350.00 0.20 $70.00 $70.00 $0.00 A 486 5/21/2020 UH Reviewed letters provided by client from Brian Owsley. $ 225.00 0.20 $45.00 $45.00 $0.00 A 56 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 487 5/21/2020 UH Reviewed police incident report re Brian hitting 18 year old. $ 225.00 0.30 $67.50 $67.50 $0.00 A 488 5/22/2020 GO Confer with attorney regarding deposition of respondent. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 489 5/22/2020 GO Reply to email from client regarding deposition of respondent; noticed and forwarded deposition notice ofrespondent; copy to all parties. $ 95.00 0.80 $76.00 $38.00 $38.00 E 490 5/25/2020 KPK Work on supplementation. $ 350.00 0.40 $140.00 $105.00 $35.00 V 491 5/26/2020 GO Confer with attorneys regarding discovery and medical expense reimbursement. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 492 5/26/2020 GO Various telephone conferences with client regarding medical expense reimbursement; review of discovery responses for same; prepared and forwarded to opposing counsel supplemental responses to discovery requests; prepared and efiled certificate of written discovery; forwarded to opposing counsel correspondence regarding order on hearing and copy of motion request. $ 95.00 5.40 $513.00 $384.75 $128.25 BB 493 5/26/2020 GO Various telephone conferences with client on medical expenses; review of discovery responses; prepared and forwarded supplemental responses to discovery; prepared and efiled motion for enforcement of medical reimbursement; prepared and efiled certificate of written discovery; forwarded correspondence to opposing counsel regarding order on hearing and copy of motion. $ 95.00 4.20 $399.00 $0.00 $399.00 UN/D see 492 494 5/26/2020 UH Reviewed & signed supplemental Disclosures Responses. $ 225.00 0.20 $45.00 $45.00 $0.00 A 495 5/26/2020 UH Teleconference with client regarding attorneys fees. $ 225.00 0.20 $45.00 $45.00 $0.00 A 496 5/26/2020 UH Drafted letter to Bill Dudley. $ 225.00 0.20 $45.00 $45.00 $0.00 A 497 5/26/2020 UH Reviewed outgoing supplemental production. $ 225.00 0.30 $67.50 $67.50 $0.00 A 498 5/26/2020 UH Reviewed Motion for Enforcement. $ 225.00 0.20 $45.00 $45.00 $0.00 A 499 5/26/2020 KPK Work on supplementation & reimbursement of medical expenses & follow up on Order. $ 350.00 1.00 $350.00 $350.00 $0.00 A 500 5/27/2020 GO Confer with attorney regarding attorney fees. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 501 5/27/2020 GO Revised and efiled 3rd amended petition; worked on notebook for deposition of respondent; telephone conference with client; forwarded email to Ms. Curtis on application for attorney fees; telephone conference with court reporter; forwarded emails to court. reporter on deposition. $ 95.00 4.70 $446.50 $223.25 $223.25 E 502 5/27/2020 UH Drafted Third Amended Petition. $ 225.00 0.30 $67.50 $67.50 $0.00 A 503 5/27/2020 UH Reviewed correspondence & bills sent by Client $ 225.00 0.50 $112.50 $112.50 $0.00 A 504 5/27/2020 UH Set up drop box for supplemental discovery. $ 225.00 0.40 $90.00 $0.00 $90.00 C/NC 505 5/27/2020 KPK Read correspondence & prepare for deposition. $ 350.00 3.50 $1,225.00 $612.50 $612.50 E 506 5/28/2020 GO Assist with deposition; worked on deposition exhibits; research and download of previous documents from court's docket. $ 95.00 3.40 $323.00 $161.50 $161.50 E 507 5/28/2020 UH Reviewed proposed deposition questions. $ 225.00 0.30 $67.50 $33.75 $33.75 E 508 5/28/2020 UH Reviewed correspondence & drafted Order Compelling Discovery $ 225.00 1.30 $292.50 $292.50 $0.00 A 509 5/28/2020 UH Attended deposition of Brian Owsley. $ 225.00 2.70 $607.50 $303.75 $303.75 E 510 5/28/2020 KPK Prepare for and take the deposition of Brian Owsley $ 350.00 11.00 $3,850.00 $1,925.00 $1,925.00 E 511 5/29/2020 GO Review of Elizabeth's suicidal note. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 512 5/29/2020 GO Review of email from Ms. Curtis regarding application for attorney fees. $ 95.00 0.40 $38.00 $38.00 $0.00 A 513 5/29/2020 UH Revised Order Compelling Discovery. $ 225.00 0.20 $45.00 $45.00 $0.00 A 514 5/29/2020 UH Reviewed suicide note. $ 225.00 0.20 $45.00 $45.00 $0.00 A 515 5/29/2020 KPK Memo regarding "things to do". $ 350.00 0.40 $140.00 $105.00 $35.00 V 516 5/29/2020 KPK Read suicide letter. $ 350.00 0.30 $105.00 $105.00 $0.00 A 57 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 517 6/1/2020 GO (2) Telephone conferences with Joy with Michael O'Reilly regarding mediation; forwarded email to client on same; reply to emails from court reporter on deposition of respondent. $ 95.00 1.10 $104.50 $78.38 $26.12 BB 518 6/1/2020 UH Reviewed documents & prepare memo. $ 225.00 0.90 $202.50 $151.88 $50.62 V 519 6/1/2020 KPK Correspondence to client regarding Mr. O'Reilly. $ 350.00 0.20 $70.00 $70.00 $0.00 A 520 6/2/2020 GO Prepared request for citation, show cause to district clerk on motion for enforcement of final decree on medical reimbursement. $ 95.00 0.70 $66.50 $66.50 $0.00 A 521 6/3/2020 KPK Email to Bill Dudley regarding Elizabeth's travel on June 5th. (KPK didn't provide time) $ - 0.00 $0.00 $0.00 $0.00 A 522 6/4/2020 GO Confer with attorney regarding application for attorney fees. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 523 6/6/2020 KPK Read email. $ 350.00 0.30 $105.00 $78.75 $26.25 V 524 6/8/2020 GO Started compelling of OFW text messages between parties for attorney review. $ 95.00 0.20 $19.00 $19.00 $0.00 A 525 6/8/2020 GO Worked on application for attorney fees. $ 95.00 0.30 $28.50 $28.50 $0.00 A 526 6/8/2020 KPK Confer regarding O. Family Wizard. $ 350.00 0.20 $70.00 $70.00 $0.00 A 527 6/9/2020 GO Confer with attorney regarding trial and possible continuation for in-person trial. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 528 6/9/2020 GO (2) Telephone conferences with court reporter regarding deposition transcript ofrespondent; forwarded email to court reporter on same. $ 95.00 0.30 $28.50 $21.38 $7.12 BB 529 6/10/2020 GO Confer with attorney regarding continuation of trial date and review of respondent's discovery responses. No charge $ - 0.30 $0.00 $0.00 $0.00 A 530 6/10/2020 GO Prepared notebook on OFW messages between parties; telephone conference with client regarding authority to continue case for an in-person trial setting and regarding review Of respondent's discovery responses. $ 95.00 0.90 $85.50 $64.13 $21.37 BB 531 6/10/2020 KPK Call to Bill Dudley & confer with Lana. $ 350.00 0.30 $105.00 $105.00 $0.00 A 532 6/11/2020 UH Prepared 1st Interim Fee Application. $ 225.00 1.60 $360.00 $360.00 $0.00 A 533 6/19/2020 JM Obtained documents re: finalizing and filing Interim Application for Attorney's fees and expenses for D&K. $ 95.00 1.20 $114.00 $114.00 $0.00 A 534 6/24/2020 DPS Review of file for preparation of deposition transcript to Televideo & teleconference with Marilu with Televideo; met with Rep from Televideo to provide page/lines & transcript; Finalized Petitioner's Motion to Exclude Evidence, Order Setting hearing for same & e filed same; teleconference with 319th Clerk regarding filing of Pet's Motion to Exclude Evidence; assisted with trial preparation. $ 95.00 2.00 $190.00 $142.50 $47.50 BB 535 6/24/2020 GO Continued working on preparations for trial; worked on trial exhibits; visit with client; forwarded email to Lindsey with Dr. Kit Harrison regarding testimony; forwarded voice message to V. Shuey on respondent records; telephone conference with Marilee with Nueces District Court regarding exhibits; forwarded deposition page lines to opposing counsel; efiled same with court. $ 95.00 6.10 $579.50 $434.63 $144.87 BB 536 6/24/2020 UH Trial preparation. $ 225.00 6.50 $1,462.50 $1,462.50 $0.00 A 537 6/25/2020 GO Confer with attorneys regarding trial. No charge. $ - 0.50 $0.00 $0.00 $0.00 A 538 6/25/2020 GO Prepared correspondence to Judge Rincones forwarding thumb drive on respondent's deposition excerpts; copy to opposing counsel and Ms. Cortez; various telephone conferences with Marilou with Judge Rincones on exhibits; forwarded same to Marilou; copy to counsel; prepared and forwarded petitioner's supplemental exhibit list; forwarded suicide note and respondent's December email between parties regarding Elizabeth to Dr. Kit Harrison; forwarded email to client regarding testimony of Dr. Harrison; telephone conference with Lindsey with Dr. Harrison; download of respondent's trial exhibits. $ 95.00 4.30 $408.50 $306.38 $102.12 BB 539 6/25/2020 UH Trial preparation. $ 225.00 2.90 $652.50 $652.50 $0.00 A 540 6/25/2020 UH Trial. $ 225.00 5.20 $1,170.00 $1,170.00 $0.00 A 541 6/25/2020 KPK Trial and prepare for trial. $ 350.00 12.00 $4,200.00 $4,200.00 $0.00 A 542 6/26/2020 GO Assist with trial; forwarded page lines to attorney; prepared list of respondent's trial exhibit list; telephone conference with Marylou with Televideo; forwarded to court reporter deposition transcript of respondent; prepared and forwarded correspondence to Dr. Kit Harrison regarding testimony. $ 95.00 1.80 $171.00 $128.25 $42.75 BB 543 6/26/2020 S Summarize Owsley documents. $ 95.00 7.00 $665.00 $498.75 $166.25 V 58 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 544 6/26/2020 UH Trial. $ 225.00 7.00 $1,575.00 $1,575.00 $0.00 A 545 6/26/2020 UH Prepared attorney's fees questions. $ 225.00 0.30 $67.50 $67.50 $0.00 A 546 6/26/2020 KPK Attend trial. $ 350.00 9.00 $3,150.00 $3,150.00 $0.00 A 547 6/27/2020 S Summarize Owsley documents. $ 95.00 5.00 $475.00 $356.25 $118.75 V 548 6/29/2020 KPK Review ex 24 and follow up on application for fees. $ 350.00 0.30 $105.00 $105.00 $0.00 A 549 6/30/2020 JM Emails with Curtis requesting hearing on First Application. Court will set it of objection filed. $ - 0.50 $0.00 $0.00 $0.00 A 550 6/30/2020 GO Forwarded to client correspondence received from opposing counsel regarding final orders and pleadings; telephone conference with court reporter regarding video of respondent's deposition. $ 95.00 0.20 $19.00 $14.25 $4.75 BB 551 6/30/2020 KPK Confer regarding therapy appt. $ 350.00 0.20 $70.00 $70.00 $0.00 A 552 7/1/2020 GO Updated discovery notebook for trial. $ 95.00 0.40 $38.00 $38.00 $0.00 A 553 7/1/2020 UH Prepare for trial. $ 225.00 1.10 $247.50 $247.50 $0.00 A 554 7/2/2020 GO Worked on trial exhibit list; forwarded petitioner's second supplemental trial exhibit list to court and counsel; copy to attorney and client; prepared correspondence to court efiling supplemental trial exhibit list; prepared and forwarded petitioner's third supplemental trial exhibit list to court and all parties; efiled same. $ 95.00 1.20 $114.00 $85.50 $28.50 BB 555 7/2/2020 UH Trial $ 225.00 8.00 $1,800.00 $1,800.00 $0.00 A 556 7/2/2020 KPK Conduct zoom trial and prepare. $ 350.00 11.00 $3,850.00 $3,850.00 $0.00 A 557 7/3/2020 KPK Trial Summary. $ 350.00 1.50 $525.00 $393.75 $131.25 V 558 7/4/2020 KPK Continue with memo of trial summary. $ 350.00 1.00 $350.00 $262.50 $87.50 V 559 7/5/2020 KPK Continue with memo of trial summary. $ 350.00 1.00 $350.00 $262.50 $87.50 V 560 7/7/2020 UH Prepared final order in suit to modify. $ 225.00 1.80 $405.00 $202.50 $202.50 E 561 7/7/2020 UH Responded to email from Catherine Curtis. $ 225.00 0.20 $45.00 $45.00 $0.00 A 562 7/7/2020 KPK Complete trial summary memorandum and rulings of Court $ 350.00 2.00 $700.00 $525.00 $175.00 V 563 7/8/2020 GO Confer with attorney regarding passports; review of trial memo. No charge. $ - 0.70 $0.00 $0.00 $0.00 A 564 7/8/2020 GO Forwarded email to client regarding passports; forwarded correspondence to Catherine Curtis regarding medical expense reimbursement issues. $ 95.00 0.50 $47.50 $35.63 $11.87 BB 565 7/8/2020 UH Sent email to opposing counsel regarding letter waiving service $ 225.00 0.20 $45.00 $45.00 $0.00 A 566 7/8/2020 UH Teleconference to Christine Cortez regarding final order. $ 225.00 0.10 $22.50 $22.50 $0.00 A 567 7/8/2020 UH Revised draft final order. $ 225.00 1.80 $405.00 $202.50 $202.50 E 568 7/8/2020 UH Teleconference from Catherine Curtis regarding letter requested by judge. $ 225.00 0.20 $45.00 $45.00 $0.00 A 569 7/8/2020 KPK Revise decree and confer with Bill Dudley; confer with C Curtis. $ 350.00 1.50 $525.00 $393.75 $131.25 BB 570 7/8/2020 KPK Read correspondence to court. $ 350.00 0.40 $140.00 $140.00 $0.00 A 571 7/9/2020 GO Forwarded email to client regarding current employer and medical expenses list; forwarded email to opposing counsel on school expenses; copy to client. $ 95.00 0.20 $19.00 $0.00 $19.00 C/NC 572 7/9/2020 UH Finished revising final order and sent to amicus for review $ 225.00 1.50 $337.50 $168.75 $168.75 E 573 7/9/2020 KPK Confer with Curtis. $ 350.00 0.30 $105.00 $105.00 $0.00 A 574 7/9/2020 KPK Confer regarding decree changes. $ 350.00 0.20 $70.00 $35.00 $35.00 E 575 7/10/2020 GO Reply to email from opposing counsel regarding documents to be received from respondent; forwarded same to client; forwarded email to client on Respondent's paid medical expenses. $ 95.00 0.20 $19.00 $19.00 $0.00 A 59 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 576 7/10/2020 UH Responded to email from Catherine Curtis. $ 225.00 0.10 $22.50 $22.50 $0.00 A 577 7/10/2020 UH Teleconference to Christine Cortez regarding status of reviewing order. $ 225.00 0.20 $45.00 $22.50 $22.50 E 578 7/10/2020 UH Teleconference to client regarding credit for retroactive support. $ 225.00 0.10 $22.50 $22.50 $0.00 A 579 7/10/2020 KPK Teleconference with client and Catherine Curtis. $ 350.00 0.50 $175.00 $175.00 $0.00 A 580 7/12/2020 KPK Prepare correspondence to Catherine Curtis. $ 350.00 0.50 $175.00 $175.00 $0.00 A 581 7/13/2020 KPK Read email from Catherine Curtis and respond. $ 350.00 0.70 $245.00 $245.00 $0.00 A 582 7/14/2020 KPK Read email and respond to email from client and Catherine Curtis. $ 350.00 0.20 $70.00 $70.00 $0.00 A 583 7/15/2020 KPK Email to Catherine Curtis. $ 350.00 0.20 $70.00 $70.00 $0.00 A 584 7/19/2020 KPK Review letter from Curtis. $ 350.00 0.50 $175.00 $175.00 $0.00 A 585 7/20/2020 GO Forwarded to client revised proposed final order. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 586 7/20/2020 UH Made revisions to final order and sent to opposing counsel and amicus. $ 225.00 0.40 $90.00 $45.00 $45.00 E 587 7/21/2020 UH Reviewed objection to DK fees. $ 225.00 0.40 $90.00 $0.00 $90.00 C/NC 588 7/21/2020 UH Legal research regarding response to objection fees. $ 225.00 1.40 $315.00 $0.00 $315.00 C/NC 589 7/23/2020 UH Sent email to opposing counsel regarding order status and unreimbursed medicals. $ 225.00 0.20 $45.00 $22.50 $22.50 E 590 7/23/2020 KPK Read email and memo regarding new medicals. $ 350.00 0.40 $140.00 $105.00 $35.00 V 591 7/24/2020 GO Review of trial summary; confer with attorneys regarding proposed revisions to final order. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 592 7/24/2020 GO Forwarded to attorney for review, revisions to proposed final order from oppsoing counsel reply to email from client; forwarded revisions to client. $ 95.00 0.20 $19.00 $14.25 $4.75 BB 593 7/24/2020 UH Reviewed letter from Bill Dudley. $ 225.00 0.20 $45.00 $22.50 $22.50 E 594 7/24/2020 UH Teleconference from Christine Cortez to go over final order changes requested by Bill Dudley. $ 225.00 0.50 $112.50 $56.25 $56.25 E 595 7/24/2020 UH Made tentative revisions to final decree. $ 225.00 1.00 $225.00 $112.50 $112.50 E 596 7/24/2020 UH Sent email to opposing counsel. $ 225.00 0.10 $22.50 $11.25 $11.25 E 597 7/24/2020 UH Reviewed requested order changes with co-counsel. $ 225.00 0.30 $67.50 $33.75 $33.75 E 598 7/24/2020 KPK Review changes requested by Bill Dudley; Corresponce to Bill Dudley and read Bankruptcy Ruling. $ 350.00 1.50 $525.00 $393.75 $131.25 BB 599 7/27/2020 SC Prepared email to Bill Dudley enclosing letter on Order. $ 95.00 0.50 $47.50 $23.75 $23.75 E 600 7/27/2020 UH Revised letter to opposing counsel. $ 225.00 0.20 $45.00 $22.50 $22.50 E 601 7/28/2020 GO Forwarded zoom invitation to client for hearing; worked on notebook for hearing. $ 95.00 2.10 $199.50 $149.63 $49.87 BB 602 7/28/2020 UH Reviewed and responded to email from amicus $ 225.00 0.20 $45.00 $22.50 $22.50 E 603 7/28/2020 UH Made revisions consented to. $ 225.00 0.60 $135.00 $67.50 $67.50 E 604 7/28/2020 KPK Respond to court regarding hearing. $ 350.00 0.30 $105.00 $52.50 $52.50 E 605 7/28/2020 KPK Prepare for hearing. $ 350.00 0.70 $245.00 $122.50 $122.50 E 606 7/29/2020 GO Confered with attorneys regarding hearing and medical expenses. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 607 7/29/2020 UH Drafted motion to reopen evidence. $ 225.00 0.40 $90.00 $45.00 $45.00 E 60 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 608 7/29/2020 UH Reviewed letter efiling by opposing counsel. $ 225.00 0.70 $157.50 $78.75 $78.75 E 609 7/29/2020 UH Attended hearing on entry of order. $ 225.00 1.60 $360.00 $180.00 $180.00 E 610 7/29/2020 UH Drafted order on motion for enforcement. $ 225.00 0.70 $157.50 $157.50 $0.00 A 611 7/29/2020 UH Teleconference and email to Catherine Curtis and Randy Pullman $ 225.00 0.30 $67.50 $67.50 $0.00 A 612 7/29/2020 UH Made revisions to final order and sent to opposing counsel and client. $ 225.00 0.40 $90.00 $45.00 $45.00 E 613 7/29/2020 GO Continued working on notebook for hearing; forwarded email to client on medical expenses; revised motion to re-enter evidence; prepared order setting hearing; efiled motion and order. $ 237.50 2.50 $237.50 $178.13 $59.37 BB 614 7/29/2020 KPK Prepare for and attend hearing. $ 350.00 2.60 $910.00 $455.00 $455.00 E 615 7/29/2020 KPK Revisions to Order. $ 350.00 1.50 $525.00 $262.50 $262.50 E 616 7/30/2020 GO Confer with attorneys regarding final order. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 617 7/30/2020 GO Revised and efiled correspondence to Judge Gloria Rincones regarding final order; copy to client. $ 95.00 0.40 $38.00 $19.00 $19.00 E 618 7/30/2020 UH Multiple teleconference and email to and from amicus and opposing counsel regarding final order $ 225.00 0.70 $157.50 $78.75 $78.75 E 619 7/30/2020 UH Multiple revisions to final order and enforcement order. $ 225.00 0.80 $180.00 $90.00 $90.00 E 620 7/30/2020 UH Teleconference to client regarding final order holiday provisions. $ 225.00 0.20 $45.00 $22.50 $22.50 E 621 7/30/2020 UH Drafted letter to court. $ 225.00 0.20 $45.00 $22.50 $22.50 E 622 7/30/2020 KPK Confer regarding changes to Order multiple times. $ 350.00 1.20 $420.00 $210.00 $210.00 E 623 7/30/2020 KPK Confer regarding extending deadline. $ 350.00 0.20 $70.00 $52.50 $17.50 V 624 7/31/2020 GO Confer with attorneys regarding final order and hearing. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 625 7/31/2020 GO Telephone conference with Cecilia with Judge Rincones regarding final order and upcoming hearing; prepared memo regarding contact information for court reporter; telephone conference with client; attempts to forward opposing counsel's revisions to final order to client via text. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 626 7/31/2020 KPK Review correspondence from Bill Dudley. $ 350.00 0.30 $105.00 $52.50 $52.50 E 627 8/3/2020 KPK Read messages and read Motion to Convert and Appoint Trustee. $ - 0.60 $0.00 $0.00 $0.00 A 628 8/3/2020 GO Forwarded zoom invitation for hearing to client; telephone conference with Leah with amicus attorney confirming payment from petitioner; forwarded opposing counsel's revisions to final order to client; reply to emails from client; telephone conference with client. $ 95.00 0.70 $66.50 $49.88 $16.62 BB 629 8/3/2020 UH Reviewed requested changes to orders. $ 225.00 0.40 $90.00 $45.00 $45.00 E 630 8/3/2020 UH Revised order on enforcement. $ 225.00 0.30 $67.50 $67.50 $0.00 A 631 8/3/2020 UH Revised final order in suit to modify. $ 225.00 0.80 $180.00 $90.00 $90.00 E 632 8/3/2020 KPK Review Bill Dudley's changes to Order. $ 350.00 0.40 $140.00 $70.00 $70.00 E 633 8/4/2020 GO Confer with attorney regarding holiday provisions. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 634 8/4/2020 GO Revised motion for reconsideration of holiday provisions; prepared order setting hearing; efiled motion and order; copy to client. $ 95.00 0.60 $57.00 $42.75 $14.25 BB 635 8/4/2020 UH Teleconference to and from client regarding order revisions. $ 225.00 0.30 $67.50 $33.75 $33.75 E 636 8/4/2020 UH Made further revisions to order and sent out. $ 225.00 0.40 $90.00 $45.00 $45.00 E 637 8/4/2020 UH Teleconference to client regarding motion for reconsideration on holidays. $ 225.00 0.30 $67.50 $33.75 $33.75 E 61 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 638 8/4/2020 UH Drafted motion for reconsideration. $ 225.00 0.30 $67.50 $33.75 $33.75 E 639 8/4/2020 UH Sent motion and proposed order to court coordinator. $ 225.00 0.20 $45.00 $22.50 $22.50 E 640 8/4/2020 UH Sent revised motion and proposed order to court coordinator. $ 225.00 0.10 $22.50 $11.25 $11.25 E 641 8/4/2020 KPK Confer regarding changes to Order. $ 350.00 0.30 $105.00 $52.50 $52.50 E 642 8/4/2020 KPK Review Bankruptcy Docs regarding claims. $ 350.00 0.40 $140.00 $105.00 $35.00 V 643 8/4/2020 KPK Read Declaration of Jimie Owsley $ 350.00 0.40 $140.00 $140.00 $0.00 A 644 8/4/2020 KPK Review open questions and revise Decree; attend hearing. $ 350.00 4.00 $1,400.00 $1,050.00 $350.00 BB 645 8/5/2020 GO Assist with hearing. $ 95.00 0.30 $28.50 $14.25 $14.25 E 646 8/5/2020 UH Multiple teleconference to Bill Dudley regarding order changes. $ 225.00 1.00 $225.00 $112.50 $112.50 E 647 8/5/2020 UH Multiple teleconference to client regarding order changes. $ 225.00 0.40 $90.00 $45.00 $45.00 E 648 8/5/2020 UH Made revisions to order. $ 225.00 0.50 $112.50 $56.25 $56.25 E 649 8/5/2020 UH Attend hearing. $ 225.00 0.30 $67.50 $33.75 $33.75 E 650 8/5/2020 UH Teleconference with Christine Cortez regarding order changes. $ 225.00 0.40 $90.00 $45.00 $45.00 E 651 8/5/2020 UH Sent newest order version to court coordinator. $ 225.00 0.10 $22.50 $11.25 $11.25 E 652 8/5/2020 UH Made court-ordered revisions and sent to opposing counsel and amicus. $ 225.00 0.40 $90.00 $45.00 $45.00 E 653 8/5/2020 UH Multiple teleconference to Bill Dudley regarding order changes. $ 225.00 1.00 $225.00 $0.00 $225.00 UN/D see 646 654 8/5/2020 UH Multiple teleconference to client regarding order changes. $ 225.00 0.40 $90.00 $0.00 $90.00 UN/D see 647 655 8/5/2020 UH Made revisions to order. $ 225.00 0.50 $112.50 $0.00 $112.50 UN/D see 648 656 8/5/2020 UH Attend hearing. $ 225.00 0.30 $67.50 $0.00 $67.50 UN/D see 649 657 8/5/2020 UH Teleconference from Christine Cortez regarding order changes. $ 225.00 0.40 $90.00 $0.00 $90.00 UN/D see 650 658 8/5/2020 UH Sent newest order version to court coordinator. $ 225.00 0.10 $22.50 $0.00 $22.50 UN/D see 651 659 8/5/2020 UH Made court-ordered revisions and sent to opposing counsel and amicus. $ 225.00 0.40 $90.00 $0.00 $90.00 UN/D see 652 660 8/6/2020 GO Confer with attorneys regarding amending application for attorney fees. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 661 8/6/2020 GO Worked on response to opposition to debtor's first interim application fees and expenses; revisions to same; forwarded response to Catherine Curtis for review; copy to client. $ - 1.50 $0.00 $0.00 $0.00 A 662 8/6/2020 UH Reviewed billing sample. $ - 0.20 $0.00 $0.00 $0.00 A 663 8/6/2020 UH Reviewed and compared orders. $ 225.00 0.70 $157.50 $78.75 $78.75 E 664 8/6/2020 UH Made revisions to order and efiled. $ 225.00 0.20 $45.00 $22.50 $22.50 E 665 8/6/2020 UH Teleconference with Christine Cortez. $ 225.00 0.20 $45.00 $22.50 $22.50 E 666 8/6/2020 KPK Revise Order and correspond with Mr. Dudley; teleconference with Ms. Cortez; revise Response to Objections. $ 350.00 1.20 $420.00 $210.00 $210.00 E 667 8/7/2020 GO Confer with attorneys regarding comparison of final decree versions. No charge. $ - 0.40 $0.00 $0.00 $0.00 A 62 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 668 8/7/2020 GO Worked on preparations for hearing; assist with hearing; telephone conference with Cecilia with Judge Rincones; forwarded petitioner's and respondent's version of final order to client for review; prepared and forwarded correspondence to Cecilia with Judge Rincones; forwarded order on motion for enforcement to Catherine Curtis; copy to client $ 95.00 1.00 $95.00 $71.25 $23.75 BB 669 8/7/2020 UH Prepared for zoom hearing. $ 225.00 0.40 $90.00 $45.00 $45.00 E 670 8/7/2020 UH Reviewed and compared order signed by judge with our order. $ 225.00 0.30 $67.50 $33.75 $33.75 E 671 8/7/2020 UH Spoke to Christine Cortez regarding signed order. $ 225.00 0.10 $22.50 $11.25 $11.25 E 672 8/7/2020 UH Drafted 1st amended interim application for fees. $ 225.00 0.80 $180.00 $0.00 $180.00 C/NC 673 8/7/2020 KPK Confer regarding final Orders; review signed Order and prepare for hearing. $ 350.00 0.80 $280.00 $140.00 $140.00 E 674 8/7/2020 KPK Revise Application. $ 350.00 0.30 $105.00 $105.00 $0.00 A 675 8/10/2020 GO Reply to email from client on medical expenses; worked on exhibit and witness list; download of documents received from Catherine Curtis. $ 95.00 0.90 $85.50 $64.13 $21.37 BB 676 8/10/2020 UH Revised response to opposition to fee application. $ 225.00 0.80 $180.00 $0.00 $180.00 C/NC 677 8/10/2020 UH Prepared exhibit and witness list. $ 225.00 0.30 $67.50 $0.00 $67.50 C/NC 678 8/10/2020 UH Emails to and from client regarding bankruptcy order. $ 225.00 0.30 $67.50 $67.50 $0.00 A 679 8/10/2020 KPK Review request for medical reimbursement. $ 350.00 0.30 $105.00 $105.00 $0.00 A 680 8/10/2020 KPK Work on hearing exhibits. $ 350.00 0.40 $140.00 $0.00 $140.00 C/NC 681 8/10/2020 KPK Work on Witness List and Response to Objection $ 350.00 0.80 $280.00 $0.00 $280.00 C/NC 682 8/11/2020 KPK Confer with counsel regarding hearing on 8/12. $ 350.00 0.60 $210.00 $0.00 $210.00 C/NC 683 8/12/2020 GO Worked on preparation for hearing. $ 95.00 0.50 $47.50 $0.00 $47.50 C/NC 684 8/12/2020 UH Reviewed trial exhibits, documents, and receipts regarding unreimbursement medicals. $ 225.00 1.40 $315.00 $315.00 $0.00 A 685 8/12/2020 UH Hearing preparation and setup. $ 225.00 0.30 $67.50 $0.00 $67.50 C/NC 686 8/12/2020 UH Attended hearing on fees. $ 225.00 1.40 $315.00 $0.00 $315.00 C/NC 687 8/12/2020 KPK Prepare for hearing and attend hearing and preparation of attorney fees questions. $ 350.00 2.00 $700.00 $0.00 $700.00 C/NC 688 8/13/2020 UH Reviewed current billing statements. $ - 0.30 $0.00 $0.00 $0.00 A 689 8/13/2020 UH Prepared 2nd amended fee application. $ 225.00 2.00 $450.00 $0.00 $450.00 C/NC 690 8/13/2020 UH Reviewed email from opposing counsel. $ 225.00 0.10 $22.50 $22.50 $0.00 A 691 8/14/2020 KPK Revise attorney fee statements (n/c) $ - 0.30 $0.00 $0.00 $0.00 A 692 8/15/2020 KPK Memo regarding "things to do". $ 350.00 0.20 $70.00 $52.50 $17.50 V 693 8/21/2020 GO confer with attorney regarding documents to be filed. $ - 0.20 $0.00 $0.00 $0.00 A 694 8/25/2020 UH Reviewed ethics opinion. $ 225.00 0.20 $45.00 $0.00 $45.00 C/NC 695 8/26/2020 KPK Email to court reporter. $ 350.00 0.20 $70.00 $70.00 $0.00 A 696 8/26/2020 KPK Confer regarding unpaid medicals. $ 350.00 0.30 $105.00 $105.00 $0.00 A 697 8/27/2020 KPK Review Transcript $ 350.00 0.50 $175.00 $131.25 $43.75 V 698 8/28/2020 GO Telephone conference with court reporter regarding deposition transcript of Brian Owsley; worked on efiling of exhibits in bankruptcy court $ 95.00 5.30 $503.50 $377.63 $125.87 BB 699 8/31/2020 KPK Confer regarding new application and email $ 350.00 0.30 $105.00 $0.00 $105.00 C/NC 700 9/2/2020 UH Reviewed signed Rule 11 $ 350.00 0.30 $67.50 $67.50 $0.00 A 701 9/4/2020 KPK Follow up on attorneys fees $ 350.00 0.20 $70.00 $52.50 $17.50 V 702 9/15/2020 GO Reply to email from client regarding Respondent's violations of final order; forwarded final order signed by Judge to client. $ 95.00 0.10 $9.50 $9.50 $0.00 A 703 9/15/2020 KPK Work on new medical issues. $ 350.00 0.20 $70.00 $70.00 $0.00 A 704 9/17/2020 GO Confer with attorney regarding Respondent's violations of final order. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 705 9/18/2020 UH Teleconference with client regarding unpaid bills. $ 225.00 0.20 $45.00 $45.00 $0.00 A 63 Glossary BB Block-Billed entries, reduced by 25%. E Excessive entries, reduced by 50%. UN/D Unnecessary work, allowed at $0.00. C/NC Clerical or other non-compensable work, allowed at $0.00. V Vague, reduced by 25%. UA Unauthorized work, allowed at $0.00. A Allowed in full. Entry Date Billing Professional Description Rate Hours Amount Req. Allowed Disallowed Disallowance (See Glossary) 706 9/18/2020 UH Forwarded final Order of OAG. $ 225.00 0.10 $22.50 $22.50 $0.00 A 707 9/22/2020 GO Forwarded correspondence to opposing counsel regarding Respondent's violations of final order; copy to client. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 708 9/22/2020 UH Drafted letter to opposing counsel. $ 225.00 0.20 $45.00 $45.00 $0.00 A 709 9/24/2020 GO Confer With attorney regarding respondent's violations. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 710 9/24/2020 GO Confer with attorney regarding documents received from opposing on payments as per court order. No charge. $ - 0.30 $0.00 $0.00 $0.00 A 711 9/24/2020 GO Download of multiple attachments to correspondence from opposing counsel regarding Respondent's payments as per court's order; forwarded same to client; $ 95.00 0.40 $38.00 $0.00 $38.00 C/NC 712 9/24/2020 UH Reviewed documents sent by Bill Dudley $ 225.00 0.80 $180.00 $135.00 $45.00 V 713 9/24/2020 UH Teleconference with Office of Attorney General regarding child support. $ 225.00 0.50 $112.50 $112.50 $0.00 A 714 9/24/2020 UH Drafted email to client regarding Office of Attorney General & Bill Dudley documents. $ 225.00 0.20 $45.00 $45.00 $0.00 A 715 9/24/2020 UH Reviewed & responded to email from client. $ 225.00 0.20 $45.00 $45.00 $0.00 A 716 9/25/2020 GO Confer with attorney regarding child support payment record. No charge. $ - 0.20 $0.00 $0.00 $0.00 A 717 9/25/2020 GO Telephonc conference with Patricia with Attorney General's Office regarding request for child support report. $ 95.00 0.20 $19.00 $19.00 $0.00 A 718 9/25/2020 UH Teleconference with Office of Attorney General's office regarding unentered Orders $ 225.00 0.40 $90.00 $90.00 $0.00 A 719 9/28/2020 GO Forwarded to client: (2) correspondences received from the Office of the Attorney General. $ 95.00 0.10 $9.50 $0.00 $9.50 C/NC 720 10/1/2020 KPK Review Attorney General notices. $ 350.00 0.20 $70.00 $70.00 $0.00 A 721 10/2/2020 GO Confer with attorney regarding reimbutsement of medical expenses owed by respondent. $ - 0.20 $0.00 $0.00 $0.00 A 722 10/2/2020 GO Worked on list of monies owed by respondent as reimbursement of medical expense, $ 95.00 0.50 $47.50 $47.50 $0.00 A 723 10/2/2020 UH Reviewed financial activity report & sent email to client. $ 225.00 0.20 $45.00 $45.00 $0.00 A 724 10/2/2020 UH Reviewed & responded to client's email regarding support $ 225.00 0.30 $67.50 $67.50 $0.00 A 725 10/2/2020 KPK Review Child Support Ledger $ 350.00 0.20 $70.00 $70.00 $0.00 A 726 10/21/2020 KPK Read email & respond to same. $ 350.00 0.30 $105.00 $78.75 $26.25 V Totals: 670.40 $127,641.50 $90,114.00 $37,527.50