exhibit - kcc class action - active casesclassaction.kccllc.net/documents/nwd0001/577-2...case...

EXHIBIT 2

Case 1:13-cv-06802-WHP Document 577-2 Filed 07/13/16 of 264

SUSMAN GODFREY L.L.P. A REGISTERED LIMITED LIABILITY PARTNERSHIP

July 8, 2016 Invoice# 274698 Matter# 013828

Tax I.D.# 74‐2138615

Fees

Date Attorney Description Hours Amount

06/06/13 J. Southwick Reviewing materials from S. Berry re lawsuit by CPGs against News America. Researching factual matters re CPG case against NAMIS.

5.00 $3,125.00

06/10/13 J. Southwick Reviewing memorandums and fee proposals from S. Berry. Researching claims and procedural posture of both the Detroit and the New York declaratory judgment suit.

2.40 $1,500.00

06/11/13 J. Southwick Reviewing derivative suit filed against News Corp and emails with S. Berry and S. Benz.

1.00 $625.00

06/14/13 R. Hess Case acceptance re NAM‐FSI. 1.20 $570.00

06/14/13 J. Southwick Reviewing J. Pauley class certification order in Fox intern case. Preparing for and participating in call with S. Berry and S. Benz.

2.60 $1,625.00

06/18/13 J. Southwick Conferring by email with P. Folse re thoughts on case against NAMIS and potential cocounsel.

0.50 $312.50

06/21/13 J. Southwick Reviewing American Express Supreme Court opinion re effective vindication of antitrust law and consider effective NAMIS contractual limitations on class plaintiffs statute of limitation. Preparing spreadsheet of potential recovery. Conferring by emails with P. Folse. Conferring by email with S. Berry.

4.00 $2,500.00

06/24/13 J. Southwick Reviewing draft third amended complaint from S. Berry. Researching points of law re monopolization claims.

1.50 $937.50

06/27/13 J. Southwick Reviewing case dockets in Detroit and New York. Conferring by emails with S. Berry. Conferring by phone with P. Folse.

1.00 $625.00

07/02/13 J. Southwick Traveling to Washington DC. Preparing and meeting with S. Berry. Traveling to Houston.

9.50 $5,937.50

07/26/13 R. Caughey Conferring with J. Southwick and R. Hess re initial case tasks and issues. Reviewing dockets and circulating summary of key points to team. Reviewing pleadings and cocounsel agreement. Conferring with team re conference call. Conferring with

2.00 $750.00

Case 1:13-cv-06802-WHP Document 577-2 Filed 07/13/16 Page 2 of 264



Tax I.D.# 74‐2138615

document vendor re issues.

07/26/13 R. Hess Conferring in office with J. Southwick and R. Caughey.

0.30 $142.50

07/26/13 J. Southwick Conferring with R. Hess and R. Caughey re nature of the case, procedural posture, and cocounsel arrangements. Emailing case materials to R. Hess and R. Caughey. Reviewing email from R. Caughey re his review of dockets in Michigan and New York cases and upcoming deadlines. Conferring by email with cocounsel re arranging trial team calls.

2.20 $1,375.00

07/28/13 R. Caughey Reviewing pleadings and agreements. 0.80 $300.00

08/01/13 J. Southwick Conferring by emails with cocounsel. 0.50 $312.50

08/02/13 R. Caughey Reviewing and revising third amended complaint.

1.00 $375.00

08/02/13 R. Hess Reviewing email and Reply in support of Motion to Supplement.

0.10 $47.50

08/04/13 R. Hess Reviewing draft Third Amended Complaint. 0.70 $332.50

08/05/13 R. Hess Reviewing draft amended complaint. Reviewing R. Caughey proposed changes to amended complaint.

0.80 $380.00

08/05/13 R. Caughey Reviewing and revising Third Amended Complaint. Circulating to J. Southwick and R. Hess for review.

2.50 $937.50

08/06/13 J. Southwick Traveling to Dallas. (2.0) Meeting with L. LeClair, S. Berry, and J. Presant. (1.5) Traveling to Houston. (2.0)

5.50 $3,437.50

08/06/13 R. Caughey Reviewing amended complaint. Conferring with trial team re issues.

0.50 $187.50

08/08/13 R. Caughey Preparing research re mechanics of separation of News Corp. and 21st Century Fox. Conferring with trial team re R .Emmel and injunction issues.

0.50 $187.50

08/09/13 J. Southwick Reviewing emails re contracts. 0.30 $187.50

08/12/13 J. Southwick Reviewing email from R. Caughey re News Corp post separation from Fox. Reviewing News Corp SEC filings.

2.20 $1,375.00

08/12/13 R. Caughey Preparing memorandum re News Corp.'s 2.50 $937.50




Tax I.D.# 74‐2138615

separation and capitalization. Preparing follow‐up research. Conferring with trial team re related issues.

08/13/13 J. Southwick Reviewing research from R. Caughey re News Corp financing and structure. Preparing for and calling cocounsel. Preparing first task sheet. Conferring by phone with R. Caughey.

2.60 $1,625.00

08/13/13 R. Caughey Participating in weekly trial team call. Preparing follow‐up research re News Corp.'s capitalizing. Making arrangements for in‐person meeting in Houston.

1.00 $375.00

08/14/13 J. Southwick Finalizing and circulating task sheet to trial team. Reviewing and responding to emails from trial team.

1.00 $625.00

08/14/13 J. Stanley Preparing materials for R. Caughey and J. Southwick to review.

1.00 $250.00

08/14/13 R. Caughey Reviewing and responding to correspondence.

0.20 $75.00

08/15/13 R. Hess Reviewing NAM FSI contracts with CPGs. Reviewing redlines to third amended Complaint. Reviewing correspondence with co‐counsel on fee agreements. Conferring with J. Southwick re same.

0.60 $285.00

08/16/13 J. Southwick Reviewing emails and filings re third amended complaint. Reviewing correspondence re discovery of Foster Farms in SDNY action.

1.00 $625.00

08/16/13 R. Hess Reviewing NAM FSI contracts with CPGs. 3.30 $1,567.50

08/16/13 R. Caughey Conferring with trial team re strategy. Reviewing contracts. Reviewing finalized Third Amended Complaint and redlines. Conferring with R. Hess re issues.

1.20 $450.00

08/19/13 R. Hess Conferring in office with J. Southwick re ROFR contracts.

0.70 $332.50

08/20/13 J. Southwick Reviewing emails in preparation for trial team call. Reviewing discovery in SDNY re Foster Farms.

2.50 $1,562.50

08/20/13 J. Stanley Preparing materials for J. Southwick to review.

1.00 $250.00




Tax I.D.# 74‐2138615

08/20/13 R. Caughey Conferring with team re initial disclosures. Reviewing emails and correspondence. Reviewing draft pleadings. Reviewing conflict letter. Participating in weekly trial team conference call.

1.10 $412.50

08/21/13 R. Hess Reviewing draft motion to dismiss. Reviewing emails and draft discovery responses from Foster Farms.

0.50 $237.50

08/21/13 J. Stanley Reviewing agreements to determine who still has not signed.

1.00 $250.00

08/21/13 R. Caughey Reviewing and commenting on client conflicts letter. Conferring with team re initial disclosures for Foster Farms. Reviewing discovery and dockets.

1.00 $375.00

08/22/13 J. Southwick Updating task sheet. Reviewing and responding to email with cocounsel.

1.00 $625.00


2.00 $500.00

08/23/13 R. Hess Revising motion to dismiss brief. Conferring with trial team.

0.70 $332.50

08/23/13 J. Southwick Conferring by phone with D. Goldman re Coca‐Cola.

0.30 $187.50

08/24/13 R. Caughey Reviewing and responding to correspondence. Reviewing pleadings.

0.40 $150.00

08/26/13 J. Southwick Reviewing draft motion to dismiss case in Southern District of New York and emailing J. Presant. Conferring with R. Hess re Foster Farms discovery requests. Reviewing News interrogatories and requests for production to Foster Farms. Reviewing emails from Foster Farms re initial disclosures. Conferring by phone with R. Boyce of Foster Farms re responses to News discovery requests.

1.80 $1,125.00

08/26/13 R. Caughey Participating in call with trial team and Foster Farms re discovery. Preparing and revising Foster Farms initial disclosures and circulating to trial team. Reviewing materials in connection with preparing initial disclosures.

2.10 $787.50




Tax I.D.# 74‐2138615

08/26/13 R. Hess Conferring by phone with Foster Farms' Randy Boyce and trial team.

0.20 $95.00

08/27/13 R. Caughey Preparing interrogatory responses, responses to requests for production, and initial disclosures for Foster Farms. Conferring with J. Southwick re discovery responses. Conferring with J. Corsiglia‐Keim re initial disclosures and discovery responses. Preparing memorandum to Foster Farms re discovery issues. Preparing memorandum to trial team re email service law and issues. Reviewing pleadings and public materials in connection with preparing discovery responses.

3.50 $1,312.50

08/27/13 J. Southwick Conferring with R. Caughey re preparation of discovery responses and initial disclosures for Foster Farms. Participating in weekly trial team call with cocounsel.

1.40 $875.00

08/28/13 J. Southwick Conferring by phone with D. Goldman re Coca Cola. Attending lunch with D. Goldman.

1.00 $625.00

08/28/13 R. Caughey Preparing and revising Foster Farms discovery responses. Preparing materials re initial disclosures and interrogatory responses. Conferring with team re strategy.

1.70 $637.50

08/29/13 J. Southwick Reviewing testimony of J. Mackie‐Mason and P. Ferris from Valassis case. Participating in conference call with cocounsel with J. Mackie‐Mason and his associates re potential expert work. Participating in conference call with P. Farris re potential expert work.

3.70 $2,312.50

08/29/13 R. Caughey Preparing discovery responses and reviewing contracts. Conferring with Foster Farms re discovery issues and information. Conferring with trial team re same. Conferring with J. Present re discovery dates and relation back. Preparing interrogatory responses.

2.50 $937.50

08/30/13 J. Southwick Conferring by emails with trial team re potential expert witnesses. Reviewing B.

1.00 $625.00




Tax I.D.# 74‐2138615

Wecker's website to see his recent work.

08/30/13 R. Caughey Conferring with R. Boyce re discovery materials and travel to California. Conferring with team re initial disclosures and discovery. Preparing discovery materials. Conferring with J. Corsiglia‐Keim and reviewing information she sent to us.

0.70 $262.50

08/30/13 R. Caughey Revising initial disclosures and circulating revised disclosures to team. Conferring with team re disclosures. Preparing memorandum to team re discovery date ranges and class damages period. Conferring with J. Presant re same.

3.00 $1,125.00

08/30/13 R. Caughey Conferring with team re issues. 0.20 $75.00

09/02/13 R. Caughey Circulating memorandum to team re discovery date range.

0.20 $75.00

09/03/13 J. Southwick Participating in discussion with J. Carter and R. Hess re client waiver of conflict agreement. Reviewing revised initial disclosures for Foster Farms. Preparing for meeting in Houston with cocounsel. Researching potential expert witnesses.

5.20 $3,250.00

09/03/13 R. Caughey Revising initial disclosures. Preparing for in‐person meeting in Houston. Conferring by telephone with opposing counsel re email service and discovery. Preparing discovery responses. Reviewing contracts. Preparing correspondence with opposing counsel. Organizing logistics of in‐person meeting. Conferring with Foster Farms re initial disclosures, interrogatories, etc. Revising initial disclosures and conferring with J. Southwick re same. Circulating disclosures to cocounsel. Conferring with R. Boyce re interrogatories and preparing analysis for same.

3.30 $1,237.50

09/04/13 J. Southwick Meeting with cocounsel in SG's offices. Conferring by email to D. Bernheim re potential expert work. Conferring by emails with D. Goldman re status of limitations shortening by contract.

2.90 $1,812.50




Tax I.D.# 74‐2138615

09/04/13 R. Hess Reviewing expert CV's, resumes and transcripts. Conferring with trial team re same. Attending meeting of co‐counsel in Houston. Conferring by phone with JPOR re expert references. Preparing for trial team meeting.

3.60 $1,710.00

09/04/13 R. Caughey Participating in in‐person team meeting in Houston. Preparing for meeting in Houston. Preparing research re potential expert witnesses and circulating to team. Canvassing case law and circulating to team. Finalizing Foster Farms initial disclosures and serving on opposing counsel. Conferring with team re initial disclosures. Conferring with Foster Farms repeatedly re initial disclosures and interrogatory responses. Preparing interrogatory responses. Conferring with opposing counsel re email service and discovery. Conferring with R. Boyce re interrogatory responses and relevant individuals.

5.70 $2,137.50

09/05/13 J. Southwick Conferring by phone with D. Goldman re research concerning shortening the statue of limitations through contract. Reviewing and responding to emails from cocounsel.

0.20 $125.00

09/05/13 R. Caughey Preparing task list and circulating to team. Conferring with Foster Farms personnel re issues. Preparing list of client information. Preparing document preservation and retention notice and circulating to team. Reviewing contracts. Conferring with J. Presant re discovery and document collection. Reviewing expert biographical materials.

3.70 $1,387.50

09/06/13 J. Southwick Conferring by emails with and re retaining D. Bernheim as potential expert.

0.40 $250.00

09/06/13 R. Caughey Circulating document preservation memorandum to entire trial team. Conferring with J. Southwick re discovery dates.

1.50 $562.50

09/08/13 R. Caughey Preparing responses and objections to interrogatories and requests for production.

1.40 $525.00




Tax I.D.# 74‐2138615

Circulating responses to trial team. Preparing factual research re responses. Reviewing task sheet and itinerary. Conferring with J. Corsiglia‐Keim re personnel.

09/09/13 R. Hess Reviewing correspondence and conferring with trial team re plaintiff discovery and trial team calls. Reviewing correspondence from trial team re BEF discovery. Reviewing task list. Conferring by phone with trial team re filing and disclosure.

0.90 $427.50

09/09/13 R. Caughey Revising and circulating task list to team. Reviewing and revising document preservation notice, and circulating to team. Addressing Foster Farms discovery issues.

1.20 $450.00

09/09/13 R. Caughey Conferring with J. Corsiglia‐Keim re interrogatories. Conferring with team re strategy and issues.

0.40 $150.00

09/09/13 J. Southwick Conferring by emails with cocounsel and Susman Godfrey trial team re discovery. Arranging visits to Bob Evans and Foster Farms.

1.00 $625.00

09/10/13 J. Southwick Participating in weekly call with cocounsel. Reviewing emails and memorandums re statute of limitations. Conferring by emails re retaining experts. Conferring with R. Caughey re written discovery responses for Foster Farms. Updating and circulating spreadsheet re damages and statute of limitations.

3.30 $2,062.50

09/10/13 R. Hess Reviewing memorandum from co‐counsel. Reviewing spreadsheet from J. Southwick. Conferring by phone with trial team.

1.30 $617.50

09/11/13 R. Caughey Conferring with team re meeting in Columbus, Ohio. Circulating article re News Corp. investors. Preparing memorandum to team re Southeast Asset Management.

0.90 $337.50

09/11/13 J. Southwick Conferring by emails re meeting B. Evans. Arranging calls and meetings with potential experts. Preparing discovery to News America.

1.00 $625.00




Tax I.D.# 74‐2138615

09/11/13 R. Hess Conferring with trial team re in‐person meeting with client. Preparing for conference with B. Evans re discovery requests.

0.50 $237.50

09/12/13 R. Caughey Revising discovery responses in light of various comments and circulating to trial team and client. Conferring with the team re discovery. Participating in teleconference with D. Bernheim re expert retention. Organizing travel to Columbus, Ohio to meet with B. Evans. Reviewing correspondence re contracts and organizing materials in advance of B. Evans meeting.

3.80 $1,425.00

09/12/13 R. Hess Revising discovery responses. Revising responses to interrogatories. Conferring by phone with R. Caughey. Revising responses to requests for production. Conferring by phone with R. Caughey. Preparing for conference with client in Columbus, OH.

2.70 $1,282.50

09/12/13 J. Southwick Preparing for and participating in call with D. Bernheim and cocounsel to discuss potential retention as an expert witness. Conferring by emails inquiring about recent experience using J. Leitzinger as an expert witness. Conferring by emails re draft responses to discovery on Foster Farms in SDNY.

3.00 $1,875.00

09/13/13 R. Caughey Revising discovery responses and circulating to trial team in light of revisions by client. Circulating revised responses. Conferring with trial team re discovery and emails.

1.50 $562.50

09/15/13 R. Caughey Conferring with J. Corsiglia‐Keim re interrogatories. Revising interrogatory responses.

0.50 $187.50

09/16/13 R. Caughey Preparing research re opinions and exclusion of Dr. Leitzinger. Participating in teleconference with D. Leitzinger and conferring with J. Southwick re same. Revising Foster Farms discovery responses in light of comments from client and trial team. Serving Foster Farms discovery responses. Reviewing Bob Evans materials in advance of meeting.

3.10 $1,162.50




Tax I.D.# 74‐2138615

09/16/13 R. Hess Revising and reviewing Foster Farms Interrogatory responses and document requests.

0.50 $237.50

09/16/13 J. Southwick Reviewing email from R. Caughey re J. Leitzinger reported cases. Conferring by phone with J. Leitzinger and cocounsel re potential retention as expert witness. Conferring by emails to J. Leitzinger and D. Bernheim re forwarding amended complaint. Reviewing cases and decisions involving J. Leitinger.

2.50 $1,562.50

09/16/13 J. Stanley Preparing materials for J. Southwick and R. Caughey to review.

2.00 $500.00

09/17/13 J. Southwick Preparing for and participating in weekly call with cocounsel. Reviewing and responding to emails re meetings with Bob Evans and Foster Farms to discuss document gathering.

1.50 $937.50

09/17/13 R. Caughey Participating in weekly trial team call. Conferring with Foster Farms re discovery and meeting. Conferring with team re issues and travel. Reviewing contacts and materials.

1.40 $525.00

09/17/13 R. Hess Conferring by phone with trial team. 0.50 $237.50

09/18/13 R. Caughey Preparing and reviewing correspondence re experts and meetings with class representatives. Preparing for meeting at Bob Evans.

1.00 $375.00

09/18/13 R. Hess Traveling to Columbus. 4.50 $2,137.50

09/19/13 R. Caughey Meeting with Bob Evans personnel in Columbus, Ohio. Preparing for meeting and reviewing Bob Evans materials. Preparing memorandum to file re meeting. Preparing and reviewing correspondence re discovery. Traveling to Columbus, OH, and traveling back to Houston, TX.

11.30 $4,237.50

09/19/13 R. Hess Attending meeting of trial team and clients at Bob Evans Farms. Preparing same.

3.00 $1,425.00

09/20/13 J. Southwick Preparing Susman Godfrey time and expenses for August and circulating to cocounsel. Reviewing cocounsel time and expert summaries. Conferring with R. Hess

1.30 $812.50




Tax I.D.# 74‐2138615

about Bob Evans and Foster Farms document and discovery matters. Reviewing and responding to email with cocounsel.

09/20/13 R. Caughey Preparing memorandum summarizing meeting and circulating to team. Making arrangements to visit Foster Farms and conferring with client and team re same. Reviewing Foster Farms materials and contract materials. Conferring with J. Corsiglia‐Keim re issues.

2.50 $937.50

09/20/13 R. Hess Traveling from Columbus. Conferring in office with J. Southwick re Foster Farms and Bob Evans Farm. Reviewing meeting summary. Preparing for conference with Foster Farms.

7.40 $3,515.00

09/23/13 R. Caughey Reviewing memorandum re statutes of limitations in contracts. Conferring with trial team re statutes of limitations. Arranging travel to California to meet with Foster Farms.

1.80 $675.00

09/23/13 R. Hess Reviewing memorandum from co‐counsel and task list.

0.50 $237.50

09/23/13 J. Southwick Reviewing memo and case law concerning contractually shortening the statute of limitations for an antitrust claim. Reviewing emails re statute of limitations memo.

1.50 $937.50

09/24/13 J. Southwick Participating in weekly trial team call. Reviewing order transferring Michigan case to New York. Reviewing and responding to emails re transfer order.

2.80 $1,750.00

09/24/13 R. Caughey Participating in weekly trial team call. Conferring with J. Southwick re research and strategy. Conferring with team re document collection. Preparing memorandum re motions to dismiss and preparing legal research re same.

3.50 $1,312.50

09/24/13 R. Caughey Preparing and revising memorandum re amendments to complaints and 12(b)(6) motions. Preparing legal research re same. Circulating memorandum to J. Southwick and R. Hess for review. Reviewing expert

3.50 $1,312.50




Tax I.D.# 74‐2138615

materials and related correspondence. Reviewing Foster Farms materials in advance of meeting. Preparing agenda for Foster Farms meeting and circulating to trial team and client. Reviewing document retention notices and related documents for Foster Farms. Reviewing Motion to Dismiss to assess continued relevancy in light of transfer of case. Preparing memorandum to team re same. Coordinating travel to Livingston, CA and conferring with R. Hess re same.

09/24/13 R. Hess Reviewing correspondence from trial team and client. Reviewing order transferring case to Southern District of New York. Conferring with trial team. Conferring by phone with trial team.

0.70 $332.50

09/25/13 J. Southwick Conferring by phone with J. Mackie‐Mason and cocounsel re potential work as expert witness. Preparing email to cocounsel re call with J. Mackie‐Mason. Conferring with R. Caughey re research effect of transfer order on pending motion to dismiss in SDNY and ability of NAM to move to dismiss pursuant to Rule 12 amended complaint. Conferring with J. Presant re motion to dismiss in SDNY. Conferring with D. Goldman re motion to dismiss SDNY.

3.00 $1,875.00

09/25/13 R. Hess Reviewing correspondence from trial team re potential experts. Preparing for conference with Foster Farms. Preparing for conference.

0.40 $190.00

09/26/13 R. Caughey Meeting with R. Boyce, J. Corsiglia‐Keim, other Foster Farms personnel, and R. Hess in Livingston, CA. Reviewing Foster Farms contracts and materials in connection with, and in preparation for, meeting with Foster Farms. Preparing summary of Foster Farms meeting for trial team. Conferring with team re issues. Conferring with R. Hess re strategy and issues. Traveling from Houston, TX to Livingston, CA, and then traveling from

12.50 $4,687.50




Tax I.D.# 74‐2138615

Livingston, CA to San Francisco, CA

09/26/13 R. Hess Conferring in office with client at Foster Farms. Traveling from Livingston, California. Traveling to San Francisco, CA for Foster Farms meeting. Reviewing statute of limitations memo.

5.70 $2,707.50

09/27/13 J. Southwick Reviewing emails re meeting with Foster Farms. Reviewing research from R. Caughey re Rule 12 motions.

1.00 $625.00

09/27/13 R. Caughey Preparing summary of meeting with Foster Farms. Reviewing Foster Farms materials. Preparing 12(b)(6) memorandum. Conferring with team re issues. Traveling from San Francisco, CA to Houston, TX.

8.20 $3,075.00

09/27/13 R. Hess Traveling from Livingston, California. 5.50 $2,612.50

09/28/13 R. Caughey Revising summary of meeting with Foster Farms and circulating to trial team for review. Conferring with team re issues.

0.50 $187.50

09/29/13 R. Caughey Preparing formal memo to team re Rule 12(b)(6) waiver issue. Preparing legal research re same. Reviewing materials and addressing discovery issues.

3.60 $1,350.00

09/30/13 R. Caughey Conferring with J. Southwick and R. Hess re opposition to motion to dismiss, privilege issues, and strategy. Reviewing pleadings in transferred case. Conferring with Foster Farms. Reviewing memoranda.

1.90 $712.50

09/30/13 J. Southwick Conferring with R. Hess re visit to Foster Farms. Reviewing NAM brief in opposition to motion to dismiss declaratory judgment action. Researching Berry Law v. Kraft case referenced in NAM brief.

2.00 $1,250.00

10/01/13 R. Caughey Participating in weekly trial team call. Reviewing correspondence and memoranda. Preparing revisions to proposed joint case management statement. Conferring with J. Southwick and R. Hess re strategy. Preparing summary of call to J. Southwick.

1.20 $450.00

10/01/13 R. Caughey Reviewing correspondence and preparing analysis for team. Reviewing joint case management statement. Conferring with

2.50 $937.50




Tax I.D.# 74‐2138615

team re upcoming meetings. Reviewing reply in support of motion to dismiss.

10/01/13 J. Southwick Conferring by email re arranging a meeting with News counsel to discuss schedule. Attending weekly call with cocounsel.

1.10 $687.50

10/02/13 J. Southwick Conferring by phone with J. Presant multiple times.

0.20 $125.00

10/03/13 R. Caughey Reviewing and commenting on reply in support of motion to dismiss. Conferring with team re upcoming meeting with Valassis. Reviewing Mackie‐Mason issues.

1.30 $487.50

10/03/13 J. Southwick Reviewing draft reply in support of motion to dismiss. Reviewing and responding to trial team emails.

1.00 $625.00

10/04/13 R. Hess Reviewing correspondence from trial team and opposing counsel.

0.10 $47.50

10/04/13 R. Caughey Conferring with R. Hess re Southern District of New York admission and appearance. Conferring with Foster Farms re document collection and production. Reviewing pleadings and filings. Conferring with cocounsel re document vendors and related issues.

1.10 $412.50

10/04/13 J. Southwick Reviewing and responding to emails with trial team re various subjects including meeting with Valassis counsel, expert retainer agreements, and client document collection.

1.10 $687.50

10/07/13 R. Caughey Reviewing Valassis transcripts. Reviewing Reply brief. Reviewing correspondence. Conferring with J. Corsiglia‐Keim re teleconference and documents. Conferring with J. Stanley re review and processing of Foster Farms documents. Reviewing Foster Farms documents.

1.10 $412.50

10/08/13 R. Caughey Participating in weekly trial team call and conferring with J. Southwick and R. Hess re same. Sending summary to J. Southwick. Addressing issues with Foster Farms discovery. Conferring with J. Present et al re discovery, document hosting, and Valassis

2.90 $1,087.50




Tax I.D.# 74‐2138615

transcripts. Conferring with J. Corsiglia‐Keim re document and interrogatory discovery issues. Preparing memorandum summarizing call with J. Corsiglia‐Keim and circulating to Foster Farms and internal team. Arranging travel to Washington, DC for Valassis meeting. Conferring with team re same.

10/09/13 R. Caughey Reviewing Valassis transcripts and Foster Farms documents. Traveling from Houston, TX to Washington, DC for Valassis meeting. Reviewing and preparing correspondence. Conferring with R. Hess re meetings with Valassis and strategy. Preparing for meeting with Valassis.

5.50 $2,062.50

10/10/13 J. Southwick Reviewing and responding to emails re meeting with Valassis counsel and letter from J. O'Brien re meeting and conferring over various issues in advance of 10/24 hearing.

0.40 $250.00

10/10/13 R. Caughey Attending meeting with Valassis counsel. Conferring with trial team re same. Conferring with J. Southwick and R. Hess re Valassis meeting. Preparing for Valassis meeting. Reviewing correspondence from opposing counsel and preparing correspondence re same. Traveling from Washington, DC to Houston, TX.

6.70 $2,512.50

10/11/13 R. Caughey Conferring with J. Southwick re Valassis meeting and strategy. Conferring with trial team re issues.

0.50 $187.50

10/13/13 R. Caughey Preparing summary of meeting with Valassis. 0.40 $150.00

10/13/13 R. Caughey Preparing summary of meeting with Valassis and circulating to trial team. Conferring with J. Presant re meeting with Valassis. Reviewing correspondence from opposing counsel. Addressing discovery issues. Addressing issues with prior R. Emmel depositions.

1.50 $562.50

10/14/13 J. Southwick Reviewing emails from R. Caughey re meeting with Valassis counsel.

0.50 $312.50




Tax I.D.# 74‐2138615

10/15/13 R. Caughey Participating in weekly trial team conference call. Reviewing Foster Farms documents and preparing for production. Reviewing correspondence from trial team.

0.80 $300.00

10/15/13 J. Southwick Participating in weekly trial team call. 0.50 $312.50

10/17/13 R. Caughey Reviewing and preparing correspondence re subpoena and scheduling. Conferring with J. Presant re discovery issues.

0.50 $187.50

10/18/13 R. Caughey Preparing and reviewing correspondence re discovery and case management.

0.30 $112.50

10/21/13 J. Southwick Reviewing draft schedule with R. Caughey. Reviewing letter to court from opposing counsel re staying declaratory judgment action. Conferring by emails with R. Hess re requests for production and interrogatories.

1.70 $1,062.50

10/21/13 R. Caughey Conferring repeatedly with J. Southwick and J. Presant re discovery schedule and pretrial statement. Preparing memoranda to trial team re same. Reviewing interrogatories and requests for production. Reviewing correspondence re upcoming status conference. Conferring with Foster Farms re document production and collection status. Conferring with W. Conyngham and J. Presant re production of Foster Farms documents. Reviewing Foster Farms documents in advance of production.

2.50 $937.50

10/21/13 J. Stanley Preparing fees tracking chart. 1.00 $250.00

10/22/13 J. Southwick Reviewing emails re proposed case schedule. 0.50 $312.50

10/22/13 R. Hess Reviewing and revising draft interrogatories. Conferring with trial team re same. Reviewing and revising draft requests for production. Conferring with trial team re same. Conferring with R. Caughey re edits to Third Amended Complaint.

2.20 $1,045.00

10/22/13 J. Stanley Updating fees chart. 0.40 $100.00

10/22/13 R. Caughey Participating in management committee call. Conferring with W. Conyngham and J. Presant re production of Foster Farms documents. Producing Foster Farms documents. Conferring with J. Corsiglia‐

3.30 $1,237.50




Tax I.D.# 74‐2138615

Keim re Foster Farms collection status. Reviewing case management statement in light of pilot project. Preparing Southern District of New York admissions information. Conferring with team and J. Southwick re filing of case management statement. Preparing memorandum to team re conference with J. Corsiglia‐Keim. Preparing memorandum to team re revisions to joint case management statement. Conferring with J. Stanley re document production issues, databases, and vendors.

10/23/13 R. Hess Reviewing correspondence from S. Berry and K. Gallo. Reviewing draft schedule.

0.60 $285.00

10/23/13 J. Southwick Reviewing time in case from cocounsel. Working with J. Stanley to create spreadsheet to track time in case for all plaintiffs firms.

0.50 $312.50

10/23/13 R. Caughey Reviewing and preparing correspondence. 0.30 $112.50

10/24/13 J. Southwick Traveling to New York and attending hearing with J. Pauley re scheduling.

6.50 $4,062.50

10/24/13 R. Caughey Reviewing correspondence. 0.20 $75.00

10/25/13 J. Southwick Traveling to Houston. 4.50 $2,812.50

10/25/13 R. Hess Reviewing correspondence from trial team re hearing.

0.20 $95.00

10/25/13 R. Caughey Conferring with J. Southwick and R. Hess re hearing and upcoming discovery tasks.

0.20 $75.00

10/28/13 R. Caughey Reviewing and commenting on interrogatories. Researching Southern District of New York local rules re interrogatories.

0.40 $150.00

10/29/13 R. Caughey Participating in weekly conference call. Conferring with Bob Evans re documents, discovery, and teleconference. Conferring with R. Hess and J. Southwick re same. Preparing subpoena to Insignia Systems. Reviewing subpoenas and FOIA requests. Reviewing third amended complaint. Addressing pro hac vice application. Conferring with R. Hess re R. Emmel and Floorgraphics.

1.90 $712.50




Tax I.D.# 74‐2138615

10/29/13 J. Southwick Attending weekly trial team call. Reviewing and responding to email.

1.10 $687.50

10/30/13 R. Hess Conferring with trial team re R. Emmel. Conferring by phone with P. Hilder.

0.20 $95.00

10/30/13 R. Caughey Participating in call with Valassis counsel. Conferring with J. Presant re same. Preparing memorandum re Valassis call to J. Southwick and R. Hess. Conferring with Bob Evans re discovery.

0.90 $337.50

11/03/13 R. Caughey Addressing Bob Evans discovery issues and preparing correspondence re same. Conferring with team re morning court hearing.

1.10 $412.50

11/04/13 R. Caughey Participating in telephone hearing with Judge Pauley. Reviewing scheduling order and sending comments to team. Conferring with J. Southwick re scheduling order and strategy. Reviewing correspondence with opposing counsel. Participating in teleconference with P. Farris. Reviewing and commenting on discovery correspondence. Preparing subpoenas for Insignia, Floorgraphics, and Theme Promotions, preparing research re same, and circulating to team for review. Reviewing draft discovery letter and conferring with team re responses and interrogatory issues.

3.50 $1,312.50

11/04/13 J. Southwick Conferring by phone with J. Pauley re schedule. Conferring by phone with Applecon re expert work. Reviewing and responding to email from trial team.

2.20 $1,375.00

11/05/13 R. Hess Conferring by phone with G. Rebh. 1.00 $475.00

11/05/13 R. Caughey Participating in weekly teleconference. Conferring with team re schedule. Revising subpoenas and conferring with J. Southwick and R. Hess re service of subpoenas. Addressing discovery issues with team. Participating in call with Valassis counsel. Addressing issues with Insignia counsel.

1.50 $562.50

11/05/13 J. Stanley Researching subpoena service information. 1.00 $250.00

11/06/13 J. Southwick Reviewing and responding to emails from 0.70 $437.50




Tax I.D.# 74‐2138615

trial team.

11/06/13 R. Caughey Participating in call with Valassis counsel. Conferring with J. Southwick re strategy. Conferring with S. Berry re Valassis call. Reviewing discovery correspondence and commenting to team. Conferring with Foster Farms re document collection.

1.50 $562.50

11/07/13 R. Caughey Conferring with team re Valassis and third party subpoenas. Conferring with Foster Farms re discovery. Conferring with Bob Evans. Participating in conference call with L. LeClair re class certification briefing.

1.00 $375.00

11/07/13 J. Southwick Conferring by phone with L. LeClair and R. Caughey re class certification.

0.50 $312.50

11/08/13 R. Hess Reviewing correspondence from trial team and third parties.

0.10 $47.50

11/08/13 R. Caughey Conferring with team re experts. Conferring with S. Berry re third‐party subpoenas. Conferring with L. Krompass re class certification briefing. Reviewing and commenting on protective order.

1.50 $562.50

11/11/13 R. Caughey Conferring with R. Hess re third‐party subpoenas. Conferring with team re same.

0.40 $150.00

11/11/13 J. Southwick Reviewing Valassis complaint against News Corp. Reviewing and responding to emails.

1.60 $1,000.00

11/12/13 J. Southwick Participating in weekly trial team call. Conferring with R. Caughey and reviewing and responding to emails.

1.70 $1,062.50

11/12/13 J. Stanley Reviewing pleadings in related case prior to sending to entire trial team for confidentiality.

1.60 $400.00

11/12/13 R. Caughey Participating in weekly conference call. Conferring with opposing counsel re Foster Farms discovery. Conferring with J. Southwick and R. Hess re discovery. Conferring with Insignia counsel re subpoena and documents. Conferring with team re subpoenas. Revising subpoenas to third parties. Conferring with Bob Evans. Collecting prior class certification briefing. Participating in conference call with Valassis

3.40 $1,275.00




Tax I.D.# 74‐2138615

counsel. Circulating sample briefing to L. LeClair. Conferring with team re Valassis communications.

11/13/13 J. Southwick Reviewing and responding to emails re common interest privilege and discovery and experts.

1.90 $1,187.50

11/13/13 R. Caughey Addressing third‐party subpoena issues. Preparing legal research on common interest privilege and preparing memorandum to team re same. Conferring with J. Southwick re strategy and issues. Participating in call with team re common interest privilege and Valassis documents.

2.70 $1,012.50

11/14/13 R. Hess Reviewing common interest research and emails. Reviewing correspondence and legal research re common interest privilege. Conferring with R. Caughey via email re email to Insignia counsel. Reviewing summary of Farris‐Heinz interview.

1.30 $617.50

11/14/13 R. Caughey Compiling all communications with Valassis. Conferring with Insignia counsel re third‐party discovery and subpoena. Conferring with team re same. Preparing memoranda re common interest doctrine. Conferring by telephone with J. O'Brien et al re Foster Farms discovery. Preparing memorandum re Foster Farms discovery. Addressing common interest doctrine issues and preparing research re same.

1.50 $562.50

11/14/13 J. Southwick Reviewing and responding to emails re common interest doctrine and related privilege. Reviewing and responding to emails re progress of expert work.

1.00 $625.00

11/15/13 R. Caughey Preparing research re common interest doctrine. Conferring with counsel for Theme Promotions. Conferring with team re common interest privilege and discovery.

0.90 $337.50

11/16/13 R. Caughey Conferring with Insignia counsel re third‐party discovery. Conferring with J. Presant re discovery.

0.30 $112.50

11/17/13 R. Caughey Preparing memo to team re third‐party 0.40 $150.00




Tax I.D.# 74‐2138615

discovery. Addressing common interest doctrine.

11/18/13 R. Caughey Conferring with M. McBride re Insignia discovery and subpoena. Conferring with team re third‐party discovery. Conferring with Bob Evans re discovery, disclosures, and teleconference with experts. Conferring with experts re Bob Evans teleconference. Conferring with team re documents. Conferring with T. Herhold re Theme Promotions subpoena. Conferring with lawyers from Insignia. Conferring with Floorgraphics lawyers re third‐party discovery. Preparing research re common interest doctrine. Preparing memorandum to team re third‐party discovery.

1.90 $712.50

11/19/13 R. Hess Conferring by phone with trial team. Conferring with J. Southwick via email re protective order issue.

1.20 $570.00

11/19/13 R. Caughey Participating in weekly conference call. Conferring with team re in‐person meet and confer with Paul Weiss. Conferring with counsel for Insignia re third‐party discovery. Conferring with J. Presant re common interest doctrine and preparing legal research re same. Preparing memorandum re Insignia discovery and circulating to team. Preparing legal research re common interest doctrine and circulating to team. Preparing non‐NY research re common interest doctrine and analyzing same.

3.50 $1,312.50

11/20/13 R. Caughey Conferring with S. Benz and J. Presant re Insignia discovery. Conferring with team re same. Conferring with J. Ansel re Insignia discovery. Reviewing and responding to correspondence. Preparing research re common interest doctrine. Conferring with opposing counsel re upcoming meet and confer in Washington, DC. Conferring with J. Roberts re Bob Evans discovery and preparing discovery responses. Conferring with team re common interest doctrine.

3.00 $1,125.00




Tax I.D.# 74‐2138615

Conferring with J. Southwick re status of case.

11/21/13 R. Hess Reviewing communications with third party subpoena targets. Conferring with trial team re same.

0.40 $190.00

11/21/13 R. Caughey Preparing memorandum re common interest doctrine and circulating to team. Preparing legal research re same. Conferring with K. Hartman at Dilworth re Floorgraphics discovery. Preparing memorandum to R. Hess and J. Southwick re same. Conferring with R. Hess and J. Southwick re discovery, Floorgraphics, etc. Conferring with team re custodians. Conferring with clients re custodians. Preparing joint initial disclosures for all clients.

4.80 $1,800.00

11/22/13 R. Caughey Researching issue of how to obtain third‐party discovery of News' documents in light of protective orders and discovery rules. Conferring with J. Presant re same. Conferring with opposing counsel re custodians, search terms, and document discovery. Conferring with team re same. Conferring with team re initial disclosures. Preparing joint initial disclosures and revising disclosures. Circulating disclosures to team. Preparing research re disclosures. Conferring with Bob Evans re disclosures. Circulating common interest research to clients.

5.40 $2,025.00

11/22/13 J. Southwick Reviewing research and cases re common interest privilege.

1.60 $1,000.00

11/24/13 R. Caughey Conferring with team re initial disclosures. Reviewing and revising initial disclosures, and circulating to team for review. Preparing legal research re third‐party subpoenas. Conferring with team re in‐person meet and confer.

2.90 $1,087.50

11/25/13 J. Stanley Preparing case notebook for J. Southwick. 1.00 $250.00

11/25/13 R. Caughey Revising, finalizing, and serving initial disclosures. Conferring repeatedly with

5.20 $1,950.00




Tax I.D.# 74‐2138615

team re revisions of initial disclosures. Conferring with client re same. Addressing subpoena issues with team. Conferring with J. Southwick re strategy. Conferring with team re meetings in Washington, DC. Researching Rule 45 subpoena issues. Revising common interest agreement in light of legal research.

11/25/13 J. Southwick Reviewing draft of clients' initial disclosures. Conferring with R. Caughey re initial disclosures and various discovery issues. Drafting and responding to emails re initial disclosures.

2.70 $1,687.50

11/26/13 R. Caughey Researching subpoena issues. Participating in weekly call. Conferring with opposing counsel re meeting. Reviewing answer on behalf of Foster Farms. Revising common interest agreement and circulating to team. Participating in teleconference with P. Farris et al. and Bob Evans employees.

2.70 $1,012.50

11/26/13 J. Southwick Participating in weekly trial team call. Reviewing and responding to emails re discovery and expert issues.

1.80 $1,125.00

11/26/13 R. Hess Conferring by phone with M. Garber. Conferring by phone with trial team. Preparing summary of Garber call.

0.60 $285.00

12/01/13 R. Caughey Conferring with team re meetings in Washington, DC. Conferring with class representatives.

0.50 $187.50

12/02/13 J. Stanley Updating time and expense chart with all firms information.

1.00 $250.00

12/02/13 R. Hess Reviewing and revising draft answer. 0.50 $237.50

12/02/13 R. Caughey Conferring with Foster Farms re issues. Conferring with Bob Evans re discovery.

0.50 $187.50

12/02/13 J. Southwick Attending discussion with R. Caughey re discovery issues and preparation for meeting in Washington with cocounsel and experts. Reviewing draft of proposed answer to counterclaims.

3.40 $2,125.00

12/03/13 R. Caughey Attending team meeting with experts and management committee. Conferring with J.

8.10 $3,037.50




Tax I.D.# 74‐2138615

Southwick re tasks and schedule. Reviewing proposed answer. Conferring with S. Musalem re discovery. Conferring with Foster Farms and Bob Evans re issues. Conferring with J. Ansel of Winthrop re Insignia subpoena. Traveling from Houston, Texas to Washington, DC.

12/03/13 J. Southwick Traveling to Washington DC. 3.00 $1,875.00

12/03/13 J. Southwick Meeting with cocounsel and experts at Kellogg Huber Offices.

4.00 $2,500.00

12/03/13 R. Hess Revising answer. Conferring with S. Musallem.

0.50 $237.50

12/04/13 R. Caughey Conferring with team re discovery and expert materials. Conferring with T. Herhold re Theme Promotions discovery. Conferring with J. Ansel re Insignia discovery. Conferring with Foster Farms re custodians. Reviewing and commenting on News' discovery responses.

5.10 $1,912.50

12/04/13 J. Southwick Traveling to Houston. Reviewing impact of dismissing FSI claims from case.

5.50 $3,437.50

12/05/13 R. Caughey Conferring with opposing counsel re discovery. Conferring with clients re custodians. Participating in call with associates re search terms, custodians, and discovery strategy.

1.10 $412.50

12/05/13 J. Southwick Preparing for and attending weekly call with cocounsel. Reviewing and responding to emails re whether to retain FSI class and class definitions.

2.00 $1,250.00

12/06/13 R. Caughey Participating in discovery call with team. Conferring with third parties re subpoenas. Conferring with clients re custodians.

2.00 $750.00

12/06/13 J. Southwick Preparing for and attending call with cocounsel to prepare for meet and confer with News counsel over discovery scope issues.

1.00 $625.00


2.00 $500.00

12/08/13 R. Caughey Preparing agenda for upcoming discovery 1.00 $375.00




Tax I.D.# 74‐2138615

meeting. Arranging travel. Conferring with clients re documents and discovery.

12/09/13 J. Southwick Reviewing and responding to emails re discovery and upcoming meet and confer with News counsel.

1.60 $1,000.00

12/09/13 R. Caughey Preparing itinerary for in‐person meet and confer. Conferring with team re same. Addressing discovery issues with Foster Farms and Bob Evans. Conferring with team re discovery issues. Conferring with Insignia re third‐party discovery. Reviewing Insignia protective order.

3.10 $1,162.50

12/10/13 R. Hess Reviewing and revising search terms. Conferring with trial team re same. Conferring in office with J. Southwick re case update and damages case. Reviewing memorandum from trial team, emails from experts, and discovery correspondence.

1.70 $807.50

12/10/13 J. Southwick Reviewing emails and discussion with R. Caughey re discovery issues and third party subpoenas. Revising spreadsheet of ISP‐only economics.

2.20 $1,375.00

12/10/13 R. Caughey Participating in in‐person meet and confer with Paul Weiss. Meeting with trial team in advance of meet and confer. Preparing memorandum re meet and confer. Addressing discovery issues with team. Conferring with Foster Farms and Bob Evans re discovery, custodians, and documents. Preparing research re protective orders. Traveling from Houston, TX to Washington, DC.

9.50 $3,562.50

12/11/13 R. Hess Conferring in office with J. Southwick. Conferring by phone with trial team.

1.00 $475.00

12/11/13 J. Southwick Preparing for and participating in weekly trial team call. Reviewing emails re discovery issues.

2.00 $1,250.00

12/11/13 J. Stanley Conferring with R. Caughey re document collections.

0.50 $125.00

12/11/13 R. Caughey Researching protective order issues. Conferring with team re meet and confer.

6.50 $2,437.50




Tax I.D.# 74‐2138615

Traveling from Washington, DC to Houston, TX.

12/12/13 J. Stanley Updating time and expense chart. 1.00 $250.00

12/12/13 R. Caughey Participating in call with Bob Evans and addressing related discovery issues.

0.80 $300.00

12/13/13 J. Stanley Preparing Bob Evans documents for production. Updating monthly time and expense spreadsheet.

2.50 $625.00

12/13/13 R. Caughey Conferring with J. Stanley re document collection and production. Finalizing interrogatory response materials. Preparing Bob Evans documents for production. Conferring with Foster Farms re organizational charts. Preparing memorandum re meet and confer and circulating to team.

1.80 $675.00

12/16/13 J. Southwick Reviewing and responding to emails re discovery issues.

0.70 $437.50

12/16/13 R. Caughey Finalizing interrogatory responses and circulating to team. Conferring with clients re document collection and custodians.

0.80 $300.00

12/17/13 R. Hess Reviewing interview summaries. Conferring by phone with trial team.

1.10 $522.50

12/17/13 J. Southwick Participating in weekly trial team call. Reviewing emails re discovery issues.

1.00 $625.00

12/17/13 R. Caughey Conferring with J. Briody re Insignia and other protective order issues. Conferring with clients re discovery calls and document collection.

1.00 $375.00

12/18/13 J. Stanley Updating time and expense chart. 0.40 $100.00

12/18/13 J. Southwick Conferring by phone with D. Goldman re R. Emmel and FSI issues. Reviewing and responding to emails re discovery issues.

1.10 $687.50

12/18/13 R. Caughey Conferring with Bob Evans and Foster Farms re discovery and document collection. Addressing written discovery and document discovery issues. Preparing legal research re use of depositions.

1.80 $675.00

12/19/13 J. Stanley Updating time and expense chart. Conferring with vendor and clients re document

3.00 $750.00




Tax I.D.# 74‐2138615

collections.

12/20/13 R. Caughey Reviewing and commenting on draft supplemental protective order. Preparing subpoenas and letters. Conferring with team re custodial descriptions.

2.10 $787.50

12/20/13 R. Hess Reviewing motion to dismiss Valassis complaint. Conferring with trial team re same. Reviewing legal research re depositions.

0.60 $285.00

12/21/13 R. Caughey Conferring with J. Ansel re Insignia discovery. Conferring with team re same.

0.70 $262.50

12/23/13 R. Caughey Conferring with J. Ansel re Insignia discovery. Preparing Theme subpoena for service and conferring with J. Stanley re same. Conferring with Bob Evans and Foster Farms re custodians and descriptions. Preparing custodian descriptions for Bob Evans and Foster Farms.

2.20 $825.00

12/24/13 R. Caughey Participating in conference calls re discovery. 1.50 $562.50

12/24/13 R. Caughey Participating in conference calls re discovery. 1.50 $562.50

12/26/13 J. Stanley Processing documents for production. 2.00 $500.00

12/26/13 R. Caughey Addressing document production issues with Foster Farms and Bob Evans. Conferring with team re same. Conferring with Foster Farms re custodian interviews and document collection. Conferring with J. Stanley re subpoenas. Finalizing subpoenas and addressing issues with third‐party discovery. Reviewing and revising letter to News.

3.20 $1,200.00

12/27/13 J. Stanley Preparing subpoenas. 1.00 $250.00

12/27/13 J. Southwick Reviewing and responding to emails among trial team re ongoing discovery issues.

1.00 $625.00

12/27/13 R. Caughey Addressing third‐party discovery issues with Insignia and Theme Promotions. Reviewing discovery correspondence.

1.10 $412.50

12/29/13 R. Caughey Preparing custodian descriptions for Bob Evans and Foster Farms. Finalizing subpoenas and circulating to team. Addressing issues with custodian interviews

2.10 $787.50




Tax I.D.# 74‐2138615

and collection. Reviewing protective orders and preparing legal research in connection with third‐party discovery. Conferring with team.

12/30/13 J. Stanley Processing documents for production. 2.00 $500.00

12/30/13 R. Caughey Finalizing subpoenas. Drafting correspondence to transmit with subpoenas. Conferring with team re revisions to subpoenas. Conferring with R. Hess re subpoenas. Conferring with third‐party counsel, J. Ansel and T. Herhold re subpoenas. Addressing issues relating to protective orders in prior cases. Conferring with J. Presant re custodian descriptions. Preparing Bob Evans documents for production. Reviewing correspondence re discovery. Conferring with team re Floorgraphics and related third‐party discovery issues.

5.10 $1,912.50

12/31/13 R. Caughey Conferring with Foster Farms and Bob Evans re discovery and custodians. Reviewing and responding to correspondence. Reviewing Bob Evans documents. Addressing third‐party discovery issues.

3.90 $1,462.50

01/01/14 R. Caughey Addressing discovery issues and conferring with J. Stanley re same. Reviewing organizational charts. Reviewing documents.

1.20 $510.00

01/02/14 J. Stanley Preparing Foster Farms and Bob Evans documents for production.

1.40 $378.00

01/02/14 R. Caughey Conferring with clients re document collection and organizational charts. Conferring with custodians re interviews. Preparing pro hac vice forms. Addressing issues relating to Floorgraphics subpoena and related matters.

1.50 $637.50

01/03/14 R. Caughey Conferring with clients re document production and discovery. Addressing issues with custodians.

0.50 $212.50

01/04/14 R. Caughey Conferring with team re collection of documents and issues with discovery.

0.50 $212.50

01/06/14 J. Southwick Reviewing and responding to emails re 0.90 $607.50




Tax I.D.# 74‐2138615

document collection and discovery.

01/06/14 R. Caughey Conferring with clients re production schedule. Reviewing correspondence from opposing counsel. Conferring with J. Briody re discovery and discovery calls.

1.10 $467.50

01/07/14 J. Southwick Reviewing correspondence re discovery issues. Participating in weekly trial team call with cocounsel.

2.30 $1,552.50

01/07/14 R. Caughey Conferring with J. Briody re discovery and document collection. Conferring with clients re document collection, custodians, and scheduling. Participating in weekly team call. Conferring with Floorgraphics re subpoena and document collection. Participating in meet and confer with opposing counsel. Conferring with Floorgraphics re issues. Conferring with Floorgraphics counsel re subpoena. Reviewing factual data re ISP and FSI.

2.20 $935.00

01/08/14 J. Southwick Reviewing and responding to emails from cocounsel re discovery and defendant financial information.

0.60 $405.00

01/08/14 R. Caughey Conducting custodian interviews with Bob Evans employees, including J. Bush, T. Muir, T. Hill, and D. Brotherton. Preparing memorandum re custodian interviews. Conferring with team repeatedly re privilege and confidentiality review. Conferring with J. Stanley and document vendor re document collection and issues. Conferring with Bob Evans team re FSI and ISP. Reviewing correspondence re ISP and FSI figures.

2.50 $1,062.50

01/09/14 J. Southwick Attending lunch discussion with S. Benz and J. Presant.

0.50 $337.50

01/09/14 R. Caughey Conferring with J. Southwick and R. Hess re document review protocol. Conducting custodian interviews with Bob Evans custodians. Addressing confidentiality issues. Conferring with Foster Farms re discovery. Addressing issues relating to protective

3.30 $1,402.50




Tax I.D.# 74‐2138615

order.

01/10/14 J. Stanley Conferring with client and document vendor re document collection process. Preparing complete time keeper hourly rates list for J. Southwick.

1.40 $378.00

01/10/14 R. Caughey Participating in discovery and document collection call with Epiq as well as Bob Evans employees and managers. Conferring with J. Stanley re document collection. Conferring with Insignia counsel re subpoena and reviewing objection letter re same. Conferring with team re staff attorneys. Conferring with team re document review training logistics.

3.40 $1,445.00

01/11/14 R. Caughey Preparing memorandum to team re Insignia objections. Conferring with Insignia counsel re objections. Conferring with counsel for Theme Promotions re subpoena and documents. Addressing issues with custodian list.

1.20 $510.00

01/12/14 R. Caughey Conferring with D. Brotherton re document collection issues. Preparing memoranda to Bob Evans re document collection. Conferring with discovery team re search terms and custodians.

0.60 $255.00

01/13/14 J. Southwick Meeting with M. Downey, K. Horman and R. Caughey. Reviewing and responding to emails re discovery issues.

2.10 $1,417.50

01/13/14 R. Caughey Conferring with Bob Evans re logistics of January 21, 2014 document collection. Preparing list of access needs re same. Preparing draft response to opposing counsel re protective orders. Conferring with J. Ansel re Insignia production, subpoena, and objections. Meeting with reviewing staff attorneys and giving them summary of the case. Conferring with team re document review training and WebEx. Participating in conference call with Theo Muir.

3.80 $1,615.00

01/13/14 K. Hormann Conferring with R. Caughey and J. Southwick 1.50 $412.50




Tax I.D.# 74‐2138615

re document review project. Reviewing prepared memorandum re same.

01/13/14 M. Downey Meeting with trial team re project. Reviewing documents.

0.60 $165.00

01/14/14 J. Southwick Participating in weekly trial team call. Reviewing draft letter to Judge Pauley re discovery issues and related emails from cocounsel.

2.00 $1,350.00

01/14/14 R. Caughey Conferring with Bob Evans re documents and collection. Participating in weekly team call. Participating in doc review training session. Conferring with team re protective order issues. Conferring with team re interview of Chris Lambrix. Conferring with team re Foster Farms spending figures.

2.90 $1,232.50


01/14/14 K. Hormann Conferring via teleconference with trial team re document review project.

0.60 $165.00

01/14/14 M. Downey Participating in Web‐Ex. 1.00 $275.00

01/15/14 R. Caughey Addressing discovery issues relating to collections at Bob Evans and Foster Farms. Participating in teleconferences with Foster Farms IT personnel. Coordinating discovery with J. Stanley. Preparing research re sales conference of M. Garafolo. Conferring with M. Fisher re document review. Conferring with Bob Evans re custodian interviews. Addressing issues related to billing for third‐party vendor. Conferring with J. Ansel re protective order. Conferring with counsel for Theme Promotions. Conferring with associates re discovery issues.

2.20 $935.00

01/15/14 J. Stanley Reviewing database. Updating logs. Producing Theme third party documents.

2.40 $648.00

01/15/14 M. Fisher Reviewing documents for document production.

3.50 $962.50

01/15/14 K. Hormann Reviewing documents produced by NAM. 5.30 $1,457.50

01/15/14 M. Downey Reviewing emails and documents. 0.30 $82.50

01/16/14 R. Caughey Training staff attorneys to review documents. Addressing subpoena and

3.50 $1,487.50




Tax I.D.# 74‐2138615

protective orders with Insignia. Addressing third‐party discovery and subpoena issues with counsel for Floorgraphics. Reviewing hot documents. Conferring with team re discovery strategy. Setting up document collections in California and Ohio. Conferring with J. Stanley re same.


8.20 $2,255.00


01/16/14 M. Downey Reviewing emails and documents. 0.10 $27.50

01/16/14 J. Southwick Reviewing and responding to email re discovery issues.

1.20 $810.00

01/17/14 R. Caughey Conducting custodian interviews of Foster Farms custodians. Conducting custodian interviews of C. Lambrix and D. Brotherton of Bob Evans. Addressing third‐party discovery issues. Preparing letter and memorandum re custodian descriptions. Conferring with team re same.

2.00 $850.00

01/17/14 R. Hess Conferring with J. Southwick and R. Caughey via email re Insignia documents. Reviewing proposed changes to protective order and trial team correspondence re same.

0.40 $200.00


7.60 $2,090.00


01/17/14 M. Downey Reviewing emails and documents. 4.50 $1,237.50

01/18/14 R. Caughey Conferring with third parties re discovery. Conferring with team re third‐party discovery and preparing memoranda re same. Conferring with clients and Epiq re document collection.

1.20 $510.00

01/19/14 R. Caughey Conferring with clients and vendor re document collection.

0.40 $170.00

01/20/14 R. Caughey Preparing for BEF Foods document collection. Conferring with client and vendor re same. Participating in discovery call with team. Addressing third‐party subpoena issues with team. Conferring with R. Hess re

7.80 $3,315.00




Tax I.D.# 74‐2138615

NAM custodians. Conducting interviews of Foster Farms custodians. Addressing document review issues with review team. Traveling from Houston, TX to Columbus, OH for Bob Evans meeting.

01/20/14 K. Hormann Reviewing documents produced by NAM. 3.50 $962.50


01/21/14 R. Caughey Directing Bob Evans document collection in Columbus, OH. Conferring with team re third‐party discovery. Preparing correspondence to NAM re custodians and conferring with opposing counsel re same. Conferring with review team re issues relating to document review. Organizing Foster Farms document collection. Conducting Foster Farms custodian interviews.

7.50 $3,187.50


8.40 $2,310.00

01/22/14 K. Hormann Reviewing documents produced by NAM. Conferring with R. Caughey, M. Fisher and M. Downey re same.

8.50 $2,337.50

01/22/14 R. Hess Conferring with trial team re custodians and expert agenda.

0.50 $250.00

01/22/14 M. Downey Reviewing documents. 2.00 $550.00

01/22/14 J. Southwick Conferring with R. Caughey re document collection at Bob Evans and negotiation of subpoenaed materials with Insignia.

2.20 $1,485.00

01/22/14 R. Caughey Reviewing and revising motion for protective order. Conferring with J. Southwick re case strategy and Insignia subpoena. Reviewing protective orders and advising team re same. Meeting with document review team and preparing status memorandum to J. Southwick and R. Hess. Reviewing tagged documents. Preparing summary memorandum re Bob Evans document collection and circulating to team. Conferring with Bob Evans and Foster Farms employees re Valassis communications and doc review. Traveling from Columbus, OH to

7.50 $3,187.50




Tax I.D.# 74‐2138615

Houston, TX.


8.10 $2,227.50


01/23/14 J. Stanley Processing Bob Evans documents for production. Preparing notebook for J. Southwick.

2.00 $540.00

01/23/14 M. Downey Corresponding with trial team. 0.50 $137.50

01/23/14 J. Southwick Reviewing financial materials from News production. Participating in weekly team call. Reviewing and responding to email re document review and discovery. Reviewing materials and preparing notes re options for FSI class definition.

4.10 $2,767.50

01/23/14 R. Caughey Reviewing motion for protective order. Reviewing correspondence and memorandums re custodians and organizational charts. Conferring with team re same. Conferring with team re Insignia and Floorgraphics.

0.50 $212.50


01/24/14 M. Downey Corresponding with trial team. 0.30 $82.50

01/24/14 J. Southwick Reviewing memorandums and cases re class certification and potential revision of FSI class definition.

2.90 $1,957.50

01/24/14 R. Caughey Addressing Bob Evans document production. Participating in call with Foster Farms' personnel and document vendor.

0.30 $127.50

01/25/14 R. Caughey Preparing for Foster Farms document collection.

0.50 $212.50

01/25/14 R. Caughey Addressing discovery issues and preparing for Foster Farms document collection. Conferring with J. Southwick re class definition.

1.00 $425.00

01/27/14 J. Stanley Reviewing production for contracts. 2.00 $540.00

01/27/14 J. Southwick Reviewing memorandums and cases in preparation and call with cocounsel re FSI class and discovery. Reviewing and responding to emails re discovery with News and third parties.

3.60 $2,430.00




Tax I.D.# 74‐2138615

01/27/14 R. Hess Preparing custodians list based on prior litigation. Reviewing transcript of initial conference. Reviewing correspondence from opposing counsel. Reviewing transcript of initial conference with Judge Pauley. Preparing summary of meeting re custodians. Conferring with J. Southwick via email. Conferring by phone with trial team. Conferring in office with R. Caughey. Conferring by phone with trial team re potential custodians. Reviewing custodian list and meeting agendas.

4.50 $2,250.00


01/27/14 R. Caughey Participating in weekly trial team call. Preparing correspondence to J. Ansel and experts re Insignia. Participating in conversation re NAM custodians. Conferring with Floorgraphics. Participating in weekly discovery call. Reviewing contracts for clients. Preparing for document collection at Foster Farms.

4.10 $1,742.50


8.10 $2,227.50

01/28/14 J. Stanley Reviewing production for contracts. Updating fees and expense chart with all firms time.

3.00 $810.00


01/28/14 R. Caughey Preparing for Foster Farms document collection. Reviewing potential NAM custodians. Conferring with outside counsel for Floorgraphics. Preparing discovery related correspondence to team. Reviewing correspondence re FSI and ISP bundled contracts. Traveling from Houston, TX to Livingston, CA.

8.20 $3,485.00


5.20 $1,430.00

01/28/14 M. Downey Reviewing trial team emails. Reviewing documents.

0.20 $55.00

01/29/14 J. Stanley Preparing contracts for J. Southwick to review. Updating fee and expense

1.00 $270.00




Tax I.D.# 74‐2138615

spreadsheet.

01/29/14 J. Southwick Conferring by emails re FSI class definition and cocounsel rate discrepancies.

0.70 $472.50

01/29/14 R. Hess Conferring by phone with trial team re custodians.

0.80 $400.00


01/29/14 R. Caughey Supervising document collection at Foster Farms. Meeting with Foster Farms custodians, executives, and general counsel. Reviewing custodian lists and conferring with team re custodian issues. Conferring with team re Insignia document collection and discovery priorities. Preparing correspondence to Insignia re same. Conferring with group re document review.

4.80 $2,040.00


2.20 $605.00

01/29/14 M. Downey Reviewing documents. 4.70 $1,292.50


01/30/14 R. Caughey Supervising document collection at Foster Farms. Meeting with Foster Farms custodians. Conferring with team re various discovery issues. Traveling from San Francisco, CA to Houston, TX.

7.50 $3,187.50


1.30 $357.50

01/30/14 J. Southwick Reviewing and responding to emails with cocounsel re discovery and comparative hourly rates of counsel. Reviewing materials re FSI class.

1.90 $1,282.50


01/31/14 R. Caughey Reviewing retailer contracts. Reviewing correspondence from opposing counsel. Conferring with Foster Farms re document collection wrap‐up and follow‐up questions. Conferring with team re same.

2.50 $1,062.50


4.90 $1,347.50

02/02/14 J. Southwick Reviewing Foster Farms and Bob Evans contract files. Preparing email re contract

2.90 $1,957.50




Tax I.D.# 74‐2138615

files.


6.60 $1,815.00


02/03/14 R. Caughey Participating in discovery call with team. Analyzing contracts and conferring with J. Southwick and R. Hess re FSI, ISP, and class definition. Conferring with clients re document collection. Conferring with review team re status and meeting. Conferring with J. Ansel re subpoena. Revising Floographics subpoena and conferring with team re same. Preparing summary of client contracting for S. Musallem. Conferring with team re anecdotal evidence of overcharges.

3.80 $1,615.00

02/03/14 M. Downey Reviewing documents and emails from trial team.

0.50 $137.50

02/03/14 R. Hess Conferring in office with J. Southwick and R. Caughey re class certification issues.

0.70 $350.00

02/03/14 J. Southwick Reviewing emails summarizing contract clauses in client agreements with News America. Researching re class certification of FSI class. Conferring with R. Hess and R. Caughey re FSI class certification issues. Reviewing and responding to email re FSI class certification and definition issues.

5.90 $3,982.50


2.70 $742.50


02/04/14 R. Caughey Participating in weekly teleconference. Meeting with J. Southwick and R. Hess. Meeting with document reviewers re issues. Conferring with Insignia counsel re subpoena and document production. Preparing letter to J. O'Brien re discovery. Conferring with J. Presant, S. Musallem, and J. Smith re custodians and search terms. Revising letter to J. Ansel and circulating to team and J. Ansel.

3.20 $1,360.00

02/04/14 R. Hess Reviewing documents and preparing for conference with trial team and experts.

4.20 $2,100.00




Tax I.D.# 74‐2138615

Preparing summary of call. Reviewing contract analysis. Conferring by phone with trial team. Preparing for conference with trial team and experts.

02/04/14 J. Southwick Reviewing and responding to emails re contract analysis and class certification issues for the FSI class. Reviewing hot documents document review.

2.70 $1,822.50


4.20 $1,155.00


02/05/14 R. Caughey Preparing correspondence with J. O'Brien. Conferring with J. Southwick re experts. Reviewing correspondence re class definition. Meeting with review team. Addressing search term and custodian issues.

1.00 $425.00


02/05/14 R. Hess Traveling to expert meeting. Preparing same.

4.10 $2,050.00

02/05/14 J. Southwick Reviewing emails re common impact and predominance issues in the FSI class. Reviewing budget books and executive presentation to analysts.

2.60 $1,755.00


2.30 $632.50


02/06/14 R. Caughey Participating telephonically in expert witness meeting. Conferring with J. Southwick and R. Hess re same. Preparing and revising letter to opposing counsel re custodians and search terms. Conferring with J. Southwick re strategy.

5.70 $2,422.50

02/06/14 R. Hess Attending meeting of trial team and experts. Conferring with trial team re same. Reviewing deposition summary from prior case. Conferring with paralegals re same.

3.10 $1,550.00

02/06/14 J. Southwick Conferring on telephone conference with cocounsel and experts re class certification issues. Reviewing and responding to email

2.00 $1,350.00




Tax I.D.# 74‐2138615

re discovery and expert meeting.


1.10 $302.50

02/07/14 R. Caughey Meeting with team re document review, discovery, and strategy. Conferring with team re letter to opposing counsel and custodian and search term strategy. Revising letter to J. O'brien and sending to team.

2.60 $1,105.00

02/07/14 R. Hess Traveling from expert meeting. Reviewing emails and memos from cocounsel and expert re damages and class certification. Conferring in office with J. Southwick re next steps with potential FSI class. Preparing email to expert re analysis.

4.40 $2,200.00

02/07/14 J. Southwick Conferring with document review team. Reviewing and responding to emails. Reviewing memorandum from R. Pfau re prices and margins in FSI market.

1.70 $1,147.50

02/08/14 R. Caughey Revising correspondence to opposing counsel and transmitting letter. Conferring with team re same.

1.00 $425.00


3.60 $990.00

02/10/14 J. Stanley Updating fee and expense spreadsheet. 0.40 $108.00

02/11/14 J. Southwick Participating in trial team call re FSI class definition issues and discovery.

1.00 $675.00

02/11/14 R. Hess Conferring by phone with trial team re task list and FSI class decisions.

1.20 $600.00

02/11/14 R. Caughey Participating in weekly teleconference. Conferring with J. Ansel re discovery. Conferring with team re issues. Reviewing documents. Addressing issues with search terms and custodians.

2.20 $935.00

02/12/14 J. Southwick Reviewing emails re margin analysis. 1.00 $675.00


02/12/14 R. Hess Reviewing email between experts and trial team re NAM financials.

0.50 $250.00

02/12/14 R. Caughey Conferring with clients re interrogatories and verifications. Addressing third‐party discovery and custodians issues.

1.00 $425.00




Tax I.D.# 74‐2138615

02/13/14 J. Southwick Reviewing emails re discussions of margins with AppleCon on 2/14/14. Reviewing emails re state of production of documents. Conferring with R. Caughey re common impact analysis.

1.20 $810.00

02/13/14 K. Hormann Reviewing documents produced by NAM. Conferring via email with R. Caughey re same.

7.10 $1,952.50


2.30 $632.50

02/13/14 R. Caughey Preparing legal research and associated memorandum for J. Southwick re antitrust questions, especially re commonality and predominance. Conferring with J. Southwick re same. Conferring with third parties re discovery. Conferring with team re discovery. Conferring with team re hot docs.

4.10 $1,742.50



4.50 $1,237.50

02/14/14 R. Hess Conferring by phone with trial team and experts.

0.10 $50.00

02/14/14 R. Caughey Meeting with J. Southwick re antitrust legal research and discussing FSI class. Participating in conference call with experts. Addressing discovery issues.

2.20 $935.00

02/14/14 J. Southwick Conferring by emails with R. Caughey re failsafe classes. Preparing for and participating in call with expert and cocounsel re FSI pricing and costs.

2.20 $1,485.00

02/17/14 R. Hess Reviewing Valassis complaint and recent filings.

0.70 $350.00

02/17/14 J. Southwick Reviewing Valassis response to motion to dismiss in Valassis II case. Researching class certification issues. Reviewing and responding to emails re FSI class. Reviewing expert reports of Farris and Bamberger from Valassis I case.

6.80 $4,590.00

02/17/14 R. Caughey Conferring with J. Southwick re FSI pricing and Valassis motion to dismiss. Conferring

2.40 $1,020.00




Tax I.D.# 74‐2138615

with team re meet and confer and FGI subpoena. Conferring with J. Southwick re expert testimony. Participating in weekly discovery call. Addressing issues with FGI subpoena and Insignia subpoena. Preparing memorandum to team re subpoenas.



6.60 $1,815.00

02/18/14 J. Southwick Reviewing transcripts of Mackie‐Mason testimony in Valassis I trial. Attending weekly trial team call with cocounsel. Reviewing emails re discovery from News and third parties.

3.30 $2,227.50

02/18/14 R. Caughey Addressing issues with Insignia subpoena, document production and review, and related issues. Conferring with S. Musallem re issues. Conferring with FGI counsel re subpoena. Conferring with team re custodians, search terms, and correspondence to J. O'Brien.

2.70 $1,147.50



4.20 $1,155.00

02/18/14 R. Hess Preparing for conference with trial team. Reviewing motion to dismiss response.

1.00 $500.00

02/19/14 R. Caughey Participating in search term and custodian call with team. Conferring with team re same. Participating in call re document processing and production. Conferring with J. Stanley re same. Conferring with team re common interest agreement. Preparing letter to J. Ansel. Conferring with J. Stanley re Insignia SEC filings.

3.20 $1,360.00



4.50 $1,237.50

02/19/14 J. Stanley Conferring with document vendor. 0.80 $216.00

02/19/14 R. Hess Conferring by phone with trial team re custodians and search terms.

1.40 $700.00




Tax I.D.# 74‐2138615

02/20/14 J. Southwick Reviewing emails re expert work and analysis of FSI issues.

0.70 $472.50



8.30 $2,282.50

02/20/14 R. Caughey Preparing correspondence to opposing counsel re custodians, preparing revisions to same, conferring with team re same, and transmitting to opposing counsel. Conferring with team re discovery strategy. Preparing correspondence to third parties re discovery. Reviewing documents and conferring with review team. Reviewing Insignia SEC reports.

4.10 $1,742.50



4.10 $1,127.50

02/21/14 R. Caughey Preparing correspondence to opposing counsel and third parties. Participating in meet and confer with opposing counsel re search terms and custodians. Preparing memoranda to team re same. Preparing for call with opposing counsel. Preparing research re FSI issues. Addressing document review issues.

3.90 $1,657.50

02/21/14 R. Hess Conferring by phone with opposing counsel. Conferring in office with R. Caughey.

0.70 $350.00

02/21/14 J. Southwick Reviewing and responding to emails re progress of expert work and proposed changes to the case schedule. Reviewing emails re document management vendor costs.

1.10 $742.50

02/24/14 R. Caughey Participating in teleconference with document vendor. Conferring with document vendor re issues. Preparing memorandum to vendor re search terms and privilege. Conferring with team re same. Participating in call re discovery with discovery team.

2.00 $850.00

02/24/14 J. Stanley Conferring with document vendor. 0.60 $162.00




Tax I.D.# 74‐2138615

02/24/14 J. Southwick Reviewing case and expert materials. Preparing long email to co‐counsel regarding FSI class and case schedule.

2.20 $1,485.00


02/24/14 R. Hess Reviewing draft letter to third party counsel. Revising same. Reviewing email from trial team.

0.30 $150.00

02/25/14 J. Southwick Preparing for weekly call with co‐counsel and discussion of FSI class and case schedule.

1.00 $675.00


02/25/14 R. Caughey Revising letter to J. Ansel and transmitting to J. Ansel. Participating in management committee meeting and conferring with team re same. Conferring with team re J. Ansel order. Conferring with document vendor re timing and production.

2.90 $1,232.50


4.80 $1,320.00


02/26/14 R. Caughey Finalizing and sending letter to J. Ansel re Insignia discovery. Addressing third‐party discovery issues. Reviewing correspondence to opposing counsel re custodians and discovery disputes. Conferring with J. Briody and R. Hess re same.

1.50 $637.50


4.50 $1,237.50


02/27/14 R. Caughey Revising interrogatory responses on behalf of Foster Farms and BEF, and conferring with J. Smith and J. Briody re same. Conferring with clients re verifications to interrogatories. Reviewing factual basis of interrogatory responses. Conferring with J. Stanley and document vendor re document issues.

2.10 $892.50


5.30 $1,457.50

02/28/14 J. Stanley Updating and circulating master fees and 0.60 $162.00




Tax I.D.# 74‐2138615

expense chart.



5.30 $1,457.50

03/02/14 R. Caughey Conferring with vendor re document production.

0.20 $85.00



4.00 $1,100.00

03/03/14 R. Caughey Addressing production and review issues. Conferring with M. Wachlin of Dilworth re Floorgraphics subpoena. Participating in weekly discovery call and addressing Insignia matter. Conferring with J. Southwick re strategy. Conferring with document vendor re production timeline.

1.50 $637.50

03/03/14 J. Stanley Preparing documents for production. 1.00 $270.00

03/04/14 J. Southwick Reviewing memorandum from S. Berry re FSI class and researching points discussed therein.

1.70 $1,147.50

03/04/14 R. Hess Reviewing memorandum from S. Berry re FSI class.

0.40 $200.00



2.50 $687.50

03/04/14 R. Caughey Reviewing memoranda and materials re FSI class and strategy. Conferring with document vendor re collection issues. Addressing Insignia issues. Reviewing correspondence from Insignia. Conferring with team re discovery issues and reviewing letter to court re News discovery.

1.40 $595.00

03/05/14 J. Southwick Conferring with R. Caughey re FSI issues raised by S. Berry memorandum. Conferring by phone with D. Goldman re FSI memorandum. Conferring by phone with J. Leitzinger re FSI class issues. Reviewing and responding to emails. Reviewing letter filed with court re discovery.

2.70 $1,822.50





Tax I.D.# 74‐2138615


4.50 $1,237.50

03/05/14 R. Caughey Conferring with team re NDA agreement. Reviewing letter to court. Conferring with J. Southwick re Insignia issue, FSI issue, and related issues. Addressing issues with document vendor.

1.50 $637.50

03/06/14 J. Southwick Conferring with R. Hess re FSI memorandum from S. Berry. Reviewing and responding to emails with cocounsel re FSI issues. Conferring by phone with cocounsel re FSI class issues.

2.10 $1,417.50

03/06/14 R. Hess Conferring in office with J. Southwick re FSI class. Conferring in office with J. Southwick re FSI class.

1.40 $700.00



4.30 $1,182.50

03/06/14 R. Caughey Participating in call re FSI class and experts. Conferring with J. Southwick re same. Addressing document collection and production issues.

1.20 $510.00

03/07/14 R. Hess Conferring with trial team re potential experts. Reviewing email and responding to same.

0.60 $300.00



5.30 $1,457.50

03/07/14 R. Caughey Conferring with document vendor re discovery. Addressing issues with expert discovery.

0.80 $340.00

03/07/14 J. Southwick Reviewing and responding to emails regarding FSI class issues and class certification experts.

0.80 $540.00

03/10/14 R. Caughey Conferring with team re discovery conference. Reviewing discovery correspondence. Performing quality control of BEF and Foster Farms productions. Addressing third‐party discovery issues. Reviewing documents.

1.50 $637.50




Tax I.D.# 74‐2138615



6.60 $1,815.00

03/10/14 R. Hess Reviewing email and discovery correspondence. Conferring with trial team. Reviewing draft discovery requests. Reviewing previous case public documents re Carlucci discovery.

1.50 $750.00

03/11/14 J. Southwick Preparing and weekly call with trial team. Reviewing D. Zona vita and related materials. Conferring by phone with cocounsel and D. Zona. Conferring by phone with J. Goldberg re D. Zona. Emailing re D. Zona as potential expert. Reviewing and responding to emails re discovery.

2.80 $1,890.00

03/11/14 R. Caughey Participating in weekly trial team call. Conferring with team re Insignia. Addressing FSI issues. Reviewing documents for QC. Drafting correspondence to Insignia re document production and motion to compel. Addressing issues with Floorgraphics. Conferring with opposing counsel re third‐party documents. Conferring with J. Briody re issues. Preparing summary of third‐party discovery issues to team.

5.20 $2,210.00


2.50 $687.50

03/12/14 J. Southwick Reviewing and responding to emails concerning discovery issues.

0.60 $405.00

03/12/14 R. Caughey Addressing third‐party discovery issues. Reviewing document databases. Conferring with team re strategy.

1.10 $467.50


4.50 $1,237.50

03/12/14 R. Hess Reviewing and revising email and draft correspondence re discovery requests.

0.40 $200.00

03/13/14 R. Caughey Participating in call with experts re FSI. Participating in discovery call. Conferring with review team re documents and facts.

1.20 $510.00




Tax I.D.# 74‐2138615

03/13/14 K. Hormann Reviewing documents produced by Bob Evans Foods and Foster Farms. Conferring with R. Caughey re same.

2.50 $687.50


8.50 $2,337.50

03/13/14 R. Hess Conferring with J. Southwick re Potok discovery.

0.10 $50.00

03/13/14 M. Downey Reviewing documents. Corresponding with trial team.

2.50 $687.50

03/14/14 R. Caughey Conferring with clients re document requests and supplemental information. Conferring with team re same. Conferring with J. Southwick re status and issues. Preparing legal research. Preparing research re categories of documents and reviewing documents re same. Conferring with reviewers. Preparing spreadsheet of documents.

2.10 $892.50


7.20 $1,980.00

03/14/14 J. Southwick Discussing with R. Caughey re state of document discovery and review. Conferring by email re upcoming discovery hearing.

1.10 $742.50

03/15/14 R. Caughey Reviewing documents in light of discovery dispute with News over discrete categories of documents. Conferring with J. Briody re same.

1.80 $765.00

03/16/14 R. Caughey Conferring with team re discovery. Reviewing letters with the court and addressing discovery issues. Conferring with team re custodians.

0.30 $127.50

03/17/14 R. Caughey Participating in team discovery call. Reviewing correspondence with opposing counsel. Addressing document review issues. Conferring with J. Ansel re Insignia subpoena. Reviewing documents. Addressing issues with hearing. Conferring with J. Briody re discovery issues and client burden. Conferring with clients. Reviewing documents.

1.90 $807.50

03/17/14 M. Fisher Reviewing documents for document 8.90 $2,447.50




Tax I.D.# 74‐2138615

production.

03/17/14 J. Stanley Updating firm time and expenses chart. 0.40 $108.00



2.50 $687.50

03/18/14 R. Caughey Conferring with J. Briody re discovery strategy. Reviewing correspondence re class definition. Arranging travel to New York hearing. Conferring with team re issues. Conferring with J. Ansel re Insignia subpoena. Addressing custodian descriptions and related information. Participating in weekly management committee call. Preparing memorandum to team re Insignia update. Conferring with S. Musallem re legal research re confidentiality. Preparing and sending correspondence to Insignia counsel. Reviewing hot documents and other materials.

3.80 $1,615.00

03/19/14 R. Caughey Participating in strategy call with experts re FSI and ISP class definition. Conferring with S. Musallem re strategy. Reviewing hot docs. Arranging travel to New York. Drafting letter to J. Ansel and preparing research re same. Conferring with team re Insignia issues. Participating in call with experts re FSI and conferring with S. Musallem re same.

2.80 $1,190.00

03/20/14 R. Hess Reviewing emails and memos re class certification and discovery. Preparing witness summary for disputed custodians. Conferring with trial team via email.

1.70 $850.00

03/20/14 R. Caughey Preparing memorandum to team re expert teleconference. Conferring with team re strategy. Revising and sending J. Ansel letter re Insignia subpoena. Conferring with FGI's counsel re production of litigation materials and preparing memorandum to team re same. Conferring with J. Southwick re FSI strategy and case issues. Conferring with J. Briody re FGI witnesses. Participating in call

2.90 $1,232.50




Tax I.D.# 74‐2138615

with associates re discovery and document review capacity and strategy.

03/21/14 R. Caughey Participating in hearing in front of Judge Pauley at S.D. New York. Meeting with team re hearing strategy and case issues. Preparing for hearing. Preparing correspondence to K. Drye. Conferring with J. Ansel re Insignia subpoena. Preparing memorandum to J. Southwick and R. Hess re summary of hearing and issues. Traveling from Houston, TX to New York, NY.

7.90 $3,357.50


03/22/14 R. Caughey Reviewing hot documents. Conferring with team re upcoming tasks. Addressing Insignia issues. Traveling from New York, NY to Houston, TX.

5.50 $2,337.50

03/24/14 R. Caughey Conferring with J. Southwick and R. Hess re amended complaint and memo to clients. Participating in weekly discovery call. Addressing document review and contract attorney issues. Preparing correspondence to team re Insignia subpoena issues and preparing legal research re Rule 45 cost‐sharing and shifting. Conferring with J. Presant re amended complaint. Participating in call with document vendor re privilege review.

2.80 $1,190.00

03/24/14 J. Southwick Reviewing and responding to emails. 0.40 $270.00

03/24/14 R. Hess Reviewing draft letter to court. Conferring with R. Caughey and J. Southwick re amending complaint.

0.40 $200.00


3.60 $990.00

03/25/14 R. Hess Researching potential FGI exhibits for use in discovery letter.

2.70 $1,350.00

03/25/14 R. Caughey Addressing third‐party discovery issues. Conferring with team re amended complaint. Conferring with team re J. Ansel letter and strategy re Insignia. Conferring with team re strategy vis a vis Kelley Drye. Identifying documents re R. Kovalesky and L.

2.80 $1,190.00




Tax I.D.# 74‐2138615

Sutherland. Conferring with review team re same. Conferring with DTI re contract review options. Analyzing amended complaint and sending comments to J. Southwick and R. Hess.


4.50 $1,237.50


03/26/14 R. Hess Reviewing email from J. Briody. Reviewing proposed stipulation. Conferring by phone with trial team. Researching cites for letter to court. Researching witness list descriptions in FGI case for letter to court.

1.50 $750.00

03/26/14 J. Southwick Meeting with cocounsel. Reviewing and responding to emails re discovery issues. Arranging call with J. Mackie Mason.

1.60 $1,080.00

03/26/14 R. Caughey Addressing third‐party discovery issues. Conferring with J. Solotorobsky re Insignia and Kelley Drye subpoenas. Participating in weekly call. Addressing issues relating to custodian requests and supporting documents. Preparing correspondence to J. Ansel re third‐party discovery issues.

3.90 $1,657.50


2.50 $687.50

03/27/14 R. Caughey Researching for and preparing memorandum re defendants' corporate structure and parties. Reviewing correspondence to court. Addressing issues with complaint amendment. Addressing issues with third‐party discovery.

2.70 $1,147.50

03/27/14 R. Hess Reviewing pricing for contract reviewers. 1.30 $650.00


5.90 $1,622.50


03/28/14 R. Caughey Revising fourth amended complaint. Conferring with Kelley Drye re Insignia discovery. Conferring with team re fourth amended complaint and News corporate structure. Meeting with J. Southwick re

1.60 $680.00




Tax I.D.# 74‐2138615

amended complaint.

03/28/14 J. Southwick Reviewing proposed revisions to complaint. Conferring by phone with cocounsel re amending complaint.

1.10 $742.50

03/28/14 R. Hess Reviewing amended complaint. Conferring with R. Caughey and J. Southwick. Reviewing Sullivan complaint. Reviewing correspondence to Court. Conferring by phone with trial team re amended complaint.

2.10 $1,050.00


6.90 $1,897.50

03/29/14 R. Caughey Conferring with counsel for Insignia re third‐party discovery. Preparing corporate disclosure statements for clients and conferring with clients re same.

0.50 $212.50

03/31/14 R. Caughey Discussing third‐party discovery with J. Ansel, counsel for Insignia. Preparing memorandum re same. Conferring with team re complaint amendment and preparing memorandum to team re same. Conferring with team re corporate disclosure statements. Meeting with review team re document review issues. Participating in conference call re amended complaint.

2.10 $892.50

03/31/14 J. Southwick Preparing for call with Applecon and cocounsel re class certification. Reviewing and responding to emails re letters to the court re discovery issues.

0.90 $607.50


03/31/14 R. Hess Reviewing amended complaint. Conferring with R. Caughey and J. Southwick. Reviewing email from L. LeClair. Reviewing scheduling order.

1.20 $600.00


7.70 $2,117.50

04/01/14 R. Caughey Participating in weekly conference call. Addressing third‐party discovery issues. Finalizing and filing corporate disclosure statements. Conferring with BEF re FSI

1.80 $765.00




Tax I.D.# 74‐2138615

provider and issues. Participating in discovery conference call. Conferring with R. Hess re Emmel issues. Reviewing discovery correspondence.



8.10 $2,227.50

04/01/14 R. Hess Conferring by phone with J. Briody. Conferring with J. Southwick and R. Caughey re Emmel. Reviewing P&L and letters to court. Conferring by phone with trial team. Reviewing draft schedule.

1.10 $550.00

04/02/14 R. Caughey Addressing discovery issues. Reviewing correspondence with opposing counsel. Addressing logistics of privilege review. Conferring with J. Stanley re same.

0.50 $212.50



9.20 $2,530.00

04/02/14 R. Hess Revising and reviewing draft stipulation re experts. Conferring with J. Southwick. Reviewing proposed expert report dates.

0.60 $300.00

04/03/14 R. Caughey Addressing document collection and review issues and conferring with J. Stanley re same. Conferring with clients re Insignia subpoena and reviewing correspondence re same. Corresponding with J. Ansel. Addressing subpoena scheduling issues.

1.00 $425.00

04/03/14 R. Caughey Addressing third‐party discovery issues and conferring with team and J. Ansel re same. Conferring with document review team.

0.30 $127.50



8.90 $2,447.50

04/03/14 R. Hess Conferring with R. Caughey re upcoming hearing. Reviewing schedules and disputed issues.

0.80 $400.00



7.10 $1,952.50




Tax I.D.# 74‐2138615

04/06/14 R. Caughey Participating in weekly discovery call. Conferring with Foster Farms re document collection. Addressing third‐party discovery issues. Reviewing recent class cert jurisprudence. Preparing correspondence to J. Ansel. Conferring with J. Solotorovsky. Conferring with clients re requests for production and interrogatories.

1.60 $680.00


9.10 $2,502.50


8.80 $2,420.00


04/08/14 R. Hess Reviewing deposition notices. Reviewing draft email to third party counsel. Reviewing letters to clients. Reviewing and revising correspondence to third party counsel.

1.10 $550.00

04/09/14 R. Caughey Conferring with BEF re document collection and issues. Conferring with J. Southwick re case strategy. Conferring with third‐parties re discovery. Reviewing case correspondence. Conferring with review team re review issues.

1.00 $425.00

04/09/14 R. Caughey Conferring with team re client calls. Participating in calls with Foster Farms and Bob Evans re discovery and 30(b)(6) depositions. Communicating with J. Ansel re Insignia discovery. Conferring with J. Southwick and R. Hess re issues.

1.50 $637.50


3.30 $907.50

04/09/14 J. Southwick Conferring with R. Caughey re state of discovery and document review. Reviewing and responding to emails from cocounsel re discovery issues.

1.10 $742.50

04/09/14 R. Hess Reviewing emails, documents and correspondence from trial team.

0.20 $100.00

04/10/14 R. Caughey Participating in management committee call. Conferring with J. Solotorovsky re Insignia prior production materials. Conferring with

1.90 $807.50




Tax I.D.# 74‐2138615

J. Ansel re Insignia documents and third‐party production issues. Conferring with J. Southwick and R. Hess re 30(b)(6) depositions. Reviewing 30(b)(6) notices. Conferring with clients re document collection. Arranging travel to New York.


4.40 $1,210.00

04/11/14 R. Caughey Conferring with clients re 30(b)(6) depositions. Reviewing J. Briody letter to court. Conferring with J. Briody. Reviewing and analyzing correspondence from J. Solotorovsky.

0.80 $340.00


7.40 $2,035.00

04/11/14 J. Southwick Reviewing and responding to email with cocounsel re discovery issues. Reviewing Paul Hastings revisions to draft letter to clients re FSI.

1.20 $810.00

04/12/14 R. Caughey Reviewing J. Briody correspondence and corresponding with team re same.

0.30 $127.50

04/14/14 J. Southwick Reviewing and editing draft memorandum to clients re FSI claim. Reviewing emails re discovery of materials from NAM and Insignia.

2.60 $1,755.00


8.10 $2,227.50

04/14/14 R. Caughey Addressing issues with Insignia discovery and obtaining court order re sealed documents from Insignia case. Conferring with J. Roberts of BEF re 30(b)(6) depositions, trade‐promotions discovery, and related issues.

1.80 $765.00

04/15/14 J. Southwick Participating in weekly call with cocounsel. Reviewing revised memorandum to clients re FSI. Conferring by email with J. Mackie‐Mason and R. Pfau seeking update call. Reviewing emails with cocounsel, NAM, and clients.

2.20 $1,485.00


8.90 $2,447.50




Tax I.D.# 74‐2138615

04/15/14 R. Hess Reviewing and revising memorandum to client. Reviewing email to expert. Conferring with J. Southwick re same.

1.00 $500.00

04/15/14 J. Stanley Updating master time and expense chart. 1.00 $270.00

04/15/14 R. Caughey Participating in management committee call. Conferring with J. Solotorovsky re Insignia materials and materials filed under seal. Conferring with J. Ansel re issues. Reviewing 30(b)(6) topics. Conferring with J. Southwick re tasks and strategy. Conferring with J. Briody re conferences with J. O'Brien re Insignia discovery. Reviewing FSI letter to clients. Conferring with clients re designation of in‐house attorneys. Reviewing 30(b)(6) objection letter.

1.90 $807.50

04/16/14 J. Southwick Conferring by emails re proposed letter to court re News production of transactional data. Conferring by emails to schedule status call with economic experts.

0.40 $270.00


7.50 $2,062.50

04/16/14 R. Caughey Conferring with R. Pfau re transactional data. Reviewing BEF documents and producing same. Conferring with D. Brotherton at BEF re documents. Revising 30(b)(6) objection letter. Conferring with third parties re discovery. Conferring with J. Ansel re Insignia discovery issues.

2.40 $1,020.00

04/17/14 J. Southwick Arranging call with economists re progress of class certification work. Reviewing and responding to emails re discovery issues.

0.50 $337.50


4.20 $1,155.00

04/17/14 R. Hess Reviewing draft 30(b)(6) responses. Conferring in office with J. Southwick.

0.50 $250.00


04/18/14 J. Southwick Preparing for and participating in call with cocounsel and J. Mackie‐Mason and R. Pfau re progress of class certification work.

1.10 $742.50

04/18/14 R. Hess Reviewing draft memorandum and email to 0.30 $150.00




Tax I.D.# 74‐2138615

clients re FSI class.

04/18/14 R. Caughey Conferring with clients re dropping FSI class. Conferring with team re same. Reviewing and responding to correspondence re strategy.

0.40 $170.00

04/21/14 J. Southwick Conferring by phone with cocounsel and Spectrum Brands to discuss FSI class. Reviewing and responding to email re upcoming discovery hearing before Judge Pauley.

1.10 $742.50


8.50 $2,337.50

04/22/14 R. Caughey Participating in weekly discovery call. Conferring with J. Solotorovsky and J. Stanley re third‐party discovery logistics. Conferring with J. O'Brian and J. Briody re Insignia discovery and pleadings. Arranging travel to New York. Conferring with J. Corsiglia‐Keim at Foster Farms re discovery and J. Roberts at BEF re same.

3.10 $1,317.50


7.40 $2,035.00

04/22/14 J. Southwick Participating in weekly trial team call. Conferring by phone with HP Hood re FSI class. Reviewing and responding to correspondence and emails re discovery from News and hearing before J. Pauley on discovery issues.

2.60 $1,755.00

04/23/14 R. Caughey Attending discovery hearing before Judge Pauley. Drafting and circulating summary memorandum to team. Reviewing expert reports from prior News litigation. Conferring with team re strategy and third‐party discovery. Conferring with experts re expert materials from prior cases. Traveling from New York to Houston.

7.50 $3,187.50

04/24/14 R. Caughey Addressing discovery issues. Conferring with team re 30(b)(6) meet and confer. Reviewing correspondence.

0.50 $212.50

04/25/14 R. Caughey Participating in meet and confer with J. O'Brien re 30(b)(6) topics and Emmel hard

1.80 $765.00




Tax I.D.# 74‐2138615

drive. Participating in strategy call with S. Musallem, J. Presant, and J. Smith. Conferring with J. Solotorovsky and team re Insignia subpoena and discovery. Conferring with J. Ansel re discovery. Conferring with J. Southwick re settlement issues, hearing, and strategy. Reviewing settlement memorandum and sending comments to S. Berry.

04/27/14 R. Caughey Conferring with J. Ansel re Insignia discovery.

0.20 $85.00

04/28/14 R. Caughey Participating in weekly associate discovery call. Conferring with team re issues. Addressing issues with interrogatory responses.

0.70 $297.50

04/28/14 R. Hess Conferring in office with J. Southwick re individual FSI claims.

0.30 $150.00


5.50 $1,512.50



5.40 $1,485.00

04/29/14 J. Southwick Preparing for and participating in call with trial team. Reviewing and responding to emails re discovery issues.

1.60 $1,080.00

04/29/14 R. Hess Conferring by phone with trial team re task list. Conferring in office with J. Southwick.

0.50 $250.00

04/29/14 R. Caughey Participating in weekly management committee call. Conferring with clients re FSI claims. Addressing deposition topics.

1.20 $510.00



7.50 $2,062.50

04/30/14 R. Caughey Reviewing correspondence from J. Solotorovsky re Kelley Drye production. Reviewing correspondence from team re data and strategy issues. Addressing document issues.

1.00 $425.00

05/01/14 R. Caughey Participating in call with BEF re FSI claims. Conferring with J. Southwick, R. Hess et al. re

1.20 $510.00




Tax I.D.# 74‐2138615

FSI and ISP spending figures. Conferring with team re call scheduling and deposition preparation.

05/01/14 J. Southwick Conferring by phone with R. Caughey, R. Hess, and Bob Evans re FSI claims and upcoming discovery objections.

0.40 $270.00


8.20 $2,255.00



05/02/14 R. Caughey Participating in expert call with D. Zona and trial team. Participating in call with associates re 30(b)(6) depositions and discovery matters. Conferring with clients re issues.

2.00 $850.00

05/02/14 J. Southwick Conferring by phone with R. Caughey re conference call with D. Zona and Applecon.

0.20 $135.00


8.00 $2,200.00


05/03/14 R. Caughey Conferring with team re Zona call. 0.30 $127.50

05/04/14 R. Caughey Conferring with team re interrogatory responses and discovery. Conferring with clients re same.

0.50 $212.50

05/05/14 R. Caughey Conferring with team re 30(b)(6) depositions. Conferring with J. Presant re transactional data. Conferring with clients re discovery. Preparing discovery responses. Preparing responses and objections to NAM's second RFPs and Interrogatories. Conferring with team re same. Conferring with clients re FSI claims. Conferring with J. Corsiglia‐Keim re discovery.

2.70 $1,147.50

05/05/14 J. Southwick Reviewing emails re discovery and expert scheduling.

0.40 $270.00


7.80 $2,145.00


05/06/14 R. Caughey Participating in weekly trial team call. 3.20 $1,360.00




Tax I.D.# 74‐2138615

Participating in weekly discovery call. Conferring with BEF re strategy in light of FSI issues. Conferring with J. Corsiglia‐Keim re Foster Farms discovery status. Reviewing privilege domains in connection with privilege review. Participating in call with D. Brotherton re documents and discovery. Revising requests for production and interrogatory responses and circulating to team for review. Conferring repeatedly with associates and clients re discovery issues.


7.40 $2,035.00

05/06/14 J. Southwick Attending weekly trial team call. Reviewing and responding to emails. Reviewing transcript of last hearing with J. Pauley.

1.60 $1,080.00

05/06/14 R. Hess Conferring in office with J. Southwick re dismissal or settlement. Conferring by phone with trial team re task list.

0.50 $250.00


05/07/14 J. Southwick Conferring by phone with cocounsel and experts re class certification. Reviewing and responding to emails re call and other discovery issues.

1.40 $945.00

05/07/14 R. Caughey Participating in call with experts. Revising interrogatory responses and request for production responses and circulating to team and clients. Conferring with J. Briody re strategy and team re requests for production/ interrogatory issues. Conferring with J. Southwick re expert tasks. Conferring with clients re discovery responses and issues. Conferring with J. Corsiglia‐Keim re Foster Farms documents. Conferring with J. Stanley re document logistics. Preparing research re local rules.

2.50 $1,062.50


6.50 $1,787.50

05/07/14 J. Stanley Preparing documents for production. Reviewing document database.

3.00 $810.00

05/07/14 R. Hess Conferring by phone with experts re data 1.30 $650.00




Tax I.D.# 74‐2138615

issues and timing of reports. Reviewing meet and confer summary and email from experts re data.


05/08/14 R. Caughey Conferring with J. O'Brien re extension and class representatives. Conferring with team re discovery responses. Reviewing correspondence. Revising discovery responses. Conferring with clients re trade promotions data.

1.60 $680.00


7.20 $1,980.00

05/08/14 R. Hess Reviewing correspondence from opposing counsel.

0.20 $100.00


0.30 $127.50


6.20 $1,705.00

05/11/14 R. Caughey Reviewing correspondence. 0.30 $127.50

05/12/14 J. Southwick Conferring with P. Farris, T. Fazzone and cocounsel re class certification report. Conferring by phone with J. Metzler of Applecon, Navigant, and cocounsel re Oracle database. Reviewing and responding to email re class certification and discovery.

2.20 $1,485.00

05/12/14 R. Hess Reviewing correspondence to and from opposing counsel.

0.40 $200.00

05/12/14 R. Caughey Participating in call with P. Farris et al. re expert reports. Revising discovery responses and circulating to team. Participating in weekly discovery call. Addressing 30(b)(6) issues.

3.10 $1,317.50


7.80 $2,145.00

05/13/14 J. Southwick Preparing for and participating in weekly trial team call. Reviewing emails re class certification schedule and progress.

1.50 $1,012.50

05/13/14 R. Caughey Participating in weekly management committee call. Finalizing requests for production and interrogatory responses and

2.40 $1,020.00




Tax I.D.# 74‐2138615

serving on opposing counsel. Conferring with Kelley Drye re production of prior litigation materials. Conferring with J. Stanley re same. Reviewing correspondence re expert reports, etc. Conferring with clients re brand coverage and advertising.


05/14/14 J. Southwick Conferring by phone with Applecon and Navigant re Oracle database from News. Reviewing and responding to email re discovery and class certification.

1.10 $742.50

05/14/14 R. Caughey Conferring with team re extensions and briefing schedule. Participating in expert call. Conferring with J. Southwick re strategy. Conferring with discovery team re use of FSI and ISP. Conferring with J. Corsiglia‐Keim re Foster Farms marketing. Conferring with D. Brotherton re BEF marketing. Conferring with K. Briggs re privilege review. Meeting with staff attorneys re privilege review.

3.40 $1,445.00

05/14/14 K. Hormann Conferring with R. Caughey re upcoming privilege review.

0.30 $82.50

05/14/14 M. Downey Corresponding with trial team re privileged documents. Reviewing case emails.

0.30 $82.50

05/15/14 J. Southwick Reviewing and responding to emails re 30b6 depositions of News and discovery issues, as well as Navigant work on Oracle database.

1.20 $810.00

05/15/14 R. Caughey Conferring with K. Briggs re privileged documents. Conferring with clients re business practices discovery. Conferring with team re upcoming depositions. Reviewing hot documents and conferring with reviewers re next tasks. Addressing discovery issues. Preparing document production.

1.80 $765.00

05/15/14 J. Stanley Updating master time and fee chart. 0.50 $135.00

05/15/14 R. Hess Preparing to take deposition of News 30(b)(6) witness.

0.90 $450.00





Tax I.D.# 74‐2138615

05/16/14 R. Caughey Addressing Insignia discovery information. Coordinating with J. Stanley re same. Reviewing documents. Conferring with J. Southwick re strategy. Reviewing expert correspondence.

1.00 $425.00

05/16/14 J. Stanley Preparing documents for R. Hess. 3.00 $810.00

05/16/14 R. Hess Preparing to take deposition of News 30(b)(6) witness.

0.50 $250.00

05/18/14 R. Caughey Reviewing correspondence with experts and opposing counsel. Conferring with clients re discovery and business practices.

0.40 $170.00


0.40 $110.00

05/19/14 R. Caughey Participating in weekly discovery call. Conferring with team re tasks and strategy. Conferring with S. Musallem re issues and deposition scheduling. Conferring with clients re business practices. Conferring with clients re 30(b)(6) depositions. Conferring with J. Southwick and R. Hess re deposition logistics and strategy. Reviewing correspondence from opposing counsel.

1.90 $807.50

05/20/14 R. Caughey Participating in weekly management committee call. Addressing issues with privilege review. Addressing issues relating to 30(b)(6) depositions and conferring with R. Hess re same. Conferring with J. Southwick re 30(b)(6) strategy. Conferring with clients re 30(b)(6) depositions, business practices, and related matters. Reviewing privilege domains. Conferring with Foster Farms re issues. Reviewing correspondence from opposing counsel.

2.50 $1,062.50

05/20/14 R. Hess Reviewing memorandum to P. Farris. Reviewing NAM discovery responses. Reviewing deposition preparation outline. Reviewing email from Navigant re database issues. Preparing to take deposition of News 30(b)(6) witness. Conferring in office with R. Caughey re client depositions. Preparing to take deposition of News witness.

3.00 $1,500.00




Tax I.D.# 74‐2138615

05/21/14 R. Caughey Conferring with team re 30(b)(6) depositions and strategy. Conferring with clients re depositions and discovery. Reviewing correspondence re depositions and discovery. Reviewing documents. Conferring with reviewers re privilege review.

1.90 $807.50

05/21/14 R. Hess Conferring by phone with client rep re 30(b)(6). Preparing to take deposition of News witness. Reviewing documents re same. Traveling to New York City, NY. Reviewing deposition notices. Conferring by phone with trial team.

7.00 $3,500.00

05/21/14 J. Southwick Reviewing and responding to emails re discovery issues, expert work, and potential withdrawal of B. Evans.

0.50 $337.50

05/22/14 K. Monkhouse Reviewing documents. R. Caughey. re: Bob Evans Privilege Review.

1.78 $400.50

05/22/14 K. Monkhouse Reviewing memorandum. Re: Bob Evans, Foster Farms privilege review. R. Caughey.

0.75 $168.75

05/22/14 K. Monkhouse Conferring by phone with R. Caughey re: Bob Evans privilege review.

0.08 $18.00

05/22/14 K. Monkhouse Conferring in office with R. Caughey and M. Fisher re: Bob Evans privilege review

0.33 $74.25

05/22/14 K. Monkhouse Conferring in office with R. Caughey re: Bob Evans and Foster Farms privilege review.

0.33 $74.25


1.80 $495.00

05/22/14 R. Caughey Training reviewers on privilege review. Conferring repeatedly with team re privilege review. Conferring with R. Boyce of Foster Farms re 30(b)(6) depositions and dates. Conferring with J. Roberts re 30(b)(6) and fact depositions. Conferring with team re depositions. Conferring with team re business practices information. Preparing for depositions. Addressing third‐party discovery issues. Conferring with R. Hess re BEF depositions and issues. Conferring with J. Briody re discovery. Reviewing correspondence to opposing counsel.

3.30 $1,402.50

05/22/14 R. Hess Attending deposition of News 30(b)(6) 12.00 $6,000.00




Tax I.D.# 74‐2138615

witness Traveling from New York City, NY, including weather delays and flight cancellation.

05/22/14 M. Downey Reviewing trial team emails. 0.20 $55.00

05/23/14 K. Monkhouse Reviewing documents re: Bob Evans privilege review. R. Caughey.

4.95 $1,113.75

05/23/14 K. Monkhouse Conferring by phone with M. Fisher re: Bob Evans privilege review.

0.08 $18.00


1.00 $275.00

05/23/14 R. Caughey Conferring with team re 30(b)(6) deposition dates. Conferring with team re business practices discovery. Conferring with Foster Farms re business practices issues and 30(b)(6) depositions. Conferring with D. Brotherton re business practices issues. Conferring with BEF re trade promotions.

2.50 $1,062.50

05/23/14 R. Hess Preparing deposition summary. Conferring by phone with R. Caughey re deposition scheduling. Conferring with cocounsel via email re same. Responding to emails re client call and privileged doc review. Traveling from New York City, NY including weather delays and flight cancellation.

5.80 $2,900.00

05/24/14 R. Caughey Conferring with clients re discovery. 0.50 $212.50

05/24/14 R. Hess Researching points of law re class certification standards.

0.40 $200.00


5.19 $1,167.75

05/27/14 K. Monkhouse Conferring by email with R. Caughey re: Bob Evans privilege review.

0.08 $18.00

05/27/14 J. Southwick Participating in weekly trial team call. Conferring by phone with J. Roberts of B. Evans re upcoming depositions. Reviewing emails re deposition scheduling.

1.60 $1,080.00

05/27/14 M. Fisher Reviewing documents for production. 1.40 $385.00

05/27/14 R. Hess Preparing to take deposition of BEF 30(b)(6) witness. Conferring by phone with trial team. Scheduling deposition preparation.

3.30 $1,650.00

05/27/14 R. Caughey Participating in management committee call. 2.50 $1,062.50




Tax I.D.# 74‐2138615

Participating in call with J. Roberts and team re BEF's participation and deposition logistics. Conferring with clients re deposition scheduling and logistics. Conferring with R. Boyce re 30(b)(6) depositions and strategy. Reviewing documents. Conferring with document review team. Conferring with J. Corsiglia‐Keim re 30(b)(6) deposition preparation. Conferring with J. Southwick re case issues.

05/27/14 M. Downey Reviewing trial team emails re privilege. 0.10 $27.50

05/28/14 K. Monkhouse Conferring in office with R. Caughey re: Bob Evans privilege review.

0.10 $22.50

05/28/14 K. Monkhouse Reviewing documents re Bob Evans privilege review. R. Caughey.

5.37 $1,208.25

05/28/14 J. Southwick Conferring by phone with cocounsel and Applecon re progress of class certification work and need for extension. Reviewing and responding to emails re class certification extension and discovery issues.

1.10 $742.50

05/28/14 R. Hess Preparing to take deposition of BEF 30(b)(6) witness. Reviewing email from client and sending email to same re deposition preparation.

1.00 $500.00

05/28/14 R. Caughey Conferring with K. Briggs re various discovery issues. Conferring with document review team re status and issues. Conferring with clients re deposition preparation. Reviewing documents in connection with deposition preparation. Conferring with clients re business practices information.

1.90 $807.50


6.47 $1,455.75

05/29/14 R. Hess Reviewing draft letter to court and revised case management order.

0.20 $100.00

05/29/14 R. Caughey Conferring with team re business practices issues. Conferring with B. Reese, S. Worthington, and B. Keller at Foster Farms re business practices information. Conferring with review team re privilege review.

0.50 $212.50

05/29/14 M. Downey Corresponding with trial team re privilege 1.00 $275.00




Tax I.D.# 74‐2138615

review. Corresponding with K. Briggs re tags.


4.00 $900.00

05/30/14 R. Hess Conferring with cocounsel via email re BEF witness schedules. Reviewing draft letter to court.

0.20 $100.00

05/30/14 R. Caughey Participating in calls with S. Worthington and B. Keller re business practices. Conferring with J. Smith re business practices. Reviewing business practices submission to the court. Conferring with team re strategy and issues. Reviewing correspondence re extension and related issues. Conferring with K. Briggs re privilege review.

1.20 $510.00

05/30/14 J. Southwick Reviewing and responding to emails re request for extension of case schedule.

0.40 $270.00

05/30/14 K. Hormann Reviewing Foster Farms documents for privilege.

7.30 $2,007.50

06/02/14 K. Monkhouse Conferring by email with R. Caughey and M. Fisher re Bob Evans privilege review. Conferring in office with M. Fisher re Bob Evans privilege review

0.33 $74.25


4.07 $915.75

06/02/14 K. Monkhouse Conferring by phone with R. Caughey re Bob Evans and Foster Farms privilege review. Conference call with R. Caughey, Kimberly Briggs, Missy Downey, Kevin Hormann, Mateo Fisher.

0.27 $60.75

06/02/14 K. Monkhouse Reviewing documents re Foster Farms privilege review. R. Caughey.

0.84 $189.00

06/02/14 J. Southwick Reviewing and responding to emails re extension of schedule and related letter to the court.

0.40 $270.00


6.80 $1,870.00

06/02/14 R. Caughey Conferring with clients re 30(b)(6) depositions and documents. Conferring with team re document review and issues.

2.50 $1,062.50




Tax I.D.# 74‐2138615

Reviewing correspondence and filings relating to request for extension. Conferring with K. Briggs re privilege review. Reviewing documents. Participating in weekly discovery call. Arranging travel for deposition preparation sessions. Reviewing correspondence re privilege issues and depositions.

06/02/14 K. Hormann Reviewing Foster Farms documents for privilege. Conferring via phone with R. Caughey and others re same.

9.30 $2,557.50

06/02/14 R. Hess Reviewing letter from opposing counsel. 0.20 $100.00

06/02/14 M. Downey Reviewing documents for privilege. 4.00 $1,100.00

06/03/14 K. Monkhouse Reviewing documents re Foster Farms privilege review. R. Caughey.

1.07 $240.75

06/03/14 K. Monkhouse Conferring by email with R. Caughey re Foster Farms privilege review.

0.08 $18.00


4.09 $920.25


4.30 $1,182.50

06/03/14 R. Caughey Conferring with B. Kellert of Foster Farms re business practices discovery. Participating in weekly Management Committee call. Conferring with J. Corsiglia‐Keim re 30(b)(6) deposition preparation. Conferring with reviewers re privilege review. Pulling documents in connection with upcoming deposition preparation sessions. Conferring with clients re 30(b)(6) depositions. Making travel arrangements for 30(b)(6) deposition preparation.

1.20 $510.00

06/03/14 K. Hormann Reviewing Foster Farms documents for privilege. Conferring via email with R. Caughey re same.

8.90 $2,447.50

06/03/14 R. Hess Reviewing correspondence from opposing counsel. Conferring with client re deposition schedule. Conferring by phone with trial team. Preparing to take deposition of BEF witnesses.

0.90 $450.00




Tax I.D.# 74‐2138615



2.97 $668.25

06/04/14 K. Monkhouse Reviewing documents, preparing for deposition of Jennifer Corsiglia‐Keim re Foster Farms. R. Caughey.

1.64 $369.00

06/04/14 J. Southwick Conferring with R. Caughey and R. Hess re upcoming depositions and state of document review.

0.50 $337.50


4.80 $1,320.00

06/04/14 R. Caughey Conferring with J. Southwick and R. Hess re upcoming tasks and strategy. Conferring with J. Corsiglia‐Keim re documents and issues. Conferring with clients re 30(b)(6) deposition dates. Preparing materials for deposition preparation of J. Corsiglia‐Keim and M. Polk. Conferring with client re same. Coordinating privilege review and witness kits for J. Corsiglia‐Keim and M. Polk. Conferring with associates re review of hot documents.

1.80 $765.00

06/04/14 R. Hess Conferring in office with J. Southwick and R. Caughey re case update and 30(b)(6) depositions.

0.50 $250.00


06/05/14 K. Monkhouse Reviewing documents, Preparing for deposition of Jennifer Corsiglia‐Keim re Foster Farms. R. Caughey.

1.71 $384.75


3.30 $907.50

06/05/14 R. Caughey Meeting with J. Corsiglia‐Keim and M. Polk to prepare for upcoming depositions. Preparing for deposition preparation meetings. Conferring with J. Corsiglia‐Keim re deposition preparation. Addressing document review and privilege issues. Addressing common interest agreement. Conferring with R. Boyce re depositions. Traveling from Houston, TX to Dublin, CA.

10.50 $4,462.50




Tax I.D.# 74‐2138615

06/06/14 K. Monkhouse Reviewing documents, preparing for deposition of Jennifer Corsiglia‐Keim re Foster Farms.

3.16 $711.00


1.90 $522.50

06/06/14 R. Caughey Preparing witnesses for 30(b)(6) depositions and communicating with clients re same. Conferring with team re issues. Conferring with R. Hess re upcoming depositions and scheduling. Traveling from San Francisco, CA to Houston, TX.

4.50 $1,912.50

06/06/14 R. Hess Preparing to take deposition of BEF witnesses. Reviewing prepare notebook. Arranging prep schedules. Reviewing letter from opposing counsel.

1.50 $750.00

06/08/14 R. Caughey Conferring with team re business practices. Conferring with clients re scheduling.

0.30 $127.50


2.96 $666.00

06/09/14 K. Monkhouse Conferring by email with R. Caughey re: Foster Farms document review, Preparing for deposition of Jennifer Corsiglia‐Keim.

0.17 $38.25

06/09/14 R. Caughey Addressing correspondence relating to 30(b)(6) depositions. Conferring with Foster Farms re business practices. Conferring with R. Hess, J. Stanley, and M. Fisher re witness kits and preparation. Conferring with B. Kellert re business practices documents. Preparing J. Corsiglia‐Keim witness kit. Conferring with K. Monkhouse re document preparation. Conferring with opposing counsel re 30(b)(6) depositions and topics. Participating in weekly associate discovery call.

1.00 $425.00

06/09/14 J. Stanley Preparing materials for deposition preparation.

3.00 $810.00


4.00 $1,100.00

06/09/14 J. Southwick Reviewing and responding to emails re discovery and deposition issues.

0.40 $270.00




Tax I.D.# 74‐2138615


3.72 $837.00


4.20 $1,155.00

06/10/14 R. Hess Preparing to take deposition of BEF's corporate representative. Traveling to Columbus, OH for deposition preparation.

6.40 $3,200.00

06/10/14 R. Caughey Conferring with team re business practices. Addressing privilege review issues and privilege documents and conferring with K. Briggs re same. Reviewing correspondence re hearing. Conferring with J. Presant re witness kits. Preparing witness kits for BEF witnesses and preparing for 30(b)(6) depositions. Conferring with K. Monkhouse re document review and deposition issues. Addressing discovery issues.

1.80 $765.00

06/11/14 K. Monkhouse Reviewing documents re Bob Evans privilege review.

1.75 $393.75

06/11/14 K. Monkhouse Reviewing documents, preparing for deposition of Dave Brotherton re Bob Evans.

0.88 $198.00

06/11/14 K. Monkhouse Reviewing documents re Foster Farms privilege review.

2.44 $549.00


2.80 $770.00

06/11/14 R. Hess Reviewing and responding to emails from client and opposing counsel. Preparing to take deposition of BEF corporate representative. Attending meeting of T. Muir and D. Brotherton. Traveling from Columbus, OH.

10.30 $5,150.00

06/11/14 R. Caughey Participating in call with experts re Farris report. Conferring with trial team re Farris report and participating in management committee call. Conferring with clients re depositions. Preparing materials for 30(b)(6) depositions. Addressing common interest issues. Finalizing privilege review for BEF documents and conferring with K. Briggs and J. Stanley re same. Preparing for 30(b)(6)

2.90 $1,232.50




Tax I.D.# 74‐2138615

depositions and conferring with team re same. Conferring with clients re 30(b)(6) depositions.

06/11/14 J. Stanley Preparing documents for witness files. 2.00 $540.00

06/11/14 J. Stanley Updating witness files. 1.40 $378.00

06/12/14 K. Monkhouse Reviewing documents re: Foster Farms privilege review. R. Caughey.

1.57 $353.25

06/12/14 K. Monkhouse Conferring by email with R. Caughey re: Bob Evans, Foster Farms document review on privilege and preparing for deposition of Jennifer Corsiglia‐Keim.

0.17 $38.25

06/12/14 R. Hess Preparing to take deposition of BEF corporate representative. Reviewing documents for witness file.

4.30 $2,150.00

06/12/14 R. Caughey Conferring with clients re deposition dates. Preparing witness kit for J. Corsiglia‐Keim by reviewing documents and preparing outline re same. Conferring with J. Stanley and K. Monkhouse re witness kit for J. Corsiglia‐Keim Reviewing hot documents and other discovery materials.

3.20 $1,360.00

06/13/14 K. Monkhouse Reviewing documents, Preparing for deposition of Dave Brotherton re Bob Evans.

3.88 $873.00

06/13/14 K. Monkhouse Conferring by email with R. Caughey re Dave Brotherton Bob Evans document review.

0.17 $38.25

06/13/14 R. Hess Preparing to take deposition of BEF corporate representative. Reviewing documents for witness file. Conferring in office with R. Caughey.

1.30 $650.00

06/13/14 R. Caughey Conferring with R. Hess re BEF depositions, strategy, hardest questions, etc. Conferring with opposing counsel re deposition scheduling. Conferring with clients re 30(b)(6) depositions. Reviewing correspondence from opposing counsel re discovery issues. Investigating BEF discovery and conferring with trial team re same.

2.50 $1,062.50

06/14/14 R. Hess Reviewing correspondence from opposing counsel. Conferring by phone with J. Southwick and R. Caughey. Conferring by

2.00 $1,000.00




Tax I.D.# 74‐2138615

phone with cocounsel. Preparing correspondence to trial team.

06/14/14 R. Caughey Investigating issues with BEF production, BEF financials, and related issues, and conferring with team re same. Conferring with R. Hess re BEF issues, including depositions and production issues. Preparing memorandum to team re BEF financials. Conferring with J. Southwick re BEF issues.

2.50 $1,062.50

06/15/14 R. Hess Traveling to Columbus for deposition preparation. Preparing to take deposition of BEF corporate representative.

5.50 $2,750.00

06/15/14 R. Caughey Investigating issues with BEF production, BEF financials, and related issues, and conferring with team re same. Addressing issues with upcoming depositions.

1.40 $595.00


3.50 $787.50

06/16/14 R. Hess Preparing to take deposition of BEF corporate representative. Negotiating with opposing counsel. Conferring with trial team. Preparing hardest questions memorandum. Preparing witness for deposition. Conferring with trial team re updated reports.

10.50 $5,250.00

06/16/14 R. Caughey Conferring with team and opposing counsel re BEF production and depositions. Conferring with R. Hess re BEF production and issues with depositions. Conferring with M. Fisher re review of BEF documents. Conferring with D. Brotherton re BEF documents. Reviewing correspondence from K. Gallo re document collection. Reviewing BEF financial documents. Conferring with J. Southwick and R. Hess re deposition issues. Conferring with S. Musallem re 30(b)(6) depositions.

2.90 $1,232.50

06/16/14 J. Southwick Reviewing emails re discovery and delaying 30b6 deposition of Bob Evans Farm. Conferring by phone with R. Caughey and R. Hess to discuss discovery issues re BEF.

0.60 $405.00




Tax I.D.# 74‐2138615


6.00 $1,650.00


2.63 $591.75

06/17/14 R. Caughey Participating in weekly management committee call. Preparing research on second set of 30(b)(6) topics and conferring with team re same. Reviewing correspondence re second set of 30(b)(6) topics. Conferring with R. Hess re BEF documents and financial reports. Conferring with D. Brotherton re financial summaries. Preparing research and analysis re privilege and factual basis issues, and preparing memorandum re second set of 30(b)(6) topics. Reviewing financial documents from clients in connection with preparing summary sheets. Conferring with review team re collection of promotional and marketing agreements.

4.40 $1,870.00


8.20 $2,255.00

06/17/14 R. Hess Traveling from Columbus. Reviewing emails and correspondence from trial team and opposing counsel. Responding to same. Preparing memorandum to trial team re opposing counsel negotiations. Conferring by phone with trial team. Conferring in office with R. Caughey re updated reports. Reviewing correspondence from opposing counsel and trial team.

6.10 $3,050.00


3.78 $850.50

06/18/14 R. Caughey Preparing memorandum re second set of 30(b)(6) deposition topics, and preparing legal research re same. Conferring with team re second set of 30(b)(6) deposition topics. Conferring with clients re financial information. Conferring with R. Hess re deadlines and documents. Preparing correspondence to opposing counsel re BEF documents and depositions. Conferring with

2.50 $1,062.50




Tax I.D.# 74‐2138615

team re 30(b)(6) depositions. Addressing issues with witness kits.


8.30 $2,282.50

06/18/14 R. Hess Reviewing draft motion. Preparing correspondence to opposing counsel re BEF reports.

0.60 $300.00


3.22 $724.50

06/19/14 R. Caughey Conferring with team re 30(b)(6) topics and preparing legal research re same. Conferring with review team re witness kit tasks. Conferring with R. Hess re 30(b)(6) topics. Conferring with J. Southwick and R. Hess re ISP ROFR.

1.20 $510.00


8.10 $2,227.50

06/19/14 R. Hess Reviewing trial team emails re privilege and 30(b)(6). Sending emails to R. Caughey re same.

0.30 $150.00

06/20/14 K. Monkhouse Reviewing documents, Preparing for deposition of Dave Brotherton re Bob Evans.

3.33 $749.25

06/20/14 K. Monkhouse Conferring in office with R. Caughey re Bob Evans document review.

0.17 $38.25

06/20/14 R. Caughey Reviewing and commenting on business practices letter from J. Briody. Conferring with team re 30(b)(6) depositions. Conferring with K. Gallo re BEF summary documents. Conferring with R. Hess re same. Reviewing documents, including hot documents. Conferring with review team.

1.80 $765.00


7.80 $2,145.00

06/22/14 J. Stanley Updating case files. Updating master time and expense chart.

1.00 $270.00

06/23/14 J. Southwick Reviewing emails. 1.30 $877.50


1.00 $275.00

06/23/14 R. Caughey Reviewing correspondence re business practices and conferring with J. Briody re

1.40 $595.00




Tax I.D.# 74‐2138615

same. Conferring with D. Brotherton re financial summaries. Reviewing revised P. Farris report. Reviewing hot documents. Conferring with review team.

06/24/14 K. Monkhouse Reviewing documents, preparing for deposition of Dave Brotherton re: Bob Evans. R. Caughey.

3.15 $708.75

06/24/14 J. Southwick Participating in weekly trial team call. Reviewing emails re discovery issues.

0.70 $472.50


8.40 $2,310.00

06/24/14 R. Caughey Participating in weekly trial team call. Preparing correspondence to opposing counsel and conferring with K. Gallo re BEF summaries. Conferring with R. Hess re BEF summaries and document issues. Reviewing HP Hood 30(b)(6) deposition transcript and commenting re same. Reviewing and revising BEF financial summaries.

2.70 $1,147.50


2.23 $501.75

06/25/14 K. Monkhouse Reviewing documents re News production related to Corsiglia and Brotherton.

0.30 $67.50

06/25/14 J. Southwick Reviewing emails re Dial deposition. 0.40 $270.00

06/25/14 R. Caughey Conferring with D. Brotherton about financial summary documents, and conferring with R. Hess re same. Revising financial summary documents and serving on opposing counsel. Preparing communications with opposing counsel. Reviewing deposition transcript of Dial 30(b)(6) deposition. Conferring with review team. Reviewing deposition materials. Conferring with J. Stanley re Insignia documents.

2.60 $1,105.00

06/26/14 J. Southwick Reviewing emails re discovery and upcoming deposition.

0.80 $540.00


7.00 $1,925.00

06/26/14 R. Caughey Conferring with J. Presant re depositions. 0.80 $340.00




Tax I.D.# 74‐2138615

Reviewing documents. Conferring with team re strategy and deposition schedules.

06/26/14 J. Stanley Preparing documents for production. 1.00 $270.00


7.80 $2,145.00

06/27/14 R. Caughey Conferring with R. Hess re BEF depositions. 0.30 $127.50

06/29/14 R. Caughey Conferring with D. Brotherton and T. Muir re financial documents and depositions. Conferring with opposing counsel.

0.40 $170.00

06/30/14 K. Monkhouse Reviewing documents re News America Production on Corsiglia and Brotherton.

1.00 $225.00

06/30/14 R. Hess Conferring with R. Caughey re deposition prep for Muir.

1.20 $600.00

06/30/14 R. Caughey Preparing for T. Muir deposition. Reviewing prior deposition transcripts. Conferring with R. Hess and J. Southwick re T. Muir deposition. Conferring with trial team re discovery items. Conferring with clients re discovery. Conferring with opposing counsel re BEF financial documents. Conferring with document review team re witness kits.

3.00 $1,275.00

06/30/14 J. Stanley Preparing Corsiglia documents for review. 2.00 $540.00

07/01/14 J. Stanley Preparing Corsiglia document chronology. 1.00 $270.00

07/01/14 R. Caughey Preparing for T. Muir deposition and conferring with T. Muir re same. Conferring with D. Brotherton re documents and T. Muir deposition. Conferring with team re same. Preparing correspondence to opposing counsel re documents and T. Muir deposition. Reviewing BEF documents and prior 30(b)(6) deposition transcripts. Traveling from Houston, TX to Columbus, OH.

7.50 $3,187.50

07/01/14 R. Hess Preparing to take deposition of D. Brotherton. Conferring with trial team re same. Reviewing draft expert report. Reviewing draft of Farris report, draft of business practices letter agreement, correspondence from opposing counsel and emails from trial team. Preparing for and

2.40 $1,200.00




Tax I.D.# 74‐2138615

conferring by phone with trial team.


3.90 $1,072.50

07/02/14 J. Stanley Reviewing documents for deposition preparation.

2.00 $540.00

07/02/14 J. Southwick Conferring with cocounsel and AppleEcon re progress of class certification work. Conferring by emails with R. Caughey re Bob Evans corporate representative deposition preparation.

1.30 $877.50

07/02/14 R. Caughey Preparing for T. Muir deposition and conferring with trial team re same. Meeting with T. Muir and D. Brotherton to prepare for T. Muir's deposition. Conferring with D. Brotherton re financial documents and contracts. Conferring with BEF personnel re financial documents and contracts. Reviewing past deposition transcripts. Reviewing financial information in advance of deposition. Addressing issues with document production, preparing correspondence to opposing counsel, and producing documents. Conferring with J. Stanley re document logistics. Preparing hardest questions and best answers for T. Muir.

7.90 $3,357.50

07/02/14 R. Hess Attending meeting of cocounsel and experts via teleconference re expert report update. Reviewing correspondence from trial team. Reviewing deposition summary.

1.10 $550.00

07/03/14 R. Caughey Defending deposition of T. Muir. Conferring with J. Southwick and R. Hess re T. Muir deposition. Meeting with T. Muir re deposition. Conferring with opposing counsel re issues. Traveling from Columbus, OH to Houston, TX.

11.50 $4,887.50

07/04/14 R. Caughey Preparing summary of deposition and circulating to team. Preparing supplemental interrogatory responses and circulating to team.

1.00 $425.00

07/07/14 J. Southwick Updating reading and researching re 2.00 $1,350.00




Tax I.D.# 74‐2138615

monopolization claims.

07/07/14 R. Caughey Conferring with J. Southwick re case tasks and strategy. Conferring with team re depositions. Addressing discovery issues.

0.50 $212.50

07/08/14 R. Hess Reviewing documents produced by News America Marketing. Conferring in office with J. Southwick re tasks. Preparing for conference with trial team. Preparing to take deposition of D. Brotherton. Conferring with R. Caughey.

1.00 $500.00

07/08/14 R. Caughey Reviewing deposition summary of Dietz deposition. Conferring with J. Southwick and R. Hess re tasks. Conferring with team re deposition scheduling. Conferring with J. Corsiglia‐Keim re deposition preparation. Reviewing hot documents for Foster Farms and NAM.

1.10 $467.50

07/09/14 J. Southwick Reviewing and responding to emails re document discovery issues and inadvertent production of privileged documents.

0.60 $405.00

07/09/14 R. Caughey Conferring with K. Briggs re document production issues and interrogatories. Conferring with team re depositions. Identifying documents for production.

0.40 $170.00


07/10/14 R. Hess Attending meeting of cocounsel via teleconference. Preparing for conference with cocounsel.

0.70 $350.00

07/14/14 J. Southwick Reviewing J. Pauley decisions re class certification and emails with trial team re class certification.

2.70 $1,822.50

07/14/14 J. Stanley Updating master fees & expense chart. 0.40 $108.00

07/15/14 J. Southwick Preparing for and participating in weekly call with trial team. Reviewing and responding to emails.

0.80 $540.00


07/16/14 J. Southwick Preparing for and conferring by phone with R. Pfau and cocounsel. Reviewing and responding to email re discovery issues.

1.80 $1,215.00

07/16/14 R. Caughey Conferring with team re depositions and 0.30 $127.50




Tax I.D.# 74‐2138615

discovery items. Conferring with clients re deposition scheduling.

07/18/14 R. Caughey Conferring with clients re deposition dates. 0.20 $85.00

07/18/14 R. Hess Researching factual matters re computer hacking allegations.

0.60 $300.00

07/21/14 R. Caughey Participating in call with P. Farris, R. Pfau, and trial team re Farris report. Conferring with team re discovery. Conferring with Foster Farms re depositions and discovery. Participating in weekly discovery call. Conferring with team re privilege review. Conferring with opposing counsel re depositions.

2.10 $892.50

07/22/14 J. Southwick Participating in weekly trial team call. Reviewing emails re discovery.

1.10 $742.50

07/22/14 R. Caughey Participating in weekly conference call. Conferring with J. Corsiglia‐Keim re financial documents. Reviewing hot documents. Conferring with team re strategy. Conferring with BEF re action items. Conferring with J. Stanley re issues.

1.40 $595.00

07/23/14 R. Caughey Addressing discovery issues with clients. Reviewing documents. Conferring with review team re strategy. Conferring with clients re deposition scheduling. Reviewing correspondence.

1.00 $425.00

07/24/14 J. Southwick Conferring on phone and emails with trial team re hearing re Spectrum withdrawal.

1.20 $810.00

07/24/14 R. Caughey Conferring with clients re discovery items. 0.30 $127.50

07/25/14 J. Southwick Conferring by emails with trial team re FSI email and class certification briefing. Reviewing draft class certification briefing.

4.30 $2,902.50

07/25/14 R. Caughey Reviewing draft class brief and expert report. Conferring with J. Southwick re same.

0.90 $382.50

07/26/14 J. Southwick Reviewing draft reports from P. Farris and R. Pfau. Reviewing and editing class certification brief.

2.90 $1,957.50

07/27/14 J. Southwick Reviewing draft reports from P. Farris and R. Pfau. Reviewing and editing class

3.70 $2,497.50




Tax I.D.# 74‐2138615

certification brief.

07/27/14 R. Caughey Conferring with clients re discovery items. 0.30 $127.50

07/28/14 R. Caughey Participating in call re expert report. Preparing memorandum to team re discovery update. Reviewing class brief. Conferring with clients re discovery. Participating in weekly discovery call. Conferring with J. Southwick and R. Hess re class brief.

2.10 $892.50

07/28/14 J. Southwick Preparing for and participating in call with ApplEcon re draft report supporting class certification. Revising and commenting on draft class certification brief.

5.80 $3,915.00

07/29/14 J. Stanley Reviewing documents for R. Hess. 3.00 $810.00

07/29/14 R. Caughey Participating in weekly trial team call. Conferring with clients re discovery. Revising class brief and preparing research re same. Conferring with J. Southwick and R. Hess re revisions to class brief.

2.90 $1,232.50

07/29/14 R. Hess Revising and reviewing draft brief in support of class certification.

1.20 $600.00

07/30/14 J. Stanley Reviewing case files and preparing information for R. Hess.

1.00 $270.00

07/30/14 R. Caughey Revising class brief. Conferring with clients re discovery issues. Conferring with R. Hess re class brief.

2.50 $1,062.50

07/30/14 R. Hess Conferring with R. Caughey re edits to brief. Researching factual matters re computer hacking allegations.

0.50 $250.00

07/31/14 R. Caughey Revising class brief. Conferring with clients re discovery issues. Conferring with R. Hess re class brief. Conferring with opposing counsel re discovery. Conferring with in‐house team re discovery. Reviewing correspondence and deposition transcripts. Preparing legal research.

3.10 $1,317.50

07/31/14 R. Hess Revising and reviewing draft brief in support of class certification.

0.50 $250.00

08/01/14 R. Hess Revising draft class certification brief. 2.60 $1,300.00

08/01/14 J. Southwick Conferring on emails re revisions to class 1.00 $675.00




Tax I.D.# 74‐2138615

certification motion.

08/01/14 J. Stanley Reviewing documents for R. Caughey. 0.60 $162.00

08/01/14 R. Caughey Revising and circulating class brief. Conferring with R. Hess re revisions to class brief. Reconciling revisions in class brief. Reviewing documents and preparing legal research in connection with class brief research. Circulating class brief to counsel group.

3.00 $1,275.00

08/02/14 J. Southwick Reviewing draft of class certification brief from R. Caughey.

2.20 $1,485.00

08/02/14 R. Caughey Conferring with cocounsel re draft issues. 0.30 $127.50

08/04/14 R. Caughey Analyzing Foster Farms financial documents. Reviewing correspondence re class brief and strategy. Participating in discovery call with opposing counsel re client data. Participating in weekly associates discovery call. Reviewing hot documents. Reviewing revised class brief.

1.50 $637.50

08/05/14 R. Hess Reviewing emails from trial team and experts re expert report. Conferring by phone with trial team re class certification brief edits.

2.20 $1,100.00

08/05/14 J. Stanley Reviewing previously filed declarations used with class certification motions.

0.60 $162.00

08/05/14 R. Caughey Participating in weekly trial team conference call. Reviewing deposition transcripts. Reviewing revised Farris report. Conferring with clients re discovery issues. Conferring with J. Southwick and R. Hess re strategy.

1.80 $765.00

08/06/14 R. Hess Reviewing emails and sending emails re class certification brief. Attending teleconference with Professor Farris re expert report.

2.70 $1,350.00

08/06/14 J. Southwick Reviewing drafts of class certification papers and experts reports. Conferring by phone with cocounsel re class certification motion issues.

3.30 $2,227.50

08/06/14 R. Caughey Participating in call re J. MacKie‐Mason report. Participating in call re Farris report. Conferring with J. Southwick and R. Hess re

2.50 $1,062.50




Tax I.D.# 74‐2138615

expert reports, strategy, and FRCP 23(g) declarations. Reviewing hot documents in connection with class briefing. Reviewing class briefing and expert reports.

08/07/14 R. Hess Reviewing email from trial team re P. Farris. 0.10 $50.00

08/07/14 J. Southwick Reviewing emails and drafts of briefs and expert reports in support of motion for class certification.

1.70 $1,147.50

08/07/14 R. Caughey Reviewing class briefing and expert reports. Conferring with R. Hess et al re lead counsel declarations.

0.70 $297.50

08/08/14 R. Hess Reviewing class certification and expert report edits. Sending and receiving emails. Conferring with R. Caughey re class certification declarations. Reviewing same. Reviewing Susman Godfrey's declarations for class certification.

1.60 $800.00

08/08/14 J. Southwick Reviewing emails, drafts of briefs and expert reports in support of motion for class certification.

2.90 $1,957.50

08/08/14 R. Caughey Preparing Rule 23(g) declaration for J. Southwick. Participating in call re class briefing and expert reports. Conferring with clients and opposing counsel re data discovery.

1.50 $637.50

08/09/14 J. Southwick Preparing for and participating in call with cocounsel re class certification motion. Reviewing and responding to emails re class certification motion and expert reports.

4.10 $2,767.50

08/09/14 R. Caughey Revising J. Southwick FRCP 23(g) declaration. Participating in conference call re expert reports.

0.80 $340.00

08/10/14 J. Southwick Reviewing and responding to emails re class certification motion and expert reports.

2.00 $1,350.00

08/10/14 R. Hess Reviewing draft of expert report. Conferring with R. Caughey via email re declarations. Reviewing and revising same.

0.80 $400.00

08/11/14 J. Southwick Reviewing emails re final class certification motion papers and expert reports.

1.40 $945.00

08/11/14 R. Caughey Preparing exhibits for J. Southwick FRCP 1.00 $425.00




Tax I.D.# 74‐2138615

23(g) declaration. Reviewing correspondence re filing and reports. Conferring with associates re discovery.

08/11/14 R. Hess Reviewing drafts of motion to certify class and draft expert report.

0.50 $250.00

08/12/14 J. Southwick Reviewing filings and emails from class certification motion. Conferring with R. Hess re class certification and upcoming discovery.

0.90 $607.50

08/12/14 R. Caughey Conferring with team re strategy and next steps. Conferring with J. Corsiglia‐Keim re issues.

0.30 $127.50

08/12/14 R. Hess Reviewing emails and final version of class certification brief and expert reports. Conferring in office with J. Southwick.

0.50 $250.00

08/13/14 R. Caughey Reviewing correspondence re class certification and deposition issues. Reviewing correspondence from opposing counsel. Conferring with clients re issues.

0.20 $85.00

08/14/14 R. Caughey Reviewing correspondence re class briefing. Conferring with clients re discovery. Conferring with R. Hess re case strategy and issues.

0.40 $170.00

08/14/14 R. Hess Conferring by phone with J. Southwick. Conferring with R. Caughey re trial team call.

0.10 $50.00

08/15/14 R. Caughey Conferring with clients re data collection. Reviewing BEF financial data.

0.40 $170.00

08/15/14 R. Hess Conferring in office with R. Caughey (on 8/14). Reviewing emails re upcoming BEF production.

0.30 $150.00

08/16/14 R. Caughey Conferring with clients re data collection. 0.20 $85.00

08/18/14 R. Hess Attending hearing on motion to seal. 0.30 $150.00

08/19/14 J. Southwick Preparing for and participating in weekly trial team call. Investigating needs and goals of a plaintiffs' deposition campaign.

3.30 $2,227.50


08/20/14 J. Southwick Reviewing file and discussing with M. Fischer in preparation of deposition.

6.10 $4,117.50

08/20/14 M. Fisher Conferring in office with J. Southwick re 2.20 $605.00




Tax I.D.# 74‐2138615

document review project. Reviewing documents for document review project.

08/21/14 R. Caughey Addressing discovery issues. 0.50 $212.50

08/21/14 J. Southwick Conferring with M. Fisher re merits discovery issues and begin determining plan for merits depositions.

7.00 $4,725.00


2.60 $715.00

08/22/14 J. Southwick Reviewing detailed report and preparing for defense of deposition of J. Mackie‐Mason. Reviewing materials from M. Fisher re merits discovery.

6.80 $4,590.00

08/25/14 J. Southwick Reviewing detailed report. Preparing for defense of deposition of J. Mackie‐Mason.

2.90 $1,957.50


4.30 $1,182.50

08/25/14 R. Caughey Drafting sections of discovery letter for Foster Farms and BEF. Analyzing discovery responses of Foster Farms and BEF. Participating in weekly discovery call. Reviewing offensive discovery issues. Reviewing hot documents. Conferring with opposing counsel re 30(b)(6) depositions. Conferring with team re strategy.

3.40 $1,445.00

08/26/14 J. Southwick Preparing for and discussing with cocounsel on weekly call. Conferring with cocounsel and Applecon re class certification and merits expert work. Reviewing materials for merits discovery and identify deponents.

7.10 $4,792.50


2.00 $550.00

08/26/14 R. Caughey Conferring with team re 30(b)(6) depositions. Conferring with team re data discovery issues. Participating in weekly management committee call. Reviewing hot documents. Reviewing correspondence. Conferring with J. Southwick re strategy and tasks. Conferring with opposing counsel re 30(b)(6) depositions. Participating in call with expert witnesses re reports and depositions. Conferring with M. Fischer re

4.10 $1,742.50




Tax I.D.# 74‐2138615

documents and issues.

08/27/14 M. Fisher Conferring in office with J. Southwick, R. Caughey, and K. Hormann regarding document review project. Reviewing documents for document review project.

3.20 $880.00

08/27/14 J. Southwick Meeting with SG trial team re merits discovery strategy. Reviewing research re expert analysis and regression in preparation for J. Mackie‐Mason deposition.

7.70 $5,197.50

08/27/14 K. Hormann Conferring in person with J. Southwick, R. Caughey, and M. Fisher re preparations for depositions.

2.00 $550.00

08/27/14 R. Caughey Reviewing hot documents and identifying deponents. Conferring with J. Southwick re case strategy and tactics. Conferring with document reviewers re documents and tasks. Participating in meet and confer with opposing counsel. Conferring with J. Briody and S. Musallem re document review and tasks. Conferring with J. Southwick re expert depositions.

3.40 $1,445.00


2.90 $797.50

08/28/14 J. Southwick Researching use of regression to prove class wide impact and consider merits deposition strategy.

7.60 $5,130.00

08/28/14 J. Stanley Conferring with trial team. Reviewing documents to be printed. Updating fees chart.

4.00 $1,080.00

08/28/14 K. Hormann Reviewing documents produced by NAM to determine involvement of M. Schulman.

3.50 $962.50

08/28/14 R. Caughey Reviewing documents and conferring with J. Southwick and R. Hess re ISP spending. Conferring with document review team. Scheduling depositions.

1.70 $722.50

08/29/14 J. Southwick Reviewing correspondence re discovery and case schedule. Conferring on call with J. Briody re proposed adjustments to case schedule. Making travel arrangements for J. Mackie Mason preparation and deposition.

1.80 $1,215.00




Tax I.D.# 74‐2138615

08/29/14 R. Caughey Preparing deposition notice for expert deposition. Making arrangements for expert deposition. Conferring with clients re depositions. Reviewing documents.

1.50 $637.50

09/01/14 R. Caughey Conferring with team re calls and discovery. Reviewing correspondence.

0.40 $170.00

09/02/14 J. Southwick Preparing for and participating in weekly call with cocounsel. Conferring by emails re possible extension of schedule to accommodate ApplEcon. Reviewing possible cross‐exam topics for J. Mackie‐Mason. Researching Rose Advertising and Star Karts.

3.60 $2,430.00


1.50 $412.50

09/02/14 J. Stanley Reviewing hot documents for chronology. 3.00 $810.00


09/02/14 R. Caughey Participating in weekly management committee call. Participating in call with associates re discovery. Preparing for depositions. Reviewing hot documents. Revising deposition notice and conferring with team re same.

2.00 $850.00


1.20 $330.00

09/03/14 J. Stanley Reviewing hot documents for document chronology.

5.00 $1,350.00

09/03/14 J. Southwick Reviewing materials re potential deponents on merits issues. Conferring by emails re proposed extension of merits schedule.

3.60 $2,430.00

09/03/14 R. Caughey Conferring with J. Southwick and R. Hess re deposition and strategic plans. Making arrangements for J. Corsiglia‐Keim deposition. Serving deposition notice. Reviewing documents and coordinating with review team. Preparing materials for J. Corsiglia‐Keim witness preparation.

2.90 $1,232.50

09/04/14 J. Southwick Traveling to Ann Arbor. Reviewing briefs re class certification and Daubert motions in E‐books litigation. Conferring with R. Pfau. Meeting with J. Mackie Mason, R. Pfau, S.

13.00 $8,775.00




Tax I.D.# 74‐2138615

Berry and other ApplEcon people. Conferring on call with cocounsel re schedule and discovery issues. Conferring by emails re proposed class certification and merits schedule changes. Traveling to Houston.


1.80 $495.00

09/04/14 R. Caughey Conferring with team re damages reports. Participating in calls and deposition prep with damages expert. Preparing for 30(b)(6) depositions. Reviewing marketing documents.

2.20 $935.00


0.80 $220.00

09/05/14 J. Stanley Preparing document chronology. 3.40 $918.00

09/05/14 J. Southwick Conferring with cocounsel re revising schedule for merits discovery and expert reports. Reviewing expert reports in e‐books case, federal judicial center publication on scientific evidence, and articles on use of regression evidence in preparation for J. Mackie Mason deposition and for class certification motion generally.

5.80 $3,915.00

09/05/14 R. Caughey Reviewing correspondence. Reviewing hot documents and addressing discovery issues. Preparing for upcoming depositions.

1.90 $807.50

09/08/14 R. Hess Reviewing email from trial team re opposing counsel requests.

0.20 $100.00

09/08/14 J. Southwick Preparing for deposition of J. Mackie Mason. Reviewing hot chronology of documents. Traveling to Ann Arbor.

10.60 $7,155.00

09/08/14 R. Caughey Participating in weekly associate discovery call. Reviewing hot documents. Preparing for depositions.

1.00 $425.00


1.00 $275.00

09/09/14 J. Southwick Preparing mock cross‐examination of J. Mackie Mason. Preparing for deposition with J. Mackie Mason and ApplEcon.

7.90 $5,332.50




Tax I.D.# 74‐2138615

Participating in weekly call with cocounsel. Reviewing and commenting on draft letter to court re adjusting case schedule.

09/09/14 R. Caughey Conferring with S. Musallem re depositions. Conferring with J. Southwick re several issues in light of J. Mackie‐Mason deposition and preparing communications re same. Reviewing documents in preparation for depositions.

2.10 $892.50


0.60 $165.00

09/09/14 R. Hess Reviewing draft letter agreements and deposition lists. Preparing for conference call. Conferring by phone with trial team.

1.00 $500.00

09/10/14 J. Southwick Attending deposition of J. Mackie Mason. Traveling to Houston.

14.50 $9,787.50

09/10/14 R. Caughey Preparing for Foster Farms 30(b)(6) deposition. Conferring with team re discovery and related issues. Reviewing documents. Preparing research re potential deponents.

1.90 $807.50


3.50 $962.50

09/10/14 J. Stanley Preparing notebook for deposition preparation per J. Southwick.

1.00 $270.00

09/11/14 R. Caughey Conferring with J. Southwick re depositions. Conferring with clients re depositions. Reviewing documents in advance of Foster Farms deposition. Reviewing correspondence with court and opposing counsel.

1.80 $765.00

09/11/14 R. Caughey Conferring with J. Southwick re depositions. Conferring with clients re depositions. Reviewing documents in advance of Foster Farms deposition. Reviewing correspondence with court and opposing counsel.

1.80 $765.00

09/11/14 J. Southwick Preparing and circulating summary of deposition of J. Mackie Mason. Reviewing and responding to emails re production costs and depositions. Drafting letter to

2.90 $1,957.50




Tax I.D.# 74‐2138615

Court concerning class certification briefing and adjusting deadlines.


1.20 $330.00

09/12/14 J. Southwick Reviewing and responding to emails re class certification, anticipated Daubert motion, and merits discovery.

0.40 $270.00

09/12/14 R. Caughey Preparing for Foster Farms 30(b)(6) deposition. Conferring with team re discovery and related issues. Reviewing documents. Preparing research re potential deponents.

2.50 $1,062.50

09/14/14 R. Caughey Preparing for Foster Farms 30(b)(6) deposition. Conferring with team re discovery and related issues.

2.90 $1,232.50

09/15/14 R. Caughey Preparing for Foster Farms 30(b)(6) deposition. Reviewing documents re same. Preparing production of Foster Farms documents. Participating in weekly discovery call. Reviewing hot documents. Conferring with clients re discovery.

7.40 $3,145.00


1.50 $412.50

09/16/14 J. Stanley Preparing materials for R. Hess to review. Updating deposition files.

1.00 $270.00

09/16/14 R. Hess Traveling to San Francisco for Corseglia‐Keim deposition. Preparing same. Preparing to take deposition. Conferring with R. Caughey. Reviewing transcript of prior corporation representative depositions. Traveling from San Francisco.

16.30 $8,150.00

09/16/14 R. Caughey Meeting with J. Corsiglia‐Keim, R. Boyce, and R. Hess for Foster Farms 30(b)(6) prep. Preparing for 30(b)(6) deposition. Traveling from Houston, TX to Dublin, CA.

12.60 $5,355.00


6.10 $1,677.50


09/17/14 R. Caughey Defending deposition of Jennifer Corsiliglia‐Keim. Preparing for deposition of Jennifer

11.90 $5,057.50




Tax I.D.# 74‐2138615

Corsiglia‐Keim. Meeting with Jennifer Corsiglia‐Keim and R. Boyce. Preparing summary of deposition for team. Reviewing and responding to correspondence.


7.80 $2,145.00

09/17/14 R. Hess Traveling from San Francisco, CA. 0.70 $350.00

09/18/14 R. Caughey Participating in conference call re document review training. Traveling from San Francisco, CA to Salt Lake City, Utah. Reviewing deposition transcript and documents. Conferring with client re issues. Conferring with J. Southwick and R. Hess re deposition. Conferring with team re deposition.

4.50 $1,912.50

09/22/14 R. Caughey Reviewing deposition transcript. Reviewing correspondence. Conferring with teams re issues.

0.50 $212.50

09/23/14 J. Southwick Preparing for and participating in weekly call.

0.80 $540.00

09/23/14 R. Caughey Participating in weekly conference call. Addressing document production and deposition issues. Conferring with document review team. Conferring with clients.

1.00 $425.00

09/24/14 M. Fisher Reviewing documents for M. Schulman custodial file. Reviewing documents for CPG contracts from 2010‐2014.

8.10 $2,227.50

09/24/14 R. Caughey Reviewing correspondence re discovery and depositions.

0.30 $127.50

09/25/14 J. Southwick Reviewing documents concerning retailer contracts in 2010‐2013.

0.80 $540.00


7.70 $2,117.50

09/25/14 R. Caughey Reviewing correspondence. Reviewing deposition materials.

0.40 $170.00


7.20 $1,980.00

09/28/14 R. Hess Reviewing legal research memorandum on 0.30 $150.00




Tax I.D.# 74‐2138615

prior depositions.

09/29/14 J. Southwick Reviewing retailer renewal documents. Reviewing K. Murphy materials. Reviewing Urethanes decision from 10th Circuit affirming class certification.

4.80 $3,240.00

09/29/14 M. Fisher Reviewing documents for M. Schulman custodial file.

6.40 $1,760.00

09/29/14 R. Caughey Conferring with team re discovery. Conferring with clients re depositions.

0.30 $127.50


1.80 $495.00

09/30/14 R. Caughey Participating in weekly conference call. Participating in discovery call. Addressing discovery issues. Meeting with J. Southwick re discovery and depositions and conferring with team re same.

1.00 $425.00

09/30/14 J. Southwick Reviewing Urethanes appellate decision. Participating in weekly call with cocounsel. Reviewing documents re renewal of retainer contracts in 2010‐2013, Conferring with R. Caughey re state of discovery from BEF and FF and how to deal with recently departed employees from those firms.

4.70 $3,172.50

10/01/14 J. Southwick Reading recent class certification opinions. Reviewing K. Murphy materials. Reviewing retailer renewal documents.

2.20 $1,485.00


1.60 $440.00

10/01/14 R. Caughey Participating in conference call re discovery and tasks.

0.30 $127.50

10/06/14 R. Caughey Participating in weekly discovery call. Conferring with R. Pfau re issues. Conferring with J. Southwick and R. Hess re expert deposition. Reviewing correspondence. Conferring with clients re representation of former employees. Conferring with team re deposition notices.

1.30 $552.50

10/06/14 J. Southwick Conferring by phone with L. LeClair and D. Goldman re class certification. Reviewing hot document chronology and preparing for

4.40 $2,970.00




Tax I.D.# 74‐2138615

deposition of News expert in opposition to class certification.

10/07/14 J. Southwick Participating on weekly call with cocounsel. Reading class certification decision in optical disc drive and preparing email to trial team. Reviewing briefing and expert reports in optical disc drive class certification motion and comparing to Mackie Mason's report in support of class certification.

4.80 $3,240.00

10/07/14 R. Caughey Conferring with team re calls and discovery. Addressing issues with depositions. Participating in call with R. Pfau and J. Corsiglia‐Keim and conferring with participants re same.

1.00 $425.00


1.40 $378.00

10/08/14 J. Southwick Reviewing and responding to emails and filings. Reviewing hot document chronology.

2.20 $1,485.00

10/08/14 R. Caughey Addressing discovery issues with client reps. Reviewing correspondence.

0.50 $212.50

10/09/14 R. Caughey Meeting with J. Southwick re expert deposition. Preparing arrangements for expert deposition. Reviewing correspondence. Reviewing deposition transcripts.

1.20 $510.00

10/09/14 J. Southwick Researching class certification issues. Preparing for deposition of News economists.

5.40 $3,645.00

10/10/14 R. Caughey Reviewing class certification opposition and expert report of J. Hausman. Conferring with team re opposition. Reviewing correspondence. Reviewing expert materials.

1.60 $680.00

10/10/14 J. Southwick Reviewing cases and materials in support of class certification in preparation for reply in support of class certification and deposition of News expert. Reviewing opposition to class certification.

6.30 $4,252.50

10/11/14 J. Southwick Reviewing defendants filing in opposition to class certification.

2.00 $1,350.00




Tax I.D.# 74‐2138615

10/13/14 R. Caughey Conferring with S. Berry re Hausman deposition. Conferring with team re same. Meeting with J. Southwick re case. Participating in weekly discovery call.

1.40 $595.00

10/13/14 J. Stanley Preparing notebooks for class certification briefing. Downloading expert backup.

2.00 $540.00

10/14/14 J. Southwick Participating in weekly trial team call. Reviewing defendants filing in opposition to class certification and Hausman expert report.

7.20 $4,860.00

10/14/14 R. Caughey Participating in management committee call. Reviewing J. Hausman materials in advance of deposition. Conferring with J. Southwick re reply brief. Reviewing correspondence.

1.50 $637.50


10/14/14 J. Stanley Reviewing briefing and preparing notebooks. 2.00 $540.00

10/15/14 J. Southwick Conferring by phone with cocounsel re division of labor in responding to opposition to class certification. Continuing review of opposition to summary judgment and Hausman materials.

5.80 $3,915.00

10/15/14 R. Caughey Conferring with opposing counsel re J. Hausman data backup. Conferring with team re J. Hausman deposition. Conferring with J. Briody re discovery issues. Conferring with J. Southwick re deposition.

1.30 $552.50

10/16/14 J. Southwick Reviewing Hausman expert report and preparing for Hausman deposition. Conferring with cocounsel and Applecon re reply report in support of class certification.

4.40 $2,970.00

10/16/14 R. Caughey Participating in call with expert witnesses re rebuttal class report. Reviewing correspondence re discovery and J. Hausman materials. Reviewing depositions in preparation for J. Hausman deposition.

1.90 $807.50

10/16/14 J. Stanley Reviewing briefing and preparing notebooks. 2.00 $540.00

10/17/14 R. Caughey Preparing for J. Hausman deposition. Reviewing Murphy transcripts and reports and analyzing same. Meeting with J. Southwick. Reviewing J. Hausman report.

2.50 $1,062.50




Tax I.D.# 74‐2138615

Conferring with R. Pfau and J. Southwick re deposition logistics.

10/17/14 J. Southwick Reviewing opposition to class certification. Working on deposition of J. Hausman.

5.40 $3,645.00

10/18/14 R. Caughey Reviewing deposition transcripts and expert materials in advance of J. Hausman deposition.

1.00 $425.00

10/19/14 R. Caughey Preparing and serving deposition notice. Conferring with J. Southwick re J. Hausman deposition. Preparing for J. Hausman deposition. Preparing legal research re benefits from anticompetitive activity. Preparing notes re deposition transcripts.

1.80 $765.00

10/19/14 J. Southwick Reviewing class certification materials. Preparing for deposition of J. Hausman.

3.70 $2,497.50

10/20/14 J. Southwick Preparing for deposition of J. Hausman. 4.90 $3,307.50

10/20/14 J. Stanley Preparing documents for deposition. 2.00 $540.00

10/20/14 R. Caughey Preparing and serving deposition notice. Conferring with J. Southwick re Hausman deposition. Preparing for Hausman deposition. Preparing legal research re benefits from anticompetitive activity. Preparing notes re deposition transcripts.

4.20 $1,785.00

10/21/14 J. Southwick Traveling to New York. Meeting with R. PFau, R. Caughey, J. Briody, S. Mussallam to prepare for deposition of J. Hausman. Preparing for deposition of J. Hausman.

11.00 $7,425.00

10/21/14 R. Caughey Meeting with J. Southwick, R. Pfau, J. Briody, and S. Musallam to prepare for J. Hausman deposition. Reviewing materials, including expert reports and deposition transcripts, in preparation for Hausman deposition. Traveling from Houston, TX to New York, NY for Hausman deposition.

10.50 $4,462.50

10/22/14 R. Caughey Attending deposition of J. Hausman. Preparing for deposition of J. Hausman. Meeting with team in connection with deposition. Reviewing deposition transcript. Conferring with R. Pfau re network effects. Conferring with J. Southwick re strategy and reply brief. Reviewing literature re network

6.50 $2,762.50




Tax I.D.# 74‐2138615

effects. Reviewing prior litigation documents and Murphy reports.

10/22/14 J. Southwick Preparing for and attending deposition of J. Hausman. Reviewing class certification cases and materials in support of reply brief.

7.20 $4,860.00

10/23/14 R. Caughey Preparing analysis for Reply brief. Reviewing Murphy, Hausman, and Overstreet materials. Reviewing summary judgment filings in prior cases. Conferring with team re briefs. Preparing legal research re Comcast issues. Traveling from New York, NY to Houston, TX.

6.20 $2,635.00

10/23/14 J. Southwick Traveling to Houston. Continuing to work on class certification reply papers.

6.80 $4,590.00

10/24/14 R. Caughey Reviewing Hausman deposition transcript. Reviewing case law for Reply brief. Conferring with J. Southwick.

1.50 $637.50

10/24/14 J. Southwick Reviewing draft reply brief from S. Berry. Working on class certification reply papers.

2.00 $1,350.00

10/26/14 J. Southwick Reviewing draft reply in support of class certification and begin preparing revisions to reply brief.

1.70 $1,147.50

10/26/14 R. Caughey Reviewing Hausman deposition transcript and preparing summary for team.

0.40 $170.00

10/27/14 R. Caughey Conferring with J. Southwick re reply in support of class certification. Preparing analysis re reply in support of class certification. Reviewing deposition materials and briefing. Participating in weekly discovery call.

3.60 $1,530.00

10/27/14 J. Southwick Working on reply in support of class certification.

4.10 $2,767.50

10/28/14 J. Southwick Participating in weekly call with cocounsel. Working with R. Caughey on draft of reply brief in support of class certification.

7.80 $5,265.00

10/28/14 R. Caughey Participating in weekly trial team call. Revising reply in support of class certification. Preparing outline of reply in support of class certification. Preparing legal research re reply in support of class

8.80 $3,740.00




Tax I.D.# 74‐2138615

certification. Reviewing pleadings and other materials in connection with preparing reply. Conferring with J. Southwick re reply.

10/28/14 R. Hess Conferring by phone with trial team. Reviewing case law.

0.70 $350.00

10/29/14 J. Southwick Working on reply in support of class certification. Conferring by phone with Applecon re rebuttal report in support of class certification.

2.90 $1,957.50

10/29/14 R. Caughey Participating in call with expert witnesses re common impact analysis. Revising reply in support of class certification. Preparing outline of reply in support of class certification. Preparing legal research re reply in support of class certification. Reviewing pleadings and other materials in connection with preparing reply. Conferring with J. Southwick re reply. Reviewing correspondence from opposing counsel. Addressing discovery issues and conferring with clients re prior‐employee representation.

9.90 $4,207.50

10/30/14 R. Caughey Revising reply in support of class certification. Preparing outline of reply in support of class certification. Preparing legal research re reply in support of class certification. Reviewing pleadings and other materials in connection with preparing reply. Conferring with J. Southwick re reply.

10.50 $4,462.50

10/30/14 J. Southwick Working on reply in support of class certification and related expert rebuttal issues.

8.20 $5,535.00

10/31/14 R. Caughey Revising reply in support of class certification. Preparing legal research re reply in support of class certification. Conferring with J. Southwick re reply.

3.10 $1,317.50

10/31/14 J. Southwick Revising and editing reply in support of class certification. Reviewing draft of economist's rebuttal report in support of class certification.

10.40 $7,020.00

11/01/14 R. Caughey Reviewing reply in support of class 0.30 $127.50




Tax I.D.# 74‐2138615

certification.

11/02/14 R. Caughey Reviewing and revising reply in support of class certification. Conferring with team re reply. Reviewing correspondence.

0.60 $255.00

11/02/14 R. Hess Reviewing draft reply. 0.50 $250.00

11/03/14 J. Southwick Reviewing and revising drafts of reply in support of class certification rebuttal report of J. Mackie‐Mason. Conferring by phone with J. Briody re finalizing and filing class certification reply brief.

3.10 $2,092.50

11/03/14 R. Caughey Reviewing correspondence re reply. Reviewing rebuttal report and offering revisions. Meeting with J. Southwick re reply. Conferring with J. Briody re reply. Participating in discovery call. Preparing legal research re antitrust impact. Meeting with J. Southwick re strategy.

2.90 $1,232.50

11/03/14 R. Hess Reviewing draft rebuttal expert report and draft reply brief. Conferring with J. Southwick re same. Conferring in office with J. Southwick re staffing.

0.90 $450.00

11/04/14 J. Southwick Participating in weekly trial team call. Reviewing revised drafts of reply in support of class certification. Conferring by phone with R. Pfau re expert's rebuttal report.

4.80 $3,240.00

11/04/14 R. Caughey Participating in management committee conference call. Reviewing expert communications and report. Reviewing correspondence re class certification hearing. Reviewing hot documents. Reviewing revised drafts of brief.

1.80 $765.00

11/04/14 J. Stanley Reviewing database for March 2005 emails. 3.00 $810.00

11/04/14 R. Hess Reviewing former hot chronology re Floorgraphics. Researching factual matters re Floorgraphics historical financials. Conferring by phone with trial team.

1.70 $850.00

11/05/14 J. Southwick Reviewing revised drafts of reply in support of class certification and revised rebuttal report of J. MacKie‐Mason.

3.60 $2,430.00

11/05/14 R. Caughey Reviewing hot documents and other 4.20 $1,785.00




Tax I.D.# 74‐2138615

documents in connection with reply in support of class certification. Conferring with R. Hess and J. Stanley re documents produced in FGI litigation and related events. Conferring with trial team re hot documents and network effects. Reviewing Goldman Sachs materials. Reviewing revised reply in support of class certification.

11/05/14 J. Stanley Reviewing database for March 2005 emails. 1.00 $270.00

11/05/14 R. Hess Reviewing and revising reply brief. Reviewing edits to reply brief in support of class certification. Reviewing subpoena from Valassis to Dial. Researching factual matters re loss of Floorgraphics retailer contracts. Revising reply brief in support of class certification.

2.50 $1,250.00

11/06/14 J. Southwick Reviewing revised expert rebuttal report. Conferring by phone with L. LeClair re revised rebuttal report. Conferring by phone with trial team re rebuttal report in support of class certification. Conferring by emails with R. Pfau re regression event study. Reviewing near final version of reply brief in support of class certification.

6.60 $4,455.00

11/06/14 R. Caughey Reviewing class reply brief and expert report. Meeting with J. Southwick re econometric analysis. Reviewing case law in connection with brief and preparing analysis re same. Conferring with team re revisions to brief. Addressing issues with BEF confidentiality.

3.00 $1,275.00

11/06/14 R. Hess Preparing edits to reply brief. Reviewing emails re draft reply report. Conferring with trial team re same. Revising reply brief. Conferring with J. Briody via email re same.

1.70 $850.00

11/07/14 B. Rosenthal Conferring with J. Southwick , R. Caughey and M. Fisher.

0.75 $225.00

11/07/14 R. Caughey Addressing final revisions to reply in support of class certification. Conferring with team re same. Reviewing final draft of expert report. Conferring with J. Briody and J. Smith

3.00 $1,275.00




Tax I.D.# 74‐2138615

re revisions to final draft of report. Meeting with J. Southwick, B. Rosenthal, and M. Fisher re case status and strategy. Conferring with client contacts re former employees.

11/07/14 J. Southwick Reviewing emails re class certification reply and filing. Meeting with R. Caughey, M. Fisher, and B. Rosenthal to discuss merits and B Rosenthal's role.

2.40 $1,620.00

11/08/14 R. Hess Reviewing correspondence from opposing counsel. Reviewing redacted version of briefing. Reviewing discovery letter.

0.50 $250.00

11/10/14 R. Caughey Participating in weekly discovery call. Reviewing documents. Meeting with B. Rosenthal and M. Fisher re discovery projects. Conferring with team re tasks.

1.20 $510.00

11/10/14 J. Stanley Reviewing documents for R. Caughey. Updating fees/expense chart.

2.00 $540.00

11/10/14 M. Fisher Attending teleconference with R. Caughey and associates.

0.50 $137.50

11/10/14 B. Rosenthal Conferring by phone with R. Caughey and M. Fisher re merits discovery, document review, and deposition strategy for Newscorp.

0.50 $150.00

11/10/14 B. Rosenthal Reviewing file, including class certification papers.

1.75 $525.00

11/11/14 J. Southwick Participating in weekly call with cocounsel. Conferring by phone with J. Briody re communications and discussions with Valassis. Reviewing and responding to email.

2.00 $1,350.00

11/11/14 M. Fisher Reviewing documents for NAM document review.

1.30 $357.50

11/11/14 B. Rosenthal Conferring by phone with management committee re merits discovery.

0.75 $225.00

11/11/14 B. Rosenthal Reviewing file, in particular class certification papers.

1.00 $300.00

11/11/14 B. Rosenthal Conferring by phone with R. Caughey re merits discovery and hot document review.

0.25 $75.00

11/11/14 B. Rosenthal Reviewing documents for merits matters in Newscorp case.

2.00 $600.00




Tax I.D.# 74‐2138615

11/11/14 R. Caughey Participating in weekly management committee call. Conferring with team re issues. Conferring with B. Rosenthal re strategy. Meeting with J. Southwick re Valassis and merits discovery. Conferring with team re hot documents. Reviewing documents and addressing discovery issues.

3.10 $1,317.50



3.10 $852.50

11/12/14 B. Rosenthal Reviewing documents for merits discovery. 2.50 $750.00

11/12/14 R. Caughey Reviewing G. Henderson and L. Sutherland deposition transcripts and taking notes re same. Reviewing documents. Conferring with team re document review and discovery projects.

4.20 $1,785.00


1.60 $440.00

11/13/14 B. Rosenthal Conferring by email with R. Caughey re merits discovery.

0.25 $75.00

11/13/14 B. Rosenthal Reviewing documents for merits discovery. 2.17 $651.00

11/13/14 R. Caughey Reviewing hot documents. Conferring with B. Rosenthal re hot document review and ISP hot documents. Reviewing deposition transcripts. Conferring with team re tasks. Addressing discovery issues. Conferring with clients. Preparing research re retailer project

3.00 $1,275.00

11/14/14 B. Rosenthal Conferring by phone with management committee re merits discovery and merits expert report.

0.83 $249.00

11/14/14 B. Rosenthal Conferring by phone with R. Caughey and Samer Musallam from Paul Hastings re merits discovery and merits expert report.

1.00 $300.00

11/14/14 J. Southwick Preparing for and participating in call with trial team and Applecon re plan for preparing expert reports on merits issues.

1.10 $742.50

11/14/14 R. Caughey Reviewing deposition transcripts. Reviewing hot documents. Participating in call with experts re tasks. Conferring with S. Musallem and B. Rosenthal re tasks and

3.00 $1,275.00




Tax I.D.# 74‐2138615

strategy.

11/16/14 B. Rosenthal Reviewing documents re merits discovery of New production.

1.25 $375.00

11/17/14 R. Caughey Conferring with team re hot document review and case map. Participating in weekly discovery call. Conferring with B. Rosenthal re discovery. Reviewing hot documents and populating Case Map spreadsheet. Conferring with team re discovery.

2.70 $1,147.50

11/17/14 J. Southwick Reviewing and responding to emails re merits discovery and potential meeting with Valassis.

0.50 $337.50

11/17/14 B. Rosenthal Reviewing documents for merits discovery re retailer contracts and competition with Valassis.

3.67 $1,101.00

11/17/14 B. Rosenthal Conferring by phone with management committee and R. Caughey.

0.75 $225.00

11/18/14 J. Stanley Preparing documents for R. Caughey to review.

1.00 $270.00

11/18/14 B. Rosenthal Conferring by phone with management committee about merits discovery on weekly conference call.

0.50 $150.00

11/18/14 B. Rosenthal Reviewing documents for merits discovery, focusing on NAM's retailer relationships and in‐store product pricing.

3.67 $1,101.00

11/18/14 B. Rosenthal Preparing correspondence to R. Caughey, J. Southwick , R. Hess re findings in merits discovery.

0.75 $225.00

11/18/14 R. Caughey Reviewing hot documents and preparing research for retailer project. Populating CaseMap. Participating in weekly management committee call. Conferring with B. Rosenthal re issues. Addressing discovery issues with clients.

3.50 $1,487.50

11/18/14 J. Southwick Preparing for and participating in weekly call with trial team. Reviewing materials re potential deponents. Conferring by email re potential meeting with counsel for Valassis. Reviewing and responding to emails re merits discovery from B. Rosenthal.

4.00 $2,700.00




Tax I.D.# 74‐2138615

11/19/14 B. Rosenthal Reviewing documents for merits discovery re retailer exclusivity and pricing.

2.75 $825.00

11/19/14 R. Caughey Reviewing hot documents. Conferring with J. Southwick and B. Rosenthal re fact development and strategy. Populating CaseMap. Meeting with J. Southwick re discovery strategy. Reviewing letters re depositions. Preparing factual research. Conferring with B. Rosenthal re tasks.

3.10 $1,317.50

11/19/14 J. Southwick Reviewing and responding to emails re merits discovery issues with SG trial team. Reviewing materials re potential deponents. Reviewing and responding to emails re use of depositions from prior cases and related draft letter to News.

2.90 $1,957.50

11/20/14 B. Rosenthal Reviewing documents for merits discovery re retail contracts.

3.33 $999.00

11/20/14 R. Caughey Conferring with B. Rosenthal re fact investigation tasks. Reviewing hot documents and retailer documents. Preparing analysis in connection with potential depositions.

3.20 $1,360.00

11/21/14 J. Stanley Conferring with R. Caughey and K. Brown re witness files.

0.40 $108.00

11/21/14 B. Rosenthal Conferring by phone with management committee re merits discovery and potential deponents.

0.50 $150.00

11/21/14 B. Rosenthal Conferring by phone with R. Caughey and J. Southwick re potential deponents.

0.25 $75.00

11/21/14 B. Rosenthal Reviewing documents to identify potential deponents.

2.00 $600.00

11/21/14 R. Hess Conferring by phone with trial team re discovery plan.

0.40 $200.00

11/21/14 R. Caughey Preparing analysis re potential deponents. Preparing memorandum to team re deponents. Conferring with J. Southwick and B. Rosenthal re deponents. Participating in team call re discovery priorities and merits report. Conferring with J. Stanley re tasks.

3.30 $1,402.50

11/21/14 J. Southwick Preparing for and participating in call with 1.90 $1,282.50




Tax I.D.# 74‐2138615

trial team re merits discovery discussion with R. Caughey and B. Rosenthal re selection of deponents and scheduling.

11/23/14 R. Hess Conferring by phone with J. Carter re ethical duties in receiving non‐confidential information from former employees. Conferring by phone with J. Southwick re deposition strategy.

0.70 $350.00

11/24/14 B. Rosenthal Conferring by phone with co‐counsel associates re merits discovery and depositions.

0.50 $150.00

11/24/14 R. Hess Reviewing court orders and conferring by phone with potential witness. Conferring by phone with J. Carter re ethical duties in receiving non‐confidential information from former employees.

0.70 $350.00

11/24/14 R. Caughey Reviewing documents in advance of depositions. Updating CaseMap with reviewed documents from Valassis production. Conferring with team re upcoming depositions. Participating in weekly discovery call. Conferring with J. Stanley and K. Briggs re documents. Conferring with J. Southwick re strategy.

3.70 $1,572.50

11/25/14 B. Rosenthal Conferring by phone with management committee re first round of depositions.

0.42 $126.00

11/25/14 R. Hess Reviewing documents. Conferring by phone with potential witness. Conferring by phone with trial team. Reviewing draft correspondence to opposing counsel. Conferring in office with R. Caughey re potential avenues of fact inquiry.

2.20 $1,100.00

11/25/14 J. Stanley Preparing documents for R. Hess to review. 1.00 $270.00

11/25/14 R. Caughey Participating in weekly management committee call. Meeting with R. Hess re discovery strategy. Preparing discovery letter to opposing counsel.

2.50 $1,062.50

11/26/14 B. Rosenthal Researching factual matters re NAM retail contracts and pricing. Reviewing and looking for evidence requested by experts for merits report.

4.50 $1,350.00




Tax I.D.# 74‐2138615

11/26/14 R. Hess Conferring by phone with potential witness. 0.60 $300.00

11/30/14 B. Rosenthal Reviewing documents re retailer contracts and information requested by AppleEcon for expert merits report.

1.00 $300.00

12/01/14 B. Rosenthal Conferring by phone with management committee and experts re expert merits report. Conferring by phone with associates re merits discovery.

1.00 $300.00

12/01/14 B. Rosenthal Reviewing documents re retailer contracts and predation for expert merits report.

1.00 $300.00

12/01/14 R. Caughey Participating in call with experts re merits report. Participating in weekly discovery call. Conferring with B. Rosenthal re tasks. Meeting with M. Fisher re retailer project. Addressing document and deposition issues. Addressing issues with privilege logs.

1.80 $765.00

12/02/14 B. Rosenthal Conferring by phone with management committee re ongoing discovery projects and expert needs.

0.25 $75.00

12/02/14 B. Rosenthal Conferring by email with expert Rick Pfau re NAM's predatory and exclusionary tactics against competition for retailer contracts.

0.33 $99.00

12/02/14 B. Rosenthal Reviewing documents for merits discovery. Reviewing for evidence of predatory and exclusionary tactics against competition for retailers.

2.75 $825.00

12/02/14 J. Southwick Conferring by phone with Applecon re merits report on liability and damages.

0.40 $270.00

12/02/14 J. Stanley Reviewing documents. 1.00 $270.00

12/03/14 B. Rosenthal Reviewing documents re retailer contracts and internal NAM communications re potential anticompetitive conduct. Conferring by phone with management committee re cooperation with Valassis on discovery. Preparing for mock trial, specifically, questions for moot class certification hearing.

4.25 $1,275.00

12/03/14 J. Southwick Reviewing emails and spreadsheets re merits experts reports. Preparing for and participating in call with cocounsel re

2.10 $1,417.50




Tax I.D.# 74‐2138615

upcoming meeting with Valassis.

12/03/14 R. Caughey Conferring with J. Stanley re Emmel documents. Participating in call re Valassis meeting. Addressing issues with discovery and documents. Reviewing correspondence. Preparing questions in advance of class certification hearing. Conferring with clients re production to Valassis.

1.10 $467.50

12/04/14 B. Rosenthal Reviewing documents for merits discovery. Reviewing and looking for retailer agreements and evidence of predation. Reviewing brief re class certification to prepare questions for class certification moot.

2.50 $750.00


1.10 $302.50

12/04/14 R. Caughey Addressing discovery issues. Conferring with team re discovery tasks. Reviewing communications re expert analysis.

0.40 $170.00

12/04/14 J. Southwick Reviewing email correspondence. Reviewing docket and filings in Valassis case in preparation for meeting in Michigan with Valassis counsel.

4.90 $3,307.50

12/04/14 V. Lee Loading data into the News_Garofalo Eclipse database.

0.50 $62.50

12/05/14 B. Rosenthal Reviewing documents with keyword searches in database for "toehold" or "foothold". Reviewing and looking for NAM correspondence re excluding competitors from getting established in retailer market. Conferring by email with expert and conferring with R. Caughey re same. Reviewing transcript of Christ Mixson's deposition from 2008.

4.75 $1,425.00


8.20 $2,255.00

12/05/14 J. Southwick Traveling to Detroit. Meeting with Valassis counsel. Traveling to Houston.

10.00 $6,750.00


1.50 $187.50




Tax I.D.# 74‐2138615

12/06/14 R. Caughey Conferring with R. Boyce (Foster Farms) re discovery matters and subpoenas. Conferring with team re Valassis issues. Reviewing documents. Preparing for class cert hearing by assisting J. Southwick. Conferring with opposing counsel re deponents.

1.50 $637.50

12/07/14 R. Caughey Conferring with team re document review and retailers. Conferring with opposing counsel. Addressing discovery issues.

0.50 $212.50

12/08/14 R. Caughey Participating in weekly discovery call. Conferring with J. Southwick re status. Conferring with B. Rosenthal and M. Fisher re tasks and retailers. Reviewing retailer memoranda.

1.60 $680.00

12/08/14 B. Rosenthal Reviewing documents, specifically, Mixson deposition transcript, Valassis production, and Goldman Sachs production. Conferring by email with R. Caughey re discovery assignments. Preparing for oral argument on class certification with potential questions and answers. Conferring by phone with co‐counsel associates re discovery assignments.

7.67 $2,301.00

12/08/14 J. Stanley Updating fees and expenses chart. 1.00 $270.00

12/09/14 R. Caughey Participating in weekly management committee call. Meeting with J. Southwick and B. Rosenthal re oral argument prep. Reviewing Goldman Sachs documents circulated by B. Rosenthal. Reviewing correspondence from team and docket. Conferring with opposing counsel re depositions.

2.30 $977.50

12/09/14 B. Rosenthal Reviewing documents from Goldman Sachs production. Conferring by email with R. Caughey, J. Southwick, and cocounsel re retailer renewal commissions. Conferring by phone with J. Southwick and R. Caughey re preparation for class certification hearing.

5.83 $1,749.00

12/09/14 J. Southwick Reviewing class certification materials. Preparing for class certification moot court session in New York. Conferring by phone

5.70 $3,847.50




Tax I.D.# 74‐2138615

and emails with R. Caughey and B. Rosenthal re class certification moot court preparation.

12/10/14 J. Southwick Traveling to New York City. 3.40 $2,295.00

12/10/14 J. Southwick Preparing for and meeting with cocounsel to prepare for class certification oral argument.

7.00 $4,725.00

12/10/14 B. Rosenthal Attending mock trial class certification by phone. Reviewing documents re NAM's quarterly retail fact book and retailer commission strategy.

3.92 $1,176.00


8.40 $2,310.00

12/10/14 R. Caughey Participating in prep session for oral argument on class certification. Reviewing documents. Conferring with opposing counsel re depositions and discovery. Conferring with B. Rosenthal re issues.

2.10 $892.50

12/10/14 R. Hess Conferring with J. Southwick and R. Caughey re class certification moot.

0.10 $50.00


0.30 $37.50

12/11/14 B. Rosenthal Reviewing class certification argument powerpoint presentation. Reviewing documents in Goldman Sachs production re Capital IQ and retailer commissions. Conferring by email with R. Caughey and J. Southwick re next round of potential NAM deponents. Conferring by phone with co‐counsel S. Musallam re Capital IQ references in Goldman Sachs porduction.

2.75 $825.00


8.90 $2,447.50

12/11/14 R. Caughey Preparing communications re deponents and depositions. Conferring with team re discovery issues.

0.50 $212.50


2.40 $300.00


8.40 $2,310.00

12/12/14 R. Caughey Reviewing correspondence re class certification hearing. Communicating with

0.50 $212.50




Tax I.D.# 74‐2138615

opposing counsel re depositions. Addressing discovery issues.

12/12/14 J. Southwick Attending hearing on class certification and discussing hearing with trial team. Traveling to Houston.

10.20 $6,885.00

12/12/14 V. Lee Loading data into the News_Garofalo and News_Emmel Eclipse databases.

2.30 $287.50

12/13/14 R. Caughey Conferring with opposing counsel re depositions.

0.30 $127.50

12/15/14 R. Caughey Participating in weekly discovery call. Conferring with J. Southwick and S. Musallem re class certification hearing. Conferring with team re discovery and depositions. Reviewing memoranda re retailer contracts.

2.80 $1,190.00

12/15/14 J. Southwick Conferring with R. Caughey re class certification. Reviewing and responding to email correspondence.

2.00 $1,350.00

12/15/14 B. Rosenthal Reviewing documents from Goldman Sacs production re NAM financials and plans. Conferring by phone with co‐counsel associates re ongoing discovery, last week's class certification hearing, and upcoming deadlines.

1.50 $450.00


9.00 $2,475.00

12/15/14 V. Lee Loading data into the News_Garofalo and the News_Emmel Eclipse databases.

3.30 $412.50

12/16/14 J. Southwick Participating in weekly trial team call. Reviewing Goldman Sachs materials. Conferring by phone and emails with B. Rosenthal.

3.30 $2,227.50

12/16/14 B. Rosenthal Conferring by phone with NAM management committee on weekly conference call. Reviewing documents in the Goldman Sachs production re Project Neptune valuation of NAM. Reviewing transcript of class certification hearing. Conferring by phone with J. Southwick re findings in Goldman Sachs production. Conferring by email with J. Southwick, R.

8.33 $2,499.00




Tax I.D.# 74‐2138615

Caughey, and cocounsel re findings in Goldman Sachs production.

12/16/14 V. Lee Loading data into the News_Garofalo and News_Emmel Eclipse databases.

0.60 $75.00

12/16/14 R. Hess Conferring by phone with trial team. Reviewing transcript class certification hearing.

0.60 $300.00

12/16/14 R. Caughey Participating in management committee call. Analyzing potential deponents and circulating list to team. Conferring with clients re interviews with experts. Conferring with B. Rosenthal re Goldman Sachs documents and tasks. Preparing search for and analysis of Kmart and SuperValu documents, including by reviewing Garofalo documents. Reviewing transcript of hearing.

3.90 $1,657.50

12/17/14 J. Southwick Conferring by phone with Applecon re progress on merits report. Conferring with cocounsel re depositions and scheduling. Reviewing documents from Goldman Sachs production. Conferring by emails and calls with R. Caughey and B. Rosenthal re Goldman Sachs documents.

4.40 $2,970.00

12/17/14 B. Rosenthal Conferring by email with J. Southwick and R. Caughey re Project Neptune findings in Goldman Sachs production. Conferring by phone with management committee and experts re status of experts merit report. Reviewing documents in Goldman Sachs production.

2.25 $675.00

12/17/14 R. Hess Conferring by phone with potential witness. Conferring in office with J. Southwick re same. Reviewing injunction.

0.60 $300.00

12/17/14 J. Stanley Assembling documents for Emmel witness file.

1.00 $270.00

12/17/14 R. Caughey Participating in call with experts re merits report. Reviewing documents in connection with identifying potential deponents. Reviewing documents in connection with retailer project. Conferring with team re Goldman Sachs documents.

2.90 $1,232.50




Tax I.D.# 74‐2138615

12/18/14 J. Southwick Reviewing and responding to emails re deposition scheduling. Conferring by phone with S. Benz re deposition scheduling. Reviewing and responding to emails re News's request for an agreed stay of merits discovery pending class certification decision. Conferring with J. Stanley re database issues and preparing for merits depositions.

2.60 $1,755.00

12/18/14 B. Rosenthal Reviewing documents from Goldman Sachs production and compiling and annotating hot documents from this production. Conferring by phone with R. Caughey, experts, and client representative from BEF re BEF's in‐store ad buying.

4.25 $1,275.00

12/18/14 R. Caughey Preparing analysis of potential deponents. Preparing research re retailers and deponents. Conferring with J. Southwick and B. Rosenthal re depositions and discovery. Participating in call with BEF and experts re ISP purchases. Organizing calls with experts.

3.70 $1,572.50

12/19/14 B. Rosenthal Reviewing documents in Goldman Sachs production. Conferring by phone with R. Caughey re Supervalue and K‐mart retailer discovery, potential deponents, and status of Goldman Sachs production report.

4.25 $1,275.00

12/19/14 J. Southwick Reviewing potential deponents with R. Caughley and emails re next round of deponents to request from NAM.

1.60 $1,080.00

12/19/14 R. Caughey Participating in conference call re CaseMap and documents. Reviewing hot documents. Addressing issues with depositions and conferring with opposing counsel re deponents and depositions. Conferring with team and preparing memoranda re potential witnesses. Reviewing documents in connection with analyzing Kmart negotiations. Reviewing documents in connection with identifying deponents. Participating in call with clients and experts re CPG purchasing.

4.90 $2,082.50

12/21/14 B. Rosenthal Reviewing documents in Goldman Sachs 3.50 $1,050.00




Tax I.D.# 74‐2138615

production. Preparing and reviewing email to cocounsel re hot documents from Goldman Sachs production. Reviewing documents re Supervalue contracts.

12/22/14 B. Rosenthal Reviewing documents re NAM's losing business of retailer Supervalu. Preparing correspondence to cocounsel re Supervalu documents. Preparing correspondence to cocounsel re Goldman Sachs production.

4.75 $1,425.00

12/22/14 M. Fisher Preparing for and meeting with J. Southwick, R. Caughey, R. Hess, T. Saunders, J. Stanley.

1.20 $330.00

12/22/14 J. Stanley Conferring with trial team re upcoming tasks.

1.00 $270.00

12/22/14 R. Caughey Participating in team meeting re documents, next tasks, and depositions. Conferring with opposing counsel re depositions. Conferring with K. Briggs and J. Stanley re document tasks. Preparing memorandum to team re document issues.

2.50 $1,062.50

12/23/14 B. Rosenthal Conferring by email with cocounsel re issues implicated by Supervalu hot documents.

0.42 $126.00

12/23/14 J. Southwick Preparing for and attending weekly trial team call.

1.00 $675.00

12/23/14 R. Caughey Drafting, revising, and circulating memorandum summarizing Kmart negotiations. Conferring with team re discovery tasks. Addressing issues relating to our representation of former CPG employees.

4.80 $2,040.00

12/29/14 R. Caughey Participating in weekly associate discovery call. Reviewing deposition memoranda in connection with Kroc deposition. Conferring with clients re former employees.

1.00 $425.00



0.50 $137.50

12/30/14 B. Rosenthal Conferring by phone with management committee on weekly call. Conferring by email with R. Caughey re upcoming discovery tasks.

0.58 $174.00




Tax I.D.# 74‐2138615

12/30/14 R. Caughey Participating in weekly management committee call. Conferring with team re former employee witnesses. Addressing discovery issues. Conferring with Foster Farms and Bob Evans.

1.50 $637.50

12/31/14 B. Rosenthal Conferring with R. Caughey, J. Southwick, and R. Hess re contacting and representing clients' recently departed employees with knowledge about the case.

0.58 $174.00

12/31/14 J. Southwick Conferring by phone with R. Hess. R. Caughley and B. Rosenthal re representing former employees of Bob Evans Farms.

0.20 $135.00

12/31/14 R. Caughey Conferring with team re former employee witnesses. Reviewing disclosures and conferring with clients re former employees. Addressing discovery issues.

1.20 $510.00

01/05/15 B. Rosenthal Conferring by phone with cocounsel re discovery and depositions. Interviewing former employees re knowledge of in‐store advertising. Conferring by email with J. Southwick and R. Caughey re former employees and Supervalu retailers. Researching whereabouts of certain former employees as potential witnesses.

2.84 $923.00

01/05/15 J. Southwick Reviewing memorandums from trial team re retailer contract negotiations.

3.30 $2,310.00

01/05/15 R. Caughey Conferring with team re contacting former employees. Conferring with team re discovery matters. Reviewing correspondence from opposing counsel.

0.30 $142.50

01/06/15 B. Rosenthal Conferring by phone with management committee re discovery, depositions, former client employees, and expert report.

0.58 $188.50

01/06/15 J. Southwick Participating in weekly trial team call. Reading draft expert report from Applecon.

6.40 $4,480.00

01/07/15 B. Rosenthal Interviewing former employee Sam Cohen re experience at Foster Farms and working with NAM. Researching factual matters in effort to locate other former employees of Foster Farms and attempting contact.

2.75 $893.75

01/07/15 M. Fisher Reviewing documents for NAM document 1.50 $412.50




Tax I.D.# 74‐2138615

review.

01/07/15 J. Southwick Reviewing draft expert report from J. Mackie‐Mason.

2.10 $1,470.00

01/08/15 J. Southwick Reviewing draft expert report from J. Mackie‐Mason. Conferring by phone with cocounsel and Applecon to discuss draft expert report.

5.80 $4,060.00

01/08/15 B. Rosenthal Interviewing former Foster Farms employee M. Perry Russell re experience at FF working with NAM.

0.42 $136.50

01/09/15 J. Southwick Reviewing draft expert report from Applecon. Conferring by emails with trial team re meeting with Valassis.

3.10 $2,170.00

01/09/15 B. Rosenthal Attempting to contact former employees of Foster Farms and B. Evans as potential witnesses on initial disclosures.

0.75 $243.75

01/12/15 J. Southwick Conferring with R. Caughey re deposition assignments. Reviewing and responding to email.

1.00 $700.00

01/12/15 B. Rosenthal Conferring by phone with cocounsel on weekly discovery call. Contacting former employees listed as potential witnesses. Reviewing draft report from Farris. Preparing email correspondence to former employees.

3.75 $1,218.75

01/12/15 J. Stanley Updating fee/expense chart. Conferring with court reporter re upcoming depositions. Updating deposition files.

2.40 $648.00


3.80 $1,045.00

01/12/15 R. Caughey Meeting with J. Southwick re M. Garofalo deposition. Making arrangements for M. Garofalo deposition. Participating in weekly discovery call. Preparing for M. Garofalo deposition. Addressing issues with former employees. Preparing correspondence to opposing counsel re former employees and representation. Reviewing expert reports.

3.50 $1,662.50

01/12/15 V. Lee Creating and loading documents into the News_BEF Privilege and the News_Foster

1.10 $137.50




Tax I.D.# 74‐2138615

Farms Privilege Eclipse databases.

01/13/15 J. Stanley Reviewing documents. Preparing documents for attorney review.

2.00 $540.00

01/13/15 B. Rosenthal Conferring by phone with management committee on weekly call. Conferring by phone with cocounsel and experts re Dr. Farris' concerns about network effects. Contacting clients' former employees listed as potential witnesses. Conferring by phone with R. Caughey re reviewing document production for privileged material.

2.84 $923.00

01/13/15 M. Fisher Conferring by phone with News Litigation Team.

0.60 $165.00

01/13/15 R. Caughey Addressing issues relating to former employees. Participating in management committee call. Addressing document privilege issues. Conferring with M. Fisher. Conferring with BEF re representation of former employees. Reviewing documents for privilege. Conferring with former employees re representation and conferring with B. Rosenthal re same. Participating in call with experts re retailer contracts.

4.20 $1,995.00

01/13/15 J. Southwick Participating in weekly trial team call. Reviewing emails re former employee interview and representing former employees of class plaintiffs. Reviewing draft expert reports. Conferring by phone with Applecon to discuss draft report.

6.70 $4,690.00

01/14/15 J. Southwick Conferring by phone with S. Mussallam re expert report of P. Farris. Reviewing and responding to emails re deposition scheduling.

0.30 $210.00


01/14/15 M. Fisher Reviewing Foster Farms privileged documents.

5.50 $1,512.50

01/14/15 R. Caughey Conferring with opposing counsel re representation of former employees. Conferring with clients re representation of former employees. Reviewing documents for privilege. Addressing discovery issues

3.80 $1,805.00




Tax I.D.# 74‐2138615

with opposing counsel.

01/15/15 J. Southwick Reviewing revised expert report and exhibits from Applecon. Conferring on calls and emails re revised expert report. Conferring by phone with P. Farris, A. Fazzone, and S. Musallem re P. Farris expert report.

7.20 $5,040.00

01/15/15 J. Stanley Reviewing documents. Preparing documents for J. Southwick to review.

4.00 $1,080.00

01/15/15 R. Caughey Reviewing deposition transcripts re trade promotions testimony. Conferring with J. Southwick re statute of limitations arguments and related issues.

2.90 $1,377.50

01/15/15 V. Lee Updating the News_Foster Farms Privilege Eclipse database.

1.00 $125.00

01/16/15 J. Stanley Updating fee and expense chart. 1.00 $270.00

01/16/15 J. Southwick Reviewing expert report from J. Mackie Mason and related emails. Reviewing statute of limitations issue from contracts and letters of commitment.

3.30 $2,310.00

01/19/15 R. Caughey Conferring with co‐counsel and opposing counsel re deposition schedule.

0.30 $142.50

01/20/15 R. Caughey Reviewing documents for privilege and conferring with team re same. Participating in weekly management committee call. Conferring with B. Rosenthal and S. Musallem re discovery. Addressing issues relating to Goldman Sachs deposition. Conferring with opposing counsel re depositions. Reviewing hot documents.

4.40 $2,090.00

01/20/15 J. Southwick Participating in weekly trial team call. Conferring with B. Rosenthal re Goldman Sachs documents and related emails re need for Goldman Sachs deposition and expert reliance on inadmissible materials. Reviewing case map materials.

5.10 $3,570.00

01/20/15 J. Southwick Participating in weekly trial team call. Conferring by phone with B. Rosenthal re Goldman Sachs documents and related emails re need for Goldman Sachs deposition and expert reliance on inadmissible materials. Reviewing case map

5.10 $3,570.00




Tax I.D.# 74‐2138615

materials.

01/20/15 B. Rosenthal Conferring by phone with management committee on weekly calls. Reviewing file on Goldman Sachs production to determine potential deponents. Conferring by phone with J. Southwick re Goldman Sachs deponents. Conferring by email with trial team re Goldman Sachs depositions. Conferring by phone with associates on weekly discovery call re privilege logs and third party depositions.

2.20 $715.00

01/20/15 M. Fisher Conferring by phone with News Litigation Team. Reviewing Foster Farm documents for second level privilege review.

7.60 $2,090.00

01/20/15 J. Stanley Preparing expert report notebook. Reviewing expert report for documents cited.

2.60 $702.00

01/21/15 B. Rosenthal Reviewing documents from Bob Evans production for privilege. Conferring by email with R. Caughey and J. Southwick re potential deposition of Goldman Sachs personnel.

1.20 $390.00

01/21/15 R. Caughey Meeting with J. Southwick re tasks and strategy. Conferring with M. Fisher re document review. Reviewing documents for privilege. Meeting with J. Stanley re privilege logs. Conferring with opposing counsel and co‐counsel re depositions. Addressing deposition issues.

2.90 $1,377.50

01/21/15 L. Eccles Conferring with J. Southwick re case background. Reviewing file and drafting internal memo re case strategy.

2.40 $1,200.00

01/21/15 M. Fisher Conferring by phone with News Litigation Team. Reviewing Bob Evans Farm documents for second level privilege review.

3.40 $935.00

01/21/15 J. Stanley Updating privilege log. Preparing materials for L.G. Eccles.

6.40 $1,728.00

01/21/15 J. Southwick Reviewing CaseMap. Conferring by emails to trial team re discovery issues, especially materials from Goldman Sachs.

2.90 $2,030.00

01/22/15 B. Rosenthal Reviewing documents for privileged 3.50 $1,137.50




Tax I.D.# 74‐2138615

material. Conferring by email with J. Southwick, R. Caughey, and co‐counsel re potential Goldman Sachs deposition.

01/22/15 R. Caughey Reviewing documents for privilege and conferring with team re same. Addressing deposition issues with team and opposing counsel. Preparing research re evidentiary issues and addressing issues with Goldman Sachs documents.

2.90 $1,377.50

01/22/15 J. Stanley Preparing documents that are cited in expert report for review. Updating privilege log.

7.00 $1,890.00

01/22/15 J. Southwick Conferring by phone with L. Eccles re background and nature of case. Preparing for meeting with Valassis counsel.

2.20 $1,540.00

01/23/15 B. Rosenthal Researching points of law re applicability of business‐records exception to hearsay to Goldman Sachs documents. Preparing and reviewing email to J. Southwick and R. Caughey re same.

2.50 $812.50

01/23/15 R. Caughey Conferring with L. Eccles re casemap summary. Addressing discovery issues with team and opposing counsel and conferring with B. Rosenthal re same.

1.50 $712.50

01/23/15 L. Eccles Reviewing file and developing issues outline. 0.60 $300.00

01/23/15 J. Southwick Traveling to Detroit. Traveling to Houston 6.00 $4,200.00

01/23/15 J. Southwick Meeting with Valassis counsel. 4.50 $3,150.00

01/23/15 J. Stanley Updating privilege log and documents cited by expert.

6.00 $1,620.00

01/25/15 R. Caughey Conferring with team and opposing counsel re depositions.

0.20 $95.00

01/25/15 L. Eccles Reviewing file and developing issues outline. 2.60 $1,300.00

01/26/15 J. Stanley Updating privilege log. 3.00 $810.00

01/26/15 R. Caughey Reviewing BEF privilege documents and conferring with J. Stanley re same. Participating in weekly associates' discovery call. Conferring with opposing counsel re discovery and depositions. Reviewing discovery plan.

1.90 $902.50

01/26/15 L. Eccles Reviewing file and developing proof outline. 4.70 $2,350.00




Tax I.D.# 74‐2138615

01/27/15 V. Lee Updating the News_Garofalo and the News_Foster Farms Privilege Eclipse databases.

2.70 $337.50

01/27/15 B. Rosenthal Conferring by phone with management committee on weekly call. Preparing business records affidavits for Goldman Sachs personnel.

1.60 $520.00

01/27/15 R. Caughey Conferring with K. Briggs re custodian documents in advance of depositions. Participating in weekly management committee call. Reviewing information re contacting class members. Addressing deposition scheduling and document issues. Preparing legal analysis re contact with absent class members by defendants.

1.80 $855.00

01/27/15 L. Eccles Participating in weekly trial team call. Reviewing case file. Reviewing and drafting email. Drafting trial outline.

1.50 $750.00

01/27/15 J. Southwick Participating in weekly trial team call. Discussing and emails re News contacting absent class members.

2.20 $1,540.00

01/27/15 J. Stanley Updating privilege logs. 4.00 $1,080.00


0.50 $137.50

01/28/15 J. Southwick Reviewing materials re defendants contacting absent class members. Conferring with B. Rosenthal.

1.10 $770.00

01/28/15 V. Lee Updating the News_Garofalo Eclipse database.

1.70 $212.50

01/28/15 B. Rosenthal Conferring by phone with J. Southwick re potential motion to prevent NAM from contacting absentee class members. Researching points of law re same.

1.70 $552.50

01/28/15 R. Caughey Conferring with team re discussions with opposing counsel. Addressing deposition issues. Addressing privilege log and discovery issues. Reviewing deposition transcripts.

2.10 $997.50

01/28/15 J. Stanley Conferring with V. Lee and K. Briggs re document issues. Updating privilege log.

4.00 $1,080.00




Tax I.D.# 74‐2138615

01/29/15 B. Rosenthal Researching points of law and Preparing memorandum to J. Southwick, R. Caughey, and L. Godfrey re limiting NAM's contact with absentee class members. Conferring by phone with J. Southwick re same.

5.90 $1,917.50

01/29/15 R. Caughey Addressing issues with depositions and privilege logs. Preparing analysis re contacting former employees. Conferring with team re discovery and former employees.

1.10 $522.50

01/29/15 L. Eccles Reviewing trial team email. 0.20 $100.00


01/30/15 B. Rosenthal Conferring by phone with L.G. Eccles re options for limiting NAM's contact of absentee class members. Conferring by email with J. Southwick, L.G. Eccles, R. Caughey, and co‐counsel re same.

1.20 $390.00

01/30/15 R. Caughey Addressing issues with privilege logs and conferring with J. Stanley re same. Addressing deposition scheduling issues. Conferring with in‐house counsel re representation of former employees.

0.60 $285.00

01/30/15 L. Eccles Participating in teleconference with B. Rosenthal re research on communications with absent class members by defendants.

0.30 $150.00

01/30/15 J. Southwick Preparing for and participating in telephone hearing with Judge Pauley re pre‐motion letter discovery dispute between NAM and subpoenas to McAndrews & Forbes and Harland Clarke. Conferring by email to trial team re hearing. Reviewing B. Rosenthal research on NAM contacting absent class members. Drafting email to trial team concerning appropriateness of interrogatory to NAM and likely related motion practice.

2.80 $1,960.00


01/30/15 M. Fisher Preparing and conferring by phone with News Litigation Team for court teleconference.

1.00 $275.00

02/01/15 R. Caughey Conferring with team re deposition scheduling and conferring with opposing

0.60 $285.00




Tax I.D.# 74‐2138615

counsel re same. Conferring with former employees re representation.

02/02/15 J. Southwick Reviewing emails re discovery. Conferring with D. Goldman re Kramer Levin.

0.60 $420.00

02/02/15 B. Rosenthal Conferring by phone with co‐counsel associates on weekly discovery call.

0.20 $65.00

02/02/15 R. Caughey Conferring with D. Hadley re representation. Addressing document discovery issues. Conferring with team re former employees. Conferring with opposing counsel re scheduling. Participating in weekly discovery call. Meeting with J. Southwick re tasks.

2.00 $950.00

02/02/15 L. Eccles Reviewing case map. Emailing trial team. 2.10 $1,050.00


02/03/15 B. Rosenthal Conferring by phone with trial team on weekly call. Conferring by phone with J. Briody from McKool re Goldman Sachs business records affidavits.

0.93 $302.25

02/03/15 R. Caughey Participating in weekly management committee call. Conferring with team re depositions and discovery. Addressing document discovery issues.

1.30 $617.50

02/03/15 L. Eccles Participating in trial team weekly call. Reviewing case map, file and emails.

0.80 $400.00


0.40 $110.00


02/03/15 J. Southwick Participating in weekly trial team call. Revising and circulating draft interrogatory to News concerning contact and settlements with potential class members. Reviewing and responding to emails re discovery issues.

2.60 $1,820.00

02/04/15 J. Southwick Reviewing and responding to emails re review of third party depositions in Valassis/Insignia/FGI cases and discovery generally. Reviewing list of third party depositions from prior cases.

1.30 $910.00

02/04/15 B. Rosenthal Preparing descriptions of withheld documents for privilege log. Preparing and

1.10 $357.50




Tax I.D.# 74‐2138615

attempting to contact client's former employees who are listed as witnesses.

02/04/15 R. Caughey Conferring with J. Stanley and team re privilege logs. Meeting with J. Southwick re tasks and strategy. Conferring with S. Musallem re discovery. Conferring with D. Hadley re representation. Conferring with B. Rosenthal re discovery tasks. Conferring with opposing counsel re depositions. Addressing issues relating to depositions of former employees.

1.90 $902.50

02/04/15 L. Eccles Reviewing case map. Participating in teleconference with J. Southwick and R. Caughey re third party depositions.

2.70 $1,350.00

02/04/15 M. Fisher Reviewing Foster Farms privilege log. 0.50 $137.50

02/04/15 J. Stanley Preparing privilege logs. Conferring with R. Rosenthal re privilege log.

6.00 $1,620.00

02/05/15 B. Rosenthal Conferring by phone with M. Fisher and R. Caughey re privilege log. Conferring by phone with R. Caughey and L.G. Eccles re third party depositions. Reviewing documents marked privilege and inputting summary data into log.

2.30 $747.50

02/05/15 R. Caughey Conferring with team re deposition transcript review and third‐party deposition letter. Conferring with team re privilege logs and review. Conferring with co‐counsel re discovery. Addressing issues with third‐party depositions.

1.90 $902.50

02/05/15 L. Eccles Participating in telephone conference with R. Caughey and B. Rosenthal.

0.50 $250.00

02/05/15 L. Eccles Reviewing case map. Emailing trial team re deposition transcript review.

3.90 $1,950.00

02/05/15 M. Fisher Conferring by phone with R. Caughey and B. Rosenthal re Foster Farms privilege log.

0.20 $55.00

02/05/15 J. Stanley Updating privilege logs. 3.00 $810.00

02/06/15 J. Southwick Reviewing and responding to emails re depositions.

0.50 $350.00

02/06/15 R. Caughey Addressing issues relating to privilege logs. Conferring with team re discovery and

0.80 $380.00




Tax I.D.# 74‐2138615

depositions. Reviewing documents.

02/06/15 L. Eccles Reviewing trial team and co‐counsel email. 0.20 $100.00

02/06/15 L. Eccles Reviewing casemap, class certification brief and class certification exhibits.

4.10 $2,050.00

02/06/15 B. Rosenthal Preparing description of entries for News privilege log.

1.00 $325.00

02/06/15 M. Fisher Preparing Foster Farms privilege log. 4.50 $1,237.50


1.30 $650.00


2.20 $1,100.00

02/09/15 J. Southwick Reviewing and responding to emails re discovery issues and trial team meeting.

0.20 $140.00

02/09/15 B. Rosenthal Conferring by phone with co‐counsel associates on weekly discovery call.

0.50 $162.50

02/09/15 R. Caughey Participating in weekly discovery call. Conferring with team re privilege logs and prior deposition testimony.

1.00 $475.00

02/09/15 L. Eccles Reviewing file, case map and trial team email. Participating in co‐counsel discovery call.

7.20 $3,600.00

02/10/15 B. Rosenthal Preparing Foster Farms privilege log. 2.90 $942.50

02/10/15 R. Hess Conferring by phone with potential third party witness.

0.30 $165.00

02/10/15 R. Caughey Conferring with team re privilege logs. 0.30 $142.50



02/10/15 L. Eccles Reviewing file and case map. 6.00 $3,000.00

02/11/15 J. Southwick Reviewing Second Circuit class certification decision in Applebees case. Reviewing and responding to emails re discovery issues.

0.70 $490.00

02/11/15 B. Rosenthal Reviewing documents from Goldman Sachs production to identify documents for which business records depositions are needed.

1.10 $357.50

02/11/15 M. Fisher Drafting Foster Farms privilege log descriptions.

6.20 $1,705.00

02/11/15 R. Caughey Reviewing correspondence re opt outs. Conferring with team re privilege logs.

1.50 $712.50




Tax I.D.# 74‐2138615

Reviewing Bevilacqua deposition transcript. Conferring with team re third‐party deposition assignments and revising memorandum re same.


02/11/15 L. Eccles Reviewing file, case map, trial team email and expert report.

8.20 $4,100.00

02/12/15 J. Southwick Participating in weekly trial team call. Conferring with R. Caughey re deposition preparation for Garafalo and Hansa. Reviewing and commenting on proposed letter to J. Pauley re Appelbees Second Circuit decision.

1.40 $980.00

02/12/15 M. Fisher Drafting Foster Farms privilege log. Conferring by phone with News litigation team.

7.60 $2,090.00

02/12/15 R. Caughey Participating in management committee call. Conferring with team re privilege logs. Conferring with team re deposition scheduling. Conferring with J. Southwick re tasks and depositions. Preparing for Garofalo deposition and reviewing transcripts re same. Reviewing Comcast caselaw and correspondence with court re same.

1.60 $760.00


02/12/15 L. Eccles Participating in weekly trial team call. Reviewing expert report.

3.40 $1,700.00

02/12/15 V. Lee Updating the News_Foster Farms Privilege Concordance database.

0.70 $87.50

02/13/15 R. Caughey Preparing privilege logs. Conferring with team re discovery issues. Organizing depositions. Conferring with team re deposition preparation and documents.

1.00 $475.00

02/13/15 J. Stanley Updating privilege log. 4.00 $1,080.00

02/13/15 L. Eccles Reviewing expert report. Participating in telephone conference with R. Caughey and J. Southwick

4.50 $2,250.00

02/14/15 R. Caughey Revising and circulating privilege log. Conferring with team re third‐party

0.50 $237.50




Tax I.D.# 74‐2138615

depositions.

02/16/15 R. Caughey Conferring with team re privilege logs. Conferring with B. Rosenthal re tasks. Addressing deposition scheduling.

0.40 $190.00


02/17/15 J. Southwick Participating in weekly trial team call. Reviewing draft privilege logs and preparing email concerning content of privilege logs.

1.40 $980.00

02/17/15 R. Caughey Participating in weekly trial team conference call. Reviewing privilege logs and addressing issues. Addressing issues relating to depositions and discovery. Conferring with J. Stanley re privilege logs.

1.50 $712.50

02/17/15 B. Rosenthal Conferring by phone with management committee on weekly call.

0.50 $162.50

02/17/15 R. Hess Reviewing correspondence with court. Conferring by email with SG trial team. Conferring in office with J. Southwick.

0.50 $275.00


0.50 $137.50


02/18/15 J. Southwick Conferring by phone with cocounsel re privilege logs. Reviewing and responding to emails re various discovery issues. Conferring by phone with M. Palizzi.

1.90 $1,330.00

02/18/15 R. Caughey Reviewing correspondence re privilege log. Conferring with J. Southwick re tasks and strategy re Valassis. Addressing deposition preparation issues. Conferring with L. Godfrey re case issues and tasks.

2.30 $1,092.50

02/18/15 L. Eccles Conferring with co‐counsel via email and telephone conference re privilege logs and deposition transcripts. Conferring with R. Caughey re case issues.

4.10 $2,050.00

02/18/15 M. Fisher Conferring by phone with News Litigation Team. Reviewing eclipse database for B. Recchia documents.

3.00 $825.00



0.70 $87.50




Tax I.D.# 74‐2138615

02/19/15 R. Caughey Addressing issues with documents and privilege logs. Compiling witness documents and preparing for depositions.

2.80 $1,330.00

02/19/15 L. Eccles Conferring with J. Stanley re deposition transcript. Conferring with J. Southwick. Reviewing CaseMap issues list and related legal research. Reviewing third‐party deposition transcripts.

5.80 $2,900.00

02/19/15 B. Rosenthal Preparing for deposition of Dominic Hansa by reviewing documents re Hansa.

0.70 $227.50

02/19/15 M. Fisher Reviewing documents for B. Recchia review. 3.00 $825.00

02/19/15 J. Stanley Updating privilege log. Preparing materials for L.G. Eccles.

2.00 $540.00

02/19/15 V. Lee Creating and loading documents into the News_Hansa Eclipse database.

0.60 $75.00

02/20/15 J. Southwick Conferring by phone with Susman Godfrey trial team re upcoming tasks. Conferring with M. Fisher re M. Recchia and documents in Valassis database.

1.00 $700.00

02/20/15 L. Eccles Participating in trial team call. Reviewing deposition transcripts. Reviewing file and trial team email.

5.50 $2,750.00

02/20/15 B. Rosenthal Conferring by phone with R. Caughey, J. Stanley, and K. Briggs re witness files for upcoming depositions. Reviewing documents re same.

0.80 $260.00


02/20/15 M. Fisher Reviewing documents for B. Recchia review. 5.00 $1,375.00

02/20/15 J. Stanley Preparing materials for depositions. Updating privilege log.

4.00 $1,080.00

02/20/15 V. Lee Loading documents into the News_Hansa Eclipse database.

0.30 $37.50

02/21/15 M. Fisher Reviewing documents for B. Recchia review. 4.20 $1,155.00

02/22/15 L. Eccles Reviewing deposition transcripts. 1.50 $750.00

02/23/15 J. Southwick Conferring with M. Fisher and R. Caughey re Valassis document production and documents referencing M. Recchia.

0.50 $350.00

02/23/15 M. Fisher Revising Foster Farms Privilege Log. Reviewing for Recchia documents.

7.20 $1,980.00




Tax I.D.# 74‐2138615

02/23/15 J. Stanley Conferring with team re document issues. Updating privilege log.

3.00 $810.00

02/23/15 L. Eccles Emailing trial team and co‐counsel re discovery. Reviewing deposition transcripts. Reviewing briefing re motion to quash.

6.30 $3,150.00

02/23/15 R. Caughey Drafting and revising privilege logs. Participating in weekly associate discovery call. Preparing for M. Garofalo deposition by reviewing Garofalo transcripts and exhibits. Addressing issues with Valassis discovery with J. Southwick and M. Fisher.

3.70 $1,757.50

02/23/15 V. Lee Updating the News_Hansa Eclipse database. 1.70 $212.50

02/24/15 J. Southwick Conferring by emails re deposition of Valassis witness. Participating in weekly trial team call. Conferring by phone with Susman Godfrey trial team. Reviewing and commenting on draft letter to News re use of prior testimony in other cases. Reviewing and responding to emails re depositions. Reviewing proposed amendment to cocounsel agreement re Paul Hastings ‐ Kramer Levin.

3.70 $2,590.00

02/24/15 B. Rosenthal Conferring by phone with management committee on weekly call. Conferring by phone with SG team re upcoming depositions. Conferring by phone with J. Briody re 30(b)(6) deposition of Goldman Sachs.

1.80 $585.00

02/24/15 M. Fisher Conferring by phone with News Litigation Team. Conferring by phone with SG News Litigation Team. Reviewing for Recchia documents.

6.40 $1,760.00

02/24/15 L. Eccles Participating in weekly calls. Emailing re documents. Reviewing deposition transcripts. Drafting letter re admissibility of same. Conducting legal research re same.

6.90 $3,450.00

02/24/15 R. Hess Researching points of law re prior depositions. Conferring by phone with trial team.

0.90 $495.00

02/24/15 R. Caughey Preparing for depositions. Reviewing documents and transcripts in connection

2.90 $1,377.50




Tax I.D.# 74‐2138615

with preparing for depositions. Addressing document collection and processing issues and participating in calls with team re same. Conferring with L. Eccles re third‐party deposition review.


4.00 $500.00


0.50 $62.50

02/25/15 J. Southwick Reviewing emails and case law re use of depositions from prior cases. Conferring with J. Ross re background and state of case. Conferring with B. Rosenthal re upcoming depositions. Reviewing emails re Schulman deposition.

3.90 $2,730.00

02/25/15 J. Ross Meeting with J. Southwick re assisting on case. Reviewing materials to come up to speed.

2.00 $1,400.00

02/25/15 M. Fisher Reviewing for Recchia documents in News Database.

6.60 $1,815.00

02/25/15 J. Stanley Updating privilege log. Preparing materials for R. Caughey to review.

2.00 $540.00

02/25/15 L. Eccles Reviewing deposition transcripts. Revising letter re admissibility of same. Conducting legal research re same. Emailing re same.

2.10 $1,050.00

02/25/15 R. Caughey Preparing for Garofalo deposition. Conferring with team re tasks and deposition. Reviewing documents and prior depositions.

5.50 $2,612.50


0.50 $62.50

02/26/15 B. Rosenthal Preparing for deposition of Dominic Hansa by reviewing hot documents in his file.

1.30 $422.50

02/26/15 J. Ross Reviewing expert report. 3.50 $2,450.00

02/26/15 M. Fisher Revising Bob Evans Privilege Log. 7.80 $2,145.00

02/26/15 J. Stanley Updating privilege log. Preparing materials for R. Caughey. Preparing trial notebook for J. Ross.

4.00 $1,080.00

02/26/15 L. Eccles Reviewing deposition transcripts. Emailing trial team re same. Revising draft letter re

4.70 $2,350.00




Tax I.D.# 74‐2138615

deposition transcripts. Conferring with J. Ross re same.

02/26/15 J. Southwick Reviewing draft letter from L. Eccles re third party depositions. Conferring with J. Ross re state of case and future projects.

2.90 $2,030.00

02/26/15 R. Caughey Preparing for Garofalo deposition. Reviewing documents. Addressing discovery issues. Addressing issues with privilege logs.

5.50 $2,612.50


1.00 $125.00

02/27/15 J. Ross Reviewing expert report and other materials. Reviewing draft letter re using previous case materials at trial. Discussing same with L.G. Eccles . Attending to records needed to be proved up by Goldman Sachs.

2.80 $1,960.00

02/27/15 M. Fisher Revising Bob Evans Privilege Log. 6.90 $1,897.50

02/27/15 J. Stanley Preparing documents for R. Caughey to review. Preparing deposition transcripts for trial team to review. Conferring with trial team re document issues.

5.00 $1,350.00

02/27/15 B. Rosenthal Preparing to take deposition of Dominic Hansa by reviewing second level hot documents associated with Hansa.

3.20 $1,040.00

02/27/15 L. Eccles Reviewing deposition transcripts. Emailing re documents. Participating in trial team call re documents.

5.10 $2,550.00

02/27/15 J. Southwick Meeting with Susman Godfrey trial team to discuss database access and issues.

1.10 $770.00

02/27/15 R. Caughey Preparing for Garofalo deposition and reviewing documents re same. Meeting with team re document review, review platform, and deposition preparation. Conferring with team re privilege logs. Conferring with team re review of third‐party deposition transcripts.

7.50 $3,562.50

02/27/15 V. Lee Exporting documents from the News_Garofalo Eclipse database.

1.00 $125.00

02/28/15 J. Ross Reviewing expert report and supporting documents.

4.50 $3,150.00

02/28/15 R. Caughey Preparing for Garofalo deposition. 4.40 $2,090.00




Tax I.D.# 74‐2138615

03/01/15 L. Eccles Reviewing trial team email re deposition transcripts and surveys.

0.10 $50.00

03/01/15 B. Rosenthal Preparing to take deposition of Dominic Hansa by reviewing documents associated with Hansa.

4.00 $1,300.00

03/01/15 R. Caughey Preparing for Garofalo deposition. Conferring with J. Stanley re documents and deposition materials. Preparing and sending Garofalo deposition notice.

6.90 $3,277.50

03/01/15 J. Stanley Preparing witness files. Conferring with K. Briggs re documents.

4.00 $1,080.00

03/01/15 V. Lee Creating and loading documents into the "News_Garofalo Remaining" and the "News_Garofalo_Other Witness Binders" Eclipse databases.

4.75 $593.75

03/02/15 J. Southwick Conferring by phone with B. Rosenthal re preparation for Hansa deposition. Conferring by emails re deposition scheduling and assignments. Reviewing proposals for jury research. Conferring by email to trial team re completing proposals. Conferring by phone with M. Palizzi and K. Scott re Valassis corporate representative deposition.

5.50 $3,850.00

03/02/15 B. Rosenthal Preparing deposition notice and subpoena for Goldman Sachs 30(b)(6) deposition. Conferring by phone with J. Southwick re strategy for deposition of Dominic Hansa. Preparing to take deposition of Dominic Hansa by reviewing documents.

5.80 $1,885.00

03/02/15 L. Eccles Emailing trial team re depositions. Emailing cocounsel re same. Reviewing filings. Reviewing deposition transcripts.

7.40 $3,700.00

03/02/15 R. Caughey Preparing for Garofalo deposition. Conferring with team re Garofalo deposition. Participating in weekly associates' discovery call.

8.90 $4,227.50

03/02/15 J. Ross Attending to GS subpoena. Sending same to plaintiffs' group. Reviewing documents and deposition testimony for J. Aversano deposition.

4.30 $3,010.00




Tax I.D.# 74‐2138615

03/02/15 J. Stanley Preparing witness files. Conferring with K. Briggs re documents.

3.00 $810.00

03/02/15 V. Lee Creating and loading documents into the News_Hansa Eclipse database. Exporting documents from the News_Garofalo Eclipse database.

3.40 $425.00

03/03/15 J. Southwick Participating in weekly trial team call. Traveling to New York. Reviewing depositions of Kroc, Mixson, and Bevilaqua. Conferring by emails with trial team re various discovery issues. Conferring with R. Caughey re M. Garofalo.

7.00 $4,900.00

03/03/15 B. Rosenthal Preparing for deposition of Dominic Hansa and reviewing documents related to Hansa. Traveling to NYC for deposition.

5.50 $1,787.50

03/03/15 L. Eccles Participating in weekly call. Emailing re deposition transcript review. Reviewing transcripts.

6.40 $3,200.00

03/03/15 R. Caughey Preparing for Garofalo deposition. Meeting with J. Southwick re Garofalo deposition. Conferring with opposing counsel re depositions. Conferring with team re discovery and privilege logs. Traveling from Houston, TX to New York, NY.

13.50 $6,412.50

03/03/15 J. Ross Editing GS subpoena. Discussing same with J. Briody. Reviewing documents for J. Aversano deposition.

2.40 $1,680.00


03/03/15 M. Fisher Conferring by phone with News litigation team.

0.60 $165.00

03/03/15 J. Stanley Preparing documents for deposition. Preparing documents for chronology. Updating Foster Farms privilege log.

6.00 $1,620.00

03/03/15 V. Lee Updating the "News_Foster Farms Privilege" Eclipse database.

1.50 $187.50

03/04/15 B. Rosenthal Attending deposition of Marty Garofalo. Preparing for and reviewing documents relating to deposition of Dominic Hansa.

8.00 $2,600.00

03/04/15 L. Eccles Reviewing deposition transcripts. Emailing re same. Revising chart re same.

4.80 $2,400.00




Tax I.D.# 74‐2138615

Participating in trial team call.

03/04/15 J. Southwick Attending deposition of M. Garafalo. Conferring with B. Rosenthal re Hansa deposition. Conferring by emails with J. Stanley re documents for Hansa deposition.

7.70 $5,390.00

03/04/15 R. Caughey Deposing M. Garofalo. Meeting with team re Garofalo deposition. Preparing summary memorandum of Garofalo deposition. Preparing for Garofalo deposition. Conferring with team re other depositions. Conferring with team re deposition schedule.

8.50 $4,037.50

03/04/15 J. Stanley Preparing documents for deposition. Updating Foster Farms privilege log. Updating chronology.

7.00 $1,890.00

03/04/15 V. Lee Updating the "News_Foster Farms Privilege" Eclipse database. Exporting documents from the News_Hansa Eclipse database.

2.10 $262.50

03/05/15 B. Rosenthal Preparing for and reviewing documents related to deposition of Dominic Hansa.

8.00 $2,600.00

03/05/15 L. Eccles Reviewing deposition transcripts. Emailing re same. Revising chart re same. Participating in weekly trial team call.

6.80 $3,400.00

03/05/15 J. Southwick Preparing for deposition of D. Hansa. Participating in weekly call with Susman Godfrey team.

11.50 $8,050.00

03/05/15 R. Caughey Conferring with team re discovery issues. Reviewing deposition transcripts. Traveling form New York, NY to Houston, TX.

5.30 $2,517.50

03/05/15 J. Ross Revising and sending out GS subpoena. Preparing for and attending trial team call. Discussing case issues with J. Southwick. Preparing for J. Aversano deposition.

3.00 $2,100.00

03/05/15 M. Fisher Reviewing NAM documents for documents relating to "Project Pre‐empt".

6.50 $1,787.50

03/05/15 R. Hess Reviewing transcript of Y. Anidjar, M. Devlin, and J. Gibson depsoitions in FGI‐Safeway matter. Reviewing transcript G. Rebh, D. Carpenter, M. Folks and C. Hamilton

5.60 $3,080.00




Tax I.D.# 74‐2138615

depositions. Conferring by phone with trial team re deposition review and designations.

03/05/15 J. Stanley Preparing documents for deposition. Updating chronology.

5.00 $1,350.00

03/05/15 V. Lee Updating the News_Hansa Eclipse database. 0.30 $37.50

03/06/15 B. Rosenthal Preparing for and attending deposition of Dominic Hansa. Conferring by email with trial team re same.

5.50 $1,787.50

03/06/15 L. Eccles Reviewing deposition transcripts. Emailing re same. Revising chart re same. Reviewing email re depositions.

1.40 $700.00

03/06/15 J. Southwick Preparing for and attending deposition of D. Hansa. Reviewing and responding to emails re Hansa deposition. Conferring by phone with D. Mendelson.

7.00 $4,900.00


03/06/15 R. Caughey Reviewing deposition transcripts. Conferring with team re depositions. Addressing issues with privilege logs.

0.70 $332.50

03/06/15 J. Ross Preparing for J. Aversano deposition. 1.80 $1,260.00

03/06/15 R. Hess Reviewing transcript (rough) of D. Hansa deposition. Reviewing deposition summary. Reviewing disclosures re potential third party witnesses.

1.00 $550.00

03/07/15 B. Rosenthal Traveling from NYC to Dallas from deposition of Dominic Hansa.

5.00 $1,625.00

03/08/15 L. Eccles Reviewing deposition transcripts. 2.00 $1,000.00


03/09/15 R. Caughey Participating in meeting re pretrial preparations. Conferring with associates re discovery. Finalizing privilege logs. Reviewing deposition testimony.

2.50 $1,187.50

03/09/15 J. Ross Reviewing documents and deposition transcripts in preparation for J. Aversano deposition.

8.90 $6,230.00

03/09/15 R. Hess Conferring in office with J. Ross, J. Southwick, and R. Caughey re discovery and pretrial deadlines.

1.20 $660.00

03/09/15 J. Southwick Conferring by email with trial team re call 4.90 $3,430.00




Tax I.D.# 74‐2138615

with D. Mendelson. Reviewing emails re pretrial filings and meeting with R. Caughey, J. Ross, and R. Hess to discuss pretrial tasks and assignments.

03/09/15 L. Eccles Emailing trial team and colead counsel re discovery and deposition designations. Reviewing casemap.

1.70 $850.00

03/10/15 J. Stanley Conferring with K. Briggs re witness files. Updating case file. Conferring with court reporter re deposition scheduling.

2.00 $540.00

03/10/15 B. Rosenthal Conferring by phone with trial team on weekly call.

0.83 $269.75

03/10/15 J. Southwick Participating in weekly call with cocounsel. Conferring by phone with Susman Godfrey trial team. Conferring by phone with P. Farris. Conferring by phone with R. Pfau. Reviewing emails re Goldman Sachs documents and discovery issues. Commenting on draft letter re third party depositions. Begin drafting memorandum to trial team re Hansa and NAM themes revealed in depositions.

5.80 $4,060.00

03/10/15 L. Eccles Preparing for trial team and co‐lead weekly call. Participating in same. Emailing re discovery.

4.30 $2,150.00

03/10/15 R. Caughey Preparing for depositions. Conferring with J. Ross re J. Aversano deposition. Participating in weekly management committee call. Addressing issues with privilege logs.

1.50 $712.50

03/10/15 J. Ross Attention to GS subpoena. Reviewing documents and drafting same. Preparing for and attending plaintiff management call. Reviewing J. Aversano documents.

6.70 $4,690.00


0.60 $165.00

03/10/15 R. Hess Conferring in office with trial team re deposition review and designations.

0.70 $385.00

03/10/15 V. Lee Creating and loading documents into the News_Aversano Eclipse database.

0.70 $87.50

03/11/15 J. Southwick Conferring by emails re letter concerning use 4.70 $3,290.00




Tax I.D.# 74‐2138615

of third party deposition. Reviewing and responding to emails re discovery and pre‐trial filings. Reading letter from K. Gallo to Court requesting adjournment of deadlines.

03/11/15 L. Eccles Conferring with trial team and co‐lead counsel via email re discovery. Reviewing casemap and deposition designations.

3.20 $1,600.00

03/11/15 R. Caughey Addressing issues with privilege logs and discovery.

1.90 $902.50

03/11/15 J. Ross Drafting GS subpoena. Sending same to GS counsel. Discussing same with GS counsel. Reviewing J. Aversano documents.

8.50 $5,950.00

03/11/15 M. Fisher Drafting Bob Evans Privilege Log. 7.90 $2,172.50

03/11/15 R. Hess Conferring by email with L.G. Eccles re deposition and trial testimony letter.

0.30 $165.00

03/11/15 V. Lee Removing the News_Hansa data from the SG network.

0.80 $100.00

03/12/15 J. Southwick Reviewing letter seeking adjournment of deadlines from NAM and draft response thereto. Reviewing Foster Farms and Heinz privilege logs. Reviewing and responding to emails re draft letter re third party depositions.

2.70 $1,890.00

03/12/15 L. Eccles Emailing trial team and co‐lead re discovery. Reviewing casemap and deposition designations.

5.70 $2,850.00

03/12/15 R. Caughey Conferring with J. Southwick re privilege logs. Reviewing NAM letter to the court. Reviewing correspondence with experts. Addressing issues with privilege logs. Conferring with K. Briggs and J. Stanley re documents.

1.50 $712.50


03/12/15 M. Fisher Drafting Bob Evans privilege log. Conferring by phone with R. Caughey and New Litigation Team to organize exhibit list division of labor.

8.40 $2,310.00

03/12/15 J. Stanley Preparing documents for attorneys to review.

2.00 $540.00

03/13/15 L. Eccles Emailing co‐lead counsel re letter brief. 2.30 $1,150.00




Tax I.D.# 74‐2138615

Revising third party deposition letter. Reviewing casemap.

03/13/15 R. Caughey Conferring with J. Southwick re expert reports and schedule. Reviewing letter brief re schedule. Conferring with J. Ross re Aversano deposition.

1.00 $475.00


03/13/15 M. Fisher Drafting Bob Evans privilege log. 4.40 $1,210.00

03/13/15 J. Southwick Reviewing draft letter to court re case schedule and defendants' request to extend deadlines.

0.40 $280.00

03/14/15 R. Caughey Reviewing expert reports. 0.50 $237.50

03/15/15 J. Ross Reviewing defendants' expert reports. 4.80 $3,360.00

03/16/15 J. Ross Reviewing expert reports. Preparing for J. Aversano deposition.

3.50 $2,450.00

03/16/15 L. Eccles Emailing re experts. Reviewing depositions and deposition designations. Reviewing expert reports.

3.10 $1,550.00

03/16/15 R. Caughey Conferring with J. Ross re Aversano deposition. Conferring with team re privilege logs and pretrial preparations. Conferring with opposing counsel re Carlucci deposition.

0.60 $285.00

03/17/15 J. Southwick Reviewing expert reports from NAM and email of issues raised from T. Fazzone. Responding to email from T. Fazzone.

2.00 $1,400.00

03/17/15 L. Eccles Reviewing deposition designations. Emailing re experts. Contacting experts.

4.70 $2,350.00

03/17/15 R. Caughey Participating in expert calls. Conferring with J. Southwick re expert calls. Reviewing documents and deposition transcripts. Preparing for depositions.

2.80 $1,330.00

03/17/15 J. Ross Attending to deposition designations. 2.10 $1,470.00

03/17/15 J. Stanley Preparing deposition calendar. Updating Bob Evans privilege log. Preparing deposition notices.

6.00 $1,620.00

03/18/15 J. Southwick Reviewing and responding to email re discovery and expert reports. Conferring by phone with R. Caughey re summary of calls

1.10 $770.00




Tax I.D.# 74‐2138615

with P. Farris and Applecon. Attending weekly trial team call.

03/18/15 L. Eccles Emailing co‐lead counsel re discovery. Participating in weekly call. Reviewing deposition designations.

5.20 $2,600.00

03/18/15 R. Caughey Preparing chart of retailer agreements and extensions and conferring with D. Goldman re same. Revising deposition memorandum and circulating to team. Reviewing deposition transcripts. Participating in weekly management call. Conferring with team re retailer issues. Conferring with J. Southwick re Valassis and expert call. Conferring with opposing counsel re depositions.

3.20 $1,520.00


03/18/15 J. Stanley Updating BEF privilege log. 0.80 $216.00

03/19/15 L. Eccles Emailing trial team re casemap, experts and jury research. Reviewing Pfau memos.

2.80 $1,400.00

03/19/15 R. Caughey Preparing deposition designations. Conferring with team re depositions. Preparing for Bedell deposition. Participating in expert discussions and setting up expert call.

2.80 $1,330.00


03/19/15 J. Stanley Preparing documents for review. Updating notebooks.

3.00 $810.00

03/19/15 V. Lee Creating and loading documents into the "News_2nd Level Review" and the News_Bedell Eclipse databases.

2.00 $250.00

03/20/15 L. Eccles Emailing trial team and co‐lead re deposition designations and privilege logs.

0.20 $100.00

03/20/15 M. Fisher Reviewing second level hot documents for potential exhibits.

6.00 $1,650.00

03/20/15 J. Stanley Preparing documents for attorney review. 3.00 $810.00


03/22/15 R. Caughey Addressing issues with deposition designations.

0.30 $142.50





Tax I.D.# 74‐2138615

03/23/15 R. Caughey Participating in weekly discovery call. Addressing issues with deposition designations and witness lists. Reviewing correspondence.

1.00 $475.00

03/23/15 J. Southwick Preparing for call with R. Pfau and cocounsel re issues of concern re Valassis. Reviewing memorandums re Valassis and retailer issues. Beginning preparation of deposition outline for Valassis. Conferring by email with L. Eccles re SOL tolling research.

4.90 $3,430.00


03/23/15 L. Eccles Conferring with trial team via email re deposition designations. Reviewing deposition designations.

5.90 $2,950.00

03/23/15 J. Stanley Preparing for depositions. 4.00 $1,080.00

03/23/15 M. Fisher Reviewing hot documents. 6.90 $1,897.50

03/24/15 J. Ross Preparing for J. Aversano deposition. Traveling to New York for same.

10.50 $7,350.00

03/24/15 J. Southwick Participating in weekly trial team call. Reviewing defendant's expert reports. Conferring by phone with J. Ross re Aversano deposition. Reading order adjourning pre‐trial date.

7.70 $5,390.00

03/24/15 L. Eccles Conferring with trial team via email. Reviewing tolling agreement and deposition designations.

4.20 $2,100.00

03/24/15 R. Caughey Preparing pretrial materials. Conferring with team re pretrial issues and depositions.

0.50 $237.50

03/24/15 R. Hess Conferring by phone and by email with trial team re internal tasks, privilege log and deposition designations.

0.40 $220.00

03/24/15 J. Stanley Updating privilege log. Preparing deposition designations. Preparing for deposition.

5.00 $1,350.00


03/25/15 J. Southwick Reviewing news reports re Kraft/Heinz merger. Conferring by emails with cocounsel re depositions. Conferring on calls with L. LeClair, S. Benz, and D. Goldman re developments in the case, including vacatur of the pre‐trial order filing date and

7.40 $5,180.00




Tax I.D.# 74‐2138615

Kraft/Heinz merger. Reviewing docket in Barry v. Kraft case. Reviewing defendants' expert reports.

03/25/15 L. Eccles Conferring via email with trial team and co‐lead counsel.

0.70 $350.00

03/25/15 R. Caughey Addressing issues with depositions and discovery.

0.50 $237.50

03/25/15 J. Ross Preparing for and taking J. Aversano deposition. Traveling back to Houston.

13.00 $9,100.00

03/25/15 J. Stanley Preparing materials for deposition. 2.00 $540.00

03/25/15 J. Stanley Updating documents. Preparing depositions designations.

2.00 $540.00


03/26/15 J. Southwick Conferring by phone with Susman Godfrey lawyers to review current tasks. Preparing for calls with M. Palizzi and K. Scott re potential Valassis deposition. Conferring by phone with R. Pfau re upcoming rebuttal report. Reviewing defendants' expert reports.

7.00 $4,900.00

03/26/15 L. Eccles Participating in trial team call. Reviewing email re merger and depositions.

0.50 $250.00

03/26/15 V. Lee Exporting documents from the "News_2nd Level Review" Eclipse database.

0.10 $12.50

03/26/15 R. Caughey Addressing discovery and deposition issues. Addressing privilege log issues. Reviewing correspondence. Reviewing documents re staggering and preparing memorandum re same.

1.30 $617.50

03/26/15 J. Ross Attending to pretrial deposition designations. Reviewing expert reports.

5.40 $3,780.00


03/27/15 J. Southwick Conferring by emails re privilege logs and discovery. Conferring by emails with R. Pfau. Preparing for Valassis deposition. Conferring by phone with M. Palizzi.

6.70 $4,690.00

03/27/15 L. Eccles Emailing opposing counsel re prior testimony.

0.20 $100.00

03/27/15 V. Lee Updating the "News_BEF Privilege" Eclipse 0.60 $75.00




Tax I.D.# 74‐2138615

database.

03/27/15 R. Caughey Finalizing BEF privilege log and serving. Conferring with team re discovery issues. Meeting with M. Fisher re discovery.

1.00 $475.00

03/27/15 J. Ross Attending to pretrial designation work. Reviewing hot chronology.

3.40 $2,380.00

03/27/15 J. Stanley Preparing documents for chronology. Preparing documents for L. Berg review.

4.00 $1,080.00


03/29/15 R. Caughey Reviewing documents in connection with retailer projects and upcoming depositions.

0.50 $237.50

03/30/15 V. Lee Creating and loading documents into the News_Berg Eclipse database.

1.00 $125.00

03/30/15 R. Caughey Preparing memorandum re Winn Dixie and BI‐LO negotiations and conferring with M. Fisher re same. Reviewing documents re Winn Dixie and BI‐LO. Compiling retailer contracts. Preparing for deposition. Meeting with J. Southwick re tasks and strategy.

3.80 $1,805.00

03/30/15 J. Ross Reviewing expert reports and documents. 3.60 $2,520.00

03/30/15 M. Fisher Reviewing hot documents. 2.70 $742.50

03/30/15 J. Southwick Conferring by email with cocounsel re issues for discussion on weekly call. Attending conference call re Kraft‐Heinz merger. Reviewing defendants' expert reports and preparing for depositions of K. Murphy and Valassis.

7.50 $5,250.00

03/30/15 L. Eccles Conferring with trial team via email. Sending correspondence to opposing counsel. Participating in telephone conference with J. Southwick re discovery issues.

1.90 $950.00

03/30/15 J. Stanley Updating document chronology. Preparing documents for L. Berg deposition.

5.00 $1,350.00

03/31/15 V. Lee Updating the News_Berg Eclipse database. 0.50 $62.50

03/31/15 R. Caughey Addressing issues with CaseMap, pretrial discovery, and documents. Reviewing Berg documents and conferring with team re same.

1.50 $712.50




Tax I.D.# 74‐2138615

03/31/15 M. Fisher Reviewing documents for Winn Dixie and Bi‐Lo background.

2.40 $660.00

03/31/15 J. Southwick Attending weekly trial team call. Conferring by phone with SG lawyers re upcoming and ongoing tasks. Conferring by phone with M. Palizzi and K. Scott. Preparing for depositions of K. Murphy and L. Berg.

6.60 $4,620.00

03/31/15 L. Eccles Participating in weekly calls. Emailing re prior testimony issue. Reviewing casemap. Researching statute of limitations.

2.70 $1,350.00

03/31/15 J. Ross Preparing for and attending lead counsel and trial team conference calls. Reviewing transcript of J. Aversano deposition and drafting email summary to plaintiffs' group. Reviewing documents.

3.70 $2,590.00

03/31/15 J. Stanley Reviewing and preparing documents for L. Berg deposition. Updating chronology.

4.00 $1,080.00

04/01/15 J. Southwick Conferring with R. Caughey re Valassis documents. Conferring by phone with K. Scott re Valassis document production. Reading and responding to emails re written discovery requests. Conferring by phone with J. Smith re draft requests for admission.

2.20 $1,540.00

04/01/15 L. Eccles Sending trial team an email re casemap, prior testimony and privilege log. Revising casemap.

0.40 $200.00

04/01/15 M. Fisher Reviewing documents for Winn Dixie and Bi‐Lo background.

6.80 $1,870.00

04/01/15 J. Ross Reviewing case map documents. Attending to hot chronology.

2.60 $1,820.00

04/01/15 J. Stanley Preparing documents for R. Caughey to review. Updating chronology.

4.20 $1,134.00

04/02/15 L. Eccles Sending trial team email. Participating in trial team conference re casemap.

1.20 $600.00

04/02/15 J. Ross Reviewing case map documents. 3.00 $2,100.00

04/02/15 R. Caughey Conferring with team re expert reports. Reviewing notes re depositions. Conferring with team re upcoming deponents and arranging deposition of T. Bedell. Reviewing retailer documents and preparing analysis

5.90 $2,802.50




Tax I.D.# 74‐2138615

and memorandum re same. Conferring with team re retailer issues. Participating in teleconference with experts and meeting with J. Southwick and J. Ross re same.

04/02/15 J. Stanley Conferring with K. Briggs re CaseMap. Preparing documents for review.

4.00 $1,080.00

04/02/15 J. Southwick Conferring and emails with J. Ross and J. Briody re Goldman Sachs declaration. Reviewing and responding to emails re discovery issues.

2.10 $1,470.00

04/02/15 V. Lee Creating and loading documents into the News_Valassis Eclipse database.

0.20 $25.00

04/03/15 R. Caughey Drafting, revising, and circulating memorandum re Winn Dixie negotiations and BI‐LO agreements. Preparing for Bedell deposition and Brotherton deposition. Conferring with team re retailer issues.

3.50 $1,662.50

04/05/15 R. Caughey Preparing correspondence to team re retailer objections. Preparing for Bedell deposition. Circulating privilege logs.

1.00 $475.00

04/06/15 J. Southwick Reviewing Valassis materials and reviewing draft subpoena to Valassis. Reviewing and responding to email re discovery issues.

6.60 $4,620.00

04/06/15 L. Eccles Conferring with trial team and co‐lead via email. Reviewing subpoenas and expert materials.

4.80 $2,400.00

04/06/15 R. Caughey Conferring with team re privilege log issues. Reviewing expert materials. Addressing issues with interrogatories. Preparing to defend D. Brotherton deposition. Preparing for Bedell deposition. Conferring with co‐counsel re discovery issues.

4.50 $2,137.50

04/06/15 J. Stanley Updating chronology. 3.60 $972.00

04/06/15 V. Lee Updating the News_Valassis Eclipse database.

0.20 $25.00

04/07/15 J. Southwick Traveling to Washington DC. Preparing for meeting with L. LeClair, S. Benz, S. Berry, and D. Goldman. Returning to Houston. Reviewing and responding to emails re Valassis deposition and various discovery

11.50 $8,050.00




Tax I.D.# 74‐2138615

issues.

04/07/15 R. Caughey Addressing issues with interrogatories and preparing correspondence re same. Reviewing Valassis documents in connection with upcoming L. Berg deposition and conferring with team re same. Preparing for upcoming depositions and making arrangements re same.

5.80 $2,755.00

04/08/15 J. Southwick Reviewing interrogatories and answers from both plaintiffs and defendant. Conferring by phone with trial team to discuss need to amend interrogatory answers, need to compel further answers, and responses to recently served interrogatories and requests for admissions. Reviewing documents selected from Valassis production.

5.20 $3,640.00

04/08/15 M. Fisher Reviewing Valassis documents regarding L. Berg. Reviewing News privilege log for irregularities. Attending conference call.

6.30 $1,732.50

04/08/15 L. Eccles Preparing for meet and confer. Participating in meet and confer re use of prior testimony. Emailing re same. Emailing trial team and co‐lead re discovery. Participating in trial team call re interrogatories.

2.50 $1,250.00

04/08/15 J. Ross Reviewing documents. Preparing for upcoming depositions.

2.40 $1,680.00

04/08/15 R. Caughey Preparing for D. Brotherton deposition. Preparing for T. Bedell deposition. Addressing issues with interrogatories and expert reports. Conferring with clients re interrogatories and requests for admission. Conferring with team re strategy. Conferring with J. Southwick re L. Mortimer. Reviewing MMM and ROI documents and conferring with team re same. Traveling from Houston, TX to Columbus, OH.

8.80 $4,180.00

04/08/15 J. Stanley Preparing L. Berg documents for J. Southwick to review.

4.60 $1,242.00

04/08/15 V. Lee Exporting documents from the News_Valassis Eclipse database.

0.40 $50.00

04/09/15 J. Southwick Traveling to Detroit and preparing and 12.00 $8,400.00




Tax I.D.# 74‐2138615

meeting with K. Scott and M. Palizzi. Returning to Houston.

04/09/15 M. Fisher Reviewing News privilege log for irregularities.

6.50 $1,787.50

04/09/15 L. Eccles Reviewing co‐lead email. 0.10 $50.00

04/09/15 R. Caughey Meeting with D. Brotherton in preparation for his deposition. Reviewing documents in connection with preparations for D. Brotherton deposition. Preparing for T. Bedell deposition. Conferring with team re L. Mortimer documents.

8.00 $3,800.00

04/09/15 J. Stanley Updating chronology. Preparing documents for R. Caughey and J. Southwick to review.

4.00 $1,080.00

04/09/15 V. Lee Creating and loading documents into the News_Bedell2 Eclipse database.

0.50 $62.50

04/10/15 J. Southwick Reviewing documents re L. Mortimer, Supervalu, and Winn Dixie. Reviewing emails re D. Brotherton deposition. Reviewing newly served discovery notices. Reviewing defendants' expert reports.

3.90 $2,730.00

04/10/15 M. Fisher Reviewing News privilege log for irregularities. Reviewing documents re L. Mortimer.

5.00 $1,375.00

04/10/15 L. Eccles Emailing trial team and co‐lead re discovery. 1.60 $800.00

04/10/15 R. Caughey Defending D. Brotherton deposition. Preparing for D. Brotherton deposition and meeting with D. Brotherton re same. Preparing summary memorandum of D. Brotherton deposition. Preparing for T. Bedell deposition and addressing discovery issues. Traveling from Columbus, OH to Houston, TX.

11.90 $5,652.50

04/10/15 J. Stanley Preparing documents for attorneys to review.

4.20 $1,134.00

04/12/15 R. Caughey Preparing for T. Bedell deposition and conferring with team re discovery.

0.50 $237.50

04/13/15 R. Caughey Preparing for T. Bedell deposition. Conferring with team re depositions and discovery. Preparing research re L. Mortimer and conferring with team re same.

5.50 $2,612.50




Tax I.D.# 74‐2138615

Participating in weekly discovery call. Reviewing privilege logs and preparing correspondence to opposing counsel re same. Conferring with J. Southwick re expert depositions and reviewing expert materials. Organizing logistics for deposition.

04/13/15 J. Stanley Updating time & expense chart. Reviewing invoices and updating billing rate chart. Preparing documents for C. Bedell deposition.

6.00 $1,620.00

04/13/15 L. Eccles Reviewing stipulations. Conferring via email with trial team re same. Emailing re discovery.

0.70 $350.00

04/13/15 M. Fisher Reviewing documents re L. Mortimer. 1.30 $357.50

04/13/15 J. Southwick Reviewing documents and memorandums concerning Win‐Dixie and L. Mortimer. Preparing for deposition of L. Berg.

3.90 $2,730.00

04/13/15 V. Lee Exporting documents from the News Eclipse databases.

0.30 $37.50

04/14/15 J. Southwick Participating in weekly call with Susman Godfrey team to discuss tasks and how to proceed with use of depositions from other cases. Participating in weekly trial team call with cocounsel. Reviewing letter from NAM counsel re production of large quantity of additional emails. Reviewing order from Valassis case re NAM's motion to quash Valassis subpoena to Dial. Conferring by phone with M. Palizzi and K. Scott re Valassis subpoena to Dial. Conferring by emails re Valassis subpoena and call with J. Briody. Reviewing materials re draft rebuttal expert report.

6.40 $4,480.00


3.00 $810.00

04/14/15 L. Eccles Preparing for trial team call. Participating in weekly trial team call. Drafting stipulations.

2.10 $1,050.00

04/14/15 R. Caughey Preparing for deposition of T. Bedell. Conferring with team re discovery issues. Participating in weekly teleconference. Reviewing deposition transcripts.

6.50 $3,087.50




Tax I.D.# 74‐2138615


1.00 $275.00

04/14/15 V. Lee Exporting tagging data from the News_BEF_Privilege Eclipse database.

0.20 $25.00

04/15/15 J. Stanley Preparing documents for attorney review. Preparing exhibits for C. Bedell deposition.

7.00 $1,890.00

04/15/15 J. Southwick Conferring by email with cocounsel re discovery issues and defendants' privilege log. Reviewing draft rebuttal report. Conferring by phone with Applecon re draft rebuttal report. Reviewing NAM subpoena to Valassis. Conferring by phone with K. Scott.

4.40 $3,080.00

04/15/15 L. Eccles Participating in trial team call. 0.30 $150.00

04/15/15 R. Caughey Preparing for deposition of T. Bedell. Reviewing other deposition transcripts. Participating in expert calls. Conferring with J. Briody re discovery and deposition issues. Preparing legal and factual research. Conferring with J. Southwick re subpoena issues.

10.00 $4,750.00


04/15/15 J. Ross Attending to upcoming depositions. Attending to other discovery issues.

3.50 $2,450.00

04/16/15 J. Southwick Reviewing draft expert report of J. MacKie‐Mason. Conferring by phone with Applecon to discuss draft report. Reviewing and responding to emails re discovery and depositions.

4.80 $3,360.00

04/16/15 L. Eccles Conferring with trial team via email. 0.20 $100.00

04/16/15 R. Caughey Preparing for deposition of T. Bedell. Preparing retailer analysis. Reviewing documents. Conferring with R. Pfau re retailers. Conferring with team re depositions and tasks. Reviewing expert reports. Preparing factual research to bolster citations in expert reports. Conferring with team re expert reports. Reviewing issues re documents and privilege logs. Traveling from Houston, TX to New York, NY for T. Bedell deposition.

13.40 $6,365.00




Tax I.D.# 74‐2138615


04/16/15 J. Ross Attending to pretrial issues. Reviewing proposed stipulations. Editing same. Preparing for upcoming Food Lion deposition. Reviewing draft expert reports.

5.70 $3,990.00

04/16/15 J. Stanley Preparing documents for C. Bedell deposition. Preparing notice of depositions. Preparing Bob Evans documents for production.

6.00 $1,620.00


1.30 $162.50

04/17/15 J. Southwick Reviewing draft of Farris report and emails concerning Farris report.

5.50 $3,850.00

04/17/15 R. Caughey Taking deposition of T. Bedell. Preparing summary of deposition of T. Bedell. Conferring with team re hot documents. Reviewing correspondence re discovery issues.

10.50 $4,987.50

04/17/15 M. Fisher Reviewing documents for document review project.

3.90 $1,072.50

04/17/15 J. Ross Reviewing draft expert reports. Reviewing depositions for testimony for same. Sending information found to expert for analysis and potential inclusion in report.

5.40 $3,780.00

04/17/15 J. Stanley Processing Bob Evans documents for production. Updating logs. Preparing documents for deposition preparation.

5.00 $1,350.00


04/18/15 R. Caughey Preparing for K. Murphy deposition. Reviewing expert materials. Reviewing correspondence.

2.00 $950.00


04/20/15 R. Caughey Participating in weekly discovery call. Addressing issues with privilege logs and preparing memorandum re same. Preparing legal research re privilege issues. Meeting with J. Southwick re depositions. Preparing for K. Murphy deposition. Reviewing deposition transcripts. Preparing research re antitrust.

4.50 $2,137.50




Tax I.D.# 74‐2138615

04/20/15 J. Southwick Conferring with J. Smith and J. Briody re response to Valassis subpoena. Conferring by phone with J. Smith, J. Briody, and K. Scott. Conferring with R. Caughey re privilege log review and T. Bedell deposition. Reviewing proposed stipulations concerning use of depositions from other cases, authentication of documents, and depositions of trial witnesses. Reviewing and responding to various emails re discovery and deposition issues.

4.40 $3,080.00

04/20/15 J. Ross Preparing for Food Lion deposition. 3.50 $2,450.00

04/20/15 L. Eccles Conferring with trial team via email re discovery and expert issues.

5.40 $2,700.00

04/20/15 M. Fisher Reviewing documents re L. Mortimer. 5.50 $1,512.50


1.30 $162.50

04/20/15 J. Stanley Preparing Bob Evans supplemental production.

1.00 $270.00

04/21/15 R. Caughey Participating in management committee call. Addressing issues with discovery. Preparing and sending notice letters to third parties. Preparing for Murphy deposition. Preparing correspondence re privilege log and preparing legal research re same. Reviewing NAM's privilege log.

4.90 $2,327.50

04/21/15 L. Eccles Participating in trial team call. Conferring with trial team via email re discovery and expert issues.

6.20 $3,100.00

04/21/15 M. Fisher Conferring by phone with News litigation team. Reviewing documents re L. Mortimer. Reviewing documents re Krasdale, Retail Marketing Group, and Niemann Foods.

5.00 $1,375.00


1.00 $125.00

04/21/15 J. Ross Reviewing documents for D. Godfredson deposition. Preparing for and attending counsel call.

8.60 $6,020.00

04/21/15 J. Southwick Participating in weekly call with cocounsel. Preparing for deposition of J. Mackie‐Mason.

7.40 $5,180.00




Tax I.D.# 74‐2138615

04/22/15 J. Southwick Preparing for and meeting with J. Mackie‐Mason to prepare for deposition. Reviewing and responding to emails re discovery issues. Meeting with K. Scott.

5.80 $4,060.00

04/22/15 J. Southwick Traveling to Ann Arbor. 3.00 $2,100.00

04/22/15 R. Caughey Addressing discovery issues. Reviewing privilege logs and case law re privilege in S.D.N.Y. Preparing letter re privilege logs. Preparing for depositions. Conferring with J. Ross re deposition preparation.

6.20 $2,945.00

04/22/15 L. Eccles Conferring with trial team via email re discovery issues.

2.20 $1,100.00

04/22/15 M. Fisher Reviewing documents re Krasdale, Retail Marketing Group, and Niemann Foods.

6.80 $1,870.00

04/22/15 R. Hess Reviewing emails, deposition summaries, proposed correspondence to opposing counsel and documents produced by News.

1.40 $770.00

04/22/15 J. Ross Reviewing documents for D. Godfredson deposition.

9.50 $6,650.00

04/22/15 V. Lee Creating and loading documents into the News_Gofredson Eclipse database.

0.80 $100.00

04/22/15 J. Stanley Reviewing documents. Updating privilege log. Processing documents for production. Preparing documents for J. Ross to review.

7.00 $1,890.00

04/23/15 R. Caughey Preparing for Murphy deposition. Addressing discovery issues with team. Addressing expert issues. Preparing correspondence re privilege logs. Addressing issues with interrogatory responses and conferring with client re same. Reviewing documents in connection with retailer research.

5.10 $2,422.50

04/23/15 J. Southwick Attending deposition of J. MacKie‐Mason. 7.00 $4,900.00


04/23/15 L. Eccles Conferring with trial team and co‐lead re discovery issues.

0.90 $450.00

04/23/15 M. Fisher Reviewing documents re FSI communications with Valassis.

6.60 $1,815.00

04/23/15 J. Ross Reviewing documents for D. Godfredson deposition. Preparing outline re same.

10.50 $7,350.00




Tax I.D.# 74‐2138615

04/23/15 V. Lee Exporting documents from the News_Godfredson Eclipse database. Exporting tagging data from the News_BEF_Privilege Eclipse database.

2.40 $300.00

04/23/15 J. Stanley Preparing notebooks. Preparing Food Lion documents for sdepositon.

6.00 $1,620.00

04/24/15 R. Caughey Conferring with M. Fischer re privilege logs. Addressing issues with depositions.

0.30 $142.50

04/24/15 J. Southwick Reviewing and responding to emails re numerous deposition and discovery issues. Preparing for deposition of L. Berg.

3.30 $2,310.00

04/24/15 M. Fisher Reviewing and revising Bob Evans privilege log. Reviewing documents re FSI communications with Valassis.

5.30 $1,457.50

04/24/15 J. Ross Preparing outline for D. Godfredson deposition. Discussing same with S. Benz.

8.90 $6,230.00


1.50 $187.50

04/24/15 J. Stanley Preparing documents for K. Briggs re the Bob Evans production. Preparing documents for deposition.

3.00 $810.00

04/26/15 J. Southwick Reviewing exhibits and preparing outline for L. Berg deposition.

3.90 $2,730.00

04/26/15 L. Eccles Traveling to California for deposition of M. Ordman. Preparing for deposition of M. Ordman.

5.00 $2,500.00

04/27/15 R. Hess Reviewing draft interrogatories and request for admission responses.

0.90 $495.00

04/27/15 J. Ross Attending to litigation issues. 3.40 $2,380.00

04/27/15 J. Stanley Preparing for deposition. 3.00 $810.00

04/27/15 J. Southwick Reviewing letter from defendants re email production problems. Discussing with J. Ross. Preparing for deposition of L. Berg. Reviewing emails re various discovery issues involving document production.

6.10 $4,270.00

04/27/15 M. Fisher Revising Foster Farms privilege log. 0.90 $247.50

04/27/15 L. Eccles Preparing for and attending deposition of M. Ordman. Summarizing deposition of M. Ordman. Conferring with co‐counsel re case

9.60 $4,800.00




Tax I.D.# 74‐2138615

issues. Sending trial team and co‐counsel email re discovery issues. Traveling to Seattle from Los Angeles.

04/27/15 R. Caughey Preparing for deposition of K. Murphy. Preparing interrogatory responses. Conferring with team re interrogatory responses. Participating in discovery call. Meeting with J. Southwick. Revising privilege letter to opposing counsel and conferring with team re same. Conferring with J. Stanley re documents and expert invoices.

8.50 $4,037.50

04/28/15 J. Southwick Participating in call with cocounsel. Reviewing and responding to emails re proposed stipulations and privilege logs. Preparing for deposition of L. Berg. Traveling to Detroit.

11.00 $7,700.00

04/28/15 J. Stanley Preparing documents for deposition. Preparing documents for production and review. Updating exhibits.

5.00 $1,350.00

04/28/15 R. Hess Conferring by email with paralegals re case deposition notebook. Conferring in office with R. Caughey re emails to third parties and expert materials. Conferring by phone with trial team.

1.30 $715.00

04/28/15 M. Fisher Conferring by phone with News litigation team. Revising Foster Farms privilege log.

2.90 $797.50

04/28/15 L. Eccles Participating in weekly trial team call. Emailing opposing counsel re draft stipulations on prior testimony. Emailing re Dole witness.

4.70 $2,350.00

04/28/15 R. Caughey Participating in management committee call. Redacting and producing Valassis communications. Conferring with team re privilege claims. Revising and sending privilege log letter to opposing counsel. Preparing for K. Murphy deposition. Preparing interrogatory responses. Meeting with J. Southwick.

7.30 $3,467.50

04/29/15 J. Stanley Preparing for deposition. Conferring with K. Briggs re Bobs Evans documents. Preparing documents for production. Updating

6.00 $1,620.00




Tax I.D.# 74‐2138615

exhibits.

04/29/15 V. Lee Creating and loading documents into the News_Dmochowski Eclipse database. Creating and loading documents into the BEF_Newly_Priv Eclipse database.

1.20 $150.00

04/29/15 J. Ross Reviewing deposition transcript and documents in preparation for upcoming deposition.

5.40 $3,780.00

04/29/15 J. Southwick Preparing for and attending deposition of L. Berg.

8.50 $5,950.00


04/29/15 R. Hess Reviewing and revising draft correspondence re privilege log. Reviewing transcript of deposition, expert depositions and amended complaint. Conferring by email with trial team. Reviewing correspondence from trial team and opposing counsel. Reviewing and revising draft letter to opposing counsel.

3.50 $1,925.00


04/29/15 L. Eccles Emailing re Dole witness. Emailing and researching prior testimony. Drafting joint letter re prior testimony. Emailing and reviewing letter to court.

3.10 $1,550.00

04/29/15 R. Caughey Preparing for K. Murphy deposition. Revising interrogatory responses. Addressing discovery and privilege log issues. Conferring with clients re interrogatory responses. Reviewing deposition transcripts and preparing memoranda re Kmart.

5.50 $2,612.50

04/30/15 V. Lee Exporting documents from the News_Dmochowski Eclipse database.

0.40 $50.00

04/30/15 J. Ross Preparing for Safeway deposition. Participating in conference call. Communicating with cocounsel.

6.50 $4,550.00

04/30/15 J. Southwick Reviewing emails re discovery issues and letter to the court re defendants email production. Conferring by phone with cocounsel re letter to the court and proposed stipulations. Preparing summary

6.00 $4,200.00




Tax I.D.# 74‐2138615

of L. Berg deposition.


04/30/15 R. Hess Revising letter to J. Pauley. Reviewing transcript of expert and defendant depositions. Conferring by phone with trial team re letter to J. Pauley. Reviewing deposition summary. Conferring by email with J. Southwick re same. Conferring by email with trial team re letter to Court. Conferring with J. Southwick re same.

8.30 $4,565.00

04/30/15 L. Eccles Emailing re Dole. Reviewing draft letter to court and emailing re same. Participating in trial team call.

2.00 $1,000.00

04/30/15 R. Caughey Preparing for K. Murphy deposition. Meeting with R. Pfau. Conferring with team re discovery. Reviewing deposition transcripts. Traveling from Houston, TX to Chicago, IL.

14.20 $6,745.00

05/01/15 L. Eccles Sending trial team an email re discovery issues. Participating in teleconference with Dole. Emailing re same. Preparing and filing stipulation.

1.70 $850.00

05/01/15 J. Southwick Drafting summary of L. Berg deposition. Conferring by phone with M. Palizzi re M. Kowalczyk. Reviewing and responding to emails re discovery issues.

2.20 $1,540.00

05/01/15 R. Hess Reviewing correspondence from trial team and opposing counsel. Reviewing transcript of expert and defendant depositions.

1.60 $880.00

05/01/15 M. Fisher Revising BEF privilege log. 1.20 $330.00

05/01/15 R. Caughey Deposing K. Murphy. Preparing summary of K. Murphy deposition. Preparing for K. Murphy deposition. Conferring with R. Pfau re K. Murphy deposition. Conferring with team re discovery issues. Traveling from Chicago, IL to Houston, TX.

13.00 $6,175.00

05/02/15 R. Caughey Preparing research re K. Murphy Whole Foods analysis.

0.40 $190.00

05/04/15 J. Ross Preparing for Safeway deposition. 3.40 $2,380.00

05/04/15 J. Southwick Reviewing correspondence from March 2015 re defendants desire to seek summary

2.00 $1,400.00




Tax I.D.# 74‐2138615

judgment. Reviewing draft letter re K. Dickson discovery dispute. Reviewing and responding to emails re discovery issues.

05/04/15 V. Lee Updating the News_Bedell2 Eclipse database and the News_Gofredson Eclipse database.

0.70 $87.50

05/04/15 M. Fisher Conferring by phone with News Litigation team. Conferring in office with R. Caughey and J. Southwick re Docu‐gate. Researching and drafting memorandum re L. Berg lack of foundation arguments.

2.30 $632.50

05/04/15 J. Stanley Preparing documents for J. Ross to review for deposition. Preparing deposition notice. Updating BEF privilege log.

5.00 $1,350.00

05/04/15 R. Hess Reviewing deposition summaries. Reviewing correspondence from trial team and opposing counsel.

1.20 $660.00

05/04/15 R. Caughey Revising privilege logs. Circulating summary of Murphy deposition and conferring with J. Southwick re same. Participating in weekly associates' discovery call. Conferring with D. Brotherton re revisions to deposition. Conferring with L. Cohen re Goldman Sachs subpoena. Conferring with GSK re Dial subpoena.

3.50 $1,662.50

05/05/15 J. Southwick Participating in weekly trial team call. Reviewing letter from defense filed with court re document production. Conferring with R. Caughey and M. Fisher re approach to upcoming review of newly produced and yet to be produced documents from defendants.

2.20 $1,540.00

05/05/15 L. Eccles Participating in trial team weekly call. Emailing re same. Reviewing filings.

1.20 $600.00

05/05/15 J. Ross Preparing for upcoming Safeway deposition. Preparing for and attending conference call.

3.70 $2,590.00

05/05/15 M. Fisher Researching and drafting memorandum re L. Berg lack of foundation arguments.

1.10 $302.50

05/05/15 J. Stanley Reviewing documents for deposition. 4.00 $1,080.00

05/05/15 R. Hess Reviewing transcript of hearings. Reviewing correspondence from opposing counsel.

2.80 $1,540.00




Tax I.D.# 74‐2138615

Conferring in office with J. Southwick. Conferring by phone with potential witness. Conferring by phone with trial team.

05/05/15 R. Caughey Conferring with J. Southwick re discovery and summary judgment issues. Participating in management committee call. Preparing factual research re retailer contracts and negotiations. Revising privilege logs and addressing privilege log issues. Reviewing correspondence from opposing counsel.

3.00 $1,425.00

05/06/15 L. Eccles Reviewing email re docugate and other issues.

1.30 $650.00

05/06/15 J. Ross Preparing for upcoming deposition. 2.80 $1,960.00


2.40 $660.00

05/06/15 J. Southwick Reviewing emails and conferring with R. Caughey re BEF ROFR with NAM and discovery generally.

1.00 $700.00

05/06/15 R. Hess Reviewing correspondence from trial team and opposing counsel. Conferring by email with trial team. Reviewing expert reports to prepare response to SJ letter. Reviewing correspondence from opposing counsel re summary judgment and privilege logs. Conferring by email with R. Caughey re privilege logs.

2.30 $1,265.00

05/06/15 R. Caughey Reviewing expert materials. Revising privilege logs. Reviewing and analyzing NAM's privilege logs and preparing correspondence re same. Reviewing documents in connection with preparation for summary judgment. Conferring with team re factual arguments. Preparing legal research re monopolization. Preparing research re BI‐LO contract. Conferring with clients re ROFR agreements.

4.10 $1,947.50


3.40 $935.00

05/07/15 J. Stanley Reviewing documents for R. Caughey. 1.00 $270.00

05/07/15 J. Stanley Preparing and serving deposition notice. 0.50 $135.00




Tax I.D.# 74‐2138615

05/07/15 R. Hess Reviewing expert reports to prepare response to SJ letter.

6.20 $3,410.00

05/07/15 R. Caughey Preparing factual research re summary judgment. Drafting summary judgment letter response and conferring with team re same. Reviewing expert materials. Conferring with opposing counsel re discovery issues.

3.10 $1,472.50

05/08/15 L. Eccles Reviewing and editing draft letters and briefs.

0.30 $150.00


6.20 $1,705.00

05/08/15 J. Stanley Reviewing documents for R. Caughey . 3.00 $810.00

05/08/15 R. Hess Reviewing expert reports to prepare response to SJ letter.

0.90 $495.00

05/08/15 R. Caughey Preparing summary judgment letter. Conferring with team re summary judgment issues. Conferring with team re discovery issues.

3.00 $1,425.00

05/10/15 J. Ross Preparing for D. Dmochowski deposition. Traveling to New York for same.

7.50 $5,250.00

05/11/15 J. Ross Preparing for and taking D. Dmochowski deposition. Writing up summary of same and sending to plaintiff's counsel.

8.00 $5,600.00

05/11/15 J. Southwick Reviewing letter from NAM filed with court seeking pre‐motion conference re summary judgment motion and related emails from trial team.

2.20 $1,540.00

05/11/15 J. Stanley Preparing documents for deposition. Updating fee/expense chart.

3.00 $810.00

05/11/15 R. Hess Reviewing correspondence and attached transcripts from opposing counsel. Reviewing transcript of experts. Conferring by email with J. Ross re Safeway deposition. Reviewing draft response to opposing counsel correspondence.

4.70 $2,585.00

05/11/15 L. Eccles Reviewing News request for summary judgment. Drafting response and emailing re same.

2.20 $1,100.00

05/11/15 M. Fisher Revising BEF privilege Log. 1.30 $357.50




Tax I.D.# 74‐2138615

05/11/15 R. Caughey Preparing summary judgment letter. Addressing fact issues. Reviewing deposition testimony. Addressing privilege log issues. Participating in associates' discovery call.

3.00 $1,425.00

05/12/15 L. Eccles Participating in weekly trial team call. Reviewing draft summary judgment letter.

1.40 $700.00

05/12/15 M. Fisher Conferring by phone with News Litigation team. Revising BEF privilege Log.

1.80 $495.00

05/12/15 J. Ross Reviewing documents. Preparing for and attending weekly conference call.

3.40 $2,380.00

05/12/15 R. Hess Revising letter to J. Pauley. Conferring by phone and email with trial team. Researching points of law re market definition.

6.80 $3,740.00


2.00 $540.00

05/12/15 J. Southwick Researching, drafting, revising, and circulating letter to court re defendants request for summary judgment.

8.80 $6,160.00

05/12/15 R. Caughey Revising summary judgment letter and conferring with team re same. Conferring with J. Southwick re L. Mortimer documents and preparing factual research re same. Conferring with clients re summary judgment verification.

1.00 $475.00

05/13/15 J. Southwick Reviewing emails re letter to court re possible summary judgment motion.

3.70 $2,590.00

05/13/15 L. Eccles Emailing trial team re summary judgment letter draft. Revising same.

2.90 $1,450.00

05/13/15 J. Ross Reviewing documents. Returning to Houston from deposition.

5.60 $3,920.00

05/13/15 R. Hess Revising correspondence to court. Reviewing drafts of same. Reviewing correspondence from trial team. Reviewing transcript of expert deposition.

2.10 $1,155.00

05/13/15 J. Stanley Preparing documents for J. Southwick to review.

3.00 $810.00

05/13/15 R. Caughey Addressing issues relating to third‐party discovery. Addressing issues relating to document production.

1.00 $475.00




Tax I.D.# 74‐2138615

05/14/15 L. Eccles Emailing re summary judgment letter. Reviewing case and prepping for same.

1.20 $600.00

05/14/15 J. Ross Attending to upcoming pretrial tasks. Reviewing documents re same.

2.50 $1,750.00

05/14/15 R. Hess Conferring by email with trial team. Reviewing and revising draft portions of motion for summary judgment letter response. Researching points of law and preparing same.

2.00 $1,100.00

05/14/15 J. Southwick Researching and revising letter to court re defendants request for summary judgment.

7.50 $5,250.00

05/14/15 R. Caughey Drafting and revising summary judgment letter, including damages portion. Conferring with team re same. Checking and revising factual citations.

3.00 $1,425.00

05/15/15 J. Ross Attending to correspondence and strategic issues. Reviewing documents related to privilege log issues. Reviewing documents.

3.40 $2,380.00

05/15/15 R. Hess Conferring by phone with attorney for potential witness. Reviewing privilege logs and documents in preparation for same.

1.10 $605.00

05/15/15 J. Southwick Fact citing letter to court re defendants' request for leave to file summary judgment. Conferring with J. Smith re edits to letter.

2.20 $1,540.00

05/18/15 J. Southwick Reviewing and responding to emails re remaining discovery items.

0.60 $420.00

05/18/15 R. Hess Conferring by email with trial team. Reviewing correspondence from opposing counsel.

0.70 $385.00

05/19/15 J. Southwick Participating in weekly trial team call. Reviewing and responding to emails re NAM production at Susman Godfrey. Reviewing 30b6 notice to NAM re document production issues. Reviewing draft interrogatory responses.

4.70 $3,290.00

05/19/15 L. Eccles Reviewing email re docugate. 0.30 $150.00

05/19/15 J. Ross Preparing for and attending trial team conference call.

1.00 $700.00

05/19/15 R. Hess Conferring by phone and preparing for conference with trial team.

0.90 $495.00




Tax I.D.# 74‐2138615

05/19/15 M. Fisher Conferring by phone with News litigation team. Drafting and emailing verifications to Foster Farms and BEF.

1.80 $495.00

05/19/15 V. Lee Conferring with Mr. Southwick, Mr. Peacock, and Kellogg, Huber staff about the reception of a 500 GB data set. Creating and loading text into the News_DocuGate Eclipse database.

2.90 $362.50

05/20/15 J. Southwick Reviewing and responding to emails re recent production of documents by NAM and plaintiffs responses to interrogatories.

0.50 $350.00

05/20/15 J. Ross Reviewing documents. 3.40 $2,380.00

05/20/15 R. Hess Reviewing transcripts of depositions and expert reports. Reviewing correspondence between counsel and responding to same. Reviewing and conferring by email re privilege log issues.

3.80 $2,090.00

05/20/15 J. Stanley Preparing materials to be sent to K. Briggs for production.

1.00 $270.00

05/20/15 V. Lee Loading data and text into the News_DocuGate Eclipse database.

2.80 $350.00

05/21/15 V. Lee Loading data, text, and documents into the News_DocuGate Eclipse database.

6.20 $775.00

05/22/15 J. Ross Attending to discovery issues. Reviewing correspondence. Reviewing new News production issues.

2.40 $1,680.00

05/22/15 M. Fisher Reviewing News privilege log for T. Bedell related documents.

4.50 $1,237.50

05/22/15 V. Lee Loading documents into the News_DocuGate Eclipse database.

4.00 $500.00

05/23/15 V. Lee Loading documents into the News_DocuGate Eclipse database.

1.00 $125.00

05/26/15 J. Stanley Reviewing and updating privilege logs. 1.00 $270.00

05/26/15 M. Fisher Conferring by phone with News Litigation team. Revising privilege logs for BEF and Foster Farms.

3.90 $1,072.50

05/26/15 J. Ross Preparing for and participating in cocounsel call. Reporting to Susman Godfrey trial team re same. Reviewing documents re expert issues. Attending to pretrial issues.

8.50 $5,950.00




Tax I.D.# 74‐2138615

Attending to privilege log issues.

05/26/15 L. Eccles Attending weekly call. 0.70 $350.00

05/27/15 M. Fisher Revising privilege logs for BEF and Foster Farms.

2.20 $605.00

05/27/15 R. Hess Reviewing correspondence from opposing counsel and trial team. Reviewing correspondence from opposing counsel re privilege logs. Reviewing correspondence from trial team re 30(b)(6) deposition.

1.20 $660.00

05/27/15 L. Eccles Sending trial team email. 0.10 $50.00

05/28/15 L. Eccles Reviewing trial team email. 2.20 $1,100.00

06/01/15 J. Ross Discussing log issues with other counsel. Attending to same. Reviewing documents.

2.60 $1,820.00

06/01/15 M. Fisher Conferring by phone with News Litigation Associate team. Revising privilege logs for BEF and Foster Farms.

6.80 $1,870.00

06/01/15 R. Caughey Addressing discovery and privilege issues. Conferring with M. Fischer re same.

1.30 $617.50

06/02/15 J. Southwick Preparing for and participating in weekly call with cocounsel. Reviewing and responding to emails re hosting new document production and document reviewing plans.

1.30 $910.00

06/02/15 L. Eccles Attending weekly call. Reviewing email re docugate.

1.10 $550.00

06/02/15 R. Hess Reviewing correspondence from trial team. Conferring by phone with trial team.

1.00 $550.00


2.20 $605.00

06/02/15 R. Caughey Reviewing DocuGate documents and conferring with team re same. Participating in management committee call. Conferring with team re discovery and document issues. Addressing privilege log issues. Preparing memorandum to team re DocuGate review and retailer memorandum.

3.50 $1,662.50

06/03/15 J. Southwick Reviewing NAM letter re 30(b)(6). Conferring by phone with cocounsel re 30(b)(6) situation and whether to seek court intervention. Reviewing and responding to

1.30 $910.00




Tax I.D.# 74‐2138615

email re analyzing newly produced documents from NAM.

06/03/15 J. Ross Reviewing documents. Attending to document production failure issue.

4.70 $3,290.00

06/03/15 L. Eccles Conferring by email with trial team re docugate.

0.50 $250.00


8.40 $2,310.00

06/03/15 R. Hess Conferring by email with trial team. 0.60 $330.00

06/03/15 J. Stanley Preparing documents for R. Caughey. 1.00 $270.00

06/03/15 R. Caughey Reviewing documents and preparing memoranda re same. Participating in call re retailer memoranda and preparing memoranda to team re same.

2.00 $950.00

06/04/15 J. Southwick Reviewing draft letter to News re 30b6 witness. Reviewing and responding to email re document review.

0.90 $630.00

06/04/15 L. Eccles Reviewing trial team email re opposing counsel. Reviewing retailer chronologies.

1.20 $600.00


6.30 $1,732.50

06/04/15 R. Caughey Reviewing documents and preparing memoranda re same. Addressing issues with privilege log.

2.00 $950.00


8.20 $2,255.00

06/05/15 R. Caughey Reviewing documents. Meeting with team re retailer memorandum. Reviewing documents re retailer memorandum.

1.50 $712.50

06/06/15 V. Lee Creating and loading documents into the News_Docugate2 Eclipse database.

0.50 $62.50

06/08/15 V. Lee Loading documents into the News_Docugate2 Eclipse database.

2.20 $275.00

06/08/15 M. Fisher Conferring by phone with News Litigation Associate team. Revising privilege logs for BEF and Foster Farms.

8.30 $2,282.50

06/08/15 R. Caughey Participating in weekly discovery call. Preparing privilege logs. Reviewing DocuGate documents and preparing

2.80 $1,330.00




Tax I.D.# 74‐2138615

memoranda re same. Addressing discovery issues.


7.80 $2,145.00

06/09/15 R. Hess Researching points of law re class certification case before Supreme Court.

0.30 $165.00

06/09/15 R. Caughey Reviewing DocuGate documents and preparing memorandum to team re same. Addressing issues relating to third‐party discovery.

3.00 $1,425.00

06/10/15 V. Lee Updating the News_Docugate2 Eclipse database.

0.70 $87.50


8.00 $2,200.00


06/10/15 R. Caughey Reviewing DocuGate documents and preparing memorandum to team re same. Addressing issues with documents and privilege logs.

2.00 $950.00

06/11/15 M. Fisher Revising privilege logs for BEF and Foster Farms. Researching and preparing memorandum on Valassis SuperValu contract.

8.90 $2,447.50


3.20 $400.00

06/12/15 M. Fisher Revising privilege logs for BEF and Foster Farms. Researching and preparing memorandum on Valassis SuperValu contract.

5.20 $1,430.00

06/12/15 L. Eccles Conferring by email with trial team re discovery issues

1.50 $750.00

06/12/15 R. Caughey Drafting memorandum re Kroger retailer agreements and negotiations. Addressing issues relating to retailer documents. Reviewing DocuGate documents.

3.50 $1,662.50


06/15/15 R. Hess Reviewing correspondence from trial team re pre‐conference letter exchange.

0.20 $110.00




Tax I.D.# 74‐2138615

06/15/15 L. Eccles Conferring by email re third party deposition issue. Reviewing file re same.

0.40 $200.00

06/15/15 M. Fisher Conferring by phone with News Litigation Associate team. Revising Privilege Logs for BEF and Foster Farms.

8.10 $2,227.50

06/15/15 R. Caughey Reviewing documents. Addressing privilege log issues. Reviewing DocuGate documents. Preparing retailer memorandums. Conferring with team re discovery issues.

3.00 $1,425.00

06/15/15 V. Lee Creating and loading documents into the News_Non‐Docugate Eclipse database.

1.00 $125.00

06/16/15 R. Caughey Reviewing DocuGate documents and preparing memorandum re same. Preparing retailer memoranda. Addressing privilege log and discovery issues.

3.50 $1,662.50

06/17/15 M. Fisher Revising Privilege Logs for BEF and Foster Farms.

7.80 $2,145.00

06/17/15 R. Caughey Reviewing DocuGate documents and preparing memoranda re same.

1.00 $475.00

06/18/15 J. Southwick Reviewing order on class certification. Conferring on calls and emails re class certification order and lead counsel issue.

2.00 $1,400.00

06/18/15 L. Eccles Reviewing trial team email. Reviewing class certification order.

0.30 $150.00

06/18/15 M. Fisher Revising Privilege Logs for BEF and Foster Farms.

9.20 $2,530.00

06/18/15 R. Caughey Participating in management committee call. Reviewing DocuGate documents. Conferring with team re privilege logs and retailers. Reviewing class certification order and conferring with team re same. Conferring with J. Smith re issues.

2.20 $1,045.00

06/18/15 R. Hess Conferring by email with J. Southwick. Reviewing class certification order. Researching points of law and researching factual matters re same.

2.70 $1,485.00

06/19/15 J. Southwick Conferring by phone with D. Goldman and emails re lead counsel issue.

0.50 $350.00

06/19/15 L. Eccles Reviewing trial team email re class certification and schedule.

0.20 $100.00




Tax I.D.# 74‐2138615

06/19/15 M. Fisher Researching and preparing memorandum on Supervalu.

5.50 $1,512.50

06/19/15 R. Caughey Reviewing documents, preparing correspondence, and addressing scheduling issues.

1.00 $475.00

06/22/15 J. Southwick Conferring by phone with M. Palizzi. Preparing and conferring by phone with cocounsel re lead counsel issue and hearing on June 30. Reviewing and responding to email.

1.40 $980.00

06/22/15 M. Fisher Conferring by phone with News Litigation Associates. Researching and preparing Supervalu memorandum. Revising BEF and Foster Farms privilege logs

6.60 $1,815.00

06/22/15 R. Caughey Participating in weekly discovery call. Revising privilege logs. Preparing retailer memoranda. Conferring with J. Southwick re strategy. Reviewing DocuGate documents.

2.50 $1,187.50

06/22/15 L. Eccles Conferring by email with trial team. 0.20 $100.00

06/23/15 J. Southwick Attending weekly call with cocounsel. Reviewing and responding to emails.

0.80 $560.00

06/23/15 V. Lee Updating the News_Non‐Docugate Eclipse database.

1.30 $162.50

06/23/15 M. Fisher Researching and preparing Supervalu memorandum.

2.20 $605.00

06/23/15 R. Caughey Reviewing DocuGate documents and sending memoranda to team re hot documents.

3.20 $1,520.00

06/24/15 M. Fisher Revising Foster Farms privilege log. Revising BEF privilege log.

9.20 $2,530.00

06/24/15 R. Caughey Revising privilege logs and conferring with M. Fisher re same. Reviewing case law re privilege logs. Reviewing DocuGate documents and materials re 23(f) appeal. Conferring with team and reviewing correspondence. Conferring with team re terms and conditions of BEF‐NAM agreement.

2.50 $1,187.50

06/24/15 V. Lee Updating the News_Non‐Docugate Eclipse database.

1.30 $162.50




Tax I.D.# 74‐2138615

06/25/15 R. Hess Reviewing correspondence from opposing counsel. Conferring by email with trial team.

0.30 $165.00

06/25/15 M. Fisher Revising Foster Farms privilege log. Revising BEF privilege log.

9.40 $2,585.00

06/25/15 R. Caughey Conferring with J. Southwick re appeal. Preparing research re appeal. Reviewing correspondence re privilege logs. Conferring with counsel group re privilege logs.

1.20 $570.00


06/25/15 L. Eccles Reviewing K. Gallo letter, D. Goldman letter, and trial team email re hot documents and schedule.

0.80 $400.00

06/26/15 M. Fisher Revising Foster Farms privilege log. Revising BEF privilege log. Redacting privileged BEF documents. Preparing production of BEF and Foster Farms documents.

7.40 $2,035.00

06/28/15 J. Southwick Reviewing cocounsel agreement and emails re lead counsel issue.

1.10 $770.00

06/29/15 R. Caughey Participating in weekly discovery call. Addressing discovery and document issues.

0.40 $190.00

06/29/15 R. Hess Reviewing correspondence from trial team and opposing counsel. Conferring in office with J. Southwick re court order.

0.80 $440.00

06/29/15 J. Southwick Conferring with R. Hess, J. Ross, and S. Benz re lead counsel. Traveling to New York. Preparing for hearing.

7.70 $5,390.00

06/29/15 L. Eccles Reviewing trial team email and filings. 0.20 $100.00

06/30/15 J. Southwick Preparing for and attending hearing re summary judgment and 30(b)(6). Conferring with cocounsel re lead counsel.

6.00 $4,200.00



06/30/15 R. Caughey Reviewing DocuGate documents and addressing issues with discovery. Conferring with clients. Addressing scheduling issues.

2.90 $1,377.50

07/01/15 J. Southwick Conferring by phone with S. Benz re lead counsel. Reviewing total firm billings to date and finances of the case. Reviewing and responding to email. Conferring with R.

5.90 $4,130.00




Tax I.D.# 74‐2138615

Caughey and M. Fisher re tasks going forward. Reviewing rule 23(f) case law.

07/01/15 L. Eccles Reviewing trial team email re scheduling conference.

0.20 $100.00

07/01/15 J. Ross Reviewing documents. 1.30 $910.00

07/01/15 R. Caughey Preparing legal research re Rule 23(f) response and preparing memorandum re same. Conferring with J. Southwick re 23(f) issues. Reviewing order and class certification briefing. Preparing retailer memoranda. Reviewing DocuGate documents.

3.50 $1,662.50

07/02/15 J. Southwick Reviewing Second Circuit opinion reversing class certification of intern class and preparing email to trial team. Reviewing defendants 23(f) petition. Conferring by phone with S. Benz and L. LeClair re lead counsel issue.

3.30 $2,310.00

07/02/15 L. Eccles Reviewing email re upcoming tasks. 0.10 $50.00

07/02/15 R. Caughey Preparing memorandum to team re upcoming tasks and assignments. Meeting with J. Southwick. Reviewing and commenting on NAM's Rule 23(f) Petition. Preparing legal research re Rule 23(f) Petition. Reviewing DocuGate documents.

5.00 $2,375.00

07/03/15 J. Southwick Reviewing Nam's 23(f) petition and reviewing case law.

3.10 $2,170.00

07/03/15 J. Ross Reviewing draft outline of reply brief. Reviewing legal cases.

2.50 $1,750.00

07/03/15 R. Caughey Preparing legal research re Rule 23(f) Petition. Preparing outline and memoranda re Rule 23(f) petition and circulating to team.

4.90 $2,327.50

07/06/15 J. Southwick Reviewing and responding to emails re 23(f) opposition. Conferring with R. Hess re state of case and 6/30/15 hearing. Conferring on phone with S. Benz and L. LeClair re lead counsel.

1.60 $1,120.00

07/06/15 J. Ross Meeting with trial team re drafting response to Rule 2(f) motion. Researching factual

5.80 $4,060.00




Tax I.D.# 74‐2138615

matters and researching points of law re same.

07/06/15 R. Hess Researching factual matters and researching re 23(f) petition. Reviewing same. Conferring by email with trial team. Reviewing correspondence from trial team. Conferring in office with J. Southwick re hearing and conference with trial team. Reviewing transcript of hearing.

3.20 $1,760.00

07/06/15 R. Caughey Preparing response to 23(f) petition and meeting with team re same. Conferring with J. Southwick re 23(f) petition. Preparing legal research. Participating in weekly discovery call. Conferring with R. Pfau re 23(f) issues.

3.50 $1,662.50

07/06/15 M. Fisher Conferring at office of R. Caughey with J. Ross regarding 23(f) motion. Researching and drafting outline for section of 23(f) response motion.

2.30 $632.50

07/07/15 J. Southwick Participating in weekly trial team call. Reviewing and responding to email re discovery issues and 23(f) opposition brief. Conferring with J. Ross re 23(f) petition. Conferring with D. Goldman and S. Benz re lead counsel issue.

3.50 $2,450.00

07/07/15 R. Caughey Drafting Rule 23(f) Petition response and conferring with team re same.

3.00 $1,425.00

07/07/15 M. Fisher Researching and drafting outline for section of 23(f) response motion.

4.20 $1,155.00

07/07/15 R. Hess Reviewing and revising outline for 26(f) response. Researching points of law re same. Reviewing case law and pending SC petitions. Reviewing correspondence from trial team. Conferring in office with J. Southwick. Reviewing class certification order. Researching points of law and researching factual matters re same. Conferring by phone with trial team. Conferring by email with J. Southwick and R. Caughey.

8.50 $4,675.00

07/07/15 J. Ross Attending to Rule 23(f) response. Conferring with trial team re same. Reviewing expert

5.60 $3,920.00




Tax I.D.# 74‐2138615

response re same.

07/08/15 J. Southwick Conferring by phone and emails re lead counsel issue. Preparing letter to court re lead counsel selection. Reviewing and responding to emails re 23(f) opposition.

1.40 $980.00

07/08/15 R. Caughey Drafting, revising, and circulating draft of Rule 23(f) response. Preparing legal research and conferring with team re same.

10.90 $5,177.50

07/08/15 J. Stanley Conferring with R. Caughey re brief. 0.50 $135.00

07/08/15 M. Fisher Researching and drafting outline for section of 23(f) response motion.

9.40 $2,585.00

07/08/15 R. Hess Reviewing and revising draft correspondence to opposing counsel. Reviewing draft stipulation. Reviewing and revising long from class notice. Reviewing proposals from administrators. Reviewing and revising outline for 23(f) response. Researching points of law re same. Reviewing case law and pending SC petitions. Reviewing and revising potential agreement. Conferring by email with J. Southwick.

5.30 $2,915.00

07/08/15 J. Ross Researching factual matters and researching points of law re section of Rule 23(f) response. Drafting and editing same. Reviewing other sections of the brief. Editing same.

8.50 $5,950.00

07/08/15 L. Eccles Conferring via email with trial team re petition response and call with R. Caughey.

0.60 $300.00

07/09/15 R. Caughey Drafting, revising, and circulating revisions of Rule 23(f) response. Preparing research and analysis re adequacy issues. Addressing logistics of filing Rule 23(f) response and meeting with team re same.

11.10 $5,272.50

07/09/15 J. Southwick Reviewing case law and commenting on draft brief opposing 23(f) petition.

5.40 $3,780.00

07/09/15 M. Fisher Revising and editing 23(f) response motion. Researching question of "adequacy" in class certification.

8.70 $2,392.50

07/09/15 R. Hess Revising response to 23(f) petition. 3.80 $2,090.00




Tax I.D.# 74‐2138615

07/09/15 J. Ross Reviewing and editing various sections of Rule 23(f) brief.

8.00 $5,600.00

07/09/15 L. Eccles Revising brief. 2.90 $1,450.00

07/10/15 J. Southwick Revising and editing brief opposing 23(f) petition.

4.20 $2,940.00

07/10/15 R. Caughey Drafting and revising Rule 23(f) Response. Addressing discovery issues and filing issues. Conferring with J. Southwick re issues.

5.50 $2,612.50

07/10/15 R. Hess Revising response to 23(f) petition. 6.80 $3,740.00

07/10/15 J. Ross Attending to Rule 23(f) brief. 4.70 $3,290.00

07/11/15 J. Southwick Conferring by emails re edits to 23(f) opposition brief.

1.00 $700.00

07/11/15 R. Caughey Reviewing comments to Rule 23(f) response, inputting changes, and preparing memorandum re Sykes to team. Conferring with J. Southwick.

1.90 $902.50

07/11/15 R. Hess Revising response to 23(f) petition. 0.30 $165.00

07/12/15 J. Southwick Conferring by emails re edits to 23(f) opposition brief.

0.40 $280.00

07/12/15 R. Caughey Inputting revisions to Rule 23(f) response, preparing legal research re Rule 23(f) response, and circulating revised version to team.

2.00 $950.00

07/12/15 R. Hess Revising response to 23(f) petition. 0.30 $165.00

07/12/15 J. Ross Attending to final review of Rule 23(f) brief. 1.50 $1,050.00

07/12/15 L. Eccles Conferring via email re 23(f) motion. 0.50 $250.00

07/13/15 J. Stanley Assisting with brief and preparing for filing. 2.00 $540.00

07/13/15 J. Southwick Conferring with R. Caughey and J. Stanley re final preparation and filing of opposition to rule 23(f) petition.

0.70 $490.00

07/13/15 R. Caughey Revising, finalizing, and filing Rule 23(f) response and conferring with team re same. Participating in weekly discovery call. Reviewing documents. Meeting with J. Southwick.

8.00 $3,800.00

07/13/15 V. Lee Updating the News_Docugate3 and News_Non‐Docugate Eclipse databases. Creating and loading documents into the News_Docugate4 Eclipse database.

3.40 $425.00




Tax I.D.# 74‐2138615

07/13/15 R. Hess Revising response to 23(f) petition. Reviewing task list and draft filing. Conferring by email with trial team.

1.30 $715.00

07/13/15 J. Ross Attending to pretrial issues. 4.80 $3,360.00

07/13/15 M. Fisher Conferring by phone with R. Caughey and News Associates; Researching "docugate" database for SuperValu documents.

2.30 $632.50

07/14/15 J. Southwick Preparing for and participating in trial team call. Reviewing and responding to emails re consultant for 30(b)(6) deposition. Attending lunch meeting with R. Hess, J. Ross, and R. Caughey.

4.10 $2,870.00

07/14/15 L. Eccles Attending weekly conference call. 1.20 $600.00


0.20 $25.00

07/14/15 M. Fisher Conferring by phone with News Litigation team. Researching "docugate" database for SuperValu documents.

2.50 $687.50

07/14/15 J. Ross Meeting with trial team. Preparing for and attending weekly conference call. Reviewing documents.

3.50 $2,450.00

07/14/15 R. Hess Reviewing class certification papers and decision. Reviewing summary judgment issues. Conferring by email with trial team. Reviewing and revising task list. Attending trial team meeting. Conferring by phone with trial team.

5.40 $2,970.00

07/14/15 R. Caughey Preparing letter to opposing counsel re privilege logs. Participating in management committee call. Meeting with team re upcoming tasks. Reviewing documents and preparing retailer memoranda.

4.00 $1,900.00

07/15/15 J. Southwick Conferring by phone with K. Hoek re background of case and upcoming tasks.

0.30 $210.00

07/15/15 M. Fisher Researching "docugate" database for SuperValu documents.

2.20 $605.00


07/15/15 J. Ross Reviewing pleadings and correspondence. 1.70 $1,190.00

07/15/15 K. Hoek Participating in call with J. Southwick to discuss background. Reviewing background

0.70 $420.00




Tax I.D.# 74‐2138615

materials.

07/15/15 R. Hess Reviewing class certification papers and decision. Reviewing summary judgment issues. Conferring by email with trial team. Reviewing and revising task list.

0.60 $330.00

07/15/15 R. Caughey Addressing document review protocols. Conferring with team re upcoming tasks and meetings. Reviewing documents. Preparing legal research re contract terms.

1.90 $902.50

07/16/15 J. Southwick Meeting with Susman Godfrey team to develop task sheet for all cocounsel document review and legal research needs in preparation for summary judgment. Reviewing and responding to emails.

2.50 $1,750.00

07/16/15 L. Eccles Preparing for and attending trial team conference call. Reviewing co‐lead email.

1.30 $650.00


8.40 $2,310.00

07/16/15 J. Stanley Conferring with trial team and K. Briggs re documents.

2.80 $756.00

07/16/15 K. Hoek Participating in call with SG trial team to discuss document review and legal research projects. Reviewing background materials.

3.00 $1,800.00

07/16/15 R. Hess Conferring in office with Susman Godfrey trial team. Reviewing summary judgment letter briefs and hearing transcript. Conferring by email with trial team. Reviewing proposed correspondence to opposing counsel. Reviewing class administrator proposals.

2.70 $1,485.00

07/16/15 R. Caughey Preparing retailer memorandums. Reviewing DocuGate documents. Meeting with team re fact development tasks. Preparing task list re fact development tasks. Reviewing discovery correspondence. Addressing privilege log issues.

3.50 $1,662.50

07/17/15 J. Southwick Conferring by phone with cocounsel re tasks to complete review of recently produced documents. Reviewing and responding to email.

0.80 $560.00




Tax I.D.# 74‐2138615


8.30 $2,282.50

07/17/15 J. Stanley Updating case files. Preparing documents for review.

2.00 $540.00

07/17/15 J. Ross Reviewing draft pleadings. Commenting on same. Reviewing documents.

4.50 $3,150.00

07/17/15 K. Hoek Reviewing background materials. 4.00 $2,400.00

07/17/15 R. Hess Conferring by email with trial team. 0.20 $110.00

07/17/15 R. Caughey Reviewing DocuGate documents. Conferring with opposing counsel re discovery issues. Participating in call re document discovery tasks and conferring with team re same.

2.80 $1,330.00

07/19/15 R. Caughey Conferring with team re issues re Rule 23(f) petition and discovery.

0.50 $237.50

07/20/15 J. Southwick Conferring by email re News motion to file reply in support of 23(f) petition.

0.30 $210.00


8.10 $2,227.50


1.40 $378.00

07/20/15 R. Hess Reviewing reply on 23(f). Conferring by email with trial team. Reviewing class notice papers.

1.00 $550.00

07/20/15 R. Caughey Reviewing and commenting on News's proposed Rule 23(f) reply. Reviewing DocuGate hot documents and preparing memorandum to team re same. Participating in weekly discovery teleconference. Updating task list and circulating to team. Preparing retailer memoranda.

3.50 $1,662.50

07/20/15 K. Hoek Reviewing case materials and emails. 6.00 $3,600.00

07/20/15 L. Eccles Reviewing emails re 23(f). 0.10 $50.00

07/21/15 J. Southwick Attending weekly trial team call. Reviewing emails re opposition to News request for leave to file sur‐reply in support of 23(f) petition.

0.90 $630.00

07/21/15 R. Caughey Drafting, revising, and circulating response to News's motion for leave. Participating in

2.50 $1,187.50




Tax I.D.# 74‐2138615

weekly management committee call. Addressing document discovery issues.

07/21/15 K. Hoek Reviewing case materials and emails. 5.50 $3,300.00

07/21/15 L. Eccles Conferring via email with J. Southwick re third‐party testimony.

0.20 $100.00

07/21/15 L. Eccles Drafting letter re third‐party testimony. 1.00 $500.00

07/21/15 L. Eccles Reviewing emails re 23(f) and other issues. 0.40 $200.00


8.00 $2,200.00

07/21/15 R. Hess Reviewing and revising response to motion for leave for surreply. Reviewing and revising response to motion for leave.

2.30 $1,265.00

07/22/15 J. Southwick Reading cases referenced in opposition to motion for leave to file reply in support of 23(f) petition and discussing with R. Caughey.

2.60 $1,820.00

07/22/15 R. Caughey Preparing legal research re predominance and adequacy. Conferring with team re Rule 23(f) issues. Reviewing and revising Rule 23(f) brief and meeting with J. Southwick re same. Conferring with K. Hoek re legal research and background.

1.10 $522.50

07/22/15 K. Hoek Reviewing case materials 1.00 $600.00

07/22/15 L. Eccles Conferring via email with trial team re motion for leave and other issues.

0.20 $100.00


7.80 $2,145.00

07/23/15 J. Southwick Reviewing and commenting on brief opposition motion for leave to file a reply in support of defendant's 23(f) appeal. Reviewing proposed stipulation concerning FSI claims. Conferring by phone with R. Caughey, J. Briody, and D. Goldman re proposed stipulation.

3.70 $2,590.00

07/23/15 R. Caughey Reviewing, revising, and filing opposition to motion for leave. Meeting with team re opposition to motion for leave. Reviewing DocuGate documents and conferring with team re same. Addressing issues relating to retailer project.

3.50 $1,662.50




Tax I.D.# 74‐2138615

07/23/15 K. Hoek Reviewing and analyzing expert materials. 3.50 $2,100.00

07/24/15 J. Southwick Reviewing and responding to emails re hosting email production on SG servers, pre‐motion letter re use of testimony from prior cases, and K. Hoek research.

0.60 $420.00

07/24/15 R. Caughey Addressing issues relating to documents and data. Addressing issues relating to legal research. Preparing memoranda.

1.00 $475.00

07/24/15 K. Hoek Reviewing and analyzing expert materials. 3.00 $1,800.00

07/27/15 R. Caughey Participating in weekly discovery call. Updating and circulating task list to team. Addressing document and data issues. Reviewing communications.

1.00 $475.00

07/27/15 R. Hess Researching points of law re use of prior case depositions.

2.50 $1,375.00

07/27/15 J. Ross Reviewing documents re Kroger negotiations.

3.00 $2,100.00

07/27/15 L. Eccles Conferring via email with trial team re third party testimony.

1.20 $600.00


0.70 $87.50

07/28/15 R. Caughey Participating in weekly conference call. Reviewing DocuGate documents. Conferring with team re research projects. Conferring with team re scheduling. Reviewing legal research re exclusionary conduct. Reviewing fourth amended complaint.

1.90 $902.50

07/28/15 L. Eccles Conferring via email with trial team re documents, jury consultants, and third party testimony. Conferring via telephone with R. Hess re same.

1.70 $850.00

07/29/15 R. Caughey Reviewing DocuGate documents. Conferring with J. Smith re MMM and depositions. Addressing issues with documents. Preparing retailer memoranda.

2.90 $1,377.50


3.80 $1,045.00

07/29/15 L. Eccles Conferring via email re third party testimony letter.

0.10 $50.00

07/30/15 R. Caughey Addressing document management issues. 1.50 $712.50




Tax I.D.# 74‐2138615

Reviewing memoranda and preparing retailer memoranda. Communicating with cocounsel re discovery issues.

07/30/15 K. Hoek Reviewing emails and case materials. 1.50 $900.00


2.10 $577.50

07/30/15 L. Eccles Conferring via email re third party testimony.

0.10 $50.00

07/31/15 R. Caughey Reviewing privilege log issues. Conferring with team re documents and discovery. Preparing retailer memoranda.

1.50 $712.50


07/31/15 L. Eccles Revising third party letter. 0.60 $300.00

08/02/15 R. Caughey Reviewing and preparing memorandum re NAM privilege log.

1.00 $475.00

08/03/15 K. Hoek Conducting legal research regarding exclusivity provisions of contract.

1.50 $900.00

08/03/15 R. Hess Researching HEB information. 0.50 $275.00

08/03/15 M. Fisher Conferring by phone with NAM litigation associates. Researching "docugate" database for SuperValu documents.

0.60 $165.00

08/03/15 R. Caughey Reviewing privilege log and preparing memorandum re same. Participating in weekly discovery call. Revising task list. Reviewing documents.

2.10 $997.50


08/04/15 R. Hess Preparing for conference call. Reviewing stipulation of dismissal. Reviewing jury research proposals. Reviewing and revising letter re third party depositions. Conferring by phone with trial team. Conferring by email with J. Southwick, L.G. Eccles and J. Stanley. Conferring by phone with R. Caughey. Researching factual matters re HEB‐NAM contractual relationship re retailer memorandum. Researching points of law re staggered contracts and business foreclosure. Reviewing memoranda. Reviewing documents re Nestle and Uniliver settlements.

6.90 $3,795.00




Tax I.D.# 74‐2138615

08/04/15 M. Fisher Conferring by phone with NAM litigation team. Researching "docugate" database for SuperValu documents.

1.10 $302.50

08/04/15 V. Lee Creating and loading documents into the News_20150804 Eclipse database.

1.60 $200.00

08/04/15 R. Caughey Participating in weekly management committee call. Communicating with opposing counsel re document production and privilege logs. Communicating with cocounsel re privilege logs. Reviewing and analyzing NAM's privilege log. Conferring with R. Hess re retailer memoranda. Addressing document issues.

4.50 $2,137.50

08/05/15 R. Hess Reviewing documents and conferring by email with L.G. Eccles. Conferring by email with K. Hoek re legal research. Reviewing documents and preparing memorandum.

4.40 $2,420.00


1.70 $467.50

08/05/15 V. Lee Updating the News_20150804 Eclipse database.

0.70 $87.50

08/05/15 R. Caughey Reviewing privilege log and preparing memorandum re same. Conferring with opposing counsel re discovery. Reviewing DocuGate documents. Preparing fact discovery memoranda. Addressing document discovery issues.

4.10 $1,947.50

08/06/15 K. Hoek Conducting legal research regarding exclusivity and long‐term agreements.

3.00 $1,800.00


8.30 $2,282.50

08/06/15 R. Hess Reviewing documents and preparing memorandum. Reviewing proposed letter and stipulation. Conferring by email with J. Southwick re same.

4.10 $2,255.00

08/06/15 R. Caughey Reviewing summary of DocuGate deposition and conferring with team re follow‐up. Conferring with K. Hoek re legal research issues. Reviewing and analyzing privilege log entries and preparing memorandum re same. Addressing retailer contract project

4.50 $2,137.50




Tax I.D.# 74‐2138615

and document issues.

08/07/15 L. Eccles Conferring via email with trial team re discovery, filings, depositions, and various other issues.

2.00 $1,000.00

08/07/15 K. Hoek Conducting legal research regarding long‐term and staggered agreements.

4.00 $2,400.00


8.60 $2,365.00

08/07/15 R. Hess Reviewing documents and preparing memorandum.

1.60 $880.00

08/07/15 V. Lee Copying 570 GB data set to the Susman Godfrey network.

2.00 $250.00

08/07/15 R. Caughey Reviewing NAM's privilege log and preparing memorandum re same. Conferring with opposing counsel re privilege logs. Addressing issues relating to document management.

4.40 $2,090.00

08/09/15 J. Stanley Preparing documents for R. Hess to review. 1.00 $270.00

08/10/15 R. Hess Reviewing documents and preparing memorandum.

6.90 $3,795.00


3.20 $400.00

08/10/15 K. Hoek Conducting legal research regarding section 2 monopolization.

5.10 $3,060.00

08/10/15 M. Fisher Conferring by phone with NAM litigation associates. Researching "docugate" database for SuperValu documents.

8.10 $2,227.50

08/10/15 R. Caughey Addressing document issues. Addressing privilege log issues. Reviewing documents. Participating in weekly discovery call. Conferring with K. Hoek re research issues. Preparing memorandum re privilege log issues.

2.90 $1,377.50

08/10/15 J. Stanley Updating exhibit and deposition files. 2.00 $540.00

08/11/15 J. Southwick Preparing for and participating in weekly trial team call. Reviewing and commenting on draft stipulation concerning FSI counts in complaint. Conferring wit R. Caughey re progress of various tasks. Reviewing email traffic on various issues. Conferring with K.

3.30 $2,310.00




Tax I.D.# 74‐2138615

Hoek re legal research project. Reviewing billing, case costs and related emails.


1.50 $187.50

08/11/15 K. Hoek Conducting legal research regarding section 2 monopolization.

4.70 $2,820.00

08/11/15 M. Fisher Conferring by phone with NAM litigation team. Researching "docugate" database for SuperValu documents.

7.80 $2,145.00

08/11/15 R. Hess Reviewing documents and preparing memorandum. Conferring by phone with trial team. Conferring in office with J. Stanley re document databases. Reviewing correspondence from trial team.

7.70 $4,235.00

08/11/15 L. Eccles Attending weekly phone meeting. 0.50 $250.00

08/11/15 R. Caughey Participating in management committee call. Revising memorandum re privilege log entries and circulating to team. Drafting and revising retailer memoranda. Preparing document searches and addressing database issues.

3.00 $1,425.00

08/11/15 J. Stanley Preparing documents for review by R. Hess. 2.00 $540.00

08/12/15 J. Southwick Reviewing and responding to emails, including stipulation of dismissal of FSI claims.

1.20 $840.00


1.90 $237.50

08/12/15 K. Hoek Conducting legal research regarding section 2 monopolization. Reviewing case materials.

3.00 $1,800.00


7.50 $2,062.50

08/12/15 R. Hess Reviewing documents and preparing memorandum. Conferring by phone with trial team. Conferring in office with J. Stanley re document databases. Reviewing correspondence from trial team.

7.20 $3,960.00

08/12/15 R. Caughey Preparing privilege log analysis. Drafting and revising retailer memoranda.

2.80 $1,330.00

08/13/15 J. Southwick Conferring by phone with L. Clair. Conferring by emails with R. Hess re L. Berg

1.10 $770.00




Tax I.D.# 74‐2138615

deposition objection issue. Reviewing and responding to emails with trial team.


1.00 $600.00

08/13/15 V. Lee Creating and loading documents into the News_SG005 and the News_SG006 Eclipse database.

4.20 $525.00


8.10 $2,227.50

08/13/15 R. Hess Conferring by email with J. Southwick re Valassis deposition and legal research re same. Reviewing documents re HEB memorandum. Conferring by email with J. Stanley.

5.20 $2,860.00

08/13/15 L. Eccles Reviewing email re FSI claims. 0.50 $250.00

08/13/15 R. Caughey Drafting and revising retailer memoranda. Identifying privilege log issues. Preparing correspondence to opposing counsel re privilege log issues. Researching SDNY law on privilege issues. Reviewing DocuGate documents. Conferring with R. Hess re retailer project and documents.

5.50 $2,612.50

08/13/15 J. Stanley Reviewing and preparing documents for R. Hess to review.

2.50 $675.00

08/13/15 J. Stanley Reviewing and preparing documents for R. Hess to review.

3.00 $810.00


4.30 $2,580.00

08/14/15 V. Lee Creating and loading documents into the News_SG002 and the News_SG003 Eclipse databases.

4.50 $562.50

08/14/15 J. Ross Attending to Kroger memorandum. 2.80 $1,960.00


7.70 $2,117.50

08/14/15 R. Caughey Drafting and revising retailer memoranda. Revising task list and circulating to team. Conferring with team re retailer memoranda and documents.

4.90 $2,327.50

08/15/15 K. Hoek Reviewing case materials. Conducting legal research re pricing claims.

2.50 $1,500.00




Tax I.D.# 74‐2138615

08/16/15 R. Hess Reviewing transcript of Berg deposition. Reviewing legal research memorandum. Preparing notes re potential additional deposition.

2.70 $1,485.00

08/16/15 K. Hoek Reviewing case materials for supporting facts re pricing and long‐term contracts.

1.90 $1,140.00

08/17/15 V. Lee Updating the News_SG003 and the News_SG004 Eclipse databases.

4.30 $537.50

08/17/15 J. Ross Reviewing documents re Kroger memorandum.

4.80 $3,360.00

08/17/15 R. Hess Preparing memorandum to J. Southwick re Berg deposition and potential follow up. Reviewing transcript of Berg deposition. Reviewing legal research memorandum. Preparing notes re potential additional deposition.

4.70 $2,585.00

08/17/15 R. Caughey Reviewing and revising discovery letter, circulating to team, and conferring with J. Ross. Conferring with cocounsel re discovery issues. Addressing retailer memoranda issues.

2.00 $950.00

08/17/15 J. Southwick Reviewing and responding to email re various topics, including memorandum on Valassis deposition hearsay objections.

1.60 $1,120.00

08/17/15 K. Hoek Conducting legal research re pricing claims. Reviewing emails and case materials.

5.10 $3,060.00


7.20 $1,980.00

08/17/15 J. Stanley Preparing documents to be reviewed. 1.40 $378.00

08/18/15 J. Southwick Reviewing draft letter re privilege log issues. Preparing for and participating in weekly trial team call.

1.00 $700.00

08/18/15 K. Hoek Reviewing cases addressing section 2 claims involving exclusive dealing arrangements.

1.50 $900.00

08/18/15 R. Hess Preparing for conference. Reviewing transcript of Berg deposition. Reviewing case law. Conferring by phone with trial team. Reviewing documents.

5.00 $2,750.00

08/18/15 J. Ross Researching factual matters and researching points of law re Kroger/NAM relationship.

5.60 $3,920.00




Tax I.D.# 74‐2138615

Reviewing documents.


7.80 $2,145.00

08/18/15 R. Caughey Revising privilege log letter and appendices and circulating to team. Participating in management committee call. Participating in weekly discovery call.

1.80 $855.00

08/18/15 V. Lee Creating and loading documents into the News_SG001 Eclipse database.

3.50 $437.50



7.70 $2,117.50

08/19/15 J. Southwick Reviewing and responding to emails. Reviewing cocounsel lodestars through July 2015.

2.60 $1,820.00


08/19/15 K. Hoek Reviewing and responding to emails. Conducting legal research re exclusive dealing and pricing claims.

3.00 $1,800.00

08/19/15 J. Ross Reviewing Kroger documents. 4.50 $3,150.00

08/19/15 R. Caughey Drafting retailer memoranda. Reviewing DocuGate and other documents. Drafting and revising privilege log letter. Addressing issues with privilege log.

4.50 $2,137.50

08/19/15 V. Lee Creating and loading documents into the News_SG002 Eclipse database.

1.00 $125.00

08/20/15 J. Southwick Reviewing privilege log challenge issues with R. Caughey.

1.40 $980.00

08/20/15 L. Eccles Reviewing trial team email re privilege logs. Reviewing order re docketing conference.

0.20 $100.00

08/20/15 K. Hoek Preparing memorandum addressing exclusive dealing claims in preparation for summary judgment motions.

2.60 $1,560.00

08/20/15 R. Hess Reviewing documents and preparing retailer memorandum.

5.40 $2,970.00

08/20/15 M. Fisher Researching SG database for SuperValu documents.

8.40 $2,310.00

08/20/15 R. Caughey Drafting and revising retailer memoranda. Reviewing documents re retailer

8.50 $4,037.50




Tax I.D.# 74‐2138615

memoranda. Revising privilege log letters in light of meeting with J. Southwick. Preparing analysis of privilege log and conferring with J. Smith re same. Preparing proposed email re privilege log.

08/20/15 V. Lee Updating the News_SG001 and the News_SG002 Eclipse databases.

1.90 $237.50


3.30 $1,980.00

08/21/15 R. Hess Conferring by email with trial team. Reviewing documents.

0.50 $275.00


8.60 $2,365.00

08/21/15 J. Southwick Reviewing July billing. Conferring by emails with trial team.

1.00 $700.00

08/21/15 R. Caughey Drafting, revising, and circulating retailer contract memoranda. Conferring with cocounsel re privilege log challenge. Conferring with cocounsel re discovery.

8.70 $4,132.50

08/21/15 V. Lee Updating the News_SG005 Eclipse database. 0.20 $25.00

08/21/15 J. Stanley Reviewing documents. 4.00 $1,080.00


3.10 $1,860.00

08/22/15 R. Hess Reviewing documents and reviewing retailer memorandum.

1.10 $605.00

08/22/15 M. Fisher Researching SG database for SuperValu documents.

3.40 $935.00

08/23/15 K. Hoek Reviewing memoranda summarizing evidence as to key individual retailers.

2.00 $1,200.00

08/23/15 R. Hess Reviewing documents and reviewing retailer memorandum.

1.20 $660.00

08/23/15 R. Caughey Revising and circulating privilege log letter. 0.40 $190.00

08/24/15 K. Hoek Preparing memorandum addressing exclusive dealing claims in preparation for summary judgment motions. Reviewing and responding to emails.

3.30 $1,980.00

08/24/15 J. Ross Reviewing documents for Kroger 2.80 $1,960.00




Tax I.D.# 74‐2138615

memorandum.

08/24/15 J. Southwick Conferring by emails re July cost statement. 1.00 $700.00

08/24/15 M. Fisher Drafting SuperValu memorandum. 6.30 $1,732.50

08/24/15 J. Stanley Reviewing documents. Reviewing ApplEcon bills. Preparing documents for review.

3.00 $810.00

08/24/15 R. Hess Reviewing retailer memorandums. 2.00 $1,100.00

08/24/15 R. Caughey Drafting and revising retailer memoranda. Drafting and revising Mortimer memorandum. Preparing recommendation re Mortimer deposition. Reviewing DocuGate and other documents. Drafting and revising privilege log letter and circulating to team. Participating in weekly discovery call.

5.80 $2,755.00

08/25/15 J. Southwick Participating in weekly trial team call. Reviewing materials from S. Berry re litigation fund, Berry Law arrears and state of funding. Participating in related call and emails with cocounsel. Conferring by phone with R. Pfau and J. Metzler re Applecon bills.

4.50 $3,150.00


08/25/15 R. Hess Reviewing transcript of depositions. Reviewing retailer memorandum. Conferring by email with trial team. Preparing memorandum to J. Southwick re Kowaczyk. Conferring by phone with trial team. Conferring in office with J. Southwick.

2.50 $1,375.00

08/25/15 J. Ross Participating on conference call. 0.50 $350.00

08/25/15 R. Caughey Participating in weekly call. Addressing issues with privilege log challenge. Reviewing documents. Conferring with team re discovery projects. Conferring with team re potential deponents. Conferring with cocounsel re K‐Mart subpoena.

2.00 $950.00

08/25/15 K. Hoek Reviewing retailer memorandums. Reviewing and responding to emails. Preparing legal research memorandum addressing exclusive dealing claims in preparation for summary judgment motions.

6.50 $3,900.00

08/26/15 J. Southwick Reviewing ledger entries for litigation fund. 4.00 $2,800.00




Tax I.D.# 74‐2138615

Conferring on calls and emails with cocounsel re litigation fund.

08/26/15 R. Caughey Conferring with team re requests for admissions and Berry Law v. Kraft. Addressing issues with retailer memoranda. Preparing research re retailer issues. Revising privilege log letter and conferring with J. Southwick re same.

3.50 $1,662.50

08/27/15 J. Southwick Reviewing and editing letter regarding News's privilege log. Reviewing updated litigation fund ledger and related emails.

2.90 $2,030.00

08/27/15 R. Caughey Revising privilege log letter and serving on opposing counsel. Conferring with J. Southwick re privilege log letter issues. Conferring with team re retailer contract memoranda. Revising Winn Dixie memorandum and circulating to team. Reviewing and commenting on K‐Mart subpoena.

4.00 $1,900.00

08/28/15 J. Southwick Reviewing emails re litigation fund. Reviewing memorandums re retailer contracting.

1.80 $1,260.00

08/28/15 M. Fisher Researching and editing SuperValu memorandum.

7.40 $2,035.00

08/28/15 R. Hess Reviewing memorandum from trial team re retailers. Reviewing documents re privilege log. Reviewing documents re Heinz requests for admission. Researching points of law re exclusionary conduct. Reviewing case law. Conferring in office with J. Southwick. Researching points of law.

5.70 $3,135.00

08/31/15 M. Fisher Conferring by phone with NAM associates. Researching and editing SuperValu memorandum.

6.80 $1,870.00

08/31/15 R. Hess Researching points of law. 7.60 $4,180.00

08/31/15 R. Caughey Conferring with J. Southwick re tasks and strategy. Participating in weekly discovery call. Addressing discovery issues.

0.50 $237.50

08/31/15 K. Hoek Reviewing retailer memorandums. Reviewing and responding to emails. Preparing legal research memo addressing

6.00 $3,600.00




Tax I.D.# 74‐2138615

exclusive dealing claims in preparation for summary judgment motions.

08/31/15 J. Southwick Conferring by email with Susman Godfrey lawyers re Applecon proposal for work through summary judgment and related issues. Leaving message for Tree Top Inc., class member who left message requesting information.

0.60 $420.00

09/01/15 K. Hoek Reviewing retailer memos. Reviewing and responding to emails. Preparing legal research memorandum addressing exclusive dealing claims in preparation for summary judgment motions.

5.80 $3,480.00

09/01/15 R. Hess Researching points of law re price‐cost test and rule of reason. Preparing memorandum to trial team.

7.70 $4,235.00

09/01/15 R. Caughey Conferring with team re upcoming tasks re privilege log. Reviewing antitrust literature. Preparing draft of letter to court re privilege log.

1.80 $855.00

09/02/15 J. Southwick Reviewing memoranda on retailer negotiations and related emails. Conferring with R. Hess re September 16 hearing and September 1 trial team call.

3.00 $2,100.00

09/02/15 K. Hoek Reviewing retailer memorandums. Reviewing and responding to emails. Preparing legal research memorandum addressing exclusive dealing claims in preparation for summary judgment motions.

5.00 $3,000.00

09/02/15 R. Hess Researching points of law and conferring by email with K. Hoek. Researching points of law re exclusionary bidding, staggered contracts, preemptive renewals and price‐cost test. Preparing memorandum to trial team.

9.50 $5,225.00

09/02/15 R. Caughey Addressing privilege log issues. Reviewing and commenting on retailer memoranda and conferring with J. Southwick re same. Conferring with J. Southwick re opt‐out issues.

1.00 $475.00

09/03/15 K. Hoek Reviewing retailer memorandums. 3.70 $2,220.00




Tax I.D.# 74‐2138615

Reviewing and responding to emails. Preparing legal research memorandum addressing exclusive dealing claims in preparation for summary judgment motions.

09/03/15 J. Southwick Reviewing and responding to emails re summary judgment issues. Reviewing fact memoranda re retailers.

0.30 $210.00

09/03/15 R. Hess Conferring by email with trial team. Reviewing correspondence from trial team re Valassis, Kmart, and request for admissions. Responding to same.

1.80 $990.00

09/03/15 R. Caughey Reviewing legal research memorandum. Preparing research re privilege log and third parties. Reviewing discovery‐related correspondence.

1.50 $712.50

09/04/15 K. Hoek Reviewing memorandum summarizing retailer documents.

1.00 $600.00

09/04/15 J. Southwick Reviewing filing and emails re summary judgment page limits.

0.60 $420.00

09/04/15 R. Caughey Drafting privilege log letter. Reviewing retailer memoranda and materials. Addressing discovery issues. Reviewing K. Hoek's legal research memorandum.

1.80 $855.00

09/06/15 R. Caughey Drafting and revising privilege log letter. Conferring with J. Southwick re issues.

2.10 $997.50

09/06/15 R. Caughey Drafting and revising privilege log letter. Conferring with J. Southwick re issues.

2.10 $997.50

09/07/15 J. Stanley Reviewing database for News document production counts.

1.00 $270.00

09/07/15 R. Caughey Analyzing privilege log entries. Addressing discovery issues. Drafting and revising privilege log letter. Conferring with team. Reviewing K. Hoek memorandum.

2.60 $1,235.00

09/07/15 K. Hoek Reviewing emails and case materials. Reviewing memorandums describing document productions.

2.20 $1,320.00

09/07/15 R. Caughey Analyzing privilege log entries. Addressing discovery issues. Drafting and revising privilege log letter. Conferring with team. Reviewing K. Hoek memorandum.

2.60 $1,235.00




Tax I.D.# 74‐2138615

09/08/15 J. Southwick Attending weekly trial team call. Conferring with R. Caughey re Kmart subpoena and related call with D. Goldman. Conferring by phone with M. Palizzi re various issues including M. Kowalczyck. Reviewing memorandum from K. Hoek re section 2 claims.

3.60 $2,520.00

09/08/15 R. Caughey Drafting privilege log letter and circulating to team. Participating in weekly call. Reviewing retailer memoranda. Analyzing privilege issues. Conferring with J. Southwick re K‐Mart issues and strategy.

3.10 $1,472.50

09/08/15 K. Hoek Reviewing emails and case materials. Conducting further research regarding termination provisions.

3.50 $2,100.00

09/08/15 V. Lee Creating and loading documents into the News_SG005_002 Eclipse database.

1.20 $150.00

09/08/15 R. Hess Reviewing and revising letter to court. Preparing for teleconference. Conferring by phone with trial team. Reviewing brief from opposing counsel.

1.40 $770.00

09/08/15 R. Caughey Drafting privilege log letter and circulating to team. Participating in weekly call. Reviewing retailer memoranda. Analyzing privilege issues. Conferring with J. Southwick re K‐Mart issues and strategy.

3.10 $1,472.50

09/09/15 J. Southwick Reviewing memorandum from K. Hoek and related follow‐up emails.

2.80 $1,960.00

09/09/15 R. Caughey Drafting, revising, and circulating privilege log motion to compel. Reviewing NAM's privilege logs and preparing appendixes. Reviewing retailer memoranda. Conferring with team re revisions to privilege log letter.

3.50 $1,662.50

09/09/15 L. Eccles Reviewing email re privilege logs, summary judgment, and Kraft request for admission issues. Reviewing retailer memoranda.

5.00 $2,500.00

09/09/15 J. Stanley Reviewing and preparing documents for R. Hess.

3.00 $810.00

09/09/15 K. Hoek Reviewing emails and case materials. Reviewing retailer contracts.

1.00 $600.00




Tax I.D.# 74‐2138615

09/09/15 V. Lee Updating the News_SG005_002 Eclipse database.

3.10 $387.50

09/09/15 R. Hess Preparing for conference with court. Reviewing correspondence from court and opposing counsel. Reviewing and revising letter re privilege log dispute. Conferring by email with trial team. Conferring by phone with J. Southwick re legal research memorandum. Reviewing contracts.

7.10 $3,905.00

09/09/15 R. Caughey Drafting, revising, and circulating privilege log motion to compel. Reviewing NAM's privilege logs and preparing appendixes. Reviewing retailer memoranda. Conferring with team re revisions to privilege log letter.

3.50 $1,662.50

09/10/15 J. Stanley Reviewing and preparing documents for attorney's. Researching cases for memorandum.

4.00 $1,080.00

09/10/15 J. Southwick Reviewing draft letter to court re privilege log dispute. Reviewing and responding to emails re litigation fund.

1.40 $980.00

09/10/15 K. Hoek Reviewing emails and case materials. Reviewing retailer contracts.

0.80 $480.00

09/10/15 V. Lee Updating the News_SG005_002 Eclipse database.

1.40 $175.00

09/10/15 R. Hess Reviewing court filing and reviewing memorandum from trial team. Reviewing dockets in competitors lawsuits. Preparing for conference on prior action depositions. Reviewing latest amended complaints in competitor lawsuits. Conferring by email with R. Caughey re privilege log.

4.70 $2,585.00

09/10/15 R. Caughey Conferring with team re privilege log letter. 0.30 $142.50

09/11/15 J. Stanley Preparing documents for attorney review. 4.00 $1,080.00

09/11/15 J. Southwick Reviewing summary and video excerpts from P. Carlucci deposition. Conferring by email with K. Hoek re monopolization memorandum.

1.00 $700.00

09/11/15 K. Hoek Revising legal research memorandum in light of additional facts and evidence. Collecting cases to support memorandum. Reviewing

3.50 $2,100.00




Tax I.D.# 74‐2138615

emails and case materials regarding recent depositions.

09/11/15 R. Hess Preparing for conference on prior action depositions. Conferring in office with J. Southwick re privilege log letter. Conferring by phone with R. Caughey re same. Reviewing prior lawsuit complaints. Preparing outline.

4.10 $2,255.00

09/13/15 J. Stanley Preparing documents for R. Hess. 3.00 $810.00

09/13/15 R. Caughey Analyzing privilege log, creating privilege log appendixes, and revising privilege log letter. Conferring with team re privilege log letter. Reviewing document productions. Conferring with cocounsel re privilege log issues.

1.90 $902.50



09/14/15 R. Hess Preparing for conference on prior action depositions. Reviewing prior lawsuit transcripts. Preparing outline.

8.80 $4,840.00

09/14/15 J. Southwick Conferring with R. Caughey and R. Hess re privilege log letter. Reviewing transcripts and email excerpts to K. Hoek for consideration in her research memorandum.

2.00 $1,400.00

09/14/15 R. Caughey Preparing and circulating appendixes to privilege log letter. Meeting with J. Southwick re NAM privilege log issues. Revising privilege log letter. Participating in associates' discovery call. Conferring with team re strategy.

3.10 $1,472.50

09/14/15 K. Hoek Revising memorandum re validity of NAM's anticipated defenses and grounds for summary judgment. Reviewing deposition transcripts and video clips.

4.80 $2,880.00

09/14/15 M. Fisher Reviewing documents to supplement SuperValu Retailer memorandum.

6.20 $1,705.00

09/14/15 J. Stanley Preparing documents for R. Hess to review. 5.00 $1,350.00

09/15/15 J. Southwick Reviewing privilege log letter with R. Caughey. Attending weekly trial team call. Conferring by phone with K. Hoek re issues

1.60 $1,120.00




Tax I.D.# 74‐2138615

in legal memorandum. Conferring by phone with L. A. Stevenson.

09/15/15 R. Caughey Addressing issues relating to privilege log challenge. Identifying suspect entries in privilege log. Reviewing Foster Farms and BEF documents for privilege. Participating in management committee call. Conferring with M. Fisher and J. Southwick re tasks and strategy. Reviewing K. Hoek memorandum.

4.30 $2,042.50

09/15/15 K. Hoek Discussing and conducting further factual research into issues raised by co‐counsel re termination provisions and staggering of retailer contracts.

4.00 $2,400.00

09/15/15 L. Eccles Reviewing trial team emails re privilege logs, etc.

0.40 $200.00


09/15/15 M. Fisher Conferring by phone with NAM Litigation team. Reviewing documents for privilege and redactions.

7.10 $1,952.50

09/15/15 R. Hess Preparing for conference and outlining argument. Preparing for conference on prior action depositions. Reviewing prior lawsuit transcripts. Preparing outline. Conferring by phone with trial team. Traveling to New York City. Preparing for conference.

13.60 $7,480.00

09/16/15 R. Caughey Reviewing privilege logs and revising Appendixes to privilege letter. Conferring with M. Fisher re research projects and fact development. Reviewing K. Hoek memorandum and associated correspondence.

2.20 $1,045.00

09/16/15 K. Hoek Reviewing case materials. Reviewing and responding to emails from co‐counsel regarding legal research memorandum.

1.10 $660.00

09/16/15 J. Southwick Reviewing and circulating memorandum from K. Hoek. Conferring by phone with R. Hess and then cocounsel re hearing on use of prior case transcripts. Drafting and circulating letter to court re Joint Representation Agreement.

3.90 $2,730.00

09/16/15 L. Eccles Reviewing emails re legal research. 0.20 $100.00




Tax I.D.# 74‐2138615


09/16/15 M. Fisher Reviewing NAM documents for research on rate cards and NAM pricing practices after 2011.

4.90 $1,347.50

09/16/15 R. Hess Preparing for conference and outlining argument. Attending hearing on prior lawsuit transcripts. Conferring with trial team. Conferring by phone with trial team. Traveling from New York City.

10.50 $5,775.00

09/17/15 J. Southwick Conferring on calls and emails with S. Benz, R. Hess, and cocounsel re letter to court attaching joint representation agreement.

2.60 $1,820.00

09/17/15 L. Eccles Reviewing trial team emails re legal research.

0.10 $50.00

09/17/15 R. Hess Reviewing and revising letter to court. Conferring by phone with S. Benz and J. Southwick. Conferring by phone with trial team. Reviewing previous court correspondence. Reviewing joint representation agreements and amendments. Revising letter to court. Conferring by email with trial team.

5.50 $3,025.00


09/17/15 R. Caughey Conferring with trial team re privilege log issues and discovery.

0.30 $142.50


09/18/15 L. Eccles Reviewing co‐lead emails re letter to court. Conferring via email re hearing.

0.20 $100.00


2.40 $660.00

09/18/15 K. Hoek Reviewing case materials and depositions. 1.50 $900.00

09/18/15 R. Hess Preparing correspondence to court. Conferring by email with J. Southwick, S. Benz, S. Berry, L. Leclaire and D. Goldman. Conferring by phone with trial team.

1.30 $715.00


09/19/15 R. Hess Preparing email to trial team. Conferring by email with trial team re third party depositions.

0.80 $440.00




Tax I.D.# 74‐2138615


09/21/15 R. Hess Conferring in office with J. Southwick and R. Caughey.

0.30 $165.00

09/21/15 L. Eccles Reviewing email re agenda and hearing. Reviewing privilege log letter.

0.70 $350.00


8.10 $2,227.50

09/21/15 K. Hoek Researching legal issues in preparation for summary judgment opposition. Reviewing case materials.

3.10 $1,860.00

09/21/15 R. Caughey Revising privilege log letter and conferring with team re same. Reviewing documents. Participating in discovery call. Addressing summary judgment issues.

1.90 $902.50

09/22/15 J. Southwick Participating in weekly trial team call. Conferring by emails with K. Hoek re research re use of evidence of bad acts from prior to the class period. Reviewing and editing draft letter from R. Caughey re privilege log challenges. Reviewing monthly accounting report from L. LeClair. Reviewing monthly report from J. Stanley re hours billed to case.

1.50 $1,050.00

09/22/15 J. Stanley Reviewing documents. Updating master fees & expense chart.

2.00 $540.00


09/22/15 L. Eccles Conferring via email re privilege log letter. 0.20 $100.00

09/22/15 R. Hess Reviewing transcript of prior action deposition. Conferring by phone with trial team. Conferring by email with S. Berry re additional depositions. Reviewing transcript of prior trial testimony.

2.80 $1,540.00

09/22/15 K. Hoek Researching legal issues in preparation for summary judgment opposition. Reviewing case materials.

2.90 $1,740.00

09/22/15 R. Caughey Revising privilege log letter in light of comments from J. Southwick. Participating in management committee call. Conferring with team re timing. Conferring with R. Hess

2.40 $1,140.00




Tax I.D.# 74‐2138615

re disclosure of trial witnesses. Conferring with co‐counsel re privilege strategy.


09/23/15 L. Eccles Conferring via email re case law. 0.20 $100.00

09/23/15 J. Southwick Conferring by phone with M. Palizzi. Conferring by emails with J. Briody and J. Smith re providing materials in response to Valassis subpoena to Dial.

0.80 $560.00

09/23/15 R. Hess Reviewing transcript and conferring with trial team re needed depositions.

0.90 $495.00

09/23/15 R. Caughey Reviewing retailer documents in advance of summary judgment briefing. Conferring with team re issues.

1.00 $475.00

09/24/15 J. Southwick Conferring by emails re notice of opt‐outs. Conferring by phone with M. Palizzi re M. Kowalczyk.

0.50 $350.00

09/24/15 R. Caughey Conferring with cocounsel re document production issues.

0.30 $142.50


09/25/15 J. Southwick Conferring by phone with M. Palizzi. Reviewing and responding to emails re response to request for admission to Kraft.

0.70 $490.00

09/25/15 R. Hess Preparing for conference with S. Berry. Conferring by email with trial team.

1.00 $550.00

09/28/15 R. Hess Reviewing transcript of Insignia depositions. Reviewing transcript G. Rebh testimony.

0.50 $275.00

09/28/15 J. Southwick Conferring by phone with M. Palizzi re meeting with M. Kowalczyk. Discussing death of G. Rebh with R. Hess. Conferring with R. Hess and emails re production of expert reports per Valassis subpoena.

1.80 $1,260.00

09/28/15 R. Caughey Revising and serving request for admissions response. Preparing legal research re SDNY objections and responses. Participating in discovery call. Revising and re‐circulating privilege log letter.

1.50 $712.50

09/28/15 K. Hoek Conducting legal research concerning admissibility of evidence outside class period. Reviewing case materials. Reviewing emails.

6.50 $3,900.00




Tax I.D.# 74‐2138615

09/28/15 J. Stanley Preparing witness files. 1.00 $270.00

09/28/15 L. Eccles Conferring via email re briefing and depositions.

3.40 $1,700.00

09/29/15 R. Hess Reviewing transcript of Valassis deposition. Reviewing transcript Ball, Lucidi and Wesson testimony.

2.50 $1,375.00

09/29/15 J. Southwick Reviewing and responding to emails re additional deponents for affirm prior testimony and filing of News's summary judgment motion.

0.20 $140.00


0.30 $142.50

09/29/15 K. Hoek Reviewing emails and case materials. Reviewing depositions.

2.90 $1,740.00


09/29/15 L. Eccles Reviewing emails re briefing. 0.20 $100.00

09/30/15 R. Caughey Reviewing News' summary judgment filings. 1.00 $475.00

09/30/15 R. Hess Reviewing News America Marketing filings. Conferring by email with trial team. Reviewing News America Marketing motion for summary judgment.

2.10 $1,155.00

09/30/15 J. Southwick Conferring by phone with M. Palizzi re arranging meeting with M. Kowalczyk. Conferring by emails re compliance billing.

0.50 $350.00

09/30/15 L. Eccles Reviewing memorandum re summary judgment. Conferring via email re depositions.

3.00 $1,500.00

09/30/15 J. Ross Reviewing summary judgment briefing and materials.

3.00 $2,100.00

10/01/15 M. Fisher Conferring by phone with News Litigation team.

0.70 $192.50

10/01/15 J. Stanley Preparing materials for attorney review. 1.00 $270.00

10/01/15 J. Southwick Reviewing summary judgment motion papers and Daubert motions. Participating in weekly call with cocounsel. Conferring by phone with M. Palizzi.

4.10 $2,870.00

10/01/15 L. Eccles Reviewing briefing and associated emails. Attending trial team conference call.

6.10 $3,050.00

10/01/15 K. Hoek Reviewing summary judgment papers and 3.50 $2,100.00




Tax I.D.# 74‐2138615

related emails. Conducting legal research.

10/01/15 J. Ross Attending to summary judgment work. 4.30 $3,010.00

10/01/15 R. Hess Reviewing correspondence from trial team. Reviewing memorandum K. Hoek. Reviewing memorandum from S. Berry. Reviewing News motion for summary judgment. Conferring by email with trial team. Conferring in office with R. Caughey. Conferring by phone with trial team. Conferring in office with J. Southwick, R. Caughey, and J. Ross re motion for summary judgment assignments.

3.40 $1,870.00

10/01/15 R. Caughey Reviewing and commenting on News's summary judgment papers. Conferring with J. Southwick, R. Hess, and J. Ross re News' summary judgment papers and arguments. Participating in management committee call. Conferring with experts re News' summary judgment papers.

3.90 $1,852.50

10/02/15 J. Stanley Preparing materials for attorney review. 1.60 $432.00

10/02/15 J. Southwick Reviewing summary judgment briefing by News and related emails.

0.80 $560.00

10/02/15 K. Hoek Reviewing case law and preparing insert for summary judgment opposition addressing evidence prior to class period.

1.50 $900.00

10/02/15 J. Ross Attending to summary judgment issues. Conferring with expert re same.

5.80 $4,060.00

10/02/15 R. Hess Reviewing brief filed by News. 2.00 $1,100.00

10/02/15 R. Caughey Preparing legal research re summary judgment issues. Reviewing News's exhibits re summary judgment. Conferring with team re summary judgment issues. Preparing memorandum re summary judgment legal issues.

3.50 $1,662.50

10/05/15 J. Southwick Reviewing summary judgment briefs. Conferring with R. Caughey, J. Ross and S. Benz re responding to monopolization and exclusive dealing sections. Conferring by phone with L. LeClair and S. Benz re potential revision to cocounsel agreement and first draft of revised resolution.

6.60 $4,620.00




Tax I.D.# 74‐2138615

10/05/15 K. Hoek Reviewing additional case law in response to summary judgment filings.

2.20 $1,320.00

10/05/15 J. Ross Reviewing legal cases for summary judgment briefing.

4.00 $2,800.00

10/05/15 L. Eccles Reviewing hearing transcript and attending to briefing.

0.50 $250.00


0.50 $137.50

10/06/15 J. Southwick Participating in weekly trial team call. Discussing and conferring by emails re responding to summary judgment motion. Conferring by emails with L. LeClair and S. Benz re revising July resolution of management committee.

4.90 $3,430.00

10/06/15 R. Caughey Preparing legal and factual research re summary judgment. Revising privilege log letter and serving on opposing counsel. Participating in weekly discovery call. Preparing outline of summary judgment opposition. Conferring with team re Rule 56.1 statement. Conferring with team re statute of limitations issue. Meeting with J. Southwick and J. Ross re summary judgment opposition.

3.90 $1,852.50

10/06/15 R. Caughey Participating in weekly management committee call. Conferring with Kellogg Huber re briefing strategy. Meeting with SG team re summary judgment briefing. Preparing legal and factual research re summary judgment briefing. Conferring with K. Hoek re summary judgment legal research.

6.80 $3,230.00

10/06/15 J. Stanley Preparing documents for review. 1.00 $270.00

10/06/15 J. Ross Reviewing legal cases. 4.70 $3,290.00

10/06/15 L. Eccles Conducting legal research and conferring via email re same.

0.80 $400.00

10/06/15 R. Hess Conferring by email with trial team. Conferring in office with J. Southwick and R. Caughey re motion for summary judgment assignments. Conferring by phone with trial team. Preparing conference. Reviewing brief

4.10 $2,255.00




Tax I.D.# 74‐2138615

and preparing outline.

10/06/15 K. Hoek Reviewing summary judgment motion and conducting legal research.

4.20 $2,520.00

10/07/15 J. Southwick Conferring by phone with S. Benz re responding to Valassis request for Oracle database. Conferring on calls with S. Benz, L. LeClair, and D. Goldman re draft resolution of management committee. Reviewing News response concerning pre motion letter on privilege log and discuss with R. Caughey. Conferring by emails re response to summary judgment.

3.20 $2,240.00

10/07/15 J. Stanley Reviewing and preparing documents for attorney review.

2.00 $540.00

10/07/15 L. Eccles Conducting legal research and conferring via email re same.

3.40 $1,700.00

10/07/15 R. Hess Reviewing correspondence from trial team. Conferring by email with trial team. Reviewing Rule 56.1 statement.

2.40 $1,320.00

10/07/15 R. Caughey Preparing summary judgment response. Preparing legal research re summary judgment. Reviewing trade promotions materials and conferring with J. Smith re same. Reviewing hot documents. Reviewing opposing counsel's portion of discovery dispute letter and conferring with team re same.

5.80 $2,755.00

10/07/15 K. Hoek Conducting legal research to support opposition to summary judgment motion.

3.50 $2,100.00

10/08/15 J. Southwick Conferring with R. Caughey and M. Fisher re privilege log letter and further identification of entries to challenge. Conferring by email to trial team re privilege log letter.

1.00 $700.00


10/08/15 M. Fisher Conferring in office with R. Caughey and J. Southwick re News privilege log deficiencies. Reviewing News privilege log for emails with Louis Manzo CCed.

3.20 $880.00

10/08/15 R. Caughey Preparing legal and factual research re summary judgment. Preparing outline of

6.70 $3,182.50




Tax I.D.# 74‐2138615

summary judgment response. Conferring with team re discovery dispute and privilege log. Conferring with opposing counsel re discovery dispute. Meeting with J. Southwick and M. Fisher re privilege log issues.

10/08/15 R. Hess Reviewing and revising letter to court re privilege. Reviewing Rule 56.1 statement.

2.80 $1,540.00

10/09/15 J. Southwick Preparing and circulating management committee resolution. Conferring with M. Palizzi re M. Kowalcyk and ability to produce the Oracle database. Reviewing summary judgment materials.

2.20 $1,540.00

10/09/15 M. Fisher Reviewing News privilege log for emails with Louis Manzo CCed.

4.90 $1,347.50

10/09/15 J. Ross Reviewing legal cases. Reviewing documents for response to summary judgment.

7.50 $5,250.00

10/09/15 R. Caughey Reviewing Judge Pauley summary judgment opinions. Preparing legal and factual research re summary judgment. Conferring with team re summary judgment issues. Preparing summary judgment outline. Preparing factual research re summary judgment.

4.10 $1,947.50

10/09/15 R. Hess Preparing response to statement of undisputed material facts. Conferring by email with J. Stanley. Reviewing declaration of W. Michael.

2.50 $1,375.00

10/10/15 R. Caughey Drafting and revising summary judgment opposition. Preparing legal and factual research re summary judgment. Preparing summary judgment opposition outline.

4.90 $2,327.50

10/11/15 J. Southwick Reviewing case law and fact statement in preparation for opposition to summary judgment motions.

2.20 $1,540.00


6.90 $3,277.50

10/12/15 J. Ross Researching factual matters and points of law re summary judgment motion.

4.60 $3,220.00




Tax I.D.# 74‐2138615

10/12/15 R. Caughey Reviewing CaseMap documents in connection with preparing summary judgment opposition. Participating in weekly discovery call.

1.00 $475.00

10/12/15 R. Hess Preparing response to statement of undisputed material facts. Conferring by email with J. Stanley. Reviewing declaration of W. Michael.

7.30 $4,015.00

10/12/15 J. Southwick Reviewing materials for meeting with M. Kowalczyk.

0.80 $560.00

10/12/15 J. Stanley Preparing witness file. 1.40 $378.00

10/12/15 L. Eccles Conducting legal research. 0.50 $250.00

10/12/15 K. Hoek Conducting legal research regarding exclusive dealing claim.

4.00 $2,400.00

10/13/15 J. Southwick Traveling to Ann Arbor for meeting with M. Kowalczyk and returning to Houston.

12.00 $8,400.00


10/13/15 L. Eccles Conducting legal research and conferring with co‐lead counsel via email.

7.00 $3,500.00

10/13/15 R. Hess Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring by phone with attorney for third party witness.

6.40 $3,520.00

10/13/15 R. Caughey Preparing legal and factual research re summary judgment opposition. Drafting summary judgment opposition. Conferring with M. Fisher re privilege logs and conferring with J. Smith re same.

6.40 $3,040.00

10/14/15 L. Eccles Conducting legal research and conferring with co‐lead counsel via email.

6.80 $3,400.00

10/14/15 J. Ross Reviewing facts and law re response to summary judgment.

3.70 $2,590.00


2.10 $577.50

10/14/15 R. Hess Researching points of law re use of depositions at summary judgment. Preparing responses to statement of undisputed material facts. Reviewing expert reports.

5.10 $2,805.00




Tax I.D.# 74‐2138615

10/14/15 K. Hoek Conducting legal research regarding exclusive dealing claim.

4.00 $2,400.00

10/14/15 R. Caughey Drafting opposition to summary judgment motion. Preparing legal and factual research re summary judgment. Conferring with team re summary judgment. Conferring with experts re summary judgment research. Conferring with c‐counsel re summary judgment.

7.50 $3,562.50

10/15/15 J. Stanley Updating fee and expense chart. Reviewing motion for summary judgment and pulling cases.

1.00 $270.00

10/15/15 L. Eccles Conducting legal research. Conferring via email with co‐lead counsel re settlement communications by News America Marketing.

8.20 $4,100.00

10/15/15 J. Southwick Reviewing letter to court from News re communications with class members and related emails with cocounsel.

0.60 $420.00

10/15/15 R. Hess Conferring with R. Caughey. Preparing response to statement of undisputed material facts. Reviewing expert reports.

7.40 $4,070.00

10/15/15 R. Caughey Preparing summary judgment response. Meeting with R. Hess re 56.1 statement. Meeting with team re summary judgment. Preparing legal and factual research. Conferring with experts re follow‐up research. Conferring with R. Hess re declarations. Conferring with M. Fisher re sealing documents. Preparing legal research re communications with class members and preparing memoranda re same. Meeting with J. Southwick re communications with absent class members.

8.50 $4,037.50

10/16/15 L. Eccles Conducting legal research. Conferring via email. Reviewing letter to court.

1.60 $800.00


8.40 $2,310.00

10/16/15 J. Ross Reviewing Kroger facts. 2.00 $1,400.00

10/16/15 J. Southwick Reviewing case law cited in summary 2.30 $1,610.00




Tax I.D.# 74‐2138615

judgment briefing. Conferring by phone with R. Caughey and R. Pfau re calculations concerning contract length, early termination clauses, and market foreclosure. Reviewing order denying conference to discuss joint representation agreement and conferring with R. Hess.

10/16/15 R. Hess Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring by phone with R. Pfau. Conferring in office with R. Caughey and J. Southwick.

5.60 $3,080.00

10/16/15 R. Caughey Conferring with R. Pfau, J. Southwick, and R. Hess re expert issues. Conferring with K. Hoek re summary judgment and antitrust law. Conferring with R. Hess re 56.1 statement. Preparing summary judgment responses. Preparing legal and factual research re exclusionary dealing. Analyzing contract length. Preparing memorandum to team re exclusive dealing. Conferring with team re "critical mass" issue.

7.90 $3,752.50

10/17/15 J. Southwick Reviewing and redlining initial draft of letter to court and circulating comments.

1.60 $1,120.00


4.50 $2,137.50

10/18/15 J. Southwick Reviewing research and revising letter to court re communications with class members and related email with cocounsel. Drafting responses to sections of News' Rule 56.1 statement.

7.70 $5,390.00

10/18/15 R. Caughey Drafting and revising summary judgment opposition. Preparing legal and factual research re summary judgment. Preparing summary judgment opposition outline. Conferring with co‐counsel re summary judgment issues. Conferring with experts re summary judgment issues.

4.80 $2,280.00

10/19/15 J. Southwick Reviewing research and further revising 3.10 $2,170.00




Tax I.D.# 74‐2138615

letter to court re communications with class members. Conferring by email with J. Briody re Valassis subpoena and production of Oracle database. Conferring by phone with M. Palizzi re database production.

10/19/15 R. Hess Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring in office with J. Southwick.

7.60 $4,180.00

10/19/15 R. Caughey Drafting and revising summary judgment opposition. Preparing legal and factual research re summary judgment. Revising letter to court re contact with absent class members and preparing filing and service. Reviewing documents in connection with summary judgment.

8.50 $4,037.50

10/19/15 L. Eccles Conducting legal research. Conferring via email re draft letter.

3.30 $1,650.00

10/19/15 K. Hoek Researching section 2 cases for summary judgment opposition.

3.00 $1,800.00

10/19/15 J. Stanley Preparing documents for review. 2.00 $540.00

10/20/15 M. Fisher Reviewing News' motion for summary judgment exhibits for proposed redactions.

0.80 $220.00

10/20/15 R. Caughey Participating in management committee call. Drafting and revising summary judgment opposition. Preparing legal and factual research re summary judgment. Conferring with experts. Conferring with team.

10.50 $4,987.50

10/20/15 J. Southwick Participating in weekly call with cocounsel. Drafting affidavit of M. Kowalczyk. Conferring by emails re summary judgment briefing and production of database pursuant to Valassis subpoena.

3.30 $2,310.00

10/20/15 K. Hoek Researching section 1 cases for summary judgment opposition.

2.50 $1,500.00

10/20/15 R. Hess Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring in office with J. Southwick.

5.80 $3,190.00





Tax I.D.# 74‐2138615

10/21/15 R. Caughey Drafting and circulating draft of motion for summary judgment. Preparing legal research re motion for summary judgment. Conferring with team re summary judgment issues. Meeting with J. Southwick and J. Ross re summary judgment. Conferring with co‐counsel re documents and facts. Reviewing deposition transcripts and documents.

5.50 $2,612.50

10/21/15 L. Eccles Attending to legal research and briefing. 5.00 $2,500.00

10/21/15 J. Southwick Revising draft declaration of M. Kowalczyk. Preparing emails re summary judgment and Daubert briefing.

1.50 $1,050.00

10/21/15 J. Ross Attending to summary judgment opposition briefing.

5.40 $3,780.00

10/21/15 R. Hess Reviewing and revising draft response to motion for summary judgment. Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring in office with J. Southwick.

11.40 $6,270.00

10/21/15 J. Stanley Preparing documents for attorney review. 4.00 $1,080.00

10/22/15 L. Eccles Attending to briefing. 7.30 $3,650.00

10/22/15 K. Hoek Reviewing and revising draft opposition to summary judgment motion and reviewing cases cited therein.

2.80 $1,680.00

10/22/15 J. Ross Researching factual matters and points of law re opposition to News' motion for summary judgment.

9.00 $6,300.00

10/22/15 R. Hess Reviewing draft sections of motion for summary judgment opposition. Reviewing transcript of Emmel testimony. Preparing response to statement of undisputed material facts. Reviewing expert reports. Conferring in office with J. Southwick.

10.90 $5,995.00

10/22/15 R. Caughey Revising exclusive dealing section of opposition to motion for summary judgment and circulating to team. Conferring with J. Ross re exclusive dealing revisions. Reviewing summary judgment opposition sections from opposing counsel. Preparing checklist of tasks for filing. Setting up call re filing.

10.20 $4,845.00




Tax I.D.# 74‐2138615


10/23/15 J. Southwick Reviewing draft of monopolization section of opposition to summary judgment. Conferring by phone with cocounsel re assignments for completing oppositions to summary judgment and two Daubert motions.

2.60 $1,820.00

10/23/15 L. Eccles Attending trial team call and conferring via email re briefing.

0.60 $300.00

10/23/15 L. Eccles Reviewing and revising briefing. 5.40 $2,700.00

10/23/15 M. Fisher Conferring by phone with News litigation team. Reviewing draft of opposition to News' summary judgment motion.

1.40 $385.00

10/23/15 J. Ross Attending to opposition brief. 4.50 $3,150.00

10/23/15 R. Hess Reviewing and revising Farris Daubert response. Reviewing and revising market definition section of motion for summary judgment. Reviewing draft sections of motion for summary judgment opposition. Conferring by phone with trial team re motion for summary judgment brief. Conferring in office with trial team re same. Reviewing draft sections. Preparing outline.

6.80 $3,740.00

10/23/15 R. Caughey Preparing sythesized summary judgment opposition. Conferring with team re summary judgment sections and protocol. Reviewing 56.1 opposition. Conferring with cocounsel and participating in call. Preparing legal research.

4.20 $1,995.00


10/24/15 J. Southwick Reviewing and commenting on draft motion in limine re Maskie‐Mason and inserting to summary judgment brief re Mackie‐Mason.

2.60 $1,820.00


10/24/15 R. Hess Reviewing and revising response to Rule 56.1 statement.

2.50 $1,375.00

10/24/15 R. Caughey Addressing issues relating to summary judgment opposition.

1.50 $712.50

10/25/15 J. Southwick Reviewing and commenting on draft opposition to motion in limine concerning P.

4.00 $2,800.00




Tax I.D.# 74‐2138615

Farris. Reviewing draft insert to brief opposing summary judgment re P. Farris. Reviewing case law re monopolization referenced in draft opposition to summary judgment.



10/26/15 J. Ross Conducting legal research re response to News' motion for summary judgment.

8.50 $5,950.00

10/26/15 R. Hess Conferring in office with J. Southwick. Revising motion for summary judgment sections. Revising relevant market sections of motion for summary judgment response.

9.00 $4,950.00

10/26/15 R. Caughey Preparing synthesized and revised version of summary judgment opposition. Preparing legal research re same. Addressing filing logistics. Meeting with team. Participating in weekly associates' call.

13.50 $6,412.50

10/26/15 L. Eccles Conferring via email re briefing. Attending to factual citations and expert declaration.

6.10 $3,050.00

10/26/15 J. Stanley Preparing documents for attorney review. Conferring with team re filing.

3.00 $810.00

10/26/15 J. Southwick Reviewing fact record. Drafting and revising portions of summary judgment brief.

3.90 $2,730.00

10/26/15 K. Hoek Reviewing and revising summary judgment opposition and related filings.

3.30 $1,980.00


0.60 $165.00

10/27/15 J. Southwick Drafting, revising, and editing briefs in opposition to summary judgment. Conferring by phone with J. Briody and M. Palizzi re response to subpoena from Valassis to Dial.

7.70 $5,390.00

10/27/15 R. Caughey Preparing synthesized and revised version of summary judgment opposition. Preparing legal research re same. Addressing filing logistics. Meeting with team. Participating in management committee call.

12.60 $5,985.00

10/27/15 L. Eccles Conferring via email re briefing. Attending to factual citations and expert declaration.

2.80 $1,400.00




Tax I.D.# 74‐2138615

10/27/15 J. Stanley Conferring with team re filing. Preparing materials for attorney review.

5.00 $1,350.00

10/27/15 K. Hoek Reviewing and revising materials in connection with summary judgment opposition.

2.50 $1,500.00

10/27/15 R. Hess Revising intro to motion for summary judgment brief. Revising relevant market section of motion for summary judgment response. Reviewing revisions to motion for summary judgment brief.

11.80 $6,490.00

10/27/15 J. Ross Attending to finalizing briefing papers. 6.50 $4,550.00

10/28/15 R. Caughey Revising motion for summary judgment opposition. Conferring with cocounsel re filing logistics and revisions. Finalizing MacKie‐Mason declaration and exhibits. Conferring with team.

11.80 $5,605.00

10/28/15 J. Southwick Meeting with Susman Godfrey trial team to discuss plans for completing briefing and mechanics of filing all papers under seal. Reviewing and editing briefs in opposition to summary judgment and M. Mason motion in limine. Reviewing fact statements. Conferring by phone with L. LeClair re letter to court concerning defendants communications with class members and summary judgment issues.

5.60 $3,920.00

10/28/15 L. Eccles Attending to briefing and expert declaration. 6.00 $3,000.00

10/28/15 J. Stanley Preparing documents for attorney review. Conferring with team re filing on Friday.

5.00 $1,350.00

10/28/15 K. Hoek Conducting further legal research in support of summary judgment opposition.

2.50 $1,500.00

10/28/15 R. Hess Revising response to 56.1 statement. Conferring by email with R. Caughey. Conferring in office with R. Caughey, J. Ross and J. Southwick. Conferring by email with team. Conferring by phone with F. Hall. Conferring by phone with cocounsel. Conferring in office with J. Southwick.

10.50 $5,775.00

10/28/15 J. Ross Attending to finalizing briefing papers. Attending to filing issues.

5.80 $4,060.00




Tax I.D.# 74‐2138615

10/29/15 J. Southwick Revising and editing briefs opposing summary judgment and motions in limine re Farris and M. Mason.

2.60 $1,820.00

10/29/15 L. Eccles Attending to briefing. 0.50 $250.00

10/29/15 J. Stanley Preparing documents for attorney review. Conferring with team re filing.

3.00 $810.00

10/29/15 M. Fisher Proofreading opposition to News's motion for summary judgment.

1.90 $522.50

10/29/15 K. Hoek Reviewing drafts of summary judgment opposition and supporting documents. Reviewing and responding to emails concerning summary judgment opposition.

2.20 $1,320.00

10/29/15 R. Hess Revising motion for summary judgment brief. Revising response to 56.1 statement. Conferring by phone with filing team. Revising response to Mackie‐Mason motion in limine.

7.40 $4,070.00

10/29/15 J. Ross Finalizing papers. Attending to filing requirements.

8.70 $6,090.00

10/29/15 R. Caughey Finalizing opposition to motion for summary judgment and conferring with team re same.

10.90 $5,177.50

10/30/15 L. Eccles Conferring via email re briefing. 0.40 $200.00

10/30/15 J. Stanley Preparing documents for attorney review and assisting with filing.

12.00 $3,240.00

10/30/15 M. Fisher Proofreading opposition to News's motion for summary judgment.

1.80 $495.00

10/30/15 J. Southwick Conferring on calls and emails involving service and filing of papers opposing summary judgment and motions in limine.

2.00 $1,400.00

10/30/15 K. Hoek Reviewing final drafts of summary judgment opposition and supporting papers.

1.50 $900.00

10/30/15 R. Hess Revising and finalizing briefs for motion for summary judgment and Daubert responses. Revising response to Mackie‐Mason motion in limine. Revising motion for summery judgment brief. Revising 56.1 response. Conferring by phone with R. Caughey. Conferring in office with R. Caughey. Conferring by email with trial team.

2.60 $1,430.00

10/30/15 J. Ross Finalizing papers and filing opposition 9.00 $6,300.00




Tax I.D.# 74‐2138615

papers and supporting documents.

10/30/15 R. Caughey Finalizing and filing opposition to motion for summary judgment. Conferring with experts re issues.

7.90 $3,752.50

11/02/15 V. Lee Performing network storage maintenance. 3.20 $400.00

11/02/15 J. Stanley Reviewing documents. Preparing notebooks. 2.00 $540.00

11/02/15 L. Eccles Conferring via email re deposition notice and briefing.

0.80 $400.00

11/02/15 J. Southwick Conferring by phone with S. Benz, Berry, D. Goldman, and L. LeClair to discuss work going forward including mock trial and pretrial order preparation. Conferring with J. Ross re filing of sealed materials.

1.40 $980.00

11/02/15 R. Hess Reviewing order from court. Reviewing correspondence opposing counsel re subpoena. Conferring by email with trial team re same.

0.10 $55.00

11/02/15 R. Caughey Conferring with team re summary judgment tasks and related issues.

0.20 $95.00

11/03/15 J. Southwick Attending meeting of trial team by phone. Reviewing proposed pretrial order exchange dates and emails with S. Benz. Proposing revised dates for exchanging pretrial order materials.

1.40 $980.00

11/03/15 J. Stanley Preparing summary judgment notebooks. 2.00 $540.00

11/03/15 L. Eccles Conferring via email re mock trial. Attending weekly conference call.

0.40 $200.00

11/03/15 R. Hess Conferring by phone with trial team re mock trial and pretrial tasks.

1.00 $550.00

11/03/15 J. Ross Preparing for and attending weekly conference call. Attending to privilege log challenges. Attending to pretrial order tasks.

2.50 $1,750.00

11/03/15 R. Caughey Participating in management committee call. Addressing issues related to mock trial and summary judgment.

0.50 $237.50

11/04/15 J. Southwick Preparing for oral argument of News request to engage in settlement discussions with absent class members. Editing and circulating counterproposal to News re exchange of materials for pretrial order.

6.60 $4,620.00




Tax I.D.# 74‐2138615

11/04/15 L. Eccles Conferring via email re trial schedule. Reviewing case.

0.60 $300.00

11/04/15 R. Hess Reviewing and conferring by email with trial team re proposed pretrial schedule. Conferring by email with trial team re pretrial schedule and potential jury questionnaire.

0.60 $330.00

11/04/15 R. Caughey Conferring with team re News petitions and absent class member issue.

0.50 $237.50

11/05/15 L. Eccles Conferring via email and teleconference re hearing and mock trial.

2.20 $1,100.00

11/05/15 J. Southwick Preparing for conference and conferring by phone with J. Pauley re defendant's request to pursue settlement communications with class members. Attending call with cocounsel re hearing. Preparing for oral argument of summary judgment motion. Attending call with cocounsel and DOAR re preparation for mock trial.

7.40 $5,180.00

11/05/15 R. Hess Conferring by phone with counsel for witness. Conferring by email with trial team re deposition scheduling. Preparing draft correspondence to opposing counsel. Reviewing materials supplied by expert. Reviewing correspondence from cocounsel. Conferring in office with J. Southwick and J. Ross re hearing. Conferring by phone with trial team re mock trial.

1.50 $825.00


11/06/15 L. Eccles Conferring by email re mock trial. 0.20 $100.00

11/09/15 J. Southwick Preparing task list and assignments for pretrial order. Conferring by phone with D. Goldman re G. Henderson and FGI break in evidence. Conferring by phone with S. Sparling re Valassis and his call with L. Stevenson.

3.90 $2,730.00

11/09/15 R. Caughey Preparing for weekly discovery call. 0.20 $95.00

11/09/15 J. Stanley Reviewing documents. Updating fee and expense charts. Preparing deposition chart for J. Southwick.

4.00 $1,080.00




Tax I.D.# 74‐2138615


0.50 $137.50

11/10/15 R. Caughey Participating in weekly management committee call. Conferring with team re Rule 23(f) petition. Conferring with team re mock trial.

0.60 $285.00

11/10/15 J. Southwick Participating in weekly trial team call. Reading cases in preparation for summary judgment oral argument. Reviewing orders and mandate denying 23(f) petition. Conferring with J. Ross and R. Hess re denial of 23(f) petition.

3.60 $2,520.00


11/10/15 R. Hess Reviewing Second Circuit docket re 23(f) petition. Reviewing order. Conferring by email with trial team. Conferring in office with J. Southwick re petition denial. Conferring by email with R. Caughey re Second Circuit panel. Conferring by phone with trial re upcoming depositions and mock trial.

2.30 $1,265.00

11/10/15 J. Ross Preparing for and attending weekly conference call.

1.00 $700.00

11/11/15 J. Southwick Reviewing correspondence re proposed stipulation of authenticity and conversations with J. Ross and R. Hess re proposal. Reviewing case law in preparation for summary judgment argument.

3.70 $2,590.00

11/11/15 J. Stanley Reviewing documents. Updating charts. 4.00 $1,080.00

11/11/15 R. Hess Reviewing correspondence to clients and experts. Conferring by email with J. Southwick re same. Conferring in office with J. Ross and J. Southwick re authenticating documents and News stipulation.

0.60 $330.00

11/11/15 J. Ross Reviewing Valassis documents re defendants' proposed stipulation.

2.50 $1,750.00

11/11/15 K. Hoek Reviewing case materials and correspondence.

0.60 $360.00

11/11/15 R. Caughey Addressing discovery and privilege issues. Conferring with team re summary judgment.

1.80 $855.00




Tax I.D.# 74‐2138615

Arranging travel for hearings and mock argument.

11/12/15 J. Southwick Reviewing proposed stipulation re third party exhibits from News and discussing with J. Ross and S. Benz. Reviewing cases and exhibits in summary judgment motion papers and opposition in preparation for oral argument.

5.40 $3,780.00

11/12/15 V. Lee Converting single‐page tiffs into multi‐page PDF documents.

0.20 $25.00

11/12/15 R. Hess Reviewing correspondence from opposing counsel. Preparing correspondence to same. Conferring by email with trial team re deposition dates. Reviewing transcript of Supreme Court hearing on class issue. Conferring by email with trial team re third party witness. Conferring by phone with counsel for third party witness.

2.60 $1,430.00

11/12/15 R. Caughey Conferring with cocounsel re third‐party discovery and privilege. Reviewing summary judgment materials.

1.00 $475.00

11/13/15 J. Southwick Reviewing summary judgment filings and cases in preparation for oral argument.

6.00 $4,200.00

11/13/15 V. Lee Performing network storage management. 1.70 $212.50

11/13/15 L. Eccles Reviewing email. 0.30 $150.00

11/13/15 J. Ross Reviewing documents. Attending to privilege log issue and Valassis document stipulation issue.

3.20 $2,240.00

11/13/15 R. Caughey Reviewing and commenting on News's summary judgment reply papers. Preparing for summary judgment mock argument and argument. Addressing privilege and discovery issues. Reviewing News's privilege logs.

3.00 $1,425.00

11/15/15 J. Southwick Reviewing reply papers filed in support of summary judgment motion.

1.10 $770.00

11/15/15 R. Hess Reviewing brief and reply paper in support of News motion for summary judgment.

0.90 $495.00

11/15/15 R. Caughey Preparing for summary judgment argument. 1.00 $475.00

11/16/15 J. Southwick Conferring by phone with L. LeClair re 2.00 $1,400.00




Tax I.D.# 74‐2138615

summary judgment oral argument. Selecting exhibits for summary judgment oral argument and meeting with R. Caughey and P. Radford to prepare slides for summary judgment oral argument. Reviewing reply briefs in support of motions to exclude experts. Reviewing order re communications with absent class members and reviewing options for reconsideration and appeal. Conferring by email with cocounsel re order on class member communications.

11/16/15 R. Hess Reviewing privilege logs and conferring by email with R. Caughey and J. Southwick re potential challenges. Conferring by email with trial team re court order.

2.10 $1,155.00

11/16/15 R. Caughey Participating in call with associates. Reviewing and commenting on News' reply brief. Preparing for summary judgment argument. Addressing issues with visuals and A/V in the courtroom.

2.20 $1,045.00

11/16/15 R. Caughey Preparing Q&A for summary judgment oral argument. Conferring with team re class member settlement issues. Participating in weekly call. Addressing privilege log and document production issues.

2.50 $1,187.50

11/16/15 L. Eccles Reviewing emails re mock trial. Reviewing order.

0.90 $450.00

11/17/15 M. Fisher Conferring by phone with News litigation team. Researching issue of admissibility of depositions from other cases as summary judgment evidence in 2nd Circuit. Researching admissibility of George Rebh trial testimony under FRE 804(b)(1)(a‐b) hearsay exception.

2.80 $770.00

11/17/15 J. Southwick Preparing for weekly conference call with cocounsel. Reviewing summary judgment filings in preparation for oral argument.

6.60 $4,620.00

11/17/15 R. Caughey Addressing privilege log discovery dispute issues. Preparing for oral argument on summary judgment. Conferring with clients re ROFRs. Participating in management

2.00 $950.00




Tax I.D.# 74‐2138615

committee call.


11/17/15 L. Eccles Reviewing email correspondence re order. 0.70 $350.00

11/17/15 J. Ross Preparing for and attending weekly call. 0.80 $560.00

11/17/15 R. Hess Reviewing privilege log and conferring by email with R. Caughey and J. Southwick re potential challenges.

0.50 $275.00

11/17/15 R. Hess Conferring by email with trial team re court order.

0.30 $165.00

11/17/15 R. Hess Conferring by phone with trial team. Conferring in office with J. Southwick re court order. Conferring by email with cocounsel re draft letter.

1.10 $605.00

11/18/15 R. Caughey Conferring with team re upcoming oral argument. Preparing Q&A for oral argument. Addressing issues with summary judgment record. Preparing legal research re summary judgment points.

4.90 $2,327.50

11/18/15 J. Stanley Reviewing documents and preparing materials for motion for summary judgement argument.

4.00 $1,080.00

11/18/15 M. Fisher Researching issue of admissibility of depositions from other cases as summary judgment evidence in 2nd Circuit. Researching admissibility of George Rebh trial testimony under FRE 804(b)(1)(a‐b) hearsay exception and 32(4)(a).

6.80 $1,870.00

11/18/15 R. Hess Conferring in office with J. Southwick and R. Caughey re motion for summary judgment hearing preparation.

2.50 $1,375.00

11/18/15 J. Southwick Meeting with R. Hess and R. Caughey to discuss summary judgment oral argument. Reviewing and responding to emails with cocounsel re News communications with absent class members.

2.90 $2,030.00

11/19/15 J. Stanley Reviewing documents and preparing materials for motion for summary judgment argument.

5.00 $1,350.00

11/19/15 L. Eccles Reviewing draft letter to court and associated emails.

0.50 $250.00




Tax I.D.# 74‐2138615

11/19/15 R. Caughey Attending and participating in mock oral argument. Preparing legal and factual research re summary judgment. Preparing talking points re summary judgment. Traveling to and from Washington, DC to Houston, TX.

14.50 $6,887.50

11/19/15 M. Fisher Researching issue of admissibility of depositions from other cases as summary judgment evidence in 2nd Circuit. Researching admissibility of George Rebh trial testimony under 32(4)(a).

3.40 $935.00

11/19/15 R. Hess Reviewing memorandum and correspondence from trial team re response to Judge Pauley order.

0.30 $165.00

11/19/15 R. Hess Conferring by phone with trial team re mock argument.

0.50 $275.00

11/19/15 R. Hess Conferring by phone with trial team re mock argument. Conferring by email with J. Southwick and R. Caughey re letter to Judge Pauley.

0.50 $275.00

11/19/15 J. Southwick Traveling to Washington. Preparing for and participating in mock oral arguments of summary judgment motion and motions in limine to strike experts. Conferring by phone with B. Michael and S. Benz to meet and confer over News effort to quash third party depositions.

9.80 $6,860.00

11/20/15 R. Caughey Working with J. Southwick to finalize summary judgment argument. Conferring with court re technology. Preparing motion re corrected exhibit. Reviewing objections to statement of material facts.

4.40 $2,090.00

11/20/15 M. Fisher Drafting section 5 of Plaintiffs Response to Defendants' Material Facts Statement Objections.

7.90 $2,172.50

11/20/15 R. Hess Conferring with J. Southwick re letter to court. Conferring by phone with trial team re same.

0.60 $330.00

11/20/15 R. Hess Preparing response to defendants' objections to 56.1 statement responses.

9.50 $5,225.00

11/20/15 J. Southwick Meeting with Dorian Vela from Legal Media 3.30 $2,310.00




Tax I.D.# 74‐2138615

and R. Caughey to prepare slides for summary judgment oral argument.

11/21/15 M. Fisher Drafting section 5 of plaintiffs response to defendants' material facts statement objections.

4.10 $1,127.50

11/21/15 R. Hess Preparing response to defendants' objections to 56.1 statement responses.

0.30 $165.00

11/21/15 R. Hess Revising response to defendants' objections to 56.1 statement responses.

1.10 $605.00

11/21/15 J. Southwick Preparing slides and presentation for summary judgment oral argument.

3.90 $2,730.00

11/22/15 R. Caughey Preparing for upcoming summary judgment hearing. Preparing research re evidentiary objections.

1.50 $712.50

11/22/15 J. Southwick Preparing slides and presentation for summary judgment oral argument.

3.20 $2,240.00


11/23/15 R. Caughey Preparing for summary judgment argument. Revising and filing response to evidentiary objections. Preparing and filing sealing materials for response to evidentiary objections. Traveling from Houston, TX to New York, NY.

9.50 $4,512.50

11/23/15 R. Hess Traveling to New York for motion for summary judgment hearing. Revising response to objections. Conferring with J. Southwick. Conferring by phone with attorney for third party witness.

5.30 $2,915.00

11/23/15 J. Southwick Preparing for oral argument of summary judgment motion. Meeting with Kellogg Huber, R. Caughey and R. Hess re editing and filing responses to News evidentiary objections. Reviewing letter to J. Pauley re News communications with absent class counsel.

10.20 $7,140.00

11/23/15 L. Eccles Reviewing draft briefing, argument, and class letters and conferring via email re same.

2.30 $1,150.00

11/24/15 R. Caughey Preparing for and participating in summary judgment hearing. Conferring with team re

5.90 $2,802.50




Tax I.D.# 74‐2138615

summary judgment hearing. Reviewing and revising letter to the court re depositions. Conferring with team re next steps, mock trial, and discovery.

11/24/15 J. Southwick Preparing for and attending oral argument on summary judgment. Conferring on calls and emails with cocounsel re oral argument.

6.70 $4,690.00

11/24/15 L. Eccles Reviewing filings. Conferring via email re hearing.

0.80 $400.00

11/24/15 R. Hess Preparing for hearing on motion for summary judgment and Daubert motions. Conferring with co‐counsel, J. Southwick, and R. Caughey re same. Reviewing fact statement, response, and objections. Reviewing brief in support and opposition to motion for summary judgment.

6.60 $3,630.00

11/25/15 R. Caughey Addressing issues with privilege log and discovery letter. Reviewing discovery communications with opposing counsel. Traveling from New York, NY to Charlotte, NC.

3.50 $1,662.50

11/25/15 J. Southwick Reviewing and responding to emails re letter to court re third party depositions.

1.00 $700.00

11/25/15 J. Stanley Reviewing documents. Updating charts. 2.00 $540.00

11/30/15 J. Southwick Conferring by phone with S. Benz re Kramer Levin time in October. Reviewing emails re contact with class members with whom News seeks to settle.

0.80 $560.00

11/30/15 R. Caughey Preparing deposition designations and exhibits for pre‐trial order. Making arrangements for mock trial.

2.10 $997.50

12/01/15 J. Southwick Conferring by phone with cocounsel re upcoming tasks. Conferring by phone with L. LeClair re management issues and circulating lodestar spreadsheet. Reviewing order from court re upcoming teleconference and related emails.

1.40 $980.00

12/01/15 J. Stanley Preparing for trial. 2.00 $540.00


12/01/15 L. Eccles Reviewing filings. Conferring via email re 3.10 $1,550.00




Tax I.D.# 74‐2138615

mock trial and other issues.

12/01/15 R. Caughey Participating in weekly management committee call. Preparing deposition designations and exhibits for pretrial order. Conferring with Kramer Levin re pretrial order documents. Reviewing mock trial materials and making related arrangements. Preparing research and analysis re privilege objections and related issues.

3.10 $1,472.50

12/02/15 M. Fisher Reviewing plaintiffs documents for potential trial exhibits.

2.80 $770.00

12/02/15 J. Southwick Participating in weekly call with cocounsel. Conferring by phone with management committee re Kramer Levin time submitted in October and going forward. Conferring on calls with D. Goldman and S. Benz re courtroom trial team composition. Reviewing proposed letter to J. Pauley re Dickson testimony at deposition. Conferring by phone with S. Benz re decision not to file letter.

3.30 $2,310.00

12/02/15 J. Stanley Preparing for trial. 4.00 $1,080.00

12/02/15 R. Hess Reviewing transcript of Dixson deposition. 1.00 $550.00


12/02/15 L. Eccles Reviewing email re deposition designations, mock trial, and other pretrial tasks. Reviewing deposition designations.

2.00 $1,000.00

12/02/15 J. Ross Reviewing and drafting deposition designations.

4.50 $3,150.00

12/02/15 R. Caughey Preparing deposition designations and exhibits for exhibit list. Conferring with team re pre‐trial order tasks and participating in teleconference re same. Conferring with J. Southwick re Oracle database. Preparing and sending letters to CPGs re settlement, and conferring with R. Pfau re CPG spends. Conferring with chambers of Pauley, J. re telephone hearing. Conferring with team re witness designations. Preparing legal research re post‐opt out class communications and settlements, and

4.80 $2,280.00




Tax I.D.# 74‐2138615

preparing memorandum to team re same.

12/03/15 M. Fisher Attending telephonic hearing with R. Caughey and J. Southwick re Court's November 16 memorandum and order and discovery dispute raised in November 25, 2015 joint letter. Reviewing plaintiffs documents for potential trial exhibits.

7.40 $2,035.00

12/03/15 J. Southwick Preparing for and participating in conference call with Court re communications with class members and additional depositions. Conferring with R. Hess, R. Caughey, and J. Stanley re deposition designations and pretrial order exchange on 12/7.

4.70 $3,290.00

12/03/15 R. Hess Reviewing correspondence and conferring by email with trial team. Conferring in office with trial team (J. Southwick, R. Caughey, J. Ross, and J. Stanley) re deposition designations. Reviewing and revising draft outline of argument for discovery motion. Conferring by email with S. Benz re same.

2.00 $1,100.00

12/03/15 L. Eccles Reviewing oral argument outline and providing comments. Reviewing deposition designations.

8.10 $4,050.00

12/03/15 J. Ross Drafting deposition designations. 5.00 $3,500.00

12/03/15 R. Caughey Preparing outline of oral argument on third‐party depositions for telephone hearing and conferring with S. Benz re same. Participating in telephone hearing with court. Meeting with J. Southwick re pretrial order, telephone hearing, and tasks. Making deposition designations and addressing other issues with pretrial order. Preparing summary of telephone hearing to team and conferring with team re hearing. Conferring with team re CPG settlements. Conferring with co‐counsel re deposition designations.

6.50 $3,087.50

12/04/15 M. Fisher Reviewing plaintiffs documents for potential trial exhibits.

5.60 $1,540.00


12/04/15 J. Southwick Designating deposition of D. Hansa for pretrial order. Reviewing memoranda.

3.40 $2,380.00




Tax I.D.# 74‐2138615

Conferring on call with News counsel re statutes of limitations. Conferring by phone with D. Goldman re trial preparation. Summarizing call with News re statutes of limitation.

12/04/15 R. Hess Reviewing documents and legal memorandum re statute of limitations issue. Conferring in office with J. Southwick re management committee and trial team responsibilities. Preparing deposition designations for C. Carpenter and C. Hamilton.

3.60 $1,980.00

12/04/15 L. Eccles Reviewing deposition designations. Conferring via email re mock trial and trial.

5.30 $2,650.00

12/04/15 J. Ross Drafting deposition designations. 3.70 $2,590.00

12/04/15 R. Caughey Preparing deposition designations and exhibit list items. Revising witness list. Conferring with team re strategy and issues.

4.50 $2,137.50


12/05/15 L. Eccles Reviewing deposition designations and conferring via email re same.

1.80 $900.00

12/05/15 R. Caughey Preparing deposition designations and conferring with team re same.

1.00 $475.00


12/06/15 J. Southwick Designating deposition of L. Berg for pretrial order. Reviewing and responding to emails re mock trial and pretrial order.

2.20 $1,540.00

12/06/15 R. Hess Preparing deposition designations for G. Rebh.

7.20 $3,960.00

12/06/15 R. Caughey Preparing deposition designations and conferring with team re same. Preparing for mock trial. Preparing exhibit list items. Addressing issues with witness list.

3.10 $1,472.50

12/07/15 R. Hess Preparing deposition designations for J. Weber. Traveling to New York for mock trial. Reviewing deposition designation for G. Rebh. Conferring by email with trial team. Reviewing News America Marketing exhibit list. Reviewing News America Marketing witness list. Conferring by email with trial

11.20 $6,160.00




Tax I.D.# 74‐2138615

team.

12/07/15 J. Ross Reviewing documents for exhibit list and deposition designations. Finalizing same.

3.50 $2,450.00

12/07/15 R. Caughey Preparing pretrial order submissions and conferring with team re same. Addressing issues with deposition designations. Preparing for mock trial. Reviewing privilege log issues. Preparing deposition designations for R. Spitz and R. Emmel. Conferring with R. Hess re deposition designation issues and R. Emmel. Traveling from Houston, TX to New York, NY for mock trial.

8.90 $4,227.50

12/07/15 J. Southwick Reviewing and responding to emails re preliminary exhibit list, witness list, and deposition depositions.

3.00 $2,100.00


12/07/15 L. Eccles Attending to pretrial tasks and addressing various emails. Reviewing deposition designations.

4.80 $2,400.00

12/08/15 R. Caughey Participating in mock trial in New York. Meeting with team re strategy. Preparing research re statutes of limitations. Addressing issues with pre‐trial order and deposition designations.

7.00 $3,325.00

12/08/15 J. Southwick Attending mock trial. Revising motion to request access to confidential information for Hormel. Reviewing and responding to emails re pretrial issues. Reviewing defendants' exhibit list.

5.00 $3,500.00

12/08/15 J. Stanley Preparing for trial. Preparing materials for deposition.

3.00 $810.00

12/08/15 L. Eccles Conferring via email re mock trial and deposition designations.

0.20 $100.00

12/08/15 R. Hess Attending mock trial. Conferring by email with trial team. Conferring by phone with J. Southwick and R. Caughey. Preparing for deposition of R. Emmel.

10.20 $5,610.00

12/09/15 J. Stanley Preparing for deposition. 4.00 $1,080.00

12/09/15 J. Southwick Attending mock trial. Conferring by phone with M. Palizzi. Reviewing correspondence

7.00 $4,900.00




Tax I.D.# 74‐2138615

from Valassis.

12/09/15 R. Hess Attending mock trial. Conferring by email with trial team. Conferring by phone with J. Southwick and R. Caughey. Preparing for deposition of R. Emmel. Traveling from New York City.

14.60 $8,030.00

12/09/15 R. Caughey Participating in mock trial in New York. Traveling from New York, NY to Houston, TX.

11.00 $5,225.00

12/10/15 L. Eccles Reviewing emails re jury questionnaire, trial witnesses, and filings.

1.40 $700.00

12/10/15 J. Stanley Preparing for trial. Preparing for deposition. 6.00 $1,620.00

12/10/15 J. Southwick Conferring by email with J. Vint of Navigant re Oracle database. Reviewing letter from Valassis counsel re summary judgment papers and related email to News counsel. Conferring with R. Hess re upcoming depositions of Emmel, Lucidi, and Ball.

1.40 $980.00

12/10/15 R. Hess Traveling from to New York. Preparing for deposition of R. Emmel.

4.40 $2,420.00

12/10/15 R. Hess Attending mock trial. Conferring by email with trial team. Conferring by phone with J. Southwick and R. Caughey. Preparing for deposition of R. Emmel.

10.20 $5,610.00

12/10/15 R. Caughey Preparing recap of mock trial. Reviewing documents and depositions in connection with preparing pretrial order. Conferring with opposing counsel re pretrial order. Preparing redactions.

4.80 $2,280.00

12/11/15 L. Eccles Reviewing emails re trial preparation tasks. 0.10 $50.00

12/11/15 J. Stanley Preparing for trial. Preparing for deposition. 5.00 $1,350.00

12/11/15 J. Southwick Reviewing News preliminary witness list, exhibit lists, and deposition designations. Reviewing emails re communications with class members.

1.50 $1,050.00

12/11/15 R. Hess Preparing for deposition of R. Emmel. 7.00 $3,850.00

12/11/15 R. Caughey Identifying privilege log entries to challenge and conferring with team re same. Reviewing documents and depositions in connection with preparing pretrial order. Conferring with team re redactions.

4.50 $2,137.50




Tax I.D.# 74‐2138615

Conferring with team re statute of limitations issues. Conferring with opposing counsel re redactions.

12/12/15 R. Hess Preparing for deposition of R. Emmel. Traveling to Atlanta.

14.40 $7,920.00

12/12/15 R. Caughey Conferring with R. Hess re Emmel deposition and circulating exhibits.

0.30 $142.50

12/13/15 R. Hess Traveling from Atlanta. Reviewing transcript of Emmel deposition. Preparing deposition summary. Conferring by email with trial team. Preparing for deposition of R. Emmel. Deposing R. Emmel. Conferring by phone with R. Emmel and counsel.

15.00 $8,250.00

12/13/15 R. Caughey Addressing issues with confidentiality and absent class members.

0.20 $95.00

12/14/15 J. Southwick Conferring by phone with S. Benz re various pre‐trial order issues. Conferring with R. Caughey re assigning duties for counter designating deposition testimony. Conferring with R. Caughey re Hormel Foods filing seeking access to protective order materials.

1.10 $770.00

12/14/15 R. Hess Conferring by email with trial team re pretrial order assignments. Reviewing email re limitations period. Conferring by email with R. Caughey re meet and confer.

1.00 $550.00

12/14/15 L. Eccles Conferring via email re trial preparation. Reviewing mock trial tasks.

2.30 $1,150.00


12/14/15 R. Caughey Revising petition for access to confidential information and filing. Conferring with team re same. Reviewing documents in connection with pretrial order tasks. Reviewing deposition designations. Addressing limitations issues. Preparing and circulating assignments memo. Participating in discovery call.

6.20 $2,945.00

12/15/15 R. Hess Reviewing draft of News America Marketing privilege log challenges. Conferring in office with J. Southwick re stipulation response. Reviewing memorandum re statute of

2.80 $1,540.00




Tax I.D.# 74‐2138615

limitations and contractual limitations defenses. Conferring by email with mock trial.

12/15/15 J. Southwick Reviewing and responding to emails re pretrial order materials.

0.40 $280.00

12/15/15 L. Eccles Reviewing trial team emails. 0.40 $200.00


12/15/15 R. Caughey Reviewing documents and deposition transcripts in connection with preparing pretrial order. Preparing privilege log correspondence and analyzing privilege log re same. Participating in management committee call. Conferring with team re privilege challenges. Addressing issues with redacted filings. Addressing privilege log issues.

3.90 $1,852.50

12/16/15 R. Hess Reviewing transcript and deposition summary of K. Ball. Reviewing briefing re waiving affirmative defenses.

1.00 $550.00

12/16/15 J. Southwick Attending weekly trial team call. Reviewing statute of limitations research and responding to News re proposed stipulation concerning damages period. Reviewing revised draft letter and appendices to News re privilege log and discussing with R. Caughey.

5.60 $3,920.00


12/16/15 L. Eccles Reviewing co‐lead counsel email re settlement and confidential information.

0.50 $250.00


12/16/15 R. Caughey Preparing exhibit objections and deposition counter‐designations. Addressing issues with redacted summary judgment filings. Conferring with team re privilege log issues. Preparing legal and factual research re statute of limitations and contractual limitations issues. Conferring with team re CPG settlement issues. Preparing memorandum to team re News' exhibits.

5.50 $2,612.50

12/17/15 J. Southwick Conferring with R. Caughey and R. Hess re 2.00 $1,400.00




Tax I.D.# 74‐2138615

pretrial order issues. Reviewing defendants trial exhibits.

12/17/15 L. Eccles Conferring via email re exhibit list, jury questionnaire, and other tasks.

0.20 $100.00

12/17/15 L. Eccles Reviewing exhibits and related email correspondence.

2.50 $1,250.00


12/17/15 R. Hess Reviewing draft juror questionnaire. Conferring in office with J. Southwick and R. Caughey re exhibit objections and statute of limitations defense. Conferring by phone with KHHT and R. Caughey re exhibits. Conferring in office with R. Caughey re exhibit objections. Reviewing briefing on waiver of affirmative defenses. Reviewing invoices from deposition.

5.30 $2,915.00

12/17/15 R. Caughey Preparing exhibit objections and deposition counter‐designations. Addressing related issues with pretrial order. Conferring with team and cocounsel re pretrial order tasks. Preparing and filing petitions for confidential information for CPG class members. Preparing memorandum re categories of documents and standard objections.

6.90 $3,277.50

12/18/15 J. Southwick Conferring by phone with S. Benz and D. Goldman re trial exhibits. Conferring by email and in office with R. Hess and R. Caughey re trial exhibits. Conferring by email re News efforts to settle with large class members.

2.00 $1,400.00


12/18/15 R. Hess Conferring by phone with counsel for General Mills. Conferring in office with J. Southwick re deposition expenses. Reviewing draft correspondence to opposing counsel. Reviewing privilege log. Preparing exhibit objections.

6.90 $3,795.00

12/18/15 J. Ross Reviewing deposition designations. Making counter designations and objections.

5.70 $3,990.00

12/18/15 R. Caughey Preparing objections to exhibits and 5.50 $2,612.50




Tax I.D.# 74‐2138615

deposition counter‐designations. Meeting with J. Southwick and R. Hess re same. Participating in call with Kellogg Huber re exhibit objections. Addressing issues with privilege. Conferring with opposing counsel re petitions for confidential information. Preparing redacted filings. Reviewing our exhibit list.

12/18/15 M. Bartlett Reviewing and organizing exhibits. 2.50 $375.00


12/19/15 R. Hess Preparing exhibit objections.

1.50 $825.00


12/20/15 R. Hess Preparing exhibit objections.

1.50 $825.00

12/20/15 R. Caughey Preparing objections to exhibits and deposition counter‐designations. Conferring with cocounsel re corrections to counter‐designations. Conferring with S. Berry re summary judgment hearing transcript. Conferring with J. Southwick and R. Hess re privilege log issues.

4.00 $1,900.00


12/21/15 R. Hess Preparing exhibit objections. Conferring by email with trial team re jury questionnaire. Conferring in office with R. Caughey. Conferring in office with J. Southwick. Conferring by email with trial team.

7.90 $4,345.00

12/21/15 J. Southwick Reviewing proposed trial exhibits. Reviewing emails re pretrial order exchanges.

1.10 $770.00

12/21/15 R. Caughey Preparing objections to exhibits and deposition counter‐designations. Participating in discovery call. Conferring with R. Hess and L. Eccles re exhibit objections. Addressing issues with News exhibit list documents. Preparing communications to team re General Mills audit issue. Circulating exhibit objections to team. Addressing issues with Larry Mortimer documents and conferring with Kellogg team

12.00 $5,700.00




Tax I.D.# 74‐2138615

re same. Filing redacted summary judgment papers. Conferring with team re objections to Valassis documents, especially regarding Kowalczyk and Kmart.

12/21/15 L. Eccles Conferring via email re pretrial tasks. Attending to NAM exhibit list.

0.70 $350.00

12/21/15 L. Eccles Preparing deposition designations. 3.50 $1,750.00

12/22/15 J. Southwick Attending weekly trial team call. Conferring by phone with L. LeClair re management issues. Preparing for and conferring on call with News counsel re altering the class definition and proposing a juror questionnaire. Conferring by email with cocousel re call with News counsel. Conferring with R. Caughey re pretrial order exchange materials. Identifying counter designations to L. Berg transcript.

3.70 $2,590.00

12/22/15 R. Hess Reviewing and revising juror questionnaire. Conferring by email with J. Southwick re same. Conferring by email with consultants re same. Preparing exhibit objections. Conferring by phone with trial team. Conferring in office with R. Caughey. Conferring in office with J. Southwick. Conferring by email with trial team. Conferring by phone with opposing counsel.

7.40 $4,070.00

12/22/15 R. Caughey Revising exhibit objections and coordinating with cocounsel to finalize objections. Reviewing correspondence from cocounsel re revisions to objections and pretrial order issues. Updating designations for D. Porco. Reviewing and commenting on jury questionnaire.

4.50 $2,137.50


12/23/15 J. Southwick Conferring with R. Caughey re exchange of pretrial order materials. Reviewing and responding to email re pretrial order exchange.

1.80 $1,260.00

12/23/15 R. Hess Reviewing email from cocounsel. Revising juror questionnaire.

1.00 $550.00

12/23/15 R. Caughey Preparing memorandum to team re 6.40 $3,040.00




Tax I.D.# 74‐2138615

statutory and contractual limitations issues. Conferring with team re limitations issues. Finalizing exhibit objections and deposition counter‐designations for service to opposing counsel. Conferring with J. Stanley and K. Briggs re pretrial order issues and service. Preparing corrections to certain initial deposition designations. Preparing cover pleadings for service of deposition designations. Conferring with team re revised witness list.



12/27/15 R. Caughey Conferring with J. Stanley re exhibits. Addressing issues re pretrial order tasks.

0.30 $142.50


12/28/15 R. Hess Revising juror questionnaire. Conferring by email with trial team re same.

0.40 $220.00

12/28/15 R. Caughey Participating in weekly discovery call. Preparing objections for pretrial order. Conferring with team re upcoming tasks.

0.50 $237.50


12/28/15 M. Bartlett Reviewing and organizing documents in preparation for defendant exhibit chronology.

8.00 $1,200.00


12/29/15 J. Southwick Attending weekly trial team call. Reviewing and responding to emails re pretrial exchanges.

0.80 $560.00

12/29/15 R. Caughey Addressing issues relating to pretrial order. Participating in management committee call. Reviewing designations.

1.50 $712.50


8.00 $1,200.00

12/29/15 R. Hess Reviewing News draft of juror questionnaire. Conferring by email with trial team.

1.50 $825.00


12/30/15 J. Southwick Reviewing filings re class period and use of 1.20 $840.00




Tax I.D.# 74‐2138615

deposition testimony and related emails from trial team.

12/30/15 R. Caughey Coordinating issues relating to pretrial order. Reviewing objections and designations relating to pretrial order. Conferring with opposing counsel re exhibit list and objections. Reviewing and commenting on motions from News. Preparing communications re News's evidentiary motions.

2.50 $1,187.50


8.00 $1,200.00

12/30/15 M. Bartlett Applying deposition designations to Brotherton and Keim transcripts.

3.00 $450.00

12/30/15 R. Hess Preparing correspondence to opposing counsel re jury questionnaire. Conferring by email with trial team re briefing assignment and deposition counter designations.

0.40 $220.00

12/31/15 R. Caughey Reviewing News's objections and preparing communications re key evidentiary issues. Conferring with J. Southwick re evidentiary strategy. Addressing limitations issue.

2.00 $950.00

12/31/15 J. Southwick Reviewing and responding to emails re trial and pretrial order.

0.30 $210.00

01/02/16 R. Caughey Addressing issues relating to class period and damages calculations. Preparing materials for joint pretrial order. Conferring with team re strategy.

2.00 $950.00

01/03/16 J. Southwick Reviewing filings re use of depositions from prior matters and to alter start date of class period and related emails.

1.40 $1,050.00

01/03/16 R. Caughey Preparing draft of response to News's motion re use of prior deposition testimony at trial. Preparing legal research re Rule 32(a)(8) and FRE 804. Conferring with team re prior depositions and Rebh testimony.

5.50 $2,612.50

01/04/16 M. Bartlett Preparing deposition designations. 3.00 $525.00

01/04/16 L. Eccles Conferring via email re pretrial tasks. 3.50 $1,925.00

01/04/16 R. Wojtczak Conferring with S. Schulze and preparing for 3.00 $810.00




Tax I.D.# 74‐2138615

trial.

01/04/16 J. Southwick Reviewing deposition designations from prior cases to determine what could be dropped.

3.90 $2,925.00

01/04/16 R. Hess Reviewing transcript of prior litigation depositions. Conferring in office with J. Southwick re same.

2.50 $1,375.00


01/04/16 R. Caughey Reviewing prior deposition transcripts in connection with responding to News' motion re use of prior deposition testimony at trial. Preparing legal research. Preparing draft of response to News' motion re use of prior deposition testimony at trial. Conferring with J. Southwick re strategy and legal issues. Conferring with team re reply briefing. Preparing deposition rebuttal designations. Conferring with L. Eccles re designation issues. Participating in weekly discovery call.

8.50 $4,037.50

01/05/16 L. Eccles Conferring via email re class representative issues. Drafting class representative deposition preparation outline.

4.10 $2,255.00

01/05/16 R. Wojtczak Preparing for trial. 1.50 $405.00

01/05/16 J. Southwick Reviewing settlement agreement and releases of CPGs. Reviewing documents related to arbitration agreements of Kraft and Abbott. Attending weekly call with cocounsel. Conferring by phone with D. Goldman re trial preparation. Conferring by phone with S. Benz re responding to motion concerning depositions in prior cases. Conferring by phone with M. Palizzi.

3.80 $2,850.00

01/05/16 R. Hess Conferring by phone with opposing counsel. Reviewing draft letter to court. Conferring by email with trial team re jury questionnaire. Conferring by phone with potential witness and former fact witnesses. Conferring in office with J. Southwick re same. Reviewing draft questionnaire. Conferring by email with opposing counsel.

2.30 $1,265.00




Tax I.D.# 74‐2138615

Conferring by phone with trial team. Reviewing draft letter response. Conferring by email with R. Caughey.

01/05/16 R. Caughey Drafting, revising, and circulating motion re use of prior litigation testimony at trial. Reviewing transcripts of prior litigation witnesses. Preparing legal research re Rule 32(a)(8) and FRE 804. Conferring with team re strategy. Preparing deposition rebuttal designations. Preparing revisions to premotion response letter and circulating to team. Participating in weekly management committee call. Conferring with K. Briggs re Insignia opening and document issues. Conferring with opposing counsel re Biery and Henry transcripts. Reviewing and commenting on jury questionnaire.

12.90 $6,127.50

01/06/16 M. Fisher Researching issues relating to admitting trial testimony under Federal Rule of Evidence 804 and Federal Rule of Civil Procedure 32 for a deceased deponent.

2.30 $632.50

01/06/16 L. Eccles Conferring via email re potential tasks. Preparing deposition designations.

5.80 $3,190.00

01/06/16 R. Wojtczak Conferring with S. Schulze re task assignments.

0.50 $135.00

01/06/16 R. Wojtczak Preparing for trial. Reviewing and revising deposition designations. Conferring with J. Stanley.

2.00 $540.00

01/06/16 J. Southwick Reviewing and revising opposition to motion in limine re testimony from prior cases. Conferring by phone with J. Anderson, J. Chepiga and S. Benz re prior settlements with class members. Reviewing and responding to email re pretrial issues. Reviewing letter to court re amending class period and call with F. Hall.

5.50 $4,125.00

01/06/16 R. Hess Reviewing transcript and preparing deposition counter‐designations for G. Rebh. Reviewing correspondence from trial team and opposing counsel re jury questionnaire. Preparing correspondence to opposing

2.70 $1,485.00




Tax I.D.# 74‐2138615

counsel re same. Conferring by email with trial team re Rebh deposition and trial testimony. Preparing summary of same.


01/06/16 R. Caughey Conferring with team re objection codes. Preparing rebuttal deposition designations and conferring with team re same. Preparing deposition objections. Preparing research re use of prior testimony and other pretrial issues. Meeting with team re pretrial issues. Addressing issues relating to response to motion to preclude, and revising same. Making arrangements for final pretrial hearing.

9.60 $4,560.00

01/07/16 M. Fisher Researching issues relating to admitting trial testimony under Federal Rule of Evidence 804 and Federal Rule of Civil Procedure 32 for a deceased deponent.

2.50 $687.50

01/07/16 L. Eccles Conferring via email re pretrial tasks. 1.20 $660.00

01/07/16 R. Wojtczak Preparing rebuttal deposition designations and pre‐trial filings.

8.30 $2,241.00

01/07/16 R. Hess Preparing rebuttal designations. Conferring in office with R. Caughey. Reviewing letter motion.

1.00 $550.00

01/07/16 J. Southwick Conferring by phone and emails with trial team re pretrial order materials and exchanges, trial preparation, and trial logistics.

3.00 $2,250.00


01/07/16 R. Caughey Preparing, formatting, revising, and serving rebuttal deposition designations. Reviewing News exhibits. Addressing issues relating to prior testimony motion. Preparing deposition objections and corrections. Addressing issues relating to joint pretrial order. Preparing and filing petition for access to confidential information on behalf of class member. Call with cocounsel re joint pretrial order drafting. Conferring with J. Southwick regarding proposed bargain over prior litigation testimony and Rebh, and

10.90 $5,177.50




Tax I.D.# 74‐2138615

preparing communications to team re same. Conferring with cocounsel re prior litigation testimony. Preparing memorandum to team re contractual limitations issue. Reviewing documents from News' recent productions.

01/08/16 J. Southwick Conferring by phone with B. Michael and cocounsel. Preparing email re stipulation concerning prior testimony. Conferring by phone with L. LeClair re communications with absent class member. Reviewing materials re communications with absent class members and preparing email to cocounsel. Reviewing mock trial report.

4.70 $3,525.00

01/08/16 M. Bartlett Preparing deposition designations for R. Emmel.

2.00 $350.00


01/08/16 R. Wojtczak Preparing deposition designations and preparing for trial.

6.00 $1,620.00


01/08/16 R. Caughey Preparing deposition objections. Conferring with team re prior testimony issues. Addressing issues relating to joint pretrial order. Meeting with paralegals re deposition objections. Revising deposition objection codes. Filing petition for access to confidential information by absent class member.

5.80 $2,755.00

01/09/16 J. Southwick Reviewing emails and revising stipulation re prior case testimony.

0.60 $450.00

01/10/16 R. Caughey Preparing deposition objections. Conferring with paralegals re formatting and processing of deposition objections. Conferring with F. Hall re issues.

3.00 $1,425.00


01/10/16 R. Wojtczak Reviewing and organizing case materials. 0.50 $135.00

01/11/16 J. Southwick Reviewing emails re mock trial invoice. Conferring by phone with G. Chepiga re prior testimony stipulation. Conferring by phone with D. Goldman re pretrial order and meet and confer. Attending meeting with R. Hess

2.80 $2,100.00




Tax I.D.# 74‐2138615

and R. Caughey re pretrial order and meet and confer issues. Conferring by emails with R. Pfau re potential exclusions from damages.

01/11/16 R. Hess Preparing objections to Berg deposition counter designation and rebuttal designations. Conferring by phone with J. Southwick re mock trial. Conferring by email with R. Caughey re juror questionnaire. Preparing objections to Emmel deposition counter designations. Conferring in office with J. Southwick and R. Caughey re joint pretrial order. Preparing objections to Hansa deposition counter designations. Conferring in office with R. Caughey re same. Conferring by phone with re same. Preparing to Rebh testimony counter designations.

7.10 $3,905.00

01/11/16 R. Caughey Serving deposition objections, plus revised witness list and supplemental exhibit objections. Coordinating service with Kellogg Huber. Preparing deposition objections. Formatting and finalizing deposition objections. Conferring with cocounsel, team, and paralegals re deposition objections. Proofing deposition objections. Participating in weekly discovery call. Preparing joint pretrial order. Conferring with opposing counsel re joint pretrial order and arranging call re same. Conferring with J. Southwick and R. Hess re strategy and tasks for joint pretrial order. Conferring with team re Spectrum dismissal.

12.60 $5,985.00

01/11/16 R. Wojtczak Preparing deposition objections and preparing for trial.

10.00 $2,700.00

01/12/16 R. Caughey Participating in pretrial meet and confer with Paul Weiss. Preparing memorandum re pretrial meet and confer. Participating in management committee call. Preparing memoranda to team re contractual limitations issue. Reviewing and commenting on joint pretrial order language. Addressing supplemental

8.10 $3,847.50




Tax I.D.# 74‐2138615

objections and designations. Conferring with Kellogg Huber re exhibit list and objections. Conferring with Kellogg Huber re Spectrum dismissal and privilege issues. Addressing issues relating to stipulation regarding prior litigation testimony. Revising and circulating responsive pre‐motion letter regarding jury questionnaire.

01/12/16 J. Southwick Reviewing and responding to emails re pretrial order.

0.40 $300.00

01/12/16 M. Fisher Conferring by phone with News trial team for weekly status update meeting.

0.50 $137.50

01/12/16 R. Wojtczak Organizing deposition and designation materials.

0.50 $135.00


01/12/16 R. Hess Preparing correspondence to court re letter requesting premotion conference on juror questionnaire. Conferring by phone with trial team.

6.90 $3,795.00

01/13/16 J. Southwick Conferring by phone with D. Goldman re trial preparation. Reviewing and responding to emails re pretrial order.

1.10 $825.00

01/13/16 R. Wojtczak Reviewing correspondence. 0.30 $81.00

01/13/16 R. Hess Conferring by phone with General Mills outside counsel. Conferring by email with trial team re same.

0.60 $330.00

01/13/16 R. Caughey Revising deposition objection and designation spreadsheets and serving on opposing counsel. Conferring with S. Benz re photographic evidence, Spectrum dismissal, and issues. Conferring with Foster Farms and BEF re corporate representatives for trial. Conferring with J. Southwick and R. Hess re witness list. Preparing analysis of witness list. Reviewing and revising joint pretrial order text. Reviewing and commenting on proposed stipulation re prior testimony. Reviewing exhibits. Addressing trial preparation issues.

7.50 $3,562.50

01/14/16 R. Wojtczak Adding counter‐designations to deposition transcripts and preparing for trial.

3.00 $810.00




Tax I.D.# 74‐2138615

01/14/16 R. Hess Reviewing transcript of G. Rebh testimony. Preparing rebuttal designations. Conferring by email with trial team. Conferring in office with R. Caughey. Reviewing letter motion.

6.80 $3,740.00

01/14/16 R. Caughey Preparing and revising materials for joint pretrial order. Conferring with R. Hess re Rebh designations. Conferring with team re designations. Conferring with Foster Farms and BEF re corporate representatives. Conferring with J. Southwick re Berg. Preparing proposals re witness list and circulating to team. Conferring with McKool Smith team re designations and pretrial order. Conferring with opposing counsel re pretrial order. Drafting sections of pretrial order and exchanging with opposing counsel. Reviewing reservation of rights language for exhibit list and proposing revisions re same. Proposing factual stipulations for joint pretrial order.

7.50 $3,562.50

01/14/16 J. Southwick Reviewing emails re pretrial order and Applecon's work re revised damages using recently produced data.

3.80 $2,850.00

01/15/16 R. Wojtczak Preparing for trial‐preparing portions of JPTO.

5.50 $1,485.00

01/15/16 R. Hess Reviewing transcript of G. Rebh testimony. Preparing rebuttal designations. Conferring by email with trial team.

5.90 $3,245.00

01/15/16 L. Eccles Conferring via email re pretrial tasks. Reviewing orders.

1.30 $715.00

01/15/16 R. Caughey Preparing, revising, finalizing, and filing joint pretrial order. Conferring with opposing counsel re revisions to and filing of pretrial order. Conferring with team re revisions to and filing of pretrial order. Preparing deposition objections and designations. Addressing issues relating to motions to seal. Revising witness list and conferring with clients and co‐counsel re same. Preparing legal research re evidentiary issues. Conferring with Kellogg Huber re exhibit issues. Conferring with McKool Smith re

13.50 $6,412.50




Tax I.D.# 74‐2138615

counter deposition designations for CPG witnesses. Meeting with team re summary judgment order and next steps. Addressing issues relating to CPG communications re News settlement offers.

01/15/16 J. Southwick Reviewing filings related to joint pretrial order and related emails. Reviewing supplemental damages report using recently produced data. Reviewing opinion denying summary judgment and Daubert motions.

6.60 $4,950.00

01/16/16 R. Wojtczak Reviewing case materials and JPTO. 1.00 $270.00

01/16/16 R. Caughey Conferring with team re motions in limine and exhibit lists.

0.40 $190.00

01/18/16 R. Caughey Preparing proposed motion in limine assignments. Reviewing and circulating joint pretrial order papers. Preparing for teleconference with court. Preparing for pretrial hearing. Participating in weekly associates' discovery call.

4.20 $1,995.00

01/18/16 J. Southwick Reviewing and responding to emails re pretrial issues.

0.30 $225.00

01/18/16 J. Stanley Preparing for pre‐trial. 2.00 $540.00

01/19/16 J. Southwick Reviewing spreadsheet and conferring by phone with R. Pfau re individual consumer packaged goods damages. Attending weekly call with cocounsel. Attending conference with Court re juror questionnaire and pretrial issues. Conferring with cocounsel following telephone conference re which class members are publicly traded.

3.20 $2,400.00

01/19/16 L. Eccles Conferring via email re pretrial preparation and releases.

1.70 $935.00

01/19/16 R. Wojtczak Reviewing case materials. Organizing depositions and other materials from JPTO.

1.00 $270.00

01/19/16 R. Hess Preparing for hearing on pretrial order. Conferring by phone with trial team. Conferring by phone with trial team and experts re damages and settlement calculations. Conferring in office with trial team re hearing on juror questionnaire. Preparing for hearing on pretrial order.

1.90 $1,045.00




Tax I.D.# 74‐2138615

01/19/16 R. Caughey Participating in teleconference with the court re jury questionnaire. Preparing for pretrial hearing. Preparing legal research and materials re alteration of class period and statute of limitations. Preparing memoranda re Defendants' summary exhibits and conditional exhibit list. Preparing analysis of deposition designations and exhibits in advance of pretrial hearing. Meeting with R. Hess and J. Southwick re tasks. Participating in weekly trial team call. Participating in call with experts re damages analysis.

8.80 $4,180.00

01/20/16 J. Southwick Conferring by phone and by email re class member list of public companies and judicial recusal standards. Attending telephone conference with court re juror questionnaire and class member list and post hearing call with cocounsel. Conferring by email re final pretrial hearing.

3.10 $2,325.00

01/20/16 L. Eccles Conferring via email re recusal issue and pretrial tasks.

0.90 $495.00

01/20/16 R. Wojtczak Reviewing case materials and preparing for trial.

0.80 $216.00

01/20/16 R. Hess Conferring in office with J. Southwick and R. Caughey re final pretrial order, jury questionnaire and settlement. Preparing for hearing on pretrial order.

1.20 $660.00

01/20/16 R. Caughey Addressing financial interest issues. Conferring with clients re representation at trial. Conferring with J. Southwick and R. Hess re trial exhibits. Participating in telephone hearing with the court and meeting with J. Southwick and R. Hess re strategy. Preparing for witnesses and motions in limine.

3.90 $1,852.50

01/21/16 L. Eccles Conferring via email pretrial conference and other issues.

1.20 $660.00

01/21/16 R. Wojtczak Organizing depositions. 0.50 $135.00

01/21/16 J. Southwick Conferring by phone with M. Palizzi and K. Scott. Conferring by emails re pretrial

2.00 $1,500.00




Tax I.D.# 74‐2138615

conference issues and meet and conferring on pretrial issues.

01/21/16 R. Hess Reviewing motion in limine re released claims. Conferring by email with trial team. Reviewing correspondence from same.

0.70 $385.00

01/21/16 R. Caughey Addressing issues relating to releases and class period. Preparing pretrial materials. Preparing for pretrial hearing. Conferring with opposing counsel re joint pretrial order meet and confer. Commenting on proposed jury questionnaire. Drafting motions in limine and preparing legal research re same. Preparing and filing petition for access to confidential information. Conferring with opposing counsel re pretrial issues.

7.10 $3,372.50

01/22/16 L. Eccles Conferring via email re pretrial issues. 0.30 $165.00

01/22/16 R. Hess Conferring by email with trial team. Reviewing correspondence from same.

0.90 $495.00

01/22/16 R. Caughey Preparing and filing petition for access to confidential information. Preparing memorandum re pretrial issues and status of negotiations with opposing counsel. Conferring with cocounsel re Lucidi‐Chamass testimony. Arranging travel to pretrial hearing.

5.80 $2,755.00


01/23/16 R. Wojtczak Reviewing correspondence and pleadings. 0.50 $135.00


01/25/16 J. Southwick Conferring by phone with M. Palizzi. Reviewing and responding to emails re pretrial issues. Conferring with R. Pfau re releases and associated revenues and damages, also discussing trial testimony preparation. Reviewing filing by Crowell and Moring.

2.20 $1,650.00

01/25/16 R. Hess Reviewing mock trial results. Traveling to New York City for pretrial conference. Conferring with R. Caughey.

6.20 $3,410.00

01/25/16 J. Ross Attending to pretrial issues. 1.50 $1,125.00

01/25/16 R. Caughey Drafting response to News's motion in 12.90 $6,127.50




Tax I.D.# 74‐2138615

limine re releases. Preparing legal research re releases. Conferring with team and circulating memoranda to team re releases. Preparing for pretrial hearing and conferring with team re same. Addressing evidentiary and witness issues. Traveling from Houston to New York for pretrial hearing. Conferring with cocounsel re CPG releases and preparing analysis re same.


01/25/16 R. Wojtczak Reviewing correspondence and case materials.

0.30 $81.00

01/26/16 J. Southwick Conferring on calls with R. Hess, R. Caughey, and M. Palizzi re pretrial hearing. Reviewing emails re Crowell Moring letter and other pretrial issues.

1.70 $1,275.00

01/26/16 R. Caughey Preparing for and attending pretrial hearing. Conferring with cocounsel re pretrial hearing and preparations re same. Preparing memorandum to team re pretrial hearing. Drafting opposition to News's motion re releases. Preparing legal research re releases. Conferring with team re summary exhibits and settlement. Reviewing documents relating to Crowell & Moring's proposed class member settlements and conferring with team re same. Conferring with J. Briody, J. Smith, and R. Hess re upcoming tasks and deadlines. Conferring with J. Southwick re status, meet and confer, and tasks. Traveling from New York to Houston.

13.90 $6,602.50

01/26/16 L. Eccles Reviewing letters to court re class member settlements. Conferring via email re same.

1.20 $660.00

01/26/16 R. Hess Preparing for hearing on final pretrial order. Conferring by phone with trial team. Reviewing summary judgment and other orders. Conferring by phone with J. Southwick re pretrial conference. Conferring in office with R. Caughey and trial team. Traveling from New York City for pretrial conference. Conferring with R. Caughey.

10.70 $5,885.00




Tax I.D.# 74‐2138615

01/27/16 R. Caughey Participating in weekly trial team teleconference. Participating in associates' call re pretrial tasks and meet and confer. Arranging travel to meet and confer. Reviewing exhibits and depositions in advance of meet and confer. Drafting opposition re releases and preparing legal research re same. Drafting motions in limine and preparing legal research re same. Conferring with team re motions in limine and pretrial strategy. Meeting with R. Hess re pretrial tasks. Revising rebuttal deposition designations, conferring with co‐counsel re same, and preparing communications to opposing counsel re same. Reviewing News's revised exhibit list.

7.40 $3,515.00

01/27/16 J. Southwick Preparing for and conferring on call with cocounsel re trial preparation and recap of pretrial conference.

1.60 $1,200.00

01/27/16 L. Eccles Conferring via email re pretrial tasks. Reviewing hearing transcript.

1.00 $550.00


01/27/16 R. Hess Conferring by phone with trial team. Reviewing correspondence from same.

1.10 $605.00

01/27/16 J. Ross Attending to pretrial deliverables. Participating on counsel conference call.

2.70 $2,025.00

01/28/16 J. Southwick Reviewing and responding to email re trial preparation and settlement issues.

0.30 $225.00

01/28/16 L. Eccles Corresponding via email re pretrial tasks. 0.10 $55.00

01/28/16 R. Caughey Preparing for pretrial meet and confer. Reviewing and analyzing testimony of and objections regarding Berg, Dmochowski, Emmel, and Hansa. Reviewing and analyzing objections to News and plaintiffs documents. Conferring with team re preparations for pretrial meet and confer. Drafting and revising opposition to motion in limine re releases and preparing legal research re same. Preparing documents and other logistical tasks for pretrial meet and confer. Traveling from Houston to

7.50 $3,562.50




Tax I.D.# 74‐2138615

Washington, DC.


01/28/16 R. Hess Reviewing emails. Conferring by email with trial team.

0.50 $275.00

01/29/16 L. Eccles Reviewing email re pretrial tasks. 0.10 $55.00

01/29/16 R. Caughey Participating in meet and confer with K. Gallo and W. Michael re pretrial issues, motions in limine, exhibits, and deposition transcripts. Preparing for meet and confer. Working with K. Denk to prepare memorandum memorializing meet and confer items. Meeting with co‐counsel team to discuss strategy and action items. Drafting response to motion in limine re releases and preparing legal research re same. Conferring with J. Southwick re meet and confer and amended joint pretrial order. Traveling from Washington, DC to Houston, TX.

10.90 $5,177.50


01/29/16 J. Southwick Reviewing and responding to emails re pretrial issues. Conferring with R. Caughey re meet and confer. Reviewing spreadsheets for potential response to settlement talks.

2.80 $2,100.00

01/29/16 R. Hess Conferring by phone with J. Southwick re R. Rebh. Conferring by email with trial team. Conferring by email with trial team re proposed deposition designation procedure. Conferring with trial team re settlement and proposed compromises.

1.40 $770.00

01/30/16 R. Caughey Drafting and revising opposition to motion in limine re releases. Addressing issues relating to meet and confer and joint pretrial order.

1.30 $617.50

01/30/16 R. Hess Reviewing motion in limine re released claims.

0.50 $275.00

01/31/16 R. Caughey Drafting, revising, and circulating opposition to motion in limine re releases and preparing legal research re same. Conferring with team re evidentiary objections to News photographs.

2.60 $1,235.00




Tax I.D.# 74‐2138615

01/31/16 R. Hess Reviewing motion in limine re released claims.

0.50 $275.00


02/01/16 J. Ross Attention to pretrial filings. 3.40 $2,550.00

02/01/16 J. Southwick Reviewing and responding to emails re trial preparation. Preparing for trial.

3.80 $2,850.00

02/01/16 R. Hess Reviewing and revising draft response to motion in limine re releases. Reviewing and revising pretrial proposals. Conferring by email with trial team and R. Caughey re revised final pretrial order. Reviewing damages spreadsheet from J. Southwick. Conferring by email with trial team re deposition designation procedures.

4.90 $2,695.00

02/01/16 R. Caughey Revising opposition to motion in limine re releases and circulating to team. Participating in meet and confer with opposing counsel re pretrial issues and motions in limine. Drafting motions in limine, circulating motions in limine, and preparing legal research re same. Meeting with J. Southwick re strategy. Conferring with J. Briody and J. Smith re meet and confer and strategy. Preparing for meet and confer and participating in pre‐meet and confer call with co‐counsel. Preparing research re mitigation of damages in antitrust context. Addressing rebuttal deposition designations. Reviewing and commenting on proposal for deposition designations and objections. Reviewing pleadings and pretrial filings. Preparing communications re amended joint pretrial order. Reviewing and commenting on verdict form.

8.50 $4,037.50

02/02/16 J. Southwick Conferring by phone with with D. Goldman re trial assignments. Conferring by phone with S. Benz re settlement. Conferring by phone with K. Gallo and D. Kramer. Reviewing and responding to emails re pretrial filings.

2.20 $1,650.00




Tax I.D.# 74‐2138615


02/02/16 R. Wojtczak Reviewing case materials and correspondence.

0.30 $81.00

02/02/16 R. Hess Reviewing and revising motions in limine. Conferring by phone with trial team. Reviewing and revising verdict form.

2.70 $1,485.00

02/02/16 R. Caughey Participating in weekly management committee call. Revising motions in limine and circulating to team. Preparing legal research re pass‐on defense. Preparing revisions to opposition re statute of limitations. Conferring with McKool Smith team re briefing and revisions. Preparing for trial by reviewing documents and addressing amended joint pretrial order.

6.10 $2,897.50

02/03/16 J. Southwick Conferring by phone with S. Benz, D. Goldman, and L. LeClair re settlement. Conferring by phone with management committee re settlement. Conferring by phone with D. Kramer re settlement and email to management committee. Reviewing and responding to emails re pretrial filings.

5.40 $4,050.00

02/03/16 R. Hess Reviewing News America Marketing filings and letter to court. Conferring by email with same.

1.00 $550.00

02/03/16 R. Caughey Revising, finalizing, and filing opposition to motion to exclude releases. Participating in teleconference re statute of limitations and class period. Revising motion re statute of limitations and class period and conferring with team re same. Preparing legal research re motions in limine and drafting motions in limine. Conferring with experts re class list. Reviewing joint pretrial order materials in advance of trial.

6.90 $3,277.50

02/04/16 J. Southwick Reviewing pretrial filings. Reviewing transcript of January 26 hearing.

2.20 $1,650.00

02/04/16 J. Ross Preparing for mock expert cross in preparation for trial testimony.

3.50 $2,625.00





Tax I.D.# 74‐2138615

02/04/16 R. Caughey Drafting and revising motions in limine. Conferring with team re motions in limine. Preparing legal research re motions in limine. Conferring with team re summaries. Conferring with experts and clients re potential damages.

3.00 $1,425.00

02/05/16 J. Ross Reviewing expert materials and deposition testimony to prepare expert for trial testimony.

1.80 $1,350.00


02/05/16 R. Hess Preparing responses to motion in limine re B. Emmel personal knowledge.

1.00 $550.00

02/05/16 R. Caughey Drafting oppositions to motions in limine. 2.50 $1,187.50

02/06/16 R. Caughey Preparing research re motions in limine and reviewing consulting agreements re same.

0.50 $237.50

02/07/16 J. Ross Reviewing materials and preparing mock cross examination for expert.

2.50 $1,875.00

02/07/16 R. Caughey Drafting and revision oppositions to News's motions in limine and conferring with team re same. Analyzing summary exhibits.

4.40 $2,090.00

02/08/16 J. Ross Reviewing expert materials. Preparing mock cross examination.

4.70 $3,525.00

02/08/16 R. Hess Preparing response to motion in limine re B. Emmel personal knowledge.

3.60 $1,980.00

02/08/16 R. Caughey Drafting, revising, and circulating oppositions to News's motions in limine and circulating. Preparing legal research re News's motions in limine. Conferring with team re motions in limine. Preparing petition for access for Pepsi. Gathering exhibits for oppositions. Conferring with cocounsel re court access issues and hearings.

12.50 $5,937.50


02/08/16 J. Southwick Reviewing proposed letter to Court in response to Valassis/Catalina letter from News. Conferring by emails re request for information and meeting from Davis Polk representing Pepsi in individual settlement negotiations. Conferring by emails and calls

7.90 $5,925.00




Tax I.D.# 74‐2138615

arranging hotel accommodations for entire trial team at Sofitel. Reviewing and commenting on related contract.

02/09/16 J. Southwick Preparing for meeting with Pepsi. Conferring by phone with S. Benz re settlement issues. Reviewing order re start date of class and related emails. Conferring with R. Caughey and R. Hess re order on class start date.

6.60 $4,950.00

02/09/16 R. Caughey Finalizing and facilitating filing of motion in limine oppositions. Conferring with cocounsel re motion in limine oppositions and issues with sealed filing. Conferring with J. Southwick re upcoming hearing, expert analysis, and pretrial tasks. Preparing analysis re News's summary exhibits and conferring with team re same.

4.00 $1,900.00

02/09/16 L. Eccles Conferring via email re pretrial tasks. Reviewing order and email re same.

0.60 $330.00

02/09/16 R. Hess Reviewing and revising responses to motions in limine. Conferring in office with J. Southwick re trial. Reviewing trial team re class date and damages.

1.80 $990.00



02/10/16 J. Southwick Conferring on calls and emails with D. Goldman and K. Slavitt or Reckitt concerning Reckitt's claim in the class action. Reviewing materials for examinations at trial of Mackie‐Mason and Murphy. Reviewing written settlement offer from D. Kramer and related emails with cocounsel. Preparing for meeting with Pepsi's counsel at Davis Polk re individual settlement discussions between News and Pepsi.

7.70 $5,775.00


02/10/16 R. Caughey Conferring with team re pretrial evidentiary issues. Meeting with J. Southwick re pretrial conference tasks. Conferring with class representative re attendance at trial. Conferring with opposing counsel. Preparing replies in support of motions in limine.

4.50 $2,137.50




Tax I.D.# 74‐2138615

Addressing issues with summary documents. Addressing issues re access to confidential information for absent class members. Preparing expert materials for trial.

02/11/16 J. Southwick Drafting email re proposed response to settlement letter. Reviewing letters to Court. Attending telephone hearing on whether Valassis and Catalina must present document custodians for depositions. Conferring on calls with D. Goldman, J. Briody, and M. Palizzi re document issues raised on telephone hearing. Drafting letter to D. Kramer re settlement. Traveling to New York.

12.30 $9,225.00

02/11/16 J. Ross Attention to mock cross of expert in preparation for trial testimony.

4.30 $3,225.00


02/11/16 R. Hess Reviewing and revising reply papers. 0.50 $275.00


02/11/16 R. Caughey Preparing joint pretrial order attachments and papers. Conferring with team re preparations for final pretrial conference. Preparing expert materials. Reviewing replies in support of motions in limine. Conferring with team re summary exhibits and stipulation. Conferring with team re releases. Revising deposition designations in advance of joint pretrial order. Preparing letter re depositions. Conferring with team re L. Mortimer documents. Conferring with team re Kroger documents.

4.60 $2,185.00

02/12/16 J. Southwick Draft and revising letter to D. Kramer re settlement. Preparing for and meeting with Davis Polk re Pepsi and potential individual settlement with News. Conferring with M. Palizzi re Valassis documents. Conferring with D. Goldman at lunch re trial and settlement. Conferring by phone with R. Hess re General Mills position on settlement. Reviewing and responding to emails re trial preparation.

6.80 $5,100.00




Tax I.D.# 74‐2138615


02/12/16 J. Ross Reviewing documents and transcripts for mock expert cross.

5.00 $3,750.00

02/12/16 R. Hess Conferring by phone with J. Southwick re settlement. Reviewing settlement letter.

0.50 $275.00


02/12/16 R. Caughey Finalizing deposition designations for joint pretrial order. Conferring with team re joint pretrial order issues. Conferring with J. Southwick and R. Hess re preparations for expert testimony. Preparing for arguments of motions in limine. Addressing expert testimony issues. Preparing legal research in advance of arguing motions in limine.

3.50 $1,662.50

02/13/16 R. Hess Reviewing correspondence from opposing counsel and trial team.

0.50 $275.00


02/13/16 R. Caughey Preparing for motions in limine argument. Preparing summary memorandum to team re upcoming tasks and positions. Conferring with team re trial strategy and preparations. Conferring with team re CPG releases. Participating in call re amended joint pretrial order. Conferring with team re state‐law claims.

3.50 $1,662.50

02/14/16 R. Hess Reviewing and revising amended final pretrial order.

0.80 $440.00


02/14/16 R. Caughey Coordinating issues relating to finalization and filing of joint pretrial order. Addressing issues with deposition designations. Preparing for motion in limine arguments and preparing legal and factual research re same.

3.40 $1,615.00

02/15/16 J. Ross Attention to expert work in preparation for trial.

6.80 $5,100.00

02/15/16 R. Hess Reviewing and revising proposed deposition protocol.

2.20 $1,210.00

02/15/16 J. Southwick Preparing examination of J. Mackie‐Mason. Conferring by emails with R. Pfau re revised

12.20 $9,150.00




Tax I.D.# 74‐2138615

damage calculations. Reviewing filings on motions in limine. Traveling to New York.


02/15/16 R. Caughey Preparing for motions in limine and pretrial arguments. Preparing legal and factual research re same. Meeting with team re pretrial hearing, motions in limine, and releases. Preparing expert materials for trial. Traveling from Houston, TX to New York, NY.

12.50 $5,937.50

02/16/16 J. Southwick Attending pretrial hearing. Preparing for examination of J. Mackie‐Mason. Conferring by emails with R. Pfau re revised damage calculations. Conferring by phone with D. Kramer re settlement. Conferring on calls and emails with cocounsel re settlement discussion and proposed response.

10.70 $8,025.00


02/16/16 R. Caughey Participating in pretrial hearing. Preparing for pretrial hearing, motions in limine, and preparing legal and factual research re same. Meeting with team re pretrial hearing and trial issues. Addressing expert issues. Conferring with team re motions in limine. Traveling from New York, NY to New Orleans, LA.

11.90 $5,652.50


02/16/16 J. Ross Preparing for expert testimony at trial. 5.60 $4,200.00


02/17/16 R. Caughey Preparing for trial by addressing designations and other issues. Conferring with team re pretrial tasks.

1.50 $712.50


02/17/16 J. Southwick Conferring by email and phone with cocounsel re settlement discussions. Reviewing emails and memoranda concerning whether notice must be sent to class members for dropping state law claims. Conferring by email with cocounsel concerning News officers to individual CPGs that include option to participate in class

8.60 $6,450.00




Tax I.D.# 74‐2138615

settlement. Preparing for trial.

02/17/16 R. Hess Researching factual matters and researching points of law re dropping state law claims. Preparing correspondence to General Mills re settlement question. Researching factual matters and researching points of law re notice of partial dismissal. Conferring by phone with J. Southwick re dropping state law claims. Reviewing transcript of pretrial hearing. Reviewing jury instructions. Conferring by phone with S. Benz and D. Goldman re jury instructions and settlement issues.

5.20 $2,860.00

02/17/16 J. Ross Preparing Murphy cross. Attention to mock Mackie‐Mason cross.

5.00 $3,750.00


02/18/16 J. Southwick Preparing materials for Pepsi's counsel D. Polk. Reviewing motion to dismiss state law claims. Preparing talking point for settlement discussions. Conferring with R. Caughey re drafting motion to enjoin CPG settlements that do not require exiting the class. Conferring by phone with cocounsel re settlement discussions. Preparing direct examination of J. MacKie‐Mason. Conferring by phone with D. Kramer re settlement.

8.90 $6,675.00

02/18/16 R. Hess Reviewing jury instructions. Conferring by email with trial team.

5.10 $2,805.00

02/18/16 R. Caughey Preparing for trial. Preparing deposition objections and designations for service. Addressing pretrial order and motion in limine issues. Preparing for expert directs and crosses. Preparing expert presentations. Meeting with team re issues. Conferring with team re order and releases and response. Conferring with Kramer Levin and McKool Smith teams re corporate structure and Garofalo cross. Drafting, revising, and circulating emergency motion re settlements. Preparing legal research re Rule 23, opt out procedures, and Sherman Act. Reviewing communications re settlement

12.90 $6,127.50




Tax I.D.# 74‐2138615

agreements. Meeting with J. Southwick re settlement agreement issues.

02/18/16 V. Lee Creating and loading documents into the News_Exhibits Eclipse database.

1.30 $162.50


02/19/16 J. Southwick Preparing trial examination and exhibits for J. Mackie Mason. Preparing for trial.

7.70 $5,775.00

02/19/16 R. Hess Reviewing jury instructions. Conferring by email with trial team.

3.40 $1,870.00

02/19/16 J. Ross Preparing crosses for experts. 8.50 $6,375.00

02/19/16 R. Caughey Reviewing and revising emergency motion re settlements and circulating to larger team. Preparing deposition designations. Preparing for trial. Conferring with clients re logistics and client attendance at trial. Conferring with team re J. Corsiglia‐Keim as potential witness. Reviewing law relating to jury charge and damages.

7.90 $3,752.50

02/19/16 V. Lee Updating the News_Exhibits Eclipse database.

1.20 $150.00



02/20/16 J. Southwick Preparing trial examination and exhibits for J. Mackie Mason. Reviewing draft of letter re class member individual settlements and related emails. Conferring by phone with D. Kramer re settlement. Conferring by phone with cocounsel re class member settlement letter. Conferring with D. Kramer re same.

6.50 $4,875.00

02/20/16 R. Hess Reviewing memorandum and correspondence re settlement issues with large CPGs. Conferring by phone with C. Pak re jury charge.

2.50 $1,375.00

02/20/16 R. Caughey Revising emergency motion and participating in calls re same. Preparing expert materials in advance of MacKie‐Mason meeting. Conferring with J. Southwick and team re settlement issues. Conferring with J. Southwick re damages issues and J. MacKie‐Mason. Addressing

4.90 $2,327.50




Tax I.D.# 74‐2138615

issues relating to deposition designations. Conferring with clients re trial logistics.


02/21/16 J. Southwick Preparing trial examination and exhibits for J. Mackie Mason. Reviewing filings re class member individual settlements and related emails.

7.30 $5,475.00

02/21/16 R. Hess Conferring by phone with C. Pak re jury charge. Reviewing draft of jury charge. Conferring by phone with J. Southwick re settlement. Conferring by phone with opposing counsel re jury charge.

3.20 $1,760.00

02/21/16 R. Caughey Drafting, revising, and circulating Q&A re damages. Revising MacKie‐Mason slides. Conferring with J. Southwick re expert testimony strategy. Preparing research re settlement issues. Finalizing and filing emergency letter re settlements. Conferring with clients re trial logistics.

3.30 $1,567.50


02/22/16 R. Hess Conferring by phone with C. Pak. Reviewing jury instructions and verdict form. Revising same. Conferring in office with J. Southwick re verdict form. Conferring by email with trial team re same. Revising jury instructions. Conferring by email with trial team. Conferring by phone with R. Pfau. Conferring in office with trial team. Reviewing jury questionnaire.

10.70 $5,885.00

02/22/16 J. Ross Researching facts re K. Murphy. Drafting cross of same.

7.90 $5,925.00

02/22/16 R. Caughey Re‐filing settlement letter. Conferring with team re responses to News re settlement letter, plaintiffs' objections, and strategy. Preparing deposition objections and related arguments in connection with pretrial deposition designation exchange. Meeting with J. Southwick, R. Hess, and J. Ross re damages arguments. Conferring with R. Pfau re calculations of summary exhibits, damages arguments, releases, and other

12.70 $6,032.50




Tax I.D.# 74‐2138615

issues. Preparing expert materials. Conferring with team re deposition objections. Conferring with team re witness order and related issues. Participating in call with D. James and J. Corsiglia‐Keim re witness issues and testimony. Conferring with clients re trial logistics. Preparing logistics for expert preparations and travel to New York for trial. Addressing technology order.


3.00 $375.00


02/22/16 J. Southwick Preparing for trial. Attending telephone hearing re letters discussing individual CPG class member settlement terms.

8.80 $6,600.00



0.70 $87.50


02/23/16 J. Southwick Preparing for trial. Conferring by phone with cocounsel. Addressing issues for final damages report and reviewing defendants damages reports for cross of J. Mackie Mason. Conferring by phone with D. Kramer re settlement and related emails with cocounsel.

8.20 $6,150.00


02/23/16 R. Caughey Preparing legal research and memorandum re joint and several liability and apportionment of damages and meeting with R. Hess re same. Preparing for trial with team. Addressing expert damages issues and preparing memoranda and analysis re same. Addressing settlement and opt out issues. Addressing witness preparation issues for trial and conferring with trial team re same. Participating in management committee call. Meeting with J. Ross re Murphy cross examination. Meeting with J. Southwick re trial and damages issues. Preparing logistics

7.90 $3,752.50




Tax I.D.# 74‐2138615

for trial.

02/23/16 J. Ross Preparing for J. Mackie‐Mason preparation sessions. Drafting K. Murphy cross

9.50 $7,125.00

02/23/16 R. Hess Preparing for trial and Conferring by phone with R. Caughey re B. Emmel deposition designations. Revising jury instructions. Conferring by email with trial team.

9.10 $5,005.00


02/24/16 R. Caughey Reviewing settlement agreements and conferring with team re same and strategy. Addressing pretrial conference issues. Preparing damages analysis. Preparing analysis re opt outs. Reviewing LOCs re contractual limitations and sending communications to experts re contractual limitations. Meeting with J. Southwick re trial prep. Responding to deposition objections and revising designations.

8.90 $4,227.50

02/24/16 J. Southwick Reviewing settlement agreements with individual class members. Conferring by emails re whether to seek to invalidate portions of those agreements. Preparing for trial.

8.40 $6,300.00

02/24/16 J. Ross Drafting and editing K. Murphy cross. Preparing for J. Mackie‐Mason preparation.

7.80 $5,850.00

02/24/16 R. Hess Preparing for trial and researching factual matters re corporate entity issues.

6.90 $3,795.00



02/25/16 J. Southwick Revising and commenting on draft letter to Court re enforceability of 2/23 settlements. Conferring on multiple calls with cocounsel re draft letter concerning enforceability of settlements. Reviewing materials from J. Mackie‐Mason preparation for trial. Conferring on call with cocounsel re settlement negotiations.

10.50 $7,875.00


02/25/16 R. Caughey Preparing responses to deposition designation objections. Reviewing and

10.30 $4,892.50




Tax I.D.# 74‐2138615

revising settlement motion. Conferring with J. Southwick and J. Ross re trial preparations and settlement issues. Reviewing Dr. MacKie‐Mason supplemental report. Preparing materials for Dr. MacKie‐Mason preparation sessions. Traveling from Houston, TX to Berkeley, CA for Dr. MacKie‐Mason preparation sessions.

02/25/16 R. Hess Preparing for trial and conferring by phone with J. Southwick. Preparing for trial and researching factual matters re corporate entity issues. Preparing for trial and revising and reviewing J. Mackie Mason supplemental report. Reviewing and revising supplemental report. Preparing for trial and reviewing R. Emmel deposition designations.

6.30 $3,465.00

02/25/16 J. Ross Preparing for J. Mackie‐Mason trial preparation. Finalizing first draft of K. Murphy cross. Traveling to Berkeley for preparation session.

10.00 $7,500.00


02/26/16 J. Southwick Preparing for and meeting with J. Mackie‐Mason to prepare trial testimony.

10.00 $7,500.00


02/26/16 R. Caughey Meeting with Dr. MacKie‐Mason and team in Berkeley, CA to prepare for trial testimony and cross. Preparing MacKie‐Mason direct examination Q&A and slides. Conferring with team re expert witness prep. Preparing for trial. Addressing issues with trial exhibits. Addressing issues with damages. Meeting with team re trial and settlement strategy.

10.50 $4,987.50

02/26/16 R. Hess Preparing for trial and preparing to prepare witness. Preparing for trial and traveling to California for witness preparation. Preparing for trial.

10.50 $5,775.00

02/26/16 J. Ross Preparing for and prepping expert J. Mackie‐Mason for trial.

10.50 $7,875.00

02/27/16 J. Stanley Traveling to New York for trial. Preparing for trial.

8.00 $2,160.00

02/27/16 J. Southwick Preparing for and meeting with J. Mackie‐ 6.00 $4,500.00




Tax I.D.# 74‐2138615

Mason to prepare trial testimony. Conferring on calls with D. Kramer and cocounsel re settlement negotiation.

02/27/16 J. Southwick Traveling to New York from California. 5.00 $3,750.00

02/27/16 R. Caughey Meeting with Dr. MacKie‐Mason and team in Berkeley, CA to prepare for trial testimony and cross. Preparing MacKie‐Mason direct examination Q&A and slides. Conferring with team re expert witness prep. Preparing for trial. Conferring with team re market definition exhibits. Traveling from San Francisco, CA to New York, NY.

14.50 $6,887.50

02/27/16 R. Hess Preparing for trial and traveling to New York for trial. Conferring at office of J. Mackie‐Mason re witness preparation.

12.90 $7,095.00

02/27/16 J. Ross Preparing for and prepping expert J. Mackie‐Mason for trial.

8.50 $6,375.00


02/28/16 R. Caughey Preparing witnesses for trial. Meeting with team re trial prep. Preparing materials, evidence, and argument for trial. Working with experts. Traveling from San Francisco, CA to New York, NY.

12.50 $5,937.50

02/28/16 R. Hess Preparing for trial and traveling to New York for trial. Preparing for trial.

17.50 $9,625.00

02/28/16 J. Ross Conducting legal research on verdict form issues with regards to damages number. Traveling back to Houston.

5.50 $4,125.00

02/29/16 J. Stanley Preparing for and attending trial. 12.00 $3,240.00

02/29/16 R. Caughey Preparing for jury selection and first day of trial. Preparing for arguing deposition designation objections. Attending jury selection and first day of trial. Meeting with team re strategy and trial.

11.00 $5,225.00

02/29/16 J. Southwick Negotiating settlement with News Corp and presenting settlement to Court.

10.00 $7,500.00

02/29/16 R. Hess Attending trial and negotiating settlement. 10.50 $5,775.00

02/29/16 J. Ross Conducting legal research on verdict form issue.

4.60 $3,450.00

02/29/16 V. Lee Updating the News_Exhibits Eclipse 2.80 $350.00




Tax I.D.# 74‐2138615

database.


03/01/16 R. Caughey Addressing fees issues and conferring with team re same. Traveling from New York, NY to Houston, TX.

4.50 $2,137.50

03/01/16 R. Hess Traveling from New York City. Preparing settlement agreement and managing client communications.

12.50 $6,875.00

03/01/16 J. Stanley Packing up trial office. Traveling to Houston from New York.

9.00 $2,430.00

03/01/16 J. Southwick Conferring by emails re settlement. Responding to inquiries from class members and media.

2.50 $1,875.00


2.00 $250.00

03/02/16 R. Caughey Reviewing analysis of settlement allocation and conferring with team re same.

0.30 $142.50

03/02/16 J. Southwick Conferring by emails re settlement and responding to inquiries from class members. Conferring by emails with Applecon re analysis of settlement and distribution among class members.

2.00 $1,500.00


0.50 $62.50

03/03/16 R. Caughey Conferring with cocounsel re issues relating to preliminary approval and fee application.

0.30 $142.50

03/03/16 R. Hess Reviewing emails from trial team re damages. Conferring by email with J. Southwick re opt‐out calculation. Conferring by phone with J. Southwick re settlement question.

1.10 $605.00

03/03/16 J. Southwick Preparing for and participating in call with counsel for Pepsi. Conferring by emails with Applecon re analysis of settlement and class member allocations.

2.50 $1,875.00

03/04/16 R. Caughey Conferring with team re post‐settlement filings and briefing.

0.40 $190.00

03/07/16 R. Caughey Drafting definitive settlement agreement. Conferring with team re settlement agreement and administration.

2.20 $1,045.00




Tax I.D.# 74‐2138615

03/07/16 J. Southwick Reviewing PDC and Weisheng settlement agreements. Discussing with R. Caughey re preparing long form settlement agreement to implement the 2/29 term sheet. Conferring on call and emails with B. Wojcik at Applecon re comparing value of class settlement to opt‐out settlements.

3.30 $2,475.00

03/08/16 J. Southwick Conferring with cocounsel to discuss preliminary approval and plans for implementation of settlement.

1.20 $900.00

03/08/16 R. Caughey Drafting definitive settlement agreement. Conferring with team re settlement agreement and administration. Reviewing pleadings, term sheet, law, and other documents in connection with preparing settlement agreement. Circulating settlement agreement to team.

4.40 $2,090.00

03/09/16 J. Southwick Revising settlement agreement and related emails.

4.50 $3,375.00

03/09/16 R. Hess Reviewing draft settlement agreement. 0.60 $330.00

03/09/16 R. Caughey Drafting, revising, and circulating draft of settlement agreement. Meeting with J. Ross re settlement agreement.

1.00 $475.00

03/10/16 J. Southwick Reviewing edits and comments from cocounsel on draft settlement agreement.

2.40 $1,800.00

03/10/16 R. Hess Reviewing and revising draft settlement agreement.

0.20 $110.00

03/10/16 R. Caughey Drafting, revising, and circulating revised settlement agreement.

2.90 $1,377.50

03/11/16 R. Caughey Revising and circulating revised version of settlement agreement. Conferring with team re same. Addressing issues with notice and proofs of claim.

1.00 $475.00

03/11/16 J. Southwick Drafting and revising settlement agreement and sending to Paul Weiss.

2.70 $2,025.00

03/14/16 R. Caughey Drafting, revising, and circulating proposed order granting preliminary approval. Conferring with team and cocounsel re settlement issues.

1.30 $617.50

03/15/16 R. Hess Conferring by email with J. Southwick and R. 0.90 $495.00




Tax I.D.# 74‐2138615

Caughey re communications with clients re settlement. Conferring by phone with trial team.

03/15/16 R. Caughey Conferring with team re settlement disbursement amounts to class members. Drafting motion for preliminary approval of settlement. Conferring with J. Southwick and R. Hess re settlement approval matters. Preparing legal research re settlement.

2.90 $1,377.50

03/16/16 R. Caughey Drafting motion for preliminary approval and conferring with team re same. Conferring with team re settlement issues.

1.80 $855.00

03/17/16 J. Southwick Revising and editing preliminary approval order, final judgment, notice and claim form.

2.50 $1,875.00

03/17/16 R. Hess Reviewing draft judgment, firm time statement, and draft notice. Reviewing proof of claim.

0.30 $165.00

03/17/16 R. Caughey Addressing issues with Insignia letter. Addressing issues with settlement. Drafting, revising, and circulating draft of final judgment. Conferring with Kellogg re drafts of documents.

2.20 $1,045.00

03/18/16 J. Southwick Revising and circulating to Paul Weis preliminary approval order, final judgment, notice and claims form.

2.00 $1,500.00

03/18/16 R. Hess Reviewing proposed notice claim form. Reviewing proposed order on preliminary approval.

0.80 $440.00

03/21/16 J. Ross Reviewing post settlement papers. 2.50 $1,875.00

03/21/16 J. Southwick Reviewing and responding to emails re settlement, requests for information from Kent Recovery, and time records.

1.00 $750.00

03/22/16 R. Caughey Drafting motion for preliminary approval and conferring with team re same. Conferring with team re settlement issues. Participating in weekly conference call.

1.90 $902.50

03/22/16 J. Southwick Attending weekly management committee call. Conferring by email with Kent Recovery Service.

0.50 $375.00

03/22/16 R. Hess Reviewing draft motion for preliminary 0.80 $440.00




Tax I.D.# 74‐2138615

approval. Conferring by phone with trial team. Conferring in office with J. Southwick.

03/23/16 R. Caughey Drafting, revising, and circulating motion for preliminary approval and supporting declarations. Conferring with team re same.

5.50 $2,612.50

03/24/16 R. Hess Reviewing draft motion for settlement approval. Reviewing and revising J. Southwick's declaration.

0.50 $275.00

03/24/16 R. Caughey Conferring with team re preliminary approval motion and conferring with J. Ross re same.

0.30 $142.50

03/24/16 J. Ross Reviewing and editing draft settlement documents and approval request pleadings.

3.50 $2,625.00

03/25/16 J. Southwick Reviewing and editing brief in support of preliminary approval.

1.80 $1,350.00

03/28/16 J. Southwick Conferring by phone with Sofitel Hotel to try to negotiate bill for trial.

0.30 $225.00

03/29/16 J. Southwick Participating in weekly management committee call. Conferring on emails with B. Wojicek re class member spreadsheet. Conferring on calls with Sofitel re trial bill.

0.90 $675.00

03/30/16 J. Southwick Conferring by emails with B. Wojicek re class member spreadsheet.

0.70 $525.00

03/31/16 R. Caughey Reviewing defendants' revisions to settlement agreement.

0.30 $142.50

03/31/16 J. Southwick Reviewing revised spreadsheet and Paul Weiss comments to settlement agreement.

1.70 $1,275.00

04/01/16 R. Hess Reviewing draft settlement agreement revisions. Reviewing term sheet and edits to settlement agreement.

0.60 $330.00

04/01/16 J. Southwick Preparing for and participating in call with S. Benz to review Paul Weiss comments on draft settlement agreement.

1.00 $750.00

04/03/16 R. Caughey Conferring with team re settlement amounts and client communications.

0.30 $142.50

04/04/16 R. Caughey Reviewing and revising motion for preliminary approval and supporting affidavits. Conferring with team re same. Conferring with clients re expected settlement amounts.

0.80 $380.00




Tax I.D.# 74‐2138615

04/04/16 J. Southwick Reviewing comments on settlement agreement from Paul Weiss. Drafting and responding to email re settlement agreement. Revising and circulating preliminary approval brief.

2.70 $2,025.00

04/05/16 J. Southwick Conferring by phone with cocounsel re comments to settlement agreement from P. Weiss. Preparing for call with P. Weiss to discuss comments to settlement agreement.

1.00 $750.00

04/05/16 R. Caughey Conferring with J. Southwick re preliminary approval motion and settlement agreement.

0.30 $142.50

04/06/16 J. Southwick Preparing for and participating in call with Paul Weiss to review redline of settlement agreement. Conferring on call with F. Hall to recap call with Paul Weiss. Reviewing spreadsheet of Susman Godfrey carried case expenses. Reviewing invoice for non‐carried expenses for January/February.

5.60 $4,200.00

04/06/16 R. Caughey Participating in call with opposing counsel re settlement agreement revisions. Meeting with J. Southwick re same. Reviewing proposed settlement agreement revisions. Conferring with J. Southwick re attorneys' fees motion.

1.00 $475.00

04/07/16 J. Southwick Revising preliminary approval brief. 1.10 $825.00

04/08/16 J. Southwick Revising declaration in support of preliminary approval.

3.30 $2,475.00

04/11/16 R. Caughey Reviewing and revising motion for preliminary approval.

0.30 $142.50

04/11/16 J. Southwick Reviewing Southern District of New York and Second Circuit opinions on preliminary and final approval of class settlements.

3.00 $2,250.00

04/11/16 R. Hess Conferring by phone with witness. 0.80 $440.00

04/12/16 J. Southwick Participating in weekly call with management committee. Conferring on emails with in‐house lawyer from Sanofi.

0.40 $300.00

04/12/16 R. Caughey Participating in News management committee call re settlement issues. Reviewing, revising and re‐circulating revised versions of settlement preliminary approval

1.00 $475.00




Tax I.D.# 74‐2138615

motion and Southwick declaration.

04/13/16 J. Southwick Revising preliminary approval brief. Conferring by phone with J. Steinhart of Sanofi/Chattem re Sanofi and its affiliates' claim.

1.60 $1,200.00

04/14/16 R. Caughey Conferring with J. Southwick re preliminary approval motion and settlement agreement.

0.30 $142.50

04/14/16 J. Southwick Drafting and revising brief in support of preliminary approval and accompanying declaration.

4.00 $3,000.00

04/17/16 R. Caughey Reviewing, revising and circulating revised versions of preliminary approval motion and Southwick declaration. Preparing legal and factual research re same.

2.20 $1,045.00

04/18/16 J. Southwick Reviewing emails re settlement agreement and attachments.

0.30 $225.00

04/19/16 J. Southwick Reviewing second round comments from Paul Weiss on settlement agreement, proposed orders and notice of claim form. Reviewing draft memorandum from S. Benz to K. Clark. Conferring on weekly management committee conference call. Reviewing filings re fee award to Quinn Emmanuel from Judge Cote.

5.00 $3,750.00

04/19/16 R. Caughey Conferring with team re settlement approval issues and SDNY. Participating in weekly teleconference re settlement issues.

1.10 $522.50

04/20/16 J. Southwick Reviewing comments from P. Weiss re settlement agreement documents and related emails with management committee.

2.10 $1,575.00

04/22/16 J. Southwick Preparing response to Pepsi re settlement and likely recovery, including emails with M. Coolidge re response rates to class notice in Vitamin C case. Reviewing and revising preliminary approval papers.

3.30 $2,475.00

04/25/16 J. Southwick Conferring on emails re timing of sending of notice. Circulating opinion re objectors in Southern District of New York.

0.40 $300.00

04/26/16 J. Southwick Participating in weekly call with 1.70 $1,275.00




Tax I.D.# 74‐2138615

management committee. Conferring on calls and emails with S. Benz, F. Hall and K. Denk re class list.

04/27/16 J. Southwick Conferring on call with D. Kramer, A. Synott, and S. Benz re settlement agreement. Reviewing emails re new redlines of settlement agreements.

0.90 $675.00

04/28/16 J. Southwick Preparing and circulating to defendants revised versions of settlement agreement, notice to class, proof of claim, preliminary approval order and final judgment and related email with management committee.

4.60 $3,450.00

04/28/16 J. Southwick Preparing settlement agreement. 1.00 $750.00

04/29/16 J. Southwick Reviewing revisions and edits to settlement agreement and exhibits and preliminary approval papers.

5.00 $3,750.00

04/29/16 J. Stanley Updating master fees and expense chart. 0.50 $135.00

04/30/16 R. Caughey Reviewing and commenting on opposing counsel's proposed changes to settlement agreement.

0.40 $190.00

05/01/16 J. Southwick Reviewing and responding to emails from Paul Weiss re preliminary motion papers and settlement agreement.

0.40 $300.00

05/01/16 R. Caughey Conferring with J. Southwick re preliminary approval motion.

0.30 $142.50

05/02/16 J. Southwick Working on final preparation of preliminary approval papers.

6.60 $4,950.00

05/02/16 R. Hess Conferring in office with J. Southwick re settlement agreement and filing.

0.50 $275.00

05/03/16 R. Hess Conferring in office with J. Southwick. Conferring by phone with trial team. Conferring in office with J. Southwick re final approval, potential experts and strategy.

1.10 $605.00

05/03/16 J. Southwick Participating in management committee call. 0.50 $375.00

05/04/16 J. Southwick Conferring on emails and calls with J. Briody and J. Vint re Oracle database. Reviewing News Corp. filing re preliminary approval.

1.10 $825.00

05/06/16 R. Caughey Conferring with experts re settlement allocation.

0.20 $95.00




Tax I.D.# 74‐2138615

05/09/16 J. Southwick Reviewing SG/BSF fee petition in Municipal Derivatives case in SDNY.

0.50 $375.00

05/12/16 J. Southwick Reviewing firms' time in the case for April and for life of case and related emails.

1.50 $1,125.00

05/16/16 J. Southwick Preparing for and participating in call with S. Benz and P. Ivie re KCC's escrow services.

0.50 $375.00

05/17/16 J. Southwick Reviewing emails with B. Wojcik and F. Hall re individual class member purchase information.

0.30 $225.00

05/18/16 R. Caughey Preparing for preliminary approval hearing. 0.40 $190.00

05/29/16 R. Caughey Preparing for preliminary approval hearing and conferring with J. Southwick re same.

0.80 $380.00

05/30/16 J. Southwick Preparing for preliminary approval hearing. 2.00 $1,500.00

05/30/16 R. Caughey Addressing issues with remand opposition and supporting evidence. Drafting and revising opposition papers.

2.00 $950.00

05/31/16 J. Southwick Traveling to NYC and preparing for preliminary approval hearing.

6.00 $4,500.00

05/31/16 R. Hess Reviewing emails and conferring by email with trial team re upcoming preliminary approval conference.

0.10 $55.00

05/31/16 R. Caughey Preparing for preliminary approval hearing. Preparing memorandum re second opt out opportunities. Conferring with J. Southwick re preliminary approval. Traveling from Houston, TX to New York, NY.

6.40 $3,040.00

06/01/16 J. Southwick Preparing for and participating in hearing on preliminary approval. Reviewing revised drafts of preliminary approval order and notice to class members. Conferring on calls with cocounsel re preliminary approval hearing.

5.70 $4,275.00

06/01/16 R. Caughey Preparing for and participating in preliminary approval hearing. Meeting with team re settlement issues and preliminary approval. Revising notice and proposed order and conferring with clerk re issues. Conferring with opposing counsel re settlement issues.

3.50 $1,662.50

06/02/16 J. Southwick Reviewing and responding to emails re 1.10 $825.00




Tax I.D.# 74‐2138615

revised preliminary approval order and notice to class members. Reviewing approval from court.

06/02/16 R. Caughey Conferring with clerk's office and team re proposed order and notice. Coordinating submission of proposed order.

0.50 $237.50

06/07/16 R. Hess Conferring with J. Southwick. 0.30 $165.00

06/08/16 J. Southwick Conferring by phone and multiple emails with F. Hall re class list.

1.20 $900.00

06/09/16 J. Southwick Reviewing class list issues and whether certain ISP purchasers are CPGs.

3.30 $2,475.00

06/10/16 J. Southwick Conferring by phone and emails with F. Hall re class list and notice.

1.90 $1,425.00

06/13/16 J. Southwick Reviewing and responding to emails re class list and mailing of notice.

0.20 $150.00

06/14/16 J. Southwick Participating in management committee weekly call.

0.30 $225.00

06/16/16 R. Hess Reviewing class settlement website for accuracy.

0.20 $110.00

06/16/16 J. Southwick Conferring on calls and emails re inquiries from class action recovery services.

0.80 $600.00

06/17/16 J. Southwick Conferring by phone with R. Christman of KCC re handling inquiries and requests for information from class members and claims recovery agencies.

0.60 $450.00

06/21/16 R. Caughey Participating in weekly call. Reviewing correspondence re settlement approval.

0.30 $142.50

06/22/16 J. Southwick Conferring by phone with R. Christman, S. Benz, and F. Hall re inquiries to KCC re notice. Conferring by phone with P. Jermyn of Kent Recovery Services. Reviewing time entries for fee application.

5.20 $3,900.00


Fees For Professional Services Total $4,496,561.00


exhibit - kcc class action - active casesclassaction.kccllc.net/documents/nwd0001/577-2...case...

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