On June 18, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Hannah Kim,
and
Carol Grajeda
In Her Individual Capacity,
Rita Masino
In Her Individual Capacity,
White & Case, Llp,
for Other Matters - Contract - Other
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Exhibit 3
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action
A B C D E F G H
ATTORNEY
V&A'S CLAIMED
DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES
HOURS
1 HOUR)
Apportioned across Based on Revised
Based on Hours and
As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and
As Submitted by Plaintiff Attorney Rates
by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates
Submitted by Plaintiff
where applicable Submitted by Plaintiff
2
Communications with Client re: intake information and
documents. Outlined incidents, performed legal research and
research on relevant White & Case employees, assessed legal
4/17/2020 KBM $495.00 6.20 0.78 $3,069.00 $383.63
strategy for proceeding and preparation for settlement
demand letter prior to litigation; communications with Client
3 regarding same.
Correspondence with client re: receipt of additional
4/23/2020 KBM $495.00 0.20 0.03 $99.00 $12.38
4 information and arranging tel conf to discuss.
4/25/2020 KBM $495.00 Continue to draft settlement demand letter prior to litigation. 4.40 0.55 $2,178.00 $272.25
5
Tel conf w/ client re:additional factual information and status;
prepared for call by reviewing file and itemizing topics to
4/27/2020 KBM $495.00 5.10 0.64 $2,524.50 $315.56
discuss; post call memo to file with notes and continued to
6 draft and revise settlement demand letter.
Continued to review and revise settlement demand letter:
4/29/2020 KBM $495.00 communications to and from client; tel conf w/. with client; 1.40 0.18 $693.00 $86.63
7 emailed draft of letter to client for review.
Emailed settlement demand letter; communications with
5/4/2020 KBM $495.00 0.30 0.04 $148.50 $18.56
8 client re: same.
Telephone conference with Plaintiff re: update on matter and
6/10/2020 KBM $495.00 drafting complaint; brief review of file for same; email to JE 0.70 0.09 $346.50 $43.31
9 re: initial draft of complaint.
10 6/11/2020 JE $125.00 Drafted complaint for KM. 4.50 0.56 $562.50 $70.31
11 6/15/2020 JE $125.00 Drafted complaint for KM 3.00 0.38 $375.00 $46.88
12 6/16/2020 KBM $495.00 Reviewed initial draft of complaint; began to revise same. 3.58 0.45 $1,772.10 $221.51
Finished initial draft of complaint; sent to P, reviewed edits by
6/17/2020 KBM $495.00 3.60 0.45 $1,782.00 $222.75
13 P, communications about same.
final review and edits to complaint; communications with
6/18/2020 KBM $495.00 support staff re: filing of same; reviewed communications 0.60 0.08 $297.00 $37.13
14 confirming filing.
converted word version of summons into pdf; converted word
6/18/2020 MN $125.00 version of complaint into pdf; combined S&C into one pdf 0.20 0.03 $25.00 $3.13
15 doc; made text readable, formatted, saved
16 6/18/2020 MN $125.00 Drafted Summons 0.30 0.04 $37.50 $4.69
17 6/18/2020 MN $125.00 set up online case file; e-filed S&C 0.30 0.04 $37.50 $4.69
Page 1 of 6
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action
A B C D E F G H
ATTORNEY
V&A'S CLAIMED
DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES
HOURS
HOUR)
Apportioned across Based on Revised
Based on Hours and
As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and
As Submitted by Plaintiff Attorney Rates
by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates
Submitted by Plaintiff
where applicable Submitted by Plaintiff
details in S&C (updated date filed, signatures, reviewed both
6/18/2020 MN $125.00 documents for incongruencies in jurisdiction, date filed, 0.30 0.04 $37.50 $4.69
18 attorneys listed on case, addresses, etc.)
19 6/24/2020 KBM $495.00 communications with P related to litigation. 0.30 0.04 $148.50 $18.56
20 6/26/2020 KBM $495.00 emailed P re: communication received. 0.10 0.01 $49.50 $6.19
Reviewed folders; email message from/to and re: service
7/23/2020 MN $125.00 0.30 0.04 $37.50 $4.69
21 company re aff of sevice
reviewed affidavit of service to corp. def; emailed p re: same
7/27/2020 KBM $495.00 and deadline for Answer; reviewed response and responded 0.20 0.03 $99.00 $12.38
22 to same.
9/14/2020 KBM $495.00 Drafted document and interrogatory demands to Defendants. 3.10 0.39 $1,534.50 $191.81
23
Continued to draft document and interrogatory demands to
9/15/2020 KBM $495.00 defendants; drafted notice of deposition; emailed same to 5.70 0.71 $2,821.50 $352.69
24 Defendants counsel.
9/15/2020 KBM $495.00 Reviewed notice of deposition for plaintiff sent by Defendant. 0.20 0.03 $99.00 $12.38
25
26 9/15/2020 KBM $495.00 Correspondence with P re: Def's answer and dep notice. 0.40 0.05 $198.00 $24.75
27 9/15/2020 KBM $495.00 Reviewed Defendants' answer. 0.70 0.09 $346.50 $43.31
28 9/16/2020 MN $125.00 Efiled PC request and RJI 0.50 0.06 $62.50 $7.81
29 9/16/2020 MN $125.00 Drafted PC request and RJI 0.60 0.08 $75.00 $9.38
Reviewed correspondence from court re: initial court
9/23/2020 KBM $495.00 0.20 0.03 $99.00 $12.38
30 conference; responded to same and calendared same.
Reviewed communication from court re: rescheduling initial
9/29/2020 KBM $495.00 0.10 0.01 $49.50 $6.19
31 conference; recalendared same.
Reviewed communication from Defendant re: request for
additional time to respond to P's discovery demands;
9/29/2020 KBM $495.00 0.10 0.01 $49.50 $6.19
responded to same granting extension request and
32 recalendared same.
33 10/6/2020 MN $125.00 Calendar re: 12/21 Compliance Conf 0.10 0.01 $12.50 $1.56
began formatting docs for KM - P's responses to D's document
10/7/2020 AL $125.00 1.00 0.13 $125.00 $15.63
demands and P's responses to D's interrogatories
34
Page 2 of 6
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action
A B C D E F G H
ATTORNEY
V&A'S CLAIMED
DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES
HOURS
HOUR)
Apportioned across Based on Revised
Based on Hours and
As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and
As Submitted by Plaintiff Attorney Rates
by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates
Submitted by Plaintiff
where applicable Submitted by Plaintiff
Prepared for court conference; attended virtual PC
10/8/2020 KBM $495.00 conference; reviewed pc order and executed same and 1.20 0.15 $594.00 $74.25
35 returned to court.
36 10/8/2020 MN $125.00 Docket re: downloaded, named and saved PC Order 0.10 0.01 $12.50 $1.56
formatted docs - P's responses to D's document demands and
10/9/2020 AL $125.00 2.00 0.25 $250.00 $31.25
37 P's responses to D's interrogatories -for KM.
38 10/13/2020 KBM $495.00 Drafted protective order; emailed Def re: same. 1.70 0.21 $841.50 $105.19
39 10/14/2020 MN $125.00 Calendar re: 11/19 Remote Conf/Oral Argument 0.10 0.01 $12.50 $1.56
worked on responses to document demands served by
11/18/2020 KBM $495.00 defendants; communications with Plaintiff re: documents 3.30 0.41 $1,633.50 $204.19
40 requested for same.
Communications with client re: discovery responses; work on
11/25/2020 KBM $495.00 2.60 0.33 $1,287.00 $160.88
41 updates to responses.
Reviewed documents provided by Plaintiff to respond to
discovery demands; assessed for responsiveness and
11/30/2020 KBM $495.00 6.70 0.84 $3,316.50 $414.56
redaction and confidentiality; revised interrogatory and
42 document demands.
Initial review of revisions to confidentiality stip made by
12/2/2020 KBM $495.00 0.60 0.08 $297.00 $37.13
43 Defendants.
44 12/2/2020 KBM $495.00 vm from client; Tel call with client re: discovery. 0.30 0.04 $148.50 $18.56
Tel conf w/ def re: meet and confer regarding disputes in
12/4/2020 KBM $495.00 confidentiality order; correspondence about same; reviewed 1.20 0.15 $594.00 $74.25
45 further revised draft and responded to same.
12/7/2020 KBM $495.00 communications and revisions with def re: confidentiality stip. 0.60 0.08 $297.00 $37.13
46
12/8/2020 KBM $495.00 ongoing communications and revisions to confidentiality stip. 0.40 0.05 $198.00 $24.75
47
call with def re: meet and confer to resolve outstanding issue
12/9/2020 KBM $495.00 0.50 0.06 $247.50 $30.94
48 with confidentiality stip.
Drafted stip to adjourn court conference; emailed same to def
12/14/2020 KBM $495.00 for review; received confirmation from def and emailed 0.50 0.06 $247.50 $30.94
49 support staff for filing of same.
Telephone conference with KM re discovery status, motion to
12/15/2020 LML $495.00 quash subpoena and upcoming court conf; emails with court 0.60 0.08 $297.00 $37.13
50 re adjourning upcoming conf; reviewed docket
Page 3 of 6
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action
A B C D E F G H
ATTORNEY
V&A'S CLAIMED
DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES
HOURS
HOUR)
Apportioned across Based on Revised
Based on Hours and
As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and
As Submitted by Plaintiff Attorney Rates
by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates
Submitted by Plaintiff
where applicable Submitted by Plaintiff
Reviewed communication from court re: adjournment
12/15/2020 KBM $495.00 request; communications with LL re: assistance handling 0.30 0.04 $148.50 $18.56
51 same.
Telephone conference and emails with Ds and court re
adjourning court conf;Telephone conference and emails with
12/16/2020 LML $495.00 1.00 0.13 $495.00 $61.88
D re same; emails with KM re same; reviewed file in prep for
52 Telephone conference.
Stipulation re: reviewed final version of confidentiality stip
12/26/2020 KBM $495.00 0.40 0.05 $198.00 $24.75
53 and emailed def re: permission to file same.
reviewed d's email re: document exchange and responded to
1/7/2021 KBM $495.00 0.10 0.01 $49.50 $6.19
54 same.
Reviewed email from Def re: exchange of document
production; emailed Plaintiff's documents to defendants;
1/11/2021 KBM $495.00 downloaded documents from Defendants; reviewed 2.40 0.30 $1,188.00 $148.50
documents produced from counseling works; emailed Def re:
marking of certain documents they produced as confidential.
55
Continued to review document production from white and
1/15/2021 KBM $495.00 3.10 0.39 $1,534.50 $191.81
56 case; memo to file with notes for same.
1/18/2021 KBM $495.00 Telephone conference with P re: case update and discovery. 0.80 0.10 $396.00 $49.50
57
1/19/2021 KBM $495.00 Reviewed email from def re: settlement; responded to same. 0.20 0.03 $99.00 $12.38
58
Assessed settlement strategy and calculations to prepare for
1/19/2021 KBM $495.00 2.20 0.28 $1,089.00 $136.13
59 upcoming settlement conference.
60 1/22/2021 KBM $495.00 Tel conf w/. Def re: settlement. 0.30 0.04 $148.50 $18.56
continued to review documents produced by WC and take
1/22/2021 KBM $495.00 3.70 0.46 $1,831.50 $228.94
61 notes on same.
Reviewed correspondence and attached documents from Def
1/29/2021 KBM $495.00 0.40 No Change $198.00 $198.00
62 re: P's unpaid OT; responded to same.
Call with Def re: settlement; communications with P re: same
2/1/2021 KBM $495.00 0.50 0.06 $247.50 $30.94
63 and memo to file.
continued to review discovery and take notes in file on same;
2/4/2021 KBM $495.00 3.70 No Change $1,831.50 $1,831.50
reassessed unpaid wage damages for settlement purposes.
64
Page 4 of 6
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023
Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action
A B C D E F G H
ATTORNEY
V&A'S CLAIMED
DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES
HOURS
HOUR)
Apportioned across Based on Revised
Based on Hours and
As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and
As Submitted by Plaintiff Attorney Rates
by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates
Submitted by Plaintiff
where applicable Submitted by Plaintiff
Docket re: downloaded, named and saved 2021-2-4 Stip and
2/4/2021 MN $125.00 0.10 0.01 $12.50 $1.56
65 Protective Order
continued to review documents produced by def and notes
2/9/2021 KBM $495.00 regarding same; worked on settlement counter and 4.10 No Change $2,029.50 $2,029.50
66 calculations of unpaid wages.
Communications with P re: discovery requested by Def;
3/2/2021 KBM $495.00 finished drafting deficiency letter to Defendants and emailed 1.80 0.23 $891.00 $111.38
67 same.
tel conf w/ P regarding case related matters and
developments and discovery; continued to draft response to
additional discovery and deficiency letter served by Def and
3/10/2021 KBM $495.00 calculate damages requested in same; reviewed additional 3.70 0.46 $1,831.50 $228.94
documents provided by Plaintiff; reviewed correspondence
from Def re: outstanding discovery and upcoming deposition;
68 responded to same.
69 3/16/2021 KBM $495.00 Telephone conference with P re: update on case. 0.80 0.10 $396.00 $49.50
Reviewed correspondence from Def re: check for unpaid
overtime and proposed stip to dismis OT claim; legal research
3/25/2021 KBM $495.00 for same; responded to def re: same, rejecting stip, and 0.80 No Change $396.00 $396.00
providing legal research showing payment for liquidated
damages still required for late payment of wages.
70
Communications with P re: OT check and with staff re: mailing
3/31/2021 KBM $495.00
Document Filed Date
January 19, 2023
Case Filing Date
June 18, 2020
Category
Other Matters - Contract - Other
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Preview
FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Exhibit 3 FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action A B C D E F G H ATTORNEY V&A'S CLAIMED DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES HOURS 1 HOUR) Apportioned across Based on Revised Based on Hours and As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and As Submitted by Plaintiff Attorney Rates by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates Submitted by Plaintiff where applicable Submitted by Plaintiff 2 Communications with Client re: intake information and documents. Outlined incidents, performed legal research and research on relevant White & Case employees, assessed legal 4/17/2020 KBM $495.00 6.20 0.78 $3,069.00 $383.63 strategy for proceeding and preparation for settlement demand letter prior to litigation; communications with Client 3 regarding same. Correspondence with client re: receipt of additional 4/23/2020 KBM $495.00 0.20 0.03 $99.00 $12.38 4 information and arranging tel conf to discuss. 4/25/2020 KBM $495.00 Continue to draft settlement demand letter prior to litigation. 4.40 0.55 $2,178.00 $272.25 5 Tel conf w/ client re:additional factual information and status; prepared for call by reviewing file and itemizing topics to 4/27/2020 KBM $495.00 5.10 0.64 $2,524.50 $315.56 discuss; post call memo to file with notes and continued to 6 draft and revise settlement demand letter. Continued to review and revise settlement demand letter: 4/29/2020 KBM $495.00 communications to and from client; tel conf w/. with client; 1.40 0.18 $693.00 $86.63 7 emailed draft of letter to client for review. Emailed settlement demand letter; communications with 5/4/2020 KBM $495.00 0.30 0.04 $148.50 $18.56 8 client re: same. Telephone conference with Plaintiff re: update on matter and 6/10/2020 KBM $495.00 drafting complaint; brief review of file for same; email to JE 0.70 0.09 $346.50 $43.31 9 re: initial draft of complaint. 10 6/11/2020 JE $125.00 Drafted complaint for KM. 4.50 0.56 $562.50 $70.31 11 6/15/2020 JE $125.00 Drafted complaint for KM 3.00 0.38 $375.00 $46.88 12 6/16/2020 KBM $495.00 Reviewed initial draft of complaint; began to revise same. 3.58 0.45 $1,772.10 $221.51 Finished initial draft of complaint; sent to P, reviewed edits by 6/17/2020 KBM $495.00 3.60 0.45 $1,782.00 $222.75 13 P, communications about same. final review and edits to complaint; communications with 6/18/2020 KBM $495.00 support staff re: filing of same; reviewed communications 0.60 0.08 $297.00 $37.13 14 confirming filing. converted word version of summons into pdf; converted word 6/18/2020 MN $125.00 version of complaint into pdf; combined S&C into one pdf 0.20 0.03 $25.00 $3.13 15 doc; made text readable, formatted, saved 16 6/18/2020 MN $125.00 Drafted Summons 0.30 0.04 $37.50 $4.69 17 6/18/2020 MN $125.00 set up online case file; e-filed S&C 0.30 0.04 $37.50 $4.69 Page 1 of 6 FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action A B C D E F G H ATTORNEY V&A'S CLAIMED DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES HOURS HOUR) Apportioned across Based on Revised Based on Hours and As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and As Submitted by Plaintiff Attorney Rates by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates Submitted by Plaintiff where applicable Submitted by Plaintiff details in S&C (updated date filed, signatures, reviewed both 6/18/2020 MN $125.00 documents for incongruencies in jurisdiction, date filed, 0.30 0.04 $37.50 $4.69 18 attorneys listed on case, addresses, etc.) 19 6/24/2020 KBM $495.00 communications with P related to litigation. 0.30 0.04 $148.50 $18.56 20 6/26/2020 KBM $495.00 emailed P re: communication received. 0.10 0.01 $49.50 $6.19 Reviewed folders; email message from/to and re: service 7/23/2020 MN $125.00 0.30 0.04 $37.50 $4.69 21 company re aff of sevice reviewed affidavit of service to corp. def; emailed p re: same 7/27/2020 KBM $495.00 and deadline for Answer; reviewed response and responded 0.20 0.03 $99.00 $12.38 22 to same. 9/14/2020 KBM $495.00 Drafted document and interrogatory demands to Defendants. 3.10 0.39 $1,534.50 $191.81 23 Continued to draft document and interrogatory demands to 9/15/2020 KBM $495.00 defendants; drafted notice of deposition; emailed same to 5.70 0.71 $2,821.50 $352.69 24 Defendants counsel. 9/15/2020 KBM $495.00 Reviewed notice of deposition for plaintiff sent by Defendant. 0.20 0.03 $99.00 $12.38 25 26 9/15/2020 KBM $495.00 Correspondence with P re: Def's answer and dep notice. 0.40 0.05 $198.00 $24.75 27 9/15/2020 KBM $495.00 Reviewed Defendants' answer. 0.70 0.09 $346.50 $43.31 28 9/16/2020 MN $125.00 Efiled PC request and RJI 0.50 0.06 $62.50 $7.81 29 9/16/2020 MN $125.00 Drafted PC request and RJI 0.60 0.08 $75.00 $9.38 Reviewed correspondence from court re: initial court 9/23/2020 KBM $495.00 0.20 0.03 $99.00 $12.38 30 conference; responded to same and calendared same. Reviewed communication from court re: rescheduling initial 9/29/2020 KBM $495.00 0.10 0.01 $49.50 $6.19 31 conference; recalendared same. Reviewed communication from Defendant re: request for additional time to respond to P's discovery demands; 9/29/2020 KBM $495.00 0.10 0.01 $49.50 $6.19 responded to same granting extension request and 32 recalendared same. 33 10/6/2020 MN $125.00 Calendar re: 12/21 Compliance Conf 0.10 0.01 $12.50 $1.56 began formatting docs for KM - P's responses to D's document 10/7/2020 AL $125.00 1.00 0.13 $125.00 $15.63 demands and P's responses to D's interrogatories 34 Page 2 of 6 FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action A B C D E F G H ATTORNEY V&A'S CLAIMED DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES HOURS HOUR) Apportioned across Based on Revised Based on Hours and As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and As Submitted by Plaintiff Attorney Rates by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates Submitted by Plaintiff where applicable Submitted by Plaintiff Prepared for court conference; attended virtual PC 10/8/2020 KBM $495.00 conference; reviewed pc order and executed same and 1.20 0.15 $594.00 $74.25 35 returned to court. 36 10/8/2020 MN $125.00 Docket re: downloaded, named and saved PC Order 0.10 0.01 $12.50 $1.56 formatted docs - P's responses to D's document demands and 10/9/2020 AL $125.00 2.00 0.25 $250.00 $31.25 37 P's responses to D's interrogatories -for KM. 38 10/13/2020 KBM $495.00 Drafted protective order; emailed Def re: same. 1.70 0.21 $841.50 $105.19 39 10/14/2020 MN $125.00 Calendar re: 11/19 Remote Conf/Oral Argument 0.10 0.01 $12.50 $1.56 worked on responses to document demands served by 11/18/2020 KBM $495.00 defendants; communications with Plaintiff re: documents 3.30 0.41 $1,633.50 $204.19 40 requested for same. Communications with client re: discovery responses; work on 11/25/2020 KBM $495.00 2.60 0.33 $1,287.00 $160.88 41 updates to responses. Reviewed documents provided by Plaintiff to respond to discovery demands; assessed for responsiveness and 11/30/2020 KBM $495.00 6.70 0.84 $3,316.50 $414.56 redaction and confidentiality; revised interrogatory and 42 document demands. Initial review of revisions to confidentiality stip made by 12/2/2020 KBM $495.00 0.60 0.08 $297.00 $37.13 43 Defendants. 44 12/2/2020 KBM $495.00 vm from client; Tel call with client re: discovery. 0.30 0.04 $148.50 $18.56 Tel conf w/ def re: meet and confer regarding disputes in 12/4/2020 KBM $495.00 confidentiality order; correspondence about same; reviewed 1.20 0.15 $594.00 $74.25 45 further revised draft and responded to same. 12/7/2020 KBM $495.00 communications and revisions with def re: confidentiality stip. 0.60 0.08 $297.00 $37.13 46 12/8/2020 KBM $495.00 ongoing communications and revisions to confidentiality stip. 0.40 0.05 $198.00 $24.75 47 call with def re: meet and confer to resolve outstanding issue 12/9/2020 KBM $495.00 0.50 0.06 $247.50 $30.94 48 with confidentiality stip. Drafted stip to adjourn court conference; emailed same to def 12/14/2020 KBM $495.00 for review; received confirmation from def and emailed 0.50 0.06 $247.50 $30.94 49 support staff for filing of same. Telephone conference with KM re discovery status, motion to 12/15/2020 LML $495.00 quash subpoena and upcoming court conf; emails with court 0.60 0.08 $297.00 $37.13 50 re adjourning upcoming conf; reviewed docket Page 3 of 6 FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action A B C D E F G H ATTORNEY V&A'S CLAIMED DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES HOURS HOUR) Apportioned across Based on Revised Based on Hours and As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and As Submitted by Plaintiff Attorney Rates by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates Submitted by Plaintiff where applicable Submitted by Plaintiff Reviewed communication from court re: adjournment 12/15/2020 KBM $495.00 request; communications with LL re: assistance handling 0.30 0.04 $148.50 $18.56 51 same. Telephone conference and emails with Ds and court re adjourning court conf;Telephone conference and emails with 12/16/2020 LML $495.00 1.00 0.13 $495.00 $61.88 D re same; emails with KM re same; reviewed file in prep for 52 Telephone conference. Stipulation re: reviewed final version of confidentiality stip 12/26/2020 KBM $495.00 0.40 0.05 $198.00 $24.75 53 and emailed def re: permission to file same. reviewed d's email re: document exchange and responded to 1/7/2021 KBM $495.00 0.10 0.01 $49.50 $6.19 54 same. Reviewed email from Def re: exchange of document production; emailed Plaintiff's documents to defendants; 1/11/2021 KBM $495.00 downloaded documents from Defendants; reviewed 2.40 0.30 $1,188.00 $148.50 documents produced from counseling works; emailed Def re: marking of certain documents they produced as confidential. 55 Continued to review document production from white and 1/15/2021 KBM $495.00 3.10 0.39 $1,534.50 $191.81 56 case; memo to file with notes for same. 1/18/2021 KBM $495.00 Telephone conference with P re: case update and discovery. 0.80 0.10 $396.00 $49.50 57 1/19/2021 KBM $495.00 Reviewed email from def re: settlement; responded to same. 0.20 0.03 $99.00 $12.38 58 Assessed settlement strategy and calculations to prepare for 1/19/2021 KBM $495.00 2.20 0.28 $1,089.00 $136.13 59 upcoming settlement conference. 60 1/22/2021 KBM $495.00 Tel conf w/. Def re: settlement. 0.30 0.04 $148.50 $18.56 continued to review documents produced by WC and take 1/22/2021 KBM $495.00 3.70 0.46 $1,831.50 $228.94 61 notes on same. Reviewed correspondence and attached documents from Def 1/29/2021 KBM $495.00 0.40 No Change $198.00 $198.00 62 re: P's unpaid OT; responded to same. Call with Def re: settlement; communications with P re: same 2/1/2021 KBM $495.00 0.50 0.06 $247.50 $30.94 63 and memo to file. continued to review discovery and take notes in file on same; 2/4/2021 KBM $495.00 3.70 No Change $1,831.50 $1,831.50 reassessed unpaid wage damages for settlement purposes. 64 Page 4 of 6 FILED: NEW YORK COUNTY CLERK 01/19/2023 11:46 PM INDEX NO. 154446/2020 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 01/19/2023 Defendant White Case's Proposed Apportionment of Attorney's Fees Claimed by Virginia & Ambinder, LLP on Plaintiff's Eighth Cause of Action A B C D E F G H ATTORNEY V&A'S CLAIMED DATE ATTORNEY RATE (PER DESCRIPTION OF PROFESSIONAL SERVICES REVISED HOURS V&A'S CLAIMED FEES REVISED FEES HOURS HOUR) Apportioned across Based on Revised Based on Hours and As Submitted As Submitted As Submitted As Submitted by Plaintiff's eight Hours (Column F) and As Submitted by Plaintiff Attorney Rates by Plaintiff by Plaintiff by Plaintiff Plaintiff causes of action, the Attorney Rates Submitted by Plaintiff where applicable Submitted by Plaintiff Docket re: downloaded, named and saved 2021-2-4 Stip and 2/4/2021 MN $125.00 0.10 0.01 $12.50 $1.56 65 Protective Order continued to review documents produced by def and notes 2/9/2021 KBM $495.00 regarding same; worked on settlement counter and 4.10 No Change $2,029.50 $2,029.50 66 calculations of unpaid wages. Communications with P re: discovery requested by Def; 3/2/2021 KBM $495.00 finished drafting deficiency letter to Defendants and emailed 1.80 0.23 $891.00 $111.38 67 same. tel conf w/ P regarding case related matters and developments and discovery; continued to draft response to additional discovery and deficiency letter served by Def and 3/10/2021 KBM $495.00 calculate damages requested in same; reviewed additional 3.70 0.46 $1,831.50 $228.94 documents provided by Plaintiff; reviewed correspondence from Def re: outstanding discovery and upcoming deposition; 68 responded to same. 69 3/16/2021 KBM $495.00 Telephone conference with P re: update on case. 0.80 0.10 $396.00 $49.50 Reviewed correspondence from Def re: check for unpaid overtime and proposed stip to dismis OT claim; legal research 3/25/2021 KBM $495.00 for same; responded to def re: same, rejecting stip, and 0.80 No Change $396.00 $396.00 providing legal research showing payment for liquidated damages still required for late payment of wages. 70 Communications with P re: OT check and with staff re: mailing 3/31/2021 KBM $495.00