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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
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IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
GENERAL DIVISION
Gary White, et al., Case No. 20 CV 000086
Plaintiff(s), Judge Julie Lynch
V. Magistrate Jennifer Hunt
Twin Engine Enterprises, Inc., et al.,
Defendant(s).
NOTICE OF PLAINTIFFS GARY WHITE AND KATHRYN WHITE OF FILING ADMITTED EXHIBITS
Plaintiffs Gary White and Kathryn White, by and through counsel, hereby file Plaintiffs’
Exhibits 1-5, and 11, which the Court admitted into evidence at the hearing held on April 24, 2023.
Copies of the exhibits are attached hereto.
Respectfully submitted,
/s/ Gregory A. Wetzel
Michael Hrabcak (0055716)
Gregory A. Wetzel (0082631)
HRABCAK & COMPANY, L.P.A.
67 East Wilson Bridge Road, Suite 100
Worthington, OH 43085
614-781-1400 | 614-781-1171 (Fax)
mike@hrabcaklaw.com
gwetzel@hrabcaklaw.com
Attorney(s) for Plaintiff
CERTIFICATE OF SERVICE
Thereby certify that on April 28, 2023, a copy of the foregoing was served upon the following
parties via the Court’s NEF system, which will provide them notice via email, pursuant to Civ.R.
SBIAH
Philip H. Sheridan, Jr.
915 South High Street
Columbus, OH 43206-2523
phil.sheridan68@gmail.com
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086
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Attorney for Defendants Timothy and Kristen
Dewberry
Joshua J. Brown
3979 Main Street
Hilliard, OH 43026
josh@joshbrownesq.com
Attorney for Defendant Twin Engine
Enterprises, Inc.
‘s/ GregoryA. Weitzel
Gregory A. Wetzel (0082631)
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086
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Hrabcak Attorneys At Law
& Company, L.P.A. 67 East Wilson Bridge Road, Worthington, Ohio 48085
(614) 781-1400 Phone (614) 781-1171 Fax
REEMENT FOR LEGAL ERVICES
Gary White and Kathy White, (Client) hereby retains the Hrabeak & Company, L.P.A., 67 East
Wilson Bridge Road, Suite 100, Worthington, Ohio 43085 (the Firm”) and any co-counsel
required by the Firm to perform all necessary fegal and other related services to represent Client
in regard to the following matter: Dispute regarding real estate located at 6700 Lambert
Road in Orient, Ohio.
Client agrees to pay the sum of $0.00 as a retainer for expenses and work to be performed.
The Firm assumes no responsibility for representation of Client and will begin no work for
Client until this retainer is fully paid.
3
3 Asa fee, Client agrees to pay the Firm 33 and {/3% of any benefit(s) obtained up to 91 calendar
days prior to the originally-scheduled trial date, whether the result of a settlement or of
litigation. For example, if the Firm obtains for the Cent the cancelation of a $9,000 debt,
Client would owe the Firm $3,000 before the retainer provided in paragraph two is credited
toward the fee and expenses. On and after 91 calendar days prior to the originally-scheduled
trial date, Client agrees to pay the Firm 40% of any benefil(s) obtained, whether the recovery
is a result of a settlement or of litigation. Any retainer provided in paragraph two will be
credited toward the Firm’s fee first, then expenses. “Benefit(s)” consists of both monies
promised and/or received and any non-monetary resolution, such as the forgiveness or
cancelation of debt or obtaining an ebject of value (such as the return of a motor vehicle), If
there is no benefit(s) obtained, the Firm shall receive no fee aside from the retainer provided
in paragraph two. The fee will be determined before Client’s expenses are deducted
from/added to any benefit obtained. Any settlement of this matter must be made only with the
concurrence of both Client and the Firm.
4, This agreement will be through trial and any arrangements for a subsequent appeal must be
separately negotiated and agreed to in writing.
Additionally, Client agrees to pay the Firm its expenses, which the Firm may advance or incur
in this matter. The Firm's expenses include all out-of-pocket disbursements for court costs,
court reporter transcripts and attendance fees, and costs for photocopies, postage, secretarial
overtime (if necessary), and any other expenses incurred including expert witness fees, if any.
‘The Firm reserves the right to require prepayment of expenses.
Should Client elect sometime prior to the completion of representation to discharge the Firm
or if the Firm’s representation concludes without the Firm's consent, Client agrees to pay the
Firm a percentage of any offers the Firm received to settle this matter up to that time at the rate
set forth in paragraph three above; if the Firm has received no offers, Clint agrees to pay the
Firm its hourly rate of $325 per hour for all time expended in this matter, plus expenses, to be
paid from any amount(s) recovered or settlement.
Exhibit 1
Dac ID: 143dde04ad26
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
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>?
Should the Firm decide at any time, in its sole discretion, that representation is not
economically viable, or that Client's case lacks a sufficient factual or legal basis to successfully
continue representation, the Firm reserves the right to withdraw from represe! ation. Should
the Firm withdraw for any reason, Client agrees to pay the Firm a percentage of any offers the
Firm received to settle this matterup te that time at the rate set forth in paragraph three above;
ifthe Firm has received no offers, Client agrees lo pay the Firm its hourly rate of $325 per hour
for all time expended in this matter, plus expenses, to be paid from any amount(s) recovered
or settlement.
Should ar court or decision-maker award attorney fees as a part of its judgment or award,
such fees will not be added to the amount{s) recovered prior to the determir tion of the Firm’s
fee under paragraph three (that is, attorney fees will not be split with CHent), but will be
credited toward the Firm's fee after the fee is determined.
Should any settlement occur or the Firm recover any amount(s), the Firm is required by the
Rules of Professional Conduct to deposit such amount(s) into its trast account and make
disbursements from that account for fees, expenses, and Client's portion of the recovery.
Client agrees to sign any checks received so the Firm may deposit and disburse the proceeds
accordingly.
10. A late fee of one and a half percent (1.5%) per month may be assessed on any balance that
remains unpaid after 30 days. A late fee of $1.50 may be sed on any balance less than
$100.00 that remains unpaid after thirty G0) days.
il Client agrees the Firm has made no prom eS or guarantees concerning the matter’s outcome,
nor can it, including the likelihood of success or the benefit obtained, if any.
12 The Firm’s policy is to keep a digital copy of Client’s file. Afl hardcopies of any mate: is
Client provided toe the Firm will be shredded one year after the termination of this matter, with
Client having the nght to retrieve said hardcopies at any time before then.
Ifyou are agreeable to the terms of this representation, please sign where indicated below and
return this agreement.
ny te KBoage Whit.
GaryV ate Kathy White
Michael Hrabeak, President
Hrabeak & Company, L.P_A.
Page 2 of 2
Doc ID: 143dde04dad26e7aaa97chaS76589ct4
86d9ea8d
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
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Date 1/30/2023
PRE-BILL Time: 9:44AM
lof 19
Page:
Hrabcak & Company, L.P.A.
Gary White
6700 Lambert Road
Orient, OH 43146
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
Matter Tyy REA Real Estate Originating Timekeeper: MH
File Open Da 7/25/2019 Responsible Timekeeper: MH
Billing Mo Contingency Bill Date: 1/30/2023 Billing Format Code c
Contingency Perce! 0.33% Start Date: 1/1/1900 Fees/Costs Cut Date: 1/30/2023
Billing Frequen End of Matter Last Bill: 10/30/2019 Payments Cut Date 1/30/2023
Remarks: Type of Bill Regular
Comments:
ACCOUNT Current 30-59 Days 60 - 89 Days 0 D: Vi r
AGING $ 0.00 $ 0.00 $ 0.00 $ 0.00
Fees Billed to Date: $1,966.25 Costs Billed to Date: $0.00
Fees
Ticket
Number Date Timekeeper Description Hours
36 10/5/2019 MH Receipt and review of email from client regarding 0.10 $32.50 BL
draft response to same; note to file.
37 10/9/2019 MH Emails to and from client regarding in 0.25 $81.25 BL
note to file.
38 10/14/2019 MH Meet with attorney G. Wetzel 0.25 $81.25 BL
39 10/23/2019 GW Reviewed Gay's emai) 0.10 $0.00 NC
41 1/2/2020 BN Review file; research legal claims; phone call to attorney 3.80 $1,235.00 BL
G. Wetzel to discuss same; begin draft of complaint
52 1/2/2020 GW In-house discussion with B. Nelson and M. Hrabcak re 0.40 $0.00 NC
42 1/3/2020 BN Revise and finalize draft of complaint; draft email to office 0.60 $195.00 BL
53 1/3/2020 GW Revise complaint. 0.90 $292.50 BL
54 1/3/2020 GW Emailed ae to Gary for review. 0.10 $32.50 BL
35 1/6/2020 GW Revised complaint. 0.30 $97.50 BL
56 1/9/2020 GW Enilcd ie 0.10 $0.00 NC
to Gary.
40 1/16/2020 GW Attention to file, check service status. 0.20 $65.00 BL
43 1/21/2020 GW Research on Dewberrys' whereabouts for service. 0.70 $227.50 BL
Continued On Next Page
Exhibit 2
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086
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Date: 1/30/2023
PRE-BILL Time: 9:44AM
2 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
44 1/21/2020 PAR Per instructions from attorney Wetzel, perform additional 0.50 $75.00 BL
due diligence on service address(es) for Dewberry
defendants in pending litigation - run and review Lexis
reports, check various property and court databases - draft
brief email to attorney Wetzel
45 1/22/2020 GW Reviewed in-house emails ae Responded, 0.20 $0.00 NC
46 1/30/2020 GW Read and respond to Gary's email. 0.20 $65.00 BL
47 1/30/2020 GW Review and respond to Gary's email 0.20 $65.00 BL
48 2/3/2020 GW Check service. Twin Engine served. Kristen Dewberry 0.20 $65.00 BL
served.
49 2/5/2020 GW Attention to file: review service status, email Gary. 0.20 $65.00 BL
50 2/6/2020 GW Phone call to Phil Sheridan re extension of time to answer. 0.20 $65.00 BL
Agreed. Phil will email us to confirm.
Emailed Gary .
62 2/6/2020 Phone call from attorney for Dewberry 0.10 $0.00 NC
51 2/7/2020 GW Discuss with M. Hrabeak. 0.30 $97.50 BL
Review and respond to Gary's email a.
57 2/19/2020 GW Review items Sheridan filed and served on behalf of the 0.20 $65.00 BL
Dewberrys.
38 2/19/2020 GW Attention to file: check status of service on Tim Dewberry. 0.30 $97.50 BL
Draft waiver of service for Sheridan to execute.
39 2/25/2020 GW Review Gary's discovery responses and provide responses. 0.80 $260.00 BL
Highlight complaint based upon Dewberrys' responses in
Answer.
60 2/28/2020 GW Review Twin Engine's answer and counterclaim. Email 0.50 $162.50 BL
Gary.
61 3/2/2020 GW Format Gary's discovery responses. 0.30 $97.50 BL
63 3/24/2020 GW Review Twin Engine's answer and counterclaim to prepare a 1.20 $390.00 BL
reply. Phone call to Gary|
64 3/27/2020 GW Review and revise clients' discovery responses. 1.20 $390.00 BL
65 4/2/2020 GW Review Gary's discovery responses and format to provide to 0.70 $227.50 BL
opposing counsel
66 4/2/2020 GW Revised discovery responses and formatted documents for 0.40 $130.00 BL
disclosure to opposing counsel. Drafted verification pages
for clients.
68 4/6/2020 MH Meet with icra 0.30 $97.50 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086
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Date: 1/30/2023
PRE-BILL Time: 9:44AM
3 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
67 4/7/2020 GW Review and respond to Phil Sheridan's email on PODs. 0.80 $260.00 BL
Legal Research on Twin Engine's motion to dismiss.
69 4/15/2020 GW Review motion to dismiss, begin researching memo contra. 1.70 $552.50 BL
72 4/15/2020 Meet with attorney G. Wetzel - discuss a begin review 0.25 $81.25 BL
of pleadings
73 4/16/2020 Continue review of pleadings and case law 0.50 $0.00 NC
70 4/17/2020 GW Additional Legal Research re Twin Engine's motion to 2.70 $877.50 BL
dismiss. Continued drafting memo contra. In-house
discussion with M. Hrabcak.
74 4/17/2020 Pull and review existing case law and make notes to same 1.00 $0.00 NC
75 4/17/2020 Meet with attorney G. Wetzel on motion to dismiss, analysis 0.25 $0.00 NC
and case law
71 4/20/2020 GW Finalize memo contra MTD. Send copies to attorneys and 0.80 $260.00 BL
to client.
76 4/20/2020 Review draft response - Memorandum Contra Motion for 0.50 $0.00 NC
Summary Judgment; edit and discuss same with attorney G.
Wetzel; note to file
78 5/6/2020 GW Phone call to from Josh Brown, ee 0.40 $130.00 BL
Email to Brown with discovery responses, offered to re-send
link with docs.
81 3/21/2020 GW Begin with discovery to Defs. 0.20 $65.00 BL
82 5/22/2020 GW Continue with discovery to Dewberrys. 0.20 $65.00 BL
83 5/22/2020 GW Continue with discovery to Dewberrys. 1.10 $357.50 BL
80 5/26/2020 Review draft of Request for Admissions, Request for 0.35 $0.00 NC
Production of Documents and Interrogatories and discuss
with attorney G. Wetzel; note to file
84 5/26/2020 GW Finalize discovery to Dewbertys. (1.8) 2.40 $780.00 BL
Draft and file initial disclosure of witnesses. (0.6)
79 5/28/2020 PAR Prepare subpoenas to Margot Laumann and Julie Hoffman, 0.40 $60.00 BL
for review, revision and signature by attorney Wetzel.
85 5/28/2020 GW Review subpoenas to RE agents. 0.20 $65.00 BL
86 5/28/2020 GW Review revised subpoenas. 0.10 $32.50 BL
87 6/4/2020 GW Begin drafting discovery to Twin Engine. 2.00 $650.00 BL
88 6/4/2020 GW Revise discovery requests to Twin Engine. Send to counsel. 0.20 $65.00 BL
89 6/10/2020 GW Review subpoena to Margot Laumann. Returned her phone 0.10 $0.00 NC
call, LM @ 10:11 a.m.
90 6/10/2020 GW Sent Gary as 0.10 $32.50 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086
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Date: 1/30/2023
PRE-BILL Time: 9:44AM
4 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
91 6/10/2020 GW Margot Laumann called, discussed the subpoena we sent to 0.10 $32.50 BL
her requesting docs.
92 6/10/2020 GW Phone conference with Mark Meterko - general objections 0.10 $32.50 BL
coming on subpoena to Julie Hoffman along with docs.
Should have by close of business tomorrow.
93 6/11/2020 GW Review subpoena response from Julie Hoffman. Brief 1.00 $325.00 BL
research of Twin Engine's online presence.
94 6/16/2020 GW Download and review documents from Margot Laumann. 0.30 $97.50 BL
95 6/26/2020 GW Email to Sheridan re discovery responses. 0.10 $32.50 BL
96 7/6/2020 GW Review status of discovery requests to TE; emailed OC. 0.20 $65.00 BL
97 7/15/2020 GW Draft email to opposing counsel regarding TE's discovery 0.30 $97.50 BL
responses - extended.
101 7/16/2020 Meet with attorney G. Wetzel Ee 0.20 $0.00 NC
98 7/17/2020 GW Phone call to Josh Brown, LM @ 2:58 p.m. 0.10 $0.00 NC
99 7/20/2020 GW Draft and file motion to amend case schedule. 0.60 $195.00 BL
100 7/20/2020 GW Emails on motion to amend case schedule; Phone call to 0.20 $65.00 BL
Phil Sheridan re motion, LM @ 11:28 a.m.
102 7/23/2020 GW Email to Sheridan re mot to amend case sch. 0.10 $32.50 BL
103 7/28/2020 GW Emailed Court letting it know no opposition to motion to 0.20 $65.00 BL
amend case schedule.
104 8/12/2020 GW Review status of Twin Engine's discovery responses - 0.20 $65.00 BL
calendared per tolling order.
107 8/17/2020 GW Discuss a with M. Hrabcak. 0.20 $65.00 BL
105 8/24/2020 GW Review discovery sent to TE for possible motion against it. 0.20 $65.00 BL
106 8/30/2020 GW Email to Brown re disco. resps. 0.20 $65.00 BL
108 9/1/2020 GW Draft motion to compel re Twin Engine. 0.90 $292.50 BL
109 9/3/2020 GW Revise and finalize motion to compel. File with the Court. 0.30 $97.50 BL
113 9/23/2020 GW Review court's decision on motion to compel, send to Gary. 0.20 $65.00 BL
110 10/9/2020 GW Email to Brown re TE's discovery responses. 0.10 $32.50 BL
lll 10/13/2020 GW Draft motion for sanctions. 0.70 $227.50 BL
112 10/13/2020 GW Revise motion for sanctions; file. 0.20 $65.00 BL
114 10/14/2020 GW Review and respond to Gary's email. 0.20 $65.00 BL
122 11/13/2020 GW In-house discussion with M. Hrabcak [EE 0.10 $32.50 BL
115 11/18/2020 GW Legal Research on delegable duties. 0.20 $65.00 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
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Date: 1/30/2023
PRE-BILL Time: 9:44AM
Sof 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
116 11/18/2020 GW Review time entries related to motion to compel and for 0.10 $32.50 BL
sanctions, per Court's order.
17 11/18/2020 GW Draft aff. re attorney fees. 0.30 $97.50 BL
123 11/18/2020 GW Emails 0.10 $32.50 BL
118 11/20/2020 GW Finalize affidavit on fees; draft notice of filing. File. Email 0.30 $97.50 BL
119 11/23/2020 GW Phone call to Gary re [i 0.50 $162.50 BL
Phone call to Phil Sheridan.
120 11/23/2020 GW Review damages. Emails to counsel regarding damages 0.40 $130.00 BL
hearing date.
121 12/1/2020 GW Review invoices, client email; revise spreadsheet for 0.40 $130.00 BL
damage calculation.
130 12/15/2020 GW Discuss EE with M. Hrabeak. 0.30 $97.50 BL
124 12/29/2020 GW Phone call to Phil Sheridan. Draft Motion to Am. Case 0.70 $227.50 BL
Schedule, file.
125 1/8/2021 GW Phone call to Gary. LM @ 2:50 p.m. 0.10 $0.00 NC
126 1/8/2021 GW Phone call; returned Gary's call] [iy 0.30 $97.50 BL
127 1/8/2021 GW Draft settlement demand to Dewberrys; email to their 0.60 $195.00 BL
counsel.
128 1/14/2021 GW Review documents for next week's hearing. 0.20 $65.00 BL
142 1/14/2021 GW Phone call to expert re attorney fees. 0.30 $97.50 BL
129 1/15/2021 GW Phone call to Gary. Email court re hearing. 0.20 $65.00 BL
131 1/15/2021 GW Prepare and send documents to expert to review for hearing. 0.20 $65.00 BL
132 1/19/2021 GW Phone call to Phil Sheridan. 0.20 $65.00 BL
133 1/27/2021 GW Review calendar; Phone call to Gary re | email OC re 0.30 $97.50 BL
dates and clients participating by Zoom.
134 1/27/2021 GW Phone call to Phil Sheridan. LM. Returned Phil's call. 0.80 $260.00 BL
Phone call to Gary White.
Phone call to Josh Brown.
Phone call to Steve Moyer.
Email to Josh Brown.
144 1/27/2021 Attention to file - discussion with attorney G. Wetzel 0.20 $65.00 BL
regarding
143 1/29/2021 GW Emails re new date for damages hearing. 0.30 $97.50 BL
135 2/3/2021 GW Review Brown's filings and emails. 0.20 $65.00 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
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Date: 1/30/2023
PRE-BILL Time: 9:44AM
6 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
150 2/3/2021 Review motion, crossclaims, photos and filings by attorney 0.50 $162.50 BL
for Twin Engines; meet with attorney G. Wetzel EE
153 2/3/2021 GW Discuss EEE with M. Hrabcak. 0.20 $65.00 BL
136 2/4/2021 GW Phone call to Phil Sheridan. LM @ 12:18 p.m. 0.10 $0.00 NC
137 2/4/2021 GW Phone call from Phil Sheridan. 0.20 $65.00 BL
138 2/4/2021 GW Draft memo contra motion for reconsideration. Legal 1.30 $422.50 BL
Research on 60(B) v. motion to reconsider.
139 2/10/2021 GW Sent docs to client. 2.00 $650.00 BL
Continued on memo contra TE's motion for reconsideration.
Revise.
Phone call to Gary. LM @ 12:53 p.m.
140 2/10/2021 GW Phone call from Gary. Discussed iy 0.30 $97.50 BL
141 2/10/2021 GW Finalized and filed memo contra. Sent courtesy copy to 0.20 $65.00 BL
Magistrate.
145 2/12/2021 GW Review TE's reply on motion for reconsideration. Emailed 0.30 $97.50 BL
Gary
147 3/1/2021 GW Phone call from Phil Sheridan. 0.20 $65.00 BL
148 3/1/2021 GW Review discovery requests from TE. 0.20 $65.00 BL
149 3/1/2021 GW Phone call to Gary. LM @ 7:49 p.m. 0.10 $0.00 NC
160 3/1/2021 GW Discuss court's ruling and discovery issues with M. 0.20 $65.00 BL
Hrabcak.
151 3/9/2021 GW Review and respond to Gary's email. 0.10 $32.50 BL
152 3/10/2021 GW Review Gary's discovery responses and prepare for phone 1.60 $520.00 BL
conference. Gary and Kathy called.
154 3/19/2021 GW Amend answers to discovery responses. 1.20 $390.00 BL
155 3/23/2021 GW Finalize discovery responses. 0.70 $227.50 BL
Phone call to Gary. Emailed in iii
156 3/24/2021 GW Review Gary's email and interrogatory response: Phone call 0.20 $65.00 BL
to Gary
157 4/16/2021 GW Phone call to Josh Brown. He prefers an in person depo. 0.30 $97.50 BL
Will F/U next week.
158 4/20/2021 GW Draft motion to amend case schedule. Email OC. 0.20 $65.00 BL
159 4/21/2021 GW Revise joint motion to file with the Court. 0.10 $32.50 BL
161 5/14/2021 GW Phone call from Gary i 0.20 $65.00 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
0G369 - w41
Date: 1/30/2023
PRE-BILL Time: 9:44AM
7 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
162 3/24/2021 GW Get video conference link for clients. 0.20 $65.00 BL
163 3/25/2021 GW Prep for video conference. Video conference with Gary and 1.00 $325.00 BL
Kathy.
164 3/25/2021 GW Email to clients regarding iy 0.20 $65.00 BL
165 6/3/2021 GW Review and respond to Gary's question 0.50 $162.50 BL
166 6/4/2021 GW Review and respond to Gary's email. 0.30 $97.50 BL
Phone call to Gary. LM @ 10:48 a.m.
183 6/7/2021 GW Travel to and from Brown's office: depos. of Gray and 2.60 $845.00 BL
Kathy.
167 6/9/2021 GW Draft areas of knowledge for TE corp. designee. 0.60 $195.00 BL
168 6/10/2021 GW Revise areas of knowledge for TE designee. 0.20 $65.00 BL
169 6/16/2021 GW Phone call to Phil Sheridan. Busy @ 4:54 p.m. 0.10 $0.00 NC
170 6/21/2021 GW Phone call to Sheridan. Discussed deposition dates and the 0.20 $65.00 BL
case.
71 6/22/2021 GW Email to OC re deposition dates. 0.20 $65.00 BL
172 6/24/2021 GB Draft Second Motion to Amend Case Schedule 0.20 $22.00 BL
173 6/24/2021 GW Ennil to Gary ay 0.10 $32.50 BL
174 7/8/2021 GW Review emails re deposition date and times. 0.60 $195.00 BL
Email OC.
Email clients.
175 7/9/2021 GW Review and respond to Gary's emails. 0.20 $65.00 BL
176 7/9/2021 GB Draft Notice of Deposition for Twin Engine, Tim Dewberry, 0.60 $66.00 BL
and Kristen Dewberry as well as book court reporter for
same
177 7/9/2021 GW Review notices for depositions. 0.20 $65.00 BL
178 7/13/2021 GW Draft witness outline for TE's designee. 5.80 $1,885.00 BL
179 7/14/2021 GW Continue on witness outline for Tim Dewberry. 1.00 $325.00 BL
180 7/14/2021 GB Research regardin_iii 0.50 $55.00 BL
181 7/14/2021 GW Continue preparing for depositions. 0.90 $292.50 BL
206 7/14/2021 GW Depositions of Nathan Hoy, Tim Dewberry; and Kristen 4.90 $1,592.50 BL
Dewberry.
182 7/15/2021 GW Review and respond to Gary's email. 0.20 $65.00 BL
184 7/19/2021 GW Phone call from Nate Stitzlein. 0.20 $65.00 BL
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
0G369 - w4
Date: 1/30/2023
PRE-BILL Time: 9:44AM
8 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
185 7/19/2021 GB Pull pulled of photos and link that client sent to us to save in 0.10 $11.00 BL
the file
186 7/20/2021 GW Begin drafting letter to OC re heat pump and possible 1.10 $357.50 BL
settlement.
187 7/21/2021 GB Call to AEP to attempt to obtain service tickets/records for 0.40 $44.00 BL
6700 Lambert Road in 2019; Complete Public Records
Request and call to Franklin County Economic
Development & Planning Department to find out where to
send the Public Records Request; Email Public Records
Request to Franklin County Economic Development &
Planning Department
188 7/21/2021 GW Review and respond to Gary's email. 0.20 $65.00 BL
Intra-office email
189 7/22/2021 GB Draft Subpoena to AEP 0.30 $33.00 BL
190 7/23/2021 GW Review and revise subpoena to AEP. 0.20 $65.00 BL
191 7/26/2021 GB Prepare Notice of Subpoena to AEP for filing and mailing 0.30 $33.00 BL
to AEP; a to client.
192 7/26/2021 GB Call to Five Star Heating and Cooling to obtain screen shot 0.10 $0.00 NC
for dispatch notes from June 17, 2020 - left voicemail
193 7/27/2021 GW Phone call to Efficient Electric. Spoke with Troy. 0.30 $97.50 BL
194 7/27/2021 GW Continue with letter to OC. 0.50 $162.50 BL
195 7/28/2021 GW Phone call to Gary; LM @ 6:11 p.m. 0.10 $0.00 NC
196 7/28/2021 GW Continue with letter to OC. 0.60 $195.00 BL
197 7/29/2021 GW Phone call from Gary 0.30 $97.50 BL
198 7/30/2021 GW Review and respond to Gary's email. 0.10 $0.00 NC
199 8/3/2021 GW Review and respond to Gary's email [iy 0.40 $130.00 BL
200 8/4/2021 GW Review subpoena response from AEP. 0.40 $130.00 BL
201 8/4/2021 GW Finalize offer of compromise to Defs. 0.50 $162.50 BL
202 8/6/2021 GB Prepare Return of Service for AEP Subpoena; File same 0.10 $11.00 BL
with Court
203 8/10/2021 GW Phone call from Phil Sheridan re offer to Dewberrys. 0.50 $162.50 BL
204 8/11/2021 GW Review and respond to Gary's email. 0.30 $97.50 BL
Email Isaac Burt @ Efficient Electric.
205 8/11/2021 GW Email to client, then opposing counsel regarding [i 0.10 $32.50 BL
207 9/10/2021 GB Phone call and email to Isaac Burt to schedule a phone 0.10 $11.00 BL
conference - left message with receptionist
Continued On Next Page
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086
0G369 - w4
Date: 1/30/2023
PRE-BILL Time: 9:44AM
9 of 19
Page:
Hrabcak & Company, L.P.A.
Client: 07-542 Gary White
Matter: 3266 White, Gary - Real Estate Matter
208 9/10/2021 GB Draft Motion for Summary Judgment 0.30 $33.00 BL
209 9/10/2021 GB Calculate costs for deposition transcripts; Email Attorney 0.20 $22.00 BL
Greg Wetzel regarding same
210 9/13/
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - W31 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO GENERAL DIVISION Gary White, et al., Case No. 20 CV 000086 Plaintiff(s), Judge Julie Lynch V. Magistrate Jennifer Hunt Twin Engine Enterprises, Inc., et al., Defendant(s). NOTICE OF PLAINTIFFS GARY WHITE AND KATHRYN WHITE OF FILING ADMITTED EXHIBITS Plaintiffs Gary White and Kathryn White, by and through counsel, hereby file Plaintiffs’ Exhibits 1-5, and 11, which the Court admitted into evidence at the hearing held on April 24, 2023. Copies of the exhibits are attached hereto. Respectfully submitted, /s/ Gregory A. Wetzel Michael Hrabcak (0055716) Gregory A. Wetzel (0082631) HRABCAK & COMPANY, L.P.A. 67 East Wilson Bridge Road, Suite 100 Worthington, OH 43085 614-781-1400 | 614-781-1171 (Fax) mike@hrabcaklaw.com gwetzel@hrabcaklaw.com Attorney(s) for Plaintiff CERTIFICATE OF SERVICE Thereby certify that on April 28, 2023, a copy of the foregoing was served upon the following parties via the Court’s NEF system, which will provide them notice via email, pursuant to Civ.R. SBIAH Philip H. Sheridan, Jr. 915 South High Street Columbus, OH 43206-2523 phil.sheridan68@gmail.com Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086 0G369 - W3 Attorney for Defendants Timothy and Kristen Dewberry Joshua J. Brown 3979 Main Street Hilliard, OH 43026 josh@joshbrownesq.com Attorney for Defendant Twin Engine Enterprises, Inc. ‘s/ GregoryA. Weitzel Gregory A. Wetzel (0082631) Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086 0G369 - W3 Hrabcak Attorneys At Law & Company, L.P.A. 67 East Wilson Bridge Road, Worthington, Ohio 48085 (614) 781-1400 Phone (614) 781-1171 Fax REEMENT FOR LEGAL ERVICES Gary White and Kathy White, (Client) hereby retains the Hrabeak & Company, L.P.A., 67 East Wilson Bridge Road, Suite 100, Worthington, Ohio 43085 (the Firm”) and any co-counsel required by the Firm to perform all necessary fegal and other related services to represent Client in regard to the following matter: Dispute regarding real estate located at 6700 Lambert Road in Orient, Ohio. Client agrees to pay the sum of $0.00 as a retainer for expenses and work to be performed. The Firm assumes no responsibility for representation of Client and will begin no work for Client until this retainer is fully paid. 3 3 Asa fee, Client agrees to pay the Firm 33 and {/3% of any benefit(s) obtained up to 91 calendar days prior to the originally-scheduled trial date, whether the result of a settlement or of litigation. For example, if the Firm obtains for the Cent the cancelation of a $9,000 debt, Client would owe the Firm $3,000 before the retainer provided in paragraph two is credited toward the fee and expenses. On and after 91 calendar days prior to the originally-scheduled trial date, Client agrees to pay the Firm 40% of any benefil(s) obtained, whether the recovery is a result of a settlement or of litigation. Any retainer provided in paragraph two will be credited toward the Firm’s fee first, then expenses. “Benefit(s)” consists of both monies promised and/or received and any non-monetary resolution, such as the forgiveness or cancelation of debt or obtaining an ebject of value (such as the return of a motor vehicle), If there is no benefit(s) obtained, the Firm shall receive no fee aside from the retainer provided in paragraph two. The fee will be determined before Client’s expenses are deducted from/added to any benefit obtained. Any settlement of this matter must be made only with the concurrence of both Client and the Firm. 4, This agreement will be through trial and any arrangements for a subsequent appeal must be separately negotiated and agreed to in writing. Additionally, Client agrees to pay the Firm its expenses, which the Firm may advance or incur in this matter. The Firm's expenses include all out-of-pocket disbursements for court costs, court reporter transcripts and attendance fees, and costs for photocopies, postage, secretarial overtime (if necessary), and any other expenses incurred including expert witness fees, if any. ‘The Firm reserves the right to require prepayment of expenses. Should Client elect sometime prior to the completion of representation to discharge the Firm or if the Firm’s representation concludes without the Firm's consent, Client agrees to pay the Firm a percentage of any offers the Firm received to settle this matter up to that time at the rate set forth in paragraph three above; if the Firm has received no offers, Clint agrees to pay the Firm its hourly rate of $325 per hour for all time expended in this matter, plus expenses, to be paid from any amount(s) recovered or settlement. Exhibit 1 Dac ID: 143dde04ad26 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w34 >? Should the Firm decide at any time, in its sole discretion, that representation is not economically viable, or that Client's case lacks a sufficient factual or legal basis to successfully continue representation, the Firm reserves the right to withdraw from represe! ation. Should the Firm withdraw for any reason, Client agrees to pay the Firm a percentage of any offers the Firm received to settle this matterup te that time at the rate set forth in paragraph three above; ifthe Firm has received no offers, Client agrees lo pay the Firm its hourly rate of $325 per hour for all time expended in this matter, plus expenses, to be paid from any amount(s) recovered or settlement. Should ar court or decision-maker award attorney fees as a part of its judgment or award, such fees will not be added to the amount{s) recovered prior to the determir tion of the Firm’s fee under paragraph three (that is, attorney fees will not be split with CHent), but will be credited toward the Firm's fee after the fee is determined. Should any settlement occur or the Firm recover any amount(s), the Firm is required by the Rules of Professional Conduct to deposit such amount(s) into its trast account and make disbursements from that account for fees, expenses, and Client's portion of the recovery. Client agrees to sign any checks received so the Firm may deposit and disburse the proceeds accordingly. 10. A late fee of one and a half percent (1.5%) per month may be assessed on any balance that remains unpaid after 30 days. A late fee of $1.50 may be sed on any balance less than $100.00 that remains unpaid after thirty G0) days. il Client agrees the Firm has made no prom eS or guarantees concerning the matter’s outcome, nor can it, including the likelihood of success or the benefit obtained, if any. 12 The Firm’s policy is to keep a digital copy of Client’s file. Afl hardcopies of any mate: is Client provided toe the Firm will be shredded one year after the termination of this matter, with Client having the nght to retrieve said hardcopies at any time before then. Ifyou are agreeable to the terms of this representation, please sign where indicated below and return this agreement. ny te KBoage Whit. GaryV ate Kathy White Michael Hrabeak, President Hrabeak & Company, L.P_A. Page 2 of 2 Doc ID: 143dde04dad26e7aaa97chaS76589ct4 86d9ea8d Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w3 Date 1/30/2023 PRE-BILL Time: 9:44AM lof 19 Page: Hrabcak & Company, L.P.A. Gary White 6700 Lambert Road Orient, OH 43146 Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter Matter Tyy REA Real Estate Originating Timekeeper: MH File Open Da 7/25/2019 Responsible Timekeeper: MH Billing Mo Contingency Bill Date: 1/30/2023 Billing Format Code c Contingency Perce! 0.33% Start Date: 1/1/1900 Fees/Costs Cut Date: 1/30/2023 Billing Frequen End of Matter Last Bill: 10/30/2019 Payments Cut Date 1/30/2023 Remarks: Type of Bill Regular Comments: ACCOUNT Current 30-59 Days 60 - 89 Days 0 D: Vi r AGING $ 0.00 $ 0.00 $ 0.00 $ 0.00 Fees Billed to Date: $1,966.25 Costs Billed to Date: $0.00 Fees Ticket Number Date Timekeeper Description Hours 36 10/5/2019 MH Receipt and review of email from client regarding 0.10 $32.50 BL draft response to same; note to file. 37 10/9/2019 MH Emails to and from client regarding in 0.25 $81.25 BL note to file. 38 10/14/2019 MH Meet with attorney G. Wetzel 0.25 $81.25 BL 39 10/23/2019 GW Reviewed Gay's emai) 0.10 $0.00 NC 41 1/2/2020 BN Review file; research legal claims; phone call to attorney 3.80 $1,235.00 BL G. Wetzel to discuss same; begin draft of complaint 52 1/2/2020 GW In-house discussion with B. Nelson and M. Hrabcak re 0.40 $0.00 NC 42 1/3/2020 BN Revise and finalize draft of complaint; draft email to office 0.60 $195.00 BL 53 1/3/2020 GW Revise complaint. 0.90 $292.50 BL 54 1/3/2020 GW Emailed ae to Gary for review. 0.10 $32.50 BL 35 1/6/2020 GW Revised complaint. 0.30 $97.50 BL 56 1/9/2020 GW Enilcd ie 0.10 $0.00 NC to Gary. 40 1/16/2020 GW Attention to file, check service status. 0.20 $65.00 BL 43 1/21/2020 GW Research on Dewberrys' whereabouts for service. 0.70 $227.50 BL Continued On Next Page Exhibit 2 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086 0G369 - w3 Date: 1/30/2023 PRE-BILL Time: 9:44AM 2 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 44 1/21/2020 PAR Per instructions from attorney Wetzel, perform additional 0.50 $75.00 BL due diligence on service address(es) for Dewberry defendants in pending litigation - run and review Lexis reports, check various property and court databases - draft brief email to attorney Wetzel 45 1/22/2020 GW Reviewed in-house emails ae Responded, 0.20 $0.00 NC 46 1/30/2020 GW Read and respond to Gary's email. 0.20 $65.00 BL 47 1/30/2020 GW Review and respond to Gary's email 0.20 $65.00 BL 48 2/3/2020 GW Check service. Twin Engine served. Kristen Dewberry 0.20 $65.00 BL served. 49 2/5/2020 GW Attention to file: review service status, email Gary. 0.20 $65.00 BL 50 2/6/2020 GW Phone call to Phil Sheridan re extension of time to answer. 0.20 $65.00 BL Agreed. Phil will email us to confirm. Emailed Gary . 62 2/6/2020 Phone call from attorney for Dewberry 0.10 $0.00 NC 51 2/7/2020 GW Discuss with M. Hrabeak. 0.30 $97.50 BL Review and respond to Gary's email a. 57 2/19/2020 GW Review items Sheridan filed and served on behalf of the 0.20 $65.00 BL Dewberrys. 38 2/19/2020 GW Attention to file: check status of service on Tim Dewberry. 0.30 $97.50 BL Draft waiver of service for Sheridan to execute. 39 2/25/2020 GW Review Gary's discovery responses and provide responses. 0.80 $260.00 BL Highlight complaint based upon Dewberrys' responses in Answer. 60 2/28/2020 GW Review Twin Engine's answer and counterclaim. Email 0.50 $162.50 BL Gary. 61 3/2/2020 GW Format Gary's discovery responses. 0.30 $97.50 BL 63 3/24/2020 GW Review Twin Engine's answer and counterclaim to prepare a 1.20 $390.00 BL reply. Phone call to Gary| 64 3/27/2020 GW Review and revise clients' discovery responses. 1.20 $390.00 BL 65 4/2/2020 GW Review Gary's discovery responses and format to provide to 0.70 $227.50 BL opposing counsel 66 4/2/2020 GW Revised discovery responses and formatted documents for 0.40 $130.00 BL disclosure to opposing counsel. Drafted verification pages for clients. 68 4/6/2020 MH Meet with icra 0.30 $97.50 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086 0G369 - W37 Date: 1/30/2023 PRE-BILL Time: 9:44AM 3 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 67 4/7/2020 GW Review and respond to Phil Sheridan's email on PODs. 0.80 $260.00 BL Legal Research on Twin Engine's motion to dismiss. 69 4/15/2020 GW Review motion to dismiss, begin researching memo contra. 1.70 $552.50 BL 72 4/15/2020 Meet with attorney G. Wetzel - discuss a begin review 0.25 $81.25 BL of pleadings 73 4/16/2020 Continue review of pleadings and case law 0.50 $0.00 NC 70 4/17/2020 GW Additional Legal Research re Twin Engine's motion to 2.70 $877.50 BL dismiss. Continued drafting memo contra. In-house discussion with M. Hrabcak. 74 4/17/2020 Pull and review existing case law and make notes to same 1.00 $0.00 NC 75 4/17/2020 Meet with attorney G. Wetzel on motion to dismiss, analysis 0.25 $0.00 NC and case law 71 4/20/2020 GW Finalize memo contra MTD. Send copies to attorneys and 0.80 $260.00 BL to client. 76 4/20/2020 Review draft response - Memorandum Contra Motion for 0.50 $0.00 NC Summary Judgment; edit and discuss same with attorney G. Wetzel; note to file 78 5/6/2020 GW Phone call to from Josh Brown, ee 0.40 $130.00 BL Email to Brown with discovery responses, offered to re-send link with docs. 81 3/21/2020 GW Begin with discovery to Defs. 0.20 $65.00 BL 82 5/22/2020 GW Continue with discovery to Dewberrys. 0.20 $65.00 BL 83 5/22/2020 GW Continue with discovery to Dewberrys. 1.10 $357.50 BL 80 5/26/2020 Review draft of Request for Admissions, Request for 0.35 $0.00 NC Production of Documents and Interrogatories and discuss with attorney G. Wetzel; note to file 84 5/26/2020 GW Finalize discovery to Dewbertys. (1.8) 2.40 $780.00 BL Draft and file initial disclosure of witnesses. (0.6) 79 5/28/2020 PAR Prepare subpoenas to Margot Laumann and Julie Hoffman, 0.40 $60.00 BL for review, revision and signature by attorney Wetzel. 85 5/28/2020 GW Review subpoenas to RE agents. 0.20 $65.00 BL 86 5/28/2020 GW Review revised subpoenas. 0.10 $32.50 BL 87 6/4/2020 GW Begin drafting discovery to Twin Engine. 2.00 $650.00 BL 88 6/4/2020 GW Revise discovery requests to Twin Engine. Send to counsel. 0.20 $65.00 BL 89 6/10/2020 GW Review subpoena to Margot Laumann. Returned her phone 0.10 $0.00 NC call, LM @ 10:11 a.m. 90 6/10/2020 GW Sent Gary as 0.10 $32.50 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20C 000086 0G369 - W38 Date: 1/30/2023 PRE-BILL Time: 9:44AM 4 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 91 6/10/2020 GW Margot Laumann called, discussed the subpoena we sent to 0.10 $32.50 BL her requesting docs. 92 6/10/2020 GW Phone conference with Mark Meterko - general objections 0.10 $32.50 BL coming on subpoena to Julie Hoffman along with docs. Should have by close of business tomorrow. 93 6/11/2020 GW Review subpoena response from Julie Hoffman. Brief 1.00 $325.00 BL research of Twin Engine's online presence. 94 6/16/2020 GW Download and review documents from Margot Laumann. 0.30 $97.50 BL 95 6/26/2020 GW Email to Sheridan re discovery responses. 0.10 $32.50 BL 96 7/6/2020 GW Review status of discovery requests to TE; emailed OC. 0.20 $65.00 BL 97 7/15/2020 GW Draft email to opposing counsel regarding TE's discovery 0.30 $97.50 BL responses - extended. 101 7/16/2020 Meet with attorney G. Wetzel Ee 0.20 $0.00 NC 98 7/17/2020 GW Phone call to Josh Brown, LM @ 2:58 p.m. 0.10 $0.00 NC 99 7/20/2020 GW Draft and file motion to amend case schedule. 0.60 $195.00 BL 100 7/20/2020 GW Emails on motion to amend case schedule; Phone call to 0.20 $65.00 BL Phil Sheridan re motion, LM @ 11:28 a.m. 102 7/23/2020 GW Email to Sheridan re mot to amend case sch. 0.10 $32.50 BL 103 7/28/2020 GW Emailed Court letting it know no opposition to motion to 0.20 $65.00 BL amend case schedule. 104 8/12/2020 GW Review status of Twin Engine's discovery responses - 0.20 $65.00 BL calendared per tolling order. 107 8/17/2020 GW Discuss a with M. Hrabcak. 0.20 $65.00 BL 105 8/24/2020 GW Review discovery sent to TE for possible motion against it. 0.20 $65.00 BL 106 8/30/2020 GW Email to Brown re disco. resps. 0.20 $65.00 BL 108 9/1/2020 GW Draft motion to compel re Twin Engine. 0.90 $292.50 BL 109 9/3/2020 GW Revise and finalize motion to compel. File with the Court. 0.30 $97.50 BL 113 9/23/2020 GW Review court's decision on motion to compel, send to Gary. 0.20 $65.00 BL 110 10/9/2020 GW Email to Brown re TE's discovery responses. 0.10 $32.50 BL lll 10/13/2020 GW Draft motion for sanctions. 0.70 $227.50 BL 112 10/13/2020 GW Revise motion for sanctions; file. 0.20 $65.00 BL 114 10/14/2020 GW Review and respond to Gary's email. 0.20 $65.00 BL 122 11/13/2020 GW In-house discussion with M. Hrabcak [EE 0.10 $32.50 BL 115 11/18/2020 GW Legal Research on delegable duties. 0.20 $65.00 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w3 Date: 1/30/2023 PRE-BILL Time: 9:44AM Sof 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 116 11/18/2020 GW Review time entries related to motion to compel and for 0.10 $32.50 BL sanctions, per Court's order. 17 11/18/2020 GW Draft aff. re attorney fees. 0.30 $97.50 BL 123 11/18/2020 GW Emails 0.10 $32.50 BL 118 11/20/2020 GW Finalize affidavit on fees; draft notice of filing. File. Email 0.30 $97.50 BL 119 11/23/2020 GW Phone call to Gary re [i 0.50 $162.50 BL Phone call to Phil Sheridan. 120 11/23/2020 GW Review damages. Emails to counsel regarding damages 0.40 $130.00 BL hearing date. 121 12/1/2020 GW Review invoices, client email; revise spreadsheet for 0.40 $130.00 BL damage calculation. 130 12/15/2020 GW Discuss EE with M. Hrabeak. 0.30 $97.50 BL 124 12/29/2020 GW Phone call to Phil Sheridan. Draft Motion to Am. Case 0.70 $227.50 BL Schedule, file. 125 1/8/2021 GW Phone call to Gary. LM @ 2:50 p.m. 0.10 $0.00 NC 126 1/8/2021 GW Phone call; returned Gary's call] [iy 0.30 $97.50 BL 127 1/8/2021 GW Draft settlement demand to Dewberrys; email to their 0.60 $195.00 BL counsel. 128 1/14/2021 GW Review documents for next week's hearing. 0.20 $65.00 BL 142 1/14/2021 GW Phone call to expert re attorney fees. 0.30 $97.50 BL 129 1/15/2021 GW Phone call to Gary. Email court re hearing. 0.20 $65.00 BL 131 1/15/2021 GW Prepare and send documents to expert to review for hearing. 0.20 $65.00 BL 132 1/19/2021 GW Phone call to Phil Sheridan. 0.20 $65.00 BL 133 1/27/2021 GW Review calendar; Phone call to Gary re | email OC re 0.30 $97.50 BL dates and clients participating by Zoom. 134 1/27/2021 GW Phone call to Phil Sheridan. LM. Returned Phil's call. 0.80 $260.00 BL Phone call to Gary White. Phone call to Josh Brown. Phone call to Steve Moyer. Email to Josh Brown. 144 1/27/2021 Attention to file - discussion with attorney G. Wetzel 0.20 $65.00 BL regarding 143 1/29/2021 GW Emails re new date for damages hearing. 0.30 $97.50 BL 135 2/3/2021 GW Review Brown's filings and emails. 0.20 $65.00 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w40 Date: 1/30/2023 PRE-BILL Time: 9:44AM 6 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 150 2/3/2021 Review motion, crossclaims, photos and filings by attorney 0.50 $162.50 BL for Twin Engines; meet with attorney G. Wetzel EE 153 2/3/2021 GW Discuss EEE with M. Hrabcak. 0.20 $65.00 BL 136 2/4/2021 GW Phone call to Phil Sheridan. LM @ 12:18 p.m. 0.10 $0.00 NC 137 2/4/2021 GW Phone call from Phil Sheridan. 0.20 $65.00 BL 138 2/4/2021 GW Draft memo contra motion for reconsideration. Legal 1.30 $422.50 BL Research on 60(B) v. motion to reconsider. 139 2/10/2021 GW Sent docs to client. 2.00 $650.00 BL Continued on memo contra TE's motion for reconsideration. Revise. Phone call to Gary. LM @ 12:53 p.m. 140 2/10/2021 GW Phone call from Gary. Discussed iy 0.30 $97.50 BL 141 2/10/2021 GW Finalized and filed memo contra. Sent courtesy copy to 0.20 $65.00 BL Magistrate. 145 2/12/2021 GW Review TE's reply on motion for reconsideration. Emailed 0.30 $97.50 BL Gary 147 3/1/2021 GW Phone call from Phil Sheridan. 0.20 $65.00 BL 148 3/1/2021 GW Review discovery requests from TE. 0.20 $65.00 BL 149 3/1/2021 GW Phone call to Gary. LM @ 7:49 p.m. 0.10 $0.00 NC 160 3/1/2021 GW Discuss court's ruling and discovery issues with M. 0.20 $65.00 BL Hrabcak. 151 3/9/2021 GW Review and respond to Gary's email. 0.10 $32.50 BL 152 3/10/2021 GW Review Gary's discovery responses and prepare for phone 1.60 $520.00 BL conference. Gary and Kathy called. 154 3/19/2021 GW Amend answers to discovery responses. 1.20 $390.00 BL 155 3/23/2021 GW Finalize discovery responses. 0.70 $227.50 BL Phone call to Gary. Emailed in iii 156 3/24/2021 GW Review Gary's email and interrogatory response: Phone call 0.20 $65.00 BL to Gary 157 4/16/2021 GW Phone call to Josh Brown. He prefers an in person depo. 0.30 $97.50 BL Will F/U next week. 158 4/20/2021 GW Draft motion to amend case schedule. Email OC. 0.20 $65.00 BL 159 4/21/2021 GW Revise joint motion to file with the Court. 0.10 $32.50 BL 161 5/14/2021 GW Phone call from Gary i 0.20 $65.00 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w41 Date: 1/30/2023 PRE-BILL Time: 9:44AM 7 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 162 3/24/2021 GW Get video conference link for clients. 0.20 $65.00 BL 163 3/25/2021 GW Prep for video conference. Video conference with Gary and 1.00 $325.00 BL Kathy. 164 3/25/2021 GW Email to clients regarding iy 0.20 $65.00 BL 165 6/3/2021 GW Review and respond to Gary's question 0.50 $162.50 BL 166 6/4/2021 GW Review and respond to Gary's email. 0.30 $97.50 BL Phone call to Gary. LM @ 10:48 a.m. 183 6/7/2021 GW Travel to and from Brown's office: depos. of Gray and 2.60 $845.00 BL Kathy. 167 6/9/2021 GW Draft areas of knowledge for TE corp. designee. 0.60 $195.00 BL 168 6/10/2021 GW Revise areas of knowledge for TE designee. 0.20 $65.00 BL 169 6/16/2021 GW Phone call to Phil Sheridan. Busy @ 4:54 p.m. 0.10 $0.00 NC 170 6/21/2021 GW Phone call to Sheridan. Discussed deposition dates and the 0.20 $65.00 BL case. 71 6/22/2021 GW Email to OC re deposition dates. 0.20 $65.00 BL 172 6/24/2021 GB Draft Second Motion to Amend Case Schedule 0.20 $22.00 BL 173 6/24/2021 GW Ennil to Gary ay 0.10 $32.50 BL 174 7/8/2021 GW Review emails re deposition date and times. 0.60 $195.00 BL Email OC. Email clients. 175 7/9/2021 GW Review and respond to Gary's emails. 0.20 $65.00 BL 176 7/9/2021 GB Draft Notice of Deposition for Twin Engine, Tim Dewberry, 0.60 $66.00 BL and Kristen Dewberry as well as book court reporter for same 177 7/9/2021 GW Review notices for depositions. 0.20 $65.00 BL 178 7/13/2021 GW Draft witness outline for TE's designee. 5.80 $1,885.00 BL 179 7/14/2021 GW Continue on witness outline for Tim Dewberry. 1.00 $325.00 BL 180 7/14/2021 GB Research regardin_iii 0.50 $55.00 BL 181 7/14/2021 GW Continue preparing for depositions. 0.90 $292.50 BL 206 7/14/2021 GW Depositions of Nathan Hoy, Tim Dewberry; and Kristen 4.90 $1,592.50 BL Dewberry. 182 7/15/2021 GW Review and respond to Gary's email. 0.20 $65.00 BL 184 7/19/2021 GW Phone call from Nate Stitzlein. 0.20 $65.00 BL Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w4 Date: 1/30/2023 PRE-BILL Time: 9:44AM 8 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 185 7/19/2021 GB Pull pulled of photos and link that client sent to us to save in 0.10 $11.00 BL the file 186 7/20/2021 GW Begin drafting letter to OC re heat pump and possible 1.10 $357.50 BL settlement. 187 7/21/2021 GB Call to AEP to attempt to obtain service tickets/records for 0.40 $44.00 BL 6700 Lambert Road in 2019; Complete Public Records Request and call to Franklin County Economic Development & Planning Department to find out where to send the Public Records Request; Email Public Records Request to Franklin County Economic Development & Planning Department 188 7/21/2021 GW Review and respond to Gary's email. 0.20 $65.00 BL Intra-office email 189 7/22/2021 GB Draft Subpoena to AEP 0.30 $33.00 BL 190 7/23/2021 GW Review and revise subpoena to AEP. 0.20 $65.00 BL 191 7/26/2021 GB Prepare Notice of Subpoena to AEP for filing and mailing 0.30 $33.00 BL to AEP; a to client. 192 7/26/2021 GB Call to Five Star Heating and Cooling to obtain screen shot 0.10 $0.00 NC for dispatch notes from June 17, 2020 - left voicemail 193 7/27/2021 GW Phone call to Efficient Electric. Spoke with Troy. 0.30 $97.50 BL 194 7/27/2021 GW Continue with letter to OC. 0.50 $162.50 BL 195 7/28/2021 GW Phone call to Gary; LM @ 6:11 p.m. 0.10 $0.00 NC 196 7/28/2021 GW Continue with letter to OC. 0.60 $195.00 BL 197 7/29/2021 GW Phone call from Gary 0.30 $97.50 BL 198 7/30/2021 GW Review and respond to Gary's email. 0.10 $0.00 NC 199 8/3/2021 GW Review and respond to Gary's email [iy 0.40 $130.00 BL 200 8/4/2021 GW Review subpoena response from AEP. 0.40 $130.00 BL 201 8/4/2021 GW Finalize offer of compromise to Defs. 0.50 $162.50 BL 202 8/6/2021 GB Prepare Return of Service for AEP Subpoena; File same 0.10 $11.00 BL with Court 203 8/10/2021 GW Phone call from Phil Sheridan re offer to Dewberrys. 0.50 $162.50 BL 204 8/11/2021 GW Review and respond to Gary's email. 0.30 $97.50 BL Email Isaac Burt @ Efficient Electric. 205 8/11/2021 GW Email to client, then opposing counsel regarding [i 0.10 $32.50 BL 207 9/10/2021 GB Phone call and email to Isaac Burt to schedule a phone 0.10 $11.00 BL conference - left message with receptionist Continued On Next Page Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 28 4:59 PM-20CV000086 0G369 - w4 Date: 1/30/2023 PRE-BILL Time: 9:44AM 9 of 19 Page: Hrabcak & Company, L.P.A. Client: 07-542 Gary White Matter: 3266 White, Gary - Real Estate Matter 208 9/10/2021 GB Draft Motion for Summary Judgment 0.30 $33.00 BL 209 9/10/2021 GB Calculate costs for deposition transcripts; Email Attorney 0.20 $22.00 BL Greg Wetzel regarding same 210 9/13/